ML102650568

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Notification of Inspection and Request for Information
ML102650568
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 09/22/2010
From: Brian Bonser
NRC/RGN-II/DRS/PSB1
To: Jerrica Johnson
Southern Nuclear Operating Co
References
IR-10-005
Download: ML102650568 (11)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 September 22, 2010 Mr. J. Randy Johnson Vice President - Farley Southern Nuclear Operating Company, Inc.

7388 North State Highway 95 Columbia, AL 36319

SUBJECT:

FARLEY NUCLEAR POWER PLANT - NOTIFICATION OF INSPECTION AND REQUEST FOR INFORMATION

Dear Mr. Johnson:

During the periods of October 18 - 22, 2010, and November 1 - 5, 2010, the NRC will conduct baseline radiation safety inspection activities at the Farley Nuclear Plant. The inspection will focus on the Occupational Radiation Safety Inspection cornerstone using NRC Inspection Procedure (IP) 71124.01, IP 71124.02, IP 71124.03, IP 71124.04, and Temporary Instruction (TI) 2515/179. The inspection also will use IP 71124.05 to evaluate radiation protection instrumentation used within both Occupational and Public Cornerstone areas, and evaluate Occupational and Public Cornerstone Radiation Safety sections of IP 711551.

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 conduct 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 requested that the subject informational material be made available to the NRC staff by October 11, 2010, to allow preparation for the upcoming inspection We have discussed the schedule for these inspection activities with your staff and understand that our regulatory on-site contact for this inspection will be Mr. William Oldfield of your organization. If there are any questions about this inspection or the material requested, please contact the lead inspector, George B. Kuzo at (404) 997-4658.

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

SNC 2

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,

/RA/

Brian R. Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket Nos.

50-348, and 50-364 License Nos. NPF-2 and NPF-8

Enclosure:

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

G SUNSI REVIEW COMPLETE OFFICE RII:DRS RII:DRS SIGNATURE GBK /RA/

BRB /RA/

NAME GKuzo BBonser DATE 09/20/2010 09/21/2010 E-MAIL COPY?

YES NO YES NO YES NO YES NO YES NO YES NO YES NO

SNC 3

cc w/encl:

B. D. McKinney, Jr.

Regulatory Response Manager Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution M. J. Ajluni Nuclear Licensing Director Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution T. D. Honeycutt Regulatory Response Supervisor Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution Todd L. Youngblood Plant Manager Joseph M. Farley Nuclear Plant Electronic Mail Distribution R. D. Baker Licensing Supervisor Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution E. G. Anners Licensing Engineer Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution Jeffrey T. Gasser Chief Nuclear Officer Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution N. J. Stringfellow Licensing Manager Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution L. Mike Stinson Vice President Fleet Operations Support Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution Paula Marino Vice President Engineering Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution Moanica Caston Vice President and General Counsel Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution Chris Clark Commissioner Georgia Department of Natural Resources Electronic Mail Distribution John G. Horn Site Support Manager Joseph M. Farley Nuclear Plant Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution Ted V. Jackson Emergency Response and Radiation Program Manager Environmental Protection Division Georgia Department of Natural Resources Electronic Mail Distribution Tom W. Pelham Performance Improvement Supervisor Joseph M. Farley Nuclear Plant Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution Cynthia A. Sanders Radioactive Materials Program Manager Environmental Protection Division Georgia Department of Natural Resources Electronic Mail Distribution James C. Hardeman Environmental Radiation Program Manager Environmental Protection Division Georgia Department of Natural Resources Electronic Mail Distribution (cc w/encl continued next page)

SNC 4

(cc w/encl continued)

William D. Oldfield Principal Licensing Engineer Joseph M. Farley Nuclear Plant Electronic Mail Distribution Mr. Mark Culver Chairman Houston County Commission P. O. Box 6406 Dothan, AL 36302 James A. Sommerville Program Coordination Branch Chief Environmental Protection Division Georgia Department of Natural Resources Electronic Mail Distribution James L. McNees, CHP Director Office of Radiation Control Alabama Dept. of Public Health P. O. Box 303017 Montgomery, AL 36130-3017 State Health Officer Alabama Dept. of Public Health Electronic Mail Distribution F. Allen Barnes Director Environmental Protection Division Georgia Department of Natural Resources Electronic Mail Distribution

SNC 5

Letter to J. Randy Johnson from Brian Bonser dated September 22, 2010

SUBJECT:

FARLEY NUCLEAR POWER PLANT - NOTIFICATION OF INSPECTION AND REQUEST FOR INFORMATION Distribution w/encl:

C. Evans, RII L. Douglas, RII OE Mail RIDSNRRDIRS PUBLIC RidsNrrPMFarley Resource

Enclosure PUBLIC RADIATION PROTECTION INSPECTION DOCUMENT REQUEST SITE: Farley Nuclear Plant (FNP) Report Number: 05000348, 364/2010005 INSPECTION DATES:

October 18 - 22, 2010 and November 1 - 5, 2010 NRC INSPECTORS:

George B. Kuzo, George.Kuzo@nrc.gov (404) 997-4658 Adam Nielsen, Adam.Nielsen@nrc.gov (404) 997-4660 Carmen Dykes, Carmen.Dykes@nrc.gov (404) 997-4401 PRELIMINARY LICENSEE CONTACTS: R. Vierkandt, Radiation Protection Manager (334) 814-4765), S. Varnum, Chemistry Manager (ext 4619) for Effluents/ Process Monitors, and W.

Oldfield, onsite Licensing/ Compliance (ext 4765)

Inspection Procedures:

IP 71124.01 Radiological Hazard Assessment and Exposure Controls IP 71124.02 Occupational ALARA Planning and Controls IP 71124.03 In-Plant Airborne Radioactivity Control and Mitigation IP 71124.04 Occupational Dose Assessment IP 71124.05 Radiation Monitoring Instrumentation IP 71151 Performance Indicator Verification TI 2515/179 Verification of Licensee Responses to NRC Requirement for Inventories of Materials Tracked in the National Source Tracking System Pursuant to Title 10, Code of Federal Regulations, Part 20.2207 (10 CFR 20.2207)

Note: This is a broad list of the documents the lead NRC inspector will be interested in reviewing and obtaining during the pre-inspection visit. The current version of these documents is expected unless specified otherwise. Electronic media is preferred, if readily available. (The preferred file format is Word, WordPerfect, or searchable.pdf files on electronic media, e.g.

CD-ROM or thumb drive devices. Please provide 3 copies of each electronic device that is submitted.) Information in the document lists should contain enough information to be easily understood by someone who has knowledge of the subject. During the inspection, the inspectors may request additional documents.

Enclosure GENERAL INFORMATION NEEDED Organization Charts and Contact Phone Numbers for:

o Radiation Protection o Chemistry Procedure for issuing Condition Report (CR) documents and assessing issues for risk significance and follow-up actions.

Updated Final Safety Analysis Report Chapter 11, Effluents/Radwaste; and Chapter 12 Radiation Protection Current version/revision of the Offsite Dose Calculation Manual (ODCM)

Annual Radiological Environmental Operating Report (AREOR) for Calendar Year (CY) 08 and CY 09 Annual Radiological Effluent Release Report (ARERR) documents for CY 2008 and CY 2009 Current Part 61 Analysis Results for Dry Active Waste (DAW)

Outage schedule of major activities (Gantt chart if available).

RADIOLOGICAL HAZARD ASSESSMENT AND EXPOSURE CONTROL [71124.01]

Provide Procedures/Guidance Documents for:

o external dose monitoring, i.e., dosimetry issuance and use. The documents should include: guidance for multi-badging; monitoring in steep/highly variable dose rate gradients; high radiation area (HRA), locked-HRA (LHRA) and very high radiation area (VHRA) controls for select operational / outage activities; personnel contamination events; storage/care of personal dosimeters; use of electronic dosimeters including evaluation of set-point determination; biases identified relative to TLD monitoring; remote monitoring procedures; post shutdown, fuel movement, and/or diving operations o internal dose assessment, i.e., both in vivo and in vitro bioassay and air sampling capabilities. The documents should include guidance for calibration/QC and use of whole body counter (WBC); release of contaminated individuals, use of passive monitoring as screening method for evaluations, and special in vitro sample collection and analysis, and suspect alpha particle exposures.

o contamination control, i.e., procedures for release of contaminated individuals or potentially contaminated materials from the radiologically controlled area (RCA) o Posting of areas, labeling of containers, and inventories of non-SNM materials maintained within the spent fuel pools List five highest cumulative exposure or exposure rate tasks for current outage activities.

Provide associated radiation work permit documents, if available List current outage tasks with significant potential for significant release of airborne radioactive particulates List of all positive whole body count (WBC), in vitro, or air sampling analyses since October 1, 2009, which resulted in an assigned CEDE equal to or exceeding 10 millirem [Note, a listing should be provided for use by the inspectors to select a sample of issues for in-depth review during the on-site inspection]

List of all personnel contamination events, dispersed contamination/discrete particles, identified since July 1, 2009. [Note: only a listing should be provided for use by the inspectors to select a sample of issues for in-depth review during the on site inspection]

3 Enclosure Copies of all audits, self-assessments, and/or reviews related to internal or external dosimetry issues generated since October 1, 2009. The documents provided should to include any reviews/evaluations conducted of vendor facilities, e.g., corporate or outside vendor/ or corporate calibration facilities.

Provide a list of CR documents generated since July 1, 2009, for internal or external dosimetry issues/events. [Note: only titles/summary statement should be provide for use by the inspectors to select a sample of issues for in-depth review]

71124.02: OCCUPATIONAL ALARA PLANNING AND CONTROLS Provide site and corporate procedures associated with maintaining occupational exposures ALARA. Include procedural guidance for processes used to estimate and track exposures from specific work activities, method(s) of adjusting exposure estimates or re-planning work when unexpected changes in scope or emergent work are encountered, and performance of post-job reviews.

Documentation of plant collective exposure history, current exposure trends, and ongoing or planned outage activities that present exposure challenges List of work activities ranked by actual or estimated exposure that (1) are in progress and (2) were completed during the previous outage. The inspectors will select activities from the list for review the ALARA work activity evaluations, exposure estimates, and exposure mitigation requirements.

Historical trends and current status of significant tracked plant source changes in plant fuel performance issues or changes in plant primary chemistry Audits and self-assessments performed of the ALARA program, including the previous outages ALARA reviews/summaries.

List of CAP condition reports generated since January 1, 2009, related to ALARA planning and controls.

71124.03: IN-PLANT AIRBORNE RADIOACTIVITY CONTROL AND MITIGATION Provide site and corporate procedures associated with airborne radioactivity control and mitigation. Procedures should include guidance for the following:

o Maintenance, inspection, and use of respiratory protection equipment including self-contained breathing apparatus (SCBA).

o Use of installed plant systems including containment purge, spent fuel pool ventilation, and auxiliary building ventilation.

o Use of temporary ventilation systems (e.g. HEPA/charcoal NPUs, tents, etc.)

List recent activities in which respiratory protection equipment was used (planned outage activities should also be included in the list)

Provide air testing data (i.e. Grade D certification) for supplied-air devices and SCBA bottles since July 1, 2009.

List of CAP condition reports generated since July 1, 2009 related to (1) the control and mitigation of in-plant airborne radioactivity and (2) respiratory protection. Site and corporate procedures associated with maintaining occupational exposures ALARA. Include procedural guidance for processes used to estimate and track exposures from specific work activities, method(s) of adjusting exposure estimates or re-planning work when unexpected changes in scope or emergent work are encountered, and performance of post-job reviews.

4 Enclosure DOSIMETRY [71124.04]

Provide Procedures/Guidance Documents for:

o external dose monitoring, i.e., dosimetry issuance and use. The documents should include: guidance for multi-badging; monitoring in steep/highly variable dose rate gradients; personnel contamination events; storage/care of personal dosimeters; use of electronic dosimeters including evaluation of any biases identified relative to TLD monitoring o internal dose assessment, i.e., both in vivo and in vitro bioassay and air sampling capabilities. The documents should include guidance for calibration/QC and use of whole body counter (WBC); release of contaminated individuals, use of passive monitoring as screening method for evaluations, and special in vitro sample collection and analysis, and actions for declared pregnant workers.

NVLAP accreditation documentation for current dosimetry used by site List of all positive whole body count (WBC), in vitro, or air sampling analyses which resulted in an assigned CEDE equal to or exceeding 10 millirem since July 1, 2009. [Note: only a listing should be provided for use by the inspectors to select a sample of issues for in-depth review during the on site inspection]

List of all personnel contamination events, dispersed contamination/discrete particles, identified since July 1, 2009. [Note: only a listing should be provided for use by the inspectors to select a sample of issues for in-depth review during the on site inspection]

List of declare pregnant workers [Note: do not provide this data - the documents will be reviewed on-site, only have the data readily available during the onsite inspection]

Copies of all audits, self-assessments, and/or reviews related to internal or external dosimetry issues generated since July 1, 2009. The documents provided should to include any reviews/evaluations conducted of vendor facilities, e.g., corporate or outside vendor/or corporate calibration facilities.

Provide a list of Condition Report (CR) documents generated since July 1, 2009, for Internal or external dosimetry issues/events. [Note: only titles/summary statement should be provide for use by the inspectors to select a sample of issues for in-depth review]

RADIATION MONITORING INSTRUMENTATION ) [71124.05]

Copies of the CY 2008 and CY 2009 ARERR documents [Note: provided as part of the General Information Request and duplication is not required]

Provide Procedures/Guidance Documents for:

o use of portable instrument calibrators o calibration and functional test/source checks of portable radiation detection instrumentation o calibration and functional tests of small article monitor (SAM), personnel contamination monitor (PCM), portal monitor (PM), and whole body counting (WBC) equipment; for area radiation monitor (ARM) and continuous air monitor (CAM) equipment.

o determination of set-points for ARM, CAM, PCM, PM and SAM equipment used for area and personnel monitoring equipment, as applicable o collection and analysis of high-range, post accident iodine and effluent samples

5 Enclosure Provide a list of in-service SAM, PCM, PM, and WBC equipment [Note: the list will be used to select 3 to 5 monitors for evaluation of their calibration/functional check surveillances during the onsite inspection. In addition, portable radiation detection instrumentation will be selected at random to evaluate adequacy of calibrations.]

Provide the previous two sets of calibration data for the following effluent monitors: main stack radiation monitor, liquid process radiation monitor, and Unit 1 reactor building ventilation monitor Provide the previous two sets of calibration data for the following monitors: Unit 1 Plant Vent (R-14); U1 Condenser Air Ejector Monitoring System (R15 a, b, c); Unit 1 Liquid Waste Processing System (R-18); U2 Plant Vent Stack Effluent High Range (R29-B), U2 Containment High Range Monitor (R-27B) and U2 Control Room Make-up Air Inlet (R-35)

Copies of all audits, self-assessments, and/or reviews of area and personnel monitoring equipment and portable radiation survey instruments generated since January 1, 2007. The records should include any reviews conducted of vendor facilities, e.g., outside calibration laboratories Provide a list of Condition Report (CR) documents generated since July 1, 2009, for gaseous and liquid effluent monitoring activities, for ARM and/or CAM operability issues, effluent monitoring equipment or monitoring activities; and for the release of licensed material outside of the radiologically controlled area (RCA) [Note: only titles/summary statement should be provide for use by the inspectors to select a sample of issues for in-depth review]

PERFORMANCE INDICTOR VERIFICATION [71151]

Procedure/Guidance for collection and reporting of PI data.

Provide the following records:

o CRs related to occupational and public radiation safety PI occurrences issued since July 1, 2009 o Monthly/Quarterly Occupation and Public Radiation Safety PI reports since July 1, 2009 o List of Out of Service (OOS) Effluent Monitors and Length of Inoperability since July 1, 2009. [Note these data are part of the data requested under Inspection Procedure 7112405 above and do note have to be duplicated]

Procedure for issuing CRs and assessing issues for significance and action.

Updated Final Safety Analysis Report Chapters 11 (Effluents/Radwaste) and 12 (Radiation Protection)

VERIFICATION OF LICENSEE RESPONSES TO NRC REQUIREMENT FOR INVENTORIES OF MATERIALS TRACKED IN THE NATIONAL SOURCE TRACKING SYSTEM PURSUANT TO TITLE 10, CODE OF FEDERAL REGULATIONS, PART 20.2207 (10 CFR 20.2207) [TI 2515/179]

Provide inventory NSTS records of nationally tracked sources, including radionuclide quantities, make, model number and serial number for each Provide records of leak tests and required maintenance, as applicable, for the NSTS listed devices. Records should go back to January 1, 2008, or receipt of subject source(s).

Provide records of any transfer of NSTS devices.