ML20210A265
| ML20210A265 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/23/1987 |
| From: | Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| References | |
| NUDOCS 8705050050 | |
| Download: ML20210A265 (3) | |
See also: IR 05000289/1986001
Text
.
s
p-
.-
APR 2 3 1987
Docket No. 50-289
GPU Nuclear Corporation
ATTN: Mr. H. D. Hukill
Vice President and Director of TMI-1
P. O. Box 480
2
Middletown, Pennsylvania 17057
Gentlemen:
Subject:
Inspection 50-289/86-01
This refers to your letter dated May 2,1986, in response to our letter dated
April 1, 1986.
In your response, you disagreed with our finding as being a
violation and you reiterated your disagreement in a follow-up letter dated
'
September 17, 1986.
)
Following a management meeting held at the NRC Region I office to resolve this
issue, you committed to require the use of respiratory protection gear and
]
protective clothing by at least two drill participants. An inspection of your
program on March 23-26, 1987 examined the corrective and preventive actions you
j
have taken in this area and found them acceptable,
a
j
Your cooperation with us is appreciated.
Sincerely,
.Oricinal sima p.r:
!
William V. Johnston, Acting Director
i
Division of Reactor Safety
Region I
i
i
cc w/ enc 1:
R. J. Toole, Operations and Maintenance Director, TMI-1
1
C. W. Smyth, Manager, TMI-1 Licensing
i
R. J. McGoey, Manager, PWR Licensing
E. L. Blake, Jr., Esquire
I
TMI-1 Hearing Service List
!
Public Document Room (PDR)
[
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
i
NRC Resident Inspector
Commor.vealth of Pennsylvania
}
OFFICIAL RECORD COPY
RL TMIl 86-01 - 0001.0.0
04/16/87
0705050050 870423
'
ADOCK 05000289
G
. .
__
.
.
__
-
.
.
_ _ _ . _ _
..
__
_ _ _
_
.
.
o
9
GPU Nuclear Corporation
2
bcc w/ enc 1:
Region I Docket Room (with concurrences)
W. D. Travers, Director, TMI-2 Cleanup Project Directorate
J. Goldberg, OELD: HQ
DRP Section Chief
K. Abraham, PA0
Robert J. Bores, DRSS
SEE PREVIOUS WHITE
-
RI:DRS
RI:DRS
RI:DRS
{r o culos
Ander on
Durr
,
4/9/87
4/20/87
4//6/87
0FFICIAL RECORD COPY
RL TMIl 86-01 - 0002.0.0
01/16/87
.
-
-
-
..
.
.
/
Operations
18
'
50-289
TMI-1 Hearing Service List
Sheldon J. Wolfe, Chairman
Bruce W. Churchill, Esquire
Administrative Judge
Shaw, Pittman, Potts & Trowbridge
Atomic Safety & Licensing Board Panel
2300 N Street, N.W.
U.S. Nuclear Regulatory Commission
Washington, D.C.
20037
Washington, D.C.
20555
Dr. Oscar H. Paris
Atomic Safety & Licensing Board
'
Administrative Judge
Panel
Atomic Safety & Licensing Board Panel
U.S. Nuclear Regulatory Commission
U.S. Nuclear Regulatory Commission
Washington, D.C.
20555
Washington, D.C.
20555
Frederick J. Shon
Atomic Safety & Licensing Appeal
Administrative Judge
Board Panel
Atomic Safety & Licensing Board Panel
U.S. Nuclear Regulatory Commission
U.S. Nuclear Regulatory Commission
Washington, D.C.
20555
Washington, D.C.
20555
,
Joanne Doroshow, Esquire
Docketing & Service Section
l
Three Mile Island Alert, Inc.
Office of the Secretary
i
315 Peffer Street
U.S. Nuclear Re ;1atory Commission
Harrrisburg, PA 17102
Washington, D.C.
20555
Louise Bradford
Mary E. Wagner, Esquire
1011 Green Street
Office of Executive Legal Director
Harrisburg, PA 17102
U.S. Nuclear Regulatory Commission
Washington, DC 20555
!
Thomas Y. Au
Assistant Counsel Commonwealth
Resident Inspector
of Pennsylvania
Box 311
Dept. of Environmental Resources
Middletown, PA 17057
Bureau of Environmental Resources
Room 505, Executive House
,
P. O. Box 2357
4
Harrisburg, PA 17120
\\
!
!
i
-
-
- -
-
-
- - - - - - - - - - - - - - - - -
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
I
.
.
.
,
=
. .
GPU Nuclear Corporation
NQgIgf
Post Office Box 480
Route 441 South
Middletown, Pennsylvania 17057-0191
717 944 7621
TELEX 84 2386
Writer's Direct Dial Number:
Pay 2,1986
5211-86-2078
Dr. Thomas E. Murley
Region I, Regional Adninistrator
U.S. Nuclear Regulatory Commission
631 Park Avenue
King of Prussia, PA 19406
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-1
HDH/SM0/spb:0574A
cc:
R. Conte
Enclosure
Sworn and subscribegto
before me this y
day
0*
U
d[
'
ueOA t. MTTit, no1Aff PUSUC
moeuTown sce000H, DAUPHIN COUNTY
_ 7[
m As o iIt n e No
hfhi([
s_
p.
e ennsy
es
Notary Puvl1C
<
'
GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
.
.
.
. .
.
During an NRC inspection conducted between January 10, 1986, and February 7,
1986, violations of NRC requirements were 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 10. 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.
4
-1 -
-
-
.
.-
.
. - - . _
.
.-
- . . . - .
_ . - - _ -
-.
l
. *
!'
!
RESPONSE TO NOTICE OF VIOLATION
l
t
!
i
GPUN disagrees with the violation in Inspection Report 86-01.
TNI-1 TS 6.4.2 states a training program for the Fire Brigade shall meet or
i
j
exceed the requirements of Section 27 of the NFPA Code-1976
NFPA-27, Part 52
!
j
states:
"In drills, equipment should be operated whenever possible. For
i
example, portable extinguishers should be actually discharged, respiratory
l
protective equipment should be operated and water should be turned into hose
li nes . "
I
On February 6,1986, an inspector observed a fire drill where brigade members
j
responded without respiratory protection apparatus.
This was viewed as a
j
violation of TS 6.4.2.
-
The purpose of the Fire Brigade, as stated in the TMI-1 Fire Protection Plan,
is to:
!
!
1.
protect the health and safety of the public and employees,
l
!
2.
maintain the plant in a safe, stable condition,
i
3.
limit damage from the fire, and
i
4.
contain and eliminate the fire.
l
To fulfill this purpose, we feel drills should reflect the type of fire
i
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
.
i
inspector, the initial action taken by the first responders of the brigade
!
,
i
extinguished the fire prior to the situation developing into one which would
i
require respiratory protection. Two Self-Contained Breathing Apparatus (SCBA)
j
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
j
to the scene and responded in turn-out gear, one SCBA was at the scene.
The
j
second SCBA was not at the scene since the man assigned to bring the SCBA did
i
not respond due to a page system problem.
The brigade, based on the fire
i
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.
i
,
j
It should be noted that the brigade did not receive credit for the observed
drill because there was not a full brigade response.
,
t
k
,
--
,
l
i
l
!
l
4
.-
., . . - . . - - . , , - - , , _
-,-- - -,- - -- - . . . _ , - - , - - , - , . - , . - _ _ , , - - . . , , - . , - , , - . - . - - - - . _ . . . , - _ ~
-
,
-
.
.' .
.'
.
Typically, fire brigack 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
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.
i
-3-
_. -_ _-
..
.
JAN 14 '87 09:47
HRC TLR TMI UNIT 1
P02
6;QY
"
.
.
,
.
.
NU$I%f
GPU Nuoleet Corporation
Post Office Box 4so
Route 441 South
Midd
. Pennsylvante 17o57 0191
TELEX 84 23aa
Writer's Direct Oial Number:
Sestamber 17. 1986
52'1-86-2155
l'
Dr Thomas E. Murley .
Region i Regional' Attninistrator
U.$; Nuclear Regulatory' Commtssion
631 Park Avenue
King of Prussia PA 19406
Dear Dr. Murleyt
Three Mile 11an.d Nuclea/ Station, Unit I, (TMI-1)
4
Opertflag"1.icense No. DPR-50
' Doc cet No. 50-289
Meet 1{ o~ri Fire Brigade Training Program
Ort Au ust 12, 1986, GPUWepersonnel met with Region 1 personnel to discuss the
TMt F re BrigadoxTraffli*hg Probram and5the contested violation in Inspection
.)
Report 86-01; Aspects of the training program discussed were:
,
training at the trurn building
,
role of support personnel at drills
documentation of drills
determining credit for drills
- complexity of drill scenarios
i
The contested violation in Inspection Report 86-01 concerned an alleged
violation of a section of NFPA-27
The issue was the use of respiratory
protection apparatus during drills. A A' frill was observed by an inspector
where two brigade members did not arrfys with respiratory protection
apparatus. A violation was issued by the inspector although credit had not
been given for the drill. GPUN still contends this was not a valid violation.
A review of drill data for January 1 through August 12, 1986 showed that for
all drills except the one observed by the inspector, at Icast two brigade
members arrived.in turnout gear and at least two respiratory protection
apparatus were brought. This information was provided to the NRC at the
1,LO40917
gDR
ADOCK 050
9
fu o s i\\e
/
OPU Nuclear Corporation is a subsidiary of the General Pubile Utilities Corporation
W6-4 8 4
,
!
INA U a
_ . _ _ _ _ _ _ _
. _ . . _ - . - - - - _ _ - - - -
- - - - - -
- - - - -
-
--
- - - - ~ ~
JbH14'870'9:48
HRC TLR TMI UNIT 1
P03
.-
,
.
.
.
.
5211-86-2155
-2-
September 17, 1986
,,
,
V
August 12th meeting. .Sinci'this has been routinely accomplished GPlM has
agreed to include the requirveent for two fire brigade members to obtain, don
'and utilize full turn.:ut gear and res01ratory protection apparatus during a
drill as one of the ob.fectives of 44C1 drill.
.
5incerely,
h11
Vice President 4 Of ttetor, TMI-1
HDH/900/sp6'
,
cc:
R. Conte
oCIA
.
k
.
.
8
..
O