ML18054B294
| ML18054B294 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/06/1989 |
| From: | Zwolinski J Office of Nuclear Reactor Regulation |
| To: | CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18054B295 | List: |
| References | |
| NUDOCS 8912150014 | |
| Download: ML18054B294 (9) | |
Text
In the Matter of CONSUMERS POWER COMPANY (Palisades Plant)
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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EXEMPTION I.
Docket No. 50-255 7590-01 Consumers Power Company (the licensee) is the holder of Provisional Operating License No. DPR-20, which authorizes the licensee to operate the Palisades Plant at power levels up to 2530 megawatts thermal.
The facility is a pressurized water reactor located on the licensee's site in Van Buren County, Michigan.
The license provides, among other things, that it is subject to all rules, regulations, and orders of the Nuclear Regulatory Commission (the Commission) now or hereafter in effect.
I I.
Paragraph III.0.2.(b)(ii) of Appendix J to 10 CFR Part 50, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors, states that containmerit air locks that have been opened during periods when containment integrity is not required by the plant's Technical Specifications shall be tested at the end of such periods at not less than Pa.
(Pa is the calculated peak containment pressure for design basis accidents.) Consumers Power Company has requested exemption from this requirement and proposes, in lieu of testing the air lock at Pa, to perform a between-the-seals leak test at a pressure of not less than 10 psig.
Consumers Power Company proposes to apply this alternate testing only if no maintenance or modification has been performed on the air lock during the period that could affect the sealing capability; otherwise, the
- testing as required by Paragraph III.D.2.(b)(ii) of Appendix J to 10 CFR Part 50 would be performed.
No other provisions of Appendix J to 10 CFR Part 50 are affected by this Exemption.
I I I.
Whenever the facility is in cold shutdown, defined as when the boron concentration is at shutdown concentration and the primary coolant temperature is less than 210°F, containment integrity is not required. If during this time an air lock door is opened, an overall air lock test at Pa must be performed pri_or to leaving the cold shutdown condition to comply with Paragraph III.D.2.(b)(ii) of Appendix J to 10 CFR Part 50.
The air lock door designs are such that a test at Pa of the entire air lock can be performed only with structural bracing (strongbacks) installed on the tnner door. These strongbacks are needed because the pressure exert~d on the inner door during the test is in the reverse direction to the pressure exerted during accidents.
To conduct the leak test in compliance with Paragraph III.D.2.(b)(ii) requires approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, whereas only two to four hours are required for the alternate testing proposed.
Paragraph III.D.2.(b)(iii) of Appendix J to 10 CFR Part 50 states that containment air locks that have been opened during periods when containment integrity is required by the technical specifications shall be tested within three days. This paragraph also provides that for doors with testable seals, seal testing _fu~fi_ns ~his requi_rement, and furt~e.r provides for reduced pressure test i rig of the sea 1 s. There is no reason to expect an air 1 oc k to leak excessively merely because a door was opened during cold shutdown or refueling vice during other operating ~onditions provided (!)_there has been no maintenance, modification, or other activity that could affect the
- leak-tightness or sealing capability of the air lock, (2) the air lock doors are closed in accordance with applicable procedures, and (3) the periodic test at Pa required by Paragraph III.0.2.(b)(i) of Appendix J to 10 CFR Part 50 has been performed within schedule.
The alternate testing proposed will prove air lock integrity following cold shutdown or refueling in the same manner that the air lock is proven during periods when containment integrity is required. Thus, the door seal leak test at reduced pressure (not less than 10 psig) is sufficient to demonstrate continuing integrity of the air locks.
Accordingly, we conclude that Consumers Power Company's proposed approach of substituting reduced-pressure seal leakage testing (at not less than 10 psig) per Paragraph III.0.2.(b)(iii) for the full-pressure testing per Paragraph III.0.2.(b)(ii) of Appendix J is acceptable provided (1) there has been no maintenance, modification, or other activity that could affect the leak tightness or sealing capability of the air lock, (2) the air lock doors are closed in accordance with applicable procedures, and (3) the periodic test at Pa required by Paragraph III.0.2.(b){i) of Appendix J to 10 CFR Part 50 has been performed within schedule.
Whenever conditions (1), (2), or (3) are not met, the requirements of Paragraph III.D.2.(b)(ii) of Appendix J must be met.
The proposed alternative testing of the air locks is sufficient to achieve the underlying purpose of the prescribed Appendix J testing; viz, to verify air l_ock iyitegrity iJ.fter clos_ure to assure that containment leakage is within-specified technical specifications limits. The Commission has granted previously this same exemption to other plants. Consequently, the special circumstances described by 10 CFR 50.12 (a)(2)(ii) exist in that application
( of the regulation in these particular circumstances is not necessary to achieve the underlying purpose of :;the regulation since the proposed alternative testing accomplishes the int~nt of the rEgulation.
IV.
Accordingly, the Commission has determined that pursuant to 10 CFR 50.12(a) this exemption as described in Section III is authorized by law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security. The Commission determines further that special circumstances as provided in 10 CFR 50.12(a)(2)(ii) are present justifying the exemption.
Therefore, the Commission hereby grants the exemption to Paragraph III.D.2(b)(ii) to Appendix J to 10 CFR Part 50 as discussed in Section III except that air locks opened during periods when containment integrity is riot required by the Technical Specifications shall be tested at the end of such periods at not less than Pa when maintenance, modification, or other activities that could affect air lock leak-tightness or sealing capability have beer1 p~rforffied.
Pursuant to 10 CFR 51.32, the Commission has determined that the issuance of this Exemption will have no significant impacts on the environmental (54 FR 50461 December 6, 1989).
For further detail~ with respect to this action, see the request for exemption dated August 25, 1989, which is available for public inspection at the Commission's Public Document Room, 2120 L Street, N.W., Washington, D.C.
20555, and at the Van Zoeren Library, Hope College, Holland, Michigan 49423.
This Exemption is effective upon issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Jo~i=~~r Division of Reactor Projects - III, IV, V & Special Projects Office of Nuclear Reactor Regulation
FP0685-0001L-NL04 Docket 50-255 ATTACHMENT A TO THE JULY 21, 1986 CONSUMERS POWER COMPANY FIRE PROTECTION SUBMITTAL FIRL PROTECTION - EXEMPTION REQUESTS AND MODIFIED COMMITMENTS INDEX FOR ATTACHMENT - REVISION 7 July 21, 1986 3 Pages I
FIRE PROTECTION - EXEMPTION REQUEST MODIFIED COMMITMENTS - REVISION 7 NRC APPROVAL ATTACHMENT STATUS 1
Appendix A lA lB lC 2
3 4
5 Appendix A
- Of Attach 5 N/A N/A N/A N/A N/A,
N/A Withdrawn 6/19/85 Withdrawn 6/19/85 Witlu~rawn 6/19/85 N/A NEW INFORMATION THIS SUBMITTAL (YES/NO)
NO NO NO NO NO NO NO.
NO NO NO INDEX FO ACHMENTS July 21, 1986 Page 1 of 3 TITLE APPENDIX R REVIEW PROCESS (Original Submittal April 23, 1984 - Rev 1 July 16, 1984 -
Rev 2 August 10, 1984 Rev 3, December 28, 1984)
ILLUSTRATIONS, APPENDIX R REVIEW PROCESS of Attach l (Original Submittal December 28, 1984)
ESSENTIAL EQUIPMENT FOR SAFE SHUTDOWN POST-FIRE (O~iginal Submittal August 10, 1984 Revision 1 - June 19, 1985)
Revision 2, July 21, 1986 FIRE AREA IDENTIFICATION, AUTOMATIC FIRE SUPPRESSION COVERAGE, AND FIRE DETECTOR COVERAGE (Original Submittal July 16, 1984 - Rev 1 August 10, 1984)
EMERGENC~ LIGHTING (Original Submittal, July 16, 1984 Revision 1 - October 1, 1984 Revision 2 - June 1985.)
MODIFICATIONS TO PREVIOUS FIRE PROTECTION COMMITMENTS (Original Submittal April 23, 1984 - Revision 1 July 16, 1984 Rev 2 August 10, 1984)
EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 SERVICE WATER PUMP SEPARATION IN INTAKE STRUCTURE (Original Submittal April 23, 1984 - Revision 1 July 16, 1984)
EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 ENGINEERED SAFEGUARDS AREA (Original Submittal April 23, 1984 - Revision 1 July 16, 1984)
EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 RATED BARRIERS (Original Submittal April 23, 1984 - Revision 1 July 16, 1984)
TEST REPORTS WHICH SUBSTANTIATE ATTACHMENT 5 - ITEMS a,b,c and d (Original Submittal July 16, 1984)
ATTACHMENT 6
7 8
9 10 11 12 13 FIRE PROTECTION -
EXEMPTION REQUEST MODIFIED COMMITMENTS - REVISION 7 NRC "NEW INFORMATION APPROVAL THIS SUBMITTAL STATUS YES/NO Withdrawn NO b/19/85 Withdrawn 19/4/~S "1/1t./ II YES N/A Approved 7/12/85 Approved 7/12/85 Approved 2/8/83 Withdrawn 4/23/84 Denied 2/13/85 NO NO NO NO NO NO INDEX FOR ATTACHMENTS July 21, 1986 Page 2 of 3 TITLE EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 COMPONENT COOLING WATER ROOM (Original Submittal April 23, 1984 - Revision 1 July 16, 1984)
EXEMPTION REQUEST - SECTION III.G.2 AND III.G.3 OF APPENDIX R
. TO 10 CFR 50 - CHARGING PUMPS P-55B AND P-5SC (Original Submittal April 23, 1984 - Revision 1 July 16, 1984)
SUMMARY
, PLANT MODIFICATIONS RESULTING FROM "APPENDIX R.
SELF-AUDIT" (Original Submittal April 23, 1984 - Revision 1 July 16, 1984)
EXEMPTION REQUEST - SECTION III.G.3 OF APPENDIX R TO 10 CFR SO-ENGINEERED SAFEGUARDS PANEL ROOM (Original Submittal July 2S, 1983 - Revision 1 July 16, 1984)
EXEMPTION REQUEST - SECTION III.G.3 OF APPENDIX R TO 10 CFR SO-CORRIDOR BETWEEN CHARGING PUMP ROOM AND SWITCHGEAR ROOM lC (Original Submittal July 2S, 1983 - Revision 1 July 16, 1984)
EXEMPTION REQUEST - SECTION III.G.3 OF APPENDIX R TO 10 CFR SO CONTROL ROOM (Original Submittal July 1, 1982 - Revision 1 July 16, 1984)
EXEMPTION REQUEST - SECTION Ill.G.l.a OF APPENDIX R TO 10 CFR SO REPAIR PROCEDURE HOT SHUTDOWN INSTRUMENTATION (Original Submittal December 6, 1982 - Revision 1 July 16, 1984)
EXEMPTION REQUEST - SECTION III.L.4 OF APPENDIX R TO 10 CFR 50 LOCAL TENDING OF EMERGENCY DIESEL GENERATORS (Original Submittal August 10, 1984)
FIRE PROTECTION - EXEMPTION REQUEST MODIFIED COMMITMENTS - REVISION 7 NRC APPROVAL INDEX FOR ATTACHMENTS July 21, 1986 Page 3 of 3 ATTACHMENT STATUS:
NEW INFORMATION THIS SUBMITTAL YES/NO TITLE
\\
14 15 OPEN Approved
- 7/23/85 YES NO EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 INSTRUMENT SEPARATION INSIDE CONTAINMENT (Original Submittal July 16, 1984 - Rev 1 December 28, 1984 Rev 2 October 4, 1985)
EXEMPTION REQUEST - SECTION III.G.2 OF APPENDIX R TO 10 CFR 50 *CABLE SEPARATION INSIDE CONTAINMENT (Original Submittal July 20, 1984)