PNP 2023-015, License Termination Plan, Revision 4
| ML23136A882 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 05/16/2023 |
| From: | Fleming J Holtec Decommissioning International, Holtec |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| References | |
| HDI PNP 2023-015 | |
| Download: ML23136A882 (1) | |
Text
Krishna P. Singh Technology Campu s, 1 Holtec Blvd., Camden, NJ 08104 HOLTEC Telephone (856) 797-0900 DECOMMISSION I NG Fax (856) 797-0909 INTERNATIONAL
HDI PNP 2023-015 10 CFR 50.71(e)
May 16, 2023
n U.S. Nuclear Regulatory Commissio ATTN: Document Contro l Desk Washington, DC 20555-0001
Big Rock Point Docket No. 50-155 and 72-043 Facility Operating License No. DPR-6
Subject:
Big Rock Point License Termination Plan, Revision 4
In accordance with 10 CFR 50.71(e), Maintenance of records, making of reports, Holtec Decommissioning International, LLC (HDI) on behalf of Holtec Palisades, LLC (Holtec Palisades) hereby submits an update, Revision 4, to the Big Rock Point (BRP)
License Termination Plan (LTP). Revision 4 is a general update that reflects the current final phase status of the BRP decommissioning project.
The LTP revisions were reviewed in accordance with 10 CFR 50.59, Changes, tests and experiments, and have no effect on the lic ense conditions of the BRP (DPR-6) license through amendment number 129. No parameters specified in the LTP were altered that would require prior NRC approval.
of this letter contains a summary of the changes for Revision 4 to the BRP LTP.
contains LTP replacement pages for Chapters 1,3,5,7, and 8. Chapters 2, 4, and 6 were not revised in revision 4. A single page is provided in Enclosure 2 for Chapters 2, 4, and 6, which should be placed at the beginning of these chapters to indicate that the chapters were not changed due to Revision 4 to the LTP.
This letter contains no new and no revised regulatory commitments.
Should you have any questions or require additional information, please contact Jim Miksa, Regulatory Assurance Engineer at (269) 764-2945.
I declare under penalty of perjury that the foregoing is true on Executed orrect.and c May 16, 2023.
HDI PNP 2023-015 Page 2 of 2
Respectfully, Jean A. Fleming Digitally signed by Jean A. Fleming Date: 2023.05.16 11:31:02 -04'00'
Jean A. Fle ming Vice Presid ent, of Licen sing, Regula tory Affairs & PSA Holtec Inter national
Enclosures:
- 1. Big Rock Point License Termination Plan Revision 4 Summary
Attachment:
Big Rock Point License Termination Plan Revision Matrix, Revision 4
- 2. Big Rock Point License Termination Plan Revision 4 Repla cement Pages
cc: NRC Region Ill Regional Administrator NRC Decommissioning Inspector - Big Rock Point NRC NMSS Project Manager - Big Rock Point Michigan Department of Environmental Quality HDI PNP 2023-015 Page 1 of 4
Enclosure 1 to
Big Rock Point
License Termination Plan Revision 4 Summary
HDI PNP 2023-015 Page 2 of 4
Big Rock Point License Ton Plan Revision 4 Summary erminati
- 1. History mination Plan Revision License Ter
Big Rock Point (BRP) license termination plan (L TP) Revision 3 was submitted to the NRC on July 17, 2013. It was a general update to the September 25, 2005, Revision 2 LTP to reflect the completion of phase 1, "BRP restoration project," which included NRC approval for unrestricted use of both impacted and nonimpacted land, leaving only the Independent Spent Fuel Storage Installation (lSFSI) parcel lo cated on a non-impacted part of the site.
Since issuance of LTP Revision 3 the only notable change was the transfer of the BRP operating license from Entergy Nuclear Operations, Inc. to H oltec Decommissioning International, LLC (HDI) as approved by an NRC Order on 12/13/2021, Reference 1, and conforming amendment 129 issued on June 28, 2022, Reference 2. Listed below, for reference, is a chronology of notable events significant to the decommissioning activities at the BRP site:
- August 29, 1997 - Operation permanently ceased
- September 20, 1997 - Fuel permanently removed from the BRP reactor vessel and site name changed from "Big Rock Point N uclear Plant" to "Big Rock Point Restoration Project."
- May 2, 2003 - All Spent Nuclear Fuel, Special Nuclear Material, and greater than Class C waste is stored on an ISFSI.
- March 24, 2005 - NRC approves License Amendment Request 126 that incorporates the LTP into BRP site license.
- January 8, 2007 - Release of the power reactor and non-ISFSI portions of the site from the BRP License per NRC L etter, "Big Rock Point -
Release of Land from Part 50 License for Unrestricted Use."
- April 6, 2007 - License transfer of the BRP ISFSI to Entergy Palisades LLC, project name changed from "Big Rock Point Restoration Project" to "Big Rock ISFSI."
- December 13, 2021 - License transfer of the BRP ISFSI to Holtec Palisa des, LLC approved by NRC commission order.
- June 28, 2022 - Conforming license amendment 129 issued by NRC to reflect transfer of the BRP license to Holtec Palisades, LLC as owner and Holtec Decommissioning International as operating authority.
HDI PNP 2023-015 Page 3 of 4
- 2. able Changes vision 4 NotListing of Re
BRP LTP Revision 3 is a general update to incorporate changes due to transfer of the operating license from Entergy Palisades, LLC, to Holtec Palisades, LLC (Holtec Palisades) as owner and Holtec Decommissioning Internatio nal, LLC (HDI) as operating authorit y.
Coincident with license transfer implementation BRP adopte d HDIs Decommissioning Quality Assurance Program (DQAP). Finally, th e LTP was revised to reflect that HDI submitted an annual Decommissioning Funding Status report for BRP in March of 2023. A summary of the more notable changes are provided below:
Chapter 1 - General Information
Section 1.3 In this section, and throughout the document, the following title changes were incorporated to reflect the curr ent facility owner and operating authority. The facility owner, Entergy Palisades, LLC, was changed to Holtec Palisades, LLC (Holtec Palisades) and th e operating authority was changed from Entergy Nuclear Operations, Inc. (ENOI) to Holtec Decommissioning International, LLC (HDI), (References 1 and 2).
Section 1.4 In this section, and throughout the document, the following title changes were incorporated to reflect the curr ent quality assurance program title.
The quality assurance title was changed from. Quality Assurance Program Manual or QAPM, was changed to Decommissioning Quality Assurance Program or DQAP.
Section 1.5 In this section, the Entergy Nuclear Operations, Inc. contracted low-level waste disposal facilities were replaced by the Holtec Decommissioning International, LLC facility.
Chapter 2 - Site Characterization
This section was not revised.
Chapter 3 - Identification of Remaining Site Dismantlement Activities
Other than the listed Chapter 1 changes that are applicable throughout the document, no additional notable changes were made to this section.
Chapter 4 - Site Remediation Plan
This section was not revised.
Chapter 5 - Final Status Survey Plan
Other than the listed Chapter 1 changes that are applicable throughout the document, no additional notable changes were made to this section.
Chapter 6 - Compliance with the Radiologica l Criteria for License Termination
This section was not revised.
HDI PNP 2023-015 Page 4 of 4
Decommissioning Costs Chapter 7 - Update of Site Specific
t the document, le throughouare applicabChapter 1 changes that o the listed In addition t March 31, 2023, HDI report on the status of to reflect thewas revised this section 2 g for BRP, ified the 201decommissioning fundinReference 3. Also, ident le 7-2 each year preclude revision of Tabl to historicastimates as decommissioning cost e based on the NRC requistatus reports. red annual decommissioning cost
onmental Report Chapter 8 - Supplement to the Envir
hroughout the document, no tapplicable ges that are apter 1 chanOther than the listed Ch ges were made to this section.otable chanadditional n
- 3. Conclusion
Revision 4 of the LTP reflects the transfer of the BRP operating license owner from Entergy Palisades, LLC to Holtec Palisades, LLC (Holtec Palisades) and authorized operator from Entergy Nuclear Operations, Inc. to Holtec Decommissioning Internationa l, LLC (HDI).
Further, the revisions were reviewed in accordance with 10 CFR 50.59 and have no ef fect on the license conditions of the BRP license through amendment numbe r 129. No parameters specified in the LTP were altered that would require prior NRC approval.
- 4. References
- 1. U.S. Nuclear Regulatory Commissio n, Letter to Entergy Nuclear Operations, Inc.,
Palisades Nuclear Plant and Big Rock Point Plant - Order Approving Transfer of Licenses and Draft Conforming Administrative License Amendments (EPI D No.
L-2020-LLM-0003), NRC ADAMS Accession Package Number ML21292A155, dated December 13, 2021
- 2. U.S. Nuclear Regulatory Commissio n, Letter to Holtec Decommissioning Internationa l, LLC, Palisades Nuclear Plant and Big Rock Point Plant - Issuance of A mendments Nos.
129 and 273 RE: Order Approving Transfer of Licenses and Conforming Administrative License Amendments (EPIDs L-2022-LLM-000 2 and L-2020-LLM-0003), NRC ADAMS Accession Number ML221173A173, dated June 28, 2022
- 3. Holtec Decommissioning Internationa l, LLC, Letter to the U.S. Nuclear Regulatory Commission, Report on Status of Decommissioning Funding f or Reactors and Independent Spent Fuel Storage Installations - Holtec Decommissioning International, LLC (HDI), NRC ADAMS Accession Number ML23090A140, dated March 31, 2023
- 5. Attachments
- 1. Big Rock Point License Termination Plan Revision Matrix, Revision 4
Enclosure 2
Big Rock Point License Termination Plan Revision 4 Replacement Pages
Chapter 1 - General Information
7 Pages Follow BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 1, GENERAL INFORMATION 04/15/2023
1.3 SITE DESCRIPT ION AND HISTORICAL BACKGROUND
Big Rock Point ISFSI1 is located in Charlevoix County, Michigan, approximately four miles northeast of Charlevoix, Michigan, and ap proximately eleven miles west of Petoskey, Michigan, on the northern shore of Michigans Low er Peninsula. The BRP site is owned by Holtec Palisades, LLC (Holtec Palisades). Figure 1-1 shows the original BRP site. Figure 1-2 shows the current Big Rock Point ISFSI site. The BRP Nuclear Plant was a boiling water reactor rated at 75mW electric, designed by General Electric Company.
For the BRP Nuclear Plant, Operating License D ocket No. 50-155 (License Number DPR-6) and General Independent Spent Fuel Storage Installation (ISFSI) License Docket Number 72-043, events of significance are:
Provisional Operating License issued August 30, 1962 Initial Criticality achieved September 27, 1962 Initial Power Operation achieved December 8, 1962 Commercial Operation began March 29, 1963 Full-Term Operating License issued May 1, 1964 Power level increased from 157 MWt to 240 MWt May 1964 Operation permanently ceased Aug ust 29, 1997 Fuel permanently removed from the reactor vessel September 20, 1997 All Spent Nuclear Fuel (SNF), Special Nuclear Material (SNM), and Gre ater Than Class C (GTCC) waste stored on an Independent Spent Fuel Storage Installation (ISFSI) on May 2, 2003 Termination of the NRC License for the power reactor and non-ISFSI related portions of the site on January 8, 2007 License transfer of the BRP ISFSI to Entergy Palisades LLC on April 6, 2007 License transfer of the BRP ISFSI to Holtec Palisades, LLC as Owner and Holtec Decommissioning International, LLC (HDI) as Operating Authority on June 28, 2022
The Post Shutdown Decommissioning Activitie s Report (PSDAR) was s ubmitted in accordance with 10 CFR 50.82(a)(4) on Septemb er 19, 1997, along with other documents associated with decommissioning (Offsite Dose Calculation Manual, Defueled Technical Specifications, Defueled Emergency Plan, and Emergency Pla n Exemption) [Reference 1-4]. On September 23, 1997, Consumers Energy notified the NRC of the permanent cessation of operations and the permanent removal of all fuel assemblies from the reactor pressure vessel and their placement into the spent fuel pool [Reference 1-5]. Following the cessation of operations, Consumers Energy began decommissioning BRP.
1 On April 6, 2007 the site name wa s changed from Big Rock Point Restoration Project to Big Rock Point Independent Spent Fuel Storage Installation (ISFSI) upon transfer of the license.
Page 1-2 BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 1, GENERAL INFORMATION 04/15/2023
1.4 DECOMMISSIONING APPROACH
1.4.1 Overview
This chapter provides an overview of Holtec Decommissioning Internation al, LLC (HDI) approach to the final phase of decommissioning the BRP site. References to the chapter in the LTP, where details are provid ed concerning the particular step or stage of the decommissioning process, are given in parentheses. Upon the decision to permanently cease power operations at BRP in 1997, Consumers Energy began characterization activities (Chapter 2, Site Characterization). This characterization effort, performed to the guidelines of NUREG-1575, included a historical site assessment (HSA); hydrogeological investigation; and measurements, samples and analyses to further define the present radiological conditions of the site. This effort also addressed the status of the site relative to non-radioactive contamination from hazardous and other state-regulated materials.
The final phase of decommissioning activities at BRP shall be conducted in accordance with the BRP Updated Final Hazards Summary Report (UFHSR),
Defueled Technical Specifications, HDIs Decommissioning Quality Assurance Program, the existing 10 CFR Part 50 license, and the requirements of 10 CFR 50.82(a)(6) and (a)(7). If a decommissioning activity requires pr ior NRC approval under 10 CFR 50.59(c)(2) or a change to the BRP Defueled Technical Specifications or license, a submittal shall be made to the NRC for review and approval before implementation of the activity in question. Decommissioning activities are conducted in accordance with the BRP Defueled Technica l Specifications, PSDAR, Radiation Protection Program, Off-Site Dose Calculation Manual (ODCM), and EN-IS-101, Industrial Safety and Healt h Program. These programs are established and available for inspection by the NRC.
Activities that will be conducted during the final phase of decommissioning will not pose any greater radiological or safety risk than those conducted during the initial phase of decommissioning. Radiological assessments of the Radiation Protection Program are performed annually pursuant to 10 CFR 20.1101(c). Radiological data compiled during the initial phase of decommissioning validated that Big Rocks PSDAR conclusion that projected dose for decommissioning fell well within NUREG-0586, Final Generic Environmental Impact Statement o n Decommissioning of Nuclear Facilities estimates [References 1-2 and 1-14] was accurate.
The initial site characterization, together with HSA and hydrogeological investigations, provided the basis for selection of the dose modeling scenarios and critical groups used to address possible future uses of the site. The computer code used for dose modeling calculated the Derived Concentration Guideline Levels (DCGLs) as approved in the LTP. Derived Concentration Guideline Levels correspond to a dose to the average member of the selected critical group that is as low as reasonably achievable (ALARA) and does not exce ed the total effective dose equivalent (TEDE) 25 mrem/year criteria for unre stricted use (Chapter 4, Site Remediation Plan, and Chapter 6, Compliance with the Radiological Criteria for License Termination).
Page 1-3 BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 1, GENERAL INFORMATION 04/15/2023
The letter from the U.S. Nuclear Regulatory Commission to Consumers Energy, Big Rock Point Plant, dated March 24, 2005, Issuan ce of Amendment 126 to Approve the License Termination Plan demonstrated that the NRC acknowledged the land area upon which the ISFSI was constructed was radiologically non-impacted. To validate the radiological status of the ISFSI land areas prior to construction of the ISFSI, radiological surveys were performed which confirmed the non-impacted radiological status of the land area. The ISFSI was then constructed and made operational. The spent fuel and Greater Than Class C waste was then transferred from the reactor containment building to the ISFSI in accord ance with the requirements of the Radiation Protection Program maintaining the radiologically non-impacted status of the ISFSI. Due to the design of the spent fuel storage system with no designed effluent pathways, it is not anticipated that the ISFSI will become radiologically impacted during ISFSI operations, and therefore, no remediation will be required to terminate the lice nse.
HDI intends to demolish the ISFSI pad structure and release the demolition debris to a State of Michigan licensed landfill.
1.4.2 Phased Release Approach to License T ermination
At the time of the LTP submittal, Consumers Energy chose a phased release approach for release of land from the operating license a s follows:
First Phase - Release of the majority of the site land, including non-impacted and areas impacted by power generation activities (approximately 2.281 km2 or 563.6 acres). The majority of the site land was released from the license on January 8, 2007 and,
Final Phase - Release the portion of the site associated with ISFSI operations (approximately 0.1 km2 or 20 acres).
The basis of approach for the final phase of decommissioning is that the ISFSI will be operated such that it would meet the criteria of NUREG-1 757, Consolidated Decommissioning Guidance Section 7.4 Group 2: Unrestricted Release Using Screening Criteria; No Decommissioning Plan Required.
NUREG-1757 provides the following:
Group 2 facilities may have residual radiological contamination present in building surfaces and soils. However, licensees are able to demonstrate that th eir facilities meet the provisions of 10 CFR 20.1402 (Radiological Criteria for Unrestricted Use) by applying the screening approach dose analysis described in Chapter 6.
Additionally, licensees in Group 2 typically posse ss historical records of material receipt, use, and disposal, such that quantifying past radiological material possession and use may be developed with a high degree of confidence.
Furthermore, these licensees have radiological survey records that characterize the residual radiological contamination levels present within the facilities and at their sites. That is, they are able to demonstrate residual radiological contamination leve ls
Page 1-4 BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 1, GENERAL INFORMATION 04/15/2023
1.5.2 Site Characterization
Chapter 2 of the LTP discusses the original site characterization as it applied to potential radiological and non-radiological material contamination onsite at the time of the LTP submittal.
Based upon the original site characterization and routine radiological surveys of the ISFSI from the beginning of ISFSI operations, the land upon which the ISFSI is located continues to be classified as non-impacted (Figure 1 -2). If a condition arises that changes the radiological status of the ISFSI, the land area will be appropriately characterized in accordance with the methodology previously outlined in this LTP.
Confirmation of the non-impacted status of the ISFSI area will be conducted when the spent fuel and Greater Than Class C waste is removed from the site.
1.5.3 Identification of Remaining Site Dismantlement Activities
Chapter 3 of the LTP discusses identification of remaining site dismantlement activities. HDIs primary goals are to maintain the safe storage of spent fuel until transfer to the DOE, to decommission the BRP ISFSI safely, to monitor and control radiological hazards should they exist to maintain the radiolog ical non-impacted status of the ISFSI land areas. The ISFSI will be surveyed for release and sent for disposal or recycled locally. Should there be contaminated material that cannot be decontaminated, it will be sent to an offsite radioactive waste processor or directly to a licensed low-level radioactive waste disposal site. Currently, HDI has access to a low-level waste disposal facility in Andrews, Texas.
1.5.3.1 Future Decommissioning Activitie s and Tasks
The remaining decommi ssioning activities include transfer of the spent fuel and Greater Than Class C waste to the DOE, the survey and release of the concrete storage overpacks, ISFSI storage pad and cask transfer equipment; and the assessment of ISFSI operations history and radiological surveys to confirm the non-impacted status of the ISFSI land areas.
HDI continues to operate the ISFSI under a general licen se pursuant to10 CFR Parts 50 and 72. HDI will amend this LTP if necessary to complete decommissioning of the ISFSI once the fuel is transferred to a permanent Department of Energy storage facility.
1.5.4 Site Remediation Plans
Chapter 4 of the LTP describes th e various methods to be used during the BRP ISFSI decommissioning to reduce th e levels of radioactivity to those which meet the NRC radiological release criteria in 10 CFR 20.1402, Radiological Criteria for Unrestricted Use. BRP intends to release the sit e for unrestricted use upon license termination. No post-remediation activit ies are anticipated. As the ISFSI will be operated to maintain a radiological non-impacted status, remediation of I SFSI land areas will not be required.
Page 1-6 BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 1, GENERAL INFORMATION 04/15/2023
The cost estimate focuses on the remaining work, detailed by each activity associated with the decommissioning, includin g the costs of labor, materials, equipment, energy, and services. The decommissioning estimate includes a comparison of estimated costs with t he present funds set aside for decommissioning and a description of the means to ensure there will be suf ficient funds for completing decommissioning.
Holtec Palisades, LLC owns a 100% undivided interest in the BRP ISFSI and provides financial assurance for decommissioning through th e use of an external sinking fund, funded by rates that are established by cost of service ratemaking regulation. Following 35 years of electric power generation, BRP was voluntarily shut down by Consumers Energy on August 29, 1997, and immediately entered into decommissioning. In accordance with 10 CFR 50.82(a)(8)(iii), a detailed, site-specific cost estimate was prepared for Consumers Energy and docketed with the NRC in its submittal of the BRP PSDAR.
1.5.8 Supplement to the Environmental Report
Chapter 8, Supplement to the Envir onmental Report, satisfies the requirements stated in:
A supplement to the Environmental Report pursuant to 10 CFR 51.53 shall be submitted describing any new information or significant environmental change associated with the licensees proposed termination activities.
Post operating license stage each applicant for a license amendment approving a license termination plan or decommissioning plan under paragraph 50.82 of this chapter either for unrestricted use or based on continuing use restrictions applicable to the site shall submit with its application the n umber of copies specified in paragraph 51.55, of a separate document, entitled Supplement to Applicants Environmental Report - Post Operating Licen se Stage, which will update Applicants Environmental Report - Operating License Stage, as appropriate, to reflect any new information or sign ificant environmental change associated with the proposed activities with respect to the planned storage of spent fuel.
Decommissioning activities will be accomplished with no significant adverse environmental impacts as described in Chapter 8. Decommis sioning and license termination activities remain bounded by decommissioning activities described in:
The PSDAR, NUREG-0586, Final Generic Environmental Imp act Statement on Decommissioning of Nuclear Facilities (FGEIS), and NUREG-1496, Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for License Termination on NRC Licensed Facilities [Reference 1-15].
Page 1-8 BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 1, GENERAL INFORMATION 04/15/2023 _________ I
1.7 LICENSE TERMINATION PLAN INFORMATION CONTACT
For information or comments regarding the BRP LTP, please contact the following party:
ISFSI Manager Big Rock Point ISFSI 10269 U.S. 31 North Charlevoix, MI 49720 231-237-2302
Page 1-10 BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 1, GENERAL INFORMATION 04/15/2023
I I
l I i I i I
- l----7---,------
1 I I Wegt114 ( 0<" I I ~East West Bn elme I ---=,-,- I I I NON-IMPA C TED I AREA 4---ENTERGY I B OUNDAR Y I I
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Holtec Palisades, LLC Boundary Consumers Energy Boundary
Non-Impacted Area
Figure 1-2. Big Rock Point ISFSI Non-Impacted Land Areas
Page 1-12 HDI PNP 2023-015
Enclosure 2 (Continued)
Big Rock Point License Termination Plan Revision 4 Replacement Pages
Chapter 2 - Site Characterization
No changes were made to this chapter as a result of Revision 4 to the LTP.
Replace Chapter 2 Revision 3 Cover Page
One Page Follows BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 2, SITE CHARACT ERIZATION 04/15/2023
This chapter was comp iled in April 2003 and revised in July 2004 prior to LT P approval by the NRC. It remains a historical summary of plant operational and early decommissioning characterization data.
No changes were made to this chapter as a result of Revision 4 to the License Termination Plan (LTP).
Page 2-i HDI PNP 2023-015
Enclosure 2 (continued)
Big Rock Point License Termination Plan Revision 4 Replacement Pages
Chapter 3 - Identification of Remaining Site Dismantlement Activities
Four Pages Follow BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 3, IDENTIFICATION OF REMAINING 04/15/2023 DECOMMISSIONING ACTIVITIES
3.0 IDENTIFICATION OF REMAINING SITE DISMANTLEMENT ACTIVITIES
3.1 INTRODUCTION
In accordance with 10 CFR 50.82 (a)(9)(ii)(B), the License Termination Plan (LTP) must identify the major dismantlement and decontamination activit ies. This chapter was written following the guidance of NUREG-1700, Standard Review Plan for Evaluating Nuclear Power Reactor License Ter mination Plans, and Regulatory Guide 1.179, Standard Format and Content of License Termination Plans for Nuclear Power Reactors, and will discuss those remaining dismantlement activities as of April 6, 2007 [References 3-15 and 3-17]. Information is presented to demonstrate that these activities will be performed in accordance with10 CFR Part 50 and will not be inimical to the common defense and security or to the health and safety of the public pursuant to 10 CFR 50.82(a)(10). Information that demonstrates that th ese activities will not have a significant effect on the quality of the environment is provided in LTP Chapter 8, Supplement to the Envir onmental Report.
Holtec Decommissioning Internationa l, LLC (HDI)s primary goals are to maintain the continued safe storage of spent fuel at the Big Rock Point (B RP) Independent Spent Fuel Storage Installation (ISFSI) and to decommission the ISFSI safely after transfer of the spent fuel and Greater Than Class C (GTCC) waste. As of May 2, 2003, all spent nuclear fuel, special nuclear material, and Greater Than Class C waste material was relocated to the ISFSI from the spent fuel pool. HDI will decontaminate and dismantle the ISFSI facility in accordance with the DECON alternative, as described in NUREG-0586, Final Generic Environmental Impact Statement (FGEIS)
[Reference 3-12].
Decommissioning activities at BRP shall be cond ucted as discussed in this LTP and in accordance with the Defueled Technical Specifications, HDIs Decommissioning Quality Assurance Program (DQAP), the BRP 10 CFR Part 50 license, and the requirements of 10 CFR 50.82(a)(6) and (a)(7). If an activity requires prior NRC approval under 10 CFR 50.59(c)(2) or a change to the BRP Defueled Technical Specifications or license, a submittal shall be made to the NRC for review and approval before implementation of the activity in question.
Activities conducted during decommi ssioning will not pose any greater radiological or safety risk than those conducted during former plant operations. Deco mmissioning activity radiological risk is bounded by previously analyzed radiological risk for former operating activities that occurred during major maintenance and outage evolutions.
The activities described in Section 3.4 include future decommissioning activities of the ISFSI site. Table 3-1 contains a list of future decommissioning activities to be performed by HDI or its contractors.
Page 3-1 BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 3, IDENTIFICATION OF REMAINING 04/15/2023 DECOMMISSIONING ACTIVITIES
3.2 DECOMMISSIONING OVERVIEW
Decommissioning activities for the fo rmer power reactor and associated land areas were initiated following the decision to permanently cease BRP power operations on August 29, 1997. At that time, BRP performed evaluations of major plant structures, systems, and components (SSCs) to determine what functio n, if any, these SSCs would be expected to perform during decommissioning. Each major plant SSC was evaluated to determine if the SSC, in its entiret y or any portion thereof, was important for the safe storage of the spent fuel (ISSSF), was important for the monitoring and control of radiological haz ards (IMCRH), or was needed to perform a function during the decommissioning and decontamination (D&D) of the plant.
Big Rock Point administrative procedures specify the standard methods of accomplishing plant activities an d processes. They are the documents used to implement the requirements of the DQAP. This DQAP ensures that BRP complies with the requirements of 10 CFR 50, Appendix B for quality a ssurance. Examples of administrative processes controlled by procedures include: ALARA (as low as reasonably achievable) reviews, radiation protection (including airborne and contamination control), effluent and environmental monitoring, radioactive waste processing (including transportation and release requirements), safety programs, control of design basis (modification and work package procedures), an d final status surveys.
A work control process is applied for decommissioning to document work performed and apply plant processes and contr ols to the activities. If a decommissioning activity requires NRC review pursuant to 10 CFR 50.59, an amendment t o the BRP Defueled Technical Specifications (DTS) or license will be submitted. As of June 12,
2013, NRC review for BRP license amendments associated with decommissioning activities included the following:
Amendment 120, December 24, 1998. Approval of the Defueled Techn ical Specifications (DTS).
Amendment 121, January 13, 2000. Deletion of the definition of site boundary and removal of site map.
Amendment 122, September 28, 2001. DTS reflected contr ol of heavy loads, spent fuel handling considerations, and installation of a single-failure pro of crane.
Amendment 123, July 18, 2002. License was revised to include the approved ISFSI Security Plan reference.
Amendment 124, September 11, 2002. Addition of Spent Fuel Pool applicability statements.
Amendment 125, March 19, 2004. Issuance of Amendment Related to the Transfer of all Spent Fuel Storage from the Spent Fuel Pool into Dry Cask Storage.
Amendment 126, March 24, 2005. Approval of th e License Termination Plan.
Amendment 127, April 11, 2007. Approval of Transfer of Facility Operating License No. DPR-06.
Amendment 129, December 13, 2021. Approval of Transfe r of Facility Operating License No. DPR-06 to Holtec Palisades, LLC and Operating Authority t o Holtec Decommissioning International, LLC.
Page 3-2 BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 3, IDENTIFICATION OF REMAINING 04/15/2023 DECOMMISSIONING ACTIVITIES
3.3 COMPLETED DECOMMISSIONING ACTIVITIES AND TASKS
3.3.1 Summary
Consumers Energy completed the first phase of decommissioning for the BRP power reactor and associated land areas with notification that the NRC approved release of this land from the BRP license on January 8, 2007 (Reference 3-20).
3.3.2 Description of Completed Activities
Consumers Energy completed deco mmissioning activities in accordance with the License Termination Plan as approved by Amendment 126 dated March 24, 2005, Approval of the License Termination Plan.
3.4 REMAINING DECOMMISSIONING ACTIVITIES
The focus of this section is on the demolition of the BRP ISFSI structures. Table 3-1 is a list of future decommissioning activities planned at the BRP ISFSI. The activities listed are intended to provide an overview of the remaining decommissioning activities and an e stimated time schedule for those activities.
There is no intent to revise this LTP when schedule changes occur. Schedules provided in this section are for general guidance and illustrative purposes only.
Current schedules will be finalized upon notification by the Department of Energy of intent to receive the spent fuel and Greater Than Class C waste. The a ssumptions and philosophy of HDI for the remaining BRP demolition activitie s are as follows:
General demolition activities are consistent with clean-to-dirty approach.
Demolition activities in open areas involving structures with known or suspected contamination require radiological control and isolation to prevent cross-or re-contamination by air or water pathways.
Excavated locations may remain open to support ongoing work.
Groundwater and surface water control measures are requir ed for all excavations where the potential exists for migration of radioactive or hazardous materials.
Final Status Survey (FSS) will not be required f or license termination.
Table 3-1. Remaining Decommissioning Activities Activity Projected Date Transport Fuel to DOE Repository 1st Quarter Verify Radiological Non-Impacted Status of Facility 1st Quarter NRC/ORISE Verification of Radiological Non-Impacted Status 1st Quarter Demolish ISFSI Structures 2nd Quarter Dispose of Demolition Debris 2nd Quarter Terminate License 3rd Quarter
Page 3-3 BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 3, IDENTIFICATION OF REMAINING 04/15/2023 DECOMMISSIONING ACTIVITIES
3.4.1 Decontamination and Demolition of Structures
gical loin its radiohe BRP ISFit will maintaHDI intends to operate tI such that S re not expected. ies aerefore, decontamination activitnon-impacted status. Th industry the standardtamination be identified, Should minor diffuse con
, ling, spallinging, scabbmwiping, washing, vacuuing decontamination methods includ erred method is based n of the prefand abrasive blasting will be employed. Selectio o protect necessary tls ical controand appropriate radiologtion on the specific situa nment, and to maintain the radiological non-impacted status the workforce and enviro at cannot bestructures thr portions of Structures oof the ISFSI land areas.
s radioactive waste. Approved econtaminated will be disposed of atly dsufficien ivities. These ol decontamination actes and processes contradministrative procedur ntamination controls are airborne cosure that wastewater is collected andcontrols en s are monitored. d all release ancessary,used, as ne
3.4.1.1 osal Demolition Debris Disp
sed landfill.State of Michigan licensed of at a Clean demowill be dispolition debris be generated will be disposed of at inated debris that may mically contaAny radiolog ive radioactive waste.nsed to recey licea facilit
3.5 CURRENT RADIOLOGICAL STATUS AND EXPOSURE ETSTIMAES
Exposure 3.5.1 Occupational
decommissioning was st phase of re for the firpational exposuThe cumulative occu less than the 700 to 1600 person-rem estimate of NUREG-Generic 0586, Final Environmental Impact Statement on Decommissioning of Nuclear Facilities ory for the BRP ISFSI perating histl exposure ooccupationa[Reference 3-12]. The s ed land areand associat former power reactor ase from the license of thesince relea n-rem per year. The estimated total nuclear worker e of 0 persois an averag the remaining decommiis estimated to be less than 1 cexposure fortivities ssioning a person-rem.
Exposure 3.5.2 Public
Effluent l Program, Radiologica BRPs Radiation Safety ofContinued application Program, anion d Radiological Environmental Monitoring pecificatTechnical S Program assures public protection in accordance with 10 CFR Part 20 and there has ental moni10 CFR Partmrovides that 50, Appendix I. Environtoring data p ublic expected p There is no due to ISFSI operations.surelic expobeen no pub s.ivitieing acto the remaining decommissionexposure expected due t
3.5.3 Estimate of Quantity of Radioactive Material to be Shipped for Disposal or Processing
gical loin its radiohe BRP ISFit will maintaHDI intends to operate tI such that S of radioactive material erefore, the estimate of the quantity non-impacted status. Th eet. ic fd is 0 cubto be shippe
Page 3-4 HDI PNP 2023-015
Enclosure 2 (Continued)
Big Rock Point License Termination Plan Revision 4 Replacement Pages
Chapter 4 - Site Remediation Plan
No changes were made to this chapter as a result of Revision 4 to the LTP.
Replace Chapter 4 Revision 3 Cover Page
One Page Follows BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 4, SITE REMEDIAT ION PLAN 04/15/2023
This chapter provides the site remediation plan, actions, i mpact of the radiation protection program, and an as low as reas onably achievable (ALARA) evalu ation.
No changes were made to this chapter as a result of Revision 4 to the License Termination Plan (LTP).
TABLE OF CONTENTS
4.0 SITE REMEDIATION PLAN....................................................................................... 1
4.1 INTRODUCTION
......................................................................................................... 1
4.2 REMEDIATION ACTIONS.......................................................................................... 1 4.2.1 Structures, Systems and Components................................................................... 1 4.2.2 Soil and Water........................................................................................................... 2
4.3 REMEDIATION ACTIVITY IMPACT ON T HE RADIATION PROTECTION PROGRAM.................................................................................................................. 2 4.3.1 Commitment to Radiation Protection Procedures................................................. 2
4.4 ALARA EVALUATION............................................................................................... 2
4.5 REFERENCES
............................................................................................................ 4
Page 4-i HDI PNP 2023-015
Enclosure 2 (continued)
Big Rock Point License Termination Plan Revision 4 Replacement Pages
Survey PlanChapter 5 - Final Status
One Page Follows BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 5, FINAL STATUS SURVEY PLAN 04/15/2023
5.0 FINAL STATUS SURVEY PLAN
5.1 INTRODUCTION
The Big Rock Point (BRP) Final Status Survey ( FSS) Plan was prepared for the initial phase of decommissioning using the applicable regulatory and industry guidance. The plan was used to develop the site procedures and work instruction used to perform the FSS of the BRP site.
5.1.1 Purpose
The initial phase of the decommissioning FSS Plan describ ed the final survey process used to demonstrate that the BRP site complied with radiologica l criteria for unrestricted use specified in 10 CFR 20.1402, i.e., annual dose limit of 25 mrem plus ALARA for all dose pathways. Nuclear Regulatory Commis sion (NRC) regulations applicable to radiation surveys are found in 10 CFR 50.82(a)(9)(ii)(D) and 10 CFR 20.1501(a) and (b).
5.1.2 Scope
Big Rock Point has been approved to release the site land using a phased approach.
The first phase included the majority of the site land which was released from the NRC License. The second and final phase of site release includes the Independent Spent Fuel Storage Installation (ISF SI) following spent fuel removal and facility dismantlement. Once both these phases are complete the BRP site license under 10 CFR Part 50 will be terminated. It is possible that release of non-impacted portions of the site could occur prior to completing demolition activit ies, should Holtec Decommissioning International, LLC management decide accordingly.
The FuelSolutionsTM W74 Canister Storage Final Safety Analysis Report, Chapter 7, Confinement, provides that confinement of all radioactive materials in the FuelSolutionsTM Storage System is provided by a FuelSolutionsTM canister. The design of the FuelSolutionsTM W74 canister confinement boundary assures that there are no credible design basis events that would result in a radiological release to the environment.
Due to the design of the spent fuel storage system with no designed effluent pathways it is not anticipated that the ISFSI will become radiologically imp acted during ISFSI operations, thus it is anticipated that remediation and FSS will not be necessary to release the site from the NRC License.
Therefore, the basis approach for the final phase of decommissioning is that the ISFSI will be operated such that it would meet the criteria of NUREG-1757, Consolidated Decommissioning Guidance, Section 7.4, Group 2: Unrestricted Release Using Screening Criteria; No Decommis sioning Plan Required.
5.2 REFERENCES
5-1 Letter from U.S. Nuclear Regulatory Commissio n to Consumers Energy, Big Rock Point - Release of Land from Part 50 License for Unrestricted Use, January 8, 2007
Page 5-1 HDI PNP 2023-015
Enclosure 2 (Continued)
Big Rock Point License Termination Plan Revision 4 Replacement Pages
Chapter 6 - Compliance with the Radiologica l Criteria for License Termination
No changes were made to this chapter as a result of Revision 4 to the LTP.
Replace Chapter 6 Revision 3 Cover Page
One Page Follows BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 6, COMPLIANCE WITH THE RADIOLOGICAL 04/15/2023 CRITERIA FOR LICENSE TERMINATION
This chapter provides the basis for the dose models used to develop site-specific DCGLs as approved by the NRC on March 24, 2005.
No changes were made to this chapter as a result of Revision 4 to the License Termination plan (LTP).
Page 6-i HDI PNP 2023-015
Enclosure 2 (continued)
Big Rock Point License Termination Plan Revision 4 Replacement Pages
Chapter 7 - Update of Site Specific Decommissioning Costs
6L[Pages Follow BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 7, UPDATE OF SITE-SPECIFIC 04/15/2023 DECOMMISSIONING COSTS 7.0 UPDATE OF SITE-SPECIFIC DECOMMISSIONING COSTS
7.1 INTRODUCTION
In accordance with 10 CFR 50.82(a)(9)(ii)(F), Regulatory Guide 1.179, Standard Format and Content of License Termination Plan s for Nuclear Power Plants, and 10 CFR 72.30, Financial Assurance and Recordkeeping for Decommissioning, the site-specific cost estimate and funding plans are provided in this chapter.
The License Termination Plan (LTP) must:
Provide an estimate of the remaining decommissioning co sts and compare the estimated costs with the present funds set aside for decommissioning. The financial assurance instrument required per 10 CFR 72.30(e)(2) must be funded to the amount of the cost estimate. If there is a deficit in present funding, the LTP must indicate the means for ensuring adequate funds to complete the decommissioning.
The decommissioning cost estimate should include an evaluation of the proposed practices and procedures for the decontamination of the site and facilities, and for disposal of residual radioactive materials after all spent fuel, high-level radioactive waste, and reactor-related Greater Than Class C (GTCC) waste have been removed in order to provide reasonable assurance that the decontamination and decommissioning of the ISFSI at the end of its useful life will provide adequate protection to the health and safety of the public.
Holtec Palisades, LLC (Holtec Palisades) owns a 100% undivided interest in the Big Rock Point (BRP) Independent Spent Fuel Storage Installat ion (ISFSI) and provides financial assurance for decommissioning through the use of a Parent Company Guarantee.
Following 35 years of electric power generation, BRP was voluntarily shut down by Consumers Energy on August 29, 19 97, and immediately entered into decommissioning. In accordance with 10 CFR 50.82(a)(8)(iii), a detailed site-specific cost estimate was prepared by TLG Services for Consumers Energy and docketed with the NRC in its submittal of the BRP Post Shutdown Decommissioning Activities Report (PSDAR) [References 7-2 and 7-1]. Pursuant to State of Michigan requirements to prepare and file decommissioning cost estimate updates with the Michigan Public Service Commission (MPSC) at three-year intervals, an estimate update was prepared by TLG Services in 2000 a nd filed in March 2001 as a follow-up to a site-specific decommissioning cost estimate filed with the MPSC in March 1998 [References 7-2 and 7-3]. Since the submittal of the LTP, Consumers Energy, in compliance with State of Michigan requirements, contracted TLG Services to prepare an estimate update in 200 3. This update was filed with the MPSC in March 2004, and served as the cost basis for Revision 2 of the LTP [Reference 7-4].
Consumers Energy completed the fir st phase of decommissioning and subsequently received NRC approval to release from the license the power reactor and associated land areas. The NRC license for the BRP ISFSI and associated land areas was subsequently transferred to Entergy Nuclear Palisades, LLC in 2007 and then to Holtec Palisades, LLC in 2022. In December 2021, after submission of the license
Page 7-1 BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 7, UPDATE OF SITE-SPECIFIC 04/15/2023 DECOMMISSIONING COSTS
application but before transfer of the BRP license to HDI, En tergy filed an updated cost estimate of approximately $2.8 million (202 1 dollars) in the triennial update to its 10 CFR 72.30(c) report, Reference 7-7. HDI will file the next BRP triennial update in 2024. For purposes of the 2022 annual 10 CFR 50.82(a)(8)(v) financia l assurance status report, HDI has escalated the prior ENOI estimate into 2022 dollars, Reference 7-8. This revision to the L TP contains this financial assurance status report for the final phase of decommissioning, reference letter HDI PNP 2023-010 from Holtec Decommissioning International, LLC, to the U.S. Nuclear Regulatory Commission - Decommissioning Funding Status Report per 10 CFR 50.82(a)(8)(v),
March 31, 2023.
7.2 DECOMMISSIONING COST ESTIMATE
7.2.1 Cost Estimate Description and Methodology
The methodology used to develop the cost estimate is as described in 10 CFR 72.30(c). The estimate considers (1) Spills of radioactive material producing additional residual radioactivity in on site subsurface material; (2) Facility modifications; (3) Changes in authorized posse ssion limits; and (4) Actual remediation costs that exceed the previous cost estimate.
Table 7-1, Significant Quantities and Physical Dimensions provides the e stimates of the total radioactive waste and clean debris based upon the following key assumptions:
x Decommissioning estimate is based on the current configuration of the ISFSI.
x Due to the design of the storage system, no radioactive surface contamination is expected.
x Two of the seven spent fuel overpacks contain low levels of neutron-induced residual radioactivity that would necessitate remediation.
x A small portion of the ISFSI pad (directly undern eath the two overpacks) will be activated to a level that would require remediation.
x Prior to ISFSI pad construction, the existing soils and imported fill soils were verified to be radiologically non-impacted.
x Low-level radioactive waste disposal costs are based upon Entergys negotiated rates.
x Decommissioning will be performed by an independent contractor.
x Contingency has been added at an overall rate of 25% consistent with the contingency evaluation criteria referenced in NUREG-1757.
Page 7-2 BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 7, UPDATE OF SITE-SPECIFIC 04/15/2023 DECOMMISSIONING COSTS 7.2.2 Summary of the Site-Specific Decommissioning Cost Estimate
Table 7-2, ISFSI Decommissioning Costs (Hist orical) and Waste Volumes provides the site-specific cost estimate with the 25% contingency.
Note: The attached ISFSI Decommis sioning Costs listed in table 7-2 are based on 2012 dollars and are therefore considered historical. ISFSI Decommissioning Funding Plans, which includes costs, are updated every three years in accordance with 10 CFR 72.30, Financial assurance and recordkeeping for decommissioning, paragraph (c), 10 CFR 72.30(c). The status of decommissioning funds are updated annually in accordance with 50.82(a)(8)(v).
Page 7-4
BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 7, UPDATE OF SITE-SPECIFIC 07/15/2023 DECOMMISSIONING COSTS 7.2.3 Spent Fuel Management
Completion of the BRP final phase of decommissioning is dependent upon the DOEs ability to remove spent fuel fr om the site. Until that time, HDI will continue to operate the ISFSI, which was constructed for interim storage of the spent fuel, in accordance with license requirements.
Similar to non-radiological site restor ation costs, HDI recognizes that the costs to operate an ISFSI and other spent fuel related costs fall outside the NRC definition of decommissioning. Therefore, those costs are not included within the estimates provided herein.
7.3 DECOMMISSIONING FUNDING
PLAN
HDI, in compliance with 10 CFR 72.30(e)(2) [Reference 7-5], provides financial assurance for the decommissioning of the BRP ISFSI through the use o f a Parent Company Guarantee.
As demonstrated in their recent submittal of the Financial Test for Decommissioning Funding Parent Guarantee, HDI [Ref erence 7-6] provides decommissioning assurance in the amount of $5 million for the NRC radiological decommissioning costs.
Page 7-6 BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 7, UPDATE OF SITE-SPECIFIC 07/15/2023 DECOMMISSIONING COSTS
7.4 REFERENCES
7-1 Big Rock Point Post Shutdown Decommissioning Activitie s Report (PSDAR),
Revision 2, March 26, 1998
7-2 TLG Services, Inc., Decommissioning Cost Study for the Big Rock Point N uclear Plant, March 26, 1998
7-3 TLG Services, Inc., Decommissioning Cost Study for the Big Rock Point N uclear Plant, March 22, 2001
7-4 TLG Services, Inc., Decommissioning Cost Update for the Big Rock Point Nuclear Plant, March 22, 2004
7-5 Letter (ENOC-12-00039) from Entergy Nuclear Operations, Inc. to the U.S. Nuclear Regulatory Commission - ISFSI Decommissioning Funding Plans (10 CFR 72.30),
December 13, 2012
7-6 Letter (ENOC-13-00009) from Entergy Nuclear Operations, Inc. to the U.S. Nuclear Regulatory Commission - Financial Test for Decommissioning Funding Parent Guarantee for the year ending December 31, 2012, March 29, 2013
7-7 Letter from Entergy Nuclear Operations, Inc. (E ntergy) to U.S. Nuclear Regulatory Commission, ISFSI Decommissioning Funding Plans (10 CFR 72.30),
December 15, 2021 (ADAMS Accession, No. ML21349A37)
7-8 Letter (HDI PNP 2023-010) from Holtec Decommissioning International, LLC to the U.S. Nuclear Regulatory Commission, Report on Status of Decommissioning Funding for Reactors and Independent Fuel Storage Installations - Holtec Decommissioning International, LLC (HDI), March 31, 2023 (ADAMS Accession No. ML23090A140)
Page 7-7 HDI PNP 2023-015
Enclosure 2 (continued)
Big Rock Point License Termination Plan Revision 4 Replacement Pages
onmental Report Chapter 8 - Supplement to the Envir
Follow Five Pages BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 04/15/2023 _________ I
termination activities planned at BRP. This additional information forms the basis for the conclusions provided in Section 8.7.
8.2 SITE DESCRIPT ION AFTER UNREST RICTED RELEASE
This section presents a summary of the final condition of the site at the conclusion of the final phase of decommissioning and license termination activities.
At the time of license termination, the site will meet the radiological criteria for unrestricted release as defined in 10 CFR 20.1402, in addition to applicable State of Michigan criteria for release of the site.
The only site buildings now in existence were constructed to support Dry Fuel Storage. These buildings have associated utilities (electric, phone, sanitary) which were installed to support the ISFSI. The BRP ISFSI will be d emolished and Holtec Decommissioning International, LLC (HDI) will determine the disposit ion of the support buildings and utilities at the time of final phase dismantlement. HDI will determine the use of the ISFSI and associated land areas after license termination.
Consumers Energy retains ownership of the for mer power reactor and associated land areas and will determine the future use of that site.
8.3 PSDAR UPDATE FOR REMAINING DISMANTLEMENT AND DECONTAMINATION ACTIVITIES
The License Termination Plan, Chapter 3 identifie s and details the remaining final phase dismantlement activities that are scheduled to be completed in support of license termination and unrestricted release. These activities have been compared to the descriptions provided in the PSDAR with no changes identified.
8.3.1 Post-Shutdown Deco mmissioning Activities Report De scription
The BRP PSDAR was submitted to the NRC under the provisions of 10 CFR 50.82(a)(7). The PSDAR described pla nned decommissioning activities, a schedule for their accomplishment, estimate of expected decommissioning costs, and provided the basis for concluding the environmental impacts associated with site-specific decommissioning activities will be in compliance with 10 CFR 50.82(a)(6)(ii) [Reference 8-12]. Consumers Energ y Co. dismantled the BRP power reactor and associated land areas in accordance with the DECON option found acceptable to the NRC in its FGEIS.
Page 8-4 BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 04/15/2023
8.3.2 Impacts of Decommissioning Activities
The final phase decommissioning requirements are incorporated into the LTP, as approved by the NRC, and into site procedures and programs, as necessary
[Reference 8-39]. Subsequent sections in this chapter of th e LTP provide additional information regarding environmental effects of the final phase of decommissioning.
8.4 BIG ROCK POINT SITE ENVIRONMENT AL DESCRIPTION
The information contained in this section is a summary based on the BRP ER developed for decommissioning [Reference 8-7]. The purpose of this section is to provide an overview of the site and regional environmental information. In general, the information contained in this section is derived directly from the ER, where new or different information is provided; t he appropriate reference is also included.
8.4.1 Geography and Demography
8.4.1.1 Site Location Description
The BRP ISFSI site is located near the northeast shore of Lake Michigan in Charlevoix County in the northern part of Michigan's Lower Peninsula. The site is approximately 60 miles northeast of Traverse City, Michigan, and 225 miles north-northwest of Detroit. The clo sest population centers are the cities of Charlevoix, 3.5 miles southwest, and Petoskey, 11 miles east of the ISFSI site. The site is owned by Holtec Palisades, LLC (Holtec Palisades) and occupies approximately 107 acres (0.433 km2). Figure 8-1 depicts the property boundaries and Owner-Controlled Area at the time the LTP was submitted and Figure 8-2 shows the current site boundaries and the I SFSI area. Figure 8-3 shows an aerial view of the BRP site and surrounding land prior to the first phase of decommissioning and Figure 8-4 shows an aerial view of th e BRP ISFSI site and surrounding land. The Owner-Controlled Area is identical to plant property boundaries.
Page 8-5 BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 04/15/2023
Reasonable control measures will be utilized to minimize the quantities of fugitive dust. Excavation of soils and concret e demolition may include the use of wet suppression to minimize the generation of fugitive dust.
The controlled dismantlement and packaging of the ISFSI pad and concrete storage casks will preclude fugitive dust from becoming an ambient air quality con cern during the final phase of decommissioning. The closest national ambient air quality Category 1 area is the Seney National Wildlife Refuge located approximately 70 miles northwest of the BRP site. The location of the Seney National Wildlife Preserve is generally considered upwind of the prevailing wind direction. There are no Category 1 areas within 100 miles downwind of the BRP site.
8.5.2.5 Aquatic Ecology
No adverse impacts to the aquatic flora or fauna are anticipa ted from the final phase of decommissioning activities as the activities will not adjoin Lake Michigan and the beachfront.
8.5.2.6 Terrestrial Ecology
No additional land area is expected to be utilized to complete decommissioning.
Therefore, no additional impacts to site flora and fauna are anticipated.
8.5.2.7 Threatened and Endangered Specie s
No adverse impact to any identified species is ant icipated since they are not present in locations expected to be impacted by decommission ing activities. Prior to initiation of any decommissioning activities that could potentially affect endangered shoreline species, additional surveys will be conducted using up-to-date listings to identify the existence of threatened or endangered species near areas that may be impacted.
8.5.2.8 Occupational Safety
HDI is committed to the safe decommissioning o f BRP. The Safety Program provides the basis for controlling safety during decommissioning activities. The primary objective of the Safety Program is to protect workers and visitors from industrial hazards that have the potential of developing during decommissioning activities and to achieve an injury and incident-free workplace. The Safety Program establishes and maintains a safe workplace for workers, contractors, and visitors through procedures and guidelines to be used to reduce industrial hazards and risks.
HDIs Industrial Safety and Health Program defines specific p rograms and requirements to ensure worker protection [Reference 8-3].
Page 8-23 BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 04/15/2023 CD
I.AKE: MICHIGAN
( PrOltU
/
/ /
/,,........ ____..J
--- Ho/lee Palisades, LLC Property Boundary
--Consumers Energy Property Boundary
Figure 8-1. Big Rock Point Site Boundary Map
Page 8-29 BRP LICENSE TERMINATION PLAN Revision 4 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 04/15/2023
Figure 8-4. Aerial Image of Big Rock Point ISFSI s of 2007) A (
Page 8-32