ML18044A324
| ML18044A324 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/06/1979 |
| From: | Youngdahl R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| TASK-06-04, TASK-6-4, TASK-RR NUDOCS 7912130239 | |
| Download: ML18044A324 (2) | |
Text
'"..-I"... '\\t consumers Power company R. C. Youngdahl Executive Vice President Ge;,eral Offices: 212 West Michigan Avenue, Jackson, Michigan 49201
- Area Code 517 788-0550 December 6, 1979 Mr Viet.or Stello, Jr, Director Office of Enforcement and Inspection U.S. Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255-LICENSE DPR-20 PALISADES PLANT -
CONTAINMENT ISOLATION NONCOMPLIANCE NOTICE OF PROPOSED IMPOSITION OF CIVIL PENALTIES As a result of our conversation last week in your offices, we are providing supplementary information on the subject matter.
- 1.
Additional analysis of flow rate and filter performance have been performed.
These refinements show that in the.event of a DEA with the valves open, 10 CFR 100 limits for both total body and thyroid doses would not be exceeded.
Specifically, if the filters are presumed completely ineffective, total.body dose remains well within - about 15% of - 10 CFR 100 limits while thyroid dose exceeds 10 CFR 100 limits by a factor of approximately 3.
Charcoal adsorber efficiency under DEA environmental conditions is expected to exceed that required to reduce the thyroid dose below the limits of 10 CFR 100.
Overall filter efficiency is expected to range between 68% and 92% during the containment pressure transient, which is above the efficiency required -
- 66%. - to reduce the thyroid dose to 10 CFR 100 limits.
Hence, the DEA consequences with these valves open could not exceed 10 CFR 100 limits by "several orders of. magnitude," and are, in fact, below 10 CFR 100 limits.
- 2.
Further analysis of. the structural integrity of the purge bypass system indicates that the system, with the probable exception of a failed pleat in its HEPA filter*, will remain intact under DEA conditions.
Since the HEPA filter is presumed ineffective for purposes of calculating both total body and thyroid doses, its failure does not affect the off-site consequences of the postulated accident.
Specifically, the metal duct work downstream of flow controller is not pressurized above.11.5 psig during any portion of the accident, using standard methods for calculating compressible flow and resulting pressure drops in piping systems.
Calculations supporting this.conclusion are attached.
This analysis presumes failure.of* the flow controller.
Hence, no* credit for flow and pressure reduction iri t.he duct work due to flow controller function during the pressure transient of the DEA is taken.
/J.ool
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1/1
'7! A 1.. Jl 1. 84 ?.-3CJ r
December 6, 1979
- 3; Also enclosed herewith are a summary, notes, working papers and computer output supporting our. contention that the amount of the fine, absent all other considerations, should not exceed $425,000.
This reduction of the amount in question is the result of appli-cation of the $25,000 limit per any 30-day period in conjunction with the particular schedule of.violation occurrences over the period.
.As detailed in the working papers, a mathematical optimization technique, linear programming, was used to verify the maximum fine allowable.
Yours very truly,
/s/ R C Youngdahl R C Youngdahl Executive Vice President CONSUMERS POWER COMPANY CC:
JGKeppler, USNRC w/o attachments 2