IR 05000155/1999002
| ML20206B746 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 04/26/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20206B744 | List: |
| References | |
| 50-155-99-02, 50-155-99-2, NUDOCS 9904300047 | |
| Download: ML20206B746 (27) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION lil Docket No: 50-155 License No: DPR-06 Report No: 50-155/99002(DNMS)
Licensee: Consumers Energy Company j l
t Facility: Big Rock Point Nuclear Power Plant i I
l Location: 10269 U.S. 31 North Charlevoix, MI 49720 )
Dates: February 26,1999 - April 15,1999 Inspectors: R. J. Leemon, Reactor Decommissioning Inspector R. B. Landsman, Project Engineer P. W. Harris, License Project Hanager
. D. W. Nelson, Radiation Spe& list Approved By: Bruce L. Jorgensen, Chief Decommissioning Branch Division of Nuclear Materials Safety I
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9904300047 990426 "
gDR ADOCK 05000155 PDR
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EXECUTIVE SUMMAR Big Rock Point Restoration Project NRC inspection Report 50-155/99002(DNMS)
This routine decommissioning inspection covered aspects of facility management and control, decommissioning support activities, spent fuel safety, and radiological safet e Overall, major decommissioning activities were properly controlled and were performed in accordance with schedules. The licensee effectively monitored both the conduct and the cost of decommissioning. The spent fuel pool clean out project was started and phase one (preparing control rod blades for crushing) was completed. Radiological activities were performa? 3 appropriate as-jow-as-reasonably-achievable (ALARA)
elements included in tt Facility Manaaement and Contrc e The licensee is effectively monitoring assessing and controlling the conduct and cost of decommissionin e The licensee made annual reports of occupational exposures and of changes, tests or experiments for 1998 in accordance with regulatory requirements. These reports accurately described the activities requiring reporting pursuant to Technical Specification 6.7.1 and 10 CFR 50.5 e After detailed challenging discussion for modifications to the plant and changes to plant procedures, the safety review committee found no unreviewed safety questions during this inspection perio e The Nuclear Performance Assessment Department appears to be effectively performing their function, and the corrective action system is functioning as designe e The material integrity of systems, structures and components necessary for the safe storage of spent fuel and conduct of safe decommissioning was being maintained, housekeeping was good, and control of combustible materials and operation of fire equipment were properly maintaine Decommissionina Support Activities e The correct actions were taken by the reactor deck crew related to the questionable condition of the crane hoo e Good worker performance was observed during the first phase of the spent fuel pool (SFP) clean out projec * Some of the licensee's original contingency plans for the SFP clean out project were narrowly focused. Improvements were made in scope and depth when limitations were identified to plant managemen p-
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e~ The licensee has a project for year 2000 computer problems; project items are
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scheduled to be completed by the end of June 199 Spent Fuel Safety e' .The safety of the fuelin the SFP was being maintaine Radioloalcal Safety
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e Elements of the Radiation Protection and Environmental Services Master Plan are -
being resolved and elements behind schedule are being manage e At the end of the inspection period, radiation work permits and Al. ARA briefings for known job tasks were going well; but for emergent work activities ALARA planners were not receiving the needed time and job specifics to provide effective ALARA planning before the job task was planned on being executed. This interaction is being resolved by the license e A incident involving electricians crossing a high radiation barrier without proper authorization raised questions about certain aspects of the radiation safety program; however, the licensee's investigation and response were excellen o- Radiological control activities in the areas of effluents and solid radwaste 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,
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additional plant systems were classified as not needed for safe storage of fuel. All equipment was removed from the main plant control room. Chromates were removed from plant water
. systems. The spent fuel pool (SFP) clean out project was started and phase one (preparing control rod blades for crushing) was complete .0 - Facility Management and Control General The inspector conducted frequent reviews of ongoing plant activities and atter.ded 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 Oraanization. Manaaement. and Cost Controls at Permanentiv Shut Down Reacton (36801)
-1. faeneral 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 w'as selectively examine .2.2 - Licensee's Use of Decommissionino Fund Inspection Scor>e The inspector reviewed the licensee's processes and controls for the monitoring and i
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. usage of decommissioning funds.. This review focused on site-specific f decommissioning activities and the licensee's financial monitoring of these activities to provide reasonable assurar ce that the expenditure of decommissioning monies is in -
accordance with regulatory requirements. A significant part of this inspection involved the assessment of planning and scheduling tools utilized by the Big Rock Point (BRP)
staff in the planning and execution of decommissioning activitie Observations and Findinos -
The licensee has a number of financial summary reports that are used by plant management to assess the status of money expenditure on particular decommissioning activities. These tools ranged from the daily planning summaries to more detailed reports that itemize particular decommissioning activities based on scheduled accomplishment and completion dat V .
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The BRP management conducts a Daily Site Leadership Meeting. During this meeting, management review's a safety summary describing the operability of structures, systems and components (SSCs) important to the safe conduct of decommissioning and spent fuel storage, the status of decommissioning activities, critical path activities,
. an overall monthly budgeting and funding status, and bar charts and spread theets detailing specific decommissioning activities. These charts and spread sheets identify the activities, deviations from planned start and completion dates, and the site department and individual holding lead responsibility. A 6 month look ahead schedule identifies the system, work description and projected schedule for longer-term planning and schedulin Senior BRP management closely monitors decommissioning activities and budgeting by review of periodic reports from the Operations, Cost Engineer and Scheduling Manager to the Site General Manager. For example, on February 26,1999, the operations department reported on condensate pump room dismantlement, which was scheduled to take 6 % months at a cost of $129,000. The project was completed 13 days ahead of schedule and at a cost savings of $65,000 due to, as the report stated, an effective use of small work crews, support organizations, and equipment as well as other planning considerations. Further, no lost time injuries occurred and radiation dose came in at 203 mrem versus an expected dose of 1350 mrem. The inspector reviewed other decommissioning activities as listed belo Decommissionina Activity Percent Completed Cost To Date (Ski Cost Planned (Sk)
Air System 95 173 187 SFP Clean Out 2 81 127 AC Power System 95 4,651 4,571 SFP Cooling Skid 32 111 126 Accumulator Rooms 20 24 80 Asbestos Abatement 55 877- 954 Altemate Liquid Radwaste 49 195 294 Attemate Monitoring System 50 336 524 Notes-(1) Dollars are rounded to nearest thousand (2) Data reflect"to date" values In addition, the licensee utilizes a spread sheet summary report itemizing such activities as radioactive waste processing, labor costs, emergency planning fees, radiological site characterization, hazard abatement projects, SSCs dismantlement, and decontamination. The report provides a monthly breakdown and a running total of financial expenditures, commitments, and receivables for the year and clearly tabulates cost verses activit For 1998, Consumers Energy budgeted $51.9 million and spent $51.8 million, with a variance of approximately $100,000. This budget included approximately 206 large activities with 79 percent being completed on or ahead of schedule and 7 percent being completed behind schedule, with an average 21 days behind schedule. With regard to radiation protection (RP), the activities performed in 1998 resulted in an actual occupational dose of 104 person-rem against a planned budget of 118 person-rem, thereby indicating a dose savings of 14 person-re .
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i On March 28,1998, the licensee provided to the Commission, in accordance with 10 CFR 50.82, Revision 2 to its Post-Shutdown Decommissioning Activities Report
. (PSDAR). The report showed that approximately $293.9 million dollars (in constant 1997 dollars) are needed to decommission the BRP facility. On March 22,1999, the Michigan Public Service Commission (MPSC) authorized collection of $89.2 million
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above the $184 million that was in the Decommissioning Trust Fund as of December 31,1997. The licensee currently estimates that these funds along with the projected eaming are sufficient to safely decommission the BRP facility, and the licensee is continuing to work with the MPSC to assure sufficient fundin Conclusion Based on the activities and processes reviewed, the licensee is effectively monitoring, assessing and controlling the conduct and cost of decommissioning. The reports and summaries used at the site are routinely evaluated by the BRP management staff and provide pertinent information as to the financial conduct of dismantlement and decontamination activities. The 1998 overall cost of decommissioning activities appears commensurate with that budgeted and accomplishe .2.3 Occupaticnal Exposure Annual Report for 1998 Inspection Scope The inspector examined the 1998 Annual Report Documenting Occupational Exposure for the BRP nuclear plant to review whether the reported occupational radiation doses are consistent with plant reports and reported in accordance with regulatory requirement Observations and Findir as BRP Technical Specification (TS) 6.7.1, " Annual Occupational Radiation Exposure Report," requires that an annual report shall be submitted prior to March 1 of each yea This report shall tabulate the numbers of facility, utility, and other personnel (including contractors) receiving radiation exposures greater than 100 mrem during the year, along with their associated dose according to work and job functions. The dose assignments may be based on pocket dosemeter, thermoluminescent device, or film badge measurements and small exposures less than 20 percent of the individual total dose need not be accounted for. Information regarding individuals receiving less than 100 mrem occupational radiation dose is contained in the licensee's submittal pursuant to 10 CFR 20.2206, " Reports of Individual Monitoring."
in a licensee letter dated February 23,1999, Consumers Energy reported that 207 persons at the BRP facility received greater than or equal to 100 mrem. Of these individuals,24 percent were station employees,16 percent were Consumers Energy or utility personnel, and 60 percent were contractors. Further, Consumers reported that these 207 individuals represented a total dose of 104.13 person-rem of which station personnel received 22 percent of the total, utility personnel 13 percent, and contractors 65 percen i l
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As stated in Revision 2 of its PSDAR, Consumers estimated that approximately 700 person-rem will be necessary to decommission the BRP facility. Further, the licensee stated that doses will be maintained as-low-as-reasonably-achievable (ALARA). Conclusions The annual report of occupational exposure was made in accordance with regulatory requirements. Further, the information reported was consistent with TS requirements and the guidance in Appendix A, of Regulator Guide 1.16, " Reporting of Operating information."
1.2.4 License's Annual 10 CFR 50.59 Report to the Commission Inspection Scope The inspector reviewed the licensee's October 1,1998, letter to the Commission documenting the facility changes, tests, and experiments conducted from October 8, 1997 to October 1,1998, to evaluate whether the 10 CFR 50.59 reporting requirement was met and whether any activity resulted in an unreviewed safety question (URSQ) or change to TS requiremen Observations and Findinos The inspector reviewed the following changes or experiments reported by the licensee in its October 1,1998, letter. The licensee did not report any tests conducted this period that met the reporting requirements of 10 CFR 50.5 Chances Description 97-009 Electric breaker 72-11 676-04 Electrical and sewage to maintenance building 0694 HEPA filter addition to containment HVAC system Procedure Chanoes Descnotion D5.21 Water chemistry guideline changes D Safety Review Committee T1-09 Primary system heat balance T1-02 Primary system leakage test Consumers also described the changes made to their Final Hazards Summary Report (i.e., the SAR). The Final Hazards Summary Report changes were predominantly made to accurately describe the facility following the permanent cessation of power operations that occurred on August 30,1997, and the permanent removal of all fuel from the reactor vessel on September 20,1997. In particular, the licensee revised the descriptions of those SSCs no longer necessary for public health and safety. These systems included but were not limited to reactor and turbine generator operatio %
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. Conclusion The licensee's annual report of changes, tests or experiments for 1998 accurately described the activities requiring reporting pursuant to 10 CFR 50.59. The descriptions were of sufficient detail to provide adequate information of activity conducted. The inspector identified no activities representing a change to TS requirements of URS .3 - Safety Reviews. Desian Chances. and Modifications at Permanently Shut Down Reactors (37801) .
I 1.3.1 General The inspector examined the licensee's safety review program to ascertain that the )
program was effective at identifying potential URSQs in accordance with 10 CFR 50.5 ]
The activities of the licensee's onsite safety review committees (SRC) were evaluated to determine whether they were fulfilling their respective charters, the requirements of Defueled Technical Specification (DTS) and the requirements of the quality assurance (QA) pla ]
1.3.2 Safety Review Committee Review of Modifications and Procedures Inspection Scope (42700)
The inspector observed several SRC meeting during this inspection perio j i Observations and Findinas When attending SRC meetings, the inspector observed that a quorum was present and that the members understood the change to the procedure or plant modification under discussion. The members held challenging discussions on items and at times retumed procedures or modifications to the author for enhancements prior to determining that the change did not create an URS SRC members discussed and reviewed procedure changes. Technical items were discussed until the words in the procedure were clear, accurate, and had the same meaning to all members of the committee. Procedure changes related to processing 10 CFR 50.59 and 10 CFR 50.82 evaluations were retumed to the author for enhancements. These procedure changes would be retumed to the SRC at a later date for approval. Human factors were also considered in the changing of these procedures. Each procedure change was evaluated to determine if an URSQ was created. None were create Based on these observations, the inspector determined that there were no issues which required changes to TSs, no URSQs were loentified, and the requirements of
.10 CFR 50.82 were me Conclusion After detailed challenging discussion for modifications to the plant and changes to plant procedures, the SRC found no URSQs during this inspection perio Y ]
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i 1.3.3 Monitored Decommissionina 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, DTS, Updated Final Hazards Summary Report, PSDAR, and Defueled Emergency Plan (DEP). Decommissioning activities monitored by the inspector were as described in the following section .3.4 Plant Systems and Comoonents Removed from Service Plant syr,tems and components determined not needed for the safe storage of spent fuel and permanently removed from service during this inspection period were:
a portions of the control rod drive system
- portions of main turbine casing (the casing is now completely removed)
. station battery
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main 138 KV transformer portions of plant control room (all equipment has been removed)
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- SPF cooling system (chromates have been removed from the water)
- reactor cooling water system (chromates have been removed from the water)
- post incident system (chromates have been removed from the water)
- containment cooling system (remains in service but the chromates have been removed from the water)
1.3.5 Plant Modifications 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 Plant modifications that were in progress or completed during the inspection period were:
. Planning for dry cask storage of spent fuel
- Completion of the chemical decontamination of chromated systems
- Execution of the SFP clean out project j 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, .
I the inspector determined that no URSQs were developed by the above changes, and the changes were within the requirements of 10 CFR 50.8 l 1.3.6 Manaaed Plant Hazard Reductions The primary hazardous materials removed from the plant during the inspection period were asbestos, and chromates, which are biological hazard ,
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Approximately 80 percent of the asbestos on plant systems has been remove Chromates (a toxic substance) have been removed from the water in plant system The main station battery has been removed from the station power room. The plant developed a colored tape and colored plastic bag system to bag hazardous material at the work site so that the hazardous material does not end up in the wrong waste stream. Items in the plant that contain hazardous material are now marked with purple tape containing the labeling " Hazardous Material." Self-Assessment. Auditina. and Corrective Action (40801)
1.4.1 General The licensee's controls for identifying, resolving and preventing issues that degrade safety or qt'ality were examin6d, including self-assessments, auditing, corrective actions, SRCs, root cause evaluations and third party reviews. The inspector also attended corrective action review boards (CARBs) and management review boards (MRBs).
The QA plan and applicable implementing procedures formed the basis for the inspection. 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 Independent Assessment of BRP Activities Inspection Scope (40801)
The inspector held a discussion with Nuclear Performance Assessment Department '
(NPAD) assessors, attended NPAD exit meetings, reviewed NPAD audits and reports, and condition reports written by NPAD. The condition report provides tracking of the finding and assigns resources to determine the root cause of the finding so that the root cause can be correcte The inspector also observed NPAD inspectors observing and assessing the licensee performance in the plant. The effectiveness of the corrective action system was evaluated, Observations and Findinas The inspector observed NPAD actively monitoring decommissioning activities and ]
pre-job briefings, and providing management timely feedback on their concems. The onsite leader of NPAD meets with plant management at a planned monthly meeting to discuss NPAD's findings, and to answer any questions on the findings. Conditions identified by NPAD as adverse to quality are entered into the plant corrective action system to ensure followup. NPAD appeared to be effectively performing its missio When the licensee discovered concems or off normal conditions, the appropriate condition report was written and dispostioned by the CAR k ,
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7 The inspector reviewed condition reports, closed corrective actions for condition L'
reports, and reviewed trend reports for the corrective action system. The inspector also attended CARBs and MRBs. The corrective action system is being managed, generally correct root causes are being identified, and corrective actions are being closed in a reasonable tim Conclusion NPAD appears to be effectively performing their function, and the corrective action system is fmetioning as designe .5 Decommissionino Performance and Status Review at Permanentiv Shut Down Reactors (71801)
1.5.1 General Decommissioning, and licensee and contracted workforce conduct of decommissioning activities were evaluated to determine if these activities were performed in accordance with licensed requirements and commitments. Control and conduct of facility decommissioning activities were examined to verify the requirements of the license, and DTS, were followed; and the requirements and commitments described in the Updated Final Hazard Summary Report, PSDAR, and DEP were followed. Exemptions from certain physical protection requirements were granted by the NRC. Specific events and findings are detailed in the section belo .5.2 Exemption from Certain (10 CFR Part 73) Physical Protection Reauirements On March 29,1999, the NRC granted an exemption to BRP from certain requirements of 10 CFR Part 73, to allow the implementation of a safeguard contingency plan
- reflecting the permanent shutdown and defueled condition of the BRP Nuclear Plan This exemption is authorized by law and will not endanger life or properly or the common defense and security, and is otherwise in the public interes This exemption will allow BRP to change the security plan. Changes to the security plan will be inspected at a later date by a Region ill Security Specialis .5.3 Plant Tours to Evaluate Material Conditions. Housekeepina. and Fire Protection 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 decommissioning, to observe and assess the status of facility housekeeping, and to evaluate fire protection issues such as control of combustibles, condition of fire fighting equipment and presence of the plant fire brigad b; Observations and Findinas After conducting plant tours, the inspector determined the materialintegrity of SSCs of systems important to safe storage of spent fuel (ISSSF) was being maintained. The
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inspector discussed tour observations with plant management. The inspector also observed that plant management was actively monitoring plant material condition The inspector's housekeeping observations focused on the areas adjacent to and containing SSCs necessary for the safe storage of spent fuel, radiological effluent control, or radiation protection and monitoring. The hspector 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 hazards, Pre-job briefings for work on the reactor deck contained discussions of possible tripping hazards because of the wire and hoses spread across the reactor deck. General area housekeeping was good with no areas of inspector concem during this perio 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 inspector determined that fire fighting equipment and stations were properly maintained and ready for 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 function Active dismantlement activities including cutting and grinding were performed with the proper fire protection in place. Not even a small fire was started during these activitie Conclusion Material integrity of SSC's important to safe storage of spent fuel and safety in decommissioning was being maintained. Housekeeping was good. Control of combustible materials and operation of fire equipment were property maintained, and not even any small fire were started during dismantlement activitie Onsite Followuo. Written Reports of Non-routine Events at Power Reactor Facilities (92700)
1 6.1 (Closed) VIO 50-155/97004-01: The violation was for two examples of failure to follow procedure in initiating and clearing equipment tagouts related to challenging the control room and the main steam isolation valve with the reactor operating. The inspector reviewed the corrective actions and verified that the specified procedural changes had been made. However, the licensee had not accomplished many dismantlement activities at the last review of this issue. Since then, major dismantlernent activities have been performed and activities ISSSF and important to monitoring and control of radiological hazards (IMCRH) have been performed without any more related tagging errors. The plant electrical power system has been shifted over to a new decommissioning power system to help reduce the possibility of electrical tagging errors with the continuing dismantlement of the plant. When an error does occur, the work is stopped and a condition report is written and evaluated before electrical work continues. This violation is close .6.2 (Closed) IFl 50-155/97012-02: Implementation of Fitness for Duty (FFD) program enhancements. The licensee has enhanced its FFD. Condition Report C-BRP-97-
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0372, FFD Program Deficiencies, describes the programs potential weaknesses relating to the potential to subvert the drug testing process, the recommendations and corrective actions that resulted from the licensee's corporate legal department investigation, and documentation of the completion of the corrective actions. The inspector has reviewed the completed condition report and has no further concems with enhancements to the FFD program to subvert the drug test process. This inspection
' followup item is close .6.3 ' '(Closed) IFl 50-155/97015-02: Resolution for positive control over cables hanging in SFP. Inspection Report 97015 raised an issue regarding control of high dose items hanging by cables in the SFP. Cables with high dose items hanging from them are hooked over the SFP rails. The weight of the items varies from 12 pounds to 100 pounds. These cables could be lifted by hand. The dose of the items hung from these cables varies from 3 R/hr to 1700 R/hr at 1 foo The potential for a high exposure from an individual pulling a high-dose item from the pool was identified by NPAD and the inspector and documented in Field Monitor Report FM-B-97-129. The licensee did not initially take positive measures to prevent a person from inadvertently pulling one of these items to the surface and receiving a very high exposur Management subsequently took effective corrective action to place the SFP cover on the pool, making these cables inaccessible. On January 30,1998, a daily order was written stating the covers need to be placed back over the SFP as soon as possible after any work is performed that requires removal of the covers. The licensee also wrote Condition Report C-BRP-97-05344 to track the resolution of this issu Two methods of positive control of the cables have now been put in place:
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The first control measure is a locked outside door to the clothing change room leading to the SFP contaminated area surrounding the pool. The door is beked when the area is unoccupie The second control measure is individual signs attached to each cable stating
" Grave Danger " The Grave Danger Sign contains the following message; Removal of this item from the water could create a VERY HIGH RADIATION ;
AREA (500 RAD /HR at 1 M) HP must be present for handling of this ite ,
On March 2,1999, the sbove Lctions were completed; therefore, this inspector followup item is close .6.4 (Closed) IFl 50-155/98006-01(DNMS): Procedure D1.11, Safety Evaluations. This
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licensee procedure did not provide clear instructions and guidance for implementing 10 CFR 50.59 and 50.82 requirements, in particular, the procedure, in part, confused i the requirements of 10 CFR 50.82(a)(6) and (a)(7), t , not provide clear guidance on the evaluation of radioic ?ical consequences, did not differentiate between an URSQ and a change to a TS requirement, and did not implement Consumers' initiative to define SSCs, ISSSF and IMCRH, respectivel ,
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The inspector reviewed the h:ensee changes to D1.11 and concluded that the revisions adequately resolved the inspector observations identified in NRC Inspection Report 98-006, Paragraph 1.32. The D1.11 revisions were besed on a licensee review and utilization of industry guidancs and applicable regulatory requirements. Procedural wording associated with spent fuel storage, ISSSF, and iMCRH wa clarified to J enhance the readers understanding ot the particular regulatory and gocedure requirement. The licensee's SRC evaluated the inspector's comments ,egarding the j identification of responsibilities for evaluaticq of 10 CFR 50.82(a)(6) and (a)(7) I requirements. This item is close .6.5 (Open) IFl 50-155/98009-02: Development of an attemate containment heating contingency plan for safe storage of fuel and fuel support systems. After reviewing Procedure DOP-9, Heating and Ventilation System, Step 6.1.6.," Cold Weather Loss of Heating Boiler," the inspector concluded that this step weakly provided the necessary contingency plan. At the time of the inspection, the licensee had written a daily order outlining the required steps to provide attemate containment heating. This daily order will be kept in place until the procedure is revised. After the inspector's review of
- Revision 3 to Procedure DOP-9 on April 5,1999, the inspector determined that the proadure had not been revised. The inspector also concluded that management has not given this issue the management oversite that it deserves. The inspector discussed this concem with plant management. The licensee then wrote Condition Report C-BRP-0072, " Commitment to Revise DOP-9, ' Heating and Ventilation System'
not Completed in a Timely Fashion." The recommendation on this condition report is to issue a corrective action to document the commitment to include a contin gency for SFP freeze protection in DOP-9 with a completion date of 5/7/99 and to revise O-VAS-1
" Cold / Warm Weather Checklist" by 6/7/99. This inspection followup item will be reexamined again after 6/7/9 .0 Decommissioning Support Activities 2.1- Maintenance and Surveillance at Permanentiv Shut Down Reactors (62801)
2.1.1 General The inspector 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 evaluate the proper implementation of DTS, and 10 CFR 50, Appendix B requirement .1.2 Dismant(sment Activities (62801)
Dismantlement activities observed or evaluated by the inspector during the period were:
- removal of portions of the control room
- removal of lower turbine casing
- removal of control rod drive system piping
- removal of equipment from the electrical sub station
- removal of equipment and walls of the un-interruptible power supply battery
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- removal of equipment from the electrical room
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relocation of standby diesel generator from outside to inside the plant fenced-in-area The inspector observed that proper maintenance, personnel safety, fire protection, radiation protection practices, and health physics survey practices were performed during these activitie .1.3 . Standby Diesel Moved to Plant Area The standby diesel generator was moved next to the main diesel generator building i and connected to decommissioning electrical power. On March 16,1999, the diesel was load tested and retumed to service. Both diesel generators are now connected to
- backup decommissioning electrical powe .1.4 Reactor Buildino Crane 75 Ton Hook inspechon On April 6,1999, when a worker inspected the reactor building 75 ton hook prior to installing the lifting rig for a cas4, the worked noticed that the hook could be out of alignment (slightly twisted out of plumb). This was brought to the attention of the reactor deck supervisor. Rigging activities related to the cask lift were stopped and the next day a magnetic particle inspection of the book was performed. The hook passed the inspection. The crane records were reviewed by the licensee. This same condition was observed by a maintenance worker during the November 1998 crane inspection but was not documented in the crane's records. After a discussion with the maintenance engineer who observed the hook inspection, the inspector leamed that what appears to be a slight misalignment of about 1/8 of an inch, in a discontinuation of a metal cask forging line on the surface of the hook. The correct actions were taken by the reactor deck crew related to the questionable condition of the crane boo .1.5 Spent Fuel Pool Clean Out Proiect Activities Inspechon Scope The inspector observed various aspects of the SFP clean out project which will involve the removal of all non-fuel bearing components from the SFP. Each component will be surveyed, radioactively characterized, radioactively waste classified, processed,
- packaged, and shipped for burial. The inspector attended kickoff meetings for the project, attended planning meetings, and attended pre-job and ALARA daily briefing The inspector observed the workers perform the above activities in and ,'tound the
. SFP. The inspector also reviewed the SFP clean out project contingency plan Observations and Findinas The SFP kickoff meetings were well organized, had a lot of worker participation by asking questions and generating interactions among the various work groups, and the Al. ARA plan for the project was discussed in great detail. At the kickoff meetings, it was stated that RP had the authority to stop work at anytime that the dose rate or RP practices were in questio w
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At the daily pre-job briefing and ALARA meeting, improvements in the ways to perform work activities leamed from the day before work experiences were discussed. The plan of the day oecame formalized reflecting planned work from thn previous aftemoon's planning meeting. This wasn't the case early in the project. This allowed a better ALARA discussion and a better briefing on the correct RWP.- Early in the project at the
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moming pre-job briefing, there was some confusion as to what work was to be performed and what RWP covered those work activities. Workers were told, if a radiation or electric dosimetry (ED) alarm goes off, place the item back into the pool, and then back away, and the RP technician will evaluate the radiological situation. The ALARA and RWP briefings were well conducted by the RP technician. The plan of the day briefing improved as the project progressed and as the briefing became more fonnal. After the need arose to use contingency plans, other contingency plans were discussed in later plan of the day pre-job briefing Daily work activities were performed well on the reactor deck. When problems were encountered, the supervisors were notified and the activity was stopped until the correct contingency plan was generated and executed or repairs were made to processing equipment. However, one control rod blade (CRB) was processed out of sequence. When it came time to process that CRB the error was realized. This was a human factor error in the second verification process. The two CRBs were similar in radioactive dose characteristics; therefore, there was no shipping or packaging consequence to this error. Condition Report C-BRP-99-0077, " Wrong Control Rod Blade Processed," was written by the license The first phase of the SFP clean out project, which involved processing CRBs in preparation for crushing them (cutting the four upper comers of the blade containing stellite roller balls, and cutting the blade spud off the lower end of the blade), and cutting incore detectors into two pieces (to make them short enough to fit into the shipping cask) was completed with only one personnel error, Conclusion Good worker performance was observed during the first phase of the SFP clean out projec .1.6 Continoency Plans for SFP Clean Out Project Inspection Scope The inspector attended kick-off meetings where the contingency plans for the SFP clean out project were discussed, reviewed the contingency plans and held discussions with plant management about the weakness of some of the plans. Thses plans were developed to reduce radiation dose or to minimize dose consequences of potential problems, consistent with 10 CFR 20 requirements for Al. ARA planning. The inspector also observed the licensee's actions on occasions when_ it became necessary to implement some of the plan Contingency plans were developed by the licensee to be pre-approved actions for likely problems occurring during the SFP clean out projec .
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b. Observations and Findinas Stellite Ball Misses Bucket The first version of this contingency plan stated this could not happen. After a stellite ball fell into fuel channels below the CRB punch, some effort and slightly increased exposure were incurred before the ball was located and retrieved from the channe The licensee then placed a screen under the CRB punch to catch loose ball A few CRBs later the corner of a blade did not cut correctly, and small pieces of the support for the blade handle . support broke and fell on to the screen. This proved the value of having the screen located under the CRB punc Control Rod Blade Handle Breakage The contingency plan for CRB handle breakage was to handle the blade with a hydraulic gripper. While processing the above blade, one side of the handle broke free of the blade. At the time the handle broke, the contingency plan for a CRB handle breakage was not used by the reactor deck crew; however, work was stopped. The contingency plan called for the use of a hydraulic gripper to grip and hold the CRB if the handle brok The licensee held a contingency planning meeting and a plan was developed to move the blade from the CRB punch to a safe storage location in the SFP so that if the blade fell over it would not impact the fuel. This plan was reviewed and approved by the SRC before the plan was executed. The blade was moved using safety wire ropes around the blade. The next day a safe storage location was made available in the SFP. The blade was hanging from the SFP wall when the processing began. The blade (again with the use of wire safety rope) was then moved into this safe storage locatio .
The contractor did not bring the hydraulic gripper with them since they only anticipated this failure during blade compacting operations. The hydraulic gripper was received onsite before any other blades were processed. The hydraulic gripper was used on this blade to complete the processing of the blad Possible Cask Drop in Reactor Vessel The probability of dropping the shipping cask into the reactor vessel is low. The cask weighs 24 tons and the reactor building crane is rated at 75 tons. Also, the cask move is very carefully performe The contingency plan for a shipping cask drop onto the reactor support plate had the following consequences: the reactor vessel support could shear, causing the reactor vessel to fall, rupturing connecting pipe, and releasing reactor vessel water which would be a loss of shielding. If all the shielding water was lost, the dose rate at the reactor vessel flange could reach 12,000 R/h If this event (complete loss of reactor vessel shielding water) did happen the immediate action was for the reactor deck crew to evacuate the reactor deck and the containmen .
The ALARA evaluation concluded that the dose to the reactor deck crew would be about 2 rem per-person for this even In the initial version, the only remedial action plan was to have the reactor vessel head pre-rigged to allow expeditious placement of the head over the fallen reactor vessel, to provide remedial shielding. The inspector concluded that this contingency plan was deficient, in that it did not address personnel in containment other than the deck crew, it did not reduce dose to the recovery personnel, and it did not provide procedural guidance to the operators in the monitor station to handle the event. After the inspector's discussions with the ALARA planner and senior plant management a
' detailed contingency plan was developed by the SFP clean out project team and approved by the SR This new plan was in place and discussed with all workers at the pre-job briefing for putting the shipping cask into the reactor vessel prior to putting the shipping cask into the reactor vessel. On April 6,1999, the shipping cask was placed into the reactor vessel without an incident. The shipping cask will be moved into and out of the reactor vessel about 16 more times, Conclusion Some of the licensee's original contingency plans for the SFP clean out project were narrowly focused. Improvements were made in scope and depth when limitatins were identified to plant managemen .1.7 Status of Year 2000 (Y2K) Computer Problem Plan Inspection Scope The inspector attended management meetings, and performance indicator meetings which discussed the status of the Y2K issue at BRP. The inspector reviewed the BRP Year 2000 Project status of open issues, and held discussions with the engineer responsible for the projec Observations and Findinos The new Plant Monitoring Station equipment was tested during post modification
- testing and wac found to be compliant with making an error free transition into year
> 2000. However, if this equipment fails unexpectedly direct readings by operations I department personnel on equipment rounds will be performe The security computer was tested and will function after December 31,1999. One date related issue (February 29,1999) has a contingency in place. Also, if this equipment fails unexpectedly, a contingency plan is already in place as part of the security pla Items that remain to be upgraded and tested are the plant telephones, the Radiation Protection Management System, and the Maintenance Information System (electronic dosimeters). Remediation of these items is scheduled to be complete by June 15, 199 ,...-
e BRP management plans to augment the onsite staff on December 31,1999, during the transition to the year 2000. Contingency plans will consider loss of essential utilities (offsite electric, normal communication, well water, and the plant heating systems).
Plant systems related to storage of spent fuel are being considered in the contingency
. pla Conclusion The licensee has a project for year 2000 computer problems. The open items in this project will be completed at the end of June 199 NOTE: The licensee requested the following statement for the Y2K information above:
""**"" THIS IS A YEAR 2000 READINESS DISCLOSURE """"" ' 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 Plant Response to Under Voltaae on the 46 KV Line ,
On February 23,1999, because of an error in switching in an offsite sub station, the plant experienced under voltage and three plant busses were de-er:9pized for about 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The inspector monitored the restoration of electrical FLwier from the monitor station. Throughout this loss of power, spent fuel safety was maintained. The licensee wrote Condition Report C-BRP-99-0044, "Under voltage on the 46 KV Line, to Evaluate Corrective Actions and Lessons Leamed from this Event." No Licensee Event Report will be written as it is not required, even though there was a lost of ENS I
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communication. The review of the licensee's corrective action items for the under voltage on the 46 KV Line is an inspector followup item (50-155/99002-01(DNMS)). Spent Fuel Safety a.- Inspection Scope (60801)
The inspector 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
. and power supply. The inspector reviewed station logs and held discussions with the licensee The inspector also inspected the SFP and SFP support system's valve lineups during plant tour Observations and Findinas The inspector reviewed the Auxiliary Operator logs containing SFP parameters and locally monitored SFP level and temperature. The inspector verified the criticality
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monitor was functioning. The inspector also observed that foreign material controls were being used in and around the SF . The operating range for temperature of the SFP is 40 to 80 'F. The DTS SFP 1 temperature limit is 140*F. On April 14,1999, the SFP temperature was 61 *F, the time .
for the temperature to rise to 140*F was 11.4 days. The present SFP heatup rate is 0.29'F/ hour. During this inspector period the SFP attemate cooling system was shut )
off during the time when the SFP clean out project activities were in progress to reduce i the amount of corrosion product getting into the system. Controlling the temperature of
, the SFP within the operating band was with this type of operation was not a proble Conclusion The safety of the fuelin the SFP was being maintaine .0 Radiological Safety General l The inspector conducted reviews of ongoing activities in order to assess the overall RP I program. Specific findings are detailed in the sections belo j Occupational Radiation 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 ear 1y identification of potential problems. Areas examined included: audits and appraisals; planning and preparation; training and qualifications of personnel; extemal exposure control; internal exposure control; control of radioactive materials and
. contamination; surveys and monitoring; and maintaining occupational exposure-ALAR .3 Status of Radiation Protection and Environmental Services Master Plan Inspection Scgpe The inspector discussed the Radiation Protection and Environmental Services (RP&ES)
Master Plan with the RP supervisor and reviewed the status of the open elements in the pro 0 ra ' Observations and Findinos in Inspection Report 50-155/99001(DNMS) details of the RP&ES Master Plan were discussed. This plan was developed to address weakness in the RP&E3 program as ,
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discussed in inspection Report 50-155/98005(DMNS). The plan now also includes elements for improvements in the RP progra Listed below are the elements of the master plan that are still open: ,
- Redesign and implement new access control
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e improve daily waste management activities
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Industrial safety culture enhancement
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Enhance respiratory protection program
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Site characterization
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Source term reduction
.. Develop / revise shielding program
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Hydro laser procurement project
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Radworker deficiency improvement plan *
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Improve radiological survey program and documentation
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Establish decommissioning free release criteria
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Replace electronic dosimetry system *
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RP&ES Department procedure revision project *
Sixteen other elements have been resolved. Three of the above elements are slightly behind schedule but are being managed (*). Conclusion Elements of the RP&ES Master Plan are being resolved and elements behind schedule are being manage .4 Processino and Removal of Materials from the SFP Inspection Scope (83750. 83728)
The inspector reviewed the licensse's progress for planning, processing and removal of
. materials (DRBs, incore detectors, etc.) from the SFP During the inspection the inspector reviewed the following RWPs:
. RWP 899002 Operation personnel performing rounds / inspections / tagging and training activitie RAP B99004 Tours, inspections, evaluations and job planning, security functions except coverage of specific RAP . RAP B993025 Rigging / loading / handling / inspection and mockup ci shipping cas *
RAP B993029 Repair of underwater equipmen . RAP 899033 Processing CABS and incore detectors in SFP/ Reactor Vessel for shipping and disposa The inspector attended the pre-job, RWP, and ALARA briefings forjobs requiring the use of these RWP Observations and Findinas The ALARA and the RAP briefing addressed the anticipated radiological conditions, access control, the use of mock-up training, and contamination control and hot particle
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-- issues. The licensee also generated specific dose goals for each RAP which was job task evaluate For ALARA purposes (keeping unnecessary personnel off the reactor deck area during the SFP clean out project) RAP was rewritten not to include the reactor deck in the general RAP. Several different RAPS were written because of the different ALARA considerations related to various tasks for the SFP clean out project.. This was a good ALARA practice. Early in the SFP clean out project at the daily briefing the RP technician had difficulty knowing which RWPs to brief on. This was because the work scope was being changed at the last minute and the same worker was going to work several job tasks. As the SFP clean out project team matured, the job tasks were determined the night before, one job task was performed at a time and that RWP was briefed, the team then retumed to the briefing room and discussed the next job task and received the RWP briefing for that job task. As experience was gained, the assignments of job tasks and RWP briefing improved. However, there is a need for improvement in providing the ALARA planners with details of expected job activities for emergent work, the personnel to be assigned to these job activities, and some lead time before the job task will take place. This will allow the ALARA planners the opportunity to provide a better ALARA input to the RWP planning process, thus possibility reducing exposure to the worker Conclusions At the end of the inspection period, RWPs and ALARA briefings for known job tasks were going well; but for emergent work activities ALARA planners were not receiving the needed time and job specifics to provide effective Al. ARA planning before the job task was planned on being executed This interaction is being resolved by the license .5 Condition Report C-5RP-99-0019 Inspection Scope (83750)
The inspector reviewed Condition Rewt C-BPR-99-0019 for the licensee's investigation and proposed corrective activitie Observations and Findinas On January 13,1999, at approximately 8:00 a.m. and 10:00 a.m., two electricians passed through a posted High Radiation barrier without proper authorization (Condition Report, C-BRP-99-0019). In both cases the electricians saw he high radiation boundary posting but did not realize that it was a high radiation barrier. During the second entry the electrician's supervisor (who was accompanying the electricians) also entered and passed through the high radiation area without proper authorization. The electricians were signed in on RWP 99-003 and had been removing old transformer They were unaware that the radiological conditions in an area leading into the work site had changed due to the draining of a sock tank. The sock tank had been drained earlier that moming and surveys indicated that the area around the tank had changed from a radiation area to a high radiation area. Entry into and passing through a high radiation area when it has not been specifically authorized on the applicable RWP is
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I contrary to licensee procedural requirements and is a violation of requirements of the j NRC licens Even though the changed radiological conditions were discussed at the RP shift tumover meeting that moming, the access point RP technician, who had attended the meeting, neither discussed the changed radiological conditions with the electricians nor stopped the electricians from signing in on an invalid RWP. Durir;g routine daily inspections by a RP supervisor and the containment supervisor, the supervisors noticed the electricians and questioned them about the radiological conditions in the are When it was discovered that the electricians were not authorized to enter into a high radiation area, work was immediately halted and electricians were instructed to leave the area. Since the electricians only passed through the high radiation area on their way to the work site, dose to the workers was minima The subsequent investigation of the incident as documented iri Condition Report C-BRP-99-0019 was, in general, comprehensive in scope and the investigator's causal factor analysis was well thought out and documented. The root causes for the incident included human error, poor verbal communication, inadequate written communications, poor work practices, J. . ;r planning / scheduling and inadequate change management. The licensee's response included both counseling of the electricians and attendance at the next MAC department safety meeting in which the electricians discussed their failure to comply with RP posting requirement Management felt the workers did an excellent job of taking ownership for the incident and making the point to others about the need to avoid complacency. A review of the Condition Reports identified no other recent incidents where a worker failed to comply with a radiation protection posting. Due to the infrequency of these incidents, this incident is considered an isolated occurrence and not indicative of a degradation in the RP program. Licensee response to the January 13,1999, incident was considered excellent. Given the minimal significance of the actual and poter tial radiation exposure control issues which occurred in this event, it is considered a minor violation for which
, no NRC enforcement action will be take A review of Condition Report C-BRP-99-0019 did raise several questions about the causal factor analysis and the lack of addressing all of the identified root causes in the corrective section of the Condition Report. Training was not considered a casual factor )
in the Condition Report even though the station workers had just completed back-to-basic training. The fact that the electricians did not recognize the high radiation posting as a barrier requiring specific authorization to pass the barrier raised questions about the adequacy of the training. In addition, planning / scheduling was not addressed in the corrective section of the Condition Report even though planning / scheduling had been specifically identified as a casual factor by the investigators. These questions were raised with management. Management indicated that training had not been identified as a causal factor because the investigators concluded that the training given the workers had been adequate. The workers knew the requirements; due to human error they had failed to recognize that the high raciation posting was a barrier. The planning / scheduling casual factor was not addressed in the Condition Report because it was being addressed in a separate Condition Report. Management acknowledged that addressing the planning / scheduling causal factor in a separate Condition Report should have been documented in the corrective action section of Condition Report C-BRP-99-001 I 23 i
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. Conclusions An incident occurred in which electricians passed through a high radiation barrier without proper authority. A minor violation of NRC requirements resulted which the licensee's response to and subsequent investigation of the incident were excellen .6 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 activitie .7 Solid Radwaste Manaaement and Transoorte* ion of Radioactive Materials (86750)
The inspection included an evaluation to determine whethor 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 are Radiological control activities in the areas of effluents and solid radwaste were being conducted safely and in compliance with applicable requirement .0 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the
. conclusion of the inspection on April 15,1999. The licensee acknowledged the findings presented. The inspectors reviewed no proprietary infomiation during this inspection perio The licensee did identify any documents or processes reviewed by the inspectors as proprietary At the exit the licensee requested that the following statement be attached to the writeup on Y2K:
- "*" THIS IS A 2000 READINESS DISCLOSURE"*""*"
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PARTIAL LIST OF PERSONS CONTACTED ldGR!Mff M. Bourassa, Licensing Supervisor L. Darrah, Technical Support & Assessment Superintendent (RP&ES)
C. Jurgens, Planning, Maintenance & Construction Manager M. Lesinski, Radiation Protection and Environmental Services Manager (RP&ES)
R. McCaleb, Nuclear Performance Assessment, Site Lead (NPAD)
G. Petitjean, Senior Engineer i
< L. Potter, Maintenance Supervisor K. Powers, Site General Manager J. Rang, Industry issues .
G. Rowell, Corrective Action Supervisor G. Szczotka, Manager, Nuclear Performance Assessment Department (NPAD) J W, Trubilowicz, Operations, Cost Engineering & Scheduling Manager M. VanAlst, Security Manager ,
R. Wills, Radwaste Superintendent G. Withrow, Engineering & Licensing Manager K. Wooster, Emergency Planning Coordinator l '
E. Zienert, Human Resources & Administrative Department Manager INSPECTlON 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 42700: Review of Modifications and Procedures 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 Permaner,tly Shut Down Reactors IP 83750: Occupational Radiation Exposure IP 84750: Radwaste Treatment, Effluent and Environmental Monitoring IP 86750: Solid Radwaste Management and Transportation of Radioactive Materials l
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ITEMS OPENED, CLOSED, AND DISCUSSED Opened IFl 50-155/99002-01 Review of the Ikensee's corrective action items for the under voltage on the 46 KV Lin Closed VIO 50-155/97004-01 The violation was for two examples of failure to follow procedure in initiating and clearing equipment tagouts related to challenging the control room and the main steam isolation valve with the reactor operatin IFl 50-155/97012-02 Implementation of Fitness for Duty program enhancements IFl 50-155/97015-02 Resolution for positiva control over cables hanging in Spent Fuel Poo IFl 50-155/98006-01 Procedure D1.11, Safety Evaluations. This licensee procedure did not provide clear instructions and guidance for implementing 10 CFR 50.59 and 50.82 requirement Discussed IFl 50-155/98009-02 Development of an altemate containment heating contingency plan for safe storage of fuel and fuel support system F
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LIST OF ACRONYMS USED
- ALARA As-Low-As-Reasonably-Achievable l BRP Big Rock Point CARB Corrective Action Review Board CFR Code of Federal Regulations CRB Control Rod Blade DEP' Defueled Emergency Plan DTS Defueled Technical Specifications ED Electric Dosimetry FFD Fitness for Duty FHSR Final Hazards Summary Report IMCRH 1mportant to Monitoring and Control of Radiological Hazards ISSSF Important to Safe Storage of Spent Fuel MPSC Michigan Public Service Commission MRB Management Review Board NPAD Nuclear Performance Assessment Departraent NRC Nuclear Regulatory Commission PRC Plant Review Committee PSDAR Post-Shutdown Decommissioning Activities Report QA Quality Assurance RP Radiation Protection RP&ES Radiation Protection and Environmental S9rvices RWP Radiation Work Permit SAR Safety Analysis Report SFP Spent Fuel Pool SRC Safety Review Committee SSCs Systems, Structures and Components TS Technical Specification URSQ Unreviewed Safety Ouestion VIO Violation LICENSEE DOCUMENTS REVIEWED Licensee documents reviewed and utilized during the course of this inspection are specifically identified in the " Report Details" abov i
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