ML18057A257

Responds to NRC 900509 Ltr Re Violations Noted in Insp Rept 50-255/90-12.Corrective Actions:Continuing Training Program Will Be Developed for Supervisors That Will Discuss Fire Protection Program Implementation Topics

ML18057A257
Person / Time
Site:	Palisades
Issue date:	06/08/1990
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9006130246
Download: ML18057A257 (3)

See also: IR 05000255/1990012

Text

consumers

Power POW ERi Nii MICHlliAN'S

PRDliRESS

General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-1636 June 8, 1990 Nuclear Regulatory

Commission

Document Control Desk Washington, DC 20555 DOCKET 50-255 -LICENSE DPR-20 -PALISADES

PLANT -RESPONSE TO INSPECTION

REPORT 90012; NOTICE OF VIOLATION

Kenneth W Berry Director Nuclear Licensing

Nuclear Regulatory

Commission (NRC) Inspection

Report 90012, dated May 9, 1990 documented

the results of a routine safety inspection

and resulted in issuance of a violation

for inadequate

implementation

of Site Fire Protection

Program procedures.

In accordance

with 10 CFR 2.201, our response to the identified

examples of noncompliance

follows: VIOLATION

50-255/90012-04(DRP):

Technical

Specification

6.8.1.f requires that written procedures

shall be established, implemented

and maintained

for activities

that are associated

with the Site Fire Protection

Program. Fire Protection

Implementing

Procedure

No 7 (FPIP-7), "Fire Prevention

Activities", Paragraph

6.3.3.b, requires that properly labeled safety cans equipped with flame arrestors

and spring actuated caps shall be used for storage and handling of all Class 1 liquids. Contrary to the above, on March 22, 1990 the inspector

identified

several instances

where Class 1 flammable

liquids were stored in a locker without use of the required safety cans. In addition, on April 17, 1990 the inspector

observed use of a Class 1 liquid that was not in an approved safety can during floor coating activities.

REASON FOR VIOLATION

In response to Branch

Position APCSB 9.5-1, Appendix A, "Guidelines

for Fire Protection

for Nuclear Power Plants Docketed prior to July 1, 1976", Palisades

committed

to comply with National Fire Protection

Association

Standard 30 (NFPA-30), "Flammable

and Combustible

Liquids Code. The guidelines

of NFPA-30 are reflected

in our Site Fire Protection

Program, and are implemented, in part, through Fire Protection

Program Implementing

Procedures (FPIPs). Our administrative

method for ensuring compliance

with the

guidelines

for storage and handling of Class 1 flammable

liquids is directed under Fire Protection

Program Implementing

Procedure

No 7 (FPIP-7), "Fire Prevention

Activities".

OC0690-0037-NL04-LI01

F'DR A:OOCK G! 90060:3 050002!55

F'DC A GW5 ENERGY COMPANY

Nuclear Regulatory

Commission

Palisades

Plant Response to IR 90012 June 8, 1990 2 NRC Inspection

Report 255/90012

identified

three examples whereby Class 1 flammable

liquids were not stored or handled in accordance

with FPIP-7. In two of the examples, Class 1 flammable

liquids were not stored in safety cans equipped with flame arrestors

and spring actuated caps. At the time when these examples were identified, FPIP-7, Paragraph

6.3.3.b, stated that safety cans equipped with flame arrestors

and spring actuated caps shall be used for storage and handling of all Class 1 flammable

liquids. In the other example, a storage locker was found to contain more than one bottle each of three Class 1 flammable

liquids. These bottles ranged in capacity from one quart to one gallon. At the time when this example was identified, FPIP-7, Paragraph

6.3.3.a stated that, "storage of flammable/combustible

liquids should always be maintained

at the lowest practical

level". The administrative

requirements

for storage and handling of Class 1 flammable

liquids contained

in FPIP-7 are considerably

more stringent

than the NFPA-30 guidelines

which we committed

to in response to Branch Technical

Position APCSB 9.5-1. Although FPIP-7 requires that all Class 1 flammable

liquids shall be stored in safety cans equipped with flame arrestors

and spring actuated caps, NFPA-30 allows small quantities

of these liquids to be stored in other types of containers.

When we implemented

the stricter storage and handling requirements

of FPIP-7 our intent was to simplify field tation of the NFPA-30 guidelines.

It was also intended that alternate, NFPA-30 allowable

provisions

for storing and handling Class 1.flammable

liquids would be allowed on a case by case basis in situations

where the liquid could not be reasonably

stored in a safety can. As an example, some Class 1 flammable

liquids, such as paints, epoxies, and laboratory

reagents cannot be reasonably

stored in safety cans due to either viscosity

or purity considerations.

An evaluation

was performed

for each the three examples described

above. It was determined

that the two examples which involved Class 1 flammable

liquids that were not stored in safety cans did not comply with the requirements

of procedure

FPIP-7. However, in each of these examples it was also determined

that both the storage containers

and the storage quantities

involved were will within the guidelines

of NFPA-30. With respect to the example involving

storage of more than one bottle each of several Class 1 flammable

liquids, although the results of efforts made to limit storage of flammable

liquids to the lowest practical

quantity did not strictly comply with FPIP-7, the stored quantities

and method of storage were found to be well within NFPA-30 guidelines.

We concur with the NRC evaluation

of the identified

deficiencies

as examples of noncompliance

with the requirement

to implement

Site Fire Protection

Program procedures.

CORRECTIVE

ACTION TAKEN ANP RESULTS ACHIEVED The three examples cited in this violation

were evaluated

to determine

their effect on Site Fire Protection

Program compliance

with NFPA-30 guidelines.

The results of this evaluation

indicate that each of the examples was within NFPA-30 guidelines, and that no additional

actions were necessary

in order to achieve Site Fire Protection

Program compliance

with these guidelines.

Additionally, a Plant walkdown of combustible

material storage lockers was performed

and excess materials

were removed. OC0690-0037-NL04-LI01

,, * Nuclear Regulatory

Commission

Palisades

Plant Response to IR 90012 June 8, 1990 CORRECTIVE

ACTIONS TAKEN TO AVOID FURTHER NON-COMPLIANCE

3 A continuing

training program will be developed

for utility and contractor

supervisors

that will discuss Fire Protection

Program implementation

topics. Additionally, FPIP-7 has been revised to more adequately

reflect the storage quantity and container

guidelines

of NFPA-30, and to make procedure

compliance

more understandable.

DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED The Fire Protection

Program procedure

implementation

deficiencies

identified

in NRC Inspection

Report 255/90012

did not result in a lack of compliance

with NFPA-30 Guidelines

or a deviation

from our commitment

to satisfy these guidelines.

Procedure

FPIP-7 has been revised to correct deficiencies

and make procedure

implementation

and compliance

more understandable.

It is expected that the continuing

training program will be developed

and that this training will be provided by November 30, 1990. Kenneth W Berry Director, Nuclear Licensing

CC Administrator, Region III, USNRC NRC Resident Inspector

-Palisades

OC0690-0037-NL04-LI01