ML20041A109

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Forwards Addl Comments to Address Conclusions VI.3 & VI-7 in NRC 810609 Draft Evaluation of SEP Topic VI-4,containment Isolation Sys.Info on Mods on Some of Penetrations Also Submitted
ML20041A109
Person / Time
Site: Palisades 
Issue date: 02/15/1982
From: Vincent R
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To: Crutchfield D
Office of Nuclear Reactor Regulation
References
TASK-06-04, TASK-6-4, TASK-RR NUDOCS 8202190108
Download: ML20041A109 (8)


Text

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l COnSum8f8 Power Company General Offices: 1946 West Pernell Road, Jackson, MI 49201 * (517) 788-0550 g

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2 FEB181982* P Dennis M Crutchfield, Chief g g.44 mu m 'O 3

Operation Reactor Branch No 5

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Huclear Reactor Regulation g

US Nuclear Regulatory Co==ission N

Washington, DC 20555 mi DOCKET 50-255 - LICENSE DPR PALISADES PLANT - SEP TOPIC VI-4, COUTAIRMENT ISOLATION SYSTEMS By letter dated June 9,1981, the NRC issued a draft evaluation of SEP Topic VI-4 for the Palisades Plant. Since that time, Consumers Power Company has addressed various aspects of this topic in letters dated August 10, 1981 and January 4,1982 and several discussions have been held with the NRC. The issues have now been clarified and refined to the point where the staff's concerns can be addressed in more specific detail. Therefore, the attached additional coc=ents are provided to more fully address conclusions VI.3 and VI.T in the June 9,1981 letter, and to provide information on modifications recently completed on some of the penetration.

We trust that this information will assist in the resolution of the remaining concerns.

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Robert A Vincent Staff Licensing Engineer CC Administrator, Region III, USHRC URC Resident Inspector - Palisades ATTACHMENT - 7 Pages bo$

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8202190108 820215 PDR ADOCK 05000255 P

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PALISADES PLANT Additional Comments on NRC Evaluation of SEP TOPIC VI-4 1.

As a general comment, the use of threaded caps is allowe,d on lines which. penetrate containment.

This was previously stated-in CPCo-

. letter dated August 10, 1981.

Specific reference is made to the 1980 edition of the ASME B&PV Code,Section III, Art. HE-3367 in

. addition to the design requirements for Class 2 piping contained in earlier code editions.

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.2.

Penetration 13 - This service water line is continuously pressurized during operating and under accident conditions to a pressure greater than containment design pressure.

The service water system is defined as an essential system and is seismically qualified inside containment.

Use~ of branch line caps in this system, and particularly the question of welded vs threaded caps is imnaterial since this portion of the-system is effectively being pressure tested on a continuous basis.

3 Penetration 17 and 17a - Attached is a sketch showing the configuration of these penetrations following recent plant modifications.

Previous NRC concerns are no longer applicable.

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Penetration 21 and 21a - Attached is a sketch showing the configuration of these penetrations following recent plant modifications.

Previous NRC concerns are no longer applicable.

5 Penetration 25 - The capped line is a 1" line.

The cap is tested-during Integrated Leak Rate Tests under Appendix J and Palisades Technical Specification h.5.1.

6.

1+4etration 27 - The cap is the third isolation barrier.

This

,enetration up to and including the blank flange is tested during Local Leak Rate Tests under Appendix J and Palisades Technical Specification h.5 2.

7 Penetration 28 - Attached is a sketch showing the configuration of this penetration following recent plant modifications.

Previous NRC concernsLare no longer applicable.

8.

Penetration 29 - The cap on this penetration is welded.

9 Penetrations 38 and 39 - The caps at these penetrations are on 1" lines. These are tested during Integrated Leak Rate Tests under Appendix J and Palisades Technical Specification 4.5 1.

10.

Penetration 48 - Attached is a sketch showing the configuration of this penetration following recent plant modifications.

Previous URC concerns are no longer applicable.

+

4 2

Palisades Plant Additional-Comments on NRC Evaluation of'SEP Topic VI-k February 15, 1982

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11.

Penetration T3 - This penetration was recently modified to route a

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new auxiliary feedwater supply line into containment. 'Ihe previous cap / blank flange configuration no longer exists. Previous URC concerns are therefore no longer applicable.

12.

Penetration 18 - The blank flanges on this penetration are tested l

during Local. Leak Rate Tests under Appendix J and Palisades Technical Specification 4.5 2.

13 Penetration 19.- The personnel air lock has several small-capped lines.

In no case however, is a single cap the' only isolation barrier.

between the interior and exterior of containment.

These caps and the threaded connections in the pressurization line through the outer air lock wall are all routinely pressure tested during the Local Leak Rate Tests performed under Appendix J and Palisades Technical Specification 4 5 2.

14.

Penetration 50 - The emergency air lock has several small capped lines.

In no case, however, is a single cap the only isolation barrier between the interior and exterior of containment.

These caps are all routinely pressure tested during the local leak rate

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tests performed under Appendix J and Palisades Technical Specification 4.5 2.

15 Penetration 51 - This 1/4" line provides access to the annulus between the double seals on the equipment hatch.

These seals are tested after each opening of the equipment hatch.during Local Leak Rate Tests under Appendix J and Palisades Technical Specification 4.5 2.

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