ML073400098

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IR 05000390-08-002 & 05000391-08-002, on 02/11-15/2008 & 02/25-29/2008, Watts Bar Baseline Occupational Radiation Safety Inspection
ML073400098
Person / Time
Site: Watts Bar  Tennessee Valley Authority icon.png
Issue date: 12/03/2007
From: Brian Bonser
NRC/RGN-II/DRS/PSB2
To: Campbell W
Tennessee Valley Authority
References
IR-08-002
Download: ML073400098 (11)


See also: IR 05000390/2008002

Text

December 3, 2007

Tennessee Valley Authority

ATTN: Mr. William R. Campbell

Chief Nuclear Officer and

Executive Vice President

6A Lookout Place

1101 Market Street

Chattanooga, TN 37402-2801

SUBJECT:

NRC INSPECTION REPORT NO. 50-390/2008002 AND 50-391/2008002

Dear Mr. Campbell:

On February 11-15 and February 25-29, 2008, the NRC will perform the baseline Occupational

Radiation Safety Inspection at the Watts Bar Nuclear Plant (NRC Inspection Procedures

71121.01, 71121.02, and 71122.02 and the radiation safety section of 71151). Experience has

shown that this inspection is resource intensive both for the NRC inspectors and your staff. In

order to minimize the impact to your on-site resources and to ensure a productive inspection,

we have enclosed a request for documents needed for this inspection.

It is important that all of these documents are up to date and complete, in order to minimize the

number of additional documents requested during the preparation and/or the onsite portions of

the inspection. The lead inspector has scheduled a two-day pre-inspection visit with your staff

for January 14-16, 2008. The material requested will be reviewed and collected at that time.

We have discussed the schedule for these inspection activities with your staff and understand

that our regulatory contact for this inspection will be Jerry Bushnell of your organization. If

there are any questions about this inspection or the material requested, please contact the lead

inspector, Heather Gepford, at (404) 562-4659, or the Plant Support Branch 1 Chief, Brian

Bonser, at (404) 562-4653.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and

its enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRC's document system

(ADAMS).

TVA

2

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/ reading-rm/adams.html

(the Public Electronic Reading Room).

Should you have any questions concerning this letter, please contact us.

Sincerely,

/RA/

Brian R. Bonser, Chief

Plant Support Branch 2

Division of Reactor Safety

Docket Nos. 50-390, 50-391

License No. NPF-90 and Construction

Permit No. CPPR-92

Enclosure: Pre-Inspection Document Request

cc: See Page 3

TVA

3

cc w/encl:

Gordon P. Arent

New Generation Licensing Manager

Tennessee Valley Authority

5A Lookout Place

1101 Market Street

Chattanooga, TN 37402-2801

Ashok S. Bhatnagar

Senior Vice President

Nuclear Generation Development

and Construction

Tennessee Valley Authority

Electronic Mail Distribution

James R. Douet

Vice President, Nuclear Support

Tennessee Valley Authority

Electronic Mail Distribution

H. Rick Rogers, Vice President

Nuclear Engineering & Technical Services

Tennessee Valley Authority

3R Lookout Place

1101 Market Street

Chattanooga, TN 37402-2801

Michael D. Skaggs

Site Vice President

Watts Bar Nuclear Plant

Tennessee Valley Authority

Electronic Mail Distribution

General Counsel

Tennessee Valley Authority

Electronic Mail Distribution

John C. Fornicola, General Manager

Nuclear Assurance

Tennessee Valley Authority

Electronic Mail Distribution

Larry E. Nicholson, General Manager

Performance Improvement

Tennessee Valley Authority

4X Blue Ridge

1101 Market Street

Chattanooga, TN 37402-2801

Beth A. Wetzel, Manager

Corporate Nuclear Licensing and

Industry Affairs

Tennessee Valley Authority

Electronic Mail Distribution

Michael K. Brandon, Manager

Licensing and Industry Affairs

Watts Bar Nuclear Plant

Tennessee Valley Authority

P. O. Box 2000

Spring City, TN 37381

Michael J. Lorek, Plant Manager

Watts Bar Nuclear Plant

Tennessee Valley Authority

Electronic Mail Distribution

County Executive

Rhea County Courthouse

375 Church Street, Suite 215

Dayton, TN 37321

County Mayor

P.O. Box 156

Decatur, TN 37322

Lawrence E. Nanney, Director

TN Dept. of Environment & Conservation

Division of Radiological Health

Electronic Mail Distribution

TVA

4

Masoud Bajestani

Vice President

Watts Bar Unit 2

Watts Bar Nuclear Plant

Tennessee Valley Authority

P.O. Box 2000

Spring City, TN 37381

Ann Harris

341 Swing Loop

Rockwood, TN 37854

James H. Bassham, Director

Tennessee Emergency Management Agency

Electronic Mail Distribution

_________________________

OFFICE

RII:DRS

RII:DRS

RII:DRS

RII:DRS

SIGNATURE

/RA/

/RA/

NAME

B. Bonser

H. Gepford

DATE

12/3/2007

11/30/2007

E-MAIL COPY?

YES

NO YES

NO YES

NO YES

NO YES

NO YES

NO YES

NO

Enclosure

Pre-Inspection Document Request

Occupational Radiation Safety Cornerstone

L i c e n s e e:

Watts Bar Nuclear Plant

Docket Numbers:

50-390, 391

Inspection Dates:

February 11-15 and February 25-29, 2008

Inspection Procedures to be performed:

71121.01

Access Controls to Radiologically Significant Areas

71121.02

ALARA Planning and Controls

71122.01

Radioactive Gases and Liquid Effluent Treatment & Monitoring Systems [limited

scope, Sections 02.01(e), 2.02 (d & e)]

71122.02

Radioactive Material Processing and Transportation

71151

Performance Indicator Verification

The most recent inspection completed for the listed inspection procedures was performed on June

21-25, 2007. Unless otherwise specified, documentation is requested from the date of the

previous inspection to the present.

We would prefer as much of the information as possible in electronic form. An index to the CD

contents is also helpful. For those items requesting a list of documents/areas, the inspectors will

select documents/areas from the list for on-site review. If any of the requested information is too

burdensome to provide electronically or as hard copies during the bagman trip, simply indicate that

the requested material is available for onsite review by the inspectors.

If you have any questions, please call Heather Gepford at 404-562-4659. Thank you in advance

for all your effort in putting together this material.

Assistance Requested During Bagman Trip

G

Introductions to, and discussions with, licensee personnel who will be assisting with the

inspection

G

Plant familiarization tour

Assistance Requested During On-Site Inspection

G

Identification of work activities during the inspection for inspector observations, including

notification of pre-job briefings, notification of diving activities, audio/visual surveillance for

remote job coverage.

G

Health physics assistance in plant walk-downs assessing access controls, e.g. verifying the

posting and locking of entrances to HDR-HRA and VHRA, and spent fuel pool controls.

G

Health physics assistance in plant walk-downs/job coverage of ongoing outage activities to

assess access controls and ALARA practices.

2

Enclosure

G

Discussions with appropriate individuals regarding access controls and ALARA planning.

G

Schedule of transportation shipments during the inspection and notification of opportunities

for observations of shipment preparation/receipt; discussions with appropriate individuals

regarding the transportation program.

General Information Request

G

Telephone numbers of contacts

G

Plant and Radiation Protection organizational charts, including personnel involved in solid

radwaste processing and transportation of radwaste/radioactive materials.

G

Electronic copy of applicable chapters of UFSAR (e.g. radiation protection program, liquid

and solid radioactive waste program, etc.)

G

Outage schedule, including work activities to be conducted during the week(s) of the

inspection

G

List of active radiation work permits, including those specific to outage activities, with their

administrative limits, electronic dosimeter dose rate limit, and dose limit.

G

List of radiation protection procedures

G

Corrective Action Program procedures

G

Procedure(s) for identifying, notification, tracking, and correcting PI occurrences.

G

List of all Performance Indicators (PIs) and copies of associated corrective action reports

for Occupational Exposure Control Effectiveness and RETS/ODCM Radiological Effluent

Occurrences

G

Audits and self-assessments performed since the last inspection that encompass the areas

of (1) access controls, (2) the ALARA program and implementation, (3) liquid and solid

radwaste processing, and (4) transportation of radioactive material/radwaste.

71122.01 Radioactive Gases and Liquid Effluent Treatment & Monitoring Systems

G

Procedures for onsite/offsite surface/groundwater monitoring activities and leak detection

G

Summary of spill, leak, or unexpected liquid discharge data documented in the sites

10 CFR 50.75(g) files. Note: Only provide summary, 50.75(g) file details may be reviewed

during onsite inspection

G

List of PERs issued since June 2006 for tritium or other radioisotopes in ground water

wells, or identification of spills or leaks from contaminated systems, structures, and

components.

G

Audits and self assessments conducted since June 2006 for groundwater monitoring.

3

Enclosure

G

Annual Effluent/REMP Reports for CY 2006: focus on surface and groundwater

monitoring.

71121.01 Access Controls to Radiologically Significant Areas

G

Site and corporate procedures associated with the access control program. Procedures

should include:

<

Radiological surveys, postings, and radiation control barricades

<

Security and control of high radiation sources/objects stored in pools

<

Radiation Work Permits

<

Radiological Job-Coverage

<

Controlling access to High Radiation Areas (HRAs), High Dose Rate High Radiation

Areas (HDR-HRAs), and Very High Radiation Areas (VHRAs)

<

Key controls for all high radiation areas

<

Radioactive material control, including contamination and hot particles

<

Dosimetry monitoring (electronic dosimeters, multi-badging, etc.)

<

Calculations of internal exposures

G

List of the 10 most exposure significant work areas within radiation areas, high radiation

areas (<1R/hr), or airborne radioactivity areas in the plant. This may include areas with low

dose rates but high collective dose. Identify any high radiation areas with significant dose

gradients (factor of five or more), including underwater diving activities.

G

RWPs for the top five dose rate areas or tasks.

G

Plant/elevation maps of all HRAs, LHRAs, HDR-HRAs (>25 rem in one hour @ 30 cm), and

VHRAs. Include areas with the potential to become a HRA during routine operations or

outages.

G

Internal dose assessments, including calculations, for any internal exposures greater that

50 mrem CEDE since the last inspection.

G

List of PERs generated since the last inspection related to access controls, including the

following:

<

Access controls, including high radiation area radiological incidents

<

Radiological events caused by radiation worker errors

<

Radiological events caused by radiation protection technician errors

71121.02: ALARA Planning and Controls

G

Site and corporate procedures associated with maintaining site dose ALARA, including

those involving ALARA work activities. These procedures should include:

<

ALARA program implementation, including ALARA committee activities and ALARA

planning, briefing, and reviews

<

Radiation work permit preparation and worker compliance

4

Enclosure

<

Processes used to estimate and track work activity specific exposures

<

Making changes to dose estimates during task performance

<

Work controls

<

Engineering controls

<

Exposure mitigation requirements

G

ALARA documents related to current outage:

<

List approximately 10-15 work activities planned during the inspection likely to result

in the highest personnel collective exposures and those which present the greatest

radiological risk to workers (e.g. work in HRAs, diving, potentially changing

radiological conditions). Include the dose projections and ALARA package

numbers.

<

ALARA planning packages for the five highest dose jobs being performed during

the outage

<

Temporary shielding requests generated for the outage.

G

ALARA documents related to previous outage:

<

Completed ALARA packages (including post-job reviews) for the five work activities

that were completed during the last outage which had the greatest collective dose

and/or presented significant radiological risk.

<

List of five activities (including ALARA package number) from the previous outage

in which the work scope changed or was extended and alternative ALARA

measures were taken to respond to the emergent conditions.

<

List of five activities from the previous outage in which the estimated work hours

were significantly different than the actual hours expended.

<

List of five activities in which the estimated and actual hours expended were

accurate.

G

Documents related to the ALARA planning process:

<

Annual ALARA goals for 2006-2008, previous/current outage ALARA goals, and the

methodology utilized to make the projections.

<

Most recent annual ALARA report and most recent refueling outage report.

<

ALARA Committee activity summaries (e.g. meeting minutes) for three months or 3

meetings after the last refueling outage and the three months or 3 meetings prior to

the upcoming refueling outage.

G

Outline of the source term reduction strategy. Information should include:

<

Historic trends and current status of plant source term

<

Factors that affect the source term

<

Activities employed to reduce the source term

<

Specific sources identified for reduction actions

<

Source term reduction evaluation

<

Results achieved since last inspection

G

Records for declared pregnant workers since the last inspection, listing their monthly

radiation exposure during the term or year-to-date.

5

Enclosure

G

List of PERs generated since the last inspection related to the ALARA program, including

the following:

<

ALARA planning

<

Post-job review identified problems

<

Radiation worker practices

<

Occurrences where the collective exposure was greater than intended dose

determined to be ALARA for the individual work activities

71122.02 Radioactive Material Processing and Transportation

G

Site and corporate procedures/manuals describing licensee compliance with 10 CFR Parts 20, 61, and 71 and 49 CFR Parts 170-189. Procedures/manuals should include:

<

Solid and liquid radwaste processing procedures

<

Procedure(s) for transferring radioactive waste resin and sludge discharges into

shipping/disposal containers.

<

Waste stream mixing and/or sampling procedures, including (1) waste

concentration averaging, (2) use of scaling factors and calculations used to account

for difficult-to-measure radionuclides, and (3) ensuring waste stream composition

data accounts for changing operational parameters

<

Shipping/transportation procedures

<

Cask loading and closure procedures (licensee and vendor) applicable to last three

cask transports

G

Process Control Program (PCP).

G

Most recent Annual Radioactive Effluents Release Report.

G

Most recent radio-chemical sample analysis results (i.e., 10 CFR Part 61" analysis) for

each of the radioactive waste streams (e.g., dry active waste (DAW), ion exchange resins,

mechanical filters, and sludges and activated materials, etc.).

G

List and documentation of any changes made to the radioactive waste processing systems

(liquid and solid) and/or the PCP since the last inspection and associated 10 CFR 50.59

documentation, as appropriate.

G

Copies of applicable transport cask Certificate of Compliance for the last three transport

cask shipments.

G

Training and qualification records for personnel responsible for radioactive waste

processing and radioactive material shipment preparation activities.

G

Copy of the Radioactive Shipping Log for the last 12 months. (The inspector will select

transportation shipping packages for review during the inspection.)

G

List of PERs generated since the last inspection involving radioactive waste and radioactive

material/waste transportation.

6

Enclosure

G

Available for onsite review during the inspection:

<

Site drawing(s) showing the location of all stored radioactive materials and all

stored radioactive waste.

<

Plant drawings sufficient to permit the inspector to walk-down the liquid and solid

radioactive waste processing systems to verify current system

configuration/operation agree with the descriptions contained in the UFSAR and

in the PCP.

<

Documentation describing the status of any radioactive waste process

equipment that is not operational and/or is abandoned in place.

<

Information concerning the sites waste disposal volume and waste reduction

program.

<

Training curriculum and primary lesson plans for qualifying persons, including

vendors, for radwaste processing, packaging, and making shipments of

radioactive materials and radioactive waste as specified by 49 CFR 172.

71151 Performance Indicator Verification

G

List of all PERs since January 2007 using keywords: HRA, LHRA, VHRA, unintended dose,

unlocked door, offsite dose, ODCM, etc.

G

Monthly PI reports since January 2007.

G

List of all dose rate alarms > 1 R/hr and all dose alarms since January 2007.

G

All final release point effluent monitor out-of-service dates since January 2007.

G

Most recent gaseous and liquid effluent release permits.

Lead Inspector Contact Information:

Heather Gepford, Ph.D., CHP

(404) 562-4659

hjg1@nrc.gov

Mailing Address

US NRC Region II

ATTN: Adam Nielsen

61 Forsyth Street, SW

Suite 23T85

Atlanta, GA 30303-3415