ML18057A257
| ML18057A257 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/08/1990 |
| From: | BERRY K W 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