IR 05000155/1998007

Insp Rept 50-155/98-07 on 980827-1007.No Violations Noted. Major Areas Inspected:Facility Mgt & Control,Physical Security,Spent Fuel Safety & Radiological Safety

ML20154M257
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	10/14/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20154M224	List: IR 05000155/1998007 ML20154M221
References
50-155-98-07, 50-155-98-7, NUDOCS 9810200212
Download: ML20154M257 (15)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lil Docket No:

50-155 License No:

DPR-06 Report No:

50-155/98007(DNMS)

Licensee:

Consumers Energy Company Facility:

Big Rock Point Restoration Project Location:

10269 U.S. 31 North Chadevok, MI 49720 Dates:

August 27 - October 7,1998 Inspectors:

R. J. Leemon, Senior Resident inspector i

W. G. Snell, Health Physics Manager P. W. Harris, NRC Project Manager R. B. Landsi.lan, Project Engineer J. R. Kniceley, Security Specialist Accompanying Personnel:

D. Minnaar, Michigan Dept. of Environmental Quality R. Skowronek, Michigan Dopt. of Environmental Quality Approved By:

Bruce L. Jorgensen, Chief Decommissioning Branch Division of Nuclear Materials Safety 9810200212 981014 U

FDR ADOCK 05000155

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l-EXECUTIVE SUMMARY

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Big Rock Point Restoration Project NRC Inspection Report 50-155/98007(DNMS)

l This routine decommissioning inspection covered aspects of licensee management and l

control, decommissioning support activities (including physical security), spent fuel safety, and l

radiological safety.

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 plans.

Facility Manaoement and Control I

e 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 concerns were identified.

e The Defueled Emergency Plan has been reviewed by the Commission, and BRP's requested exemptions to 10 CFR 50.47(b) and 10 CFR 50, Appendix E have been approved by the Commission.

e The materialintegrity of systems, structures and components necessary for the safe storage of spent fuel and conduct of safe decommissioning was being maintained

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e-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 safety, e

Storage of combustible material, operation of fire equipment, and effectiveness of the fire brigade were being monitored and maintained.

The Decommissioning Project has entered Phase B of the Decommissioning Deacon

Altemative Time Line for Major Periods and is on time, on projected dose and on budget.

Physical Security Security inspection by NRC verified compliance with the licensee's approved Physical e

Security Plan (PSP) during the Big Rock Point Restoration Project.

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implementation of the PSP and associated implementing procedures were in e

compliance with NRC criteria.

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Security event reports were adequately reviewed and reported to the NRC.

e PSP revisions, which did not decrease the effectiveness of the security plan, were

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adequately implemented and submitted to the NRC.

. Security personnel were knowledgeable of their duties and responsibilities.

e Soent Fuel Safety

e The safety of the fuel in the spent fuel pool was being maintained.

Radioloaical Safety i

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Radiological safety activities were being conducted safely and in compliance with applicable requirements.

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B9Dort Details Summary of Plant Activities During the inspection period, equipment not necessary for the safe storage of spent fuel and

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potentially hazardous components and materials was removed from the facility. Also,

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additional plant systems were classified as not needed for safe storage of fuel. The Decommissioning Project has entered Phase B of the Decommissioning Deacon Alternative Time Line for Major Periods and is on time, on projected dose and on budget.

1.0 Facility Management and Control 1.1 General 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 and findings are detailed in the sections below.

1.2 Oroanization. Manaaement and Cost Controls at Permanentiv Shut Down Reactors (36801)

1.2.1 General The inspector selectively reviewed the licensee's activities involving overall management and control of the decommissioning process. The effectiveness of the licensee's review of regulatory information applicable to the facility was selectively examined.

1.2.2 Manaaement and Oraanizations Chanaes a.

Inspection Scope (36800)

The inspector evaluated licensee decommissioning organization changes and verified that key positions were filled by qualified persons.

b.

Observations and Findinac

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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 Point (BRP) and the engineering manager and the scheduling and project control manager were jointly assigned the plant manager's duties until the development of a new decommissioning organization.

On September 14,1998, BRP functional organizational changes were made. The new organization realigned the department managers and their responsibilities. The site general manager also assumed the duties and responsibilities of the plant manager.

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The present functional organization is headed by the site general manager and consists of five departments. The five departments are: (1) operations, cost engineering and scheduling; (2) engineering and licensing; (3) purchasing and material services; (4) planning maintenance and construction; and (5) radiation protection and environmental.

Several key personnel were moved from one department to another to improve the decommissioning functions.

c.

Conclusion

' Sensee management and organizational changes met established requirements

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and appeared gauged to improve the effectiveness of decommissioning activities at BRP.

1.3 Safety Reviews. Desian Chanaes, and Modifications at Permanentiv Shut Down Reactors (37801)

1.3.1 Genera.1 The inspector examined the licensee's safety review program to ascertain that the program was eFective 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 Specifications (TSs) and the Quality Assurance Plan.

1.3.2 Procedures and Modifications Reviewed by Plant Safety Review Committee (PRC)

The inspector determined that there were no required change to TSs, no Unresolved Safety Questions (USQs) identified, and the requirements of 10 CFR 50.82 were met for the following procedures and modifications reviewed by the PRC:

e D2.1.1 Shift Operations e

Volume 17 Quality List e

Volume 2 Plant Operating License and Technical Specifications e

DOP3 Spent Fuel Pool Operation e

MA 98039 Repower the EDG Autostart Circuit to the Station Battery e

MRVG-1 Removal of Reactor Vessel Head e

TV-60 Fuel Pool Clearance and Flow Non-Obstruction Verification e

TV-59 Fuel Pool Heatup Test

DEP Defueled Emergency Plan

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Acronyms for above list D

Decommissioning Procedure DOP Decommissioning Operations Procedure MA Minor Alteration MRVG Maintenance Reactor Vessel TV Test Variable Time Schedule DEP Defueled Emergency Plan c.

Conclusions The licensee adequately justified their conclusions that their planned decommissioning activities did not represent a change to TS requirements,

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i unreviewed safety question, or condition contrary to the requirements of L

10 CFR 50.82(a)(6) and (7). Further, no safety concems were identified.

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1.3.3 Monitored Decommissionina Activities The inspector attended licensee meetings where the planning, reviewing, assessing, l

and scheduling of decommissioning activities were observed. The Inspector ascertained that activities were in accordance with licensed requirements and l

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docketed commitments as stated in 10 CFR, TS, Final Hazards Summary Report (FHSR), PSDAR, and emergency plan.

1.3.4 Defueled Emeroency Plan The Commission on September 30,1998, completed its review of the BRP Defueled Emergency Plan (DEP); and the Commission issued BRP's requested exemptions from 10 CFR 50.47(b) and Appendix E to 10 CFR part 50 to allow BRP to discontinue offsite emergency planning activities and reduce the scope of onsite emergency planning as a result of BRP's permanently shutdown and defueled status.

1.3.5 Plant Systems and Components Removod 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:

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reactor depressurization system o

circulating water system o

turbine lube oil system o

condensate system o

portions of instrument and service air system uninterruptable power supply (UPS) Battery A removed o

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e main generator casing removed e

upper turbine casing removed cleanup demineralizer sample sink removed e

turbine, condenser, and condensate pump room electrical isolations completed e

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control rod drive accumulator rooms electricalisolations completed l

condensate pump room mechanical isolation completed e

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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 process.

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Plant modifications that were in progress during the inspection period were:

e Installation of a decommissioning power system.

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Pianning for the altemate radwaste domineralizer and filter system. The resin retention element in the plant radv'.ste demineralizer failed and was permanently out of service, e

Installing decommissioning altemate air and nitrogen bottles to control air operated valves and dampers. This modification will allow removal of the

station air system, i

e Planning for dry cask storage of spent fuel.

e Planning for radiological hot spot removals in the steam drum area

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e Soil bcre hole samples for the dry fuel cask storage pad I

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 unreAwed safety questions were developed by the changes.

1.3.7 Manaaed Plant Hazard Reductions

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One hazard removed from the plant during the inspection period was the UPS Battery

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A (as a reduction to electrical hazards). To date, approximately 34 percent of the asbestos on piant systems has been removed (as a reduction to biological hazards).

. 1.4 Decommissionina Performance and Status Review at Permanentiv Shut Down

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Reactors (71801)

1.4.1 General The status of decommissioning, &nd licensee and contracted workferce conduct of decommissioning activities in accordance with licensed requirements and commitments were evaluated. Control and conduct of facility decommissioning were

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examined to verify compliance with the license and TS requirements and commitments described in the updated FHSR, and Post-Shutdown Decommissioning Activities Report. Specific events and findings are detailed in the section below.

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1.4.2 Plant Tours to Evaluate Material Conditions. Housekeepina. and Fire Protection 1.4.2.1 Material Conditions a.

Inspection Scope The inspector conducted plant tours to evaluate the materialintegrity of systems, structures and components (SSCs) necessary for the safe storage of spent fuel and conduct of safe decommissioning.

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Observations and Findinos After conducting piant tours, the inspector determined the material integrity of SSCs important to safe storage of spent fuel was being maintained. The inspector discussed tour observations with plant management. The inspector also observed that plant management was actively monitoring plant material conditions.

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Conclusion The materialintegrity of SSCs necessary for the safe storage of spent fuel and conduct of safe decommissioning was being maintained.

1.4.2.2 Housekeepina a.

Inspection Scope The Inspector conducted plant tours to observe and assess the status of facility housekeeping. The inspector also assessed whether field conditions would contribute to safe decommissioning and or would represent conditions adverse to plant or personnel safety.

b.

Observations and Findinas The inspector's observations focused on the areas adjacent to and containing SSCs necassary for the safe storage of spent fuel, radiological effluent control, or radiation I rotection and monitoring. The inspector determined that all areas of the plant wero 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 hazards.

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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 safety.

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1.4.2.3 Fire Protection a.

Inspection Scope The inspector conducted plant tours to obsente and assess the storage of combustible and flammable materials. The inspector also determined the presence and effectiveness of the site fire brigade.

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Observations and Findinas 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 i

use. The inspector also determined that installed fire detection and suppression systems were effectively maintained, surveillances were performed, and the equipment was capable of performing the intended functions.

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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 tne fire hazard.

1.5 Decommissionina Deacon Attemative Time Line for Maior Periods in July 1998, the BRP Decommissioning Project completed Phase A (Mobilization and Hazard Reduction) and started Phase B (System and Reactor Pressure Vessel intemals Removal) of the Decommissioning Deacon Altemative Time Line for Major Periods as presented in Figure 1 of the Post-Shutdown Decommissioning Activities Report. The Decommissioning Project at BRP is on time, on dose projection and on budget. No problems were noted in the review of thase activities.

2.0 Decommissioning Support Activities

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2.1 Maintenance and Surveillance at Permanentiv Shut Down Reactors (62801)

2.1.1 General 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 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,

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Appendix B requirements.

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2.1.2 Dismantiement Activities Dismantlement activities observed by the inspector during the period were:

o turbine upper casing removal e

generator casing removal e

cleanup domineralizer sample sink removal

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The inspector observed that proper maintenance and health physics survey practices were performed during these activities.

2.1.3 Spent Fuel Pool (SFP) Heatuo Test TV-59, " Fuel Pool Heatup Test," was changed from a monthly to quarterly test. On October 1,1998, the temperature of the SFP was 72* F and the heatup rate was 0.32' F/hr. The time for the SFP to heat from 80' F to 150' F was 10.16 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 heats

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and the fuel decays away, the amount of time for the licensee to respond to loss of cooling in the SFP will be increased.

2.2 Physical Security Assessment at Permanentiv Shutdown Reactor (81700)

2.2.1 General A security inspection was conducted to ensure compliance with the licensee's approved Physical Security Plan (PSP) during the Big Rock Point Restoration Project.

Also discussed during the inspection were the proposed security plan changes which are being submitted, by the licensee, to the Office of Nuclear Reactor Regulation (NRR) Reactor Security Specialist as exemptions to the regulations. This inspection was conducted through a review of selected records, interviews with personnel, and direct observation of work activities in the area of physical security.

2.2.2 Safeauards Prooram implementation (81700)

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Inspection Scope The inspector reviewed the Big Rock Point Safeguards Program to determine whether physical security requirements were implemented in accordance with the requirements of the PSP and site security procedures, b.

Observations and Findinas To determine if the security program was adequately being implemented the inspector toured the Owner Controllec Area, Protected Areas (pas) and Vital Areas and observed the integrity of the fences, gates, alarm systems and the vehicle barriers. Fences, gates, assessment and detection systems, and the vehicle barriers were intact, adequately maintained and operable. Access control search equipment was adequately utilized and functioned as required. Personnel requiring access were identified, badged, and escorted as required. Packages and vehicles were inspected

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by security officers at the entrance to the pas as required by the PSP, Security force manning levels were maintained as required by the PSP.

All the officers were armed with a handgun and equipped with a radio. The inspector witnessed radio tests and concluded that there was appropriate communication capability. Equipment observed within the alarm stations and the Access Facility functioned as designed and the facilities were adequately manned. Maintenance support for security equipment seemed timely and adequate.

The inspector also interviewed officers posted and on patrol and found them to be knowledgeable of their duties and responsibilities. The inspector reviewed selected security procedures, post orders, and other security documents pertaining to security performance and determined that they were adequately being maintained. The security procedures provided adequate guidance for security officer duties.

Security program audits were conducted as required and concluded that the security program meets PSP requirements and is effective at providing physical protection of vital and pas in accordance with the PSP and Implementing Procedures.

The Headquarters NRR Reactor Security Specialist responsible for security plan reviews, changes and approvals accompanied the inspector during this inspection.

The licensee discussed their proposed reductions to the security regulations and security plan requirements. The licensee was informed that the suggested changes would need to be submitted to NRR as exemptions to the regulations. Once the exemptions are approved the licensee could implement those changes and change their security plan under 10 CFR 50.54 (p).

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Conclusions Through observations, interviews, independent verification and records review the inspector verified that the licensee is in compliance with PSP commitments.

The inspector concludod that security measures are effectively in place, procedures are adequate, training is effective and that the licensee is meeting the requirements of the PSP. Security equipment functioned as designed and procedures and post orders reviewed were adequate.

3.0 Spent Fuel Safety 3.1 General The inspector evaluated the performance or condition of SSCs associated with storage, control, and maintenance of spent fuelin a safe manner.

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3.2 Soent Fuel Pool Safety at Permanentiv Shut Down Reactors a.

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, local valve lineup and power supply. The inspector reviewed station logs and held discussions with the licensee, b.

Observations and Findinas The inspector reviewed the Nuclear Safety Indicators Graph, Auxiliary Operator logs

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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 insoector also observed that foreign i

material controls were being used in and around the SFP.

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Conclusion The safety of the fuelin the SFP was being maintained.

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4.0 Radiological Safety 4.1 Occupational Radiation Exposure (83750)

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Numerous aspects of licensee processes to minimize occupational radiation exposure j

were selectively examined in order to evaluate overall radiation safety and to provide i

for early identification of potential problems. Areas examined included: audits and

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appraisals; planning and preparation; training and qualifications of personnel;

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extemal exposure control; intemal exposure control; control of radioactive materials and contamination; surveys and monitoring; and maintaining occupational exposure as low as rcasonably achievable (ALARA).

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The decommissioning project dose for the year 1998 to date was 85.2 Person Rem.

The total decommissioning project dose to date was 115.7 Person Rem compared to the decommissioning project dose goal of 700 Person Rem.

The licensee tracks radiation contaminations to monitor efforts to minimize total

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radiation exposure throughout the decommissioning. This is a measurement of the effectiveness of the radiological protection program and radiation worker practices to minimize radiation exposure and contamination to plant workers. The licensee has a good performance record in contamination control. To date,99.95 percent of the entries into the radiological controlled area have not resulted in contaminations, 44,331 entries were made, with 31 of these entries resulted in minor contamination.

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No problems were noted in review of these activities.

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4.2 Radioactive Waste (Radwaste) 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 environment; and to ensure that required radiological environmental monitoring programs were effectively implemented. No problems were noted in review of these activities.

During the inspection period two Michigan Department of Environmental Quality representatives visited the facility. The representatives accompanied the inspectors on tours of the facility, observed the collection of a water sample from the facility's discharge channel and inspected the operation of the licensee's in-situ gamma spectroscopy system. The Michigan representatives also toured the Waste Facility and interviewed selected individuals from the licensee's radiation protection program.

4.3 Solid Radwaste Manaaement and Transportation of Radioactive Materials (86750)

l The inspection included an evaluation to determine whether the licensee properly 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 area.

4.4 Conclusions Radiological safety activities were being conducted safely and in compliance with applicable requirements.

5.0 Exit Meeting Summary The security inspection scope and results were summarized and discussed with the plant management during an exit briefing on September 24,1998. There were no dissenting comments expressed by the licensee.

The inspector presented the remaining inspection results to members of licensee management

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L at the conclusion of the inspection on October 7,1998. The licensee acknowledged the findings presented. The licensee did not identify any of the documents or processes reviewed by the inspector as proprietary.

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l PARTIAL LIST OF PERSONS CONTACTED R. Baker, Bums Security M. Bourassa, Licensing Supervisor

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

L. Potter, Maintenance Supervisor K. Powers, General Manager J. Rang, Business and Regulatory Services Manager G. Rowell, Corrective Action Supervisor G. Szczotka, Manager Nuclear Performance Assessment Department W. Trubilowicz, Scheduling and Project Control Manager M. VanAlst, Security Manager R. Wills, Radwaste 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

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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 l

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Operational Safety Verification IP 71801:

Decommissioning Performance and Status Review at Permanently Shut Down Reactors IP 81700 Physical Security Program for Power Reactors IP 83750:

Occupational Radiation Exposure IP 84750:

Radwaste Treatment, Effluent and Environmental Monitoring IP 86750:

Solid Radwaste Management and Transportation of Radioactive Materials IP 92700:

Onsite Followup, Written Reports or Non-routine Events at Power Reactor Facilities IP 92702:

Followup On Corrective Actions For Violations and Deviations

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LIST OF ACRONYMS USED j

ALARA As Low As Reasonably Achievable BRP Big Rock Point CFR Code of Federal Regulations NRC Nuclear Regulatory Commission

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NRR Office of Nuclear Reactor Regulation

'PA Protected Area PSP Physical Security Plan PRC Plant Reviev! Committee Radwaste Radioactive Waste SE Safety Evaluation-SFP Spent Fuel Pool SSCs Systems, Structures and Components TS Technical Specification USQ Unresolved Safety Question VA Vital Area LICENSEE DOCUMENTS REVIEWED Physical Security Plan - Revision 32, dated 9/9/97 Nuclear Performance Assessment Department Audit PA-98-07, conducted 6/98 Borg-Wamer Protective Services Compliance and Performance Audit, conducted 9/98 Other licensee documents reviewed and utilized during the course of this inspection are specifically identified in the " Report Details" above,

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