ML13009A177

IR 07200043-12-001 & 05000155-12-001, 12/18/2012, Big Rock Point Plant and Independent Spent Fuel Storage Installation

ML13009A177
Person / Time
Site:	Big Rock Point  File:Consumers Energy icon.png
Issue date:	01/08/2013
From:	Christine Lipa NRC/RGN-III/DNMS/DB
To:	Vitale A Entergy Nuclear Operations
Tapp J
References
IR-12-001
Download: ML13009A177 (13)

See also: IR 07200043/2012001

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 Warrenville Road, Ste 210

Lisle, IL 60532-4362

January 8, 2013

Mr. Anthony Vitale

Vice-President, Operations

Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant

27780 Blue Star Memorial Highway

Covert, MI 49043-9530

SUBJECT: BIG ROCK POINT INDEPENDENT SPENT FUEL STORAGE INSTALLATION

INSPECTION REPORTS 07200043/12001(DNMS) AND 05000155/12001(DNMS)

Dear Mr. Vitale:

On December 18, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed a routine

inspection at the Big Rock Point Independent Spent Fuel Storage Installation (ISFSI). The

purpose of the inspection was to evaluate whether the facility was operating in accordance with

NRC approved License Conditions and Technical Specifications, and to evaluate the biennial

exercise of the Emergency Plan. At the conclusion of the on-site inspection on October 11, 2012,

the inspector discussed the interim inspection results with members of your staff. At the

conclusion of the in-office review on December 18, 2012, a final telephone exit meeting was

conducted to discuss the final results with members of your staff.

The inspection consisted of review and evaluation of radiation protection, surveillance and

maintenance, environmental protection, quality assurance, and the observation and evaluation

of the ISFSI Emergency Preparedness exercise. Areas examined during the inspection

consisted of observations of activities in progress, interviews with personnel, and a select

review of procedures and representative records.

Based on the results of this inspection, the NRC has determined that one Severity Level IV

violation of NRC requirements occurred. This violation is being treated as a Non-Cited

Violation (NCV), consistent with Section 2.3.2 of the Enforcement Policy. The NCV is described

in the subject inspection report. If you contest the violation or significance of the NCV, you

should provide a response within 30 days of the date of this inspection report, with the basis for

your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk,

Washington DC 20555-0001, with copies to: (1) the Regional Administrator, Region III; and

(2) the Director, Office of Enforcement, United States Nuclear Regulatory Commission,

Washington, DC 20555-0001.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRCs

Rules of Practice, a copy of this letter and enclosure will be available electronically for public

inspection in the NRC Public Document Room or from the NRC's Agencywide Documents

Access and Management System (ADAMS), accessible from the NRC website at

http://www.nrc.gov/reading-rm/adams.html.

A. Vitale -2-

We will gladly discuss any questions you may have regarding this inspection. If you have

questions, please contact Mr. Jeremy Tapp of my staff at 630-829-9862.

Sincerely,

/RA/

Christine A. Lipa, Chief

Materials Control, ISFSI, and

Decommissioning Branch

Division of Nuclear Materials Safety

Docket Nos. 072-00043; 050-00155

License No. DPR-6

Enclosures:

Inspection Report Nos. 07200043/12001(DNMS);

05000155/12001(DNMS)

cc w/encls: Distribution via ListServ for Palisades

K. Yale, Michigan State Liaison Officer

D. Malone, Palisades and Big Rock EP

R. Vanwagner, Manager, Dry Fuel Storage

O. Gustafson, Manager, Licensing

L. Potter, ISFSI Supervisor, Big Rock

Point Restoration Site

F. Rives, Director, Nuclear Fuels

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket Nos.: 072-00043; 050-00155

License No.: DPR-6

Report Nos.: 07200043/12001(DNMS)

05000155/12001(DNMS)

Licensee: Entergy Nuclear Operations, Inc.

Facility: Big Rock Point Independent Spent

Fuel Storage Installation

Location: 10269 U.S. 31 North

Charlevoix, MI 49720

Dates: Onsite: October 10 - 11, 2012

In-Office Review through December 18, 2012

Inspector: Jeremy Tapp, Health Physicist

Approved by: Christine A. Lipa, Chief

Materials Control, ISFSI, and

Decommissioning Branch

Division of Nuclear Materials Safety

Enclosure

EXECUTIVE SUMMARY

Entergy Nuclear Operations, Inc.

Big Rock Point Independent Spent Fuel Storage Installation

NRC Inspection Reports 07200043/12001(DNMS) and 05000155/12001(DNMS)

The inspection consisted of observations and an evaluation of the licensees programs

including, surveillance and maintenance, environmental monitoring, quality assurance, and

observation and evaluation of the Independent Spent Fuel Storage Installation (ISFSI)

emergency preparedness (EP) exercise.

Emergency Preparedness

• The licensee adequately demonstrated the effectiveness of its ISFSI Emergency Plan

and its ability to implement the plan in response to an emergency (Section 1.1).

Surveillance and Maintenance

• The licensee implemented its surveillance and maintenance program in accordance with

applicable regulations, the License, and Technical Specifications (TS). The U.S.

Nuclear Regulatory Commission (NRC) is continuing to review the licensees evaluation

of the conditions noted from the interior of the storage cask from the five-year cask

inspection (Section 1.2).

Environmental Monitoring

• The licensee established and maintained its environmental monitoring program in

accordance with applicable Title 10 Code of Federal Regulations (CFR) Part 20, 50 and

72 regulations, the License, and TS (Section 1.3).

Quality Assurance

• The licensee performed changes to its EP program in accordance with site procedures

and applicable regulations. The licensee also performed audits of its Radiation

Protection program that were of adequate scope and in accordance with the applicable

regulations. The licensee implemented its corrective action program in accordance with

the applicable regulations and site Quality

Assurance (QA) requirements with one exception. The licensee failed to update the

License Termination Plan (LTP) in accordance with license requirements, which was not

identified by the licensee through their corrective action process. The licensee has

implemented prompt corrective actions to restore compliance and prevent recurrence

(Section 1.4).

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Report Details

1.0 Away from Reactor Independent Spent Fuel Storage Installation (ISFSI)

(IP 60858)

1.1 Emergency Preparedness

a. Inspection Scope

The inspector observed and evaluated the conduct of the ISFSI biennial radiological

emergency preparedness (EP) exercise. The inspector reviewed the Big Rock Point

ISFSI Emergency Plan and implementing procedures, and the applicable documents

which contained the exercise scenario and the sequence of actions needed to mitigate

consequences of the event. The inspector reviewed the proposed exercise scenario to

understand its scope and evaluate its adequacy to ensure the licensee could

demonstrate its emergency response capabilities. The inspector observed the

pre-exercise briefing, the exercise, and the licensees formal post-exercise critique.

b. Observations and Findings

Section 5.8 of the Big Rock Point ISFSI Emergency Plan requires the licensee to

perform a biennial exercise to demonstrate emergency response capabilities and

effectiveness of the licensees Emergency Plan. The scenario for the

October 10, 2012, exercise involved a simulated lightning strike and subsequent fire

within the ISFSI protected area that caused damage to a loaded storage cask and

storage area electrical systems. Local firefighters provided offsite support in real time in

response to the simulated emergency. In addition, local law enforcement participated in

providing simulated support of the site security force, including traffic control at the entry

road.

In response to the event, the licensee implemented appropriate, timely, and necessary

actions to address the simulated event. The licensee correctly classified the event,

made timely notifications, augmented personnel as needed, conducted adequate

radiological monitoring, and ensured the safety of personnel. Licensee personnel

maintained control throughout the scenario, starting with a prompt recognition of the

initiating event and through recovery discussions. Throughout the exercise, the

licensees staff communicated well with all involved parties and demonstrated

knowledge of the Emergency Plan. During the post-exercise critique, the licensee

adequately evaluated its emergency response and management capability.

The inspector identified observations in the areas of radiation protection and

communications. Site personnel did not perform response checks on radiological

instruments before use to assess radiological conditions in the field. Response checks

are a standard industry practice that are performed before use to ensure instruments will

respond appropriately to radiation. This observation has been entered into the

licensees corrective action program. In addition, during the review of logs, the inspector

was not able to determine if the identification and classification of a Notice of Unusual

Event (NOUE) was communicated to the State of Michigan. The licensee had declared

an Alert shortly after the NOUE was declared and due to that short time frame, had

potentially not notified the State of Michigan of the NOUE declaration before notifying

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them of the Alert. The licensee was not able to verify whether or not the notification of

the NOUE had been communicated. This observation has also been entered into the

licensees corrective action program.

No findings of significance were identified.

c. Conclusion

The licensee adequately demonstrated the effectiveness of its ISFSI Emergency Plan

and its ability to implement the plan in response to an emergency.

1.2 Surveillance and Maintenance

a. Inspection Scope

The inspector reviewed the licensees surveillance and maintenance program associated

with dry fuel storage to verify compliance with the applicable regulations, the License,

and Technical Specifications (TS). The inspector walked down the ISFSI pad, observed

daily surveillance activities, interviewed personnel, and reviewed select documents. The

inspector reviewed temperature logs for June, July, and August 2011 and January, May,

July, and August 2012. The inspector also reviewed the licensees results from the

second five-year inspection of the first loaded storage cask.

b. Observations and Findings

The inspector conducted a walk down of the ISFSI pad and observed authorized and

trained licensee staff perform daily surveillances of the casks including temperature

monitoring, verifying the readings were well below Technical Specification limits, and

inlet and outlet vent screen checks to ensure they were free of significant blockage or

damage. The inspector also evaluated the general condition of the pad, the transfer

cask, lift unit, horizontal transfer system and the J-skid. The inspector noted that the

review of temperature log data indicated that the casks operated as designed with no

abnormalities. The inspector found that the licensee performed and documented the

surveillance activities as required by TS and site procedures. In addition, the inspector

performed independent radiation surveys of the casks and general ISFSI area with a

Canberra UltraRadiac dose rate meter, and the results were bounded by the radiological

posting and consistent with the licensees.

In addition, the inspector reviewed the licensees five-year cask inspection

documentation for storage cask number 7 that includes both pictures and video of the

interior of the cask. The licensee performed this inspection as required by T365-35, Dry

Fuel Storage Cask Inspections, Revision 7. The inspector noted a material deposit and

streaking on the canister shell and also mineral deposits on the interior of the storage

cask. The licensee performed an evaluation of the deposits and streaking and

documented it in CAMCA-12-023, Evaluation of Big Rock Point FuelSolutions' W150

Cask 5-Year Inspection Results, dated November 8, 2012. The licensee determined

that the conditions identified above do not adversely affect the ability of the cask system

to perform its intended safety functions and do not require repair. As of the exit date for

this inspection, the adequacy of this evaluation and its conclusion is currently under

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review by the NRC (IFI 07200043/12001-01 and IFI 05000155/12001-01; Adequacy of

Five-year Cask Inspection Evaluation).

No findings of significance were identified.

c. Conclusion

The licensee implemented its surveillance and maintenance program in accordance with

applicable regulations, the License, and TS. The NRC is continuing to review the

licensees evaluation of the conditions noted from the interior of the storage cask from

the five-year cask inspection.

1.3 Environmental Monitoring

a. Inspection Scope

The inspector reviewed the licensees annual Radioactive Effluent Release Report for

2010 and 2011, which was prepared in accordance with the requirements of Title 10 of

the Code of Federal Regulations (CFR) 50, Appendix I and Technical Specifications 6.6.2. The inspector also reviewed gamma dose results for 2010 and 2011 for the ISFSI

protected area fence and controlled area boundary. This review evaluated whether the

licensee was in compliance with the off-site dose requirements prescribed by 10 CFR

72.104.

b. Observations and Findings

Currently, the only radiological environmental monitoring required for the ISFSI is gamma

dose because the licensee no longer has any liquid or gaseous effluent releases. In

addition, the licensee did not perform any activities since 2009 that generated any solid

radioactive waste. The results for both 2010 and 2011 were similar and well under the

limits of 10 CFR 72.104.

No findings of significance were identified.

c. Conclusion

The licensee established and maintained its environmental monitoring program in

accordance with applicable 10 CFR Part 20, 50 and 72 regulations, the License, and

Technical Specifications.

1.4 Quality Assurance

a. Inspection Scope

The inspector reviewed corrective action reports from 2011 and 2012 to determine the

licensees effectiveness in identifying, resolving, and preventing problems. The inspector

reviewed facility procedural changes to its EP program and their associated evaluations

from 2011 to verify compliance with the applicable regulations and site quality assurance

(QA) requirements. The inspector also reviewed and evaluated the 2010 and 2011

Radiation Protection Program Annual Reviews required by 10 CFR 20.1101(c) to

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determine the adequacy of their scope and evaluate the results and any subsequent

actions taken by the licensee.

b. Observations and Findings

A review of condition reports (CRs) written during 2011 and 2012 indicated that the

licensee was effectively identifying and following up on pertinent facility issues. The

inspector determined that issues were being effectively addressed and adequately

closed out to prevent recurrence with one exception as described below.

During the review of CR-PLP-2011-01700, the inspector noted that the licensee determined

an update to their License Termination Plan (LTP) was not performed as required by

10 CFR 50.71(g). The licensee last updated their LTP on September 27, 2005. During the

licensees performance of corrective actions as a result of this determination, the licensee

concluded that 10 CFR 50.71(g) did not apply to the LTP. Subsequently, the inspector

reviewed the requirements to update the LTP. The inspector determined that the licensees

evaluation failed to recognize that a condition of the facility license required a periodic

update.

As a result of this review, the NRC identified a Severity Level IV Non-Cited Violation (NCV)

of Condition 2.C.(4) of License No. DPR-06, Amendment 127 dated April 13, 2007 for

failure to update the LTP every 24 months. Specifically, during the period between 2007

and 2011, the licensee did not submit an updated LTP every 24 months.

Condition 2.C.(4) of License No. DPR-06, Amendment 127 dated April 13, 2007, states,

in part, the licensee shall submit an updated LTP in accordance with 10 CFR 50.71(e).

10 CFR 50.71(e) states, in part, nuclear power reactor facilities shall update the Final

Safety Analysis Report (FSAR) periodically. For facilities that have submitted their

certifications required by 10 CFR 50.82(a)(1), subsequent revisions to the FSAR must

be filed every 24 months.

Contrary to the above, the licensee failed to submit an updated LTP in accordance with

10 CFR 50.71(e) from 2005 to 2011. The inspector used Traditional Enforcement

guidance to determine the significance of the violation. This violation was determined to

be a Severity Level IV violation using the Enforcement Policy, Example 6.1.d.3, in that the

licensee failed to update the LTP as required but the potential erroneous information was

not used to make an unacceptable change to the facility or procedures. The licensee

entered this issue into the corrective action program (CR-PLP-2012-7785) and is currently

completing an update to the LTP. This violation is being treated as an NCV, consistent

with Section 3.1.1 of the NRC Enforcement Manual. (NCV 07200043/12001-01 and

NCV 05000155/12001-01; Failure to Update the LTP Every 24 Months)

One Severity Level IV NCV was identified.

c. Conclusion

The licensee performed changes to its EP program in accordance with site procedures

and applicable regulations. The licensee also performed audits of its Radiation

Protection program that were of adequate scope and in accordance with the applicable

regulations. The licensee implemented its corrective action program in accordance with

6

the applicable regulations and site QA requirements with one exception. The licensee

failed to update the LTP in accordance with license requirements, which was not

identified by the licensee through their corrective action process. The licensee has

implemented prompt corrective actions to restore compliance and prevent recurrence.

2.0 Exit Meeting

The inspector presented the interim inspection results to members of the licensee staff

at the completion of the onsite inspection activities on October 11, 2012. After the

conclusion of the in-office review, the inspector presented the final inspection results to

members of the licensee staff during an exit teleconference on December 18, 2012. The

licensee acknowledged the results presented and did not identify any of the documents

reviewed as proprietary in nature.

ATTACHMENT: SUPPLEMENTAL INFORMATION

7

SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PEOPLE CONTACTED

Larry Potter, Big Rock Point ISFSI Supervisor

Bob Vanwagner, Manager, Dry Fuel Storage

Steve LaJoice, Securitas Security Manager

INSPECTION PROCEDURE USED

60858 Away-From-Reactor ISFSI Inspection Guidance

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened Type Summary

IFI 07200046/12001-01 IFI Adequacy of Five-year Cask Inspection Evaluation

IFI 05000155/12001-01

NCV 07200046/12001-01 NCV Failure to Update the LTP Every 24 Months

NCV 05000155/12001-01

Closed

NCV 07200046/12001-01 NCV Failure to Update the LTP Every 24 Months

NCV 05000155/12001-01

Discussed

None

LIST OF ACRONYMS USED

ADAMS Agencywide Documents Access and Management System

CFR Code of Federal Regulations

CR Condition Report

DNMS Division of Nuclear Materials Safety

EP Emergency Preparedness

IFI Inspection Follow-Up Item

IP Inspection Procedure

ISFSI Independent Spent Fuel Storage Installation

LTP License Termination Plan

NCV Non-Cited Violation

NOUE Notice of Unusual Event

NRC U.S. Nuclear Regulatory Commission

QA Quality Assurance

TS Technical Specifications

Attachment

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection. Inclusion on this list does

not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that

selected sections of portions of the documents were evaluated as part of the overall inspection

effort. Inclusion of a document on this list does not imply NRC acceptance of the document or

any part of it, unless this is stated in the body of the inspection report.

Emergency Preparedness

Big Rock Point ISFSI Emergency Plan, Revision 6

Big Rock Point 2012 Emergency Exercise

Surveillance and Maintenance

Licensee documents reviewed and utilized during the course of this inspection are specifically

identified in the Report Details above.

Environmental Monitoring

PNP-2012-018; 2011 ISFSI Annual Radioactive Effluent Release Report, dated February 22,

2012

PNP-2011-023; 2010 ISFSI Annual Radioactive Effluent Release Report, dated March 1, 2011

Quality Assurance

10CFR50.54(q) Evaluation; Big Rock ISFSI Procedure, Volume 35; BRP ISFSI Emergency

Plan, Revision 5; dated October 31, 2011

10CFR50.54(q) Evaluation; Big Rock ISFSI Procedure, Volume 35A-02; BRP Emergency

Response Organization Responsibilities, Revision 8; dated October 31, 2011

10CFR50.54(q) Evaluation; Big Rock ISFSI Procedure, Volume 35A; IEPIP-10, Emergency

Response Organization Training, Revision 3; dated October 27, 2011

CR-PLP-2010-06273; During Big Rock Emergency Plan Exercise there was confusion between

dose rate and frisker readings; dated November 24, 2010

CR-PLP-2011-00243; ISFSI Horizontal Transfer System hydraulic power unit 2 has a small leak;

dated January 18, 2011

CR-PLP-2011-01700; Big Rock LTP was not performed as required by 10 CFR 50.71(g); dated

April 6, 2011

CR-PLP-2011-02073; LTP Review Discovered No Formal Review of the Big Rock Radiation

Program was performed; dated April 26, 2011

CR-PLP-2011-05610; ISFSI Emergency Plan Implementing procedure revision 50.54q

screening not completed prior to final approval; dated October 25, 2011

2

LIST OF DOCUMENTS REVIEWED (Continued)

CR-PLP-2012-04104; Horizontal Transfer System Bi-monthly test tower #3 would not fully

retract; dated May 24, 2012

CR-PLP-2012-06262; Defects/ Bug holes in the concrete exterior of the Big Rock Cask number

110; dated September 17, 2012

A. Vitale -2-

We will gladly discuss any questions you may have regarding this inspection. If you have

questions, please contact Mr. Jeremy Tapp of my staff at 630-829-9862.

Sincerely,

/RA/

Christine A. Lipa, Chief

Materials Control, ISFSI, and

Decommissioning Branch

Division of Nuclear Materials Safety

Docket Nos. 072-00043; 050-00155

License No. DPR-6

Enclosures:

Inspection Report Nos. 07200043/12001(DNMS);

05000155/12001(DNMS)

cc w/encls: Distribution via ListServ for Palisades

K. Yale, Michigan State Liaison Officer

D. Malone, Palisades and Big Rock EP

R. Vanwagner, Manager, Dry Fuel Storage

O. Gustafson, Manager, Licensing

L. Potter, ISFSI Supervisor, Big Rock

Point Restoration Site

F. Rives, Director, Nuclear Fuels

DISTRIBUTION w/encls: Jared Heck Thomas Taylor

Pamela Longmire Steven Orth Carole Ariano

Cynthia Pederson Patricia Lougheed Linda Linn

Anne Boland John Giessner MCID Branch

ADAMS Accession Number: ML13009A177

DOCUMENT NAME: G:\DNMSIII\Work in progress\IR - BRP IR 12-01 r0.docx

Publicly Available Non-Publicly Available Sensitive Non-Sensitive

To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl N" = No copy

OFFICE RIII DNMS RIII DNMS E RIII RIII

NAME JETapp: jm*JET CALipa*CAL

DATE 01/8/13 01/8/13

OFFICIAL RECORD COPY

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