ML18057A257

Responds to NRC 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)

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 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 Tech~ical 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 NFPA~30 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".

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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 implemen-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