ML092290729
| ML092290729 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 08/17/2009 |
| From: | Brian Bonser NRC/RGN-II/DRS/PSB1 |
| To: | Baxter D Duke Energy Carolinas |
| References | |
| Download: ML092290729 (9) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II SAM NUNN ATLANTA FEDERAL CENTER 61 FORSYTH STREET, SW, SUITE 23T85 ATLANTA, GEORGIA 30303-8931 August 17, 2009 Mr. David A. Baxter Site Vice President Duke Energy Carolinas, LLC Oconee Nuclear Station 7800 Rochester Highway Seneca, SC 29672
SUBJECT:
OCONEE NUCLEAR STATION - NOTIFICATION OF INSPECTION AND REQUEST FOR INFORMATION
Dear Mr. Baxter:
From October 13 - 16 and October 26 - 30, 2009, the NRC will perform baseline Public and Occupational Radiation Safety inspections at the Oconee Nuclear Station, (NRC Inspection Procedures 71121.01, Access Controls to Radiologically Significant Areas; 71121.02, ALARA Planning and Controls; 71122.02, Radioactive Material Processing and Transportation; and Radiation Safety Sections of 71151, Performance Indicator Verification). 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.
We have discussed the schedule for these inspection activities with your staff and understand that our regulatory contact for this inspection will be Judy Smith (864-885-4309) of your organization. Our inspection dates are subject to change based on your updated schedule of outage activities. If there are any questions about this inspection or the material requested, please contact the lead inspector Wade T. Loo at (404) 562-4727 (wade.loo@nrc.gov).
DEC 2
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). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/HJG RA for/
Brian R Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket Nos.: 50-269, 270, 287 License Nos.: DPR-38, 47, 55
Enclosure:
Pre-Inspection Document Request cc w/encl.: (See page 3)
X SUNSI REVIEW COMPLETE OFFICE RII:DRS RII:DRS RII:DRP SIGNATURE WTL /RA/
BRB /RA/
JHB /RA/
NAME WLoo BBonser JBartley DATE 08/17/2009 08/17/2009 08/17/2009 E-MAIL COPY?
YES NO YES NO YES NO YES NO YES NO YES NO YES NO
DEC 3
cc w/encl:
Robert Meixell Regulatory Compliance Manager Oconee Nuclear Station Duke Energy Carolinas, LLC Electronic Mail Distribution Scott L. Batson Engineering Manager Oconee Nuclear Station Duke Energy Carolinas, LLC Electronic Mail Distribution Clark E. Curry Mechanical and Civil Engineering Manager Oconee Nuclear Station Duke Energy Carolinas, LLC Electronic Mail Distribution Philip J. Culbertson Oconee Nuclear Station Duke Energy Carolinas, LLC Electronic Mail Distribution Preston Gillespie Manager Oconee Nuclear Station Duke Energy Carolinas, LLC Electronic Mail Distribution R. L. Gill, Jr.
Manager Nuclear Regulatory Issues & Industry Affairs Duke Energy Carolinas, LLC Electronic Mail Distribution Dhiaa M. Jamil Group Executive and Chief Nuclear Officer Duke Energy Carolinas, LLC Electronic Mail Distribution County Supervisor of Oconee County 415 S. Pine Street Walhalla, SC 29691-2145 Lisa F. Vaughn Associate General Counsel Duke Energy Corporation 526 South Church Street-EC07H Charlotte, NC 28202 Kathryn B. Nolan Senior Counsel Duke Energy Corporation 526 South Church Street-EC07H Charlotte, NC 28202 Charles Brinkman Director Washington Operations Westinghouse Electric Company Electronic Mail Distribution David A. Repka Winston Strawn LLP Electronic Mail Distribution R. Mike Gandy Division of Radioactive Waste Mgmt.
S.C. Department of Health and Environmental Control Electronic Mail Distribution Susan E. Jenkins Director, Division of Waste Management Bureau of Land and Waste Management S.C. Department of Health and Environmental Control Electronic Mail Distribution Beverly O. Hall Chief, Radiation Protection Section Department of Environmental Health N.C. Department of Environmental Commerce & Natural Resources Electronic Mail Distribution
DEC 4
Letter to David A. Baxter from Brian Bonser dated August 17, 2009
SUBJECT:
OCONEE NUCLEAR STATION - NOTIFICATION OF INSPECTION AND REQUEST FOR INFORMATION Distribution w/encl:
C. Evans, RII L. Slack, RII OE Mail RIDSNRRDIRS PUBLIC RidsNrrPMOconee Resource
Enclosure Pre-Inspection Document Request Licensee:
Oconee Nuclear Power Station Docket Numbers:
050-000269, 270 and 287 Inspection Dates:
10/13 - 10/16/09 and 10/26 - 10/30/09 Inspection Procedures to be performed:
71121.01 Access Controls to Radiologically Significant Areas 71121.02 ALARA Planning and Controls 71122.02 Radioactive Material Processing and Transportation 71151 Performance Indicator Verification (Radiation Safety Sections)
The most recent inspection completed for Access Controls & Performance Indicator Verification was performed 07/14 - 07/18/08. The most recent inspection for ALARA & Radioactive Material Processing & Transportation was performed 6/02-06/08. 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 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 Required During On-Site Inspection G
Introductions to, and discussions with, licensee personnel who will be assisting with the inspection G
Plant familiarization tour G
Health physics assistance in walk-down of ISFSI 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 waste processing systems.
G Discussions with appropriate individuals regarding access controls and ALARA planning.
G Assistance with observations of shipment preparation/receipt, and discussions with appropriate individuals regarding the transportation program.
G Other activities to complete the inspection procedure.
2 Enclosure General Information Request G
Telephone numbers of contacts G
Plant and Radiation Protection organization charts G
Site map, showing location of site buildings 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 Electronic copy of UFSAR G
List of radiation protection procedures G
Corrective Action Program procedures G
List of all Performance Indicators (PIs) and copies of associated corrective action reports for Occupational Exposure Control Effectiveness (TS HRA, VHRA, and unintended exposure occurrences) and RETS/ODCM Radiological Effluent Occurrences (unmonitored releases, unplanned releases, or releases in which any dose limit or administrative dose limit was exceeded).
G Procedure(s) for identifying, notification, tracking, and correcting PI occurrences 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 Monitoring transuranics 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 Contamination and hot particle control 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.
G List of HRAs, LHRAs, HDR-HRAs (>25 rem in one hour @ 30 cm), and VHRAs.
G List of high radiation work areas with significant dose rate gradients (factor of 5 or more) or any underwater diving activities.
G List of areas with the potential to become a HRA during routine operations or outages.
G Elevation maps with most recent operating radiation survey levels.
G Elevation maps with most recent outage radiation survey levels.
G RWPs for the top five dose rate areas or tasks.
G Any procedural changes affecting HDR-HRA and VHRA controls
3 Enclosure G
Licensee Event Reports, Special Reports, audits, and self assessments related to the access control program performed since the last inspection and any associated corrective action reports.
G List of corrective action reports related to access controls.
G List of corrective action reports documenting radiation worker and/or radiation protection technician errors associated with radiation protection program implementation.
G Internal dose assessments, including calculations, for any internal exposures greater that 50 mrem CEDE since the last inspection.
G GET documentation on radiation worker response to electronic dosimeter dose and dose rate alarms.
G Plant policy (methodology) for electronic pocket dosimeter alarm set-point determination process.
G Procedures associated with the ISFSI facility. Procedures should include:
Radiological surveys, postings, and radiation control barricades Environmental monitoring (including TLDs)
Loading of casks Routine activities G
Radiation surveys of the ISFSI from July 2008 to present G
ALARA reviews and planning and associated RWPs G
Environmental monitoring results (e.g. TLDs)
G Radiological records for the loading of casks since July 2008 G
Records of contamination incidents since July 2008 G
List of corrective action reports related to the ISFSI with respect to radiation protection (i.e. access controls, ALARA, contamination, radiation levels, etc.) since July 2008 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 ALARA committee activities ALARA planning, briefing, and reviews Radiation work permit preparation Radiation work permit compliance (by workers)
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, 2008 and 2009 and the methodology utilized to make the projections.
G Site collective dose totals and 3-year averages for the last three years.
G Site specific trends in collective exposure and source-term measurements.
G List of the 5-10 work activities planned during the inspection likely to result in the highest personnel collective exposures. Include the dose projections.
G List of the jobs-in-progress during the inspection with work activities which present the greatest radiological risk to workers (e.g. work in HRAs, diving, potentially changing radiological conditions).
4 Enclosure G
Temporary shielding requests generated for the outage.
G List of six techniques integrated into work activities that result in significant collective dose reductions during outages and/or routine operations.
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.
G Licensee Event Reports, Special Reports, audits, and self assessments related to the ALARA program performed since the last inspection, and any associated corrective action reports.
G List of corrective action reports related to the ALARA program and radiation worker practices since the last inspection. Include occurrences where the collective exposure was greater than intended dose determined to be ALARA for the individual work activities.
G Outline of the interfaces between operations, radiation protection, maintenance, maintenance planning, scheduling, and engineering groups with respect to the ALARA program and ALARA planning.
G Outline of the source term reduction strategy. Specific information should include:
Historic trends and current status of plant source term Factors that effect the source term Activities employed to reduce the source term Source term reduction evaluation Results achieved since last inspection 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 in the past 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 List of five events where the work scope changed or was extended and alternative ALARA measures were taken to respond to the unexpected conditions.
G List of activities since that last inspection that were reviewed for ALARA problems and actions taken to prevent recurrence.
G Identify the system(s) utilized to track and trend collective dose, providing sufficient detail to assess the ability of the system to detect and control work activity specific trends.
G Records of personnel monitored for radiation exposure that show the total TEDE to-date for each person. Include the workers dose limit if available.
G Records for declared pregnant workers in the last 12 months, listing their monthly radiation exposure during the term or year-to-date.
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.
5 Enclosure Waste stream mixing and/or sampling procedures Shipping/transportation procedures Cask loading and closure procedures (licensee and vendor) applicable to last three cask transports G
Most recent Annual Radioactive Effluents Release Report.
G Site drawing(s) showing the location of all stored radioactive materials and all stored radioactive waste.
G 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 FSAR and in the PCP.
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 Documentation describing the status of any radioactive waste process equipment that is not operational and/or is abandoned in place.
G Process and methodology for waste concentration averaging.
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 Procedures/documentation for the use of scaling factors and calculations used to account for difficult-to-measure radionuclides.
G Procedures/documentation to ensure waste stream composition data accounts for changing operational parameters.
G Information concerning the sites waste disposal volume and waste reduction program.
G Copies of applicable transport cask Certificate of Compliance for the last three transport cask shipments.
G Organizational chart or list of personnel involved in solid radwaste processing and transportation (e.g. preparing shipments) of radioactive waste/materials.
G Training and qualification records for personnel responsible for radioactive waste processing and radioactive material shipment preparation activities.
G 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 subpart H.
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 Schedule of transportation shipments during the refueling outage.
G List of corrective action reports involving radioactive waste and radioactive material/
waste transportation.
G Licensee Event Reports, Special Reports, audits, and self assessments related to the radioactive material and transportation programs performed since the last inspection, and any associated corrective action reports