attachment i consumers energy company ...pursuant to 10 cfr 50.59(d)(3), attached to this letter is...

Consmeise

A CMS Energy Company Big Rock Point Nuclear Plant Kuar A. Haas10269 US-31 North General ManagerCharlevoix, AMl 49720

April 13, 2005 10 CFR 50.59(d)(3)10 CFR 50.7110 CFR 50.4

U.S. Nuclear Regulatory CommissionDocument Control DeskWashington, DC 20555-0001

DOCKETS 50-155 AND 72-043 - LICENSE DPR-6 - BIG ROCK POINT PLANT -10 CFR 50.59 REPORT OF CHANGES, TESTS AND EXPERIMENTS

Pursuant to 10 CFR 50.59(d)(3), attached to this letter is Consumers Energy Company'sreport of completed changes, tests, and experiments for the Big Rock Point RestorationProject as described in the Updated Final Hazards Summary Report (UFHSR).

In addition, during the period, the Quality Program for Big Rock Point (Volume 34A,CPC-2A, Quality Program Description for Nuclear power Plants, Part 1, Big Rock PointPlant) was reviewed and accepted by the U.S. NRC in their Safety Evaluation Reportdated October 28, 2003. No revisions have been made to this document since itsacceptance.

Attachment I describes the modifications performed to support decommissioning and siterestoration. This report provides a summary of changes to the facility performed fromJuly 16, 2002 through March 31, 2005. The report includes a brief description of eachchange and a summary of the 10 CFR 50.59 evaluations.

Attachment II provides changes to procedures, programs, and Defueled TechnicalSpecifications, where appropriate. This report provides a summary of changes to theprocedures, programs, and Defueled Technical Specifications from September 1, 2003through March 31, 2005. The report includes a brief description of each change and asummary of the 10 CFR 50.59 evaluations.

-3Weg>SSt

Attachment III is a complete, replacement copy of the Updated Final Hazards SummaryReport (UFHSR). Revision 12 to the UFHSR (safety analysis report) replaced UFHSR,revision 1 1, in its entirety. Re-write of the UFHSR was required due to:

1. Modifications to the facility, and2. Revisions of procedures, programs, and Defueled Technical Specifications.

These activities were performed for dismantlement and decommissioning and removal offuel from the spent fuel pool to the Independent Spent Fuel Storage Installation (ISFSI).The required evaluations concluded that these changes did not require NRC approvalpursuant to 10 CFR 50.59.

In addition, Chapter 11 of the UFHSR comprises revision 13. This revision incorporatedthe January 19, 2005 U.S. Nuclear Regulatory Agency Safety Evaluation Report for theApproval of revised demolition debris disposal procedures in accordance with 10 CFR20.2002.

Kurt M. HaasSite General Manager

cc: Administrator, Region III, USNRCNRC Decommissioning Inspector - Big Rock PointNRC NMSS Project Manager - James C. Shepherd

Attachments

ATTACHMENT I

CONSUMERS ENERGY COMPANYBIG ROCK POINT PLANT

DOCKET 50-155 AND 72-043 - LICENSE DPR-6

REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS

April 13, 2005

Modifications

4 pages

Big Rock Point PlantBiennial Report of Facility Changes, Tests, and Experiments

Attachment I - Modifications

NOTE: The temporary modification listed below is for historical reference only. TheCondensate Storage Tank was made available for decommissioning. Revisionto the UFHSR consisted of addition of reference to use of temporary receivertanks for short-term storage of liquid radwaste.

JLB-03-0004Radwaste Sump Pump Temporary Discharge to the Condensate Storage Tank (CST)

Radwaste Sump pump was modified. A temporary line was installed to allow collected waterto be pumped to the Condensate Storage Tank for disposal.

Safety Evaluation Summary

The installation of the temporary liquid radwaste discharge line is consistent with theUFHSR, Chapter 11.2.

The process for Liquid Radwaste (LRW) handling meets Offsite Dose Calculation Manual(ODCM) and State discharge permit requirements.

Use of the CST rather than another receiver tank is equivalent to the current method. Anytank is a passive, equivalent component.

Temporary equipment is used in accordance with the ODCM for periodic sampling ofeffluents.

Since a JLB and other minor alterations are in accordance with approved ODCMmethodology, no departure from the design basis results.

QRF Log # 689-03Cartridge/Frame 4874/1310

Page 1 of 4



MA-02-0026ISFSI Security and Office Building

This minor alteration installed a two-story building south of the ISFSI pad to house sitesecurity and ISFSI administrative personnel.


The UFHSR was updated to include a revised Site Plan, showing the location of the ISFSIfacility, the ISFSI Administrative Building, and the ISFSI access road (former railroadaccess.) This revision is considered administrative.

QRF Log # 32-03 and 34-04Cartridge/Frame 4789/1051 and 4877/1520

Page 2 of 4


Attachment I -Modifications

NOTE: The Modification listed below is for historical reference only. The plant septicwas made available for decommissioning. Revision to the UFHSR consistedof deletion of references to the former sewage and chlorination system.

MA-02-0029Modification of the Existing Septic System Outside of the Protected Area

This minor alteration diverted the existing septic system in anticipation of demolitionactivities within the former Plant protected area. The waste is collected in a temporarystorage tank and transported offsite for processing.

Safety Evaluation Summary.

The change was superceded by the overall review of the UFHSR (deletion of references tothe Sewage and Chlorination System) and is being submitted as another completed revision(revision 12).


Page 3 of 4



NOTE: The Modification listed below is for historical reference only. The Wastereceiver tanks were made available for decommissioning. Revision to theUFHSR consisted of addition of reference to use of temporary receiver tanksfor short-term storage of liquid radwaste.

MA-03-0009Isolate the Clean and Dirty Waste Receiver Tanks to enable them to be removed fromservice.EDC-MA-03-0009-001Isolate the Dirty Waste Receiver Tank

To continue with decommissioning and demolition of selective portions of the radioactivewaste system, the dirty waste receiver tank #2 was isolated from the radwaste system. Dirtywaste receiver tank #1, pump P-16A, and other radioactive waste system components willremain in service.


One dirty waste receiver tank has sufficient volume to accept all anticipated flow from theradioactive waste sump, the reactor clean and dirty sumps, and the turbine room sumps.

The proposed change due to this modification was superceded by complete revision ofUFHSR Chapter 11 and submitted to the US NRC as revision 12.

This minor alteration/ Engineering Design Change did not involve a change in the DefueledTechnical Specifications incorporated in the license nor did it require prior NRC approvalpursuant to 10 CFR 50.59.

QRF Log # 518-03 and 617-03Cartridge/Frame 4913/0889 and 4855/0958

Page 4 of 4

ATTACHMENT II

CONSUMERS ENERGY COMPANYBIG ROCK POINT PLANT

DOCKET 50-155 AND 72-043 - LICENSE DPR-6

REPORT OF FACILITY CHANGES, TESTS, AND EXPERIMENTS

April 13, 2005

Procedures and Programs

16 pages


Attachment II- Procedures and Programs

ALP 1.21, ALP1.22Deletion of Volume 3 - Alarm Operating Procedures

Deletion of monitoring station alarms and associated procedure is due to changing conditionsof decommissioning.


The occurrence of accidents does not increase, as no alarms remain in the former plantindustrial area. All source term is located on the Independent Spent Fuel Storage Installation(ISFSI). With removal of the screen house and availability of the Fire Protection System (FPS)for decommissioning, no SSCs important to safety remain in the former industrial area.


Page I of 16



Administrative Procedures - Procedure Re-Write and Creation of Volume 34AProcedures and Deletion of Volume 1 Procedures

The cancellation of several Administrative (Volume 1) procedures satisfied development ofrevised Administrative procedures to match the quality program (Volume 34) and simplifyadministrative processes associated with greatly decreased Quality-related SSCs and theprograms to which they apply.

Procedure 34A - 01: Site Organization Responsibilities and TrainingReplaced Administrative ProceduresDL.0 Plant Decommissioning Organization and ResponsibilitiesD2.1 Operations Department Organization and ResponsibilitiesD2.1.1 Shift OperationsD2.1.2 Operations Documents

Procedure 34A - 02: Site Document Review, Approval, and ControlReplaced Administrative ProceduresD1.1 Procedures ProgramDI.I.l Procedure Writer's Requirements and GuidelinesDl .2 Plant DocumentsD3.1.4 Preparation and Control of Electrical, Civil, Mech. Specs.D3.1.8 Revisions to Plant DrawingsD4.1.7 Issuance & Control of Procedures, Drawings/Specs & Vendor Equip Info

Procedure 34A - 03: Records ManagementReplaced Administrative ProcedureD4.1.1 Plant Records Management

Procedure 34A - 04: Corrective ActionReplaced Administrative ProcedureDl.3 Corrective Action

Procedure 34A - 05: Safety Review and Independent Safety Review Committee ReviewReplaced Administrative ProceduresDl.4 Safety Review CommitteeDl.8 Restoration Safety Review CommitteeD1.1 I 10 CFR 50.59 and 10 CFR 50.82 EvaluationsD1.12 10 CFR 72.48 EvaluationsD1.21 Preparation and Control of 10 CFR 72.212 and CoC ReportD3.2 UFHSR ManagementD3.5 Reporting RequirementsD3.6 PSDAR ManagementD4.3 Commitment TrackingD4.5 Format, Composition, & Distribution of Licensing Correspondence

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Procedure 34A - 06: ISFSI Work ProcessReplaced Administrative ProceduresD1.17 VT-2 ExaminationsD1.18 Control of Work InstructionsD2.1.4 Plant Status and Equipment ControlD3.1 Decommissioning Work PackagesD3.1.1 Plant ModificationsD3.1.1.1 Facility ChangesD3.1.1.3 Set Point ChangesD3.1.1.7 Engineering Work PackageD3.1.1.8 Minor AlterationsD3.1.2 Engineering Analysis and SketchesD3.1.3 Milestone Work PackagesD3.1.7 External Transmittal of Engineering InformationD3.1.9 Equipment DatabaseD3.2.9 Control of Special Processes

Procedure 34A - 07: Surveillance, Testing, and Work SchedulesReplaced Administrative ProceduresDl.9 Surveillance, Testing, and Inspection ProgramsD1.15 Conduct of Infrequently Performed Tests of EvolutionsD2. 1.4.1 Personnel Protective Tagging ConventionsD2.2.2 Control of Measuring & Test Equipment & Plant Installed EquipD2.2.3 Decommissioning Periodic and Predetermined Activity Control

Procedure 34A - 08: Material ControlReplaced Administrative ProceduresD4.2.1 Material ControlD4.2.1.1 Receipt InspectionD4.2. 1.2 Control of Weld Filler MaterialD4.2.1.3 Control of Nonconforming Materials/ItemsD4.2.1.4 Qualification/Certification of Receipt InspectorsD4.2.4 Procurement - General RequirementsD4.2.4.1 Procurement of SR Items from SuppliersD4.2.4.2 Procurement of Commercial Grade Items SR (CQ)D4.2.4.3 Procurement of NSR ItemsD4.2.4.6 QA Review of Procurement DocumentsD4.2.4.7 Source VerificationD4.2.4.8 Qualification/Certification of QA ReviewersD4.2.7 Contracted ServicesD4.2.7.1 Project Manager/Service Coordinator

Safety Evaluation Summart

The revision to the UFHSR was editorial as a result of this procedure re-write project. TheChapter on Conduct of Operations included the title of a specific work process,

Page 3 of 16


Attachment II -Procedures and Programs

"Decommissioning Work Packaged (DWPs)," which was eliminated and combined with theoverall work process.

The editorial change was due to a revision of work process and enabled the deletion ofredundant procedures. The revised work process continues to satisfy the requirements of theQuality Program.

QRF Log #106-04, 107-04, 38-05, 39-05, and 52-05 (New Procedure 34A-01)96-04, 98-04, 99-04, 100-04, 102-04, 103-04, and 105-04 (New Procedure 34A-02)93-04 and 94-04 (New Procedure 34A-03)61-04 and 62-04 (New Procedure 34A-04)119-04, 121-04, 123-04, 124-04, 127-04, 128-04, 130-04, 132-04, 136-04, 05-04through 09-04, 101-04, 104-04, 219-04, 220-04, and 262-04 (New Procedure 34A-05)702-03, 138-04, 140-04, 142-04, 143-04, 145-04, and 147-04 (New Procedure 34A-06)108-04 through 112-04, an d 179-04 (New Procedure 34A-07)76-04, 78-04, 80-04 through 92-04 (New Procedure 34A-08)

Cartridge/Frame Numbers upon request

Page 4 of 16


Attachment II - Procedures and Programs

Procedure O-RBR-01Retention Basin Release System Operation

A new procedure was written for operation of the Retention Basis Release System. This systemwas installed to provide a means to monitor, store, and release as effluent, the groundwaterpumped from excavations in the former plant industrial area.


The process for liquid radwaste (LRW) handling is an activity that is quality related. Sincewater pumped from excavations has the potential to be slightly contaminated, it is monitoredand processed to meet the Offsite Dose Calculation Manual (ODCM) and State dischargepermit requirements. The retention basin provides a temporary means to meet ODCM andState requirements.

The temporary monitoring equipment enables effluent monitoring according to ODCMrequirements and is equivalent to previously installed discharge canal monitors. Periodicsampling of effluent and criteria to trigger that sampling continues to meet the requirements ofthe 10 CFR Part 20 program, regardless of the equipment used. Equipment is calibrated underthe Quality Program requirements. The approved ODCM methodology ensures compliancewith regulations. No departure from design basis results since monitoring continues to be inaccordance with ODCM requirements.


Page 5 of 16



Volume 2Defueled Technical Specifications - Amendment 125 - Spent Fuel from Wet Storage toDry Storage on an Independent Spent Fuel Storage Installation (ISFSI)

License Amendment 125: Revision to the Defueled Technical Specifications (DTS) followingthe removal of all Spent Fuel from wet storage in the fuel pool, originally submitted onNovember 02, 2002 and supplemented on August 6, 2003 and November 25, 2003.

The Updated Final Hazards Summary Report (UFHSR) paragraph that discusses Managementand Technical Support Organization was revised to indicate that the delegation of authority isin affect whether the Site General Manager is on-site or absent. In addition, the Site GeneralManager, or his designate, shall verify that required security and Emergency Plan staffing hasbeen met.

The U.S. NRC issued DTS amendment 125 on March 19, 2004.


The Amendment was an administrative change to the DTS to reflect permanent removal ofspent fuel from wet storage in the spent fuel pool. All spent nuclear fuel (SNF), greater-thanclass C (GTCC) waste, and special nuclear material (SNM) are stored on an Independent SpentFuel Storage Installation (ISFSI). This configuration presents significantly reduced risk topublic health and safety. The revision did not affect any accidents described and evaluated inthe UFHSR, except for elimination of those scenarios that are no longer credible (spent fuelpool accidents).

Big Rock Point (BRP) structures, systems, and components (SSCs) that were formerly requiredfor reactor and wet storage of spent fuel were made obsolete by the ISFSI operation for SNF,GTCC, and SNM storage. The amendment made obsolete former accident analyses; includingtheir occurrence, consequences, and malfunction.

Different "type" accidents, their methods of evaluation, and affect on fission product barrier(now the dry fuel storage casks) are evaluated in the vendor Safety Analysis Report approvedby issuance of a general license under 10 CFR Part 72 and Certificate of Compliance (CoC)Number Docket 72-1026.

This amendment resulted in a major re-write of the UFHSR. A complete revision (revision 11)was submitted to the U.S. NRC on April 20, 2004 and has been revised again to reflect furtherdismantlement of the former Plant area in Revision 12 (see Attachment III to this letter.)

On November 25, 2003, in reply to questions on the proposed August 6, 2003 DefueledTechnical Specification Change request, a commitment was made to incorporate staffingrequirements into the UFHSR. With all spent nuclear fuel stored on the ISFSI, staffingrequirements are no longer driven by "Operating Mode". Staffing is now dependent on therequirements in the Security and Emergency Plans.

Page 6 of 16



The removal of staffing requirements from the DTS of "obsolete" reactor modes left no directguidance on staffing of the ISFSI. Although Security and Emergency Plans have staffingrequirements, the responsibility for ensuring that they are met is not evident. This changeadministratively assigns responsibility for staffing to the Site General Manager. There is noaffect on any accident or radiological analyses in the UFHSR as a result of this revision.

This change satisfies a commitment made on November 25, 2003. Although the Security andEmergency Plans have staffing requirements, the responsibility for ensuring they were met wasnot evident. Assignment of responsibility has no direct affect on any accidents. UFHSRChapter 15 accident analyses are not affected by this Amendment.

QRF Log # 156-03, 695-03 and 152-04Cartridge/Frame 4865/0004, 4874/1373, and 4889/1484

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Attachment II - Procedures and Programs

Volume 2Defueled Technical Specification Amendment 126 - License Termination Plan

On March 24,2005, the U.S. NRC issued Amendment 126 to the Big Rock Point FacilityOperating License. This amendment incorporated licensing conditions for the approval of theBig Rock Point License Termination Plan.


The License Termination Plan (LTP) was incorporated by reference in to the Updated FinalHazards Summary Report.

LTP activities shall be performed in accordance with approved plant procedures, as outlined inthe LTP. CPC-2A, and the radiological control program apply to LTP decommissioningactivities. The Final Status Survey Quality Assurance Project Plan (Chapter 5 of the LTP)conforms to guidance found in NUREG-1 575 (MARSSIM). The Environmental Report forDecommissioning (Volume 32) was reviewed in Chapter 8 of the LTP. The performance ofthese activities has no affect on accident analyses in Chapter 15 of the UFHSR. However,Chapter 15 Section 15.10.4, Non-Fuel Related Decommissioning Accidents, was revised toensure future changes to methods or evaluations outlined in the LTP are examined to ensurethey are bounded by NUREG-0586, Generic Environmental Impact Statement onDecommissioning Nuclear Facilities (GEIS).

The addition of the License Termination Plan (LTP) by reference to the UFHSR outlinesprocesses used to enable eventual termination of the 1OCFR Part 50 license. The ultimate goalof this activity is to ensure the termination of the license is not inimical to the common defenseand security or to the health and safety of the public. In addition, the LTP outlines methods toachieve license termination that result in no significant effect on the quality of theenvironment. Title 10 of the CFR, Section 20.1402 has two criteria for evaluating siteconditions for unrestricted use, namely 25 mrem/yr TEDE and ALARA.

LTP activities are not an adverse change to Structures, Systems, or Components (SSCs) sincethe activities will not be performed until SSCs are declared available for decommissioning.LTP activities are done to ensure 10CFR Part 20 requirements are met. As such, no SSC designfunctions are affected. However, the activities in the LTP have the potential to affectprocedures and methods of evaluation, not currently described in the UFHSR, which may haveindirect adverse affects on the environment.

License Termination Plan activities *vere approved by the NRC on March 24,2005 andbecome a supplement to the UFHSR. Activities described in the LTP may be considered as atest. The proposed License Conditions outline activities that are considered as tests orevaluations. For example, NRC prior approval will be required if changes in the statistical testused for survey unit data evaluations (e.g., the "Sign Test") are made.

QRF Log # 69-03 and 91-05Cartridge/Frame 4791/1255 and upon request

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Volume 9Emergency Plan'

Revision of Volume 9, Emergency Plan, Chapter 7, Communications, Chapter 8, Organization,Chapter 9, Emergency Response, Chapter 10, Radiological Assessment, Chapter 12,Maintaining Emergency Preparedness, and Appendix A, Letters of Agreement

The revisions to the Emergency Plan were a result of corrective action (C-BRP-04-0069) andAudit findings on training deficiencies (C-BRP-04-0228 and C-BRP-05-0009).

C-BRP-04-0069: Communication responsibilities were transferred from the former Pantmonitoring station to the Independent Spent Fuel Storage Installation (ISFSI) Central AlarmStation (CAS). Several editorial revisions included revising reference from the monitoringstation to CAS, Shift Supervisor to "On-Shift Operations Personnel," and revision of thelocation of the Emergency Support Center.

C-BRP-04-0228 and C-BRP-05-0009: Training Matrix specifies "Plant Support Personnel",who were not identified. Plan wvas revised to indicate that the Emergency ResponseOrganization (ERO) has all the responsibilities in the Plan, and any additional Supportpersonnel work directly under the supervision of the ERO personnel, who are trained.


As a result of the revision, a thorough review of the Updated Final hazards Summary Report(UFHSR) was also done. UFHSR Section 2.1.3.3 contained a site-specific definition of BigRock Point's Low Population Zone (LPZ) and Emergency Planning Zone (EPZ), which wererevised. This revision to the UFHSR was NOT a result of the above Emergency Plan revisions.Rather, the definition of the LPZ became void and the Emergency Planning Zone became thesite boundary with the exemptions from offsite emergency planning granted by the NRC onSeptember 30, 1998.

The above revisions were evaluated in accordance with the guidance of and found not todecrease the effectiveness (DIE) of the Emergency Plan. These evaluations and revisions weredocumented in letters to the U.S. NRC dated August 18, 2003 and February 2, 2005.

QRF Log # 170-04, 264-04, 01-05 through 04-05Cartridge/Frame 4902/2444 and upon request

' Proposed Emergency Plan Exemption Request Submitted to the US NRC October 31, 2003 was withdrawn in aletter to the US NRC dated September 7,2004. The September 7,2004 submittal is a revision of the EmergencyPlan, which is a decrease in effectiveness, currently under NRC review.

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Volume 26Fire Protection Summary and Associated Administrative Procedures

Revision of Volume 26, Fire Protection Summary and revision of deletion of variousAdministrative Procedures and Operational Procedures was performed to incorporate allprocedures as an Appendix to the Fire Protection Summary. In addition, the Fire ProtectionSummary was reviewed and revised to reflect current site conditions [all Spent Nuclear Fuel(SNF), Greater Than Class C (GTCC) waste, and Special Nuclear Material (SNM) stored onthe Independent Spent Fuel Storage Installation (ISFSI)].

The revisions also incorporated the greatly reduced scope of the Fire Protection Plan. DefueledTechnical Specification Amendment 125 (March 19, 2004) deleted all Limiting Conditions forOperations (LCOs) for the Fire Protection System. The Fire system was made available fordismantlement in May of 2004. No credible accident with release in excess of design basislimits exists with all SNF, GTCC, and SNM on the ISFSI.


The revision to the Fire Protection Summary did not adversely affect the any method ofevaluation of accidents in Chapter 15 of the UFHSR. No structures, systems, or components(SSCs) remain in the former plant area that are relied upon for accident mitigation.

The design basis function of fire protection to prevent off-site radiological releases belowregulatory limits (10 CFR 20.1402) is no longer a concern. Fire protection plan for the formerindustrial area is an industrial fire plan. ISFSI fire hazard was analyzed in the site-specific 10CFR 72.212 fire analysis. Remaining radiological concerns consist of ALARA considerationsonly. Hazardous radiological releases are no longer credible with all SNF, GTCC, and SNMstored on the ISFSI.

No new types of system or component failures are introduced by the revision of Volume 26.No active SSCs remain to mitigate Design Basis Accidents. Commitments to previouscommitments for fire protection were made void by the use of a passive dry fuel storagesystem to contain spent nuclear fuel. Analysis of fire effects on storage of spent nuclear fuel inthe BNFL FuelSolutionsTm storage system has been thoroughly reviewed via the 10 CFR72.212 evaluation.

Revision of the fire plan is consistent with remaining credible, analyzed accidents and removalof systems and components from Big Rock Point.

QRF Log 184-04, 185-04, 187-04, through 191-04, 193-02 through 198-04Cartridge/Frame 4913/2624 and upon request

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Volume 33, BRP-212, 1OCFR72.212 and Certificate Compliance Evaluation Report

Revision to this document was made as a result of revised application to the U.S. NRC (datedSeptember 15, 2004) and approval of the 10 CFR 20.2002 procedures for disposal of non-impacted waste from Big Rock Point Plant (dated January 19, 20005). This revision consistedof deletion of specific dose scenarios and amounts of demolition debris in the CoC Evaluation.

Prior NRC approval for this alternate disposal was obtained pursuant to 10 CFR 20.2002. Theanalysis of record for previous approval, dated February 5, 2002, did not include distance tothe licensed landfill that accepts PCB contaminated waste. The density of material shipped,along with the increased number of trips for truck driver dose was increased.


The analysis submitted (and approved) yielded results that were essentially the same. The samemethod of evaluation (RESRAD) was used to perform the dose evaluations for transportationworker, landfill worker, and resident/farmer. Results differ slightly, due to revision in quantity,density, and number of trips for transportation workers.

QRF Log # 281-04

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Volume 34CPC-2A, Quality Program Description for Nuclear Power Plants, Part 1, Big Rock PointPlant

The Quality Program for Big Rock was reviewed and accepted by the U.S. NRC in their SafetyEvaluation Report dated October 28, 2003. No revisions have been made to this documentsince its acceptance. The Quality Program, as accepted, was incorporated into a local Volumeon January 28, 2004 as Revision 21.

QRF Log # 710-03Cartridge/Frame Upon Request

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Updated Final Hazards Summary Report (UFHSR)Review and Revision (12) due to Decommissioning and Dismantlement Activities

A project to review and update the Final Hazards Summary Report was undertaken to ensurethe UFHSR was current and reflected Site conditions as of October 1, 2004. With all spentnuclear fuel removed to the Independent Spent Fuel Storage Installation (ISFSI) and sitestructures (Turbine Building, Screenhouse, and Reactor Building) released for demolition,systems, structures, and components (SSCs) described in the UFHSR were no longer safety-related. Removal of these SSCs from the site had made portions of the UFHSR immaterial. Ageneral review of the document was performed to remove SSCs that have been eliminatedfrom the site.


With all spent nuclear fuel removed from the former industrial area and placed onto the ISFSI,accidents involving fuel are no longer affected. No SSCs that are Quality- Related (Safety-Related or Important-to-Safety) remain in the former industrial area. Demolition activities inthe former industrial area can no longer affect the consequences of an accident; all significantsource term material is in dry storage at the ISFSI.

QRF Log # 247-04

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Big Rock Point PlantBiennial Report of Facility Changes, Tests, and Experiments'


Updated Final Hazards Summary Report (UFHSR)Revision (13) due to Revised Demolition Debris Disposal Procedures Approved by theU.S. NRC Pursuant 10 CFR 20.2002

Editorial revisions were made to the UFHSR, Chapter 11, Radiological Waste Management.The revisions updated discussions on the Big Rock Point Bulk Material Disposal Program. OnSeptember 15, 2004, Big Rock requested revision to the 10 CFR 20.2002 procedures grantedby the U.S. NRC on February 5, 2002. The changes were required to include disposal ofpolychlorobiphenyl (PCB) contaminated steel in a landfill at a revised distance from originallyapproved by the NRC in their approval of Big Rock Point disposal under 10 CFR 20.2002 SERdated February 5,2002. NRC approval was obtained on January 19, 2005.


The changes were required to include disposal of PCB contaminated steel in a landfill at arevised distance from originally approved by the NRC in their SER dated February 5,2002.

Dose effects to waste truck drivers, landfill workers and future resident farmer from therevisions outlined are considered minor, are consistent with the original submittal and are wellbelow the public dose objective of I mrem/year. Changes as a result of revised assumptionsand dose calculations are included in the proposed request. It is important to note that nocredit is taken for reduction in landfill worker or resident farmer doses associated with thedisposal of demolition debris in Type II landfill for PCB wastes material sent to the EQCofacility. However, if the entire estimated quantity of PCB bulk product waste were sent to theEQCo facility, doses associated with disposal at the licensed Type II landfill would be reducedfor these individuals.

Analyses used to calculate the doses to landfill workers, transportation worker, andfarmer/residents were based on quantities of materials presented to the MPSC in April of 2004.The revised analyses and assumptions of quantities resulted in verification of no changes toEnvironmental Impacts (the doses remain bounded by the FGEIS). PSDAR sections anddiscussion of disposal of waste, PCB, and general decommissioning activities remain valid andare not revised by this submittal. Revisions ensure the waste disposal will continue so the sitemay be release for unrestricted use in accordance with the PSDAR and LTP assumptions.Disposal of non-radiologically contaminated waste at landfills continues to ensure the cost ofdecommissioning will not be adversely impacted.

QRF Log # 73-05

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Post Shutdown Decommissioning Activities Report (PSDAR)Period Review and Revision (4) due to Decommissioning and Dismantlement Activities

A general review of the Past Shutdown Activities Report (PSDAR) was performed to ensureconsistency with the completed decommissioning activities and in conjunction with therevision to the Updated Final Hazards Summary Report. The revisions included:

1. Specifying completed activities and revising the schedule for decommissioning toreflect the current schedule.

2. Changing a paragraph on method for monitoring airflow by referencing the OffsiteDose Calculation Manual (ODCM) as the document that is used for controllingairborne contamination.

3. Modifying the "Environmental Impact" section to be consistent with the September 15,2004 submittal/revision to the NRC for approval of disposal of demolition debris inaccordance with 10 CFR 20.2002. The revision broke waste streams into radioactivewaste (which continues to be bounded by NUREG-0586, "Final Generic EnvironmentalImpact Statement on Decommissioning of Nuclear Facilities") and demolition debrisdisposed of in accordance with procedures approved by the U.S. NRC under 10 CFR20.2002.

4. Provide an update of information on the "Estimate of Expected DecommissioningCosts," which is consistent with information provided to the Michigan Public ServiceCommission in March of 2004 and through December 31,2004.


PSDAR and UFHSR specify work practices and procedural controls used at BRP that precludethe release of radioactive or other hazardous materials that could threaten future site release.

Revisions do not potentially contaminate or otherwise deposit radioactive or other hazardousmaterials on the site and could threaten site release for unrestricted use.

Safety analyses have been performed for fuel-related accidents, external events, andnon-fuel-related decommissioning activities. Decommissioning activities (activities completedon the schedule and revisions as requested to the NRC for proposed procedures under 10 CFR20.2002 for disposal of demolition debris) have been assessed and compared to the GenericEnvironmental Impact Statement (GEIS), and found to be within the bounds of the genericanalysis. Decommissioning activities evaluated were equipment deactivation, decontamination,and dismantlement; radioactive material handling and storage; and transportation of radioactivematerials. Types of accidents postulated to occur during these activities and evaluated were:explosions and fires, loss of contamination control, waste transportation accidents, externalevents and natural phenomena. All activities remain bounded by UFHSR and FGEISassumptions.

The PSDAR and UFHSR specify work practices and procedural controls used at BRP thatpreclude the release of radioactive or other hazardous materials that could impact public safetyand health.

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All decommissioning activities identified in the PSDAR have been adequately funded. ThePSDAR identifies decommissioning activities in a broad scope, such as: remove asbestosinsulation, perform primary system decontamination, remove turbine control oil, and ship andproperly dispose of all radioactive materials. Specific activities falling under these broadguidelines have been sufficiently funded. No significant cost increases resulted (a new totalcost estimate of 20 percent above the PSDAR total cost estimate or a 25 percent increase incost above a major milestone estimate. New estimate of 331.1 million for NRC radiologicaldecommissioning is a less than an 11% increase (revised from 299.4 million.)

QRF Log # 27-05

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