ML20197J936
| ML20197J936 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/02/1986 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 5211-86-2078, NUDOCS 8605200210 | |
| Download: ML20197J936 (4) | |
Text
GPU Nuclear Corporation NUCIMr Post Office Box 480 Route 441 South Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:
May 2, 1986 5211-86-2078 Dr. Thomas E. Murley Region I, Regional Adninistrator U.S. Nuclear Regulatory Commission 631 Park Avenue King of Frussia, PA 19406 i
Dear Dr. Murley:
Three Mile Island Nuclear Station Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Notice of Violation - Inspection Report 86-01 Enclosed is the GPUN response to the Notice of Violation in Appendix A of Inspection Report 50-289/86-01.
Sincerely,
. D.
utill Director, TMI-l HDH/SM0/spb:0574A cc:
R. Conte Enclosure Sworn and subscribed to before me this ?'"
day of D/g4
, 1986.
UNDA L R11TER. NOTARY PUBUC g
ElDDLETOM BOROUGH, DAUPHIN COUMTV
/
MY COMMIS$10N UPlRES FEB. 26.1990 y
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<a (4A 9 -
c Nember Pennsyfv+nia Associstha of Ne **es Notary Publ1C 8605200210 860502 PDR ADOCK 05000289 G
PDR GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation g -c \\ l I
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1 NOTICE OF VIOLATION During an NRC inspection conducted between January 10, 1986, and February 7, 1986, violations of NRC requirements ware identified.
In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Action,"
10 CFR Part 2, Appendix C (1985), the violation is set forth below.
-Technical Specification 6.4.2 requires that a training program for the fire brigade shall meet or exceed the requirements of NFPA Standard No. 27, 1976 edition. One NFPA 27 training requirement is that fire brigade members responding to a drill wear respiratory protection apparatus.
Contrary to the above, on February 6,1986, it was observed that fire brigade members responded to a fire drill without the required respiratory protection apparatus.
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RESPONSE TO NOTICE OF VIOLATION GPUN disagrees with the violation in Inspection Report 86-01.
TMI-l TS 6.4.2 states a training program for the Fire Brigade shall meet or exceed the requirements of Section 27 of the NFPA Code-1976 NFPA-27, Part 52 states:
"In drills, equipment should be operated whenever possible. For example, portable extinguishers should be actually discharged, respiratory protective equipment should be operated and water should be turned into hose l i ne s. "
On February 6,1986, an inspector observed a fire drill where brigade members responded without respiratory protection apparatus. This was viewed as a violation of TS 6.4.2.
The purpose of the Fire Brigade, as stated in the TMI-l Fire Protection Plan, is to:
1.
protect the health and safety of the public and employees, 2.
maintain the plant in a safe, stable condition, 3.
limit damage trom the fire, and 4.
contain and eliminate the fire.
To fulfill this purpose, we feel drills should reflect the type of fire problems which the brigade may face. Further, the NFPA Code does not require all drills to include the use of all equipment.
The drill scenario establishes the type of equipment required.
During the drill observed by the inspector, the initial action taken by the first responders of the brigade extinguished the fire prior to the situation developing into one which would require respiratory protection. Two Self-Contained Breathing Apparatus (SCBA) were required to be brought to the scene by brigade members per Procedure EP 1202-31, " Fire. " One brigade member passed the equipment locker on the way to the scene and responded in turn-out gear, one SCBA was at the scene.
The second SCBA was not at the scene since the man assigned to bring the SCBA did not respond due to a page system problem.
The brigade, based on the fire conditions given by the scenario and controlled by the observers, extinguished the fire properly and promptly, and therefore, the particular situation did not require respiratory protection.
It should be noted that the brigade did not receive credit for the observed drill because there was not a full brigade response.
- Typically, fire brigade drills involve the use of respiratory equipment.
There are drills, though, such as the drill observed by the inspector, that do not. This is in support of the conclusion that small, localized electrical I
fires are the most typical type, as documented in fire reports.
- Also, NPFA-27, Part 51 states:
" Practice drills should be held to check the ability of members to perform the operations they are expected to carry out with the fire equipment provided."
In conclusion, we feel our fire brigade training program does meet NFPA-27 and provides the experience necessary to fulfill the purpose of the Fire Brigade at TMI-1.
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