ML060870648

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Meeting Notice: Meeting Regarding Consumers Energy Proposed Technical Specification Amendment for a Bulk Material Controls Program
ML060870648
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 09/20/2000
From:
NRC Region 1
To:
References
FOIA/PA-2005-0293
Download: ML060870648 (16)
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SUBJECT:

MEETING REGARDING CONSUMERS ENERGY PROPOSED TECHNICAL SPECIFICATION AMENDMENT FOR A BULK MATERIAL CONTROLS PROGRAM DATE & TIME: Wednesday, Sept 20, 2000 11:00 - 12:00 noon LOCATION: 0-1 4B8 PURPOSE: Inform NRC stakeholders of the Consumers Energy license amendment, discuss the communications plan, and hear comments and considerations from staff and management.

AGENDA: As attached.

PARTI _IPANTS:

NRC NMSS/DWM OGC Clearance Research S. Richards J. Greeves A. Hodgdon P. Holihan C. Trottier M. Masnik R. Nelson J. Lieberman A. Huffert P. Harris T. Essig S. Klementowicz Persons invited yet unable to attend:

S. Treby D. Cool Docket No. 50-155 CONTACT: Paul W. Harris, NRR-415-1169 and PWH1 @nrc.gov fi

AGENDA NRC Staff Meeting On Consumers Energy Company Proposed Technical Specification Amendment Establishment of a Bulk Material Control Program Meeting Chair: Paul W. Harris Agenda

1. License Amendment Overview
2. Background Information (very brief)
3. Communication Plan Summary
4. Discussion

Purpose:

Provide an initial briefing to NRC stakeholders whop may have an interest in this license amendment.

FU>NRC Staff Meeting BRP: Bulk Material Controls Program OVERVIEW The licensee submitted an amendment to establish a process by which the licensee will survey solid material to verify that it is free of licensed radioactive material LOGISTICS Lead Office: NRR NRR Tasks

1. NRR to perform No Significant Hazards Determination
2. NRR to prepare Safety Evaluation for the proposed license amendment.!
3. NRR to prepare Environmental Assessment on proposed action
4. NRR to conduct briefs to stakeholders.

NMSS Tasks (proposed):

1. NMSS to perform an evaluation of the licensee's RESRAD runs, assumptions, and default values to ascertain whether the licensee's conclusions are reasonable.
2. NMSS to support briefs to stakeholders.

Principal Communication Tools:

NRC - Internal

  • NRR/DLPM briefs to Decommissioning Management Board (see Comms Plan)

NRC - External

  • Public Meeting in vicinity of plant
  • Meetings with State, NEI, etc. (open to.public observation)

NRC Staff Meeting BRP: Bulk Material Controls Program LICENSE AMENDMENT OVERVIEW Submittal: August 10, 2000 14RR Instruction: Office Letter 802, "License Amendment Review Process."

1. Preparation of a Work Plan
2. Development of Public Notification
3. Preparation of Safety Evaluation
4. Determination of regulatory basis and framework 50.90: submittal appears acceptable 50.36(c): LCO, Surveillance, and Administration 50.36(c)(6): decommissioning TSs, case-by-case 50.36a: Environmental TSs ... no applicability (gaseous and liquid)

Part 20, SubPart K, 20.2001, deals w/licensed material .... no applicability transfer - decay - effluent release (20.1301) - others (sewers, burn etc)

Submittal req's: material description waste disposal considerations disposal site environment other nearby facilities - potential impacts ALARA considerations Precedent: by Steve Klementowicz

5. Concurrence Identification .... per Communications Plan
6. Approval or Denial .... per Communications Plan
7. Generic Applicability .... per Communications Plan

Ft bNRC Staff Meeting BRP: Bulk Material Controls Program PROF'OSED LICENSE AMENDMENT Limiting Condition for Operation D)EMOLITION DEBRIS shall be surveyed prior to release for disposal in a State of Michigan landfill with a bulk container assay system having a DETECTION CAPABILITY ior principal gamma emitters of 6 pcVgr for C0-60 or 14 pci/gr for Cesium-1 37.

  • rhe DEMOLITION DEBRIS survey shall be in accordance with the Bulk Materials Control Program requirements and the specifications and methodology of the BMCM as required by TS Section 6.6.2.11 (a new TS requirement to implement the BMCP).

Applicability: At all times Action: 1. With DETECTION CAPABILITY less than that required above IMMEDIATELY suspend surveying and revise the count time

2. If licensed material is detected:
a. survey to find licensed material, remove licensed material, and re-assay the bulk container, or
b. transport the contents to a radioactive waste processor
c. transport the contents as radioactive waste Surveillance Requirement When DEMOLITION DEBRIS is being surveyed, the DETECTION CAPABILITY shall be verified to be within the limits of this specification as follows:
a. DAILY by performing a CHANNEL CHECK
b. DAILY by performing a mathematical CHANNEL CALIBRATION New Proaram Requirement BMCP: established, implemented and maintained surface contamination survey requirements bulk survey requirements count times for bulk assay instrumentation requirements administrative controls Changes: Approved by the Site General Manager Reports: BMCP changes submitted to NRC with Radioactive Effluent Release Report

COMMUNICATION PLAN Big Rock Point Nuclear Plant (BRP)

Bulk Material Control Program

  • 4B Proposed Technical Specification Amendmenl General Overview On August 10, 2000, Consumers Energy submitted proposed technical specification (TS) amendment to establish a bulk material control program (BMCP). This program, as docketed, defines, in part, the types of materials to be included in the BMCP; radiological survey criteria, techniques, and methodologies; control and administrative processes; and, evaluations to provide reasonable assurance that the release of demolition debris from the BRP site as a result of dismantlement activities will not result in conditions adverse to public health or safety and the environment. The submittal also included, in part, proposed Limiting Conditions for Operations, surveillance requirements, definitions, and TS bases and provided supporting safety and regulatory evaluations. The licensee requested approval of this TS amendment by August 10, 2001.

Communications Plan Objectives

  • Provide accurate and timely information
  • Assure all applicable parties are informed

+ Deal with negative perceptions, dispel rumors, and reduce uncertainty

  • Cooperate with stakeholders and maintain positive relationships Key Policy Considerations
1. Maintain Safety The establishment of a BMCP requirement in the licensee's T.Ss will provide substantial assurance that thousands of cubic yards of demolition debris being released from the site as a result of facility decommissioning will be free of-licensed material (10 CFR 20.1003). This will be accomplished because the proposed amendment establishes radiological survey, instrumentation, and quality assurance requirements, and the controls, processes, and techniques to assure that surveys are consistently effective and based on pre-approved and technically-justified methodologies that are predicated on specific radioactive isotopes, state-of-

-art instrumentation, and detailed procedures.

2. Enhance Public Confidence The submittal of the proposed license amendment is not necessary to safely accomplish decommissioning, however, tangible gains in public confidence-will occur because the licensee embraces the concept of pre-approval of significant activities, such as the release of thousands of cubic yards of demolition debris. The licensee decision to submit the amendment allows the public to scrutinize its solid material radiological survey program, instrumentation, Date: D9/2D/O0 Revision Original

6j COMMUNICATION PLAN Big Rock Point Nuclear Plant Bulk Material Control Pornam management oversight, and other programmatic elements. Further, the license amendment and hearing process assures that the public will have an opportunity to review and comment on NRC actions and findings. The conduct of decommissioning in an open forum lends to increased public confidence.

3. Improve Efficiency and Effectiveness A BMCP TS requirement establishes, in part, a regulatory basis for "how hard" a licensee must look for licensed material (10 CFR 20.1003) in solid material; beyond a "no detectable standard," NRC rules, regulations, and guidance in this area are generally silent. Consumers Energy intends, in part, to "spell out" requirements for the survey of solid demolition debris.

As a result, the BMCP TS, in effect, forces licensee resources to effectively sunrey for radiological isotopes to ensure that demolition debris are indeed free of licensed material, prior to being released from the site. Efficiency will be gained because licensee BMCP surveys will become more consistent and routine. In addition, because the NRC inspection and staff will have measurable standards (e.g., the BMCP and associated TS requirements) by which to independently evaluate licensee survey activities, staff efficiencies will be gained in inspection program implementation.

4. Reduce Unnecessary Regulatory Burden as the process becomes more efficient and effective.

Communication Messages Summary Message Consumers Energy is proposing a license amendment to establish a process by which solid material will be radiologically surveyed to verify that it is free of licensed radioactive material Key Messages

1. On August 10, 2000, Consumers Energy proposed a license amendment to establish TS requirements for the radiological survey of solid material demolition debris. These requirements will included, in part, Limiting Conditions for Operations, surveillance, instrumentation, and quality assurance requirements, and the controls, processes, and techniques to assure that the radiological survey of demolition debris is consistently effective and based on pre-approved and technically-justified methodologies. These methodologies will be based on specific radioactive isotopes, state-of-art instrumentation, and detailed-procedures (i.e., the BMCM).

Date: 9/20/00 Revision: Original

COMMUNICATION PLAN Big Rock Point Nuclear Plant Bulk Material Control Proarn

2. The licensee-proposed Bulk Material Control Program (BMCP) will include only demolition debris from the decommissioning of the BRP facility, where demolition debris is limited to concrete, rebar, structural steel, sheet metal, roofing materials, foundation concrete, and minor amounts of dug up soil. Demolition debris will riot include plant systems or components.
3. It is very important to note the central focus of the Consumers Energy approach: the debris is surveyed and radiologically clean, however, the licensee is to implement another step to provide further assurance it's clean. All material entering the program will already be free of detectable radioactivity using existing industry practices and the additional radiological survey step (i.e., the bulk assay) will provide defense-in-depth that the material is indeed free of licenced material. The licensee is not proposing a standard to which it will survey and free release radioactive material.
4. Demolition debris will be disposed of in a State of Michigan licensed landfill.
5. The licensee has stated that demolition debris released from the site will not enter the waste or recycle streams.
6. The licensee proposes a "how hard to look" program based on the radioactive isotope of concern, instrumentation capabilities, and statistical assurance that principal gamma emitters will be detected. The licensee will not establish a radiological dose limit, clearance level, or a limit below which could be considered "below regulatory concern."
7. If demolition debris is released from the BRP site to the State licensed landfill at the established limits of detectability (which are dependent, in part, on the radiological isotope, instrumentation, and background), the worst-case radiological dose to an average member of the critical group will be less than or equal to 1 mrem/yr (TEDE) from all exposure pathways.

,3. The State of Michigan Department of Environmental Quality has provided preliminary support of the licensee's proposed actions.

9. The Bulk Material Control Manual (BMCM) is simply a licensee prograrm that is similar in format to the BRP Offsite Dose Calculation Manual (ODCM) and Radiological Effluent Monitoring Program. The BMCM is divided into five parts:
1. Specifications and requirements for BMCGM implementation
2. Bases and descriptions of methodology, modeling, and assessment
3. Record keeping requirements
4. Quality assurance and control considerations
5. Reporting and change requirements Date: 9.'20/00

-3 -- Revision: Original

COMMUNICATION PLAN

  • ,, * ,,*+Big Rock Point Nuclear Plant Bulk Material Control Program
10. The licensee's submittal will undergo the NRC normal review and approval process.

However, approval is not a foregone conclusion. Many considerations need to be evaluated and assessed by the staff and NRC management, such as: regulatory justification and basis, public health and safety, and potential environmental considerations.

11. The staff plans to directly solicit public comment through the conduct of public meetings at NRC Headquarters and in the vicinity of the BRP facility. Further, meetings with the licensee, State of Michigan, and other stakeholders will be open to the public, as necessary. The staff will address all comments and questions when asked or respond in writing if further staff evaluation is necessary.
12. NRC regional inspection will verify adequacy of program implementation.
13. To summarize, this is a license submittal, similar to an Offsite Dose Calculation Manual or Radiological Effluent Monitoring Program, the defines a process by which the licensee will radiologically survey solid materials to determine whether the debris is free of licensed material. The licensee is not free releasing radioactive material.

Stakeholder Identification Internal lI External Group E: State Programs Grou NpRPublic A: & Press Group A: NRR I Interest Groups (NEI)

Individual Utilities Group B: NMSS Group C: Commission EDO Decom Mgt Board Clearance Group Group D: Research Regions Grouping Rational Group A Overall project management and technical responsibility Group B Primary responsibility for close modeling evaluation Group C Policy and direction -

Group D Regional Inspection of BMCP implementation and Research Group E External stakeholders Date: 9.'20/00 4- Revision: Original

IM71 COMMUNICATION PLAN

,*. Big Rock Point Nuclear Plant Bulk Material Control Piomram Other Stakeholders (5 Special Groups)

1. Nuclear Energy Institute NEI has demonstrated keen interest in NRR decommissioning rulemaking and generic communication initiatives, including NRR update of the Generic Environmental Impact Statement on decommissioning facilities (NUREG 0586). Further, NEI interest is focused on license termination and industry approaches to dismantlement and decontamination.

Actions to Improve Communications:

a. Brief the NRR NEI liaison officer.
b. At next NRR/NEI meeting on decommissioning mention the receipt of the proposed license amendment.

c Invite NEI to public meeting.

d. Consider inviting NEI to NRC/Licensee meeting.
2. Environmental Protection Agency EPA has demonstrated interest in: (1) Big Rock Point decommissioning, most notably with offsite emergency preparedness; (2) NRC's effort to update the Generic Environmental Impact Statement on decommissioning facilities (NUREG 0586); and, (3) the environmental evaluations by the staff following licensee submittal of its Post-Shutdown Decommissioning Activities Report.

Actions to Improve Communications:

a. Brief the NRR EPA liaison officer.
b. Ensure the OGC NEPA expert is briefed and kept informed.
c. Brief the NRC Region III management regarding EPA communications.
d. Invite EPA to the public meeting.
3. U.S. Senate and Congressional Representatives from Michigan Although the Michigan Department of Environmental Quality (DEQ), a State agency working for the Governor's Office, indicated support for the licensee's proposed actions to dispose demolition debris verified free of licensed material in a State-licensed landfill, US. .Senate and Congressional representatives have not indicated their views or positions.

Actions to Improve Communications:

a. Brief the NRC State Liaison, both in Region IlIl and Headquarters. -.
b. Brief NRC Congressional Liaison.
c. Be prepared to meet with Senate and Congressional Aides. -- -
d. Consider invite to public meeting.

Date: S/20/00 SRevision: Original

COMMUNICATION PLAN Big Rock Point Nuclear Plant Bulk Material Control Proaram

4. Charlevoix and Surrounding County Elected Officials Locally-elected Officials and/or public concerns regarding the licensee's proposed actions may be concerned about: (a) radiological safety during transportation; (b) radiological safety during and after landfill disposal; (c) public transportation safety; and (d) landfill capacity and use.

Actions to Improve Communications:

a. Brief the NRC State Liaison, both in Region Ill and Headquarters.
b. Propose to meet with locally-elected Officials.
c. Coordinate With Michigan DEQ to ensure that locally-elected Officials are well briefed.
d. Invite to public meeting (newspaper press release et al).
5. Big Rock Point Citizens Awareness Committee This Committee consists of local public citizens who by and large represent the community surround the BRP facility. The Committee meets periodically to listen tc) licensee presentations, discuss licensee activities and materials, and make recommendations to BRP management. Although Committee actions and recommendations are not binding upon the licensee, Consumers Energy has historically been receptive to its comments and concerns. The NRC has briefed this committee on a number of occasions.

Actions to Improve Communications:

a. Provide a copy of the proposed licensee amendment to the BRP CAC.
b. Brief the BRP CAC on regulatory amendment process, technical review, schedule, and respond to questions.

Cross.-Cutting Stakeholder Issues:

1. Similarity to "Clearance" rulemaking
2. Similarity to "Below Regulatory Concern"
3. Circumvention of license termination process
4. Dose modeling assumptions
5. Environmental assessment scope and impact
6. Regulatory basis for granting approval Date: 9120/00 Revision: 04ginal

Sl COMMUNICATION PLAN Big Rock Point Nuclear Plant Bulk Material Control Program Cost End Schedule All licensing activities will be conducted in-house. There will be no maintenance or external (e.g., contractor) costs.

Other internal costs will include:

Licensee and Public Meeting(s) travel, preparation, advertisement, meeting room, audio visual, court reporter Web Site - performed in-house, routine, minor update requirements Public Affairs Interfaces and Point Of Contacts Communications Protocol

a. Incoming external communications to NRC Headquarters -

direct to NRC Public Affairs (Victor Dricks @ 301-415-8204).

b. Incoming external communications to NRC Region IlIl -

direct to Region III Public Affairs (Jan Strasma @ 630-829-9663)

c. Internal Headquarters and Regional communications -

direct to Overall Project Lead (Paul Harris @ 301-415-1149)

Overall Proiect Lead Paul Harris, Project Manager, Big Rock Point Phone: 301-415-1169 Decommissioning Section E-mail: PWH1 @nrc.gov Project Directorate IV & Decommissioning Division of Licensing Project Management Office of Nuclear Reactor Regulation Public Affairs NRC: Victor Dricks 301-415-8204 OPA Rg III: Jan Strasma 630-829-9663 OPA Point of Contacts NRR: Paul W. Harris 301-415-1169 NRR/DLPWPDIV-D NMSS: Robert "Bob" Nelson 301-415-7298 NMSS/DWM/DCB RES: Cheryl Trottier 301-415-6232 RES/DRAA/RPERWMI

- OGC: Ann Hodgdon 301-415-1587 OGC -

Rg Ill: Bruce Jorgensen 630-829-9615 RGN-III/DNMS/DB Decommissioning Mgt Board A-Chaicx Larry Camper 301-415-6708 NMSS/DWM Clearance Steering Group A-Chair: Don Cool 301-415-7197 NMSS/IMNS Date: 9/20/00

- Revision: Original

o COMMUNICATION PLAN

  • +Big. Rock Point Nuclear Plant Bulk Material Control Proam NRC Internet Home Page A summary of the licensee's proposed TS recquest will be:
a. Posted on the NRC Internet Home Page.
b. Provided to:
1. The Public Affairs interfaces
2. State DEQ representative
3. BRP CAC Evaluation Progress measured by:
a. accomplishment of "Presentations"
b. NRR Work Request schedule
c. Technical Assignment Control (TAC) process Feedback measured by:
a. NRR/DLPM public meeting feedback forms
b. NRC staff and management feedback Findings Reporting of Results
a. Briefings/Presentations (see applicable sections
i. NRR/NMSS management briefings ii. Decommissioning Management Board brief iii. et al
b. Acceptance of Denial letter to licensee
c. Federal Register notice on acceptance or denial
d. Public Meeting with stakeholders Date: 9/20/00

-- Revision: Original

COMMUNICATION PLAN Big Rock Point Nuclear Plant Bulk Material Control Piogram Communication Tools Tools' Group l SelGroups F Reason . I E-mail A, B, C, D na informal communication tool Website all all succinct and accurate info Face-To-Face all all, if possible effective and efficient Communications succinct and accurate public out-Press Release Ereach initiative Written Summary Detailed C2 . implementation of clear and plain Less-detailed D, E all language writing initiative vall succinct and accurate public out-Public Meeting all invited reach initiative LAN N na site-specific licensing action Announcements NR&C s na site-specific licensing action Surveys naasite-specific licensing action Posters/Fliers na site-specific licensing action na - not applicable Group A: NRR Group D: Research Group B: NMSS Regions Group C: Commission Group E: State Programs EDO Public & Press Decom Mgt Board Interest Groups Clearance Steering Group Individual Utilities Special Groups

1. Nuclear Energy Institute
2. Environmental Protection Agency
3. U.S. Senate and Congressional Representatives from Michigan
4. Charlevoix and Surrounding County Elected Officials
5. Big Rock Point Citizens Awareness Committee Note 1: As required.

Note 2: Detailed summaries only to EDO and Commission.

Date: 9/20/00

-9 Revision: Original

COMMUNICATION PLAN Big Rock Point Nuclear Plant Bulk Material Control Program Review, Concurrence, and Approval Review Concurrence Approval Notes NRR/DLPM V V V All packages NRR/DIPM/IOLB I/ SERI for BMCP technical evaluation NRR/DRIP/RGEB V - EA2 for license amendment NMSS V V SER 3 for RESRAD/dose modeling Research Note 4

  • Regions Note 4 Decom Mgt Board Note 4 See 'Presentations' Note 1: SER review, writing, concurrence, & approval within IOLB followed by submittal to NRR/DLPiMV Note 2: EA review, writing, concurrence, & approval with RGEB followed by submittal to NRR/DLPM Note 3: SER (or equivalent) evaluation, review, writing, concurrence, & approval within DWM followed by submittal to NRR/IOLB Note 4: Courtesy copies will be provided and comments will be evaluated &dispositioned, as required Presentations (Initial and Final Briefings)

Initial Briefings: To Inform of Licensee Submittal (see Notes next page)

Informal Formal Public Mtq Date Notes NRR/DIPM/IOLB V - no Sept 19, 00 completed NRR/DRIP/RGEB V - no Sept 15, 00 completed NRR/DLPM1PD V no Sept 20, 00 determines need for NRR Dep Dir brief NMSS/DWM I- no Sept 20, 00 determines need for NMSS Director brief NMSS Director V no tbd if required NRR Director V no tbd if required Decom Mgt Bd #1 . V no Sept 14 completed by S. Klementowicz Research - V no Sept00 attendance at Sept 14 Decom Mgt Bd Regions - V no Sept00 attendance at Sept 14 Decom Mgt Bd Clearance Steering - V no Oct 19 if directed by Decom Mgt Board Meeting with State - - / Yes tbd at State of Michigan DEQ office ACNW - V Yes tbd if required EDO Staff V - no tbd if required Commission TAs V - no tbd if required Commission aV no tbd if required icensee Mtg #1 V - Yes tbd Status, RAI, technical, etc NEI Meeting V - Yes tbd combine with Licensee Meetings?

Public Meeting - / Yes Jan 01 in vicinity of the plant Decom Mgt Bd #2 - V no Sept 14 After public, NEI, and licensee meetings Date: 9/20/00

. . Revision: Original

COMMUNICATION PLAN Big Rock Point Nuclear Plant Bulk Material Control Proaram mw-l Final Briefings: To Inform of Staff Disposition of Amendment (See Notes below)

Conducted prior to issuance of Approval or Denial.

Informal Formal Public Mta Date Notes Licensee Mtg #2 - V Yes tbd if required NRR mgt V no tbd if required NMSS mgt V no tbd if required ACNW V Yes tbd if required EDO Staff V - no tbd if required EDO V no tbd if required Commission TAs no tbd if required Commission Brief / no tbd if required Decom Mgt Bd #3 - / no tbd Notes:

1. OGC and Research will be invited to all presentations and meetings.
2. Comments from Regions and Research will be solicited and dispositioned.
3. This schedule will change if a hearing is granted.
4. Overall Project Lead is responsible for all meeting notices and notifications.

Date: 9/20/00 Revision: Original

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