ML18054A582
| ML18054A582 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 02/28/1989 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8903100401 | |
| Download: ML18054A582 (2) | |
Text
consumers Power POW ERIN&
lllllCHlliAN"S PRDliRESS General Offices:
1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-1636 February 28, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
RESPONSE TO INSPECTION REPORT 88019, UNRESOLVED ITEMS Kenneth W Berry Director Nuclear licensing NRC correspondence dated December 9, 1988 regarding Inspection Report 88019 requested a response to Unresolved Item 88019-03.
Specifically, the NRC requested Consumers Power to submit a description of how our local leak rate test methodology meets or e~ceeds the requirements specified in 10CFR Part 50, Appendix J, Paragraph III.A.5(b)(l).
10CFR50, Appendix J, Paragraph III.A.5(b)(l) requires that if local leakage measurements are taken to effect repairs in order to meet the acceptance criteria to the Type A test, these measurements shall be taken at a test pressure Pt (Type A test pressure at Pt).
Post-maintenance LLRT's performed at Palisades are conducted at test pressure P.
Our position is that the performance of local leak rate testing (Types Baand C) at P is more conservative.
a In support of the 1988 ILRT, nine penetrations required maintenance.
Four of the nine are steam generator manways which are tested utilizing vacuum retent-ion.
Therefore, five penetrations are in question regarding LLRT test pressure:
MZ-17 MZ-33 MZ-36 MZ-40 MZ-41 Containment Pressure Instrumentation Line Safety Injection Tank Drain Letdown to Ion Exchanger Primary Coolant System Sample Degasifier Pump Discharge During the current outage (January 1989 Steam Generator Forced Outage), six penetrations were Type C tested at test pressure P and P
- These included four of the penetrations requiring maintenance durtng theal988 Refout.
The test data below clearly indicates that testing at P is more conservative than a
at Pt.
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Nuclear Regulatory Commission Pal,isades Plant R~sponse to IR 88019 February 28, 1989 Penetration MZ-17 MZ-36 MZ-40 MZ-41 MZ-52 MZ-67 p t (cc/min) 0.0 o.o
- 21. 7 0.0 192.5 709.1 pa (cc/min) 9.8 9.6 204.1 13.2 1725.0 1304.8 Valve Type Globe/Globe Globe/Globe Globe/Globe Globe/Check Globe/Globe Globe/Check The fifth penetration MZ-33 which required maintenance in 1988, will be similarly tested at the next outage of sufficient duration.
2 CPCo notes that the wording of Inspection Report 88-019 could be misinterpreted as written. It states that we "committed to determine by testing that all of their (our) containment isolation valves demonstrate more conservative leakage *** "
What was stated at the exit meeting was that we believed that tests at P were more conservative than tests at P and we would demonstrate this throughaa testing program.
We believe the esting program we have completed adequately demonstrates with reasonable assurance that tests at P are more conservative.
a Inspection Report 88019 included two additional Unresolved Items for which we are providing the following status.
Unresolved Items 88019-01 involved our testing of the steam generator secondary manway covers with a vacuum retention test. Per a telephone conversation with NRR Inspector, R Mendez, on February 21, 1989, Consumers Power Company learned that NRR had recently resolved this issue and was issuing generic guidance.
We will respond to this unresolved item after this guidance is received.
Unresolved Item 88019-02 involved the instrument air line containment isolation valves CV-1211 and CK-CA400, penetration MZ-65.
A Type C test is not routinely performed on this penetration.
During the referenced telephone conversation, Mr Mendez suggested that Consumers Power submit a request to exempt this penetration from Type C tests because MZ-65 does not meet the acceptance criterion of Appendix J, Paragraph III.C.
Consumers Power, however, feels that an exemption request is not necessary because MZ-65 is not required to be Type C tested as per Appendix J, Paragraph II.B and H.
Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, NRG NRG Resident Inspector - Palisades OC0289-0071-NL02