ML111080520

Radiation Protection Inspection - Robinson Nuclear Plant

ML111080520
Person / Time
Site:	Robinson
Issue date:	04/14/2011
From:	Brian Bonser NRC/RGN-II/DRS/PSB1
To:	Duncan R Progress Energy Carolinas
References
Download: ML111080520 (8)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 April 14, 2011 Mr. Robert J. Duncan II Vice President Progress Energy H. B. Robinson Steam Electric Plant, Unit 2 3581 West Entrance Rd Hartsville, SC 29550

SUBJECT:

RADIATION PROTECTION INSPECTION - ROBINSON NUCLEAR PLANT

Dear Mr. Duncan:

On May 16 - 27, 2011, the NRC will perform a baseline Radiation Safety Inspection at Robinson Nuclear Plant, (NRC Inspection Procedures 71124.01, 71124.04, 71124.05, 71124.06, 71124.07, Radiation Safety Sections of 71151, and TI 2515/179). 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 activity. The NRC requests that these documents be provided to the inspectors no later than May 2, 2011.

We have discussed the schedule for these inspection activities with your staff and understand that our regulatory contact for this inspection will be Garrett Sanders of your organization. If there are any questions about this inspection or the material requested, please contact the lead inspector, Adam Nielsen, at (404) 997-4660, or the Plant Support Branch 1 Chief, Brian Bonser, at (404) 997-4653.

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). ADAMS is accessible from the NRC web site at http://www.nrc.gov.

Sincerely,

/ RA /

Brian R. Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket No.: 50-261 License No.: DPR-23

Enclosure:

Document Request List cc w/encl.: (See page 2)

Progress Energy 2

cc w/encl:

Division of Radiological Health TN Dept. of Environment & Conservation 401 Church Street Nashville, TN 37243-1532 Sandra Threatt, Manager Nuclear Response and Emergency Environmental Surveillance Bureau of Land and Waste Management Department of Health and Environmental Control Electronic Mail Distribution Robert J. Duncan II Vice President H.B. Robinson Steam Electric Plant, Unit 2 Progress Energy Electronic Mail Distribution Brian C. McCabe Manager, Nuclear Oversight Shearon Harris Nuclear Power Plant Progress Energy Electronic Mail Distribution John Caves Supervisor, Licensing/Regulatory Programs H. B. Robinson Steam Electric Plant Electronic Mail Distribution Scott D. West Superintendent Security H. B. Robinson Steam Electric Plant Progress Energy Electronic Mail Distribution Joseph W. Donahue Vice President Nuclear Oversight Progress Energy Electronic Mail Distribution David T. Conley Senior Counsel Legal Department Progress Energy Electronic Mail Distribution John H. O'Neill, Jr.

Shaw, Pittman, Potts & Trowbridge 2300 N. Street, NW Washington, DC 20037-1128 Richard Haynes Director, Division of Waste Management Bureau of Land and Waste Management S.C. Department of Health and Environmental Control Electronic Mail Distribution Kelvin Henderson General Manager Nuclear Fleet Operations Progress Energy Electronic Mail Distribution Thomas Cosgrove Plant General Manager H.B. Robinson Steam Electric Plant, Unit 2 Progress Energy Electronic Mail Distribution Donna B. Alexander Manager, Nuclear Regulatory Affairs (interim)

Progress Energy Electronic Mail Distribution Robert P. Gruber Executive Director Public Staff - NCUC 4326 Mail Service Center Raleigh, NC 27699-4326 W. Lee Cox, III Section Chief Radiation Protection Section N.C. Department of Environmental Commerce & Natural Resources Electronic Mail Distribution Greg Kilpatrick Operations Manager H.B. Robinson Steam Electric Plant, Unit 2 Progress Energy Electronic Mail Distribution

Progress Energy 3

Mark Yeager Division of Radioactive Waste Mgmt.

S.C. Department of Health and Environmental Control 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 Henry Curry Training Manager H.B. Robinson Steam Electric Plant, Unit 2 Progress Energy Electronic Mail Distribution Senior Resident Inspector U.S. Nuclear Regulatory Commission H. B. Robinson Steam Electric Plant 2112 Old Camden Rd Hartsville, SC 29550

Mr. Robert J. Duncan II Vice President Progress Energy H. B. Robinson Steam Electric Plant, Unit 2 3581 West Entrance Rd Hartsville, SC 29550

SUBJECT:

RADIATION PROTECTION INSPECTION - ROBINSON NUCLEAR PLANT

Dear Mr. Duncan:

On May 16 - 27, 2011, the NRC will perform a baseline Radiation Safety Inspection at Robinson Nuclear Plant, (NRC Inspection Procedures 71124.01, 71124.04, 71124.05, 71124.06, 71124.07, Radiation Safety Sections of 71151, and TI 2515/179). 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 activity. The NRC requests that these documents be provided to the inspectors no later than May 2, 2011.

We have discussed the schedule for these inspection activities with your staff and understand that our regulatory contact for this inspection will be Garrett Sanders of your organization. If there are any questions about this inspection or the material requested, please contact the lead inspector, Adam Nielsen, at (404) 997-4660, or the Plant Support Branch 1 Chief, Brian Bonser, at (404) 997-4653.

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). ADAMS is accessible from the NRC web site at http://www.nrc.gov.

Sincerely,

/RA/

Brian R. Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket No.: 50-261 License No.: DPR-23

Enclosure:

Document Request List cc w/encl.: (See page 2)

Distribution w/encl:

PUBLIC RidsNrrPMRobinson Resource X PUBLICLY AVAILABLE G NON-PUBLICLY AVAILABLE G SENSITIVE X NON-SENSITIVE ADAMS: X Yes ACCESSION NUMBER: ML111080520 X SUNSI REVIEW COMPLETE OFFICE RII:DRS RII:DRS SIGNATURE RA RA NAME ANIELSEN BBONSER DATE 04/13/2011 04/13/2011 E-MAIL COPY?

YES NO YES NO YES NO YES NO YES NO YES NO YES NO OFFICIAL RECORD COPY DOCUMENT NAME:

G:\\DRSII\\PSB1\\ROBINSON\\ROB_11-03_DOCREQUEST.DOCX

Enclosure Document Request List Inspection Dates:

May 16 - 27, 2011 Inspection Procedures:

IP 71124.01 Radiological Hazard Assessment and Exposure Controls IP 71124.04 Occupational Dose Assessment IP 71124.05 Radiation Monitoring Instrumentation IP 71124.06 Radioactive Gaseous and Liquid Effluent Treatment IP 71124.07 Radiological Environmental Monitoring Program 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: 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 CDROM). Note that the inspectors cannot accept data provided on USB or flash drives due to NRC IT security policies. Please organize the information as it is arranged below to the extent possible. Experience has shown that a poorly organized CD leads to a less efficient inspection and places additional burden on licensee staff. If there are questions regarding the documents requested, please do not hesitate to contact the lead inspector.

General Information Request

1. Plant Management, Radiation Protection, and Chemistry organizational charts w/ contact numbers.

2. Electronic copy of relevant UFSAR chapters (e.g. site description, radwaste program, and radiation protection).

3. Corrective Action Program procedures.

4. Procedures for gathering and reporting NRC Performance Indicator data.

71124.01 - Radiological Hazard Assessment and Exposure Controls

1. List of active RWPs.

2. Latest survey of all Locked HRAs and VHRAs (as applicable).

3. Latest survey of ISFSI areas.

4. Procedures related to HP controls (e.g. Posting, labeling, surveys, RWPs, contamination control, HRA/LHRA/VHRA control, key control, control of divers, special controls during fuel offload, hot spots, etc.).

5. Procedures related to release of personnel and materials (e.g. release surveys, decontamination, guidance for alarm follow up, etc.).

6. List of Nationally Tracked Sources and any change-of-ownership transactions.

2 Enclosure

7. List of all non-fuel items stored in spent fuel pool.

8. All self-assessments and audits covering HP controls since April 2010.

9. LIST of NCRs related to HP controls where the cause was listed as human performance (radworker error) or human performance (HP technician error) issued since April 2010. This should be a list of corrective action documents containing an AR number and brief description, not full NCRs.

10. All NCRs related to Nationally Tracked Sources since January 31, 2009.

71124.04 - Occupational Dose Assessment

1. Procedures related to occupational dose assessment (e.g. external dose monitoring, dosimetry issuance and use, guidance for multi-badging, personnel contamination events, storage/care of personal dosimeters, use of electronic dosimeters, in-vivo and in-vitro internal dose assessment, QC for whole body counter, use of passive monitoring if applicable, declared pregnant workers)

2. NVLAP accreditation documentation for current dosimetry used by site

3. LIST of all positive whole body counts, in vitro, or air sampling analyses which resulted in an assigned CEDE equal to or exceeding 10 millirem since January 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 onsite inspection]

4. List of all personnel contamination events identified since January 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 onsite inspection]

5. All audits and self-assessments of the dosimetry program ( including audits of the lab that processes site dosimetry) since January 2009.

6. LIST of NCRs generated since January 2009, for internal or external dosimetry issues/events. This should be a list of corrective action documents containing an AR number and brief description, not full NCRs.

71124.05 - Radiation Monitoring Instrumentation

1. Procedures/Guidance Documents for:

a) use of portable instrument calibrators (e.g. Shepherd calibrator) b)

calibration and functional test/source checks of portable radiation detection instrumentation c) calibration and functional tests of small article monitor (SAM), personnel contamination monitor (PCM), portal monitor (PM), whole body counting (WBC) equipment; and continuous air monitors (CAMs) d)

determination of set-points for Area Radiation Monitor (ARM), CAM, PCM, PM and SAM equipment e) collection and analysis of high-range, post accident effluent samples f)

QA program for count room instruments

2. The last 2 calibration records for the following monitors:

a)

R-14, Plant Vent, Channels C, D, E b)

R-18, Waste Disposal Liquid Effluent c)

R-21, Fuel Handling Building Upper Level Exhaust Vent d)

R-1, Control Room Area

3 Enclosure e)

R-32, Containment Area, Channels A & B f)

Whole Body Counter in Dosimetry area g)

All SAMs at RCA exit point) i)

All ARGOS at RCA exit point j)

All portal monitors at RCA exit point k)

Count room high-purity Ge detector no. 1 l)

Count room liquid scintillation detector no. 1

3. Certificates for the sources used to calibrate the above requested monitors showing traceability to a national standard (NIST), as applicable

4. The last 2 test records of the portable instrument calibrator (Shepherd validation testing)

5. Copies of all audits, self-assessments, and/or reviews of area and personnel monitoring equipment and portable radiation survey instruments generated since January 2009. The records should include any reviews conducted of vendor facilities, e.g., outside calibration laboratories, as applicable.

6. List of NCRs generated since January 2009, related to portable instruments, effluent and area monitors, CAMs, RCA release point monitors, WBCs, and count room instruments.

This should be a list of corrective action documents containing an AR number and brief description, not full NCRs.

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment

1. 2009 and 2010 Annual Radioactive Effluent Reports.

2. Offsite Dose Calculation Manual (ODCM) and a list of changes made since the last revision

3. Procedures/Guidance Documents for:

a) collection, analysis, release and dose evaluations for gaseous and liquid effluents b) groundwater monitoring program c) determination of rad monitor set-points for main plant gaseous and liquid effluent discharge pathways

4. List of changes made to radioactive effluent processing systems since January 2009.

5. List of any non-radioactive systems that have become contaminated since January 2009.

6. List of any unmonitored, unplanned, or otherwise abnormal gaseous or liquid releases since January 2009.

7. List of 10 CFR 50.75(g) entries made since January 2009.

8. List of liquid and gaseous effluent monitors listed as out-of-service (OOS) since January 2009.

9. Groundwater monitoring results since January 2009.

10. Inter-laboratory comparison program results (for onsite count lab) since January 2009.

11. Results of last 2 filtration system (HEPA/Charcoal) surveillances for gaseous effluent pathways.

12. All audits, self-assessments, and/or reviews of the radioactive effluent monitoring program since January 2009. Include any reviews conducted of vendor activities and their facilities, as applicable.

13. List of NCRs generated since January 2009, as a result of gaseous and liquid effluent processing and/or ODCM related activities. This should be a list of corrective action documents containing an AR number and brief description, not full NCRs.

4 Enclosure 71124.07 - Radiological Environmental Monitoring Program (REMP)

1. 2009 and 2010 Annual Radiological Environmental Operating Reports

2. Procedures/Guidance Documents for:

a) collection and analysis of environmental samples b) calibration and maintenance of REMP air and/or water samplers c) calibration of meteorological monitoring instruments (wind speed & direction, air temperature, etc.)

d) periodic meteorological instrumentation surveillance requirements

3. Calibration records for REMP air and water sampling equipment (as applicable) since January 2009.

4. Last 2 calibration records for each meteorological monitoring instrument on the primary tower (wind speed & direction and air temperature).

5. Inter-laboratory comparison program results (environmental lab) since January 2009.

6. Copies of all audits, self-assessments, and/or reviews of REMP activities. The data should include any reviews conducted of vendor activities and their facilities (e.g. environmental lab).

7. List of systems, structures, or components (SSCs), identified as credible mechanism(s) having the potential for release of licensed material to the groundwater environs

8. List of changes to the REMP (sample locations, sample frequency, type of samples, etc.)

since January 2009.

9. List of NCRs generated as a result of REMP activities since July 2009. This should be a list of corrective action documents containing an AR number and brief description, not full NCRs.