IR 05000155/1998006

Insp Rept 50-155/98-06 on 980716-0826.No Violations Noted. Major Areas Inspected:Aspects of Licensee Mgt & Control, Decommissioning Support Activities,Spent Fuel Safety & Radiological Safety

ML20239A257
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	09/03/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20239A252	List: IR 05000155/1998006 ML20239A249
References
50-155-98-06, 50-155-98-6, NUDOCS 9809080343
Download: ML20239A257 (16)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lli Docket No: 50-155 License No: DPR-06 Report No: 50-155/98006(DNMS)

Licensee: Consumers Energy Company Facility: Big Rock Point Restoration Project Location: 10269 U.S. 31 North Charlevoix, MI 49720 Dates: July 16 - August 26,1998 Inspectors: R. J. Leemon, Senior Resident inspector W. G. Snell, Health Physics Manager P. W. Harris, NRC Project Manager Approved By: Bruce L. Jorgensen, Chief Decommissioning Branch Division of Nuclear Materials Safety l

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EXECUTIVE SUMMARY Big Rock Point Restoration Project NRC Inspection Report 50-155/98006(DNMS)

This routine decommissioning inspection covered aspects of licensee management and control, decommissioning support activities, spent fuel safety, and radiological safet o Overall, major decommissioning activities were performed in accordance with schedules, and radiological activities were performed with as low as reasonably achievable elements

~ included in the plan Escility Manaaement and Control Licensee management and organizational changes met established requirements and appeared gauged to improve the effectiveness of decommissioning activities at Big Rock Point (BRP).

• Safety evaluations written for various decommissioning activities showed that the licensee adequately justified their conclusions that their planned decommissioning activities did not represent a change to technical specification requirements, and did not create any unreviewed safety question or condition contrary to the requirements of 10 CFR 50.82(a)(6) and (7). Further, no safety concems were identifie * Procedure D1.11 " Safety Evaluations," did not provide clear instructions as to the specific requirements of 50.59 and 50.82. Specifically, the procedure confused requirements of 10 CFR 50.82(a)(6) with those of 10 CFR 50.82(a)(7), did not provide clear guidance on the evaluation of radiological consequence, and did not differentiate between an unreviewed safety question and a change to a technical specification requiremen Further, the licensee's initiative to define systems, structures and components (SSCs)

important to the safe storage of spent fuel and SSCs important to monitoring and control of radiological hazards was not addressed. Responsibilities regarding independent assessment of a 50.82 evaluation were not described and the licensee's safety evaluation worksheet did not explicitly question all elements of 10 CFR 50.82 to provide reasonable assurance that all 50.82 requirements are explicitly evaluated, e The scope and completion of monitored decommissioning activities were described during a meeting between the licensee and NRC which was open to public observatio . The licensee summarized the current licensing, decommissioning, and safety issues faced by Consumers regarding the decommissioning of the BRP facility. They clearly articulated that their number one priority for the NRC staff is the approval of the defueled emergency plan and associated exemption. They also indicated that their cost and scheduling controls provide reasonable assurance that the expenditure of decommissioning costs do not result in an inability to release the site for unrestricted use.

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This meeting contributed to the NRC staff's understanding of issues important to the decommissioning of the BRP facility, e The Nuclear Performance Assessment Department audit team was effective in identifying programmatic and implementation weaknesses, and areas of declining performance when conducting Audit PA-98-0 e The material integrity of SCCs necessary for the safe storage of spent fuel and conduct of safe decommissioning was being maintained.

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o Housekeeping was good and was being monitored by plant management. The state of housekeeping contributed to safe decommissioning and did not represent conditions adverse to plant or personnel safet * Storage of combustible material, operation of fire equipment, and effectiveness of the fire brigade were being monitored and maintained. The licensee removed oils from the site to reduce the fire hazar Spent Fuel Safety e The safety of the fuelin the spent fuel pool was being maintaine Radiological Safety e Radiological safety activities were being conducted safely and in compliance with applicable requirement _ _ _ - _ _ - _ _ _ _ _ _ _ _ _

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'- Report Details Summary of Plant Activities During the inspection period, equipment not necessary for the safe storage of spent fuel and potentially hazardous components and materials was removed from the facility. Also, additional l plant systems were classified as not needed for safe storage of fuel. Licensee representatives l met with the NRC staff to discuss the emergency plan and the new defueled Technical Specifications (TS). On August 25,1998, a milestone was achieved when the reactor head was

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removed from the reactor vessel for the last time.

! Facility Management and Control General I

The inspector 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 arid findings are detailed in the sections belo .2 Omar*=*lan. Manaoement. and Cost Controls at Permanentiv Shut Down Reactors f36601)

1. General The inspector selectively reviewed the licensee's activities involving overall management

and control of the decommissioning process. The effectiveness of the licenses's review of regulatory information applicable to the facility was selectively examined.

i 1.2.2 Reaulatory information The inspector assessed the licensee's review of regulatory information applicable to a decommissioned power reactor. The inspector reviewed generic letters and information notices, held discussions with the regulatory information coordinator, attended Plant Review Committee (PRC) meetings, and reviewed the status of regulatory information in past PRC minutes and concluded that, for a decommissioned power plant, the licensee

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property applied appropriate actions related to regulatory information,

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1.2.3 Management and Organizations Channes Inspection Scope

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The inspector evaluated licensee decommissioning organization changes, l

l Observations and Findinas On July 27,1998, the site general manager announced that the plant manager had accepted a reassignment to another position in the company. The plant manager was immediately relieved of his duties at Big Rock and the engineering manager and the scheduling and project control manager were jointly assigned the plant manager duties until the development of a new decommissioning organizatio l

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l The Nuclear Performance Assessment Department (NPAD) health physics (HP) specialist transferred to the position of radwaste superintendent. The licensee then hired an NPAD

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inspector possessing skills in both oprations and H The licensee also reorganized the radiation protection and environmental services organization into five departments to better perform decommissioning activitie i Qonclusion Licensee management and organizational changes met established requirements and ,

appeared gauged to improve the effectiveness of decommissioning activities at Big Rock {

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I Safety Reviews. Desian Chances. and Modifications at Permanently Shut Down Reactors j (37801) {

1.3.1 Gener,a,j The inspector examined the licensee's safety review program to ascertain that the program was effective at identifying potential unreviewed safety quest lons 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 TS and the quality assurance pla .3.2 Procedure D1.11. " Safety Evaluations." Revision 0 Inspection Scope The inspector reviewed Procedure D1.11 " Safety Evaluations," Revision 0, to assess whether appropriate administrative controls and instructions are provided to contribute to the assurance that the licensee staff performs adequate safety evaluations in accordance with 10 CFR 50.59, " Changes, Tests and Experiments." In addition, the inspector asseused whether adequate guidance is provided in licensee procedures and/or instructions to provide reasonable assurance that the BRP staff will evaluate whether proposed decommissioning activiths in accordance with 10 CFR 50.82(a)(6) and (7).

10 CFR 50.82(6) precludes the performance of any decommissioning activity that:

(1) forecloses release of the site for possible unrestric'ed use; (2) results in any significant environmental impacts not previously reviewed; or (3) results in there no longer being reasonable assurance that adequate funds will be available for decommissioning.10 CFR 50.82(a)(7) requires, in part, that in taking actions permitted under 10 CFR 50.59 the NRC shall be notified prior to performing any decommissioning activity which (1) is inconsistent with or results in a significant schedule change from the actions and schedules provided in the BRP Post-Shutdown Decommissioning Activities ,

Report (PSDAR) or (2) results in a significant increase in the decommissioning cost. The l following BRP Safety Evaluation (SE) reports were reviewed: ]

• Decommission Electrical Power Supply (FC-696, No. 216-98)

• Containment Vessel Procedure Change (SOP-10, No. 203-98)

• UFHSR, Chapter 1, Revision (No. 89-98)

• UFHSR, Chapter 15, Revision (No. 435-98)

• Post-Shutdown Decommissioning Activities Report, Revision 2 (No. 486-98) l

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• Liquid Radioactive Waste - FRAC Tank Procedure Change (No. 651-98)

1 * Liquid Radioactive Waste - FRAC Tank Placement (No. 98-20) j i

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l b. Observations and Findinos l BRP requires that safety evaluations, as described in the BRP Procedure D1.11, shall be performed for procedures, tests and experiments, in addition, D1.11 requires that safety evaiustions be performed for all decommissioning work packages. Therefore, the scope of Procedure D1.11 applies to all decommissioning work that is being performed onsit In accordance v.ith 10 CFR 50.5g a licensee may make changes and conduct tests or experiments without prior NRC approval if the change, test or experiment does not involve an unreviewed safety question or change in TSs. The inspector observed that D1.11 provides adequate assurance that this particular requirement can and will be met; i however, D1.11 (for example D1.11, Section 5.1.3) does not clearly differentiate the 1 difference between a change to TSs and an unreviewed safety questio i BRP lists all systems, structure, and components (SSCs) important to decommissioning on a Q-list which is used by the plant staff, in part, to ascertain the administrative controls (such as quality assurance (QA)) that should be applied to these SSCs. With the permanent cessation of power operations, BRP has concluded that three SSCs at BRP remain classified as safety related: the spent fuel assemblies; the spent fuel pool (SFP) ,

storage racks and the SFP structures; therefore, all other SSCs are nonsafety related, i However, to provide reasonable assurance that appropriate controls and mechanisms are applied to all SSCs important to the conduct of safe decommissioning, the licensee has defined two new terms: Important to the Safe Storage of Spent Fuel (ISSSF) and important to Monitoring and Control of Radiological Hazards (IMCRH) to broaden the scope of SSCs to which appropriate QA and management controls are applied. Insofar as this inspection was concemed, the broad scope of SSCs captured by ISSSF and IMCRH and the control applied was considered commendable. However, the inspector noted ihet the terminology used in D1.11 is inconsistent with the licensee's ISSSF and IMCRH in referring only to safety and nonsafety related SSCs. This has the potential to reduce the scope of SSCs requiring SE Procedure D1.11 specifically lists a number of appropriate responsibilities for the

" preparer" of the SE and NPAD to ensure the quality and effectiveness of BRP SE However, neither the " preparer" nor NPAD is assigned the responsibility of assuring that the requirements of 10 CFR 50.82(a)(6) and (7) are me D1.11 did not clearty differentiate the differences between 10 CFR 50.82(a)(6) and (7) requirements. For example, D1.11, Section 5.3.2, stated in part, that a copy of the

"10 CFR 50.82 Evaluation, if required, shall accompany other documentation for the item or activity being evaluated." This wording does not clearly indicate that for all decommissioning activities 10 CFR 50.82(a)(6) shall be met, and for all actions taken under 10 CFR 50.5g, that the requirements of 10 CFR 50.82(a)(7) shall be met. Another for which this observation applies is D1.11, Section 5.3.2.5, Procedure D1.11 provided appropriate instructions on the process used to disposition unreviewed safety questions or changes to TS requirements.

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c. Conclusions The licensee adequately justified their conclusions that their planned decommissioning activities did not represent a change to TS requirements, unreviewed safety question, or condition contrary to the requirements of 10 CFR 50.82(a)(6) and (7). Further, no safety concems were identifie !

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Notwithstanding appropriate conclusions reached by the licensee, Procedure D1.11 does not provide clear instructions as to the specific requirements of 50.59 and 50.82. The procedure confused the specific requirements of 10 CFR 50.82(a)(6) with that of 10 CFR 50.82(a)(7), did not provide clear guidance on the evaluation of radiological consequence, did not differentiate between an unreviewed safety question and a change

. to TS requirement, nor did it implement the licensee's initiative to define SSCs ISSSF and SSCs IMCRCH. Further, responsibilities regarding the evaluation and independent assessment of a 50.82 evaluation were not described and the licensee's safety evaluation worksheet did not explicitly question all elements of 10 CFR 50.82 to provide reasonable assurance that all 50.82 requirements have been explicitly evaluated. These potential weaknesses could reduce the assurance that future safety evaluations will consistently consider all relevant regulatory requirement Procedure D1.11 not providing clear instructions and guidance for implementing 10 CFR 50.59 and 50.82 requirements is an inspector followup item (IFl 50-155/98006-01).

1.3.3' 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, and emergency pla Decommissioning activities monitored by the inspector were as described in the following section .3.4. Meetina with BRP Representatives Reaardina Decommissioning Activities

, Inspection Scope On August 13,1998, BRP representatives met with NRC staff at NRC headquarters, Rockville, Maryland, to discuss the status of BRP decommissioning. Topics discussed during this meeting were the current status of decommissioning activities, licensing submittels, and planned changes to the facility to support decommissioning.

' Observations and Findinas The licensee described their initiative to segregate, identify, and modify, as necessar their onsite electrical power system to improve personnel safety and enhance the r reliability and operability of systems important to safety, such as those associated with

! spent fuel storage and radiological effluents. They also summarized their project to characterize and package for offsite waste disposal the non-fuel radioactive components i

currently stored in the SFP. This would not only increase the available room in the SFP, I to ease the conduct of spent fuel operations, but reduce the amount of radioactive waste stored in the pool. The licensee representatives also described their initiative to construct an onsite monitoring station to replace the control room. This new station will be provided with instrumentation and facilities necessary to monitor the safe storage of spent fuel as well as other facility systems. Finally, the licensee presented some planning and scheduling information and described some of the actions they are taking (such as staffing and schedule changes) to control and manage cost o

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- Conclusions L The licensee clearty articulated their goal to complete the decommissioning of the BRP facility safely and economically.' The licensee summarized the current licensing, decommissioning, and safety issues being addressed in the decommissioning of the BRP facility. They clearly articulated that their number one priority for the NRC staff is the approval of the defueled emergency plan and associated exemption. The licensee initiatives described above were presented as modifications to enhance personnel and material safety. They also indicated that their cost and scheduling controls associated with these and other modifications provide reasonable assurance that the expenditure of decommissioning costs do not result in an inability to release the site for unrestricted us This meeting was open to public observation and contributed to the NRC staff's understanding ofissues important to the decommissioning of the BRP facilit .3.5 Plant Systems and Comoonents Removed from Service Plant systems and components determined not needed for the safe storage of spent fuel and permanently removed from service during this inspection period were:

e control rod drive system o circulating water system o main generator e pipe tunnel block wall e turbine lube oil system o portions of instrument and service air system o condensate system o condensate pump room block wall e main steam system 1.3.6 Plant Modifications Specific design changes or modifications were reviewed to assess program effectiveness in application. This included a review of written SEs 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 Plant modifications that were in progress during the inspection period were:

e Installation of a decommissioning power syste * Pouring the floor for an attemate radwaste demineralized and filter system. The resin retention element in the plant radwaste domineralizer failed and was permanently out of service, e Installing altemate air and nitrogen bottles to control air operated valves and dampers.' This modification will allow removal of the station air syste * Planning for dry cask storage of spent fue Two major criteria used by the licensee for scoping decommissioning activities were annual budgeted money and budgeted person-rem exposure. The inspector had no ,

concems with the scope and status of monitored decommissioning activities. Further, the inspector determined that no unreviewed safety questions were developed by the change ,

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, .3.7. Managed Plant Hazard Reductions Hazards removed from the plant during the inspection period were oils (as a reduction to fire hazards) and approximately 34 percent of the asbestos on plant systems (as a reduction to biological hazards). Self-Assessment. Auditina. and Corrective Action (40801)

1. General The licensee's controls for identifying, resolving and preventing issues that degrade safety or quality were examined, including self-assessments, auditing, corrective actions, safety reviaw committees and root cause evaluation The QA plan and applicable implementing procedures formed the basis for the inspectio In addition, the procedures were evaluated from the perspective of their adequacy to accomplish the objective of assuring that management and staff are knowledgeable of plant / activity performance and contribute effectively to safety and quality in conduct of important activitie .4.2 Nuclear Performance Assessment Department Decommissioning Audit PA-9(1E- Inspection Scope The inspector evaluated the effectiveness of NPAD in identifying programmatic and implementation weaknesses, and areas of declining performance, Observations and Findinas The NPAD BRP Decommissioning Audit PA-98-07 was conducted by a thirteen-member audit team. The audit evaluated the adequacy and effectiveness of BRP activities with respect to 10 CFR 50, Appendix B; the Quality Program for Operational Nuclear Plants (CPC-2A); TSs; and various plant procedures. Thirteen condition reports (CRs) were written as a result of the audit. Four of the CRs were for significant conditions adverse to quality and nine of the CRs were for conditions adverse to quality. The audit also identified two conditions of dual procedures being active at the same time, a supervisor not meeting the American National Standards institute (ANSI) experience requirements, two open items, and three strength The inspector verified that the audit team members were independent, reviewed the detailed audit report, and attended the corrective action review boards where the CRs were reviewed by plant management. The inspector also verified that the supervisor who

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did not meet the ANSI requirements was moved to a position which he was qualified for.

l The decommissioning audit was well conducted by independent auditors. The report contained good details explaining the weaknesses and the findings were converted into corrective action report Conclusion The NPAD audit team was effective in identifying programmatic and implementation I weaknesses, and areas of declining performance when conducting Audit PA-98-0 !. ,

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. Decommissioning Performance and Status Review at Permanentiv Shut Down Reactors

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1. General 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 Updated Final Hazard Summary Report (FHSR), and PSDAR. Specific events and findings are detailed in the section belo .5.2 Plant Tours to Evaluate Material Conditions. Housekeanina. and Fire Protection 1.5.2.1Matenal Conditions i Inspection Scope The inspector conducted plant tours to evaluate the material integrity of SSCs necessary for the safe storage of spent fuel and conduct of safe decommissionin Observations and Findinas After conducting plant tours, the inspector determined the material integrity of SSCs of systems ISSSF was being maintained. The inspector discussed tour observations with plant management. The inspector also observed that plant management was actively monitoring plant material condition Conclusion The material integrity of SSCs necessary for the safe storage of spent fuel and conduct of safe decommissioning was being maintaine .5.2.2 Housekeeping Inspection Scope The inspector conducted plant tours to observe and assess the status of facility housekeeping. The inspector also assessed w'r, ether field conditions would contribute to safe decommissioning and or would represent conditions adverse to plant or personnel safet Observations and Findinas The inspector's observations focused on the areas adjacent to and containing SSCs necessary for the safe storage of spent fuel, radiological effluent control, or radiation I protection and monitoring. The inspector determined that all areas of the plant were kept clean and free of the accumulation of dismantlement debris As material was disassembled, it was placed into metal boxes. Portable cables were routed so as not to cause tripping hazard _ _ - - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ -

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I Conclusion Housekeeping was good and was being monitored by plant management. The state of housekeeping contributed to safe decommissioning and did not represent conditions adverse to plant or personnel safet .5.2.3 Fire Protection Insoection Scooe I

The inspector conducted plant tours to observe and assess the storage of combustible q and flammable materials. The inspector also determined the presence and effectiveness i of the site fire brigade and observed a fire brigade training dril l l Observations and Findinos The inspector determined that the storage of combustible and flammable materials was within the fire loading limits for transient combustibles and that combustible materials were not accumulating in the plant. The licensee has now removed most oils from the plant to reduce the fire hazard. The inspector determined that fire fighting equipment and stations were properly maintained, inventoried, and ready for use. The inspector also determined that installed fire detection and suppression systems were effectively maintained, surveillance were performed, and the equipment was capable of performing the intended functions. The inspector also determined that the effectiveness of site fire brigade training and qualifications were being maintaine Conclusion Storage of combustible material, operation of fire equipment, and effectiveness of the fire brigade were being monitored and maintained. Also, the licensee removed oils from the site to reduce the fire hazar .6 Onsite Followup. Written Reports of Non-routine Events at Power Reactor Facilities (92700)

1. (Closed) LER 50-155/98001: Liquid poison tank discharge pipe found severed during facility decommissioning. In review of the event and Licensee Event Report (LER), the inspector concluded that the LER corrective actions were adequate. In an August 25, 1998, letter to the licensee, the NRC exercised enforcement discretion on this issue. This 4 LER is close . (Closed) VIO 50-155/98003-01: Determination of when the poison tank discharge dip .

tube failed. The determination was made that the dip tube had failed between 1979 and 1984. The event was discussed in LER 50-155/98001. The NRC stated in a letter to the ,

licensee dated August 25,1998, titled " Exercise of Enforcement Discretion," that as l provided for in NUREG-1600, " General Statement of Policy and Procedure for NRC j Enforcement Actions," Revision 1, Section Vll.B.6 enforcement discretion is warranted i I

due to the circumstances of this case. Therefore, a Notice of Violation will not be issued and a Civil Penalty will not be proposed. This apparent violation is closed.

l 1. (Closed) IFl 50-155/98004-01(DRS): Evaluation of periodic assessment. At the time of l the baseline inspection, the periodic assessment required by Paragraph (a)(3) of the rule i had not yet been completed. During the inspection, the inspector considered the j

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licensee's procedural guidance and schedule for completing the assessment as in accordance with the rule, although the inspector noted that the guidance was minimal and was more appropriate for an operating plant. The licensee anticipated completing the assessment at the end of May 1998, following an update of the procedure to more properly consider the shutdown nature of the plan The assessment was completed on June 10,1998, and covered the period June 1996 to

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June 1998. The inspector reviewed the assessment and determined that it met the maintenance rule, contained the elements recommended by industry guidance, and property considered the plant's shutdown condition. The inspector determined that assessment properiy evaluated system / function performance and the effectiveness of both maintenance and the maintenance rule program. Balancing of reliability and availability was to be accomplished by examining system /fanction performance for

' changes, if changes were identified, system / function outages would be examined. This assessment identified no changes in performance and concluded that because performance had neither changed nor deteriorated, changes in outages were not needed.-

This item is close .7 . Followuo On Corrective Actions For Violations and Deviations (92702)

1. (Closed) Esceleted Enforcement items VIOs 50-155/97197-01013. 50-155/97197-0102 /97197-01033. and 50-155/97197-01043 (50-155/97005-01(a.b). 50-155/97005-02(a.b). and 50-155/97005-03): Three events occurred in the first quarter of 1997 that were indicative of a programmatic deficiency in the areas of pre-job planning, as low as reasonably achieved (ALARA) planning, and radiological assessment.' In the .

August 12,1997, NRC transmittal letter describing the violations, the NRC discussed the corrective actions already taken to address these items. This included the conclusion that the corrective actions taken and planned to correct the violation and prevent recurrence were already adequately addressed. Since that letter was issued, significant organizational and staffing changes have occurred as a res' ult of the permanent shutdown and initiation of decommissioning activities at BRP. For example, ALARA planning is now a separate department of eight persons, including five ALARA planners, and an enhanced Radiation Work Permit (RWP) program is expected to be implemented in the near future. These changes, as well as other program initiatives, appear to be adequate to prevent a programmatic breakdown similar to the one that occurred in early 199 .0 Decommissioning Support Activitics Maintenance and Surveillance at Permanentiv Shut Down Reactors (62801)

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I The inspection evaluated maintenance and surveillance for SSCs 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 l

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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 requirement i l-l

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- 2.1.2 Dismantlement Activities Removal of block walls commenced which will facilitate future system and component removal. Dismantlement activities observed by the inspector during the period were:

o removal of condensate pump room block wall e removal of the pipe tunnel block wall

.* removal of main generator windings e removal of control rod drive piping e removal of the reactor vessel head

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The inspector observed that proper maintenance and HP survey practices were performed during these activitie .1.3 SFP Heatuo Test On August 18,1998, TV-59, " Fuel Pool Heatup Test," was completed with the heatup rate being 0.32" F/hr. The time for the SFP to heat from 80' F to 150' F was 9.91 days; greater than the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> assumed in the proposed defueled TS. As the decay heat in the fuel decays away, the amount of time for the licensee to respond to loss of cooling in the SFP will be increase .2 Operational Safety Verification (71707)

2.2.1 General The' inspector conducted frequent reviews of ongoing decommissioning activitie Specific events and findings are detailed in sections belo .2.2 . Control Room Instrumentation During control room tours the inspector noted that abandoned alarm windows were labeled " abandoned," and abandoned meter and recorder faces were covered with pape !

The inspector held discussions with the operators and determined that by identifying the abandoned equipment the operator can readily identify and monitor operating instrumentation spent Fuel Safety General

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The inspector evaluated the performance or condition of SSCs associated with storage,

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control, and maintenance of spent fuel in a safe manne .2 Spent Fuel Pool Safety at Permanentiv Shut Down Reactors Inspection Scope (60801) .]

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 I and power supply. The inspector reviewed station logs and held discussioris with the license j (-

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' 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 and that the SFP area criticality monitor was functioning. The inspector also observed that foreign material controls were being used in and around the SF Conclusion The safety of the fuelin the SFP was I:.eing maintaine .0 Radiological Safety Omuontional Rad'.aion Exposure (83750)

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 contamination; surveys and monitoring; and maintaining occupational exposure ALAR No problems were noted in review of these activitie .2 Redweste Treatment. and Effluent and Environmental Monitorina (84750)

The inspection included an evaluation of various aspects of licensee activities in the areas of waste treatment and effluent and environmental monitoring to ensure that radioactive waste treatment systems were being maintained and operated to keep onsite and offsite doses ALARA; to ensure that the licensee effectively controlled, monitored, and quantified releases of radioactive materials to the environments; and to ensure that required radiological environmental monitoring programs were effectively implemente No problems were noted in review of these activitie .3 . SW Radweste Manaaement and Transportation of Radioactive Materials (86750)

The inspection included an evaluation to determine whether the licensee property i processed, packaged, stored, and shipped radioactive materials, in order to assess the

. potential for safety problems resulting from these activities and from the transportation of radioactive materials. No problems were noted in the evaluation of this are .4 Conclusions Radiologic # 1afety activities were being conducted safely and in compliance with applicable requirements.

! Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on August 26,1998. The licensee acknowledged the findings . presented. The inspector reviewed propriety information related to dry cask storage of fue None of that information was included in this report. The licensee did not identify any other of the documents or processes reviewed by the inspector as proprietary.

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PARTIAL LIST OF PERSONS CONTACTED Licensee M. Bourassa, Licensing Supervisor

J. Corley, Nuclear Performance Assessment L Darrah, Operations Supervisor D. Debner, Nuclear Fuel Projects Manager G. Hausler, Work Control Supervisor D. Hice, Plant Manager C. Jurgens, Construction Manager K. Pallegi, Radiation Protection and Environmental Manager G. Petitjean, Senior Engineer (Altemale PRC Chairman)

L Potter, Maintenance Supervisor 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 R. Wills, Radweste Superintendent G. Withrow, Engineering Manager K. Wooster, Emergency Planning Manager E. Zienert, Human Resources Director 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 40801: Self-Assessment, Auditing, Corrective Action 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 Reactors IP 83750: Occupational Radiation Expos 1re IP 84750: Radwaste Treatment, Effluent ud Environmental Monitoring IP 86750: Solid Radweste Management and Transportation of Radioactive Materials IP g2700: Onsite Followup, Written Reports or Non-routine Events at Power Reactor Facilities IP g2702: Followup On Corrective Actions For Violations and Deviations

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l l-ITEMS OPENED AND CLOSED r Opened i

50-155/98006-01- IFl D1.11 Not Providing Clear instructions and Guidance for implementing 10 CFR 50.59 and 50.82 Requirements

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Closed 50-155/98001 LER Liquid Poison Tank Discharge Pipe Found Severed During Facility

, Decommissioning l 50-155/98003-01 VIO Determination of When the Poison Tank Discharge Dip Tube l Failed 50-155/98004-01 IFl- Evaluation of Periodic Assessment

' 50-155/97197-01013 VIO Failure to Properiy Evaluate Radiological Hazards for Plant Tour 50-155/97197-01023 VIO Failure to Property Evaluate Radiological Hazards for Filter

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l 50-155/97197-01033 VIO Failure to Exit HRA When ED Alarm Activated Per Procedure i 50-155/97197-01043 VIO- Entry into HRA by Worker Without Proper Coverage or Qualifications

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Discussed

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, None LIST OF ACRONYMS USED I ALARA- As Low As Reasonably Achievable I' ANSI American National Standards Institute l BRP Big Rock Point l CFR- Code of Federal Regulations l CRs Condition Reports -

I HP Health Physics

IMCRH Important to Monitoring and Control of Radiological Hazards l lSSSF' Important to Safe Storage of Spent Fuel

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LER Licensee Event Report NPAD Nuclear Performance Assessment Department

!- NRC Nuclear Regulatory Commission PRC Plant Review Committee i PSDAR Post-Shutdown Decommissioning Activities Report

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QA Quality Assurance

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Radweste Radioactive Waste RWP Radiation Work Permit SE Safety Evaluation SFP Spent Fuel Pool

SSCs Systems, Structures and Components TS Technical Specification l

UFHSR Updated Facility Hazards Summary Report LICENSEE DOCUMENTS REVIEWED Licensee documents reviewed and utilized during the course of this inspection are specifically identified in the " Report Details" above, g 16

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