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t UNITED STATESNUCLEAR REGULATORY COMMISSI

REGION II101 MARIETTAST., N.W., suITE 3100

ATLANTA'EORGIA30303

Report Nos. SO-259/81-01 and 50-260/81-01 and 50-296/81-01

Licensee: Tennessee Valley Authority500A Chestnut; StreetChattanooga, TN 37401.

Facility Name: Browns Ferry

Docket Nos. 50-259, 50-260 and 509-296

License Nos. DPR-33, DPR-55 and DPR-68

Inspection at: Browns Ferry site near Decatur, Alabama

Inspected by:M. H. Ni'lier, Jr.

~~ 8']Date Signed

Approved by:~ '

T. E. Conlon, c on Chi f, RCES Branch

Date of Inspection: January 6-9 and, 20-23, 1981

Areas Inspected:

Da e. Signed

This routine, unannounced inspection involved 54 inspector-hours onsite in theareas of fire protection/prevention.

Results:

0

Of the areas inspected, 7 apparent 'violations were found. (sprinkler systemnot provided for Intake Pumping Station - Paragraph 5.a.(1); fire suppressionsystems for cable spreading rooms do not conform to license requirements-Paragraph S.a.(2); substandard; fire barrier enclosures for battery r'ooms;failure to follow fire protection, and. prevention procedures — Paragraphs 5.a.(8)and 5.d.(3)", nonfunction fire doors — Paragraph 5.a.(9); failure to deter'mineoperability of fire pump A during October 1980 — Paragraph S.d.(1)(b); and,fail'ure. to provide adequate. fire watch while COZ fire protection system was outof service - Paragraph 5.d.(6).) Three deviations were found (HPCI sprinklersystem deluge valves not approved for fire service — Paragraph 5.a.(S); improperhardware on fire. door between the el'ectrical equipment rooms. in the Unit 1 and 2diesel generator building - paragraph 5.a.9.(c); and, failure to complete firedoor modifications —Paragraph 5.a.(10).

8i08i8033i 8i0323~IPDR ADOCK 050002599 PDR i

DETAILS

Persons Contacted

Licensee Employees

"H. L. Abercrombie, Pl'ant Superintendent*J. L. Harness, Assistant. Plant Superintendent"T; Chinn, Compliance. Officer~R. T. Smith, QA Supervisor*R. Phifer, Safety/Fire Protection

R. Hunkapillar; Assistant Operations Supervisor"R. C. Boyer, Public Affairs Officer"G. H. Jones, Safety/Fire Protection"R. Battles, Engineering Aid,~J. D. Glover, Operations Training Officer"R. E. Thompson, TVA-Chattanooga/Fire Protection Engineer Supervisor"T. Keckeisen-, TYA-Chattanooga/Fire Protection EngineerJ. M. Price, Training OfficerD. Thompson, Electrical Engineer/MaintenanceJ. G. Blackburn,'Supervisor Administrative ServicesC. Rozear; QAL. L. Kennedy, Shift Engineer

.NRC Resident Inspectors

*R. F-; Sullivan-

~J; W-. Chase:"G. Paulk-

2.

"Attended"'exit interview.

Exit Interview

3.

The inspection scope and findings were summarized on January 9 and 23, l981with, those persons indicated in Paragraph 1 above..

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Licensee:,Action. on Pi evious I'nspection Findings

Not inspected.

4.. Unresolved Items

Unresolved items are matters about which more informati'on is required todetermine whether they are acceptable or may involve noncompliance ordeviations. New unresolved items identified during this inspection are.discussed in Paragraph Nos. 5.a.(3), 5'.c., and S.d'.(2).

5. Fire Protection/Prevention Program (Module No. 64703B)

a. Plant Tour

A. tour. was made of'he plant to inspect the fire protection featuresand systems. provided for safety related areas. All of the installedfire protection systems-'equired" by Technical Specification Section4. 11 were found:in service. However, the following items were noted:

Intake Pumping Station.

The automatic sprinkler system for the portion of the pumpingstation as shown on Figure 5.2-15 of Part X Section A to TVA-Browns Ferry Nuclear Plant Design Changes for the Recovery Fromthe Fire of. March 22, 1975 had not been installed. This systemwas required to be installed by the end of the first refuelingoutage after the 1975 fire of any of the'nits by OperatingLicense Paragraphs 2.D..(1).(b) for Units 1 and '2 and Paragraph2.E.(2).(b) for Unit 3. Unit 1. restarted from the first refueling.outage on January 15, 1978. This item is identified as ViolationItem 259/81-01-01, 260/81-01-01, and 296/81-01-01), spri nkl ersystem not provided for Intake Pumping Station. EffectiveJanuary 15, 1981., the! licensee established a continuous fire watchfor the: pumping station which will be maintained until thesprinkler system is installed. This will meet the provisions ofTechnical Specifications.

(2) Cable Spreading Rooms

The. sprinkler systems for the cable spreading rooms contain anumber. of'oderate to serious design and installation discrep-ancies.. These items are listed'n the, October 1980 fire'rotec.—tions audit discussed in below paragraph 5.c. Also, the sprinklersystems for the spreading rooms are automatic and= not manual asrequired by Operating License Paragraphs 2.D.(1).(c) for- Units 1

and 2 and Paragraph 2.E.(2).(c) for Unit 3. The manual carbondioxide systems have not been changed to automatic operation,',as.required by Operating License Paragraph 2.D.(1).(d) for Units 1

and 2 and, Paragraph 2.E.(2).(d) for Unit 3. The licensee. advisedthat. these changes were made based on guidance. provided by NRR.This is. apparently confirmed by TVA's letter of'pril 20, 1978from J. E; Gilleland, to G. Lear NRC/NRR-DOR which stated that themodifications were to be made, but. TVA did not, request. that theoperating license be revised; This item is identified as Viola-tion I'tern (259/81-01-02, 260/81-01-02 and 296/81-01-02), firesuppression systems for cable spreading rooms do not. conform tolicense requirements.

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(3) Control Room

The ceiling in the control rooms is a. combustible plasticmaterial. 10CFR50 Appendix A, Criterion 3, states that non-combustible materials shall be used wherever practical throughoutthe; unit, particularly, in. locations such as the containment

and'ontrolrooms., It, appears that. the use of. this material is commonto all TVA'ites and is current'ly under evaluation by TVA and,NRC/NRR. This item is identified as Unresolved Item (259/81-01-03, 260/81-01-03 and 296/81-01-03), combustible ceiling in controlrooms, and wi 1 1 be revi ewed fo1 lowing the evaluation.

Battery Rooms

(5)'he

battery rooms are required by Operating License Paragraphs2.0.(1).e for Units 1 and 2 and Paragraph 2.E.(2).(e) for Unit 3to meet one of the following:, provide a fire rated barrierenclosure for each battery room that exceeds the fire load con-tained in the rooms; reduce the fire load to be within the firebarrier capability of 14 hours, or provide a remote manuallyactuated sprinkler system in each room and provide the 1~ hourfire barrier separation. This change was required, to be made bythe end of the first refueling outage of any unit following the1975 fi,re. Unit. 1. restarted from the first refueling outage onJanuary 15, 1978. Each battery room has been equipped withautomatic. sprinkler protection and a fire rated enclosure has beenprovided around. each room. The fire resistance rating. of thebattery rooms enclosures has been voided due to the installationof ventilation ducts, which are: not provided with fire dampers at .

barrier penetrations. This item is identified as Violation Item(259/81.-01-04,. 260/81-01'-04- and 296/81-,01-04),. substandard firebarrier enclosures. for battery ~ooms. The fire doors into thebattery rooms have louvered openings which the licensee. states areprovided with fire, dampers. This will be verified during asubsequent,NRC inspection.

Reactor Building

The deluge valves which control the water flow to the HPCI.sprinkler- systems, are not. approved. and tested for use-in fire-protection systems. The i.ndustry standard for the design andinstallation of sprinkler systems is National Fire ProtectionAssocition.Standard No. 13 (NFPA-13)', Automatic Sprinkler Systems.Section 1-8. 1. 12 of'FPA-13 states that only '"approved" materialsand devices. shall be used in sprinkler systems. The NFPA defi-nition for "approved" devices is those that have been tested forcompliance with appropriate standards. The failure to providestandard approved type fire protection control valves in the HPCI

sprinkler systems is identified as Deviation Item (259/81-.01-05,260/81-01-05, and 296/81-01;-05), use of unapproved automaticallyactivated deluge valves in the HPCI fire protection'prinklersystem.

(6) Diesel Fire Pump House

The air. release valve for the diesel pump is not automatic asrequired. by NFPA-20, Centrifugal Fire Pumps, due to a normallyclosed valve installed between the air release valve. and the pumpdischarge piping. This valve is shown in the open position onFigure 10. 11-1a of the FSAR. The licensee agreed to review thisitem and take the necessary corrective action.

(7) Outside Fire Protection Equipment Houses

Outside fire equipment houses Nos ~ FEH 2 and 3 were inspected bythe inspector. These houses contained a. hose cart with some. firefighting equipment and a wheeled fire extinguisher unit. Thequantity of equipment provided. for the hose cart did not fullymeet the 'criteria of,NFPA-24, Outside Protection, in that anadequate number of fire nozzles, hydrant wrenches, couplingspanners were not provided. Also,'the equipment in the houses arenot inspected monthly as'is the general industry practice. Thelicensee is to revise Procedure NMI 63, Fire- Hose Cabinets, Reelsand" Carts Inspection, to require a monthly inspection of theequipment within the'ire equipment houses and is to re-evaluate ,

the. existing equipment. and provide additional equipment where,considered. necessary.

(8) Cable'rays

TVA's Procedure MMIi75, Installation and Repair of Penetration andFire Stops, limits the number of uncoated (not coated with "Flame-mastic.") cables within a cable. tray to ten. Cable trays wg~enoted throughout the plant. in which over ten uncoated cables wereinstalled. This problem has been identified by gA Survey MA-15-gA's-80-275, Cable" Tray Inspection, dated. August. 4, 1980 and a

minor deficiency< report- has been sent to the plant.. Presently,work is in process. to coat the cables identified by the gA survey.The gA. Supervisor advi,sed that a follow-up inspection will beconducted by February 1., 1981. to determi.ne the status of thisitem. I'f the problem is not. corrected, a, corrective action reportwill be 'issued, by,, the. gA'roup. This item is a violation from thefire. protection and: prevention procedures required by TechnicalSpecifications Section 6.3.A. 10 and is. identified as ViolationItem (259/81-01.-06, 260/81-01-06 and 296/81-01-06), fai l ure tofollow fire protection and.prevention procedures.

(9) Fire Doors — Nonfunctional

The inspector noted the following fire doors to be nonfunctionalwithout a posted fire watch:

(a) Fire door 632 to 480V Shutdown Board Room 1B was open due tothe door closer being inoperative.

(b) Fire doors 655 and 656'o the Unit 3'hutdown board. rooms,were blocked in the open position. There was no apparentmaintenance or repair work in process in this area. Thereason for these doors being blocked open was not determined.

These nonfunctional doors are a .deviation from the coderequirements of- NFPA-80, Fire Doors and Windows. Section14-2.3 of NFPA-80 prohibits the blocking or wedging of firedoors. in the open position. Section 14-2.4 of NFPA-80requires that. self-closing devices for fire doors shall bekept in proper working condition. Furthermore, Section3. 11..F of the Technical Specifications states that anattendant shall be posted on each side of an open, breachedfire stop penetration until the work is completed and thepenetration is resealed. This item is identified as Viola-..tion Item (259/81-01.-07, 260/81-01-07 and'96/81-01-07),nonfunctional fire doors.

('c) Fire Door 294 (2 doors) between the electrical equipmentrooms'n the. Units 1. and 2 diesel generator building arearranged for automatic closing but one door is provided withmanual type latching hardware instead of the automatic typewhich is required'for use on automatic closing doors.

This nonfunctional fire door's a deviation from the. coderequirements of NFPA-80 Section 2.8.2 which requires that allactive swinging fire doors be equipped with positve latchinghardware that automatically. engages when the doors move. tothe closed position; This is identified as Deviation Item259/81-01.-13 and 260/81-01-13), improper hardware on a firedoor between the. electrical equipment rooms in the Units 1,and. 2. diesel generator rooms in the Units 1 and 2 dieselgenerator building.

(10) Fire Door Modifications

TVA's 1'etter of'pril 21, 1977 from J., E. Gilleland to E. G. Caseof NRC/NRR identified a number of doors through'out the plant. whichwere to be changed to fire doors or to be upgraded to doorsequivalent to, fire door. Host of the doors identified in TVA'sApril 21, 1977'letter have been replaced or modified. However,

several nonrated doors with ventilation openings on the 593 and617 foot elevations have not been changed or modified. Thesedoors were to be changed or modified by ECN 1856 dated March 11,1977, but it appears that work on this ECN was never fullycompleted. The; modifications were. originally to be completed bythe- end of either Unit. 1 or 2 first-,refueling outage after the1975'ire. Unit 1. returned to power from this outage on.January 15, 1978. Section 10. 11.3.1 of the FSAR identifies, theApril 21, 1977 TVA letter as providing additional details on thefi're protection modifications. Therefore, this item is considereda failure to meet a commitment to the NRC and is identified asDevi ati on Item (259/81-01-08, 260/81-01-08 and 296/81-01-08)failure to complete fire door modifications.

b. Administrative Procedures

The inspector reviewed the licensee's administrative procedures whichimplements the fire protection/prevention program. These included thefollowing:

(1) Program administration procedures designating personnel onsite andoffsite. responsible for implementation of the fire protection/prevention program (Technical Specifications - Section 6; DivisionProcedure Manual N78S2 (DPM) - Sections Fl and F3; Emergency Plan;BF14.16; and" BF4.6);

(2) Procedures for the control of combustible and flammable materials(OPM Sections F16,. F20 and'24; BF3.6; and. BF14.19);

(3)'rocedures for the control'f welding, cutting, grinding and'thertypes of ignition sources (DPM Section F22; BF14.6; and MMI75);

(4) Procedures for fire brigade organization and training (DPMSections F2 and'3; Emergency Plan; BF4.6;, and BF14. 16); and

(5) Procedures for fire fighting strategies in safety related areas ofthe .plant (Appendix to Emergency Plan). n

These procedures meet the intent or exceed the. provision of NRC guide-lines in document entitled "Nuclear Plant, Fire Protection FunctionalResponsibilities, Administrative Controls and equality Assurance".However, revisions are currently being made to. several procedures tobring some areas up. to the new provisions of 10CFR50 Appendix R cri-teria.. These items include the. requirement. for an annual physical forall fire brigade members, frequency, of fire brigade drills and trainingof brigade members and leaders.

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Audits

The inspector reviewed the audit report (Browns Ferry Triennial FireProtection Audit) of the fire= protection program by Professional LossControl, Inc. dated October 2, 1980. This report. contained 99 recom-.mendations of which approximately 56 recommendations were associatedwith the.- Nuclear portion of'he- plant.'he: licensee stated thatcorrective action had'been initiated on several of these items and the.remaining items were being forwarded to .other divisions within TVA suchas the design and engineering groups for review and comment. This itemis identified as Unresolved Item (259/81-01.-09, 260/81-01-09 and296/81-01-09), Corrective action to be taken on Triennial Fire Pro-tection Audit, and will be reviewed during a subsequent NRC inspectionsThe licensee has been requested to advise NRC Region II as "to theaction to be taken on the recommendations in the audit report.

Records

(1) Surveillance of Fire Protection Systems

The following fire protection system surveillance inspection andtest procedures and recorded test data for the indicated dateswere reviewed. The. inspection and test data was satisfactoryexcept, where noted:

(a) SI4-.11.A.l..a, Simulated Automatic. and Manual Activation ofHigh- Pressure Fire Pumps and Automatic Valve Operability(Yearly): June 11, 1979 through July 1980.

(b)'I4'. 11..A. l.b, High Pressure Fire Protection System Fire Pump

Operability Check (Monthly): January 1980 through December1980.. Surveillance test documents- were not avail'able for the,operability. test on electric fire pump Nos. A and B forAugust 1980 and pump Nos. A and C for October 1980. A reviewof the licensee's "Daily Log of the Unit Operator" indicatedthat Pumps A and B were apparently operated on August 12,1980, but records were not available to indicate that Rllthree pumps were operated during the month of October, 1980.The.- pumps were scheduled to be operated on October 14, 1980,;,test; data on Pump B'is dated both October 18 and 22, 1980 but.notes are not provided to indicate why two dates were shown;and, furthermore, log data indicates that pumps B and C wereoperated on October 22, 1980. The failure to conduct. themonthly surveillance inspection and test for fi,re pump No. A

required by Technical Specification Section 4. 11.A.l.b isidentified as'iolation Item (259/81-01-10, 260/81-01-10 and

~ 296/81-01-10), failure- to determine operability of fire pump

No. A during October 1980.

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(c) SI4.11.A.1.b. (a) High Pressure Fire Protection Diesel DrivenFire Pump Operability Check (Monthly): January 11 throughDecember 2, 1980. No discrepancies noted. However, thediesel engine is only required by the procedure to be oper-ated 10 minutes in lieu of the 30 minutes stipulated byNFPA-20, Centrifugal Fire Pumps, Section 8-6. 1. The proce-dure does not indicate acceptance and rejection criteria for*the-pump.and engine. These-items are currentl'y under evalua-tion. The licensee stated that approximate corrective actionwould be taken.

(d)

(e)

(f)

(g)

SI4.11.A.1.d, Fire Pump capabi 1 ity (3 years): TestedJanuary 19, 1979.

SI4.11.A.l.d. (a), Diesel Driven Fire Pump Flow Test (3years): Tested June 15, 1979.

SI4.11.A. l.e, Testing of Fixed Water Nozzles for Blockage(Annual) June 4-22, 1979 and June 13-July 18, 1980.

SI4.11.A.1.g, High Pressure Fire Protection System BuildingHydraulic. Performance Verification (3 years): June 8-16,1979.

'h) SI4.11.A'.1.h, High Pressure Fire Protection System Yard Loopand Cooling Tower Loop Hydraulic Performance Verification(Annual): June 5-6, 1979 and July 27, 1980; The 1980 testwas extended due to required use of cooling towers andchlorination of raw water system. The 1979 tests were notconducted at sufficient volume, to adequately demonstrate the:available. hydraulic characteristics of the water supplysystem., The li.censee's advised that future tests will followthe 1980 test procedure.

(i)- SI'4.11.A.3, Simulated Automatic and Manual Actuation of Raw

Service Water Pumps and Operation of Tank Level Switcges(Annual):. April 4, 1979. and.May 10-13, 1980. r-

SI4.11.A.5, Valve. Alignment. (3 months): August 28, 1979through December 2, 1980. The quarterly frequency of valveinspection does not. adhere to the general industry practiceof monthly inspections. Also, the valves are not required,

to'e.

sealed. or locked in the correct alignment.. These itemsare identified in the 3 year fire- protection- audit report ofthe facility (refer to above paragraph 5'.c.).

(k) SI4.11.B.1.a, Carbon Dioxide Fire Protection System SimulatedAutomatic and Manual Actuation (Annual): February 21-24,1980. The. previous tests were conducted in February 1979.

9

(2)

This data was in permanent record storage and was not.reviewed.

'I4.

11.B. 1 ~ (c), Testing of Carbon Dioxide Fire ProtectionNozzles for Blockage (3 year): June 2, 1979.

(m) SI4.11.c.1/5, Fire Protection 'esting of Smoke and HeatDetectors (Semiannually)': August: 8-22,, 1980. The previoustest was conducted February 26, 1980 but this test. data wasin permanent. record storage and was not reviewed.

(n) SI4.11.c.2, Fire Protection System Detector Circuitry forNon-Class A Supervised Circuits Providing Alarm Only(Monthly): January 12, 1980 through December 8, 1980.

(o) SI4.1l.c.3 5 4, Fire Protection System Class A SupervisedDetector Alarm Circuits and Circuits From Panel to ControlRoom (2 months): July 1 through November 27, 1980.

Fire Brigade Training

The fire brigade, training records were reviewed. These recordsare'aintained by the Plant Training Officer and OperationsTraining Officer and are kept within the employees'lant per-sonnel record files. A random sample. of 12 out of'pproximately

-110 brigade members'ecords were reviewed. The training recordsindicated that the brigade members had attended the annual fire-brigade retaining program for 1980. A review was made of 8 of theshift: engineers and assistant shift engineers personnel recordfiles. The training records. for the. fire. brigade leadershiptraining was not on file for 4 of these employees. A revi'ew was .

made- of 8 assistant unit, operators'ersonnel record files todetermine; if records of'heir initial fire brigade training wasavailable. However, record. data was only avai 1 able for 4employees.

The initial fire brigade training and the fire brigade leadershiptraining: courses are conducted offsite and it appears that theserecords are not being maintained on site as required- by thelicensee's procedure, Standard Practice. BF4.6, Speciali.zed Train-ing Program;, The licensee is evaluating this problem to determineif'he training records have- been misplaced or if there is adistribution or record retention problem. Training records areconsidered a Quality C'ontrol Records. by TVA. QA Topical ReportTVA-75'-1; therefore, this item is identified as Unresolved Item(259/81'-01;11, 260/81-01.-11 and 296'/81-01-.11), fi re brigadetraining records not available on site, and will be reviewedduring" a subsequent NRC inspection after TYA's evaluation of this

. item.

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(3) Fire Brigade Drills

The drills of the fire brigade are recorded in the operations log.Drills, are required by Emergency Plan - Fire, Explosion andNatural Disaster Plan Section 11 to be conducted, with such fre-quency that:each shift operating crew shall participate in a drillnot. less- than once per.3 months. A review of the 1980 log indi-cated, that: each shift operating crew (5 groups) did, not partici-pate in a drill each 3. months., The actual participation of the 5

groups was as follows:

First quarter Group 3

Second quarter Group 1

Third quarter 'roups 4 and 5

Fourth quarter Groups 1, 2 and 4

Note: Group 5 participated in a drill on Jan. 1,1981.

The failure to provide: a: fire. brigade drill for each shift opera-ting crew. each 3 months for 1980 as required by the Site EmergencyPlan is a violation from the fire protection and preventionprocedures of Technical Specifications Section 6.3.A. 10. This isidentified, as another example of Violation Item (259/81.-01-06,260/81-01-06, and 296/81-01-06), Failure to follow- fire protectionand.prevention procedures.

(4-) Fire Brigade Manning

The shift" assignment logs-for-the following dates were reviewed:

NovemberDecemberDecemberDecember.JanuaryJanuaryJanuary

1T-23, 19808-14, 1980

15-21, 198022-28, 1980

5"11, 198112"18, 198119-25, 1981.

These,. logs indicated that adequate personnel were available tomeet the.- required. minimum 5. man fire brigade'. However, the firebrigade chief'r leader duties were routinely assigned to per-sonnel who had. not. completed the., fire brigade. leadership course.TVA' manual OPM N78S2 Section F3 req'uires the assistant shiftengineers who are assigned fire brigade chief duties to receivethis leadership training course as soon as operating and training

11

schedules permit in a period not to exceed one year after appoint-ment. Presently, 5 personnel have recently been promoted fromunit operator positions to assistant shift engineers and have notyet received. the. fire brigade leadership training. These fiveemployees have been assigned to fill the Unit 2. assistant shiftengineer position which is also the assigned fire brigade chief.The licensee agreed to revise the shift assignments and beginningJanuary 26; 1981, only personnel who have completed the. firebrigade: leadership training course will be assigned to the. posi-tion of Unit 2. assistant. shift. engineer'. A review of theOperator's Schedule for week of January 26-February 1, 1981indicated that this change had been accomplished. Since theTechnical Specifications (Figure 6.3-1) are not clear as to whenthe brigade chief must receive the brigade leadership training andsince other assistant shift engineers were on duty who hadreceived the brigade leadership training, this item was notconsidered a. violation.

Offsite Fire Department Training

The records of the training given to the offsite Athens FireDepartment was ,reviewed. These records indicated that onOctober 30, 1980, a, Fire Chief Officer.and 5 firefighters from theAthens,„ Alabama, Fire Department visited the plant for a tour ofthe hazardous areas of the plant and. received a general plantorientation and training in the basic. principles of Radiation.This annual training was provided as required by TVA EmergencyPlan-Fire Explosion and Natural Disaster Plan, Section 12.

LER 259",8080

Duri'ng the resident inspector's review of LER 259-8080, whichreported the removal of the carbon dioxide (C02) fire protectionsystem from service in order to repair a leaking valve, theresident inspectors determined that the individuals assigned tothe fire watch detail did not fulfill the Technical Specificationrequirements.

The C02. system was taken out of service on October 15, 1980 from7:12.,p..m:. until 9:00 p.m. to repair valve 39-11. TechnicalSpecification 3. 11.B requires- that. a continuous fi're watch- beestablished in-the cable spreading rooms and the diese-1 generatorbuilding when the C02 protection is lost. and other affected areasare to be checked hourly. However, the assigned, fire watchpersonnel only checked the. cable spreading rooms intermittentlyand. made no entries to any of the three auxiliary instrument roomsduring the. period the C02 system was out of service. This item is

identified as Violation Item (259/81-01-12, 260/81-01-12, and296'/81-01-12), failure to provide adequate fire watch while C02.system was out. of service.

(7) Work, Plan 4386 (ECN L9063)

Part X Section A to TVA-Browns Ferry Nuclear Plant Design" Changefor the Recovery from the Fire of March 22, 1975, S'ection 5.4.—4.(1) states that isolation valve No. 0-26-528 in the fireprotection. water. distribution system was to be removed. Work Plan4386 required the internals of this valve to be removed and toreplace the bonnet with a solid bolted plat. The completion sheetfor this work plan was reviewed by the inspector and it- was notedthat the item was completed on March 16, 1976.

Except as noted above, within- the areas examined, no additional items ofviolation or deviations were identified.

hp

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