ML051080060

10 CFR 50.59 Report of Changes,Tests and Experiments

ML051080060
Person / Time
Site:	Big Rock Point  File:Consumers Energy icon.png
Issue date:	04/13/2005
From:	Haas K Consumers Energy
To:	Document Control Desk, NRC/FSME
References
Download: ML051080060 (24)

Text

Consmeise A CMS Energy Company Big Rock Point Nuclear Plant Kuar A. Haas 10269 US-31 North General Manager Charlevoix, AMl 49720 April 13, 2005 10 CFR 50.59(d)(3) 10 CFR 50.71 10 CFR 50.4 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 DOCKETS 50-155 AND 72-043 - LICENSE DPR BIG ROCK POINT PLANT -

10 CFR 50.59 REPORT OF CHANGES, TESTS AND EXPERIMENTS Pursuant to 10 CFR 50.59(d)(3), attached to this letter is Consumers Energy Company's report of completed changes, tests, and experiments for the Big Rock Point Restoration Project as described in the Updated Final Hazards Summary Report (UFHSR).

In addition, during the period, the Quality Program for Big Rock Point (Volume 34A, CPC-2A, Quality Program Description for Nuclear power Plants, Part 1, Big Rock Point Plant) was reviewed and accepted by the U.S. NRC in their Safety Evaluation Report dated October 28, 2003. No revisions have been made to this document since its acceptance.

Attachment I describes the modifications performed to support decommissioning and site restoration. This report provides a summary of changes to the facility performed from July 16, 2002 through March 31, 2005. The report includes a brief description of each change and a summary of the 10 CFR 50.59 evaluations.

Attachment II provides changes to procedures, programs, and Defueled Technical Specifications, where appropriate. This report provides a summary of changes to the procedures, programs, and Defueled Technical Specifications from September 1, 2003 through March 31, 2005. The report includes a brief description of each change and a summary of the 10 CFR 50.59 evaluations.

-3We g>SSt

Attachment III is a complete, replacement copy of the Updated Final Hazards Summary Report (UFHSR). Revision 12 to the UFHSR (safety analysis report) replaced UFHSR, revision 11, in its entirety. Re-write of the UFHSR was required due to:

1. Modifications to the facility, and

2. Revisions of procedures, programs, and Defueled Technical Specifications.

These activities were performed for dismantlement and decommissioning and removal of fuel from the spent fuel pool to the Independent Spent Fuel Storage Installation (ISFSI).

The required evaluations concluded that these changes did not require NRC approval pursuant to 10 CFR 50.59.

In addition, Chapter 11 of the UFHSR comprises revision 13. This revision incorporated the January 19, 2005 U.S. Nuclear Regulatory Agency Safety Evaluation Report for the Approval of revised demolition debris disposal procedures in accordance with 10 CFR 20.2002.

Kurt M. Haas Site General Manager cc: Administrator, Region III, USNRC NRC Decommissioning Inspector - Big Rock Point NRC NMSS Project Manager - James C. Shepherd Attachments

ATTACHMENT I CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT DOCKET 50-155 AND 72-043 - LICENSE DPR-6 REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS April 13, 2005 Modifications 4 pages

Big Rock Point Plant Biennial Report of Facility Changes, Tests, and Experiments Attachment I - Modifications NOTE: The temporary modification listed below is for historical reference only. The Condensate Storage Tank was made available for decommissioning. Revision to the UFHSR consisted of addition of reference to use of temporary receiver tanks for short-term storage of liquid radwaste.

JLB-03-0004 Radwaste Sump Pump Temporary Discharge to the Condensate Storage Tank (CST)

Radwaste Sump pump was modified. A temporary line was installed to allow collected water to be pumped to the Condensate Storage Tank for disposal.

Safety Evaluation Summary The installation of the temporary liquid radwaste discharge line is consistent with the UFHSR, Chapter 11.2.

The process for Liquid Radwaste (LRW) handling meets Offsite Dose Calculation Manual (ODCM) and State discharge permit requirements.

Use of the CST rather than another receiver tank is equivalent to the current method. Any tank is a passive, equivalent component.

Temporary equipment is used in accordance with the ODCM for periodic sampling of effluents.

Since a JLB and other minor alterations are in accordance with approved ODCM methodology, no departure from the design basis results.

QRF Log # 689-03 Cartridge/Frame 4874/1310 Page 1 of 4

Big Rock Point Plant Biennial Report of Facility Changes, Tests, and Experiments Attachment I - Modifications MA-02-0026 ISFSI Security and Office Building This minor alteration installed a two-story building south of the ISFSI pad to house site security and ISFSI administrative personnel.

Safety Evaluation Summary The UFHSR was updated to include a revised Site Plan, showing the location of the ISFSI facility, the ISFSI Administrative Building, and the ISFSI access road (former railroad access.) This revision is considered administrative.

QRF Log # 32-03 and 34-04 Cartridge/Frame 4789/1051 and 4877/1520 Page 2 of 4

Big Rock Point Plant Biennial Report of Facility Changes, Tests, and Experiments Attachment I -Modifications NOTE: The Modification listed below is for historical reference only. The plant septic was made available for decommissioning. Revision to the UFHSR consisted of deletion of references to the former sewage and chlorination system.

MA-02-0029 Modification of the Existing Septic System Outside of the Protected Area This minor alteration diverted the existing septic system in anticipation of demolition activities within the former Plant protected area. The waste is collected in a temporary storage tank and transported offsite for processing.

Safety Evaluation Summary.

The change was superceded by the overall review of the UFHSR (deletion of references to the Sewage and Chlorination System) and is being submitted as another completed revision (revision 12).

QRF Log # 212-03 Cartridge/Frame 4914/0281 Page 3 of 4

Big Rock Point Plant Biennial Report of Facility Changes, Tests, and Experiments Attachment I - Modifications NOTE: The Modification listed below is for historical reference only. The Waste receiver tanks were made available for decommissioning. Revision to the UFHSR consisted of addition of reference to use of temporary receiver tanks for short-term storage of liquid radwaste.

MA-03-0009 Isolate the Clean and Dirty Waste Receiver Tanks to enable them to be removed from service.

EDC-MA-03-0009-001 Isolate the Dirty Waste Receiver Tank To continue with decommissioning and demolition of selective portions of the radioactive waste system, the dirty waste receiver tank #2 was isolated from the radwaste system. Dirty waste receiver tank #1, pump P-16A, and other radioactive waste system components will remain in service.

Safety Evaluation Summary One dirty waste receiver tank has sufficient volume to accept all anticipated flow from the radioactive waste sump, the reactor clean and dirty sumps, and the turbine room sumps.

The proposed change due to this modification was superceded by complete revision of UFHSR Chapter 11 and submitted to the US NRC as revision 12.

This minor alteration/ Engineering Design Change did not involve a change in the Defueled Technical Specifications incorporated in the license nor did it require prior NRC approval pursuant to 10 CFR 50.59.

QRF Log # 518-03 and 617-03 Cartridge/Frame 4913/0889 and 4855/0958 Page 4 of 4

ATTACHMENT II CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT DOCKET 50-155 AND 72-043 - LICENSE DPR-6 REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS April 13, 2005 Procedures and Programs 16 pages

Big Rock Point Plant Biennial Report of Facility Changes, Tests, and Experiments Attachment II- Procedures and Programs ALP 1.21, ALP1.22 Deletion of Volume 3 - Alarm Operating Procedures Deletion of monitoring station alarms and associated procedure is due to changing conditions of decommissioning.

Safety Evaluation Summary The occurrence of accidents does not increase, as no alarms remain in the former plant industrial area. All source term is located on the Independent Spent Fuel Storage Installation (ISFSI). With removal of the screen house and availability of the Fire Protection System (FPS) for decommissioning, no SSCs important to safety remain in the former industrial area.

QRF Log # 167-04 Cartridge/Frame 4889/1543 Page I of 16

Big Rock Point Plant Biennial Report of Facility Changes, Tests, and Experiments Attachment II- Procedures and Programs Administrative Procedures - Procedure Re-Write and Creation of Volume 34A Procedures and Deletion of Volume 1 Procedures The cancellation of several Administrative (Volume 1) procedures satisfied development of revised Administrative procedures to match the quality program (Volume 34) and simplify administrative processes associated with greatly decreased Quality-related SSCs and the programs to which they apply.

Procedure 34A - 01: Site Organization Responsibilities and Training Replaced Administrative Procedures DL.0 Plant Decommissioning Organization and Responsibilities D2.1 Operations Department Organization and Responsibilities D2.1.1 Shift Operations D2.1.2 Operations Documents Procedure 34A - 02: Site Document Review, Approval, and Control Replaced Administrative Procedures D1.1 Procedures Program DI.I.l Procedure Writer's Requirements and Guidelines Dl .2 Plant Documents D3.1.4 Preparation and Control of Electrical, Civil, Mech. Specs.

D3.1.8 Revisions to Plant Drawings D4.1.7 Issuance & Control of Procedures, Drawings/Specs & Vendor Equip Info Procedure 34A - 03: Records Management Replaced Administrative Procedure D4.1.1 Plant Records Management Procedure 34A - 04: Corrective Action Replaced Administrative Procedure Dl.3 Corrective Action Procedure 34A - 05: Safety Review and Independent Safety Review Committee Review Replaced Administrative Procedures Dl.4 Safety Review Committee Dl.8 Restoration Safety Review Committee D1.1 I 10 CFR 50.59 and 10 CFR 50.82 Evaluations D1.12 10 CFR 72.48 Evaluations D1.21 Preparation and Control of 10 CFR 72.212 and CoC Report D3.2 UFHSR Management D3.5 Reporting Requirements D3.6 PSDAR Management D4.3 Commitment Tracking D4.5 Format, Composition, & Distribution of Licensing Correspondence Page 2 of 16

Big Rock Point Plant Biennial Report of Facility Changes, Tests, and Experiments Attachment II- Procedures and Programs Procedure 34A - 06: ISFSI Work Process Replaced Administrative Procedures D1.17 VT-2 Examinations D1.18 Control of Work Instructions D2.1.4 Plant Status and Equipment Control D3.1 Decommissioning Work Packages D3.1.1 Plant Modifications D3.1.1.1 Facility Changes D3.1.1.3 Set Point Changes D3.1.1.7 Engineering Work Package D3.1.1.8 Minor Alterations D3.1.2 Engineering Analysis and Sketches D3.1.3 Milestone Work Packages D3.1.7 External Transmittal of Engineering Information D3.1.9 Equipment Database D3.2.9 Control of Special Processes Procedure 34A - 07: Surveillance, Testing, and Work Schedules Replaced Administrative Procedures Dl.9 Surveillance, Testing, and Inspection Programs D1.15 Conduct of Infrequently Performed Tests of Evolutions D2. 1.4.1 Personnel Protective Tagging Conventions D2.2.2 Control of Measuring & Test Equipment & Plant Installed Equip D2.2.3 Decommissioning Periodic and Predetermined Activity Control Procedure 34A - 08: Material Control Replaced Administrative Procedures D4.2.1 Material Control D4.2.1.1 Receipt Inspection D4.2. 1.2 Control of Weld Filler Material D4.2.1.3 Control of Nonconforming Materials/Items D4.2.1.4 Qualification/Certification of Receipt Inspectors D4.2.4 Procurement - General Requirements D4.2.4.1 Procurement of SR Items from Suppliers D4.2.4.2 Procurement of Commercial Grade Items SR (CQ)

D4.2.4.3 Procurement of NSR Items D4.2.4.6 QA Review of Procurement Documents D4.2.4.7 Source Verification D4.2.4.8 Qualification/Certification of QA Reviewers D4.2.7 Contracted Services D4.2.7.1 Project Manager/Service Coordinator Safety Evaluation Summart The revision to the UFHSR was editorial as a result of this procedure re-write project. The Chapter on Conduct of Operations included the title of a specific work process, Page 3 of 16

Big Rock Point Plant Biennial Report of Facility Changes, Tests, and Experiments Attachment II -Procedures and Programs "Decommissioning Work Packaged (DWPs)," which was eliminated and combined with the overall work process.

The editorial change was due to a revision of work process and enabled the deletion of redundant procedures. The revised work process continues to satisfy the requirements of the Quality Program.

QRF Log #

106-04, 107-04, 38-05, 39-05, and 52-05 (New Procedure 34A-01) 96-04, 98-04, 99-04, 100-04, 102-04, 103-04, and 105-04 (New Procedure 34A-02) 93-04 and 94-04 (New Procedure 34A-03) 61-04 and 62-04 (New Procedure 34A-04) 119-04, 121-04, 123-04, 124-04, 127-04, 128-04, 130-04, 132-04, 136-04, 05-04 through 09-04, 101-04, 104-04, 219-04, 220-04, and 262-04 (New Procedure 34A-05) 702-03, 138-04, 140-04, 142-04, 143-04, 145-04, and 147-04 (New Procedure 34A-06) 108-04 through 112-04, an d 179-04 (New Procedure 34A-07) 76-04, 78-04, 80-04 through 92-04 (New Procedure 34A-08)

Cartridge/Frame Numbers upon request Page 4 of 16

Big Rock Point Plant Biennial Report of Facility Changes, Tests, and Experiments Attachment II - Procedures and Programs Procedure O-RBR-01 Retention Basin Release System Operation A new procedure was written for operation of the Retention Basis Release System. This system was installed to provide a means to monitor, store, and release as effluent, the groundwater pumped from excavations in the former plant industrial area.

Safety Evaluation Summary The process for liquid radwaste (LRW) handling is an activity that is quality related. Since water pumped from excavations has the potential to be slightly contaminated, it is monitored and processed to meet the Offsite Dose Calculation Manual (ODCM) and State discharge permit requirements. The retention basin provides a temporary means to meet ODCM and State requirements.

The temporary monitoring equipment enables effluent monitoring according to ODCM requirements and is equivalent to previously installed discharge canal monitors. Periodic sampling of effluent and criteria to trigger that sampling continues to meet the requirements of the 10 CFR Part 20 program, regardless of the equipment used. Equipment is calibrated under the Quality Program requirements. The approved ODCM methodology ensures compliance with regulations. No departure from design basis results since monitoring continues to be in accordance with ODCM requirements.

QRF Log # 208-04 Cartridge/Frame 4902/2747 Page 5 of 16

Big Rock Point Plant Biennial Report of Facility Changes, Tests, and Experiments Attachment II- Procedures and Programs Volume 2 Defueled Technical Specifications - Amendment 125 - Spent Fuel from Wet Storage to Dry Storage on an Independent Spent Fuel Storage Installation (ISFSI)

License Amendment 125: Revision to the Defueled Technical Specifications (DTS) following the removal of all Spent Fuel from wet storage in the fuel pool, originally submitted on November 02, 2002 and supplemented on August 6, 2003 and November 25, 2003.

The Updated Final Hazards Summary Report (UFHSR) paragraph that discusses Management and Technical Support Organization was revised to indicate that the delegation of authority is in affect whether the Site General Manager is on-site or absent. In addition, the Site General Manager, or his designate, shall verify that required security and Emergency Plan staffing has been met.

The U.S. NRC issued DTS amendment 125 on March 19, 2004.

Safety Evaluation Summary The Amendment was an administrative change to the DTS to reflect permanent removal of spent fuel from wet storage in the spent fuel pool. All spent nuclear fuel (SNF), greater-than class C (GTCC) waste, and special nuclear material (SNM) are stored on an Independent Spent Fuel Storage Installation (ISFSI). This configuration presents significantly reduced risk to public health and safety. The revision did not affect any accidents described and evaluated in the UFHSR, except for elimination of those scenarios that are no longer credible (spent fuel pool accidents).

Big Rock Point (BRP) structures, systems, and components (SSCs) that were formerly required for reactor and wet storage of spent fuel were made obsolete by the ISFSI operation for SNF, GTCC, and SNM storage. The amendment made obsolete former accident analyses; including their occurrence, consequences, and malfunction.

Different "type" accidents, their methods of evaluation, and affect on fission product barrier (now the dry fuel storage casks) are evaluated in the vendor Safety Analysis Report approved by issuance of a general license under 10 CFR Part 72 and Certificate of Compliance (CoC)

Number Docket 72-1026.

This amendment resulted in a major re-write of the UFHSR. A complete revision (revision 11) was submitted to the U.S. NRC on April 20, 2004 and has been revised again to reflect further dismantlement of the former Plant area in Revision 12 (see Attachment III to this letter.)

On November 25, 2003, in reply to questions on the proposed August 6, 2003 Defueled Technical Specification Change request, a commitment was made to incorporate staffing requirements into the UFHSR. With all spent nuclear fuel stored on the ISFSI, staffing requirements are no longer driven by "Operating Mode". Staffing is now dependent on the requirements in the Security and Emergency Plans.

Page 6 of 16

Big Rock Point Plant Biennial Report of Facility Changes, Tests, and Experiments Attachment II- Procedures and Programs The removal of staffing requirements from the DTS of "obsolete" reactor modes left no direct guidance on staffing of the ISFSI. Although Security and Emergency Plans have staffing requirements, the responsibility for ensuring that they are met is not evident. This change administratively assigns responsibility for staffing to the Site General Manager. There is no affect on any accident or radiological analyses in the UFHSR as a result of this revision.

This change satisfies a commitment made on November 25, 2003. Although the Security and Emergency Plans have staffing requirements, the responsibility for ensuring they were met was not evident. Assignment of responsibility has no direct affect on any accidents. UFHSR Chapter 15 accident analyses are not affected by this Amendment.

QRF Log # 156-03, 695-03 and 152-04 Cartridge/Frame 4865/0004, 4874/1373, and 4889/1484 Page 7 of 16

Big Rock Point Plant Biennial Report of Facility Changes, Tests, and Experiments Attachment II - Procedures and Programs Volume 2 Defueled Technical Specification Amendment 126 - License Termination Plan On March 24,2005, the U.S. NRC issued Amendment 126 to the Big Rock Point Facility Operating License. This amendment incorporated licensing conditions for the approval of the Big Rock Point License Termination Plan.

Safety Evaluation Summary The License Termination Plan (LTP) was incorporated by reference in to the Updated Final Hazards Summary Report.

LTP activities shall be performed in accordance with approved plant procedures, as outlined in the LTP. CPC-2A, and the radiological control program apply to LTP decommissioning activities. The Final Status Survey Quality Assurance Project Plan (Chapter 5 of the LTP) conforms to guidance found in NUREG-1 575 (MARSSIM). The Environmental Report for Decommissioning (Volume 32) was reviewed in Chapter 8 of the LTP. The performance of these activities has no affect on accident analyses in Chapter 15 of the UFHSR. However, Chapter 15 Section 15.10.4, Non-Fuel Related Decommissioning Accidents, was revised to ensure future changes to methods or evaluations outlined in the LTP are examined to ensure they are bounded by NUREG-0586, Generic Environmental Impact Statement on Decommissioning Nuclear Facilities (GEIS).

The addition of the License Termination Plan (LTP) by reference to the UFHSR outlines processes used to enable eventual termination of the 10CFR Part 50 license. The ultimate goal of this activity is to ensure the termination of the license is not inimical to the common defense and security or to the health and safety of the public. In addition, the LTP outlines methods to achieve license termination that result in no significant effect on the quality of the environment. Title 10 of the CFR, Section 20.1402 has two criteria for evaluating site conditions for unrestricted use, namely 25 mrem/yr TEDE and ALARA.

LTP activities are not an adverse change to Structures, Systems, or Components (SSCs) since the activities will not be performed until SSCs are declared available for decommissioning.

LTP activities are done to ensure 10CFR Part 20 requirements are met. As such, no SSC design functions are affected. However, the activities in the LTP have the potential to affect procedures and methods of evaluation, not currently described in the UFHSR, which may have indirect adverse affects on the environment.

License Termination Plan activities *vere approved by the NRC on March 24,2005 and become a supplement to the UFHSR. Activities described in the LTP may be considered as a test. The proposed License Conditions outline activities that are considered as tests or evaluations. For example, NRC prior approval will be required if changes in the statistical test used for survey unit data evaluations (e.g., the "Sign Test") are made.

QRF Log # 69-03 and 91-05 Cartridge/Frame 4791/1255 and upon request Page 8 of 16

Big Rock Point Plant Biennial Report of Facility Changes, Tests, and Experiments Attachment II- Procedures and Programs Volume 9 Emergency Plan' Revision of Volume 9, Emergency Plan, Chapter 7, Communications, Chapter 8, Organization, Chapter 9, Emergency Response, Chapter 10, Radiological Assessment, Chapter 12, Maintaining Emergency Preparedness, and Appendix A, Letters of Agreement The revisions to the Emergency Plan were a result of corrective action (C-BRP-04-0069) and Audit findings on training deficiencies (C-BRP-04-0228 and C-BRP-05-0009).

C-BRP-04-0069: Communication responsibilities were transferred from the former Pant monitoring station to the Independent Spent Fuel Storage Installation (ISFSI) Central Alarm Station (CAS). Several editorial revisions included revising reference from the monitoring station to CAS, Shift Supervisor to "On-Shift Operations Personnel," and revision of the location of the Emergency Support Center.

C-BRP-04-0228 and C-BRP-05-0009: Training Matrix specifies "Plant Support Personnel",

who were not identified. Plan wvas revised to indicate that the Emergency Response Organization (ERO) has all the responsibilities in the Plan, and any additional Support personnel work directly under the supervision of the ERO personnel, who are trained.

Safety Evaluation Summary As a result of the revision, a thorough review of the Updated Final hazards Summary Report (UFHSR) was also done. UFHSR Section 2.1.3.3 contained a site-specific definition of Big Rock Point's Low Population Zone (LPZ) and Emergency Planning Zone (EPZ), which were revised. This revision to the UFHSR was NOT a result of the above Emergency Plan revisions.

Rather, the definition of the LPZ became void and the Emergency Planning Zone became the site boundary with the exemptions from offsite emergency planning granted by the NRC on September 30, 1998.

The above revisions were evaluated in accordance with the guidance of and found not to decrease the effectiveness (DIE) of the Emergency Plan. These evaluations and revisions were documented in letters to the U.S. NRC dated August 18, 2003 and February 2, 2005.

QRF Log # 170-04, 264-04, 01-05 through 04-05 Cartridge/Frame 4902/2444 and upon request

' Proposed Emergency Plan Exemption Request Submitted to the US NRC October 31, 2003 was withdrawn in a letter to the US NRC dated September 7,2004. The September 7,2004 submittal isa revision of the Emergency Plan, which is a decrease in effectiveness, currently under NRC review.

Page 9 of 16

Big Rock Point Plant Biennial Report of Facility Changes, Tests, and Experiments Attachment II- Procedures and Programs Volume 26 Fire Protection Summary and Associated Administrative Procedures Revision of Volume 26, Fire Protection Summary and revision of deletion of various Administrative Procedures and Operational Procedures was performed to incorporate all procedures as an Appendix to the Fire Protection Summary. In addition, the Fire Protection Summary was reviewed and revised to reflect current site conditions [all Spent Nuclear Fuel (SNF), Greater Than Class C (GTCC) waste, and Special Nuclear Material (SNM) stored on the Independent Spent Fuel Storage Installation (ISFSI)].

The revisions also incorporated the greatly reduced scope of the Fire Protection Plan. Defueled Technical Specification Amendment 125 (March 19, 2004) deleted all Limiting Conditions for Operations (LCOs) for the Fire Protection System. The Fire system was made available for dismantlement in May of 2004. No credible accident with release in excess of design basis limits exists with all SNF, GTCC, and SNM on the ISFSI.

Safety Evaluation Summary The revision to the Fire Protection Summary did not adversely affect the any method of evaluation of accidents in Chapter 15 of the UFHSR. No structures, systems, or components (SSCs) remain in the former plant area that are relied upon for accident mitigation.

The design basis function of fire protection to prevent off-site radiological releases below regulatory limits (10 CFR 20.1402) is no longer a concern. Fire protection plan for the former industrial area is an industrial fire plan. ISFSI fire hazard was analyzed in the site-specific 10 CFR 72.212 fire analysis. Remaining radiological concerns consist of ALARA considerations only. Hazardous radiological releases are no longer credible with all SNF, GTCC, and SNM stored on the ISFSI.

No new types of system or component failures are introduced by the revision of Volume 26.

No active SSCs remain to mitigate Design Basis Accidents. Commitments to previous commitments for fire protection were made void by the use of a passive dry fuel storage system to contain spent nuclear fuel. Analysis of fire effects on storage of spent nuclear fuel in the BNFL FuelSolutionsTm storage system has been thoroughly reviewed via the 10 CFR 72.212 evaluation.

Revision of the fire plan is consistent with remaining credible, analyzed accidents and removal of systems and components from Big Rock Point.

QRF Log 184-04, 185-04, 187-04, through 191-04, 193-02 through 198-04 Cartridge/Frame 4913/2624 and upon request Page 10 of 16

Big Rock Point Plant Biennial Report of Facility Changes, Tests, and Experiments Attachment II- Procedures and Programs Volume 33, BRP-212, 10CFR72.212 and Certificate Compliance Evaluation Report Revision to this document was made as a result of revised application to the U.S. NRC (dated September 15, 2004) and approval of the 10 CFR 20.2002 procedures for disposal of non-impacted waste from Big Rock Point Plant (dated January 19, 20005). This revision consisted of deletion of specific dose scenarios and amounts of demolition debris in the CoC Evaluation.

Prior NRC approval for this alternate disposal was obtained pursuant to 10 CFR 20.2002. The analysis of record for previous approval, dated February 5, 2002, did not include distance to the licensed landfill that accepts PCB contaminated waste. The density of material shipped, along with the increased number of trips for truck driver dose was increased.

Safety Evaluation Summary The analysis submitted (and approved) yielded results that were essentially the same. The same method of evaluation (RESRAD) was used to perform the dose evaluations for transportation worker, landfill worker, and resident/farmer. Results differ slightly, due to revision in quantity, density, and number of trips for transportation workers.

QRF Log # 281-04 Page 1Iof 16

Big Rock Point Plant Biennial Report of Facility Changes, Tests, and Experiments Attachment II- Procedures and Programs Volume 34 CPC-2A, Quality Program Description for Nuclear Power Plants, Part 1, Big Rock Point Plant The Quality Program for Big Rock was reviewed and accepted by the U.S. NRC in their Safety Evaluation Report dated October 28, 2003. No revisions have been made to this document since its acceptance. The Quality Program, as accepted, was incorporated into a local Volume on January 28, 2004 as Revision 21.

QRF Log # 710-03 Cartridge/Frame Upon Request Page 12 of 16

Big Rock Point Plant Biennial Report of Facility Changes, Tests, and Experiments Attachment II- Procedures and Programs Updated Final Hazards Summary Report (UFHSR)

Review and Revision (12) due to Decommissioning and Dismantlement Activities A project to review and update the Final Hazards Summary Report was undertaken to ensure the UFHSR was current and reflected Site conditions as of October 1, 2004. With all spent nuclear fuel removed to the Independent Spent Fuel Storage Installation (ISFSI) and site structures (Turbine Building, Screenhouse, and Reactor Building) released for demolition, systems, structures, and components (SSCs) described in the UFHSR were no longer safety-related. Removal of these SSCs from the site had made portions of the UFHSR immaterial. A general review of the document was performed to remove SSCs that have been eliminated from the site.

Safety Evaluation Summary With all spent nuclear fuel removed from the former industrial area and placed onto the ISFSI, accidents involving fuel are no longer affected. No SSCs that are Quality-Related (Safety-Related or Important-to-Safety) remain in the former industrial area. Demolition activities in the former industrial area can no longer affect the consequences of an accident; all significant source term material is in dry storage at the ISFSI.

QRF Log # 247-04 Page 13 of 16

Big Rock Point Plant Biennial Report of Facility Changes, Tests, and Experiments' Attachment II -Procedures and Programs Updated Final Hazards Summary Report (UFHSR)

Revision (13) due to Revised Demolition Debris Disposal Procedures Approved by the U.S. NRC Pursuant 10 CFR 20.2002 Editorial revisions were made to the UFHSR, Chapter 11, Radiological Waste Management.

The revisions updated discussions on the Big Rock Point Bulk Material Disposal Program. On September 15, 2004, Big Rock requested revision to the 10 CFR 20.2002 procedures granted by the U.S. NRC on February 5, 2002. The changes were required to include disposal of polychlorobiphenyl (PCB) contaminated steel in a landfill at a revised distance from originally approved by the NRC in their approval of Big Rock Point disposal under 10 CFR 20.2002 SER dated February 5,2002. NRC approval was obtained on January 19, 2005.

Safety Evaluation Summary The changes were required to include disposal of PCB contaminated steel in a landfill at a revised distance from originally approved by the NRC in their SER dated February 5,2002.

Dose effects to waste truck drivers, landfill workers and future resident farmer from the revisions outlined are considered minor, are consistent with the original submittal and are well below the public dose objective of I mrem/year. Changes as a result of revised assumptions and dose calculations are included in the proposed request. It is important to note that no credit is taken for reduction in landfill worker or resident farmer doses associated with the disposal of demolition debris in Type II landfill for PCB wastes material sent to the EQCo facility. However, if the entire estimated quantity of PCB bulk product waste were sent to the EQCo facility, doses associated with disposal at the licensed Type II landfill would be reduced for these individuals.

Analyses used to calculate the doses to landfill workers, transportation worker, and farmer/residents were based on quantities of materials presented to the MPSC in April of 2004.

The revised analyses and assumptions of quantities resulted in verification of no changes to Environmental Impacts (the doses remain bounded by the FGEIS). PSDAR sections and discussion of disposal of waste, PCB, and general decommissioning activities remain valid and are not revised by this submittal. Revisions ensure the waste disposal will continue so the site may be release for unrestricted use in accordance with the PSDAR and LTP assumptions.

Disposal of non-radiologically contaminated waste at landfills continues to ensure the cost of decommissioning will not be adversely impacted.

QRF Log # 73-05 Page 14 of 16

Big Rock Point Plant Biennial Report of Facility Changes, Tests, and Experiments Attachment II -Procedures and Programs Post Shutdown Decommissioning Activities Report (PSDAR)

Period Review and Revision (4) due to Decommissioning and Dismantlement Activities A general review of the Past Shutdown Activities Report (PSDAR) was performed to ensure consistency with the completed decommissioning activities and in conjunction with the revision to the Updated Final Hazards Summary Report. The revisions included:

1. Specifying completed activities and revising the schedule for decommissioning to reflect the current schedule.

2. Changing a paragraph on method for monitoring airflow by referencing the Offsite Dose Calculation Manual (ODCM) as the document that is used for controlling airborne contamination.

3. Modifying the "Environmental Impact" section to be consistent with the September 15, 2004 submittal/revision to the NRC for approval of disposal of demolition debris in accordance with 10 CFR 20.2002. The revision broke waste streams into radioactive waste (which continues to be bounded by NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities") and demolition debris disposed of in accordance with procedures approved by the U.S. NRC under 10 CFR 20.2002.

4. Provide an update of information on the "Estimate of Expected Decommissioning Costs," which is consistent with information provided to the Michigan Public Service Commission in March of 2004 and through December 31,2004.

Safety Evaluation Summary PSDAR and UFHSR specify work practices and procedural controls used at BRP that preclude the release of radioactive or other hazardous materials that could threaten future site release.

Revisions do not potentially contaminate or otherwise deposit radioactive or other hazardous materials on the site and could threaten site release for unrestricted use.

Safety analyses have been performed for fuel-related accidents, external events, and non-fuel-related decommissioning activities. Decommissioning activities (activities completed on the schedule and revisions as requested to the NRC for proposed procedures under 10 CFR 20.2002 for disposal of demolition debris) have been assessed and compared to the Generic Environmental Impact Statement (GEIS), and found to be within the bounds of the generic analysis. Decommissioning activities evaluated were equipment deactivation, decontamination, and dismantlement; radioactive material handling and storage; and transportation of radioactive materials. Types of accidents postulated to occur during these activities and evaluated were:

explosions and fires, loss of contamination control, waste transportation accidents, external events and natural phenomena. All activities remain bounded by UFHSR and FGEIS assumptions.

The PSDAR and UFHSR specify work practices and procedural controls used at BRP that preclude the release of radioactive or other hazardous materials that could impact public safety and health.

Page 15 of 16

Big Rock Point Plant Biennial Report of Facility Changes, Tests, and Experiments Attachment II- Procedures and Programs All decommissioning activities identified in the PSDAR have been adequately funded. The PSDAR identifies decommissioning activities in a broad scope, such as: remove asbestos insulation, perform primary system decontamination, remove turbine control oil, and ship and properly dispose of all radioactive materials. Specific activities falling under these broad guidelines have been sufficiently funded. No significant cost increases resulted (a new total cost estimate of 20 percent above the PSDAR total cost estimate or a 25 percent increase in cost above a major milestone estimate. New estimate of 331.1 million for NRC radiological decommissioning is a less than an 11% increase (revised from 299.4 million.)

QRF Log # 27-05 Page 16of16