ML18344A413

Letter Notice of Proposed Imposition of Civil Penalties Due to Noncompliance of Containment Isolation

ML18344A413
Person / Time
Site:	Palisades
Issue date:	12/06/1979
From:	Youngdahl R Consumers Power Co
To:	Stello V NRC/IE
References
Download: ML18344A413 (3)

Text

consumers Power company R. C. Youngdahl Executive Vice President General Offices: 212 West Michigan Avenue, Jackson, Michigan 49201

• Area Code 517 788*0550 December 6, 1979 Mr Victor Stello, Jr, Director Office of Enforcement and Inspection U.S. Nuclear Regulatory Commission Washington, DC 20555 DOCiv:T 50-255-LICENSE DPR-20 PALISADES PLANT -

CONTAINMENT ISOLATION NONCOMPLIANCE NOTICE OF PROPOSED IMPOSITION OF CIVIL PENALTIES

'l ',...l 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 DBA 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 re~uired - 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 ~robable exception of a failed pleat in its HEPA filter, will remain intact under DB.A 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 in the duct work due to flow controller function during the pressure transient of the DEA is taken.

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December 6, 1979

3.

Also enclosed herewith are a Sllll'.mary, notes, working pa~ers and comDuter outDut suDnorting our contention that the amount of the fin~, absent - all other co;siderations., 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 particy-:4.i:Jschedule of violation occurrences over the period.

As deta1f.'~d-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

PALISADES FINE REVIEW

SUMMARY

\\.

Sta teroen t of Probl~r.i: *

l.

Give.n (a) the calendar dates on which a fine might be levied; (b) the constraints that the daily fine may not exceed $5, 000 ( $9, oo*o on 4/6/7 8) and that in any (and hence, all) 30-day periods, the fine may not exceed $25,000; calculate the maximum possible fine that can be levied.

2.

The problem was first analyzed by inspection.

These results were then verified using linear programming techniques.

The IB!-'l *linear programming package MPSX was used to perform t.~e calculations.

3.

The input data was set up in a format consistent with MPSX requirenents.

Two cases were run, the first using oT-iginal KRC data and the second using CPCo data

~hich included corrections to certain of the NRC data.

4.

"The results verify the preliminary analysis.

The maxi~lli~ possible fine which can be levied, consistent with the constraints, is $425,000.

This result is the sane for both the NRC violation dates and the CPCo corr.ected violation dates.

DAL 12/5/79