IR 05000155/1998003

Insp Rept 50-155/98-03 on 980407-0527.Violation Noted.Major Areas Inspected:Licensee Mgt & Control,Decommissioning Support Activities,Spent Fuel Safety & Radiological Safety

ML20249B308
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	06/16/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20249B305	List: IR 05000155/1998003 ML20249B304
References
50-155-98-03, 50-155-98-3, NUDOCS 9806220304
Download: ML20249B308 (16)

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U.S. NUCLEAR REGULATORY COMMISSION REGION 111 j Docket No: 50-155  :

License No: DPR-6 Report No: 50-155/98003(DNMS)

l Licensee: Consumers Energy Company l Facility: Big Rock Point Nuclear Power Plant Location: 10269 U.S. 31 North Charlevoix, MI 49720 Dates: April 7 - May 27,1998 Inspectors: R. J. Leemon, Senior Resident hspector P. W. Harris, License Project Manager D. W.' Nelson, Radiation Specialist Approved By: Bruce L. Jorgensen, Chief Decommissioning Branch Division of Nuclear Materials Safety L

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EXECUTIVE SUMMARY Big Rock Point Nuclear Power Plant NRC Inspection Report 50-155/98003(DNMS)

This routine decommissioning inspection covered aspects of licensee management and control, decommissioning support activities, spent fuel safety, and radiological safety, o Major c' commissioning activities were performed in accordance with schedules, an radiolors ical activities were performed with as-low-as-reasonably-achievable (ALARA)

elements meluded in the plans. Also, licensee workers received training on the rules and regulations for shippers of radioactive material e Corrosion failure of the liquid poison tank discharge dip tube rendered the liquid poison system inoperable, apparently for a substantial period of time. Appropriate notification of this finding was made to NRC. Inoperability of the system on or before September 20, 1997, is an apparent violation which is being considered for escalated enforcement by NR Eacility Manaaement and Control e Operator licenses for senior licensed operators and licensed operators are no longer required as there are no controls at the Big Rock Point facility that, when manipulated, would result in a change of reactivity or power level in the reactor, o The NRC approved the Big Rock Point training program for certified fuel handler * The scope and status of major decommissioning activities were in accordance with planned schedule * The Plant Safety Revlaw Committee identified plant systems upon which maintenance and surveillance were no longer required to be performed, and plant systems upon which maintenance and surveillance were still required to be performe Decommissioning Support Activities e The materialintegrity of structures, systems, and components necessary for the safe storage of spent fuel and conduct of safe decommissioning was being maintained. Plant housekeeping and fire protection were generally good and were being monitored by plant managemen Spent Fuel Safety e The safety of the spent fuel in the spent fuel pool was maintaine Radioloalcal Safety

.e: Overall, ALARA planning and adjustments were made in an acceptable manner and in accordance with plant procedure .

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e Licensee personnel received training on the rules and regulations for shippers of radioactive materia e The licensee's environmental monitoring program for 1997 appeared to be in compliance with the requirements of Technical Specifications and applicable regulatory requirements.

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ReDort Details Summary of Plant Activities l

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During the inspection period, large pies of equipment not needed for the safe storage of spent

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. fuel, a large quantity of resin, and some potentially hazardous components or materials were removed from the facility. Also, some additional plant systems were classified as not needed for safe storage of fuel. Milestones achieved were the NRC's approval of the certified fuel handlers l training program, and the NRC's determination that reactor operator and senior reactor operator

licenses are no longer required. An event occurred and notification was made to the NRC when the licensee discovered that the liquid poison tank discharge dip tube was corroded in two. At the end of the inspection period, the reactor recirculation piping to the reactor vessel had been cut and capped and the reactor vessel refilled with water resulting in the reactor vessel becoming a tan .0 Facility Management and Control General The inspectors conducted frequent reviews of ongoing plant activities and attended licensee meetings and reviews addressing these activities, in order to assess overall facility management and controls. Specific events and findings are detailed in the sections belo .2 Organization. Manaaement. and Cost Controls at Permanently Shut Down Reactors (36801)

1. General The inspector reviewed the licensee's systems for overall management and control of the decommissioning process. Specific processes which were selectively examined included the programs for identification and resolution of safety concems and the commitment tracking programs and procedures. The effectiveness of the licensee's review of regulatory information, including generic letters and information notices applicable to the facility, was selectively examine .2.2 Operator Licenses No Lonaer Reauired On April 16,1998, the NRC concluded that operator licenses for senior licensed operators and licensed operators are no longer required as there are no controls at the Big Rock Point (BRP) facility that when manipulated would result M :: change of reactivity or power level in the reactor. The determination that the licenses are not required is in accordance with 10 CFR 55. Consumers Energy certified the permanent cessation of power operations and defueled status of the facilit .2.3 Certified Fuel Handler (CFH) Trainino Prooram On April 16,1998, the NRC approved the BRP training program for certified fuel handlers following meetings and discussion with BRP licensing and training personnel in the resolution of NRC comments for planned decommissioning activities. The CFH training program is in accordance with 10 CFR 50.2 and provides adequate confidence that appropriate training of CFH personnel will be conducted to ensure that the facility is maintained in a safe condition while spent fuel is stored in the spent fuel pool (SFP).

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. Safety Reviews. Desian Channes. and Modifications at Permanentiv Shut Down Reactors (37801)

1. Genggi The inspector examined the licensee's safety review program to ascertain that the program was effective at identifying potential unreviewed safety questions in accordance with 10 CFR 50.59. The activities of the licensee's onsite and offsite safety review committees were evaluated to determine whether they were fulfilling their respective charters and the requirements of Technical Specification (TS) and the quality assurance pla Specific design changes or modifications were reviewed to assess program effectiveness in application. This included a review of written safety evaluations and other records. In addition, a sample of maintenance and repair activities was reviewed to ascertain whether the licensee had made changes to the facility without properly invoking their safety review proces '1. Eauioment Removed from Facility Major pieces of plant equipment that the Plant Safety Review Committee (PRC) classified as not needed for the safe storage of spent fuel and removed from the facility were:

o main generator rotor e main generator exciter e pump motors e reactor vessel shield plug e reactor vessel thermal shield The plant is nearing the end of phase "A,"" Mobilization and Hazard Reduction" of the Big Rock Point major periods decommissioning time line, which is part of the Post-Shutdown Decommissioning Activities Report (PSDAR). Plant equipment that was removed from the facility for hazard reduction is:

e - acid tank e activated resin e altemate shutdown system battery e reactor depressurization system train "B," "C," and "D" batteries e twenty-five percent of the plant asbestos e pump motor oils e hydrogen control panel'

1. Plant Systems and Components Evaluated by the PRC The following systems or major components were evaluated by the PRC and determined

. not needed for the safe storage of spent fuel; therefore, maintenance or surveillance are no longer required on these system or components:

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e- altemate shutdown system e- feedwater system o primary coolant system o post incident system i e core spray system

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e condensate polisher e reactor depressurization system e- control rod drive system e~ reactor vessel e steam drum e reactor cleanup system e shutdown cooling system o reactor protection system e liquid poison system o emergency condenser system o neutron monitoring system o main steam system e turbine generator e' feedwater heaters and extraction steam system o seal and lube oil system e air ejectors e Off gas system e high range accident containment gamma monitoring system The following systems have been evaluated by the PRC and remain in service; therefore, maintenance and surveillance requirements still apply:

e spent fuel cooling system o reactor cooling water system e service water system e fuel handling system e area monitoring system o stack gas monitoring system e radioactive waste system o process monitoring system e fire protection system o heating ventilation and air conditioning system e emergency diesel generator system-e service and instrument air system o station power system e direct current distribution system o attemate current distribution system o portion of decommissioning power system e security system e communication system

• - demineralized water system

- e- domestic water system o condenser system o chlorination system o sumps and drains system o cranes-e cathodic protection system L e sanitation system -

The inspector concluded that the above lists are in accordance with present plant needs for the safe storage of spent fue !

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, Decommissianina Performance and Status Review at Permanentiv Shut Down Reactors (71801)

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The status of decommissioning, and licensee and contracted workforce conduct of decommissioning activities in accordance with licensed requirements and commitments were evaluated. Control and conduct of facility decommissioning were examined to verify the license and TS requirements and commitments described in the Final Safety Analysis Report (or equivalent), and PSDAR. Specific events and findings are detailed in the section belo .4.2 Monitored Decommissioning Activities The inspector attended licensee meetings where the planning, reviewing, assessing, and scheduling of decommissioning activities were observed. The inspector ascertained that activities were in accordance with licensed requirements and docketed commitments as stated in 10 CFR, TS, Final Hazards Summary Report, and PSDAR. The inspector also monitored schedule a therence for the decommissioning activities and determined that routine management %tention was applied to ensure that resource adjustments were made to keep the activities on or near schedule and when necessary schedule adjustments were made. Decommissioning activities monitored by the inspector were:

e CP1 cutting and capping the reactor recirculation system piping, resulting in the reactor vessel becoming a tank e CP4 resin disposal project e P001 reactor shield plug removed e PWO2 temporary RadWaste domin skid, Phase 2 e ENG-014 decommissioning power system, Phase 2 e MAC-004 asbestos abatement e ENG-400 steam drum / recirculation pump room, Phase 1 The two major criteria used by the licensee for rescoping decommissioning activities were annual budgeted money and budgeted Person-Rem exposure. The inspector had no concems with the scope and status of monitored decommissioning activitie .4.3 Plant Tours to Evaluate Material Conditions. Housekeeping and Fire Protection a. Insoection Scoce l

Plant tours were performed to evaluate the material integrity of structures, systems, and components necessary for the safe storage of spent fuel and conduct of safe decommissioning, and to evaluate plant housekeeping and fire protectio ;

l b. Observations and Findinas Observations made by the inspector on plant tours were:

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e; bags of radioactive waste placed on portable power cables - a fire hazard e containment particulate air monitor trending up-scale - paper drive stopped L . advancing paper - health physics technician corrected

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e radioactive waste collection bin placed under telephone in machine shop -

unnecessary exposure to plant personnel using the telephone - bin was removed a welder helper removed welding rods from welding rod heater too soon before the use of the welding rods - helper then destroyed the rods Strenoths e radioactive waste not accumulating in plant area - waste either removed from plant or stored in proper container e plant cleanliness maintained e portable cable and hoses properly routed to eliminate tripping hazards After conducting plant tours, the inspector discussed the findings with plant managemen The inspector observed that pant management was actively monitoring plant housekeeping and fire protection. When issues arose, the issues were resolve c. Conclusions The inspector concluded that the material integrity of structures, systems and components necessary for the safe storage of spent fuel and conduct of safe j decommissioning was being maintained. Plant housekeeping and fire prNoction were generally good and were being monitored by plant managemen .5 Onsite Followup. Written Reports of Non-routine Events at Power Reactor Facilities (92700)

1. (Closed) IFl 50-155/97013-03: Diesel fuel oil spill soil sampling. The inspector reviewed j

corrective actions for condition report (CR) C-BRP-97-563, " Diesel Fuel Spill from '

Tractor." The tractor fuel sediment bowl had failed resulting in approximately 25 gallons of diesel fuel oil draining to the ground. Approximately 20 cubic yards of diesel impacted soil was excavated, put in 55-gallon drums, sampled and stored as mixed waste. The 56 drums are stored in the site waste storage building awaiting the required analysis for release from a nuclear facility and will be disposed of in accordance with regulations in the Fall of 1998. . The diesel fuel spill from the tractor was an isolated occurrenc Corrective actions included parking vehicles in areas where, if a spill should occur, the j problem would be minimized. The inspector has no further concems. This inspection j followup item is close I

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1.5.2 (Closed) IFl 50-155/97015-01: Resolution of flow induced vibration on damper VHV32 On March 24,1998, damper VHV324 was replaced with a damper constructed of heavier metal, having better bearings, and with a more positive position retention mechanis The new damper has maintained its set position since installation; thus, resolving the problem of the old damper becoming loose and changing position. An up-stream flow straightener was not installed as originally planned. This inspection followup item is close .5.3 (Closed) IFl 50-155/98002-01: Review of zircaloy oxidation analysis. The zircaloy oxidation analysis rasults indicated that 220 days after plant shutdown the cladding of the spent fuel in the SFP with the covers on and all cooling removed would not reach the peak oxidation temperature of 1049'F. Therefore, after April 6,1998, self-sustained oxidation of zircaloy fuel cladding would no longer occur. This inspection followup item is close _ _ _ - _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _

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1.5.4 (Closedll&50-155/98002-04- Radioactivity in discharge canal from algae. The inspector reviewed the results of CR C-BRP-98-056 " Canal Liquid Process Monitor Alarm" and Event Notification No. 33901 which was made to the NRC on March 15,1998, at 0620 EST. With the plant in decommissioning status, the canal discharge liquid effluent -

radiation monitor alarmed. The alarm was confirmed to be accurate by taking samples

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which indicated that for a liquid release the canal effluent was at the maximum permissible Co-60 concentration.

I The radioactivity in the discharge canal was found to be bome by periphyton (gray-brown a'gae) which had concentrated at the screenhouse due to prevailing weather condition During the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to the alarm, winds were directly from the north at an average speed of 25 miles per hour. Waves in excess of five feet scoured accumulated periphyton from the rocks and suspended the organisms in the water The weather

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conditions, combined with no circulating water flow to take the canal discharge to the lake as the circulating water pumps were off, allowed for the accumulation of the periphyto Subsequently, the periphyton became dislodged and was brought into the plant water intake through the discharge weir and the recirculation warming line. This recycled the periphyton between the plant water intake and the discharge, resulting in elevated levels of radioactivity being indicated in the plant discharge canal. After the wind shifted direction and the licensee started a circulating water pump for dilution the condition cleare Sediment samples collected in the discharge, along with samples collected by divers between the screenhouse and intake structure indicated normal activity levels consistent with past environmental data. This indicated that the algae was the carrier of the radioactivity and that it was introduced into the intake through the warming line causing the canal radiation monitor to alarm. Corrective actions were to ensure that circulating water pumps are on for all liquid batch releases and to revise Emergency Procedure EPlP-1 to remove the requirement for the declaration of an unusual event at twice maximum permissible concentration, which is below the reporting limits. This inspection followup item is close .0 Decommissioning Support Activities Maintenance and Surveillance at Permanently Shut Down Reactors (62801)

2. General The inspection evaluated maintenance and surveillance for structures, systems, and components potentially affecting the safe storage of spent fuel and reliable operation of radiation monitoring and effluent control equipment. Direct observations, reviews, and interviews of licensee personnel were conducted to assess whether maintenance and surveillance were performed in accordance with regulatory requirements and resulted in the safe storage of spent fuel and reliable operation of radiation monitoring and effluent control equipment. This included the proper implementation of TS and 10 CFR 50, Appendix B, requirements. An examination of planned or completed maintenance and surveillance activities was conducted to assess the maintenance and surveillance process from its inception to its completio The inspectors observed all or portions of the following surveillance activities:

• T7-28 emergency generator auto test start

• T180-16 functional test of the fire detection system

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. Operational Safetv Verif; cation (71707)

2. General The inspector conducted frequent reviews of ongoing decommissioning activitie Specific events and findings are detailed in sections belo . Llauid Poison Tank Discharoe Dio Tube Failure n.- Inspection Sconst The inspector investigated the liquid poison tank discharge dip tube corrosion which resulted in the liquid poison tank becoming inoperabl Observations and Findinos The liquid poison system was to provide a means of rendering and holding the reactor suberitical while the reactor cooled down in the event that the control rods were unable to do so because the control rods had become stuck in the retracted position or if all of the

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various indications of reactor power level in the control room had failed. In the event that the reactor could not have been shut down with the control bladss, the liquid poison system would have injected a sodium pentaborate solution into the reactor vessel to shut down the reactor in about 5 minutes. If the liquid poison system had been activated, valves would have been opened and nitrogen would have pressurized the liquid poison tank with 2000 pounds of nitrogen pressure forcing sodium pentaborate out of the tank discharge dip tube and the discharge line into attemate injection points at the bottom of the reactor vessel and into the recirculating pump suction line The reactor was permanently shut down on August 29,1997, and on September 20, 1997, the last fuel bundle was removed from the reactor vessel and placed in the spent fuel pool (SFP). The liquid poison system was then no longer required to be operabl On March 27,1998, operations personnel attempted to empty the liquid poison tank by transferring the sodium pentaborate into drums. However, only air was transferred making the licensee suspect that the tank discharge dip tube was broken. On April 24, '

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1998, engineers inspected the liquid poison tank with a boroscope and confirmed that the liquid poison tank discharge dip tube was corroded in two. The break was 12 inches I

below the tank top flange and 6 inches above the water line with the rest of the tube leaning against the side of the tank. The discharge dip tube being broken prevented the fulfillment of the system safety function. The high pressure nitrogen would have gone out the broken discharge dip tube instead of forcing out the sodium pentaborate. On April 24, 1998, the licensee called the NRC with information Event Notification No. 3412 The sodium pentaborate was subsequently removed into drums by putting a pipe into the tank through the level indicator flange drums and the poison tank was permanently removed from service. On May 14,1998, the liquid poison tank was opened. The licensee and the inspector visually inspected the discharge dip tube which appeared to

' have corroded in two pieces. The exact length of time it had been broken in two is

. Indeterminent, but it was a substantial period of time, dating from some time before September 20,199 '

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The liquid poison tank discharge dip tube was sent to a laboratory for analysis to attempt to determine more precisely when the tube had failed and resulted in the liquid poison system becoming inoperabl c. Conclusions Corrosion failure of the liquid poison tank discharge dip tube rendered the liquid poison system inoperable during some periods when the system was required to be operable.

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TS 5.2.3 " Liquid Poison System," states, "The liquid poison system shall be available for

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operation at all times during refueling and power operation." The liquid poison tank being inoperable before September 20,1997, is an apparent violation of TS 5. (50-155/98003-01(DNMS)). Spent Fuel Safety General The inspectors evaluated the performance or condition of structures, systems or components associated with storage, control, and maintenance of spent fuel in a safe manne .2 Soent Fuel Pool (SFP) Safety at Permanentiv Shut Down Reactors (60801) Inspection Scoce The inspection evaluated spent fuel and fuel pool safety. Factors considered in the evaluation included SFP heatup rate; SFP instrumentation, alarms, and leakage detection; SFP chemistry and cleanliness control; criticality controls; and SFP operation f and power supply, i Observations and Findinas The inspector reviewed the Auxiliary Operator logs containing SFP parameters and locally monitored SFP temperature and level. The inspector verified that no leakage was coming

! from the SFP liner telitails and that the SFP area criticality monitor was functioning. The l Inspector also observed that foreign material controls were being used in and around the

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SF c, Conclusions The inspector concluded that the safety of the fuel in the SFP was being maintaine .0 Radiological Safety Occupational Radiation Exposure (83750)

4.1.1- General Numerous aspects of licensee processes to minimize occupational radiation exposure were selectively examined in order to evaluate overall radiation safety and to provide for early identification of potential problems. Areas examined included: audits and appraisals; planning and preparation; training and qualifications of personnel; extemal exposure control; intemal exposure control; control of radioactive materials and

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contamination; surveys and monitorings; and maintaining occupational exposure ALAR Specific events and findings are detailed in the sections belo .1.2 ALARA Plannina 1 During the month of April, challenges to Person-Rem estimates developed. Following the failure of the RadWaste demineralized resin retention element, the resin disposal project was increased to remove all plant resins. This resulted in the filling of three additional resin liners. The recirculation pump room allowable exposure was increased because of the need to build more scaffolding to support the cutting of the j 20-inch recirculation system piping. The extra scaffolding was needed because room and component configurations were not fully evaluated in the pre-planning. An ALARA hold was placed on steam drum asbestos abatement activities because insulation removal 3 revealed higher than expected dose rates and new hot spots. The total Person-Rom estimate for the month of April was targeted at 17.5 Person-Rem and the total exposure at the end of the month was 21.585 Person-Rem; a variance of 23 percent. The inspector concluded that overall the ALARA planning and adjustments were made in an acceptable manner and in accordance with plant procedure .2 Radioactive Waste Treatment. and Effluent and Environmental Monitorina (IP 84750) Inspection Scope The inspectors reviewed the Annual Radiological Environmental Monitoring Report for the period January 1 - December 31,1997, to determine if the environmental monitoring program was in compliance with the Technical Specifications and regulatory requirements. The results of the monitoring were also reviewed to determine in they were in compliance with the requirements of the regulations, Observations and Findinas The inspector reviewed the results of airbome particulate and lodine-131, milk, lake water, well water, drinking water, crop, sediment, fish and vegetation sample analyse The inspector also reviewed the environmental Thermoluminescent dosimetry (TLD) and interlaboratory comparison result The reviews indicated that all activity levels in the samples collected were at or near environmental background levels and no Technical Specification reporting levels were exceeded. TLD levels were also within the regulatory limits. The interlaboratory comparison results indicated that the onsite laboratory analyses compared favorably with the reference laboratory result Conclusions The licensee cmAded that the operation of Big Rock Point had minimal environmental j

radiological ime buring 417, and the overall environmental build-up remains insignificant. Based on the review of the 1997 radiological environmental monitoring l

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, . report, the inspector determined that the licensee's conclusion was justifie Paragraph 1.5.4 of this report details one occurrence in 1998 when environmental radiological build-up reached an identifiable leve j l

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.. Solid RadWaste Manaoement and Transportation of Radioactive Materials (86750)

The inspector monitored the 40-hour-training class " Radioactive Material Transportation

' and Disposal" for shippers of radioactive material. Materials covered in the course were 49 CFR Parts 171-177 and 10 CFR Part 61. Alllicensee personnelin attendance successfully passed the course examination and are now qualified for the shipping and transportation of radioactive waste. The licensee personnel have been trained on the rules and regulations for shippers of radioactive materia .0 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on May 27,1998. The licensee acknowledged the findings presented. The inspector reviewed proprietary documents related to dry cask storage. None of this information is included in this report. The licensee did not identify any other documents or processes reviewed by the inspectors as proprietar .

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.4 PARTIAL LIST OF PERSONS CONTACTED Li_cpateg L Berry, Site Licensing Engineer M. Bourassa, Licensing Supervisor J. Codey, Nuclear Performance Assessment -

L. Darrah, Operations Supervisor -

D. Debner, Nuclear Fuel Projects Manager G. Hausler, Work Control Supervisor D. Hice, Plant Manager

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C. Jurgens, Construction Manager-K. Pallagi, Radiation Protection and Environmental Manager G. Petitjean, Senior Engineer (Altemate PRC Chairman)

L. Potter, Maintenance Supervisor

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K. Powers,' General Manager

_J. Rang, Business and Regulatory Services Manager G. Rowell, Corrective Action Supervisor W. Trubilowicz, Scheduling and Project Control Manager M. VanAlst, Security Manager G. Withrow, Engineering Manager K. Wooster, Emergency Planning Manager E. Zienert, Human Resources Director

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INSPECTION PROCEDURES USED IP 36801: Organization, Management, and Cost Controls at Permanently Shut Down .

Reactors

'IP 37801: Safety Review, Design Changes, and Modifications at Permanently Shut Down Reactors IP 60801: Spent Fuel Pool Safety at Permanently Shut Down Reactors IP 62801: Maintenance and Surveillance at Permanently Shut Down Reactors IP 71707: ' Operational Safety Verification IP 71801: Decommissioning Performance and Status Review at Permanently Shut Down .I Reactors

. IP 83750: Occupational Radiation Exposure

. IP 84750: RadWaste Treatment, Effluent and Environmental Monitoring f

IP 86750: Solid RadWaste Management and Transportation of Radioactive Materials IP 92700: Onsite Followup, Written Reports or Non-routine Events at Power Reactor Facilities ITEMS OPENED, CLOSED AND DISCUSSED Opened 50-155/98003-01 APV Liquid Poison Tank inoperable before 09/20/97 Closed 50-155/97013-03 IFl Diesel Fuel Oil Spill Soil Sampling 50-155/97015-01 IFl Resolution of Flow Induced Vibration on Damper VHV324 50-155/98002-01 IFl Review of Zircaloy Oxidation Analysis 50-155/98002-04 IFl Radioactivity in Discharge Canal from Algae Discussed None r

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'd UST OF ACRONYMS USED ALARA ~ As-Low-Reasonably-Achievable BRP Big Rock Point CFH Certified Fuel Handler CFR Code of Federal Regulations IFl Inspection Followup Item NRC Nuclear Regulatory Commission PRC Plant Safety Review Committee PSDAR- Post-Shutdown Decommissioning Activities Report RadWaste Radioactive Waste SFP Spent Fuel Pool TLD Thermoluminescent dosimetry TS Technical Specification LICENSEE DOCUMENTS REVIEWED The licensee documents used in arriving at findings or conclusions are specifically identified in the pertinent sections of the report " Details."

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