ML20030A560
| ML20030A560 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 09/13/1974 |
| From: | Sewell R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20030A559 | List: |
| References | |
| NUDOCS 8101100042 | |
| Download: ML20030A560 (2) | |
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/6*C Mr. James 0. Keppler, Regional Director Re: Docket 50-eW-Directorate of Regulatory Operations License DPR-96 6 Region III Palisades Plant US Atomic Energy Commission 799 Roosevelt Road Olen Ellyn, I'L 60137
Dear Mr. Keppler:
Your letter dated August 27, 197h~ stated that certain of our activities appeared to be in violation-of AEC requirements and requested a response on one of those items. This letter is to provide the requested response.
Violation Contrary to Technical SpecirJeation Section 3.6 and 10 CFR 50, Appendix J, the applicable leak rate test was not performed following the replacement on April 9, 197h of supply, ventilation valve (CV 4097).
A refueling operation which requires containment integrity was subse-quently performed without the leak rate test having been accomplished.
Response
Immediate corrective action was taken and satisfactory results were obtained as outlined in Abnormal Occurrence Report A0-10-74 dated May 6, 197h.
In order to avoid s.imilar occurrences in the future, the plant Procedures Manual has been revised to incorporate the rrquirements of 10 CFR 50, Appendix J, as a step in all maintenar.ce procedures that in -
volve a containment pressure boundary component repair. This procedure addition has been approved and will be incorporated in Section B.10 of the plant Procedures Manual by September 17, 1974.
Even though the Technical Specifications were violated, it should be noted that the potential for release of significant amounts of fission gases did not exist. Rcrueling operationc were the only oper-ations performed in the period between the installation of the valve and the performing of the containment integrited leak rate test. Refueling operations are performed with the primary system at atmospherie conditions and the reactor vessel head removed. The only postulated accidents that 8YDH 000 %* 6 WE' I
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2 Paliccdss Plant Septembtr 13, 197h involve a significant pressurization of the containment'are those postulated accidents which involve a breach of the primary system when the primary system is in a hot condition. As there was no potential for significant pressurization of the containment and even though the valve flange was not tightened properly, no potential accident can be postulated during the refueling condition which would have caused sig-nificant leakage of fission gases from the containment via the im-properly tightened flan 6e-Therefore, we believe that-this violation should be classified as a Category III violation (a procedural matter readily correctable) rather than a Category II violation. Category II violations are defined in the United States Atomic Energy Commission letter of June 5,1973 to all licensees as being violations which, if not corrected, might con-tribute to a situation involving radiation exposure to employees or the public in excess of permissible limits or the release of radioactive materials in effluents in excess of permissible limits or a threat to the environment. Because the potential for,a significant amount of leakage did not exist during refueling operations, this violation or future similar violations cannot be :ategorized as potentially involving an overexposure to employees or the public, causing release of effluents in excess of limits or causing a threat to the Edvironment.
Yours very truly,.
n RBS/mel Ralph B. Seve11 Nuclear Licensing Administrator e
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