ML090400425

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Notification of Inspection and Request for Information
ML090400425
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 02/09/2009
From: Brian Bonser
NRC/RGN-II/DRS/PSB1
To: Burton C
Carolina Power & Light Co
References
Download: ML090400425 (10)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II SAM NUNN ATLANTA FEDERAL CENTER 61 FORSYTH STREET, SW, SUITE 23T85 ATLANTA, GEORGIA 30303-8931 February 9, 2009 Mr. Christopher L. Burton Vice President Carolina Power & Light Company Shearon Harris Nuclear Plant P.O. Box 165, Mail Zone 1 New Hill, NC 27562-0165

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT, NOTIFICATION OF INSPECTION AND REQUEST FOR INFORMATION

Dear Mr. Burton:

During the periods of April 20 - 24 and April 27 - May 1, 2009, the NRC will perform the baseline Occupational Radiation Safety Inspection at the Shearon Harris Nuclear Power Plant, (NRC Inspection Procedures 71121.01, 71121.02, 71122.02, and Radiation Safety Sections of 71151). Experience has shown that this inspection is resource intensive for both 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 material requested for this inspection is requested by March 30, 2009 We have discussed the schedule for these inspection activities with your staff and understand that our regulatory contact for this inspection will be Michael Wallace of your organization. If there are any questions about this inspection or the material requested, please contact the lead inspector, Wade T. Loo at (404) 562-4727.

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.)

CP&L 2

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/ reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Brian R. Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket No. 50-400 License No. NPF-63

Enclosure:

Occupational Radiation Protection Inspection Document Request (cc: w/encl - See Page 3)

CP&L 3

cc w/encl:

Brian C. McCabe Manager Nuclear Regulatory Affairs Progress Energy Electronic Mail Distribution Paul Fulford Manager Performance Evaluation and Regulatory Affairs PEB5 Carolina Power & Light Company Electronic Mail Distribution R. J. Duncan, II Vice President Nuclear Operations Carolina Power & Light Company Electronic Mail Distribution J. Wayne Guganious Training Manager Harris Progress Energy Carolinas, Inc.

Electronic Mail Distribution Kimberly Harshaw Manager Support Services Progress Energy Carolinas, Inc.

Electronic Mail Distribution David H. Corlett Supervisor Licensing/Regulatory Programs Carolina Power & Light Company Electronic Mail Distribution David T. Conley Associate General Counsel Legal Dept.

Progress Energy Service Company, LLC Electronic Mail Distribution John H. O'Neill, Jr.

Shaw, Pittman, Potts & Trowbridge 2300 N. Street, NW Washington, DC 20037-1128 Beverly O. Hall Chief, Radiation Protection Section Department of Environmental Health N.C. Department of Environmental Commerce & Natural Resources Electronic Mail Distribution Public Service Commission State of South Carolina P.O. Box 11649 Columbia, SC 29211 Chairman North Carolina Utilities Commission Electronic Mail Distribution Robert P. Gruber Executive Director Public Staff - NCUC 4326 Mail Service Center Raleigh, NC 27699-4326 Herb Council Chair Board of County Commissioners of Wake County P.O. Box 550 Raleigh, NC 27602 Tommy Emerson Chair Board of County Commissioners of Chatham County 186 Emerson Road Siler City, NC 27344 Kelvin Henderson Plant General Manager Carolina Power and Light Company Shearon Harris Nuclear Power Plant Electronic Mail Distribution Senior Resident Inspector Carolina Power and Light Company Shearon Harris Nuclear Power Plant U.S. NRC 5421 Shearon Harris Rd New Hill, NC 27562-9998

OFFICE RII:DRS RII:DRS SIGNATURE

/RA/

/RA/

NAME WLoo BBonser DATE 2/9/2009 2/9/2009 2/ /2009 2/ /2009 2/ /2009 2/ /2009 2/ /2009 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 Licensee:

Harris Nuclear Plant Docket Number:

50-400 Inspection Dates:

April 20 - 24 and April 27 - May 1, 2009 Inspection Procedures to be performed:

71121.01 Access Controls to Radiologically Significant Areas (08/25 - 08/29/08) 71121.02 ALARA Planning and Controls (04/10 - 04/14 and 04/24 - 04/28/06) 71122.02 Radioactive Material Processing and Transportation (04/10 - 04/14 and 04/24 -

04/28/06) 71151 Performance Indicator Verification (08/25 - 08/29/08)

The most recent inspection completed for the listed inspection procedures were performed on is listed to the right of the inspection procedure title in brackets. Documentation is requested from May 1, 2006 to the present for all items pertaining to ALARA Planning and Controls and Radioactive Materials Processing and Transportation. All other documentation is requested from September 1, 2008 to present.

We would prefer as much of the information as possible in electronic form (Information on CD as discussed with M. Wallace). 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 Wade Loo at 404-562-4727. Thank you in advance for all your effort in putting together this material.

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.

G Assistance in plant walk-downs of the solid and liquid radwaste processing systems.

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.

2 Enclosure 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.

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 List of 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.

3 Enclosure G

List of internal dose assessments, including calculations, for any internal exposures greater that 50 mrem CEDE since September 1, 2008.

G List of corrective action reports generated since September 1, 2008, 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 error G

Available for onsite review during inspection:

Elevation maps with most recent operating and outage radiation survey levels.

RWPs for the top five dose rate areas or tasks 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 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

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

G Annual ALARA goals for 2007, and 2008 and the methodology utilized to make the projections.

G Historic trends and current status of plant source term.

G 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.

G 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.

4 Enclosure G

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.

G List of five activities (including ALARA package number if applicable) 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.

G List of five activities from the previous outage in which the estimated work hours were significantly different than the actual hours expended. List five activities in which the estimated and actual hours expended were accurate.

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

List of activities since that last inspection that were reviewed for ALARA problems and actions taken to prevent recurrence. Include corrective action report number(s) if applicable.

G List of corrective action reports generated since May 1, 2006, 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 G

Available for onsite review during the inspection:

ALARA planning packages for jobs being performed during the Outage Temporary shielding requests generated for the outage.

Records of personnel monitored for radiation exposure that show the total TEDE to date for each person. If possible, sort individuals by work group. Records for declared pregnant workers since the last inspection, listing their monthly radiation exposure during the term or year-to-date

5 Enclosure 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 Last two years Annual Radioactive Effluents Release Reports.

G Last two years 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 associate 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 two years. (The inspector will select transportation shipping packages for review during the inspection.)

G List of corrective action reports generated since the last inspection involving radioactive waste and radioactive material/waste transportation.

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

6 Enclosure 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.