ML18044A404
| ML18044A404 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/28/1979 |
| From: | Frost S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML18044A401 | List: |
| References | |
| NUDOCS 8001100316 | |
| Download: ML18044A404 (3) | |
Text
e consumers Pov:sr company General Offices: 2'1:2 West Michigan Avenue,.Jackson, Michigan 49201
- Area Code 517 788-0550 December 10, 1979 Mr James G Keppler Office of Inspection and Enforcement Region III US Nuclear Regulatory Conunission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR-20 PALISADES PLANT - IE INSPECTION REPORT 79-16 Consumers Power Company's response to the alleged discrepancies noted in IE Inspection Report 79-16 dated November 7, 1979 is as follows:
ITEM 1 - INFRACTION 10 CFR 30.41(c), "Transfer of byproduct material" requires that, before transferring licensed material, you.verify that the transferee's license authorizes receipt of the type, form, and quantity of byproduct material to be transferred.
10 CFR 30.41(d) specifies the requirements for verifying authorization.
Contrary to this requirement, on August 2, 1979, you transferred a barrel (in shipment No_. 79-025-S) containing about 35 gallons of free liquid byproduct material to the waste burial facility at Barnwell, South Carolina, a licensee not authorized to receive free liquid. Further, you violated your Radiological Control Procedure H.P. 6.16, Revision O, dated October 4, 1978, which stated in Paragraph 4.2 under "Precautions and Limitations," "No liquid to be shipped for radwaste burials."
RESPONSE
Corrective Action Taken and the Results Achieved Upon notification of the "free water" problem, a representative from Consumers Power Company was sent to the burial site to analyze a sample of the free water for chemical constituents and radiological activity.
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- Response to IE Inspect-Report 79-16 Results of the analysis were consistent with rainwater containing slight contamination due to the addition of slightly contaminated solid waste (plastic).
It should be noted that this analysis was performed by representatives from Consumers Power Company, Chem-Nuclear and the State of South Carolina.
All were in agreement with the analysis.
Due to the low activity observed in the free water, Chem-Nuclear agreed to dispose of the material in accordance with the burial site license.
Corrective Action To Avoid Further Noncompliance 2
Procedural changes havebeenimplemented to avoid future problems of this nature. Specifically, Health Physics Procedure HP 2.44 was written to provide detailed guidance to plant personnel in the proper methods of radwaste handling on site and burial ground disposal criteri~. Also provided by this procedure is the documentation of verification/inspection of radwaste containers for free water.
The completed check sheets documenting the free water inspection, the type of waste contained in the container and the radiation survey data are reviewed by the Health Physics supervisory personnel cognizant of the procedural, regulatory and license criteria for radwaste shipment and burials.
The scope of Health Physics Procedure HP 2.44 addresses compacted trash, solidified evaporator bottoms, noncompactable solid waste and resin shipments and/or burials.
A current copy of the Chem-Nuclear Barnwell site license with accompanying State and Company burial criteria are maintained on site (Palisades).
The criteria presented in this documentation is reflected in Health Physics Procedure HP 2.44 and also considered by the Health Physics supervisory personnel reviewing the final shipping forms.
Date When Full Compliance Will Be Achieved All changes to plant procedures were completed, per the immediate action letter issued by Region III dated August 10, 1979, prior to the shipment of any radioactive waste from the Palisades Plant.
Procedure HP 2.44 was issued on August 23, 1979.
ITEM 2 - INFRACTION Technical Specification 6.8.1.a requires that certain writ~en procedures, including radioactive waste handling, be established, implemented, maintained, and adhered to. Radiological Control Procedure H.P. 6.16 Revision O, dated October 4, 1978, in Paragraph 5.5.6.under "Solidification System Containers,"
requires that data from the free liquid leakage check of containers be logged.
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- Response to IE Inspection Report 79-16 Contrary to the above, Procedure H.P. 6.16 was violated, in that free liquid leakage data were not logged on any of the containers in the thirteen shipments made since the effective date of the procedure (October 4, 1978),
including those in the shipment of June 27, 1979.
RESPONSE
Corrective Action and Results Achieved The corrective action taken is described in the next section, "Corrective Action To Avoid Further Noncompliance." There is not any type of correction that can be taken to correct thirteen containers already shipped.
Corrective Action To Avoid Further Noncompliance Health Physics Procedure HP 6.16 was deleted and an expanded version of 3
HP 6.16 has been written and added to the Health Physics' procedures (HP 2~44, see Item 1).
Procedure HP 2.44 requires documented inspection of solidified evaporator bottom containers prior to shipment to insure the absence of free liquid.
The inspection is documented on Form HP 2.44-1.
The requirement for logging the total quantity of water drained has been deleted from the procedures; however, experience with the Delaware Custom Material Silicate Solidification System, presently being used at Palisades (replacing the UF System), indicated that greatly reduced quantities of liner drainings will be encountered in the future.
Therefore, an inspection of the liner (by opening the drain plug and/or the top) for free liquid will provide reasonable assurance of no free liquid.
Date When Full Compliance Will Be Achieved All changes to plant procedures were completed, per the immediate action letter issued by Region III dated August 10, 1979, prior to the shipment of any radioactive waste from the Palisades Plant.
Procedure HP 2.44 was issued on August 23, 1979.
Steven R Frost Palisades Nuclear Licensing Engineer CC JGKeppler, USNRC