ML20217C303

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Annual Rept of Facility Changes,Tests & Experiments
ML20217C303
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 09/28/1999
From:
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML20217C280 List:
References
NUDOCS 9910130224
Download: ML20217C303 (49)


Text

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NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment I- Modifications Performed to Support Decommissioning DECOMMISSIONING WORK PACKAGE RBA05 Reactor Cooling Water Heat Exchanger Room 420 This decommissioning work package (DWP) controlled the removal of equipment from the reactor cooling water heat exchanger room (420) The service water system (SWS) was isolated from the reactor cooling water system (RCW) on MA-98-0073. This eliminated the cooling function the RCW

. system formerlyhad when the plant was in powed operation. The RCW system was able to be' removed because it no longer served any plant function. UFHSR revision reflects removal of components in the RCW system.

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SAFETY EVALUATION

SUMMARY

This' decommissioning work package did not involve a change in the Defueled Technical Specifications incorporated in the license. This modification was not an unreviewed safety question. Reactor Cooling Water System references in the UFHSR were revised or deleted.

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L NUCLEAR REGULATORY COMMISSION :

l BIG ROCK POINT PLANT l-- ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment I - Modifications' Performed to Support Decommissioning DECOMMISSIONING WORK PACKAGE TBA01B l ,

Condensate Pump Room This decommissioning work package (DWP) removed systems and components from the Condensate Pump Room. The components were removed to I

accommodate the placement of the temporary radwaste skid. Seven systems  ;

affected by the DWP were the Air Ejector and Mechanical Vacuum Pump l System (AES)., Service and Instrument Air System (CAS), Condensate Systu a l (CDS), Control Rod Drive System (CRD), Liquid Process Monitoring System (LPM), Resin Regeneration System (RGS), and Off-Gas Monitoring System l (WGS). Major components which were removed included the condensate pumps, condensate vacuum pump, control rod drive booster pump, condensate L pump inlet and outlet valves, condensate pump outlet check valves, and valves l in the condensate recirculation line.

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SAFETY EVALUATION

SUMMARY

The interface of concern for this decommissioning work package was the

. power supply for the liquid process monitors which were re-routed. (The two

! systems were separated). This DWP did not result in an unresolved safety l ' question. This work did not involve a change in the Defueled Technical l Specifications incorporated in the license.

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t NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment I- Modifications Performed to Support Decommissioning DECOMMISSIONING WORK PACKAGE TBA12 Isolation and Removal of the Equipment from the RDS UPS Battery Rooms

< This decommissioning work package (DWP) removed equipment from inside the RDS battery rooms along the machine shop wall, the hallway next to the RDS battery rooms connected to the service building, and inside the tool crib along the wall to the air compressor room. Systems affected included Reactor Depressurization System (RDS), Emergency. Power System (EPS), Fire Protection System (FPS), Heating and Ventilation System (VAS), and Security System (PRO). The four RDS/UPS battery rooms and the tool crib area were cleared. The interior walls were removed. All equipment in the RDS UPS battery rooms was removed including the battery racks, uninterruptable power supplies, electrical panels, ventilation ducts, interior fire doors, and security grating in the tool crib area.

i SAFETY EVALUATION

SUMMARY

.t The reinoval of this equipment did not result in an unreviewed safety question.

Isolation with systems not available for decommissioning was accomplished on a separate facility change. This work did not involve a change in the Defueled Technical Specifications incorporated in the license.

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, NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT.

ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment l- Modifications Performed to Support Decommissioning

-DECOMMISSIONING WORK PACKAGE TBCO2B

' Remove the Portion of the Fire Protection System Supplying

. the Automatic Sprinkler Heads over the Reactor Feedwater i- . Pump Auxiliary Lube Oil Pump Reservoirs The fire system is "Q", however, this portion of the system is considered non--

. O (therefore non-safety-related) for.the secondary backup supply of water for the Spent Fuel pool. Secondary backup supply is available from a fire protection system (FPS) hose station and the opening of MO-7072 which allows FPS water to go directly into the spent fuel pool. The removal is allowable since the automatic sprinklers over the Reactor Feedwater pump >

lube oil reservoirs will be isolated from the FPS Q-function and not affect it.

The Lube oil reservoirs for the reactor feedwater pumps were removed, so 4 sprinklers'could also'be removed.

e SAFETY EVALUATION

SUMMARY

The decommissioning. work process did not result in an unreviewed safety

. question. It did not affect the Defueled Technical Specifications.

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NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT-ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment,1 - Modifications Performed to Support Decommissioning ENGINEERING ANALYSIS for FACILITY CHANGE 695-05 Replace Area Radiation Monitoring Instrumentation, Setpoint ,

Calculations I The engineering analysis (EA) documented the ranges and setpoints associated with the analog inputs'to the Monitoring Station for the liquid process monitors. RT-8289 is a new instrument which provides input to the Monitoring Station via LU-RP13 and monitors radiation levels in the canal effluent. RT-8290 is a new instrument which provides input to the Monitoring Station via LU-RP14 and monitors service water system effluent radiation levels. RT-8291 is a new instrument which provides input to the Monitoring Station via LU . l RP15 and monitors radwaste system effluent. RT-8292 is a new instrument  ;

which provides input to the Monitoring Station via LU-RP15 and monitors stack j gas / noble gas.

SAFETY EV LUATION

SUMMARY

This engineering analysis did not involve a change in the Defueled Technical-Specifications incorporated in the license nor was it an unreviewed safety

- question.

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.o NUCLEAR REGULATORY COMMISS!ON BIG ROCK POINT PLANT ANNUAL' REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment I- Modifications Performed to Support Decommissioning ENGINEERING ANALYSIS for FACILITY CHANGE 699-06 Spent Fuel Pool Decay Heat Forecast This engineering analysis (EA) was done as part of FC-699, Spent Fuel Pool Cooling Skid Installation The purpose of the EA was to forecast the spent fuel pool decay heat through 1/1/2006. The data will be revised in the UFHSR in a table format verses a graph.

SAFETY EVALUATION

SUMMARY

The EA demonstrated that the calculated heat load remains bounded by accidents previously evaluated in the UFHSR. This UFHSR revision did not involve a change in the Defueled Technical Specifications incorporated in the '

license nor was it an unreviewed safety question.

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' ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment I- Modifications Performed to Support Decommissioning ,

FACILITY CHANGE 695 Monitoring Station This facility change installed a new Monitoring Station to replace the Plant control room. The facility change provided a'means of control, monitoring, alarming, and data archiving for selected system parameters during decommissioning. The facility change replaced the spent fuel pool and radwaste area radiation monitors. An instrument for monitoring the spent fuel pool water temperature from the remote monitoring station was added. The plant emergency siren is controlled from the monitoring station. Outside -

temperature, wind speed, and wind direction instrumentation are provided to the Monitoring Station. Containment ventilation valve control and position

,. indication are available in the monitoring station. The monitoring station is located in the Security Building, east of the Secondary Alarm Station.

SAFETY EVALUATION

SUMMARY

This facility change did not involve a change in the Defueled Technical Specifications incorporated in the license. The Control room was abandoned and the Monitoring Station was declared operable with the approval of amendment 120 of the Defueled Technical Specifications, 12/24/98. This modification was not an unreviewed safety question, items considered in the review included control room habitability requirements, seismic design, and evaluations of structures to withstand design basis events. Emergency diesel generator alarm and control circuitry and alternate shutdown capabilities were determined to be not applicable with the plant in the decommissioning phase.

Other remote alarms were analyzed with respect to effects on design basis accidents an'd need for continued applicability in the new Monitoring Statiori.

The UFHSR revisions included editorial changes (from " Control Room" to

" Monitoring Station".)

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1 NUCLEAR REGULATORY COMMISSION 4 BIG ROCK POINT PLANT

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ANNUAL REPORT OF FACILITY. CHANGES, TESTS, AND EXPERIMENTS Attachment I- Modifications Performed to Support Decommissioning i

l FACILITY CHANGE 696 )

Phase 11 of Decommissioning Power System l j

1 This facility change replaces the existing Station Power System (SPS) with j Decommissioning Power System (DPS). DPS is used to supply power only to i those components needed during the decommissioning phase.

DPS is supplied from a new substation in the southeast corner of the plant  ;

site. The substation is outside the plant fence and is fed from the existing 46 {

kV transmission line. The tie to the 46 kV transmission line is through j Decommissioning Power Transformer No.1. This transformer drops down the  !

.e 46 kV high side potential to the 8.32 kV required for distribution around the )

site, The 8.32 kV potential is stepped down further to 480 volts for major l component operation. No equipment was identified as needing 125 vde, so battery chargers and battery banks were not kept.

Spent fuel pool emergency support system requirements were met by retaining the rruin diesel generator in the event that site pov,er is lost.

SAFETY EVALUATION

SUMMARY

The modification did not involve a change in the Defueled Technical Specifications incorporated in the license nor was it an unreviewed safety 1

_ question.

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NUCLEAR REGULATORY COMMISSION -

BIG ROCK POINT PLANT ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS

' Attachment I - Modifications Performed to Support Decommissioning l

FACILITY CHANGE 699 Spent Fuel Pool System Upgrade / Replacement

'This facility change installed a new Spent Fuel Pool (SFP) cooling system so the major components of the existing SFP cooling systern may be dismantled in support of decommissioning activities.- J l

1 The new SFP cooling system uses' compact plate and frame heat exchangers cooled by the existing Service Water System (SWS), eliminating the need to maintain the existing Reactor Cooling Water (RCW) System connections. The

'new SFP cooling system rejects heat directly into Lake Michigan via SWS, eliminating the intermediate RCW cooling loop. The new plate and frame heat exchangers are highly efficient and reliable, with the design of the heat exchangers inherently preventing the possibility of mixing the two fluids.

Skid' component leakage is captured and routed to the alternate radwaste i system by the existing floor drains. This heat exchanger design precludes the potential for inter-system cross contamination thereby assuring compliance with the operating characteristics described in the UFHSR, section 5.4.9.2.

The new SFP cooling system is designed to maintain the SFP below its original design temperature of 95 F and is capable of maintaining the SFP temperature well below 150 F maximum temperature.

The new SFP cooling equipment consists of two motor driven pumps, two plate.and frame heat exchangers, one bag filter, water chemistry control connections and necessar'; controls, instrumentation, and interconnecting piping and valves. The system is capable of removing at least 205,200 BTU /hr per train and maintains the SFP temperature well below the 150 F max imum.

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- ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment I- Modifications Performed to Support Decommissioning The' control room location project (FC-695) will provide SFP temperature and

. level indication. A SFP Cooling Skid Trouble alarm will be provided to the monitoring station from the cooling skid to alert the operators to conditions such as high temperature, pump trips, high filter differential pressure, and high radiation levels in the vicinity of the cooling skid.

I The system is configured as two parallel pumps and two parallel heat exchangers, each 100% capacity, allowing for flexibility in system operation. l This allows the other pump and heat exchanger to be used in the standby mode and allows the components to be switched out for maintenance, as necessary. l l

t The equipment is powered from 480Vac, provided via the Decommissioning Power System.

SAFETY EVALUATION

SUMMARY

SFP cooling function was not'affected by this modification. Probability for

. accidents and consequences was not affected. UFHSR Section 3.5, Missile

Projection, provided evaluation of the original spent fuel pool cooling system susceptibility to missals. The installation and location of the alternate cooling system is bounded by that analysis. The new equipment is located in an area l

.previously occupied by critical SFP cooling equipment and piping. The , l continued use of this location for SFP cooling equipment does not create nor  ;

increase the likelihood or consequences of a loss of SFP cooling accident. The l Facility Change did not involve a change in the Defueled Technical Specifications incorporated in the license nor was it an unreviewed safety question.

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NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment 1 - Modifications Performed to Support Decommissioning FACILITY CHANGE 700 Modify Control Air System (CAS) to Allow Continued Operation of Some Portions While Other Portions are Decommissioned This facility change resulted in the control air system being broken down into a number of.relatively small segments, each segment supplied by its own air source. The air sources consist of cylinders of compressed gas or small air compressors.

SAFETY EVALUATION

SUMMARY

This facility change d d not result in an unreviewed safety question. The method of supplying air to various components was revised by the facility change. Components needed to mitigate or prevent accidents are stillin place and operable; only the soucce of air is different. The facility change is consistent with and did not i.'volve a change to the Defueled Technical Specifications incorporated in tes license (Control Air System is not included in the Defueled Technical Specificatiocs).

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NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment I - Modifications Performed to Support Decommissioning FACILITY CHANGE 701 Revision to Conceptual Design of New Opening into Containment This modification: 1. Extends containment out to the south end of the pipe tunnel, 2. Establishes the pipe tunnel walls, ceiling, floor, and new door walls as the new containment boundary, and 3. Cuts an opening through the Containment sphere at the north end of-the pipe tunnel.

The new door will be locked from the Turbine Building side, allowing access from the containment recirculation pump room only. This satisfies the -

requirements for entering a high radiation area.

I SAFETY EVALUATION

SUMMARY

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i This modification will maintain containment closure through the installation of a door wall at the south end of the pipe tunnel. Containment ventilation flow, security, and radiation protection controls will be retained through the use of procedural controls establishing entry requirements. Containment closure is not a prerequisite for design basis event mitigation and the structural integrity of the containment sphere is not compromised. The modification is passive in i nature; designed to maintain plant structural requirements. The modification I did not involve a change in the Defueled Technical Specifications incorporated in the license nor was it an unreviewed safety question.

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l Attachment I Modifications Performed to Support Decommissioning MINOR ALTERATION 98-0018 i

L Remove Alternate Vent Path in the Recirculation Pump Room This minor alteration installed an additional ventilation path into the return air l duct in the recirculation pump room. The existing return duct drew air from the upper portion of the room (the steam drum area). During the setup for asbestos  ;

removal for the steam drum area, this return duct was isolated from the rest of the recirculation pump room (to allow asbestos abatement activities in the

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j area). The alternate flow path was installed to allow return flows to the area to l remain as normal as possible.

l SAFETY EVALUATION

SUMMARY

No unreviewed safety question resulted from this minor alteration. The rate of -

air exchange or makeup was not changed to the area. The minor alteration did not involve a change in the Defueled Technical Specifications incorporated in the license. l l

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NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT.-

ANNUAL REPORT OF FACILITY CHANGES,- TESTS, AND EXPERIMENTS l Attachment I - Modifications Performed to Support Decommissioning MINOR ALTERATION 98-0033 Installation of Replacement Demineralizer, Filters and Piping )

in the Liquid Rad Waste System MA-99-0033 replaced the'demineralizer and added redundant filters to the

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Radiation Waste System. The process lines were directed from the radwaste pump room to the condensate pump room via an outside radwaste pump room access. The outside lines are double walled, sloped, and heat traced. The new 13 foot span of pipe is located within an existing radiologically controlled area j

(Zone 1 A). I I

l SAFETY EVALUATION

SUMMARY

The safety evaluation concluded UFHSR desigr r asis ac'cident analysis ,

assumptions were not changed by the minor al. cation. Administrative Controls ensure that requirements of 10 CFR, part 20, " Standards for Protection -

Against Radiation," are met. Design features (heat trace, location in a -

radiologically controlled area, double wall construction, and berms) address -

single failure of the fluid containing components. The ability to safely store spent fuelis not compromised by the minor alteration. The minor alteration did l

'not involve a change in the Defueled Technical Specifications incorporated in the license nor was it an unreviewed safety question.

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I' NUCLEAR REGULATORY COMMISSION l BIG ROCK POINT PLANT .

!- ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment I - Modifications Performed to Support Decommissioning j l

MINOR ALTERATION 98-0039 I

(- Placing the Emergency Diesel Generator (EDG) Auto Start .

and Main 480Vac Breaker Indication Circuit on the Station I Battery And Remove it from the UPS-A Battery l The emergency diesel generator (EDG) circuitry was moved to facilitate the dismantlement of the RDS/UPS battery room. The circuit was retained. The I minor alteration eliminated the Q-interface with the UPS Battery A. I I

l i I SAFETY EVALUATION

SUMMARY

l l This minor alteration did not result in an unreviewed safety question..

Changing the power supply from the UPS-A battery to the Station battery did not affect the probability or consequences of accidents.

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, NUCLEAR REGULA. TORY COMMISSION BIG ROCK POINT PLANT ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment I - Modifications Performed to Support Decommissioning MINOR ALTERATION 98-0044

.lsolation and Removal of Service Water Piping in the Electrical Equipment and Air Compressor Room This minor alteration resulted in the removal of service water supply to the air compressor jackets and aftercoolers. The UFHSR service water supply

- reference to air compressor jackets and aftercoolers was deleted. This minor

' alteration supported FC-0700, Modification of Control Air System (CAS). FC-0700 changed the sources of control air from plant air compressors to small,  ;

local air compressors or cylinders of compressed gas, j

- SAFETY EVALUATION

SUMMARY

This minor alteration did not involve a change in the Defueled Technical LSpecifications incorporated in the license nor was it an unreviewed safety question.

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NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT.

ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment I - Modifications Performed to Support Decommissioning MINOR ALTERATION 98-0052 Retiring in-Place the Cooling Coil for the Air Compressors /

Electrical Equipment Room Cooling Unit The cooling coil in the electrical Equipment Room was found to be leaking service water. Inspection revealed poor condition of coil. Since the Electrical Equipment room has been removed from service for decommissioning,'the cooling load has decreased. The coils were retired in place and the service water connections plugged. ,

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SAFETY EVALUATION

SUMMARY

The Minor Alteration did not involve a change in the Technical Specifications

, ' incorporated in the license nor was it an unreviewed safety question.

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NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT 1 ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment I- Modifications Performed to Support Decommissioning MINOR ALTERATION 98-0064 )

Demineralizer System Trolley The purpose of the trolley is to lift, move, and load the demineralizer filter cask into a high integrity container for ship' ment. Formerly, a boom truck lifted and transported the filters to the radwaste storage vault. l SAFETY EVALUATION

SUMMARY

The safety evaluation concluded there was no effect on Section design basis

!- accidents analyzed in the UFHSR. The change did not involve a change in the Defueled Technical Specifications incorporated in the license nor was it an unreviewed safety question.

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NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment I- Modifications Performed to Support Decommissioning MINOR ALTERATION 98-0068 Radwaste System Repowering MA-98-0068 repowered all radwaste system equipment, including the alarm i panel, from decommissioning power. System trouble alarms are )

. transmitted / relayed to the new monitoring station. i SAFETY EVALUATION

SUMMARY

The safety evaluation concluded UFHSR design basis accident assumptions were not changed by the minor alteration. The method of Radwaste processing is not discussed in Defueled Technical Specifications. The change did not

. involve a change in the Defueled Technical Specifications incorporated in the license nor was it an unreviewed safety question.

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' ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment I - Modifications Performed to Support Decommissioning MINOR ALTERATION 98-0071 Service Water System (SWS) Bypass Line in Turbine Building This Minor Alteration added a non-safety-related flowpath in the Turbine Building to provide a dilution function for liquid radwaste releases to the canal.

This flowpath allows the house service water pump flow rate to be maintained above the minimum value recommended by the manufacturer for the spent fuel pool skid. This minor alteration was done in conjunction to MA-98-0073 (Removal of Reactor Cooling Water System).

SAFETY EVALUATION

SUMMARY

I The UFHSR design basis accidents were not affected by this minor alteration.

The UFHSR was updated to add a statement on the addition of service water bypass line in the Turbine Building. The change did not involve a change in the I

Defueled Technical Specifications incorporated in the license nor was it an  !

unreviewed safety question.

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NUCLEAR REGULATORY COMMISSION

. BIG ROCK POINT PLANT

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~ ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment I- Modifications Performed to Support Decommissioning MINOR ALTERATION 98-0072

-New Refueling Crane ]

This' Minor Alteration a'd ded a new refueling crane, which replaced the existing refueling platform and its 500 pound jib crane.

1 SAFETY EVALUATION

SUMMARY

This minor alteration was ilot an unreviewed safety question and did not involve a change in the Defueled Technical Specifications incorporated in the -

license.

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l NUCLEAR REGULATORY COMMISSION

' BIG ROCK POINT PLANT ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment I- Modifications Performed to Support Decommissioning MINOR ALTERATION 98-0073 Modification, and Temporary Shutdown'of Service Water System (SWS)'in Preparation of Removing the Reactor Cooling Water (RCW) System - In Support of DWP-RBA05, installation of 4". Bypass Line Around the Turbine Lube Oil Coolers This minor alteration temporarily shut down the Service Water System (SWS) to allow installation of a 4" bypass line around the Turbine Lube Oil coolers.

The installation of the line was'part of decommissioning work package DWP-RB05A. The minor alteration and installation of the bypass line resulted in a new configuration of RCW and SWS and supported the establishment of a new.

. spent fuel pool cooling system. The bypass line maintains service water flow, increasing the efficiency of the SWS pumps, allowing necessary work to be

'done to install the new SFP cooling system.' This minor alteration also resulted 4

in allowing RCW to be made available for decommissioning, by eliminating the RCW function of supporting spent fuel pool cooling.

l SAFETY EVALUATION

SUMMARY

During the isolation work period,~when SWS was out of service, the rise in  !

spent fuel pool (SFP) temperature was monitored and found to be below the Defueled Technical Specification limits. This minor alteration did not involve a l change in the Defueled Technical Specifications incorporated in the license nor l

was it an unreviewed safety question.

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NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT ANNUAL ~ REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment I - Modifications Performed to Support Decommissioning MINOR ALTERATION 98-0077 Installation of Decommissioning Fire Detection This minor alteration replaced existing fire detection instrumentation in selected areas (Screenhouse and Diesel Generator Room, Radwaste Processing i Building, Cable Penetration Room and Cable Spreading Area in the Electrical J Equipment room and Spent Fuel Pool Skid Area). Detectors are connected to a j common alarm panel for each area. Alarm signals are radio transmitted to a I receiver in the Monitoring Station.

SAFETY EVALUATION

SUMMARY

The minor aiteration did not involve a change in the Defueled Technical  !

. Specifications incorporated in the license nor was it an unreviewed safety question, v

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NfTACIIMENT II J

I CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT DOCKET 50-155 i LICENSE DPR-6 l l

ANNUAL REPORT OF FACILITY CliANGES, TESTS, AND EXPERIMENTS Technical Specifications, Procedures and UFHSR ( 26 pages) i f

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NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT.

ANNU.AL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS f

~ Attachment II- Changes to Procedures, Programs, Defueled Technical Specifications, and the UFHSR ADMINISTRATIVE PROCEDUPi U LICENSED OPERATOR PHYSICAL EXAMINATIONS

.The purpose of this revision was to cancel the existing administrative procedure to be consistent with the Defueled Technical Specifications.10 CFR Part 55 licenses are no longer required since the Certified Fuel Handler program was approved [ Reference Letters from the Nuclear Regulatory Commission to KPPowers dated 4/16/98, CONSUMER'S REQUEST FOR EXEMPTION FROM CERTAIN REQUIREMENTS OF 10 CFR 50.54, CONDITIONS 'OF LICENSE (TAC No. MA1009) and APPROVAL OF BIG ROCK POINT (BRP) CERTIFIED FUEL HANDLER (CFH) TRAINING PROGRAM (TAC i No. M99690).]

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i SAFETY EVALUATION

SUMMARY

No unreviewed safety question resulted due to this procedure deletion.

Training requirements are consistent with those in the Defueled Technical Specification's. The deletion did not affect the Defueled technical Spe ' cations incorporated in the license.

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BIG ROCK POINT PLANT-ANNU,AL RE, PORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment 11 - Changes to Procedures, Programs, Defueled I Technical Specifications, and the UFHSR I l

ADMINISTRATIVE PROCEDURE 1.7.10 MAINTENANCE SUPERVISOR TRAINING -

Procedure was deleted. Training is now identified in Program D5.0,

' Construction Department Personnel Training Requirements. Revision to the UFHSR is identical with that for section MASTER TRAINING PROGRAM.

! SAFETY EVALUATION

SUMMARY

The proposed change did not involve a change to the Defueled Technical Specifications. The Operator training Programs for Certified Fuel Handlers were approved by the NRC and meets ANSI 18.1,1971. No unreviewed safety question resulted due to this procedure deletion.

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BIG ROCK POINT PLANT ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS

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.. Attachment ll - Changes to Procedures, Programs, Defueled Technical Specifications, and the UFHSR ADMINISTRATIVE PROCEDURE 1.7.7 MECHANICAL AND ELECTRICAL TRAINING PRCCEDURE This procedure was deleted. Training is now identified in Program D5.0, Construction Department Personnel Training Requirements. Revision to the j UFHSR is identical with that for section MASTER TRAINING PROGRAM.

SAFETY EVALUATION

SUMMARY

The proposed change did not involve a change to the Defueled Technical Specifications. The Operator training Programs for Certified Fuel Handlers were approved by the NRC and meets ANSI 18.1,1971. No unreviewed -

safety question resulted due to this procedure deletion.

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i NUCLEAR REGULATORY COMMISSION l

- BIG ROCK POINT PLANT l ANNU,AL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS j Attachment II- Changes to Procedures, Programs, Defueled )

Technical Specifications, and the UFHSR l ADMINISTRATIVE PROCEDURE 1.7.8 MECHANICAL AND ELECTRICAL OJT PROCEDURE TRAINING This Administrative Procedure was deleted. Training is now identified in l Program D5.0, Construction Department Personnel Training Requirements. {

Revision to the UFHSR is identical with that for section MASTER TRAINING PROGRAM.

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i SAFETY EVALUATION

SUMMARY

The proposed change did not involve a change to the Defueled Technical Specifications. The Operator training Programs for Certified Fuel Handlers were approved by the NRC and meets ANSI 18.1,1971. No unreviewed safety question resulted due to this procedure deletion.

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Attachment ll- Changes to Procedures, Programs, Defueled Technical Specifications, and the UFHSR ADMINISTRATIVE PROCEDURE D1.0 PLANT DECOMMISSIONING ORGANIZATION AND RESPONSIBILITIES Administrative Procedure was revised to support the Defueled Tuchnical Specifications, issued 12/24/98. This revision incorporated the new organization for the Big Rock Point Restoration project.

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SAFETY EVALUATION

SUMMARY

]

l l . The proposed change did not involve a change in the Defueled Technical

Specifications incorporated in the license nor was it an unreviewed safety question. All 10 CFR 50 Appendix B and CPC-2A requirements continue to be met.

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i NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT ANNU,AL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment II - Changes to Procedures, Programs, Defueled Technical Specifications, and the UFHSR ADMINISTRATIVE PROCEDURE D1.1 PROCEDURES PROGRAM

-Administrative Procedure was revised to support the Defueled Technical

. Specifications, issued 12/24/98. This revision incorporated the new organization for the Big Rock Point Restoration project.

SAFETY EVALUATION

SUMMARY

The proposed change did not involve a change in the Defueled Technical Specifications incorporated in the license nor was it an unreviewed safety question. The change met the requirements of CPC-2A.

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NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT-ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment 11 - Changes to Procedures, Programs, Defueled Technical Specifications, and the UFHSR ADMINISTRATIVE PROCEDURE D1.4 SAFETY REVIEW COMMITTEE The procedure revision addresses the change from Plant Review Committee (PRC) to Safety Review Committee (SRC) associated with the Defueled Technical Specification and CPC-2A change. It also incorporated the new requirements for performing 10 CFR 50.82 assessments.

SAFETY EVALUATION

SUMMARY

This procedure change did not result in an unreviewed safety question. It made the UFHSR consistent with the Defueled Technical Specifications, amendment 120, approved December 24,1998.This revision did not involve a change to the Defueled Technical Specifications incorporated in the license.

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ANNUAL REPORT OF_ FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment ll - Changes to Procedures, Programs, Defueled Technical Specifications, and the UFHSR ADMINISTRATIVE PROCEDURE D1.7 MASTER TRAINING PROGRAM Administrative Procedure was revised to reflect the new Defueled Technical Specifications approved by the NRC. The UFHSR revision deleted references to Decommissioning Workers I,11, IV, and V.-The wording was revised to reference Decommissioning Workers performing mechanical and electrical maintenance and referenced the master training program. The Operator training programs for Certified Fuel Handlers were approved by the NRC

[ reference Letters from the Nuclear Regulatory Commission to KPPowers dated 4/16/98, CONSUMER'S REQUEST FOR EXEMPTION FROM CERTAIN REQUIREMENTS OF 10 CFR 50.54, CONDITIONS OF LICENSE (TAC No.

MA1009) and APPROVAL OF BIG ROCK POINT (BRP) CERTIFIED FUEL

, HANDLER (CFH) TRAINING PROGRAM (TAC No. M99690.1 The' revision meets ANSI 18.1,1971 requirements.

SAFETY EVALUATION

SUMMARY

The proposed' change did not involve a change to the Defueled Technical

-Specifications. The Operator training Programs for Certified Fuei Handlers

. have'been approved by the NRC and meets' ANSI 18.1,1971 requirements.

The. revision did not involve a change to the Defueled Technical Specifications incorporated into the license. .

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l Attachment 11 - Changes to Procedures, Programs, Defueled 4 Technical Specifications, and the UFHSR l

ADMINISTRATIVE PROCEDURE D1.7.6 i

-ENGINEERING SUPPORT PERSONNEL TRAINING This procedure was deleted and a minor editorial revision was made to the ,

I UFHSR (deleted " comprehensive" from the description of the training program.)

SAFETY EVALUATION

SUMMARY

This procedure change did not involve a change in the Defueled Technical

, Specifications incorporated in the license no.r was is it an unreviewed safety question.

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NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT ANNyAL RE. PORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment 11 - Changes to Procedures, Programs, Defueled Technical Specifications, and the UFHSR ADMINISTRATIVE PROCEDURE D2.1.7 ON-CALL TECHNICAL ADVISOR The revision to the UFHSR was a result of the deletion of the On-Call Technical Advisor from the Defueled Technical Specifications, Amendment 120, approved 12/24/98.

SAFETY EVALUATION

SUMMARY

This revision did not involve a change.in the Defueled Technical Specifications incorporated in the license (it supported the revised Defueled Technical Specification.) This revision was not an unreviewed safety question.

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. NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment 11 - Changes to Procedures, Programs, Defueled Technical Specifications, and the UFHSR ADMINISTRATIVE PROCEDURE D2.3.3 FIRE PROTECTION ALARM AND RESPONSE This procedure revision decreases the size of the fire brigade from 5 to 3 members (excluding 1 member of the minimum shift crew). This revision was incorporated for consistency with the Defueled Technical Specifications, I amendment 120, approved 12/24/98. i i

SAFETY EVALUAT:ON

SUMMARY

l This procedure change did not involve a change in the Defueled Technical i Specifications incorporated in the license nor was it an unreviewed safety question, i

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NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT

- ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment ll - Changes to Procedures, Programs, Defueled Technical Specifications, and the UFHSR ADMINISTRATIVE PROCEDURE D3.1.5 INSERVICE INSPECTION PROCEDURE FOR SERVICE WATER, REACTOR COOLING WATER, AND SPENT FUEL POOL COOLING SYSTEMS This change restores a description of the BRP In-Service inspection (ISI) program to the UFHSR.

SAFETY EVALUATION

SUMMARY

Performance of ISI program has no effect on accident probability or 4 consequences (systems within the scope of the ISI program are not relied upon for accident prevention or mitigation.) ISI implementation is intended to i detect problems and thereby permit resolution prior to system malfunction.

Systems falling under the scope of ISI program do not have safety functions.

ISI activities are nondestructive and do not affect system performance. The ISI program is being revised to bring it into alignment with Defueled Technical Specifications. The change did not involve a change in the Defueled

- Technical Specifications incorporated in the license nor was it an unreviewed safety question.

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Attachment II - Changes to Procedures, Programs, Defueled l Technical Specifications, and the UFHSR l

ADMINISTRATIVE PROCEDURE D5.2.1 l WATER CHEMISTRY GUIDELINES l The spent fuel pool (SFP) will be maintained until fuel is removed. This administrative procedure adopts the water quality standards approved for decommissioning and are sufficient to ensure that the fuel does not degrade during storage in the SFP.

SAFETY EVALUATION

SUMMARY

This procedure change did not result in an unreviewed safety question. It is ,

consistent with the Defueled Technical Specifications, amendment 120, approved December 24,1998. The procedure change did not result in a change in the Defueled Technical Specifications incorporated in the license.

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NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT ANNUAL RE, PORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment 11 - Changes to Procedures, Programs, Defueled Technical Specifications, and the UFHSR 1

ADMINISTRATRATIVE PROCEDURE D4.1 sk BUSINESS AND REGut.../ORY SERVICES DEPARTMENT ORGANIZATION AND RESPONSIBILITIES Entire procedure was deleted due to reorganization, effective 9/14/98, which dissolved the Business and Regulatory Services Department. The change is consistent with revisions to Administrative Procedure D1.0, Plant Decommissioning Organization and Responsibilities.

SAFETY EVALUATION

SUMMARY

l This revision was an administrative change, which did not affect accident '

l probability, equipment malfunction, accidents or consequences. This l

l procedure change did not involve a change in the Defueled Technical Specifications incorporated in the license nor is it an unreviewed safety question.

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NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment 11 -' Changes to Procedures, Programs, Defueled Technical Specifications, and the UFHSR CONTINGENCY PLAN Spent Fuel Pool Cleanout Project Contingency Plan, Control Rod Blade (CRB)

Handle Breakage in the Spent Fuel Pool During CRB Punch Operations The Contingency Plan provides for methods to stabilize the blade should the handle unexpectedly break. The Contingency Plan also provides for safe movement of a control blade within the spent fuel pool, including the use of a hydraulic gripper. The UFHSR revision was made to include the hydraulic gripper and description under the description of miscellaneous reactor tools.

SAFETY EVALUATION

SUMMARY

This procedure did not involve a change in the Defueled Technical Specifications incorporated in the license. This procedure was not an.  !

unreviewed safety question. Miscellaneous reactor tool section in the UFHSR was revised.

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ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment il - Changes to Procedures, Programs, Defueled Technical Specifications, and the UFHSR l

DOP-3 .

l DECOMMISSIONING OPERATIONS PROCEDURE - SPENT FUEL POOL I OPERATIONS i This procedure revision resulted from the need of a process for removing non- '

fuel items from the spent fuel pool. Removal of non-fuel items increases circulation flow paths in the spent fuel pool. This has a positive affect on the thermal characteristics of the spent fuel pool. The procedure incorporated the use of a new hook which is attached to the spent fuel pool or reactor bridge hoist. The UFHSR was updated to describe the new components and a sentence was added about the removal of channels, control blades and associated racks for decommissioning.

SAFETY EVALUATION

SUMMARY

I This procedure change did not involve a change n the Defueled Technical 8

q Specifications incorporated in the license nor was it an unreviewed safety question, l l

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ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment ll - Changes to Procedures, Programs, Defueled Technical Specifications, and the UFHSR 1

DOP DECOMMISSIONING OPERATIONS PROCEDURE - FUEL POOL SYSTEM, ENGINEERING ANALYSIS: EA-DOP-04-01, Spent Fuel Pool Heatup Spread Sheet Results, June 3,1999 The revision to DOP-4 was the result of an engineering analysis performed to calculate SFP heatup for Facility Change FC-699, Alternate Spent Fuel Pool Cooling (skid). The Calculation of spent fuel pool heatup rate also resulted in a revision to the Operating Procedure for the Fuel Pool System.

SAFETY- EVALUATION

SUMMARY

I This procedure change did not involve ~a change'in the Defueled Technical

- Specifications incorporated in the license nor was it an unreviewed safety question.

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e NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment li- Changes to Procedures, Programs, Defueled i

Technical Specifications, and the UFHSR

_ - . . _ _ _ _ . . _ _ _ _ _ _ _ _ . . _ . _ . . _ . _ _ . _ . . _ . - _ . . _ . _ _ . _ _ _ j

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1 Editorial Revisions Revise Reference from Emergency Diesel Generator (EDG) to Mai.. Diesel Generator (MDG) j l

The revisions to the UFHSR were editorial. They consisted of revising the i name of the emergency diesel generator (EDG) to the main diesel generator (MDG) and correction of typograpMcal errors.

SAFETY EVALUATION

SUMMARY

This editorial change did not involve a change in the Defueled Technical Specifications incorporated in the license nor was it an unreviewed safety -

question.

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=-.--.x. ..- - - - - ---

ENGINEERING ANALYSIS FOR QUALITY REVIEW FORM 0435-98-01 DOSE RATE CALCULATION FOR CONTINUED OCCUPANCY FOLLOWING A f POSTULATED SPENT FUEL POOL ACCIDENT New text was'added to UFHSR section 15.10.2.2, Decommissioning Spent Fuel Pool Storage Events, as a result of an engineering analysis of dose

. calculation for continued occupancy following a postulated spent fuel pool accident. The calculated dose rate is less than the 15 mrem /hr dose rate established by NUREG-0737 for areas continuously occupied after an accident. General Design Criteria 19 of Appendix A to 10 CFR 50 requires 1 that for control rooms designs, adequate radiation protection must be

. provided to limit doses to workers to 5 rem whole body for the duration of the accident. The calculated dose rate of less than 2.5 rem is below the l general design critena. 1

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SUMMARY

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! Dose calculations added to the UFHSR do not result in an unreviewed safety l l- question. Personnel dose estimates are not included in the Defueled I

l. Technical Specifications basis. The revision did not involve a change to the
j. Defueled Technical Specifications incorporated into the license.  ;

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BIG ROCK POINT PLANT j ANNUAL RE,P. ORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS q Attachment ll- Changes to Procedures, Programs, Defueled Technical Specifications, and the UFHSR l

- . . - . - - - - - - . . - - - - . . - _ - - . - - _ . . . - - - - 1 Letter from the NRC to BRP,3/29/99 Exemption form Certain Physical Protection Requirements (10 CFR Part 73)-

Big Rock Point Nuclear Plant (TAC No. MA4240)

The US NRC granted an exemption from certain requirements of 10 CFR Part 73 to allow the implementation of a safeguards contingency plan reflecting the permanent shutdown and defueled condition of the Big Rock Point Nuclear Plant. This was in response to an exemption request dated 11/12/98.

SAFETY EVALOATION

SUMMARY

Section 13.6 of the UFHSR was supplemented to include a discussion of an l exemption related to the decommissioned status of the facility. The  !

exemption did not involve a change in the Defueled Technical Specifications incorporated in the license nor was it an unreviewed safety question.

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-BIG ROCK POINT PLANT ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS l

Attachment ll- Changes to Frocedures, Programs, Defueled i Technical Specifications, and the UFHSR i

Letter from the NRC to BRP,9/30/98 Exemption from Certain Requirements of 10 CFR 50.54(q) Regarding Offsite Emergency Planning Activities at Big Rock Point Nuclear Plant and Approval of Defueled Emergency Plan (TAC Nos. M99688 and M99689)

The US NRC granted an exemption from certain requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50 to allow Big Rock Point to discontinue offsite emergency planning activities and to reduce the scope of the onsite emergency planning as a result of its permanently defueled status.

' This exemption was in response to BRP exemption requests dated 9/19/97, 10/29/97,' 11/20/97, 3/2/98, 4/29/98, 7/30/98, and 8/28/98.

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SAFETY EVALUATION

SUMMARY

4 i .

i Section 13.3 of the UFHSR was supplemented to include a discussion of an )

exemption related to the decommissioned status of the facility. The exemption did not involve a change in the Defueled Technical Specifications l incorporated in the license nor was it an unreviewed safety question.

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9/28/99 j

r-NUCLEAR REGULATORY COMMISSION l- BIG ROCK POINT PLANT ANNU'AL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment ll- Changes to Procedures, Programs, Defueled Technical Specifications, and the UFHSR VOLUME 2, DEFUELED TECHNICAL SPECIFICATIONS Amendment 120,12/24/98 This revision to the UFHSR is a result of the approval of amendment 120 of Big Rock Point Defueled Technical Specifications. It included reference to the

' Defueled Off-Site Dose Calculation Manual, editorial revisions (Site Defueled ,

Emergency Plan was revised to Defueled Emergency Plan, Technical i Specifications and Permanently Defueled Technical Specifications revised to Defueled Technical Specifications), revision of definition of containment closure, deletion to reference for fuel with a decay time of over one year, and

]

revision of spent fuel pool water chemistry values. 1 l

SAFETY. EVALUATION

SUMMARY

l The UFHSR was revised to reflect the Defueled Technical Specifications (DTS) requirements that were approved by the NRC 12/24/98. The approved l ' DTS do not affect UFHSR eccident analysis. No unreviewed safety question resulted due to the revision.

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NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment II - Changes to Procedures, Programs, Defueled Technical Specifications, and the UFHSR 1

VOLUME 2, DEFUELED TECHNICAL SPECIFICATIONS Amendment 120,12/24/98 The purpose of this revision was editorial, to incorporate the definitions of Important to the Safe Storage of Spent Fuel (ISSSF) and important to the Monitoring and Control of Radiological Hazards (IMCRH) into the UFHSR.

l SAFETY EVALUATION

SUMMARY

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j No unreviewed safety question resulted due to this editorial revision.

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BIG ROCK POINT PLANT l ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS l Attachment 11 - Changes to Procedures, Programs, Defueled j Technical Specifications, and the UFHSR '

I VOLUME 2, DEFUELED TECHNICAL SPECIFICATIONS Big Rock Point Proposed Defueled Technical Specifications Responses to Selected NRC RAI dated 4/16/98 This revision to the UFHSR clarified containment closure definition and outlined features which constitute containment closure by clarifying engineering alternatives.

SAFETY EVALUATION

SUMMARY

j This revision aligns the UFHSR with the responses to the NRC in regards to controls for CONTAINMENT CLOSURE and DIRECT PATHS. It brings the UFHSR into agreement with the Defueled Technical Specifications which were approved and put in place 12/24/98. The revision did not constitute an unreviewed safety question.

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, NUC. LEAR REGULATORY COMMISSION BIG ROCK POINT PLANT {

' ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS l i

Attachment 11 - Changes to Procedures, Programs, Defueled Technical Specifications, and the UFHSR l

\

VOLUME 9 SITE EMERGENCY PLAN APPENDIX C UFHSR Table 6.1 and Figure 1 were revised. Evacuation times and table were revised to reflect a change from sectors to geographically boundaried areas.

The map (Figure 1) shows new area verses sectors. Evacuation time was also revised to meet estimated hours provided by the State of Michigan and reflect current Charlevoix/ Emmet County populations.

SAFETY EVALUATION

SUMMARY

The procedure revision had no affect on the Defueled Technical l Specifications incorporated in the license and did not result in an unreviewed i

. safety question.

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= NUCLEAR REGULATORY COMMISSION BIG ROCK POINT PLANT ANNUAL REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS Attachment il- Changes to Procedures, Programs, Defueled Technical Specifications, and the UFHSR VOLUME 17 QUALITY LIST (Q-LIST)

' Components which were re-classified in the Quality List as available for decommissioning affected the UFHSR. The affected components were in the air ejector system and the stack gas systems. Reclassification was needed to enable decommissioning of the condensate pump room. The ventilation flow path for the radwaste area was altered by the removal of a block wall (DWP-lTBA04A-03 and -04). No structural or fire barriers were affected in the DWP l process.

SAFETY EVALUATION

SUMMARY

This procedure change (and subsequent decommissioning work process) did not result in an unresolved safety question. No Defueled Technical ~

Specifications apply to the revision. The revision did not change the Defueled Technical Specifications incorporated into the license.

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