ML13009A177
| ML13009A177 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 01/08/2013 |
| From: | Christine Lipa NRC/RGN-III/DNMS/DB |
| To: | Vitale A Entergy Nuclear Operations |
| Tapp J | |
| References | |
| IR-12-001 | |
| Download: ML13009A177 (13) | |
See also: IR 07200043/2012001
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 Warrenville Road, Ste 210
Lisle, IL 60532-4362
January 8, 2013
Mr. Anthony Vitale
Vice-President, Operations
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant
27780 Blue Star Memorial Highway
Covert, MI 49043-9530
SUBJECT: BIG ROCK POINT INDEPENDENT SPENT FUEL STORAGE INSTALLATION
INSPECTION REPORTS 07200043/12001(DNMS) AND 05000155/12001(DNMS)
Dear Mr. Vitale:
On December 18, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed a routine
inspection at the Big Rock Point Independent Spent Fuel Storage Installation (ISFSI). The
purpose of the inspection was to evaluate whether the facility was operating in accordance with
NRC approved License Conditions and Technical Specifications, and to evaluate the biennial
exercise of the Emergency Plan. At the conclusion of the on-site inspection on October 11, 2012,
the inspector discussed the interim inspection results with members of your staff. At the
conclusion of the in-office review on December 18, 2012, a final telephone exit meeting was
conducted to discuss the final results with members of your staff.
The inspection consisted of review and evaluation of radiation protection, surveillance and
maintenance, environmental protection, quality assurance, and the observation and evaluation
of the ISFSI Emergency Preparedness exercise. Areas examined during the inspection
consisted of observations of activities in progress, interviews with personnel, and a select
review of procedures and representative records.
Based on the results of this inspection, the NRC has determined that one Severity Level IV
violation of NRC requirements occurred. This violation is being treated as a Non-Cited
Violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy. The NCV is described
in the subject inspection report. If you contest the violation or significance of the NCV, you
should provide a response within 30 days of the date of this inspection report, with the basis for
your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk,
Washington DC 20555-0001, with copies to: (1) the Regional Administrator, Region III; and
(2) the Director, Office of Enforcement, United States Nuclear Regulatory Commission,
Washington, DC 20555-0001.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRCs
Rules of Practice, a copy of this letter and enclosure will be available electronically for public
inspection in the NRC Public Document Room or from the NRC's Agencywide Documents
Access and Management System (ADAMS), accessible from the NRC website at
http://www.nrc.gov/reading-rm/adams.html.
A. Vitale -2-
We will gladly discuss any questions you may have regarding this inspection. If you have
questions, please contact Mr. Jeremy Tapp of my staff at 630-829-9862.
Sincerely,
/RA/
Christine A. Lipa, Chief
Materials Control, ISFSI, and
Decommissioning Branch
Division of Nuclear Materials Safety
Docket Nos. 072-00043; 050-00155
License No. DPR-6
Enclosures:
Inspection Report Nos. 07200043/12001(DNMS);
cc w/encls: Distribution via ListServ for Palisades
K. Yale, Michigan State Liaison Officer
D. Malone, Palisades and Big Rock EP
R. Vanwagner, Manager, Dry Fuel Storage
O. Gustafson, Manager, Licensing
L. Potter, ISFSI Supervisor, Big Rock
Point Restoration Site
F. Rives, Director, Nuclear Fuels
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket Nos.: 072-00043; 050-00155
License No.: DPR-6
Report Nos.: 07200043/12001(DNMS)
Licensee: Entergy Nuclear Operations, Inc.
Facility: Big Rock Point Independent Spent
Fuel Storage Installation
Location: 10269 U.S. 31 North
Charlevoix, MI 49720
Dates: Onsite: October 10 - 11, 2012
In-Office Review through December 18, 2012
Inspector: Jeremy Tapp, Health Physicist
Approved by: Christine A. Lipa, Chief
Materials Control, ISFSI, and
Decommissioning Branch
Division of Nuclear Materials Safety
Enclosure
EXECUTIVE SUMMARY
Entergy Nuclear Operations, Inc.
Big Rock Point Independent Spent Fuel Storage Installation
NRC Inspection Reports 07200043/12001(DNMS) and 05000155/12001(DNMS)
The inspection consisted of observations and an evaluation of the licensees programs
including, surveillance and maintenance, environmental monitoring, quality assurance, and
observation and evaluation of the Independent Spent Fuel Storage Installation (ISFSI)
emergency preparedness (EP) exercise.
- The licensee adequately demonstrated the effectiveness of its ISFSI Emergency Plan
and its ability to implement the plan in response to an emergency (Section 1.1).
Surveillance and Maintenance
- The licensee implemented its surveillance and maintenance program in accordance with
applicable regulations, the License, and Technical Specifications (TS). The U.S.
Nuclear Regulatory Commission (NRC) is continuing to review the licensees evaluation
of the conditions noted from the interior of the storage cask from the five-year cask
inspection (Section 1.2).
Environmental Monitoring
- The licensee established and maintained its environmental monitoring program in
accordance with applicable Title 10 Code of Federal Regulations (CFR) Part 20, 50 and
72 regulations, the License, and TS (Section 1.3).
Quality Assurance
- The licensee performed changes to its EP program in accordance with site procedures
and applicable regulations. The licensee also performed audits of its Radiation
Protection program that were of adequate scope and in accordance with the applicable
regulations. The licensee implemented its corrective action program in accordance with
the applicable regulations and site Quality
Assurance (QA) requirements with one exception. The licensee failed to update the
License Termination Plan (LTP) in accordance with license requirements, which was not
identified by the licensee through their corrective action process. The licensee has
implemented prompt corrective actions to restore compliance and prevent recurrence
(Section 1.4).
2
Report Details
1.0 Away from Reactor Independent Spent Fuel Storage Installation (ISFSI)
(IP 60858)
a. Inspection Scope
The inspector observed and evaluated the conduct of the ISFSI biennial radiological
emergency preparedness (EP) exercise. The inspector reviewed the Big Rock Point
ISFSI Emergency Plan and implementing procedures, and the applicable documents
which contained the exercise scenario and the sequence of actions needed to mitigate
consequences of the event. The inspector reviewed the proposed exercise scenario to
understand its scope and evaluate its adequacy to ensure the licensee could
demonstrate its emergency response capabilities. The inspector observed the
pre-exercise briefing, the exercise, and the licensees formal post-exercise critique.
b. Observations and Findings
Section 5.8 of the Big Rock Point ISFSI Emergency Plan requires the licensee to
perform a biennial exercise to demonstrate emergency response capabilities and
effectiveness of the licensees Emergency Plan. The scenario for the
October 10, 2012, exercise involved a simulated lightning strike and subsequent fire
within the ISFSI protected area that caused damage to a loaded storage cask and
storage area electrical systems. Local firefighters provided offsite support in real time in
response to the simulated emergency. In addition, local law enforcement participated in
providing simulated support of the site security force, including traffic control at the entry
road.
In response to the event, the licensee implemented appropriate, timely, and necessary
actions to address the simulated event. The licensee correctly classified the event,
made timely notifications, augmented personnel as needed, conducted adequate
radiological monitoring, and ensured the safety of personnel. Licensee personnel
maintained control throughout the scenario, starting with a prompt recognition of the
initiating event and through recovery discussions. Throughout the exercise, the
licensees staff communicated well with all involved parties and demonstrated
knowledge of the Emergency Plan. During the post-exercise critique, the licensee
adequately evaluated its emergency response and management capability.
The inspector identified observations in the areas of radiation protection and
communications. Site personnel did not perform response checks on radiological
instruments before use to assess radiological conditions in the field. Response checks
are a standard industry practice that are performed before use to ensure instruments will
respond appropriately to radiation. This observation has been entered into the
licensees corrective action program. In addition, during the review of logs, the inspector
was not able to determine if the identification and classification of a Notice of Unusual
Event (NOUE) was communicated to the State of Michigan. The licensee had declared
an Alert shortly after the NOUE was declared and due to that short time frame, had
potentially not notified the State of Michigan of the NOUE declaration before notifying
3
them of the Alert. The licensee was not able to verify whether or not the notification of
the NOUE had been communicated. This observation has also been entered into the
licensees corrective action program.
No findings of significance were identified.
c. Conclusion
The licensee adequately demonstrated the effectiveness of its ISFSI Emergency Plan
and its ability to implement the plan in response to an emergency.
1.2 Surveillance and Maintenance
a. Inspection Scope
The inspector reviewed the licensees surveillance and maintenance program associated
with dry fuel storage to verify compliance with the applicable regulations, the License,
and Technical Specifications (TS). The inspector walked down the ISFSI pad, observed
daily surveillance activities, interviewed personnel, and reviewed select documents. The
inspector reviewed temperature logs for June, July, and August 2011 and January, May,
July, and August 2012. The inspector also reviewed the licensees results from the
second five-year inspection of the first loaded storage cask.
b. Observations and Findings
The inspector conducted a walk down of the ISFSI pad and observed authorized and
trained licensee staff perform daily surveillances of the casks including temperature
monitoring, verifying the readings were well below Technical Specification limits, and
inlet and outlet vent screen checks to ensure they were free of significant blockage or
damage. The inspector also evaluated the general condition of the pad, the transfer
cask, lift unit, horizontal transfer system and the J-skid. The inspector noted that the
review of temperature log data indicated that the casks operated as designed with no
abnormalities. The inspector found that the licensee performed and documented the
surveillance activities as required by TS and site procedures. In addition, the inspector
performed independent radiation surveys of the casks and general ISFSI area with a
Canberra UltraRadiac dose rate meter, and the results were bounded by the radiological
posting and consistent with the licensees.
In addition, the inspector reviewed the licensees five-year cask inspection
documentation for storage cask number 7 that includes both pictures and video of the
interior of the cask. The licensee performed this inspection as required by T365-35, Dry
Fuel Storage Cask Inspections, Revision 7. The inspector noted a material deposit and
streaking on the canister shell and also mineral deposits on the interior of the storage
cask. The licensee performed an evaluation of the deposits and streaking and
documented it in CAMCA-12-023, Evaluation of Big Rock Point FuelSolutions' W150
Cask 5-Year Inspection Results, dated November 8, 2012. The licensee determined
that the conditions identified above do not adversely affect the ability of the cask system
to perform its intended safety functions and do not require repair. As of the exit date for
this inspection, the adequacy of this evaluation and its conclusion is currently under
4
review by the NRC (IFI 07200043/12001-01 and IFI 05000155/12001-01; Adequacy of
Five-year Cask Inspection Evaluation).
No findings of significance were identified.
c. Conclusion
The licensee implemented its surveillance and maintenance program in accordance with
applicable regulations, the License, and TS. The NRC is continuing to review the
licensees evaluation of the conditions noted from the interior of the storage cask from
the five-year cask inspection.
1.3 Environmental Monitoring
a. Inspection Scope
The inspector reviewed the licensees annual Radioactive Effluent Release Report for
2010 and 2011, which was prepared in accordance with the requirements of Title 10 of
the Code of Federal Regulations (CFR) 50, Appendix I and Technical Specifications 6.6.2. The inspector also reviewed gamma dose results for 2010 and 2011 for the ISFSI
protected area fence and controlled area boundary. This review evaluated whether the
licensee was in compliance with the off-site dose requirements prescribed by 10 CFR
72.104.
b. Observations and Findings
Currently, the only radiological environmental monitoring required for the ISFSI is gamma
dose because the licensee no longer has any liquid or gaseous effluent releases. In
addition, the licensee did not perform any activities since 2009 that generated any solid
radioactive waste. The results for both 2010 and 2011 were similar and well under the
limits of 10 CFR 72.104.
No findings of significance were identified.
c. Conclusion
The licensee established and maintained its environmental monitoring program in
accordance with applicable 10 CFR Part 20, 50 and 72 regulations, the License, and
Technical Specifications.
1.4 Quality Assurance
a. Inspection Scope
The inspector reviewed corrective action reports from 2011 and 2012 to determine the
licensees effectiveness in identifying, resolving, and preventing problems. The inspector
reviewed facility procedural changes to its EP program and their associated evaluations
from 2011 to verify compliance with the applicable regulations and site quality assurance
(QA) requirements. The inspector also reviewed and evaluated the 2010 and 2011
Radiation Protection Program Annual Reviews required by 10 CFR 20.1101(c) to
5
determine the adequacy of their scope and evaluate the results and any subsequent
actions taken by the licensee.
b. Observations and Findings
A review of condition reports (CRs) written during 2011 and 2012 indicated that the
licensee was effectively identifying and following up on pertinent facility issues. The
inspector determined that issues were being effectively addressed and adequately
closed out to prevent recurrence with one exception as described below.
During the review of CR-PLP-2011-01700, the inspector noted that the licensee determined
an update to their License Termination Plan (LTP) was not performed as required by
10 CFR 50.71(g). The licensee last updated their LTP on September 27, 2005. During the
licensees performance of corrective actions as a result of this determination, the licensee
concluded that 10 CFR 50.71(g) did not apply to the LTP. Subsequently, the inspector
reviewed the requirements to update the LTP. The inspector determined that the licensees
evaluation failed to recognize that a condition of the facility license required a periodic
update.
As a result of this review, the NRC identified a Severity Level IV Non-Cited Violation (NCV)
of Condition 2.C.(4) of License No. DPR-06, Amendment 127 dated April 13, 2007 for
failure to update the LTP every 24 months. Specifically, during the period between 2007
and 2011, the licensee did not submit an updated LTP every 24 months.
Condition 2.C.(4) of License No. DPR-06, Amendment 127 dated April 13, 2007, states,
in part, the licensee shall submit an updated LTP in accordance with 10 CFR 50.71(e).
10 CFR 50.71(e) states, in part, nuclear power reactor facilities shall update the Final
Safety Analysis Report (FSAR) periodically. For facilities that have submitted their
certifications required by 10 CFR 50.82(a)(1), subsequent revisions to the FSAR must
be filed every 24 months.
Contrary to the above, the licensee failed to submit an updated LTP in accordance with
10 CFR 50.71(e) from 2005 to 2011. The inspector used Traditional Enforcement
guidance to determine the significance of the violation. This violation was determined to
be a Severity Level IV violation using the Enforcement Policy, Example 6.1.d.3, in that the
licensee failed to update the LTP as required but the potential erroneous information was
not used to make an unacceptable change to the facility or procedures. The licensee
entered this issue into the corrective action program (CR-PLP-2012-7785) and is currently
completing an update to the LTP. This violation is being treated as an NCV, consistent
with Section 3.1.1 of the NRC Enforcement Manual. (NCV 07200043/12001-01 and
NCV 05000155/12001-01; Failure to Update the LTP Every 24 Months)
One Severity Level IV NCV was identified.
c. Conclusion
The licensee performed changes to its EP program in accordance with site procedures
and applicable regulations. The licensee also performed audits of its Radiation
Protection program that were of adequate scope and in accordance with the applicable
regulations. The licensee implemented its corrective action program in accordance with
6
the applicable regulations and site QA requirements with one exception. The licensee
failed to update the LTP in accordance with license requirements, which was not
identified by the licensee through their corrective action process. The licensee has
implemented prompt corrective actions to restore compliance and prevent recurrence.
2.0 Exit Meeting
The inspector presented the interim inspection results to members of the licensee staff
at the completion of the onsite inspection activities on October 11, 2012. After the
conclusion of the in-office review, the inspector presented the final inspection results to
members of the licensee staff during an exit teleconference on December 18, 2012. The
licensee acknowledged the results presented and did not identify any of the documents
reviewed as proprietary in nature.
ATTACHMENT: SUPPLEMENTAL INFORMATION
7
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PEOPLE CONTACTED
Larry Potter, Big Rock Point ISFSI Supervisor
Bob Vanwagner, Manager, Dry Fuel Storage
Steve LaJoice, Securitas Security Manager
INSPECTION PROCEDURE USED
60858 Away-From-Reactor ISFSI Inspection Guidance
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened Type Summary
IFI 07200046/12001-01 IFI Adequacy of Five-year Cask Inspection Evaluation
NCV 07200046/12001-01 NCV Failure to Update the LTP Every 24 Months
Closed
NCV 07200046/12001-01 NCV Failure to Update the LTP Every 24 Months
Discussed
None
LIST OF ACRONYMS USED
ADAMS Agencywide Documents Access and Management System
CFR Code of Federal Regulations
CR Condition Report
DNMS Division of Nuclear Materials Safety
IFI Inspection Follow-Up Item
IP Inspection Procedure
ISFSI Independent Spent Fuel Storage Installation
LTP License Termination Plan
NCV Non-Cited Violation
NOUE Notice of Unusual Event
NRC U.S. Nuclear Regulatory Commission
QA Quality Assurance
TS Technical Specifications
Attachment
LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection. Inclusion on this list does
not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that
selected sections of portions of the documents were evaluated as part of the overall inspection
effort. Inclusion of a document on this list does not imply NRC acceptance of the document or
any part of it, unless this is stated in the body of the inspection report.
Big Rock Point ISFSI Emergency Plan, Revision 6
Big Rock Point 2012 Emergency Exercise
Surveillance and Maintenance
Licensee documents reviewed and utilized during the course of this inspection are specifically
identified in the Report Details above.
Environmental Monitoring
PNP-2012-018; 2011 ISFSI Annual Radioactive Effluent Release Report, dated February 22,
2012
PNP-2011-023; 2010 ISFSI Annual Radioactive Effluent Release Report, dated March 1, 2011
Quality Assurance
10CFR50.54(q) Evaluation; Big Rock ISFSI Procedure, Volume 35; BRP ISFSI Emergency
Plan, Revision 5; dated October 31, 2011
10CFR50.54(q) Evaluation; Big Rock ISFSI Procedure, Volume 35A-02; BRP Emergency
Response Organization Responsibilities, Revision 8; dated October 31, 2011
10CFR50.54(q) Evaluation; Big Rock ISFSI Procedure, Volume 35A; IEPIP-10, Emergency
Response Organization Training, Revision 3; dated October 27, 2011
CR-PLP-2010-06273; During Big Rock Emergency Plan Exercise there was confusion between
dose rate and frisker readings; dated November 24, 2010
CR-PLP-2011-00243; ISFSI Horizontal Transfer System hydraulic power unit 2 has a small leak;
dated January 18, 2011
CR-PLP-2011-01700; Big Rock LTP was not performed as required by 10 CFR 50.71(g); dated
April 6, 2011
CR-PLP-2011-02073; LTP Review Discovered No Formal Review of the Big Rock Radiation
Program was performed; dated April 26, 2011
CR-PLP-2011-05610; ISFSI Emergency Plan Implementing procedure revision 50.54q
screening not completed prior to final approval; dated October 25, 2011
2
LIST OF DOCUMENTS REVIEWED (Continued)
CR-PLP-2012-04104; Horizontal Transfer System Bi-monthly test tower #3 would not fully
retract; dated May 24, 2012
CR-PLP-2012-06262; Defects/ Bug holes in the concrete exterior of the Big Rock Cask number
110; dated September 17, 2012
A. Vitale -2-
We will gladly discuss any questions you may have regarding this inspection. If you have
questions, please contact Mr. Jeremy Tapp of my staff at 630-829-9862.
Sincerely,
/RA/
Christine A. Lipa, Chief
Materials Control, ISFSI, and
Decommissioning Branch
Division of Nuclear Materials Safety
Docket Nos. 072-00043; 050-00155
License No. DPR-6
Enclosures:
Inspection Report Nos. 07200043/12001(DNMS);
cc w/encls: Distribution via ListServ for Palisades
K. Yale, Michigan State Liaison Officer
D. Malone, Palisades and Big Rock EP
R. Vanwagner, Manager, Dry Fuel Storage
O. Gustafson, Manager, Licensing
L. Potter, ISFSI Supervisor, Big Rock
Point Restoration Site
F. Rives, Director, Nuclear Fuels
DISTRIBUTION w/encls: Jared Heck Thomas Taylor
Pamela Longmire Steven Orth Carole Ariano
Cynthia Pederson Patricia Lougheed Linda Linn
Anne Boland John Giessner MCID Branch
ADAMS Accession Number: ML13009A177
DOCUMENT NAME: G:\DNMSIII\Work in progress\IR - BRP IR 12-01 r0.docx
Publicly Available Non-Publicly Available Sensitive Non-Sensitive
To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl N" = No copy
OFFICE RIII DNMS RIII DNMS E RIII RIII
NAME JETapp: jm*JET CALipa*CAL
DATE 01/8/13 01/8/13
OFFICIAL RECORD COPY
2