ML18058A368
| ML18058A368 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/15/1992 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9204270088 | |
| Download: ML18058A368 (24) | |
Text
- ..
PaUsades Nuclear Plant:
27780 Blue Star Memorial Highway; Covert,' Ml 49043 April 15, -1~92 Nuclear Regulatory Commission Document Control Desk*
Washington, DC.20555 GB Slade General Manager DOCKET 50-255 - LICENSE DPR PALISADES PLANT - UPDATED REPLY TO NOTICE OF
.VIOLATIQN; NRC INSPECTION REPORT 91022 In response to NRC Inspection Report 92008, an update of our January 10, i992 reply to a Notice of Violation (NOV) (91022-01) is att~thed. This update addresses four additional examples of inadequate 10 GFR 50.59 evaluations of the Palisades radio~ctive waste processing facilities~ In addition, change~
. to corrective actions addressing the causes of the radioactive material shipment incident an~ emergency instruction problems are discussed below.
The four example~ of failing to perform 10 CFR 50.59 evaluations are for the following activities identified in Section 4 of IR 92008:
- a.
The relocation of.solid radioactive waste pro~essing from the Auxiliary Building to the South Radwaste (SRW) Building in 1978.
- b.
The temporary storage of radioactive waste in the East Radwa~te (ERW)
Building. Temporary storage of radioactive waste commenced in this facility in 1980 and continues to th~ present.
- c.
The modification and expansion of the ERW. building in 1988.
- d.
The relocation of solid radioactive waste processing from the SRW building to the ERW building in 1988.
Violation 91022-01 perta-ined solely to the.recommissioning of the South Radwaste Building, however, our corrective actions addressed not only the
. South Radwaste Building but also the East Radwaste Building.
Our corrective action items 1, 3, 4, 5, and 6 in our reply to the NOV applied to all site facilities in which radioactive materials are stored or processed.
In addition to the attached updated reply to the NOV, *the safety evaluation whiGh addresses the four examples cited above, is also attached.
9204270088 920415 PDR ADOCK 05000255 G
2 Changes to the corrective actions discussed in ~our March20, 1992 insp~ction report {IR 92008), Section 3.d, haye*been determined to be necessary. These*
corrective actions address the causes of the radioactive material shipment and emergency instruction problems and were discussed at the time of th.e*.
investigation.
Based on further evaluation of the ~hipping incident, we are changing corrective actions 3, 4 and 5 identified in the inspection report.
The Shift Supervisor will now be used as the emergency contact.
Thi~ position is continually filled on a 24-hours per day, 7-days per week basis. The Shift Supervisors will {a) receive Emergency Response Notification training, {b) have a copy of required emergency response actions for a specific shipment and.
{c) have a call list of knowledgeable individuals who can ans~er questions ort each shipment. These actions.will ensure compliance with the ~equirements of 49 CFR 172.604(a). Since the Shift Supervisor will assume the em~~gency
- contact duties, it will no longer be necessary for a pager to be used nor will the switchboard operator instructions be revised as noted in the.irtspectiqn report.
Updates. to the corrective actions contained in the attachment are marked by change bars in the right column.
- ,//~_,k __
- {e~)Jc;¥ Slade
'General Manager.
CC Adfuinistrator, Region 111, USNRC NRC Resident Inspector - Palisades
ATTACHMENT 1 Consumers Power Company Palisades Plant Docket 50-255*
UPDATED REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPO~T 91022.*
- April 15, 1992 5 Pages.
Vi0lat1on UPDATED REPLY TO NOTICE OF VIoLATION NRC INSPECTION REPORT 91022 JO CFR 50.59(a}(l} allows licensees to make changes to the facility as
- described in the ~afety Analysis Report* without-prior NRG approval, provided that the change does not require a charige to the Technical Specification, or involve an unreviewed safety question.
JO CFR 50.59(a}(2f states that a proposeq change sha71 be deemed to involve an unreviewed safety question if the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased~
Contrary to the above, on March 12, 1991, a safety analysis performed for changes to the Updated Final Safety Analysis Report (FSAR) failed tO evaluate whether these changes involved an*unreviewed safety question.
The changes to
- the FSAR involved the reactivation of the south radwaste storage building for storage of radioactive waste.
The safety analysis failed to identify the proje~ted contained source term, failed to address the potential dose impact to the public, failed to evaluate radioactive material release pathways and dose impact to the public, failed to evaluate the potential for radioactive
- inaterial releaseduring normal and abnormal operating conditions and accidents; and failed to evaluate the need for filtration and radiation monitoring systems.
Reasons for the Violation The original ~adwaste storage at Palisades (1971) included an outdoor pad and a shtelded vault at the location of the South Radwaste Area.
In 1978, an unshielded building was erected over the vault.and pad. A safety review perfo~med a~ part of the modification package for erecting the building determined that a safety analysis was not necessary.
The basis for this determination was that an unreviewed safety question did not exist for erecting a building over an outdoor storage pad.
During the 1978 construction of the building, the sc_ope of the project was changed to* include moving the baler (compactor) from the Auxiliary Building to the new storage building. A safety review (or revision to the safety review for the building) was not performed for this change to the scope of the modification. Compaction (at that time) was not considered radwaste "processing" in the context of the FSAR.
The FSAR discussions concerning radwaste "processing" were interpreted to apply to the process system~ for handling liquid arid gaseous radwaste
- streams and not the handling of dry active waste.
In 1979 all shipments of radioactive waste were suspended when the burial sites were closed. Shipments were again resumed in early 1980 when the burial sites were again re-opened.
However, the NRC recognized that radioactive waste shipping could at any time be interrupted and force fuel cycl~ and
radioactive fuaterials licensees to store low-level radioactive waste for an
-indeterminate p~riod of time. Therefore, the NRC issued Generi_c Letter 81-38 entitled* "Storage of Low-Level Radioactive Waste at Power Reactor Sites." - The generic letter did not require a response_, but tasked the licensee with determining if changes to the operating licensee, technical specifications,
~etc;~ were required to address an inc~ease in radioactive waste storage
- i cap<:::.. ity. -The generic letter discussed the steps to be taken by the licensee if increased storage capacity was deemed necessary as well as the reviews and approvals required.
However, since shipping capability had_been restored, Palisades did not envision any need _to increase its radioactive waste storage capacity and no further.action was taken.
Furthermore, GL-81-38 was not _
viewed as containing design criteria against which 'existing radioactive waste
- storage capacity (buildings) were required to be evaluated~ ther~fore, no actio~ was taken to re-evaluate radioactive waste storage areas.at Palisades.
The South Storage Building (then referred to a~ t~e South Radwaste Building) was used for all processing and storing of dry active waste produced-at Palisades from 1978 to 1989.
During this peri~d several cooling tower overflows occurred whi~h resulted in flooding this building and spreading contamination from the processing area to the surrounding soil. This spread of contamination necessitated implementation of actions to prevent future flooding and resulted in NRC Open Items 85019-01 and 89025-01.
In 1988 it was decided to relocate the dry activewaste processing functions performed in the South Radwa~te Building-to a new addition at the East Radwaste Building to -
- prevent the spread of contamination in the event of future cooling tower overflows.
The transfer of these.actiiities from the_South Radwaste Buildiri~
to the East Ridwaste Building was considered to be sfmilar to the relocation of these same.activi_ties which occurred in 1978 mentioned previously._ All dry active w~ste packaging equipment was relocated to the East Radwaste Building and the South.Radwaste Building was decontaminated~* The South Radwaste Building (then re-named the South Sto~age Building) was no longer used for radioactive ~aste processing.
In November 1990, radioactive waste generators in the State of Michigan were ban~ed from the three currently active burial sites. As a result of this ban a*ct ion was taken to ensure that Pali sades maintained the interim capability to store radioactive waste until such time as we were again-able to gain access to the burial sites. Since it was envisioned that Palisades may be forced to store low level radioactive waste for an indeterminate period of time, a decision *was made to reactivate the South Storage Building for use as a dry active waste (DAW) storage area.
When use of the South Storage Building for DAW storage was evaluated, a safety analysis was performed to address previous NRC concerns on contamination of soil in the area, even though the South Storage Building was being returned to its original (radioactive waste storage) use as described in the FSAR.
The safety evaluation (10CFR50.59 evaluation) speci fi ca lly addressed recent criteria for storage facilities*
provided by the NRC in Information Notice 90-09, dated February 5, 1990, -
entitled 11 Extended Interim Storage of Low-Level Radioactive Waste by Fuel Cycle and Materials Licens~es.
11 The safety evaluation made no attempt to reconstruct the original bases for use of the building in the manner described in* the f SAR.
In IN 90-09i the.NRC provided guidante on interim storage facilities.
Thi~
information notice was referenced in the safety evaluation. as a source of requirements applicable to.the South Storage B~ildi~g. It ~as planned that this building w6uld *be used for radioactive waste packaged in accordance wit~
NRC; Department of Transportation, and burial state requirements which minimizes do~e and effluent concerns.
The safety evaluation ~reparer
- inferpreterl IN 90-09 to su~gest that the most significant building *requirement was for a structure in which "... the waste will be protected from the weather*
at all times."
[IN 90-09, Attachment 1, Item 3.c.] It was also assumed that previous use of the South Storage Building for.radwaste storage and the.FSAR de~cription of the S9uth Storage Buildi~g as a radwaste storage facility would contim.ie to qualify the bui.lding as*a radwaste storage facility.. It was again not recognized that Generic Letter 81-38 had backfit additional requirements to be considered.
. Since the time the safety evaluation for the reactivation of the South*Storage Building was approved, no radioactive waste has been stored in the building.
The root cause of the viol.ation ~as itiadequate understanding of the design.
requirements applicable to radioactive waste processing and storage facilities,. and inadequate sensitivity to the FSAR.discussions pertinent to these facilities.
Corrective Actions Taken and Results Achieved During Inspection 91-022, CPCo decided to stop all *radioactive waste processing in areas outsfae the auxiliary bu*icl ding until. the concerns raised.
during the inspection were addressed.
One exception to this position, which***
was discussed with the NRC Inspector, the NRC Senior Resident Inspector and the Region III Chief of Radiological Controls and Emergency Preparedness
- Section prior to the activity taking place, was the movement of a de-watered resin high integrity cask (HIC) from the auxiliary building to the East Radwaste Building. A safety evaluation was ~re~~red for the movement and storage of the HIC.
None of the NRC staff involved in the discussion.
expressed any concerris with the movement of the HIC.
In mid-December 1991 the HIC was moved without incident.
Corrective Action to Avoid Future Non-Compliance
- 1.
An evaluation will be performed to define all applicable* design requirements for site facilities in which radioactive materials are stored or processed. This activity is scheduled for completiori in Febru~ry 1992.
Opdate The evaluation 4escribed above was completed and included en~ineering analyses for accident and direct doses from the radioactive waste storage buildings.
\\.
i
- 2.
After applicable design requirements have be_en defined, the safety evaluation for use of the South Storage Building will be rewritten to address all relevant licensing-bases.. This activity is scheduled for completion in February_ 1992.
- Update.
A Safety Evaluation (10 CFR 50.59 evaluation) has been compl~ted addressing the design criteria as applied. to 40 CFR 90, 10 CFR 20, 10 CFR 50 - Appendices A and I, and 10 CFR 100 for the radioactive waste processing activities at the East.Radwaste (ERW) complex and for the propose~* reuse of the South Radwaste
~Building (SRW).
3.. Any hardware additions (eg. ventilation, process monitors, dos*e rate monitors, fire extinguishers, etc.) to the radioactive material storage and processing areas which result from the new safety Update
. evaluation will be installed prior to beginning any radioactive material handling activities in the area. This activity is scheduled for completion in February 1992.
The ventilation system and the associated iampling s~stem have been installed in the radioactive ~aste prbcessing area of the East Radwaste Building.. An air_monitor for the East Radwaste Building and area-type radiation monitors have been obtained for the East Radwaste Building and the South Radwaste Building. Since ERW and SRW are not occupied 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day *and are not part of from the main plant work areas, an automatic telephone dialing system will be installed to operate upon activati~n of either the fire alarms -0r the area radiation alarms.
The auto-dialer alarm system for the high radiation monitor alarms.. and fire alarm is scheduled for i~stallation in April 1~92~
.4.
Existing site buildings used for radioactive material storage will also be reviewed to verify compliance with the appli~able design criteria. If the FSAR description of those facilities is found to be*
in error, corrections will be submitted.
This activity is scheduled for completion in May 1992.
Update The d~sign ~riteria for existing site buildings used for radioactive waste proces~ing and storage, and buildings used for radioactive material storage have been reviewed.
A draf~ of the proposed FSAR wording changes for the
- radwaste processing and storage activities has been developed and is currently being reviewed.
Proposed FSAR wording changes pertaining to the radioactive material storage issue is being developed.
The scheduled completion date.for this activity is still May 1992.
The changes to the FSAR will be submitted as part of the regular FSAR revision process in accordance with 10 CFR 50.71 which is schedul~d for the end of 1992.
- 5.
Training will be provided for preparers and reviewers.of safety evaluations pertaining to radwaste processing and storage facilities to assure understanding and consistent interpretation of requirements.
This training will *consider the guidance provided by Information*
Update
- Notice 90-09, I.E Circular 80-18, and Generic Letters 81-38 and 85-14, as well as the information in the FSAR.
This activity is scheduled for completion.in Aarch 1992.
Because.of the 1992 refuel i rig outage, sufficient time.was not available to..
dev~lop the required traini~g. Furthermbre, the individuals scheduled for the training were ~ot available because of. their outage work schedules. *The*
scheduled completion date for this activity is now May 1992.
The extended completion date was deemed acceptable since no new modificati.ons to the radioactive waste storage buildings, other than those requ*i red as *a result of
- this inspection report, were planned for the near future.
- 6.
The Plant Safety and Licensing Department will evaluate the Generic*
.Letter handling process to determine if an administrative process is required to ensure new requirements of Generic Letters are input into
. design criteria, etc; This activity is scheduled for completion in
-August '1992.
Update The scheduled completion date for this activity is unchanged.
Date When Full Compliance wi11 be Achieved AlJ radfoactive waste processi.ng activities in areas outside the Auxiliary Building have ceased at Palisades until evaluations and modifications for the
- East Radwaste Building have been completed.
Radioactive waste continues to be stored in the East Radwaste Building.
No radioactive waste will be store.d in th~*south Storage Building until th~ concerns identified in.this. violation are addressed.
Update.
Rad~aste processing activities have. res~med in the ERW building.
Until th~
a~to-dialer system for the radiation monitors and the fire detectors is fully operational in the ERW building, daily tours and radiation surveys of the building will be performed.
Once the auto-dialer system is fully functional, the daily tours and radiation surveys will be suspended.
The status of the SRW btiilding remains unchanged.
N6 radioactive waste is stored in the building and no radwaste processing activities ~ake place in the building. These ~onditions will exist until the modifications, which are required tb bring the building into compliance with applicable design criteria, are completed.
ATTACHMENT 2 Consumers Power Company Palisades Plant Docket 50-255 10CFR50.59 REVIEW OF EAST AND SOUTH RADWASTE ACTIVITIES April 15, 1992 15 Pages
_j
PALISADES NUCLEAR PLANT SAFETY REVIEW Proc No 3.07 Attachment :
Revis~cn S Page I of 1 PS&L Log No __ 9_;;2_* -~ _0_4_o.....Jf]~----
_J_
£115( 11-1.Jp
~u.rH SE REV Item Identification:
No Rev Title 1";2ff();,i.).lfr;n:; 1J",,_r.4\\/6
&r1v'1 T/~y;
(!?£1/t.Mt!J.]
(ITA-E:*PAL- *'"Jl*OE,oJ l.e.~~CJ.lu.
mtl~rle
.~;;;,.~~ tn,hv1'1ie"r,
I Describe Issue/Change:
Reason for Issue/Change:
t4t,o,~I~
-,,.. c/_e.;u-( 6..?J..
t ;, Ef. /f'f!..
- 1.
Does the item involve a change to procedures as described in Yes No the FSAR?
FSAR Sections affected N.,."'ll.IL FSAR Sections reviewed 5
II I Z..
v
- 2.
Does the item in the FSAR?
involve a change to the facility as described FSAR Sections affected
.£1.1. (/.-/
(
7'2fi/e. /1-/<.
~
FSAR Sections reviewed K
II IZ.
- 3.
Does the item involve a test or experiment not described in the FSAR?
FSAR Sections affected FSAR Sections r~viewed
.f' ", z,,.
/
- 4.
Should the Technical Specifications or any of their Bases be changed in contunction with this item?
TS Sections af ected
,.;-~
/
TS Sections reviewed
~ 1-Justify No Answers below if logic is not obvious:
N~ r.:<. J l.U-.:t 1./..,_
-; -'-c *
~
- ikU&t t..
- 2.-/b-9~
- 1. Will the probability of an accident previously evaluated in the FSAR be increased?
- 2.
- 4.
- 5.
- 6.
- 7.
- 2. Is an application for amendment to the Palisades Operating License. required?
- 3. Is NRC approval required prior to implementation of this item?
- )-/7-']')_
- IH.) D.s bu.TI*
- (E-PAL 91-030)
- 1.
- least through
- 1996.
- It is proposed to use existing buildings at East and South locations a~ well as a new build.ing at East for the. storage of radioactive waste.
- . blasting contaminated metal or planing c_ontaminated wood.
- The control panel of the B-400 has an exhaust system low-flow indicator and.an exhaust system filter
- high differential indicator. These provide alarms to the riser that exhaust airflow is inadequ~te or that system pre-filter or HEPA filters should be changed~
- 2.
- the main floor.
- to storage only, identical to the South Building, of dry active waste in boxes.
- c.
- l. l.
- 1305 174 2400.. 1400 600
- 1)
- 2)
- 91-030-01 is attached.
- 4.
- However, to: show-
- 5.
- c*ontainers were selected based on:
- exposure to internal and external environment over a long period of time.
- is* <1 mR/year.
- Radwaste Buildings w~ll be inspected. quarterly for.container integrity, proper labeling and contamination levels.
- c.
- Buildi:ng.
- 1)
- 2)
- setpoints.
- 1)
- The processing/sorting area at* East Radwaste Facility is equipped with a portable 2000 CFM ventilation unit with HEPA filter.
- with a
- continuous collection system *. This system consists
- of a flow meter, vacuum pump and particulate filter sampler.* When this.ventilation unit is operated a:
- Manual
- methodology. *
- The ventilation and sampler will be run continually when processing is occurring.
- 2)
- packaged in accordance with
- NRC, DOT and buri~l-site requirements ready for transportation wh.:j.ch would
- eliminate potential effluent release pathways.
- types, cubic. feet, total activity, dates of storage, container radiation levels, etc. shall be.maintained.*
- I.
- One inch
- control Room.
- basis.
- 6.
- Question 7~ Thei:e is no margin of safety defined for radwaste storage, therefore -
- rhe desigIJ. bases.in Section 2. 0 have been met.
=====
(Consumers Power company -
- 037)
File ~ef:
Page.
File Run date:
RESINREF.MSH February 5, 1992 11:05 a.m.
- Date: _l_I_
By:
Run time:
checked:
CASE: RESIN REFERENCE CASE GEOMETRY 8: Cylindrical source from.side - slab shields Distance to detector ************...**...*..**
Source length............ ~....................
Dose point height from base.*.*.......*....**
Sou~ce cylinder radius.**.**.**..*..........*
Thickness of second shield *.*..*.*....*....**
Thickness of third shield **..***.*..*.. ~.**..
Microshield inserted air gap.***......... ~.. a x
L y
Tl T2 T3 air 190.5 182.880 91.440
- 91. 440 7.620 45.720 45.720 Source Volume: 4.80384e+6 cubic centimeters Material Air Aluminum Carbon Concrete Hydrogen Iron Lead Lithium Nickel Tin Titanium Tungsten Urania Uranium Water Zirconium 37 Curie liner MATERIAL DENSITIES (g/cc):
source Shield 2
- shield 3 Air gap
.001220
.001220 2.350
.6730 cm.
II II II II II II I
Page 2 File: RESINREF.MSH CASE: RESIN REFERENCE CASE BUILDUP FACTOR: based on GP method.
Using the characteristics *of the materials in shield 1.
- INTEGRATION PARAMETERS:
Number of lateral angle segments (Ntheta).....
11 Number of azimuthal angle segments (Npsi) *****
11 Number of radial segmen_ts (Nradius) * * * * * * * * * *
- 11 SOURCE NUCLIDES:
Nuclide Curies Nuclide Curies Nuclide Curies Aril-241 4.7220e-04 Ba-137m 1.4300e+Ol C-14 4.6330e-02 Cm-244 1.4300e-04 Co-58 4.4080e+OO Co-60 5.9370e+OO Cs-134 3.9110e+OO Cs-137 1~4300e+01 Fe-55 1.7210e+OO H-3 2.8320e-Ol I.-129 7.8640e-04 I-131
8.0060e-02 Sr-90 2.7160e-Ol Tc-99 3.7170e-02 Xe-131m 1.0070e-03 RESULTS:
Group Energy Activity Dose point flux Dose rate (MeV)
(photons/sec)
MeV/(sq cm)/sec (mr/hr) 1 1.3379 2.249e+11 2.394e+03 4.318e+OO 2
1.1786 2.237e+ll 1.547e+03 2.876e+OO 3
.8062 3.769e+ll 7.815e+02 1.570e+OO 4
.6498 6.182.e+ll 5.850e+02 1.211e+oo 5
.5323 8.530e+10 4.076e+Ol 8.368e-02 6
.3672 7~559e+09 9.184e-Ol 1.889e-03 7
.2919 6.084e+08 3.131e-02 6.267e-05 8
.2734 5.123e+07 1.911e-03 3.790e-06 9
.1792 2.539e+07 1.40le~o4 2.517e-07 10
.1172 8.558e+03 2.618e-12 4.132e-15 11 12 13 14 15 16 17 18 19 20 TOTALS:
- 1. 537e+12 5.349e+03 1.007e+Ol EA-E-PAL 91-030*01 design value is double this calculation 2x=2.0le+Ol mr/h:
TPN