IR 05000155/2004001

IR 05000155-04-001(DNMS), Big Rock Point, on 04/12/04 - 04/16/04, 05/11/04 - 05/14/04, and 06/01/04 - 06/04/04, Decommissioning Support Activities

ML041840273
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	07/02/2004
From:	O'Brien K NRC/RGN-III/DNMS/DB
To:	Haas K Consumers Energy
References
-RFPFR IR-04-001
Download: ML041840273 (10)

Text

uly 2, 2004

SUBJECT:

BIG ROCK POINT INSPECTION REPORT 050-00155/2004-001(DNMS)

Dear Mr. Haas:

On June 4, 2004, the NRC completed an inspection at the Big Rock Point Nuclear Plant. The purpose of the inspection was to determine whether decommissioning activities were conducted safely and in accordance with NRC requirements. Specifically, the inspectors evaluated decommissioning support activities and radiological safety. At the conclusion of on-site inspections on April 16, May14, and June 4, 2004, the inspectors discussed the inspection findings with you and members of your staff.

This inspection consisted of an examination of decommissioning activities at the Big Rock Point Nuclear Plant as they relate to safety and compliance with the Commissions rules and regulations. Areas examined during the inspection are identified in the enclosed report. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations of activities in progress, and interviews with personnel.

Based on the results of this inspection, the NRC did not identify any violations. The decommissioning activities reviewed were being conducted in accordance with applicable regulations and license conditions.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). The NRCs document system is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). We will gladly discuss any questions you may have regarding this inspection.

Sincerely,

/RA/

Kenneth G. OBrien, Chief Decommissioning Branch Docket No. 05000155 License No. DPR-6

Enclosure:

Inspection Report 05000155/2004-001(DNMS)

REGION III==

Docket No. 05000155 License No. DPR-6 Report No. 050-00155/2004-001(DNMS)

Licensee: Consumers Energy Company Facility: Big Rock Point Nuclear Site Location: 10269 U.S. 31 North Charlevoix, MI 49720 Dates: April 12-16, 2004, May 11-14, 2004, and June 1-4, 2004 Inspectors: William G. Snell, Health Physics Manager Christopher R. Martin, Health Physicist Approved by: Kenneth G. OBrien, Chief Decommissioning Branch Division of Nuclear Materials Safety

EXECUTIVE SUMMARY Big Rock Point Restoration Project NRC Inspection Report 05000155/2004-001(DNMS)

This routine decommissioning inspection involved review of the licensees performance related to decommissioning support activities and radiological safety. During this inspection period, the major activities reviewed included the conduct of demolition and decontamination efforts, and radiological surveys.

Decommissioning Support Activities

 The inspectors determined that licensee and contractor personnel were cognizant of the radiological conditions in their assigned work area. The inspectors concluded that the licensee and its contractors conducted decommissioning activities in a manner that protected the health and safety of workers and the general public. (Section 1.1)

 The licensees management team adequately characterized condition reports and developed appropriate corrective actions to prevent recurrence. The inspectors concluded that licensee management adequately implemented the condition report program. (Section 1.2)

Radiological Safety

 The inspectors concluded that the licensee implemented the radiological survey program in accordance with approved decommissioning procedures. (Section 2.1)

 The inspectors concluded that the licensee met regulatory requirements for the processing and shipping of low-level radioactive waste for disposal. (Section 2.2)

 The inspectors concluded that the licensees collection and analysis of soil samples was adequate. A comparison of the licensees analytical results and those obtained from the NRCs independent laboratory analysis of split samples indicated acceptable agreement. (Section 2.3)

Report Details1 1.0 Decommissioning Support Activities 1.1 Status of Decommissioning (71801, 83750)

a. Inspection Scope The inspectors evaluated decommissioning activities to ensure they were conducted in a manner that protected the health and safety of workers and the general public.

b. Observations and Findings The inspectors observed numerous decommissioning activities during several comprehensive plant tours. The activities observed by inspectors included: scabbling of building surfaces, decontamination and surveys of equipment and building surfaces, radiation protection work practices, movement of heavy loads, demolition activities, and licensee oversight of decommissioning work. During the plant tours, the inspectors discussed work hazards with health physics technicians and workers to verify they understood the radiological issues pertinent to their assigned work.

The licensees staff and contractors were cognizant of the radiological conditions in their work area and aware of what actions could cause the radiological conditions to change.

In addition, the licensees staff and contractors communicated effectively, demonstrated appropriate concern for industrial safety, conducted work in accordance with applicable procedural requirements, and employed adequate work practices to ensure safety. The inspectors noted that the material condition of facilities and equipment was acceptable and housekeeping within the controlled area was adequate.

The inspectors observed that the licensees staff and contractors wore appropriate anti-contamination clothing and dosimetry, followed the proper technique when removing their anti-contamination clothing, and performed exit monitoring adequately.

c. Conclusion The inspectors determined that licensee and contractor personnel were cognizant of the radiological conditions in their assigned work area. The inspectors concluded that the licensee and its contractors conducted decommissioning activities in a manner that protected the health and safety of workers and the general public.

1.2 Self-Assessment, Auditing and Corrective Actions (40801)

a. Inspection Scope The inspectors evaluated the management teams disposition of select condition reports.

A list of acronyms used in the report is included at the end of the report.

b. Observations and Findings The inspectors observed site management assess numerous condition reports (CRs),

including: C-BRP-04-069, C-BRP-04-0073, C-BRP-04-080, C-BRP-04-091, and C-BRP-04-092. The management team assessed each CR in accordance with applicable procedural requirements to determine if all the information was available regarding the issue, to characterize the issue, to determine if the root cause was appropriate, and to identify the appropriate corrective or follow-up action necessary to resolve the issue. Once the management team understood the significance of each issue they were able to develop appropriate corrective actions to address the cause(s)

and prevent recurrence.

The issues reviewed by the inspectors were either safety and health or radiological concerns identified by the workers or managers. Based upon a review of the information associated with the CRs, the inspectors determined that the corrective actions proposed by the management team were responsive to the identified concerns.

c. Conclusions The licensees management team adequately characterized CRs and developed appropriate corrective actions to prevent recurrence. The inspectors concluded that licensee management adequately implemented the CR program.

2.0 Radiological Safety 2.1 Inspection of Final Surveys (83801)

a. Inspection Scope The inspectors reviewed the licensees documentation and interviewed the staff regarding the conduct of and the results associated with the decommissioning survey activities.

b. Observations and Findings The inspectors reviewed the following Information, Survey, and Verification work packages:

1. Work Package 2003-0084, Turbine Building, B-3, Room 126/127; 2. Work Package 2003-0085, Turbine Building, Room 105/111; 3. Work Package 2003-0085A, Turbine Building, Room 105/111; 4. Work Package 2003-0086, Turbine Building Room 112 Turbine Lube Oil Tanks; 5. Work Package 2003-0091, Turbine Building Room 113 Stairwell No. 8;"

6. Work Package 2003-0096, Machine Shop Room 104; 7. Work Package 2003-0097, Floor Plugs - Turbine Deck; 8. Work Package 2003-0104, Service Building (B-3) North East Flower Box and East Entry Porch; 9. Work Package 2003-0107, Turbine Shield Wall; and 10. Work Package 2004-001, Block Wall 109/121.

The inspectors noted that each completed work package contained pre-demolition radiological survey results, verification survey results, historical basis for survey area classification, instrumentation calibration information, survey grid layouts, and photographs of the survey areas. The inspectors also noted the work packages were complete and contained sufficient detail to support the conclusions contained within the package.

The inspectors determined that the survey package included sufficient information to document that surveys were conducted in accordance with the licensees decommissioning procedures. The inspectors observed that the verification survey teams adequately conducted their surveys and were independent of the survey teams conducting screening and final surveys.

c. Conclusions The inspectors concluded that the licensee implemented the radiological survey program in accordance with approved decommissioning procedures.

2.2 Solid Radioactive Waste Management and Transportation of Radioactive Materials (86750)

a. Inspection Scope The inspectors evaluated the licensees method for processing waste and shipment of low-level radioactive waste.

b. Observations and Findings The inspectors reviewed a licensee document dated August 20, 2003, entitled Release of Materials to the Waters Landfill Through the Bulk Material Counting System. This document addressed the release of legacy asphalt and concrete material that had been stored along the old power line right-of-way. The inspectors determined that the August 20, 2003, document adequately addressed the handling of the legacy asphalt and concrete material.

The inspectors observed the preparation of a low-level radioactive waste shipment and determined that the transport vehicle was properly placarded and the individual containers were appropriately prepared and labeled. The inspectors conducted independent and confirmatory radiation surveys of the loaded vehicle and obtained survey results consistent with the licensees pre-shipment survey results. The inspectors reviewed the shipping papers associated with the shipment and determined that the papers contained the required information and were readily available and stored as required.

c. Conclusions The inspectors concluded that the licensee met regulatory requirements for the processing and shipping of low-level radioactive waste for disposal.

2.3 Radioactive Waste Treatment, and Effluent and Environmental Monitoring (84750)

a. Inspection Scope The inspectors evaluated the licensees collection of soil samples and obtained split samples for independent analysis to evaluate the licensees environmental monitoring program.

b. Observations and Findings The inspectors observed the licensee collect soil samples in conjunction with conducting final status surveys of soil excavated as a result of construction activities. The licensees environmental management staff ensured the area had been properly prepared before sampling. The 18 sites selected for sampling were an accordance with approved decommissioning procedures. The inspectors noted that the licensees procedures and techniques for the collection of environmental soil samples were adequate.

The inspectors conducted independent and confirmatory radiological surface scans. In addition, the inspectors randomly selected 3 of the 18 soil samples collected by the licensees staff to split for independent NRC analysis at the Oak Ridge Institute of Science and Education (ORISE).

The results of the analyses are listed in Table 2.3. The inspectors compared the analytical results obtained by the NRCs contractor, licensee, and ORISE for cobalt-60 (Co-60) and cesium-137 (Cs-137) and noted that all three samples contained less than the minimum detectable concentration (MDC) of Co-60 and slightly greater than the MDC of Cs-137. However, the Co-137 concentrations were consistent with background levels.

Table 2.3 Soil Co-60 (pCi/g) Cs-137 (pCi/g)

Sample Licenseea ORISEb Licenseec ORISEd 3 -0.012+/-0.04 0.01+/-0.06 0.455+/-0.11 0.48+/-0.13 9 0.010+/-0.05 0.00+/-0.04 0.304+/-0.09 0.27+/-0.10 15 0.010+/-0.05 0.00+/-0.05 0.253+/-0.08 0.19+/-0.07 a

The MDC for Co-60 was 0.06 picoCuries/gram (pCi/g).

b The average MDC for Co-60 was 0.11 pCi/g.

c The MDC for Cs-137 was 0.04 pCi/g.

d The average MDC for Cs-137 was 0.07 pCi/g.

The licensee and ORISE also analyzed the above soil samples for manganese-54 (Mn-54), europium-152 (Eu-152), europium-154 (Eu-154), and europium-155 (Eu-155).

The analysis results, obtained by the licensee and ORISE for each of these isotopes, were consistent and slightly below the MDC values for each isotope.

c. Conclusions The inspectors concluded that the licensees collection and analysis of soil samples was adequate. A comparison of the licensees analytical results and those obtained from the NRCs independent laboratory analysis of split samples indicated acceptable agreement.

3.0 Exit Meeting The inspector presented preliminary inspection results to members of the licensee management at the conclusion of onsite inspections on April 16, May 14, and June 4, 2004. The licensee acknowledged the findings presented. The licensee did not identify any documents or processes reviewed by the inspector as proprietary.

PARTIAL LIST OF PERSONS CONTACTED Licensee Kurt Haas, Site General Manager Ken Pallagi, Radiation Protection & Environmental Services Manager Greg Withrow, Engineering, Operations & Licensing Manager William Trubilowicz, Cost, Scheduling and Purchase Manager INSPECTION PROCEDURES USED IP 40801 Self-Assessment, Auditing and Corrective Action IP 71801 Decommissioning Performance and Status Review IP 83750 Occupational Radiation Exposure IP 83801 Inspection of Final Surveys at Permanently Shutdown Reactors IP 84750 Radwaste Treatment, and Effluent & Environmental Monitoring IP 86750 Solid Radioactive Waste Management and Transportation ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed None Discussed None LICENSEE DOCUMENTS REVIEWED Licensee documents reviewed and utilized during the course of this inspection are specifically identified in the Report Details above.

LIST OF ACRONYMS USED ALARA As-Low-As-Reasonably-Achievable BMR Bulk Material Release CR Condition Report DNMS Division of Nuclear Materials Safety IFI Inspection Follow-up Item MDC Minimum Detectable Concentration NRC Nuclear Regulatory Commission ORISE Oak Ridge Institute of Science and Education pCi/g picoCuries per gram 8