ML063410368

Safety Evaluation Report of the Completion of Decommissioning for License No. DPR-006

ML063410368
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	01/08/2007
From:	James Shepherd, Bruce Watson NRC/FSME/DWMEP/DURLD
To:
References
Download: ML063410368 (9)

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SAFETY EVALUATION REPORT OF THE COMPLETION OF DECOMMISSIONING FOR LICENSE NO. DPR-6Consumers EnergyBig Rock PointDOCKET NO. 50-1551.INTRODUCTIONThe Big Rock Point nuclear plant (BRP or the facility) began commercial operation in 1962. In1997, after 35 years of operation, Consumers Energy (CE or the licensee) notified the U.S.

Nuclear Regulatory Commission (NRC) of its decision to permanently cease power operations.

In accordance with the requirements of Title 10, U.S. Code of Federal Regulations (10 CFR)50.82(a)(9) the licensee submitted the "Big Rock Point License Termination Plan" (LTP) for its facility. By letter dated April 1, 2003 (NRC Agencywide Documents and Management System Accession Number ML031050635), and supplemented by letter dated July 1, 2004 (ML042640320) CE submitted a request to amend Facility Operating License No. DPR-6 for BRP to incorporate its LTP. Section 1.4.2 of the LTP submittal included a request to reduce the site boundaries to those necessary to support ISFSI operations. Under the provisions of 10 CFR 50.82(a)(10), the NRC approved the LTP by license amendment 126 dated March 24, 2005. On April 3, 2006 Consumers Energy (CE) submitted written notification to the NRC(ML060960235) of Big Rock Point's intent to release a portion of the site pursuant to the approved Big Rock Point License Termination Plan (BRP LTP). On November 16, 2006, CE submitted its summary Final Status Survey Report (FSSR) and a request to release site land forunrestricted use (ML063260085). This Safety Evaluation Report (SER) documents the NRC's approval of CE's final status survey reports to demonstrate compliance with criteria for release for unrestricted use.2.BACKGROUNDThe plant was permanently shut down on August 29, 1997. CE submitted its post shutdowndecommissioning activities report (PSDAR) on September 19, 1997. The licensee constructed an on-site Independent Spent Fuel Storage Installation (ISFSI) under a general license pursuant to 10 CFR Part 72, Subpart K which allows the storage of spent fuel in an ISFSI at power reactor sites under Part 50. Transfer of the spent nuclear fuel from the spent fuel pool to the ISFSI was completed in March 2003. The portion of the site containing the ISFSI is designated as Parcel A. This area is not being released for unrestricted use at this time.

Parcel A consists of approximately 30 acres containing the ISFSI and approximately 75 acres surrounding the ISFSI, and will remain under the NRC Part 50 license. CE submitted its original LTP on April 1, 2003. Following responses to a staff request for additional information, NRC approved Revision 1 of the LTP by license amendment 126 on March 24, 2005 (ML050840453). The licensee conducted decommissioning activities in accordance with the PSDAR and theapproved LTP from September 1997 through August 2006. In accordance with the approved LTP, the licensee conducted final site surveys (FSSs) to demonstrate that the area of the site to be released meets the 25 millirem per year (mrem/yr) criteria for unrestricted release in 10 CFR 20.1402. CE submitted details of the FSS results to the U.S. Nuclear RegulatoryCommission (NRC) in several FSSRs. Additional information regarding each of these is provided in Section 3 of this SER. The legal description of the site is contained in a letter dated May 4, 2006 (ML061280381), andshown in BRP's controlled drawing 0740G20003 and Figure 2.2 of the Updated Final Hazards Summary Report (UFHSR). In accordance with Section 1.4.2 of the approved LTP, the site description for ISFSI operations is given in Attachment 2 to the April 3, 2006 letter. 3.EVALUATIONCE requested that most of the land under the jurisdiction of its Part 50 license be released forunrestricted use. Although the Part 50 license is not being terminated at this time, the staff has evaluated the FSSR and supporting FSSs against the license termination requirements of 10 CFR 50.82(a)(11) because the LTP was approved in 2005. For the reasons discussed below, the staff finds that: (i) The dismantlement has been performed in accordance with the approved LTP, and (ii) The final radiation survey and associated documentation, including an assessment of dose contributions associated with parts released for use before approval of the LTP, demonstrate that the facility and site have met the criteria for decommissioning in 10 CFR part 20, subpart E. 3.1Dismantlement Activities In accordance with the requirement of 10 CFR 50.82(a)(9)(ii)(B), Section 3 of the LTP provideda discussion of the remaining dismantlement activities as of March 2003. All of these activities were completed by August 2006. In the LTP the licensee stated it planned to remediate the site, to the criteria specified in 10CFR Part 20, for unrestricted use. Except for the sanitary drain field and the under-water portion of the former cooling water intake pipe, all structures, systems, and components except those necessary for ISFSI operations have been removed from the site. The staff has reviewed the licensee's FSSRs for BRP and determined that the licensee hasremediated the site consistent with Section 3 of the LTP. Therefore, the staff concludes that the dismantlement and decontamination activities have been completed in accordance with the approved LTP. 3.2Final Site Surveys The FSS is the radiation survey performed after an area has been fully characterized,remediation has been completed, and the licensee believes that the area is ready to be released for unrestricted use. The purpose of the FSS is to demonstrate that the area meets the radiological criteria for unrestricted use. The primary objectives of a Historical Site Assessment ( HSA) include identifying potentialsources of contamination, differentiating impacted from non-impacted areas, and providing input to scoping and characterization survey designs. Based on more than 1100measurements made during the site characterization process and from information gathered during the HSA, the licensee assigned all land areas an initial classification in preparation for the FSS. In accordance with NUREG 1575, Multi-Agency Survey and Site Investigation Manual, (MARSSIM), site areas are initially classified as impacted or non-impacted based on the results of the HSA. Areas that have no reasonable potential for residual contamination are classified as non-impacted areas. Non-impacted areas do not receive any level of survey coverage because they have no potential for containing residual radioactivity. The scope of the FSS includes all BRP impacted land areas; Table 5-2 of the LTP provides a summary of initial survey unit classifications. For operational efficiency, each of the final survey areas listed maybe subdivided Into multiple areas, as shown in Tables 3-1 through 3-5 of the November 16, 2006 submittal. FSS results were submitted to the NRC in the following separate FSSRs: TITLEDESCRIPTIONDATEADAMS #Survey of TurbineBuilding Excavation Excavation Following Removal ofFoundationsApr 3, 2006ML061030307Transmittal of ExcavatedSurface SurveysTurbine Building Excavation,Circulating Water Excavation, etc.Aug 24, 2006ML062410073Transmittal of RelocatedSoil Survey Packages Turbine Building/ContainmentDemolition, etc.

Sep 20, 2006ML062700556Transmittal of SurveyPackages Discharge Canal, Retention Pond,Screen House, Slurry Wall, etc.Oct 9, 2006ML063130292Transmittal of RelocatedSoil Survey Packages North Protected Area, etcOct 10, 2006ML062990070Transmittal of SurveyPackages South, West Protected Area, etc.Oct 13, 2006ML062960040Transmittal of SurveyPackages East Woods Area, etc.Oct 30, 2006ML063120580Transmittal of SurveyPackages Rad Waste Staging AreasOct 31, 2006ML063100390Transmittal of ErrataPages to Survey[s]North, East Protected AreasNov 2, 2006ML063120127Transmittal of SurveyPackages South Protected Area, Power LineCorridor, etc.Nov 8, 2006ML063180461Request to Release Site LandFSSR SummaryNov 16, 2006ML063260085 3.3NRC Review of FSSRsA release criterion is a regulatory limit expressed in terms of dose. For NRC licensees, therelease criterion for unrestricted use is 25 mrem/yr. A release criterion is typically based on the total effective dose equivalent and generally cannot be measured directly. Exposure pathway modeling is used to calculate a radionuclide-specific predicted concentration that could result ina dose equal to the release criterion. Such a concentration is termed the derived concentration guideline level (DCGL). The concentrations measured during the final status survey are then compared to the DCGLs to determine compliance with release limits. The NRC conducted a number of performance-based, in-process inspections of the licensee'sFSS program during the decommissioning process. The purpose of the inspections was to verify that the FSSs were being conducted in accordance with the commitments made by the licensee in the LTP, and to evaluate the quality of the FSS by reviewing the FSS procedures, methodology, equipment, surveyor training and qualifications, document quality control, and survey data supporting the FSSRs. In addition, the NRC conducted a number of independent confirmatory surveys to verify the FSS results obtained and reported by the licensee.

Confirmatory surveys consisted of surface scans for gamma radiation and collection of soil and water samples to determine residual radioactivity. 3.3.1Final Survey Reports for Class 1 Survey Units The Class 1 survey units are divided into open land areas; major building excavations fromwhich the material was subsequently removed from the site (referred to in the FSSR as Demolition); and those for residual soils that remained on site. Eighteen of the Class 1 survey units were independently surveyed by NRC or its contractor, Oak Ridge Institute for Science and Education (ORISE). Six of the Class 1 major building excavations were independently surveyed. The results are shown in the table below. CLASS 1 AREAS - FINAL STATUS SURVEY OF SURFACES SURVEY AREAU.S. NRC Review METHODIndependent SURVEY 1NRC Inspection Report 050-00155/06-001, June, 2006, HQ andORISE independent surveys. ML062720586ORISE Survey June 2006 - 20% Scan Survey: All areas < Scan MDC 2NRC Inspection Report 050-00155/06-001, June, 2006, HQ andORISE independent surveys. ML062720586ORISE Survey June 2006 - 60% Scan Survey: All areas < Scan MDC 3NRC Inspection Report 050-00155/06-001, June, 2006, HQ andORISE independent surveys. ML062720586ORISE Survey June 2006 - 60% Scan Survey: All areas < Scan MDC, 2 soil biased samples, Cs-137- 0.24 and Co 0.03 pCi/g Max 4NRC Inspection Report 050-00155/06-001, June, 2006, HQ andORISE independent surveys. ML062720586ORISE Survey June 2006 - 50% Scan Survey: All areas < Scan MDC, 2 soil biased samples, Cs-137- 0.12 and Co 0.02 pCi/g Max 5NRC Inspection Report 050-00155/06-001, June, 2006, HQ andORISE independent surveys. ML062720586ORISE Survey June 2006 - 25% Scan Survey: All areas < Scan MDC, 3 soil biased samples, Cs-137- 0.44 and Co 0.24 pCi/g Max 6NRC Inspection Report 050-00155/06-001, June, 2006, HQ andORISE independent surveys. ML062720586 ORISE Survey June 2006 - 25% Scan Survey: All areas < Scan MDC, 3 soil biased samples, Cs-137- 0.03 and Co 0.07 pCi/g Max 7NRC Inspection Report 050-00155/06-001, June, 2006, HQ andORISE independent surveys. ML062720586ORISE Survey June 2006 - 20% Scan Survey: All areas < Scan MDC, 2 soil biased samples, Cs-137- 0.09 and Co 0.07 pCi/g Max 8NRC Inspection Report 050-00155/06-001, June, 2006, HQ andORISE independent surveys. ML062720586ORISE Survey June 2006 - 20% Scan SurveyAll areas < Scan MDC, no soil samples 9NRC Inspection Report 050-00155/06-001, June, 2006, HQ andORISE independent surveys. ML062720586ORISE Survey June 2006 - 20% Scan Survey: All areas < Scan MDC, 2 soil biased samples, Cs-137- 0.01 and Co 0.01 pCi/g Max 10NRC Inspection Report 050-00155/06-001, June, 2006, HQ andORISE independent surveys. ML062720586 ORISE Survey June 2006 - 20% Scan Survey: All areas < Scan MDC, 1 soil biased sample, Cs-137- 0.05 and Co 0.01 pCi/g Max SURVEY AREAU.S. NRC Review METHODIndependent SURVEY 11NRC Inspection Report 050-00155/06-002, October, 2006, Region III independent surveys. ML063070200 NRC Region III Survey Oc tober, 2006 50 % scan survey. All areas<scan MDC, no soil samples 15NRC Inspection Report 050-00155/06-001, June, 2006, HQ andORISE independent surveys. ML062720586ORISE Survey June 2006 - 80% Scan Survey: All areas < Scan MDC, no soil samples 20NRC Inspection Report 050-00155/06-002, October, 2006, Region III independent surveys. ML063070200 NRC Region III Survey October, 2006 80 % scan survey. All areas <scan MDC, no soil samples 9NRC Inspection Report 050-00155/04-003, November, 2004 Region III Independent Surveys ML050180402 NRC Region III Survey 75% scan surveyed All areas < scan MDC, 2 biased soil samples, 0.03 pCi/g Cs-137 pCi/g Max and 0.03 pCi/g C0-60 max 10NRC Inspection Report 050-00155/03-002, April,2003 Region IIIIndependent Surveys ML031700220 NRC Region III Survey 20% scan surveyed All areas < scan MDC, 7 biased soil samples, 2.28 pCi/g Cs-137 pCi/g Max and 0.12 pCi/g C0-60 max Contain-mentNRC Inspection Report 050-00155/06-001, June, 2006, HQ andORISE independent surveys. ML062720586ORISE Survey June 2006 - 90% Scan Survey: All areas < Scan MDC, 6 soil biased samples, Cs-137- 0.03 and Co 0.06 pCi/g MaxCirculatingWater PipingNRC Inspection Report 050-00155/06-001, June, 2006, RegionIII independent surveys. ML062720586NRC Region III Survey 20% scan surveyed All areas < scan MDC, 3 biased soil samples, 0.00 pCi/g Cs-137 pCi/g Max and 0.01 pCi/g C0-60 max Turbine BuildingNRC Inspection Report 050-00155/05-004, November, 2005, Region III independent surveys. ML053260093ORISE Survey November, 2005 - 90% Scan Survey, All areas < scan MDC, 5 biased soil samples, <0.02 pCi/g Cs-137 max and 0.01 pCi/g Co-60 max Turbine BuildingNRC Inspection Report 050-00155/05-004, November, 2005, Region III independent surveys. ML053260093ORISE Survey November 17, 2005 - 90% Scan Survey, All areas < scan MDC, 5 biased soil samples, <0.02 pCi/g Cs-137 max and 0.01 pCi/g Co-60 max 3.3.2Final Survey Reports for Class 2 Survey UnitsFor the Class 2 survey units, six were independently surveyed. The average soil surfaceresults were about 2% of the DCGLs. The results are shown in the table below. 3.3.3Final Survey Reports for Class 3 Areas Two of the Class 3 survey units were independently surveyed. The average soil surface resultswere about 2% of the DCGLs. The results are shown in the table below. 3.3.4Summary of Results The calculated dose rate from all residual radioactivity is less than 1 mrem/y. Tritium in soilremains <1% of the limit. This calculated dose rate is far below the limit in 10 CFR 20 Subpart E of 25 mrem/y. The residual radioactivity in soil is less than 10% of the values in Table 1 of the NRC- EPA MOU dated October 9, 2002. Therefore, no consultation with the EPA is required. 4.STATE CONSULTATIONDuring the FSS process, NRC staff and the State of Michigan communicated regularly ontechnical issues associated with radiological measurements and results.

CLASS 2 AREAS - FINAL STATUS SURVEY OF SURFACE SURVEY AREAU.S. NRC Review METHODIndependent SURVEY12NRC Inspection Report 050-00155/06-001, June, 2006, HQ andORISE independent surveys. ML062720586ORISE Survey June, 2006 - 20% scan survey, All areas< scan MDC , 5 biased soil samples, 0.44 Cs-137 max and 0.35 Co-60 max 15NRC Inspection Report 050-00155/06-001, June, 2006, HQ andORISE independent surveys. ML062720586ORISE Survey June, 2006 - 20% scan survey, all areas < scan MDC, 5 biased soil samples 0.44 Cs-137 max and 0.35 pCi/g Co-60 max 16NRC Inspection Report 050-00155/06-001, June, 2006, HQ andORISE independent surveys. ML062720586 ORISE Survey June, 2006 - 20% scan survey, All areas <scan, MDC2 biased soil samples 0.09 Cs-137 max and 0.68 pCi/g Co-60 max 19NRC Inspection Report 050-00155/06-002, October, 2006, Region III independent surveys. ML063070200NRC Region III Survey October, 2006 30 % scan survey. All areas <scan MDC, no soilsamples 21NRC Inspection Report 050-00155/06-002, October, 2006, Region III independent surveys. ML063070200NRC Region III Survey October 8, 2006 50 % scan survey. all areas < scan MDC, no soilsamples 22NRC Inspection Report 050-00155/06-002, October, 2006, Region III independent surveys. ML062720586 andML063070200 ORISE Survey June, 2006 - 5% scan survey, All areas < scan MDC, 5 biased soil samples,0.50 Cs-137 max and 0.05 pCi/g Co-60 max .CLASS 3 AREAS - Final Status Surveys of Surfaces SURVEY AREAU.S. NRC Review METHODIndependent SURVEY 14NRC Inspection Report 050-00155/06-001, June, 2006, HQ andORISE independent surveys. ML062720586ORISE Survey June, 2006 - 20% scan survey, All areas < scan MDC, 2 biased soil samples, 0.21 Cs-137 max and 0.02 pCi/g Co-60 max 18NRC Inspection Report 050-00155/06-002, October, 2006, Region III independent surveys. ML063070200NRC Region III Survey October, 2006 50 % scan surveyof 50 m2 area of NE corner. All areas < scan MDC, no soil samples 5.ENVIRONMENTAL CONSIDERATIONSOn February 12, 2003, pursuant to 10 CFR 51.21, 51.32, and 51.35, NRC published in theFederal Register (70 FR 3072) the Environmental Assessment (EA) and finding of no significantimpact (FONSI) for approval of the BRP LTP (ML043370159). This EA evaluated the environmental effects from LTP approval and subsequent release of the site for unrestricted use. Included in the evaluation was a determination of the adequacy of the radiation release criteria and the adequacy of the FSS as presented in the LTP.CE has completed remediation in accordance with the approved LTP. Because theenvironmental effects of remediation were previously evaluated, no EA is required for this action. 6.CONCLUSIONThe NRC staff concludes, based on the considerations discussed above, that decommissioningactivities have been performed in accordance with the approved LTP. More specifically, in accordance with 10 CFR 50.82(a)(11), the staff finds that: (i) The dismantlement has been performed in accordance with the approved LTP; and (ii) The final radiation survey and associated documentation, including an assessment of dose contributions associated with parts released for use before approval LTP, demonstrate that the facility and site, except for Parcel A, meet the radiological criteria for unrestricted use in 10 CFR Part 20, subpart E. Principal Contributors: J. Shepherd, FSME/DWMEP/DURLD B. Watson, FSME/DWMEP/DURLDDate:January 5, 2007