ML103210596
| ML103210596 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 11/15/2010 |
| From: | Brian Bonser NRC/RGN-II/DRS/PSB1 |
| To: | Nazar M Florida Power & Light Co |
| References | |
| Download: ML103210596 (9) | |
See also: IR 05000335/2020010
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
245 PEACHTREE CENTER AVENUE NE, SUITE 1200
ATLANTA, GEORGIA 30303-1257
November 15, 2010
Mr. Mano Nazar
Executive Vice President and Chief Nuclear Officer
Florida Power & Light Company
P.O. Box 14000
Juno Beach, FL 33408-0420
SUBJECT:
PLANT ST. LUCIE - NOTIFICATION OF INSPECTION AND REQUEST FOR
INFORMATION 05000335/2010 AND 05000389/2010
Dear Mr. Nazar:
During the periods of January 10 - 14, 2011 and February 7 - 11, 2011, the NRC will perform the
baseline Occupational and Public Radiation Safety Inspection at the St. Lucie Nuclear Power Station,
(NRC Inspection Procedures 71124.01, 71124.02, 71124.03, 71124.04, 71124.05, Radiation Safety
Sections of 71151, and TI 2515/179). 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. We request that the documents on the enclosed list be provided in the form of computer
readable optical media such as a CD or available for review on a shared drive.
We have discussed the schedule for these inspection activities with your staff and understand that our
regulatory contact for this inspection will be Don Cecchett and Christopher Martin of your organization
with the material available for review by December 17, 2010. If there are any questions about this
inspection or the material requested, please contact the lead inspector, Wade T. Loo at (404) 997-
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). 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
Dockets Nos.: 50-335, 50-389,
License Nos.: DPR-67 and NPF-16
Enclosure: Occupational Radiation Protection Inspection Document Request
cc w/encl.: See page 2
2
cc w/encl:
Richard L. Anderson
Site Vice President
St. Lucie Nuclear Plant
Electronic Mail Distribution
Robert J. Hughes
Plant General Manager
St. Lucie Nuclear Plant
Electronic Mail Distribution
Gene St. Pierre
Vice President, Fleet Support
Florida Power & Light Company
Electronic Mail Distribution
Ronnie Lingle
Operations Manager
St. Lucie Nuclear Plant
Electronic Mail Distribution
Eric Katzman
Licensing Manager
St. Lucie Nuclear Plant
Electronic Mail Distribution
Director
Licensing
Florida Power & Light Company
Electronic Mail Distribution
Alison Brown
Nuclear Licensing
Florida Power & Light Company
Electronic Mail Distribution
Mitch S. Ross
Vice President and Associate General
Counsel
Florida Power & Light Company
Electronic Mail Distribution
Marjan Mashhadi
Senior Attorney
Florida Power & Light Company
Electronic Mail Distribution
William A. Passetti
Chief
Florida Bureau of Radiation Control
Department of Health
Electronic Mail Distribution
Ruben D. Almaguer
Director
Division of Emergency Preparedness
Department of Community Affairs
Electronic Mail Distribution
J. Kammel
Radiological Emergency Planning
Administrator
Department of Public Safety
Electronic Mail Distribution
Mano Nazar
Executive Vice President and Chief Nuclear
Officer
Florida Power & Light Company
P. O. Box 14000
Juno Beach, FL 33408
Senior Resident Inspector
St. Lucie Nuclear Plant
U.S. Nuclear Regulatory Commission
P.O. Box 6090
Jensen Beach, FL 34957-2010
Seth B. Duston
Training Manager
St. Lucie Nuclear Plant
Electronic Mail Distribution
Faye Outlaw
County Administrator
St. Lucie County
Electronic Mail Distribution
Jack Southard
Director
Public Safety Department
St. Lucie County
Electronic Mail Distribution
_________________________
X SUNSI REVIEW COMPLETE
OFFICE
RII: DRS
RII: DRS
SIGNATURE
NAME
W. LOO
B. BONSER
DATE
11/15/2010
11/15/2010
E-MAIL COPY?
YES
NO YES
NO YES
NO YES
NO YES
NO YES
NO YES
NO
Enclosure
Pre-Inspection Document Request
Occupational and Public Radiation Safety Cornerstone
Licensee:
St. Lucie Nuclear Plant
Docket Numbers:
50-335, 50-389
Inspection Dates:
January 10 - 14, 2011 and February 7 - 11, 2011
Inspection Procedures to be performed:
Radiological Hazard Assessment and Exposure Controls
Occupational ALARA Planning and Controls
In-Plant Airborne Radioactivity Control and Mitigation
Occupational Dose Assessment
Radiation Monitoring Instrumentation
71151
Performance Indicator Verification
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)
Documentation is requested from May, 2009, to the present for all items.
We would prefer as much of the information as possible in electronic form. An index to the CD
or shared drive 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, simply
indicate that the requested material is available for onsite review by the inspectors.
If you have any questions, please call Wade Loo at 404-997-4727. Thank you in advance for all
your effort in putting together this material.
Assistance Requested During On-Site Inspection
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.
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.
Health physics assistance in plant walk-downs/job coverage of ongoing outage activities to
assess access controls and ALARA practices.
Discussions with appropriate individuals regarding access controls and ALARA planning.
General Information Request
Telephone numbers of contacts.
Plant and Radiation Protection organizational charts, including personnel involved in solid
radwaste processing and transportation of radwaste/radioactive materials.
Electronic copy of applicable chapters of UFSAR (e.g. radiation protection program, liquid
Enclosure
and solid radioactive waste program, etc.).
Outage schedule, including work activities to be conducted during the week(s) of the
inspection.
List of active radiation work permits, including those specific to outage activities, with their
administrative limits, electronic dosimeter dose rate limit, and dose limit.
List of radiation protection procedures.
Corrective Action Program procedures.
Procedure(s) for identifying, notification, tracking, and correcting PI occurrences.
List of all Performance Indicators (PIs) and copies of associated corrective action reports for
Occupational Exposure Control Effectiveness and RETS/ODCM Radiological Effluent
Occurrences.
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.
Procedures associated with the ISFSI facility. Procedures should include:
o Radiological surveys, postings, and radiation control barricades
o Environmental monitoring (including TLDs)
o Loading of casks
o Routine activities
Radiation surveys of the ISFSI since the last inspection.
ALARA reviews and planning and associated RWPs for cask loading activities.
Environmental monitoring results (e.g. TLDs).
Radiological records for the loading of casks since the last inspection.
Records of contamination incidents since the last inspection.
List of corrective action reports related to the ISFSI with respect to radiation protection (i.e.
access controls, ALARA, contamination, radiation levels, etc.) since the last inspection.
71124.01: Radiological Hazard Assessment and Exposure Controls
Site and corporate procedures associated with the access control program. Procedures
should include:
o Radiological surveys, postings, and radiation control barricades
o Security and control of high radiation sources/objects stored in pools
o Radiation Work Permits
o Radiological Job-Coverage
o Controlling access to High Radiation Areas (HRAs), High Dose Rate High Radiation
Areas (HDR-HRAs), and Very High Radiation Areas (VHRAs)
o Key controls for all high radiation areas
o Radioactive material control, including contamination and hot particles
Enclosure
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.
List of LHRAs, HDR-HRAs (>25 rem in one hour @ 30 cm), and VHRAs. Include areas with
the potential to become a LHRA during routine operations or outages.
List of corrective action reports generated since the last inspection related to access
controls, including the following:
o Access controls, including high radiation area radiological incidents
o Radiological events caused by radiation worker errors
o Radiological events caused by radiation protection technician errors
Available for onsite review during inspection:
o Elevation maps with most recent operating and outage radiation survey levels.
o RWPs for the top five dose rate areas or tasks.
71124.02: ALARA Planning and Controls
Site and corporate procedures associated with maintaining site dose ALARA, including
those involving ALARA work activities. These procedures should include:
o ALARA program implementation, including ALARA committee activities and ALARA
planning, briefing, and reviews
o Radiation work permit preparation and worker compliance
o Processes used to estimate and track work activity specific exposures
o Making changes to dose estimates during task performance
o Work controls
o Engineering controls
o Exposure mitigation requirements
Most recent annual ALARA report and most recent refueling outage report.
Annual ALARA goals for 2010, and 2011, and the methodology utilized to make the
projections.
Historic trends and current status of plant source term.
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 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.
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
Enclosure
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 five activities in which the
estimated and actual hours expended were accurate.
Outline of the source term reduction strategy. Information should include:
o Historic trends and current status of plant source term
o Factors that affect the source term
o Activities employed to reduce the source term
o Specific sources identified for reduction actions
o Source term reduction evaluation
o Results achieved since last inspection
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.
List of corrective action reports generated since the last inspection related to the ALARA
program, including the following:
o ALARA planning
o Post-job review identified problems
o Radiation worker practices
o Occurrences where the collective exposure was greater than intended dose
determined to be ALARA for the individual work activities
Available for onsite review during the inspection:
o ALARA planning packages for jobs being performed during the outage
o Temporary shielding requests generated for the outage.
o Records of personnel monitored for radiation exposure that show the total TEDE to
date for each person. If possible, sort individuals by work group.
71124.03: In-Plant Airborne Radioactivity Control and Mitigation
Site and corporate procedures/manuals associated with airborne radiation monitoring
instrumentation and respiratory protection. Procedures/manuals should include:
o Operation, calibration, and maintenance of air sampling instrumentation, including
set-point determination (e.g., low-vols, high vols, goosenecks, AMS 4s, etc.)
o Calibration and maintenance of portable instruments
o Actions to be taken when air sampling instrumentation is found to be significantly out
of tolerance/calibration
o Issuance and use of respiratory protective equipment (emphasis on SCBA and air-
supplied equipment)
o Training, including fit-testing, for use of SCBA and supplied-air systems
Enclosure
o SCBA maintenance activities, including vital components (i.e. regulators)
o Determination/verification of Grade D air for SCBA
Two most recent calibrations for the following CAM equipment:
o Control Room Ventilation
o Spent Fuel Pool
o Radioactive Waste Processing
Records of certification of air quality for equipment used to provide breathing air for air-
supplied respirators and SCBA bottles since the last inspection.
List of corrective action reports generated since the last inspection involving radiation
monitoring and protective equipment deficiencies, including the following:
o Continuous air monitors
o Respiratory protection equipment and program implementation
Available for onsite review by inspector during inspection:
o Inventory, inspection, and maintenance records for SCBA equipment
o Training records, including fit-testing, for SCBA-qualified individuals
o Training records/certification for individuals qualified to perform maintenance on vital
components (e.g. regulators) on SCBA
71124.04: Occupational Dose Assessment
1.
Site and corporate procedures associated with dosimetry operations. Procedures should
include:
a. Issuance/use of external dosimetry (routine, multibadging, extremity, neutron, declared
pregnant workers, assigning dose of record, etc.)
b. For non-NVLAP accredited passive dosimeters, procedures for calibration, application
of calibration factors, zeroing, etc.
c. Calibration and use of electronic dosimeters, including, if applicable, use of a
correction factor to address response of ED with respect to TLD
d. Assessment of internal dose (operation of whole body counter, assignment of dose
based on DAC-hours, urinalysis, etc.)
e. Evaluation of, and dose assessment for, radiological incidents (e.g. distributed
contamination, hot particles, loss of dosimetry, etc.)
2.
Most recent NVLAP accreditation report.
3.
List of the types of dosimetry used, e.g. TLD, OSL, bubble dosimeter, electronic
dosimeter, by manufacturer and, if applicable, model number M.
4.
List of any internal dose assessments exceeding 10 mrem CEDE and any skin dose
assessments performed since May, 2009.
5.
List of CAP condition reports generated since May, 2009, related to internal and external
dosimetry, dose assessment, etc.
Enclosure
71124.05: Radiation Monitoring Instrumentation
Site and corporate procedures associated with radiation detection and monitoring
instrumentation. Procedures should include:
o Portable radiation survey instrument calibrations and source checks
o Electronic dosimeter calibration and use
o Whole body counter, personnel contamination monitor, portal monitor, and small
article monitor calibrations and source checks
o Area radiation monitor alarm setpoint values and setpoint bases, calibration, and
source checks
o Effluent monitor alarm setpoint bases and calculational methods
o Collecting and analyzing high-range, post-accident iodine effluent samples
o Maintenance and calibration/certification of calibration sources/ranges
List of in-service survey instrumentation including air samplers, small article monitors,
personnel contamination monitors, portal monitors, whole body counters, neutron monitoring
instrumentation, etc.
Technical Specifications related to post-accident monitoring instrumentation, effluent
monitoring, and emergency assessment.
Most recent channel calibration and functional test for the effluent/process monitors, post-
accident monitoring instruments, and area radiation monitors.
Whole body counter calibration reports since May, 2009, calibration/check source
information, and WBC analysis library.
List of CAP condition reports generated since May, 2009, related to radiation monitoring
instrumentation, including the following:
o Radiation survey instruments/calibrations
o Radiation Monitoring System, including effluent monitors, process monitors, and area
radiation monitors
o Chemistry count lab, including cross-check analysis and QC
o Whole body counter, PCMs, PMs, and SAMs
71151: Performance Indicator (PI) Verification
Monthly PI reports since September, 2010, and copies of associated condition reports for
any RETS/ODCM Radiological Effluent occurrences.
Liquid and gaseous effluent release permits which specify the monthly, quarterly, and
annual curies released by isotope and associated public dose assessments since
September, 2010.
List of all corrective action documents since September, 2010, using keywords such as:
HRA, LHRA, VHRA, unintended dose, unlocked door, etc.
List of all electronic dosimeter (ED) dose rate alarms > 1 R/hr and all ED dose alarms since
September, 2010.