IR 05000155/2024001

NRC Inspection Report No. 07200043/2024001; 05000155/2024001 Big Rock Point Independent Spent Fuel Storage Installation

ML24303A357
Person / Time
Site:	Big Rock Point  File:Consumers Energy icon.png
Issue date:	10/31/2024
From:	Dave Hills NRC/RGN-III/DRSS
To:	Mlynarek M Holtec Decommissioning International
References
IR 2024001
Download: ML24303A357 (1)

Text

SUBJECT:

NRC INSPECTION REPORT NO. 07200043/2024001; 05000155/2024001 BIG ROCK POINT INDEPENDENT SPENT FUEL STORAGE INSTALLATION

Dear Mike Mlynarek:

On October 9, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Big Rock Point (BRP) Independent Spent Fuel Storage Installation (ISFSI). The purpose of the inspection was to determine whether activities authorized by the license were conducted safely and in accordance with NRC requirements. The results of this inspection which were discussed with you and other members of your staff on October 9, 2024, are documented in the enclosed report.

During the inspection, the NRC inspector reviewed the following aspects of onsite activities:

design changes, radiation protection, emergency preparedness, maintenance and surveillances, environmental monitoring, and quality insurance. The inspection consisted of an examination of activities at the site 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, reviewing work activities, and interviews with personnel.

Based on the results of this inspection, the inspectors did not identify any violations of NRC requirements.October 31, 2024 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, David E. Hills, Chief Decommissioning, Reactor, and ISFSI HP Branch Division of Radiological Safety and Security Docket No: 07200043; 05000155 License No: DPR-6

Enclosure:

IR Nos. 07200043/2024001 05000155/2024001

REGION III==

Docket No: 07200043 05000155

License No: DPR-6

Report No: 07200043/2024001 05000155/2024001

Licensee: Holtec Decommissioning International, LLC

Facility: Big Rock Point Independent Spent Fuel Storage Installation

Location: Charlevoix, MI

Inspection Dates: October 7, 2024, to October 9, 2024

Inspectors: Nathan Audia, Reactor Inspector

Approved by: David E. Hills, Chief Decommissioning, Reactor, and ISFSI HP Branch Division of Radiological Safety and Security

Enclosure EXECUTIVE SUMMARY

Big Rock Point Independent Spent Fuel Storage Installation NRC Inspection Report 07200043/2024001; 05000155/20240001

The inspection consisted of interviews of site personnel, on-site walkdowns, observation of the biennial emergency exercise, reviews of facility and program changes, observations of licensed activities at the ISFSI and evaluation of the licensees programs using inspection procedure (IP) 60858.

Changes, Test, and Experiments and 72.212 Evaluations

• The licensee implemented changes to the site and controlling documents in accordance with applicable regulations. (Section 1.1)

Radiation Protection Program

• The licensee has implemented and maintained the radiation protection program in accordance with applicable regulations and the license. (Section 1.2)

Emergency Preparedness Program

• The licensee has maintained and implemented the emergency preparedness program in accordance with applicable regulations and the license. (Section 1.3)

Maintenance and Surveillance Program

• The licensee has maintained and implemented the maintenance and surveillance programs in accordance with applicable regulations and the license. (Section 1.4)

Environmental Monitoring Program

• The licensee has maintained and implemented the environmental monitoring program in accordance with the applicable regulations and the license. (Section 1.5)

Quality Assurance Program

• The licensee has maintained and implemented the quality assurance (QA) and corrective action programs in accordance with applicable regulations and the license. (Section 1.6)

Report Details

1.0 Away-from-Reactor ISFSI Inspection Guidance (IP 60858)

1.1 Changes, Tests, and Experiments and 72.212 Evaluations

a. Inspection Scope

The inspector reviewed selected changes associated with the ISFSI to verify that the changes were made in accordance with 10 CFR Part 72.48 and did not require a license amendment.

The inspector reviewed selected changes to 10 CFR 72.212 evaluations since the last ISFSI inspection.

b. Observations and Findings

The licensee only implemented procedural changes since the last ISFSI inspection. The changes were administrative in nature. The site did not have any 10 CFR 72.48 evaluations since the last inspection. The inspector did not identify any changes made by the licensee which would require NRC approval.

The inspector verified the 10 CFR 72.212 report accurately reflected the site status.

Changes to the 10 CFR 72.212 report since the last inspection were administrative in nature.

No findings of significance were identified.

1.3 Conclusions

The licensee implemented changes to the site and controlling documents in accordance with applicable regulations.

2.0 Radiation Protection Program

a. Inspection Scope

The inspector reviewed the licensees plans and preparations for controlling radiologically significant activities.

The inspector reviewed selected records and took independent measurements to verify ISFSI dose and contamination levels are within the prescribed limits of 10 CFR 20 and 10 CFR 72.104.

The inspector verified that radioactive material, including special nuclear material, is properly stored, controlled, and accounted for in accordance with site requirements, the license and 10 CFR 72.72.

b. Observations and Findings

The inspector interviewed licensee personnel to discuss the sites plans and preparations for controlling radiologically significant activities. Occupational doses for radiation workers were under regulatory occupational dose limits and were reasonable for the work performed at the site. Survey meters were calibrated and readily available for use. The reviewed radiation work permit included appropriate descriptions of the anticipated radiological conditions, and the radiation protection controls in place. The inspector observed appropriately controlled and posted radiological areas at the facility.

The inspector reviewed selected radiological surveys of the ISFSI. The survey results indicated that the radiological conditions were in accordance with the limits of the license, and 10 CFR 72.104. The inspector verified the survey results by taking independent radiological measurements of the ISFSI pad and surrounding area which were consistent with the licensees measurements.

The inspector verified the site was conducting a special nuclear materials inventory at the correct frequency and observed that special nuclear materials stored at the site were accounted for. The type and quantities of radioactive material stored on-site were in conformance with the license and 10 CFR 72.72.

No findings of significance were identified.

c. Conclusions

The licensee has implemented and maintained the radiation protection program in accordance with applicable regulations and the license.

1.3 Emergency Preparedness Program

a. Inspection Scope

The inspector verified that changes made to the emergency preparedness program did not decrease the effectiveness of the licensees plan and were properly coordinated with off-site personnel.

The inspector observed the on-site emergency plan exercise. The inspector also reviewed selected emergency plan drills and exercises since the last inspection to assess the effectiveness of the program.

The inspector examined audits of the emergency preparedness program that were conducted since the last inspection.

b. Observations and Findings

The inspector reviewed the most recent revision of the emergency plan and observed changes which were accompanied with a 10 CFR 50.54(q)(3) screening. The inspector did not identify any changes which decreased the effectiveness of the emergency plan.

Off-site response was still conducted in accordance with the plan.

The inspector observed the sites biennial emergency preparedness exercise on October 8, 2024. The inspector monitored the licensees actions and communications throughout the emergency preparedness exercise and during the post-exercise critique.

During the exercise, the site coordinated with offsite responders and protected the health and safety of site and off-site personnel. The site appropriately identified the emergency, declared the correct emergency action level, and notified stakeholders within the required time frame. The licensee documented any deficiencies they identified.

The inspector reviewed select previously performed drills, exercises and audits associated with the emergency preparedness plan. The site conducted drills and exercises in accordance with timeliness requirements, and the site documented deficiencies into their corrective action program.

No findings of significance were identified.

c. Conclusions

The licensee has maintained and implemented the emergency preparedness program in accordance with applicable regulations and the license.

1.4 Maintenance and Surveillance Program

a. Inspection Scope

The inspector verified that maintenance and surveillance activities are performed in accordance with regulatory requirements.

The inspector performed a walkdown of the ISFSI to assess the overall material condition of the casks and pad.

The inspector verified that combustible materials were properly located and that the fire loading did not exceed the fire analysis limits in the Safety Analysis Report.

b. Observations and Findings

The inspector reviewed select surveillance records and associated procedures for the ISFSI. Deficiencies which were identified were placed into the sites corrective action program. The site is routinely monitoring the material condition of the ISFSI.

The inspector conducted a walkdown of the ISFSI pad and evaluated the structural condition of the pad and storage cask. The inspector verified the structural condition of the pad and casks were consistent with the condition documented in the licensees reports.

The inspector identified combustible material at the site, and verified the material was properly located. The fire loading did not exceed the fire analysis limits in the Safety Analysis Report.

No findings of significance were identified.

c. Conclusions

The licensee has maintained and implemented the maintenance and surveillance programs in accordance with applicable regulations and the license.

1.5 Environmental Monitoring Program

a. Inspection Scope

The inspector verified that doses to the nearest real individual are within the limits prescribed by 10 CFR 72.104.

b. Observations and Findings

The inspector reviewed the licensees environmental monitoring program which defines the methodology for determining the maximum potential public dose from direct radiation sources. The licensee did not monitor for effluents at the site as it was not required since the facility consisted of sealed canisters. The inspector reviewed the 2023 Big Rock Point Annual Radiological Environmental Operating Report, as well as several surveys on and around the ISFSI pad. The inspector determined that the licensee was appropriately accounting for and monitoring direct radiation dose to the public and were below the dose limits in 10 CFR 72.104.

No findings of significance were identified.

c. Conclusions

The licensee has maintained and implemented the environmental monitoring program in accordance with the applicable regulations and the license.

1.6 Quality Assurance Program

a. Inspection Scope

The inspector evaluated the licensees effectiveness in identifying, resolving, and preventing problems, by reviewing the overall corrective action program. The inspector reviewed a list of condition reports since October 2020, which included brief descriptions for each report. The inspector reviewed a selection of the condition reports, as well as audits in depth to verify the licensee is effectively identifying and correcting issues.

b. Observations and Findings

The inspector evaluated the licensees corrective action program and determined that the site was effective at identifying and correcting issues. Condition reports were generated when an issue arose, priority was assigned based on its significance, and appropriate corrective actions were taken. Audits were conducted in accordance with the licensees QA program, and identified issues were place into the sites corrective action program.

No findings of significance were identified.

c. Conclusions

The licensee has maintained and implemented the QA and corrective action programs in accordance with applicable regulations and the license.

10.0 Exit Meeting

The inspector presented the results of the inspection to Thomas Lacroix and other members of the licensee staff on October 9, 2024. The licensee acknowledged the results presented and did not identify any of the information discussed as proprietary.

ATTACHMENT: SUPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

T. LaCroix, BRP Project Manager S. Lowery, Security Manager B. Crandell, Security Operations Supervisor

INSPECTION PROCEDURES (IPs) USED

IP 60858 Away-From-Reactor Independent Spent Fuel Storage Installation Inspection Guidance

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened, Closed, Discussed Type Summary None

PARTIAL LIST OF DOCUMENTS REVIEWED

The following is a partial list of documents reviewed during the inspection. Inclusion on this list does not imply that the NRC inspector reviewed the documents in their entirety, but rather that selected sections of portions of the documents were evaluated as part of the overall inspection effort. Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.

- 014-22; Big Rock Point ISFSI Emergency Plan; 06/27/2022

- 017-24; BRP 212, 10CFR72.212 and Certificate Compliance Evaluation Report; 08/13/2024

- 0572_001; Big Rock Point ISFSI Emergency Plan; 05/31/2022

- 0573_001; ISFSI Emergency Response Organization Responsibilities; 05/26/2022

- 0574_001; Emergency Preparedness Drills, Exercises, and Equipment Checks; 05/26/2022

- 0575_001; Radiological Environmental Monitoring; 05/26/2022

- 0576_001; ISFSI Emergency Plan Implementing Procedure 35A-12 - Dose Assessment; 05/26/2022

- 2022 Emergency Plan Drill; 03/07/2023

- Audit 2023-I-21; Internal Audit Report; 10/16/2023

- Big Rock Point Biennial Emergency Exercise; 12/05/2022

- Big Rock Point Emergency Drill; 10/07/2021

- Big Rock Point Emergency Plan Annual Radiological Medical Drill; 10/26/2023

- BRP016; Procedure Change Form; 08/15/2024

- BRP 151; Radiological Survey and Status Sheet; 03/28/2023

- BRP 151; Radiological Survey and Status Sheet; 04/01/2021

- BRP 151; Radiological Survey and Status Sheet; 06/25/2024

- CD-020; Decommissioning Quality Assurance Program (DQAP); Revision 2

- EN-NF-200; Special Nuclear Material Control; 03/28/2023

- EN-NF-200; Special Nuclear Material Control; 03/28/2024

- HP 9.13; Eberline RO-2/2A and RO-20 Certificate of Calibration; 11/20/2023

- PAL-01981; Temperature Anomaly on Cask 0810 Daily Temperature Readings; 03/22/2024

- PAL-02086; Environmental Monitoring Dosimetry Missing; 04/15/2024

- PAL-02913; BRP Cask Inspection Results; 08/13/2024

- PAL-02943; BRP Annual ISFSI Pad Surface Inspection; 08/14/2024

- PAL-02945; BRP Dry Fuel Storage Transfer Cask Inspection Results, 08/14/2024

- PAL-03498; Oxy-acetylene tanks located adjacent to BRP ISFSI; 10/08/2024

- PAL-03499; EP Drill Actions Did Not Focus on Personnel Safety; 10/08/2024

- PAL-03515; **NRC Identified** Imperfections on DFS Pad at Big Rock Point; 10/09/2024

- QA-3-7-9-14-16-18-2021-BRP-1; Quality Assurance Audit Report; 10/05/2021

- T1-12; Dry Fuel Storage Cask Daily checks; Revision 11

- T365-35; Dry Fuel Storage Cask Inspections; 08/13/2024

- T365-35; Dry Fuel Storage Cask Inspections, 10/03/2023

- T365-37; Dry Fuel Storage (W100) Transfer Cask Inspections; 08/13/2024

- T365-37; Dry Fuel Storage (W100) Transfer Cask Inspections; 10/04/2023

- Volume 25; Off-Site Dose Calculation Manual and Related Documents A. Off-Site Dose Calculation Manual; Revision 30

- Volume 26; Fire Protection Summary; Revision 35

- Volume 33; 10 CFR 72.212 and Certificate of Compliance Evaluation Report; Revision 6

- Volume 35; Big Rock Point Independent Spent Fuel Storage Installation (ISFSI)

Emergency Plan; Revision 12

LIST OF ACRONYMS USED

ADAMS Agencywide Document Access and Management System BRP Big Rock Point CFR Code of Federal Regulations DRSS Division of Radiological Safety and Security IP Inspection Procedure IR Inspection Report ISFSI Independent Spent Fuel Storage Installation NRC U.S. Nuclear Regulatory Commission QA Quality Assurance

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