* Consumers Energy has a Big Rock Point decommissioning webpage.

June 30, 2007

New this week from NRC Public Document Room

* [2007-06-30] 2007/06/28-Commision Memorandum and Order (CLI-07-21) ML071790530 2007-06-28 8 05000155 07200043 50-155-LT 72-043-LT CLI-07-21 RAS 13810 2007-06-28 2007-06-29 2007-06-28 1 Petitioners based their claims of standing solely on this ground. See Request for Hearing and Petition to Intervene at 1-2 (Feb. 20, 2007). 2 In their Petition for

* [2007-06-29] M070628-Affirmation Session: I - SECY-07-0097 - Consumers Energy Co. Big Rock Point ISFSI License Transfer Application Petition for Recon.; II. SECY-07-0098 - Consumers Energy Co. et al Palisades License Transfer Application Petition for Recon ML071790364 2007-06-28 2 CLI-07-18 CLI-07-19 M070628 SECY-07-0097 SECY-07-0098 SRM-M070628 2007-06-28 2007-06-28 1 Section 201 of the Energy Reorganization Act, 42 U.S.C. Section 5841, provides that action of the Commission shall be determined by a "majority vote of the members pr

* [2007-06-28] Transcript of Public Meeting Big Rock Point, on Thursday, November 13, 1997, Pages 1-84 ML071780024 1997-11-13 86 05000155 ASB-300-41 1997-11-13 2007-06-27 OFFICIAL TRANSCRIPT OF PROCEEDINGS UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Title: PUBLIC MEETING BIG ROCK POINT Docket No.: Work Order No.: LOCATION: ASB-300-41 Charlevoix, MI DATE: Thursday, Novembe

June 23, 2007

New this week from NRC Public Document Room

* [2007-06-22] Big Rock Point Plant - Annual Radioactive Effluent Release Report for the Period of January 1, 2006 - December 31, 2006 ML071080301 2007-04-11 18 05000155 07200043 DPR-006 2007-04-11 2007-06-21 Consmr-5 Energyy A CMS Energy Company. Big Rock Point Nuclear Plant Kurt NA Haas 10269 US-31 North General Manager Charlevoix, MI 49720 April 11, 2007 10 CFR 50 Appendix I, Section IV.B.1 10 CFR 50.36(a) U.S.

* [2007-06-21] Big Rock Point - Annual Radioactive Environmental Report for the Period of January 1, 2006 - December 31, 2006 ML071080303 2007-04-11 56 05000155 07200043 DPR-006 2007-04-11 2007-06-20 Consunws Enem A CMS Energy Company Big Rock Point Nuclear Plant Kurt M. Haas 10269 US-31 North General Manager Charlevoix, M1 49720 April 11, 2007 10 CFR 50, Appendix I, IV.B.2 10 CFR 50, Appendix I, IV.B.3 1

June 16, 2007

New this week from NRC Public Document Room

* [2007-06-15] 2007/05/07- Big Rock Point - Petition for Reconsideration of 04/26/2007 Memorandum & Order Denying Petitioners the Status of Intervenors ML071350496 2007-05-07 10 05000155 07200043 50-155-LT 72-043-LT RAS 13605 2007-05-07 2007-06-14 2007-05-08 'Mt S J (0 DOCKETED USNRC May 8, 2007 (8:07am) OFFICE OF SECRETARY UNITED STATES OF AMERICA RULEMAKINGS AND NUCLEAR REGULATORY COM4ISSION ADJUDICATIONS STAFF In the Matter of

* [2007-06-13] L. Dean ltr re: Culmination of NRC Participation in the Memorandum of Agreement on the Big Rock Point Site ML071550289 2007-06-11 2 05000155 2007-06-11 2007-06-12 June 11, 2007 Ms. Laura Henley Dean Program Analyst Advisory Council on Historic Preservation 1100 Pennsylvania Avenue, NW, Suite 803 Old Post Office Building Washington, DC 20004 SUBJECT: CULMINATION OF NRC PARTICIPATION IN

June 9, 2007

New this week from NRC Public Document Room

* [2007-06-07] FY 2007 Final Fee Rule Workpapers ML071520399 2007-05-30 341 05000003 05000010 05000029 05000133 05000155 05000206 05000213 05000245 05000295 05000304 05000309 05000312 05000409 07200001 07200009 07200017 07200020 07200022 07200025 2007-05-30 2007-06-06 FY 2007 Final Fee Rule Workpapers Part 171 Annual Fees Operatin

* [2007-06-07] Letter to MI SHPO re MOA at BRP, re Culmination of NRC Participation in the Memorandum of Agreement on the Big Rock Point Site ML071230066 2007-05-29 2 05000155 2007-05-29 2007-06-06 May 29, 2007 Brian D. Conway, SHPO State Historic Preservation Office Michigan Historical Center Department of History, Arts and Libraries Box 30740 Lansing, MI 48909-8240 SUBJECT: CULMINATION OF NRC PARTICIPATION IN THE MEMO

May 26, 2007

New this week from NRC Public Document Room

* [2007-05-26] 2007/05/17- Big Rock Point - Answer in Opposition to Petition for Reconsideration ML071410246 2007-05-17 10 05000155 05000255 07200043 50-155-LT 72-043-LT RAS 13656 2007-05-17 2007-05-25 2007-05-17 S 1lo6 DOCKETED USNRC May 17, 2007 (4:12pm) UNITED STATES OF AMERICA OFFICE OF SECRETARY BEFORE THE RULEMAKINGS AND NUCLEAR REGULATORY COMMISSION ADJUDICATIONS STAFF

* [2007-05-25] IR 03034760-04-001, on 11/29/2004, Rapoca Energy Co., Big Rock, VA, 591M, Part 1 and 2 ML043560426 2004-11-29 2 03034760 45-25438-01 IR-04-001 2004-11-29 2007-05-24 LOTZ us3 01 (E&- L t C lUVd W C60 NUOJ 3UN N01133dSNI 33NVlldVU03 QNV ltlOd3tl N01133dSNI Al3dVS JOISSIyYWO3 AUOlVlfl93U UV313flN ÔSTl NRC FORM 591 M PART 2 (1 1 9 0 3 ) 10 CFR 2201 U.S. NUCLEAR REGULATO

* [2007-05-24] Summit Engineering, Inc., Amendment Request dated 1/2/2006, Received 4/14/2006. Amends License No. 45-30987-01 to Reflect New Mailing and Physical/911 Addresses ML061100417 2006-01-02 2 03036812 45-30987-01 138725 2006-01-02 2007-05-23 TO : Date: January 2 7 Ó From: Byrd Cop,&> Re: Virginia Office Address Change Outer Offices and Clients As of January 2, 2006 our address will be the following: Mailing Address: P.O. Box 40 Big Rock, Virgin

May 19, 2007

New this week from NRC Public Document Room

* [2007-05-16] VR-SECY-07-0062 - Final Rule: Requirements for Expanded Definition of Byproduct Material (RIN:3150-AH84). ML071350056 2007-05-14 14 05000155 RIN 3150-AH84 SECY-07-0062 VR-SECY-07-0062 2007-05-14 2007-05-15 SECR 0 UNITED STATES NUCLEAR REGULATORY COMMISSION 0 WASHINGTON, D.C. 20555-0001 May 14, 2007 ETARY COMMISSION VOTING RECORD DECISION ITEM: SECY-07-0062 TITLE: FINAL RULE: REQUIREMEN

* [2007-05-15] Reactor Decommissioning Program Lessons-Learned. ML071240185 2005-12-31 14 05000029 05000155 05000206 05000213 05000309 05000312 05000344 05000361 05000362 2005-12-31 2007-05-14 ML071240165+ Reactor Decommissioning Program Lessons-Learned .4y *Ralph Andersen, CHP (NEI) Sean Bushart, Ph.D (EPRI) C 2005 Electric Power Research Inst

* [2007-05-15] 07/13/2005 Big Rock Point - RSRC Update, Part 1 of 2. ML070650489 2005-07-13 27 2005-07-13 2007-05-14

* [2007-05-15] 07/13/2005 Big Rock Point - RSRC Update, Part 2 of 2. ML070650490 2005-07-15 22 2005-07-15 2007-05-14

* [2007-05-15] 07/13/2005 Big Rock Point - RSRC Update. ML070650488 2007-05-14

* [2007-05-15] Attachment 1, Transmittal of Survey Packages in Support of Big Rock Point Phased License Termination, Matrix of FSS Supporting Documentation. ML070600738 2006-10-27 6 2006-10-27 2007-05-14

* [2007-05-15] Attachment 2, Transmittal of Survey Packages in Support of Big Rock Point Phased License Termination, Class 1 Final Status Survey Release Record, 07C11, South East Protected Area. ML070600751 2006-10-27 38 2006-10-27 2007-05-14

* [2007-05-15] Attachment 3, Transmittal of Survey Packages in Support of Big Rock Point Phased License Termination, Class 1 Final Status Survey Release Record, 08C11, East Central Protected Area. ML070600761 2006-10-27 37 2006-10-27 2007-05-14

* [2007-05-15] Attachment 4, Transmittal of Survey Packages In Support of Big Rock Point Phased License Termination, Class 1 Final Status Survey Release Record, 10C11, East Protected Area. ML070600765 2006-10-27 38 2006-10-27 2007-05-14

* [2007-05-15] Attachment 5, Transmittal of Survey Packages in Support of Big Rock Point Phased License Termination, Class 1 Final Status Survey Release Record, 11C11, East Protected Area. ML070600772 2006-10-27 38 2006-10-27 2007-05-14

* [2007-05-15] Big Rock Point - Independent Spent Fuel Storage Installation - Annual Radioactive Effluent Release Report for Period From January 1, 2006 Through December 31, 2006. ML070460597 2007-02-02 4 2007-02-02 2007-05-14

* [2007-05-15] Big Rock Point - Overflights. ML032540364 1988-06-13 7 1988-06-13 2007-05-14 ML032540222+

* [2007-05-15] Consumers Energy Co Letter to EPA R5 re Inadvertent Torch Cut of Containment Shell Piece at Big Rock Point. ML070640329 2005-11-10 5 2005-11-10 2007-05-14

* [2007-05-15] FOIA/PA-2007-0113 - Big Rock Restoration Project, Michigan, records re: monitoring levels of radiation from ISFSI & residual contamination ML070380253 2007-02-06 2 2007-02-06 2007-05-14 ML070710186+

* [2007-05-15] October 27, 2006 Transmittal of Survey Packages - Big Rock Point FSSR. ML070600728 2007-05-14

* [2007-05-15] October 27, 2006 Transmittal of Survey Packages - Big Rock Point FSSR. ML070600733 2006-10-27 2 2006-10-27 2007-05-14

* [2007-05-15] ORISE In-Process Survey for Turbine Building Excavation at Big Rock Point. ML070640332 2005-11-01 7 2005-11-01 2007-05-14

* [2007-05-15] Transmittal of Survey Packages in Support of Big Rock Point Phased License Termination. ML070600673 2006-10-24 161 2006-10-24 2007-05-14

May 12, 2007

New this week from NRC Public Document Room

* [2007-05-10] 2007/02/20-Request for Hearing and Petition to Intervene ML071230335 2007-02-20 35 05000155 07200043 DPR-006 50-155-LT 72-043-LT RAS 13557 2007-02-20 2007-05-09 2007-02-20 1?5 13 657 DOCKETED USNRC UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION OFFICE OF THE SECRETARY February 20, 2007 (3:40pm) OFFICE OF SECRETARY RULE

* [2007-05-10] 2007/04/20-Letter from Kevin Kamps to Emile L. Julian enclosing Request for Hearing and Petition to Intervene that was e-mailed to the Office of the Secretary on 02/20/07 ML071220308 2007-04-20 2 05000155 07200043 50-155-LT 72-043-LT RAS 13558 2007-04-20 2007-05-09 2007-04-26 136585 NUCLEAR INFORMATION AND RESOURCE SERVICE DOCKETED USNRC 6930 Carroll Avenue, Suite 340, Takoma Park, MD 20912 301-270-NIRS (301-270-6477); Fax: 301-270-4291 AprI 26,200

May 5, 2007

New this week from NRC Public Document Room

* [2007-05-05] Mr. Arunas T Udrys Ltr re: Big Rock Point - Issuance of Amendment 127 for Approval of Transfer of Facility Operating License No. DPR-06 (TAC J60565). ML071020085 2007-04-13 1 05000155 07200043 DPR-006 TAC J60565 2007-04-13 2007-05-04 ML071010036+ April 13, 2007 Mr. Arunas T. Udrys Assistant General Counsel Consumers Energy Company One Energy Plaza Jackson, MI 49201 SUBJECT: BIG ROCK POINT - ISSUANCE OF AMENDMENT 127 FOR APPROVA

* [2007-05-05] Mr. Douglas E. Levanway Ltr re: Big Rock Point - Issuance of Amendment 127 for Approval of Transfer of Facility Operating License No. DPR-06 (TAC J60565). ML071020172 2007-04-13 1 05000155 07200043 DPR-006 TAC J60565 2007-04-13 2007-05-04 ML071010036+ April 13, 2007 Mr. Douglas E. Levanway Wise Carter Child and Caraway, P.A. P.O. Box 651 Jackson, MS 39205 SUBJECT: BIG ROCK POINT - ISSUANCE OF AMENDMENT 127 FOR APPROVAL OF TRANSFER O

* [2007-05-05] Mr. Sam Behrends Ltr Re: Big Rock Point- Issuance of Amendment 127 for Approval of Transfer of Facility Operating License No. DPR-O6 (TAC J60565). ML071020233 2007-04-13 2 05000155 07200043 DPR-006 TAC J60565 2007-04-13 2007-05-04 ML071010036+ April 13, 2007 Mr. Sam Behrends LeBoeuf, Lamb, Greene and MacRae, LLP 1875 Connecticut Avenue, NW, Suite 1200 Washington, DC 20009 SUBJECT: BIG ROCK POINT - ISSUANCE OF AMENDMENT 127 F

* [2007-05-05] R.A. Fenech Letter re: Big Rock Point - Issuance of Amendment 127 for Approval of Transfer of Facility Operating License No. DPR-06 (TAC J60565). ML071000510 2007-04-13 20 05000155 07200043 DPR-006 TAC J60565 2007-04-13 2007-05-04 ML071010036+ April 13, 2007 Mr. Robert A. Fenech Senior Vice President for Nuclear, Fossil, and Hydro Operations Consumers Energy Company One Energy Plaza Jackson, MI 49201 SUBJECT: BIG ROCK POINT

* [2007-05-05] Big Rock Point, License Amendment No. 127 for Approval of Transfer of Facility Operating License No. DPR-06. ML071010036 2007-05-04 ML071000510+ML071020085+ML071020172+ML071020233+ FNWEBNAVIGATE=1.0 SYSTEMTYPE=MEZZANINE DOCUMENTID=071010036 STARTPAGE=1 LIBRARYNAME=ml_adams^hqntad01

April 28, 2007

New this week from NRC Public Document Room

* [2007-04-27] M070426 - Affirmation Session: a. SECY-07-0040 - Consumers Energy Company, et. Al. (Palisades Nuclear Plant); License Transfer Application; b. SECY-07-0071 - Consumers Energy Co. (Big Rock Point ISFSI); License Transfer Application. ML071160268 2007-04-26 5 05000155 05000255 07200043 M070426 SECY-07-0040 SECY-07-0071 2007-04-26 2007-04-26 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ***** AFFIRMATION SESSION *** PUBLIC MEETING *** Nuclear Regulatory Commission Commission Hearing Room 11555 Rockville

* [2007-04-27] SRM-M070426 - Affirmation Session: (1) SECY-07-0040 - Consumers Energy Co. (Palisades); (2) SECY-07-0071 - Consumers Energy Co. (Big Rock Point ISFSI). ML071160231 2007-04-26 2 05000155 05000255 07200043 M070426 SECY-07-0040 SECY-07-0071 SRM-M070426 2007-04-26 2007-04-26 1 Section 201 of the Energy Reorganization Act, 42 U.S.C. Section 5841, provides that action of the Commission shall be determined by a "majority vote of the mem

* [2007-04-24] Palisades, Big Rock Point, and Big Rock Point ISFSI, Evidence of Insurance Required by 10 CFR 140 and 10 CFR 50.54(w). ML071100488 2007-04-10 24 05000155 05000255 07200043 ENOC-07-00011 TAC MD2954 2007-04-10 2007-04-23 Entergy Nuclear Northeast Entergy Nuclear Operations, Inc. 440 Hamilton Avenue EnteP. RO. Box 5029 White Plains, NY 10601-5029 Tel 914 272 3500 April 10, 2007 ENOC-07-00011 Mr. James

April 21, 2007

New this week from NRC Public Document Room

* [2007-04-17] Big Rock Point FY 2007 Integrated Inspection Plan. ML070990524 2007-04-09 2 05000155 07200043 DPR-006 2007-04-09 2007-04-16 April 9, 2007 Laurie Lahti Licensing Manager Palisades Nuclear Plant 27780 Blue Star Hwy Covert, MI 49043 SUBJECT: BIG ROCK POINT FISCAL YEAR (FY) 2007 INTEGRATED INSPECTION PLAN Dear Ms. Lahti: Pursuant to M

* [2007-04-17] Robert Frounfelker ltr re: Change to Indemnity Agreement Number B-22. ML071010273 2007-04-11 5 05000155 DPR-006 2007-04-11 2007-04-16 April 11, 2007 Consumers Energy Company ATTENTION: Mr. Robert Frounfelker One Energy Plaza OEP 12-401 Jackson, MI 49203 SUBJECT: CHANGE TO INDEMNITY AGREEMENT NUMBER B-22 Dear Mr. Frounfelker: Enclosed are three origi

Recent NRC inspections

* (released March 18) Big Rock Point decommissioning report 50-155-2003-7

* (released Nov 20) Big Rock decommissioning report 50-155-2003-5

* (released Sept 23) Big Rock Point decommissioning report 50-155-2003-4

* (released Sept 11) Big Rock Point ISFSI safeguards report 72-043-2003-3

* Big Rock Point ISFSI report 72-043-2003-1

* Big Rock Point report 50-155-2003-1

February 28, 2004

39 things NRC wants to see addressed in Big Rock License Termination Plan

REQUEST FOR ADDITIONAL INFORMATION
RELATED TO BIG ROCK POINT LICENSE TERMINATION PLAN (2/17/2004)

Based upon the LTP, supporting documents, and discussions with the licensee and its contractors during a site visit in August 2003, the licensee should be able to revise its LTP and satisfy the concerns. The following requests for additional information (RAIs) list the issues that should be addressed in the revised LTP.

GROUNDWATER AND SURFACE WATER

1. The licensee should discuss the impact of seasonal changes on the potentiometric surfaces of the water-bearing units at this site. The licensee should provide, in the LTP, groundwater potentiometric maps for wet and dry seasons for each water-bearing unit with generalized groundwater flow directions indicated on these maps.

2. The impact of recharge from precipitation on groundwater levels and fate and transport of the radionuclides in the groundwater should be evaluated and discussed.

3. The impact of water level fluctuations in Lake Michigan, including tidal effects and in particular recent water level declines, on groundwater levels and on fate and transport of radionuclides in the groundwater should be evaluated and discussed.

Basis for 1-3: Groundwater flow directions and potentiometric maps of the water-bearing units are necessary for proper characterization and for meeting the radiological criteria for license termination in Subpart E of 10 CFR 20.

4. Tritium plume maps for the three water-bearing units should be developed and provided in the revised LTP. If other radionuclides have plumes, the plumes should be delineated and provided via maps.

Basis: The H-3 plume maps for the aquifers or water-bearing units are necessary for proper characterization and for meeting the radiological criteria for license termination in Subpart E.

5. The licensee should discuss the significance of the vertical and horizontal flow patterns within and between the water-bearing units with respect to the fate and transport of site-generated radionuclides. The licensee should also discuss the effect of building foundations on groundwater flow and radionuclide transport, and changes that may result from the removal of the foundations.

6. The licensee should provide a description of the process it plans to use to remove the tritium source term under the turbine building. This should include the method of extraction that would be used, any barriers that will be used to limit migration, the monitoring plan to determine if migration has occurred, a discussion of how the sufficiency of remediation will be demonstrated, and the corrective actions if migration is detected.

Basis for 5-6: The groundwater flow patterns associated with the foundations are necessary for proper characterization and for meeting the radiological criteria for license termination in Subpart E.

7. The licensee should discuss whether site-generated radionuclides have moved offsite, or whether there is the potential for site-generated radionuclides to move offsite. If radionuclides have moved offsite or if they will move offsite, the licensee should provide an estimate of the time for radionuclides to travel offsite.

8. What are the sample collection dates for the groundwater analyses listed in Table 2-10?

Basis for 7-8: Radionuclide movement in the water-bearing units is necessary for proper characterization and for meeting the radiological criteria for license termination in Subpart E.

9. Additional groundwater sampling events (or data) to evaluate the effects of seasonal changes on the radionuclide concentrations should be provided (one sampling event per season).

10. The licensee should evaluate the potential radionuclide impact of the septic system drain field on groundwater at this site. The evaluation should include a determination of whether additional groundwater monitoring wells should be installed down gradient from the drain field.

11. The licensee should discuss how it will evaluate and remediate, if necessary, potential radionuclide contamination of the groundwater adjacent to the Annex drain field.

12. The licensee should discuss the potential contamination of the groundwater and surface water by radionuclides within the dredged materials at this site.

13. The licensee should discuss its post-remediation groundwater monitoring. This discussion should include the monitoring wells that will be sampled, frequency and number of monitoring events, and radionuclides that will be analyzed. Licensee should justify that its groundwater monitoring program will sample potential site-generated radionuclide plumes that will flow toward Lake Michigan. Basis for 9-13: The radionuclides present in the water-bearing units are necessary for proper characterization and for meeting the radiological criteria for license termination in Subpart E.

DERIVED CONCENTRATION GUIDELINE LEVELS (DCGLs)

A. Use of Screening DCGLs

14. The licensee must demonstrate that the use of either published screening DCGLs or site-specific DCGLs is appropriate for Survey Unit 12 given the reported H-3 concentrations in the groundwater beneath the survey unit.

15. The licensee should report a screening DCGL for Pu-241 that is consistent with the description of its demonstration provided in the LTP.

Basis for 14-15: NUREG-1757, Volume 2, Appendix H advises NRC staff that screening analyses may not be applicable to demonstrate compliance with 10 CFR 20, Subpart E, because of the status of contaminants or because of site-specific physical conditions. Published screening DCGLs may be applicable to sites provided conditions are consistent with those for which the screening DCGLs are developed.

B. Use of Site-Specific Industrial Area DCGLs

16. The licenseeÕs demonstration of compliance inherently assumes a retardation coefficient of unity. However, the licenseeÕs derived site-specific retardation coefficients are inconsistent with this inherent assumption. The licensee should provide a demonstration of the reduction in dose limit due to groundwater contamination consistent with the site conceptual model.

17. The description in section 6.8.2.3 of the analyses performed to compare dose contributions from radionuclides at the surface with those from the subsurface is inconsistent with the results presented in Table 6-11 for surficial dose contributions. The licensee should provide a description of the analysis that is consistent with the reported values in Table 6-11.

18. The licensee reports H-3 is known to be present in groundwater onsite and is, therefore, potentially present in soil. The licensee should demonstrate the effects on DCGLs of H-3 in subsurface soils in a manner consistent with site conditions.

Basis for 16-18: The licensee must provide defensible assumptions and models to demonstrate compliance with 10 CFR 20, Subpart E.

C. Sensitivity Analysis of The Big Rock Point Dose Model

19. The licensee should provide the RESRAD uncertainty summary reports for all analyses associated with sensitivity analyses and a demonstration that the results of the sensitivity analyses, in terms of the most sensitive parameters, appropriately accounts for uncertainty (i.e., are the results stable?).

D. Derivation of Area Factors

20. The licensee reports results of analyses to derive area factors in Appendix 6-L. The licensee should provide the RESRAD summary reports for the analyses which produced these results.

Basis for 19-20: Demonstration of compliance with 10 CFR 20, Subpart E, requires the licensee to provide sufficient information to allow an independent evaluation of the potential dose resulting from residual radioactivity after license termination.

ALARA ANALYSIS

21. The licensee should provide analyses to determine average concentrations of residual radioactivity in units of pCi/g of soil for each of the radionuclides reported in Appendix 4-A.

22. The licensee should account for tritium concentrations in the subsurface when quantifying the present worth of future collective averted dose.

Basis for 21-22: The information supplied to support a demonstration of compliance with 10 CFR 20, Subpart E, should be sufficient to allow independent review of the basis for the licenseeÕs conclusions that residual radioactivity concentrations are ALARA.

RADIOLOGICAL HEALTH AND SAFETY

23. The numerical sizes for impacted and non-impacted areas in ¤2.2.5.1 do not add to the Òencompassed area.Ó Please provide consistent values.

Basis: The size of survey units is required to ensure that data quality objectives, QA/QC objectives as described in NUREG-1575, Rev. 1 are met.

24. Section 2.2.4.2 states that the HSA data identified no occurrence of transuranic contamination beyond the Containment Building at the site. Validation of this through the analysis of environmental characterization samples specifically for transuranics was not apparent. A review of Chapter 6 does provide an indication that transuranics were included in the analysis of samples identified during characterization with the highest gamma-emitter activities. Please clarify whether specific analyses for transuranics were performed to ensure that they are not a contaminant of concern.

Basis: Proper characterization of the soil is necessary for the dose assessment and compliance with decommissioning requirements in Subpart E of 10 CFR 20.

25. Section 2.2.4.2: Item 5 of this section states that spent fuel was routinely shipped offsite for testing and reprocessing throughout the 1960s and 1970s. This appears to contradict Item 8 of this section where the statement is made "Éfuel has never been routinely handled outside of the Containment Building." Please clarify the handling of spent fuel in the facility environs. This is also a potential concern as it relates to the possibility of transuranic contamination as discussed in comment no. 24.

Basis: Proper characterization of the soil is necessary for the dose assessment and compliance with decommissioning requirements in Subpart E of 10 CFR 20.

26. Page 2-15. Provide information regarding Big Rock Point's vender hot cross check program. Specifically provide information on equipment validation test and frequency of check performance evaluation.

Basis: Properly calibrated and functioning instruments are required to perform surveys as required in 10 CFR 20.1501.

27. Page 2-16, 2.3.1.3. This section describes the staff training and qualification requirements. Provide information on general training requirements, and on implementation of new procedures and requirements for refresher training.

Basis: Staff training ensures knowledge of procedural changes and ensures that data quality objectives, QA/QC objectives as described in NUREG-1575, Rev. 1 are met.

28. Page 2-19. BRPÕs current acceptance criteria for the Global Positioning Survey (GPS) is accuracy to +/- 10 meters. Provide the actual accuracy of the GPS system and additional explanation on the use and appropriateness of the GPS system.

Basis: Accurate survey equipment is necessary for the proper characterization and meeting the remediation requirements in Subpart E of 10 CFR 20.

29. Page 2-19 and 2-20. The LTP states that In-Situ gamma spectroscopy may be used for soil surveys. The detector efficiency is calculated at a 25 cm source to detector distance. However, in the field the source to detector distance will be 7.07 meter. Provide the efficiency of the detector, the Minimum Detectable Concentration (MDC) of the detector, and a description of the effect differences in soil density and moisture content have on the MDC at 7.07 meters.

Basis: Verification of system performance, proper calculation of efficiency and MDC is necessary for characterization and meeting the remediation requirements in Subpart E of 10 CFR 20.

30. Page 2-45. Water samples were tested for the presence of gamma emitters and H-3. Only samples with H-3 contamination were analyzed for other hard-to-detect radionuclides. Provide evidence that samples without H-3 contamination do not contain other hard-to-detect radionuclides.

Basis: Proper characterization of the groundwater is necessary to meet the remediation requirements in Subpart E of 10 CFR 20.

31. Page 2-49. The ratio of Fe-55 to Co-60 is 0.47 and the ratio of Sr-90 to Cs-137 is 0.020. The Fe-55 ratio was based on one measurement and the Sr-90 was based on two measurements. Provide additional information that supports the assumption that these surrogate ratios are representative of the whole site.

Basis: Proper characterization of the soil is necessary for the dose assessment and compliance with decommissioning requirements in Subpart E of 10 CFR 20.

32. There appear to be several gaps in the Historical Site Assessment (HSA) time line(65-72, 78-81, 82-84, 89-91, 91-93). Confirm that no events significant to decommissioning of the site occurred during these gaps.

Basis: An unbroken historical site assessment is necessary for the dose assessment and compliance with decommissioning requirements in Subpart E of 10 CFR 20.

33. Page 2-114. The DCGL and concentration for Mn-54 was used in the calculations for number of data points required for the survey. No values for Mn-54 were reported in the results for Survey Unit 5(1). However, Am-241 was reported in the survey results on page 2-118. The DCGL and concentration of Am-241 were not used in the calculations for number of data points required for the survey. Provide a revised report for Survey Unit 5(1).

Basis: Proper characterization is necessary for the dose assessment and compliance with decommissioning requirements in Subpart E of 10 CFR 20.

34. The proposed evaluation of tritium in soil during final status surveys discussed in ¤5.2.1.3 does not provide sufficient detail to enable the reviewer to independently evaluate the approach. The reviewer recognizes that at this stage in the project, all required information may not be available. Therefore, the licensee should provide additional, specific information for demonstrating compliance with the tritium DCGLs in soil. Conversely, the LTP could propose that the general approach be contingent upon the results of an NRC in-process inspection once the licensee formalizes the plan.

Basis: Proper characterization of the soil is necessary for the dose assessment and compliance with decommissioning requirements in Subpart E of 10 CFR 20.

35. Section 5.3.6.3, Page 5-22: Item no. 2 states that Co-60 would provide the most limiting conditions for variable ratio survey areas and the impacts on required scan MDCs and investigation levels. However, the area factors table (Table 5-6, Page 5-21) shows that Eu-155 is the most limiting for areas less than 1012 m 2 . Additional information should be provided to support the statement in Item no. 2.

Basis: This information is necessary to determine if the survey method for excavated soil is adequate to meet decommissioning requirements in Subpart E of 10 CFR 20.

36. Page 5-25. For small excavations, a combination of laboratory analysis and scans will be performed to characterize excavated soil. Provide a detailed explanation of the methodology that will be used for surveys of soils from small excavations. For large excavation areas, provide information on the type of containers (material, wall thickness, volume), survey instrument MDC, and survey method to be used to survey excavated soils. The LTP states that other methods may be used to survey excavated soils. Confirm that, for methods that are not in the LTP, NRC will be given the opportunity to review the new methods before being implemented at BRP.

Basis: This information is necessary to determine if the survey method for excavated soil is adequate to meet decommissioning requirements in Subpart E of 10 CFR 20.

37. Page 5-27. The LTP states that alternate instruments or technologies may be used in the FSS program. Confirm that NRC will be given the opportunity to review the technical basis evaluation before the use of alternate instruments or technologies.

Basis: Review prior to use ensures NRC that new procedures and equipment will perform as stated in the LTP.

38. Page 5-29, 5.4.3.5. This section provides the detection sensitivity for NaI detector. Provide the type of survey meter that will be used with the NaI detector.

Basis: This information is necessary to determine if the survey equipment is adequate to meet decommissioning requirements in Subpart E of 10 CFR 20.

39. Page 5-34. The LTP states that if a survey unit fails additional samples will be taken to show compliance. Discuss the impacts on the remediation process if a survey unit fails. Describe how additional samples will be taken to include whether a new survey with a greater number samples will be performed or will additional samples be taken and added to the original survey. If additional samples will be added to the original survey, provide a detailed description of the procedures for double sampling including the effect of double sampling on the Type I and Type II errors.

Basis: Double sampling affects the Type I and Type II error rates. This information is necessary to determine if the survey is adequate to meet decommissioning requirements in Subpart E of 10 CFR 20.