ML052770168

Revision 2 to License Termination Plan

ML052770168
Person / Time
Site:	Big Rock Point  File:Consumers Energy icon.png
Issue date:	09/27/2005
From:	Haas K Consumers Energy
To:	Document Control Desk, NRC/FSME
References
+kBR1SISP20060112
Download: ML052770168 (193)

Text

Consumers A CMS Energy Company Big Rock Point Restoration Project Kurt M. Haas 10269 US-31 North General Manager Charlevoix, MI 49720 September 27, 2005 10 CFR 50.82(a)(9)

U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 DOCKETS 50-155 AND 72-043 - LICENSE DPR BIG ROCK POINT PLANT -

REVISION 2 OF THE BIG ROCK POINT LICENSE TERMINATION PLAN

References:

1. Big Rock Point to the U.S. NRC, April 1, 2003, Proposed License Amendment -

License Termination Plan

2. U.S. NRC to Big Rock Point, February 13, 2004, Results of Preliminary Review of the Big Rock Point License Termination Plan of April 2003

3. Big Rock Point to the U.S. NRC, March 6, 2004, Schedule for Response to Request for Additional Information Regarding the Big Rock Point License Termination Plan

4. Big Rock Point to the U.S. NRC, July 1, 2004, Response to Request for Additional Information (RAI) on Big Rock Point License Termination Plan

5. U.S. NRC to Big Rock Point, March 24, 2005, License Amendment 126 Incorporating the License Termination Plan Attachment 1 of this letter contains the License Termination Plan (LTP), Revision 2. Revision 2 was performed as a general update to the LTP to reflect the current status of the Big Rock Point Decommissioning Project. The revisions were reviewed in accordance with 10 CFR 50.59 and have no affect on the license conditions of Big Rock Point (DPR-6) License Amendment 126.

No parameters specified in the LTP were altered that would require prior NRC approval. All final status survey program requirements contained in Chapter 5 of the LTP remain unaffected by this revision. A new section (5.4.2.6) was added, which addresses and clarifies surveys of excavated soils. This section is consistent with currently approved NUREG-1 575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) methodology.

Attachment 2 of this letter contains a summary of the changes for Revision 2. Grammatical and typographic corrections are not included in this summary.

cc: Administrator, Region III, USNRC NRC Decommissioning Inspector - Big Rock Point NRC NMSS Project Manager Michigan Department of Environmental Quality Attachments Page 1 of 2

Pages provided in Attachment 1 should be used to replace your current LTP. Chapters 1, 3, 4, 5, 7, and 8 are complete Chapter replacements. Chapters 2 and 6 were not revised in Revision 2 and remain as approved by the U.S. NRC in License Amendment 126 of March of 2005. A single page is provided in Attachment 1 for Chapters 2 and 6, which should be placed at the beginning of these Chapters to indicate that no changes were made as a result of Revision 2 to the LTP.

If you have any additional questions, please contact Ms. Tracy Goble, Radiation Protection and Environmental Services Superintendent, at (231) 547-8389.

/

Kurt M. Haas Site General Manager cc: Administrator, Region Ill, USNRC NRC Decommissioning Inspector - Big Rock Point NRC NMSS Project Manager Michigan Department of Environmental Quality Attachments Page 2 of 2

Attachment 1 Consumers Energy BIG ROCK POINT Docket Numbers 50-155 and 72-043 Big Rock Point License Termination Plan REPLACEMENT PAGES Revision 2, Dated September 27, 2005 187 Pages

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 1, GENERAL INFORMATION 9127/2005 TABLE OF CONTENTS 1.0 GENERAL INFORMATION ................................................... 1I 1.1 PURPOSE .................................................... 1 1.2 SCOPE .................................................... 1 1.3 SITE DESCRIPTION AND HISTORICAL BACKGROUND .......................................... 1 1.4 DECOMMISSIONING APPROACH ................................................... 2 1.4.1 Overview .................................................... 2 1.4.2 Phased Release Approach to License Termination.................................................4 1.5 PLAN

SUMMARY

.................................................... 5 1.5.1 General Information .................................................... 5 1.5.2 Site Characterization .................................................... 6 1.5.3 Identification of Remaining Site Dismantlement Activities ..................................... 7 1.5.4 Site Remediation Plans .................................................... 9 1.5.5 Final Status Survey Plan.................................................... 9 1.5.6 Compliance with the Radiological Criteria for License Termination .................... 10 1.5.7 Update of Site-Specific Decommissioning Costs .................................................. 10 1.5.8 Supplement to the Environmental Report ................................................... 11 1.6 LICENSE TERMINATION PLAN CHANGE PROCESS ............................................. 12 1.7 LICENSE TERMINATION PLAN INFORMATION CONTACT ................................... 13

1.8 REFERENCES

.................................................... 15 FIGURES Figure 1-1 Big Rock Point Owner Controlled Area .14 Page 1-i

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 1, GENERAL INFORMATION 9/27/2005 1.0 GENERAL INFORMATION 1.1 PURPOSE The objective for decommissioning the Big Rock Point (BRP) Nuclear Plant site is to reduce residual radioactivity to levels that permit release of the site for unrestricted use and for termination of the 10 CFR 50 license. The purpose of the BRP License Termination Plan (LTP) is to satisfy the requirements of 10 CFR 50.82(a)(9),

Termination of License, using the guidance provided by Nuclear Regulatory Commission (NRC) Regulatory Guide 1.179, Standard Format and Content of License Termination Plans for Nuclear Power Reactors, NUREG-1 575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), NUREG-1700, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans, NUREG-1727, NMSS Decommissioning Standard Review Plan, and NUREG-1 757, Consolidated NMSS Decommissioning Guidance [References 1-16, 1-17, 1-18, 1-19, and 1-20].

This LTP is incorporated by reference into the BRP Updated Final Hazards Summary Report (UFHSR). The LTP will be updated in accordance with 10 CFR 50.71(e).

The LTP was approved on March 24, 2005, along with License Amendment 126

[Reference 1-11].

1.2 SCOPE The LTP describes the decommissioning activities that will be performed, the process for performing final status surveys, and the method for demonstrating that the site meets the criteria for unrestricted use. The LTP contains information on:

• Historical Site Assessment and Site Characterization,

• Remaining Decommissioning Activities,

• Site Remediation Plans,

• Final Status Survey (FSS) Plan,

• Dose Modeling Scenarios,

• Update to the Site-Specific Decommissioning Cost Estimate, and

• Supplement to the Environmental Report.

The purpose and content of each chapter of the LTP is summarized in Section 1.4.

1.3 SITE DESCRIPTION AND HISTORICAL BACKGROUND Big Rock Point Restoration Project' is located in Charlevoix County, Michigan, approximately four miles northeast of Charlevoix, Michigan, and approximately eleven miles west of Petoskey, Michigan, on the northern shore of Michigan's lower peninsula. The BRP site is owned by Consumers Energy Company. Figure 1-1 shows the BRP site. The BRP Nuclear Plant was a boiling water reactor rated at 75mW electric, designed by General Electric Company.

In 1997 the site name was changed from Big Rock Point Nuclear Plant to Big Rock Point Restoration Project.

Page 1-1

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 1, GENERAL INFORMATION 9/27/2005 For the BRP Nuclear Plant, Operating License Docket 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 August 29, 1997

• Fuel permanently removed from the reactor vessel September 20, 1997

• All Spent Nuclear Fuel (SNF), Special Nuclear Material (SNM), and Greater Than Class C (GTCC) waste stored on an Independent Spent Fuel Storage Installation (ISFSI) on March 26, 2003 The Post Shutdown Decommissioning Activities Report (PSDAR) was submitted in accordance with 10 CFR 50.82(a)(4) on September 19, 1997, along with other documents associated with decommissioning (Offsite Dose Calculation Manual, Defueled Technical Specifications, Defueled Emergency Plan, and Emergency Plan 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.

1.4 DECOMMISSIONING APPROACH 1.4.1 Overview This chapter provides an overview of Consumers Energy's approach to decommissioning the BRP site. References to the chapter in the LTP, where details are provided 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.

Decommissioning activities at BRP shall be conducted in accordance with the BRP Updated Final Hazards Summary Report (UFHSR), Defueled Technical Specifications, Consumers Energy Quality Program Description for Nuclear Power Plants (Part 1) - Big Rock Point (CPC-2A), 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 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 Page 1-2

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 1, GENERAL INFORMATION 9/27/2005 for review and approval before implementation of the activity in question.

Decommissioning activities are conducted in accordance with the BRP Defueled Technical Specifications, PSDAR, Radiation Protection Program, Off-Site Dose Calculation Manual (ODCM), Industrial Safety Program, and Bulk Material Control Program. These programs are established and frequently inspected by the NRC.

Activities conducted during decommissioning do not pose any greater radiological or safety risk than those conducted during former plant operations. Radiological assessments of the Radiation Protection Program are performed annually pursuant to 10 CFR 20.1101(c). This assessment and the Big Rock PSDAR conclude that projected dose for decommissioning falls well within NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities estimates

[References 1-2 and 1-14].

The initial site characterization, together with HSA and hydrogeological investigations, provide the basis for selection of the appropriate dose modeling scenarios and critical groups to address possible future uses of the site. The computer code used for dose modeling calculates the Derived Concentration Guideline Levels (DCGLs). 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 exceed the total effective dose equivalent (TEDE) 25 mrem/year criteria for unrestricted use (Chapter 4, Site Remediation Plan, and Chapter 6, Compliance with the Radiological Criteria for License Termination).

Concurrent with characterization of the site, decommissioning activities are ongoing.

Activities performed during this period include the removal of contaminated components from the site for final disposition and the demolition of site buildings (Chapter 3, Identification of Remaining Site Dismantlement Activities).

Remediation of soils will be performed based upon the input of the initial site characterization and cleanup levels determined by dose modeling. Title 10 of the CFR, Section 20.1402, has two criteria for evaluating site conditions for unrestricted use; 25 mrem/year TEDE and ALARA. A site dose limit of 25 mrem/year for soils and groundwater has been chosen as the ALARA values for BRP, as it is consistent with Section 7 of NUREG-1575. If additional remediation activities are required to meet DCGLs, they will be performed as necessary. Once areas have been remediated to the required level, administrative controls will be put into place to prevent recontamination of the area(s) (Chapter 5, Final Status Survey Plan).

The FSS Plan describes the methodology by which plant areas will be verified to be at or below the DCGLs required to meet the site release criteria for unrestricted use.

The FSS will be conducted on site soils and groundwater in accordance with approved procedures and industry guidance. The NRC will be notified so independent confirmatory surveys can be scheduled and performed, as necessary.

The FSS results will be compiled in a series of reports by survey area(s) and will be submitted to the NRC for review.

Page 1-3

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 1, GENERAL INFORMATION 912712005 Consumers Energy intends to demolish structure(s) and release the demolition debris to either a State of Michigan licensed landfill or EPA licensed landfill in accordance with a 10 CFR 20.2002 alternate disposal method approval by the NRC dated February 5, 2002, as amended on January 19, 2005, or to a radioactive waste processing facility. The only structures that will remain onsite will be those supporting ISFSI operations. Although no buildings utilized during power operation are expected to remain on the site at the time of the FSS, it is recognized a contingency might arise for a specific structure to be in use at the time of the FSS. If so, any such building would be surveyed in accordance with NUREG-1575 guidelines, and would be included in the FSS results provided to the NRC.

Consumers Energy does not intend to use onsite burial, disposal, or incineration of any low-level radioactive waste. Any materials remaining onsite (e.g., septic field) will meet the appropriate DCGLs for unrestricted release.

Consumers Energy may release specific areas from the 10 CFR 50 license after they have been surveyed and the results documented and provided to the NRC for review. Consumers Energy will conclude the decommissioning process upon completion of remediation, final status surveys, and confirmation the site release criteria have been met.

1.4.2 Phased Release Approach to License Termination Consumers Energy may remove specific areas from the license in a phased manner.

The approach for phased release and removal from the license, after approval of the LTP, is explained below.

Following completion of decommissioning activities and FSS of a survey unit, Consumers Energy will compile an FSS report to address the area(s) where decommissioning or remediation tasks are complete and the criteria of 10 CFR 20.1402 have been met. The results of these surveys will be documented in a report and submitted to the NRC. The FSS report contents are discussed in Chapter 5.

Once an area has been verified ready for release, no additional surveys or decontamination of the subject area will be required unless administrative controls to prevent recontamination are known or suspected to have been compromised.

Consumers Energy will review and assess the impacts on the following documents before releasing land areas from the license:

• Updated Final Hazards Summary Report and Technical Specifications,

• Environmental Monitoring Program,

• Offsite Dose Calculation Manual,

• Defueled Emergency Plan,

• Security Plan,

• Post Shutdown Decommissioning Activities Report,

• 10 CFR 100 Siting Criteria, and

• Environmental Report.

Page 1-4

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 1, GENERAL INFORMATION 9127/2005 Consumers Energy has chosen a phased release approach for release of land from the operating license as follows:

• The majority of the site land, including non-impacted and areas impacted by power generation activities (approximately 2.281 km2 or 563.6 acres), and

• The portion of the site associated with ISFSI operations (approximately 0.1 km2 or 20 acres).

Upon completion of the BRP Restoration Project, an FSS report will be prepared and submitted to the NRC summarizing surveys supporting the release of site land from the 10 CFR 50 license.

1.5 PLAN

SUMMARY

Termination or partial release of the NRC license and environmental closure of the BRP site are closely related activities, completion of which will allow the site to be released for future unrestricted use. The LTP describes the processes to be used in meeting the requirements for terminating the NRC license. BRP currently intends to restore the site to a "Greenfield" condition as defined below:

• The asphalt access road approaching the site terminates at a gravel parking area,

• No visible building structures remain in the vicinity of the former industrial area,

• All subsurface structures have been removed,

• The shoreline has been returned to its original contour by filling a portion of the discharge canal; the break wall remains in place,

• The lake water intake terminates at the former screen house and has been plugged with concrete,

• All subsurface piping has been removed with the exception of the septic drainfield,

• The asphalt ISFSI road is retained to the southern end of the former Radwaste building site and all other asphalt has been removed,

• The only site facilities in existence are those supporting dry fuel storage and are located on or near the ISFSI pad,

• Cleared areas are graded for proper drainage, and Topsoil, seed, and other plantings are utilized, where appropriate, to achieve the final Greenfield condition.

1.5.1 General Information This LTP has been prepared for BRP in accordance with 10 CFR 50.82(a)(9). The LTP is being maintained as a supplement to the BRP UFHSR to support the application for a license amendment to meet 10 CFR 50.82(a)(9) and 10 CFR 50.90.

Each of the chapters required by 10 CFR 50.82(a)(9) are outlined in the subsections below. Note all figures and references (listed in alphabetical order) are located at the end of the corresponding chapter.

Page 1-5

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 1, GENERAL INFORMATION 9127/2005 1.5.2 Site Characterization Chapter 2 of the LTP discusses site characterization as it applies to potential radiological and non-radiological material contamination onsite.

Site characterization identifies, quantifies, and documents any residual contaminants of plant origin present on the site. It classifies land areas as impacted or non-impacted and provides further, detailed classification of the site impacted property into areas of similar type (Class 1,2, 3). The scope of the contamination evaluation at BRP is restricted to site soils and groundwater as all systems, structures, and components will be dismantled and removed from site (with the exception of the ISFSI structures.) Characterization of the ISFSI area will be done as a revision to this LTP when the Department of Energy removes spent fuel from the site.

Site characterization is performed in accordance with the guidelines of NUREG-1575. The BRP site characterization is founded on the HSA and characterization surveys performed from 1997-2001.

The HSA is an investigation of historical events involving radioactive and non-radioactive materials either known to have impacted the environment or with the potential to impact the environment. The HSA consisted of an investigative review and compilation of the following information: health physics logs, corrective action documents, radiological incident files, operational survey records, and annual reports to the NRC. Personnel interviews were conducted with present and former plant employees and contractors to obtain additional information regarding operational events that may have impacted the environment.

As a result of the HSA information and process knowledge evaluation as described in Chapter 2, approximately 1.742 km2 or 430.4 acres have been initially identified as "non-impacted" as defined in NUREG-1575. Final classification of impacted areas as Class 1,2, or 3 will be completed prior to the FSS, in accordance with NUREG-1575 methodology.

Radiation surveys and additional characterization measurements and samples obtained during decommissioning activities will be used to confirm the area classification. Evaluation of survey equipment, processes, techniques, and data will support development of the FSS Plan.

The information obtained from the characterization process will be used as the basis for remediation activities. The characterization process also provides a foundation for the FSS that demonstrates compliance with criteria for release of the site for unrestricted use (10 CFR 20, Subpart E.)

Page 1-6

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 1, GENERAL INFORMATION 9127/2005 1.5.3 Identification of Remaining Site Dismantlement Activities Consumers Energy is conducting decontamination and dismantlement activities at the BRP site consistent with those discussed in the BRP PSDAR. Chapter 3 of the LTP describes those decontamination and dismantlement activities that remain at BRP as of June 30, 2005. Also included in this chapter are estimates of radiation dose to workers from decommissioning activities and projected quantities of radioactive waste. Chapter 3, Table 3.1, Decommissioning Periods, contains descriptions of major decommissioning periods and activities.

Consumers Energy's primary goals are to decommission BRP safely, to monitor and control radiological hazards, and to maintain the safe storage of spent fuel.

Demolition debris will be sent for disposal locally in accordance with alternate disposal approval under 10 CFR 20.2002. Materials that cannot be decontaminated will be sent to an offsite radioactive waste processor or directly to a licensed low-level radioactive waste disposal site. Completion of the decommissioning at the BRP site depends on the availability of a low-level waste disposal site. Currently, BRP has access to low-level waste disposal facilities in Barnwell, South Carolina, and Clive, Utah.

Major decommissioning activities completed as of June 30, 2005 include:

• Decontamination of the primary system,

• Spent fuel pool clean-out (non-fuel irradiated reactor internal),

• Installation of site construction power,

• Establishment of a new spent fuel pool cooling system,

• Removal of the reactor feed pumps,

• Removal of the turbine and condenser,

• Relocation of the control room to a spent fuel pool monitoring station,

• Demolition of the alternate shut-down (ASD) building,

• Construction of an ISFSI,

• Installation of a single-failure-proof containment building crane,

• Removal of the reactor intemals,

• Poison tank removal,

• Emergency condenser removal,

• Removal of fuel from the spent fuel pool to a dry fuel storage system,

• Removal of the spent fuel racks and pool liner,

• Removal of the Reactor Vessel,

• Removal of the Steam Drum,

• Removal of irradiated concrete,

• Demolition of the Administration Building

• Demolition of the Screenhouse,

• Demolition of the Stack, 'and

• Demolition of the Turbine Building.

Page 1-7

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 1, GENERAL INFORMATION 9127/2005 1.5.3.1 Future Decommissioning Activities and Tasks The remaining decommissioning activities include decontamination and removal of site buildings, structures, and cleanup of site land areas. Many of these activities will be performed concurrently. Decontamination and dismantlement activities are currently expected to continue until the second quarter of 2006.

Decontamination of plant structures and equipment may be utilized to reduce dose rates or improve material shipping condition. Decontamination techniques may range from water washing to removal of a layer of building surface material.

Contaminated equipment and structural material will be packaged and either shipped to a processing facility or shipped directly to a low-level radioactive waste disposal facility. Soil and groundwater remediation is discussed in Chapter 4 of the LTP.

Following decontamination, buildings will be demolished and the concrete and structural debris buried in a Michigan landfill. On February 5, 2002, and January 19, 2005, Consumers Energy received NRC approval for disposal of demolition debris in accordance with provisions of 10 CFR 20.2002 [References 1-10 and 1-8]. Letters from Consumers Energy on May 18 and June 20, 2001, and September 15, 2004, serve as a description of the process used for ensuring decontaminated demolition debris meets the criteria for disposal in a local landfill [References 1-6, 1-7, and 1-12]. The demolition debris would consist of flooring material, concrete, rebar, roofing materials, structural steel, incidental soil associated with digging up foundations, and concrete and/or asphalt pavement or other similar solid materials originating from decommissioning activities. Demolition materials not meeting the requirements for disposal in a Michigan landfill will be disposed of as radioactive waste.

The NRC issued an environmental assessment and finding of no significant impact in the Federal Register on December 7, 2001, (Volume 66, Number 236, pages 63567

- 63568) and on January 19, 2005, (Volume 70, Number 12, pages 3072 - 3074).

This assessment concluded there are no significant radiological environmental impacts associated with Consumers' request to dispose of demolition debris in accordance with 10 CFR 20.2002. The NRC concluded the environmental impacts of processing the total waste projected for BRP approximately 18,000 cubic meters (635,100 cubic feet), which includes approximately 16,000 cubic meters (563,000 cubic feet) of clean demolition debris proposed to be sent to a State of Michigan licensed landfill. Clean demolition debris, sent to a State of Michigan and EPA licensed landfill, are bounded by NUREG-0586. The NRC further concluded the requested action did not involve any historic sites, nor affect non-radiological plant effluents and has no other environmental impact.

A detailed description of the coordination of activities, requirements, permits, and licenses covered by other regulatory agencies is also included. These activities, requirements, permits and licenses include National Pollutant Discharge Elimination System (NPDES) permits, Great Lakes construction permits, mixed low-level waste storage permits, mixed low-level waste storage building closure certification, tank closure certification, stormwater management plan, erosion and sediment control, Page 1-8

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 1, GENERAL INFORMATION 9127/2005 asbestos and PCB characterization, remediation and disposal, noise regulations, air emissions, etc. These efforts involve coordination between Consumers Energy and other stakeholders, including the Michigan Department of Environmental Quality and the U.S. EPA.

Consumers Energy plans to operate the ISFSI under a general license pursuant tol0O CFR Parts 50 and 72. Consumers Energy will amend this LTP to include decommissioning of the ISFSI once the fuel is transferred to a permanent Department of Energy storage facility.

1.5.4 Site Remedlation Plans Chapter 4 of the LTP describes the various methods to be used during BRP decommissioning to reduce the levels of radioactivity to those which meet the NRC radiological release criteria in 10 CFR 20.1402, Radiological Critera for Unrestricted Use. Big Rock Point intends to release the site for unrestricted use upon license termination. No post-remediation activities are anticipated except ISFSI operations.

Activities for remediation initiated prior to license termination shall be completed in accordance with applicable State and Federal Regulations.

Remediation will be performed for all survey units that exhibit activity levels greater than the DCGL based upon 25 mrem/year for soil and drinking water.

1.5.5 Final Status Survey Plan Chapter 5 of the LTP describes the methods to be used in planning, designing, conducting, and evaluating final status surveys at BRP to demonstrate the site meets the NRC's radiological criteria for unrestricted use as specified in 10 CFR 20.1402 (i.e., 25 mrem plus ALARA for all dose pathways). The FSS Plan follows the guidelines developed in NUREG-1 575 as they apply to the BRP site.

The primary objective of the FSS is to demonstrate the site meets the criteria for unrestricted release for termination of license. All site buildings and subsurface structures and equipment, with the exception of the facilities supporting ISFSI, will be demolished and removed from the site prior to the FSS. Chapter 5 addresses data quality objectives, final status survey design, survey methods and instrumentation, data collection, data reviews, reporting of survey results and quality assurance and quality control requirements. The BRP FSS Plan also includes measures to ensure FSS activities are planned and communicated to regulatory agencies to allow the scheduling of inspection activities by these agencies.

Page 1-9

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 1, GENERAL INFORMATION 9/27/2005 1.5.6 Compliance with the Radiological Criteria for License Termination Chapter 6, together with Chapters 4 and 5,describes the process to demonstrate compliance with the radiological criteria of 10 CFR 20.1402 for unrestricted future use of the BRP site. The goal of the BRP Restoration Project is to release the site for unrestricted use in compliance with the NRC's dose limit of 25 mrern-year plus ALARA. The NRC dose limit applies to residual radioactivity that is distinguishable from background. This chapter of the LTP provides the methods for calculating the annual dose from residual radioactivity that may remain when the site is released for unrestricted use and the methods used to demonstrate compliance with the unrestricted use criteria.

Structures, foundations, paved surfaces and buried piping and utilities will have been removed prior to performance of the FSS for each specified survey area. Therefore, the scope of this chapter is limited to calculating annual dose resulting from surface and subsurface soil and groundwater contamination. This chapter provides a description of and the justification for source term assumptions, exposure scenarios considering the site environment, the mathematical model/computational method used, and the parameter values and a measure of their uncertainty.

Consumers Energy utilized accepted industry technical and computer codes to model dose from soils and groundwater and develop associated DCGLs. Derived Concentration Guideline Levels are the concentration radioactivity limits that will be the basis for evaluating the results of the FSS. The computer dose model is a modified resident farmer scenario for site soils and groundwater using RESRAD version 6.21.

1.5.7 Update of Site-Specific Decommissioning Costs In accordance with 10 CFR 50.82(9)(ii)(f), Chapter 7, Update of Site-Specific Decommissioning Costs, provides an updated, site-specific estimate of the remaining decommissioning costs. Regulatory Guide 1.179 provides guidance with respect to the information to be presented. The LTP must provide an estimate of the remaining decommissioning costs and compare the estimated costs with the present funds set aside for decommissioning. The financial assurance instrument required per 10 CFR 50.75 must be funded to the amount of the cost estimate [References 1-20 and 1-11]. If there is a deficit in present funding, the LTP must indicate the means for ensuring adequate funds to complete the decommissioning.

The cost estimate focuses on the remaining work, detailed by each activity associated with the decommissioning, including the costs of labor, materials, equipment, energy, and services. The decommissioning estimate includes a comparison of estimated costs with the present funds set aside for decommissioning and a description of the means to ensure there will be sufficient funds for completing decommissioning.

Page 1-10

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 1, GENERAL INFORMATION 9/27/2005 Consumers Energy owns a 100% undivided interest in the BRP Nuclear Plant and provides financial assurance for decommissioning through the 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. Inaccordance 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. 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, a cost estimate update was prepared in 2003 and filed in March 2004. This updated cost estimate serves as the cost basis for the LTP.

1.5.8 Supplement to the Environmental Report Chapter 8, Supplement to the Environmental Report, satisfies the requirements stated in:

• 10 CFR 50.82(a)(9)(ii)(G)

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 licensee's proposed termination activities.

• 10 CFR 51.53(d)

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 number of copies specified in paragraph 51.55, of a separate document, entitled "Supplement to Applicant's Environmental Report - Post Operating License Stage, "which will update "Applicants Environmental Report - Operating License Stage," as appropriate, to reflect any new information or significant 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. Decommissioning and license termination activities remain bounded by decommissioning activities described in:

• The PSDAR,

• NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities (FGEIS), and

• NUREG-1496, Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for Ucense Termination on NRC Licensed Facilities [Reference 1-15].

Page 1-11

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 1, GENERAL INFORMATION 912712005 The BRP PSDAR was submitted to the NRC in accordance with 10 CFR 50.82 (a)(4)(i). Inthe PSDAR, Consumers Energy performed an environmental review to evaluate actual or potential environmental impacts associated with proposed decommissioning activities. This site-specific evaluation used NUREG-0586 guidance and concluded environmental impacts were bounded by NUREG-0586 criterion.

Consumers Energy did not prepare an Environmental Report during original construction permitting. (An Environmental Report was not required under the Atomic Energy Commission regulations at the time of original BRP licensing.) In 1994, Consumers Energy prepared an Environmental Report for Decommissioning in conjunction with the Decommissioning Plan. This report was updated to reflect current plant conditions and parameters and was incorporated by reference into the UFHSR and submitted to the NRC on September 18, 2002.

The purpose of Chapter 8 of the LTP is to revise the BRP Environmental Report with new information or significant environmental change associated with proposed license termination/partial release activities.

1.6 LICENSE TERMINATION PLAN CHANGE PROCESS Consumers Energy is submitting this LTP as a supplement to the UFHSR.

Accordingly, the LTP will be updated in accordance with 10 CFR 50.71(e). Once the LTP has been approved, the following change criteria will be used in addition to those criteria specified in 10 CFR 50.59, 10 CFR 72.48, 10 CFR 50.82(a)(6), and 10 CFR 50.82(a)(7). Changes to the LTP that require NRC approval prior to implementation include:

• Increasing the radionuclide-specific DCGLs or area factors (as discussed in Chapters 5 and 6);

• Increasing the probability of making a Type I decision error above the level stated in the LTP (discussed in Chapter 5);

• Increasing the investigation level thresholds for a given survey unit classification (as given in Chapter 5);

• Changing the classification of a survey unit from a more restrictive classification to a less restrictive classification (e.g., Class 1 to Class 2);

• Reducing the coverage requirements for scan measurements (as discussed in Chapter 5); or

• Using statistical tests other than the Sign Test for data evaluation (as discussed in Chapter 5).

License Amendment 126 to Facility Operation License DPR-6 for Big Rock Point to include conditions for the License Termination Plan was issued by the U.S. NRC on March 24, 2005 [Reference 1-11].

Page 1-12

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 1, GENERAL INFORMATION 912712005 1.7 LICENSE TERMINATION PLAN INFORMATION CONTACT For information or comments regarding the BRP LTP, please contact the following party:

Mr. Kurt M. Haas Site General Manager Big Rock Point Restoration Project 10269 U.S. 31 North Charlevoix, MI 49720 231-547-8388 email: kmhaas~cmsenergy.com Page 1-13

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 1, GENERAL INFORMATION 9127/2005 1 LAKE MECHIGAN US"1 Screr I I I I I I I I I Metors Figure 1-1. Big Rock Point Owner Controlled Area Page 1-14

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 1, GENERAL INFORMATION 9/2712005

1.8 REFERENCES

1-1 Big Rock Point Plant Facility Operating License (DPR-6) issued May 31, 1960 as amended January 13, 2000 1-2 Big Rock Point Plant Inter-Office Memorandum KEP 02-02, Radiation Protection 2000 Program Review 10 CFR 20. 1101, from KEPallagi, RP&ES Manager to Self-Assessment File, February 19, 2002 1-3 Letter from Consumers Energy, Big Rock Point Plant to the U.S. Nuclear Regulatory Commission, Decommissioning Plan and Environmental Report for the Decommissioning Plan for Big Rock Point Nuclear Plant, February 27, 1995 1-4 Letter from Consumers Energy, Big Rock Point Plant to the U.S. Nuclear Regulatory Commission, Documents Associated with Decommissioning (PSDAR, Rev. 1, ODCM, Defueled Technical Specifications, Defueled Emergency Plan, Emergency Plan Exemption), September 19, 1997 1-5 Letter from Consumers Energy, Big Rock Point Plant to the U.S. Nuclear Regulatory Commission, Certification of Permanent Fuel Removal - Removed on September 20, 1997, September 23, 1997 1-6 Letter from Consumers Energy, Big Rock Point Plant to the U.S. Nuclear Regulatory Commission, Request for Approval of Proposed Disposal Procedures in Accordance with 10 CFR 20.2002, May 18, 2001 1-7 Letter from Consumers Energy, Big Rock Point Plant to the U.S. Nuclear Regulatory Commission, Request for Approval of Proposed Disposal Procedures in Accordance with 10 CFR 20.2002, June 20, 2001 1-8 Letter from Consumers Energy, Big Rock Point Plant to the U.S. Nuclear Regulatory Commission, Request for Approval of Proposed Disposal Procedures in Accordance with 10 CFR 20.2002, September 15, 2004 1-9 Letter from Consumers Energy, Big Rock Point Plant to the U.S. Nuclear Regulatory Commission, Documents Associated with Decommissioning (PSDAR, Rev. 1, ODCM, Defueled Technical Specifications, Defueled Emergency Plan, Emergency Plan Exemption), September 19, 1997 1-10 Letter from the U.S. Nuclear Regulatory Commission to Consumers Energy, Big Rock Point Plant, Proposed Disposal Procedures in Accordance With 10 CFR 20.2002, February 5, 2002 1-11 Letter from the U.S. Nuclear Regulatory Commission to Consumers Energy, Big Rock Point Plant, dated March 24, 2005, Issuance of Amendment 126 to Approve the License Termination Plan Page 1-15

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 1, GENERAL INFORMATION 912712005 1-12 Letter from the U.S. Nuclear Regulatory Commission to Consumers Energy, Big Rock Point Plant, dated January 19, 2005, Approval of Proposed Revision to Disposal Procedures in Accordance with 10 CFR 20.2002 1-13 U.S. Federal Register, Volume 66, Number 236, Friday, December 7, 2001, page 63567 (66 FR 63567) Consumers Energy Company; Big Rock Point Plant; Environmental Assessment and Finding of No Significant Impact 1-14 U.S. Nuclear Regulatory Commission NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, August 1988 1-15 U.S. Nuclear Regulatory Commission NUREG-1496, Generic Environmental Impact Statement in Support of Rulemaking on Radiological Criteria for License Termination on NRC Licensed Facilities, July 1997 1-16 U.S. Nuclear Regulatory Commission NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), December 1997 1-17 U.S. Nuclear Regulatory Commission NUREG-1 700, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans, April 2000 1-18 U.S. Nuclear Regulatory Commission NUREG-1727, NMSS Decommissioning Standard Review Plan, September 2000 1-19 U.S. Nuclear Regulatory Commission NUREG-1757, Consolidate NMSS Decommissioning Guidance, September 2002 1-20 U.S. Nuclear Regulatory Commission Regulatory Guide 1.179, Standard Format and Content of License Termination Plans for Nuclear Power Reactors, January 1999 Page 1-16

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 2, SITE CHARACTERIZATION 9127/2005 I This chapter was compiled In April 2003 and revised In July 2004 prior to LTP 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 2 to the LTP.

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 912712005 DECOMMISSIONING ACTIVITIES TABLE OF CONTENTS 3.0 IDENTIFICATION OF REMAINING SITE DISMANTLEMENT ACTIVITIES .............. i

3.1 INTRODUCTION

.......................................................... 1 3.2 DECOMMISSIONING OVERVIEW ........................................................... 2 3.3 COMPLETED DECOMMISSIONING ACTIVITIES AND TASKS ............................... 4 3.3.1 Summary ........................................................... 4 3.3.2 Activities Performed in Support of Continued Spent Fuel Storage ..................... 5 3.3.3 Activities Performed In Support of Worker or Radiological Safety ..................... 6 3.3.4 Description of Completed Activities .......................................................... 7 3.4 REMAINING DECOMMISSIONING ACTIVITIES .................................................... 16 3.4.1 Decontamination and Demolition of Structures .................................................. 17 3.4.2 Underground Piping..............................................................................................18 3.4.3 Control Mechanisms to Ensure No Recontamination.........................................18 3.5 CURRENT RADIOLOGICAL STATUS AND EXPOSURE ESTIMATES ................. 19 3.5.1 Occupational Exposure ......................................................... 19 3.5.2 Public Exposure ......................................................... 19 3.5.3 Estimate of Quantity of Radioactive Material to be Shipped for Disposal or Processing.............................................................................................................19 3.5.4 Solid Waste Activity and Volume ......................................................... 19 3.5.5 Liquid Effluents Activity and Volume ......................................................... 21 3.5.6 Gaseous Effluents Activity and Volume ......................................................... 22 3.6 COORDINATION WITH OUTSIDE ENTITIES ......................................................... 22

3.7 REFERENCES

.......................................................... 28 Page 3-i

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 9127/2005 DECOMMISSIONING ACTiVITiES TABLES 3-1 Decomm i ssioning Periods............................................ 3 3-2 Description of Completed Decommissioning Activities..........................................8 3-3 Remaining Decommissioning Activities ........................................... 17 3-4 Solid Waste Summary ........................................... 20 3-5 Liquid Effluent Release Summary ........................................... 21 3-6 Gaseous Effluent Release Summary ........................................... 22 FIGURE' S 3-1 Big Rock Point Former Site Plan ............................................ 24 3-2 Demolition/Final Status Survey Interface Schedule ........................................... 25 3-3 Flow Diagram of the Demolition Debris Disposal Process .................................... 26 3-4 Dose Summary- Goal, Estimate, and Actual ........................................... 27 Page 3-ii

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 912712005 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 activities. This chapter was written following the guidance of NUREG-1 700, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans, and Regulatory Guide 1.179, Standard Format and Content of License Termination Plans for Nuclear Power Reactors, and will discuss those dismantlement activities as of June 30, 2005

[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 these activities will not have a significant effect on the quality of the environment is provided in LTP Chapter 8, Supplement to the Environmental Report.

Consumers Energy's primary goals are to decommission the Big Rock Point (BRP)

Nuclear Plant safely and to maintain the continued safe storage of spent fuel in an Independent Spent Fuel Storage Installation (ISFSI). As of May 2, 2003, all spent nuclear fuel, special nuclear material, and Greater Than Class C (GTCC) waste material was relocated to the ISFSI. Consumers Energy will decontaminate and dismantle the remaining operational facility in accordance with the DECON alternative, as described in NUREG-0586, Final Generic Environmental Impact Statement (FGEIS) [Reference 3-12]. Completion of the DECON option is contingent upon continued access to one or more low-level waste (LLW) disposal sites. Currently, BRP has access to LLW disposal facilities located in Bamwell, South Carolina, and in Clive, Utah.

Decommissioning activities at BRP shall be conducted as discussed in this LTP and in accordance with the Defueled Technical Specifications, Consumers Energy Quality Program Description (QPD) for Nuclear Power Plants, existing 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.

Decommissioning activities are conducted under the BRP Radiation Protection Program, the Off-Site Dose Calculation Manual (ODCM), Safety Program, and Bulk Material Control Program. Such activities are and shall be conducted in accordance with these established programs and associated procedures that are frequently inspected by the NRC. Activities conducted during decommissioning do not pose any greater radiological or safety risk than those conducted during former plant operations. Decommissioning activity radiological risk is bounded by previously analyzed radiological risk for former operating activities that occurred during major maintenance and outage evolutions.

Page 3-1

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 9127/2005 DECOMMISSIONING ACTIVITIES The activities described in Section 3.2 to 3.4 include decommissioning activities up to the future release of the site, with the exception of facilities supporting ISFSI operations. Table 3-1 describes the decommissioning phases at BRP and Table 3-2 provides a list of completed decommissioning activities. The dismantlement activities described in these sections provide the NRC the information to support site release and future license termination pursuant to 10 CFR 50.82(a)(1 1)(i).

Therefore, this section was written to clearly indicate each dismantlement activity that remains to be completed prior to qualifying for license termination. The final state of the site will be a Greenfield condition (as defined in Chapter 1 of this LTP) with buried foundations and piping removed. Decommissioning activities performed will reduce residual radioactivity to a level that permits release of the property for unrestricted use.

Information related to the remaining decommissioning tasks is also provided. This information includes an estimate of the quantity of radioactive material to be released to unrestricted areas, a description of proposed control mechanisms to ensure areas are not recontaminated, estimates of occupational exposures, and characterization of radiological conditions to be encountered and the types and quantities of radioactive waste. This information supports the assessment of impacts considered in other sections of the LTP and provides sufficient detail to identify inspection or technical resources needed during the remaining dismantlement activities. Many of these dismantlement tasks require coordination with other Federal, State or local regulatory agencies or groups. Table 3-3 contains a list of future decommissioning activities to be performed by Consumers Energy or its contractors.

3.2 DECOMMISSIONING OVERVIEW Decommissioning activities were initiated following the decision to permanenty 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 function, if any, these SSCs would be expected to perform during decommissioning. Each major plant SSC was evaluated to determine if the SSC, in its entirety or any portion thereof, was important for the safe storage of the spent fuel (ISSSF), was important for the monitoring and control of radiological hazards (IMCRH), or was needed to perform a function during the decommissioning and decontamination (D&D) of the plant. Table 3-1 provides a general outline of the phases for BRP Decommissioning.

Performance of decommissioning activities that have the possibility of affecting the safe storage of spent fuel or monitoring and control of radiological hazards are controlled by BRP's administrative processes. Big Rock Point administrative procedures specify the standard methods of accomplishing plant activities and processes. They are the documents used to implement the requirements of the QPD. This QPD ensures that BRP complies with the requirements of 10 CFR 50, Appendix B for quality assurance. Examples of administrative processes controlled by procedures include: ALARA (as low as reasonably achievable) reviews, Page 3-2

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 9127/2005 DECOMMISSIONING ACTIVITIES 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), and final status surveys.

A work control process is applied for decommissioning to document work performed and apply plant processes and controls to the activities. If a decommissioning activity requires NRC review pursuant to 10 CFR 50.59, an amendment to the BRP Defueled Technical Specifications (DTS) or license will be submitted. As of June 30, 2005, NRC review for BRP license amendments associated with decommissioning activities included the following:

• Amendment 120, December 24, 1998. Approval of the Defueled Technical 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 control of heavy loads, spent fuel handling considerations, and installation of a single-failure proof 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 the License Termination Plan.

Table 3-1. Decommissioning Periods Decommissioning Plan and Preparation for Shutdown

• Decommissioning Team formed October 1993 Original Decommissioning Plan submitted February 1995

• Plant Shutdown August 29. 1997 Hazard Reduction

• Core Off-Load completed September 1997

• Chemical Decontamination of the Primary System completed January 1998

• Phase I of Decommissioning Power completed March 1998

• Phase 2 of Decommissioning Power completed February 1999

• Spent Fuel Pool Cleanout (Non-SNM and GTCC materials) completed March 2000

• SSC radiological and hazardous waste (asbestos) decontamination - In progress Relocation I Reconfiguration of SSCs

• High Efficiency Particulate Air Filters completed January 1998

• Monitoring Station relocated February 1999

• Spent Fuel Pool Cooling Skid completed May 1999

• Construction of the ISFSI completed June 2001

• Containment Building Crane Installation completed October 2001

• Relocation of fuel to the ISFSI completed March 2003

• Greater Than Class C (GTCC) Waste Cask on the ISFSI completed May 2003

• ISFSI Operation - In progress Decommissioning Work Projects - completed March 2W05 Decontamination of Structures prior to demolition - in progress Page 3-3

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 9127M2005 DECOMMISSIONING ACTIVITIES Removal of Major Systems and Components

• Spent Fuel Pool and Fuel Racks completed April 2003

• Reactor Vessel completed October 2003

• Steam Drum completed November 2003

• Spent Fuel Pool Uner completed December 2004

• Irradiated Concrete completed February 2005 Demolition of Structures

• ASD Building Removal completed April 2001

• Solid Radwaste Building completed March 2003

• Administrative Building completed September 2004

• Screenhouse completed November 2004

• Stack completed March 2005

• Turbine Building completed March 2005

• Uquid Radwaste Vaults - projected 4" quarter 2005

• Containment Building - projected 4 quarter 20065

• Buried Piping and Building Foundations - projected 2' quarter 2006 Ucense Termination

• General Ucensee under 10 CFR Part 72 - February 2001

• Develop and Submit Plan - April 2005

• Public Meetings on the LTP - August 2003

• Plan Approval - March 2005

• Final Site Survey (Non-4SFSI area) - projected 4' quarter 2006

• Submittal of Final Status Survey Report (Non-ISFSI area) - projected 4" quarter 2006

• Final Status Survey Approval - projected 2007

• Shipment of Fuel to Department of Energy - 2012

• Final Site Survey of the ISFSI - 2012

• Regulatory Final Site Survey Review - 2012

• Termination of Part 50 Ucense - 2012 3.3 COMPLETED DECOMMISSIONING ACTIVITIES AND TASKS 3.3.1 Summary I

Consumers Energy initiated decommissioning activities in 1997 with existing plant resources supplemented by contract employees. This section describes activities performed to remove the facility from service from the time that BRP certified that the facility had permanently ceased operation in August 1997, including movement of spent fuel to the ISFSI facility and building demolition. Table 3-2 lists completed decommissioning projects through June 30, 2005. Completed projects involved the safe storage of spent fuel, monitoring of radiological hazards, providing worker safety from radiological and industrial hazards, and supporting the D&D process.

Successful completion of these activities demonstrate the project team's ability to safely and effectively decommission the BRP site. Consumers Energy personnel perform all contract oversight functions for the site.

In general, the following sequence has been and will continue to be followed in the dismantlement and demolition process.

1. Plant systems, piping, and components are removed. This work is dispositioned and disposed of as radioactive LLW or as clean material, as appropriate.

2. Decontaminate structural components as necessary.

I Page 34

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 912712005 DECOMMISSIONING ACTIVITIES

3. Perform pre-demolition and confirmatory surveys of the structural components to ensure proper disposal as demolition debris or radioactive waste.

4. Demolish the structure.

5. Perform bulk assay evaluation of demolition debris to allow material release (per BRP Demolition Debris Disposal Program - see Section 3.4.2).

All projects and significant activities were subject to a detailed scheduling process to ensure efficient use of plant resources. Evaluation of these decommissioning activities through the 10 CFR 50.59 review process ensured prior NRC approval or license amendment was obtained, as necessary.

3.3.2 Activities Performed In Support of Continued Spent Fuel Storage This portion of the process began immediately after the fuel was permanently removed from the reactor vessel. Only systems needed to support the spent fuel pool (where the fuel resided until transfer to an ISFSI) were maintained. In some cases, alternate means of functions to support decay heat removal from the pool were established (spent fuel pool cooling skid and liquid radwaste processing skid installation). On May 2, 2003, all spent nuclear fuel, special nuclear material, and GTCC waste material was relocated to the ISFSI.

The following activities include facility modifications and major activities that were required to maintain SSCs important for safe storage of spent fuel or for monitoring and control of radiological hazards in support of D&D activities.

• Installation of Decommissioning Air

• Installation of the Liquid Radwaste Processing Skid

• Validation and Verification Program for Fuel Storage

• Installation of Decommissioning Power

• Relocation of Control Room to Monitoring Station

• Relocation of the Standby Diesel Generator

• Installation of the Spent Fuel Pool Cooling Skid

• Modification of the Circulation Water System

• Completion of the Spent Fuel Pool Cleanout Project

• Installation of the Containment Construction Access

• Construction of Transportation Path from Containment to the ISFSI

• Construction of the ISFSI Facility

• Installation of new Containment Building Crane

• Installation of ISFSI Security System

• Dry Fuel, GTCC Waste and Special Nuclear Material Storage on an ISFSI Page 3-5

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 912712005 DECOMMISSIONING ACTIVITIES 3.3.3 Activities Performed In Support of Worker or Radiological Safety This section describes activities performed to ensure worker safety from radiological and non-radiological hazards. Non-radiological hazards include occupational health hazards (e.g., asbestos), energized component protection, and worker safety measures. Immediately after cessation of reactor operation, several activities were performed to reduce radiological and non-radiological hazards to workers performing decommissioning activities. The following are descriptions of these activities:

• Asbestos Abatement The following areas were subjected to removal of asbestos: Turbine Deck, Pipe Tunnel, Emergency Condenser, Turbine Building, Steam Drum, Recirculation Pump Room, ScreenhouselDiesel Generator Room, Sphere, Air Compressor Room, Shutdown Heat Exchanger Room, RCW Heat Exchanger Room, Ventilation/HVAC Room, and other miscellaneous areas.

The process of asbestos removal began June 1997, and continued until the majority of asbestos abatement was completed for structures and components in September 2000. Administrative processes were used to control the method of abatement. In the event that small quantities of asbestos are discovered that require abatement, the administrative process remains in place to remove asbestos containing materials.

• Chemical Decontamination of the Primary System The Electric Power Research Institute (EPRI) DfD chemical decontamination process, developed by Bradtec Ltd., was performed at BRP in December 1997. The EPRI DfD process used dilute fluoroboric acid (HBF 4) under conditions of controlled oxidation potential to remove contamination from surfaces and collect the contamination on ion exchange resin. The process was used to remove loose and fixed contamination from the internal surfaces of the Reactor Cleanup System, as well as the reactor vessel, steam drum, reactor coolant cleanup and shutdown cooling systems. Over 400 curies of radioactivity were removed, which accounted for 96% of the estimated internal contamination. A cumulative dose savings of at least 400 person-rem to plant workers is expected during dismantlement as result of performing the post shutdown chemical decontamination.

• HEPA Filter Installation A High Efficiency Particulate Air (HEPA) filter was installed in early 1998 to minimize radioactive particulate release through the stack during major dismantlement activities. The modification incorporated a HEPA filtration skid, which exhausts into the existing containment exhaust flow path when activities are performed with significant potential for release of radioactive materials into containment. With completion of significant source term removal in Containment in late 2004, the HEPA is no longer required for decommissioning activities. However, this unit is still available for use with containment building ventilation in accordance with the Offsite Dose Calculation Manual (ODCM).

Page 3-6

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 9127/2005 DECOMMISSIONING ACTIVITIES

• Chromated Systems Chemical Decontamination In March 1999, three chromated systems (VAS, PIS and RCW') were decontaminated using the CITROX process. The purpose of the decontamination was two-fold. It was performed to reduce radiation levels in the piping and system components and to remove the hazardous hexavalent chromium for the process fluids. The end result of the decontamination process was a reduction in radiation and chromium hazards to workers during decommissioning activities. Termination of the process left the three systems filled with demineralized water. All the chromium removed from the systems was deposited on resin and verified by testing to be non-hazardous.

• Pipe Tunnel Decontamination Proiect This project was performed to reduce general dose rates in the pipe tunnel to provide ALARA conditions for the workers in the area.

3.3.4 Description of Completed Activities This section describes decommissioning activities performed to support the D&D process. Table 3-2 lists major decommissioning activities along with the corresponding completion date. Structures, systems, and components were declared available for decommissioning once their functions were no longer needed for the safe storage, control, or maintenance of spent fuel. Structures, systems, and components removed were not relied upon for accident mitigation in the defueled condition.

System and equipment evaluations resulted in SSCs becoming available for decommissioning. A work control process was applied to SSCs available for decommissioning to document work performed and apply plant processes and controls to the activities. Multi-disciplined review of work packages and procedures for D&D activities include radiation protection reviews, design basis review (availability for decommissioning), construction review for feasibility of demolition method, and review for safety and environmental concerns.

'Ventilation System (VAS), Post-incident System (PIS), Reactor Cooling Water (RCS).

Page 3-7

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 9127/2005 DECOMMISSIONING ACTIVITIES Table 3-2. Description of Completed Decommissioning Activities I Activity Description Date Install Plant HEPA A HEPA for the Containment Building was installed. January 1998 This activity removed the concentrated acid tank (T-42) from the site. The tank was made obsolete by February Remove Acid Tank the installation of the liquid radwaste-processing skid. 1998 The acid tank was no longer needed with an alternate means of processing wastewater.

Remove Reactor The reactor feedwater system (FWS) pumps and March 1998 Feedpump and Motors motors were removed from the turbine deck.

Cut and Remove Reactor This activity was performed to enable cutting and May 1998 Shield Plug and Thermal capping reactor vessel lines (see below). My19 Shield Plug Remove Condensate The condensate pump room wall was removed to May 1998 Pump Room Wall facilitate the removal of condenser components.

Cut and Cap lines from This activity was done to isolate the reactor vessel. May 1998 the Reactor Vessel Clear Hydrogen Control Hydrogen equipment was removed from the rooms that contained components from the turbine generator June 1998 PanelAreasystem (TGS.)

Remove Feedwater and FWS and condensate system (CDS) piping wasJue19 I Condensate Piping on the removed from the turbine deck. June 1998 Turbine Deck Remove the Reactor Feed The reactor FWS pumps and motors were removed June 1998 I Pumps from the turbine deck.

Drain and Remove Lube Lubrication oil for the FWS pump motors was no June 1998 I Oil longer needed once the feedpumps were removed.

Remove Pipe Tunnel Pipe tunnel block walls were removed to facilitate the August 1998 I Block Walls removal of the turbine and condenser.

Remove Main Generator The main turbine generator was removed. September 1998 Remove Turbine The turbine was removed. November Equipment was removed from the rooms that Clear the Fuel Pool Sock contained radwaste system (RWS) components made January 1999 Area Rooms obsolete by the installation of the liquid radwaste- I processing skid.

Page 3-8

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 9127/2005 DECOMMISSIONING ACTIVITIES Activity Description Completed Equipment was removed from the rooms that contained components from the air ejector system (AES - made obsolete with the installation of the Clear the Condensate HEPA filter), Control Air System (CAS - made Pump Room obsolete with the installation of the decommissioning January 1999 air system), CDS, demineralized water system, and the resin regeneration system (DMW/RGS - made obsolete by the installation of the liquid radwaste processing skid).

Equipment was removed from the rooms that Clear the UPS Battery contained components from the emergency power March 1999 I Room system (EPS - made obsolete with the installation of decommissioning power).

Equipment from the Alternate Shutdown (ASD)

Clear the Alternate Building including HVAC unit, control panels, battery Shutdown Building chargers, emergency lights, smoke detectors, and April 1999 I Eq .cardn readers.

removed.AllAllASD equipmentre thatBuilding remainedinterior components was bare concrete walls, main structural steel, and the exterior door.

This project dismantled and removed former Clear the Substation substation. Decommissioning power new substation May 1999 installation rendered the old substation obsolete.

Clear the Accumulator Equipment was removed from the rooms that I Rooms contained components from the control rod drive May 1999 (CRD) system.

Equipment was removed from the rooms that contained components from the air ejector and waste gas systems (AES / WGS - made obsolete with the Clear the Air Ejector installation of the HEPA filter), control air system June 1999 I Rooms and Platform (CAS - made obsolete with the installation of the decommissioning air system), and the RWS (made obsolete by the installation of the liquid radwaste processing skid).

Remove the Condenser and Turbine Low Pressure These components were removed. June 1999 I Shell Remove the Feedwater These components were removed. July 1999 I Heaters Page 3-9

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 912712005 DECOMMISSIONING ACTIVITIES Activity Description Date

_ Completed Equipment was removed from the rooms that Clear the Interior and contained obsolete components from the CIS, power Exterior Cable Penetration system (replaced by decommissioning power August 1999 Rooms supplies), and reactor protection system (RPS) components.

Equipment was removed from the rooms that contained components from the CAS (made obsolete with the installation of the decommissioning air system), CDS, DWS, containment isolation system Clear the Pipe Tunnel (CIS), CRD system, DMW I RWS (made obsolete by July 1999 the installation of the liquid radwaste processing skid),

FWS, heater extraction drain (HED) system, main steam system (MSS), reactor cooling water system (RCW), and the TGS.

Clear the Core Spray Equipment was removed from the rooms that August 1999 Equipment Room contained PIS/emergency core cooling components.

Clear the Reactor Cooling Equipment was removed from the rooms that September Water Heat Exchanger contained RCW components 1999 Room Equipment was removed from the rooms that Clear the Electrical contained components from the station power system September Equipment Room (SPS - made obsolete with the installation of 1999 decommissioning power.)

This modification installed an access door between containment recirculation pump room and the pipe tunnel in the turbine building. The door was installed Install the Pipe Tunnel to facilitate dismantlement. The design of the door Door met the containment closure definition from BRP's November Defueled Technical Specifications (DTS). Installation 1999 of openings in containment meets the DTS requirements, but render the Containment Building as a non-pressure vessel.

Clear the Fuel Pit Pumps Equipment was removed from the rooms that and Heat Exchanger contained spent fuel pool (SFP) obsolete November Room components - i.e., heat exchangers made obsolete 1999 with the installation of the SFP cooling skid.

Clear the CRD Pump Equipment was removed from the rooms that January 2000 I Room contained CRD components.

Remove the Reactor Reactor recirculation pumps were part of the FWS February Cooling Waterfothrecr.20 Recirculation Pumpsfothrecr.20 Page 3-10

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 912712005 DECOMMISSIONING ACTIVITIES Activity Description Completed Clear the Emergency Equipment was removed from the rooms that 2 Condenser Area contained liquid poison system (LPS) components. March 000 Clear the Shutdown Heat Equipment was removed from the rooms that A 2000 Exchanger Room contained SCS components.

Clear the Containment Equipment was removed from the rooms that Instrument Room contained components from the neutron monitoring June 2000 Instrmentsystem (INMS).

Clear Storage Area in Equipment was removed from the rooms that June 2000 Containment contained CRD nitrogen charging bottles.

Clear CRD Access Room Equipment was and contained PCS removed from the rooms that PIS components. June 2000 Remove Reactor Vessel Reactor vessel grid bars were removed to prepare June 2000 Internals the vessel for shipment.

Remove Lube Oil Tank The lube oil tank and room components were not and Complete Clearing needed since they were components from the MSS July 2000 the Lube Oil Tank Room and turbine lube oil system (SLO).

Clean out Liquid Resins from the liquid radwaste tank were no longer Radwaste and Remove needed with the installation of the liquid radwaste July 2000 I Resin skid.

Clear Chemistry Equipment was removed from the former lab areas I Laborato after the lab was moved to the new access control August 2000 ry portable building.

Equipment was removed from the rooms that contained components from the AES (made obsolete with the installation of the HEPA filter), CAS (made Clear Condensate obsolete with the installation of the decommissioning September I Demineralizer Room air system), CDS, demineralized water system, and 2000 the resin regeneration system (DMW / RGS - made obsolete by the installation of the liquid radwaste processing skid).

Equipment was removed from the rooms that Clear Machine Shop contained components from the SPS (made obsolete October 2000 with the installation of decommissioning power).

Clear Electrical and I&C Obsolete mechanical, electrical, and HVAC Shop equipment was removed from the electrical and l&C October 2000 I shop areas.

Clear Balance of Equipment was removed from the rooms that October 2000 Accumulator Room contained CRD components. I Page 3-11

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 9/27/2005 DECOMMISSIONING ACTIVITIES Activity Description pted Clear Filter Room 419 Equipment was removed from the rooms that November contained RCW I LPS components. 2000 I Equipment was removed from the rooms that contained components from the CRD system, the Clear Balance of emergency core cooling system (ECS), the FWS, the December Recirculation Pump Room LPS, the MSS, the PCS, the RCW system, the 2000 reactor steam drum system (RSD), the RWS, and others.

Remove Poison Tank and December Emergency Condenser These components were removed. 2000 Clear Turbine Deck The turbine deck was cleared of all components that January 2001 General Area were obsolete with decommissioning.

Clear Core Spray Tank Equipment was removed from the rooms that January 2001 Rooms contained PIS I ECS components.

Remove Steam Drum Blast Wall and Aggregate components were removed. March 2001 The ASD Building was demolished. Itwas a small structure located inside the protected area. It had Demolish the Alternate previously been cleared of all components and April 2001 Shutdown Building consisted of the concrete structure and steel support I beams. Prior to demolition, the structure was radiologically surveyed.

Remove Reactor Shield The reactor shield tank was removed and the reactor Tank and Prepare Reactor vessel prepared for shipment to provide for efficient June 2001 I Vessel for Shipment decommissioning.

Remove Containment A facility change was done to remove part of the Structures to containment structures to enable removal of the June 2001 I Accommodate Reactor reactor vessel.

Vessel Removal Containment Building modifications were performed Modify Containment prior to the installation of the new Containment Building (SFP cover) Building crane. Other modifications were performed August 2001 I to enable more efficient dry fuel transfer from the SFP to the dry fuel storage canisters.

Remove Condensate September Demineralizer Tank These components were removed. 2001 I Clear Office Building Equipment was removed from the former office February Rooms areas. 2002 I Page 3-12

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 9127/2005 DECOMMISSIONING ACTIVITIES Activity Description Completed Clear Demineralizer Pump Equipment was removed from the rooms that February Room contained RCS system components. 2002 I The Radwaste Building and internal concrete storage Demolish Radwaste vaults located south of the Protected Areas were Building and Storage demolished. This building was a steel structure with March 2002 Vaults a concrete floor. The concrete vaults were disposed I of as radioactive waste.

Clear Service Building Components (including fire water piping) were March 2003 First Floor removed from this area. I Remove Spent Fuel Empty spent fuel racks were removed from the spent April 2003 Racks fuel pool. I Clear Non-Regen and Piping and other components were removed from June 2003 Regen Heat Exchanger this room.Jue20 Room 439 Clear Maintenance Piping and other components were removed from June 2003 Building Room 901 this room. I Remove Condensate and Condensate and demineralized water tanks and J 2003 Demineralizer Tanks associated piping and valves were removed. une I Clear Heating Boiler Heating and ventilation ductwork and piping and September Room other components were removed from this room. 2003 I Clear Ventilation Room Heating and ventilation ductwork and piping and September other components were removed from this room. 2003 I Drain the Spent Fuel Pool The water in the spent fuel pool was drained and September processed as the final Liquid Radwaste. 2003 Perform Final Clearing of Piping and other components were removed from September the Recirculation Pump this room. 2003 Room Clear the Decontamination Piping and other components were removed from September Washroom Area - Room Piin ndote 2003 121tisoo.20 Remove the Turbine and 'Layers" of roofing material were removed and September Service Building Roofs surveyed in preparation for the Turbine Building 2003 demolition.

Clear Decontamination PiigadohrcmoetweerovdfmSpebr and Washdown Rooms Pipigsan rother copnns0eermoe0rm3etme 444 and 451thsrom.20 Page 3-13

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 912712005 DECOMMISSIONING ACTIVITIES Activity Description Completed Cleanup Heat Exchanger Heat exchanger was removed. September Clear Diesel Generator Fire System (and other) piping and other components September Room were removed from this room. 2003 Plant heating boiler and associated components September Remove Heating Boiler were removed. Temporary heating was provided as 2003 needed.

Remove Reactor Vessel Reactor vessel was removed from Containment for October disposal. 2003 Remove Steam Drum Steam drum was removed from Containment for November disposal. 2003 Remove Concentrated December Waste and Radwaste These components were removed. 2003 Tanks Clear Waste Holdup Tank Components in this room were removed. 2003 Clear Liquid Radwaste December Area Components in this area were removed. 2003 Clear Liquid Radwaste Piping, valves, and other components associated December Operating Gallery with Liquid Radwaste were removed. 2003 Remove the Spent Fuel The stainless steel liner was removed. December Pool Liner 2003 Clear the Track Alley Piping and other components were removed from the June 2004 Turbine Building track alley.

Clear the Off-Gas Stack Components in the stack and stack base were June 2004 I removed prior to demolition of the stack structure.

Remove Containment The Containment Building crane was removed and June 2004 I Building Crane returned to the vendor.

Clear Screenwell and Components in the screenhouse (traveling screens, Au ust 2004 I Pump House piping, and other equipment) were removed. g Restore Discharge Canal Discharge canal was remediated, surveyed, and August 2004 I restored by backfilling to original contour.

Clear Remaining Turbine A final removal of remaining components was done September Building Systems prior to demolition of the Turbine Building. 2004 I Page 3-14

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 9127/2005 DECOMMISSIONING ACTIVITIES Activity Description Completed Clear Reactor Building A final removal of remaining components was done September Remaining Systems prior to removal of remaining contamination in 2004 Containment.

Demolish Administrative The Administrative and Services Buildings were September Building demolished (above grade structure.) 2004 I Clear Spent Fuel Storage Components were removed from these areas. November Area Rooms 437 and 448 Cmoetweermvdfmthsaes.2004 I The Screenwell and Pump House was demolished.

The shoreline has been returned to its original Demolish Screenwell and contour by filling a portion of the discharge canal; the November Pump House break wall remains in place. The lake water intake 2004 terminates at the former screenhouse and has been plugged with concrete.

Demolish Off-Gas Stack The Off-Gas Stack was demolished (above grade November structure). 2004 Demolish Service Service The Service Building was demolished. January Building 2005 Demolish Turbine Building The Turbine Building was demolished (above grade March 2005 structure.)

Clear Surge Tank Room Components in the spent fuel pool surge tank room March 2005 448 were removed.

Remove Turbine Building The Turbine Building crane was removed from the March 2005 Crane Turbine Building.

Demolish Concrete and Reactor Vessel concrete and shield cooling panels March 2005 Shield Cooling Panels were demolished.

Clear Supply Air Shed Supply Air Shed cleared. April 2005 Clear Shield Laydown Shield Laydown Area, Vent Panel, and Supply Fan Apr 205 Area, Vent Panel, and Areas cleared. pl25 Supply Fan Areas Page 3-15

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 9/27/2005 DECOMMISSIONING ACTIVITIES 3.4 REMAINING DECOMMISSIONING ACTIVITIES The focus of this section is on the decontamination and demolition of structures in the Industrial Area. Table 3-3 is a list of future decommissioning activities planned at BRP. The activities listed are intended to provide an overview of the remaining decommissioning activities and an estimated time schedule for those activities.

Major scheduled activities are outlined in the BRP PSDAR. Schedules provided in this section are for general guidance and illustrative purposes only. There is no intent to revise this LTP when schedule changes occur. Current schedules are available onsite for review. The assumptions and philosophy of BRP remaining demolition activities 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 (Turbine, Service, and Containment Building footprints).

• Groundwater and surface water control measures are required for all excavations where the potential exists for migration of radioactive or hazardous materials.

• Stormwater and groundwater from dewatering activities will be released to Lake Michigan in accordance with all applicable State and local regulations.

• Final Status Survey (FSS) on areas cannot be performed until physical demolition work in the area is complete (see Chapter 5, Final Status Survey Plan, of this LTP).

• Excavations will be backfilled with soil determined acceptable for backfilling (see Section 5.4.2).

• Final Status Survey of surface soils will occur after all demolition, remediation and backfill, but prior to topsoil addition for final restoration.

Figure 3-2 provides a graphical illustration of tasks performed by different work groups on site.

Page 3-16

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING DECOMMISSIONING ACTIVITIES 9)2712005 I Table 3-3. Remaining Decommissioning Activities I

Activity Projected Date Decontaminate Concrete - Containment Building 3a Quarter 2005 Demolish Liquid Radwaste Vaults 4" Quarter 2005 Demolish Turbine Building Foundation 3 Quarter 2005 Clear Personnel and Equipment Locks 3 Quarter 2005 Demolish Containment Building Sphere 4" Quarter 2005 Removal of Remaining Structures, Piping, and Foundations from 2na Quarter 2006 the Industrial Area Clear Security Building 2no Quarter 2006 Complete Final Restoration of Site (other than ISFSI area) 3 Quarter 2006 Final Status Survey (other than ISFSI area) 4 Quarter 2006 Transport Fuel to DOE Repository Projected 2012 Complete Final Restoration of Remaining Site Projected 2012 Terminate License Projected 2012 3.4.1 Decontamination and Demolition of Structures The remaining structures to be decontaminated and demolished inside the Industrial Area include the Containment Building, the underground Liquid Radwaste Vaults, and subsurface foundations and piping beneath the former Turbine Building.

Figure 3-1 depicts the locations of these structures.

Decontamination methods include wiping, washing, vacuuming, scabbling, spalling, and abrasive blasting. Selection of the preferred method is based on the specific situation. Structures or portions of structures that cannot be sufficiently decontaminated will be disposed of as radioactive waste. Approved administrative procedures and processes control decontamination activities. These controls ensure that wastewater is collected and airborne contamination controls are used, as necessary, and all releases are monitored.

3.4.1.1 Demolition Debris Disposal Big Rock established a program for the removal of bulk materials originating from demolition activities associated with the dismantlement of the facility under the provisions of 10 CFR 20.2002. The NRC granted approval of the request for an alternate waste disposal method on February 5, 2002, and as amended on January 19, 2005. Under the provisions of this approved request, BRP is authorized to dispose of demolition debris within a State of Michigan licensed Type II landfill and/or a landfill licensed by the U.S. EPA once required radiological surveys have been completed satisfactorily. Figure 3-3 is a flow chart depicting the demolition debris disposal process.

Page 3-17

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 9127/2005 DECOMMISSIONING ACTIVITIES 3.4.1.2 Containment Building Demolition The containment steel structure will be cut into sections and lowered to ground level.

These sections will be further size-reduced for placement in shipping containers.

Interior concrete portions of the containment will be decontaminated to the extent possible prior to demolition to ensure NUREG-0586, OFinalGeneric Environmental Impact Statement (FGEIS) on Decommissioning of Nuclear Facilities," and its supplement bound the structure for accident considerations and assumptions in the UFHSR [References 3-12 and 3-13]. The 10 CFR 50.59 and 10 CFR 50.82 processes, including FGEIS accident analyses assumptions and methodology, shall be utilized to ensure methods to demolish containment are evaluated prior to implementation.

3.4.2 Underground Piping Buried piping in the Industrial Area includes fire protection, well water, sanitary, compressed air, service water, circulating water, and radwaste system piping in addition to electrical cable and conduit and stormwater piping. Removal of this piping will be conducted through the BRP work planning process utilizing plant drawings to identify buried piping and equipment. The septic field west of the Industrial Area and intake pipe and structure in Lake Michigan will remain in place in accordance with the Greenfield definition (see Section 1.5). Prior to FSS, a ground-penetrating radar survey will be performed, as necessary, to verify that all underground piping has been removed.

3.4.3 Control Mechanisms to Ensure No Recontamination Recontamination may occur through transmission of contaminants through groundwater, air, or surface water. Control mechanisms to prevent the above scenarios include engineering controls and evaluation of demolition methods to minimize impacts of cross or re-contamination. Engineering controls will include provisions for minimizing groundwater and rain/snow seepage into open excavations.

Methods such as temporary covering, trenching, or limiting length of time an excavation is open may be used. Groundwater from excavations will be sampled and evaluated prior to dewatering.

Page 3-18

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 9127/2005 DECOMMISSIONING ACTIVITIES 3.5 CURRENT RADIOLOGICAL STATUS AND EXPOSURE ESTIMATES 3.5.1 Occupational Exposure Figure 3-4 provides BRP cumulative site dose and goals for the decommissioning project. This estimate was developed to provide site management ALARA goals.

The goals are verified by summation of actual site dose, as read by personnel dosimetry via thermoluminescent dosimeters (TLDs). ALARA estimates are a compilation of work plan (radiation work permit) estimates for the period. This information is in addition to information gathered for reporting of yearly site dose in accordance with BRP Defueled Technical Specification 6.6.1. The annual report of occupational dose meets the guidance of NRC Regulatory Guide 1.16, Reporting of Operating Information, Appendix A [Reference 3-16]. The estimated total nuclear worker exposure during decommissioning is estimated to be 700 person-rem. This estimate is in the 700-1600 person-rem range of the FGEIS [Reference 3-12].

3.5.2 Public Exposure Continued application of BRP's Radiation Safety Program, Demolition Debris Disposal Plan, Radiological Effluent Technical Specification Program, and Radiological Environmental Monitoring Program assures public protection in accordance with 10 CFR Part 20 and 10 CFR Part 50, Appendix I. Section 8.5.1 contains an evaluation of estimated public exposure as a result of decommissioning activities including the transportation of radioactive waste as compared to the FGEIS

[Reference 3-12].

3.5.3 Estimate of Quantity of Radioactive Material to be Shipped for Disposal or Processing Total volume of waste projected for BRP decommissioning is 1.34 million cubic feet, which includes 142,000 cubic feet of radioactive waste and 1.2 million cubic feet of demolition debris with no detectable radioactivity.2 Although actual waste volume may deviate from original estimates, this volume of waste remains bounded by the FGEIS waste value for the reference boiling water reactor [Reference 3-12].

3.5.4 Solid Waste Activity and Volume Consumers Energy contracted with Duratek, Inc., to provide waste processing/

disposal services for the BRP decommissioning project. To support contractual arrangements and administration, waste quantities are estimated in units of weight (kg/pounds) as opposed to volume. This is consistent with TLG Services, Inc.,

estimates of waste quantity units. In addition, BRP has secured fixed-price contracts for disposal of large components and significant waste streams. Table 8-3, Total Estimated Waste (Section 8.5.1) to be shipped from BRP, summarizes the estimated waste types by waste class pursuant to 10 CFR 61.55.

2 TLG Services, Inc. estimate completed in 1997 for the BRP PSDAR.

Page 3-19

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 9/27/2005 DECOMMISSIONING ACTIVITIES In accordance with Defueled Technical Specification 6.6.2 and 6.6.3 and 10 CFR 50.36(a), BRP Annual Radioactive Environmental Monitoring and Radioactive Effluent Release Reports includes data on solid waste activity and volumes. A summary of solid waste disposal quantities for 1997 through 2004 is provided in Table 3-4, below.

Table 3-4. Solid Waste Summary Waste Source Year Volume Volume Total Principle Class _ (kgd)Ibs)_ Curies Radionuclides I AU* DAW; 1997 59.1 130.4 0.22 Co-60, Mn-54, compacted 1998 1101 2427.0 1.32 Cs-137, Zn-65, waste, from 1999 1175 2589.5 2.40 Fe-55, Ni-63, plant 2000 25506 56,230.8 5.47 H-3, Am-241, demolition, 2001 20107 44,329.4 7.20 Pu-241 and 2002 9263.3 20,422.0 1.51 incineration 2003 2,214,819 4,882,839 39.20 ash 2004 3,329,406 7,340,084 32.00 AU Activated 2003 24,517 54,050 .06 Co-60, Fe-55, Metal Mn-54, Ni-63, Reactor Head Am-241, Pu-241, H-3, Cs-137 AS** DAW and 1998 88.5 195.0 0.32 Co-60, Mn-54, Irradiated 2000 95.7 211.0 1.28 Cs-137, Zn-65, Metals; CRD 2002 284 626.0 10.50 Fe-55, Ni-63 I systemI AS Resin from 2000 91.7 202.1 7.86 Co-60, Mn-54, processing Fe-55, Ni-63, water Cs-137 B Dewatered 1997 537.5 1,184.9 184.24 Co-60, Mn-54, Resin 2000 218.2 481.0 255.00 Cs-1 37, Zn-65, 2003 5,129.3 11,308.2 1.03 Fe-55, Ni-63, Am-241, H-3, Pu-241 C Dewatered 1998 692.5 1,526.8 1,748.00 Co-60, Mn-54, Resins Cs-137, Zn-65, Fe-55 C Dewatered 1998 60.1 132.4 26.60 Co-60, Mn-54, Filters 1999 120.1 264.8 18.90 Cs- 137, Zn-65, 2000 223.8 493.3 29.30 Fe-55, Ni-63, 2001 40.6 90.3 3.93 Am-241, 2003 20, 508.7 45,214.0 150.00 Pu-241, H-3 C DAW 1999 61.2 134.9 2.81 Co-60, Mn-54, 2000 60.8 134.0 0.92 Cs-1 37, Zn-65, Fe-55, Fe-55, Ni-63 I Page 3-20

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 912712005 DECOMMISSIONING ACTIVITIES Waste Source Year Volume Volume Total Principle Class ___ ___ _ (kg) Curies Radionuclides I C Irradiated 1999 331.9 731.8 65,100.0 Co-60, Mn-54, Components 0 Cr-51, H-3, Fe-55, C-14 I C Irradiated 2000 125.6 277.0 5,390.00 Co-60, Mn-54, Metal; Fuel Fe-55, Ni-63, channels and Cs-1 37 reactor internals C Reactor 2003 120,536.7 265,738.0 10,000.0 Co-60, Fe-55, Vessel 0 Mn-54, Ni-63, Am-241, Pu-241, H-3, Cs-137

• Class A, Unstable: Waste, which may leave voids when buried at the LLW facility.

• • Class A, Stable: Waste, which will leave no voids when buried at the LLW facility.

• • • Reference 3-18: demolition debris is assumed to have a density of 94 pounds per cubic foot. I 3.5.5 Liquid Effluents Activity and Volume The Annual Radioactive Effluent Release Report includes data on liquid effluents. A summary of the liquid waste effluent release report for 1997 through 2004 is provided in Table 3-5, below.

Table 3-5. Liquid Effluent Release Summary Dissolved Other Trtium and Alpha Fission and Waste Volume of Max. Dose Max Dose Year R Entrained Release Activation Volume Dilution Commitment Commitment YerRees Gas Rlase rouc Volume Water Whole Body Organ Release Release ers Uters mrem mrem Cl Cl _ _ _ _ _ _ _ _ __ _ _ _ _

1997 1.36 E-01 0.00 4.34 E-06 2.42 E-02 8.72 E+04 6.11 E+10 0.042 0.073 1998 7.30 E-01 0.00 4.75 E-06 8.76 E-02 3.26E+05 3.15 E+10 0.057 0.085 1999 1.07 E-02 0.00 1.08 E-06 1.19 E-02 5.36 E+04 1.80 E+09 0.312 0.527 2000 7.00 E-02 0.00 1.27 E-05 2.99 E-02 2.57 E+05 3.63 E+10 0.184 0.203 2001 2.38 E-02 0.00 2.13 E-07 6.50 E-03 6.74 E+04 4.80 E+10 0.017 0.025 2002 4.07 E-03 0.00 1.88 E-07 3.21 E-03 3.01 E+04 5.02 E+10 0.004 0.010 2003 5.03 E-01 0.00 2.64 E-05 3.43 E-02 2.55 E+04 5.00 E+10 0.087 0.200 2004 2.02 E-03 0.00 5.18 E-07 7.32 E-04 1.32 E+04 3.40 E+09 0.006 0.014 Page 3-21

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 9127/2005 DECOMMISSIONING ACTIVITIES 3.5.6 Gaseous Effluents Activity and Volume I Radioactive Effluent Release Reports includes data on gaseous effluents. A summary of the liquid waste effluent release report for 1997 through 2004 is provided in Table 3-6, below.

Table 3-6. Gaseous Effluent Release Summary Fission and AcUvaltion lodines Particulates Tritium Whole Body Whole Body Organ Dose Year Gas c Dose,je Dose, y m~remn Release mrads mrads aC 1997 2.21 E+01 3.50 E-03 3.68 E-03 2.31 EOO 1.04 E-02 1.81 E-02 1.88 E-02 I

1998 0.00 0.00 2.24 E-04 1.19 EOO 0.00 0.00 2.05 E-04 I

1999 0.00 0.00 1.64 E-04 1.19 E00 0.00 0.00 2.05 E-03 I

2000 0.00 0.00 9.77 E-06 1.19 E00 0.00 0.00 1.66 E-03 I

2001 0.00 0.00 3.71 E-06 1.19 EOO 0.00 0.00 1.66 E-.03 I

2002 0.00 0.00 4.26 E-05 2.56 E-01 0.00 0.00 9.66 E.04 I

2003 0.00 0.00 1.94 E-04 2.56 E-01 0.00 0.00 6.82 E-03 I

2004 0.00 0.00 2.65 E-04 2.56 E-01 0.00 0.00 8.19 E-03 I

3.6 COORDINATION WITH OUTSIDE ENTITIES The decommissioning and termination of the BRP 10 CFR Part 50 license involves coordination with various Federal, State, and local agencies, including, the:

• U.S. NRC,

• State of Michigan Occupational Safety and Health Administration,

• U.S. Environmental Protection Agency,

• Michigan Department of Environmental Quality,

• State Historic Preservation Office,

• State Fire Marshall,

• U.S. Coast Guard,

• U.S. Department of Energy, and

• Local law enforcement agencies.

Chapter 8 of this LTP provides a detailed discussion of Federal, State, and local requirements.

Page 3-22

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 9127/2005 DECOMMISSIONING ACTIVITIES The BRP Citizen's Advisory Board (CAB) was established in 1995 to enhance opportunities for public involvement in the BRP decommissioning process. Citizen's Advisory Board was established for the purpose of providing a formal channel of communication and feedback to BRP and Consumers Energy management on issues relevant to the plant in the area of operations and decommissioning. Citizen's Advisory Board members include Petoskey and Charlevoix City Managers, Charlevoix and Emmet County Commissioners, Petoskey and Charlevoix Chamber of Commerce representatives, a local environmentalist, local township representatives, and local business representatives. Members or member affiliations of the BRP CAB may change over the decommissioning project; membership changes will not alter the effectiveness of this group.

Page 3-23

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 9127/2005 DECOMMISSIONING ACTIVITIES Figure 3-1. Big Rock Point Former Site Plan Prior to Dismantlement Activities Page 3-24

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 912712005 11 DECOMMISSIONING ACTIVITIES 8/05 9/05 10/05 11/05 12/05 1/06 2/06 3/06 4/06 5/06 6/06 7/06 8/06 9/06 I I I I I 1 I I I 1 1 I I 1 n e ... E E...*R Stack Foundation Restoration Complete Turbine and Service Building October 2006 I

West of Turbine Building Upper (Clean) and Lower Radwaste Vault Containment Interior Concrete Sphere

-

E Demolitio Final Structures and Foundations

• Remediation / FSS E Backfill Figure 3-2. Demolition/Final Status Survey Interface Schedule Page 3-25

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 9127/2005 DECOMMISSIONING ACTIVITIES I

I I

Figure 3-3. Flow Diagram of the Demolition Debris Disposal Process Page 3-26

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 9/27/2005 DECOMMISSIONING ACTIVITIES 800 600 400 200 0'

1997 1998 1999 2000 2001 2002 2003 2004 2005

- Actual-Esthnate ALARA Goal I Figure 34. Dose Summary-Goal, Estimate and Actual 9- I Page 3-27

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 9127/2005 DECOMMISSIONING ACTIVITIES

3.7 REFERENCES

3-1 Big Rock Point Decommissioning Administrative Procedure, Volume 1, D3.1, Decommissioning Work Packages 3-2 Big Rock Point Decommissioning Administrative Procedure, Volume 1, D3.1.3, Milestone Work Packages 3-3 Big Rock Point Defueled Technical Specifications, Volume 2 3-4 Big Rock Point Post Shutdown Decommissioning Activities Report (PSDAR),

Revision 2, March 26, 1998 3-5 Big Rock Point Updated Final Hazards Summary Report (UFHSR), Revision 10, September 18, 2002 3-6 Consumers Energy Quality Program Description for Nuclear Power Plants, (CPC-2A)

(Part 1) - Big Rock Point 3-7 Letter from Consumers Energy, Big Rock Point to U.S. Nuclear Regulatory Commission, Request for Approval of Proposed Disposal Procedures in Accordance with 10 CFR 20.2002, May 18, 2001 3-8 Letter from Consumers Energy, Big Rock Point to U.S. Nuclear Regulatory Commission, Request for Approval of Proposed Disposal Procedures in Accordance with 10 CFR 20.2002, June 20, 2001 3-9 Letter from U.S. Nuclear Regulatory Commission to Consumers Energy, Big Rock Point, Environmental Assessment and Finding of No Significant Impact Related to Request for Approval of Proposed Disposal Procedures in Accordance with 10 CFR 20.2002, December 3, 2001 3-10 Letter from U.S. Nuclear Regulatory Commission to Consumers Energy, Big Rock Point, Proposed Disposal Procedures in Accordance with 10 CFR 20.2002 (TAC NO.

MB 1463), February 5, 2002 3-11 U.S. Nuclear Regulatory Commission NUREG-0554, Single-Failure-Proof Cranes for Nuclear Power Plants, January 1979 3-12 U.S. Nuclear Regulatory Commission NUREG-0586, Final Generic Environmental Impact Statement (FGEIS) on Decommissioning of Nuclear Facilities, August 1998 3-13 U.S. Nuclear Regulatory Commission NUREG-0586, Supplement 1, Generic Environmental Impact Statement (GElS) on Decommissioning of Nuclear Facilities, October 2002 3-14 U.S. Nuclear Regulatory Commission NUREG-0612, Control of Heavy Loads at Nuclear Plants, July 1980 Page 3-28

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 3, IDENTIFICATION OF REMAINING 9/27/2005 DECOMMISSIONING ACTIVITIES 3-15 U.S. Nuclear Regulatory Commission NUREG-1 700, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans, April 2000 3-16 U.S. Nuclear Regulatory Commission Regulatory Guide 1.16, Reporting of Operating Information - Appendix A, Technical Specifications, August 1975 3-17 U.S. Nuclear Regulatory Commission Regulatory Guide 1.179, Standard Format and Content of License Termination Plans for Power Reactors, January 1999 3-18 Letter from Consumers Energy, Big Rock Point to U.S. Nuclear Regulatory Commission, Request for Approval of Proposed Disposal Procedures in Accordance with 10 CFR 20.2002, September 15, 2004 3-19 Letter from U.S. Nuclear Regulatory Commission to Consumers Energy, Big Rock Point, Approval of Proposed Revision to Disposal Procedures in Accordance with 10 CFR 20.2002 (TAC No. L52096), January 19, 2005 Page 3-29

-

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 9/27/2005 TABLE OF CONTENTS 4.0 SITE REMEDIATION PLAN .......................................................... 1i

4.1 INTRODUCTION

........................................................... 1 4.1.1 Purpose ........................................................... 1 4.1.2 Scope ........................................................... 1 4.2 REMEDIATION ACTIONS ........................................................... 2 4.2.1 Structures, Systems and Components ........................................................... 2 4.2.2 Soil and Water ........................................................... 3 4.3 REMEDIATION ACTIVITY IMPACT ON THE RADIATION PROTECTION PROGRAM ........................................................... 8 4.3.1 Commitment to Radiation Protection Procedures ...................................................... 8 4.4 ALARA EVALUATION .......................................................... 10 4.4.1 Dose Models .......................................................... 10 4.4.2 Methods for ALARA Evaluation .......................................................... 10 4.4.3 Remedlation Methods and Cost .......................................................... 10 4.4.4 Remediation Cost Basis .......................................................... 11 4.5 UNIT COST ESTIMATES .......................................................... 11 4.5.1 Waste Disposal Cost .......................................................... 12 4.5.2 Worker Accident Costs .......................................................... 13 4.5.3 Worker Dose .......................................................... 13 4.5.4 Labor Costs .......................................................... 13 4.5.5 Equipment Costs .......................................................... 13 4.5.6 Schedule Delay Cost ........................................................... 14 4.6 PRESENT WORTH OF FUTURE COLLECTIVE AVERTED DOSE ............................. 14 4.7 ALARA CALCULATION RESULTS ........................................................... 14 4.7.1 ALARA Cost Benefit (Concentration/DCGL) for Soil Excavation ............................. 15

4.8 REFERENCES

.......................................................... 16 APPENDICES 4-A ALARA Calculations .4A-1 4-B Soil Remediatlon Cost Data .4B-1 4-C-1 Screening Level Calculations .4C-1 4-C-2 Site-Specific DCGL Calculations .4C-3 4-D Average Soil Radionuclide Concentrations for Big Rock Point .4D-1 Page 4-i

BRP LICENSE TERMINATION PLAN Revislon 2 CHAPTER 4, SITE REMEDIATION PLAN 9127/2005 4.0 SITE REMEDIATION PLAN

4.1 INTRODUCTION

This section of the License Termination Plan (LTP) describes remediation actions proposed for use in the decommissioning of Big Rock Point (BRP). In accordance with 10 CFR 20, Appendix 4-B, remediation will assure that dose less than or equal to the annual dose limit of 25 mrem/year, reduced to as low as reasonably achievable (ALARA), is met for the critical population group. Inaddition, the portion of this dose attributable to drinking water sources has been subtracted from the dose available to radionuclides in soil in the calculation of site-specific Derived Concentration Guideline Level (DCGL). License Termination Plan Section 6.8.2 provides a complete discussion of site-specific DCGL derivation. Remediation will be perfomied under the Radiation Protection Program in a manner that will assure that both worker doses and environmental doses will be ALARA.

4.1.1 Purpose This remediation plan describes the use of characterization data to define the requirements for remediation, projected remediation volumes, and methods to be utilized to reduce site soils to levels that will allow the Greenfield site to meet unrestricted release criteria.

4.1.2 Scope This remediation plan addresses current and planned remediation actions for soil and water at BRP, as well as remediation that may be performed on sediments in portions of the plant discharge canal. Because the site is intended to be released after the removal of all aboveground and most belowground structures, (see LTP Section 4.2), this remediation plan addresses only briefly the activities involved with structures, systems and components (SSCs). Further description of previous and future decommissioning activities involving SSCs may be found in LTP Chapter 3, Identificationof Remaining Site DismantlementActivities.

Remediation of soils has occurred as a normal course of business at BRP, both during and following the plant operational phase. Early remediation has served to limit both lateral and vertical spread of residual radioactivity with time. However, residual radioactivities in areas of high dose rate, and in areas inaccessible to workers during power operations, have remained for future remediation. This plan focuses on current and future remediation actions. Past remediations are described in Appendix 2-B of LTP Chapter 2, Site Characterization.

This section also discusses BRP's commitment to health physics procedures and approved work practices applicable to remediation, in order that worker health and safety is assured, and releases of radioactive materials to the environment are minimized. It also addresses ALARA for dose to the public following unrestricted site release.

Page 4-1

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 9127/2005 4.2 REMEDIATION ACTIONS The BRP site will be decommissioned to the Greenfield definition provided in LTP Section 1.5. All equipment, buildings and structures, including subsurface foundations, are expected to be removed, either as material meeting unrestricted release criteria, material meeting the requirements of the BRP 10 CFR 20.2002 license requirements for disposal of demolition debris, or material that requires disposal as radioactive waste [Reference 4-5]. Soil and groundwater, as the only materials remaining at the time of site release, are the only materials that are subject to remediation.

NUREG-1 700, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans, guidance for the content of LTP Chapter 4 calls for discussion of activities involving remediation of all structures with residual radioactivity levels in excess of unrestricted use limits [Reference 4-8]. Due to the Greenfield definition, no structures will be remediated for release with the site. Consequently, specific discussion is limited to remediation considerations for surface and subsurface soil, and surface and subsurface groundwater at this site. However, general discussion of SSCs dismantlement activities is provided in LTP Section 4.2.1 and in LTP Chapter 3.

Soil remediation may be initiated as residual radioactivity is identified in areas accessible for safe and effective remediation. If an area is not immediately available, remediation may be initiated when the area becomes available due to structure removal, when dose rates from surrounding activities and facilities are ALARA, and when the area can be adequately protected from recontamination. The approximate schedule for completion of soil remediation in various areas is linked to the schedule for final status surveys. This schedule is provided in LTP Section 5.8.2.6 and summarized in Table 5-11. Figure 3-2 of this LTP illustrates the relationships among demolition and remediation activities, remediation surveys and the Final Status Survey (FSS). These schedules are meant to illustrate the general order and duration of activities, and are not to be taken as licensing commitments.

4.2.1 Structures, Systems and Components All equipment, components and structures, including subsurface foundations, but excluding an onsite septic drainfield and the plant intake water pipe, will be removed rather than undergo remediation'. The drainfield is being retained in place, with the concurrence from local and state health officials. The drainfield is in an impacted area, but characterization studies show that it will meet site release criteria without remediation. The plant intake water pipe will be plugged and retained in place in order to minimize environmental impact. The intake water pipe is a non-impacted structure and exists predominately in public waters.

Facilities supporting the ISFSI will remain on site until after spent fuel has been transported to a permanent federal repository.

Page 4-2

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 912712005 Following system and component removal, contaminated structures are removed in a general sequence of perimeter buildings first, followed by the Containment Building and support facilities. The Containment Building's steel sphere will remain in place until the major sources of contamination, including fuel pool structure, reactor vessel and reactor bioshield, either have been removed, or have been packaged for shipping. This sequence assures that radioactive materials are appropriately protected against uncontrolled release to the environment during the dismantlement process. Table 3-3 of this LTP provides projected dates for future decommissioning activities.

To the extent possible, structures are to be decontaminated to safe levels and/or environmental controls have been evaluated and implemented prior to demolition.

This serves to limit the possibility of environmental residual radioactivity and also aids in maximizing the amount of material that may be disposed of by unrestricted release or as industrial demolition debris under the provisions of the NRC approved10 CFR 20.2002 alternate disposal procedure request (Reference 4-5]. Structures or portions of structures are subsequently removed, evaluated as required, and shipped to the appropriate disposal facility. Soils uncovered by these activities are surveyed and remediated, as necessary, prior to backfill. Soils with radionuclide concentrations higher than acceptable for retention on site (higher than DCGL for the mixture) will be packaged and shipped for disposal as radioactive waste.

4.2.2 Soil and Water Considering the 35-year operating history of BRP, relatively little soil contamination has occurred. Factors that have mitigated residual radioactivity external to the containment sphere are discussed in LTP Section 2.2.4.2. However, one significant event of groundwater contamination occurred due to leakage of approximately 20,000 gallons of steam condensate from the Condensate Storage Tank in 1984.

Details of this event are provided in LTP Section 2.2.5.3.d.3. Other liquid spills also occurred as identified in LTP Chapter 2, but all were much less significant Analyses of water samples from groundwater monitoring wells (1 994-present), numerous samplings of groundwater obtained by core borings through the Turbine Building and Containment floors, and water samples from excavations during ongoing demolition activities, have identified only tritium to be present above environmental LLDs (lower limits of detection).

4.2.2.1 Soil Several areas exist where sampling has shown that limited residual radioactivity levels could be present in soils above site-specific DCGLs. Remediation activities completed as of June 30, 2005, include the Solid Radwaste Vaults, Pipe Tunnel, and Plant Discharge Canal. Remediation of these areas are consistent with the original plans as summarized below. The areas with sufficient residual radioactivity to warrant consideration as candidates for remediation are [Reference 4-2]:

Page 4-3

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 912712005

1) West of and Beneath Turbine Building This area has been affected by past leaks from the outside Condensate Storage Tank. Although some soil was removed following the incidents during the plant operational phase, the volume of soil still requiring remediation is estimated to be approximately 10 cubic meters. Ratio of Cs-1 37 to Co-60 from soil samples in this area is approximately 200.

2) Pipe Tunnel, South of Containment Building Expansion joints and penetrations through the floor allowed condensed liquid from steam leaks to soak into soil beneath the pipe tunnel floor in the area adjacent to the Containment Building on its south side. There also were other recorded incidents of contamination in this area (see Appendix 2-B of Chapter 2). The volume of soil estimated to require removal is approximately 30 cubic meters. Ratio of Cs-1 37 to Co-60 from soil samples in this area is approximately 0.05.

3) North of Condensate Storage Tank An area west of the Turbine Building and north of the Condensate Storage Tank location that was affected by Waste Hold Tank overflows and possible contamination from radioactive filters and resins during transfer from the Liquid Waste Vaults (the vaults are just east of the residual radioactivity area). This area has been partially remediated in the past, but is still estimated to require removal of approximately 40 cubic meters of contaminated soil. Ratio of Cs-137 to Co-60 from soil samples in this area is approximately 20.

4) Plant Discharge Canal The area to be remediated is approximately 600 square meters. Residual radioactivity averages less than 15 cm deep into sediments that lie interspersed with and in some low flow areas, on top of, cobble. Remediation of contaminated sediment is expected to result in approximately 30 cubic meters of waste. This area has been impacted by permitted discharge into Lake Michigan, and currently is under water. However, due to the Greenfield objective of returning the lakeshore to original contours, the current deep area adjacent to the plant may be filled. The filled area would be accessible by the public at the current low water level of Lake Michigan. The purpose of remediation would be to treat the area as if it were part of the plant site. Ratio of Cs-1 37 to Co-60 from sediment samples in this area is approximately 0.6.

5) Other Potential Areas An estimate for all additional potential, but yet unidentified residual radioactivities above site-specific DCGLs, has been made based on a residual radioactivity depth of 15 cm for 200 square meters of subsurface foundation area (30 cubic meters). This volume includes foundation areas not yet available for characterization, including a suspect area beneath the Liquid Page 4-4

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 912712005 Radwaste Vault where high dose rates have not allowed core borings to be obtained directly through the floor to this point in time. Ratio of Cs-137 to Co-60 in these areas is assumed to be at the site-wide soil average of approximately 1.2.

Based on the known and potential residual radioactivity areas described above, the total soil volume that contains at least some residual radioactivity above site-specific DCGLs is expected to be approximately 150 cubic meters. Residual radioactivity in soil above the site-specific DCGLs will be removed from the above areas, (and any other locations which may later be found greater than site-specific DCGL concentrations), and will be disposed of as radioactive waste. Where appropriate, site excavation procedures, work permits, and other appropriate site requirement documents will address dewatering, analysis and disposition of liquids accumulating within excavations, control of dust, control of contamination, safety requirements, and other constraints. As needed, additional investigations will be performed to ensure that any changing soil residual radioactivity profile during the remediation actions is adequately identified and addressed [Reference 4-61.

Soil remediation equipment will include, but not be limited to, back and track hoe excavators, front-end loaders and hand digging. As practical, when the remediation depth approaches the soil interface region for unacceptable and acceptable residual radioactivity levels, a squared edge excavator bucket design or similar technique may be used. This minimizes the mixing of contaminated soils with acceptable lower soil layers as would occur with a toothed bucket. However, due to the cobbly nature of many plant soils, toothed buckets or hand digging may be required where residual radioactivity occurs in the vicinity of imbedded cobble and rocks.

The site characterization process has established the location and extent of residual radioactivity in soil. Details may be found in Chapter 2 of this LTP. However, it should also be noted that soil volume estimates (or implied volumes of soil used in LTP Chapter 6, Compliance with the RadiologicalCriteria for License Termination, dose calculations, etc.) may vary slightly from section to section.

Depth profiles have shown that residual radioactivity in soils greater than site-specific DCGLs do not extend deeper than 0.30 meter except for one sample in vicinity of the waste hold tank leaks and two isolated samples in the pipe tunnel. In each case, nearby samples did not detect deep residual radioactivity. Thus, the extent of subsurface residual radioactivity is known to be very limited. However, local residual radioactivity not detected by core samples performed to date may be found when foundations or subsurface piping are removed. While these and other excavations are open, evaluations will be performed by use of sampling, scanning, in situ measurements, or other approved method defined by plant procedures, to assess the need for remediation. License Termination Plan Section 5.4 discusses soil sampling and survey methods.

Page 4-5

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 912712005 4.2.2.2 Groundwater Tritium exists in groundwater as described in Sections 2.4.5.3 and 6.8.2.1 of this LTP. However, at the current time, no tritium above the Environmental Protection Agency (EPA) drinking water guidelines has been detected in the aquifer suitable as a drinking water supply (maximum detected in the potential drinking water aquifer is 1560 pCVI, well below the EPA guideline of 20,000 pCi/A). Twenty monitoring wells are utilized to monitor for tritium and other potential radionuclides in groundwater.

No radionuclide other than tritium has been detected in groundwater at greater than environmental LLD levels [Reference 4-4].

Inthe latter part of 2002, samples were taken of soil and water beneath the Turbine Building slab during the removal of an equipment drain. The water contained tritium at levels, corrected for decay, evaluated to be consistent with those originally present in the condensate tank at the time of the leak in 1984. The water has been trapped within a sub-floor vault support foundation within the Turbine Building that was originally filled with dry sand (see Section 2.4.5.3.c). Hydrostatic pressure generated by the condensate system leak has caused tritiated water in-leakage along pipe penetrations that pass through this structure. The sub-floor vault area has held the condensate water in place and has intermittently released small amounts into the environment as a result of localized fluctuations in water table conditions.

Removal of this tritium source term beneath the Turbine Building was a phased process and has been completed as described below:

Phase One: Removed tritium contaminated water by conventional pumping in all areas below the Turbine Building identifying tritium concentrations above the EPA drinking water standard of 20,000 pCiAI.

Phase Two: Removed all available free water trapped inside the sub-floor vault by vacuum extraction.

Phase Three: Removed soil and residual water from the sub-floor vault prior to removal of the Turbine Building foundation. This effort removed the tritium source term and served to protect the environment from potential contamination during subsurface demolition and foundation removal.

Phase One dewatering in the Turbine Building began in April 2003 by intervals of low capacity pumping separated by periods in which water levels were allowed to recover. This effort was conducted over an approximate 6-month period and terminated when well production in the sub-floor vault area became insufficient for standard water removal methods.

A remediation vendor was contracted to perform the Phase Two removal of residual water remaining within the sub-floor vault by means of vacuum assisted recovery.

Drop pipes were placed in 14 locations near the sub-floor elevation and connected by manifold to a diesel driven vacuum pump. The vacuum recovery process, conducted during December 2003, effectively removed all available free water from the sub-floor vault area. To date, 6,300 gallons of tritiated water have been removed Page 4-6

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 912712005 from 14 sample/extraction wells installed within the sub-floor vault and 18,000 gallons have been removed from 15 sample/extraction wells in other Turbine Building areas within the contaminant migration pathway. Tritium concentration in all sample locations outside the sub-floor vault have been reduced to levels below the EPA drinking standard (20,000 pCi/I).

The Turbine Building and Containment structures cover an area of approximately 2800 m2 and have foundations that extend to a maximum depth of 11 m (35 feet).

When these foundations are removed, the excavation will encompass a total volume of over 30,000 m3 and will include temporary removal of both shallow and intermediate groundwater zones at this location. Soils that are excavated in support of foundation removal will be subject to final status survey in accordance with LTP, Section 5.4.2.4. Soil volumes exceeding the release criterion will be disposed of as radiological waste. Foundation materials will be surveyed, then handled as radiological waste or under procedures that implement the approved 10 CFR 20.2002 process, as appropriate.

A comprehensive dewatering system, located inside the Industrial Area, installed to maintain excavation conditions as dry as possible for worker safety. This system includes construction of a slurry wall to isolate excavated areas from shallow groundwater intrusion and placement of wells to dewater the shallow and intermediate groundwater zones. Dewatering activities will continue to reduce tritium concentrations in the shallow and intermediate groundwater zones. Groundwater collected from the dewatering process will be pumped to a retention basin for sediment collection and then released under provisions of the Big Rock Point Offsite Dose Calculation Manual (ODCM) and state and local surface water discharge regulations.

Following the FSS of the excavated area, this location will be backfilled and returned to grade elevation. The slurry wall will be breached to reestablish northerly groundwater flow conditions. Monitoring for potential contaminants will continue to be performed in all three groundwater strata until the FSS is complete to insure that radioactivity concentrations are known and fully within the bounds of the allowable dose requirements for site release.

The EPA guideline of 20,000 pCi/I does not apply to water confined in subsurface structures beneath the Turbine Building and Containment, or within the upper or intermediate groundwater zones, all of which are unsuitable by health standards as a potable water supply. However, no groundwater monitoring wells show tritium concentrations greater than 20,000 pCi/l. This assures that these water sources will not eventually reach the deeper potable supply at concentrations capable of elevating that aquifer to or above the EPA guideline value.

4.2.2.3 Surface Water No radionuclides of plant origin have been detected in surface water at the plant site, other than those detected in samples taken at the discharge weir during permitted release of liquid batch discharges to the discharge canal. Consequently, no remediation of surface waters is required.

Page 4-7

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 9/2712005 4.3 REMEDIATION ACTIVITY IMPACT ON THE RADIATION PROTECTION PROGRAM The Radiation Protection Program approved for decommissioning is similar to the program in place during 35 years of commercial power operation. During power operations, contaminated SSCs were decontaminated in order to perform maintenance or repair actions and contaminated soils were removed to prevent further spread of contamination into the environment. The techniques were similar to those being used for decommissioning. Many components were removed and replaced during operation. The techniques used for component removal did not differ significantly from those being used during decommissioning. However, chemical decontamination and radioactive decay both allow component removal at lower dose levels than observed during the plant operational period. Reactor system chemical decontamination at BRP was performed immediately after final shutdown.

Subsequent component removal and dismantlement activities have been performed at much lower dose rates than would have been present otherwise.

The BRP Radiation Protection Program adequately controlled radiation and radioactive contamination during power operation, although plant age and design provided significant challenges to the limitation of worker dose. Since shutdown, dose rates have been lowered by chemical decontamination, and ALARA engineers have been able to plan major personnel dose evolutions such as reactor vessel and bioshield removal late in the decommissioning schedule. At these later dates, radioactive decay of activated materials (primarily Co-60) has lowered component dose rates another 50%. The combination of these factors has greatly improved the plant's ability to limit personnel exposure to radiation. Consequently, Radiation Protection Program effectiveness has improved for decommissioning in comparison to power operations.

With specific reference to soil remediation, application of the Greenfield definition for site release is seen as a major factor in reduction of worker dose. With removal of equipment and structures from an area prior to major soil remediation efforts, only the radioactive materials within the soil remain present as a source of radiation exposure to the remediation worker. Since average concentration of soil radioactivity is well below the DCGL, worker doses are minimal under such conditions.

4.3.1 Commitment to Radiation Protection Procedures Big Rock Point intends to continue under its Part 50 license throughout the decommissioning process. Radiation Protection procedures are required under the Defueled Technical Specifications for implementation of the requirements of 10 CFR 20. The Defueled Technical Specifications, in conjunction with the requirement for maintaining an Offsite Dose Calculation Manual (containing relocated technical specifications), also specify requirements for effluent controls, environmental monitoring, reporting requirements, and limitation of offsite dose within the guidelines of 10 CFR 50, Appendix I.

Page 4-8

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 912712005 Radiation Protection procedures developed and utilized during plant operation continue to be utilized for the protection of plant and contract personnel, and for protection of the environment. Changes and additions to these procedures, to improve applicability to specific circumstances during the decommissioning process, are made under plant administrative controls that include appropriate reviews and approvals. Training and instructions provided to plant and contract workers follow the requirements of 10 CFR 19.12, and reports of personnel exposure are provided pursuant to the applicable sections of 10 CFR Parts 19 and 20. The requirements of these regulations are implemented by means of plant procedures.

4.3.1.1 Remediation Procedures Procedures applicable to remediation of soils during plant operation have been found to be equally applicable to use during decommissioning, although the criteria for extent of remediation has changed. During plant operation, various ALARA and cost criteria were used to determine the extent of remediation. For decommissioning, criteria for release of an area specifically for the FSS are in accordance with criteria for survey area turnover (see LTP Section 5.1.3.2). In general, remediation will not be considered complete for decommissioning purposes until the sum of the DCGL fractions is shown to be less than 1.0 for Class 1 and Class 2 survey areas and less than 0.5 for Class 3 areas. Remediation surveys are discussed in LTP Chapter 5, Final Status Survey Plan.

The soil remediation process begins with a remediation area walkdown and subsequent evaluation of appropriate work processes necessary to assure worker safety, environmental protection and effective removal of residual radioactivity. Deep excavations require consideration of need for shoring or alternatively, requirements for angle of slope, dependent on soil type, to avoid cave-in. Potential need for personnel monitoring and engineering controls to limit inhalation and airborne environmental release is assessed, as is the need for controls to prohibit or limit contamination spread into or out of the excavation by other means, such as by surface water flow or transfer by equipment. Potential for the presence of subsurface installations such as piping or electrical conduit is evaluated. Based on these and other inputs, a work plan is developed, along with any radiation work permit(s) necessary for the work to be performed.

The processes of soil handling and analysis for excavated soils are described in LTP Section 5.4.2.4. LTP Section 5.4.1 provides descriptions of instruments and survey methods applicable both to remediation and FSS activities. Approved procedures are utilized for all such activities.

No unique safety or remediation issues have been identified associated with remediation of soil or groundwater at BRP. As described above, decommissioning remediation processes and procedures are similar to those utilized during plant operation, but differ in terms of endpoint of remediation. Consequently, decommissioning remediation work is coordinated closely with FSS personnel in order to ensure appropriate monitoring and control of excavated materials and the Page 4-9

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 9/27/2005 level of remediation required for the specific area (see LTP Sections 5.3.6.4 and 5.3.6.5). At the conclusion of the remediation process, FSS personnel perform a walkdown of the remediated area, and the area may be turned over for final survey, as appropriate.

4.4 ALARA EVALUATION As described in LTP Chapter 6, dose assessment scenarios were evaluated for the residual radioactivity that could remain in soils. The ALARA analysis is conservatively based on a modified resident farmer scenario. The resident farmer critical group applies to existing open land areas and all site areas where standing buildings have been removed.

4.4.1 Dose Models As discussed above, the critical group for BRP under the Greenfield definition is the resident farmer. Accordingly, the ALARA evaluations for remediation actions in this section use the parameters for population density, evaluation time interval, monetary discount rate and area that are applicable to the resident farmer scenario.

4.4.2 Methods for ALARA Evaluation NUREG- 727, Decommissioning Standard Review Plan, Section 7.0, ALARA Analysis, states Licensees or responsible parties that remediate building surfaces or soil to the generic screening levels established by the NRC staff do not need to demonstrate that these levels are ALARA" [Reference 4-71. The DCGLs for BRP soil are site-specific values. Approximately half of the site-specific DCGLs are below the generic screening levels and half above. Appendix 4-C-1 includes screening levels, and Appendix 4-C-2 includes site-specific DCGLs for the radionuclides present in BRP soils. Chapter 6 of this LTP provides details on the BRP site-specific DCGL derivation. Because some of the site-specific DCGLs exceed screening level values, BRP is conservatively providing an ALARA evaluation of the remediation actions for soil.

The ALARA evaluations were performed in accordance with the guidance in NUREG-1727. The dose contribution of each radionuclide in the BRP mixture was evaluated and the contributions summed. The principle equations used for the calculations are presented in Appendix 4-A. The evaluation determines if the benefit of the dose averted by the remediation is greater or less than the cost of the remediation. When the benefit is greater than the cost, additional remediation is required. Conversely, when the benefit is less than the cost, remediation is not required beyond the point that the average member of the critical population group would receive 25 mrem/year.

4.4.3 Remediation Methods and Cost Remediation methods and costs for other than soil remediation are not applicable to BRP, due to the plant's commitment of restoration to a Greenfield condition.

Additional information on the restoration process is provided in LTP Chapter 3.

Groundwater remediation is discussed in LTP Section 4.2.2.2.

Page 4-1 0

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 9127/2005 4.4.4 Remediation Cost Basis Unit costs for soil excavation are established for 150 m3 of contaminated soil excavated and shipped from the site, and also for a lower volume of 33 M3. The larger volume of 150 m3 represents soil at the average concentration of contaminated soils measured in the characterization analyses (average concentration for the total mixture of radionuclides is approximately 1.6 pCi/g, per Case 1 of Appendices 4-C-1 and 4-C-2). Description of component areas and volumes is provided in LTP Section 4.2.2. The lower volume of 33 M3 is commensurate with removal of only the small volumes of residual radioactivity where the sum of the site-specific DCGL and screening level fractions of the individual nuclides equals unity for the shipped mixture, or approximately 7 pCi/g, per Case 2 of Appendices 4-C-1 and 4-C-2. The 150 M3 and 33 i 3 soil volume cases are presented here, as Case 1 and Case 2, respectively (see Section 4.5), to illustrate the variations in costs and benefit as a function of volume. Remediation volumes from BRP are likely to be nearest 150 i 3, and are not expected to be less than 33 M3 . If volumes greater than 150 m3 are generated, the cost/benefit ratio will remain above unity: the calculations show that the larger the volume, the greater the cost/benefit ratio.

Soil remediation unit costs (dollars per cubic meter) were determined for methods appropriate to the volumes removed. Power excavation equipment and/or hand shoveling are employed in contaminated soils removal. Non-radioactive materials such as rocks and cobble may be separated out either during the excavation process or later. For sediments, dewatering has been used to meet shipping requirements.

In each case, the costs are based on the net volume of soil shipped for disposal.

Certain activities which are wholly or partially attributable to other decommissioning activities, such as removal of asphalt paving, foundations and floors of buildings, and excavation of soils over subsurface pipes and drains, are not included in the cost of remediation, since these activities would be undertaken whether or not soils in the area were contaminated. Likewise, dewatering activities are excluded, since dewatering is routinely performed to assist in safe removal of subsurface structures, as well as to assist in radiological surveys and remediation, when required.

Dewatering small volumes of tritium trapped by underground structures has not been found to be a significant cost factor, so this also is excluded.

Residual radioactivity reduction, based on total quantity of radioactivity removed, is assumed at 95%. The formulas associated with the cost elements are provided in Appendix 4-A, and the cost elements themselves are listed and further described in Appendix 4-B.

4.5 UNIT COST ESTIMATES In order to perform ALARA evaluations, unit cost values are required. These values are used to perform the NUREG-1 727 cost-benefit analysis. Two cases were investigated:

Case 1 Soil at the average concentration of radionuclides identified by characterization studies to date, (150 m3), and Page 4-11

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 9/2712005 Case 2 Soil at the generic screening and site-specific DCGL levels for the mixture of radionuclides identified by characterization. This total nuclide concentration is approximately a factor of 4.5 times as high as the mean identified for the 150 m3 case, and thus represents a volume of 1/4.5 =

0.22 times 150 M3, or 33 M3 .

For Case 1,the most significant cost factors are the soil excavation cost factor, at

$1808/M3 , and the waste disposal cost factor, at $1349/M 3. Total cost factor is

$3192/M3 . These are provided in Appendix 4-B, along with associated component costs and appropriate reference bases.

For Case 2, unit excavation cost is lower ($887/M 3 ) due to lower power equipment utilization, and disposal costs are greater ($23981m3) because the higher radionuclide concentrations require a greater fraction of waste to be shipped to Envirocare in the state of Utah. Total unit cost for this case is $3340/mn. Further description of these costs follow, and a summary of data for both cases is provided in Appendix 4-B.

4.5.1 Waste Disposal Cost Round triD truck transportation:

Clive, Utah (Envirocare site) round trip: 5140 km.

Oak Ridge, TN round trip: 2830 km Average distance = 3985 km Case 1 Disposal Cost:

The BRP contract for soil disposal is $X per pound, if sent to Utah, and $Y per pound, if meeting criteria for disposal at Oak Ridge.

1.6 kg/liter of soil, or (f1)(11,600 kg/m3)(0.454 lb/kg) ($X/lb) = (726.4)(f 1)($X)/m 3 1.6 kg/liter of soil, or (f2)(1,600 kg/M3)(0.454 lb/kg) ($Y/lb) = (726.4)(f,)($y2/M3

$1,349/mr Note: X and Y are proprietary values defined by negotiated contract; f, and f2 are fractions of waste sent to Utah and Tennessee, respectively.

Case 1 Accident Cost:

Volume of 13.6 M3 of soil per truck shipment, per NUREG-1727, Table D2, with average distance of 3985 km/ round trip, total miles for 150 M3 (11 trips) equals 43,800 km. Rail transport for soil is not anticipated due to the small volumes of soil involved. The distance and haul volume are used for determining transport accident cost in accordance with NUREG-1727, Appendix D, (Equations D6) and the fatal accident rate of 3.8E-08/km given in NUREG-1727, Table D2.

Transport accident cost totals $5,000.

Page 4-12

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 9127/2005 Case 2 DisDosal and Accident Costs Due to the higher concentrations, more waste is assumed sent to Clive, Utah. Unit cost, calculated as for Case I above = $2398/M 3 Three truckloads, conservatively assuming a haul distance of 5140 km = 15420 km:

Transport accident cost totals $1,758.

4.5.2 Worker Accident Costs To determine worker accident cost in accordance with NUREG-1 727 Appendix D, the accident rate of 4.2E-08/hour was applied to NUREG-1727 Equation (D5). The hours used for labor cost, times number of field workers on a crew, were used for worker accident cost. Accident cost of $60 for Case 1 and $30 for Case 2 are not significant contributors to total cost.

4.5.3 Worker Dose Costs associated with worker dose are a function of the hours worked and the workers' radiation exposure for the task. Slightly elevated background dose rates, with an average of 0.5 mrem/hour are used for all soil remediation activities. This low value reflects soil remediation and removal of structures and equipment in accordance with the Greenfield definition. Therefore, dose rates are significantly reduced. At $2000 per person-rem, this cost totals $474 for Case I and $236 for Case 2.

4.5.4 Labor Costs Manpower cost assumptions are based on contracts established with the principle site contractors and for Consumers Energy site personnel. Appendix 4-B utilizes an hourly cost for the remediation crew of $180/hour in Case 1 and $160/hour for Case 2. These crew rates assume a manual labor rate of $35/hour and technician, supervisory and specialized equipment operator rates of $50/hour. Engineering and technical support costs are included as identified in Appendix 4-B. Unit labor costs are $237/m3 for Case 1 (high equipment utilization) and $402/M 3 for Case 2 (predominantly manual labor with lower volume productivity).

4.5.5 Equipment Costs Hand tools, power excavation equipment, and underwater sediment removal equipment are among the tools that may be utilized for soil remediation. Total cost of $210,700 is calculated for this cost category in Case 1. A cost of $1000 is included for equipment mobilization in Case 1 and $500 is included for Case 2. The bulk of Case I equipment cost derives from the underwater sediment removal activities at the discharge canal. Case 1 unit cost is $1405/M 3 . For Case 2, there is limited powered land excavation, but no underwater work. Backhoe and loader costs are $100/hour and dump trucks $50/hour, excluding the $50/hour operator cost that is assigned to labor costs, above. Equipment utilization cost of $16,000 is assigned for Case 2 and equipment unit cost is calculated to be $485/M 3 .

Page 4-13

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 9/27/2005 4.5.6 Schedule Delay Cost A contract clause requires payment of fees for certain delays in schedule. A total delay cost of $25,000 is assumed for Case 1. The type of delay most likely to occur is assumed to be that of major equipment availability, either due to delivery problems, or operability problems during use. No delay charges are assumed in Case 2, since hand digging and small equipment operations are less likely to have major impact on schedule.

4.6 PRESENT WORTH OF FUTURE COLLECTIVE AVERTED DOSE The remediation cost of $3192/M3 derived for soil in Appendix 4-B for Case 1 and

$3340 for Case 2 was compared to the benefit of the dose averted through the remediation action. As noted earlier, activity concentration in the lower volume (33 M3) Case 2 is a factor of approximately 4.5 times as high as in Case 1. The benefits of averted dose were calculated using Equations Di and D2 in NUREG-1727 as modified to account for multiple radionuclides as presented in Equation A-2 of this LTP Section. Appendices 4-C-1 and 4-C-2 provide spreadsheet tables of these calculations for both volumes against NRC screening levels and site-specific DCGLs, respectively. The averted dose, being proportional to excavated soil concentration, also is a factor of approximately 4.5 times higher for Case 2 than for Case 1. It is conservatively assumed that the soil is spread over a 10,000 mi2 area, 15 cm thick in both cases, even though there would not be enough soil to actually meet this condition.

The parameters used in the equations were taken from NUREG-1727, Table D2, as suitable for the resident farmer scenario. The calculation of present worth of the future collective averted dose was performed in Case 1 for the observed average total concentration equaling 1.6 pCi/g, with individual nuclides included as low as 0.0093 pCi/g (Sr-90) [Reference 4-1]. Concentration inputs are shown in the spreadsheets of Appendices 4-C-1 and 4-C-2. Results of all radionuclides are summed. Based on NRC default screening levels, a value of $415 is obtained for the total benefit from the collective averted dose in Case 1 and $1888 is obtained for Case 2. Based on site-specific DCGLs, a value of $404 is obtained for the total benefit from the collective averted dose in Case 1 and $1719 is obtained for Case 2.

4.7 ALARA CALCULATION RESULTS The total remediation cost may be compared with the benefit from the collective averted dose using Equation D8 from NUREG-1727. This equation is presented in Appendix 4-A as Equation A-2. The calculational inputs and outputs are presented in Appendix 4-C-1 for screening levels and in Appendix 4-C-2 for site-specific DCGLs.

Page 4-14

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 9127/2005 4.7.1 ALARA Cost Benefit (Concentration/DCGL) for Soil Excavation Due to high removal and shipping costs, excavation of the expected quantities of soil from the site show that the residual radioactivity is ALARA at both the site-specific DCGL and generic screening level for the mix without additional actions in either Case 1 or Case 2. A farm resident population of four individuals on areas of 10,000 m2 is assumed for each of the cost/benefit calculations. However, at a contamination depth of 0.15 m, the 150 m3 volume (Case 1) would cover only 10% of this area and the 33 m3 volume (Case 2) would cover only approximately 2.2% of this area. Use of these fractions would reduce dose and each of the cost/benefit ratios given below would be increased. Such increased values would provide increased support that concentrations need not be reduced below either the site-specific DCGLs or the generic screening levels to be ALARA.

For Case 1, a Concentration/DCGL value of $478,800/$415 = 1154 is obtained with plant soil concentrations evaluated against the surface soil screening values from NUREG-1727, Table C2.3. When evaluated against site-specific DCGLs, the value is $478,800/$404 = 1185.

For the 33 m3 soil excavation volume (Case 2), the screening level case gives

$110,223/$1888 = 58.4 and the site-specific DCGL case gives $110,223/$1719 =

64.1.

Since the Concentration/DCGL values are greater than one for all cases of soil remediation, remediation below the 25 mrem/year dose limit is not justified. It is observed that the cost/benefit ratio is lower for smaller volumes of higher activity concentration and increases with larger volumes of lower activity concentration.

It should be noted that all calculations in this LTP chapter equate both the generic screening levels and the site-specific DCGLs to 25 mrem/year. This conforms to the guidance in NUREG-1727. However, 25 mrem/year gives slightly conservative doses for specific concentrations of radionuclides in soil at BRP since, as described in Section 6.8.2 of this LTP, site-specific DCGLs for BRP soils are based on an annual dose of 24.219 mrem/year. This lower dose basis compensates for a conservatively calculated annual dose of 0.782 mremlyear from tritium in an aquifer that could be used as a future drinking water supply [Reference 4-3]. Validity of the ALARA cost/benefit analysis result is not affected by this minor difference.

Page 4-15

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 9127/2005

4.8 REFERENCES

4-1 Big Rock Point Engineering Analysis EA-BRP-SC-02-06, Surrogate Measurement of Hard-to-Detect Nuclides 4-2 Big Rock Point Engineering Analysis EA-BRP-SC-02-04, Radionuclides Present in Onsite Soil and Water 4-3 Big Rock Point Engineering Analysis EA-BRP-SC-02-05, Effect of Subsurface Soil and Water Contamination and the Development of Surface Soil DCGLs 4-4 Big Rock Point Offsite Dose Calculation Manual, Volume 25A,Section I, Procedural and Surveillance Requirements, (Relocated Technical Specifications) 4-5 Letter from U.S. Nuclear Regulatory Commission letter to Big Rock Point dated February 5, 2002, Big Rock Point Plant - Proposed Disposal Procedures in Accordance with 10 CFR 20.2002 4-6 U.S. Nuclear Regulatory Commission NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), August 2000 4-7 U.S. Nuclear Regulatory Commission NUREG-1727, Decommissioning Standard Review Plan 4-8 U.S. Nuclear Regulatory Commission NUREG-1 700, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans, April 2000 Page 4-16

BRPP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 9/2712005 APPENDIX 4-A, ALARA Calculations A.1 Present Worth of Future Collective Averted Dose The present worth of future collective averted dose may be estimated by use of Equation D2 of NUREG-1 727:

PW=(PD)(A)(O.025)(F)[ Cn 1 r+A (Equation A-1)

Where:

Pd = Population Density for Resident Farmer (0.0004/M 2)

A = Area of residual radioactivity (10,000 M2 ) for this resident farmer calculation 0.025 = Annual dose (remly) to the average resident farmer from residual radioactivity at the DCGL F = Fraction of the residual radioactivity removed by the remedial action.

Assumed equal to 0.95.

Conc = Average concentration of residual radioactivity being evaluated in units of pCVg of soil DCGL = Derived concentration guideline level that represents dose rate of 25mrem/year in pCi/g r = Monetary discount rate (0.030y 1')

= Radiological decay constant for a radionuclide in units of y-1 N = Length of time collective dose is calculated (1,000y)

Page 4A-1

BRPP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 9127/2005 APPENDIX 4-A. ALARA Calculations A.2 Concentration/DCGL Concentration/DCGL is the ratio of soil concentration to the derived concentration guideline that is calculated as a cost to benefit ratio for the remediation process. If the ratio exceeds 1.0, further costs are not justified for remediation to below 25mrem/year. If the cost-benefit ratio is less than 1.0, it is cost effective to reduce levels to a level below 25 mremlyear that gives a ratio of 1.0 or greater.

Equation D8 of NUREG-1 727 may be expressed for the summation of all nuclides as follows:

Conc

[

CostT (Equation A-2)

CL($2000)(PD)(0.025)(Dfi)(F)(A) 1 r +A,tj Where:

- (Conc/DCGL) 1 Df, = Dose Fraction = (Di) 1 {(Di) X,.(Conc/ DCGL)i D,= (25)(Conc/DCGL)i = annual dose contribution (mrem) from individual residual nuclide at site release This equals (25)(Df1) when the mixture is at the site-specific DCGL or generic screening level for the mix.

,(Di) = annual dose total from all residual nuclides in soil at time of site release (mrem).

And the remaining symbols are as defined for Equation A-1.

Df, relates dose of a single radionuclide of a mixture to total dose from the mixture. A mixture that will provide 25 mremlyear may be termed the mixture DCGL. Setting Df1 equal to 1.0 in this equation (thus reducing it to the equivalent of Equation A-1, rearranged for expression of ConcIDCGL) will result in a value of ConcIDCGL at the nuclide's observed concentration, rather than at the mixture's DCGL.

Page 4A-2

BRPP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 9/27/2005 APPENDIX 4-B, Soil Remediation Cost Data Case 1. Soil Excavation Remediation -150M 3 at observed average concentration Volume Evaluated For Unit Cost Determination: 150 M3 , Total mix conc. = 1.6 pCig Primary Crew Size: 3. Supervisor, 1; RP, 0.5; Laborers, 1; Equipment operator, 0.5 Support Personnel: 0.4. Resident and Schedule Engineers, 0.15; HP/ Environmental, 0.25 Hourly Cost: $180 Excavation Rate, including beneficiation: 1.9 m3/h Hours: 158 (150 m3 /1.9m /h)(2.0) [2.0 = contingency]

Labor Cost: $35,550 (Includes 25% for contingency and non-field support staff)

Equipment Costs: Land, $23,700; Underwater Equipment, $186,000 (consumables $3,100)

Mobilization Costs: $1000 Prime Contract Delay Cost: $25,000 Total Excavation Cost: $271,250 = $1808/ M3 Waste Generation: 150 m3 (5,300 ft3/35.315 ft3/m3)

Waste Disposal Cost: $202,000 ($1349/M 3)

Worker Accident Cost @158x3 hours = 2.OE-5 fatalities: $60 Per NUREG-1 727 Transportation Accident Cost @ 43,800 km (1.66E-3 fatalities by truck): $5000 Per NUREG-1727, Appendix D Worker Dose, 158 hours0.00183 days <br />0.0439 hours <br />2.612434e-4 weeks <br />6.0119e-5 months <br /> for 3 in field @ 0.0005 rem/hour: 0.237 person-rem = $474 Total Costs: $478,800 Cost per m3: $3,192 Case 2. Soil Excavation Remedlation - 33 m3 at default screening level or site-specific DCGL level for nuclide mix Volume Evaluated For Unit Cost Determination: 33 M3 , Total mix Concentration = 6.87 pCi/g Primary Crew Size: 3.8, Supervisor, 1; RP, 0.5; Laborers, 2; Equip Operator, 0.3 Support Personnel: 0.4, Resident and Schedule Engineers, 0.15; HP/ Environmental, 0.25 Hourly Cost: $160 Excavation Rate, with minor beneficiation: 0.8 m3/h Hours: 62 (33 m3 /0.8/ 31h)(1.5) [1.5 = contingency]

Labor Cost: $13,260 (Includes 25% for contingency and non-field support staff)

Equipment Costs: $15,500 (consumables $2,000)

Mobilization Costs: $500 Prime Contract Delay Cost: None Total Excavation Cost: $29,260 = $887/ m3 Waste Generation: 33 M3 (1165 ft3 /35.315 ft3/m3)

Waste Disposal Cost: $79,134 ($2398/M 3)

Worker Accident Cost @ 62 hours7.175926e-4 days <br />0.0172 hours <br />1.025132e-4 weeks <br />2.3591e-5 months <br /> x 3.8 workers = 9.9E-6 fatalities: $30 Per NUREG-1 727 Transportation Accident Cost @ 15,420 km (5.86E-4 fatalities by truck):

$1758 Per NUREG-1727, Appendix D Worker Dose, 62 hours7.175926e-4 days <br />0.0172 hours <br />1.025132e-4 weeks <br />2.3591e-5 months <br /> x 3.8 workers infield ( 0.0005 rem/hour: 0.118 person-rem = $236 Total Costs: $110,223 Cost per M3 : $3340 Page 4B-1

BRPP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 912712005 APPENDIX 4-C-1, Screening Level Calculations PW at Actual mean Soil Concentration vs

_ _ _ _ , - It _3

__.__,,

Case 1 screenin Levei (150 cu. m _)

Radionuclide l A Pd*A*F/40 T Conc l Screen l N r PW l (I1yr) (unitless) (pCig) (pCi/g) I(years (1iY) (unitLess) s-137 0.0231 0.095 0.6680 .10E+01 1000 0.03 1.09E-01 60 0.1317 0.095 0.5720 3.80E+00 1000 0.03 8.84E-0 r-90 0.0427 0.095 0.0094 1.70E+00 1000 0.03 9.56E-03 n-54 0.5749 0.095 0.0370 1.50E+01 1000 0.03 3.87E-04 e-55 0.2665 0.095 1.7600 1.00E+04 1000 0.03 5.64E-05 H-3* 0.0563 0.0951 0.0490 1.1OE+02 1000 0.03 4.90E-04 otal _ 3.0954 0.208 Benefit of Averted Dose = $2000*PW 415.1 PW at Screening Level for Mix In 33 Case 2 cubic meters _ _ -

Radionuclide AX Pd*A*F/40 Conc Screen N r PW (1/yr) (unitless) (pClg) (pCi/g) (years) (1/y) (unitless)

Cs-137 0.0231 0.095 3.039 1.1OE+01 1000 0.03 4.95E-01 Co 60 0.1317 0.095 2.602 3.80E+00 1000 0.03 4.02E-01 Sr-90 0.0247 0.095 0.043 1.70E+00 1000 0.03 4.35E-02 Mn-54 0.5749 0.095 0.168 1.50E+01 1000 0.03 1.76E-03 Fe-55 0.2665 0.09 8.006 1.OOE+04 1000 0.03 2.56E-04 H-3' 0.0563 0.095 0.223 1.1OE+02 1000 0.03 2.23E-03 Total 14.0801 0.944 Benefit of Averted Dose = $2000*PW 1,888.1 Page 4C-1

BRPP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN APPENDIX 4-C-1. Screenina Level Calculations 9J27/2005 I Calculation of Gross Activity Screening Level for Mix1 Radionuclide I Original Conc Screening Level l (P!g P!g Conct cen l Conc Mix Scm I Dose Check (pi~) p~l) Sren (pCl~g) (mremlyr)

Cs-137 0.6680 1.10E+01 6.07E-02 3.04E+00 6.91 E+OI Co 60 0.5720 3.80E+00 1.51E-01 2.60E+00 1.71 E+01 Sr-90 0.0094 1.70E+0C 5.50E-03 4.26E-02 6.26E-O1 Mn-54 0.0370 1.50E+01 2.47E-03 1.68E-01 2.81E-O1 e-55 1.7600 1.00E+04 1.76E-04 8.01E+00 1.92E-O:

-3 0.0490 1.10E+02 4.45E-04 2.23E-01 4.91 E-O:

otal 3.0954 2.20E-01 1.41 E+01 2.42E+01 Equation 4-4 of NUREG-1575 Page 4C-2

BRPP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 9127/2005 1 APPENDIX 4-C-2. Site-Specific DCGL Calculations Case I PW at Actual mean Soil Concentration vs DCGL (150 cu. m3)

Radionuclide X Pd*A*FI40 Conc DCGL N r PW (1/yr) (unitless) (pCCog) (pCig) (years) (1/y) (unitless)

Cs-137 0.0231 0.0951 0.6680 1.32E+01 1000 0.03 9.05E-2O Co-60 0.1317 0.095 0.5720 3.21E+00 1000 0.03 1.05E-01 Sr-90 0.0427 0.095 0.0094 2.47E+00 1000 0.03 6.58E-03 Mn-54 0.5749 0.095 0.0370 1.37E+01 1000 0.03 4.24E4 Fe55 0.2665 0.095 1.7600 3.58E+0' 1000 0.03 1.57E-06 H-3** 0.0563 0.095 0.0490 3.25E+02 1000 0.03 1.66E4 otal 1.6038 _ 0.202 Benefit of Averted Dose= $2000*PW $ 404.74 Case 2 PW at DCGL for Mix In 33 cubic meters of Soil Radionuclide X Pd*A*F/40 Conc DCGL N r PW (1/yr) (unitless) (pCig) (pCUg) (years) (1/y) (unitless)

Cs-137 0.0231 0.095 2.837 1.32E+01 1000 0.03 3.85E-01 Co-60 0.1317 0.095 2.429 3.21 E+00 1000 0.03 4.45E-01 Sr-90 0.0427 0.095 0.040 2.48E+00 1000 0.03 2.79E-02 Mn-54 0.5749 0.095 0.157 1.37E+01 1000 0.03 1.80E-03 Fe-55 0.2665 0.095 7.475 3.58E+05 1000 0.03 6.69E-06 H-3** 0.0563 0.095 0.208 3.28E+02 1000 0.03 7.05E 04 llen 1_De_ 13.147 _ _ _ _ 0.860 Benefit of Averted Dose= $2000*PW 1I,719.0 Page 4C-3

BRPP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 912712005 1 APPENDIX 4-C-2, Site-Specific DCGL Calculations Calculation of Gross Activity DCGL for Mix It Original Site-Spec. Conc/ Conc @ Dose Radionuclide Conc (pCi~g) DCGL Mix DCGL Check Radiouclid (pCilg)memyr s-137 0.6680 1.32E+01 5.06E-02 2.84E+0( 5.21 E+00 Co-60 0.5720 3.21 E+00 1.78E-01 2.43E+00 1.83E+01 Sr-90 0.0094 2.47E+00 3.79E-03 3.97E-02 3.89E-01 Mn-54 0.0370 1.37E+01 2.70E-03 1.57E-01 2.78E-O1 Fe-55 0.2694 3.58E+05 4.91 E-06 7.46E+O0 5.05E-04 H-3 0.048 3.25E+02 1.51 E-04 2.08E-01 1.55E-0O Total 1.6038, 2.35E-01 1.31 E+01 2.42E+Ol

• Equation 4-4 of NUREG-1575 Page 4C-4

BRPP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 912712005 APPENDIX 4-D, Average Soil Radionuclide Concentrations for Big Rock Point DATA SOURCE This analysis utilizes soil and groundwater characterization data from systematic sampling (random and judgmental) of Survey Units 5, 8, and Canal. The data set includes all 389 plant gamma analysis samples with positive results for any radionuclide of potential plant origin listed in the survey unit characterization data tables of LTP Chapter 2 for Survey Units 5(1), 5(2), 8, and Canal. These survey units represent the areas of highest onsite soil concentrations. In addition, this analysis utilizes data of LTP Tables 2-14 and 2-11. These tables provide data for all soil surface samples analyzed for combined gamma and HTD (hard-to-detect) nuclides (13 samples obtained for representative high contamination areas), plus subsurface soil samples analyzed for combined gamma and HTD nudides (seven samples obtained in two areas where contamination exceeded 15 cm depth), and groundwater samples analyzed for gamma and HTD nuclides (seven samples, including representative samples of each groundwater zone).

This analysis also utilizes soil tritium data obtained from analyses in August 2002, from Survey Unit 12 (cores from the PZ-3MA location) where the upper and intermediate groundwater tritium plumes are present. This analysis is documented in the revised LTP Section 6.8.2.4.

ANALYSIS Data obtained from analyses performed by offsite vendors for HTD radionuclides (LTP Table 2-14) have been utilized to determine surrogate relationships specific to soils and contamination types at the BRP site. Samples with positive identification of HTD nuclides (two samples with Sr-90 and one with Fe-55) are shown in Table 4D-1. Ratios (scaling factors) of the HTD radionuclides to the surrogate nuclides Cs-137 and Co-60 based on activity of positively identified Sr-90 and Fe-55, are presented in Table 4D-2.

Additional analysis was performed to identify scaling factors from a larger data population that included identified activity of HTD nuclides as well as minimum detectable activity (MDA) values when the surrogate is greater than 2.5 pC!g. The cutoff of 2.5 pCi/g was utilized because all positive identifications occurred with surrogates above this level. Results of this analysis are provided in Table 4D-3. Use of MDA values gives a higher, therefore more conservative, ratio of 3.07 for Fe-55 than obtained by use of the single value greater than MDA (0.47). Thus, the more conservative value of 3.07 is chosen for use. In the case of Sr-90, use of the MDA data provides a lower ratio (0.012) than use of only the two values above MDA (0.020). Thus, the more conservative value of 0.020 is chosen for use.

In order to identify the actual radionuclides present, all the site and vendor data described here has been reviewed for nuclides reported as present in the analyzed samples. The radionuclides Cs-1 34 and Zn-65 (one identification of each among the 389 samples) have been excluded on the basis of low concentration (Cs-1 34 at 0.01 pCVg) and short halflife (Zn-65 at 0.33 pCig).

The data set provided in the tabulations of characterization data for Survey Units 5(1), 5(2), 8, and Canal (Appendix 2-E) have been evaluated by extraction of the sample means, ranges, medians, and number of positive samples from the database. The scaling rations discussed above were then applied to the mean soil concentrations of Cs-1 37 and Co-60 to provide scaled means for Sr-90 and Fe-55. This data is provided in Table 4D-4.

Page 4D-1

BRPP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN 912712005 APPENDIX 4-D, Average Soil Radionuclide Concentrations for Big Rock Point RESULTS Radionuclides of plant origin present in BRP soils and water are as follows:

I Dry Soils: I Cs-137 I Sr-90 I Mn-54 I Co-60 I Fe-55 Water: H-3 I 1 I Table 4D-1. Levels of Hard-to-Detect Nuclides and Surrogates In Soil t 12 Grid 250 Grid 228 Soil Sample Years pCi/g 3/02 pCi/g 3/02 Co-60 5.27 80.7 0.51 Cs-137 30.17 3.8 8.14 Fe-55 2.7 38 Sr-90 29 0.13 0.04 Table 4D-2. Hard-to-Detect Nuclides Scaled to Surrogates, Positive Results Only Activity Scale Scaled Nuclide Factor to Surroaate Sum (oCVU)

Co-60 80.70 - _

Cs-1 37 l 11.944T Fe-55 38.00 0.47 Co-60 Sr-90 0.17 0.02 Cs-137 Table 4D-3. Scaling by Inclusion of Minimum Detectable Activity Levels (MDAs)

Surrogate by actual and MDA (from LTP Table 2-14)

Sr-90 Actual Actual Grid 318 318 318 250 266 248 248 247 247 228 Cs-137 3.56 4.01 4.18 3.8 21.7 14 10.2 25.7 13.36 8.14 Sr-90 <0.02 <0.04 <0.04 0.13 <0.06 <0.6 <0.06 <0.04 <0.1 0.04 MDA Ratio Mean S.D.

0.010 0.0095 0.034 0.0027 0.042 0.0058 0.0015 0.0074 0.0049 Sr-90/

Cs-137 _

0.0056

_ _ 0.012 0.014 Fe-55 l JActual l l l Grid 269 250 250 266 Canal Co-60 6A3 80.7 15.6 5.17 8.27 Fe-55 MDA 38 <3.66 <36 <1.7 Ratio Fe-55ICo-60 I 7A6 OA70 0.234 l 6.96 l0.205 l Mean I S.D.

I I I I I 1 3.07 1 3.79 d The most conservative (highest) scaling factors of Tables 4D-2 and 4D-3 have been applied in Table 4D-4 to the gamma surrogate soil and sediment concentration means provided by ArcView:

Page 4D-2

BRPP LICENSE TERMINATION PLAN Revision 2 CHAPTER 4, SITE REMEDIATION PLAN APPENDIX 4-D, Average Soil Radionuclide Concentrations 9/27/2005 I for Blg Rock Point Table 4D-4. Characterization Survey Data, 389 Samples Analyzed (ArcView Output Except for Surrogate Scaling)

Nuclide Positive Samples Mean pCi/g Range pCi/g Median pCVg' Cs-1 37 193 0.668 0 - 30.7 0.39 Co-60 125 0.572 0- 105.9 0.25 Mn-54 20 0.037 0 - 8.68 0.17 HTD Nuclide III__

Sr-90 2 (193) 0.013 1 Fe-553 (125) 1.76 _

1 - Median excludes samples with zero activity for nuclide of interest 2 _Scaled at 0.020xCs-137 (using data from Table 4D-2) 3- Scaled at 3.07xCo-60 (using data from Table 4D-3)

Only three soil tritium analyses have been performed to date. The highest soil tritium identified (a sample taken from the upper groundwater zone near the center of the tritium plume just beyond the north industrial area fence line) is 0.049 pCVg (see LTP Section 6.8.2.4).

CONCLUSION The mean concentrations for onsite soils, as determined for the survey areas with highest contamination levels, are appropriate for use in LTP Chapter 4 ALARA analysis. These values are documented in Table 4D-4. Hard-to-detect radionuclides Sr-90 and Fe-55 should be utilized as shown in Table 4D-4. These values are obtained by use of the conservative scaling factors of 0.020 for Sr-90: Cs-1 37 and 3.07 for Fe-55: Co-60.

Due to the small number of soil tritium analyses to date, the highest observed tritium concentration (0.049 pCVg) should be utilized.

Page 4D-3

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 TABLE OF CONTENTS 5.0 FINAL STATUS SURVEY PLAN ................................................ 1I

5.1 INTRODUCTION

................................................ 1I 5.1.1 Purpose ................................................. 1 5.1.2 Scope ................................................. 1 5.1.3 Final Status Survey Preparation and Implementation Overview ............................. 2 5.1.4 Regulatory Requirements and Industry Guidance ................................................. 6 5.2 DEVELOPMENT OF SURVEY PLAN ................................................. 7 5.2.1 Radiological Status ................................................. 7 5.2.2 Classification of Areas...............................................................................................9 5.2.3 Establishing Survey Units ................................................ 12 5.2 A AccessControl Measures ................................................ 13 5.3 SURVEY DESIGN AND DATA QUALITY OBJECTIVES ........................................... 15 5.3.1 Data Quality Objectives (DQOs) ................................................ 15 5.3.2 Scan Survey Coverage.............................................................................................15 5.3.3 Sample Size Determination ................................................ 16 5.3.4 Background Reference Area ................................................ 18 5.3.5 Sample Locations and Reference Grid ................................................. 18 5.3.6 Investigation Levels and Elevated Areas Test ................................................ 19 5.4 SURVEY METHODS AND INSTRUMENTATION ................................................ 23 5.4.1 Survey Measurement Methods ................................................ 23 5.4.2 Specific Survey Area Considerations ................................................ 24 5.4.3 Instrumentation ................................................ 27 5.5 DATA COLLECTION AND PROCESSING ................................................ 31 5.5.1 Sample Handling and Record Keeping...................................................................31 5.5.2 Data Management.....................................................................................................31 5.5.3 Data Verification and Validation ................................................ 32 5.5.4 Graphical Data Review ................................................ 33 5.6 DATA ASSESSMENT AND COMPLIANCE ................................................ 33 5.6.1 Data Assessment Including Statistical Analysis....................................................33 5.6.2 Data Conclusions ................................................ 35 5.6.3 Compliance ................................................ 35 5.7 REPORTING FORMAT .................... 35 5.7.1 History File .................... 36 5.7.2 Survey Unit Release Record .................... 36 5.7.3 Final Status Survey Report .................... 36 5.7.4 Other Reports...........................................................................................................37 5.8 FINAL STATUS SURVEY QUALITY PROGRAM .................................. 37 5.8.1 Big Rock Point Quality Assurance Program .................................. 37 5.8.2 FSS Quality Assurance Project Plan (QAPP) ................................... 37

5.9 REFERENCES

.................................. 48 Page 5-i

BRP LICENSE TERMINATION PLAN Revision 2 l CHAPTER 5, FINAL STATUS SURVEY PLAN 9/27/2005 1 TABLES Table 5-1 BRP Site-Specific Radionuclides and Soil DCGL Values ................................ 8 Table 5-2 Big Rock Point Initial Land Area Survey Units .............................................. 11 Table 5-3 Survey Unit Sizes................................................ 13 Table 5-4 Scan Measurement Coverage ................................................ 16 Table 5-5 Investigation Levels................................................ 20 Table 5-6 Area Factors for Open Land Areas ................................................ 21 Table 5-7 Investigation Actions for Individual Survey Unit Measurements .................22 Table 5-8 Typical FSS Instrumentation Characteristics................................................31 Table 5-9 Interpretation of Sample Measurements for Sign Test ................................. 34 Table 5-10 BRP Procedures Applicable to FSSs ................................................ 39 Table 5-11 Target Schedule for FSS of Various Areas ................................................ 43 FIGURES Figure 5-1 Overall FSS Process................................................. 44 Figure 5-2 Big Rock Point Owner Controlled Area ................................................ 45 Figure 5-3 Initial Land Area Survey Units ................................................ 46 Figure 5-4 Example of Survey Unit Local Coordinate Grid ............................................. 47 APPENDICES Appendix 5-A Calculation of Tritium In Sols ............................................................ 5A-1 Page 5-ii I

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 5.0 FINAL STATUS SURVEY PLAN

5.1 INTRODUCTION

The Big Rock Point (BRP) Final Status Survey (FSS) Plan has been prepared using the applicable regulatory and industry guidance. This plan will be used to develop site procedures and work instruction to perform the FSS of the BRP site.

5.1.1 Purpose The FSS Plan describes the final survey process used to demonstrate that the BRP site complies with radiological 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 Commission (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 intends to release site land using a phased approach. The first phase includes the majority of the site land (approximately 560 acres) scheduled for release after all demolition, remediation and FSS activities associated with plant operation are complete. The second and final phase of site release includes the Independent Spent Fuel Storage Installation (ISFSI) following spent fuel removal, facility dismantlement and any required remediation. 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 activities, should Consumers Energy management decide accordingly.

This FSS Plan addresses requirements applicable to the first phase of site release.

This Plan address only land areas that are identified as contaminated or potentially contaminated (impacted) resulting from activities associated with commercial nuclear plant operation. All site buildings and subsurface structures and equipment, with the exception of the facilities supporting ISFSI, will be demolished and removed from the site prior to the FSS on surface spills. Surveys on excavated areas will be performed prior to backfilling (see Section 5.4.2.6 for detailed discussion on surveys of excavated areas and soils reused for backfill).

To the extent practical, excavation area surveys will be designed and conducted in accordance with NUREG-1 575 Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), guidance for surface surveys [Reference 5-10J.1 1Excavation surveys and surveys of soil removed from excavations are termed OFinal Status Surveys' (FSSs) at some places in this section. However, there are no pre-defined Survey Unit areas for such surveys. They will be reported as "miscellaneous data sets as described in LTP Section 5.7.3, for the appropriate surface survey unit described InTable 5-2, rather than under their own survey unit headings.

Page 5-1

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 l 5.1.3 Final Status Survey Preparation and Implementation Overview The FSS Plan contained in this chapter will be used as the basis for developing FSS procedures and applying existing procedures to the FSS process. Section 5.1.4 contains a list of regulatory documents used as guidance in preparing the FSS Plan.

Figure 5-1 provides an overview of the FSS process. Quality Assurance requirements are outlined in Section 5.8 and apply to activities associated with decommissioning and FSS activities.

An FSS Package will be produced for each survey area; this survey package is a collection of documentation detailing survey design, survey implementation and data evaluation for a final status survey of an area. The sections below describe specific elements of the FSS organization, preparation and implementation. All processes associated with final status surveys will be conducted in accordance with approved site procedures.

5.1.3.1 FSS Organization The general FSS organization will consist of supervision, technical specialists, work planning coordinators, field coordinators, data analysts, and technicians. Since the FSS organization has not been implemented at the time of LTP development, it is expected that specific job titles may vary over the period of project execution. These titles are used within this document to describe various functional areas of responsibility and do not necessarily refer to specific job titles. Refer to Section 5.8.2.1 for additional detail on the FSS organization.

5.1.3.2 Survey Preparation Survey preparation is the first step in the final status survey process and occurs after any necessary remediation is completed. In areas where remediation is required, a remediation survey or equivalent evaluation will be performed to confirm that remediation was successful prior to initiating final status survey activities. If remediation surveys, turnover surveys, or equivalent evaluation for areas not requiring remediation are performed using the same process and controls as a final status survey, then data from these surveys may be used as part of the final status survey data. In order for survey data to be used for final status survey, it must have been designed and collected in compliance with Sections 5.3 through 5.5 and the area controlled in accordance with Section 5.2.4. Following tumover/remediation surveys or post-remediation evaluation, the FSS is performed. Areas to be surveyed are isolated and/or controlled to ensure that radioactive material is not reintroduced into the area from ongoing demolition or remediation activities nearby and to maintain control of the area. Section 5.2 address specific survey preparation requirements and considerations.

Survey Package Initiation Each survey unit and package is assigned a unique identification number. To allow continuity of area identification, the protocol used for identifying survey areas during the characterization survey is used, as appropriate. Survey unit identification numbers differing from those used for characterization survey may be necessary if survey boundaries are modified. Survey unit nomenclature is defined in Section 2.4.1.

Page 5-2

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9/27/2005

• Review of Historical Site Assessment and Characterization Survey Historical data applicable to the survey area are reviewed; this information is used for survey design and is filed in the survey package. Sources of historical data include:

• Historical Site Assessment,

• Characterization Survey,

• Remediation Files,

• Background Study,

• Survey Records,

• Personnel Accounts, and

• 10 CFR 50.75(g) File

• Survey Area Walkdown A walkdown is performed to gather information about the physical characteristics of the survey area. The walkdown provides an opportunity to determine if any physical or safety related interferences are present that may affect survey design or survey implementation, and to determine any support activities necessary to implement surveys. Typical walkdown observation items include observation that demolition work is complete and all debris has been removed, grade is suitable for surveys, and the work area Is safe for survey activities. The walkdown is documented and filed in the survey package. In conjunction with or following the walkdown, representative maps of the survey area are prepared.

• Survey Area Readiness Prior to performing final status surveys all decommissioning, remediation and housekeeping activities identified as having the potential to affect the area are completed. Radiation Protection personnel may perform surveys to verify that the area meets specific radiological criteria for performance of the FSS. These surveys include readiness surveys that are conducted to 1) support remediation activities, 2) determine when a site or survey unit is ready for the final status survey, and 3) provide updated estimates of site-specific parameters to use for planning the FSS (see NUREG-1575, Section 5.4.1). In orderto differentiate among these three applications, the following terminologies are utilized:

a. Remedial Action Support Survey An In-process survey performed to expedite the remediation process.

This survey provides information to assist in cost effective remediation, but Is not normally expected to provide information sufficient to demonstrate compliance with final release criteria. However, data from these surveys may provide valid information for use in evaluation of readiness for turnover in preparation for the FSS.

Page 5-3

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 812712005

b. Turnover Survey (a.k.a. Post-Remediation Survey)

A survey, or data compilation from Remedial Action Support Surveys, that may be used to evaluate the completion status of remediation activities.

If this is a formal survey designed to meet the objectives of a final status survey as described by NUREG-1575, it may serve as the FSS for the remediated area.

c. Characterization Survey (Remediation Area or Other)

This survey, if found necessary by virtue of the turnover survey or the evaluation of other applicable data, is performed in accordance with NUREG-1575, Section 5.3. As with the Turnover Survey, if the Characterization Survey is designed to meet the objectives of a final status survey as described by NUREG-1575, it may serve as the FSS.

The survey unit can then be posted to indicate that the area is controlled for the performance of final status surveys. Controls are implemented to prevent contamination of areas during and following final status surveys, as appropriate.

5.1.3.3 Survey Design The impacted area is organized into survey units and classified by potential for residual radioactivity as Class 1, Class 2, or Class 3. The size of the survey unit is based on survey unit classification requirements in accordance with the guidance provided in NUREG-1575 (MARSSIM). The survey design process establishes the methods and performance criteria used to conduct the FSS and defines the sample point locations and type of measurements to be performed for each survey unit.

Section 5.2 contains a detailed discussion of survey design requirements.

A survey map is prepared for each survey unit and a reference grid is superimposed on the map to allow use of an (x,y) coordinate system. Random numbers between 0 and 1 are generated, which are then multiplied by the maximum x and y axis values of the sample grid. This provides coordinates for each random sample location, or a random start location for systematic grid, as appropriate. The measurement/sample locations are plotted on the map. Each measurement/sample location is assigned a unique identification code, which identifies the measurement/sample by survey unit, and sequential number. The appropriate instruments and detectors, instrument operating modes and survey methods to be used to collect and analyze data are specified.

Written survey instructions that incorporate the requirements set forth in the survey design are completed. Direction is provided, as applicable to survey design, for selection of instruments, count times, instrument modes, survey methods, required documentation, alarm/investigation setpoints, alarm actions, background requirements and other appropriate instructions. In conjunction with the survey instructions, survey data forms may be prepared to assist in survey documentation.

Alternatively, electronic data recording systems may be utilized. The survey design is reviewed and quality verification steps applied to ensure that appropriate instruments, survey methods, and sample locations have been properly identified.

Page 5-4

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 5.1.3.4 Survey Data Collection After preparation of a survey package, the final survey data are collected. Trained and qualified personnel will perform the necessary measurements using calibrated instruments in accordance with approved procedures and instructions contained in the survey package. Section 5.5 addresses FSS data collection requirements.

Survey areas and/or locations are identified by gridding, markings, or flags as appropriate. An FSS field coordinator performs a pre-survey briefing with the survey technicians during which the survey instructions are reviewed and additional survey unit considerations are discussed (e.g., safety). The technicians gather instruments and equipment as indicated and perform surveys in accordance with the appropriate procedures and survey package specifications. Technicians are responsible for documenting survey results and maintaining custody of samples and instrumentation. At the completion of surveys, technicians return instruments and prepare samples for analysis. Survey instruments provided to the technicians are prepared in accordance with appropriate procedures and the survey instructions.

Instrument calibration and performance checks are performed in accordance with applicable procedures. Data are reviewed to flag any measurements that exceed investigation criteria so that appropriate investigation surveys and remediation can be performed as necessary.

Following completion of an FSS, the need for Quality Control (QC) surveys (replicate surveys, sample recounts, etc.) is determined. If necessary, a QC survey package is developed. QC measurement results are compared to the original measurement results. If QC results do not agree with the original survey, an investigation is performed. Section 5.8 provides additional detail regarding QC survey requirements.

Following investigation, the survey data validity is assessed (see below).

5.1.3.5 Data Evaluation Survey data assessment is performed to verify that the data are sufficient to demonstrate that the survey unit meets the unrestricted use criterion. Statistical analyses are performed on the data and compared to pre-determined investigation levels (see Section 5.3.6.2). Depending on the results of the data assessment and any required investigation, the survey unit may either be released or require further remediation, reclassification, and/or resurvey. Assumptions and requirements in the survey package are reviewed for applicability and completeness; additional data needs are identified during this review. Specific data assessment requirements are contained in Section 5.6.

A review is performed of survey data and sample counting reports to verify completeness, legibility and compliance with survey design and associated instructions. As directed by FSS supervision, the following types of activities may be performed:

a. Convert data to reporting units,

b. Calculate mean, median and range of the data set,

c. Review the data for outlers,

d. Calculate the standard deviation of the data set, Page 5-5

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 l

e. Calculate minimum detectable concentration (MDC) for each survey type performed, and

f. Create posting, frequency or quantile plots for visual interpretation of data.

Computer programs may be utilized for these activities. FSS personnel include data quality verifications in their evaluations of statistical calculations; integrity and usefulness of the data set and the need for further data or investigation is also included. The data evaluation process is documented and filed in the survey package.

5.1.3.6 Final Status Survey Package Completion Survey results are documented by survey unit in corresponding survey packages.

Each FSS Package may contain the data from the several survey units that are contained in a given survey area. The data are reviewed, analyzed, and processed and the results documented in the FSS Package. This documentation file provides a record of the information necessary to support the decision to release the survey units for unrestricted use. An FSS Report will be prepared to provide the necessary data and analyses from survey packages for submittal to the NRC. Section 5.7 addresses reporting of survey results and conclusions.

5.1.4 Regulatory Requirements and Industry Guidance This FSS Plan has been developed using the guidance contained in the following documents:

a. NUREG-1 575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), (August 2000) [Reference 5-10].

b. NUREG-1 505, A Nonparametric Statistical Methodology for the Design and Analysis of Final Status Decommissioning Surveys, Revision 1 (June 1998 draft)

[Reference 5-12].

c. NUREG-1 507, Minimum Detectable Concentrations With Typical Radiation Survey Instruments for Various Contaminants and Field Conditions (June 1998)

[Reference 5-121.

d. NUREG-1 700, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans, (December 1998, draft) [Reference 5-13].

e. NUREG-1 727, NMSS Decommissioning Standard Review Plan, (September 2000) [Reference 5-14]

f. Regulatory Guide 1.179, Standard Format and Content of License Termination Plans for Nuclear Power Reactors, (January 1999) [Reference 5-15].

Other documents used in the preparation of this plan are listed in the References section (see Section 5.9).

Page 5-6

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 912712005 Big Rock Point anticipates both the NRC and the Michigan Department of Environmental Quality (MDEQ) - Radiological Protection Measurement and Standards Unit may choose to conduct confirmatory measurements during BRP FSS activities. The NRC may take confirmatory measurements to make a determination in accordance with 10 CFR 50.82(a)(1 1) that the FSS and associated documentation demonstrate that the site is suitable for release in accordance with the criteria established in 10 CFR Part 20, subpart E.

5.2 DEVELOPMENT OF SURVEY PLAN 5.2.1 Radiological Status The following sections provide a summary of site characterization and dose modeling results applicable to development of the BRP FSS Plan.

5.2.1.1 Identification of Radiological Contaminants Big Rock Point Plant conducted extensive radiological characterization of the site property between 1997 and 2000 to identify and document residual contamination resulting from nuclear plant operation. The effort included reviews of historical information as well as physical measurements of onsite soils and groundwater.

LTP Chapter 2, Site Characterization, contains a detailed discussion of this effort

[References 5-4 and 5-6].

5.2.1.2 Dose Modeling Summary Dose models based on NUREG/CR-5512, Volume 1 and RESRAD Version 6.2 were used to calculate Derived Concentration Guideline Levels (DCGLs) for the BRP site.

These dose models translate residual radioactivity levels into potential radiation doses to the public and are defined by three factors: (1) exposure scenario, (2) exposure pathways, and (3) exposed critical group. The scenarios presented in NUREG/CR-5512 address the major exposure pathways of direct exposure to penetrating radiation and inhalation and ingestion of radioactive materials. These scenarios also Identify the critical group. The critical group" is the group of individuals reasonably expected to receive the greatest exposure to residual radioactivity within the assumption of the particular land use scenario.

Since all buildings, above- and below-grade structures, and equipment within the industrial area will be demolished and removed from the site, a modified resident farmer scenario was selected to develop site-specific soil DCGLs for BRP. Due to site-specific environmental parameters, the modified residential farmer scenario is considered a very conservative dose model for the BRP site. Chapter 6, Compliance with the Radiological Criteria for License Termination, contains the basis and results of dose modeling performed for BRP and describes modifications of the standard resident farmer scenario to exclude meat and milk pathways. Table 5-1 provides a list of all potential radionuclides that may be present in onsite soils and the corresponding DCGLs.

Page 5-7

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9/27/2005 I Table 5-1. BRP Site-Specific Radionuclides and Soil DCGL Values 25 mrem/yr Limit Radionuclide Open Land Areas (Surface and Subsurface Soils)

(pCiIg)

H-3 3.27 E+02 Mn-54 1.37 E+01 Fe-55 3.58 E+05 Co-60 3.21 E+00 Sr-90 2.48 E+00 Cs-137 1.32 E+01 Eu-1 52* 7.35 E+00 Eu-1 54* 6.78 E+00 Eu-1 55* 2.87 E+02 Europium is included due to the potential to contaminate soil from concrete demolition activities.

5.2.1.3 Tritium Evaluation for Soils The final site survey will address tritium in soils by tritium analyses on 10% of the final status survey samples for all survey areas impacted by the tritium plume (see Figures 2-13, 2-14 and 2-15). A significant portion of the tritium plume area is to be excavated for removal of Turbine Building, Radwaste Vault and Containment foundations. Tritium analysis for 10% of samples taken from excavated soils from the defined plume area, as described in LTP Section 5.4.2.4, will be performed.

Investigation will be initiated if any sample of that survey area exceeds 10% of the tritium DCGL (32.7 pCilg), and complete resampling, with analysis of 100% of samples for tritium will be required if investigation shows that 50% of the tritium DCGL (164 pCVg) is exceeded. An accredited laboratory will perform these analyses on samples that have been protected from moisture loss in the interval between sampling and analysis.

Soil moisture capacity of Alpena sandy gravelly loam, making up a major portion of the native soil present at the site, is 8.75% [Reference 5-17]. A calculation that utilizes a bounding tritium water concentration of 20,000 pCi/A in contact with soil is presented in Appendix 5-A. At the 20,000 pCiA concentration for water, soil concentration for tritium is 1.03 pCi/g. This represents an annual dose contribution of 0.076 mrem/year and is less than 1%of the soil DCGL.

In addition to soil tritium analysis, monitoring for tritium in groundwater, surface waters and effluents, under the current environmental monitoring program, will continue to be performed until the final status survey is complete.

Page 5-8

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 5.2.1.4 DCGLs for Surrogate Measurements DCGLs for CS-1 37 and Co-60 presented above will be modified to account for the presence of hard-to-detect (HTD) nuclides, Sr-90 and Fe-55, respectively, using surrogate ratios developed from characterization data and in accordance with NUREG-1 575, Section 4.3.2 [Reference 5-8]. The equation below will be used to adjust DCGL values for Cs-137 and Co-60 to demonstrate compliance with DCGLs for Sr-90 and Fe-55, respectively.

DCLAJ= DCGLM X DCGLHTD DCGLADJ [(CHTD /CM )XDCGLMJ + DCGLHTD where:

DCGLADJ - DCGL adjusted for surrogate measurements DCGLM - DCGL for measured nuclide (e.g., Cs-1 37)

DCGLI,. - DCGL for HTD nuclide (e.g., Sr-90)

CHum / CM - Concentration ratio for HTD nuclide to measured nuclide 5.2.2 Classification of Areas Prior to the FSS, a thorough characterization of the radiological status and history of the site will be completed. Although more than 90% complete at this time, characterization of a few inaccessible areas await further dismantlement. The methods and results from site characterization are described in Chapter 2. Initial classification of site areas is based on historical information and site characterization data and was performed following the guidance in Section 4.4 of NUREG-1575 and Appendix E of NUREG-1727. Since all buildings and structures will be demolished and removed from the site for disposal prior to the FSS, classification of building areas was not performed. Area classification ensures that the number of samples and the scan coverage are commensurate with the potential for residual contamination to exceed the unrestricted use criteria. Reclassification of a survey unit will only occur to a more restrictive classification, e.g., from Class 2 to a Class I area; and would occur if future data indicate that the initial classification was incorrect. Any survey unit reclassification will include an evaluation of the basis for the initial classification and also the potential for survey unit classification programmatic deficiency. The basis for any reclassification will be documented, a redesign of the survey package completed, and the redesigned survey initiated. If during the conduct of an FSS, sufficient evidence is accumulated to warrant an investigation and reclassification of the survey unit, the survey may be terminated without completing the survey unit package.

5.2.2.1 Non-Impacted Areas Non-impacted areas are defined as areas that have no reasonable potential for residual contamination resulting from nuclear plant operations. Non-impacted areas are shown on Figure 5-2.

Page 5-9

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 912712005 l 5.2.2.2 Impacted Areas Impacted areas may contain residual radioactivity from licensed activities. Based on the levels of residual radioactivity present, impacted areas are further divided into Class 1, Class 2, or Class 3 designations. The definitions provided below are from NUREG-1727, Pages El and E2.

a. Class I areas are impacted areas that, prior to remediation, are expected to contain residual contamination in excess of the DCGL, 2.

b. Class 2 areas are impacted areas that are not likely to contain residual radioactivity in excess of the DCGLW.

c. Class 3 areas are impacted areas that have a low probability of containing residual radioactivity.

5.2.2.3 Inibal Classification Based on more than 1100 measurements made during the site characterization process and from information gathered during the Historical Site Assessment (HSA),

all land areas were assigned an initial classification in preparation for the FSS. In areas where data were limited, the initial classification is considered to be conservative to minimize future reclassification and additional sampling. The scope of the FSS includes all BRP impacted land areas. Table 5-2 provides a summary of initial survey unit classifications (see Chapter 2, Appendix E for a more detailed discussion of survey units). Figure 5-3 depicts these area classifications in a site map. The scope and boundaries of the FSS will be increased if survey data show significant levels of radioactivity above background in peripheral areas.

Characterization was performed and reported by initial survey unit. The area designations developed for the characterization process were used, for the most part, to delineate and classify areas for final status survey. This allows characterization data to be efficiently used for final survey area classification and for estimating the sigma value for sample size determination. For operational efficiency, each of the final survey areas listed in Table 5-2 may be subdivided into multiple areas. Smaller survey areas may be necessary to enhance the efficiency of data collection, processing, and review and serve to better support the decommissioning schedule. The classification of all subdivided survey areas will be the same as indicated in Table 5-2, unless reclassified in accordance with this LTP.

5.2.2.4 Classification Changes Initial classification of site areas is based on historical information and site characterization data. Data from operational surveys performed in support of decommissioning, routine surveillance, and any other applicable survey data may be used to change the initial classification of an area up to the time of commencement of the FSS as long as the classification reflects the levels of residual radioactivity that 2The w In DCGLW refers to the Wilcoxon Rank Sum test per MARSSIM (NUREG-1 575, page 2-3) and generally represents the uniform level of residual contamination that results inthe dose limit, regardless of the statistical test used. Big Rock Point Intends to use the Sign Test and will still use the term DCGLW to denote soil contamination limits, see Section 5.42.

Page 5-10

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 I existed prior to remediation. Areas within initial survey units may be upgraded in classification due to future requirements for laydown and storage areas during demolition activities or incorrect initial classification.

Table 5-2. Big Rock Point Initial Land Area Survey Units Survey Unit Initial Physical Designation* Description" MARSSIM Size' Des_______ DsClassification W)

Southwest corner of Protected Area (PA) 1 contains various storage and warehouse 1 1624 buildings and subsurface piping/utilities.

West-central section of PA contains 2 Maintenance/ Construction Complex (MCC) and 1 2002 subsurface piping/utilities.

3 Northwestern section of PA contains subsurface 1 2000 structures and piping/utilities.

North-central section of PA contains subsurface 4 foundations of Equipment Lock and Containment 1 1613 Sphere and various pipinglutilities Southwest of Containment encompasses northern section underground Radwaste 5(1) Vaults/Liquid Radwaste Processing System and 1 687 portions of Equipment Lock, Containment Sphere and northwest Turbine Building foundations West of Turbine Building encompasses the 5(2) Liquid radwaste storage tanks; Stack, southwest 1 837 Turbine Building and storage tanks foundations and various buried pipinglutilities South-central section of PA contains various 6 subsurface piping/equipment including liquid 1 1512 radwaste discharge line South-east section of PA contains subsurface 7 piping/equipment include liquid radwaste 1 2160 discharge line Area beneath Pipe Tunnel, between Containment 8PT' and Turbine Buildings, contains some subsurface 1 313 piping 8Sphere Area beneath Containment contains significant 1 851 subsurface foundations.

Area beneath Turbine/Service Building contains 8TB" extensive subsurface structures/foundations and 1 1347 significant system piping and electrical conduit.

Northeast comer of PA includes below-grade 9 structures including Screenhouse foundation, 1 2884 portions of Containment foundation and underground storage tanks 10 East-central section of PA includes portions of 1 943 Turbine/Service and Security Buildings I I Page 5-11

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5. FINAL STATUS SURVEY PLAN 912712005 I Survey Unit Initial Physical SeylUnat Description** MARSSIM Slze+

Designation* Classification (m) 11 Radwaste compound due south of PA 1 2350 12 Lake Michigan beach north of PA 2 9778 13 Lake Michigan beach east of discharge canal to 49,370 east property line 14 Lake Michigan beach west of industrial area 3 43,334 Wooded property due west of PA bounded by 15(1) drainage ditch to the east, includes septic 2 11,611 drainfield 15(2) Wooded property west of industrial area, south of 2 10,285 beach property 15(2R) Remediated section of survey unit 15(2) 1 18 15(3) Wooded property west of industrial area, south of 3 10,056 beach property 15(4) Wooded property west of industrial area, south of 3 10,955 beach property 16 Lake Michigan beach due east of discharge 2 8347 canal 17 Wooded property east of industrial area 3 263,220 18 Wooded property west of industrial area 3 84,677 Wooded, wetland property south of PA 19 surrounding Radwaste Compound (Survey 2 11,891 Unit 11) 59 Site property located south of US Hwy 131 (plant 3 34 railroad spur)

Canal Plant discharge canal sediment, currently below 1 610 water surface Seasonal stream and surface water conveyance Ditch located west of the Industrial Area flowing into 2 370 Lake Michigan

• Figure 5-3 depicts locations of survey units listed on this table.

• • Chapter 2, Appendix 2-E provides a detailed description of BRP survey units and associated operating history.

"PT - Pipe Tunnel UTB -Turbine Building

- Survey unit areas are preliminary based on site characterization and HSA information as of 12131103. Survey area sizes may be revised prior to FSS.

5.2.3 Establishing Survey Units Survey units are areas that have similar physical characteristics and contamination levels. Survey units are assigned only one classification. The site land areas vwil be surveyed, evaluated, and released on a survey unit basis.

Page 5-12

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 5.2.3.1 Survey Unit Size Survey unit sizes will be selected based on area classification, survey execution logistics, building demolition sequence and applicable regulatory guidance documents.

Typical survey unit sizes for soil are listed below in Table 5-3; these are consistent with NUREG-1575 guidance. Class I and 2 areas provided in Table 5-2 may be further subdivided into smaller areas to meet the guidelines present in Table 5-3. If larger survey unit areas are used, a technical evaluation will be presented in the FSS Package for the specific survey unit justifying the survey unit size.

Table 5-3. Survey Unit Sizes Impacted Area Suggested Survey Unit Classification Land Area 1 2000 m 2 2 >2000tolO,000m 2 3 No Limit 5.2.3.2 Site Reference Coordinate System (Reference Grid)

A reference coordinate system is used for impacted areas to facilitate the identification of survey units within the survey area. The reference coordinate system is an X-Y plot of the site area referenced to the North American Datum (NAD)

- Michigan Georeference Coordinate System. Once the reference point is established, grids may be overlaid parallel to lines of latitude and longitude.

5.2.4 Access Control Measures 5.2.4.1 Turnover Due to the large scope of demolition activities, it is anticipated that some surveys will be performed in parallel with dismantlement activities. This will require a systematic approach to turnover of areas be established. Prior to acceptance of a survey unit for final status survey, the following conditions must be satisfied in accordance with applicable procedures. These include:

a. Decommissioning activities having the potential to contaminate a survey unit shall be complete or measures taken to eliminate such potential.

b. Tools and equipment not required for the survey must be removed, and housekeeping and cleanup shall be complete.

c. Decontamination activities in the area shall be complete.

d. Access control or other measures to prevent recontamination must be implemented.

e. Turnover or remediation surveys may be performed and documented to the same standards as final status surveys so that data can be used for the FSS.

Page 5-13

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 5.2.4.2 Walkdown The principal objective of the walkdown is to assess the physical scope of the survey unit. Walkdowns of open land areas will be completed when the final configuration of the area is known, usually near or after completion of decommissioning activities for the area. The walkdown ensures that the area has been left in the necessary configuration for FSS or that any further work has been identified. The walkdown provides detailed physical information for survey design. Details such as structural interferences or sources needing special survey techniques can be determined.

Specific requirements will be identified for accessing the survey area and obtaining support functions necessary to conduct final status surveys, such as excavation shoring, interference removal, dewatering, etc. Industrial safety and environmental concerns will also be identified during this walkdown.

5.2.4.3 Transfer of Control Once a walkdown has been performed and the turnover requirements have been met, control of access to the area is transferred from the Radiation Protection -

Operations group to the FSS group. Access control and isolation methods are described in the subsection below.

5.2.4.4 Isolation and Control Measures Since all decommissioning activities will not be completed prior to the start of the FSS, measures will be implemented to protect survey areas from contamination during and subsequent to the FSS. Decommissioning activities creating a potential for the spread of contamination will be completed within each survey unit prior to the FSS. Additionally, decommissioning activities that create a potential for the spread of contamination to adjacent areas will be evaluated and controlled. Upon commencement of the FSS for survey areas where there is a potential for re-contamination, implementation of one or more of the following control measures will be required:

• Personnel training,

• Installation of barriers to control access to surveyed areas,

• Installation of barriers to prevent the migration of contamination from adjacent or overhead areas from water runoff, etc.,

• Installation of postings requiring contamination monitoring prior to surveyed area access,

• Locking entrances to surveyed areas of the facility,

• Installation of tamper-evident devices at entrance points, or

• Routine surveys to monitor and verify adequacy of isolation and control measures. Where adjacent activities have the potential to impact previously surveyed surfaces, monitoring surveys consisting of soil samples and/or scans will be conducted monthly, as a minimum.

Page 5-14

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 912712005 Routine surveys will not be required for open land areas that are not normally occupied and are unlikely to be impacted by decommissioning activities. Post-FSS survey locations will be judgmentally selected for survey, based on technical or site-specific knowledge and current conditions present in or near the survey area. These surveys are primarily designed to detect the potential migration of contaminants from decommissioning activities taking place in adjacent areas.

5.3 SURVEY DESIGN AND DATA QUALITY OBJECTIVES This section describes the methods and data required to determine the number and location of measurements or samples in each survey unit and the coverage fraction for scan surveys. The design activities described in this section will be documented in a survey package for each survey unit. Survey design includes the following:

• Data Quality Objectives (DQOs)

• Scan Survey Coverage

• Sample Size Determination

• Reference Grid and Sample Location 5.3.1 Data Quality Objectives (DQOs)

The appropriate design for a given survey area is developed during the DQO process as outlined in NUREG-1575 (MARSSIM, Appendix D). These seven steps are:

• State the problem

• Identify the decision

• Identify inputs to the decision

• Define the study boundaries

• Develop a decision rule Specify limits on decision errors

• Optimize the design for obtaining data The DQO process will be used for designing and conducting all final status surveys at BRP. Each survey package will contain the appropriate information, hypothesis, statistical parameters and contingencies to support the DQO process.

5.3.2 Scan Survey Coverage The area covered by scan measurement is based on the survey unit classification as described in NUREG-1575 (MARSSIM) and as shown in Table 5-4 below. A 100%

scan coverage of Class 1 survey units will be required. The emphasis will be placed on scanning the higher risk areas of Class 2 survey units. Scanning percentage of Class 3 survey units will be performed on potential areas of contamination based on the judgment of FSS technical personnel.

Page 5-15

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 Table 5-4. Scan Measurement Coverage Class Coverage Percent 1 100%

2 10-100%

3 Judgmental (<10%)

For Class 2 Survey Units, the amount of scan coverage will be proportional to the potential for finding areas of elevated activity or areas close to the release criterion In accordance with NUREG-1575 (MARSSIM, Section 5.5.3). Accordingly, BRP personnel will use the results of individual measurements collected during characterization to correlate this activity potential to scan coverage levels.

5.3.3 Sample Size Determination NUREG-1 575 (MARSSIM) describes the process for determining the number of survey measurements necessary to ensure a data set sufficient for statistical analysis. Sample size is based on the relative shift, Type I and 11errors, sigma, and the specific statistical test used to evaluate the data. Data point measurements or samples are used in the statistical analysis assume a random distribution. Altemate measurement processes or new technologies may be utilized provided they meet the applicable requirements of this plan for calibration, detection limit, area coverage, operator qualification, etc.

5.3.3.1 Statistical Tests Appropriate tests will be used for the statistical evaluation of survey data as described in NUREG-1575 (MARSSIM). For BRP final status surveys, it has been determined that contaminants (i.e., Cs-137) present in background constitute only a small fraction of the DCGL; therefore, the Sign Test will be used for the majority of the survey unit data evaluations (see Section 2.3.3). Alternate statistical tests may be employed as appropriate or as specific situations are encountered.

5.3.3.2 Decision Errors The probability of making decision errors is controlled by hypothesis testing. The survey results will be used to select between one condition of the environment (the null hypothesis) and an alternate condition (the alternative hypothesis). These hypotheses, chosen from NUREG-1575, are defined as follows:

• Null Hypothesis (Ho): The survey unit does not meet the release criteria

• Altemate Hypothesis (HJ): The survey unit does meet the release criteria A Type I decision error would result in the release of a survey unit containing residual radioactivity above the release criteria. This occurs when the null hypothesis is rejected when it is actually true. The probability of making a Type I error is designated as Wau. A Type II decision error would result in the failure to release a survey unit when the residual radioactivity is below the release criteria. This occurs when the Null Hypothesis is accepted when it is not true. The probability of making a Page 5-16

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 Type II error is designated as wpm. Type I and Type II decision error probabilities are initially set at 0.05. These values may be modified to optimize survey designs following the guidance of NUREG-1575, Appendix D. Type I decision errors will only be increased in accordance with the requirements of Section I.

5.3.3.3 Relative Shift The relative shift (8 / a) is an expression of the resolution of the measurements in units of uncertainty. The relative shift is calculated as follows:

- (DCGL - LBGR)/

ar a where:

8 - Shift or width of Gray Region equivalent to (DCGL-LBGR)

DCGL - Derived Concentration Guideline Level LBGR - Lower Bound of the Gray Region a - Sigma, estimate of the standard deviation of the concentration of radioactivity in the survey unit

£ Lower Bound of the Gray Region The Lower Bound of the Gray Region (LBGR) is the point of acceptable Type 11(,)

error. The LBGR is initially set at 0.5 times the DCGL,; however, this value may be adjusted to optimize the relative shift for the determination of sample size as described in NUREG-1575, Appendix D. Generally, Table 5-5 of NUREG-1575 will be used to determine the number of sample data points.

• Sigma The sigma value is the estimate of the standard deviation of the concentration of radioactivity in the survey unit. Sigma values for survey design are developed from survey data that have utilized identical measurement techniques as those to be performed in the FSS. Sigma values may also be determined by estimation based on site-specific knowledge.

5.3.3.4 Sign Test Sample Size The number of data points is determined from NUREG-1575 (MARSSIM), Table 5.5, for application of the Sign Test. This table includes the recommended 20%

adjustment to ensure an adequate sample size and will be used to determine the appropriate sample size using the applicable parameters for Type I (a) and Type II (P)decision errors and relative shift (8 / a) discussed previously.

5.3.3.5 Elevated Measurement Comparison (EMC) Sample Size Adjustment If the actual scan MDC is greater than the required scan MDC (see Section 5.3.6.3),

the sample size for the area of elevated activity will be determined using the equation provided below.

Page 5-17

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 1 NEMC = A / AEMC where:

NEMC - Elevated Measurement Comparison sample size A - Survey unit area AEmc - Area corresponding to the area factor calculated using the scan MDC Concentration (see Section 5.3.6.3) 5.3A Background Reference Area Since it has been determined Cs-137 is present at less than 5% of the DCGL, background reference area measurements are not necessary (see Section 2.3.3). In the event that it is determined that background measurements are needed, they will be collected as described in Chapter 12 of NUREG-1505. If this occurs, the appropriate statistical test will be utilized in accordance with NUREG-1575 (MARSSIM).

5.3.5 Sample Locations and Reference Grid Sample location is a function of the number of measurements required, the survey unit classification, and the contaminant variability.

5.3.5.1 Sample Locations Measurement locations within the survey unit are clearly identified and documented for purposes of reproducibility. Actual measurement locations are identified by tags, labels, flags, stakes, paint marks, geopositioning units or photographic records. An identification code matches a survey location to a particular survey unit. Sample points for Class I and Class 2 survey units are positioned in a systematic pattern or grid throughout the survey unit by first randomly selecting a start point coordinate. A random number generator is used to determine the start point of the square grid pattem. The grid spacing, L, is a function of the area of the survey unit as shown below:

for a square grid A L= A where:

L = grid spacing length A = the area of the survey unit, n = the number of sample points in the survey unit (determined from NUREG-1575, Table 5.5)

Page 5-18

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 Sample points are located, L,distance from the random start point in both the X and Y directions. Random sample point locations are used for Class 3 survey units.

Sample location coordinates are specified using a random number generator.

Measurement locations selected using a random selection process or a randomly-started systematic pattern that do not fall within the survey unit or that cannot be surveyed due to site conditions are replaced with additional random point locations as appropriate.

5.3.5.2 Reference Grid The sample reference grid is illustrated on sample location maps. Grid reference points may also be physically marked in the field. An example reference grid and sample location map is shown in Figure 5-4. Global Positioning System (GPS) instruments may be used in open land areas to determine reference or sample grid locations within the survey area.

5.3.6 Investigation Levels and Elevated Areas Test During survey unit measurements, levels of radioactivity may be identified that warrant investigation. Depending on the results of the investigation, the survey unit may require no action, remediation, and/or reclassification and resurvey.

Investigation process and investigation levels are described below.

5.3.6.1 Investigation Process During the survey process, locations with residual activity exceeding investigation levels are marked for further investigation. The elevated survey measurement is verified by resurvey. For Class 1 areas, size and average activity level in the elevated area is acceptable if it complies with the area factors and other criteria that may apply to evaluation of the DCGL for elevated measurements DCGLEMC. As discussed in Section 5.3.6.3 below, the DCGLEMC is applicable only for Class I areas. If any location in a Class 2 area exceeds the DCGLW, scanning coverage in the vicinity is increased in order to determine the extent and level of the elevated reading(s) and the area evaluated for reclassification. If the elevated reading occurs in a Class 3 area, the scanning coverage is increased and the area evaluated for reclassification and resurvey under the criteria of the new classification. All survey unit investigations will be conducted in accordance with the applicable FSS data quality objectives (DQOs).

Investigations should address: (1)the assumptions made in the survey unit classification; (2)the most likely or known cause of the contamination; and (3)the effects of summing multiple land areas with elevated activity within the survey unit.

Depending on the results of the investigation, a portion of the survey unit may be reclassified or combined with an adjacent area with similar characteristics if there is sufficient justification. Either action would result in resurvey of the (new) area(s).

The results of the investigation process are documented in the Survey Package.

Page 5-19

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 5.3.6.2 Investigation Levels NUREG-1575 (Table 5.8) and NUREG-1727 (Table E.2) provide investigation levels for scan surveys. In addition to investigation levels for scan surveys, direct measurement survey investigation levels have also been developed. These additional investigation levels include a very conservative value for Class 3 survey units as shown in Table 5-5.

Table 5-5. Investigation Levels Classification Scan Measurement Soll Sample Analyses Class I > DCGLEMC > DCGLEMC or > DCGL, + (statistical ass___ Ebased _ parameter value)

Class 2 > DCGLW or >MDC,,n* > DCGL, Class 3 > DCGLW or >MDCsmn* > 0.5DCGLW

• The larger of MDCSwan or DCGLwill be used.

Soil samples collected for tritium analysis (Section 5.2.1.3) are subject to the following additional investigation requirements:

Soil tritium concentrations greater than 10% DCGL

• Verify sample location and analysis, and

• Investigate potential trending in tritium concentration within the survey unit Soil tritium concentrations greater than 50% DCGL

• Determine the lateral and vertical extent of tritium contamination within the survey unit, and

• Repeat the final status survey process for the survey unit to include tritium analysis and evaluation for all samples collected 5.3.6.3 Elevated Measurement Comparison (EMC)

The elevated measurement comparison is used for Class 1 survey units when one or more scan or static measurement exceeds the investigation level. The EMC provides assurance unusually large measurements receive the proper attention and that any area having the potential for significant dose contribution is identified. As stated in NUREG-1 575, the EMC is intended to flag potential failures in the remediation process and should not be considered the primary means to identify whether or not a survey unit meets the release criterion. Locations identified by scan methodology with levels of residual radioactivity which exceed the DCGLEMC or soil sample analyses measurements with levels of residual radioactivity which exceed the DCGLEMC or DCGLW + (mean + 3a) (of survey unit) are subject to additional surveys to determine compliance with the elevated measurement criteria. The size of the area containing the elevated residual radioactivity and the average level of residual activity within the area are determined. The average level of activity is compared to the DCGLW based on the actual area of elevated activity. The initial DCGLEMC is established during the survey design and is calculated as follows:

Page 5-20

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9/27/2005 I DCGLEMC = Area Factor x DCGLw The area factor is the multiple of the DCGLw that is permitted in the area of elevated residual radioactivity without remediation. The area factor is related to the size of the area over which the elevated activity is distributed. That area is generally bordered by levels of residual radioactivity below the DCGLW and is determined by the investigation process. Area factors calculations are described in Section 6.10 and summarized in Table 5-6 [Reference 5-5]. Alternatively, Figures 6-2 and 6-3 provide a graphical method for selecting applicable area factors. The actual area of elevated activity is determined by investigation surveys and the area factor is adjusted for the actual area of elevated activity. The product of the adjusted area factor and the DCGL, determines the DCGLEMC. If the DCGLmc is exceeded, the area subject to the elevated activity calculation is remediated and resurveyed. The results of the elevated area investigations in a given survey unit that are below the DCGLEMC limit I

are evaluated using the equation below. If more than one elevated area is identified in a given survey unit, the unity rule can be used to determine compliance. If the formula value is less than unity, no further elevated area testing is required and the EMC test is satisfied.

Table 5-6. Area Factors for Open Land Areas*

Contaminated Calculated Area Factors at Time of Peak Dose Area (M2) H-3 Mn-54 Fe-55 Co-60 Sr-90 Cs-137 Eu-152 Eu-154 Eu-155 8094 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 4047 1.00 1.01 1.00 1.01 1.00 1.02 1.02 1.01 1.02 2024 1.00 1.03 1.00 1.03 1.00 1.03 1.03 1.03 1.03 1012 1.35 1.04 1.00 1.04 1.00 1.04 1.05 1.04 1.04 506 2.91 1.09 1.98 1.08 1.98 1.13 1.07 1.07 1.06 253 6.05 1.14 3.95 1.13 3.94 1.20 1.11 1.11 1.09 126 12.4 1.20 7.93 1.20 7.87 1.29 1.17 1.16 1.14 63 24.9 1.30 15.8 1.30 15.6 1.A1 1.27 1.26 1.23 32 49.2 1.49 31.2 1.49 30.5 1.62 1.44 1.45 1.39 16 98.9 1.78 62.0 1.78 59.9 1.93 1.72 1.73 1.63 8 198 2.38 123 2.38 117 2.58 2.30 2.31 2.14 4 397 3.61 243 3.62 230 3.91 3.49 3.52 3.19 2 794 5.68 473 5.75 452 6.14 5.48 5.55 4.90 1 1590 9.57 905 9.73 887 10.3 9.24 9.39 7.88 Table 5-6 is identical to Appendix 6-L of Chapter 6.

The following formula applies to a single radionuclide contaminant. When multiple radionuclides are present, the calculation is made for each radionuclide and the sum for all radionuclides must total less than one.

'R -fnr,__Ad DL + \\"SAVGv <1 DCGLjv (AreaFactorXDCGLw) where:

ConcAvG - average concentration in elevated area 8 - Estimate of average concentration of residual radioactivity Page 5-21

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9/27/2005 If more than one elevated area exists in the survey unit, a separate term check will be included for each.

In practice, the ratio of Co-60 to Cs-1 37 in BRP soils is variable. Although this does not affect the ability to determine actual DCGL for the mixture from laboratory analyses or in-situ gamma spectrum analyses, it does affect ability to pre-define investigation levels and scan MDCs where ratios vary within a survey area. To address this issue, BRP will employ one of the following approaches:

1) Subdivide the survey unit into areas having low variability so that actual pre-determined nuclide ratios may be taken into account in the mixture DCGL and MDC calculations, or

2) Utilize conservative calculational techniques for variable ratio survey areas, which assume that the most limiting gamma-emitting radionuclide (lowest DCGL of the gamma-emitting nuclides detected at BRP) dominates the mixture (Co-60).

5.3.6.4 Remediation and Reclassification As shown in Table 5-7, Class 1 or Class 2 areas of elevated residual activity above the DCGLEMC are remediated to reduce the residual radioactivity to acceptable levels. Based on survey data, it may be necessary to remediate an entire survey unit or only a portion of it. If an individual survey measurement (scan or direct) in a Class 2 survey unit exceeds the DCGL,, the survey unit or a portion of it may be reclassified to a Class 1 survey unit and the survey redesigned and re-performed accordingly. If an individual survey measurement in a Class 3 survey unit exceeds 0.5 DCGLW, the survey unit, or portion of a survey unit, will be evaluated, and if necessary, reclassified to a Class 2 and the survey redesigned and re-performed accordingly.

Table 5-7. Investigation Actions for Individual Survey Unit Measurements Survey Unit Action if Investigation Results Exceed: I Classification DCGLEMC DCGLW .5 DCGL, Remediate or Class I perform EMC Acceptable* N/A evaluation Class 2 Remediate or Reclassify and Clss2reclassify and investigate" N/ I

_____

____ ____ investigate "*_ _ _ _ __ _ _ _ _ _

Classify and Reclassify and Reclassify and Class 3 investigate" resurvey, increase inveigaeinvegaescan coverage

• For individual measurements above DCGL, plus the designated statistical-based parameter, the Sign Test will be conducted on the survey unit and an EMC evaluation performed.

• "Requires an investigation of the initial classification process and a survey unit evaluation of sufficient intensity to satisfy the requirements of new classification status.

Page 5-22

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 5.3.6.5 Resurvey Following an investigation, if a survey unit is reclassified to a more restrictive classification or if remediation activities were performed, a resurvey is performed in accordance with approved procedures. If a Class 2 area had contamination greater than the DCGLw, it should be reclassified to a Class I area. If the average value of Class 2 direct survey measurements was less than the DCGLW, the scan MDC was sensitive enough to detect the DCGLEMC, and there were no areas greater than the DCGLEMC, the survey redesign may be limited to obtaining a 100% scan without having to reperform the soil sample analyses. This condition assumes that the sample density meets the requirements for a Class I area.

5.4 SURVEY METHODS AND INSTRUMENTATION 5.4.1 Survey Measurement Methods Survey measurements and sample collection are performed by personnel who have received training and are qualified to perform these activities. The techniques for performing survey measurements or collecting samples are specified in approved procedures. Final status survey measurements include surface scans and gamma spectroscopy of soil samples. In-situ gamma spectroscopy or other methods may be utilized provided that approved procedures are utilized and instrument sensitivity is sufficient to meet or exceed minimum required detection levels. Volumetric soil samples may be analyzed using on-site laboratory gamma spectroscopy, in-situ gamma spectroscopy, and sodium-iodide gamma detection for scanning in accordance with applicable procedures. Off-site laboratory facilities may also be used for QC as specified in applicable procedures. Analytical methods for both onsite and offsite laboratory facilities will be established to ensure minimum detection levels of 10% to 50% of the DCGL value. Other methods not specifically described may also be used for final status surveys provided that approved procedures for these methods are utilized.

Soil will receive scan surveys at the coverage level described in Table 5-4 and volumetric samples will be taken at designated locations. Surface soil samples will normally be taken at a depth of 0 to 15 cm. Areas of sub-surface soil contamination will require sampling at a depth greater than 15 cm. The potential for sub-surface contamination will be addressed during the survey design process, and the associated survey package will contain requirements for sampling or in-situ measurements of soil below 15 cm, as necessary. All activities will be performed in accordance with approved procedures.

5.4.1.1 Scans Open land areas are scanned for gamma emitting nuclides. The gamma emitters are used as surrogates for the HTD radionuclides. Sodium iodide detectors will be used for scanning open land areas at the BRP site.

Page 5-23

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 5.4.1.2 Volumetric Samples Laboratory gamma spectroscopy is used to analyze collected soil samples. Soil samples size is approximately 1600 grams. Surface samples are collected from the top 15 cm of soil and subsurface soil samples are collected at depths below 15 cm.

Sample preparation includes removing extraneous material, homogenizing, and drying the soil for gamma isotopic analysis. Separate containers are used for each sample and each container is tracked through the analysis process using a chain-of-custody record. Samples are split when required by the applicable QC procedures.

5.4.2 Specific Survey Area Considerations 5.4.2.1 Septic Field The only onsite subsurface equipment to remain in place after site release is the septic system drainfield located just west of the former plant protected area. The septic drainfield is a ceramic tile system, approximately 3000 M2. All piping leading to this drainfield and associated tanks will be removed. The drainfield is considered a Class 2 area and will be surveyed as a single survey unit. The FSS for this survey unit will include both an evaluation of surface and subsurface soils. Mechanical coring equipment may be utilized to provide access for down-hole measurements and to obtain necessary subsurface samples. The FSS of the septic drainfield will also include collection of shallow groundwater samples for radioactivity analysis.

5.4.2.2 Pavement-Covered Areas Survey of paved areas will be required along the roadways providing ingress and egress to the site. Evaluation has determined that paved roadways are Class 3 areas. All other pavement, including that in parking lots and asphalt within the protected area, will be removed for disposal prior to the FSS. The survey design of paved areas will be based on soil survey unit sizes since they are outdoor areas where the exposure scenario is most similar to direct radiation from surface soil.

Scan and static gamma and beta-gamma surveys are made as determined by the survey unit design. If the potential exists for sub-surface contamination under pavement, either the pavement/asphalt will be removed prior to the FSS or samples obtained through the pavement. Pavement will remain only in Class 3 areas; scanning of paved areas will generally not be conducted, as Class 3 areas only require judgmental scanning of a small portion of the survey unit (see Section 5.3.2).

Paved areas may be separate survey units or they may be incorporated into surveys of other adjacent open land areas of like classification. Surveys of paved areas may include road right-of-ways to check for radioactivity relocated from water runoff.

Right-of-ways may also be separate survey units.

Page 5-24

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9/27/2005 5.4.2.3 Discharge Canal Sediment The discharge canal area will be evaluated as a separate survey unit. A coffer dam or equivalent method will be used to control lake water during survey activities in this area. The FSS will be performed prior to returning the shoreline to its original contour. The FSS of the discharge canal may be performed in conjunction with surveys of adjacent beach areas.

5.4.2.4 Stored Excavated Soil It is expected that soil will be stored around the site resulting from various decommissioning activities. Soil volumes resulting from excavations to remove building foundations or buried piping may be relocated to support work activities.

The locations from which stored soil originated will be tracked and storage areas controlled so that no contamination of soils will occur as a result of decommissioning activities. It is anticipated that much of this stored soil can be used for backfilling soil excavation areas after the FSS is completed. The following paragraphs provide the survey methodology for verifying that this soil is acceptable for backfill purposes.

The primary method for evaluation of excavated soils originating from Class I and Class 2 areas will follow the guidance provided in NUREG-1 575 for final status survey of Class I areas. Excavated soil will be evaluated in accordance with BRP procedures to determine suitability for transport and final status evaluation. Prior to performing a final status survey, excavated soil will be characterized to determine suitability for transport to an area dedicated for excavated soils. Soils that do not identify residual radioactivity greater than DCGL values will be relocated to an area dedicated for soil evaluation and graded to a maximum depth of one meter. A survey meeting criteria of a Class 1 final status survey will then be conducted with samples for laboratory analysis homogenized over the total depth of soil. Surface scanning and laboratory analyses will be directly compared with DCGL values. Any measurement location identifying residual radioactivity above the DCGL will be investigated and remediated. Controls will be instituted to prevent mixing of soils from different survey areas prior to evaluation. Soils satisfying the criterion for unrestricted release will be stockpiled for use as onsite backfill material.

The radiological evaluation of soils resulting from minor trenching and digging efforts in Class 3 defined areas (no reasonable potential for subsurface contamination) will be performed by characterization survey in accordance with site procedures.

Excavated soils that demonstrate residual radioactivity consistent with Class 3 status will be released for use as onsite excavation backfill.

An alternate method that may be used for evaluation of excavated soil is large-container assay performed by gamma spectroscopy.3 If alternate methods other than those described above are to be utilized for the evaluation of excavated soils, the NRC will be given the opportunity to review technical basis evaluation(s) justifying the alternate techniques.

3 This survey method is the same as that used for the 10 CFR 20.2002 process approved for disposal of BRP demolition debris.

Page 5-25

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 5.4.2.5 Groundwater Surveys Groundwater sampling and monitoring will be performed during excavation of building foundations and subsurface structures and during FSS of corresponding survey areas, as necessary. Groundwater sampling will consist of gamma spectrum analysis and tritium analysis since this is the only radionuclide identified in site groundwater. Additionally, groundwater and surface water flow control measures will be in place during demolition activities to minimize or eliminate the impact of water movement. Dewatering activities may require placement of temporary barriers to inhibit groundwater flow; groundwater flow is not expected to be influenced beyond the demolition Interval.

Monitoring wells within the tritium plume (wells MW-5 and MW-6 and piezometric wells PZ-3MA, PZ-3MB, PZ-3D and PZ-5S) will remain operable through the end of the final status survey and be sampled and analyzed quarterly, as available, for both gamma-emitting radioisotopes and tritium. To ensure that adequate data from groundwater strata are obtained, BRP will replace or repair any of these wells that become unusable. Any replacement well will allow sampling of the same groundwater zone as the well it replaces, and will be placed as close to the original location as possible in order to allow data continuity.

5.4.2.6 Excavations and Subsurface Sampling Potentially contaminated areas beneath removed foundations will be surveyed to reflect the criteria, as closely as practical, of a final status survey prior to backfill.

Survey units encompassing planned excavations have been classified based on characterization data and the potential for subsurface soils to contain residual radioactivity from site operations. Excavated footprints of several structures may be combined for final survey. Following the satisfactory demonstration that the survey meets FSS acceptance criteria for the excavated footprint surface, the excavation area will be backfilled. After backfill, a surface FSS is performed commensurate with the area classification.

If contamination deeper than 15 cm is suspected or known (for either the final surface or an excavated surface), samples will be collected using an auger or equivalent method. If a survey area has already been excavated and remediated to the soil DCGL, this area will be treated as a surface soil, and a survey performed as closely as practical to FSS requirements. Since all buildings and structures used during nuclear plant operations are scheduled for removal, it is expected that the majority of the survey units within the Industrial Area will include excavated areas.

Soil samples will be collected to depths at which there is high confidence that deeper samples will not result in higher concentrations. Alternatively, a sodium-iodide detector or intrinsic germanium detector of sufficient sensitivity to detect DCGL concentrations may be utilized in a "down hole configuration to identify the presence or absence of subsurface contamination and the extent of such contamination. If the detector identifies the presence of contamination at a significant fraction of the DCGL Is based on 1.5 meters of contamination. Application to radioactivity to 15 cm depth Is conservative for surface soils. However, the DCGL remains applicable to concentration average over 1.5 meter depth.

Page 5-26

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 DCGL, confirmatory laboratory analyses of soil samples of the suspect areas will be performed. Areas where subsurface samples may be collected or excavated area surveys performed include the Turbine Building, Containment Building, liquid and solid radioactive waste vaults, effluent stack foundation area, and discharge canal (the canal, prior to fill, is considered to be an "excavated area").

All subsurface sampling will be performed in accordance with the guidance in Appendix E, Section 11.1 of NUREG-1727. The sample size for subsurface samples will be determined using the same methods described for surface soil. Per NUREG-1727, scanning is not applicable to subsurface areas; however, BRP subsurface surveys will employ scanning techniques commensurate with the survey unit classification. Scanning on subsurface soils, where accessible as an excavated surface, will demonstrate compliance with site release criteria.

Narrow trenches and small excavations unsafe for manned entry or too small to require full FSS-type survey will be evaluated by means of excavated soils analysis in accordance with Section 5.4.2.4, and/or use of "down hole" techniques described above.

Data from surveys of excavated area surfaces and excavated soils will be utilized to demonstrate acceptability for site release in lieu of deep cores from such areas.

5.4.3 Instrumentation Radiation detection and measurement instrumentation for the FSS is selected to provide both reliable operation and adequate sensitivity to detect the radionuclides identified at the site at levels sufficiently below the DCGL. Site history and characterization efforts have identified Cs-137 and Co-60 as the predominant radionuclides present in BRP site soils. Other radionuclides of plant origin, including HTD nuclides are present at levels much lower that those of Cs-1 37 and Co-60.

Table 5-1 provides a list of potential radionuclides for evaluation in BRP site soils.

Soil sampling and analysis have demonstrated that direct measurements of Cs-137 and Co-60 can be used as surrogates for estimating levels of other contaminants that may be present in BRP soils.

Detector selection is based on detection sensitivity, operating characteristics and expected performance in the field. Portable instruments, laboratory instruments and bulk assay equipment may be used to perform these basic survey measurements:

• surface scanning,

• laboratory gamma spectroscopy of soil samples,

• gamma spectroscopy using the bulk assay monitor equipment, and

• direct surface contamination measurements (static or in-situ).

Radiation Protection instrumentation procedures control the issuance, use, and calibration of instrumentation. Records supporting the instrumentation program are maintained in accordance with site document control procedures.

Page 5-27

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 912712005 5.4.3.1 Selection Radiation detection and measurement instrumentation is selected to meet the requirements of survey design. Gamma spectroscopy instruments used for soil sample analyses are capable of residual radioactivity detection at values less than 10% of the DCGL,. Instruments used for surface scanning are capable of detecting radioactive material at levels below the DCGLEMC in Class 1 areas [Reference 5-3].

MDC values for scanning instruments used in Class 1 and 2 areas have the capability of detecting residual radioactivity below the DCGL,. Instrumentation currently proposed for use in the FSS is listed in Table 5-8 found in Section 5.4.3.5.

Instrument MDCs are discussed in Section 5.4.3.4 and nominal MDC values are also listed in Table 5-8.

Other measurement instruments or techniques other than gamma spectroscopy or Nal scanning may be utilized if evaluation determines that alternate instrumentation is equally or more efficient than the survey instruments currently proposed in this plan. The acceptability of alternate instruments or technologies for use in the FSS Program would be justified in a technical basis evaluation document to ensure equivalent or better instrument sensitivity. Technical basis evaluations for alternate final status survey instruments or techniques will be provided for NRC review prior to use. An instrument technical analysis document will include the following:

a. Description of the conditions under which the method would be used;

b. Description of the measurement method, instrumentation and criteria;

c. Justification that the technique would provide the required sensitivity for the given survey unit classification in accordance with Table 5-5; and

d. Demonstration that the instrument provides sufficient sensitivity for measurement below the release criteria with Type 1 error equivalent to 5% or less.

5.4.3.2 Calibration And Maintenance Instruments and detectors are calibrated for the radiation types and energies of interest at the site. Gamma scintillation detectors are calibrated using Cs-1 37, but the energy response and MDC for Co-60 has also been determined since discrete areas of Co-60 contamination have been found by soil surface scans.

Instrumentation for detecting alpha contamination is not expected to be required for BRP FSSs based on HSA information and site characterization data (see Sections 2.2.4 and 2.3.2).

Instrumentation used for the FSS will be calibrated and maintained in accordance with the BRP Radiation Protection & Environmental Services Department procedures. Radioactive sources used for calibration are traceable to the National Institute of Standards and Technology (NIST) and have been obtained in standard geometries to match the type of samples being counted. If vendor services are used, these will be obtained in accordance with purchasing requirements for quality related services, to ensure the same level of quality.

Page 5-28

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 5.4.3.3 Response Checks Instrumentation response checks are conducted to assure proper instrument response and operation. An acceptable response for field and laboratory instrumentation is an instrument reading within +/- 3 sigma as documented on a control chart. As a minimum, response checks are performed daily prior to instrument use. Source checks use source energies consistent-with the nuclides encountered at the BRP site. If an instrument fails a response check, it is appropriately identified and withheld from use until the problem is corrected in accordance with applicable procedures. Measurements made from the time of the last acceptable check and the failed checks are evaluated to determine if they should remain in the data set.

5.4.3.4 Minimum Detectable Concentration (MDC)

An MDC is determined for each of the instruments used for final status surveys. The MDC is the concentration of radioactivity that an instrument can be expected to detect 95 percent of the time.

• Laboratory Spectrometer Analysis The onsite chemistry laboratory maintains two gamma isotopic spectrometers that are calibrated to various sample geometries, including a one-liter marinelli geometry for soil analysis. These systems are calibrated using a NIST mixed gamma source. Both detectors are manufactured by PGT and operate using the VMS Genie platform from Canberra Industries. Laboratory counting systems have software controlled count times which are set to meet a maximum MDC of 0.15 pCi/g for Cs-1 37 in soil; this is calculated as follows:

MDC=LIK*V*T where:

4 - limit of detection = 3+ 4.65

• Pi K - proportionality constant relating detector response to activity level V - mass of sample T - count time

• Land Area Scans Evaluation of open land areas for unrestricted release must include a detection methodology of sufficient sensitivity to allow identification of small areas of potentially elevated activity within a survey unit. Surface scanning measurements for BRP land areas are performed by continuously passing a 2-inch x 2-inch sodium iodide (Nal) gamma scintillation detector over the subject land surface at a specified rate of speed. The scan technique uses an audible response to monitor for increase in count rate (see Chapter 2, Appendix D). An audible increase in instrument count rate requires further investigation to verify findings and define the level and extent of contamination.

Page 5-29

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 l Alternatively, in-situ gamma spectroscopy of variable size areas may be utilized for areas with special considerations. In-situ measurements will cover up to one survey grid (1lOm x 1Oim) of the survey area and may also provide measurements of the same small areas (one square meter) of potentially elevated activity. The value of in-situ spectroscopy is its ability to distinguish between residual radioactive material contamination and natural radioactive materials in stone or rock. Such natural materials have been found in onsite characterization surveys and are difficult to analyze by laboratory means when large stones or rocks are responsible for the elevated activity.

• Land Area Scan Instrument Sensitivity A determination of scanning sensitivity is performed to ensure that the measurement system is able to detect concentrations of radioactivity at levels below the release limit. Expressed in terms of the scan MDC, this sensitivity is the lowest concentration of radioactivity for a given background that the measurements system is able to detect at a specified performance level. Survey planning for soil survey units will be based on a scan MDC associated with a one-meter wide strip for scanning. Rate of scan transverse will be such that the resulting scan MDC is sufficient to detect areas of elevated activity with a measurement accuracy confidence limit of 95%. This two-stage scanning technique is described in NUREG-1 507 and has been evaluated for use on BRP open land areas (see Chapter 2, Appendix 2-D).

• In-Situ Measurement Sensitivity A Canberra ISOCS in-situ system, utilizing a 40% intrinsic germanium detector, has been used in site characterization [Reference 5-2]. Sensitivity for Cs-1 37 and Co-60 of less than 10% of initial DCGLs has been demonstrated. In-situ gamma spectroscopy for FSS will be conducted in association with the laboratory analysis of soil grab samples and/or other approved measurement techniques.

The resulting analyses are then compared for the identification of potential non-homogeneous radioactivity concentrations within the survey unit. Survey units failing acceptance criteria will require further investigation.

5.4.3.5 Detection Sensitivity The nominal detection sensitivity of detectors that may be used for final status surveys has been determined. Count times are instrument-specific and are selected to ensure that the measurements are sufficiently sensitive for the DCGL. For example, the count times associated with gamma spectroscopy of volumetric materials are administratively established to achieve MDCs less than the DCGL.

The MDC scan values may not always be less than the DCGLw, but will be less than DCGLEMC (see Section 5.3.6.3). Table 5-8 provides a summary of FSS instruments for BRP.

Page 5-30

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 l Table 5-8. Typical FSS Instrumentation Characteristics Instrument and Measurement Type Instrument Efficiency MDAIMDC Detector 2" x 2"Nal Gamma* 1200 cpm/mR/hr (Cs-137) Class I < DCGLEmc**

____ ___

___ ___ ___ ___ ____ ___ ___ Class 2&3 < DCGLw Canberra Genie Laboratory Gamma 9.7% &44.1d  % < 10% of < DCGLW

__ __ _ __ _ _ __ __ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ (2 d etecto rs)_ _ _ _ _ _ _ _ _ _ _ _

Canberra ISOCS In-Situ Gamma 40% < DCGLw Scan for gamma emitting nuclides using the Ludlum 2350-1 rate meter or equivalent.

• MDC values for varying background values are provided in Chapter 2, Appendix 2-D.

Site-specific DCGLs have not been established for transuranic radionuclides, since they have been discounted on the basis of dose in LTP Section 6.7.2.2. However, since transuranic radionuclides are of potential concern, laboratory and in-situ gamma analyses will continue to utilize the Am-241 MDC of 0.44 pCig of soil that has been applied in characterization studies to identify the presence or absence of residual transuranic radioactivity. This MDC provides for data continuity from characterization through final site surveys. Since there is no Am-241 DCGL, the NRC will be notified prior to performing any dose evaluation to allow soils to remain onsite when Am-241 is determined to be present at or above its MDC in those soils.

5.5 DATA COLLECTION AND PROCESSING This section describes data collection, review, validation, and record keeping requirements for final status surveys.

5.5.1 Sample Handling and Record Keeping A chain-of-custody record accompanies each sample from the point of collection through obtaining the final results to ensure the validity of the sample data. Sample tracking records are controlled and maintained in accordance with applicable procedures. Each survey unit has a document package associated with it that covers the design and field implementation of the survey requirements. Survey unit records are considered quality records.

5.5.2 Data Management Survey data are collected from several sources during the data life cycle and are evaluated for validity throughout the survey process. Quality Control replicate measurements are not used as final status survey data. (See Section 5.8.4.2 for design and use of QC measurements.) Measurements performed during turnover and investigation surveys can be used as final status survey data if they were performed according to the same requirements as the final status survey data.

These requirements are:

a. Survey data shall reflect the as-left survey unit condition, i.e., no further remediation required; Page 5-31

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9/27/2005

b. The application of isolation measures to the survey unit to prevent re-contamination and to maintain final configuration are in effect; and

c. The data collection and design were in accordance with FSS methods and procedures, e.g., scan MDC, investigation levels, survey data point number and location, statistical tests, and EMC tests.

Measurement results stored as final status survey data constitute the final survey of record and are included in the data set for each survey unit used for determining compliance with the site release criteria. Measurements are recorded in units appropriate for comparison to the applicable DCGL. Numerical values, even negative numbers, are recorded. Measurement records include, at a minimum, the surveyor's name, the location of the measurement, the instrument used, measurement results, the date and time of the measurement, any surveyor comments, and records of applicable reviews.

5.5.3 Data Verification and Validation The final status survey data are reviewed before data assessment to ensure that they are complete, fully documented, and technically acceptable. The review criteria for data acceptability will include at a minimum, the following items:

a. The instrumentation MDC for fixed or volumetric measurements was below the DCGLEMC for Class 1, below the DCGLW for Class 2, and below 0.5 DCGLW for Class 3 survey units;

b. The instrument calibration was current and traceable to NIST standards;

c. The field instruments were source checked with satisfactory results each day data was collected or data was evaluated if instruments did not pass a response check in accordance with Section 5.4.3.3;

d. The MDCs and assumptions used to develop them were appropriate for the instruments and techniques used to perform the survey;

e. The survey methods used to collect data were proper for the types of radiation involved and for the media being surveyed;

f. wSpecial methods for data collection were properly applied for the survey unit under review;

g. The chain-of-custody was tracked from the point of sample collection to the point of obtaining results;

h. The data set is comprised of qualified measurement results collected in accordance with the survey design which accurately reflect the radiological status of the facility; and

i. The data have been properly recorded.

If the data review criteria are not met, the discrepancy will be evaluated and the decision to accept or reject the data will be documented in accordance with approved procedures. The BRP Corrective Action Program will be used to document and resolve discrepancies as applicable.

Page 5-32

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 5.5.4 Graphical Data Review Survey data may be graphed to identify pattems, relationships or possible anomalies that might not be evident using other methods of review. A posting plot or a frequency plot may be made. Other special graphical representations of the data will be made as the need dictates.

5.5.4.1 Posting Plots Posting plots may be used to identify spatial patterns in the data. The posting plot consists of the survey unit map with the numerical data shown at the location from which it was obtained. Posting plots can reveal patches of elevated radioactivity or local areas in which the DCGL is exceeded. Incongruities in the background data may be the result of residual, undetected activity.

5.5.4.2 Frequency Plots Frequency plots may be used to examine the general shape of the data distribution.

Frequency plots are basically bar charts showing data points within a given range of values. Frequency plots reveal such things as skewness and bimodality (having two peaks). Skewness may be the result of a few areas of elevated activity. Multiple peaks in the data may indicate the presence of isolated areas of residual radioactivity due to variation of soil types. Variability may also indicate the need to subdivide the survey unit by soil type or by different nuclide distributions.

5.6 DATA ASSESSMENT AND COMPLIANCE An assessment is performed on final status survey data to ensure that they are adequate to support the determination to release the survey unit. Simple assessment methods such as comparing the survey data to the DCGL or comparing the mean value to the DCGL are first performed. The statistical tests are then applied to the final data set, where required, and conclusions are made as to whether the survey unit meets the site release criterion.

5.6.1 Data Assessment Including Statistical Analysis The results of the survey measurements are evaluated to determine whether the survey unit meets the release criterion. In some cases, the determination can be made without performing complex, statistical analyses.

5.6.1.1 Interpretation of Sample Measurement Results An assessment of the measurement results is used to quickly determine whether the survey unit passes or fails the release criterion. Final status surveys for BRP land will ublize the Sign Test on the basis that contaminants originating from plant operation that may reside in soil (or groundwater) do not exist in general background in appreciable quantities. Evaluation criteria for the Sign Test is provided in Table 5-9.

Page 5-33

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 Table 5-9. Interpretation of Sample Measurements for Sign Test Measurement Results Conclusion All concentrations less than DCGLW Survey unit meets release Average concentrabon greater than Survey unit fails DCGLW _ _ _ _ _ _ _ _ _ _

Any concentration greater than Conduct Sign Test and DCGLW and average concentration elevated measurements test.

less than DCGLW In addition, survey data are evaluated against the elevated measurement comparison criteria as previously described in Section 5.3.6.3. The statistical test is based on the null hypothesis (Ho) that the residual radioactivity in the survey unit exceeds the DCGLW. There must be sufficient survey data at or below the DCGLW to reject the null hypothesis and conclude the survey unit meets the site release criterion for dose. Statistical analyses are performed using specially designed computer-based calculations or, if necessary, using hand calculations.

5.6.1.2 Sign Test The Sign Test and Sign Test Unity Rule are one-sample statistical tests used for situations in which the radionuclide of concern is not present in background, or is present at acceptable low fractions compared to the DCGLw. If contaminant is present in background, the gross measurement is assumed to be entirely from plant activities. This option is used when it can be reasonably expected that including the background concentration will not affect the outcome of the Sign Test. The advantage of using the Sign Test is a background reference area is not needed. 4 The Sign Test is conducted as follows:

a. The survey unit measurements, Xi, i = 1, 2, 3, ...n; where n = the number of measurements, are listed.

b. Xi is subtracted from the DCGLw to obtain the difference (DCGLw - X,, i = 1, 2, 3,...,n).

c. Differences where the value is exactly zero are discarded and n is reduced by the number of such zero measurements.

d. The number of positive differences are counted. The result is the test statistic S+. Note that a positive difference corresponds to a measurement below the DCGLw and contributes evidence that the survey unit meets the site release criterion.

4 The Sign Test may be used with background reference areas in accordance with Chapter 12 of NUREG-1 505.

Page 5-34

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005

e. The value of S+ is compared to the critical value given in Table 1.3 of NUREG-1575. The table contains critical values for given values of N and Alpha (a). The value of a is set at 0.05 during survey design. If S+ is greater than the critical value given in the table, the survey unit meets the site release criterion. If S+ is less than or equal to the critical value, the survey unit fails to meet the release criterion.

5.6.2 Data Conclusions The results of the statistical tests, including application of the EMC, allow one of two conclusions to be made. The first conclusion is that the survey unit meets the site release criterion. The data provide statistical evidence that the level of residual radioactivity in the survey unit does not exceed the release criterion. The decision to release the survey unit is made with sufficient confidence and without further analysis. The second conclusion that can be made is that the survey unit fails to meet the release criterion. The data are not conclusive in showing that the residual radioactivity is less than the release criterion. The data are analyzed further to determine the reason for the failure. Possible reasons are that:

a. The average residual radioactivity exceeds the DCGLw,

b. The average residual radioactivity is less than the DCGLw, however, the survey unit fails statistical testing or elevated measurement comparison.

c. The survey design or implementation was insufficient to demonstrate compliance for unrestricted release.

If failure was due to the presence of residual radioactivity in excess of the release criterion, the survey unit shall be remediated. Survey unit failure due to inadequate design or implementation shall require investigation and reinitiation of the Final Status Survey process.

5.6.3 Compliance The FSS is designed to demonstrate licensed radioactive materials have been removed from BRP property to the extent remaining residual radioactivity is below the radiological criteria for unrestricted release. The site-specific radiological criteria presented in this plan demonstrate compliance with the criteria of 10 CFR 20.1402.

If the measurement results pass the requirements of Table 5-5 and the elevated areas evaluated per Section 5.3.6.3 pass the elevated measurement comparison, the survey unit is suitable for unrestricted release. If survey measurements do not meet the criteria specified in Table 5-5, an investigation will be performed.

Investigations will include an evaluation of survey design, instrumentation use and calculations, as necessary. All investigations of this nature will be documented using the corrective action process as discussed in Section 5.8.2 and 5.8.5.

5.7 REPORTING FORMAT Survey results are documented in history files, survey unit release records, and in the FSS Report. Other reports may be generated as requested by the NRC.

Page 5-35

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 5.7.1 History File A history file of relevant operational and decommissioning data is compiled. The purpose of the history file is to provide a substantive basis for the survey unit classification, and hence, the level of intensity of the FSS. The history file contains the following items:

• Operating history which could affect radiological status,

• Summarized scoping and site characterization data, and

• Other relevant information, as deemed necessary.

5.7.2 Survey Unit Release Record A separate release record is prepared for each final status survey unit. The survey unit release record is a stand-alone document containing the information necessary to demonstrate compliance with the site release criteria. This record includes:

• Description of the survey unit,

• Survey unit design information,

• Survey unit measurement locations and corresponding data,

• Survey unit investigations performed and their results, and

• Survey unit data assessment results.

When a survey unit release record is given final approval, it becomes a quality record.

5.7.3 Final Status Survey Report Survey results will be described in a written report to the NRC. The FSS Report provides a summary of the survey results and the overall conclusions to demonstrate the BRP site meets the radiological criteria for unrestricted use. Information such as the number and type of measurements, basic statistical quantities, and statistical analysis results will be included in the report. The level of detail is sufficient to clearly describe the FSS Program and to certify the results. The FSS Report will contain the following topics:

• Overview of the Results

• Discussion of Changes to FSS

• Final Status Survey Methodology

• Survey unit sample size

• Justification for sample size

• Final Status Survey Results

• Number of measurements taken

• Survey maps

• Sample concentrations

• Statistical evaluations, including power curves

• Judgmental and miscellaneous data sets

• Anomalous Data Page 5-36

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005

• Conclusion for Survey Units

• Summary of Changes from Initial Assumptions on Residual Radioactivity.

5.7.4 Other Reports Other reports relating to final status survey activities may be prepared and submitted as necessary.

5.8 FINAL STATUS SURVEY QUALITY PROGRAM Quality is built in to each phase of the FSS Program and measures must be taken during the execution of the plan to determine whether the expected level of quality is being achieved. The FSS Program will ensure that the site will be surveyed, evaluated and determined to be acceptable for unrestricted release if the residual activity results Inan annual Total Effective Dose Equivalent (TEDE) to the average member of the critical group of 25 mrem/year or less for all pathways. The following sections provide a description of applicable BRP quality programs and specific quality elements of the FSS Program.

5.8.1 Big Rock Point Quality Assurance Program The BRP quality assurance program is applied to systems, structures, components and activities important to the safe storage, control and maintenance of spent nuclear fuel and to the monitoring and control of radiological hazards. The Consumers Energy Quality Program Description (QPD) for Nuclear Power Plants defines the responsibilities and requirements to ensure decommissioning and construction/operation of the ISFSI comply with licenses and applicable regulations (10 CFR 50 and 10 CFR 72). This QPD addresses organizational responsibilities, staff qualifications, procedure review and approval, design and modification controls, procurement, measurement and test equipment (M&TE) calibration and control, testing of installed equipment, document control, and other information pertinent to quality [Reference 5-9].

5.8.2 FSS Quality Assurance Project Plan (QAPP)

The objective of the FSS QAPP is to ensure the survey data collected are of the type and quality needed to demonstrate with sufficient confidence the site is suitable for unrestricted release. The objective is met through use of the DQO process for FSS design, analysis and evaluation. The plan ensures the following items are accomplished:

a. The elements of the FSS Plan are implemented in accordance with the approved procedures;

b. Surveys are conducted by trained personnel using calibrated instrumentation;

c. The quality of the data collected is adequate; and

d. Corrective actions, when identified, are implemented in a timely manner and are determined to be effective.

Page 5-37

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 The following sections describe the basic elements of the FSS QAPP.

5.8.2.1 Project Management and Organization An FSS organization will be established for the BRP site. This organization will be responsible for planning and implementation of final status surveys. Since the FSS organization has not been fully implemented at the time of LTP development, specific job titles may vary over the period of project execution. However, the following descriptions refer to various functional areas of responsibility and do not necessarily correspond to specific job titles. It is also important to note qualified individuals may assume the responsibilities of more than one of the functional positions described below. The FSS organization consists of the following functional areas:

• Final Status Survey Supervisor The FSS Supervisor has overall responsibility for program direction, technical content, and ensuring the program complies with applicable NRC regulations and guidance. This supervisor is responsible for preparation and implementation of the FSS procedures. Additional responsibility areas may include resolution of issues or concerns raised by the NRC, the Michigan Department of Environmental Quality (MDEQ) or other Stakeholders, as well as programmatic issues raised by BRP site management. The FSS Supervisor provides overall FSS project coordination, which may include, but is not limited to, interfaces with site personnel in areas of nuclear licensing, demolition, and waste disposal.

• Final Status Survey Technical Specialists Responsibilities of FSS Technical Specialists may include technical support and development of FSS procedures, design of final status surveys, preparation of survey execution instructions, development of specific technical analysis documents supporting FSS activities, and review of survey packages and data collected in support of the FSS.

• Work Planning Coordinators Work Planning Coordinators develop detailed, job-specific work instructions using the site work order process. These individuals are tasked with ensuring the appropriate interface between various site functional groups is specified in work order documents. These individuals possess specific knowledge regarding Radiation Protection, FSS, and Industrial Safety requirements.

• Final Status Survey Field Coordinators Final Status Survey Field Coordinators are responsible for control and implementation of survey packages during field activities. Specific responsibilities are likely to include:

• Coordination of turnover surveys,

• Survey area preparation (e.g., gridding),

• Ensuring final status survey sampling is conducted in accordance with applicable procedures and work instructions,

• Maintaining access controls over completed FSS survey areas,

• Determining survey area accessibility requirements, Page 5-38

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9/27/2005

• Coordination and scheduling of FSS Technicians to support the decommissioning schedule, and

• Ensuring all necessary instrumentation and other equipment is available to support survey activities.

• Final Status Survey Data Specialist The FSS Data Specialist is responsible for maintaining the FSS data records in both electronic formats and hardcopy files, as applicable. This includes maintaining survey measurement data and supporting data files and generating reports of survey results. Responsibilities also include maintaining the integrity of the FSS database and implementing FSS Database QA requirements.

• Final Status Survey Technician Final Status Survey Technicians are responsible for performance of final status survey measurements and collection of final status survey samples in accordance with applicable site procedures and survey package instructions. An FSS Technician will be responsible for maintaining the pedigree of instrumentation used in the survey by implementing the procedural requirements for calibration, maintenance, and daily checks. Final Status Survey Technicians will be trained and task-qualified for the performance of the final status activibes assigned to them. Final Status Survey Technicians may also participate in survey area preparations.

5.8.2.2 Written Procedures Sampling and survey tasks must be performed properly and consistently in order to assure the quality of final status survey results. The measurements will be performed in accordance with approved, written procedures. Approved procedures describe the methods and techniques used for final status survey measurements.

Table 5-10 provides a list of BRP site procedures applicable to final status surveys and their current status.

Table 5-10. BRP Procedures Applicable to FSSs Procedure Title Status D5.1 Radiation Protection and Environmental Services Active

_________ Policy and Program Description _ _ _

D5.3 Big Rock Point Radiological Environmental Program Active D5.24 ALARA Program Active D5.19 Radiation Detection Instrumentation Calibration Active

. _ Facility and Source Control D5.26 Final Status Survey Program Active RM-76 Final Status Survey Design Active RM-77 Final Status Survey Implementation Active RM-78 Final Status Survey Assessment Active Page 5-39

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 912712005 Procedure Title Status RM-79 Final Status Survey Quality Control Active RIP-59 Scan Measurements Active RIP-60 Calibration and Operation of the Canberra Genie Active 2000 (In-Situ Gamma Spectroscopy)

RM-72 Sample Chain of Custody Active CIP-46 Operation of Canberra "Genie" Active CIP-50 Calibration, Functional Check and Use of Acculab V- Active

_____ _____ 4kg Balance_ _ _ _ _ _

RM-59 Sampling and Analysis of Bulk Material for Site Active Characterization or Free Release RP-29 Radiological Surveys Active 34A-04 Corrective Action Active 34A-02 Plant Documents Active D1.5 Personnel Safety Active D1.7 Master Training Plan Active D1.10 Computer Software Control Active 34A-05 Safety Review Committee and Independent Safety Review Review Active D3.3 Work Management Process Active 34A-03 Records Management Active 34A-08 Material Control Active RPG-ES-1, Spill Prevention Active I Section 1 RPG-ES-l, Stormwater Plan Active I Section 2 Volume 25 BRP Offsite Dose Calculation Manual Active Volume 34 Quality Program Description for Nuclear Power Active Plants (Part 1)- Big Rock Point 5.8.2.3 Training and Qualification Personnel performing final status survey measurements will be trained and qualified.

Training will include the following topics:

• Procedures governing the conduct of the FSS,

• Operation of field and laboratory instrumentation used in the FSS, and

• Collection of final status survey measurements and samples.

Page 5-40

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 Qualification is obtained upon satisfactory demonstration of proficiency in implementation of procedural requirements. The extent of training and qualification will be commensurate with the education, experience and proficiency of the individual and the scope, complexity and nature of the activity required to be performed by that individual. Records of training and qualification will be maintained in accordance with approved training procedures [References 5-1 and 5-7].

5.8.2.4 Measurement and Data Acquisitions The FSS records have been designated as quality documents and will be governed by site quality programs and procedures. Generation, handling and storage of the original final status survey design and data packages will be controlled by site procedures. Each final status survey measurement will be identified by individual, date, instrument, location, type of measurement, and mode of operation.

a. Quality Control Surveys The FSS Procedure has built-in QC checks for the survey process, instrumentation, field, and laboratory measurements. A minimum of 5%of final survey soil, water, and sediment samples will be evaluated through the QC program. Quality Control will consist of one or more of the following: in-house recounts, split samples, third party analysis, and/or statistical comparisons.

Acceptance criterion will be based on NRC Inspection Procedure 84750 or a standard statistical test. Unacceptable QC comparisons will require a documented investigation and may result in reanalysis, resurvey, or resampling.

b. Instrumentation Selection, Calibration and Operation Proper selection and use of instrumentation will ensure sensitivities are sufficient to detect radionuclides at the minimum detection capabilities as specified in Section 5.4.3 as well as assure the validity of the survey data. Instrument calibration will be performed with NIST traceable sources using approved procedures. Issuance, control and operation of the survey instruments will be conducted in accordance with the instrumentation procedures.

5.8.2.5 Assessment and Oversight Assessments and project oversight will include the following:

a. Self-assessments will be conducted in accordance with approved procedures and programs. As applicable, actions will be tracked in accordance with these documents.

b. Independent review of randomly selected survey packages (approximately 5%)

from selected survey units will be performed by onsite quality assurance programs to ensure the survey measurements have been taken and documented in accordance with approved procedures.

c. The BRP Corrective Action Program will be applied to the FSS Program in accordance with site procedures. Applicable procedures describe the methods used to initiate condition reports (CRs) and resolve associated corrective actions.

Page 5-41

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9/27/2005

d. Assessment and oversight by independent organizations will be conducted on a periodic basis, as deemed appropriate by site management.

5.8.2.6 Data Validation and Verification Survey data will be reviewed prior to evaluation or analysis for completeness and for the presence of outliers. Comparisons to investigation levels will be made and measurements exceeding the investigation levels will be evaluated. Procedurally verified data will be subjected to the Sign Test as discussed in Section 5.8.1.2.

Technical evaluations or calculations used to support the development of DCGLs will be independently verified to ensure correctness of the method and the quality of data.

a. Confirmatory Measurements Consumers Energy Co. anticipates that both the NRC and the MDEQ -

Radioactive Material & Standards Unit may choose to conduct confirmatory measurements. The NRC may take confirmatory measurements to make a determination in accordance with 10 CFR 50.82(a)(1 1) that the FSS and associated documentation demonstrate the site is suitable for release in accordance with the criteria for decommissioning in 10 CFR Part 20, subpart E.

Confirmatory measurements may include collecting radiological measurements for the purpose of verifying compliance with applicable state laws and confirming and verifying compliance with NRC standards for unrestricted license termination. Timely and frequent communications with these agencies will ensure they are afforded sufficient opportunity for these confirmatory measurements prior to implementing any irreversible decommissioning actions.

b. Project Schedule Portions of the FSS may be performed following demolition activities as areas become available for survey. Table 5-11 provides an estimate of FSS schedule based on dismantlement and demolition of specific structures and buildings.

Table 5-11 is presented at a target schedule summary only; specific timeframes may be adjusted by site management or due to weather conditions, as necessary, during the demolition phase of decommissioning.

Page 5-42

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2005 Table 5-11. Target Schedule for FSS of Various Areas Unit Description FSS Target Start Estimated FSS Survey Date Duration Radwaste Building Vault Area March 2003 Completed Screenhouse/Discharge Canal Area November 2004 Completed Liquid Radwaste Vault Area November 2005 1 month AdministrativelService Building Area November 2005 1 month Turbine Building Area November 2005 1 month Stack Area November 2005 1 month Yard Area - remaining foundations June 2006 1 month Containment Building Area July 2006 1 month All Remaining soil surfaces August 2006 1 month Page 5-43

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 6, FINAL STATUS SURVEY PLAN 9/2712005 I Develop DOOs Specify hypothesis and error rates Perform Readiness Surveys, as applicable

}a

/ Remediation Remediation

-i I I No Design Final Status Survey Calculate no. of samples, spacing and select sample locations Perform survey and sample analyses Perform Data Evaluation Conduct statistical test and EMC, as applicable

. .

Perform Investigative Actions as Req'd by

\ these tets Survey Unit Class fall? (see Table 5-7)

No Survey Unit Meets Release Criteria Figure 5-1. Overall FSS Process Report results

_

Page 5-44

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9/27/2005 N

U531 7

Legend l Impacted Arms Iy W UnimpactedArea Figure 5-2: Big Rock Point Owner Controlled Area Page 5-45 C, " 03

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9/27/2005 wtv A

mgfl~ Pi pi I LEend Areas r7)Impacted F"Unimpeded Arae Figure 5-3. Initial Land Area Survey Units Page 5-46 C,

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 9127/2006 S

I I 53 6 57 0

12B 133 if' 0

147 152 8-(_A 0  :

Z 171 X

- 185 Or 190

_ _ 0 204 209 Legend

= 1OX10 Square Meter Grids wibnique Number No 10X1 0 Square Meter Grids within Designated Survey Unit

• Examrple Sample Point where: Grid 205, X=7.6 m, Y=3.5 rn Figure 5-4. Example of Survey Unit Local Coordinate Grid Page 5-47 MI&

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN 912712005

5.9 REFERENCES

5-1 Big Rock Point Administrative and Working Level Procedures 5-2 Big Rock Point Engineering Analysis EA-BRP-DW-98-01, Efficiency Calibration of the Portable Gamma Spectrometer 5-3 Big Rock Point Engineering Analysis EA-BRP-SC-01-01, Deriviation of Scaling Factors for Hard-to-Detect Nuclides in Soir 5-4 Big Rock Point Engineering Analysis EA-BRP-SC-02-01, Nal Scanning Sensitivity for Open Land Survey 5-5 Big Rock Point Engineering Analysis EA-BRP-SC-02-04, Radionuclides Present in Onsite Soil and Water 5-6 Big Rock Point Engineering Analysis EA-BRP-SC-03-03, Area Factors for Use in BRP Final Status Surveys 5-7 Big Rock Point Historical Site Assessment, 1962-1997, May 2001 5-8 Big Rock Point Initial and Continuing Training for Decommissioning Course Descriptions 5-9 Consumers Energy Quality Program Description for Nuclear Power Plants, (CPC-2A)

(Part 1) - Big Rock Point 5-10 U.S. Nuclear Regulatory Commission NUREG-1 575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), August 2000 5-11 U.S. Nuclear Regulatory Commission Draft NUREG-1505, A Nonparametric Statistical Methodology for the Design and Analysis of Final Status Decommissioning Surveys, Revision 1, June 1998 5-12 U.S. Nuclear Regulatory Commission Draft NUREG-1 507, Minimum Detectable Concentrations with Typical Radiation Survey Instruments for Various Field Conditions, June 1998 5-13 U.S. Nuclear Regulatory Commission Draft NUREG-1 700, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans, April 2000 5-14 U.S. Nuclear Regulatory Commission NUREG-1 727, NMSS Decommissioning Standard Review Plan, September 15, 2000 5-15 U.S. Nuclear Regulatory Commission Regulatory Guide 1.179, Standard Format and Content of License Termination Plans for Power Reactors, January 1999 5-16 U.S. Nuclear Regulatory Commission Inspection Manual Procedure 84750, March 1994 5-17 USDA (vs. Department of Agriculture) Soil Survey, Charlevoix County, 1978 Page 5-48

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 5, FINAL STATUS SURVEY PLAN Appendix 5-A, Calculation of Tritium In Soils 9/27/2005 I Calculation of Tritium In Soils Concentration of tritium in soil is calculated from the maximum value of tritium in onsite monitoring wells accordance with Equation 5x.1. A bounding case is presented for tritium in water at a concentration of 20,000 pCi/I.

St =[(Wt)(0.0875)/(ps)]

Where:

St= Soil concentration of tritium (pCi/g)

W. = Maximum monitoring well water concentration of tritium (20,000 pCVI for bounding case) 0.0875 = Maximum water saturation (by weight) for Algoma sandy loam soil in contaminated area [Reference 5-16]

ps = Soil density (1,600 g/1) [Reference 5-2]

And Dt= (St)( 2 4 .2 18 mrem )/(DCGLt)

Where:

D, = Annual dose from tritium in soil (mrem/year)

DCGLt = Tritium DCGL (328 pCi/g) 24.218 mrem = Annual dose associated with soil tritium DCGL (adjusted from 25 mrem for contribution from tritium in the three groundwater zones)

Thus, SI = (0.0825)(20,000)11,600 = 1.03 pCi/g Dt= (St)(24.218)/(328) = (1.03)(0.0738) = 0.076 mrem/year Page 5A-1

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 6, COMPLIANCE WITH THE RADIOLOGICAL 912712005 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 2 to the LTP.

Page 6-i

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 7, UPDATE OF SITE-SPECIFIC 9/27/2005 DECOMMISSIONING COSTS TABLE OF CONTENTS l 7.0 UPDATE OF SITE-SPECIFIC DECOMMISSIONING COSTS ................................... 1

7.1 INTRODUCTION

.................................................... 1 7.2 DECOMMISSIONING COST ESTIMATE .................................................... 2 7.2.1 Cost Estimate Description and Methodology .................................................... 2 7.2.2 Summary of the Site-Specific Decommissioning Cost Estimate ......................... 3 7.2.3 Plant Radiological Decommissioning....................................................................6 7.2.4 Site Restoration (Greenfield Costs) ..................................................... 8 7.2.5 Spent Fuel Management .................................................... 8 7.2.6 Post 9-11 Incremental Security ................................................... 8 7.2.7 Summary of the Big Rock Point Decommissioning Cost Estimate ..................... 9

7.3 DECOMMISSIONING FUNDING

PLAN .................................................... 9

7.4 REFERENCES

................................................... 11 TABLES 7-1 TLG Services 2003 Decommissioning Estimate, Summary of l Decommissioning Costs, Year 2003 Constant Dollars .51 7-2 TLG Services 2003 Decommissioning Estimate, Summary of Decommissioning I Costs, Year of Expenditure Dollars .7 Page 7-i

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 7, UPDATE OF SITE-SPECIFIC 9/2712005 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 Plans for Nuclear Power Plants, and Regulatory Guide 1.159, Assuring the Availability of Funds for Decommissioning Nuclear Reactors, the site-specific cost estimate and funding plans are provided

[References 7-14 and 7-13]. Regulatory Guide 1.179 provides guidance with respect to the information to be presented.

The License Termination Plan (LTP) must:

Provide an estimate of the remaining decommissioning costs and compare the estimated costs with the present funds set aside for decommissioning. The financial assurance instrument required per 10 CFR 50.75 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 following cost elements:

• Cost assumptions used, including a contingency factor,

• Major decommissioning activities and tasks,

• Unit cost factors,

• Estimated costs of decontamination and removal of equipment and structures,

• Estimated costs of waste disposal, including applicable disposal site surcharges,

• Estimated final survey costs, and

• Estimated total costs.

The cost estimate should focus on the remaining work, detailed by each activity associated with the decommissioning, including the costs of labor, materials, equipment, energy, and services.

Consumers Energy owns a 100% undivided interest in the Big Rock Point (BRP)

Nuclear Plant and provides financial assurance for decommissioning through the 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 10CFR50.82(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 7-9 and 7-2]. 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 and filed in March 2001 as a follow-up to a site-specific decommissioning cost estimate filed with the MPSC in Page 7-1

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 7, UPDATE OF SITE-SPECIFIC 9127/2005 DECOMMISSIONING COSTS March 1998 [References 7-9 and 7-10]. Since the submittal of the LTP, Consumers Energy, in compliance with State of Michigan requirements, contracted TLG Services to prepare an estimate update in 2003. This estimate update, filed with the MPSC in March 2004, serves as the cost basis for this revision of the LTP [Reference 7-1 1].

In response to the March 1998 MPSC filing, Consumers Energy received a revised decommissioning rate surcharge order to increase annual collections through December 2000 which resulted in full funding of the decommissioning costs. Based on the same MPSC order, Consumers Energy discontinued decommissioning funding effective December 31, 2000, and is relying on the funds in the external sinking fund and fund earnings to cover the remaining amount of decommissioning expenditures for purposes of providing financial assurance. In compliance with 10 CFR 50.75(f)(1), Consumers Energy continues to demonstrate financial assurance on an annual basis.

7.2 DECOMMISSIONING COST ESTIMATE 7.2.1 Cost Estimate Description and Methodology As previously stated, Consumers Energy docketed a site-specific cost estimate prepared by TLG Services in accordance with 10 CFR 50.82(a)(8)(iii).

Subsequently, Consumers Energy, in compliance with State of Michigan require-ments for providing three-year estimate updates, filed estimate updates prepared by TLG Services with the MPSC in March 2001 and most recently in March 2004. The March 2004 estimate update was prepared in year 2003 constant dollars totaling

$431.1 million which detailed all costs to decommission BRP including radiological decommissioning, site restoration, spent fuel management (Independent Spent Fuel Storage Installation-ISFSI), post 9-11 incremental security, and a contingency factor.

The methodology used to develop the cost estimate follows the basic approach originally presented in the Atomic Industrial Forum (now Nuclear Energy Institute) program for developing standardized decommissioning cost estimates published as Al F/NESP-036, Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates, [Reference 7-1]. This document presents a unit cost factor method for estimating direct activity costs, activity by activity, simplifying the estimating process. Unit factors for the removal of equipment, concrete, steel, etc., were constructed from site-specific labor costs provided by Consumers Energy and actual worker productivity data from the BRP decommissioning project. The direct activity costs were then estimated using the plant inventory developed for each work area.

The unit cost factor method provides a demonstrable basis for establishing reliable cost estimates. The detail available in the unit cost factors for activity time, labor costs (by craft), and equipment and consumable costs provides assurance that cost elements have not been omitted. The unit cost factor, coupled with the plant-specific inventory of piping, components, and structures, provide a high degree of confidence in the reliability of the cost estimate.

Page 7-2

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 7, UPDATE OF SITE-SPECIFIC 912712005 DECOMMISSIONING COSTS Work difficulty factors (WDFs) were assigned to each work area, commensurate with the inefficiencies associated with working in confined, hazardous environments. The ranges used for the WDFs are as follows:

• Access Factor 0% to 40%

• Respiratory Protection Factor 0% to 50%

• Radiation Protection/ALARA Factor 0% to 100%

• Protective Clothing Factor 0% to 30%

• Work Break Factor 8.33%

These factors and their associated range of values were developed in conjunction with the Atomic Industrial Forum's Guidelines Study.

The period-dependent costs for the decommissioning program management, administration, field engineering, equipment rental and contracted services were developed using the critical path schedule.

Consistent with industry practice, contingencies were applied to the decontamination and dismantlement costs developed as specific provision for unforeseeable elements of cost within the defined project scope. Contingencies are particularly important where previous experience has shown unforeseeable events, which will increase costs, are likely to occur. The cost elements in the estimate are based on ideal conditions; therefore, the types of unforeseeable events that are almost certain to occur in decommissioning, based on industry experience, are addressed through a percentage contingency applied on a line item basis. The contingency, as used in the estimate, does not account for price escalation and inflation in the cost of decommissioning over the remaining project duration.

7.2.2 Summary of the Site-Specific Decommissioning Cost Estimate The estimate, prepared in year 2003 constant dollars, details all costs to decommission BRP including radiological decommissioning, site restoration, spent fuel management, post 9-11 incremental security, and a contingency factor. The estimate assumes all buildings will be demolished, including the removal of all below-grade foundations, and the site will be restored to a Greenfield condition by late 2006 with the exception of the ISFSI. The ISFSI will remain operational until the spent fuel is transferred to an approved repository by the Department of Energy (DOE);

assumed to occur starting November 2011 and be completed by May 2012.

Following completion of spent fuel transfer, the ISFSI will be demolished, which is assumed to be completed by November 2012.

Page 7-3

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 7, UPDATE OF SITE-SPECIFIC 912712005 DECOMMISSIONING COSTS Total cost to decommission BRP per the estimate prepared by TLG Services in year 2003 constant dollars is $431.1 million. Table 7-1 summarizes the decommissioning costs into four major categories: plant radiological decommissioning totaling $331.1 million, site restoration or the non-radiological Greenfield" costs totaling $28.7 million, spent fuel management which addresses the cost of dry fuel storage including ISFSI construction, storage system procurement, and ISFSI operations and dismantlement totaling $69.7 million, and post 9-11 incremental security costs totaling $1.6 million. The $431.1 million estimate includes $10.9 million in contingency dollars.

Page 7-4

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 7, UPDATE OF SITE-SPECIFIC DECOMMISSIONING COSTS 912712005 I Table 7-1. TLG Services 2003 DecommissIoning Estimate I Summary of Decommissioning Costs Year 2003 Constant Dollars I Major Cost Categories Plant Radiological Decommissloning 2003 Dollars Project Management/Staffing 4 $150,002 Major Component/Demolition Contracts $26,106 Hazard Abatement & Projects $13,454 Drv Fuel Storage Plant Mods & Fuel Load $6,075 Reactor Building Systems Dismantlement $11,254 Turbine & Service Building Systems Dismantlement $2,909 Yard Structures Dismantlement & Dewatering $2,121 Tools, Equipment & Services $13,047 Waste Processing/Disposal $51,814 Other Costs2 ' ' 4 $43,341 Contingency $10,94 Subtotal $331,063 Site Restoration (Greenfield Costs)

Project Management/Staffing4 $3,535 Major Component/Demolition Contracts $11,222 Hazard Abatement & Projects $50 Yard Structures Dismantlement & Dewatering $2,694 Tools, Equipment, & Services $877 Waste Processing/Disposal $9.033 Other/Miscellaneous2 $1.325 Subtotal $28,736 Spent Fuel Management (ISFSI)

Construction & Equipment $47,711 Staffing & Security $12,511 ISFSI Dismantlement/Restoration4 $2,739 Other Costs3'4 $6.74 Subtotal $69,706 I I

I Post 9-11 Incremental Security l $1.568 I Fotal Decommissioning Cost $431,0731 I 1 Prompt Decommissioning Alternative (DECON), costs in thousands of dollars.

2 Other costs Include energy, maintenance, overheads, etc.

3 Other costs include Insurance, taxes, fees, overheads, etc.

4Include cost of Final Status Survey.

Page 7-5

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 7, UPDATE OF SITE-SPECIFIC 912712005 DECOMMISSIONING COSTS For financial planning and cost performance monitoring purposes, the 2003 estimate was escalated for inflation at the following projected annual rates of change:

Compensation Per Hour 3.2%

U.S. - CPI, Urban 2.0%

Burial Cost 3.0%

Global Insight's "U.S. Economic Outlook for December 2003" was used to develop the annual rates of change for Compensation Per Hour and U.S. - CPI, Urban.

Consumers Energy's contract with Duratek Corporation (waste processor for BRP waste) was used in developing the annual rate of change for burial cost. Table 7-2 summarizes the resulting year of expenditure cost estimate of $439.4 million into four major categories: plant radiological decommissioning totaling $333.9 million, site restoration or non-radiological uGreenfield" costs totaling $30.3 million, spent fuel management costs totaling $73.6 million, and post 9-11 incremental security costs totaling $1.6 million. The $439.4 million estimate includes $11.5 million in contingency dollars.

7.2.3 Plant Radiological Decommissioning As summarized in Table 7-2, plant radiological decommissioning costs total $333.9 million. As of December 31, 2004, actual costs of $286.8 million have been withdrawn from the decommissioning funds leaving a forecast remaining cost of

$47.1 million.

Consistent with the NRC definition of decommissioning under 10 CFR 50.2, the radiological decommissioning costs under this category consider only those costs associated with normal decommissioning activities necessary for termination of the Part 50 license and release of the site for unrestricted use. It does not include costs associated with the disposal of non-radiological materials or structures beyond those necessary to terminate the Part 50 license or the costs associated with construction or operation of an ISFSI.

Upon permanent plant shutdown and commencement of decommissioning, Consumers Energy contracted with Duratek, Inc., to be the waste processing/

disposal contractor. All low-level radioactive waste generated from the decontamination and dismantlement activities is turned over to Duratek, Inc., for appropriate disposition. The contract specifies fixed rates for various waste streams and defines escalation rates for the duration of the project. Application of the rates against the inventory of waste materials defined in the TLG Services estimate results in a high confidence level in the waste disposition cost elements within the estimate.

Page 7-6

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 7, UPDATE OF SITE-SPECIFIC 9127/2005 DECOMMISSIONING COSTS Table 7-2. TLG Services 2003 Decommissioninq Estimate I Summary of Decommissioning Costs Year of Expenditure (YOE) Dollars I Major Cost Categories Plant Radiological Decommissioning YOE Dollars Project Management/Staffinq 4 $150,668 Major Component/Demolition Contracts S26,271 Hazard Abatement & Projects $13A454 Dry Fuel Storage Plant Mods & Fuel Load $6,075 Reactor Building Systems Dismantlement S11,288 Turbine & Service Building Systems Dismantlement S2,939 Yard Structures Dismantlement & Dewatering S2,138 Tools, Equipment, & Services $13,10 Waste Processing/Disposal $52,778 Other Costs2 3 4 $43,683 Contingency $11.498 Subtotal $333,894 SIteRestoration (GreenfieldCosts)

Project ManagementVStaffing 4 $3, 780 Major ComponentVDemolition Contracts $11,792 Hazard Abatement & Projects $52 ard Structures Dismantlement & Dewatering $2,867 Tools, Equipment, & Services $916 Waste Processing/Disposal $9,532 Other/Miscellaneous2 S1.399 Subtotal $30,338 Spent Fuel Management (ISFSI)

Construction & Equipment $4771 9 Staffing & Security $14,499 ISFSI Dismantlement/Restoration 4 $3,637 ther Costs3, 4 $7.696 Subtotal $73,550 Post 9-11 Incremental Security JI 1.585 hotal Decommissloning Cost $439,3616 I Prompt Decommissioning Alternative (DECON), costs in thousands of dollars.

2 Other costs Include energy, maintenance, overheads, etc.

3 Other costs include Insurance, taxes, fees, overheads, etc.

4Include cost of Final Status Survey.

I Page 7-7

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 7, UPDATE OF SITE-SPECIFIC 9127/2005 DECOMMISSIONING COSTS Specifically excluded from the Duratek, Inc., contract is the disposal of the Reactor Vessel. Reactor Vessel removal and disposal has been completed. Costs for these activities are included in the actual expenditures through December 31, 2004.

The site-specific waste costs provide the basis for waste disposal costs within the estimate in lieu of guidance provided in NUREG-1 307, Report on Waste Burial Charges, [Reference 7-12].

7.2.4 Site Restoration (Greenfield Costs)

Recognizing site restoration or 'Greenfield" costs, or the removal and disposal of non-radioactive waste resulting from dismantlement activities, are outside the scope of the NRC definition of decommissioning, the information in this section of Table 7-2 is supplied for informational purposes. The total cost of site restoration work is estimated at $30.3 million.

7.2.5 Spent Fuel Management Similar to non-radiological site restoration costs, Consumers Energy recognizes that the costs to construct and operate an ISFSI and other spent fuel related costs fall outside the NRC definition of decommissioning. A presentation of these costs is included for informational purposes. Also, the staff recognized, as discussed in 10 CFR 50.75(a), that funding for the decommissioning of power reactors may be subject to the jurisdiction of other Federal and State Govemment agencies.

Table 7-2 summarizes the spent fuel management costs for BRP. These costs, currently being borne by Consumers Energy, are estimated at $73.6 million.

Included in this category are ISFSI engineering, licensing, construction, dry fuel storage system licensing and procurement, and ISFSI operations until possession of the spent fuel is transferred to the DOE assumed, in this estimate, to begin in 2011.

The cost to decommission the ISFSI is included in the spent fuel management costs.

7.2.6 Post 9-11 Incremental Security Although Consumers Energy recognizes these costs as radiological decommissioning costs, they are summarized separately as State of Michigan law.

MCL460.1Od(4) provides for separate recovery of enhanced security costs that are incurred before January 1, 2006, and are a result of Federal or State regulatory security requirements issued after September 11, 2001. Consumers Energy has calculated that $1.6 million of post 9-11 incremental security costs are recoverable from ratepayers pursuant to MCL460.10d(4) and has filed an application with the MPSC in Case No. U-14148 to collect separately this amount from its ratepayers.

Page 7-8

BRP LICENSE TERMINATION PLAN Revision 2 ]

CHAPTER 7, UPDATE OF SITE-SPECIFIC 912712005 DECOMMISSIONING COSTS 7.2.7 Summary of the Big Rock Point Decommissioning Cost Estimate The Decommissioning Cost Update for the Big Rock Point Nuclear Plant, prepared by TLG Services, Inc. (Table 7-1) is the basis for the LTP cost estimate. The estimated total cost for decommissioning BRP in year 2003 constant dollars is

$431.1 million. For budgetary and financial planning purposes, this estimate, escalated for inflation, results in a year of expenditure estimate of $439.4 million (Table 7-2). Decommissioning costs, as defined by the NRC, in year of expenditure dollars, total $333.9 million for radiological decontamination and disposal. Site restoration (non-radiological), spent fuel management, and post 9-11 incremental security costs total $30.3 million, $73.6 million, and $1.6 million, respectively.

Consumers Energy has concluded that, based upon information currently available, this estimate is adequate to complete the remaining decommissioning activities for BRP.

7.3 DECOMMISSIONING FUNDING

PLAN Consumers Energy, in compliance with 10 CFR 50.75(f)(1), provides financial assurance for the decommissioning of BRP through the use of an external sinking fund, funded by rates that are established by cost of service rate making regulation under the jurisdiction of the MPSC.

Consumers Energy entered into decommissioning immediately following plant shutdown on August 29, 1997. Consumers Energy filed a site-specific decommissioning cost estimate with the MPSC as part of Case No. U-1 1662 on March 31, 1998 [Reference 7-3]. The MPSC issued an Order in Case No. U-1 1662 on March 22, 1999 authorizing a revised decommissioning surcharge to be collected through December 31, 2000, calculated to provide full funding of the decommissioning costs [Reference 7-8]. Based on the same order, Consumers Energy discontinued decommissioning funding effective December 31, 2000, and is relying on the funds in the external sinking fund and fund earnings to cover the remaining amount of decommissioning expenditures. A small portion of remaining decommissioning expenditures (approximately $2.0 million at year-end 2004) will be funded through a Federal Energy Regulatory Commission (FERC-jurisdictional reserve balance.

Pursuant to State of Michigan requirements to prepare and file decommissioning cost estimate updates with the MPSC at three-year intervals, estimate updates were filed on March 30, 2001, and most recently, the current estimate update on March 31, 2004, [References 7-4 and 7-6]. For purposes of evaluating decommissioning fund adequacy, Consumers Energy excluded, as it did in the 2001 report, spent fuel management costs totaling $73.6 million as the company is attempting to recover these costs through litigation in the United States Court of Claims. Consumers Energy also excluded post 9-11 incremental security costs totaling $1.6 million that the company expects to recover separately under State of Michigan law MCL460.10d(4). Radiological decommissioning and site restoration costs, which total $364.2 million, were included in the funding evaluation. Although Page 7-9

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 7, UPDATE OF SITE-SPECIFIC 912712005 DECOMMISSIONING COSTS the current estimate of $364.2 million was essentially unchanged from the 2001 filing

($364.1 million), the funding evaluation projected a shortfall of $25 million for this scope of work primarily due to lower than expected historical fund earnings. With site restoration activities scheduled for completion in the near future (2006),

Consumers Energy, rather than seeking additional funding as part of the March 2004 submittal, stated it would manage the decommissioning trust to meet annual NRC financial assurance requirements by withdrawing radiological decommissioning costs from the trust and initially funding site restoration costs out of the company's general funds. Consumers Energy stated, subsequent to completion of site restoration, the company plans to file a request with the MPSC addressing recovery of costs in excess of the trust fund balance.

As demonstrated in Consumers Energy's recent submittal of the annual Certification of Financial Assurance for Decommissioning of the BRP Plant pursuant to 10 CFR 50.75(f)(1) dated March 31,2005, the amount of decommissioning funds estimated to be required, based on the 2003 TLG Services site-specific cost estimate shown in Table 7-2, is $439.4 million in year of expenditure dollars [Reference 7-5]. Included in the $439.4 million are $333.9 million of NRC radiological decommissioning costs,

$30.3 million of site restoration or Greenfield costs, $73.6 million of spent fuel management costs, and $1.6 million of post 9-11 incremental security costs.

Consumers Energy is providing decommissioning assurance in the amount of $333.9 million for the NRC radiological decommissioning costs.

Of the $333.9 million of NRC radiological decommissioning costs, $279.1 million has been withdrawn from the MPSC-jurisdictional external sinking fund as of December 31, 2004, and an additional $7.7 million has been funded from the FERC-jurisdictional reserve, leaving a remaining cost of $47.1 million. Financial assurance for the $47.1 million of remaining NRC radiological decommissioning costs has been provided for through funds in the external sinking fund and assumed fund earnings. At the end of 2004, the balance in the external sinking fund was

$51.4 million, based on State Street Bank and Trust, December 31, 2004, Annual Reports. The year-end balance reflects withdrawals of $279.1 million to cover NRC radiological decommissioning expenditures incurred through December 31, 2004.

Page 7-10

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 7, UPDATE OF SITE-SPECIFIC 912712005 DECOMMISSIONING COSTS

7.4 REFERENCES

7-1 AIF/NESP-036, Guidelines for Producing Commercial Nuclear Power Plant Decommissioning Cost Estimates, May 1986 7-2 Big Rock Point Post Shutdown Decommissioning Activities Report (PSDAR),

Revision 2, March 26,1998 7-3 Letter from Consumers Energy to Michigan Public Service Commission, Case No.

U-11662, March 31, 1998 7-4 Letter from Consumers Energy to Michigan Public Service Commission, Case No.

U-10800 - Decommissioning Fund Report - Big Rock Point Nuclear Decommissioning Fund, March 30, 2001 7-5 Letter from Consumers Energy, Big Rock Point Plant to U.S. Nuclear Regulatory Commission, Dockets 50-155 and 72-043 - License DPR-6, Big Rock Point Plant -

Certification of Financial Assurance for Decommissioning Pursuant to 10 CFR 50.75(0(1), March 31, 2005 7-6 Letter from Consumers Energy to Michigan Public Service Commission, Case No.

U-10800, March 31, 2004 7-7 Letter from the Director, Licensing and Enforcement Division, Michigan Public Service Commission to Consumers Energy, Consumers Energy Decommissioning Fund Report- MPSC Case U-10800, September 19, 2001 7-8 Michigan Public Service Commission Order issued in Case No. U-1 1662, March 22, I 1999 7-9 TLG Services, Inc., Decommissioning Cost Study for the Big Rock Point Nuclear Plant, March 26,1998 7-10 TLG Services, Inc., Decommissioning Cost Study for the Big Rock Point Nuclear Plant, March 22, 2001 7-11 TLG Services, Inc., Decommissioning Cost Update for the Big Rock Point Nuclear Plant, March 22, 2004 7-12 U.S. Nuclear Regulatory Commission NUREG-1307, Report on Waste Burial Charges, Revision 10, October 2002 7-13 U.S. Nuclear Regulatory Commission Regulatory Guide 1.159, Assuring the Availability of Funds for Decommissioning Nuclear Reactors 7-14 U.S. Nuclear Regulatory Commission Regulatory Guide 1.179, Standard Format and Content of License Termination Plans for Nuclear Power Reactors, January 1999 Page 7-11

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 912712005 TABLE OF CONTENTS 8.0 SUPPLEMENT TO THE ENVIRONMENTAL REPORT .................................................... I

8.1 INTRODUCTION

AND PURPOSE ............................................................. 1 8.1.1 Purpose ............................................................. 1 8.1.2 Background ............................................................ 1 8.1.3 Site Description After Unrestricted Release ............................................................. 2 8.1.4 PSDAR Update for Remaining Dismantlement and Decontamination Activities ........ 3 8.1.5 Summary and Update of Big Rock Point Environmental Report ............... .................. 3 8.1.6 Environmental Effects of Decommissioning..................................................................3 8.1.7 Overview of Regulations Governing Decommissioning and Final Site Release ........ 3 8.1.8 Summary and Conclusions ............................................................. 3 8.2 SITE DESCRIPTION AFTER UNRESTRICTED RELEASE .............................................. 4 8.3 PSDAR UPDATE FOR REMAINING DISMANTLEMENT AND DECONTAMINATION ACTIVITIES ................................................. 4 8.3.1 Post-Shutdown Decommissioning Activities Report Description ................. .............. 5 8.3.2 Impacts of Changes to the PSDAR ................................................. 5 8.4 BIG ROCK POINT SITE ENVIRONMENTAL DESCRIPTION ........................................... 5 8.4.1 Geography and Demography .................................................. 5 8.4.2 Climate .................................................. 8 8.4.3 Geology and Seismology ................................................. 10 8.4.4 Hydrology.......................................................................................................................12 8.4.5 Natural Resources ................................................. 14 8.4.6 Cultural, Historical and Archeological Resources ................................................. 14 8.4.7 Ecological Resources ................................................. 15 8.5 ENVIRONMENTAL EFFECTS OF DECOMMISSIONING ................................................ 19 8.5.1 Radiological Impacts of Decommissioning..................................................................19 8.5.2 Non-Radiological Environmental Impacts....................................................................26 8.6 OVERVIEW OF REGULATIONS GOVERNING DECOMMISSIONING ACTIVITIES AND SITE RELEASE ....................... 31 8.6.1 Federal Requirements....................................................................................................31 8.6.2 State and Local Requirements ....................... 33 8.7

SUMMARY

AND CONCLUSIONS ........................ 34

8.8 REFERENCES

....................... 43 Page 8-i

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9127/2005 I TABLES Table 8-1 Big Rock Point Soil Types ........................................ 17 Table 8-2 Big Rock Point General Land Cover Types ........................................ 18 Table 8-3 Total Estimated Waste to be Shipped from BRP ........................................ 25 FIGURES Figure 8-1 Site Map ........................................ 36 Figure 8-2 Aerial Photograph of BRP Site and Surrounding Land ................................. 37 Figure 8-3 Land Use Around BRP ......................................... 38 Figure 8-4 Topographic Map of Area Surrounding BRP ........................................ 39 Figure 8-5 USGS Seismic History for Michigan (1977 - 1996) ........................................ 40 Figure 8-6 Big Rock Point Soil Types ......................................... 41 Figure 8-7 Big Rock Point Land Cover Types ........................................ 42 Page 8-ii

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 912712005 8.0 SUPPLEMENT TO THE ENVIRONMENTAL REPORT

8.1 INTRODUCTION

AND PURPOSE 8.1.1 Purpose The purpose of this section of the License Termination Plan (LTP) is to update the Environmental Report (ER) for Big Rock Point (BRP) with new information and significant environmental change associated with the site's proposed decommissioning and license termination activities. This section of the LTP is pursuant to 10 CFR 51.53(d) and 10 CFR 50.82(a)(9)(ii)(G).

The information contained in this chapter generally follows the Nuclear Regulatory Commission (NRC) guidance of Regulatory Guide 1.179, Standard Format and Content of License Termination Plans for Nuclear Power Reactors, dated January 1999 and NUREG-1 700, Standard Review Plan for Evaluation Nuclear Power Reactor License Termination Plans, dated April 2000. The contents of this section have also been reviewed against the appropriate sections of NUREG-1727, NMSS Decommissioning Standard Review Plan, dated September 2000. Much of the information in this document has also been provided to the NRC in other forms, e.g.,

Updated Final Hazards Summary Report (UFHSR). Guidance contained in Supplement 1 to NUREG-0586, Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities (GEIS), was also utilized during preparation of this chapter [Reference 8-34].

8.1.2 Background At the time the BRP Nuclear Plant was licensed for construction in 1960, the Atomic Energy Commission (AEC; NRC predecessor) regulations did not require submittal of an environmental report. Since this time-frame was prior to promulgation of the National Environmental Policy Act of 1969, the AEC was not required to issue an Environmental Impact Statement (EIS) for BRP. However, much of the information typically contained in an environmental report was available for the AEC's review within BRP's original Final Hazards Summary Report (FHSR) at the time of licensing

[Reference 8-10].

In 1993, BRP initiated a decommissioning study to prepare a Decommissioning Plan in accordance with 10 CFR 50.82(a) for submittal to the NRC. During this decommissioning study, it was recognized BRP had never submitted an environmental report as part of the site's original licensing basis documents. In February 1995 BRP submitted to the NRC a Decommissioning Plan and also a companion environmental report for decommissioning the BRP site [Reference 8-22]. This ER for decommissioning concluded the SAFSTOR option selected by decommissioning study was bounded by NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities (FGEIS) [References 8-6 and 8-33]. The SAFSTOR option was chosen at this time due to the unavailability of a low-level radioactive waste disposal site to licensees in the State of Michigan.

Page 8-1

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/2712005 In July 1995 the NRC proposed to amend its regulations related to decommissioning nuclear power reactors. In February 1996 BRP requested the NRC delay completion of its review of the BRP Decommissioning Plan to allow Consumers Power Company' to assess the effect of the proposed regulations on the decommissioning of BRP [Reference 8-23]. The revised decommissioning regulations were finalized in August 1996 and included a provision that a previously submitted Decommissioning Plan be considered to be equivalent to a Post Shutdown Decommissioning Activities Report (PSDAR) required under 10 CFR 50.82(a)(4). In September 1996 Consumers Power Co. reached an agreement with the NRC that the BRP Decommissioning Plan was to be considered as the site's PSDAR and that this Decommissioning Plan be appended to the BRP UFHSR [Reference 8-24].

Following permanent cessation of plant operations in August 1997, BRP submitted a revision to its PSDAR stating that immediate dismantlement (DECON option) would begin since a low-level radioactive waste burial site was now available [References 8-25 and 8-12]. This revision to the PSDAR was structured in accordance with the new decommissioning rule and superceded the previously submitted Decommissioning Plan (Rev 0 of the PSDAR). Due to the revision to decommissioning regulations and subsequent revision to the PSDAR to utilize the DECON option, the BRP Decommissioning Plan and corresponding ER for Decommissioning were never formally reviewed by the NRC and a Safety Evaluation Report (SER) was never generated for these documents. Big Rock Point did not rescind its original ER for decommissioning because it was determined by site personnel that this document was still required by 10 CFR 50.82(a)(4)(i).

During review of revisions to the 10 CFR 50.59 and 50.82 processes, BRP personnel determined that an ER was required to perform both 10 CFR 50.59 and 50.82 evaluations. Subsequently, the site's ER for decommissioning was revised and incorporated by reference into the BRP UFHSR [Reference 8-18]. This revised ER for decommissioning concluded the DECON option and immediate dismantlement currently supported by the site's PSDAR is within the bounds of NUREG-0586.

8.1.3 Site Description After Unrestricted Release A summary description of the site following license termination and unrestricted release is provided in Section 8.2. Generally, all above-grade and below-grade structures, equipment and foundations will be demolished and the resulting demolition debris will be disposed of offsite at either a low-level radioactive waste facility or a local, State of Michigan licensed, industrial waste landfill. The building foundation excavations will be backfilled with local soil fill material following any required remediation and final status survey activities.

Prior to 1998 Consumers Energy Company's legal name was Consumers Power Company.

Page 8-2

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/27/2005 8.1.4 PSDAR Update for Remaining Dismantlement and Decontamination Activities Big Rock Point LTP Chapter 3, Identification of Remaining Site Dismantlement Activities, identifies the dismantlement and decontamination activities, which are scheduled to be completed prior to license termination and unrestricted release.

These activities are compared to the descriptions provided on the PSDAR and any changes identified. The impacts of changes to these activities are described in Section 8.3.

8.1.5 Summary and Update of Big Rock Point Environmental Report The BRP ER, originally developed for decommissioning (see Section 8.1.2), was used as the basis to prepare this supplement to the ER. A review of the BRP's ER was performed to identify any relevant new information or significant environmental changes to the report. Guidance contained in Supplement 1 to NUREG-0586 was reviewed to determine the nature of any new information to be included in this section. A summary of information in the BRP ER is contained in Section 8.4.

8.1.6 Environmental Effects of Decommissioning A description of both the radiological and non-radiological environmental effects of decommissioning is provided in Section 8.5. Radiological impacts reviewed include evaluations of occupational and public doses, decommissioning accidents, low-level waste (LLW) generation, transportation and disposal, and adherence to radiological criteria for license termination. The non-radiological effects include potential impacts governed by federal (other than the NRC), state and local regulations. NUREG-0586 GEIS, Supplement 1, was utilized as guidance in evaluating the non-radiological effects of decommissioning. New information is provided concerning the decommissioning impacts on socioeconomic, cultural, historical, archeological, and environmental justice considerations.

8.1.7 Overview of Regulations Governing Decommissioning and Final Site Release Section 8.6 provides a summary of federal, state and local regulations governing decommissioning of BRP and final site release of the property.

8.1.8 Summary and Conclusions The development of information contained in the various sections of this LTP has resulted in defining additional detail regarding the evolution of planned decommissioning activities. New or relevant information and significant environmental changes were reviewed against the existing BRP PSDAR, the BRP ER, and against NUREG-0586 (GEIS) criteria to determine if the conclusions reached in these documents are still valid for decommissioning and license termination activities planned at BRP. This additional information forms the basis for the conclusions provided in Section 8.7.

Page 8-3

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 912712005 8.2 SITE DESCRIPTION AFTER UNRESTRICTED RELEASE This section presents a summary of the final Greenfield condition of the site at the conclusion of demolition and license termination activities. License Termination Plan Section 1.4 provides a more detailed description of the final Greenfield condition as it relates to specific decommissioning activities. The impacts of these activities are discussed in Section 8.5.

At the time of license termination the site will meet the radiological criteria for unrestricted release as defined in 10 CFR 20.1302 in addition to any applicable State of Michigan criteria for release of the site. All site buildings that supported operation of the BRP Nuclear Plant will be demolished and disposed of in accordance with applicable regulations. Subsurface structures, foundations, piping, equipment, and utilities that supported facilities in the Industrial Area will be removed with the exception of the septic drainfield (ceramic tile) located west of the plant site. The Screenhouse structure and foundation will be demolished, and the shoreline returned to its original contour by filling a portion of the Discharge Canal; the breakwall jetty into Lake Michigan will remain in place. The lake water intake pipe will terminate at the former Screenhouse and be plugged with concrete; the intake structure out in Lake Michigan will remain in its current location. The only site buildings in existence will support Dry Fuel Storage and will be located near the Independent Spent Fuel Storage Installation (ISFSI) pad. There may be some remaining utilities (electric, phone, sanitary) supporting the ISFSI; these utilities will be routed from the south along the ISFSI road. Asphalt within the Protected Area and parking areas will be removed. Asphalt will remain on the roads accessing the site from US Route 31 N.

The Access Road approaching the site will terminate at a gravel parking area, and a road to the ISFSI will terminate just north of the ISFSI location. Figure 8-1 is a map of the BRP site.

Upon completion of the Final Status Survey (FSS) of the site (excluding ISFSI, see Section 1.3.2), affected areas will be graded for proper drainage. Topsoil, seed and other plantings will be utilized as appropriate to achieve the final Greenfield condition. While it is not known at this time what the future use of the site will be, it is expected that future use of the site will be similar to other lakefront properties in the region.

8.3 PSDAR UPDATE FOR REMAINING DISMANTLEMENT AND DECONTAMINATION ACTIVITIES License Termination Plan Chapter 3 identifies and details the remaining dismantlement and decontamination activities that are scheduled to be completed in support of license termination and unrestricted release. These activities are compared to the descriptions provided in the PSDAR and any changes identified.

Page 84

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9127/2005 8.3.1 Post-Shutdown Decommissioning Activities Report Description The BRP PSDAR was submitted to the NRC under the provisions of 10 CFR 50.82(a)(7). The PSDAR described planned 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 8-13]. Consumers Energy Co. intends to dismantle BRP in accordance with the DECON option found acceptable to the NRC in its FGEIS. Completion of this option is contingent upon continued access to one or more LLW disposal sites.

8.3.2 Impacts of Decommissioning Activities Completed decommissioning activities have been evaluated through planning efforts to ensure that no significant impacts beyond those originally identified in the PSDAR have occurred. Remaining decommissioning requirements are incorporated into the LTP, as approved by the NRC, and into site procedures and programs, as necessary (Reference 8-40]. Subsequent sections in this chapter of the LTP provide additional information regarding environmental effects of decommissioning.

8.4 BIG ROCK POINT SITE ENVIRONMENTAL 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, the appropriate reference is also included.

8.4.1 Geography and Demography 8.4.1.1 Site Location Description The BRP site is located on 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 closest population centers are the cities of Charlevoix, 3.5 miles southwest, and Petoskey, 11 miles east of the plant site. The site is owned by Consumers Energy and occupies approximately 580 acres (2.35 km2)2. Figure 8-1 depicts the property boundaries and Owner-Controlled Area and Figure 8-2 shows an aerial view of the BRP site and surrounding land. The Owner-Controlled Area is identical to plant property boundaries, except where US Route 31 traverses plant property. In those locations US Route 31 bounds the Owner-Controlled Area.

2 BRP site is 580.4 acres including highway right-of-way and 563.6 acres without this right-of-way.

Page 8-5

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/27/2005 The area immediately surrounding the plant Industrial Area is wooded and gently sloping; a significant portion of the site property has been classified as wetlands.

Approximately three miles to the south are Lake Charlevoix and Round Lake, inland extensions of Lake Michigan. Lake Charlevoix occupies approximately 27 square miles while Round Lake is a small natural harbor connecting Lakes Michigan and Charlevoix. A small stream, Susan Creek, exists to the east of US Route 31 and drains into Lake Michigan, east of the Owner-Controlled Area boundary.

Scattered rural and resort residences and a few commercial facilities are found within three miles of the site. Significant commercial and residential areas exist in the cities of Charlevoix and Petoskey. Industrial activity in the vicinity of BRP consists primarily of small manufacturing facilities. A small plastics manufacturer, employing approximately 150 people, is located to the east, adjacent to plant property. An operating cement plant with a quarry is located about six miles to the southwest. A large housing and recreational complex is located about nine miles to the east of the BRP site.

8.4.1.2 Population The areas near BRP are generally rural to suburban. The northern part of Michigan is a well-documented tourist destination, resulting in significant seasonal population fluctuations. Peak seasonal visitation occurs in the summer months (June through August) with corresponding population increases in Charlevoix and Emmet counties of up to 75 percent.

The permanent residential population within the five-mile radius is approximately 3,800 and includes a portion of the city of Charlevoix; Charlevoix County residential population is 26,090. The permanent residential population within 50 miles is approximately 195,000. The closest city with a residential population in excess of 25,000 is Sault Ste. Marie, Ontario, Canada, located approximately 100 miles from the plant. Traverse City, Michigan, approximately 50 miles to the south, does not have a population of greater than 25,000 within its incorporated boundaries, but the greater metropolitan area does exceed 25,000. There are no significant minority populations in the areas surrounding the BRP site [Reference 8-31].

Based on Census data over the last four decades, average population increases for area municipalities is 11 percent over 40 years or approximately 0.3 percent per year. The average annual population increase for the three surrounding counties (Charlevoix, Antrim and Emmet) is approximately 2.6 percent. The increase in rural residential populations is consistent with an overall trend recognized across the country of movement from urban to suburban or rural areas. Projected population growth rate for the regional area is expected to remain relatively constant.

Page 8-6

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/27/2005 8.4.1.3 Land and Water Use Within a Five-Mile Radius The general land use surrounding BRP is shown in Figure 8-3. Vegetation in this area consists largely of wooded areas and open fields. There are relatively few farms in the area immediately surrounding the plant site. Commercial land use consists primarily of small businesses in or near the city of Charlevoix. There are several small industrial sites within the five-mile radius. Several medium-density residential developments are located to the east of the plant. The remainder of residential and vacation homes are scattered throughout the area. There are also a variety of public recreation areas and several large bodies of water located within five miles of the plant.

• Farms Land use for farming is limited in the vicinity of BRP primarily due to nutrient-poor soils. According to 1997 agricultural census, approximately 12 percent of Charlevoix County is used for farming versus 16 percent in 1987 [Reference 8-8].

In general there has been a decrease in the number of both large and small farms in Charlevoix County over the last several decades. Currently, no lakefront farms are located along Lake Michigan within 35 miles of BRP due to poor soil quality and high economic value of Lake Michigan shoreline property.

• Commercial / Industrial Areas The majority of commercial land use occurs in the city of Charlevoix, located approximately 3.5 miles southwest of the plant. A small industrial park of less than ten small businesses and a 58-room hotel are located approximately 2.5 miles southwest of the BRP site boundary. Refer to Figure 8-3 for approximate locations of commercial/industrial facilities.

• Residential Areas Several residential areas are located in the vicinity of BRP, including subdivisions to the east, west and south and also within the city limits of Charlevoix. The closest residence to BRP is located approximately 1/2 mile to the west.

• Schools / Hospitals There are four schools within five miles of the plant. The size of these schools ranges from approximately 100-700 students. Charlevoix Area Hospital and Northern Michigan Hospital, both small regional facilities, are located five miles to the southwest and twelve miles to the east, respectively.

Page 8-7

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 912712005

• Recreational Areas Waterfront recreational areas include the Mt. McSauba Recreation Area, Lake Michigan Beach, Depot Beach, and Ferry Avenue Beach located on Lake Charlevoix, in addition to several public and private marinas also located on Lake Charlevoix. In the vicinity of the plant, both Lake Charlevoix and Lake Michigan are used extensively for recreational fishing. There are two golf courses within five miles of the plant; both of these courses are located along US Route 31, between BRP and the city of Charlevoix. Approximately 1.5 acres just west of the site and 140 acres just across US Route 31 are owned by the Little Traverse l Conservancy. South of US Route 31 approximately 100 acres are owned by the Charlevoix Rod and Gun Club. A non-motorized recreational trail was completed in 2002 along the BRP property parallel to US Route 31.

• Transportation Routes US Route 31 connects the cities of Charlevoix and Petoskey and provides access to the plant. A small airport serving the area is located south of Charlevoix along US Route 31.

• Major Bodies of Water The primary body of water in the vicinity of the plant is Lake Michigan. Lake Michigan has a surface area of approximately 22,300 square miles and a maximum recorded depth of 923 feet. To the south, at a distance of about three miles, is Lake Charlevoix, an inland extension of Lake Michigan. To the east of the plant is Susan Creek, which flows from Susan Lake north into Lake Michigan.

Lake Charlevoix has a surface area of about 17,000 acres, while Susan Lake has a surface area of about 130 acres.

8.4.2 Climate The following assessment of the climatology of the plant is based on data from on-site instrumentation and from the three National Weather Service (NWS) cooperative stations in the vicinity of BRP (Charlevoix, 5.2 miles west-southwest; Petoskey, 10.3 miles east; and East Jordan, 14.8 miles south of BRP).

Due to the proximity of the site to Lake Michigan, the influence of the lake on the climatology at the plant is significant throughout most of the year. In general, the lake has a moderating effect on the weather. Prevailing westerly winds bring cooler spring and early summer temperatures while fall and early winter temperatures are milder than those experienced further inland. Since the day-to-day weather is controlled mostly by the high and low pressure fronts, the area near BRP usually does not experience prolonged periods of hot, humid weather in summer, or extreme cold in the winter.

Page 8-8

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/27/2005 8.4.2.1 Temperature A moderating effect on ambient temperatures caused by Lake Michigan water temperatures is commonly experienced at the site. On the average, the warmest normal maximum and normal minimum temperatures both occur in July (76.6 °F and 57.0 OF). The coldest normal maximum temperatures usually occur in January (26.7 °F). However, the coldest normal minimum temperatures (12.8 0F) occur in February. By February, northern Lake Michigan is usually frozen over. Thus, its moderating effects on cold temperature and cloud coverage are minimized. For all months, the diumal range for the shoreline stations is consistently less than that of the inland site. During the spring months, the high temperatures are typically two to five degrees Fahrenheit cooler near the cold lake. Conversely, low temperatures during the autumn months are two to four degrees Fahrenheit warmer at the shoreline.

8.4.2.2 Precipitation Precipitation at the BRP site is very evenly distributed, averaging between two and three inches eight months of the year. Annually, the BRP site receives an average of 31.7 inches of precipitation. During a typical year, 149 days receive measurable precipitation. Heavier daily amounts of precipitation, those at and above 0.10", occur mainly during the spring, late summer, and fall. These amounts are partially the result of the thunderstorm season, which lasts from March to November.

8.4.2.3 Evaporation Local evaporation measurements are recorded at Lake City, Michigan, approximately 70 miles south of BRP. July, the warmest month, has the highest evaporation rate.

Total evaporation for the May through October seasonal averages about 28.0 inches.

However, the normal precipitation during this period is only 18.5 inches. Thus, moisture replenishment during the fall and winter months is important in maintaining overall area hydrology.

8.4.2.4 Snowfall Annually, the BRP site averages over 106 inches of snow; however, this has varied greatly over the years, ranging from as little as 43.3 inches in 1954 to as much as 231.0 inches in 1985. January receives the most, with an average of 33.4 inches.

The daily snowfalls at the BRP site are generally the result of light, but frequent, lake-effect squalls. Major snowstorms do occasionally occur at BRP. The maximum daily snowfall recorded in the vicinity of the plant was 20.5 inches in November 1950.

BRP's winter combination of below freezing temperatures and frequent snowfalls is ideal for snow accumulation. February has the deepest average snow cover, approximately 17 inches.

Page 8-9

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/2712005 8.4.2.5 Wind Wind data are currently collected by ground-level instrumentation located near the plant Monitoring Station. Historical wind data were collected by instrumentation located on the plant stack, 71.3 meters (233.9 feet) above-grade. The highest annual average wind speeds are associated with the north-northwest and north sectors, at 7.6 m/s (17.0 mph) and 7.4 m/s (16.6 mph), respectively. The lowest speeds, 5.6 m/s (12.5 mph), are associated with northeast winds. Calm winds, defined as less than 0.4 m/s, are observed only 0.26% of the time.

8.4.2.6 Severe Weather The highest monthly frequencies for thunderstorms at BRP occur in June and July, with an incidence of seven days each. The normal annual thunderstorm total is 36 days. Most of the storms that arrive at the plant originate over Lake Michigan where moisture is plentiful. Thus, a significant portion of the daily precipitation amounts are caused by convective activity. Flooding, resulting from either probable maximum precipitation or lake flooding event, would not exceed an elevation of 594.0 feet mean sea level (msl), approximate elevation of the Industrial Area

[Reference 8-18].

Tomadic activity in the vicinity of BRP is rare. The northern part of Michigan is at the extreme fringe of the Midwest tornado belt. During the period from 1930-1985, inclusive, only two tornado sightings have been recorded in Charlevoix County.

8.4.3 Geology and Seismology The following sections provide a general discussion of site geology and seismology.

8.4.3.1 Regional Geology The BRP site lies within the Great Lakes Section of the Central Lowlands Physiographic Province. The dominant features of this section were caused by glaciation and Include lakes, prominent end moraines, outwash plains, closed basins forming swamps or lakes, eskers and drumlins, and vast areas of rolling ground moraine between the end moraines. Because of the direction of advance and retreat of the last glaciation, lower peninsula Michigan has a strong surficial northwest-southeast grain. This is also the principal structural trend in Paleozoic rock.

Bedrock consists of limestone and shale of the Traverse Group of Middle Devonian age (395 million years before present (mybp) to 375 mybp). Three formations of the Traverse Group are exposed in the region: the Petoskey, Charlevoix, and Gravel Point formations. The bedrock immediately beneath the plant is the Gravel Point formation as the Petoskey and Charlevoix formations have been eroded away.

Much of the southern shoreline of Little Traverse Bay from Charlevoix to Petoskey is formed by outcrops of the Gravel Point formation. Interbedded with the limestone strata are beds of shale and shaley limestone.

Page 8-10

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9127/2005 BRP is located in the Central Stable Region Tectonic Province. This province is characterized by major domes, basins, and arches which formed during the Paleozoic Era (570 mybp to 240 mybp). The site lies above the northern flank of the Michigan Basin, which is one of the large tectonic structures in the Central Stable Region. Bedrock in the region dips at a low angle to the southeast toward the center of the Michigan Basin. Superimposed on this regional dip in the site region are gentle undulations caused by the presence of minor synclines and anticlines. These folds strike generally northwest-southeast and plunge to the southeast. The axes of major folds within Paleozoic rocks of the Michigan Basin also have northwest-southeast trends.

Regional jointing in the northern Michigan Basin have four major vertical joint sets:

N52 E, N46 W. N89 W, and N1 E. These trends are present in the site region with the northwest set being the most prominent. The joints are usually tight and widely spaced, but locally they have been widened by solutioning. Sinkholes exposed in local quarries appear to be aligned along major joint trends.

The Michigan Basin has been relatively stable for several hundred million years and is, therefore, relatively undeformed. Faults have been identified in Paleozoic rocks in the basin, however, no major faults are known in the site area. The faults in the basin are believed to be pre-Pennsylvanian (more than 330 mybp). They do not offset Pleistocene (10,000 years to 2 mybp) glacial deposits. Minor faults related to ancient solution collapse features have been observed in local quarries. Faults have been postulated, based on seismic reflection profiling in Lake Michigan. These faults have been evaluated and interpreted to be not capable of displacement.

8.4.3.2 Site Geology Elevations at the plant property on the south shore of Little Traverse Bay range from about 580 feet msl at the lakeshore to 700 feet msl, about one mile inland. Elevation at the plant Industrial Area is approximately 590 feet msl. From the lakeshore to about one mile inland, the terrain is a lowland that was once submerged beneath ancestral Lake Michigan.

Site topography is characterized by low beach ridges separated by swampy areas.

Approximately one to five miles inland from the lake, elevations range from 700 to 900 feet above lake levels. This area is a till plain with drumlins that rise 40 to 60 feet above it. A drainage divide causes surface water and shallow groundwater to flow north to Little Traverse Bay and south to Lake Charlevoix. It is also the probable recharge area for minor artesian zones in the soil beneath the plant site. A topographic map of the area surrounding BRP is provided in Figure 8-4.

Page 8-11

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9127/2005 The geology of the site was investigated in several phases. Two exploratory borings were drilled into the top of bedrock in May 1959, and seven more borings were drilled into rock in February 1960. In 1979, three borings were drilled to determine the dynamic characteristics of the soil and rock beneath the site. In 1999, 26 borings were drilled to better define geologic and hydrogeologic conditions at the site. In 2001 and 2002, 15 groundwater wells and borings were drilled to further identify site hydrogeologic conditions in the vicinity of the Industrial Area [Reference 8-28].

Section 2.4.3 contains additional information regarding groundwater and geology investigation wells as they relate to site characterization.

8.4.3.3 Seismology The probability of earthquakes of significant intensity near BRP appears to be very low. Recorded earthquake history for Michigan and the surrounding region has classified all earthquakes in the region as minor or intermediate. The nearest recorded earthquake, occurring in 1909, was centered near Menominee, Michigan, approximately 110 miles from the plant. Since 1909, no earthquakes centered within a 150-mile radius of BRP have been documented. Figure 8-5 is a United States Geologic Survey (USGS) seismic history for Michigan [Reference 8-19].

8.4.4 Hydrology The information presented in this section describes general characteristics of the surface and groundwater within the area immediately surrounding BRP.

8.4.4.1 Surface Waters The water level of Lake Michigan has varied between approximately 576 and 583 feet msl since 1905. Lake Michigan water level experiences long-term, seasonal, and short-term variations. Long-term variations are caused by periods of higher or lower than usual precipitation or evaporation lasting several years and extending over a large part of the Great Lakes watershed. The highest recorded (1905-present) mean monthly water level on northern Lake Michigan near BRP was 582.0 feet msl (1986). The minimum monthly level of Lake Michigan was elevation 576.6 feet msl (1964) [Reference 8-30].

Big Rock Point is located in an area where surface runoff generally flows into Lake Michigan. The plant Industrial Area is currently equipped with a regulated storm drainage system, consisting of catch basins and corrugated metal pipes emptying into Lake Michigan. Drainage from building areas generally flows away from the plant area toward Lake Michigan. Some runoff from high ground is diverted around the plant to the lake by a ditch and culverts on the south and east sides of the Industrial Area. Drainage areas are well vegetated and relatively flat. All underground drainage piping will be removed and surface water flow will be channeled to a grassy area east and west of the former Industrial Area.

Page 8-12

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9127/2005 In general, the northern portion of Lake Michigan is characterized as an oligotrophic lake with excellent water quality. Periodic analyses have been performed on Lake Michigan waters in the vicinity of the plant. Water quality data reflect analyses performed on Lake Michigan waters near the plant Discharge Canal, in Little Traverse Bay, and outside the Pine River Channel leading from Round Lake to Lake Michigan (also known as the Charlevoix Harbor area). Water quality information obtained from these locations is fairly consistent and is a reasonable representation of Lake Michigan water quality in this region.

8.4.4.2 Groundwater Groundwater at the site moves north into Lake Michigan from the groundwater divide between Lakes Charlevoix and Michigan.

Three groundwater bearing zones have been identified at the site. These include the lower portion of the near-surface and gravel layer (three-five feet below the surface),

the intermediate depth sand layer (approximately 20-25 feet below the surface) and the underlying fractured limestone bedrock. The most probable entry point for groundwater found in the uppermost zone is located south of the main power station area in the undeveloped portion of the BRP site. Much of this area is low, wetland type terrain, which collects infiltration from property to the south of the site. The groundwater entry points for the other two units are most likely located even farther south. The groundwater movement direction in all three of these units is northerly into Lake Michigan. The near-surface location of the two upper groundwater bearing units would prevent their use as sources of drinking water due to lack of capacity and State Regulations on drinking water well depth. The limited thickness of these same two units would likely prevent their use as sources of irrigation water. The fractured bedrock zone is considered to be the main drinking water aquifer at the site, and it is also a potential source for other non-potable water uses.

Several groundwater monitoring wells have been installed near the BRP Industrial Area. Nine monitoring wells were installed in 1994 and are sampled semi-annually for radioactivity. Additional groundwater sampling points were installed for the 2002 hydrogeologic assessment. Section 2.4.3 provides a detailed explanation of the BRP site groundwater monitoring locations. Dewatering and groundwater control measures are expected to be necessary during subsurface foundation and equipment removal and subsequent final status surveys of excavated areas.

Dewatering activities may require temporary barriers to groundwater flow prior to and during demolition and final status surveys. These barriers are not expected to influence groundwater flow characteristics beyond the demolition and final status survey interval.

The well water system at BRP is located approximately 800 feet east of the plant at a depth of 135 feet. The site well will be decommissioned in accordance with Michigan Department of Environmental Quality (MDEQ) regulations. Other water supplies near BRP generally consist of private residential and commercial wells or well Page 8-13

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 912712005 systems serving small residential communities. The city of Charlevoix obtains water directly from Lake Michigan. The city water intake is located approximately four miles from the plant, west of the Pine River Channel connecting Lake Michigan and Round Lake.

8.4.5 Natural Resources In addition to the aquatic resources described in Section 8.4.1.3, several public lands and conservation areas are located near BRP, offering a variety of recreational opportunities including fishing, hunting, boating, swimming, hiking and picnicking.

Waterfront recreational areas include the Mt. McSauba Recreation Area, Lake Michigan Beach, Depot Beach and Ferry Avenue Beach located on Lake Charlevoix.

In the vicinity of the plant, both Lake Charlevoix and Lake Michigan are used extensively for recreational fishing. Approximately 1.5 acres just west of the plant is owned by the Little Traverse Conservancy. This land includes 500 feet of Lake Michigan shoreline, reserved as a natural habitat and receives minimal public use.

Figure 8-3 shows the locations of public lands listed above as well as the locations of recreational facilities within five miles of BRP. There are no known mineral resources as defined by USGS on the BRP site [Reference 8-32].

Commercial fishing in Lake Michigan near BRP is regulated under the terms of the 1985 negotiated settlement involving Native American tribes, the State of Michigan and the U.S. Department of Interior. Currently, three northern Michigan tribes, operating under the regulation of the Chippewa/Ottawa Treaty Fishery Management Authority (COTFMA), fish in the treaty-ceded waters of Lake Michigan. The three tribes involved are the Sault Ste. Marie Tribe of Chippewa Indians, Bay Mills Indian Community, and the Grand Traverse Band of Ottawa/Chippewa Indians. The area of Lake Michigan near BRP is considered a "transition zone," and no tribal commercial fishing is allowed for the periods from June 1 to September 30 and November 1 to December 31. Under the provisions of this treaty, the region of Lake Michigan near BRP is designated as a primary lake trout rehabilitation zone.

8.4.6 Cultural, Historical and Archeological Resources The Michigan Historic Preservation Office has reviewed the BRP LTP under the authority of Section 106 of the National Historic Preservation Act and determined that three areas within the BRP site appear to be eligible for listing in the National Register of Historic Places. These areas, discussed in the following sections, are:

1) The former nuclear power facility (buildings and equipment),

2) Prehistoric archeological site identified during Phase II archeological study, and

3) The "Big Rock" located in Lake Michigan adjacent to the shoreline west of the plant.

Page 8-14

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/27/2005 Consumers Energy, as a concurring party, intends to enter into a Memorandum of Agreement (MOA) between the NRC and the Michigan State Historic Preservation Office (SHPO), to preserve the historic, archeological and cultural resources located within the BRP site. The actions specified in the stipulations of this MOA are to be completed prior to sale or transfer of ownership of any portion of the BRP property.

8.4.6.1 Nuclear Plant Facility The nuclear plant facility is considered eligible for listing in the National Register of Historic Places. This eligibility is based on BRP's status as one of the first commercial high-density boiling water power reactors, its use as a research site for both the early nuclear power industry and medical radiation treatments, and also its 1991 designation by the American Nuclear Society as a "Nuclear Historic Landmark."

In order to ensure that the history of the plant is preserved, Consumers Energy has agreed to perform recordation to the National Park Services Historic American Engineering Record standard documenting the facility's design and operational history, and also to develop exhibit(s) in conjunction with the local historical society commemorating the history of BRP.

8.4.6.2 Archeological Studies A Phase I archaeological survey of plant property was conducted in 2000 assessing the historic significance of previously undisturbed land [Reference 8-29]. This Phase I survey identified seven prehistoric archeological sites that warranted additional study to complete their evaluation. A Phase II survey of these seven prehistoric archaeological sites was completed in 2002 [Reference 8-36]. The Phase II survey found one area (two of the seven identified locations) possesses significant artifacts from Native American prehistoric activity.

8.4.6.3 Traditional Cultural Property Along the Lake Michigan shoreline, approximately Y2 mile west of the plant Industrial Area, exists a large rock (approximately 4m by 4m in size) visible both from the water and shoreline. The 'Big Rock" has historical and cultural significance to the local Native American tribe, Little Traverse Bay Band of Odawa3 Indians, and has been documented as a navigational marker used by native people as they canoed across Little Traverse Bay each year. A Traditional Cultural Properties study completed in 2003 determined that the OBig Rock" is a significant cultural resource to local Native American groups [Reference 8-37].

8.4.7 Ecological Resources The following sections provide an overview of the aquatic flora and fauna, terrestrial flora and fauna, and Threatened and Endangered Species information for the biological communities in the vicinity of BRP.

3 Odawa isthe Native-American equivalent of the English word Ottawa.

Page 8-15

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 912712005 8.4.7.1 Aquatic Ecology

• Aquatic Flora While no current data is available on aquatic flora near the BRP site, results of several Lake Michigan near-shore water studies indicate that the year-to-year distribution of phytoplankton throughout Lake Michigan is relatively constant with expected seasonal variations.

• Aquatic Fauna Characterization of aquatic biological communities provided in this subsection focuses on Lake Michigan and Lake Charlevoix. The littoral mainland area of Lake Michigan has potential spring and summer spawning grounds for several species of fish. However, the immediate vicinity of BRP has not been identified by the U.S. Fish and Wildlife Service as a critical spawning ground. The site does not represent a unique or specialized niche for colonization or ecological activities and the habitat is typical of the northern part of Lake Michigan's lower peninsula shoreline.

Popular sport fish found in Lake Charlevoix and the Charlevoix County area of Lake Michigan include: lake trout, coho salmon, chinook salmon, rainbow trout, pink salmon, brown trout, walleye, channel catfish, burbot, yellow perch, lake whitefish, smallmouth bass, largemouth bass, northern pike, and sunfish. Forage fish stocks in Lake Michigan include such species as alewife, smelt, bloater chubs, and sculpins.

8.4.7.2 Terrestrial Ecology Terrestrial biological communities onsite are located on level to gently sloping lake plain soils that are cobbly and gravelly. Most of the site property is composed of woodlands, with limited open-land acreage that is converting to forest. Both sand and stone beaches occur onsite. Soils on the property are in the Detour-Kiva association. These soils are very poorly suited to both farming and silvicultural practices. The following sections describe soil, terrestrial plant and wildlife in the vicinity of BRP,

• Soils The soil survey of Charlevoix County, Michigan, includes all site soils in the Detour-Kiva association. Soil types and their approximate onsite acreage are provided in Table 8-1; Figure 8-6 provides information on approximate locations of these onsite soil types. In general, the site is poorly suited to agriculture use due to nutrient-poor soils and the high economic value of Lake Michigan shoreline. This high capital cost makes farming not economically feasible, although small residential gardens are possible.

Page 8-16

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8. SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9127/2005 I Table 8-1. Big Rock Point Soil Types Soil Description Onsite Type Acreage* (/) Comments AgB Alpena gravelly- 188 acres This isa soil of beach ridges and terraces. Onsite, this soil is sandy loam, (33%) found predominantly in a band about a quarter-mile wide along 0-6% slopes the beach ridges and terrace adjacent to Lake Michigan.

Permeability is rapid, natural fertility is low, organic content is moderately low. The Industrial Area Is comprised of this type.

DeB Detour cobbly 228 acres This soil is a poorly drained soil with slow permeability and loam, 0-6% (40%) surface runoff. Detour soils are poorly suited to farming slopes because of wetness. Onsite, Detour soils are generally forested.

EdB Eastport sand, 4 acres This is a soil of beach ridges and low dunes on the plant site.

0-6% slope (<I%) This soil isfound about a quarter-mile inland in a narrow band associated with the steepl sloped Emmet-Onaway soils.

EoF Emmet-Onaway 17 acres This soil type is characterized by steep slopes, are sparsely sandy loam, 25- (3%) wooded and prone to wind erosion.

50% slopes ]

Hs Hessel cobbly 105 acres Hessel soils are thin, poorly drained soils formed on lake plains loam (18%) and lake terraces. Water availability is high, organic matter and natural fertility is high. Depth is seldom more than two feet.

Lb Lake beach 27 acres These narrow strips of lake beach frontage are comprised (5%) primarily of sand, although the sand is covered by substantial cobble and boulders. These beaches are subject to storm action and may vary significantly Insize depending on Lake Michigan level.

Rc Roscommon I acre This is a poorly-drained soil with high organic matter but low sand 0-9% (<1%) natural fertility. This wetland soil occurs along Susan Creek on slopes Ithe far eastern perimeter of the plant property

• Acreage and percentage of onsite soils are based on the original plant property of 570 acres.

• Flora Table 8-2 lists land cover types and their acreage within the BRP property boundary including tree species (where available) and stocking density. Figure 8-7 depicts general forest cover on the BRP property based on 1978 color aerial photos obtained from the Michigan Department of Natural Resources (MDNR), Land and Water Management Division. Since 1978, dramatic successional changes have occurred at the BRP site. Open areas have succeeded to young stands of cedar and birch.

Growth that was formerly dominated by sawtimber-sized aspen and birch is now dominated by pole-sized white cedar and balsam fir due to death of the senescent aspen and birch and release of the coniferous understory. In general, the BRP site forest vegetation is now typically characterized as lowland conifer, pole-sized and well-stocked (cover Type 423).

Page 8-17

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8. SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/2712005 I Table 8-2. Big Rock Point General Land Cover Types Cover Description Onsite Acreage" Comments Type* (%)

146 Utilities 16 acres Areas converted to industrial use. Note: This type (3%) has increased as a result of decommissioning.

31 Open land 35 acres This is primarily old grazing or hay land that is (6%) reverting to shrubs and trees. Today, much of this type would be classified as 32, shrub land, or a young forest type.

32 Shrub land 7 acres This type represents hay or grazing lands that are (1%) reverting to a forested condition.

411 Northern 28 acres Northern hardwoods consist of sugar maple, beech Hardwoods (5%) and white ash. The majority of the acreage Is of saw-Umber size. The shrub and floral understories in these stands are well developed and diverse.

413 Aspen/White 97 acres These stands are located on the better-drained Birch (18%) soils. At pole-size, the shrub and floral understories in these stands are moderately well developed. Conifer understories are well developed on wetter areas.

414 Lowland 233 acres Floral elements and a conifer understory area were Hardwoods (41%) well developed in these stands. Today, these (Aspen) areas have succeeded to lowland conifers of pole size and would generally be typed as 423, lowland conifers 422 Upland 97 acres The current observations indicate these are Conifers (17%) lowland conifers, Type 423.

423 Lowland 50 acres Pole-sized white cedar is dominant; balsam fir, and Conifers (9%) immature white cedar are common In the understory. Natural succession has converted most of the aspen/birch and lowland hardwood stands to lowland conifers. Type 422, upland conifers, should have originally been designated as

._ Type 423, lowland conifers 72 Beaches 7 acres Beach acreage varies with lake levels, wind (1 %) direction, and storm accretion and removals.

Beach grass, wormwood, willows, white cedar, dogwood, elm and other hardy, early successional species move inland or lakeward with the availability of beach. Great Lakes beaches may contain unique floral elements, such as several threatened species, which are discussed in Section 8.4.7.3.

Nomenclature follows the Michigan Land Cover Use Classification System. The numerical system describes forest type for forested areas.

• "Acreage and percentage of onsite vegetation are based on the original plant property of 570 acres.

Page 8-18

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/2712005 Fauna Birds and mammals in the vicinity of BRP are generally representative of species found along shoreline and inland habitats in northern, lower Michigan. Species diversity, particularly of "non-game" species, may be higher onsite in the more mature habitats than they are regionally. However, species favoring younger successional stages, including uneven-aged aspen stands, such as whitetail deer, snowshoe hare or ruffed grouse may not be as abundant near the plant as they are regionally.

Employee observations indicate deer, grouse, and wild turkey are present onsite, and rarer animals such as black bear or bobcat may be present from time to time. Coyotes appear to be common, as are two of their common prey, snowshoe hare and cottontail rabbit. Both beaver and muskrat are common along Susan Creek. Several bald eagle sightings have also occurred on and near the BRP site since plant shutdown. Recreational hunting of deer, turkey, and bird occurs on private land near the BRP site.

8.4.7.3 Threatened and Endangered Species The BRP site is located in relatively undisturbed natural habitats on the shore of Lake Michigan. Great Lake beaches, both sandy beaches and rock beaches, have the potential for harboring Federally-listed threatened species such as Dwarf lake iris (Iris lacustris), Houghton's goldenrod (Solidago houghtonih), and Pitchers thistle (Cirsium pitchen). These species are well-represented in shoreline habitats in Charlevoix County and adjacent counties, as evidenced by Michigan Natural Features Inventory (MNFI) records. Several surveys by Consumers Energy have documented the presence of Pitchers Thistle and a State-listed threatened species, the Lake Huron tansy (Tanacetum huronense), on beach areas west of the plant Industrial Area. Dwarf Lake Iris and Houghton's Goldenrod were not found on the BRP site despite thorough searches, the most recent in August 2002 [Reference 8-20].

Inland, conifer swamp and upland habitats could possibly harbor plant or animal species that are State-listed as threatened or of special concern. However, no such species have been specifically identified at this time.

8.5 ENVIRONMENTAL EFFECTS OF DECOMMISSIONING The following sections address the environmental impact for the process of decommissioning and site restoration of the BRP Nuclear Plant.

8.5.1 Radiological Impacts of Decommissioning Radiological impacts of decommissioning discussed below include:

• Onsite occupational radiation doses, Page 8-19

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 912712005

• Offsite radiation exposures and monitoring, from liquid and gaseous effluent releases,

• Effects of decommissioning accidents,

• Radiation exposures resulting from LLW disposal and transportation,

• Spent fuel storage, and

• Radiological criteria for unrestricted use of the site.

8.5.1.1 Occupational Radiation Exposures Occupational radiation exposure at BRP is controlled in accordance with 10 CFR 20.

The requirements of 10 CFR 20 are implemented through a comprehensive Radiation Protection (RP) Program. The BRP RP Program is applied to all activities involving radiological hazards. The program is based on the premise that all exposures should be reduced to levels, which are as low as reasonably achievable (ALARA), to both the individual worker and to the workforce as a whole.

• Occupational Radiation Exposure Comparison to GEIS The total decommissioning dose for BRP RP activities is estimated to be 700 person-rem. This estimate is derived from the original five-year SAFSTOR dose estimate and was adjusted by the factor of radioactive decay that would have occurred if the five-year SAFSTOR option had been utilized and other radiological considerations. The immediate dismantlement (DECON option) dose estimate is significantly lower than the value of 1874 person-rem for a boiling water reactor facility identified in the GEIS. A chemical decontamination of the primary Nuclear Steam Supply System was completed in 1998, resulting in removal of approximately 435 curies of radioactivity. The performance of the chemical decontamination negates the disadvantage of the DECON option as discussed in the GEIS.

To date, actual occupational doses have been consistent with dose estimates for completed decommissioning activities. Dose projections for each calendar year are completed annually based on specific planned work activities. The most significant contributors to occupational doses for remaining dismantlement activities include handling and shipping of major components (Reactor Vessel, Steam Drum, Spent Fuel Pool); dismantlement of the radwaste system; and the handling and shipping of low-level radioactive waste.

• Radiation Protection Program The requirements of 10 CFR 19 and 20 are implemented by administrative and working level plant procedures. The elements of the BRP RP Program are described below.

Page 8-20

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 912712005

• ALARA Program The ALARA Program utilizes reviews in initial engineering phases as well as job planning and dose estimates or goals for major tasks, work groups and individual workers. Reviews are performed at various administrative levels, with the highest doses requiring the highest level of management review. Both contract and company employees are covered by these procedures.

Specific techniques of dose reduction which are considered in job planning include shielding, decontamination, special training (including mockup training or special tests of tools and procedures as appropriate), remote tools, remote video monitoring, use of alarming dosimeters, use of minimum effective crew size and other items, including suggestions from workers, which might reduce dose while permitting safe execution of the task.

• Radiation Respiratory Protection Program The BRP Radiation Respiratory Protection Program meets all requirements of 10 CFR 20, Subpart H, (20.1701 through 20.1704). The Radiation Respiratory Protection Program is a continuation of the ALARA program into the area of airborne radioactivity intake. The policy is to maintain total effective dose equivalent (TEDE) ALARA, regardless of the mix of internal and external exposure. Whenever practicable, engineering features are used to control airborne radioactivity. These features include installed ventilation, special mobile filter units, work enclosures, and other methods of maintaining the breathing zone at minimal levels of radioactivity. Individual respiratory protective devices may be utilized if such use minimizes TEDE or is required by other workplace hazards, e.g., asbestos, lead, etc.

• Radioactive Materials and Contamination Control Control of radioactive materials for BRP decommissioning involves the control of activated or contaminated materials originating from plant operation, as well as control of sealed sources licensed to the plant for use in instrument calibrations.

Activated and contaminated materials are controlled predominantly by procedures and work practices specific to decommissioning tasks involving work in radiation and contamination areas, and for handling radioactive waste. These controls are applied as a portion of the overall program of minimizing radiation exposure to both workers and members of the public. Specific program items include:

• Personnel contamination control,

• Controls to minimize spread of contamination,

• Labeling of radioactive materials,

• Release of materials for unrestricted use,

• Handling of radioactive materials for storage and shipment,

• Liquid and gaseous release, and

• Sealed source accountability.

Page 8-21

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/27/2005 8.5.1.2 Offsite Radiation Exposure and Monitoring The Radiological Environmental Monitoring Program (REMP) has been modified to monitor specifically for the effects of decommissioning activities as described in the Offsite Dose Calculation Manual (ODCM). This program currently consists of monitoring doses associated with liquid and gaseous effluents, gamma radioactivity at the site boundary and near the ISFSI, and radioactivity in specific media (shoreline sediment, fish, well water, etc.). Reports of radioactive effluents released from BRP and radiological environmental monitoring results are submitted annually to the NRC in accordance with BRP Defueled Technical Specifications, 10 CFR 50.36(a), and 10 CFR 50, Appendix I, Section lll.B.1 [Reference 8-1 1]. It is anticipated the requirements for environmental radiological monitoring will be revised as the potential for radiological effects/effluents is eliminated and documents controlling these activities are modified accordingly.

Actual doses during decommissioning are small fractions of those effluent doses received during the operating phase of the plant. Gaseous emissions decreased immediately upon plant shutdown while liquid radioactivity has decreased more slowly due to the presence of Cs-137 and Co-60 with their longer half-lives. Annual doses to the public during BRP's operating period and the initial phase of decommissioning have not exceeded 0.5 millirem for liquid effluents and 0.1 millirem from gaseous effluents.

Releases of radioactive liquid and gaseous (including particulate) effluents during the decommissioning period are minimized by use of existing radioactive effluent treatment systems until such time as those systems are deactivated in the decommissioning process. Temporary systems may be utilized, as necessary to meet the objectives of maintaining doses to the public ALARA as identified by 10 CFR 50, Appendix I. Effluent monitoring or sampling systems are maintained either by use of existing monitoring systems or by temporary equipment or actions during releases. Monitoring or sampling instruments of equal or higher sensitivity than those currently installed will be utilized as appropriate for decommissioning activities involving liquid or gaseous effluents.

Both liquid and gaseous effluent doses are calculated using industry-standard models, applying site-specific parameters of meteorology, and dilution factors to the nearest public water supply, nearby recreational activity and critical receptor. In addition, monthly, quarterly, and annual dose calculations are performed prior to each liquid batch release (or continuous gaseous release) to assure that the guidelines are not exceeded prior to completion of the release [Reference 8-35].

8.5.1.3 Environmental Effects of Accidents and Decommissioning Events Analysis of potential decommissioning accidents involved an assessment of planned BRP decommissioning activities to identify accidents with significant radiological release capabilities. These decommissioning accidents are categorized in two areas, events involving spent fuel and external events. Events involving spent fuel include fuel handling accidents, loss of spent fuel pool cooling, spent fuel pool freezing and dry fuel storage-related accidents. External events are initiating events Page 8-22

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 912712005 that have the potential to result in radiological consequences; these include loss of offsite power, aircraft hazards, fire and natural phenomena (flooding, tornadoes, etc.). The BRP UFHSR contains a detailed discussion of decommissioning accident scenarios and conclusions [Reference 8-18]. The Fuel Solution Storage System Final Safety Analysis Report addresses accidents and natural phenomena specifically applicable to the dry fuel storage system located at the ISFSI

[Reference 8-2].

A review of these scenarios to determine which accident would produce the maximum off-site radiological consequences has been performed in accordance with the guidelines of the Environmental Protection Agency (EPA) Manual of Protective Action Guides (PAGs) and Protective Actions for Nuclear Accidents, EPA- 400

[References 8-5 and 8-21]. It has been determined doses for onsite essential personnel will remain below their occupational dose limits, assuming standard protective equipment is utilized. Radiological consequences for any of these accidents will not result in any offsite dose to the public, which exceed the EPA PAGs. The evaluation of potential site accidents and corresponding worst-case radiological consequences provides the basis for the Site Emergency Plan.

An evaluation of potential non-fuel related decommissioning accidents at BRP has also been performed. Decommissioning activities following final plant shutdown were evaluated, including system and equipment deactivation, decontamination, and dismantlement; radioactive material handling and storage; and transportation of radioactive materials. Types of postulated accidents reviewed were explosions and fires, loss of contamination control, waste transportation accidents, external events, and natural phenomena. In addition to the standard decommissioning activities, postulated accidents associated with potential long-term storage of radioactive waste during decommissioning also were evaluated.

The GEIS assumes that the reference baseline BWR utilizes high efficiency particulate air (HEPA) filters for plant ventilation effluents. To remain within the bounds of the FGEIS and recognizing that during dismantlement airborne particulate releases could be significantly reduced by plant HEPA filtration, a HEPA filtration system was installed in the ventilation system and is used for dismantlement activities involving major source terms of particulate activity.

It is concluded all postulated decommissioning accidents for BRP are bounded by the results described in the GEIS. Thus, as concluded by the GEIS, decommissioning will have a minimal impact on public safety and health.

Page 8-23

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/2712005 8.5.1.4 Evaluation of Decommissioning Low-Level Radioactive Waste (LLRW) Volume &

Transportation Considerations Big Rock Point's decommissioning requires disposal of a large volume of radioactive and non-radioactive materials to restore the site and allow release of the site for unrestricted use and license termination. Materials that cannot be decontaminated to the level below the radioactive release criteria are processed as radioactive waste.

Big Rock Point ensures appropriate processing, packaging, and control of solid, liquid, and gaseous radioactive wastes through procedures implementing requirements of the Process Control Program, the ODCM, and the Demolition Debris Disposal Program [References 8-11 and 8-14]. Chapter 3 describes the Demolition Debris Disposal Program developed to dispose of non-radioactive building demolition debris at a State of Michigan licensed, regional landfill (see Section 3.4.1.1).

The much smaller size of BRP as compared to the reference BWR in the GEIS results in volumes and total quantities of radioactivity required for shipment, which are on the order of 15-20% of the quantities assumed in Appendix N of the GEIS.

Big Rock Point had a rating of 240 megawatt thermal (Mwt), significantly less than the 3320 Mwt reference BWR; thus, the total quantities of radioactivity present on site, the total volumes of waste produced and volume of waste shipped offsite are significantly less than those assumed in the FGEIS.

To date, the majority of radioactive waste shipped for disposal has included system components, material from spent fuel pool cleanout (components, resins, filters, etc.), asbestos and miscellaneous dry active waste (see Section 3.5.4). Consumers Energy contracted with Duratek, Inc., to provide waste processing/disposal services for the BRP Decommissioning Project. To support contractual arrangements and administration, waste quantities, as determined by TLG Services, Inc., are estimated and expressed in units of weight (pounds) as opposed to volume. Table 8.3 summarizes the estimated waste types by waste class as delineated in Title 10 of the Code of Federal Regulations, Part 61.55. Big Rock Point has secured disposal/

processing contracts for all large components and significant waste streams anticipated from BRP decommissioning.

Page 8-24

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 912712005 I Table 8-3. Total Estimated Waste to be Shipped from BRP Waste Type Waste Class

• Weight (Pounds)

CONTROLLED BURIAL Metal C 18,500 Metal >C 3,000 Resins B 10,000 LLRW A 465,000 Metal A 313,000 Total 809,500 PROCESSED WASTE Metal A 6,715,000 Concrete A 4,063,000 Soil A 2,255,000 Lead A 240,000 Asbestos A 250,000 Dry Active Waste A 450,000 Total 13,973,000 CLEAN PROCESSED MATERIALS Concrete N/A 80,100,000 Metal 2,126,000 Mixed Hazardous LLRW 5,000 Total 82,231,000 Waste classified as delineated in Title 10 of the Code of Federal Regulations, Part 61.55.

In general, doses due to transportation of radioactive waste are bounded by the GEIS. The quantity of radioactivity for BRP waste is offset somewhat by a longer shipping distance for the higher activity wastes (800 km assumed in the GEIS versus 1900 km to Barnwell, via the waste processor, for BRP). The majority of the lowest activity wastes designated for disposal are shipped to Envirocare in Utah (via the BRP waste processor), the very low dose rates compensate for the longer travel time. Overall, both occupational and public doses remain bounded by the GEIS calculations.

8.5.1.5 Spent Fuel Storage An onsite ISFSI will accommodate all current spent fuel in seven storage casks. An additional cask is designated for storage of greater-than-Class-C radioactive wastes.

The environmental impacts associated with dry fuel storage at BRP include land use to accommodate the ISFSI (approximately 20 acres, most of which was previously undisturbed land) and small occupational doses for workers assigned to monitor the installation. Offsite/public doses associated with the ISFSI are considered not to be significant. Figure 8-1 shows the location of the ISFSI within the BRP site boundary.

Page 8-25

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/2712005 8.5.1.6 Radiological Criteria for License Termination Following decommissioning, residual radioactivity will be limited to allow release of the property for unrestricted use such that an individual of a critical population group living on the site would not be expected to receive a dose greater than 25 mrem/year from all applicable combined environmental exposure pathways. License Termination Plan Chapters 2, Site Characterization, Chapter 5, Final Status Sunrey Plan, and Chapter 6, Compliance with the Radiological Criteria for License Termination, provide the required information regarding achieving unrestricted site release.

8.5.2 Non-Radiological Environmental Impacts The following subsections provide an assessment of the non-radiological impacts of decommissioning and site release. Generic Environmental Impact Statement Supplement 1 was utilized as the basis for identifying potential environmental impacts and determining the significance of these impacts.

8.5.2.1 Onsite / Offsite Land Use Several previously undeveloped site areas have been utilized for various decommissioning activities. These include clearing land for additional parking areas and temporary office buildings, construction of the ISFSI, and soil storage/laydown areas. Of the 580-acre site, approximately 20 acres were utilized for plant original operational activities. Approximately 40 additional acres of site property have been developed for decommissioning purposes since plant shutdown in 1997. It is not expected any additional undeveloped site property will be altered for future decommissioning activities. Also, since the site is planned to be restored to a Greenfield condition, the long-term effects of onsite land-use are not significant. It is unlikely any offsite land will be utilized for decommissioning purposes, with the exception of the designated landfill for disposal of non-radioactive building demolition debris (see Section 3.4.1.1).

8.5.2.2 Water Use Big Rock Point withdrew water directly from Lake Michigan for equipment cooling and space cooling purposes and also for the radioactive effluent releases system.

Water was withdrawn from the lake via a five-foot diameter intake pipe, located 1500 feet offshore at a depth of approximately 40 feet. The majority of the water was discharged back to Lake Michigan with little or no change to chemical or physical parameters. The environmental effects of water discharges associated with plant operation were minimal. Environmental effects associated with decommissioning water usage have also been minimal because of reduced quantities withdrawn from Lake Michigan. The National Pollutant Discharge Elimination System (NPDES) permit for BRP was terminated in October 2004.

4 Recently, land surveys conducted to support site characterization have determined the BRP site property is 580.4 acres including road right-of-way.

Page 8-26

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/27/2005 Another source of water usage is groundwater from the site well water system. The principal use of groundwater is for the domestic water system. Groundwater usage is expected to decrease as staffing levels decline throughout the decommissioning process.

8.5.2.3 Water Quality No significant, long-term impacts on Lake Michigan are expected from decommissioning activities. The thermal plume created by discharge of condenser circulating water has been eliminated when plant operation ceased. Restoration of the discharge canal and demolition of the Screenhouse structure was completed in 2004. All work along the Lake Michigan shoreline was performed under a joint permit from the U.S. Army Corps of Engineers and the MDEQ [Reference 8-38]. No adverse affects on water quality were observed during these work activities.

An unspecified amount of stormwater runoff is discharged to Lake Michigan for both industrial activities (via the remaining stormwater collection system) and construction activities. The BRP Storm Water Pollution Prevention Plan defines specific requirements for ensuring proper management of stormwater discharges from the site [Reference 8-17].

No adverse impacts on groundwater are anticipated from specific decommissioning activities. In addition, the groundwater system under the plant area is effectively separated from any potential contact with local private wells and the down-gradient direction of groundwater flow is to the north into Lake Michigan.

8.5.2.4 Air Quality Fugitive dust will be generated from the various demolitions and dismantling operations. Fugitive dust may originate from concrete during removal of buildings or structures, removal of piping and related components, and from soil excavation to remove components such as underground utilities or potentially contaminated soils.

Reasonable control measures will be utilized to minimize the quantities of fugitive dust. The existing ventilation system, supplemented by localized HEPA filtration units, will monitor and filter particulate emissions from dismantling activities inside the Containment and Turbine Buildings. Excavation of soils and concrete demolition will include the use of wet suppression or chemical stabilization, as required, to minimize the generation of fugitive dust.

The controlled dismantlement and packaging of site components and structures will preclude fugitive dust from becoming an ambient air quality concern during the decommissioning process. 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.

Page 8-27

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/2712005 8.5.2.5 Aquatic Ecology Aquatic impacts associated with plant operation were considered to be minimal, and the potential impacts associated with the decommissioning process are also minor because plant water usage and discharge quantities are greatly reduced. Therefore, no additional adverse impacts to the aquatic flora or fauna are anticipated from decommissioning activities. Additionally, all applicable NPDES limits, as approved by the EPAtMDEQ, will be maintained throughout the decommissioning process.

8.5.2.6 Terrestrial Ecology Since decommissioning activities will generally take place within the developed acreage on the plant property, additional impacts to site flora and fauna are anticipated only for the ISFSI site and new parking or laydown areas.

8.5.2.7 Threatened and Endangered Species Several threatened plant species have been identified on BRP site property (see Section 8.4.7.3). Locations of these plant species are clearly marked using ropes and signs. No adverse impact to any identified species is anticipated since they are not present in locations expected to be impacted by decommissioning activities.

Prior to initiation of any decommissioning activities that could potentially affect endangered shoreline species, including final status surveys of beach areas, 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 Consumers Energy Co. is committed to the safe decommissioning of BRP. The Industrial Safety Program provides the basis for controlling safety during decommissioning activities. The primary objective of the Industrial 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 BRP Industrial 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. The site Health and Safety Plan, in conjunction with the BRP Accident Prevention Manual, define specific programs and requirements to ensure worker protection [References 8-3 and 8-8].

While it is recognized decommissioning activities are significantly different from the plant operational period, qualified staff, facilities, and equipment are available to perform decommissioning in a safe and effective manner. Compliance with all applicable federal Occupational Safety & Health Act (OSHA) and state (Michigan Occupational Safety & Health Act, MIOSHA) regulations and to the guidance provided through industry standards and good work practices is a top priority of all site management and employees.

Page 8-28

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/27/2005 8.5.2.9 Cost Chapter 7, Update of Site-Specific Decommissioning Costs, of this LTP provides a summary and update of decommissioning costs.

8.5.2.10 Socioeconomics Socioeconomic considerations related to decommissioning result from losses of wages and tax revenues after plant shutdown. The impact of these considerations as they apply to BRP and the surrounding communities is considered to be significant based on guidance contained in Supplement I to the GEIS. The effect on socioeconomics is considered to be large if a 5% or greater decrease in the area workforce occurs and/or a greater than 20% loss of local tax revenues occurs. Since BRP began decommissioning immediately following plant operation, the initial loss of worker wages to the local community was offset by contracted workforce brought in to conduct decommissioning activities. In order to minimize this impact, BRP management has been very proactive within the local community Gob fairs, educational assistance, etc.) to assist the workforce to find local employment if desired.

The loss of tax revenues to Charlevoix County and Hayes Township is also significant. This was recognized prior to plant shutdown, and BRP staff has worked with local government officials to minimize the effect of tax revenue loss by a phased-approach to tax payments over the decommissioning period. The effect of tax revenue loss has also been offset by healthy tourism economy and nearby land development for resort, residential and recreational use.

While BRP decommissioning socioeconomic considerations are evident, they have been minimized to the extent possible through early recognition and proactive agreements/actions with local businesses and governments.

8.5.2.11 Environmental Justice Environmental justice is characterized by high and adverse health, economic or environmental effects by local low-income and minority populations. Due to a tourism-based local economy, area demographic data indicate very low incidence of low-income or minority populations in the communities affected by BRP decommissioning. Further, local Native American populations are not considered to be significantly affected by the decommissioning of BRP. Based upon area demographics and the fact that the site will be restored to a Greenfield condition acceptable for unrestricted use, environmental justice considerations are not considered significant for BRP site restoration.

Page 8-29

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9127/2005 It should be noted environmental justice issues were also considered relative to the local community where a landfill is located (Crawford County), which will be used to dispose of building demolition debris in accordance with 10 CFR 20.2002. Health and economic effects associated with disposal of demolition waste have been determined to be negligible by BRP, MDEQ and the NRC through approval under 10 CFR 20.2002 (see Section 3.6.3). The Crawford County landfill was deemed appropriate to receive the debris by regulatory agencies for the following reasons:

• The local (Charlevoix County) landfill was closed;

• A reciprocal waste disposal agreement is in place between Crawford and Charlevoix counties;

• The Crawford County site is the closest Type II industrial landfill to the plant;

• Shipping debris to the closest appropriate landfill minimizes risk associated with transportation.

BRP personnel have presented, discussed, and addressed issues concerning the disposal plan to township, county, and state officials at more than 20 meetings.

8.5.2.12 Cultural, Historical & Archeological Resources The Michigan Historic Preservation Office has determined that several locations within the BRP site are eligible for listing on the National Register of Historic Places.

Section 8.4.6 provides a discussion regarding preservation and future management of these resources.

8.5.2.13 Aesthetic Issues Aesthetic issues apply primarily to scenic preservation of public lands. The BRP site is not public land; however, its proximity to public lands (parks and conservation areas along the Lake Michigan shoreline) warrants an assessment of aesthetics.

While decommissioning activities may have some short-term effects on Lake Michigan shoreline aesthetics, restoration of the site to a Greenfield condition will result in improved shoreline natural aesthetic views.

8.5.2.14 Noise Big Rock Point is located in an area that is surrounded on three sides by dense coniferous and deciduous forests. The nearest residence is approximately one-half mile from the property boundary and the nearest recreational area is adjacent to the property boundary. Decommissioning activities will add minimally to ambient sound levels beyond the site boundary. Activities such as the operation of construction equipment may be audible along US Route 31 and over Lake Michigan. However, the operation of construction equipment will be intermittent and temporary, occurring primarily during the daylight hours. With the exception of the onsite evacuation alarms, it is anticipated any noise beyond the site boundary will be well below 50 dBA, the level above which noise levels may initiate community complaints.

Page 8-30

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/27/2005 8.5.2.15 Irretrievable Resources Irretrievable resources refer to materials utilized to construct, operate, and decommission a commercial nuclear reactor; these include, but are not limited to, uranium for the nuclear fuel cycle, building construction materials, fuel oil, disposal site (landfill) space usage, etc. The utilization of space in radioactive and industrial landfills for system components and demolition debris is less than the space gained by unrestricted release of the site property. Therefore, decommissioning, dismantlement, and restoration of the site to a Greenfield condition are determined not to have any additional adverse effect on resources beyond the materials required to construct and operate the facility.

8.6 OVERVIEW OF REGULATIONS GOVERNING DECOMMISSIONING ACTIVITIES AND SITE RELEASE Decommissioning and restoration of BRP requires adherence to many federal, state, and local regulations. Applicable federal, state, and local requirements are identified and reviewed below. The information provided below is intended as a broad overview of applicable regulations; this discussion is not intended to be all-inclusive since specific decommissioning activities may invoke regulations not discussed within this section.

8.6.1 Federal Requirements Decommissioning activities that are subject to federal regulations, permits, licenses, notification, approvals or acknowledgments include:

• Handling and removal of asbestos,

• Handling and removal of lead paint,

• Handling, packaging, and shipment of radioactive waste,

• Hazardous waste generation/disposition,

• License termination and final site release,

• Liquid effluent releases to Lake Michigan,

• Management and closure of mixed LLW storage facility,

• Radio communications,

• Soil Erosion Sedimentation and Control Permit,

• Storage of spent fuel,

• Worker radiation protection, and

• Worker health and safety.

8.6.1.1 Nuclear Regulator Commission The majority of radiological activities fall under Title 10 of the Code of Federal Regulation (CFR) and are administered by the NRC. Applicable Title 10 regulations include:

• Part 50 - decommissioning activities,

• Part 20 - radiation protection, Page 8-31

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 912712005

• Part 51 - environmental protection,

• Part 61 - disposal of radioactive waste, and

• Part 71 - packaging and transportation of radioactive waste (regulations in 49 CFR 171 to 174 also apply).

8.6.1.2 Occupational Safety and Health Administration Worker health and safety protection during decommissioning is subject to OSHA regulations. The regulations applicable to construction are 29 CFR 1910 and 1926.

These regulations include requirements for respiratory protection (non-radiological),

hearing protection, illumination, scaffold safety, crane and rigging safety, chemical usage and release response, and cleanup operations.

8.6.1.3 Environmental Protection Agency The EPA regulations outlined in Title 40 of the Code of Federal Regulations apply as follows:

• Part 61 - Asbestos Handling and Removal,

• Parts 122 to 125 - National Pollutant Discharge Elimination System (NPDES),

• Part 141 - Safe Drinking Water Standards,

• Part 190 - Radiation Protection Standards for Nuclear Power Operations,

• Parts 260 to 272 - Resource Conservation and Recovery Act (RCRA),

• Part 280 - Underground Storage Tanks,

• Part 761 - Polychlorinated Biphenyls (PCBs), and

• Part 129-132 - Clean Water Act.

Asbestos and lead paint handling and removal is subject to OSHA regulations 29 CFR 1910 and 1926 and EPA Regulations 40 CFR 61, Subpart M. Hazardous waste generation, storage, transportation, disposal and closure of the mixed LLW waste facility are subject to the regulations outlined in 40 CFR 260 through 272 of the Resource Conservation and Recovery Act (RCRA). Handling and storage of PCB waste are subject to the requirements of 40 CFR 761 or the Toxic Substances Control Act (TSCA).

Federal Communications Commission (FCC) licenses are required for radio communication equipment used at BRP. Federal Communications Commission regulations apply to any radio communication equipment used in the reactor dismantlement and radwaste processing area.

Page 8-32

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/27/2005 8.6.2 State and Local Requirements Permits and approvals from or notifications to several state and local agencies are required for safety and environmental protection purposes. Some of these are for specific decommissioning activities and others are for existing BRP site facilities and ongoing activities that may also be required to support decommissioning. Many of the state and local requirements apply to activities that are also subject to federal regulations discussed previously. Decommissioning activities and related site operations that fall under state and local jurisdiction include:

• Abandoned wells,

• Air emissions,

• Asbestos removal and disposal,

• Building permits and codes,

• Building demolition,

• Construction and industrial stormwater management,

• Facility environmental remediation,

• Fuel oil storage,

• Hazardous waste generation,

• Lead paint removal and disposal,

• Liquid industrial waste shipment,

• Management of archeological and cultural resources,

• Plant domestic water wells,

• Radioactive waste disposal,

• Site unrestricted release,

• Solid waste shipment,

• Solid waste disposal,

• Soil erosion and sedimentation,

• Wetlands protection,

• Underground storage tanks, and

• Water use and effluent quality.

Michigan's environmental acts were consolidated into the Natural Resources and Environmental Protection Act (NREPA), 1994, PA 451 as amended [Reference 8-27]. Act 451 is organized into "Parts." The following section provides a general description of the Michigan Act 451 parts applicable to decommissioning BRP.

Air emissions and asbestos removal for the site are regulated under the Michigan Air Pollution Control Rules (Part 55) in addition to the Federal Clean Air Act.

Operating permits will be revised or terminated as necessary to accommodate decommissioning activities. Notification of asbestos removal will be prepared and submitted to MDEQ staff.

Effluent discharges from the plant to Lake Michigan are regulated by an NPDES permit delegated by the EPA to the MDEQ, Water Division for administration.

Part 31 of Act 451 provides regulations for surface water discharges that apply to onsite operations. Soil erosion and sedimentation control and wetlands protection are governed by Act 451, Parts 91 and 303, respectively.

Page 8-33

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/2712005 Michigan waste management regulations are found in Parts 111, 115, 117, and 121 of Act 451. These regulations apply to generation, disposition, and disposal of hazardous waste, solid waste management, non-hazardous liquid industrial wastes, and used oil recycling. All non-hazardous, non-radioactive wastes, including demolition debris, will be disposed of as either a Type IIor Type IlIl waste.

Additionally, lead paint handling and disposal falls under MIOSHA regulations.

Three underground storage tanks exist at the BRP site for heating fuel oil, diesel generator fuel supply, and diesel fire pump fuel supply. In addition to regulation under Part 211 of Act 451, these tanks are also regulated by the State Fire Marshall.

Drinking water supplies are regulated under the Safe Drinking Water Act (PA 399, 1976) by the Drinking Water and Radiological Protection Division of the MDEQ.

In 2003, a small area of buried legacy materials was discovered; the most probable origin of this material was plant construction waste. The location of this area is not near or associated with the Radiologically Controlled Area. A plan to perform removal of the legacy material and remediation of the area was submitted to and approved by the MDEQ. Remediation of this area was performed in early 2004; the criteria utilized for this cleanup was the residential standards of Part 201 of Act 451

[Reference 8-39]. Routine radiological monitoring conducted during the remediation did not identify any residual radioactivity of plant origin. As requested by the MDEQ, shallow groundwater monitoring wells were placed in and around this area. These wells are sampled quarterly to ensure that groundwater adjacent to this area is not impacted. It is expected that all monitoring of these wells will be completed by the 3rd quarter of 2005.

At the local level, building permits will be required for temporary field office or other facilities necessary to support decommissioning activities.

8.7

SUMMARY

AND CONCLUSIONS The assessment establishes the environmental effects for decommissioning of BRP Nuclear Plant are minimal, and there are no adverse effects outside the bounds of NUREG-0586 (GEIS) or the associated Supplement 1.

Additionally, the conclusions contained in the BRP PSDAR utilized as the original basis for the decommissioning environmental assessment of radiological and non-radiological affects of decommissioning are still valid. These conclusions are summarized as follows:

• Annual occupational radiation exposures per individual will be maintained ALARA and below historical levels for the operating phase of the plant.

• All effluents, both radiological and non-radiological, will remain within regulatory limits as specified in applicable control documents and approvals throughout the decommissioning process.

Page 8-34

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9127/2005

• Exposure to onsite workers and the offsite public as a result of waste transportation are expected to be maintained well below the levels projected by NUREG-0586 (GEIS).

• Following decommissioning, residual radioactivity will be limited to allow release of the property for unrestricted use such that an individual of a critical population group living on the site would not be expected to receive a dose greater than 25 mrem/year from all combined environmental exposure pathways.

Page 8-35

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 912712005 I

!Km LAKE MICHIGAN NOTE SHORELINE TRAVERSE S BASED ONEXISTING CONSLINIMSENGRGYMAPS LAKENIPCH)GAN GOVERNMENT LOT3 SOtTHWEST 1N OF 5101011 EAST11 o THE SOUTI1EAST hA SECTION S I SECTION 7 I i

S 2 Ii U

I i 8 IF Figure 8-1. Big Rock Point Site Map Page 8-36

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9127/2005 Big Rock Point Owner Controlled Area Figure 8-2. Aerial Photograph of Big Rock Point and Surrounding Land Areas Page 8-37

KEY

• CommerciaUlndustrial Facilities

• Public Recreation Areas

• Schools A Farms/Gardens andfor Livestock (I) Industrial Park 0 Lexalite (D Leltz Industries-- Out of Business o Hospital

> Elementay School o Middle School V)St- MaryS SSho.J o Lake Michigan Beach Depot Beach Ferry Beach G Marina Marina 3 Golf Course Golf Course X Little Traverse Conservancy Charlevoix Rod & Gun Club

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/27/2005 Figure 8-4. Topographic Map of Area Surrounding Big Rock Point Page 8-39

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/27/2005

-go. -88 -86 -84 -82 48' _iiP4 8 4B - - 46 44* - - 44*

42 - - 42'

-90* -88 -6k -84 -82

-1 -1 -33 0

.151 -71 -33 0 DEPTH (Km)

• Indicates area of seismic disturbance.

Earthquake locations are from the USGS/NEIC PDE catalog.

Figure 8-5. USGS Seismic History for Michigan (1977 -1996)

Page 8-40

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9127/2005 I SITE BOILS LEGEND Ag8- Alpena Gravelly-Sandy Loam, DeB. Detour Cobbly Loan, 0 8% Slopes EdB- Eastport Sand, 0 -8% Slopes EoF. Emnet-Onawvay Sandy Loam, 25 -60% Slope.

Hs - Hsenl Cobbfy Loam Lb - Lake Beach Rc - Recreation REFER TO SOIL SURVEY OF CHARLEVOIX COUNTY FOR DESCRIPTION OF SOILS NOT FOUND ON PLANT SITE H"AES ToPIgU O a1VOIgCOINN SOIL SURVEY (U.S.DA)

Figure 8-6. Big Rock Point Soil Types Page 8-41

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/2712005 I Figure 8-7. Big Rock Point Land Cover Types Page 8-42

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 912712005

8.8 REFERENCES

8-1 Agricultural Census for Charlevoix County, htpp://govinfo.kerr.orst.edu, 1987 and 1997 8-2 BNFL Fuel Solutions Storage System FSAR, Docket 72-1026, February 2001 8-3 Big Rock Point Accident Prevention Manual 8-4 Big Rock Point Defueled Technical Specifications 8-5 Big Rock Point Emergency Plan, Volume 9 8-6 Big Rock Point Environmental Report for Decommissioning, Revision 0, February 1995 8-7 Big Rock Point Environmental Report for Decommissioning, Volume 32 8-8 Big Rock Point Health and Safety Plan, Volume 29 8-9 Big Rock Point NPDES Permit M10001431 8-10 Big Rock Point Nuclear Power Station, Application to U.S. Atomic Energy Commission for Reactor Construction Permit and Operating License Part B, Preliminary Hazards Summary Report, January 14,1960 8-11 Big Rock Point Offsite Dose Calculation Manual, Volume 25, Section B 8-12 Big Rock Point Post Shutdown Decommissioning Activities Report (PSDAR),

Revision 0, September 1997 8-13 Big Rock Point Post Shutdown Decommissioning Analysis Report, Revision 2, March 26, 1998 8-14 Big Rock Point Process Control Program, Volume 25, Section A 8-15 Big Rock Point REMP Reports, 1997-2001 8-16 Big Rock Point RETS Reports, 1997-2001 8-17 Big Rock Point Stormwater Pollution Prevention Plan, Volume 28, Section 2 8-18 Big Rock Point Updated Final Hazards Summary Report (UFHSR), Revision 10 8-19 Coast and Geodetic Survey Publication, Serial 609, Earthquake History of the United States 8-20 Consumers Energy Environmental Procedure, LM-590, Location of Threatened and Endangered Species, August 2002 Page 8-43

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9127/2005 8-21 EPA 400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Accidents, May 1992 8-22 Letter from Consumers Energy, Big Rock Point Plant to U.S. Nuclear Regulatory Commission, Decommissioning Plan for Big Rock Point Nuclear Plant, February 27, 1995 8-23 Letter from Consumers Energy, Big Rock Point Plant to U.S. Nuclear Regulatory Commission, Decommissioning Plan for Big Rock Point Nuclear Plant, February 14, 1996 8-24 Letter from Consumers Energy, Big Rock Point Plant to U.S. Nuclear Regulatory Commission, Decommissioning Plan and Environmental Report for Big Rock Point Nuclear Plant: Final Rule, September 5, 1996 8-25 Letter from Consumers Energy, Big Rock Point Plant to U.S. Nuclear Regulatory Commission, Documents Associated with Decommissioning, September 19, 1997 8-26 Michigan Historic Preservation Office, Charlevoix County Historical sites, httP://michsite.state.mi.us 8-27 Michigan Public Act 451, Natural Resources and Environmental Protection Act, 1994 8-28 Otwell Mawby, P.C., Big Rock Point Hydrogeological Assessment Report, October 2002 8-29 Phase I Archeological Site Location Survey of the Consumers Energy Big Rock Point Property, Andrews Cultural Resources, March 2001 8-30 U.S. Army Corp of Engineers, Great Lakes Water Levels 1918-1999 http://huron.lre.usace.army.milflevels/maxmin.html 8-31 U.S. Census 2000, www.census2000.gov 8-32 U.S. Geological Survey Circular 831, OPrinciples of a Resource/Reserve Classification for Minerals," 1980 8-33 U.S. Nuclear Regulatory Commission NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities," August 1988 8-34 U.S. Nuclear Regulatory Commission NUREG-0586, uGeneric Environmental Impact Statement of Decommissioning Nuclear Facilities, Supplement 1 Regarding the Decommissioning of Nuclear Power Reactors," November 2002 8-35 U.S. Nuclear Regulatory Commission Regulatory Guide 1.109, "Calculation of Annual Doses to Man From Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50," Appendix I, Revision 1, 1977 Page 8-44

BRP LICENSE TERMINATION PLAN Revision 2 CHAPTER 8, SUPPLEMENT TO THE ENVIRONMENTAL REPORT 9/27/2005 8-36 Phase I and Phase II Archaeological Investigations, Big Rock Restoration Project, R-0457, November 2002 8-37 Traditional Cultural Properties Study of Big Rock Point 20CX177, June 15, 2003 8-38 Michigan Department of Environmental Quality, Geological and Land Management Division Permit Number 04-15-0016P, May 7, 2005; Department of the Army, Corps of Engineers - Detroit District, File No. 02-056-114-0, May 18, 2004 8-39 Big Rock Point Plant, Documentation of Interim Response Actions Along Former Transmission Line, August 17, 2004 8-40 Letter from the U.S. Nuclear Regulatory Commission to Consumers Energy, Big Rock Point Plant, dated March 24, 2005, Issuance ofAmendment 126 to Approve the License Termination Plan Page 8-45

Attachment 2 Consumers Energy BIG ROCK POINT Docket Numbers 50-155 and 72-043 Big Rock Point License Termination Plan Summary of Changes for Revision 2 September 27, 2005 2 Pages

Big Rock Point License Termination Plan Summary of Changes for Revision 2 Section I Page Revision I Reason Chapter 1 1.1 1-1 Revised second paragraph to include LTP approval date and FHSR reference.

1.3 1-2 Added ISFSI storage information.

1.4.1 1-4 Revised 10 CFR 20.2002 approval dates.

1.4.2 1-5 Revised to clarify FSS Report submittal.

1.5.3 1-7 Revised to reflect completed decommissioning tasks and summarize 1remaining activities as of June 30, 2005.

1.5.3.1 to 1-9 Revised 10 CFR 20.2002 approval dates.

1-10 Added reference for Technical Specification Amendment No. 126 for 1.5.7 to 1-11 LTP approval. Added reference for updated cost estimate (see PSDAR

_ revision 4 submittal 3/31/05).

1.6 1-12 Added specific items that require prior NRC approval for LTP revision process consistent with License Amendment No. 126.

1.7 1-13 Revised site contact information and personnel.

1.8 to 1-16 Added three new references.

Chapter 2 Added statement to clarify that this chapter summarizes operational data 2-1 and early decommissioning site characterization status as of July 2004 as approved by the NRC - no revision.

Chapter3 Revised entire chapter to reflect current site status, summarize completed All 3-1 decommissioning activities, and discuss future decommissioning projects to 3-30 and schedule as of June 30, 2005. Various sections were relocated and renumbered for clarification and editorial purposes.

Table 3-2 3-8 Deleted this table and combined it with Table 3-4, Descriptions of Table_ 3-2 _3-8 Completed Decommissioning Activities.

Table 3-3 3-11 Deleted table, Primary System Decontamination Activity Removal.

Table 34 3-8 Renumbered to Table 3-2, updated completed activities, and included Tab3-15 to 4 dates.

3.7 3-30 Added two references.

Chapter 4 4-3 Revised section to reflect site status of remediation efforts conducted as 4.2.2.1 to 4-5 of June 30, 2005, Solid Radwaste Vaults, Discharge Canal and Pipe Tunnel, as compared to original plan and volume estimates.

Page 1 of 2

Section Page Revision / Reason 4.2.2.2 4-6 Revised to reflect current status of groundwater remediation as compared to 4-7 to original plan.

4.4.4, 4-11, Removed discussion of specialized underwater sediment removal 4.5.6 4-14 systems as these techniques were not utilized for restoration of the discharge canal.

Chapter 5 Referenced new Section 5.4.2.6 that clarifies survey process and 5.1.2 5-1 nomenclature for excavated soil surfaces and subsurface sampling.

5.2.2.3 5-10 Deleted third paragraph, relocated to new Section 5.4.2.6.

5.3.6.3 5-21 Added statement to clarify area subject to EMC evaluation.

Table 5-7 5-22 Changed "Area Classification" to "Survey Unit Classification" for clarification purposes.

5.4.1.2 5-24 Deleted second paragraph, relocated to new Section 5.4.2.6.

5.4.2.4 5-25 Added phrase "survey meeting criteria of a" to clarify surveys of stored excavated soils.

5.4.2.6 5-26 Added new section entitled Excavations and Subsurface Sampling to 5..2. to 5-27 better clarify survey process for these types of areas/materials.

Tae 5-43 Revised table to reflect current schedule dates.

5-11 _ _ _ _

Chapter6 Added statement to clarify that this chapter is the technical basis for the 6-1 dose model used to develop site-specific DCGLs as approved by the NRC- no revision.

Chapter 7 71 4 l7-1 Revised chapter to reflect updated cost estimate basis (March 2004);

7 to 7-11 l revision is consistent with the PSDAR, revision 4.

Chapter 8 8-14 Revised section to include result of completed archaeological and 8.4.6 to 8-15 cultural studies and preservation requirements and review of LTP by the Michigan State Historic Preservation Office (SHPO).

8.5.2.2 8-26 Revised due to terminated NPDES Permit and associated releases.

8.5.2.3 8-27 Revised to reflect restoration of the site discharge canal.

8.5.2.12 8-30 Revised to include Michigan SHPO conclusion regarding the BRP site and associated preservation requirements.

8.6.2 8-33 Added paragraph summarizing discovery of and actions taken to to 8-34 remediate legacy waste material along former transmission line.

8.8 8-45 Added four references.

Page 2 of 2