IR 05000155/1999004

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Insp Rept 50-155/99-04 on 990609-0730.No Violations Noted. Major Areas Inspected:Aspects of Facility Mgt & Control, Decommissioning Support Activities Including Security, Spent Fuel Safety & Radiological Safety
ML20210S706
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 08/12/1999
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20210S702 List:
References
50-155-99-04, NUDOCS 9908180176
Download: ML20210S706 (19)


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U.S. NUCLEAR REGULATORY COMMISSION

. REGION 111 -

1 Docket No: 50-155 License No: DPR-06 Report No: 50-155/99004(DNMS)

Licensee: Consumers Energy Company Facility: Big Rock Point Nuclear Power Plant

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l Location: 10269 U.S. 31 North l - Charlevoix, MI 49720 Dates: June 9,1999, through July 30,1999 Inspectors: R. J. Leemon, Reactor Decommissioning inspector

R. B. Landsman, Project Engineer l P. W. Harris, License Project Manager -

I J. R. Kniceley, Security Specialist l

Approved By: Bruce L. Jorgensen, Chief Decommissioning Branch Division of Nuclear Materials Safety 9908180176 990812

PDR ADOCK 05000155 8 PDR t. E ..

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l EXECUTIVE SUMMARY Big Rock Point Restoration Project ,

NRC Inspection Report 50-155/99004(DNMS)

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This routine decommissioning inspection covered aspects of facility management and control, decommissioning support activities including security, spent fuel safety, and radiological safety, l

Overall, major decommissioning activities were properly monitored and controlled, and they were performed on schedule. The second phase of the spent fuel pool clean out project, involving removal of significant quantities of radioactive material, was substantially complete Seven shipping casks, each loaded with crushed control blades and other reactor vessel )

components, were successfully loaded and shipped to a licensed burial site, with good worker j performance around the fuel pool and notable as-low-as-reasonably-achievable success in 1 achieving decreasing per-cask dose Facility Manaaement and Control

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  • The Nuclear Performance Assessment Department appeared to be effectively performing their function. The corrective action system was functioning as designe * The materialintegrity of systems, structures, and components necessary for the safe

! storage of spent fuel and conduct of safe decommissioning was being maintained, housekeeping and control of combustible materials were good, and fire equipment was being properly maintained.

! * Asbestos abatement was completed in the recirculation pump room and in the shutdown heat exchanger room, making about 98 percent of plant systems asbestos-fre Decommissionina Succort Activities

  • Good worker performance was observed during the second phase of the spent fuel pool

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clean out project. NRC and Department of Transportation requirements were me * The inspector observed that proper maintenance, personnel safety, fire protection, radiation protection, and health physics survey practices were performed during plant j dismantlement activities.

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  • The shift has been manned by two persons during this inspection period and no

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  • The licensee has a project for year 2000 computer problems. The inspector has no l concems with the Y2K status at the Big Rock Point decom'missioned plan !
  • Implementation of Revision 33 of the Physical Security Plan and associated implementing procedures was in compliance with NRC criteri !
  • Security personnel were knowledgeable of their duties and responsibilities, and security event reports were adequately reviewed and reported to the NR j

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Spent Fuel Safety e The safety of the fuel in the spent fuel pool was being maintained. Also, the spent fuel pool temperature is being maintained about 10 *F above the temperature of Lake Michiga Radological Safety e As-low-as-reasonably-achievable planning and radiation work permit briefings forjob tasks were effective, and remote TV monitoring of spent fuel pool activities was provided A notable (about 58 percent) reduction in per-cask radiation exposure was achieved when processing material to be loaded into a shipping cask, and a 68 percent reduction in the exposure was achieved when loading and transferring a shipping cas e The leading of a shipping cask onto a transport carrier and its subsequent shipment to a licensed burial site were observed to be carried out as required, with associated documentation and record keeping completed as specified by procedure. No problems were identified with the activities surrounding the shipmen * Radiological control activities in the areas of effluents and solid radwaste were being conducted safely and in compliance with applicable requirement t

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e 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 were removed from the facility. The second phase of the spent fuel pool (SFP) clean out project, involving removal of significant quantities of radioactive materials, was 78 percent complete. A security inspection was performed to ensure compliance with Revision 33 of the licensee's Physical Security Plan during the Big Rock Point Restoration Projec .0 Facility Management and Control 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 belo .2 Oraanization. Manaaement. and Cost Controls at Permanently Shut Down Reactors (36801)

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 examine .3 Safety Reviews. Desian Chanaes. and Modifications at Permanentiv Shut Down Reactors (37801) Insoection Scope The inspector monitored the licensee's safety review program to determine if the program was effective at identifying potential unreviewed safety questions (URSQs) in accordance with 10 CFR 50.59. 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 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 i

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' Safety Review Committee members discussed and reviewed procedure changes to j ensure they were clear, accurate, and had the same meaning to all members of the committee. Human factors were considered in the changing of these procedures. Each procedure change was evaluated to determine if an URSQ was created. None were create Conclusion Based on these observations, safety committee discussions were challenging and there were no issues which required changes to Technical Specifications (TSs), no URSQs were identified, and the requirements of 10 CFR 50.82 were me A 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 (FHSR), Post-Shutdown Decommissioning Activities Report (PSDAR), and Defueled Emergency Plan (DEP). Decommissioning activities monitored by the inspector were as described in the following section A.1 Plant Systems and Components Removed from Service Plant systems and components determined not needed for the safe storage of spent fuel and permanently removed from service during this inspection period were:

. portions of the main condenser a portions of the post incident shutdown cooling system

= portions of the reactor cooling system (a support cooling system interface between radioactive systems and the service water system)

1 A.2 Plant Modifications Specific design changes or modifications were reviewed to assess program effectiveness. 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 process, i

Plant modifications that were in progress or completed during the inspection period ;

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- planning for dry cask storage of spent fuel l

  • execution of the SFP clean out project Phase 2
  • completion of new access control point

.' installation of pipe tunnel to containment access door ,

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. completion of telephone system upgrade l

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Two major criteria used by the licensee for scoping decommissioning activities were annual budgeted money and budgeted person-rem exposure. No concems were identified with the scope and status of monitored decommissioning activitie .1.4.3. Managed Plant Hazard Reductions The primary hazardous material removed from the plant during the inspection period was asbestos, which is a biological hazard. Approximately g8 percent of the asbestos on plant systems has been removed. Asbestos abatement was completed in the Recirculation pump room and the shutdown heat exchanger roo .5 - Self-Assessment. Auditina. and Corrective Action (40801)

1.5.1 General The licensee's controls for identifying, resolving and preventing issues that degrade safety or quality were examined, including self-assessments, auditing, corrective

actions, 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 .5.2 Indeoendent Assessment of BRP Activities a.- Inspection Scope The inspector held discussions with Nuclear Performance Assessment Department '

(NPAD) assessors, attended NPAD exit meetings, and 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 4 root cause can be corrvete Observations and Findinos 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 met 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 were entered into the plant corrective action system to ensure followup. Nuclear Performance Assessment Department wrote condition reports for the conditions, which entered them into the plant corrective system for followup. Nuclear Performance Assessment Department appeared to be effectively performing its missio <

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When the licensee discovered concerns or abnormal conditions, the appropriate condition report was written and dispositioned by the CARB. The inspector reviewed condition reports, reviewed closed corrective actions for condition reports, and reviewed trend reports for the corrective action system. The inspector also attended CARBs and MRBs. The corrective action system was being managod, generally correct root causes were being identified, and corrective actions were being closed in a reasonable tim Conclusion l

NPAD appeared to be effectively performing their function and the corrective action I system was functioning as designe .6 Decommissionina Performance and Status Review at Permanentiv Shut Down Reactors (71801)

1. General The performance of the licensee and contracted workforce in performance of decommissioning activities was evaluated to determine if these activities were performed in accordance with licensed requirements and commitments. Control and l conduct of facility decommissioning activities were examined to verify the requirements of the license and DTS were followed, and to ensure the requirements and commitments described in the Updated Final Hazard Summary Report, PSDAR, and DEP were followed. Specific events and findings are detailed in the section belo .6.2 Plant Tours to Evaluate Material Conditions. Housekeepina. and Fire Protection Inspection Scope The inspector conducted plant tours to evaluate the material integrity of systems / structures / components (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 Observations and Findinas Observations from plant tours showed that the material integrity of SSCs important to safe storage of spent fuel (ISSSF) was being maintained. The inspector discussed tour observations with plant management. The inspector also roserved that plant management was actively monitoring plant material conditions. During this inspection period, the licensee raised the plant's material condition to an excellent level in preparation for plant tours by members of the American Nuclear Society on June 28, 1999, i

Housekeeping observations focused on the areas adjacent to and containing SSCs necessary for the safe storage of spent fuel, effluent control, or radiation protection and monitoring. The inspector determined that all areas of the plant were kept clean and free of the accumulation of dismantlement debris. As material was disassembled, it was

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placed into metal boxes. Portable cables were routed so as not to cause tripping hazards. General area housekeeping was excellent during this period with no areas of inspector concer The storage of combustible and flammable materials were within the fire loading limits l for transient combustibles and combustible materials were not accumulating in the plan l The fire fighting equipment and stations were properly maintained and ready for us l

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The installed fire detection and suppression systems were effectively maintained, surveillance tests were performed, and the equipment was capable of performing the j intended function Active dismantlement activities which included cutting and grinding were performed with j the proper fire protection in place. No fires were started during these activitie c. Conclusion Material integrity of SSC's important to safe storage of spent fuel and safety in decommissioning was being maintained. Housekeeping, control of combustible )

materials and operation of fire equipment were properly maintaine .0 Decommissioning Support Activities Maintenance and Surveillance at Permanently Shut Down Reactors (62803 I

The inspector evaluated maintenance and surveillance on 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 )

i Dismantlement Activities (62801)

Dismantlement activities observed or evaluated by the inspector during the period were:

  • removal of equipment from the electrical sub station completed a removal of equipment from the electrical and air compressor room l
  • removal of equipment from the containment interior cable penetration room I completed a condenser dismantlement completed a pipe tunnel dismantlement completed
  • alternate shutdown building dismantlement completed a scram dump tank removed a recirculation pumps gland coolers removed The inspector observed that proper maintenance, personnel safety, fire protection, radiation protection, and health physics survey practices were performed during these activitie ,

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. Soent Fuel Pool Clean Out Proiect Activities (62801)

s.- Inspection Scope-The SFP clean out project involves the removal of all non-fuel bearing components from the SFP. For this project, the reactor vessel.was being used as a water shielded processing tank. Each component was surveyed, radioactively characterized and classified, processed, packaged, and shipped for burial - inspection of radiological control activities is discussed in Paragraph 4.3 below. The inspector observed workers performing various of these activities in and around tM SFP and the reactor cavity. The inspector also attended planning meetings l attendc cre-job and as-low-as-reasonably-achievable'(ALARA) daily briefings and reviewed the SFP clean out project contingency plan Observations and F'ndinas The SFP project meetings were well organized. The daily plans were described, including possible ' fill in" work identified at the previous day's planning meeting. Work experiences from the previous day were discussed at each meeting. Contingency measures for unexpected radiological conditions were provided, along with discussion of the overall Al. ARA plan for the project.: Worker participation was fostered by asking questions and by generating interactions among the various work groups. Daily, staff were reminded that radiation protection (RP) had the authority to stop work at any time that the dose rate or RP practices were in question. At time when the doses on objects coming out of the water were in question this authority was exercised and the object was lowered back into the water until the situation was evaluated. Thus, no unnecessary 1 radiation exposure was received by the workers. Daily work activities were performed well on the reactor deck. When problems were encountered, the supervisors were l notified _ and the activity was stopped. The correct contingency plan was generated and i executed or repairs were made to processing equipment. Appropriate condition reports were written so the problems could be evaluated by managemen The second phase of the SFP clean out project, which was ongoing during this inspection period, included the following activities for each shipment:

1) Filling the inner basket: transporting control road blades (CRBs) to the reactor vessel, crushing them, then loading them into a basket along with a container of Stellite rollers which had been cut off the CRBs before crushing. Also, transporting other items to the reactor to fill the basket (CRB spud ends, incore detectors, and other radioactive reactor hardware).

2) Filling the cask: removing the CRB crusher from the reactor vessel, dose profiling the bottom of the cask liner, placing the shipping cask into the reactor vessel, inserting the liner into the shipping cask, placing the basket into the liner, placing the liner closure lid on the liner, dose profiling the upper portion of the liner, and placing the shipping cask closure lid on the shipping cas i 3) Draining and deconning the cask: removing the cask from the reactor vessel, draining, surveying and moving the cask from the reactor deck to the equipment lock lay down area, decontaminating, and re-surveying to determine that radioactive material shipping requirements were me +l )

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4) Placing the cask on the truck: removing the cask from'the containment, transporting to the turbine building truck bay, loading onto the shipping truck, and surveying and j smearing the cask again to ensure that the department of transportation regulations were me ) After radioactive material shipping requirements were met, the shipping cask was

- transported to the burial sit To date, seven shipping casks have been loaded and transported to the burial site. At -

least two more shipments are planned. Each shipping cask typically held 13 CRBs, but one shipment held only two CRBs. Nineteen CRBs remain to be shipped to the burial -

sit Conclusion Good worker performance was observed during the second phase of the SFP clean out project. NRC and Department of Transportation requirements were met.

i Ooerational Safety Verificetion (71707)

On June 7,1999, the operations department established the final shift staff complemen The operations shifts are now staffed with one shift supervisor who is a certified fuel l handler, and one decommissioning worker class I. No work is being assigned to the

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! shifts. This is the two person shift authorized by the DTS for non-fuel handling conditions. The shift has been manned by two persons during this inspection period and no problems have occurred while using this reduced staff size.

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( Safeauards Proaram imolementation (IP 81700)

l Inspection Scope The inspector reviewed the BRP Safeguards Program to determine whether physical .

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. security requirements were implemented in accordance with the requirements of the Physical Security Plan (PSP) and site security procedure . Observations and Findings  :

To determine if the security program was adequately being implemented the inspector toured the Owner Controlled Area (OCA) and Protected Area (PA) and observed the i integrity of the fences, gates, alarm system 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 l functioned as required. Personnel requiring access were identified, badged, and escorted as required. Packages and vehicles were inspected by security officers at the entrance to the PA as required by the Physical Security Plan (PSP). Security force manning levels were maintained as required by the PS j

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All the officers were aimed and equipped as required. The inspector wiMessed radio i tests and concluded that there was appropriate communication capab.!ity. Equipment l observed within the alarm station and the Access Facility functioned as designed and l both facilities were adequately manned. Maintenance support for se9urity equipment ;

seemed timely and adequat The inspector also interviewed officers posted and on patrol and found them to be i 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 dutie Security program audits were conducted as required and concluded that the Security Program meets Security Plan requirements and is edective at providing physical protection of protected areas in accordance with the Security Plan and implementing Procedure c. Conclusions i

Through observations, interviews, independent verification and records review the inspector verified that the licensee is in compliance with Physical Security Plan commitment j

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The inspector concluded that security measures are effectively in place, procedures are adequate, training is effective and that the licensee is meeting the requirements of the j Physical Security Plan. Security equipment functioned as designed and procedures and l post orders reviewed were adequat .6 Status of Year 2000 (Y2K) Computer Problem Plan l l

a. Insoection 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 project. The Y2K Status was previously discussed in inspection Report 50-155/9900 b. Observations and bndinos The new Plant Monitoring Station equipment was tested during post modification testing and was found to be compliant with making an error free transition into year 200 However, if this equipment fails unexpectedly direct readings by operations 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 e

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!4 l Items that remained to be upgraded and tested were the plant telephones, the Radiation Protection Management System, and the Maintenance Information Systern (MIS)

(eiectronic dosimeters). The telephone system has been upgraded. A new MIS is presently undergoing testing for use at the plant. However, its operation does not affect the safe storage of spent fuel. Plans are for the MIS to be upgraded and test of Y2K compliance by the end of October 199 Big Rock Point 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 c. Conclusion The licensee has a project for year 2000 computer problems. The inspector has no concerns with the Y2K status at BRP Decommissioned Plan NOTE: The licensee requested the following statement for the Y2K Information above:

        • "**" THIS IS A YEAR 2000 READINESS DISCLOSURE "***""* Spent Fuel Safety a. Insoection Scope (60801)

I The inspector evaluated spent fuel and fuel pool safety. Factors considered in the I evaluation included SFP heatup rate; SFP instrumentation, alarms, and leakage I 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 b. 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 monitor was functioning. The inspector also observed that foreign material controls

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were being used in and around the SF The operating range for temperature of the SFP was changed from 40 to 80 *F to 40 to 95 *F in revision number 5 of DOP-4, Fuel Pool System. The DTS SFP upper j temperature limit is 140*F. On July 28, the SFP temperature was 79'F and the time for l the temperature to rise to 140*F was 11.1 days. The present SFP heatup rate is j 0.23*F/ hour. The SFP temperature is about 10 *F above the temperature of Lake Michigan. This was the reason for the higher operating temperature of 95 *F in DOP- I During this inspection period the SFP altemate cooling system was shut off during the time when the SFP clean out project activities were in progress to reduce the amount of ;

corrosion products potentially getting ir;to the system. Controlling the temperature of the SFP within the operating band with this type of operation was not a proble '  ;

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' Conclusion f The safety of the fuelin the SFP was being maintained. Also, the SFP temperature is being maintained about 10 *F above the temperature of Lake Mhhiga .0 7 ; Radiological Safety General The inspector conducted reviews of ongoing activities in order to assess the overall RP program. Specific findings are detailed in the sections belo .2 - Occuoational Radiation Exoosure (83750)

Numerous aspects of licensee processes to minimize occupational radiation exposure were selectively examined in order to evaluate overall radiation safety and to provide for early identification of potential problems. Areas examined included: audits and appraisals; planning and preparation; training and qualifications of pemonnel; extemal exposure control; intemal exposure control; control of radioactive materials and contamination; surveys and monitoring; and maintaining occupational exposure ALAR No concems were identified in the examination of these area ~ Processina and Removal of Materials from the SFP

' Inspection Scone (83750. 83728)

The inspector reviewed the licensee's program for planning, processing and removal of materials (CRBs, incore detectors, etc.) from the SFP, as described in Paragraph 2.3, above. During the inspection the inspector reviewed the following radiation work permits (RWPs):

RWP B99002 Operation personnel performing rounds, inspections, tagging and training activitie RWP B99004 Tours, inspections, evaluations and job planning, security

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functions except coverage of specific RWP RWP B993025 Rigging / loading / handling / inspection and mockup of shipping cas RWP B993029 Repair of underwater equipment.

o RWP B993033 Processing CABS and incore detectors in SFP/ Reactor Vessel for l shipping and disposa The inspector attended the pre-job, RWP, and ALARA briefings for jobs requiring the use of these RWP '

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l The ALARA and the RWP briefings addressed the anticipated radiological conditions, access control, and contamination control and hot particle issues. The licensee also generated specific dose goals for each RWP which were job task evaluated. For ALARA purposes (keeping unnecessary personnel off the reactor deck area during the SFP clean out project) RWP B99004 was rewritten to remove the reactor deck from the general tour RWP. Several different RWPs were written to utilize the different ALARA considerations related to various tasks for the SFP clean out project. This was a good ALARA practice. Briefings improved as experience was gained, and the assignments of workers ic the job tasks, and the communication of the work scope to the ALARA planners also improve On June 7,1999, the TV monitor for monitoring the SFP Clean Out Project activities was placed in the computer room outside the controlled area. This is an ALARA item which allows management oversite of the project without the managers entering the I controlled area, thus saving dose. There are two zoom, pan and tilt cameras which I allow viewing activities in the SFP, in the reactor vessel and on the reactor dec The ALARA planner's review of doses assigned to RWP 8993025 ( rigging, loading, handling, inspection and mockup of shipping cask) and RWP 899033 (processing CABS and incore detectors in SFP/ Reactor Vessel for shipping and disposal) '

determined the following:

I SHIPMENT NUMBER mrem for RWP B993025 mrem for RWP 8993033 ONE 513 926 TWO 311 726 THREE 232 770 *

FOUR 447** 623 FIVE 208 419 SIX 162 385 PERSON-REM ESTIMATE 2.487 REM 8.000 REM PERSON-REM RECEIVED 2.111 REM 5.990 REM

  • equipment problems with the CRB punch
    • liner lid machining and fit problems because it did not seat The SFP clean out crew's efforts to perform work in a more efficient manner, incorporate lessons leamed, pay attention to details, and always keep ALARA principles in mind, resulted in a notable pel cask dose reduction while performing this work.

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. Conclusions At the end of this inspection period, ALARA planning, and RWP briefings for job tasks were going well, and remote TV monitoring of SFP activities was provided. Also, the increase in the team's proficiency resulted in a 58 percent reduction in exposure received by members of the team, when processing material to be loaded into a shipping cask, and a 68 percent reduction in the exposure received when loading and transferring a shipping cas .4 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 1 ensure that required radiological environmental monitoring programs were effectively implemente No problems were noted in review of these activitie .5 Solid Radwaste Manaaement and Transoortation of Radioactive Materials (86750)

4. General 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 material No problems were noted in the evaluation of this area. Radiological control activities in the areas of effluents and solid radwaste were being conducted safely and in compliance with applicable requirement . 4.5.2 Packina and Shinoina the Shiocina Cask (86740. 86750) insoection Scone (86740. 86750)

l The inspector evaluated licensee compliance with NRC and Department Of Transportation (DOT) regulations for packaging and shipment of radioactive material Specifically, the inspection focused on the shipment of a significant quantity of licensed materialinside a Type B shipping cask. Areas examined included: 1) shipping documentation; 2) loading of the cask within the reactor vessel; 3) closure of the cask for transport; 4) daily RWP briefings; and 5) Radiation Survey Technique Observations and Findinas This inspection covered several of nine planned shipments of reactor components for low level radioactive waste disposal. The licensee is using a cask provided by General

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- (designed and used in Fort St. Vrain decommissioning) and it is a Type B shipping cask with Certificate of Conformance (CoC) No. USA /9277. The licensee contracted with NUKEM to manage the loading of the cask and to assist the licensee's waste management group for the shipment of the waste. The shipment normally included: l

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13 Control Rod Blades -

- Incore detectors .

52 Stellite rollers spud ends and other reactor parts ln order to determine the nuclides and activity of the above components, the licensee contracted with Waste Management Group (WMG) to characterize the above components.~ Information provided to WMG includes, but is not limited to, dose profiles of the above components, metallurgic analysis of the components and estimated time and conditions while the components were being irradiated within the reactor vesse The characterization is provided to the licensee to be used in the completion of waste documents for the disposal of the waste which includes, but is not limited to, nuclides present, activities of each nuclide and characterization of the waste class. The licensee

. appeared to have adequately monitored the interaction between the above contractors to ensure compliance with NRC and DOT regulation Conclusions The loading of a FSV shipping cask onto a transport carrier and subsequent shipment to Bamwell in South Carolina was observed to be carried out as required, and with associated documentation and record keeping completed as required by procedure. No problems were identified with the activities surrounding the shipmen .0 - Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the

. conclusion of the inspection on July 30,1999. The licensee acknowledged the findings

' presented. The inspectors reviewed no proprietary information during this inspection perio The licensee did identify any documents or processes reviewed by the inspectors as

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proprietar The security inspection scope and results were summarized and discussed with the plant management during the security inspection. 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 i

Licensee

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. M. Bourassa, Licensing Supervisor L Darrah, Technical Support & Assessment Superintendent (RP&ES)

C. Jurgens, Planning, Maintenance & Construction Manager M. Losinski, Radiation Protection and Environmental Services Manager (RP&ES)

R. McCaleb, Nuclear Performance Assessment, Site Lead (NPAD)

G. Petitjean, Senior Engineer-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)

W. Trubilowicz, Operations, Cost Engineering & Scheduling Manager M. VanAlst, Security Manager R. Wills, Radwaste Superintendent l G. Withrow, Engineering & Licensing Manager l K. Wooster, Emergency Planning Coordinator

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E. Zienert, Human Resources & Administrative Department Manager i.

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INSPECTION PROCEDURES USED

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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 Permanently Shut Down Reactors IP 81700 Safeguards Program implementation IP 83750: Occupational Radiation Exposure IP 84750: Radwaste Treatment, Effluent and Environmental Monitoring IP86740:. Inspection of Transportation Activities IP 86750: Solid Radwaste Management and Transportation of Radioactive Materials ITEMS OPENED, CLOSED, AND DISCUSSED Ooened None Closed None Discussed j None i

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LIST OF ACRONYMS USED ALARA As-Low-As-Reasonably-Achievable CARB Corrective Action Review Board CoC Certificate of Compliance CFR Code of Federal Regulations CRB Control Rod Blade DEP Defueled Emergency Plan DOP Defueled Operating Procedure DOT Department of Transportation DTS Defueled Technical Specifications FHSR Final Hazards Summary Report FSV Fort Saint Vrain (Shipping Cask)

ISSSF 1mportant to Safe Storage of Spent Fuel MIS Maintenance information System MRB Management Review Board NPAD Nuclear Performance Assessment Department NRC Nuclear Regulatory Commission OCA ' Owner Controlled Area PSDAR Post-Shutdown Decommissioning Activities Report QA - Quality Assurance PA Protected Area RP Radiation Protection RWP Radiation Work Permit

. PSP Physical Security Plan SFP Spent Fuel Pool SRC ' Safety Review Committee SSCs Systems, Structures and Components TS Technical Specification-URSQ Unreviewed Safety Question WMG Waste Management Group LICENSEE DOCUMENTS REVIEWED

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Licensee documents reviewed and utilized during the course of this inspection are specifically identified in the " Report Details" abov l l

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