Text

IR 05000155-03-002 & IR 07200043-03-002(DNMS), on 03/17 - 05/19/2003, Big Rock Point. No Violations Noed
	ML031700220
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	06/18/2003
From:	Chris Miller; NRC/RGN-III
To:	Haas K; Consumers Energy
References
	-RFPFR IR-03-002
	Download: ML031700220 (12)
	v • d • e

June 18, 2003

Mr. Kurt M. Haas

General Manager

Big Rock Point Nuclear Plant

Consumers Energy Company

10269 US 31 North

Charlevoix, MI 49720

SUBJECT: BIG ROCK POINT INSPECTION REPORT 05000155/2003-002(DNMS) &

INSPECTION REPORT 07200043/2003-002(DNMS)

Dear Mr. Haas:

On May 19, 2003, 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, spent fuel safety and radiological safety. At the conclusion

of on-site inspections on March 20 and April 24, 2003, the inspectors discussed the inspection

findings with you and members of your staff. An additional telephone exit interview was

conducted on May 19, 2003, to discuss the results of the NRCs independent soil sample

analyses.

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 2.790 of the NRC's "Rules of Practice," a copy of this letter

and its enclosure will be made available electronically for public inspection in the NRC Public

Document Room or from the NRCs document system (ADAMS), accessible from the NRC

Web site at http://www.nrc.gov/reading-rm/adams.html.

K. Haas -2-

We will gladly discuss any questions you may have regarding this inspection.

Sincerely,

/RA/

Christopher G. Miller

Decommissioning Branch

Docket Nos. 05000155; 07200043

License No. DPR-6

Enclosures: Inspection Report 05000155/2003-002(DNMS) &

Inspection Report 07200043/2003-002(DNMS)

cc w/encl: R. A. Fenech, Senior Vice President,

Nuclear, Fossil, and Hydro Operations

Richard Whale, Michigan Public Service Commission

L. Shekter Smith, Michigan Department of

Environmental Quality

Chief, Nuclear Facilities Unit, Michigan

Department of Environmental Quality

Department of Attorney General (MI)

Emergency Management Division,

Michigan Department of State Police

Distribution:

Reading File

PUBLIC IE-01 w/encls

RIII PRR w/encls

M. Masnik, NRR w/encls

J. Shepherd, LPM, NMSS (e-mail)

J. L. Caldwell, RIII w/encls

M. L. Dapas, RIII w/encls

RIII Enf. Coordinator w/encls

DOCUMENT NAME: C:\ORPCheckout\FileNET\ML031700220.wpd

To receive a copy of this document, indicate in the box:"C" = Copy without enclosure "E"= Copy with enclosure"N"= No copy

OFFICE RIII E RIII RIII RIII E

NAME Snell:js Lee Landsman Miller

DATE 05/29/03 05/21/03 05/21/03 06/18/03

OFFICIAL RECORD COPY

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket No. 05000155; 07200043

License No. DPR-06

Report Nos. 05000155/2003-002(DNMS) &

07200043/2003-002(DNMS)

Licensee: Consumers Energy Company

Facility: Big Rock Point Nuclear Plant

Location: 10269 U.S. 31 North

Charlevoix, MI 49720

Dates: March 17 - May 19, 2003

Inspector: William Snell, Health Physics Manager

Peter Lee, Ph.D., CHP, Radiation Specialist

Ross Landsman, Ph.D., Project Engineer

G. Pirtle, Physical Security Inspector

Approved by: Christopher G. Miller, Chief

Decommissioning Branch

Division of Nuclear Materials Safety

EXECUTIVE SUMMARY

Big Rock Point Restoration Project

NRC Inspection Report 05000155/2003-002(DNMS)

& Inspection Report 07200043/2003002(DNMS)

This routine decommissioning inspection involved review of the licensees performance related

to decommissioning support activities, spent fuel safety and radiological safety. During this

assessment period, the licensee completed placing spent fuel into dry storage casks and

moving the casks to the Independent Spent Fuel Storage Installation (ISFSI). In addition, a

canister of greater than class C waste was placed on the ISFSI, and all the fuel racks were

removed from the Spent Fuel Pool. Overall, the licensees major decommissioning activities

were properly monitored and controlled.

Decommissioning Support Activities

The inspectors determined that Revision 19 of the Defueled Security, Suitability,

Training, and Qualification Plan, submitted in accordance with 10 CFR 50.54(p) resulted

in no decrease in effectiveness to the security plan. (Section 1.1)

The licensee submitted Revision 38 to the Defueled Security Plan in accordance with

10 CFR 50.54(p). The security plan change does not relieve the licensee from

complying with applicable security advisories and orders issued by the NRC. The

inspectors determined that the changes to the Defueled Security Plan did not decrease

the effectiveness of the plan. (Section 1.2)

Spent Fuel Safety

Based on direct observations of the Horizontal Transfer System (HTS) test program and

reviews of the HTS procedures, the inspectors determined that the licensee personnel

could safely transfer a loaded canister between the transfer cask and a storage cask

without using the containment building crane. Procedures and administrative controls

had been established to ensure compliance with NRC requirements.

Radiological Safety

The inspectors determined that the licensees pre-demolition surface survey

program was capable of measuring the designed radiological survey criteria of

5000 disintegrations per minute per 100 square centimeters (dpm/100 cm2).

(Section 3.1)

The bulk material assay system was designed assuming a uniform spatial distribution of

contamination within a waste volume. In conjunction with the pre-demolition surface

survey program, the inspectors determined the system, as designed, will meet the

requirements of the licensees waste disposal criteria of 5 picocuries per gram.

(Section 3.2)

The licensees radioanalytical laboratory equipment, laboratory quality assurance

program, and analytical procedures were adequate. The program for laboratory

analyses was effectively implemented. (Section 3.3)

2

Licensee personnel performed soil surface scanning and sample collection at the site of

the Old Radwaste Building and its underground vault in accordance with the final status

survey program specified in the Big Rock Point Restoration Project License Termination

Plan (LTP), which the NRC has received for review and approval. Six of seven soil

samples sent to the Oak Ridge Institute for Science and Education (ORISE) for

independent analyses showed statistical agreement with the licensees results. The

ORISE personnel concluded that the statistical difference in the one sample was

probably due to a small particle of elevated activity in the sample. However, in all cases

the sample results were less than the Derived Concentration Guideline Levels (DCGLs).

(Section 3.4)

The inspectors did not identify any concerns regarding the licensees activities

associated with a radioactive waste shipment of contaminated concrete debris and a

spent fuel rack. (Section 3.5)

3

Report Details1

1.0 Decommissioning Support Activities

1.1 Safeguards Program Implementation (81700)

a. Inspection Scope

The inspectors reviewed Revision 19, dated October 8, 2002, to the Defueled Security

Suitability, Training, and Qualification Plan. The purpose of the review was to verify that

the change did not decrease the effectiveness of the security plan. The security plan

revision was submitted in accordance with 10 CFR 50.54(p).

b. Observations and Findings

The revision to the security plan was primarily administrative in nature and addressed

security measures for movement of spent fuel.

c. Conclusions

The inspectors determined that Revision 19 of the Defueled Security, Suitability,

Training, and Qualification Plan, submitted in accordance with 10 CFR 50.54(p) resulted

in no decrease in effectiveness to the security plan.

1.2 Safeguards Program Implementation (81700)

a. Inspection Scope

The inspector reviewed Revision 38, dated March 27, 2003, to the Defueled Security

Plan. The purpose of the review was to verify that the changes did not decrease the

effectiveness of the security plan.

b. Observations and Findings

The revision to the security plan was primarily administrative in nature and described

under what conditions the provisions of the defueled security plan would be applicable.

The revision also showed changes in the security management organizational structure

and reporting responsibilities.

c. Conclusions

The licensee submitted Revision 38 to the Defueled Security Plan in accordance with

10 CFR 50.54(p). The security plan change does not relieve the licensee from

complying with applicable security advisories and orders issued by the NRC. The

inspectors determined that the changes to the Defueled Security Plan did not decrease

the effectiveness of the plan.

1

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

4

2.0 Spent Fuel Safety

2.1 Operation of an Independent Spent Fuel Storage Installation (ISFSI) (60855)

a. Inspection Scope

The inspector observed various portions of the licensees test program for the Horizontal

Transfer System (HTS) to determine whether the licensee was capable of safely

transferring a loaded canister between the transfer cask and a storage cask located on

the ISFSI storage pad. Prior to allowing the licensee to remove the containment

building crane, a successful demonstration of the licensees capability to transfer the

canister without the use of the containment building crane was required. The test

program was examined to ensure that all conditions and requirements of the Certificate

of Compliance, the Safety Analysis Report, Technical Specifications, and 10 CFR Part

72 requirements were met.

b. Observations

The inspectors reviewed licensee procedures and observed the implementation of those

procedures, which tested the licensees capability to safely transfer a loaded canister

between the transfer cask and a storage cask. The procedures were well developed

and complete. The licensee held pre-job briefings prior to the implementation of each

segment of the procedure. These pre-job meetings were conducted in a professional

manner, and the necessary issues to enhance safety (such as the need for three way

communication, pre-staging of equipment, and teamwork among work parties) were

discussed.

The inspectors observed various portions of implementing the transfer procedures.

Licensee personnel exercised good safety practices during heavy lifts and completed

the lifts in accordance with procedures. The inspectors observed proper work coverage

by health physics and security personnel on the ISFSI storage pad during work

activities. The inspector observed good communication and teamwork between

licensee personnel from various work groups.

c. Conclusions

Based on direct observations of the HTS test program and reviews of the HTS

procedures, the inspectors determined that the licensee personnel could safely transfer

a loaded canister between the transfer cask and a storage cask without using the

containment building crane. Procedures and administrative controls had been

established to ensure compliance with NRC requirements.

3.0 Radiological Safety

3.1 Pre-demolition Surface Contamination Surveys (83750)

a. Inspection Scope

The inspectors reviewed the licensees pre-demolition surface survey program. The

review included an evaluation of analytical procedures and the survey instruments

capability to meet the specified pre-demolition minimum detectable activity criteria.

5

b. Observations and Findings

The inspectors interviewed the licensees health physics technical personnel and

observed calibration and sensitivity tests of the radiological survey instruments that will

be used to conduct the pre-demolition final surface surveys. Prior to demolition, the

surveys will verify that building surface contamination levels are less than 5000

disintegrations per minute per 100 square centimeters (dpm/100 cm2). Based on the

observed verification of the instruments capabilities, the inspectors determined the

survey instruments were accurate, and would meet the specified minimum detectable

activity criteria based on the planned counting times. Use of the instruments would

allow the licensee to measure the designed survey criteria of 5000 dpm/100 cm2.

c. Conclusions

The inspectors determined that the licensees pre-demolition surface survey program

was capable of measuring the designed radiological survey criteria of 5000 dpm/

100 cm2.

3.2 Bulk Material Assay (86750)

a. Inspection Scope

Inspectors evaluated the bulk material assay program and the technical basis for

design, calibration, and operation of the bulk assay radiation detection system, to

determine whether the system would meet the requirements of the licensees waste

disposal criteria of 5 picocuries per gram (5 pCi/g).

b. Observations and Findings

By cover letter dated February 5, 2002, and in accordance with the provisions of

10 CFR 20.2002, the NRC approved the licensees proposal to dispose of demolition

debris in a State of Michigan landfill. The licensees proposal contained a commitment

that all demolition debris would be monitored by a bulk assay radiation detection system

with an alarm setpoint established at or below a 5 picocuries per gram (5 pCi/g) limit

prior to disposal. The inspectors reviewed procedures and documents regarding the

design, calibration and operation of the bulk assay radiation detection system. The

monitoring facilities and equipment were inspected and observed in operation, and

personnel knowledgeable of the system were interviewed.

The bulk assay radiation detection system consisted of two side by side trailers spaced

just far enough apart for a truck to drive between them. The demolition debris (which

was primarily concrete) was deposited into a large roll-off type container, which was

positioned on the truck. The truck was driven between the trailers. A scale was located

between the trailers so each load could be weighed. Four high-purity germanium

detectors were located inside the trailers, and two sodium iodide plastic scintillation

detectors were located on the outside of the trailers. The dimensions of the roll-off

containers were 670 cm (length) x 229 cm (width) x 107 cm (height) [263 x 90 x 42

inches]. The container was assayed by positioning the roll-off container with two

detectors on each side of the container, and with each detector centered to measure a

quadrant of the container, 350 cm x 115 cm x 107 cm.

6

The inspectors found that the bulk material assay system is designed only for a uniform

spatial distribution of contamination within a waste volume. To ensure the bulk material

assay system functions as designed, additional steps will be required to ensure a

uniform spatial distribution of contamination exists within a waste volume prior to the

assay. The licensee will ensure that the concrete waste to be monitored by the bulk

monitoring system is uniform and less than the 5pCi/gram limit by performing extensive

surface contamination surveys of the concrete walls and exposed surfaces prior to the

concrete being turned into rubble.

c. Conclusions

The bulk material assay system was designed assuming a uniform spatial distribution of

contamination within a waste volume. In conjunction with the pre-demolition surface

survey program, the inspectors determined the system, as designed, will meet the

requirements of the licensees waste disposal criteria of 5 pCi/g.

3.3 Quality Assurance/Quality Control (QA/QC) of Radioanalytical Laboratory (83750)

a. Inspection Scope

The inspectors evaluated the radioanalytical laboratory, including the Quality Assurance

and Quality Control program and pertinent analytical procedures, to ensure that sample

analyses were being performed in an acceptable manner and that the results were

accurate. The inspectors also reviewed portions of the licensee's program for laboratory

analyses, interviewed laboratory personnel, and reviewed gamma spectrum analyses of

a selection of previously analyzed archived samples.

b. Observations and Findings

The laboratory was equipped with high purity germanium detectors for soil sample

analyses. The inspectors conducted independent calibration and quality control checks.

The analytical results of soil samples previously analyzed were accurate. The

inspectors reviewed the results of the licensees radiochemistry cross check program,

and found the results were in agreement with the comparison.

c. Conclusions

The licensees radioanalytical laboratory equipment, laboratory quality assurance

program, and analytical procedures were adequate. The program for laboratory

analyses was effectively implemented.

3.4 Soil Sampling at Site of Old Radwaste Building (83801)

a. Inspection Scope

Inspectors evaluated licensee surface surveys and soil sampling for the unrestricted

release of the site where the Old Radwaste Building was located.

7

b. Observations and Findings

The licensee completed the demolition of the Old Radwaste Building and underground

vault that was located within the building, and had removed all demolition debris from

the area. Soil that been removed from around the vault during its demolition was

spread out on the ground in a layer of one meter or less in depth. The licensee had

previously collected soil samples from within the hole where the vault had been located,

and was collecting additional samples of the spread out dirt during the inspection. The

inspectors observed the licensee performing surface scanning of the soil and collecting

soil samples in accordance with the final status survey program specified in the Big

Rock Point Restoration Project License Termination Plan (LTP), which the NRC had

received for review and approval. After observing the licensees surface scanning and

soil collection and archiving techniques, the inspectors determined that the licensees

techniques were acceptable. The inspectors conducted independent scanning of some

of the same areas as the licensee, and obtained similar results.

The NRC sent seven of the soil samples collected and analyzed by the licensee to the

Oak Ridge Institute for Science and Education (ORISE) for independent analyses. In all

cases but one, ORISE obtained results similar to those of the licensee. In sample #6,

the radiological activity of the Cs-137 values were not within statistical agreement.

Since the sample size used by ORISE to analyze the sample was smaller than the

sample size used by Big Rock Point, ORISE personnel counted the remaining sample

material, recombined the soil, took two samples from the recombined soil, and counted

them. In none of the cases were the analytical results statistically equivalent. ORISE

personnel concluded that the statistical difference was probably due to a small particle

of elevated activity in the sample. However, since the results were in all cases less than

the Derived Concentration Guideline Levels (DCGLs), no further review was pursued.

The results of the analyses are listed in the following table.

8

Soil Sample Survey Results

Radwaste Building Demolition

Data in picoCuries per gram (pCi/g)

NRC (ORISE) Big Rock Point

Sample #

Co-60 Cs-137 Co-60 Cs-137

1 0.02 0.09 <MDAa 0.09

2 0.09 0.04 0.06 <MDA

3 0.02 0.02 <MDA 0.06

4 0.02 0.51 <MDA 0.37

5 0.12 0.47 0.13 0.43

6 0.11 2.28 0.12 1.62

7 0.80 3.02 0.73 3.45

a

Less than the minimum detectable activity (MDA).