ML18054A698

Responds to Addl Issues Re Tech Spec Change Request for Rev to Airlock Leak Test.Summary of Airlock Door Seal Test Data (Using Procedure DWO-13) Listed in Attachment 1.Revised Tech Spec Pages & Change Request Encl

ML18054A698
Person / Time
Site:	Palisades
Issue date:	04/20/1989
From:	Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18054A699	List: ML18054A698 ML18054A700 ML18054A701
References
TAC-M64339, NUDOCS 8904260101
Download: ML18054A698 (5)

Text

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POWERINli MICHlliAN'S PROliRESS General Offices: 1945 West Parnell Road, Jackson; Ml 49201 * (517) 788-0550 April 20, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

TECHNICAL SPECIFICATIONS CHANGE REQUEST REVISION -

AIR LOCK LEAK TEST (TAC NO. M64339)

On March 3, 1982 Consumers Power Company submitted a proposed Technical Specifications change that provided for a reduced pressure, between th~ seals test of the containment air locks. On March 21, 1988 a revision to the proposed change request was submitted in response to concerns identified by an NRC reviewer~ On March 20, 1989, and on April 10, 1989, additional issues were raised via telephone conversations with the NRC reviewer. This letter~

responds to these final issues~ Revised Technical Specifications pages are attached and our response to the issues are as follows:

1. The NRC requested that we include a discussion of the data that we have to support an air lock door seal leakage rate of 2500 cc/minute.

Attachment 1 provides a summary of our air lock door seal test data (using procedure number DW0-13). It categorizes the results by year, number of tests, % exceeding the proposed Technical Specifications criterion of 2500 cc/minute (0.023 La) and the average leakage per year per seal test. The test data indicates that the Limiting Condition for Operation proposed by this Technical Specifications Change Request would be entered approximately once per year.

Attachment 2 provides a summary listing of the full pressure air lock t_est results from procedure S0-4a. By separate enclosure to the Palisades NRC Project Manager, a complete t*able of the test results for all full press~re air lock door and all partial pressure door seal tests was provided.

2. The NRC requested that we include a discussion of the maintenance that.has been performed to improve the seal and/or reduce the leak rate.

, OC0489-0115-NL04 8904260101 890420 PDR ADOCK 05000255 1

P.- * ----**** ** PDC i ,

A CMS ENERGY COMPANY

., e Nuclear Regulatory Commission 2 Palisades Plant TSCR - Air Lock Leak Test April 20, 1989 Since prior to 1985, a leakage limit of 2500 cc/min (0.023 La) has been administratively applied to air lock door seal testing. During 1986 all the air lock maintenance and testing procedures were rewritten by the system engineer and a manufacturer's field representative. The majority of this effort focused on enhancing the maintenance procedures to clearly detail the proper methods for setting up the air locks. It can be seen from the testing history that these efforts have been successful in improving the performance and reliability of the air lock doors. Since 1985, the average year end leakage for the door seals has been reduced by a factor of 4 to

5. Also, a review of the full pressure air lock test data shows that the performance of the air lock during testing has been satisfactory since 1986 and the limits applied for testing have been adequate for not jeopardizing the overall containment leak rate.

3. Equate 2500 cc/minute in terms of fractions of La.

The criteria for containment leakage as applied by 10CFR50 Appendix J address the sum leakage for all penetrations. La is defined as the maximum allowable leakage rate at pressure P~ as specified in the Technical Specifications or associated bases. Pa is defined as the calculated peak containment internal pressure related to the design bases accident and $pecif ied either in the Technical Specifications or associated bases.

For Palisades:

108,670 cc/min = La 65,200 cc/min = .6 La 2,500 cc/min = .023 La

4. Revise the Bases to include a discussion of the leakage rate and associated LCO.

A revised Technical Specifications Bases page (4-35) is attached.

Consumers Power Company submitted a Technical Specification Interpretation letter dated November 10, 1977 that provided clarification of the Limiting Condition for Operation (LCO) for containment integrity. This change reflects the LCO time limits specified by that interpretation. _ We, therefore, commit to immediately implement this change request.

OC0489-0115-NL04

e Nuclear Regulatory Commission 3 Palisades Plant TSCR - Air Lock Leak Test April 20, 1989 Since Plant Administrative Procedures currently reflect these proposed changes, implementation of the attached may be specified as immediately upon issuance of the amendment.

Thomas C Bordine Plant Licensing Administrator CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment i

OC0489-0115-NL04

ATTACHMENT 1 AIR LOCK IXX>R SEAL TESTING

-- ------- ----~--- - - - - --- ~- -- -- ---- - - - -- - - - --t---*- - - - ---*- - -

Year No. Tests  % Exceeding 0.01 La  % Exceed 0.023 La Av. Leakage 1985 106 Tests 20 Tests 8 Tests 634 cc/min 19% 8% 0.006 La 1986 72 Tests 1 Test 0% 136 cc/min 1.4% 0.0012 La Rewrote all air lock*maint/test procedures, trained repairman, contracted vendor for 6 weeks to work w/System Engineet on improving Performance 1987 139 Tests 2 Tests 2 Tests 90 cc/min*

1.4%* 1.4%* 0.0008 La

'f<One test not included - could not pressurize - repaired - tested sa.tisfactory 1988 98 Tests 1 Test 1 Test 55 cc/min 1% 1% 0.0005 La 1989 40 Tests 4 Tests 1 Test 128 cc/min*

10%* 5.0%* 0.0012 La

• One test not included - could not pressurize - repaired - te~ted satisfactory -

DW0-13 AVERAGE LEAKAGE (YEAR-END) 600---

500---

Average 0~0-13 400---

Leakage (cc/min) 300---

200---

100---

o---

'85 1 86 1 87 '88 '89 Year MI0489-0115-NL04

ATTACHMENT 2 S0-4a TEST DATA Test Date Leak Rate 2/13/85 57,300.2 cc/min.

2/14/85 66.83.7 cc/min.

8/18/85 39.6 cc/min.

12/2/85 867.6 cc/min.

2/8/86 175.1 cc/min.

10/24/86 4.3 cc/min.

2/13/87 774. 4 cc/min.

8/19/87 1863.2 cc/min.

10/22/87 448 cc/min.

1/22/88 67 cc/min.

7/14/88 330 cc/min.

10/23/88 391.3 cc/min.

4/11/89 0 cc/min.

MI0489-0115-NL04