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05000296/FIN-2016013-022016Q1Browns FerryRecords of Fire Watch Patrol Not Complete or Accurate10 CFR 50.9, Completeness and Accuracy of Information, states, in part, information required by the Commissions regulations, orders, or license conditions to be maintained by the licensee shall be complete and accurate in all material respects. Contrary to the above, on multiple occasions in May 2015, TVA maintained records of hourly fire watch patrols that were not complete and accurate in all material respects. Specifically, fire watch patrol documentation required by NPG-SPP-18.4.6 contained incomplete documentation of fire watches for a fire impairment in the Unit 3 Diesel Building and Unit 3 4kV Shutdown Board Room. Procedure NPG-SPP-18.4.6, Rev. 0006, Control of Protection Impairments, requires the licensee to complete Attachment 6, NPG-SPP-18.4.6-6, Hourly Compensatory Fire Watch Route Sheet, by entering the time, printing name, and signing as each area is patrolled, and returning it to the foreman at the end of the shift. The procedure allows the use of an equivalent form which shall include at least: impairment number, date of coverage, area covered, and start time. However, the equivalent form intended to document completion of the fire watch patrols of the Unit 3 Diesel Building and Unit 3 4kV Shutdown Board Room in May 2015, NPG-SPP-18.4.6-2(12-10-2010), Roving Fire Watch Route/Coverage Sheet, was not filled out completely. Specifically, the start/stop times and employees initials were not entered. Complete hourly fire watch patrol data is material to the NRC in that it provides evidence of compliance with the regulatory requirements of 10 CFR 50.48. Therefore, there was an apparent violation of 10 CFR 50.9 because the record the licensee is required to maintain to document completion of hourly fire watch patrols in the Unit 3 Diesel Building and Unit 3 4kV Shutdown Board Room was incomplete.
05000327/FIN-2015008-012013Q4SequoyahProblem Implementing Fire Protection Program RequirementsDuring an NRC investigation completed on December 19, 2013, and supplemented on May 12, 2014, violations of NRC requirements were identified. In accordance with the NRC Enforcement Policy, the NRC proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and associated civil penalty are set forth below: A. 10 CFR 50.48, Fire Protection, requires that a licensee must have a fire protection plan that, in part, outlines the plans for fire protection, fire detection, suppression capability, and limitation of fire damage. Sequoyah Nuclear Plant Units 1 and 2 Technical Specification 6.8.1.f requires, in part, that written procedures be established, implemented, and maintained covering the activities involved with Fire Protection Program implementation. Tennessee Valley Authority (TVA) Corporate Procedure NPG-SPP-18.4.6, Control of Fire Protection Impairments, Revision 1, requires, in part: Section 3.6.A, requires fire watch supervisors communicate fire watch requirements. Section 3.2.6.A, states that fire watches are utilized for the surveillance of areas where fire protection systems are impaired. Section 4.2.B, states that Fire Watch Route Sheets will be retained by Fire Protection for 90 days. Appendix A, Section 3.2 requires fire watches to complete Form NPG-SPP-18.4.6-2 Fire Watch Route Sheet, as each area is patrolled. Fire Protection Impairment Permit FOR120937 dated October 2, 2012, established an hourly fire watch for a diesel generator board room air intake fire damper that failed to close and was considered to be impaired. Contrary to the above, on multiple occasions during October and November 2012, TVA willfully failed to implement procedures covering the activities involved with Fire Protection Program implementation. Specifically, the designated fire watch foremen willfully failed to have proper oversight of fire watch activities. In addition TVAs contractors willfully failed to conduct roving fire watch patrols in the Emergency Diesel Generator Building. Specific examples include: Hourly fire watches in areas where fire protection systems were impaired were not performed on multiple occasions. Fire Watch Route Sheets were not retained by Fire Protection for 90 days as required by NPG-SPP-18.4.6 section 4.2. TVAs contract supervisors deliberately solicited individuals to falsify fire watch forms B. 10 CFR 50.9 states, in part, that information required by the Commissions regulations, orders, or license conditions to be maintained shall be complete and accurate in all material respects. Sequoyah Nuclear Plant Units 1 and 2 Technical Specification 6.8.1.f requires, in part, that written procedures be established, implemented, and maintained covering the activities involved with Fire Protection Program implementation. NPG-SPP-18.4.6, Control of Fire Protection Impairments, Revision 1, Section 3.2.6.A, states that Fire watches are utilized for the surveillance of areas where fire protection systems are impaired. The compensatory fire watch process is described in Appendix A. Appendix A to NPG-SPP-18.4.6, Section 3.2.C, specifies compensatory fire watch duties and responsibilities, and requires that compensatory fire watch personnel complete Form NPG-SPP-18.4.6-2 by entering the time and initials as each area is patrolled, and return it to the Fire Protection Foreman/designee at the end of the shift. NPG-SPP-18.4.6 Rev. 0001, Section 4.2.B, specifies a 90 day retention for Form NPG-SPP- 18.4.6-2, Fire Watch Route Sheet. Fire Protection Impairment Permit FOR120937 dated October 2, 2012, established an hourly fire watch for a diesel generator board room because an air intake fire damper failed to close (was impaired). Contrary to the above, on multiple occasions in October and November 2012, TVA failed to maintain complete and accurate records of hourly fire watch patrols. These records were material to the NRC. Specifically, fire watch patrol records required by NPG-SPP-18.4.6 certified hourly fire watches were completed during the fire impairment in the Emergency Diesel Generator Building. However, the NRC has determined that in fact many fire watches were not performed. The hourly fire watch patrol data is material to the NRC because it provides evidence of compliance with NRC safety requirements. This is a Severity Level III Problem (NRC Enforcement Policy Section 6.1, 6.9). Civil Penalty - $70,000. (EA-14-003)