ML20216G907
| ML20216G907 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 04/08/1998 |
| From: | Harris P NRC (Affiliation Not Assigned) |
| To: | Vernon D DON'T WASTE MICHIGAN |
| References | |
| NUDOCS 9804200523 | |
| Download: ML20216G907 (6) | |
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- o,o April 8, 1998 i
Ms. Doris Schaller Vernon, Secretary Northern Chapter, Don't Waste Michigan 1028 Hoffman Street Petosky, MI 49770
SUBJECT:
YOUR LETTER DATED FEBRUARY 16,1998, REGARDING ACTIVITIES AT BIG ROCK POINT (BRP) NUCLEAR PLANT
Dear Ms. Schaller Vernon:
In your letter to me, dated February 16,1998, you made a few comments and asked a number of questions regarding activities at BRP. In particular, you commented that on February 3,1998, we requested additionalinformation from Consumers Energy Company regarding their proposed changes to their emergency preparedness plan, as provided to the NRC staff by Consumer's letter date September 19,1997. You also correctly noted that i
Consumer's hired an outside firm to perform chemical decontamination of their primary coolant system in order to remove radioactivity from the associated piping and components.
j You then asked several questions relating to NRC staff approval of this activity and stated, in part, that Consumer's " piloted a technique never before employed at a commercial" reactor.
Regarding your comment on the BRP emergency plan submittal, the NP.C staff continues to review the proposed emergency plans and requested exemptions and on February 3,1998, we requested additionalinformation from the licensee to support this review. The number of questions we asked and the time associated with our review of Consumer's submittal are not atypical, i
Regarding the radioactive decontamination of the primary system, while it is true that the particular chemical process used at BRP has not been used at other nuclear power plants, chemical decontamination of radioactive components has been performed at other facilities and is not a new science. In 1985, the NRC contracted with Idaho National Engineering Laboratory to study the removal of oxide films from light water primary coolant systems, i
The results of this study were published in NUREGICR-4445, " Effectiveness and Safety Aspects of Selected Decontamination Processes." This report documents the evaluation of four different chemical processes used at thirteen different power reactor facilities. This evaluation assessed,in part, dose savings, decor;tamination radioactive waste, and problems observed and lessons learned. One of many findings documented in this study was that the chemical decontamination process reduced the levels of radioactivity such that worker exposure was significantly reduced, in addition, the dose to perform chemical decontamination was relatively small. Therefore, there was a net benefit in overall dose reduction to workers. I enclosed this report's " Summary and Recommendations" for your information.
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Ms. Doris Schaller Vernon 2
i Regarding your question of whether the NRC staff approved the conduct of the primary system chemical decontamination, please note that there is no regulatory requirement that the NRC staff approve of such activity. However, the licensee is required to ascertain before undertaking such an activity, whether the activity would (1) involve a change to technical specification requirements or an unreviewed safety question pursuant to 10 CFR 50.59 or (2) foreclose release of the site for possible unrestricted use, result in significant environmentalimpacts not previously reviewed, or result in their no longer being reasonable assurance that adequate funds will be available for decommissioning (10 CFR 50.82(a)(6)).
To provide additional assurance that the decontamination activity would occur without undue risk to the public, the NRC's onsite inspector reviewed and evaluated the licensee's chemical decontamination procedure and safety evaluation, and observed the licensee's safety review committee evaluations on the decontamination process prior to conducting the decontamination. Additionally, NRC Region 111 assigned a Senior Radiation Specialist to the site to observe the actual conduct of the chemical decontamination process. These inspectors concluded that items that could possibly be a safety concern were discussed and resolved by the licensee and that unresolved safety questions did not exist.
As for the decontamination process used at BRP, NRC Inspection Report 50-155/97015, dated February 14,1998, documents NRC inspector review and assessment of this activity. To summarize, the NRC staff concluded that the decontamination prccedure was high quality and workable, planning was thorough, and communications were very effective. From a radiological perspective, the inspectors reported that the licensee removed approximately 408 curies of radioactivity from the primary system and safely transported the contamination to resin beds for radioactive material disposal. Further, the removal of radioactivity from the primary system occurred with appropriate dose-minimization planning, appropriate execution of the radiation protection program, and utilizing effective ALARA (as low as reasonably achievable) principles. The inspectors also noted that the chemical decontamination reduced dose rates by a factor of 10 or more in the vicinity of the primary system. There were two system leaks and a violation of NRC requirements due to an individual not adhering to a procedure requirement during the chemical decontamination. This inspection report is also enclosed for your information.
Regarding your question of when the licensee informed us of their intent to perform the chemical decontamination, Consumers appropriately informed the NRC staff and the public of their intent to perform chemical decontamination, as required by the regulations. These notifications were made on: (1) February 27,1995, as described in the BRP Decommissioning Plan: (2) November 13,1997, at the public meeting we held in Charlevoix, Ml; and (3) September 19,1997, as described in the BRP Post-Shutdown Decommissioning Activities Report (PSDAR). The slides that Consumers Energy used at the public meeting and the PSDAR are enclosed for your review.
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Ms. Doris Schaller Vernon 3
April 8, 1998 Please contact me at (301) 415-1169 if I can be of further assistance.
Sincerely, ORIGINAL SIGNED BY:
Paul W. Harris, Project Manager Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No. 50-155
Enclosures:
1.
NUREG/CR-4445, " Effectiveness and Safety Aspects of Selected Decontamination Processes," Section 2 " Summary and Recommendations"
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2.
NRC Inspection Report 50-155/97015 (DNMS) and Notice of Vio.lation 3.
Slides from the November 13,1997, Public Meeting Regarding Big Rock Point 4.
Big Rock Point Post-Shutdown Decommissioning Activities Report, Revision 1 cc w/o enclosures:
See next page DISTRIBUTION (hard copy) (w\\o enclosures)
TDocket File.50-155 ~
RLeemon, BRP Resident inspector PUBLIC Region 111 PDND rf EHylton (w/ copy of incoming)
SWeiss
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DISTRIBUTION (e-mail) (w/o enclosures)
MMasnik RBurrows RDudley MFairtile TFredrichs AMarkley JMinns LThonus MWebb LWheeler DOCUMENT NAME: G:\\SECY\\ HARRIS \\SCHALLER.216 To ree-ive a copy of this document. Indicate 3rdhe box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy OFFICE PDND: PM E
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PDND:(A)SC PDND:(A)D l
NAME PHarris Ebn MMasnik /f/A-MMendonca A DATE 3/; 7/98 3/h') /98 3/d/98 Yg/6f $/JQ /98 OFFICIAL RECORD C'OPY
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Ms. Doris Schaller Vernon 3
Please contact me at (301) 4151169 if I can be of further assistance.
I
~ S' cerely, Pau W.
- rris, nager Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No. 50-155
Enclosures:
.1.
NUREG/CR-4445, " Effectiveness and Safety Aspects of Selected Decontamination Processes," Section 2 " Summary and Recommendations" 2.
NRC Inspection Report 50-155/97015 (DNMS) and Notice of Violation 3.
Slides from the November 13,1997, Public Meeting Regarding Big Rock Point 4.
Big Rock Point Post-Shutdown Decommissioning Activities Report, Revision 1 cc w/o enclosures:
See next page i
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i Ms. Doris Schaller Big Rock Point Nuclear Plant Docket No. 50-155 (PAGE 1 OF 2) cc:
Mr. Thomas A. McNish, Secretary Lake Michigan Federation Consumers Energy Company ATTN: E. Roemer, Attorney 212 West Michigan Avenue 59 E. Van Buren #2215
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Jackson, Michigan 49201 Chicago, Illinois 60605 Judd L. Bacon, Esquire Ms. Irene Kock Consumers Energy Company Nuclear Awareness Project 212 West Michigan Avenue Box 2331 I
Jackson, Michigan 49201 Oshawa, Ontario L1H7V6 Ms. Jane E. Brannon, County Clerk Michigan Department of Attorney County Building Annex General 203 Antrim Street Special Litigation Division Charlevoix, Michigan 49720 630 Law Building P.O. Box 30212 Office of the Governor Lansing, Michigan 48909 Room 1 - Capitol Building Lansing, Michigan 48913 Mr. Rich Bachus Traverse City Record - Eagle Regional Administrator, Region lli 7401 Middle Road U.S. Nuclear Regulatory Commission Harbor Springs, Michigan 49740 801 Warrenville Road Lisle, Illinois 60532-4351 Ms. Ange!a S. Greenman U.S. NRC Region lli Michigan Department of 801 Warrenville Road Environmental Quality Lisle, Illinois 60532 Drinking Water and Radiological Protection Division Ms. Janenne Irene Froats
,3423 N. Martin Luther King Jr. Blvd.
P.O. Box 528 P.O. Box 30630 Petoskey, Michigan 49770 Lansing, Michigan 48909-8130 Mr. Henry Peters U.S. Nuclear Regulatory Commission Route 1 Resident inspector Office Ewen, Michigan 49925 Big Rock Point Plant 10253 U.S. 31 North Ms. Doris Schaller Charlevoix, Michigan 49720 2310 M-119 Lakeside Condo Unit #55 Mr. Rob 6rt A. Fenech Petoskey, Michigan 49770 Senior Vice President Nuclear, Fossil Operations Mr. Michael Winnell Consumers Energy Company 3250 Krouse Road 212 W. Michigan Ave.
Petoskey, Michigan 49770 Jackson, Michigan 49201 Mr. James S. Rang Ms. Kay Cumbow Consumers Power Company 15184 Dudley Road 10269 U.S. 31 North Brown City, Michigan 48416 Charlevoix, Michigan 49720
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,o Ms. Doris Schaller Big Rock Point Nuclear Plant Docket No. 50-155 (PAGE 2 OF 2) cc:
Mr. Brennain Lloyd l
Northwatch l
P.O. Box 282 North Bay, Ontario PIB 8H2 l
Mr. John W. Campbell Executive Director Eastern U.P. Regional P'e. tong
& Development Commission 524 Ashmun Street P. O. Box 520 Sault Ste. Marie, Michigan 49783 Lake Michigan Federation Attn: T. Cabala, Director 425 W. Western Avenue Muskegon, Michigan 49440 Citizens Awareness Network Box 83 l
Shelburne Falls, Massachusetts 01370 l
Jonathan M. Block, Esquire Main Street P.O. Box 566 Putney, VT 05346-0566 Ms. Deborah B. Katz, President Citizens Awareness Network P. O. Box 83 Shelburne Falls, Massachusetts 01370-0083 1
Ms. Corinne Carey 2213 River Side Drive NE Grand Rapids, MI 49505 l
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