ML20062J595
| ML20062J595 | |
| Person / Time | |
|---|---|
| Site: | Crane |
| Issue date: | 11/03/1993 |
| From: | Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Broughton T GENERAL PUBLIC UTILITIES CORP. |
| References | |
| NUDOCS 9311090013 | |
| Download: ML20062J595 (2) | |
See also: IR 05000289/1993008
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NOV 0 31993
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Docket No.
50-289
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Mr. T. Gary Broughton
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Vice President and Director, TMI-1
GPU Nuclear Corporation
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Three Mile Island Nuclear Station
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P. O. Box 480
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Middletown, Pennsylvania 17057-0191
Dear Mr. Broughton:
Subject:
Inspection No. 50-289/93-08
This letter refers to your September 10, 1993 correspondence, in response to our August 11,
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1993 letter.
Thank you for informing us of the corrective and preventive actions documented in your
letter. These actions will be examined during a future inspection of your licensed program.
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Thank you for your cooperation.
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Sincerely,
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Original Signed By
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Susan Frant Shankman
<fu Charles W. Hehl, Director
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Division of Radiation Safety
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and Safeguards
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R. E. Rogan, TMI Licensing Director
M. J. Ross, Operations and Maintenance Director, TMI l
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J. Fornicola, Licensing and Regulatory Affairs Director
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TMI-l Licensing Department
E. L. Blake, Jr., Esquire
TMI-Alert (TMIA)
Public Document Room (PDR)
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Imal Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident inspector
Commonwealth of Pennsylvania
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OFFICtAL RECORD COPY
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93110,001a vario3
ADOCK 05000299
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NOV ') * 1993
GPU Nuclear Corporation
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hec:
Region I Docket Room (with concurrences)
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bec (VIA E-MAIL):
A. Blough, DRP
N. Blumberg, DRS
K. Brockman, AEOD
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F. Kantor, NRR/EPB
V. McCree, OEDO
J. Rogge, RI
K. Smith, RI
J. Partlow, NRR
J. Lieberman, OE
M. Young, OGC
D. Holody, RI
M. Banerjee, RI
C. Hehl, RI
S. Shankman, RI
J. Joyner, RI
E. McCabe, RI
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GPU Nuclear Corporation
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Nuclear
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Middletown, Pennsylvania 17057-0480
(717)944-7621
Writer's Direct Dial Number:
(717) 948-8005
September 10, 1993
U. S. Nuclear Regulatory Commission
Attn: Docament Control Desk
Washington, DC 20555
Dear Sir:
Subject:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50,
Docket No. 50-289
"rleply to a Notice of Violation" - Inspection Report 93-08
Enclosed is the GPU Nuclear reply to the Notice of Violation transmitted by
Inspection Report 93-08.
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Sincerely,
T. G. Brou hton
Vice President and Director, TMI-1
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Attachment
cc: Region I Administrator, NRv
THI-1 Senior Project Manager, NRC
TMI Senior Resident Inspector, NRC
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GPU Nuclear Corporation is a subsdiary of General Pubhc Utilrties Corporation
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Attachment
C311-93-2130
Page 1
The Three Mile Island Unit 1 Operating License, Section 2.c(4), Fire
Protection, requires the licensee to implement and maintain in effect all
provisions of the Fire Protection Program as described in the Updated Final
Safety Analysis Report (UFSAR).
The Three Mile Island Unit 1 UFSAR specifies that plant fire protection
systems will comply with National Fire Protection Association (NFPA) and
Commonwealth of Pennsylvania Codes.
NFPA 101, Life Safety Code, Section 5-2.1.2.1.2, states that a latch or other
fastening device on a door shall be provided with a knob, handle, panic bar,
or other simple type of releasing device, the method of operation of which is
obvious, even in darkness.
NFPA 80, Standard for Fire Doors and Wir. dows, Section 1-4, defines a fire door
assembly as any combination of a fire dot,r, frame, hardware, and other
accessories which together provide a specific degree of fire protection to the
opening.
NFPA 80, Section 2-8.2.1, states that only labeled locks and latches or
labeled fire exit hardware (panic devices) meeting both life safety
requirements and fire protection requirements shall be used.
Contrary to the above, from the time of installation of deadbolts on Control
Room Fire Doors C415 and C418 (date unknown due to incomplete licensee
records) through June 10, 1993, the licensee did not maintain in effect all
provisions of the UFSAR fire protection program, in that the Control Room Fire
Doors were not equipped with proper fire exit hardware. Specifically, Fire
Doors C415 and C418 did not meet life safety criteria in that the locks were
not fitted with simple releasing devices.
Instead, they were fitted with
deadbolt locks that required a key for unlocking from either side, thereby
potentially impeding Control Room egress in case of fire. Further, these
daors had a three-hour fire rating and were equipped with locks that did not
have an equivalent fire rating.
This is a Severity Level IV violation (Supplement I).
GPU NUCLEAR RESPONSE TO THE NOTICE OF VIOLATION
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This Notice of Violation (NOV) resulted from investigation of the February 7,
1993, Intruder Incident at TMI.
The Control Room Fire Doors were locked
during the incident. An NRC inspection in June 1993 revealed that improper
locks were installed.
GPU Nuclear concurs with this finding. The locks were
changed as described below.
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Attachment
C311-93-2130
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Page 2
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Reason for the Violation
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GPU Nuclear believes the locks in question were installed in the 1981
timeframe utilizing a blanket job order for repairs of doors. The
blanket job order did not contain caution statements or requirements
specific to fire doors. The locks were installed as a result of an
observation by the Control Room staff during a security drill. The
Control Room staff believed installing locks on the Control Room fire
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doors would provide an additional level of protection during a security
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event.
II. Corrective Steos That Have Been Taken and the Results Achieved
To immediately address the situation, GPU Nuclear installed non-UL
deadbolts on the doors with available locksets that met fire egress
requirements by having deadbolt operation thumbknobs on the Control Room
side. This action was completed by June 10, 1993. On June 21, 1993,
these locks were replaced by similar locks that were UL rated.
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III. Corrective Steps That Will be Taken to Avoid Further Violations
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GPU Nuclear has confirmed that no other fire doors have locks that are
not UL rated or specifically approved for the application. Utility
personnel also have been briefed on the requirement to use UL rated locks
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on fire doors. These two actions serve as interim steps to preclude
future occurrences.
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Installation of additional locks on fire doors using current work control
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methods requires this work to be a modification requiring a specific job
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order. Appropriate controls which address fire protection requirements
are contained in this process. As an added level of assurance, Procedure
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U-22, Door Maintenance and Inspection, will be revised to include a step
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during the preventive maintenance checks that the doors' hardware, such
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as locks on fire doors, are verified as UL rated.
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IV. Date of Full Compliance
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As noted above, confirmation that no other fire doors have a similar
problem and the briefing of utility personnel has been completed.
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Procedure U-22 will be revised by January 1, 1994, or prior to the next
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inspection of fire doors using this procedure, whichever occurs first.
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