Text

Summary of 931025 Meeting W/Util in Rockville,Md Re end-of- License Issues for Plant.List of Meeting Attendees & Licensee Material Handouts Encl
	ML20059H920
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	11/03/1993
From:	Olshan L; Office of Nuclear Reactor Regulation
To:	; Office of Nuclear Reactor Regulation
References
	NUDOCS 9311100266
	Download: ML20059H920 (83)
	v • d • e

{{#Wiki_filter:. Docket No. 50-155 November 3, 1993 l I LICENSEE: Consumers Power Company FACILITY: Big Rock Point Nuclear Plant

SUBJECT:

MEETING

SUMMARY

- END-OF-LICENSE ISSUES i

On October 25, 1993, a meeting was held in Rockville, Maryland, to discuss end-of-license issues for Big Rock Point. A list of attendees is provided in. The material handed out by the licensee is contained in. The licensee stated that it is planning to cease operation of Big Rock Point. on May 31, 2000, which is the expiration date of its current license. They do not intend to pursue Construction Permit recapture, which would permit an additional 27 months of operation, or license renewal. The decommissioning i' plan is scheduled for submittal during the fourth quarter of 1994. The licensee does not anticipate that any formal regulatory policy is needed I for end-of-license activities. However, exemptions from new regulations, such as the maintenance rule, may be requested in the future. i The licensee would like to have meetings in the future with certain members of j the Nuclear Regulatory Commission (NRC) staff. They would like to meet with the head of the Committee to Review Generic Requirements (CRGR) to propose i that CRGR exempt Big Rock Point from Generic Letters or Bulletins that should not apply. They would like to meet with representatives from the Office of Nuclear Regulatory Research to explore the possibility of using the Big Rock Point plant for research activities, since it will be the first plant to. reach the end of its licensed life. They also proposed a meeting with the Non-Power Reactors and Decommissioning Projects Directorate of the Office of Nuclear Reactor Regulation (NRR) to discuss their decommissioning plan. And finally, they would like to meet the Director, NRR, the Regional Administrator for Region III, and possibly the NRC's Executive Director for Operations, to discuss the end-of-license philosophy. Original signed by Leonard N. Olshan, Project Manager 9311100266 931103 Project Directorate 111-1 DR ADOCK 0500 5 Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation

Enclosures:

1. List of attendees 2. Hand-out material 0500:0 D' . iiili IXM cc w/ enclosures: See next page OFFICE LA:PDIIIv1T 7M:PDIII-1 (A)PD:PDIII-1 CJamersorhNhk01shan:911 WDean/IIIb WAME DATE 11/M/93 11/ 3/93 11/%/93 3 COPY

JES/H0 YES/NO d,ES/NO 3{

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-{. INDEX

1. PRESENTATION OVERHEADS

2. DOCKETED LETTERS

3. E0L OUTLINE

4. BUSINESS PLAN

5. INTEGRATED PLAN PROCEDURES

6. DECOMMISSIONING PLAN

7. OTHER ACTIVITIES 1

't f t J s j

a ( ) PRESENTATION OVERHEADS - ( \\

c .=- BIG ROCK POINT END-OF-LICENSE MEETING i I WIT 11 NUCLEAR REGULATORY COMMISSION OCTOBER 25,1993 1 AG$ND_A i L INTRODUCTION D P HOFFMAN i i II. EOL PLAN G C WIT 11 ROW III.

SUMMARY

P M DONNELLY 1 IV. CLOSING REMARKS AND D P HOFFMAN FUTURE ACTIONS )

n-( INTRODUCTION e HISTORY e EXPECTATIONS 4

i EOL PLAN IMPACT ON REGULATORY TREATAENT e f i i EOL PHILOSOPHY AND PRINCIPLES e I - PRINCIPALS - PROCESS i Integrated Plan e e Human Resource Plan Communications Plan l e Decommissioning Plan \\ 1 ( e IMPACT OF DECOMMISSIONING e OTliER ACTIVITIES i [ i s I i

w. (

SUMMARY

NRC Actions BRP Commitments

y -. j i e 4 ( 5 I DOCKETED LETTERS i i i 1 i 1 - 1 I ] 1

y_ i OPP E 1832 f ^ C00SumBf5 j n-,. Power -,.na ( cAa/tr,nate otrar PQWERING MICHIGAN 5 PROGRL55 212 West MacNean Avenue, Jectson, em 43201 317) 738 1111 Generel offeost: December 17, 1992 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation t U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Tom:

f Recently, the Big Rock Point Nuclear Plant celebrated its During that time, and with appropriate 30th year of operation.the Plant has provided safe and economic oversight by the NRC, energy and has contributed greatly to numerous R&D issues for the nuclear industry. Since Big Rock does not intend to operate beyond its current operating license date of May 31, 2000, it seems appropriate that the pattern for policy making for opera-tions until "end of licensed life" can be served, once again through the joint efforts of Consumers Power Company (CPCo) and Such a program would the NRC making use of Big Rock Point (BRP). not only assist CPCo and the NRC in planning their respective f-future operations but would perhaps more importantly, provide i guidance to utilities which might need to consider early shut-It is with this in mind that CPCo has solicited NRC staff down. ideas and suggestions on how we might jointly proceed on this important undertaking. We are committed to working with the NRC to establish the bases upon which our nation's nuclear plants can continue to operate safely, economically and with a predictable process for approaching and of license. Following is a list of issues and some discussion on each, covering employee, regulatory, technical, operations / maintenance, equipment aging, and economic factors which need to be consid-cred. End of License for Bio Rock To date, no commercial nuclear plant in the United States has been operated throughout the full-term of its operating license. Although there have been a number of premature nuclear plant shutdown announcements during the recent past and other plant shutdowns are being considered, most plants are currently plan-ning to operate to either the end of their current operating license or to the end of an extended operating license. In addition to providing the NRC and utility industry with a regu}a-tory model for these full term plant operations, Big Rock's ( ation until end of license (EOL) will provide valuable o e i nformation regarding retention of adequately skilled staff, p t' 4 1e A CMS ENCRGYCOMA4NY

2 dealing with cging cquip;cnt cperOtien and maintannnea, co wall -as extending the commercial value to the community. i Also, this will instill confidence that' operating until and of license is indeed achievable, thereby engaging much neededTo this end, BRP ( public and investment community support.not be operated beyo 2000. A Joint NRC/CPCo Effort at BRP Increased NRC involvement with CPCo in its efforts to operate i BRP to end of license can provide needed reassurance to theThis joint effort public that BRP is safely operated until EOL. will afford the NRC the opportunity to evaluate firsthand theIt trade-offs routinely encountered by most nuclear utilities. would afford CPCo the opportunity to experience the perspective of the NRC in its deliberations on matters such as regulatory With compliance, generic letters, waivers and new regulations.CPCo could pu the perspective of the NRC, license, which would maximize the "best ban This would permit a better regulatory maintaining, int safety. assessment and the cost of regulation potentially promoting a This would reduction in cost while maintaining adequate safety. be formalized as part of our Integrated Living Schedule. The Roles of the Reaion and NRR ~ In some way, the use of NRC Region and NRR persons directly assigned to BRP end of license operation could play a large part j It would seem that the in the day-to-day regulatory oversight. process for NRC design / operation review of BRP ac project team co= prised of seasoned NRR, Region and CPC and economic operation for the lest five years of plant opera-nel. tions. Other Utility Suonort The NRC has the unique vantage point of factoring the perti-nent experience of other licensees into solving day-to-day BRPSuch soluti operating and maintenance issues. having other utility representatives participate in area clearing house for identifying unique experiences with other licensees that might improve EOL operations. Die Rock Ootion Study A Big Rock option Study is currently being reviewed by CPCo Within the study, many assumptions were made concern-ing plant decommissioning, low-level radwaste storage and theThe assistan Officers. need for on-site spent fuel storage. in reviewing these assumptions and perhaps reducing the uncer-i its customers and its tainties would be very helpful to CPCo, i shareholders, 4 i

3 Michican Public Service Commission (MPSCl. There is no doubt that the Michigan Public Service Commission holds CPCo accountable for the safe operation of BRP.

However,

( as representing the interests of CPCo's customers, the MPSC must exercise diligent oversight for the cost of energy production at BRP and CPCo's other generating stations. It would be a rare opportunity for the NRC to take part in the many deliberations associated with achieving the lowest cost for safe and reliable operation of BRP. Our staffs have discussed the potential uniqueness of manag-ing BRP to end of license. They have developed an outline (attached) for detailed plans to support the needs of both licensee and regulator for BRP end of license. I would suggest that we request that our respective staffs prepare a joint presentation for our review on this subject before the end of May 1993. Yours very truly, h / Frederick W. Buckman FWB/mfa CC: JColvin, NUMARC yDPHoffman, CPCo a

1 ATTACHKENT \\ ERP D='D-OF-LICENSE PI).N ( EXECUTIVE

SUMMARY

As Big Rock Point nears the end of license (EOL), efforts must be refocused to Current regulation maintain and operate the plant safely and economically. and industry practices str. ss operational excellence without weighing the This philosophy requires or asking "what is the right thing to do7'Therefore, it is necessary to develop a

cost, revision as the plant ages.

Efforts address the most cost effective way to assure safe plant operation. have begun with the NRC to build a consensus for appropriate EOL actions and regulations. DISCUSSION It should be recognized Action items were identified to address EOL concerns. that the following " plans

will be developed and vill require continued maintenance.

Human Resource Plan Address personnel considerations to assure a qualified staff is naintained Involves EKZienert, HDBourassa, BRP HR Committee and Corporate until EOL. Human Resources, whose purpose will be to provide necessary input to an existing BRP committee. i Public Relations Plen { Address the public concerns that EOL regulation does not make the plant any In addition, to instill confidence the public will be informed Involves TDPetroskey, CDdacInnis, less safe. about the future decommissioning process. BABroSan, NRR and Region III. I Decommissionine Plan Even though regulations are already in p1see, decommissioning is central to i This plan vill address the method chosen for decommissioning any EOL plan.and its significant impact on the other plans described herein. Involves JSRang, RJAlexander, and NRR Deco =missioning Branch. Enhance the Interrated Plen The " enhancement

is expected to include NRC participation in the current This participation should help prioritize workload and assist in the l

nanagement of aging issues and all other issues that have significant resource plan. Involves CCWithrow FRA (CRBoss, BABrogan), NRR and Region III. impact. Develen NRC Re rulatory Focus This plan is expected to be managed nostly by the NRC with input from ERP Interaction with the " Financial" regulator is also expected to Licensing. occur as this plan is implemented. l These five plans will need early management support to be implemented by the end of 1993 to ensure a timely solution to the EOL challenge.

e = [ 'g UNITED STATES 8 NUCLEAR REGULATORY COMMISSION B I usmuorow.o.c.mu December 30, 1992 Docket No. 50-155 Hr. Frederick W. Buckman President and Chief Executive Officer Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201

Dear Mr. Buckman:

SUBJECT:

BIG ROCK POINT PLANT: END-OF LICENSED LIFE Your letter of December 17, 1992, to Dr. Hurley discussed several issues regarding operation of the Big Rock Point Plant until its end-of-licensed life, which is projected to be May 31, 2000. I agree that the issues discussed are important issues and support continuing the interactions between our staffs regarding their resolution. These interactions began in April of 1992 and we currently plan a meeting early in 1993 to continue our discussion of these issues. We are also planning a separate meeting with your staff to discuss the regulatory process of decommissioning. I anticipate that our staffs will have a continuing dialogue over the next several years on the issues discussed in your letter, and share your view that the actions taken on these issues will not only assist Consumers Power but will also provide guidance for other licensees which may face a similar situation. If you would like to discuss this matter further, please do not hesitate to contact ce at (301) 504-1354. Sincerely, Ok J ek W. Roe, Director vision of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation cc: See next page l 'y \\ s

y~ . - - - -. -. ~ ~ -, -... i Big Rock Point Nuclear Plant ] ( cc: Mr. Thomas A.~ McNish, Secretary i Consumers Power Company 212 West Michigan Avenue j Jackson,. Michigan 49201 Judd.L. Bacon, Esquire Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Jane E. Brannon, County Clerk l County Building Charlevoix, MI 49720 Office of the Governor [ Room 1 - Capitol Building Lansing, Michigan 48913 Regional Administrator, Region III 'l U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Nuclear Facilities and Environmental l Monitoring Section Office i Division of Radiological Health Department of Public Health i 3423 N. Logan Street l P. O. Box 30195 Lansing, Michigan 48909 l .i U.S. Nuclear Regulatory Commission Lj Resident Inspector Office Big Rock Point Plant 10253 U.S. 31 North Charlevoix, Michigan 49720 -l 1 Mr. David P. Hoffman, Vice President i Nuclear Operations Big Rock Point Plant Consumers Power Company 212 West Michigan Avenue j Jackson, Michigan 49201 Mr. William L. Beckman, Plant Manager Big Rock Point Plant .i Consumers Power Company i 10269 U.S. 31 North I Charlevoix, Michigan 49201 j \\ i

T - k s EOL OUTLINE ( (

O 1. ' j ) END-OF-LICENSE OlfrLINE 1. CONCEPT CPCo's Expectations for Big Rock Point Plant Foster comitment to robust operations, maintenance, and engineering. Grow away from long-term initiatives to focus resources on maintaining facility in top condition and retaining experienced personnel to assure safe plant operation. Develop a relationship with the NRC that assures resources are correctly allocated. Prepare the facility for decomissioning concurrent with day to day safe and economic operation. 2. IMPACT ON REGULATORY TREATMENT CPC0 has concluded that the Regulatory processes in place are sufficient to address End-of-License (EOL) issues. 3. E0L PHILOSOPHY AND PRINCIPLES EOL Philosophy is to operate and regulate the plant safely and I economically to its end of license. Assurance of nuclear safety is and will continue to be of paramount importance. EOL Principles of Operation Be risk attentive, evaluate risk and react to risk conservatively. Assure selection of actions and programs provide the most cost effective risk benefit. Communicate with the NRC so they can be aware of the BRP actions and programs affect on risk. Build upon the successful risk program that already exists. Terminate plant operation if safety levels cannot be maintained. EOL Processes Integrated Plan (IP) An existing process that evaluates use of engineering resources with respect to modifications and programs. The purpose of [ this process is to work on activities that are the most important for BRP and to communicate the resulting priorities to the NRC.

,4 ~ ~- Page 2 ( The evaluation of issues is performed by the Technical Review Group (TRG) based on four criteria. The criteria are: 1) Ability to achieve safe shutdown 2) Minimization of radionuclide release 3) Enhancement of personnel safety 4) Improvement of plant availability NOTE: A new tool has become available recutly to help provide a more quantitative evaluation. The value ranking methodology has been updated to include insights and lessons learned from other utility experiences. For example, applicable local, state and federal regulations for utility operations are being reviewed. The membership of TRG is diverse representing operations, engineering, probabilistic risk assessment, health physics and nuclear licensing. The diversity is important as final rankings are necessarily subjective with quantitative input. The membership nominally involves six people of which half represent the BRP plant organization. Use of non-BRP expertise is intended to provide a more balanced evaluation. Application to Generic Issues Past SB0 ARI Recirc Pump Trip Seismic k'eak Links future SQUG Reactor Vessel Structural Integrity Maintenance Rule Human Resource Plan This process is intended to develop the necessary climate to retain the critical and experienced staff to the end of license. This is a key element in assuring safe operation of the plant. Communications Plan This process is intended to inform all of the stakeholders aware of the status and plans for BRP. Some of the different areas for comunication are employees, NRC, Michigan Public Service Commission (MPSC), media, local government bodies, environment I groups and local residents. I \\

i.~ Page 3 Decomissioning Plan ( This process is important not only in of itself but also for its impact on the other processes. Knowing how and when decomissioning will occur is important for planning purposes of all stakehM rs and allows them to define their position with respec. o BRP. ) 4. IMPACT OF DECOMMISSIONING In order to accomplish EOL, CPCo will submit a Final Decomissioning plan in the last quarter of 1994 (this date is contingent upon MPSC i filing preparation for BRP and Palisades). A letter to this effect will be doci.eted and presented by senior level CPCo management to senior level NRC management. This submittal will be the cornerstone of the EOL strategy. CPCo will use a 50.59 analagous review process to " maintain" the plan during its use. This will allow the plan to be modified during its use without NRC approval when such changes do not affect safety analyses or the health and safety of the public. 5. OTHER ACTIVITIES Our intent in 1994 is to interact with other stakeholders such as ( NUMARC, BWROG, GENERAL ELECTRIC and INP0 to determine if they can i become involved in the EOL plan. 6.

SUMMARY

NRC should promulgate guidance on the licensing and inspection of BRP in a generic framework. BRP will use existing methods and programs for its handling of E0L regulations, for example: Integrated Plan and TRG Do not expect to alter Tech Specs Submit a Decomissioning Plan Submit a letter stating our Decomissioning intent and when a submittal of the final plan is expected, i t i

P-M i BUSINESS PLAN 9 1 i i 2

L V'* b ,..--+. O O q 4 6 %= 6 4 ,*ee e*** ' ( 'd.% e ECON (29) BIG ROCK END OF LICENSE I e f ee an. 4 e I

y. i [,_ STRATEGY ACTION PLAN OUTLINE L* T ~ 2., [ v. I. GOAL The goal of this action plan is to develop the process to regulate and operate Big Rock Point safely and economically to achieve End-of-License (EOL) May 31, 2000; while maximizing the opportunity to identify, understand and manace EOL issues Wough decommissioning and the potential for repowering. II. SCOPE A. STRATEGIES ADDRESSED IN THIS ACTION PLAN including decommissioning, plan for Big Rock " Develop a retirement

1. ECON (29) human resources,

Point, reliability, regulatory compliance, public relations and removal from the rate base."

B. IMPACT ON OTHER STRATEGIES AND ACTION PLANS a) BUSINESS COSTS ECON (18) Develop an understanding of the components of r the total :ost of generation and develop strategies to reduce them. ECON (19) Develop the capability to justify normal O&M expenditures consistent with their value. I ECON (22) Identify alternatives to modification in order r to minimize overall cost. ECON (24) Support the industry initiative to reduce the cost of regulatory compliance. ECON (28) Develop an eccnomic model to aid Big Rock Point in deciding among strategic options. REL (30)~Taget maintenance ~and' tssting 'a'ctivities bias 5d '~ ~' on importance of epipment and systems to safety and reliability, performance history and cost effectiveness. b) HUMAN RESOURCE PLAN The EOL Action Plan vill create several new strategies that should be reviewed for inclusion to the Business Plan. We are currently operating (and being regulated ? as if the facility had 40 years of operation left on the incense. The whole purpose of this EOL Action Plan is to realistically determine the applicable strategies for operating (and regulating) a facility that is near the end of its licensed life. I

v The Action Plan calendar vill consider all operating, inning decommissioning and repowering options strategies beg .'J t - ( 1994. The Decommissioning Plan for NRC approval is scheduled for completion and subbittal by mid-yr'r 1994. The De.ommissioning Plan rate adjustment re p ast for MPSC approval is scheduled for completion and submittal by March 1995. Approvals from both regulatory agencies are expected in 1996. Consideration of repowering, such as a natural gas fired combined cycle unit after the plant ceases nuclear operation will be pursued through discussions with the MPSC in the decommissioning process in revision to the Integrated Resource Plan and the competitive bid power demand process. Reference the attached draft milestone schedule and the resource loading schedule. As Big Rock nears the end of license, resources must be managed more efficiently to continue to operate, decommission and eventually repower the site safely and economically. The margins that balunce decision making that exist in facilities with 35 or more years left on their licensed life certainly do not exist for Big Rock. To accomplish (EOL), the BRP staff is enloring a change to the traditional operating / regulating philosophy between the Indust y and the Nuclear Regulatory Commission. The prevailing areas of emphasis and mandated programs, such as Design Base Reccnstitution, Seismic Verification, (and future programs) etc., that take several years to plan and i implement, would need to be re-evaluated to satisfy a new RESOURCES = VALUE ADDED formula for a facility such as Big Rock. This strate g is expected to place resources where they are needed most, instilling the highest level of confidence for the regulator. III. Action Plan Sponsor JSRANG Action F1an Leader MDBOURASSA Action Plan Team Members: EKZienert BRP HR Committee (BRP Employees) Corporate HR (To be Determined (TBD)) TDPetroskay GCWithrov JSRang GRBoss WExessler BABrogan RJAlexander CEMacInnis office of Euclear Beactor Begulation Jack W. Roe LBMarsh John Zwolinski LNOlshan NRC Region III (TBD) (

.,1< NRR Decommissioning Branch (TBD) I 55 ' office of Nuclear Reactor Research: Eric Beckjord - Director of Research 6 Larn Shao - Division Nanager Gerald Weidenhauer - Technical Project Manager for Idaho l National En insering Lab (INEL) - Nuclear-Plant Aging Research (N AR). l t Lowell Nagleby - INEL NPAR Program Manager Nat Taylor - Probable Risk Assessment .l IV. ACTIONS A. Work Activities: 12 ACTIONS IM PROGRESS (EOL CHRONOLOGY) 1991 Mar,ch 1 and 2 - Grand Traverse Resort meeting to discuss the 'j future of Big Rock. i "End of License" plan first discussed. March 14 - Meeting with CPCo and NRC concerning current and i future issues at Big Rock Point. l 1991, NRC to CPCo, "the i By summary letter dated April 25 staf f agreed that due to the 11m1ted operating time remaining for the Big Rock Point facility, certala long-term requirements imposed by the NRC may not have an appreciable impa>:t on plant safety. These repirements will be reviewed i on a case-by-case basis, with relaxation of or alternative j roquiraments imposed as appropriate". 1 5 1992 J,nP;.J "irst CPCo/NRC EOL Neeting l Thi mec'ing was centered around a. speculative discussion t i bet + OPHoffman and JZwolinski on the issue of getting a nuclear plant to the end of-its license. The "value".of accomplishing this feat was explored by the regulator and the utility. Future meetings would be planned to develop an - l outline of what this process should look like. l l September 25, 1992 i .A conference call was conducted between members of the Big Rock Point staf f, NRR and Region III. The following. i emerged:- i I i i D

E. - The NRC was interested in developing a commission policy ri statement on Safety Regxlation for plants dealing with and '2 of license criteria. ( - A workshop at the plant was scheduled for october. - A letter from TWB to Dr Murley was recommended so that the policy statement could be developed. - Region III expressed the opinion that Big Rock be treated on a case by case basis as issues emerge. , october 14 The purpose of the workshop was to provide an opportunity for representatives from the NRC and CPCo to " brainstorm" an approach to manage a nuclear facility to the end of its license. Goal - Develop the process to operate and regulate a nuclear lant safely and economically as it approaches end of icense. Process proposals:

a. Develop a Human Resource Plan.

b. Develop a Public Relations Plan.

Develop a Decommissioning Plan. c. I

d. Enhance the Integrated Plan.

e. Develop NRC Regulatory focus.

December 17 A letter from FWBuckman to Dr. Tom Hurley was submitted. Topics addressed were: - committing not to op'6 rate BRP be' yond Maf'31^,"2'DDO. - proposed a joint NRC/CPCo effort at BRP. - directly assign an NRC/NRR/CPCo team to focus on the safe and economic operation of BRP for the last 5 years on the license. 4 involve other licensees where their unique experiences would improve EOL operations. - NRC review of the Big Rock Point Options study. - involve the NRC in MPSC deliberations associated with achieving the lowest cost for safe and reliable operation of BRP. t i ~ h

O <-t December 30 .. ~: sharing the view that the Letter from JWRoe to FWBuckman,ill not only assist CPCo, but

7

( actions taken on these issues w will also provide guidance for other licenses which may face a similar situation. 1993 that ef fort continue in/ presentation to DPHoffman. Recommends January 15 - EOL update a timely fashion. Present A. Human Resource Plant This plan will be very similar to the plan submitted for the Ten Year Plan. Employee " focus groups" that dealt specifically with EOL issues, have already been conducted; their input is part of the plan to attain EOL. More is forthcoming. B. Public Relations (Communication) Plant This plan will be a cooperative effort between CPCo and the NRC. Concerns about EOL and the future decommissioning process will need to be met head on to instill confidence on the public that plant safety and public protection are priority number one. The following actions have been initiated / proposed (I/P): 1. Brief local and state elected officials, local interested constituencies such as city managers, chambers of commerce, school board members and business leaders. g (I)

2. Brief local and state media outlets. (I)

3. Brief emergency planning zone residents. (P)

4. Continue and expand tour program and initiate yearly open house for community. (I)

" ~ ' " - ' '

5. Paid advertisingj' " Reports to th6 'Commnnity". (P)

6. Normal public relations such as appearing on talk shows, responding to media inquiries and community involvement.

(I) C. Decommissioning Plant A study of conceptual decommisrioning plans will be performed to determine the optimum approach for Big Rock Point. The method chosen for decommissioning (SAFSTOR vs. DECON) is expected to impact on the other process plans, i.e. employees retrained to perform decommissioning and/or repowering by other than i nuclear fuel - job skills will be different; public informed that this method is safe, etc The " Final" Decommissioning Plan is scheduled to be submitted for NRC approval by mid-year 1994. (

D. Integrated Plan Enhancements This may be the most ' ";i controversial plan out of the five. D e " enhancement" is e q ected to include NRC participation. This should help I prioritize workload and assist in the management of aging \\' i issues and all others that have a significant impact on CPCo and NRC resources. Actions proposed / initiated in this j area include:

1. Introducing and developing a concensus with the staff on the "new" value/ impact mMel. May include Advisory Committee on Reactor Safeguards (ACRS) informal i

participation. (I)

2. Integrated Plan - August 1993

a. Revise to address NRC participation in Technical Review Group (TRG). (P)

b. Revise TRG ranking method to include regulatory impact analysis. (P)

Incorporate use of thi "new" value/ impact. nodal for use c. in TRG ranking. (P) j ?

3. Complete the Internal Plant Examination (IPE). (I) l

4. Complete the public safety model of the "new" value impact model. (P)

5. Rerank existing issues with "new" TRG criteria and

[ value/ impact model. (P) E. Regulatory Focus -This plan is expected to be managed h mostly by the NRC. Policy Statements, Regulatory i etc., dealing with EOL criteria i guidelines, crocedures,la expected to be the basis for for nuclear facilities Li this sub-plan. NOTE: One of the reasons the newly assigned NRR Project i Manager, LNOlshan was given Big Rock Point (in his. vords) was-because' of his experience"in wri' ting policy ~ ~ ~ statements. ~ l The office of Nuclear Regulation has proposed a meeting i anytime after April 19 1993 to discuss. EOL. The agenda vill be ours, as is the invitation list. The meeting is expected l to occur in White Flint. l

2. Following through on the schedule listed below should ensura achieving the Goal and Future State of this Action l

Plan.

3. All current actions should continue because they support the strategies of this Action Plan.

1 i J l

e 1 0 i B. Schedule ^ NOTE: These activities will continue to 5/31/2000. Refer to attachments for additional d nformation. i ( A. Human Resource Plan: Implementation is expected to occur through l third quarter of 1994. B. Pubite Relations (Comunication) Plan: Implementation is expected to occur as the E0L strategy is formed and executed through third quarter-1994. C. Decomissioning Plan: >repare Decomissioning Plan for NRC approval. Ready for submittal >y September, 1994. prepare Decomissioning Plan rate adjustment request for MPSC approval. Submit by March 1995. approvals expected from both regulatory agencies in 1996 consideration of repowering, such as, a natural gas fired combined cycle unit after the plant ceases nuclear operation. The system demand requirements identified in the IRP ' Preferred Case" project a need for 238 MWe combined cycle unit in the year 2000. An idealized schedule for comercial operation of the unit, if placed at the BRP site, would have the unit operational by early 2002 assuming that construction could begin before BRP shuts down. [ Reference the attached schedules. D. Integrated Plan Enhancement: Developing a consensus with the staff on the new value/ impact.model should.be approached by May, June 1993. The IPE is expected to be completed by February,1994. J The public safety model should be completed by 3/30/94. Reranking current issues with 'new' TRG criteria should be. complete first quarter 1994. Start date is 10/30/93. E. Regulatory Focus: This plan should also be in place and implemented by 6/30/94 and continued thereafter however, input is required from the regulator. C. Resources This will be a difficult action to quantify. The actions described above do not require much additional funding the manpower is expected 1 to be supplied by the departments that will be involved. The focus of the department will be shifted to EOL issues, therefore, funding should remain within the bounds already established by respective department heads, t

?~. 2 t ( 6D It is anticipated that a Decomnissioning Plan Team (DPT) will be mobilized after the 1993 refueling outage to develop the Decommissioning Plan for submittsi to the NRC in mid 1994. (see attachment for project staffing). D. Assignments: Subject to change - BRP reorganization coming

1. Human Resource Plan EKZienert, MDBourassa, BRP HR Committee, Corporate Human Resources.

2. Public Relations (Communications) Plan TDPetroskey, CEMacInnis, BABrogan, NRR and Region III.

3. Decommissioning Plan JSRang, WEKessler, RJAlexander, and the NRR Decommissioning Branch.

4. Integrated Plan Enhancement GCWithrow, GRBoss, BABrogan, NRR and Region III.

5. Regulatory Focus The Office of Nuclear Reactor Regulation:

I Jack W. Roe LBMarsh John Zwolinski LNOlshan Office of Nuclear Reactor Rese'aYchi" Eric Beckjord - Director of Research Larn Shao - Division Manager Gerald Weidenhamer - Technical Project Manager for Idaho National Engineering' Lab. (INEL) - Nuclear,_ Plant Aging Research (NPAR). " Lowell Hagleby - INEL NPAR Program Manager 'egion III (TBD). Mat Taylor - Probable Risk Assessment V. BARRIERS AND CONSTRAINTS The Roles of Recion III and NRR Committing to, and implementing the use of, NRC Region and NRR personnel directly assigned to BRP EOL operation to play a large part in the day-to-day regulatory oversight, will be a challenge. It would seem that the process for NRC design / operation review of BRP activities could be expedited J

e l-and made more efficient by an appropriately defined project i e A team comprised of seasoned NRR, Region and CPCo personnel. [ ,q - Such a project team must have the specific focus of safe and economic operation for the remaining years of plant operations. HERE \\ There is no doubt that the Commission holds CPCo accountable i for the safe operation of BRP. However, as representing the interests of CPCo's customers, the MPSC must exercise diligent oversight for the cost of energy production at BRP. This will be the challenge - to demonstrate cost containment and cost effective generation through EOL. Other barriers / constraints that have an effect will reside with our other regulators and insurers, INPO, and the Insurance companies. The inter-relationships and consequences of EoL regulation is yet to be evaluated amongst these interest holders. This will be determined. I

1. Action Plan Interfaces The need to meet and discuss potential interfaces with the Action Plan Leaders previously identified exists.

Additional actions may fall out later. )

2. The EOL Plan assumes that the NOD Business Plan will be successful. CPCo will continue to operate BRP as long as it can be operated safely and reliably, and that costs can

[ be contained in doing so. VI. BUSINESS PIAN PERFORMANCE TARGETS The targets currently held in the Business Plan in-directly relate to the EOL Strategy. If the Business Plan does not succeed, the EOL strategy will not succeed. Therefore, a measure of how well the Business Plan is being implemented can be an indicator as to the performance of the EOL Plan. As er.perience is gained with the plan, performance" targets may be more ' easily define ~d'. '- ~ VII. COMMUNICATIONS i This area has already been captured in the plan as a result of the october EOL Workshop conducted between the NRC and Consumers Power Company Staff. The Human Resource and Public Relations Plans will be the medium to provide the required communications. 1 l 1

P g, t i 5 INTEGRATED PLAN PROCEDURES [ Y 'i e i i t 5 P E I } 3 ?

, T.,-- .~. _. (. PROCEDURE APPROVAL AND AUTHORIZATION BIG ROCK POINT NUCLEAR POWER PLANT Procedure No. 12tUME 1. PROCEDURE 4.5 Rev No. 1 -i Procedure Title BIG ROCK POINT INTEGRATED PLAN { i { CURRENT REVISION STATUS Author GHRPetitiean Date 09/29/88 Quality Review Form No. 1223-88 'l l APPLICABILITY ISSUE HISTORY j Revision No. 1 Date 09/29/92 Quality Review Form No. 1170-92 .f Approved for use ProcedureSponsor/ Designate /s/GCWithrow Date~ 10/06/92 Authorized Period of Use October 6. 1992 throuch October 6. 1994 j i i When applicable: PROCEDURE IMPLEMENTATION HISTORY l Reviewed for System or Component Operability Performed by Completed / Reviewed by -l l' Method of Verification l Title Title O Functional Test i O Physical Inspection Date Time Date Time O Administrative Review i f MAINTENANCE ORDER NO. (if applicable) 4-5/scb q -1

f. VOLUME 1 ADMINISTRATIVE PROCEDURES Revision 1 i PROCEDURE 4.5 Page 1 of 1 BIG ROCK POINT INTEGRATED PLAN (. TABLE OF CONTENTS / EFFECTIVE PAGES REVISION PAGES 1 1 - 11 1.0 PURPOSE 2.0 SCOPE

3.0 REFERENCES

r 4.0 RESPONSIBILITIES 5.0 DISCUSSION 6.0 RE0VIREMENTS 7.0 RECORDS 8.0 ATTACHMENTS b b i k I 4-5/ stb

i i VOLUME 1 ADMINISTRATIVE PROCEDURES Reviston 1 PROCEDURE 4.5 Page 1 of 11 BIG ROCK POINT INTEGRATED PLAN ( l 1.0 PURPOSE a This procedure sets forth requirements related to the Big Rock Point _ Integrated Plan (hereafter referred to as the Plan). 2.0 SCOPE This procedure reflects only those Plan requirements which are stipulated in the Big Rock Point Plant Operating License; other i requirements, such as _the function of the Technical Review Group and Living Schedule development, are addressed in other administrative procedures.

3.0 REFERENCES

I a. Big Rock Point Plant Facility Operating License, DPR-6. b. Amendment 82 to Facility Operating License No. DPR-6, dated February _12, 1986. 4.0 RESPONSIBILITIES l 4.1 ENGINEERING SUPERINTENDENT ( i The Engineering Superintendent is the Big Rock Point Plant Integrated Plan Manager and is responsible for implementing the Plan; this responsibility includes maintaining administrative procedures needed to implement the Plan and initiating changes to ~ the Plan when appropriate. 5.0 DISCUSSION The purpose of the Integrated Plan is to assess, coordinate, and ( schedule necessary work at Big Rock Point Plant. Objectivesof the Plan include the following elements: Satisfaction of regulatory requirements. j q Providing sufficient lead time for modifications and other 1 activities. Minimizing changes seen by the operators. Effective management of financial and human resources. Specification of the framework.for changes to developed issue resolutions and associated schedules.. t 4-5/scb 'I

VOLUME 1 ADMINISTRATIVE PROCEDURES Revision 1 PROCEDURE 4.5 Page 2 of 11 BIG ROCK POINT INTEGRATED PLAN ( The fundamental concept in the development of the Plan was recognition by both the Company and NRC of the fact that fiscal and manpower resources are finite and that it is necessary to place a limit on on-site manpower. Instructions for implementing various elements of the Plan are provided in Administrative Procedure 4.5.1. 6.0 RE0VIREMENTS (the Plan) is an NRC-approved document which is a requirement of the plant operating license. Any procedures developed to implement the Plan shall meet Plan requirements. Revisions may be made to the Plan; however, all proposed Plan revisions shall be submitted for NRC approval in accordance with existing NRC regulations. Proposed revisions to the Plan require PRC review and Plant Manager approval prior to submittal to the NRC. Revisions to the Plan cannot be made effective until the NRC has issued an amendment thereto. 7.0 RECORDS None 8.0 ATTACHMENTS - Plan for the Big Rock Point Integrated Assessment. i t 4-5/seb

y VOLUME 1 ADMINISTRATIVE PROCEDURES Revision 1 PROCEDURE 4.5 Page 3 of 11 BIG ROCK POINT INTEGRATED PLAN i ATTACHMENT 1 Consumers Power Company Big Rock Point Plant Docket 50-155 i i t i i e .i Plan For the Big Rock Point Integrated Assessment February 12, 1986 [ i + b h h t 4-5/ stb l

'~ t' VOLUME 1 ADMINISTRATIVE PROCEDURES Revision 1 PROCEDURE 4.5 Page 4 of 11 BIG ROCK POINT INTEGRATED PLAN ( ATTACHMENT I PLAN FOR THE BIG ROCK POINT INTEGRATED ASSESSMENT 1. INTRODUCTION Consumers Power Company (CPC) has developed a comprehensive program which will enable the Company to effectively manage implementation of significant changes to our Big Rock Point Plant which have been required, or proposed by, the NRC, as well as other measures to enhance plant safety and reliability which have been identified by the Company or other agencies (eg, the Institute of Nuclear Power Operations). A description of the program, identified as the " Integrated Assessment of Open Issues and Schedule for Issue Resolution (Including Environmental Equipment Qualification and Generic Letter 82-33 Issues)" was submitted to the NRC by our letter dated June 1,1983. The term Issue Resolution as used herein refers to the actions necessary to resolve concerns (safety related or otherwise) which have been identified by the NRC or CPC. This may include analyses, studies and/or plant modifications. This program was developed to assess, coordinate and schedule all necessary work at the Big Rock Point Plant, including those mandated or proposed by the NRC, or identified by CPC and others. The program objectives are to (1) satisfy regulatory requirements; (2) provide sufficient lead times for modifications; (3) minimize changes for f operators; (4) effectively manage financial and human resources; and (5) specify the framework for changes to developed issue resolutions and associated schedules. This will be accomplished within the overall objective of plant safety and availability. This program reflects the recognition by CPC and the NRC that fiscal and manpower resources are finite and that a limit on the onsite manpower is necessary. The program integrates a significant portion of presently planned work at the Big Rock Point Plant over a nominal three-year period to ensure that individual issues are properly assessed and that the tasks associated with issue resolution are effectively scheduled and coordinated. It provides a means for new requirements to be accommodated taking into account schedule and resource constraints, as well as the importance of implementing a new requirement. The purpose of this document is to describe the plan used to implement the program. It describes how the program functions, mechanisms for changing the program and updating it, the interactions and responsibilities of the NRC and licensee staffs under the program, and its resultant assessments and schedules. 4-5/scb

YOLUME I ADMINISTRATIVE PROCEDURES Revision 1 PROCEDURE 4.5 Page 5 of 11 BIG ROCK POINT INTEGRATED PLAN ( ATTACHMENT 1 PLAN FOR THE BIG ROCK POINT INTEGRATED ASSESSMENT 2.

SUMMARY

OF PROGRAM DEVELOPMENT The program is based on a list of issues, their associated resolutions and completion dates, each of which is assigned a priority resulting from an established assessment method. Assessments are performed by the Big Rock Point Plant Technical Review Group (TRG), and the assessment method involves ranking each issue or issue resolution based on its importance relative to safe shutdown, radiological elease potential, personnel safety, and plant availability. The scheduling of issue resolutions takes into account projections for budgets and site manpower and engineering support requirements for three years, on an item-by-item basis covering all significant plant modification activities. The list represents that significant portion of the Big Rock Point Plant work list and commitment list which is regularly modified and updated to meet changing conditions, including new NRC regulatory requirements. The final product of this program is the assessment of issues or issue resolutions and the development of associated schedules as discussed below, f i 4-5/scb

VOLUME I ADMINISTRATIVE PROCEDURES Revision 1 PROCEDURE 4.5 Page 6 of Il i BIG ROCK POINT INTEGRATED PLAN ( i ATTACHMENT 1 PLAN FOR THE BIG ROCK POINT INTEGRATED ASSESSMENT f 3. ASSESSMENT AND SC*dEDULING i i A first step in the development of this program involved a listing of significant open issues and their associated resolutions. In cases where a resolution to a particular open issue was not yet identified, the issue itself was retained in the list. Upon completion of the work listing, CPC determined that an assessment of issues or issue resolutions was required 1 to determine their appropriate ranking. Upon TRG completion of the issue assessment and ranking (using, in some cases, the results of probabilistic risk assessment studies), the tasks associated with each issue resolution were scheduled based on their assigned ranking and available resources. The issues or issue resolutions were organized into Issue Groups A and B based upon the origin of the issue and its ranking. Completion schedules and periodic status reports identify critical project tasks, target completion dates, progress and problem areas which enable management to develop contingency and/or schedule recovery plans. Both Issue Groups are briefly described below: Issue Group A - All issues which have resolutions and/or issue resolution implementation dates mandated by HRC rules, orders or license conditions. ~ Issue Group B - Issues (of either a generic or plant specific nature) identified by the NRC or CPC which have resolutions and/or i completion dates committed to by CPC, and which would result in either a) plant modifications, b) procedure revisions, or c) changes in facility staffing requirements. Issue resolutions and/or implementation dates in Issue Group A may be modified or deleted only with prior approval of the NRC, in accordance with existing NRC regulations. Changes to the issue resolution and/or completion dates in Issue Group B require notification to the NRC as described in Section 5. Issue Groups A and B, taken together, provide a basis for assessing the overall effects of changes to issue resolutions and/or schedules, and a departure point for discussion between the NRC and the licensee regarding suc1 changes, as discussed below. l t 4-5/scb

VOLUME 1 ADMINISTRATIVE PROCEDURES Revision 1 PROCEDURE 4.5 Fage 7 of 11 BIG ROCK POINT INTEGRATED PLAN ( ATTACHMENT 1 PLAN FOR THE BIG ROCK POINT INTEGRATED ASSESSMENT 4. ISSUE RESOLUTION AND SCHEDULE MODIFICATIONS An important aspect of CPC's planning effort is the recognition that the issues, issue resolutions, and scheduled completion dates will need to be modified or deleted at times to reflect changes in regulatory requirements, to acconrnodate those activities that CPC finds necessary to improve plant efficiency and reliability, to incorporate the results of investigations into issues, and to take into account delays resulting from events beond CPC's control. The procedure used by CPC for changing or deleting issues, issue resolutions, or scheduled completion dates will be developed and included in a separate volume of the Big Rock Point Plant Manuals. 5. CPC AND NRC RESPONSIBILITIES The proper functioning of the Integrated Plan requires that CPC apply consistent criteria to the assessment of issues, monitor the progress of all work undertaken, manage its activities to maintain the schedule, and act promptly to take necessary actions when an issue resolution or schedule change is needed. As set forth herein the NRC will treat all f Integrated Plan issues consistently and recognize that, when necessary, ranking, issue resolutions, and/or scheduled completion date changes are based on a comparison of the issue being changed to all the Integrated Plan issues, and also account for resource constraints. I a. PERIODIC UPDATING CPC will update Issue Groups A and B semi-annually and submit the revised Integrated Plan to the NRC, beginning six months following NRC approval of this plan. The revised Integrated Plan will include the following: i Summarize progress in completing or implementing issue resolutions. Identify changes since last update report. Summarize the reasons for issue resolution aid /or schedule changes associated with regulatory requirements. The listing of issues in Issue Groups A and B will contain sufficient detail to identify those issues with tasks and/or completion dates keyed to refueling outages. In such cases, a change in outage period (ie, initiation or duration) shall not be considered a schedule e change. 4-5/scb l

VOLUME 1 ADMINISTRATIVE PROCEDURES Revision I PROCEDURE 4.5 Page 8 of 11 BIG ROCK POINT INTEGRATED PLAN ( ATTACHMENT 1 PLAN FOR THE BIG ROCK POINT INTEGRATED ASSESSMENT b. CHANGES TO ISSUE RESOLUTIONS AND/0R SCHEDULES Changes to the Integrated Plan may arise from a variety of reasons, such as new issues identified; modifications to the scope of scheduled work; unplanned outages; results of investigations into an issue (eg, PRA findings); problems in delivery, procurement, etc; changes in NRC rules and regulations; or other NRC or CPC actions. Where it is necessary to add a new issue or to change the schedule for an issue, the following general guidance will be utilized to the extent appropriate: Assess the priority of the issue relative to all existing Integrated Plan issue resolutions. Schedule the new or changed issue resolution to avoid rescheduling other issues, if it can be reasonably achieved. Alter Issue Group B items before Issue Group A items. Select a schedule for the new or changed issue resolution which I will help in maintaining an optimum integrated program of work. Addition of activities to Issue Group A requires CPC to propose appropriate issue resolutions and/or completion dates and requires NRC approval of such proposals. Changes to previously established Issue Group A resolutions and/or resolution implementation dates will be proposed only after CPC has determined that changing Issue Group B issues will not significantly assist in maintaining Issue Group A without change; or that safety, resource or schedule penalties from rescheduling Issue Group B activities significantly outweigh the consequences of a change in an Issue Group A completion date. As with proposals to add Issue Group A activities, proposals to change previously existing Issue Group A activities also requires HRC approval. CPC will inform the NRC Project Manager when serious consideration is given to requesting a change in Issue Group A. When CPC determines that a change in Issue Group A is necessary, it will submit a written request for NRC approval in accordance with applicable regulations. 6 4-5/scb

VOLUME 1 ADMINISTRATIVE PROCEDURES Revision I i PROCEDURE 4.5 Page 9 of Il t BIG ROCK POINT INTEGRATED PLAN ( ~ ATTACHMENT 1 PLAN FOR THE BIG ROCK POINT INTEGRATED ASSESSMENT Issue resolutions in Issue Group B may be modified, deleted or rescheduled, or new issues may be added to Issue Group B by CPC without NRC approval; however, CPC will inform the NRC Project Manager once a change, deletion, or addition is necessary. CPC will provide the NRC with written notification of changes or deletions of Issue Group B issue resolutions or completion dates associated with NRC initiated issues at least 30 days prior to Plan-scheduled completion date. Such notification will also include the reasons for the change and describe any compensatory actions which CPC determines to be appropriate. The change, addition or deletion in Issue Group B will go into effect upon evaluation by the TRG, unless the NRC, in writing, requests further explanation or discussion. NRC requests will be made within 15 days of receipt of CPC written notification. In this event, discussions will be initiated to promptly develop an issue resolution and/or schedule which is mutually acceptable to CPC and the NRC Project Manager while considering overall program impact. The written notification by the NRC will serve to extend the schedule date for the period of time required for such discussion. If a revised issue resolution and/or schedule is established in these discussions, such i issue resolution and/or schedule will supersede the issue resolution and/or schedule set forth in Issue Group B. The revised issue resolution and/or schedule will be incorporated in a revised Issue Group B in the next update submitted to the NRC. If a revised issue resolution and/or schedule cannot be established in these discussions, CPC changes to issue resolutions and/or schedule dates will be effective unless subsequently modified by NRC Order. In the event of unplanned delays, delays which become manifest within 30 days of the Plan-scheduled completion date or in the event of circumstances beyond CPC's control, CPC shall provide timely notification to the NRC Project Manager of the revised issue resolution and/or schedule date and incorporate it in a revised Issue Group B in the next update submitted to the NRC. I f 4-5/ stb

VOLUME 1 ADMINISTRATIVE PROCEDURES Revision 1 PROCEDURE 4.5 Page 10 of 11 BIG ROCK POINT INTEGRATED PLAN k ATTACHMENT 1 PLAN FOR THE BIG ROCK POINT INTEGRATED ASSESSMENT 6. NRC REVIEW As pointed out in Section 5, b above, changes to the issues and/or schedules are inevitable. Action required by the NRC is discussed below: a. CONSUMERS POWER COMPANY ORIGINATED CHANGES 1. Upon receipt from CPC of a request for modification of Issue Group A, the NRC will act promptly (consistent with resource availability and priority of other work) to consider and decide on the request in accordance with applicable procedures. 2. If the request for a modification of Issue Group A is denied, NRC shall promptly inform CPC and provide the reasons for denial. 3. NRC consideration of CPC changes to non-issue Group A issues and/or schedules is covered by Section 5.b. b. NRC ORIGINATED CHANGES (ISSVE GROUP A) f It is recognized that formal NRC regulatory actions (ie, NRC rules, I orders, or license conditions) may: (1) impose a new regulatory requirement with a fixed date, or (2) establish a firm date for a previously identified regulatory requirement. In taking any such action, the NRC, to the extent consistent with its overall regulatory responsibilities and, unless public health, safety, or interest require otherwise, will take into account the impact of such action on CPC's ability to compete effectively the issues in Issue Groups A and B, and, in consultation with CPC, will try to minimize such impact. Although any formal regulatory action (ie, regulatory rule, order, or license condition) taken by the NRC will be effective in accordance with its terms without inclusion in Issue Group A, the NRC and CPC recognize the desirability of incorporating such action into Issue Group A, particularly in order to incorporate at the same time any other appropriate changes in the total integrated assessment program. Accordingly, once such formal regulatory action is taken (or earlier, if practicable), the NRC will provide CPC a reasonable opportunity to propose overall changes in the total integrated assessment program which would most effectively accomodate such requirements. Any rer.ulting changes in issues in Issue Group A will be (1) reviewed by the NRC, taking in account the overall objective of the Integrated Assessment Program to use available resources effectively, and (2) approved by the NRC in accordance with established procedures, and will thereupon be reflected in a revised Issue Group A submitted by CPC. CPC will inform the NRC of any resulting changes in Issue Group B in accordance with Section 5 above. ( 4-5/scb

VOLUME 1 ADMINISTRATIVE PROCEDURES Revision 1 Page 11 of 11 PROCEDURE 4.5 BIG ROCK POINT INTEGRATED PLAN ( ATTACHMENT 1 PLAN FOR THE BIG ROCK POINT INTEGRATED ASSESSMENT c. NEW NRC ISSUES flSSUE GROUP B) The NRC may, from time to time, identify new regulatory issues which may result in (a) plant modifications, (b) procedure revision or development, or (c) changes in facility staffing requirements. With i respect to issues which the NRC requests (1) scheduling information or (2) responses by a certain date, these issues may be included in Issue Group B in accordance with the issue resolution priority resulting from the TRG assessment. Issue resolutions and/or date commitments resulting from TRG evaluation will form the basis for discussions between the NRC and CPC. As for the case of NRC-originated changes to Issue Group A issues, the NRC will provide CPC a reasonable opportunity to propose overall changes in the total integrated plan program which would most effectively accommodate such issues. Any resulting changes in the integrated plan program will thereupon be reflected in a revised Issue Group B submitted by CPC. 7. MODIFICATION TO THE PLAN The licensee and the NRC recognize that the Plan itself may require future ( modifications. Accordingly, all Plan revisions will be submitted for prior NRC approval in accordance with existing NRC regulations. The revisions will be made effective upon amendment issuance by the NRC. 9 l 1 4-5/scb

BIG ROCK POINT NUCLEAR POWER PLANT PROCEDURE APPROVAL AND AUTHORIZATION Procedure No. VOLUME 1. PROCEDURE 4.S.1 Rev No. 2 Procedure Title ISSUE MANAGEMENT CURRENT REVISION STATUS Author GHRPetitiean Date 10/02/90 Quality Review Form No. 839-90 APPLICABILITY ISSUE HISTORY Revision No. 2 Date 09/29/92 Quality Review Form No. 1169-92 Approved for use Procedure Sponsor / Designate /s/Greoory C. Withrow Date 10/27/92 Authorized Period of Use October 27. 1992 throuah October 27, 1994 When applicable: PROCEDURE IMPLEMENTATION HISTORY Reviewed for System or Component Operability Performed by Completed / Reviewed by Method of Verification Title Title [] Tunctional Test [] Physical Inspection Date Time Date Time O Administrative Review ( MAINTENANCE ORDER NO. (if applicable) 4-5-1/scb

VOLUME 1 ADMINISTRATIVE PROCEDURES Revisicn 2 PROCEDURE 4.5.1 Page 1 cf 1 ISSUE KANAGEMENT ( TABLE OF CONTENTS / EFFECTIVE PAGES REVISION PAGES 2 1 - 15 1.0 PURPOSE 2.0 SCOPE

3.0 REFERENCES

4.0 RESPONSIBILITIES 4.1 PLANT MANAGER 4.2 DEPARTMENT HEADS (BIG ROCK POINT PLANT) 4.3 ENGINEERING SUPERINTENDENT 4.4 TECHNICAL REVIEW GROUP CHAIRMAN 4.5 ISSUE MANAGERS 4.6 TECHNICAL ENGINEER t 5.0 REOUIREMENTS 5.1 REVISIONS 5.2 TECHNICAL REVIEW GROUP (TRG) 5.3 PROCESSING ISSUES 5.4 SCHEDULES FOR IMPLEMENTATION OF ISSUE RESOLUTIONS 5.5 INTEGRATION OF LIVING SCHEDULE WITH OTHER WORK ACTIVITIES 5.6 REPORTS 6.0 RECORDS 7.0 ATTACHMEN(S i 4-5-1/scb

VOLUME 1 ADMINISTRATIVE PROCEDURES Revisitn 2 PROCEDURE 4.5.1 Page 1 of 15. ISSUE MANAGEMENT 1.0 PURPOSE The purpose of this procedure is to describe how Integrated Plan issues are initiated, ranked, and scheduled. Periodic status reports are also addressed. 2.0 SCOPE This procedure applies to the management of those issues which are expected to require more than $10,000 in materials and services or more than 200 man-hours of Company effort to resolve.

3.0 REFERENCES

a. Administrative Procedure 4.5 - Big Rock Point Integrated Plan. b. Administrative Procedure 1.12 - Requests for Modification 4.0 RESPONSIBILITIES 4.1 PLANT MANAGER The Plant Manager shall appoint a Technical Review Group (TRG) i Chairman. The Plant Manager approves the assignment of other i members of TRG. The Plant Manager designates an individual who is responsible for preparing periodic status reports. The Plant Manager is responsible for establishing the priorities for all projects other than those which fall within the scope of this procedure. 4.2 DEPARTMENT HEADS (BIG ROCK POINT PLANT) Plant Department Heads are responsible for presenting issues to the Technical Review Group Chairman for TRG consideration and ranking. Plant Department Heads assign issue managers for those issues which are their department's responsibility to present to TRG or to resolve following ranking by TRG. Plant Department Heads are responsible for ensuring that budget needs are adequately addressed for issues assigned to their 1 departments. i I i i 4-5-1/scb

VOLUME I ADMINISTRATIVE PROCEDURES Revision 2 PROCEDURE 4.5.1 Page 2 of 15 ISSUE MANAGEMENT k 4.3 ENGINEERING SUPERINTENDENT The Engineering Superintendent is responsible for maintaining this procedure in compliance with applicable requirements, and for i ensuring that the requirements of this procedure are implemented. 4.4 TECHNICAL REVIEW GROUP CHAIRMAN The TRG Chairman ensures TRG meetings are conducted when required, and that records of these meetings are kept. The TRG Chairman nominates regular TRG members for approval by the Plant Manager, and assigns alternate members as needed to fill i temporary vacancies. 4.4.1 TRG Members TRG members are responsible for ranking issues presented to them. They are required to familiarize themselves with issues to be ranked prior to each meeting. 4.4.2 TRG Secretary k The TRG secretary is responsible for assembling and distributing meeting agenda, recording and distributing meeting minutes, maintaining records related to integrated plan issues, and other duties under the direction of the TRG Chairman. 4.5 ISSUE MANAGERS Issue managers are responsible for assuring that sufficient information is provided to TRG during the ranking process, and that issues are adequately resolved following ranking. 4.6 TECHNICAL ENGINEER The Technical Engineer serves as the primary contact between the NRC and Company individuals or groups (eg, issue managers, TRG) for all matters related to issue management and reporting. I 5.0 REOUIREMENTS 5.1 REVISIONS i This procedure must meet applicable requirements set forth in the i Big Rock Point Integrated Plan (the Plan). Should it be determined that proposed revisions to this procedure conflict with' requirements of the Plan, then the Plan must be revised per the [ requirements of Administrative Procedure 4.5 prior to approval and implementation of the proposed revision to this procedure. 4-5-1/ stb

i VOLUME 1 ADMINISTRATIVE PROCEDURES R2vistor. 2. PROCEDURE 4.5.1 Page 3 of 15 ISSUE MANAGEMENT l ,-( n TECHN' CAL REVIEW GROUP (TRG) i I 5.2 5.2.1 Membershio The Technical Review Group consists of a Chaiman and five other-l members. More members may be assigned; however not more th'an five members plus the chairman may vote at one time. -The Chaiman is appointed by the Plant Manager. Other members are nominated by the TRG Chairman; designation as a TRG member requires Plant Manager Approval. Whenever possible, membership should include individuals whose primary responsibilities are in the following areas: Operations Health Physics Engineering i Licensing Probablistic Risk Assessment

i Assignment of individuals not assigned to the Plant is desirable; i

however not more than three members (including the Chairman) may be assigned from off-site organizations. s 5.2.2 Ouorum l t A quorum will consist of the chairman and five members. In the interest of ensuring consistency in how issues are ranked from one meeting to the next, every reasonable effort should be made to have all assigned members present at each meeting.. If one or more assigned members cannot be present for a meeting, one of the following options shall be used, with preference given to the order provided: The absent member (s) may participate via telephone. 1 If the chairman determines that issues to be ranked are not complex, the absent member (s) may vote separately from the other members. The chairman may appoint alternate members to replace the absent members. a 4-5-1/scb s- -um-w a g-- m aw-

y VOLUME 1 ADMINISTRATIVE PROCEDURES Revision 2 PROCEDURE 4.5.1 Page 4 of 15 ISSUE MANAGEMENT ( 5.2.3 Function The Technical Review Group advises the Plant Manager and other levels of plant management on the importance of issue resolution with respect to overall plant operation.(as defined by the ranking criteria discussed in this section). In addition, with respect to schedules for resolution of issues, TRG evaluates the timeliness of issue resolution as it may affect plant operation. 5.2.3.1 New Issues The Technical Review Group considers issues for inclusion in the Big Rock Point Integrated Plan. For each issue to be considered, TRG determines the importance of issue resolution in terms of anticipated benefit versus resources required to implement the resolution. The benefit of issue resolution is a function of its impact on the following aspects of plant operation: Ability to achieve safe shutdown Minimizing radioactive release Enhancement of personnel safety Improvement in plant availability I Based on the assessment of each issue by TRG, a ranked listing is developed. This listing serves as the basis for development of, and revision to the Big Rock Point Living Schedule, which is described later in this procedure. e 4-5-1/ stb e

VOLUME 1 ADMINISTRATIVE PROCEDURES Revision-2 PROCEDURE 4.5.1 Page 5 of 15 ISSUE MANAGEMENT k 5.2.3.2 Deletion of Previously Ranked Issues TRG considers requests to delete issues from the Integrated Plan according to the following methods: If the existing score for the issue is less than or equal to five (see 5.2.3.4), TRG may recommend the issue be deleted. In this instance, no further evaluation by TRG is required. If the score for the issue is greater than five, then the issue must be reevaluated; the new tot'l score serves as the basis for deleting the issue or leaving it as-is. 5.2.3.3 Schedule thanges TRG evaluates proposed changes to scheduled completion dates for issue resolutions. This evaluation considers the adverse impact on plant operations and whether or not compensatory actions (if any are taken), are adequate. Proposed schedule changes are approved or disapproved by voice vote. In those cases where unavoidable schedule changes occur and TRG finds cause not to approve the slippage, adequate interim compensatory actions E911 be implemented, or the matter referred to the appropriate level of ( management (eg, Plant Manager, Plant Review Committee, Plant Safety Committee) for further consideration and appropriate action. 5.2.3.4 Voting Methodology following review of an issue, TRG members individually determine the importance of issue resolution with respect to the aspects of plant operation to which the issue applies. Voting is recorded on Attachment I, Individual Tally Sheet. Following voting, points are assigned as follows: yql_t Points High(H) 3 Medium (M) 2 Low (L) 1 None(N) 0 The points are added, and the total score is used as a basis to determine the ranking of the issue. (- A-5-1/sch

YOLUME 1 ADMINISTRATIVE PROCEDURES R:visien 2 ) PROCEDURE 4.5.1 Page 6 ef 15 ISSUE MANAGEMENT i 5.2.4 Meetino Frecuency The Technical Review Group will normally meet once per calendar quarter; special meetings may be convened when deemed appropriate by the TRG chairman. TRG shall meet not less frequently than twice per year. 5.2.5 Aaenda The TRG chairman will assure that an agenda is prepared sufficiently in advance of a regular (quarterly) meeting to provide members the opportunity to prepare for the meeting. When practicable, agendas will be issued prior to special meetings. Items which may be included on the meeting agenda include: Minutes of the previous meeting (for approval). Status report of previously ranked issues (status reports will include schedules for issue resolution and proposed changes thereto). Reconsideration of previously ranked issues (because of t. changes, different proposed resolutions or requests to delete from the Integrated Plan). New issues to be ranked and added to the Integrated Plan. t t / 4-5-1/scb

VOLUME 1 ADMINISTRATIVE PROCEDURES Revisien 2 PROCEDURE 4.5.1 Page 7 of 15 ISSUE MANAGEMENT 5.3 PROCESSING ISSUES This section of the procedure addresses the handling of issues from initiation to the point of their being scheduled. 5.3.1 Issue Initiation Issues are identified by employees who have cognizance or expertise in the area covered by the issue. To be considered by TRG, the issue must have an issue manager assigned and must be presented to the TRG chairman in writing. The initiating document will have the concurrence of either the initiator's or issue manager's department head. As a minimum, the initiating document (eg, Action Item Record, Request for Modification, Internal Correspondence) must contain the following: Description of the problem or concern. Implications of leaving the concern unresolved. If known, proposed resolution and alternatives. If known, cost of implementing the resolution / alternatives. 3 For issues which are identified by agencies external to Consumers Power Company, the employee who is the contact for that agency will initiate the request to have the issue considered by TRG. 5.3.2 Issue Manaoer 5.3.2.1 Assignment If an issue manager has not already been assigned, the TRG chairman requests the cognizant plant Department Head to assign an issue manager. The issue manager need not be a plant employee; however, a contact in the cognizant plant department shall always be assigned. 5.3.2.2 Function The issue manager reviews all information related to the issue and, if not already performed, determines resolutions / alternatives and resources required to resolve the issue. If no resolutions i are apparent, or if the cost of determining potential resolutions is sufficient to meet the guidelines for TRG consideration, then the issue may be presented to TRG without any proposed resolution. The issue manager or his plant contact wil? be available to represent the issue at the TRG meeting during which it will be considered. a i l 4-5-1/ stb

~ VOLUME 1-ADMINISTRATIVE PROCEDURES' Revisien 2. -] PROCEDURE 4.5.1 Page 8 of 15 ISSUE MANAGEMENT h 5.3.3 Issue Rankino Using the total number of points assigned to the issue by TRG' I members, the issue is incorporated into the ranked list of issues, j which is used to determine the relative importance of a single issue with respect to all other ranked issues in the Integrated Pl an. 5.3.3.1 Issue Identification At the time issues are ranked by TRG, they will be assigned an alpha-numeric identifier. Numbers will be assigned sequentially; an alphabetic' prefix to'each number will be assigned as follows: j If the issue belongs in Issue Group A, the issue number will-be prefixed by the letter "A". This issue group is composed of issue resolutions and schedules established by NRC rule, order, or license condition. l i Issue Group B is composed'of issues of either a generic or Big Rock Point-specific nature which have been identified by the i NRC, other agencies or the Company. Issues in this group have' resolutions or completion dates committed to by the Company l and result in plant modifications, procedure revisions,'or i changes in facility staffing requirements. If.the issue i belongs in Issue Group B, and the issue has been initiated by 1 the Company or an agency other than the NRC, the issue number will.be prefixed by the letter "B"; if the issue has been initiated by the NRC or if its resolution represents a Company l commitment to the NRC, it will be prefixed by the letters "BN". i 5.4 SCHEDULES FOR IMPLEMENTATION OF ISSUE RESOLUTIONS following ranking by TRG, completion of each issue is scheduled by the issue manager responsible for its resolution. Collectively, the schedules are referred to as the "Living Schedule". The Living Schedule takes into accour t projections for budgetary, site manpower and engineering support requirements for at least a three year period. j 1 -i i i 4-5-1/seb l

VOLUME 1 ADMINISTRATIVE PROCEDURES Revision 2 PROCEDURE 4.5.1 Page 9 of 15 ISSUE MANAGEMENT k 5.4.1 Methods For issue resolutions which are not complex, the schedule need show only a starting and completion date. For resolutions of a more complex nature, it may be appropriate to utilize more sophisticated scheduling techniques; in such cases the issue manager may choose to utilize planning and scheduling support from on-site or off-site support groups. Schedules will be approved by the issue manager's department head who verifies that the schedule meets budgeting constraints and is censistent with other work priorities; the Integrated Plan Manager and TRG review the Living Schedule periodically to assure that scheduled completion dates are consistent with the importance of the issue as determined by TRG. Should TRG or the Integrated Plan Manager identify concerns with the approved schedule, the issue manager or affected department head will be contacted to resolve the concern. Unresolvable concerns are referred to higher levels of management. 5.4.2 Schedule Chances 5.4.2.1 General ( When it is necessary to add a new issue or to change the schedule for an existing issue, the following general guidance will be utilized to the extent possible and appropriate: Assess the priority (ranking) of the issue relative to all existing Integrated Plan issues. In general, scheduling of a lower ranked issue should not result in significant schedule delays for higher ranked issues. If reasonable to achieve, schedule the new or changed issue resolution to avoid rescheduling other issues. If work has not commenced on the issue which would be rescheduled, and if rescheduling will have no adverse budget impact, then resched-uling of a previously-ranked issue may be appropriate, provided the elements of 5.4.2.2 and 5.4.2.3 are satisfied. Alter schedules for Issue Group B items before Issue Group A items. Select a schedule for the new or changed issue resolution which will help in maintaining an optimum integrated program of work. 4-5-I/seb

VOLUME 1 ADMINISTPATIVE PROCEDURES Revision 2 PROCEDURE 4.5.1 Page 10 of 15 ISSUE MANAGEMENT ( 5.4.2.2 Group A Issues Addition of activities to Issue Group A requires submittal of pro-posed issue resolutions and completion dates, when known, and requires NRC approval prior to implementation. Changes to previously established Issue Group A resolutions or implementation dates will be proposed only after it has been determined that changing Issue Group B issues will not significantly assist in maintaining Issue Group A without change; or it has been determined that safety, resource or schedule penalties from rescheduling Issue Group B activities significantly outweigh the consequences of a change in an Issue Group A completion date. Proposals to change Issue Group A resolutions or schedules require prior NRC approval. As soon as it becomes apparent that a change to an Issue Group A item is likely to be requested, the issue manager notifies the Technical Engineer such that the NRC Project Manager for Big Rock Point can be made aware of the forthcoming request for an Issue Group A change. The issue manager is responsible for providing input needed in order to prepare a request for a change to the schedule or proposed resolution for a Group A issue. This input shall be ( provided to the Integrated Plan Manager and must include the reasons that the schedule or scope change is necessary. The Integrated Plan Manager uses this input and reviews other items on the Living Schedule in order to draft a submittal which includes an evaluation that changing Issue Group B issues will not significantly assist in meeting the schedule for the Group A issue or that safety, resource or schedule penalties from rescheduling Issue Group B activities significantly outweigh the consequences of a change in an Issue Group A completion date. The draft submittal will be given to the Technical Engineer, who will prepare the required written submittal to the NRC. I a 4-5-1/scb I

VOLUME 1 ADMINISTRATIVE PROCEDURES Revision 2 PROCEDURE 4.5.1 Page 11 of 15 ISSUE MANAGEMENT ( 5.4.2.3 Group B Issues Issue resolutions in Group B may be modified, deleted or rescheduled, or new issues may be added without prior NRC approval. When such action becomes necessary the issue manager notifies the TRG chairman so that TRG can evaluate the effects of the change with respect to applicable ranking criteria. Such notification must include the reasons for the change and what compensatory measures, if any, are being taken pending issue resolution. The Issue Manager also notifies the Technical Engineer so that the NRC Project Manager for Big Rock Point may be notified of the change, deletion or addition. For changes to NRC-initiated issues (ie, "BN" issues), the issue manager must ensure that the notification provided to the Technical Engineer is complete and timely such that written notification can be provided to the NRC at least 30 days in advance of the docketed scheduled completion date. Any changes affecting Group B issues will become effective upon evaluation and approval by TRG, unless the NRC requests further explanation or discussion per Section V.B. of the Plan. In the event of unplanned delays which are determined within l 30 days of the docketed scheduled completion date, the issue manager shall notify the TRG chairman and the Technical Engineer such that TRG can evaluate the effects of the change and so the NRC Project Manager for Big Rock Point can be notified. 1 i 4-5-1/seb i l

VOLUME I ADMINISTRATIVE PROCEDURES Revision 2 PROCEDURE 4.5.1 Page 12 of 15 ISSUE MANAGEMENT k 5.5 INTEGRATION OF LIVING SCHEDULE WITH OTHER WORK ACTIVITIES 5.5.1 Discussion A significant portion of the Big Rock Point workload is of such a nature that it does not fall within the scope of the Integrated Plan. Examples of such work activities include items which have no affect on any of the established ranking criteria (for example, " good business" items such as construction of new facilities), or which do not meet the resource expenditure threshold established in 2.0. Collectively, these activities may account for a major portion of the resources available to perform plant-related business; therefore the need exists to assure that these items are given appropriate priorities and scheduled accordingly. 5.5.2 Methods Periodically, all plant-related projects are reviewed in order that each may be assigned a priority. The assigned priority takes into account the importance of each project with respect to all other projects, including those which have been ranked by TRG. This method of establishing priorities may result in rescheduling Integrated Plan issues; this is permissible, provided the ( requirements of 5.4 are met. Administrative Procedure 1.12, Requests for Modification, provides detailed guidance in the methods used to establish priorities for plant projects. 5.6 REPORTS 5.6.1 General On a monthly basis, the status of each ranked issue and all other plant projects is reported by the responsible issue / project manager. Reports are collecte.1 by an individual designated by the Plant Manager; the reports will normally be entered into a computer-based data system to facilitate updating and retrieval of information. i l i i 4-5-1/scb

i VOLUME 1 ADMINISTRATIVE PRDCEDURES -Revision 2 PROCEDURE 4.5.1-Page 13 of 15. ISSUE MANAGEMENT l { 5.6.2 Periodic Reports to Manaaement Reports on the status of each plant project and ranked issue are i provided on a monthly basis to plant management. Monthly reports provide a brief synopsis of the status of the project or issue and should include: t The issue or project title, project number, issue number, TRG. ranking, plant priority number, and issue manager. j Percent complete, target completion date, and NRC-committed completion date. Significant work completed (including milestones achieved) since the previous report. Work remaining to be done. i Existing or anticipated problems which may adversely affect budget or the scheduled completion date. These reports are distributed to the Plant Manager, issue / project-managers, cognizant department heads, the TRG chairman, Integrated . (- Plan Manager, and the Technical Engineer. l 5.6.3 Periodi-Reports to the NRC j Every sir oonths, normally in February and August, a report will be provided to the NRC regarding the status of the Integrated t Plan. These reports will include-i A summary of the progress made in completing or implementing resolutions to issues which were unresolved at the beginning [ of the report period or which were added to the Living i Schedule during that period. ~ 1 Changes (additions, deletions or schedule changes) made since the last report. l t For those issues associated with regulatory requirements which 'l have been completed during the report period, provide a brief summary stating why the issue is considered to be resolved. A sumary of the reasons for schedule changes for those issues associated 6th regulatory requirements. e Issue managers provide input needed to prepare the six-month report; the Integrated Plan Manager is responsible for assembling f the report and ensuring its timely submittal. I 4-5-1/seb [ e I

.~ -. l VOLUME 1-ADMINISTRATIVE PROCEDURES Revisien 2 i PROCEDURE 4.5.1 Page 14 of 15.- i ISSUE MANAGEMENT k ~ .i 6.0 RECORDS 6.1-MEETING MINUTES Minutes shall be prepared for each meeting and will include: ] I A sumary of. general business conducted (eg, approval of previousmeetingminutes). For each issue considered, its. scope and proposed resolution.- A sumary of TRG's evaluation and approval / disapproval of scheduled implementation dates and any proposed changes thereto. j i A summary of TRG's discussions on all items considered during the meeting. Results of voting, as derived from individual tally sheets. I These sheets, which are used by each TRG member to record his votes and rationale for voting, will be maintained separately l with other information related to the related issue. The tally sheets are not considered to be a plant record. l l 1 Documents reviewed by TRG during consideration.of an. issue, a unless those documents are a plant lifetime record, in which I case they may be included in the minutes by reference. i Minutes shall be distributed to all TRG members, the Integrated Plan Manager, the Big Rock Point Plant Manager, and the Big Rock Point Technical Engineer. In addition, minutes (or applicaF e portions thereof) will be distributed to department heads ao4 issue managers responsible for those issues discussed during ti,e j meeting. 7.0 ATTACHMENTS, Individual Tally Sheet l -l L ] 1 -t 4-5-1/seb l t i

VOLUME 1 ADMINISTRATIVE PROCEDURES Revision 5. PROCEDURE ~4.5.1 Page 15 of 15 ISSUE MANAGEMENT {- ATTACHMENT I INDIVIDUAL TALLY SHEET l Issue No Date TRG Member j i Issue

Title:

Resolution to be ranked: s r t Ranking: Criterion 1 (Safe Shutdown) H M L N l Criterion 2 (Radioactive Release) H M L N l Criterion 3 (Personnel Safety) H M L N Criterion 4 (Availability) H M L N ( I Justification for ranking: (if more than one criterion ranked, indicate to j which criterion coments apply). 6 I i I I 4 t I 1 i i 1 4-5-1/scb a p

..A5. si J wds i 4--m.-- J e a-- - -1 m u_ ,_w_.A i I i f a i l 9 + ? h -aj l - t 4 k t h 4 L f -3 ?i .I + DECOMMISSIONING PLAN e i 4 I i k f I I e 9 1 8 6 h r l i i f 9 ? s

( MISSION STATEMENT To prepare the Plan for decommissioning Big Rock Point. The Plan is to be: t

Acceptable to the NRC as a Final Decommissioning Plan.

t

Useful for updating the estimate for funding Big Rock Point decommissioning cost.

e Useful to Big Rock Point for defining work opportunities and operational needs beyond the year 2000. U e i t

STRATEGIES ( To complete the NRC Plan (including the Environmental Report) by September 30, 1994. To support MPSC Decommissioning Surcharge filing by March 31, 1995. Not to exceed the 1991 MPSC order Surcharge estimate in 1994 dollars (considering like estimate assumptions). To study decommissioning alternatives and select the most cost beneficial option. To determine the feasibility of continued utilization of Big Rock Point Site as a power generating facility. To maintain Communication Plan (s) for the following: Company Employees Public I Regulatory Agencies State and Local Entities Legis1ators To optimize utilization of Big Rock Point / Consumers Power Company employees in planning and implementing decommissioning activities.

u 4 i COMMUNICATIONS (. The Decommissioning Plan Team will rely on and be relied upon for the following methods as a minimum in communications with-in the Team, BRP, and CPCo as well as with outside contacts:

Periodic presentations to BRP Plant Staff eg, Engineering Department, Operations, Maintenance, etc.
Status Reports in the Weekly Bulletin and periodically invite Plant personnel to stop by the trailer to discuss current status or questions as they may arise.

e Discuss status during weekly BRP/ NOD Staff Meetings.

Provide Mission Statement on:

- Business Cards - Posters, etc I o

2 BRP DECOMMISSIONING PLAN bONTENTS I.

SUMMARY

OF PLAN II. DECOMMISSIONING ALTERNATIVE SELECTED AND DESCRIPTION OF ACTIVITIES III. FACILITY RADIOLOGICAL STATUS - includes Final Survey IV. WASTE MANAGEMENT - Radioactive waste - high level (includes spent fuel) - low level - Non-radioactive waste V. SAFETY ANALYSES VI. COST ESTIMATE AND FUNDING PIAN VII. ADMINISTRATION - TECHNICAL SPECIFICATIONS - PROGRAMS - Security (including Fitness for Duty) - Radiation protection - Offsite Dose Calculations Manual - Process Control Program (radwaste) - REMP/RETS - Quality Assurance - Fire Protection - Occupational Safety - Training - Emergency Planning

.u STUDIES

ENVIRONMENTAL STUDIES (including Report) e DECOMMISSIONING ALTERNATIVE STUDY e SPENT FUEL STORAGE e REPOWERING e LOW LEVEL WASTE DISPOSITION ALTERNATIVES e SYSTEM RECLASSIFICATION e DISMANTLING TECHNIQUE OPTIMIZATION i

e ENVIRONMENTAL DESIGN CONSIDERATIONS, eg tornado, floods,etc e PLANT RADIOLOGICAL STATUS - INSIDE CONTROLLED AREA - OUTSIDE CONTROLLED AREA e REVISE CHAPTER 17 (accident analyses) e ELECTRICAL DELOADING OPTIMIZATION, (includes react bldg heat loads) e SITE STAFFING e REVISION OF INSURANCE COVERAGE, re Hazzards, etc e TAX ABATEMENT i [ ? e

u 1 i -INTERNAL CORRESPONDENCE - ( WHITE PAPER ON BIG ROCK POINT DECOMMISSIONING PLAN September 1993 The MPSC Order in Case No. U-9668 dated November 20,1991, requires Consumers Power to file a report to the Commission (MPSC) on the adequacy of the existing annual decommissioning provision for Big Rock within 30 days of filing its preliminary NRC decommissioning plan, but no later than March 31,1995. NRC decommissioning regulations i currently require that a preliminary decommissioning plan and a final decommissioning plan be filed within 5 years and 2 years respectively of the planned shutdown. However, discussions with the NRC have resulted in Consumers Power being allowed to submit only a final decommissioning plan early, as long as the requirements of the preliminary plan are included. It is our intent that Big Rock be the first commercial nuclear unit to operate to its intended license life and planned shutdown for decommissioning. Results of an options study related to continued operation of the Big Rock Plant and completed last year indicated, among other things, that uncertainties can be reduced and total costs controlled (and even reduced) by completing decommissioning plans in advance of plant shutdown. From a rate payer perspective, plant operation conclusions in the study indicated l a small positive net present value to an early shutdown. However, this conclusion assumed recovery of, and on, stranded investments as well as full decommissioning costs. From a i shareholder perspective, this is a smaller negative NPV for an early shutdown. The uncertainties were found to be greater for the shareholder than the rate payer. Recommendations were made in the study to begin immediate preparation for decommissioning plans to include the MPSC rate case update, a final NRC decommissioning plan, and the details for actual shutdown and dismantlement of the plant. The plant would continue to operate on a cycle to cycle basis after the decommissioning plans are completed and approved. Operation would continue until May 2000 when the current license expires, but not thereafter. The ;;reatest uncertainty related to these recommendations is the current escalation of decomm'tsioning costs. For example. with low level radioactive waste storage costs projected at $1000/ft', some nuclear plants are esumating plant decommissioning costs at $1 billion or more. It is our belief that a new process can be developed to substantially reduce nuclear plant decommissioning costs. It is planned to test the new approach in the development of the Big Rock NRC final plan. The process could also have a greater impact on our Palisades Plant with development of the Palisades decommissioning plan at a later time. Yankee Atomic Electric Company (YAEC), is completing development of their final decommissioning plan for the Yankee Power Plant with submittal scheduled to the NRC this fall. YAEC has changed considerably the structure and content of the plan by developing I standards which has the effect of bounding the dccommissioning work within the plan. In

this way, the details of actual dismantlement are not included as part of the plan for NRC ( approval, but instead it is developed internally as a work plan. He NRC appears to like the new process since it should save considerable resources with reduced changes, revisions, and new approvals to the plan during the actual decommissioning process. He plan is also considerably smaller, of less than 2" thick as compared to others that have ranged from several inches to feet. We like this new process because it allows considerable flexibility during implementation and is less prescriptive in describing the "how" to do the actual work. It is our intent to use a similar approach to Yankee's plan, but with some changes. For example, Yankee is going to the "greenfield" condition with no repowering option. We will investigate coupling the repowering option with decommissioning and maintaining a site presence since the potential l exists to reduce decommissioning costs to the customer by as much as $50 million in preliminary estimates. We will also explore the potential for capitalizing on our byproduct license at Big Rock which could result in significant reduction of NRC radiological regulations. Yankee did not have this option. We will look at removing (1) the highest source of radiation exposure (excluding fuel) and (2) the most contaminated materials at the outset to beginning the dismandement which showed a benefit to worker productivity in the latter stages of deccmmissioning. We also plan to challenge the cost estimating techniques, utilizing the Yankee experiences. We both use the same contract cost estimates (TLG). i In preliminary discussions with the NRC, they support our use of the Yankee plan, although there will be considerable changes made. In addition, the three decommissioning options f will be reevaluated which were discussed in the 1990 MPSC rate filing with the MPSC order t issued on November 20,1991. The three options include DECON or immediate dismandement, SAFSTOR or deferred dismandement up to 60 years, and ENTOMB or deferred dismandement up to 60 years. Depending on the ability to ship low level waste and high level waste and the need for power in the northwest area of Michigan and the cost to reduce radiological limits to background for public unrestricted access to the site, any of the three options may prove to be the least cost method when coupled with repowering. In ~ addition, the cost of dry cask storage will be pursued to be included in the cost of decommissioning especially if 1) DOE proves to be not ready to accept title and delivery of the spent fuel and 2) the least cost option includes the cost of dry casks and storage at the site on an interim basis. Based on input from Yankee as to what it took for them to put their NRC plan together, our proposed decommissioning plan team organization to complete an NRC filing on Big Rock is shown attached. The team will consist of about 11 people and will take approximately 1 year to complete. Specific disciplines and people skills include regulatory, radiation protection, radiation material control, mechanical, civil, structural, electrical, systems engineering and cost and schedule. The assignment will be temporary for 1 year in most cases. Considerable travel and/or temporary relocation to the Big Rock arec is a condition of acceptance. Team members assigned will return to their former position or be reassigned upon completion of this assignment. The positions were posted in the EA&P vacancy listing. The interest has been nothing short of remarkable, with over 45 candidates interviewed. It is [

iq i 3-i ( planned to select the team in early September and mobilize the team at the site by October 1, 1993. j j De cost for putting the NRC plan together will eventually be paid for out of the. l decommissioning fund currently being collected. A work order is being established along with a 9000 series account to capture the costs. De expenditure will appear on NOD's responsibility reporting system but is not included in the Income Statement. 1 i The team will be disbanded after finishing the NRC Tmal plan. However, some work will continue on the plan through the NRC review and approval process. Based on past history, it will probably take 1% to 2 years for the NRC to approve the plan (1996 approval anticipated). In addition some resources will be needed over the following 2 to 3 years to develop the detailed work plan (as bounded by the NRC final plan) which describes the actual dismantlement process. - These costs are also part of the decommissioning effort and will be charged accordingly to the work order. Specifics of the work order plan and the i resource needed will be developed later as the fmal plan begins to take shape. l l In parallel to developing the NRC fmal plan, will be development of the MPSC rate filing. } A common thread is the cost estimate for the decommissioning options considered and the ( option recommended. The cost estimate will be included as an attachraent to the NRC Tmal plan. The cost estimate, including recommended decommissioning option and testimony to I support it, will serve as the basis for the MPSC rate filing. It is anticipated that the Palisades rate filing will be made concurrent with the Big Rock rate filing, similar to that made in 1990. l Current decommissioning costs collected through July 1993 on the principle alone for Big Rock are approximately $56 M and for Palisades approximately $75 M. Interest collected. J through December 1992 was approximately $6.3 M and $8.8 M respectively. This (ecommissioning surcharge was based on the immediate dismantlement or DECON i method identified in the MPSC order issued on November 20,1991. Each of the three i decommissioning options will be re-evaluated in preparation for the next MPSC rate filing to ' l determine the recommendation and least cost decommissioning option. i The cost for preparing the Big Rock cost estimate (TLG) will probably be charged to the decommissioning fund since it is also a requirement for the NRC final plan. Since there is no plan to file a Palisades final plan with NRC at this time, the cost estimate (TM) for Palisades will probably be charged against the rate making process, the same which was done j in the 1990 rate filing. i ( i

BRP FINAL DECOMMISSIONING PLAN MILESTONES i ( i NUCLEAR REGULATORY COMMISSION RELATED October 1,1993 Initiate Decommissioning Plan Preparation Project January 1994 Perform Studies to support the Plan January 1994 Select Preferred decommissioning methodology May 1994 Complete Environmental Studies and Report July 1994 Prepare successive and final drafts of Plan September 1994 Review and finalize Plan for NRC submittal October 1994 Submit Plan to NRC for Review / Approval, on/about 1 Year Later Receive NRC Approval of BRP Final Decom'g Plan MICHIGAN PUBLIC SERVICE COMMISSION RELATED January 1994 Initiate TLG Cost Study for use with the NRC Plan I October 1994 Prepare Testimony for Decom'g Fund Surcharge Marcb 1995 File Decom'g Surcharge Rate Case, on or before 1 Year Later Receive HPSC Decom'g Fund Surcharge Rate Order (

l i NRC SUPPORT hT.EDED i ( .I 1. Concurrence with single Big Rock Decommissioning Plan submittal rather than " preliminary" and " proposed" Decommissioning Plans. j 2. NRC Decommissioning Project Manager identified. l 3. Decommissioning Kickoff Meeting with NRC (NRR & NMSS) - anticipate scheduling by December. { 4. Anticipate periodic meetings (at least monthly). ? 5. If the interface between the NRC and CPCo is timely, it should result in quick turnaround on issties and may require specific technical meetings. 6. NRC approval of the Plan within one year of submittal. 1 i s. f 1 4 i i ~ i i i

=u TEAM BACKGROUND / EXPERIENCE (' JSRang - BSME - Lavrence Institute of Technology, MBA - Notre Dame, 24 Years Nuclear Experience Former O&M Superintendent 9 Big Rock Point & Palisades Held RO 9 Big Rock - Director of Nuclear Support WEKessler - BS Physics - Eastern Michigan University 37 Years Nuclear Experience Including Management Positions @ Consumers Power, Gilbert / Commonwealth, t Westinghouse and Phillips Petroleum JLCorley - BSCE - Purdue University 28 Years Construction / Operations O Consumers Power - 24 Years Nuclear Experience RWWyniawskyj - BSCE - Temple University 15 Years Project Management / Control Experience Including Nuclear Plants in South Korea RLBurdette - Nuclear Navy; 16 Years @ Big rock - Chemical / Rad l Pro /RWD Shipping Including Supervisory Experience l RAEnglish - BS/MS/PhD, Health Physics - Union College (BS) and University of Michigan (MS & PhD) ] 17 Years HP @ Consumers Power - Corp Health Physicist i JMGrant - BSCE - Penn State; 14 Years Experience Formerly NRC; Now YAEC Licensing for Decommissioning Plan LFMonshor - BSNE - University of Michigan 20 Years Nuclear Experience, 18 0 Big Rock Point in Reactor Engineering and QA - Held SRO Cert l NALabrecque - BSCE - University of New Hampshire; 24 Years Experience, 9 Nuclear; Was Lead Civil on YAEC Decommissioning Plan GHRPetitjean - Naval Science - Naval Academy 10 Years Nuclear Navy; 18 Years CP Nuclear 9 Big Rock, l Palisades & Midland; SRO/SRO Certif @ Pal & BRP JPWeisel - AA - Electronics; 15 Years 9 Big Rock - I&C, Operator, Shift Supervisor - Has SRO License I

_v 1 ( 1 i OTHER ACTIVIHES I

m- ~- GENuclear Energy [' I GenTaw Cawnr - {.. June 24,'1993 n3 %, % s,r,a 3 3 y; ~ d i Charles Pierce Southern Nuclear Operating Company P. O. Box 1295 Birmingham, AL 35201-1295

Dear Chuck:

I received the attached Big Rock Point end-of-license plan from Michael Bourassa of Consumers Power. It appears that there are several elements of the Big Rock Point plan which overlap with the BWR Owners' Group license renewal I activity. The areas of common interest include: economics, minimum-cost modifications, and focused maintenance. I believe that we should have a presentation to the BWROG-committee on Big Rock Point's plan to' explore ways to cooperate. Let me know what you think. y r

Regards, W

Peter P. Stancavage Project Manager, License Renewal cc: Michael Bourassa, CP (w/o attach) Don Eggett, Ceco I 6 f I i i

u-V ,_~ l I P S A M II ,.-r-- S A An In=rmsonal conrewa Devoted e Die AdvaW F" 'l of Sysmenessed Methods for the Design and Operanaa of Technolosical Synams and Pnx==== i f ciety for Risk Analysis European Safary and March 20 - 241994 Sea Diego Ritten Beach and Tenana Resort Sea Diego, Cellfornis, tisA 56epers, J. R. Consumers Power Gmpany CHAIR 27780 Blue Star Memorial Highway g SCIENTBC'H. b= Covert M149043 12760 High Bluff Ddvs. Ste. 310 San Diego. CA 92130

Dear Author:

Tat (619) 755-4535 Fu (619) 755 4336 We are pleased to inform you that the following paper (s) you submitted has been accepted for AssOCIATEc{ AIR presentation and inclusion in the proceedings. Dr. Douglas D. Orvis [s0 W Tm ss 110 Reading End of Ucense - Big Roct Point san Diego.CA 9212: Coeuthors: Withrow. G.C. T:L (619) 5924189 Fu (619) 592 0586 INSTRUC.TIONS FOR PAPER PREPARATION OIAIR.TB"20CA1. PROGRAM COMMITTEE The original and a copy of the paper must be submitted to Professor George Prof. George Apmo'. skis Apostolakis by October 10,1993. We plan to have the proceedings ready at tbc Eng @ N Conference and WE MUST ADHERE 11)1 MIS DEAD 11NE. Les Angeles. CA 90024-1597 The proceedings will be published by Picnum Publishing Corporation and will be Tal 010) E25-1303 distributed work! wide. The manuscript must be prepared according to the enclosed instructiors. Fu 010) 206 2302 e The maximum number of pages is SIX (including text, tables, and figures). g 3g [ T:000CALPROGRAM t .DMMITIEE IMPORTANT NO11CE Dr. J. s. We 3$7 EngW.ng N Due to the large number of accepted papers, the meeting has been extended to include Friday, im Angeles.CA 90024-1597 March 25. Tel 010) 648 6658 Fax 010) 206 22 In order to alleviate the financial problems, the Organizing Committee has decided to reqacst that all authors enclose with their manuscript their Conference Registration Fee of $440.(0. ogggg, e ORGANIz:NG CDMMIITEE Please make your checks or (International) money orden (in US dollan drawn on a US Dr. Andrtw A.Dykas bank) peystAe to SCSRA.PSAM. PID. Inc. 4590 MacAr:hw Blvd. Ste. 400 Newpon Beach. CA 92660-2027 In case you are unable to attend the Conference, half of your fcc will not be refunded and will Tet 014) r33 2020 be your cost for having your paper published in the procredings. If you have more than coe Fu 014) 833 2 paper (singly authored) you need only stbmit $440.00. If your papers have co-authors, you must submit the required fee for each paper (and this will be the registration fcc of ooc CHAIR.sDcOR ADVISORYBOARD additional person per paper). Dr. B. John Ge.trict I 9dM cAnha Blvd. Ste. 400 Newpe,n Benh. CA 92660 2027 ywr paper. Tel. 014) 833 2020 Fax 014)133 2085 CONTERENCEORGAN:ZATIONCDMMITTIE D. C. Bicy S. B. Gna:ro D. W. Henneke V.S.Ho M. Kazarians N. Meshkati A. Mosleh R. J. Mulvihill N. Sankaran N. O. Siu PLC.inc. The Aerospace Corp. Hamteton NUS PLG. Inc. Kazarians & Assoc. USC Univ.of MD PRC. Inc. UNCCALCorp. INE2.

w-m. s.v, OCT 2E '93 13:09 FRCM PALISADES HECO PAGE.CDS ( RFACHING END OF LICENSE. BIG ROCK POINT 8 James R. Schepers' and Gregory C. Withrow 'Nudear Performance Assessmcat Department ' Big RockPoint Consumers Power Company Introduction %ere are 107 licensed operating reactors in the US today. Collectively we provide about 20 % of thir, country's electrical energy. A short review of recer:t generation st:tistics indicates this is a stable co::tdbution. However, since 1989, six smits have been removed from service wcII prior to their 40 year design life. As never before, we are an / industry under fire to live up to the promise ofsafe and affordable elecide generation Som the nuclear option. While there are many issues, pn>bably the most ireportant one facing a utility with an old plant is economic. Akhough average U.S. plant capacity factors have been generally incrMng over the past few years, costs, until recently, have also increased, generaDy faster. "Ilfe Exterision" beyond 40 years, for Big Rock Point, has not been shown to be coonomic. Herefore, Consumers Power has chosen a simple approach for Big Rock Point ; address the irsues directly and work coopeativdy with the regulators to achieve the End of License (EOL). We believe this god is appropriate for both the electric customers of the p! ant output, as we'l as an example to the industry. Big RockPoint Fo!!owing the 1992 closing of Yr.nkee Rowe, Big Rock Point became the oldest operativ plant in the industry. Big Rock is a 70 MWe General Electric Boiling Water Reactor that went into commerdal operation in 1952. There are many unique design features, including; - Single Steam and FeedwaterLines. - Oravity Feed Liquid Poison System, -Passive Ezrsg.cy Condenser. - Scram Damp Tank, - In-Cordainment Spent Fuel Pool, and - Steci, ventilt.ted Containment. s

- TOTAL PAGE.005 **

,D ~ w oCT 22 '93 13:07 FROM Pall 5ADES HECO PAGE.002 Big Rock has led the industry in several innovative areas, including ; - One of the cadiest power applications ofmixed exide fuel - An cady user ofPRA to resolve genede industry safety issues (. - Use of a 'Living ScheduW to address regulatory and plant generated Issues Big Rock has always been a ground breaking plant. Akmg the way, the plant has generated more than 10 million MWHr for the Micidgan electric grid, and emuMed a 60 % urit capacity factor (MDC). In 1991 Big Rock was awarded the status ofNuclear Hinoric hndmark by the ANS. De plant has operated for 16 years without a lost time accident. Perhaps the most significant aspect of Big Rock % performance is that it continues in the currett regulatory environment with only 154 plant employees (arx! 20 non-plant staff individuals). Big Rock EOL The last 'first* we hope to accomplish at Big Rock Point is to be the firm to operate for the full licensed period. For BRP, this is May 31, 2000. Many challenges stand between us and that goat As a strategy, we have chasen to establish reaching EOL as the primary plant goal, and ordered our efforts toward addressing the issues at hand. We have as a first matter, refined our thinking as to what success means for Big Rock Po*mt. To achieve EOL, we will need to ; - Foner com ' = to rolms Operations, Maintenance, and Engineering - Grow away from long-tenn initiatives to focus resources on mairt.aining facility ' top condition and retaming experienced personnd to m assure safe plant operation. ( -Develop a relationship with the NRC that assures resources are correctly allocated. - Prepr.re the facility for decommissioning concurrent with day to day safe and economic operation. A pdmary philosophical underpinning of this effort is our commitment to safe and c5cient operation. Assurance of nuclear safety is and will continue to be of paramount importance. Our principles of phnt operation will be as follows; - Be risk attentive, evaluate risk and react to risk conservatively. - Assure selection of actions and programs provide the most cost effective risk benefit. - Communicate with the NRC so they can be aware of the BRP actions and programs effect upon risk. - Duild upon the successfal dsk prograin that stready exists. - Temsna:e plant operation if safety levels cannot be maintained. Big Rock has orgathed a team to marage these issues, led by a senior plant staff manager. In considedng our regulatog processes, we have concluded we can accomplir,h these above objectives within the current structure. Integrated Plan (IP) i To accomplish the above in the most economic fashion, requires a single decision making process thct addresses both company internal and regulatory initiated issues At ( Dig Rock Point, this process is called the Integrated Plan (IP). Big Rock Pomt has for

s OCT 02 '93 13:08 FROM PALISADES HECO PAGE.CO3 several yests been one of the few plants using an " Integrated Living Schedulc" to rank i new regulatory issues within arrent commitments. Ris process evaluates the use of engineering resources with respect to modifications and programs The purpose of this process is to work on acdvities that are the most important for BRP and to communicate ( the resulting priorities to the NRC. The evaluadon ofissues is phed by the Technical Review Group (TRG) based upon four criteria. The criteria are; 1. He abilityto acideve safe shutdown 2. Minimization ofradionuclide rdcase 3. Enharm ofp.m.d safety 4. Improvement ofplant availabirdy Rece=tly an haproved method has been devdoped to provide a more quantitative evaluation. He value ranking methodology has been updated to bcfude insights and lessons learned from other utiDty experiences, and for example, applicable local, state and federr.l.egulations as they apply to utihty operadons. In order to better allocate scarce resources, Big Rock Point has begun implementing this more quantitadve form of project ranking This improvement attempts to explicitly achieve a better ba!ance among plant goals. Projects (and thereby issues) are evaluated and ranked according to their benefzt and cost coctribution to the following piant goals : Business Performance, Safety Performance, Hanun Performance, Re5 ability, and Regulatory Performance. The nuclear safety values of the method are supported by the plant IPE. His method produces an i:dtial ranking, that is input to the TRG process. De membership cf the TRG is diverse, representing operadons, cogineering, probabilisde risk assessment, brah physics and nuclear Ecensing. %e diversity is important as Gnal rankbgs are==Dy suidective with quantitative input. The membership nominsDy involves six peopic of which half represent tbc BRP plant or M-n. Use of non-BRP expertise is intended to provide a more balance evaluation. ( Some of the industry generic issues evaluated by this process include; Station Blackout, Alternate Rod Injecdon, Recire Pump Trip, and Seismic Weak Links. It is our intention to use this methodology to also evalcate ; SQUG, Reactor Vessd Structural Integrity, and the Mr.intenance Rule. Huntan Resources Plan Attracting and retabing critical and experienced staff to the end oflicense is a crucial issue. We are addressing this issae directly by initiating focus group meetings with all employees. Redudng the uncertainty for these employees is the primr.ry focus of the Human Resources portion of the EOL strategy. Along with the Decommissioning Planning, the Human Resources Plso, will reduce employee uncerta*mty regarding leegth of funsre service at Big Rock, Corepany re emplo3 ment and relocation. Employee direct participation in deciding their fixture is the employed strategy. The plan includes newjob and penonal development training to prepare employees for future newjobs,.in or out of CPCo. Presently there are appmxi:nardy 174 CPCo employees at Big Rock Poirt We recognize that mai::taining the right tiimate'is absolutdy essential to success b this area, ) as well as continued safe operation for any period, at any plant. Communication Plan As with ' routine' plant operation, there are many stakeholders rdated to those ( decisions occurricg ner.r the end of a pir.ats licensed operating period. Some of those 1 l

w ~ OCT 22 '93 13:08 FROM PALISADES NECO PAGE.C04 stakeholders are; employees, NRC, Michigan Publio Smioc Commission (MPSC), media, local govemment bodies, environmental groups, and local residents. All these parties need a e!!able source of routine information to satisfy their diverse values and interests Planning for this comnamication pmcess cady in the EOL development effort permita ( timely and reliable information smices The Communications Plan continues in-place s community activities such as ; an active plant tour program, spcs /ug local Chamber of Commerce %Aer Hours Nights', and periodic briermgs orelected local of5cials and enjor media was Increasingly, these contacts wi!! contain EOL speciSc content Additionally, the plan calls for the development of a Cith.en's Advisory Board, wwized of local bpinion leade% and the development of an EOL book!ct speciScaDy for employce. community comer.micaSons. The basic underfying assumption of this plan is that we have an obligation to the local commucity, and stakeholders at large, to meet their farormation needs, on their terms, as the information becomes avdable. Decommisaloning Plan This portion of the EOL effort is not only important in and ofitseK but also for its impact upon the other portions of the EOL effort. Knowing how and when decommissioning will occur is important for pir.nning purposes of all stakeholders and a!!aws them to deEne their position with rapect to BRP. b order to accomplish EOL, CPCo wG submit a Final Decommissioning plan in June of 1994. A letter to this effect will be docketed, and presented by serdor CPCo rnanagernerit to senior level NRC management This submittal will be the comerstone of the EOL strategy. CPCo wG use a 50.59 analogous review process to " maintain" the plan during its use. This will allow the plan to be modified during its use without NRC approval when such changes do not affect anfety a bsis or the health and safety of the public. ( IndnstryInitistives Given the generic significa:x:e of the BRP EOL effort, several industry discussions have been initiated, including the following; - Research Issues (INEL and NRR) -BWROG -General Electric -INPO Status Summary The above status of the Big Rock Plan provides a window into how Consumers Power is appmaching "End ofLicense" at it's oldest nuclear plant. More importantly tids presentation was intended to convey some of the reality of the pursuit of "End of Ucense". It is a form of Efe extension", the one to wfich all operating reactors abould soon give their attention. i

Big Rock Point Decommissionmg Communication Plan i draft New initiatives Citizen Advisory Board Emergency Planning Zone communication -i Purchased advertising Employee communication l 1 Ongoing initiatives Annual public tour program Briefing oflocal and state and federal elected officials, and interested constituencies such as chambers of commerce, school board members, service clubs and business leaders. l i Briefing oflocal media \\ -l Normal communications i ) I

Meeting Summary for October 25, 1993 Distribution w/ enclosures 1 & 2: Docket File NRC & Local PDRs PD#3-1 Reading BJorgensen, RIII LOlshan Distribution w/ enclosure 1: TMurley/FMiraglia l LCallan ~ JRoe JZwolinski WDean CJamerson OGC ACRS (10) PErickson i EJordan, MNBB 3701 RLeeman MPhillips, RIII BMcCabe, EDO, 17 G 21 cc: Licensee & Service List I}}

ML20059H920

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