ML19347D726
| ML19347D726 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/20/1981 |
| From: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML19347D720 | List: |
| References | |
| NUDOCS 8103261166 | |
| Download: ML19347D726 (4) | |
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APPENDIX A NOTICE OF VIOLATION i,tQ PROPOSED IMPOSITION OF CIVIL PENALTIES Tennessee Valley Authority Docket Nos. 50-259, 50-260 and 50-296 Browns Ferry 1, 2 and 3 License Nos. DPR-33, DPR-55 and DPR-68 As a result of the ins'pection conducted on January 6-9 and 20-23,1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980),
Section 234 of the Atomic Energy Act of 1954 as amended (42 USC 2282, P.L.96-195),10 CFR 2.201, and 10 CFR 2.205, the NRC proposes to impose civil penalties in the amounts set forth below for the following alleged violations.
A.
Facility Operating License paragraphs 2.D(1)(b) for Units 1 and 2 and paragraph 2.E(2)(b) for Unit 3 require the licensee to install automatic pre action sprinkler systems in all areas of the plant required for safe shutdown by the end of the first refueling outage of any of the plant units after August 20, 1976.
Unit 1 ccmpleteu the first refueling outage on January 15, 1978.
Areas requiring automatic pre-action sprinkler systems were identified in Part X, Section A of TVA's document " Browns Ferry Nuclear Plant Design Changes for the Recovery From the Fire of March 22, 1975", which included the electrical cable area for the RHR service water pumps at the intake pumping structure.
Contrary to the above, an automatic pre-action sprinkler system has not been installed in the intake pumping station.
This is a Severity Level III Violation (Supplement I.C.2).
Civil Penalty - $21,000.
B.
Facility Operating License paragraphs 2.D(1)(e) for Units 1 and 2 and 2.E(2)(e) for Unit 3 require fire protection features of the emergency battery room complex to be changed to do one of the following:
(1) provide a total fire rated barrier enclosure of the facility battery room complex that exceeds the fire load contained in the room; (2) reduce the fire load to be within the fire barrier capability of 1h hours; or (3) provide a remote manual actuated sprinkler system in eacn room and provide the 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire barrier separation.
This change was required to be completed prior to the end of,the first refueling outage.
Unit 1 completed the first refueling outage on January 15, 1978.
Contrary to the above, the fire protection features provided for the battery rooms do not meet one of the three required modifications.
TVA selected modification. item 3 and provided a sprinkler system for each emergency battery room; however, a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire barrier was not provided.
Ventila-tion ducts penetrate each battery room and'are not equipped with fire 8108260 MMC
Appendix A (Continued) dampers at each penetration.
This voids the fire resistant rating of each enclosure.
This is a Severity i.evel III Violation (Supplement I.C.2).
C vil Penalty - $8,000.
C.
Facility Operating License paragraphs 2.D(1)(c) and 2.D(1)(d) for Units 1 and 2 and paragraphs 2.E(2)(c) and 2.E(2)(d) for Unit 3 require a manual dry pipe sprinkler system for the cable spreading rooms and an automatic actuated carbon dioxide system for the cable spreading rooms.
Contrary to the above, the cable spreading rooms' dry pipe sprinkler systems are automatic operation and the carbon dioxide systems are manual in opera-tion.
A license change to describe the current operation of the fire suppression systems for the cable spreading rooms has not been obtained.
This is a Severity Level III Violation (Supplement I.C.2)
Civil Penalty - 55,000 D.
Technical Specification 3.11.B requires that a continuous fire watch be established in the c.able spreading rooms and a patrolling fire watch be established to make hourly checks of other (CO2) protected locations when-ever the CO2 fire protection system is lost.
)
Contrary to the above, the fire watches for the cable spreading rooms were conducted intermittently and the patrolling fire watch did not enter the aux-
'liary instrument rooms for hourly checks for all three units when the CO2 system was out of service on October 5, 1980 between 7:12 p.m. and 9:00 p.m.
This is a Severity Level III Violation (Supplement I.C.2).
A similar item was identified in Inspection Report 50-259/80-34.
Civil Penalty - 55,000 E.
Technical Specification Section 4.11.A.1.b requires each high pressure fire protection system pump to be tested for operability once per month.
Contrary to the above, fire pump No. A was not tested for operability during October 1980.
This is a Severity Level III Violation (Supplement I.C.2).
Civil Penalty - 52,000 F.
Technical Specifica$ ion Section 6.3. A.10 requires written procedures covering the fire protection and preventian program to be prepared, approved and adhered to.
1.
TVA Browns Ferry Emergency Plan - Fire, Explosion and Natural Disaster Plan, Section 11 requires each operating crew to participate in a fire drill at least once per three months.
Appendix A (Continued).
Contrary to the above, each operatir; crew did not participate in a fire drill at least once per three months during 1980.
The 1980 drill participation was:
Group 1 - two; Group 2 - one; Group 3 -
one; Group 4 - two; Group 5 - one.
This is a Severity Level III Violation (Supplement I.C.2).
Civil Penalty - $3,000 2.
TVA Procedure MMI-75, Installation anc Repair of Penetration and Fire Stops, Section 6.4.8 limits the maximum number of uncoated (not coated with "Flamemastic" fire resistance material) electrical cables within a cable tray to ten.
Contrary to the above, over ten uncoated electrical cables are installed ir. cable trays in all three units.
This is a Severity Level III Violaticn (Supplement I.C.2).
Civil Penalty - 52,000 G.
Technical Specifications Section 3.11.F states "If it becomes necessary to breach a fire stop, an attendant shall be posted on each side of an open penetration until work is completed and the penetration is resealed."
The required attendant was not posted in each of the following examples:
1.
The fire door (door No. 632) separating the Unit 1 electrical shutdown board rooms is a fire stop and must be maintained in the closed position.
Contrary to the above, door No. 632 was found open due to an inoper-ative door closer on January 21, 1981 and the required attendants were not posted.
This is a Severity Level III Violation (Supplement I.C.2).
Civil Penaltv - $2,000 2.
The fire stops separating the Unit 3 electrical shutdown board rooms include door Nos. 655 and 656 which are required to be maintained in a closed position.
Contrary to the above, door Nos. 655 and 656 were found blocked and wedred in the open position on January 21, 1981 and the required atte.dants were not posted.
This is a Severity Lev'el III Violation (Supplement I.C.2).
Civil Penalty - $2,000 Pursuant.to 10 CFR 2.201, Tennessee Valley Authority is hereby required to submit to this office within 25 days of ti.e date of this Notice a written statement or explanation including:
(1) admission or denial of the alleged violations, (2) the reason for the violations if admitted, (3) corrective
Appendix A (Continued) 4-steps which have been taken and the results achieved, (4) corrective steps which will be taken to avoid further violations and (5) the date when full compliance will be achieved.
Under the authority of Section 182 of the Atomic Energy Act as amended, this response shall be submitted under oath or affirm-ation.
Tennessee Valley Authority, within 25 days of the date of this Notice, may pay the civil penalty in the cumulative amount of $50,000 or may protest the imposition of the civil penalty in whole or in part by a written answer.
Should Tennessee Valley Authority fail to answer within the time specified, this office will issue an order imposing the civi.1 penalty proposed above.
Should Tennessee Valley Authority elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, such answer may (a) deny the items of noncompliance listed in this Notice in whole or in part, (b) demonstrate extenuating circumstances, (c) show error in this Notice or (d) show other reasons why the penalty should not be imposed.
In addition to protesting the civil penalty in whole or in part, such answer may request remission or mitigation of the penalty.
Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate by specific reference (e.g.,
giving page and paragraph numbers) to avoid repetition.
Tennessee Valley Authority's attention is directed to the other provisions of 10 CFR 2.205 regarding, in particular, failure to answer and ensuing orders; y
answer, consideration by this office, and ensuing orders; requests for hearings, hearings and ensuing orders; compromise; and collection.
Upon failure to pay any civil penalty due which has been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, the matter may be referred to the Attorney General and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Atomic Energy Act of 1954, as amended (42 USC 2282).
FOR THE NUCLEAR REGULATORY COMMISSION 84bfg /&
Dirsctor Victor Stello, Jr.,f)
Office of In'spectiol and Enforcement Dated at Bethesda, Maryland this 20th day of March 1981 n.