ML20153G180

Notice of Violation from Insp on 880227-0401.Violation Noted:Failure to Perform Procedural Prerequisites for Controlling Hotwork Activities in Decontamination Facility in Reactor Bldg

ML20153G180
Person / Time
Site:	Three Mile Island
Issue date:	05/04/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20153G169	List: ML20153G165 ML20153G180 ML20153G193
References
50-320-88-05, 50-320-88-5, NUDOCS 8805110162
Download: ML20153G180 (2)

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APPENDIX A NOTICE OF VIOLATION GPU Nuclear Corporation Docket No. 50-320 Three Mile Island Unit 2 License No. DRP-73 As a result of the inspection conducted February 27 - April 1, 1988, and in ac-cordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the following violation was identified:

Technical Specification 6.8.1 requires, in part, that written procedures shall be implemented covering the applicable procedu-es recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Administrative proce-dures that implement the plant's fire protection program are referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Section 4.3 of Administrative Procedure, "Control of Hot Work" (4000-ADM-1100.05), which implements a portion of the plant's fire protection program, requires that the following prerequisites be completed prior to starting hot work,

a. The jcb area shall be clear of transient combustibles such as trash and rags within a 40-foot distance to protect against ignition by slag or sparks.

b. All fixed combustibles, machinery, equipment, and cable in trays subject to possible ignition or damage by sparks or slag shall be protected by appropriate noncombustible guards or covers,

c. Fire protection and suppression equipment installed in the job area shall be verified to be in service.

d. Appropriate portable fire extinguishers shall be provided at the imme-diate job site. Size, type, and number of extinguishtrs should be ob-tained to suit the hazard in any individual job area, but shall include a minimum of o6e ABC dry chemical unit and shall be in addition to the normal complement of extinguishers installed in the area.

Contrary to the above, on February 22, 1988, and on February 27, 1988, the "Control of Hot Work," was not properly implemented at the Decontamination Facility in the reactor building in that the above-noted procedural prere-quisites were not completed. Specifically:

a. The job area was not clear of transient combustibles with trash and rags within a 40-foot distance,

b. On February 22, 1988, the High Efficiency Particulate Absolute (HEPA) ductwork for the facility was not appropriately covered.

OFFICIAL RECORD COPY DL50-320/88 0003.0.0 04/28/88 8805110162 880504 PDR ADOCK 05000320 Q DCD

Appendix A 2

c. Portable fire extinguishers at the facility failed to operate during the February 22, 1988 event (the fire extinguisher was empty).

d. On February 27, 1988, at the facility, an inappropriate carbon dioxide extinguisher was used with no ABC dry chemical unit available.

As a direct result of the failure to implement these prerequisites, fires occurred in the Decontamination Facility in the reactor building on the above dates.

This is a Severity Level IV Violation (Supplement 1).

Pursuant to the provision of 10 CFR 2.201, the GPU Nuclear Corporation is hereby required to submit to this office within thirty days of the date of the letter which transmitted this notice, a written statement or explanation in reply, in-cluding: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and, (3) the date when full compliance will be achieved. Where good cause is shown, considera-tion will be given to extending this response time.

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OFFICIAL RECORD COPY DL50-320/88 0004.0.0 04/28/88