ML040700970
| ML040700970 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 03/10/2004 |
| From: | Chris Miller NRC/RGN-III/DNMS/DB |
| To: | Haas K Consumers Energy |
| References | |
| -RFPFR IR-03-007 | |
| Download: ML040700970 (10) | |
See also: IR 05000155/2003007
Text
March 10, 2004
Mr. Kurt M. Haas
General Manager
Big Rock Point Nuclear Plant
Consumers Energy Company
10269 U.S. 31 North
Charlevoix, MI 49720
SUBJECT: BIG ROCK POINT INSPECTION REPORT 05000155/2003-007(DNMS)
Dear Mr. Haas:
On February 20, 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 inspector
evaluated decommissioning support activities and radiological safety. At the conclusion of
on-site inspections on December 4, 2003, January 15, 2004, and February 20, 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 ADAMS system is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
K. Haas -2-
We will gladly discuss any questions you may have regarding this inspection.
Sincerely,
/RA/
Christopher G. Miller, Chief
Decommissioning Branch
Docket No. 05000155
License No. DPR-6
Enclosure: Inspection Report 05000155/2003-007(DNMS)
cc w/encl: R. A. Fenech, Senior Vice President,
Nuclear, Fossil, and Hydro Operations
John King, 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:
M. Masnik, NRR w/encl
J. Shepherd, LPM, NMSS (e-mail)
G. E. Grant, RIII w/encl
M. L. Dapas, RIII w/encl
RIII Enf. Coordinator w/encl
DOCUMENT NAME: C:\ORPCheckout\FileNET\ML040700970.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 RIII C RIII E RIII E
NAME Snell:mb LaFranzo Bonano Martin Miller
DATE 03/02/04 03/02/04 03/02/04 03/02/04 03/10/04
OFFICIAL RECORD COPY
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket No. 05000155
License No. DPR-6
Report No. 05000155/2003-007(DNMS)
Licensee: Consumers Energy Company
Facility: Big Rock Point Nuclear Site
Location: 10269 U.S. 31 North
Charlevoix, MI 49720
Dates: December 1-4, 2003
January 12-15, 2004
February 17-20, 2004
Inspectors: William Snell, Health Physics Manager
Michael LaFranzo, Radiation Specialist
Gene Bonano, Radiation Specialist
Chris Martin, Health Physicist
Approved by: Christopher G. Miller, Chief
Decommissioning Branch
Division of Nuclear Materials Safety
EXECUTIVE SUMMARY
Big Rock Point Restoration Project
NRC Inspection Report 05000155/2003-007(DNMS)
This routine decommissioning inspection involved review of the licensees performance related
to decommissioning support activities and radiological safety. During this inspection period,
major activities reviewed included demolition and decontamination activities, and radiological
surveys.
Decommissioning Support Activities
The inspectors determined that the licensee conducted decommissioning activities in
accordance with procedural requirements and in a safe manner. Licensee personnel
were knowledgeable of the radiological conditions in their work areas. Workers
demonstrated effective communications and work practices. The material condition of
facilities and equipment was acceptable. Housekeeping was adequate. (Section 1.1)
The inspectors did not identify any violations or concerns regarding the licensees review
and characterization of Condition Reports. (Section 1.2)
Radiological Safety
The licensee implemented the survey program in accordance with the NRCs regulatory
requirements for decommissioning reactors and the licensees decommissioning
procedures. (Section 2.1)
The licensee met regulatory requirements for the processing and shipping of low-level
radioactive waste for disposal and transportation. No violations of NRC and Department
of Transportation (DOT) regulations were identified. (Section 2.2)
The inspectors did not identify any concerns during observations of the licensees
collection of well water samples for radioanalytical analysis. Comparisons between the
licensees analytical results and those from ORISE on split samples indicated
acceptable agreement. Overall results indicated the licensees well water sampling and
radioanalytical analysis of water samples was acceptable. (Section 2.3)
2
Report Details1
1.0 Decommissioning Support Activities
1.1 Status of Decommissioning (71801, 83750)
a. Inspection Scope
The inspectors evaluated decommissioning activities to verify that the licensee was
conducting work in accordance with procedural requirements and in a safe manner.
The inspectors conducted numerous site tours to observe licensee staff conducting
decommissioning activities. Activities observed included: scabbling, decontamination
and surveys of equipment and building surfaces, radiation protection work practices,
movement of heavy loads, demolition activities, and overall licensee oversight of work.
The inspectors discussed work activities with health physics technicians and workers
during the tours to verify they understood the radiological issues pertinent to their
assigned work.
b. Observations and Findings
Licensee staff were knowledgeable of their work assignments and attentive to their
individual tasks. The inspectors found the licensee staff to be cognizant of the
radiological conditions in their work area and aware of what actions could cause the
radiation levels to change. Workers were observed communicating effectively,
demonstrating appropriate concern for industrial safety, conducting work in accordance
with procedural requirements, and employing good work practices. The material
condition of facilities and equipment was acceptable. Housekeeping was adequate.
The inspectors observed that licensee staff were wearing appropriate anti-contamination
clothing and dosimetry, and followed proper technique when removing anti-
contamination clothing.
c. Conclusion
The inspectors determined that the licensee conducted decommissioning activities in
accordance with procedural requirements and in a safe manner. Licensee personnel
were knowledgeable of the radiological conditions in their work areas. Workers
demonstrated effective communications and work practices. The material condition of
facilities and equipment was acceptable. Housekeeping was adequate.
1.2 Self-Assessment, Auditing & Corrective Actions (40801)
1
A list of acronyms used in the report is included at the end of the report.
3
a. Inspection Scope
The inspectors observed licensee management during their review of numerous
Condition Reports (CRs). Specifically, the inspector observed licensee management
review the following CRs: C-BRP-03-0271, -03-0270, -03-0238, -03-0243, -03-0227,-04-007, -04-008,-04-009, -04-010,-04-011, -04-045,-04-046, -04-047,-04-048, and
-04-049. The inspectors observed the licensee: 1) determine if all information was
available regarding the incident, 2) characterize each CR in accordance with the
licensees procedures, 3) determine if the root cause was appropriate, and 4) determine
what appropriate corrective or follow-up actions should be taken.
b. Observations and Findings
Licensee management adequately: 1) determined that all information was available
regarding the incident or addressed what additional information was necessary, 2)
characterized each CR in accordance with the licensees procedures, 3) determined the
root cause was appropriate or recommended additional review, and 4) determined
appropriate corrective or follow-up actions.
c. Conclusions
The inspectors did not identify any violations or concerns regarding the licensees review
and characterization of Condition Reports.
2.0 Radiological Safety
2.1 Inspection of Final Surveys (83801)
a. Inspection Scope
The inspectors reviewed the licensees survey packages, which 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 reviewed the following work
packages for the Service Building: Work Package 2003-0053, Radiation Protection,
Room 206; Work Package 2003-0057, Instrument Laboratory, Rooms 314/315; Work
Package 2003-0061, Control Room; Work Package 2003-0068, Room 322; Work
Package 2003-0070, Passage Way, Room 200; Work Package 2003-0077, Technical
Support Center Closet, Room 321; Work Package 2003-0078, Vestibule, Room 323;
Work Package 2003-0080, North Stairway, Stair No. 1; Work Package 2003-0081,
South Stairway, Stair No. 2; and Work Package 2003-0103, Lobby/Vestibule. The
inspectors also reviewed Work Package 2003-0028, Poured Concrete Vehicle Barriers,
Wooden Decks, and Walkways Screening Survey Package (non-impacted material);
and Work Package 2003-0075, Turbine Building, Heating Boiler, Room 107. The
inspectors reviewed the licensees procedures, evaluated the licensees compliance with
the regulations, and interviewed the staff regarding the conduct and results of the
surveys for the Service Building and for the non-impacted bulk material.
4
b. Observations and Findings
The inspectors did not identify any concerns with the licensees implementation of its
survey program. The survey packages contained pre-demolition radiological survey
results, verification survey results, historical basis for survey area classifications,
instrumentation calibration information, survey grid layouts, and photographs of the
survey areas, and were conducted in accordance with the licensees decommissioning
procedures. Verification survey teams demonstrated competence in conducting the
surveys and maintained independence from previous survey teams conducting
screening and final surveys.
The licensee demonstrated that structures that were ready for demolition had been
surveyed and were verified to have radioactive contamination levels less than 5000
disintegrations per minute (dpm) per 100 square centimeters (cm2). The limit complies
with the provisions of a licensee request for the disposal of demolition debris that was
approved by the NRC in a letter dated February 5, 2002. All associated work packages
were complete and organized in accordance with the following licensee procedures:
Bulk Material Release-1 (BMR), Establishing Reference Grid Systems; BMR-3,
Isolation and Control Measures for Screening Surveys; BMR-4-2, Pre-Demolition
Screening Survey; BMR-5, Performance of Pre-Demolition Screening Survey; BMR-6,
Pre-Demolition Independent Verification Survey; and BMR-30, Area Classifications.
c. Conclusions
The licensee implemented the survey program in accordance with the NRCs regulatory
requirements for decommissioning reactors and the licensees decommissioning
procedures.
2.2 Solid Radioactive Waste Management and Transportation of Radioactive Materials
(86750)
a. Inspection Scope
The inspectors reviewed Radioactive Material Transportation Record (RMTR) # S-2272,
for the steam drum shipment and all associated shipping documents. The inspectors
also reviewed internal audits, evaluated compliance with the regulations, and
interviewed staff regarding the implementation of the radioactive waste program
including shipments for disposal of radioactive materials.
b. Observations and Findings
The NRC inspectors determined that the radioactive steam drum was processed and
shipped in accordance with the licensees procedures, and with NRC and Department of
Transportation (DOT) regulations. The licensee staff organized and managed the
documentation in accordance with licensee procedures and demonstrated great
attention to detail. Licensee management conducted an audit of the steam drum
shipment, which the NRC inspectors determined to be adequate. An audit was
completed for every shipment that is processed before the material leaves the site. The
licensee did not identify any problems resulting from the audit.
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c. Conclusions
The licensee met regulatory requirements for the processing and shipping of low-level
radioactive waste for disposal and transportation. No violations of NRC and DOT
regulations were identified.
2.3 Radioactive Waste Treatment, and Effluent and Environmental Monitoring (84750)
a. Inspection Scope
The inspectors observed the licensee collect environmental samples from six on-site
monitoring wells. Specifically, the inspectors observed the licensee extract water
samples from wells PZ-3D, PZ-3MB, PZ-3MA, PZ-5S, MW-6 and MW-9 using
Procedure RCP-53, Sampling of Site Characterization Piezometer (PZ) Wells, and
Procedure RCP-46, Sampling of the Site Characterization MW Wells. The inspectors
obtained split samples from each of the wells noted above and sent the samples to
Oak Ridge Institute of Science and Education (ORISE) for independent radiological
analysis. The inspectors obtained split samples to evaluate the licensees sampling
analysis program.
b. Observations and Findings
The inspectors determined that the licensees procedures and techniques for the
collection of environmental samples from the onsite monitoring wells were adequate.
A comparison of the radiological results between the licensee and ORISE for tritium
(H-3) and carbon-14 (C-14) from the split samples collected from the monitoring wells is
listed in the table below. Only three samples contained H-3 in excess of the Minimum
Detectable Concentrations (MDCs), and none of the samples detected C-14 in excess
of the MDCs. Overall, there was very good agreement between the licensees and
ORISEs analytical results.
Sample H-3 (pCi/L) C-14 (pCi/L)
Well
Licenseea ORISEb Licenseec ORISEd
MW-9 341+/-102 190+/-230 < 11.3 13+/-22
PZ-3MB 361+/-103 290+/-230 < 11.3 37+/-22
PZ-5S 315+/-101 310+/-240 < 11.3 41+/-22
PZ-3D 942+/-124 770+/-250 < 11.3 15+/-22
PZ-3MA 3183+/-182 2900+/-310 < 11.3 28+/-22
MW-6 2326+/-162 2050+/-290 < 11.3 32+/-22
a
The MDC was 200-300 picoCuries/liter (pCi/L).
b
The average MDC was 390 pCi/L.
c
The MDC was 11.3 pCi/L.
d
The average MDC was 37 pCi/L.
6
In addition to H-3 and C-14, ORISE analyzed the above well water samples for
manganese-54 (Mn-54), cobalt-60 (Co-60), zinc-65 (Zn-65), silver-110m (Ag-110m),
iodine-129 (I-129), cesium-134 (Cs-134), Cs-137, europium-152 (Eu-152), Eu-154,
Eu-155, americium-241 (Am-241), curium-243/244, (Cm-243/244), plutonium-238
(Pu-238), Pu-239/240, Pu-241, iron-55 (Fe-55), nickel-63 (Ni-63), Gross Alpha, and
Gross Beta. Because the licensee did not analyze for these isotopes a comparison
could not be made. However, all the ORISE radiological detection results were at
background levels or less than the MDC levels.
c. Conclusions
The inspectors did not identify any concerns during observations of the licensees
collection of well water samples for radioanalytical analysis. Comparisons between the
licensees analytical results and those from ORISE on split samples indicated
acceptable agreement. Overall results indicated the licensees well water sampling and
radioanalytical analysis of water samples was acceptable.
3.0 Inspection Follow-up Item
Closed IFI 05000155/2003005-001: Containment Building Crane malfunction. While
attempting to lift the reactor vessel and place it in the shipping container, the
Containment Building Crane malfunctioned. The total dose to workers repairing the
crane was approximately seven person-rem. Because of the high dose, the licensee
committed to analyze the event, and to identify and implement corrective actions.
An experienced manufacturers representative, who was brought in to inspect the crane,
identified several deficiencies in the Main Hoist Brake adjustments. The deficiencies
were caused by the lack of adequate maintenance and adjustment over a two-year
period of use. The manufacturers representative reviewed the plant crane surveillance
procedures and found that they did not contain criteria needed to make the appropriate
wear adjustments of the brake. The lack of criteria was attributed to the relative
inexperience of the original crane field representative, who participated in the crane
installation two years earlier, and had not provided adequate direction as to what should
be included in the site surveillance procedures. The surveillance procedures were
revised to include the appropriate adjustment criteria for the Main Hoist Brake and other
required vendor information. The licensee issued an Operations Event Report to inform
other industry members of potential problems with this manufacturers crane.
The reactor vessel was subsequently lifted without any problems. The last heavy lift of
radiological significance with the Containment Building Crane involved the steam drum.
That lift occurred without any problems. The crane is no longer needed, and was being
dismantled during the February 2004 inspection. This item is closed.
4.0 Exit Meeting
The inspector presented preliminary inspection results to members of the licensee
management at the conclusion of onsite inspections on December 4, 2003, January 15
and February 20, 2004. The licensee acknowledged the findings presented. The
licensee did not identify any documents or processes reviewed by the inspector as
proprietary.
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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, Audits
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 IFI 05000155/2003005-001
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
DOT Department of Transportation
IFI Inspection Follow-up Item
MDC Minimum Detectable Concentration
NRC Nuclear Regulatory Commission
ORISE Oak Ridge Institute of Science and Education
pCi/L picoCuries per Liter
PZ Piezometer
RMTP Radioactive Material Transportation Record
8