ML18058A368

Updates Response to NRC Ltr Re Violations Noted in Insp Rept 50-255/91-22.Corrective Actions:Evaluation Will Be Performed to Define Applicable Design Requirements for Site Facilities Where Radioactive Matls Are Stored or Processed

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 GB Slade General Manager April 15, -1~92 Nuclear Regulatory Commission Document Control Desk*

Washington, DC .20555 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 . PDR A CMS ENERGY COMPANY.

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 .

UPDATED REPLY TO NOTICE OF VIoLATION NRC INSPECTION REPORT 91022 Vi0lat1on 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. The safety evaluation made no attempt to 11 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 .

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

. evaluation will be installed prior to beginning any radioactive material handling activities in the area. This activity is scheduled for completion in February 1992.

• Update 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 i 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*

• 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.

Update 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 Proc No 3.07 SAFETY REVIEW Attachment :

Revis~cn S Page I of 1

• • Item Identification:

1";2ff();,i.).lfr;n:; 1J" ,,_r.4\/6 No

&r1v'1 T/~y; Rev _J_ Title PS&L Log No __9_;;2_*-~_0_4_o.....Jf]~----

£115( 11-1.Jp ~u.rH SE REV

..... (!?£1/t.Mt!J.]

(ITA-E:*PAL- *'"Jl*OE,oJ

.~;;;,.~~

I Describe Issue/Change: l.e.~~CJ.lu. mtl~rle tn,hv1'1ie"r ,

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 involve a change to the facility as described in the FSAR?

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 *~

{,A/ ce..~e ~- Cf :1-o 339 ( q :l- 0 ~~'1 'Co---f~ ir..:s ~A) If a~ Safety Review guestion listed above is answered "YES", perform a written USQ valuation accord1ng to Section 5.3. . If all Safety Review questions listed above are answered,NO, written USQ Evaluation is not required. However~ this Attachment shall accompany other review materials for the item to document t at a Safety Evaluation was not required.

ikU&t Gcu..&r:~

2.-/b-9~ {)-17-lj'J._

t.. Preparea By Date Rev1ewe--:r- Date

• PALISADES NUCLEAR PLANT Proc No 3.07 UNREVIEWED SAFETY QUESTION EVALUATION Attachment 2 Revision 5 Page 1 of 1 PS&L Log No 9:2- o 4o'B Item Identification: No SECTION I Yes No

1. Will the probability of an accident previously evaluated in the FSAR be increased? v

2. Will the consequences of an accident previously evaluated in the y FSAR be increased?

3: Will the probability of malfunctions of equipment important to safety be increased? I/

4. Will the consequences of a*malfunction of equipment important to safety be increased?

./'

5. Will the possibility of an accident of a different type than any

/ previously evaluated in the FSAR be created?

6. Will the possibility of a malfunction of a different type than any ,/

previously evaluated in the FSAR be created?

7. WiH the margin o~ safety as defined by Plant Licensing Bases ,./

be reduced? A written Safety Analysis which documents.the bases for these answers shall accompa~y this form. If any of the above questions are answered Yes, an unreviewed safety question is involved and the item shall not be implemented without prior NRC concurrence. SECTION II Yes No L Should this be included in an FSAR update?

2. Is an application for amendment to the Palisades Operating License. required?

3. Is NRC approval required prior to implementation of this item?

SECTION III JP/lvJ Prepared By I 1/lt.~/tiv I Date GcuJZrr~ Reviewed By

)-/7-']')_

Date PALISADES NUCLEAR PLANT Proc No 3.07 SAFETY ANALYSIS Attachment 3 Revision 5 Page 1 of 1 Item Identification: No Rev I Title J:;/J-sr *IH.) D .s bu.TI* DESCRIPTION OF ITEM Page - - - - ia f111oe.d "" d Ha.ciubJ JUSTIFICATION C+>.,1fa1;1 el ~ 41ta.t.hmMYf .. *'1 I I I II 2/14/92 . Safety Analysis* 10CFRS0.59 Review of East and. South Radwaste Activities

• (E-PAL 91-030)

1. Event Description Michigari has been denied access to the thre~* existing burial sites. Michigan has also been expelled ~ram the Midwest Compact. The Palisades Plant will need to temporarily store radwaste until Michigan builds a disposal facility. It . is assumed Palisades will have to store radioactive waste bnsite at

• 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.

The East Radwaste Facility cqnsists of two adjacent buildings connected by a shared roll-up door. Radioactive waste (bags, .filters, wood, metal, etc.) is .transported to the _East Facility to be processed. Dewatered resin and ev9.porator concentrates are packaged to meet criteria for dry waste prior to leaving the Auxiliary Building. The Dry Active Waste (DAW) is usually transported in a covered farm wagon used exclusively for this purpose. The West building is currently used primarily for storage of packaged.metal boxes of DAW and 55--gallon druins of solidified evaporator concentrates. In the* n~ar future (~ith Michig~n currently.banned from all disposal burial sites) this btiilding ~ill house a series of cemeht rad vaults for storage of packaged resin and filter HIC's. This building also has a separate (HEPAventilated) rooin for sand

• . blasting contaminated metal or planing c_ontaminated wood.

T~e Easi building i~ primarily used £oi probeising Dry Active Waste (DAW). It is equipped with a B-400 supercompactor.for compressing DAW. This compaction unit has a self-contained HEPA ventilation unit that provides *contamination control* during processing.

• 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~

The East briilding also contains a built-in cement shielded vault system for storage of high level filters, resin.and DAW. All items placed in the vaults for storage are packaged in High Integrity Containers (HIC) to maintairi a contamination-f ree area. This vault system is sectioned into two areas, one with 24" of concrete shielding and the other with 36" *of shielding which maintains area radiation l~~els to near background levels. ,. 2/14/92 The South Radwaste building is a 40' x 80' engineered steel* building. In January 1992 the main floor of the building was elevated. 24 inches ( 18 *inches compacted sand with 6 .inches* cement cap) to prevent water intrusion from f loading, r;ooling tower overflows or excessive rainfall. This building will be used only to store DAW in metal boxes and solidified evaporator concentrate in steel drums, packaged in accordance with NRC, DOT and .burial* site requirements. These metal boxes are to be stored around the outer walls-of

• the main floor. Every box* is equipped with risers (feet) to allow containers to be .raised off the floor to . prevent inadvertent water accumulation to cause external corrosion and possible degradation of container iritegrity. A series of 5-inch cement DAW rad vaults will be placed in the center section of the building to store solidified evaporator concentrate drums.

An ~dditional building will have to be provided at the East Facility location by 1994 to handle the predicted voltime of radioactive waste. - It will be limited

• to storage only, identical to the South Building, of dry active waste in boxes.

and solidified evaporator concentrates in steel drums packaged

• 2.

in accordance with NRC~ DOT and burial ground requirements. The safety analysis calculation for direct dose in EA-E-PAL 91-030-02 contains this projected building with ~ontents of 150 DAW boxes and 150 solidified evapor:ator concentrate drums. Design Basis A. NRC Iriformation Notice No. 90-09, "Extended Interim Storage of Low Level Radioactive Waste by Fuel Cycle and Materials Licensees" ( 2/90) . B. NRC Generic Letter 81-38, "Storage of Low Level. Radioactive Wastes at Power Reactor Sites" (11/81).

c. NRC Generic Letter 85-14, "Commercial Storage at Power Reactor Sites of Low Level Radioactive Waste Not Generated by the Utility" (8/85).

D. 10 CFR 100 - Reactor Site Criteria. E. IE Circular No. 80-18, "10 CFR 50.59 Safety Evaluations for Changes to Radioactive Waste Treatment Systems" ( 8/8 0 ) .

• 2

• • F. 10 CFR.. 50 Domestic Licensing of Production and Utilization Facilities, Appendix A, General Design Criterion 60, 63, and 64 and Appendix I, -Design Bases 2/14/92 Effluents.

G. - 10 CFR 50.59 - Changes, Tests and Experiments._ H. 10 CFR 20 - Standards for Protection Against* Radiation 3 .. Analysis A. - cumulative Projection for Radioactive Waste Storage:., i'-104 T-100 DAW Evap Bottoms Resin 3 Resin Filters Year* ft 3 Boxes .J::..L.

l. l.

3 Drums ft ft 3 - ft 3 1991 5472 57 405 54 600 200 0 1992 8472 88 705 94 . 1200 600. 200* 1993 11472 119 1005 134 1800 1000 400 1994 14472 151

• 1305 174 2400. . 1400 600 1995 ' 174 72 l82 1605 214 - 3000 1800 800 1996 2_04 72 213 1905 254 3600 2200 1000 B. 1201mding Event There are no limits for w~ste storage in the existing -

Technicai Specifications. Evalua_tion of accident and direct-. dose calculations described below and attached support not having a Curie limit. The irradiated incores with a'projected 16,000 Curies greatly exceed the other source terms but have no accident effluent contribution and little direct dose to the site boundary because of -material form and adequate _storage shielding.. The bounding number for both East Facility and South Building is 1240 DAW boxes* and - 1240 solidified evaporator c6ncentrate drums based on EA~E-PAL 91-030-01 accident case 3 analysis. It is very conservative-to set a limit of 150 DAW boxes and- 150 -concentrate drums _ at each location. The buildings, including a new one at East will not physically support more than this limit and it would force a new safety analysis to be performed if the numbers are exceeded. - This safety analysis should also be reviewed before the end of 1~94 and a submittal made to the NRC if storage is required past 199~ (~-year limit from Generic Letter 81-38) .

• 3

2/14/92 C. Analysis Methodo_logy

1) Accident and abnormal effluent dose calculation Engineering Analys'is pa-ckage EA-E-PAL

• 91-030-01 is attached. The NRC GASPAR Code was used to project maximum* dose to an individual at the nearest residence.

2) Direct Dose Calculation Engineering Analysis Package _ EA-E-PAL 91-030-02 is attached. The Microshield 3 ~ 13 Code was* used for - direct dose calculations to the nearest site boundary~-

3). Ail assumptions are contained in ~the im;iividual, engineering packages.

4. Radiological ConseQJiences A. Gaseous Accident releases from radioactive waste storage are not considered credible because of material,_ packCiging *and steel and/or cement shielding. _ However, to: show-

-compliance with Generic Letter 81-38 criteria, thre*e accident cases were run as well *as direct dose calculations to the site boundary. The accident cases were less than 10% of 10CFRlOO limits and direct dose to _ the site_ boundary was less than 1 mR/yr as required by Generic Letter 81-38. B. Liquid There are no liquid effluent consequences because all - waste in' the building meets dry *radioactive material - status except for a small amount of-liquid mixed waste and sdme contaminated oil. This waste will be over-- packed with absorbent material and ip no event could the criterion per IE Circular 80-18 of.MPC at nearest water _supply be approached.

5. Design Requirements A. Container Selection/Inspection The following lists the containers utilized by Palisades for the various waste- streams:

Solidified (asphalt) evap bottoms gal drums

• DAW 4

- B-25 metal boxes 2/1.4/92 T-104 secondary resins - Steel liners Dewatered filters, primary-side - High . Integrity. resins

• Container (HIC)

Oil and mixed waste - Overpack steel.drums w1th approved absorbents These

• c*ontainers were selected based on: structural strength, the ability to* maintain container integrity during processing, packaging, storage and transportation.

They* also demonstrate minimal corrosion effects from

• exposure to internal and external environment over a long period of time. All containers are stored inside the building to protect against corrosion from external environment. These containers comply. with the requirements of 10CFR71 and 49CFR as well as burial ground criteria to prevent the need for repackaging prior to shipment. HIC lids are equipped with passive vents to allow depressurization of hydrogen, but do not permit migration of radioactive material.

• Additional *semi-portable cement rad vaults to shield filled HIC~~ will be placed in East Radwaste Building on an as-needed basis. These vaults incorporate a pop-up*

vent to allow depressurization. and a siphon. tube *.for periodic sampling. The solidified evaporator concentrate drums- will be stored in semi"'."'"portable cement storage vaults at . both South and new East buildings. These vaults will also have a siphon tube for sampiing. These vaults are designed with adequate shielding/inserts to ensure cumulativ*e offsite dose from all stored material

• is* <1 mR/year. . .

• B. Surveillance Radwaste containers and storage areas at . the

• Radwaste Buildings w~ll be inspected .quarterly for .container integrity, proper labeling and contamination levels.

Radiation monitor alarms will also be checked quarterly. Radiation ~onitors will be source checked monthly. The Radwaste Storage Buildings will b~ checked daily if the alarm system is out of service. *

• 5

2/14/92

c. Transportation and* Location The storage .areas at East and South are outside the Plant protected area but within the owner controlled area .

. Transport routes used to reach the storage areas ~re all . within the owner controlled area. The storage areas *are both fenced and locked as well as subject to periodic security patrols. D. Liquid Waste Monitoring (10CFR50. Apperydix A. Criterion . fill)_ . . All waste stored or processed will meet the criteria for dry active waste~ Any wet waste will be returned to the Auxiliary . Building on the* same shift it is found. Contaminated oil-and mixed waste are except~d from this . requirement if overpacked with absorbent material and stored at _existing East

• Buildi:ng. Because no other liquid waste will be stored at either South or East there will be no need for liquid mohitoring.

E. Monitoring Equ~pment * ( 10CF.R50 Appendix A. Criterion 63)

1) Area Monitors Both buildings at E~st. and the South building will contain an area monitor calibrated to read out in mR/hr.

Each. area monitor has* a* specific alarm setpoint, dependent upon location in the facility. These area monitors provide local alarms and also. initiate a phone alarm to the Control Room when dose rates in the area reach or exceed alarm

• setpoints. This remote alarm system ensures** that the appropriat~ safety actions a~e taken when the .

building is unoccupied. The proposed new East Building will have duplicate criteria and monitors as the Soqth Building. *

2) Air Monitoring Both Radwaste Facilities are equipped with an AMS~3 continuous_ air monitor. This monitor samples at a rate of 2 CFM, and includes a cpm readout on graph paper. This monitor has ~n adjustable visu~l and

• audible alarm, currently set at* 1 MPC unidentified beta ( 3E-9 uCi/cc). The air monitor alarm will also initiate a phone alarm to t_he Control Room to

• initiate appropriate safety actions.

6 2/14/92' F. Effluent Monitoring (10CFR50 Appendix A. Criterion 64)

1) Auxiliary Ventilation Unit/Airborne Sampler Description~ *

• The processing/sorting area at* East Radwaste Facility is equipped with a portable 2000 CFM ventilation unit with HEPA filter. The exhaust (out of the building) is monitored

• 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:

continuous sample is collected directly from the tinit exhaust. The.suction portion of this.unit: is mobile and can be positioned in any area throughout the faci~ity. Activities will- be calculated using Offsite D_ose Calculation

• Manual ( ODCM) *methodology. *

• The ventilation and sampler will be run continually when processing is occurring. Processing is defined as compacting, s'orting, drying damp towels or mops, decorining, planin~wood, saridblastirtg, or opening* packages.* , No liquid processing is performed other than* dry.ing damp materials as described above. Any liquids or wet wastes found present will be.removed to the Auxiliary Building by erid of the shift. * *

2) There will be no effluent monitoring from South Radwaste*or the projected new East Building. No proc~ssing is ~llowed in these buildings. Stored packages - are restricted to material

• packaged in accordance with NRC, DOT and buri~l- site requirements ready for transportation wh.:j.ch would

• eliminate potential effluent release pathways.

Damaged or leaking packages _found during inspections will be overpackaged or removed and any contamination cleaned up in a timely manner. G. Inventory Inventory records of waste

• types, cubic . feet, total activity, dates of storage, container radiation levels, etc. shall be.maintained.*

• . 7'

2/14/92 H. Flooding Flooding is not considered a threat to the building. The grade el~vatibn of_ the East Buildings is well above sea level and remote from Lake Mich~gan. The South area has been subject to minor flooding and heavy rain. The floor has been. raised 24 inches to be. above all past flood levels and negate flooding. The DAW boxes have a 4-inch offset to stay above incidental water.

• I. Tornado The buildings were, not designed or built to withstand th_e impact of *a tornado. Since the structures are engineered steel buildin~s, they are expected to withstand some of the impact and remain partially intact.

The roof may be lost and the material may be released through that pathway. It is unlikely the tornado could generate a large enough pressure differential to lift the covers off the vaults, or to move or cause the shielded HIC'~ to loose their material. The concentrate-drums are also_ ~tared in cement vaults. It is possible to mov~ containers, but unlikely to cause release of activity~ The DAW is in sealed stron'g tight metal boxes, normally weighing over 5000 lbs~ The density of the DAW is very high and it is unlikely that much of this ~aterial would be released to the environment. Accident case 3 released - all activity from South or new East and didn't exceed 10% of 10CFRlOO values. J. ALARA Purification filter (F-54), activated incores and other higher level material will be stored in thirty-six inch ( 36 11 ) concrete vaults in East Building. Higher level DAW, resin (not T-104) and filters will be stored in eighteen inch (18 11 ) thick semi-portable concrete vaults. The design resin liner would have a 12-inch reading of 2 0. 1 mR/hr in the 18 11 vault (Reference 1 )

• One inch (l 11) steel donut shield is available if concrete vault is not adequate. Concentrate asphalt drums will be stored in a five inch (5") concrete vault. DAW boxes will be stacked with lowe:r reading boxes on the outside to.

minimize dose outside the radwaste areas. These shielding material and methods are provided to address ALARA principles and maintain low radworker exposure .

• 8

2/14/92 K. Fire Protection Accident case 1 addressed atmospheric release of radioactive _material equivalent to the contents of a design DAW box. The values were less than Appendix I limits. Installation of an expensive fire system is not warranted for the low effluent dose potential. Fire extinguishers will be provided near the processing area of East. The South and potehtial new East buildings ~ill only have compacted DAW boxes arid asphalt drums in concrete shields and are not considered a fire potential. There will be smoke detectors. in each building which, when alarming, will also initiate a phone alarm to the

• control Room.

• L. Volume Reduction Volume reduction techniques are being used on a full time

• basis. An asphalt extruder is used to volume reduce evaporator concentrate waste. Our 400,000 lb. ram force compactor is close to state-of-the-art. Wood planing and sand blasting are used to decontaminate wood and metal.

Vendors process some trash and wood (incineration), metal

• M.

(smelting) and low level resin (regenerate) and will return unprocessable waste and residue to the site for storage. The waste returned will be packaged to meet NRC, .DOT and burial site requirements prior to storage. Seismic Event The building should resist earthquake forces per the Uniform Building Code. The accident cases releasing a resin HIC and 150 DAW boxes and solidified concentrate drums were less than Generic Letter 81-38 acceptance criteria.

6. Conclusion Safety Analysis Questions Questions 1 and 2. Radwaste accidents are not evaluated in the present FSAR, therefore - NO.

Questions 3, 4 and 6. - There is no equipment important *to safety in the waste buildings, therefore - NO. Question 5. Accidents involving storage of radioactive waste are contained in the attachments and meet acceptance criteria in design basis. Original radwaste bounded by Fuel Handling .Accident, therefore - NO. 9 2/14/92

• Question 7~ Thei:e is no margin of safety defined for radwaste storage, therefore - NO.

rhe desigIJ. bases .in Section 2. 0 have been met. Therefore; temporary storage and processing activities are not an unreviewed safety question. _An FSAR change wi-11 be submitted*

to address the new design basis and activities. 10 Reference 1 Microshield 3.13

=====

(Consumers Power company - #037)

Page. 1 File ~ef:

File RESINREF.MSH *Date: _ l _ I _

Run date: February 5, 1992 By:

Run time: 11:05 a.m. checked:

CASE: RESIN REFERENCE CASE GEOMETRY 8: Cylindrical source from.side - slab shields Distance to detector ************...**...*..** x 190.5 cm.

Source length . ........... ~ ................... . L 182.880 II Dose point height from base .*.*.......*....** y 91.440 II Sou~ce cylinder radius .**.**.**..*..........* Tl 91. 440 II Thickness of second shield *.*..*.*....*....** T2 7.620 II Thickness of third shield **..***.*..*.. ~ .**.. T3 45.720 II Microshield inserted air gap .***......... ~ .. a air 45.720 II Source Volume: 4.80384e+6 cubic centimeters MATERIAL DENSITIES (g/cc):

Material source Shield 2 *shield 3 Air gap Air .001220 .001220 Aluminum Carbon Concrete 2.350 Hydrogen Iron Lead Lithium Nickel Tin Titanium Tungsten Urania Uranium Water .6730 Zirconium 37 Curie liner

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 2. 5170e-bl-Mn-54 2.0890e+OO Ni-63 3.8010e+OO Pu-238 7.1490e-04 Pu-239 4.8610e-04 Pu-241 . 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

1. (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