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)

Text

SAFETY EVALUATION REPORT OF THE COMPLETION OF DECOMMISSIONING FOR LICENSE NO. DPR-6 Consumers Energy Big Rock Point DOCKET NO. 50-155

1. INTRODUCTION The Big Rock Point nuclear plant (BRP or the facility) began commercial operation in 1962. In 1997, 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 for unrestricted use (ML063260085). This Safety Evaluation Report (SER) documents the NRCs approval of CEs final status survey reports to demonstrate compliance with criteria for release for unrestricted use.

2. BACKGROUND The plant was permanently shut down on August 29, 1997. CE submitted its post shutdown decommissioning 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 the approved 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 Regulatory Commission (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), and shown 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. EVALUATION CE requested that most of the land under the jurisdiction of its Part 50 license be released for unrestricted 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.

3.1 Dismantlement Activities In accordance with the requirement of 10 CFR 50.82(a)(9)(ii)(B), Section 3 of the LTP provided a 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 10 CFR 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 licensees FSSRs for BRP and determined that the licensee has remediated 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.

3.2 Final 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 potential sources of contamination, differentiating impacted from non-impacted areas, and providing

input to scoping and characterization survey designs. Based on more than 1100 measurements 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 may be 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:

TITLE DESCRIPTION DATE ADAMS #

Survey of Turbine Excavation Following Removal of Apr 3, ML061030307 Building Excavation Foundations 2006 Transmittal of Excavated Turbine Building Excavation, Aug 24, ML062410073 Surface Surveys Circulating Water Excavation, etc. 2006 Transmittal of Relocated Turbine Building/Containment Sep 20, ML062700556 Soil Survey Packages Demolition, etc. 2006 Transmittal of Survey Discharge Canal, Retention Pond, Oct 9, ML063130292 Packages Screen House, Slurry Wall, etc. 2006 Transmittal of Relocated North Protected Area, etc Oct 10, ML062990070 Soil Survey Packages 2006 Transmittal of Survey South, West Protected Area, etc. Oct 13, ML062960040 Packages 2006 Transmittal of Survey East Woods Area, etc. Oct 30, ML063120580 Packages 2006 Transmittal of Survey Rad Waste Staging Areas Oct 31, ML063100390 Packages 2006 Transmittal of Errata North, East Protected Areas Nov 2, ML063120127 Pages to Survey[s] 2006 Transmittal of Survey South Protected Area, Power Line Nov 8, ML063180461 Packages Corridor, etc. 2006 Request to Release Site FSSR Summary Nov 16, ML063260085 Land 2006

3.3 NRC Review of FSSRs A release criterion is a regulatory limit expressed in terms of dose. For NRC licensees, the release 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 in a 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 licensees FSS 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.

3.3.1 Final Survey Reports for Class 1 Survey Units The Class 1 survey units are divided into open land areas; major building excavations from which 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 U.S. NRC Review METHOD Independent SURVEY AREA 1 NRC Inspection Report 050-00155/06-001, June, 2006, HQ and ORISE Survey June 2006 - 20% Scan Survey:

ORISE independent surveys. ML062720586 All areas < Scan MDC 2 NRC Inspection Report 050-00155/06-001, June, 2006, HQ and ORISE Survey June 2006 - 60% Scan Survey:

ORISE independent surveys. ML062720586 All areas < Scan MDC 3 NRC Inspection Report 050-00155/06-001, June, 2006, HQ and ORISE Survey June 2006 - 60% Scan Survey:

ORISE independent surveys. ML062720586 All areas < Scan MDC, 2 soil biased samples, Cs-137- 0.24 and Co 0.03 pCi/g Max 4 NRC Inspection Report 050-00155/06-001, June, 2006, HQ and ORISE Survey June 2006 - 50% Scan Survey:

ORISE independent surveys. ML062720586 All areas < Scan MDC, 2 soil biased samples, Cs-137- 0.12 and Co 0.02 pCi/g Max 5 NRC Inspection Report 050-00155/06-001, June, 2006, HQ and ORISE Survey June 2006 - 25% Scan Survey:

ORISE independent surveys. ML062720586 All areas < Scan MDC, 3 soil biased samples, Cs-137- 0.44 and Co 0.24 pCi/g Max 6 NRC Inspection Report 050-00155/06-001, June, 2006, HQ and ORISE Survey June 2006 - 25% Scan Survey:

ORISE independent surveys. ML062720586 All areas < Scan MDC, 3 soil biased samples, Cs-137- 0.03 and Co 0.07 pCi/g Max 7 NRC Inspection Report 050-00155/06-001, June, 2006, HQ and ORISE Survey June 2006 - 20% Scan Survey:

ORISE independent surveys. ML062720586 All areas < Scan MDC, 2 soil biased samples, Cs-137- 0.09 and Co 0.07 pCi/g Max 8 NRC Inspection Report 050-00155/06-001, June, 2006, HQ and ORISE Survey June 2006 - 20% Scan Survey ORISE independent surveys. ML062720586 All areas < Scan MDC, no soil samples 9 NRC Inspection Report 050-00155/06-001, June, 2006, HQ and ORISE Survey June 2006 - 20% Scan Survey:

ORISE independent surveys. ML062720586 All areas < Scan MDC, 2 soil biased samples, Cs-137- 0.01 and Co 0.01 pCi/g Max 10 NRC Inspection Report 050-00155/06-001, June, 2006, HQ and ORISE Survey June 2006 - 20% Scan Survey:

ORISE independent surveys. ML062720586 All areas < Scan MDC, 1 soil biased sample, Cs-137- 0.05 and Co 0.01 pCi/g Max

SURVEY U.S. NRC Review METHOD Independent SURVEY AREA 11 NRC Inspection Report 050-00155/06-002, October, 2006, NRC Region III Survey October, 2006 Region III independent surveys. ML063070200 50 % scan survey. All areas

<scan MDC, no soil samples 15 NRC Inspection Report 050-00155/06-001, June, 2006, HQ and ORISE Survey June 2006 - 80% Scan Survey:

ORISE independent surveys. ML062720586 All areas < Scan MDC, no soil samples 20 NRC Inspection Report 050-00155/06-002, October, 2006, NRC Region III Survey October, 2006 Region III independent surveys. ML063070200 80 % scan survey. All areas <scan MDC, no soil samples 9 NRC Inspection Report 050-00155/04-003, November, 2004 NRC Region III Survey 75% scan surveyed Region III Independent Surveys ML050180402 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 10 NRC Inspection Report 050-00155/03-002, April,2003 Region III NRC Region III Survey 20% scan surveyed Independent Surveys ML031700220 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- NRC Inspection Report 050-00155/06-001, June, 2006, HQ and ORISE Survey June 2006 - 90% Scan Survey:

ment ORISE independent surveys. ML062720586 All areas < Scan MDC, 6 soil biased samples, Cs-137- 0.03 and Co 0.06 pCi/g Max Circulating NRC Inspection Report 050-00155/06-001, June, 2006, Region NRC Region III Survey 20% scan surveyed Water III independent surveys. ML062720586 All areas < scan MDC, 3 biased soil samples, Piping 0.00 pCi/g Cs-137 pCi/g Max and 0.01 pCi/g C0-60 max Turbine NRC Inspection Report 050-00155/05-004, November, 2005, ORISE Survey November, 2005 - 90% Scan Survey, Building Region III independent surveys. ML053260093 All areas < scan MDC, 5 biased soil samples,

<0.02 pCi/g Cs-137 max and 0.01 pCi/g Co-60 max Turbine NRC Inspection Report 050-00155/05-004, November, 2005, ORISE Survey November 17, 2005 - 90% Scan Survey, Building Region III independent surveys. ML053260093 All areas < scan MDC, 5 biased soil samples,

<0.02 pCi/g Cs-137 max and 0.01 pCi/g Co-60 max

3.3.2 Final Survey Reports for Class 2 Survey Units For the Class 2 survey units, six were independently surveyed. The average soil surface results were about 2% of the DCGLs. The results are shown in the table below.

3.3.3 Final Survey Reports for Class 3 Areas Two of the Class 3 survey units were independently surveyed. The average soil surface results were about 2% of the DCGLs. The results are shown in the table below.

3.3.4 Summary of Results The calculated dose rate from all residual radioactivity is less than 1 mrem/y. Tritium in soil remains <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 CONSULTATION During the FSS process, NRC staff and the State of Michigan communicated regularly on technical issues associated with radiological measurements and results.

CLASS 2 AREAS - FINAL STATUS SURVEY OF SURFACE SURVEY U.S. NRC Review METHOD Independent SURVEY AREA 12 NRC Inspection Report 050-00155/06-001, June, 2006, HQ and ORISE Survey June, 2006 - 20% scan survey, ORISE independent surveys. ML062720586 All areas< scan MDC , 5 biased soil samples, 0.44 Cs-137 max and 0.35 Co-60 max 15 NRC Inspection Report 050-00155/06-001, June, 2006, HQ and ORISE Survey June, 2006 - 20% scan survey, ORISE independent surveys. ML062720586 all areas < scan MDC, 5 biased soil samples 0.44 Cs-137 max and 0.35 pCi/g Co-60 max 16 NRC Inspection Report 050-00155/06-001, June, 2006, HQ and ORISE Survey June, 2006 - 20% scan survey, ORISE independent surveys. ML062720586 All areas <scan, MDC2 biased soil samples 0.09 Cs-137 max and 0.68 pCi/g Co-60 max 19 NRC Inspection Report 050-00155/06-002, October, 2006, NRC Region III Survey October, 2006 Region III independent surveys. ML063070200 30 % scan survey. All areas <scan MDC, no soil samples 21 NRC Inspection Report 050-00155/06-002, October, 2006, NRC Region III Survey October 8, 2006 Region III independent surveys. ML063070200 50 % scan survey. all areas < scan MDC, no soil samples 22 NRC Inspection Report 050-00155/06-002, October, 2006, ORISE Survey June, 2006 - 5% scan survey, Region III independent surveys. ML062720586 and All areas < scan MDC, 5 biased soil samples, ML063070200 0.50 Cs-137 max and 0.05 pCi/g Co-60 max .

CLASS 3 AREAS - Final Status Surveys of Surfaces SURVEY U.S. NRC Review METHOD Independent SURVEY AREA 14 NRC Inspection Report 050-00155/06-001, June, 2006, HQ and ORISE Survey June, 2006 - 20% scan survey, ORISE independent surveys. ML062720586 All areas < scan MDC, 2 biased soil samples, 0.21 Cs-137 max and 0.02 pCi/g Co-60 max 18 NRC Inspection Report 050-00155/06-002, October, 2006, NRC Region III Survey October, 2006 Region III independent surveys. ML063070200 50 % scan surveyof 50 m2 area of NE corner.

All areas < scan MDC, no soil samples

5. ENVIRONMENTAL CONSIDERATIONS On February 12, 2003, pursuant to 10 CFR 51.21, 51.32, and 51.35, NRC published in the Federal Register (70 FR 3072) the Environmental Assessment (EA) and finding of no significant impact (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 the environmental effects of remediation were previously evaluated, no EA is required for this action.

6. CONCLUSION The NRC staff concludes, based on the considerations discussed above, that decommissioning activities 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/DURLD Date: January 5, 2007