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| consumers | | consumers Power Kenneth W Berry Director PllWERINli Nuclear Licensing llllUllliAN'S PIUlliRESS General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-1636 August 25, 1989 Nuclear Regulatory *commission Document Control Desk Washington; DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - |
| * Power Kenneth W Berry Director PllWERINli Nuclear Licensing llllUllliAN'S PIUlliRESS General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-1636 August 25, 1989 Nuclear Regulatory *commission Document Control Desk Washington; DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
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| EXEMPTION REQUEST FROM 10CFR50 APPENDIX J PARAGRAPH III.D.2(Q)(ii) | | EXEMPTION REQUEST FROM 10CFR50 APPENDIX J PARAGRAPH III.D.2(Q)(ii) |
| FOR REDUCED-PRESSURE TESTING OF CONTAINMENT AIR LOCK (TAC NO. 74369) | | FOR REDUCED-PRESSURE TESTING OF CONTAINMENT AIR LOCK (TAC NO. 74369) |
| By letter dated June 1, 1989, the NRC issued Amendment 126 to the Palisades operating license. This amendment incorporated a reduced-pressure local leak rate test of the containment air lock door seals into the Technical Specifications for periods when containment integrity is required. The NRC Safety Evaluation for this amendment identified an issue dealing with the requirements of 10CFR50, Appendix J Paragraph III.D.2(b)(ii) which remained to be resolved. Specifically, this paragraph requires a full air lock pressure.test at the end of periods when containment integrity is not required. | | By letter dated June 1, 1989, the NRC issued Amendment 126 to the Palisades operating license. This amendment incorporated a reduced-pressure local leak rate test of the containment air lock door seals into the Technical Specifications for periods when containment integrity is required. The NRC Safety Evaluation for this amendment identified an issue dealing with the requirements of 10CFR50, Appendix J Paragraph III.D.2(b)(ii) which remained to be resolved. Specifically, this paragraph requires a full air lock pressure.test at the end of periods when containment integrity is not required. |
| To resolve this issue, Consumers Power Company requests an exemption, pursuant to l0CFR50.12, from the requirement of 10CFR50, Appendix J, Paragraph III .D. 2 (b) (ii) wh;Lqh- -requires- the containment,.air -locks- to ..be tested .at not less than the calculated design basis accident peak containment*internal pressure_(Pa) at the end of periods when containment integrity is not required. In lieu of the full air lock pressure test at Pa, a reduced-pressure t'est_ at not less tha,n 10 psig would be performed, as is_ done for periods when containment integrity is required. Justification for the exemption is enclosed as Attachment 1. | | To resolve this issue, Consumers Power Company requests an exemption, pursuant to 10CFR50.12, from the requirement of 10CFR50, Appendix J, Paragraph III .D. 2 (b) (ii) wh;Lqh- -requires- the containment,.air -locks- to ..be tested .at not less than the calculated design basis accident peak containment*internal pressure_(Pa) at the end of periods when containment integrity is not required. In lieu of the full air lock pressure test at Pa, a reduced-pressure t'est_ at not less tha,n 10 psig would be performed, as is_ done for periods when containment integrity is required. Justification for the exemption is enclosed as Attachment 1. |
| Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachments. | | Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachments. |
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| | ATTACHMENT 1 Consumers Power Company Palisades Plant Docket 50-255 EXEMPTION REQUEST FOR REDUCED-PRESSURE TESTING OF CONTAINMENT AIR LOCK AT THE END OF PERIODS WH~N CONTAINMENT INTEGRITY IS NOT REQUIRED August 25. ;* 1989 2 Pages OC0889-0176-NL04 |
| * ATTACHMENT 1 Consumers Power Company Palisades Plant Docket 50-255 EXEMPTION REQUEST FOR REDUCED-PRESSURE TESTING OF CONTAINMENT AIR LOCK AT THE END OF PERIODS WH~N CONTAINMENT INTEGRITY IS NOT REQUIRED August 25. ;* 1989 2 Pages OC0889-0176-NL04
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| | EXEMPTION REQUEST FOR REDUCED-PRESSURE TESTING OF CONTAINMENT AIR LOCK AT THE END OF PERIODS WHEN CONTAINMENT INTEGRITY IS NOT REQUIRED Paragraph III.D.2(b)(ii) of Appendix J to 10CFRSO requires that "air locks opened during periods when containment integrity is not required by the Plant Technical Specifications shall be tested at the end of such periods at not less than. Pa." Paragraph III.D.2(b)(iii) of Appendix J to 10CFR50 requires that "air locks opened during periods when containment integrity is required by the Plant Technical Specifications shall be tested within three days after |
| * EXEMPTION REQUEST FOR REDUCED-PRESSURE TESTING OF CONTAINMENT AIR LOCK AT THE END OF PERIODS WHEN CONTAINMENT INTEGRITY IS NOT REQUIRED Paragraph III.D.2(b)(ii) of Appendix J to lOCFRSO requires that "air locks opened during periods when containment integrity is not required by the Plant Technical Specifications shall be tested at the end of such periods at not less than. Pa." Paragraph III.D.2(b)(iii) of Appendix J to 10CFR50 requires that "air locks opened during periods when containment integrity is required by the Plant Technical Specifications shall be tested within three days after
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| * being opened. * ** (F)or air lock doors having testable seals, testing the seals fulfills the three-day test requirement. In the event that the testing cannot be at Pa, the test pressure shall be as stated in.the technical specification." | | * being opened. * ** (F)or air lock doors having testable seals, testing the seals fulfills the three-day test requirement. In the event that the testing cannot be at Pa, the test pressure shall be as stated in.the technical specification." |
| Palisades Plant requests an exemption from lOCFRSO*, Appendix J, Paragraph III.D.2(b)(ii) *that would ~llow a reduced-pressure between the seals test to be performed in lieu of a full air lock pressure test, at the calculated design basis accident peak containment internal pressure (Pa), at the end of periods when containment integrity is not required *by technical specification, provided.no mainte~ance 'or modification that could affect sealing capability | | Palisades Plant requests an exemption from 10CFRSO*, Appendix J, Paragraph III.D.2(b)(ii) *that would ~llow a reduced-pressure between the seals test to be performed in lieu of a full air lock pressure test, at the calculated design basis accident peak containment internal pressure (Pa), at the end of periods when containment integrity is not required *by technical specification, provided.no mainte~ance 'or modification that could affect sealing capability |
| *has been performed on an air lock.* If maintenance or modification that affects sealing capability is performed during the period,* full air lock pressure testing is conducted at the end of the period. | | *has been performed on an air lock.* If maintenance or modification that affects sealing capability is performed during the period,* full air lock pressure testing is conducted at the end of the period. |
| Attachment 2 is a letter dated August 29, 1984 to the NRC. from Consumers Power Company which provides a conservative interpretation of 10CFR50 Appendix J for containnient air lock testing under which Palisades has been conducting air lock testing. The NRC Safety Evaluation for Amendment 126 to the Palisa_des Operating License, dated June 1, 1989, acknowledged .this practice and requested Consumers Power -Company to submit an exemption *request*- | | Attachment 2 is a letter dated August 29, 1984 to the NRC. from Consumers Power Company which provides a conservative interpretation of 10CFR50 Appendix J for containnient air lock testing under which Palisades has been conducting air lock testing. The NRC Safety Evaluation for Amendment 126 to the Palisa_des Operating License, dated June 1, 1989, acknowledged .this practice and requested Consumers Power -Company to submit an exemption *request*- |
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| OC0889-0176-NL04 | | OC0889-0176-NL04 |
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| ATTACHMENT 2 Consumers Power Company Palisades Plant Docket 50-255 10CFR50 APPENDIX J INTERPRETATION LETTER DATED AUGUST 29, 1984 August 25, 1989 5 Pages L | | ATTACHMENT 2 Consumers Power Company Palisades Plant Docket 50-255 10CFR50 APPENDIX J INTERPRETATION LETTER DATED AUGUST 29, 1984 August 25, 1989 5 Pages L |
| OC0889-0176-NL04 | | OC0889-0176-NL04 |
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| Generel Offices: 1946 West Parnell Aoad, Jackson, Ml 49201 * (5171 788-0550 August 29, 1984 Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT 10CFR50 APPENDIX J INTERPRETATION CONTAINMENT AIR LOCK TESTING This interpretation of lOCFRSO Appendix J, III, D, 2. (b) (i), (ii) *and (iii) is.* | | Generel Offices: 1946 West Parnell Aoad, Jackson, Ml 49201 * (5171 788-0550 August 29, 1984 Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT 10CFR50 APPENDIX J INTERPRETATION CONTAINMENT AIR LOCK TESTING This interpretation of 10CFRSO Appendix J, III, D, 2. (b) (i), (ii) *and (iii) is.* |
| provided in response to concerns raised by the Palisades Plant staff regarding testing of the entire personnel airlock at internal pressures of not less than the peak calculated acciqent pressure (Pa). The Pa test requires approximate-ly 24 hours to conduct (includes set-up, pressurization, decay and dismantling of test equipment) whereas a between-the-seals test may be performed in approximately 4 hours. | | provided in response to concerns raised by the Palisades Plant staff regarding testing of the entire personnel airlock at internal pressures of not less than the peak calculated acciqent pressure (Pa). The Pa test requires approximate-ly 24 hours to conduct (includes set-up, pressurization, decay and dismantling of test equipment) whereas a between-the-seals test may be performed in approximately 4 hours. |
| In the past, the*Palisades Plant staff has conservatively interpreted the requirements of paragraph III, D, 2.(b)(ii) that a test of the entire air lock assembly before returning to power operations following a cold shutdown is required.*Since the Palisades Plant Technical Specifications do not require containment integrity to be-maintained during cold shutdown, this same require- | | In the past, the*Palisades Plant staff has conservatively interpreted the requirements of paragraph III, D, 2.(b)(ii) that a test of the entire air lock assembly before returning to power operations following a cold shutdown is required.*Since the Palisades Plant Technical Specifications do not require containment integrity to be-maintained during cold shutdown, this same require- |
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| OC0884-0015-NL02 | | OC0884-0015-NL02 |
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| Dire~tor, NRR 2 Palisades Plant . | | Dire~tor, NRR 2 Palisades Plant . |
| CONTAINMENT AIR LOCK TESTING August. 29, 1984 | | CONTAINMENT AIR LOCK TESTING August. 29, 1984 |
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| Thomas C Bordine Staff Licensing Engineer CC Administrator, Region III, Ul USNRC NRC Resident Inspector - Palisades Ln Attachment OC0884-0015-NL02 | | Thomas C Bordine Staff Licensing Engineer CC Administrator, Region III, Ul USNRC NRC Resident Inspector - Palisades Ln Attachment OC0884-0015-NL02 |
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| | ATTACHMENT 0 Consumers Power Company Ln Palisades Plant - Docket 50-255 10CFRSO APPENDIX J INTERPRETATION |
| ATTACHMENT 0 Consumers Power Company Ln Palisades Plant - Docket 50-255 lOCFRSO APPENDIX J INTERPRETATION | |
| .CONTAINMENT AIR LOCK TESTING | | .CONTAINMENT AIR LOCK TESTING |
| - 2 Pages OC0884-0015B-NL02 | | - 2 Pages OC0884-0015B-NL02 |
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| | * APPENDIX A CONTAINMENT AIRLOCKS Appendix J to lOCFllSO require* that reactor containment airlock.a be leak-tested at the peak calculat*d accidesit pressure (Pa) at aix-month intervala. |
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| * APPENDIX A CONTAINMENT AIRLOCKS | |
| * Appendix J to lOCFllSO require* that reactor containment airlock.a be leak-tested at the peak calculat*d accidesit pressure (Pa) at aix-month intervala.
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| Further, ahould the airlock.a be opened during such interval*, the airlock* vili be leak-teated after each opening. Appendix J call* out these apecific require-meDt* for airlocks becauae they present potentially large leakage path* which are subject to human error to ** larger degree than othe~ potentiai leakage paths. | | Further, ahould the airlock.a be opened during such interval*, the airlock* vili be leak-teated after each opening. Appendix J call* out these apecific require-meDt* for airlocks becauae they present potentially large leakage path* which are subject to human error to ** larger degree than othe~ potentiai leakage paths. |
| The *taff'a.interpretatioll of the objective* of the airlock-leak-testing requirement* are: | | The *taff'a.interpretatioll of the objective* of the airlock-leak-testing requirement* are: |
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| : 3. For thoae plant* which require the uae of a 9trongback or clamps to leak-teat the door aeal* at a preasure, Pa, a lover pressure (e.g., aanufacturer'* recommended pressure, which would not require the uae of auch clamping device*) ahould be uaed to con-duct the intermediate teata. The reaulta *of leakage teat* at the | | : 3. For thoae plant* which require the uae of a 9trongback or clamps to leak-teat the door aeal* at a preasure, Pa, a lover pressure (e.g., aanufacturer'* recommended pressure, which would not require the uae of auch clamping device*) ahould be uaed to con-duct the intermediate teata. The reaulta *of leakage teat* at the |
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| | reduced pressure must be conaervatively extrapolated to the |
| * reduced pressure must be conaervatively extrapolated to the
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| * leakage at the accident pressure, Pa, to determine accept-ability. (The extrapolation to be utilized must be submittect to the Hlt.C.) | | * leakage at the accident pressure, Pa, to determine accept-ability. (The extrapolation to be utilized must be submittect to the Hlt.C.) |
| In lieu of the intermediate testa, an acceptable alternative vuuld be the uae of a continuous monitoring syatem to achieve the objective of the "after-each-opening" test requirement. As in the case of the reduced-pre1aure inter-mediate test, it must be demonstrated that the continuoua monitoring aystem is | | In lieu of the intermediate testa, an acceptable alternative vuuld be the uae of a continuous monitoring syatem to achieve the objective of the "after-each-opening" test requirement. As in the case of the reduced-pre1aure inter-mediate test, it must be demonstrated that the continuoua monitoring aystem is |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML20210G8351999-07-29029 July 1999 Final Response to FOIA Request for Documents.Records in App a Encl & Will Be Available in PDR ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20209B2081999-06-29029 June 1999 Discusses Closure of Response to RAI Re GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity. Rvid,Version 2 Issued as Result of Review of Responses.Info Should Be Reviewed & Comments Submitted by 990901 ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML18068A5831999-05-0303 May 1999 Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432 ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20217A8191999-04-29029 April 1999 Forwards Listed Matls Related to Palisades Plant June 1999 Initial License Exam ML20206E8271999-04-28028 April 1999 Forwards Palisades Plant Annual Radiological Environ Operating Rept for 1998. There Were No Reportable Events During This Period ML20207B4661999-04-23023 April 1999 Forwards Copy of Final Exercise Rept for Biennial Radiological Emergency Preparedness Exercise Conducted on 981201 for Palisades Npp.No Deficiencies Noted.Seven New Arcas Identified ML18066A4531999-04-0707 April 1999 Forwards ITS Pages 3.1.4-2 & 3.1.4-8,revising Completion Time for Action D.1,as Requested by NRC 990406 Telcon,Per TS Change Request Submitted 980126.Change Submitted Does Not Alter Conclusions of No Signficant Hazards Considerations ML18066A4481999-04-0202 April 1999 Responds to Violations Noted in Insp Rept 50-255/98-06. Corrective Actions:Nuclear Performance Assessment Dept Has Reviewed Observations & Agrees That Field Observations by Qualified Personnel Are Important Aspect of Program ML18066A4471999-03-30030 March 1999 Confirms Completion of Util Review of Design Engineering Contractor Cable Ampacity Evaluation.Evaluation Available at Plant for NRC Review ML18066A4411999-03-30030 March 1999 Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review ML18066A4441999-03-26026 March 1999 Submits Certification of Financial Assurance for Decommissioning of Palisades Nuclear Plant.Certified Rept of Status of Consumers Energy Co Decommissioning Funding & Trust Agreement Encl as Attachments 1 & 2 ML18066A4401999-03-25025 March 1999 Forwards Revised Best Estimate Fluence Evaluation Using Industry Data, Providing Justification for Using Industry Data to Determine Best Estimate Fluence.Review of Info & SE Requested ML18066A4191999-03-23023 March 1999 Forwards 1998 Annual Radioactive Effluent Release & Disposal Rept, for Palisades Plant,Providing Summary of Quantities of Radioactive Liquid & Gaseous Effluent Releases & Solid Radioactive Waste Processed During 1998 ML18066A4231999-03-22022 March 1999 Forwards Answers to 990311 Telcon Request for Addl Clarification & Revs Re ITS Section 3.4.Markups of Previously Submitted TS Pages & Revised Pages for Section 3.4 Also Encl ML20204F2091999-03-18018 March 1999 Requests That Listed TS Change Requests (Tscrs) Be Issued with Allowance That Tscrs Be Fully Implemented within Sixty Days of Issuance.Request Will Allow Time for Completion of Final Training & Procedure Changes Associated with Amend ML18066A4121999-03-18018 March 1999 Concludes That Mod to Provide Automatic Switchover of Control Room Heating,Ventilation & Air Conditioning (CRHVAC) Sys to Emergency Mode Is Not Needed to Meet Regulatory Requirements.Mod Commitment Cancelled ML18066A4141999-03-18018 March 1999 Forwards Rev 4 to COLR, Containing Limits for Fuel Cycle 14 & Future Cycles ML20204E5861999-03-16016 March 1999 Submits Current Limits of Property Insurance Maintained at Consumers Energy Co Operating Nuclear Power Plants ML18066A4131999-03-11011 March 1999 Responds to NRC 990210 Ltr Re Violations Noted in Insp Rept 50-255/98-22.Corrective Actions:Analytical Evaluation, EA-C-PAL-98-1067-01, P-50A Case to Cover Stud Evaluation, Was Submitted to NRC on 981220 ML18068A5241999-02-12012 February 1999 Resubmits Relief Request 12,with Addl Info That Includes Specific Locations Where Relief Request Would Be Applied,Per 10CFR50.55a(g)(5)(iii) ML18068A5211999-02-11011 February 1999 Informs NRC That Implementation of Formal Industry Position on Severe Accident Mgt at Palisades Plant Was Completed on 981217 ML20203F2541999-02-10010 February 1999 Informs That Beginning 990216,DE Hills Will Be Chief of Operations Branch Which Includes Operator Licensing Function 1999-09-30
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML18068A5831999-05-0303 May 1999 Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432 ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20217A8191999-04-29029 April 1999 Forwards Listed Matls Related to Palisades Plant June 1999 Initial License Exam ML20206E8271999-04-28028 April 1999 Forwards Palisades Plant Annual Radiological Environ Operating Rept for 1998. There Were No Reportable Events During This Period ML20207B4661999-04-23023 April 1999 Forwards Copy of Final Exercise Rept for Biennial Radiological Emergency Preparedness Exercise Conducted on 981201 for Palisades Npp.No Deficiencies Noted.Seven New Arcas Identified ML18066A4531999-04-0707 April 1999 Forwards ITS Pages 3.1.4-2 & 3.1.4-8,revising Completion Time for Action D.1,as Requested by NRC 990406 Telcon,Per TS Change Request Submitted 980126.Change Submitted Does Not Alter Conclusions of No Signficant Hazards Considerations ML18066A4481999-04-0202 April 1999 Responds to Violations Noted in Insp Rept 50-255/98-06. Corrective Actions:Nuclear Performance Assessment Dept Has Reviewed Observations & Agrees That Field Observations by Qualified Personnel Are Important Aspect of Program ML18066A4471999-03-30030 March 1999 Confirms Completion of Util Review of Design Engineering Contractor Cable Ampacity Evaluation.Evaluation Available at Plant for NRC Review ML18066A4411999-03-30030 March 1999 Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review ML18066A4441999-03-26026 March 1999 Submits Certification of Financial Assurance for Decommissioning of Palisades Nuclear Plant.Certified Rept of Status of Consumers Energy Co Decommissioning Funding & Trust Agreement Encl as Attachments 1 & 2 ML18066A4401999-03-25025 March 1999 Forwards Revised Best Estimate Fluence Evaluation Using Industry Data, Providing Justification for Using Industry Data to Determine Best Estimate Fluence.Review of Info & SE Requested ML18066A4191999-03-23023 March 1999 Forwards 1998 Annual Radioactive Effluent Release & Disposal Rept, for Palisades Plant,Providing Summary of Quantities of Radioactive Liquid & Gaseous Effluent Releases & Solid Radioactive Waste Processed During 1998 ML18066A4231999-03-22022 March 1999 Forwards Answers to 990311 Telcon Request for Addl Clarification & Revs Re ITS Section 3.4.Markups of Previously Submitted TS Pages & Revised Pages for Section 3.4 Also Encl ML20204F2091999-03-18018 March 1999 Requests That Listed TS Change Requests (Tscrs) Be Issued with Allowance That Tscrs Be Fully Implemented within Sixty Days of Issuance.Request Will Allow Time for Completion of Final Training & Procedure Changes Associated with Amend ML18066A4141999-03-18018 March 1999 Forwards Rev 4 to COLR, Containing Limits for Fuel Cycle 14 & Future Cycles ML18066A4121999-03-18018 March 1999 Concludes That Mod to Provide Automatic Switchover of Control Room Heating,Ventilation & Air Conditioning (CRHVAC) Sys to Emergency Mode Is Not Needed to Meet Regulatory Requirements.Mod Commitment Cancelled ML20204E5861999-03-16016 March 1999 Submits Current Limits of Property Insurance Maintained at Consumers Energy Co Operating Nuclear Power Plants ML18066A4131999-03-11011 March 1999 Responds to NRC 990210 Ltr Re Violations Noted in Insp Rept 50-255/98-22.Corrective Actions:Analytical Evaluation, EA-C-PAL-98-1067-01, P-50A Case to Cover Stud Evaluation, Was Submitted to NRC on 981220 ML18068A5241999-02-12012 February 1999 Resubmits Relief Request 12,with Addl Info That Includes Specific Locations Where Relief Request Would Be Applied,Per 10CFR50.55a(g)(5)(iii) ML18068A5211999-02-11011 February 1999 Informs NRC That Implementation of Formal Industry Position on Severe Accident Mgt at Palisades Plant Was Completed on 981217 ML18066A4051999-02-10010 February 1999 Requests Copy of Consumers Energy (Palisades) Formal Response to RAI Dtd 990512 (USI A-46) ML18066A3921999-01-29029 January 1999 Forwards Licensee Interpretation of TS Requirements for Performance of SRs as Applied to Instrumentation Channel Calibr.Ltr Established No New Commitments ML18066A3891999-01-28028 January 1999 Submits Response to Concern Expressed in Insp Rept 50-255/98-06 Re Whether Palisades ISI Program Was Being Conducted IAW Applicable Requirements 1999-09-30
[Table view] Category:UTILITY TO NRC
MONTHYEARML18057A4811990-09-17017 September 1990 Confirms 900718 Telcon Notification Re Westinghouse Agreement to Join Utils as Equity Investor in Plant ML18057A4551990-09-0606 September 1990 Forwards Proprietary Info Re Dept of Labor Decision on Discharge of Former Employee of Util,Per NRC 900809 Request. No 10CFR50.7 Violation Occurred Since Job Performance Was Reason for Discharge.Encl Withheld (Ref 10CFR2.790(a)(6)) ML18057A4521990-09-0404 September 1990 Submits Addl Info Re Circuit & Raceway Schedule Enhancement Project,Per Insp Rept 50-255/90-10.Electrical Cable Separation & Channelization Anomalies Identified During Review of Physical Raceway Installations Will Be Evaluated IR 05000255/19900101990-09-0404 September 1990 Submits Addl Info Re Circuit & Raceway Schedule Enhancement Project,Per Insp Rept 50-255/90-10.Electrical Cable Separation & Channelization Anomalies Identified During Review of Physical Raceway Installations Will Be Evaluated ML18057A4371990-08-31031 August 1990 Forwards Analysis Concluding That Plant Reactor Beltline Matl Upper Shelf Energy Will Remain Greater than 50ft-lbs Until Yr 2032,per 900716 Commitment ML18057A4381990-08-31031 August 1990 Forwards Info Re Contamination of South Radwaste Area,Per 10CFR20.302,in Response to NRC 900112 Request.Approval Requested to Dispose of Low Level Radwaste in Place ML20059E0001990-08-29029 August 1990 Forwards Semiannual fitness-for-duty Program Performance Rept for Jan-June 1990 ML18057A4201990-08-24024 August 1990 Forwards Revised Application for Amend to License DPR-20, Changing Tech Specs Re Incore Analysis Program.Request Revised Per NRC Comments During 900709 Meeting ML18057A4021990-08-22022 August 1990 Forwards Missing Pages from Decommissioning Funding Rept, Consisting of Pages 25 & 26 of Attachment a to Exhibit E ML18057A4241990-08-21021 August 1990 Forwards Application for Amend to License DPR-20,changing Tech Spec 4.5.1 Re Statement on Integrated Leak Rate Test ML18057A4071990-08-21021 August 1990 Forwards Tech Specs Change Request to License DPR-20,to Remove Redundant Requirements & Change Basis Statements No Longer Applicable ML18057A4121990-08-21021 August 1990 Forwards Application for Amend to License DPR-20,changing Tech Specs to Revise Wording for Reactor Protective Sys Trip Setting Limits for Steam Generator Low Water Level ML18057A4181990-08-21021 August 1990 Forwards Description of Changes Being Made to Plant Site Emergency Plan & Emergency Plan Changes.Change Allows Reduction in Shift Staffing During Cold Shutdown for Stated Staff ML18057A3911990-08-17017 August 1990 Forwards Replacement Pages,To Palisades Second 10-Yr Interval Inservice Insp Program. ML18057A3851990-08-17017 August 1990 Forwards Addl Info in Support of NRC Development of SER for full-term OL for Plant,Including Date of SER Providing Provisional OL to Plant & Summary of Valid Exemptions from 10CFR Regulations,Per Telcon ML18057A3841990-08-17017 August 1990 Provides Addl Info Re Transfer of Plant Ownership to Palisades Generating Co,Per NRC 900725 Ltr ML18057A3821990-08-14014 August 1990 Requests That Bechtel-KWU Rept 128901/MJS, Full Flow Testing of Motor-Operated Valve MO-1042A, Be Withheld (Ref 10CFR2.790(b)(1)) ML18057A3721990-08-0808 August 1990 Forwards Addl Info Re Util Request for Exemption from Separation Criteria of 10CFR50,App R,Section III.G.2 Re Containment Air Room ML20055J1421990-07-26026 July 1990 Responds to Commitment Oversight Issue Resulting from Insp Rept 50-255/90-08.Commitment Mgt Seminar Training Will Be Complete Prior to 901001 ML18057A3561990-07-26026 July 1990 Forwards Certification of Financial Assurance for Decommissioning ML18057A3411990-07-18018 July 1990 Forwards Revised Proposed Tech Spec Page 6-3,now Designated as Page 6-1b,adding Section 6.3.4,now Designated as Section 6.3.5 to Remove Organization Charts,Per Generic Ltr 88-06 ML18057A3381990-07-16016 July 1990 Advises That Util Does Not Foresee Need to Rely on Section V.C of App G to Remain in Compliance W/Upper Shelf Energy (Use) Requirements Re Use of Matl in Reactor Beltline ML18057A3281990-07-13013 July 1990 Responds to Request for Addl Info Re Second 10-yr Interval Insp Program,Per 900418 Telcon.Util 900329 Response Revised to Reflect That Certain Components in Class 2 Sys Should Not Be Exempted,Per IWC-1220 of 1974 ASME Code Section XI ML18057A3191990-07-0909 July 1990 Forwards Performance Indicator Trend Graphs for Jan 1989 - May 1990 ML18057A3201990-07-0606 July 1990 Discusses Reassessment of Control Room Temp Following Station Blackout Event.Results of Analysis Indicate That Control Room Temp Will Remain Below 112 F for 4 H After Onset of Blackout ML18057A3171990-07-0303 July 1990 Provides Summary of Upgrades Made to Plant Electrical Distribution Sys,Per 870714 Loss of Offsite Power Event When Inadvertent Actuation of Water Deluge Spray Sys for 1-2 Startup Transformer Resulted in Bus to Ground Fault ML20058K3771990-07-0202 July 1990 Forwards Rev 26 to Security Plan.Rev Withheld (Ref 10CFR73.21(c)) ML18057A3111990-06-25025 June 1990 Forwards Endorsements 116 & 117 to Nelia Policy NF-179 & Endorsements 102 & 103 to Maelu Policy MF-50 ML18057A3101990-06-25025 June 1990 Responds to Generic Ltr 90-04, Request for Info on Status of Licensee Implementation of Generic Safety Issues Resolved W/Imposition of Requirements on Corrective Actions. ML18057A3031990-06-22022 June 1990 Provides Addl Info Re Environ Qualification of Instrument Circuit Associated W/Steam Generator Pressure Channel PT-0752D,per Insp Rept 50-255/90-05.Circuits Spliced Directly to Pigtail from Electrical Penetration Connector ML18057A3001990-06-21021 June 1990 Concurs W/Nrc Change in Terminology & Submits Revised Proposed Section 4.14 of Tech Specs ML18057A2771990-06-15015 June 1990 Forwards Corrected NRC Form 474 Re Simulation Facility Certification,Indicating Exceptions to Ansi/Ans 3.5 ML18057A2901990-06-13013 June 1990 Forwards Application for Amend to License DPR-20,revising Tech Spec 3.3.1.b Re Safety Injection Tank Min Level ML18057A2941990-06-12012 June 1990 Advises That Submittal of Second Interval Inservice Insp Program Delayed from 900615 to 900715,per 900418 Telcon ML18057A2711990-06-11011 June 1990 Requests Temporary Waiver of Compliance from Tech Spec 3.1.1i in Order to Maintain Plant in Hot Shutdown While Repair Made to Pressurizer Heater Power Supply.Request Based on 900608 Failure of Heater Transformer 15 ML18057A2641990-06-11011 June 1990 Provides Response to NRC Requalification Exam Rept Dtd 900410 on NRC Concerns Re Facility & Training Ctr Staffing. Adequate Staffing Will Be Maintained to Ensure Operator Requalification Program Successful ML18057A2591990-06-11011 June 1990 Forwards Palisades Simulator Certification Submittal. ML18057A2631990-06-10010 June 1990 Requests Temporary Waiver of Compliance from Tech Spec 3.1.1i to Enable Plant to Be Maintained in Hot Shutdown While Repair Made to Pressurizer Heater Power Supply.Waiver Requested for 900611-18 ML18057A2571990-06-0808 June 1990 Responds to NRC 900509 Ltr Re Violations Noted in Insp Rept 50-255/90-12.Corrective Actions:Continuing Training Program Will Be Developed for Supervisors That Will Discuss Fire Protection Program Implementation Topics ML20043D0601990-06-0404 June 1990 Forwards Rev 25 to Security Plan,Including Changes to Security Plan Drawings to Clarify Protected Area Boundary within Plant Security Bldg & Vital Area Boundaries in Other Specific Vital Areas of Plant.Rev Withheld (Ref 10CFR73.21) ML18057A2581990-06-0101 June 1990 Forwards Revised Response to Violations Noted in Insp Rept 50-255/89-26.Concurs That Tests Performed Using Instrumented Insp Technique During 1988 Refueling Outage Considered Invalid ML18057A2561990-05-31031 May 1990 Advises That No NPDES Notifications Required Nor Any Repts of Oil or Salt Occurred During Nov 1989 - Apr 1990 ML18057A2541990-05-30030 May 1990 Forwards Response to Technical Evaluation Rept EGG-NTA-8333 Which Evaluated Plant Compliance w/NUREG-0737,Item II.D.1 & Requested Addl Info Re New PORVs & Block Valves No Later than Jan 1990 ML18057A2511990-05-30030 May 1990 Forwards Final Response to Concerns Re Porv/Block Valve Mod, Per 900308 Meeting.Bechtel Technical Rept Withheld ML18057A2501990-05-29029 May 1990 Forwards Investigation Rept Re Unsatisfactory Performance Testing of Fitness for Duty Program Blind Performance Test Samples ML18057A2411990-05-24024 May 1990 Forwards Revised Application to Amend License DPR-20, Consisting of Revised Attachments 1 & 5 to 890227 Amend Request,Reflecting Transfer of Plant Ownership ML18057A2311990-05-17017 May 1990 Forwards Analysis of Reactor Pressure Vessel Fast Neutron Fluence & PTS Ref Temps for Palisades Nuclear Plant. Rept Concludes That PTS Screening Criteria Will Be Exceeded at Axial Welds in Sept 2001 as Opposed to Mar 2002 ML18054B5861990-05-0707 May 1990 Forwards Monthly Trend Graph Rept for Jan 1989 - Mar 1990 Covering Safety Status Performance Indicators for HPSI, Auxiliary Feedwater,Emergency Ac Power,Lpsi,Containment Spray & Svc Water Sys ML18054B5801990-04-30030 April 1990 Responds to Request for Addl Info on Proposed Administrative Changes to Tech Spec Section 3.0.4,per Generic Ltr 87-09. Licensee Will Implement Program to Assure Appropriate Level of Mgt Approval Required When Operating Conditions Changed ML18054B5741990-04-25025 April 1990 Requests That Correspondence Re 890227 Application for Amend to License DPR-20 to Permit Transfer of Ownership of Plant Be Sent to Listed Address 1990-09-06
[Table view] |
Text
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consumers Power Kenneth W Berry Director PllWERINli Nuclear Licensing llllUllliAN'S PIUlliRESS General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-1636 August 25, 1989 Nuclear Regulatory *commission Document Control Desk Washington; DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
EXEMPTION REQUEST FROM 10CFR50 APPENDIX J PARAGRAPH III.D.2(Q)(ii)
FOR REDUCED-PRESSURE TESTING OF CONTAINMENT AIR LOCK (TAC NO. 74369)
By letter dated June 1, 1989, the NRC issued Amendment 126 to the Palisades operating license. This amendment incorporated a reduced-pressure local leak rate test of the containment air lock door seals into the Technical Specifications for periods when containment integrity is required. The NRC Safety Evaluation for this amendment identified an issue dealing with the requirements of 10CFR50, Appendix J Paragraph III.D.2(b)(ii) which remained to be resolved. Specifically, this paragraph requires a full air lock pressure.test at the end of periods when containment integrity is not required.
To resolve this issue, Consumers Power Company requests an exemption, pursuant to 10CFR50.12, from the requirement of 10CFR50, Appendix J, Paragraph III .D. 2 (b) (ii) wh;Lqh- -requires- the containment,.air -locks- to ..be tested .at not less than the calculated design basis accident peak containment*internal pressure_(Pa) at the end of periods when containment integrity is not required. In lieu of the full air lock pressure test at Pa, a reduced-pressure t'est_ at not less tha,n 10 psig would be performed, as is_ done for periods when containment integrity is required. Justification for the exemption is enclosed as Attachment 1.
Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachments.
r ,--
7~--~:____o.c_0889-0l76-NL04 '!
8"i'0830nc:.-:H~"l::;.-:.~::-=:--~----
PDR Aiio1-~=.t ?:~0825 p 05000255 PDC
ATTACHMENT 1 Consumers Power Company Palisades Plant Docket 50-255 EXEMPTION REQUEST FOR REDUCED-PRESSURE TESTING OF CONTAINMENT AIR LOCK AT THE END OF PERIODS WH~N CONTAINMENT INTEGRITY IS NOT REQUIRED August 25. ;* 1989 2 Pages OC0889-0176-NL04
EXEMPTION REQUEST FOR REDUCED-PRESSURE TESTING OF CONTAINMENT AIR LOCK AT THE END OF PERIODS WHEN CONTAINMENT INTEGRITY IS NOT REQUIRED Paragraph III.D.2(b)(ii) of Appendix J to 10CFRSO requires that "air locks opened during periods when containment integrity is not required by the Plant Technical Specifications shall be tested at the end of such periods at not less than. Pa." Paragraph III.D.2(b)(iii) of Appendix J to 10CFR50 requires that "air locks opened during periods when containment integrity is required by the Plant Technical Specifications shall be tested within three days after
- being opened. * ** (F)or air lock doors having testable seals, testing the seals fulfills the three-day test requirement. In the event that the testing cannot be at Pa, the test pressure shall be as stated in.the technical specification."
Palisades Plant requests an exemption from 10CFRSO*, Appendix J, Paragraph III.D.2(b)(ii) *that would ~llow a reduced-pressure between the seals test to be performed in lieu of a full air lock pressure test, at the calculated design basis accident peak containment internal pressure (Pa), at the end of periods when containment integrity is not required *by technical specification, provided.no mainte~ance 'or modification that could affect sealing capability
- has been performed on an air lock.* If maintenance or modification that affects sealing capability is performed during the period,* full air lock pressure testing is conducted at the end of the period.
Attachment 2 is a letter dated August 29, 1984 to the NRC. from Consumers Power Company which provides a conservative interpretation of 10CFR50 Appendix J for containnient air lock testing under which Palisades has been conducting air lock testing. The NRC Safety Evaluation for Amendment 126 to the Palisa_des Operating License, dated June 1, 1989, acknowledged .this practice and requested Consumers Power -Company to submit an exemption *request*-
At Palisades, special circumstances_exist in that application of.the regulation in the particular circumst~nce-s is not necessary. to achieve the underlying purpose of the rule.. Testing the air lock per the attached letter
- will achieve the µnderling. purpose of Appendix J. That is, the. integrity of :
the air locks will be proven by the same methods that the integrity of the air lock is proven while the plant requires containment integrity. This method allows reduced-pressure testing provided a test of the entire air lock assembly is performed at least once every six months at Pa.
Since the integrity of the air lock is proven by a redu~ed-pres~ure between_
the seals test during periods when containment integrity is required, there is no technical reason why the integrity of the air lock*cannot be proven by the same methods during periods when containment integrity is not required. This is deemed an appropriate -level of testing since the probability of damaging the air lock such that a full pressure test would detect leakage, is the approximately the same whether the plant is in cold shutdown or power operation.
OC0889-0176-NL04
-In addition, strict c-ompliance with the regulation results in undue hardship and other costs that are significantly in excess of those contemplated when the regulation was adopted. The test at Pa requires approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to conduct (includes setup, pressurization, decay.and dismantling of test equipment) whereas reduced-pressure testing may be performed in approximately two to four hours. The additional time to perform the test at Pa is deemed to be an undue hardship and increased cost, given the fact that reduced-pressure testing verifies the capability of the seals.
OC0889-0176-NL04
ATTACHMENT 2 Consumers Power Company Palisades Plant Docket 50-255 10CFR50 APPENDIX J INTERPRETATION LETTER DATED AUGUST 29, 1984 August 25, 1989 5 Pages L
OC0889-0176-NL04
o\
~~
consumers
~ Power company*
Generel Offices: 1946 West Parnell Aoad, Jackson, Ml 49201 * (5171 788-0550 August 29, 1984 Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT 10CFR50 APPENDIX J INTERPRETATION CONTAINMENT AIR LOCK TESTING This interpretation of 10CFRSO Appendix J, III, D, 2. (b) (i), (ii) *and (iii) is.*
provided in response to concerns raised by the Palisades Plant staff regarding testing of the entire personnel airlock at internal pressures of not less than the peak calculated acciqent pressure (Pa). The Pa test requires approximate-ly 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to conduct (includes set-up, pressurization, decay and dismantling of test equipment) whereas a between-the-seals test may be performed in approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
In the past, the*Palisades Plant staff has conservatively interpreted the requirements of paragraph III, D, 2.(b)(ii) that a test of the entire air lock assembly before returning to power operations following a cold shutdown is required.*Since the Palisades Plant Technical Specifications do not require containment integrity to be-maintained during cold shutdown, this same require-
-
- ments implies that* a Pa* test must be performed any time a forced outage places the plant in a cold shutdown mode regardless of the fact ~hat - 1) containment integrity was indeed maintained throughout the duration of the outage; and, 2) a_Pa_test of .the air lock assembly is performed~very six months.
Appendix J, III, D, 2.(b)(iii) permits a between-the-seals test for air locks having te"&table seals. This test, in accordance with III, D, 2.(b)(iii) is performed a~'..the..Falisades Plant during periods of power operation (or any period where containment integrity is required) following an entry into the containment. NRC staff guidelines (reference the attachment to this letter which was supplied by letter to the Big Rock Po.int. Docket No 5.0-155, dated August 4, 1980) provide further guidance for an "intermediate test11 of the door seals whenever containment integrity is required. Consumers Power Company, having reviewed the attached Staff position interprets the inter-mediate test as also applicable during periods where containment integrity is
~ot required provided the following requirements have been satisfied:
OC0884-0015-NL02
Dire~tor, NRR 2 Palisades Plant .
CONTAINMENT AIR LOCK TESTING August. 29, 1984
- 1. A test of the entire air lock assembly is performed once every six months at Pa.
- 2. A*reduced-pressure test is performed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of every first-of-a series of openings during the interim, between the six month tests.
- 3. Containment integrity has been maintained since the last Pa test.
We believe this interpretation is consistent with NRC staff. positions and objectives of the air lock-testing requirements. Discussions with the Resident Inspector - Region III and a representative of your staff regarding this information occurred onAugust 27 thru 29, 1984. The Palisades Plant Review Committee has also reviewed this interpretation and has found it does not constitute on*unreviewed safety question. Procedures have been revised
accordingly.
Thomas C Bordine (Signed)
Thomas C Bordine Staff Licensing Engineer CC Administrator, Region III, Ul USNRC NRC Resident Inspector - Palisades Ln Attachment OC0884-0015-NL02
ATTACHMENT 0 Consumers Power Company Ln Palisades Plant - Docket 50-255 10CFRSO APPENDIX J INTERPRETATION
.CONTAINMENT AIR LOCK TESTING
- 2 Pages OC0884-0015B-NL02
1)
.v
- APPENDIX A CONTAINMENT AIRLOCKS Appendix J to lOCFllSO require* that reactor containment airlock.a be leak-tested at the peak calculat*d accidesit pressure (Pa) at aix-month intervala.
Further, ahould the airlock.a be opened during such interval*, the airlock* vili be leak-teated after each opening. Appendix J call* out these apecific require-meDt* for airlocks becauae they present potentially large leakage path* which are subject to human error to ** larger degree than othe~ potentiai leakage paths.
The *taff'a.interpretatioll of the objective* of the airlock-leak-testing requirement* are:
- 1. That the six-month test will provide an 1ntegrated leakage rate for the entire airlock aa*embly including electrical and mechani-cal penetrationa, the airlocks cyl1nder; hinge aasembliea, welded tn connection*, and o~her potential leakage patha.
- 2. That the "after-each-open1ng" test would provide a means of ensur-ing that the door *e.al* bad not been dam.aged or aeated improperly dur1ng airlock uae.
For thoae operat1ng facilitie* t~t ver*1 deaigned and constructed prior to the issuance of Appendix J, con*ideration baa been given to the alternatives to r...... the specific testing requirementm which will me£t the provisions of Appendix J.
tn Listed below are a number of guidelines which may be uaeful vhen cons.idering or Lil revising current airlock~leak*testillg*progr~.
I"'> 1.
- Ai:*siz-mc>nth interval* _the_ 91ltire_a~rlock assembly *hall- be leak-
.- testecf at _the. 'puk __ pru.Ure, Pa.. U the test presaur* vill lift.
the inner airlock door off it* seat, a *trongback or ~ther aecbani-cal device should be uaed ao that aeaningful test results can be obtailled at Pa.
- 2. Should the airlock be opened during the interval between.the *iz-month teat*., the airlock door **al* ab&ll be teated within 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />s- of every first of a *eriea of openings. Thia relaxation in the "aft"er-each-opening"*teat requirement of Appendiz J recognizes that a aignif icant amount of time i* required to conduct these intermediate teat* in relation to the frequency of.use of-the air-lock. These test* would be conducted vheilever containment integ-rity i* required.
- 3. For thoae plant* which require the uae of a 9trongback or clamps to leak-teat the door aeal* at a preasure, Pa, a lover pressure (e.g., aanufacturer'* recommended pressure, which would not require the uae of auch clamping device*) ahould be uaed to con-duct the intermediate teata. The reaulta *of leakage teat* at the
reduced pressure must be conaervatively extrapolated to the
- leakage at the accident pressure, Pa, to determine accept-ability. (The extrapolation to be utilized must be submittect to the Hlt.C.)
In lieu of the intermediate testa, an acceptable alternative vuuld be the uae of a continuous monitoring syatem to achieve the objective of the "after-each-opening" test requirement. As in the case of the reduced-pre1aure inter-mediate test, it must be demonstrated that the continuoua monitoring aystem is
.uff iciently aensitive to detect unacceptable leakage rate* and that the accept-able leakage-rate limits will be baaed upon a conservative extrapolation to the limiting leakage rate experienced under accident condition* (e.g., at a presaure of Pa).
N L/)
A-2