ML20087D037

Responds to NRC 911129 Ltr Re Violations Noted in Insp Rept 50-255/91-22.Corrective Actions:Radioactive Waste Processing Outside Auxiliary Bldg Stopped Until Resolution of Concerns Raised During Insp

ML20087D037
Person / Time
Site:	Palisades
Issue date:	01/10/1992
From:	Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9201150115
Download: ML20087D037 (7)

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% = DOCKET 50-255'-L LICFNSE Of d pal.ISADES l'LANT - REPl Y TO NOTICE OF WR :V10t.AT100;'NPCl INSPECTION REPORT No. 91'022 .

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NRC Inspection Repert 91-022,' dated Noven.ber -29,1991, documented the results -

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'of a routino unannounced insp9cticn of the_ radioactive waste management, U

9 effluent. monitoring cnd transportation programs and included 'a Notice of-J 1 Violation pertaining to the performance of an inadequate 10 CFR 50.59 review >

1. .. iof the rear.tivat';on of the South Storage Building for radioactive waste ,

storage, j me '

. Based on the concerns raissd during N.RC, Inspection 91-022, we do not intend to

.use;the South Storage Building for a radioactive waste storage-area, as

@ 1 4 conveyed t6 the NRC inLour letter dated April 24,-1991,- until the concerns are-

. resolved,e Qf a

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'^' ~ip (In aftelephone conversation Letweet Jinuemin of CPCo and.BLJorgensen, Region 1

.llIJReactor Projects Section Chief, on December 23, 1991, Mr Jorgensen granted'

_ T 'an exter.slon for the replyf to;0V 91022-01 untilDJanuary 10, 1992.

sponse to this violation.

m The Attachment provides the V

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' Gerald B S1ade -

General Lnager

?CC -Administrator,; Region'III,.USNRC .

NRC Resident Inspector - Palisades

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CONSUMERS POWER COMPANY Tc the best of my knowledge, information and belief, the contents of this submittal are truthful and complete.

By -- --

David-P Hoffman, Vi ent Nuclear Operatio Sworn and subscribed to before me this S ** day ofh0 e a m 1992.

!l u M GAM-Notary Public

[ SEAL) teAnn Morse van nu'en county Michigan My commission expi,res June 6, 1994

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1 ATTACHMENT Consumers Power Company Palisades Plaat Docket 50 255 l

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REPLY TO NOTICE OF VIOLATI^N  !

NRC INSPECTIM REPORT No.91-022  ;

January 10, 1992

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4 Pages l

REPLY TO NOTICE Of VIOLATION _.

'NRC INSPECTION REPORT No.91-022

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-Violation 10 CFR 50,59(a)(1) allows licensees to' make changes to the facility as l described in the Safety Analysis Report without prior NRC approval, provided that^the change does not require a change to the Technical Specification, or

. involve an unrevfewed safety questfon.

10 CFR 50.59(a)(2) states that a proposed change shall 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.

Contrery to-the above,'on March 12, 1991, a safety analysis ~ performed for 1 changes to the Updated Final- Safety Analysis: Report (FSAR) failed to evaluate' l whether these changes involved an unreviewed safety question. The changes to '

.the FSAR involved the reactivation of the south radwaste storage butiding for  !

storage of radioactive waste. The safety-analysis failed to identify the projected contained source tera, failed to address the potential dose impact.

to'the public, failed to evaluate radioactive material release pathways and dose impact to the public, falled to evaluate the potential-for radioactive material release during normal and abnormal operating conditions and

, accidents;-and failed to evaluate the need for filtration and radiation

_-monitoring systems.

Eeasons for the Violation The original radwaste storage at Palisades;(1971) included an outdoor pad and a shielded vault at the location of the South Radwaste Area.- In 1978, an

,unFhielded building Was erected over the vault and pad. A safety review performed:as 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 scope of the. project was changed to include moving the baler -(cenpactor) 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-thisLchange to the scope of the modification. Compaction (at that time) was not considered radwaste " processing"Lin the-context of the

.FSAR., The FSAR-discussions concerning radwaste-" processing" were interpreted-

. to apply:to the' process systems for handling liquid and gaseous radwaste streams-.and not'the handling of dry active waste.

In 1979_-all shipments of' radioactive waste ware suspended when the burial sitas 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 cycle and

radioactive materials licensees to store low-level radioactive waste fur an indeterminate period of time. Therefore, the NRC issued Generic 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 chahges to the operating licensee, technical specifications, etc., were required to address an increase in radioactive waste storage capacity. 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 envisinn 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, therefore, no action was taken to re-evaluate radioactive waste storage areas at Palisades.

The South Storage Building (then referred to as the South Radwaste Building) was used for all processing and storing of dry active waste produced at Palisades from 1978 to 1989. During this period several cooling tower overflows occurred which 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 active waste processing functions performed in the South Radwaste 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 activities from the South Radwaste Building to the East Radwaste Building was considered to be similar to the relocation of these same activities which occurred in 1978 mentioned previously. All dry active wasto 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 Storage Building) was no longer used for radioactive waste processing, in November 1990, radioactive waste generators in the State of Michigan were banned from the three currently active burial sites. As a result of this ban action was taken to ensure that Palisades maintained the interim capebility to store radioactive weste until such time as we were again able to gain a: cess to the burial sites. Since it was envisioned that Palisades may be hrced 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 descr(bed in the FSAR. The safety evaluation (10CFR50.59 evaluation) specifically addressed recent criteria for storage facilities provided by the NRC in Information Notice 90-09, dated February 5, 1990, entitled " Extended Interim Storage of Low-level Radioactive Waste by Fuel Cycle and Materials Licensees." The safety evaluation made no attempt to reconstruct the original bases for use of the building in the manner described in the FSAR.

In IN 90-09, the NRC provided guidance on interim storage facilities. This information notice was referenced in the safety evaluation as a source of requirements applicable to the South Storage Building. It was planned that this building would be used for radioactive waste packaged in accordance with NRC, Department of Transportation, and burial state requirements which minimizes dose and effluent concerns. The safety evaluation preparer interpreted IN 90-09 to suggest that the most significant building requirement was for a structure in which "...the waste will be protected from the weather at all times." [1N 90-09, Attachment 1, Item 3.c.) It was also assumed that previous use of the South :itorage Building for radwaste storage and the FSAR description of the South Storage Building as a radwaste storage facility would continue to qualify the building 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 violation was inadequate understanding of the design requirements applicable to radioactive waste processing and storage facilities, and inadequate sens!tivity to the FSAR discussions pertinent to these facilitiet.

Corrective' Actions Taken and Results Achieved During Inspection 91-022, CPCo decided to stop all radioactive waste processing in areas outside the auxiliary building until the concerns raised d' ring 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 prepared for the movement and

-storage of the HIC. None of the NRC staff-involved in the discussion

-expressed any concerns.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 completion in February 1992.

2. After applicable design requirements have been 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.

3. Any hardware additions (eg, ventilation, process monitors, dose 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.

4. Existing site buildings used for radioactive material storage will also be reviewed to verify compliance with the applicable 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.

5. Training will be provided for preparers and reviewers of safety evaluations pertaining to radwaste processing and storage facilities to assure understanding and cor.sistent interpretation of requirements.

This training will consider the guidance provided by Information Notice 90-09, IE 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 March 1992.

6. The Plant Safety and Licensing Department will evaluate the Generic Letter handling process to determine if an admir,istrative process is required to ensure new requirements of Generic Letters are input into design criteria, etc. This activf.y is scheduled for completion in August 1992.

Date When full Comoliance will be Achiev.gd All radioactive waste processing activities in areas outside the Auxiliary Building have ceased at Palisades until evaluations and modification for the East Radwaste Building have been completed. Radioactive waste continues to be stored in the East Radwaste Building. No radioactive waste will be stored in the South Storage Building until the concerns identified in this violation are addressed.