ML20199G392

Responds to NRC 971218 Ltr Concerning Rejection of Denial Re Violations in Insp Rept 50-348/97-10.Corrective Actions:Util Established Hourly Fire Watch for Room 160 in Oct 1996 & Watch Will Remain in Place Until Issue Resolved

ML20199G392
Person / Time
Site:	Farley
Issue date:	01/23/1998
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-348-97-10, NUDOCS 9802040270
Download: ML20199G392 (4)

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• Dav3 Morey Ssuthern N: clear

. %ce Presdent Opnating Comp:ny f artey Proje:t P.O. Box 1295 Birmirigham. Mabama 35201 Tel 205 932.5131 January 23, 1998 SOUTHERN h COMPANY Energy:o Serve YourWorld" Docket No: 50-348 10 CFR 2.201 U. S. Nuclear Regulatory Cunmission ATrN: Document Control Desk Washington, DC 20555 Joseph M. Farley Nuclear Plant - Unit 1 Reply To a Notice Of Violation (VIO) Rejectim of Denial Regarding NRC Insoeetion Report Number 50-348/97-10-08 Ladies and Gentlemen:

As tcquested by your transmittal dated December 18,1997, this letter responds to a rejection of denial regarding VIO 50-348/97 10-08," Installation of Half Ilour Kaowool Fire Barriers Without Appendix R Exemption."

The Scathern Nuclear Operating Company (SNC) response is provided in the encic,sure.

Respectfally submitted, fft )/1r2/ V Dave Morey - s EWC/ mar nev9710. doc Enclosure l

cc: Mr, L. A. Reyes, Region 11 Administrator M;. J.1. Zimmerman, NRR Project Manager Mr. T. M. Ross, Plant Sr. Resident inspector LOh O

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c ENCLOSURE VIOLATION 50-348/97-10-08," Installation of Half Hour Knowool Fire Barriers without Aroendix R Exemption"

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VIO 50-348/97-10-08, " Installation of Half Hour Knowool Fire Barriers without Appendix R

, Exemption".statesi License No, NPF-2; Condition 2.C(4), for Faney Nuclear Plant (FNP), Unit 1, states, f in part, that Southern Nuclear Operating Company, Inc. shall implement and maintain in efr ect all provisions of the approved fire protection progre.m as described in the :

- Updated Final Safety Analyt.is Repon (UFSAR).

Appendix 9B 'of the UFS AR, Fire Protection Progrt.n, documents an evaluation ofihe

,. FNP fire protection program as it complies with Appendix R to 10 CFR 50 and ,

. - embodies the contents of the Fire Protection Program Reevaluation as approved by the

NRC. Appendix 9B, Attachment B,10 CFR 50 Appendix R Exemptions, provides the F . NRC's discussion and evaluation of the licensee's Appendix R exemption requests, and i also identifies those systems and components that require 1-hour Knowool fire barriers to meet Appendix R Specifically, Appendix 9B, Attachment B, Section 21.3, states

that "the redundant charging pump power cables are provided with a barrier (two 1- H l inch thick wraps of Knowool blanket) having a fire n ating greater than that of the projected fire in the following rooms in fire area 1004; train A in rooms 161, 162,-163, and 168; train B in rooms 175,160, and 159."

, Contrary to the above, as of September 6,1997,~ the licensee installed a one 1-inch thick wrap of Kaowool on the sides and bottoms of raceways BDE-9 and BDE-15, 7 carrying train B charging pump power cables in Room 160 of fire area 1-004.

This is a Severity Level IV violation. This violation is appliceble to Unit I only.

Summary of NRC letter dated December 18,1997:

The NRC stated that "we have concluded, for the reasons presented in the enclosure to -

this letter, that the violation occurred as stated in the Notice." The NRC requested "a.

~ written statement describing the steps which have been taken to correct Violation A and the results achieved, corrective steps which will be taken to avoid further -

n violations,' and the date when full compliance will be achieved." The NRC also .

requested that SNC " address the reason for the extended schedule in submitting the exemption request for this issue proposed" in SNC's initial reply letter.

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i Corrective Steos Taken and Results Achieved Farley Nuclear Plant (FNP) established an hou:ly fire watch for Room 160 in October,1996.

The fire watch will remain in place until this issue is resolved.

Corrective Steps That Will Be Taken to Avoid Further Violation FNP will submit a revised Appendix R Exemption request for three-sided wrap on cable trays BDE-9 and 15, to NRC by February 13,1998. Upon receipt of NRC approval, the revised exemption will be incorporated into the FSAR.

Date of Full Compliance The fire watch will be removed upon iacorporation of the approved Appendix R Exemptic-revision into the FSAR which will be submitted by February 13,1998.

Reason for Extended Schedule FNP is uncertain of the NRC's expectations regarding the use of Kaowool as a raceway fire barrier. The original proposed submittal was to include additional changes or corrections based on FNP's FSAR verification effort. FNP determined that a submission date of Masca 31,1998 allowed for a thorough review of FSAR Appendix 9B, Attachment B (Appendix R Exemptions) and timely subr jssion of any changes or corrections along with the Appendix R Exemption revision request for three-sided wrap on cable trays BDE-9 and 15. Instead, FNP only intends to submit an Appendix R Exemption revision request for three-sided wrap on cable trays BDE-9 and 15 by February 13,1998. Any additional FSAR changes or corrections will be submitted at a later date.

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