ML20155C686
| ML20155C686 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/03/1988 |
| From: | Standerfer F GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8806140291 | |
| Download: ML20155C686 (4) | |
Text
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r, GPU Nuclear Corporation
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g gf Post Office Box 480 Route 441 South Middletown, Pennsylvania 17037 0191 717 944 7621 TELEX 84 2386 Writer's Direct Olal Nurnber:
(717) 948-8461 June 3, 1988 4410-88-L-0093/0393P US Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Dear Sirs:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Inspection Report 88-05 The subject Inspection Report identified a violation of the requ '.ements of i
GPU Nuclear Administrative Procedure 4000-ADM-1100.04, "Control of Hot Work,"
which implements a portion of the TMI-2 fire protection program. Pursuant to the provision of 10 CFR 2.201, GPU Nuclear hereby submits the attached reply to tne NRC Notice of Violation.
A further inspection will be conducted on June 8,1988; two (2) merrbers of the on-site NRC staff will accompany tha inspection team.
Sincerely, y'
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. R. Standerfer Director, TMI-2 EDS/ emf Attachment cc: Senior Resident Inspector, TMI - H. J. Conte I
Regional Administ.rator, Region 1 - W. T. Russell E
Director, Plant Directorate IV - J. F. Stolz l
Systems Engineer, TMI Site - L. H. lhonus
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t GPU Nuclear Corporation is a subsidiary of the General Public Ut!!ities Corporation 8806140291 880603 PDR ADO 2 -_________CK 05000320 sciasa ___ -_
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ATTACHENT 4410-88-L-0093-
-NRC NOTICE 0F VIOLATION Technical Specification 6.8.1 requires, in part, that written procedures shall be implemented-covering the applicable procedures reconynended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Administrative procedures that implement the plant's fire protection program are referenced in Appendix A c' 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 job 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, Fire protection and suppression equipment installed in the job area shall c.
be verified to be in service.
d.
Appropriate portable fire extinguishers shall be provided at the' immediate job site. Size, type, and number of extinguishers should be obtained to suit the hazard in any individual job area, but shall include a minimum of one 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, l?68, the "Control of Hot Work," was not properly implemented at the Decontamination Facility in the reactor building in that the above-noted procedural prerequisites 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.
Portable fire extinguishers at the facility failed to operate during the c.
February 22, 1988 event (the fire extinguisher was empty).
d.
On February 27, 1988, at the facility, an inappropriate carbon dioxide extinguisher wad used with no ABC dry chemical unit available.
As a direct result of the failure to implement these prerequisites, fires occurred in the Decontaminatica Facility in the reactor bulloing on the above 1
dates.
This is a Severity Level IV Violation (Seplement 1).
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Y.i' ATTACHENT 4410-88-L-0093 GPU NUCLEAR RESPONSE
-As a result of the two (2) small fires that occurred in the Decontamination
' Facility of the TMI-2 Reactor Building, significant efforts have been undertaken and accomplished to prevent recurrence of these incidents. Both fires involved portable fire extinguishers that failed to operate.
A failure to fully implement the site procedures on "Control of Hot Work," and less than adequate housekeeping were contributing factors in both fires.
In addition to the Notice of Violation, the NRC transmittal letter for Inspection No. 88-05 requested GPU Nuclear to "review (our) fire protection program implementation and provide the results of that review and any corrective actions that (we) plan." Therefore, a review of the entire TMI-2 Firo
') ot.ection Program and its implementation was undertaken with the following results:
1.
The Bi-Annual QA Fire Protection Inspection and Audit (February 19 through March 31,1988)' directed particular attention to the TMI-2 Reactor Building and extinguisher preventive maintenance (PM) program.
This audit resulted in no findings; 2.
A re-review was conducted of the Tri-Annual Audit and Inspection (August 1987) that was performed by inspectors representing GPU Nuclear, Jersey Central Power and Light, and the American Nuclear Insurers. This re-review resulted in no findings; 3.
On February 29, 1988, fire protection engineering inspections were changed from quarterly to monthly; 4.
On February 29, 1988, safety management personnel began the perfomance of twice-a-month inspections of the Reactor Building; 5.
From Merch 2 through March 7, 1988, job briefings were provided on the l
implementation of the hot work procedurr; l
6.
On May 6, 1988, a job briefing was provided for Unit 1 and Unit 2 Utility l
Department personnel on the inspection and maintenance of portable fire extinguishers; 7.
The preventive maintenance procedure and records for all of TMI-2's fire extinguishers (a total of 416 extinguishers) have been reviewed; 8.
The housekeeping effort in the Reactor Building has been increased by a factor of 5; e
9.
A goal of field testing 20% of TMI-2 fire extinguishers was set for this year. To date, 10% of the fire extinguishers have been tested with no failures experienced.
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ATTACHNENT 4410-88-L-0093 As to the failure to satisfy specific prerequisites, as noted in the violation, the following information is provided in addition to the above:
1.
ltem a. avotes the 4000-ADM-1100.05 requirement for a 40 f t. clear area.
This requirement normally would be waived based on the containment of the hot work within the hot work facility and contingent upon the facility being properly cleared of combustibles. GPU Nuclear acknowledges that, at the time of these fires, the hot work facility was not properly cleared of combustibles, but as of March 3,1988, this condition was rectified.
2.
Item b.
The HEPA ductwork was repositioned away from any area where slag, hot material, or sparks could land. However, the HEPA suction is used during work on radioactise material and occasionally may be repositioned near the hot kJrk. To prevent ignition of the ductwork, the duct was wrapped with weld cloth on February 25, 1988.
3.
Item c. requires that fire suppression systems are in service. The only fixed fire suppression equipment in the area is the hose reet standpipe system. This system was properly placed in service per the Technical Specifications while the hot work was in progress.
4.
Item d. refers to the inappropriate assignment of a carbon dioxide extinguisher to the hot work firewatch. We agree that this assignment would be inappropriate; however, this particular carbon dioxide extinguisher came from the installed extinguisher storage racks at the top of the operating floor stairway. It had not been assigned to the firewatch. Two (2) halon fire extinguishers have been staged at the Decontamination Facility and firewatches have been trained on their inspection and use.
Full compliance has been achieved through the above corrective actions. A further inspection will be conducted on June 8,1988, to verify compliance; two (2) members of the on-site NRC staff will accompany the inspection team.