ML20062J595

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-289/93-08 on 930811
ML20062J595
Person / Time
Site: Crane Constellation icon.png
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

EA No.93-193

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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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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

J. Stolz, PD I-4, NRR

R. Hernan, PD I-4, NRR

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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Middletown, Pennsylvania 17057-0480

(717)944-7621

Writer's Direct Dial Number:

(717) 948-8005

September 10, 1993

C31I-93-2130

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

NOTICE OF VIOLATION

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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