ML18054B378
| ML18054B378 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/12/1990 |
| From: | De Agazio A Office of Nuclear Reactor Regulation |
| To: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| PAL-90-002, PAL-90-2, TAC-67408, NUDOCS 9001230179 | |
| Download: ML18054B378 (5) | |
Text
-.,
Docket No. 50-255 Serial No. PAL 90-002
- Mr. Kenneth W. Berry Director, Nuclear Licensing Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201
Dear Mr. Berry:
January 12, 1990
SUBJECT:
PALISADES PLANT - REQUEST TO RETAIN SOIL IN ACCORDANCE WITH 10 CFR 20.302 (TAC NO. 67408)
By letters dated November 12, 1987 and January 25, 1988, Consumers Power Company requested authorization under the provisions of 10 CFR 20.302 to dispose contaminated soil in place. The NRC staff replied with a request for addit"iona:l information which was forwarded to you on March 15, 1988.
You provided.a~
response to that request for information in letter dated June 27, 1988.
By letter dated June 27, 1988~ Consumers Power Company provided additional information in response to our request.: ~owever, in that response, CPCo expanded the original request to include the entire South Radwaste area as a contingency against future spread of contamination and to obviate th~ need for, additional requests under 10 CFR 20.302.
For the staff to complete its revjew of this request, additional specific *information is required.. This.is becau.s~ -*~*
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NRC approva 1 under 10 CFR 20. 302 is for the di sposa 1 of specif i c:a 1 iy
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identified and characterized slightly contaminated material by the applicant.* '* *; ":
- We request that yo~ provide a revised submittal describing ihe Ti~~nsed ma~~r~al for disposal and the analysis and evaluation called for under 10 CFR t0.30~.
The attached request for additional information provides additional.detail for. ;
the content of the revised submittal.
- ,:... ~
The reporting and/or recordkeeping requirements of this letter afi~tt fewe~~ ~~:
than ten respondents; ther.efore, OMB clearance under PL 96-511_;'is:.not.retjuired.
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 Docket No. 50-255 Serial No. PAL 90-002 Mr. Kenneth W. Berry Director, Nuclear Licensing Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201
Dear Mr. Berry:
January 12, 1990
SUBJECT:
PALISADES PLANT - REQUEST TO RETAIN SOIL IN ACCORDANCE WITH 10 CFR 20.302 (TAC NO. 67408}
Dy letters dated November 1?., 1987 and January 25, 1988, Consumers PO\\'ier Company requested authorization under the provisions of 10 CFR 20.302 to dispose contarHiriated soil in place. The NRC staff replied with a request for additior1al information which \\'/aS forwarded to you on March 15, 1988.
By letter dated June 27, 1988, Consumers Power Company provicle:c additional information in response to our request.
However, in that response, CPCo
~xpanded the original request to include the entire South Radwaste area as a cor;tingency against future spread of contan-oination and to obviate the need for ac!ditional reque:sts under 10 CFR 20.302.
For the staff to complete its review of this request, additional specific information is required. This is because N~C approval under 10 CFR 20.302 is for the disposal of specifically
.ider.tified and characterized slightly ccntarr:inated material by the applicant.
We request th~t you provide a revised submittal describing the licensed material for dispcsil and the analysis and evaluation called for under 10 CFR 20.302.
The attached request for ad~itional informatior1 provides additional detail for the ccntent of the revised submittal.
The reporting and/or recordkeeping requirements of this letter affect fewer than ten resporicierits; *therefore, OMB *clearance--under PL 96-51:1 is not required.
cc: See next page Sincerely,
~/~~
Albert W. De Ag~~~ject Manager Project Directorate III-1 Division of Reactor Projects - III, IV, V & Special Projects Office of Nuclear Reactor Regulation
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Mr. Kenneth W. Berry Consumers Power Company cc:
M. I. Miller, Esquire Sidley & Austin 54th Floor One First National Plaza Chicago, Illinois 60603 Mr. Thomas A. McNish, Secretary Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Regional Adm;nistrator, Region III U.S. Nuclear Regulatory ColTlllission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Jerry Sarno Township Supervisor Covert Township 36197 M-140 Highway Covert, Michigan 49043 Office of the Governor Room 1 - Capitol Building Lansing, Michigan 48913 Mr. Gerald B. Slade Plant General Manager Palisades Plant 27780 Blue Star Memorial Hwy.*
Covert, Michigan 49043 Resident Inspector c/o U.S. Nuclear Regulatory Co1T111iss1on Palisades Plant 27782 Blue Star Memorial Hwy.
Covert, Michigan 49043 Palisades Plant Nuclear Facilities and Environmental Monitoring Section Office Division of Radiological He~lth P.O. Box 30035 Lansing, Michigan 48909
v SECOND REQUEST FOR ADDITIONAL INFORMATION (RAI)
ON THE CONSUMERS POWER COMPANY PALISADES PLANT REQUEST TO RETAIN SOIL IN ACCORDANCE WITH 10 CFR 20.302 ENCLOSURE The subject request submitted by Consumers Power Company (licensee) by letter dated November 12, 1987 and supplemented by information forwarded by letter dated January 25, 1988-contained detailed information evaluating the radiation doses via the liquid pathways for very low levels of contamination presently in areas of soil near the Palisades Plant South Radwaste Building.
Detailed evaluations were also presented of potential occupational doses from this contaminated soil.
Three significant questions arose during the staff evaluation of this request:
- 1.
The inhalation pathway for doses from the contaminated soil was not addressed.
. 2.
The proposals contain no delineatiori of the specific contaminated areas covered by the disposal request.
- 3.
The licensee's Technical Specifications for radiological environmental
_7 monitoring require an LLD of 2 x 10
µCi/gm for 137Cs determinations in sediment - yet all of the measurements reported in the request.were made with equipment 5 to 10 times less sensitive for these gamma radiations.
I By letter dated June 27, 1988 the licensee submitted additional information in response to the staff's RAI of March 15, 1988.
This submittal was unacceptable in that it addressed potentially contaminated areas and hypothetical maximum contamination parameters rather than measured licensed material to be disposed of under the regulations.
It is requested that the licensee submit a complete, revised 20.302 request incorporating the dose evaluation information of the measured contamination considered in the November 12, 1987 and January 25, 1988 submissionsand updated if appropriate with dose evaluations of the inhalation pathway based on *the same measured contamination.
As part of the proposal the licensee should record exactly what areas of measured contamination are covered by the request for which disposal under 10 CFR 20.302 is proposed.
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