ML112860294
| ML112860294 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 10/12/2011 |
| From: | Brian Bonser NRC/RGN-II/DRS/PSB1 |
| To: | Franke J Crystal River, FL |
| References | |
| Download: ML112860294 (9) | |
See also: IR 05000302/2011005
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
245 PEACHTREE CENTER AVENUE NE, SUITE 1200
ATLANTA, GEORGIA 30303-1257
October 12, 2011
Mr. Jon A. Franke
Vice President, Crystal River Nuclear Plant
Crystal River Nuclear Plant (NA2C)
15760 W. Power Line Street
Crystal River, FL 34428-6708
SUBJECT: CRYSTAL RIVER UNIT 3 - NOTIFICATION OF INSPECTION AND REQUEST
FOR INFORMATION
Dear Mr. Franke:
During the period of November 14 - 18, 2011, the NRC will conduct baseline radiation safety
inspection activities at the Crystal River 3 Nuclear Plant. The inspection will focus on both the
Occupational and Public Radiation Safety Inspection cornerstones using NRC Inspection
Procedure (IP) 71124.01, IP 71124.02, 71124.03, IP 71124.04, and IP 71124.05. The
inspection also will evaluate Occupational and Public Cornerstone Radiation Safety sections of
IP 71151 associated with Performance Indicator (PI) 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 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 November 4, 2011, 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. Dennis Herrin of your
organization. If there are any questions about this inspection or the material requested, please
contact the lead inspector, Ruben Hamilton at (404) 997-4672.
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
FPC 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. 50-302
License Nos. DPR-72
Enclosure:
Radiation Protection Inspection Document Request
cc: w/encl.: (See page 3)
ML112860294 X SUNSI REVIEW COMPLETE X FORM 665 ATTACHED
OFFICE DRS/PSB1 DRS/PSB1
NAME G. KUZO B. BONSER
DATE 10/12/2011 10/12/2011
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO
FPC 3
cc w/encl:
Kelvin Henderson Daniel R. Westcott
General Manager Supervisor
Nuclear Fleet Operations Licensing & Regulatory Programs
Progress Energy Crystal River Nuclear Plant (NA1B)
Electronic Mail Distribution Electronic Mail Distribution
Brian C. McCabe Joseph W. Donahue
Manager, Nuclear Oversight Vice President
Shearon Harris Nuclear Power Plant Nuclear Oversight
Progress Energy Progress Energy
Electronic Mail Distribution Electronic Mail Distribution
Terry D. Hobbs Jack E. Huegel
(Acting) Plant General Manager Manager, Nuclear Oversight
Crystal River Nuclear Plant (NA2C) Crystal River Nuclear Plant
Electronic Mail Distribution Electronic Mail Distribution
Stephen J. Cahill David T. Conley
Director - Engineering Nuclear Senior Counsel
Crystal River Nuclear Plant (NA2C) Legal Department
Electronic Mail Distribution Progress Energy
Electronic Mail Distribution
R. Alexander Glenn
General Counsel Mark Rigsby
Progress Energy Manager, Support Services - Nuclear
Electronic Mail Distribution Crystal River Nuclear Plant (NA2C)
Electronic Mail Distribution
Jeffrey R. Swartz
Director Site Operations Senior Resident Inspector
Crystal River Nuclear Plant U.S. Nuclear Regulatory Commission
Electronic Mail Distribution Crystal River Nuclear Generating Plant
U.S. NRC
Donna B. Alexander 6745 N Tallahassee Rd
Manager, Nuclear Regulatory Affairs Crystal River, FL 34428
(interim)
Progress Energy Attorney General
Electronic Mail Distribution Department of Legal Affairs
The Capitol PL-01
Thomas Sapporito Tallahassee, FL 32399-1050
Consulting Associate
(Public Correspondence Only) Bryan Koon, Director
Post Office Box 8413 Florida Division of Emergency Management
Jupiter, FL 33468 Electronic Mail Distribution
William A. Passetti Chairman
Chief Board of County Commissioners
Florida Bureau of Radiation Control Citrus County
Department of Health 110 N. Apopka Avenue
Electronic Mail Distribution Inverness, FL 36250
PUBLIC RADIATION PROTECTION INSPECTION
DOCUMENT REQUEST
SITE: Crystal River Unit 3 (CR3) Report Number: 05000302/2011005
INSPECTION DATES: November 14 - 18, 2011
NRC INSPECTORS: Ruben Hamilton, Ruben.Hamilton@NRC.GOV (404) 997-4672
George B. Kuzo, George.Kuzo@NRC.GOV (404) 997-4658
Robert Kellner Robert.Kellner@NRC.GOV (404) 997-4508
William Pursley William.Pursley@NRC.GOV (404) 997-4517
PRELIMINARY LICENSEE CONTACTS: Radiation Controls - Bryan Akins, (352) 464-4964[C]/
Kevin Hirsch, (352) 464-7261[C]; ALARA - Kenny Young , (352) 464-7462[C]; Transportation &
Radioactive Waste Processing, Randy Macko, (352) 795-6486 ext. 3610; Instrumentation -
Keith Shelton - (352) 464-7972 [C]; Counting Room Rudy Pinner (352) 795-6486 ext. 3141; and
Licensing - D. Herrin, (352) 563-4633.
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
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. 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.
GENERAL INFORMATION NEEDED
Organization Charts and Contact Phone Numbers for:
Radiation Protection
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 Radiation
Protection.
Current Part 61 Analysis Results for Dry Active Waste (DAW).
Schedule of major maintenance / operational activities during onsite inspection (Gantt chart
if available).
Enclosure
2
RADIOLOGICAL HAZARD ASSESSMENT AND EXPOSURE CONTROL [71124.01]
Provide Procedures/Guidance Documents for:
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.
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.
contamination control, i.e., procedures for release of contaminated individuals or
potentially contaminated materials from the radiologically controlled area (RCA).
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 on-going outage activities
since October 1, 2010.
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 October 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 onsite inspection]
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 include
any reviews/evaluations conducted of vendor facilities, e.g., corporate or outside vendor and/
or corporate calibration facilities.
Provide a list of CR documents generated since October 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/ or
(2) were completed during the current extended outage since October 1, 2010. The
Enclosure
3
inspectors will select activities from the list for review of ALARA work activity evaluations,
exposure estimates, and exposure mitigation requirements.
Historical trends and current status of plant source changes resulting from plant fuel
performance issues or chemical lay-up during the extended outage.
Audits and self-assessments performed of the ALARA program, including the previous
outages ALARA reviews/summaries.
List of CAP condition reports generated since October 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:
Maintenance, inspection, and use of respiratory protection equipment including self-
contained breathing apparatus (SCBA).
Use of installed plant systems including containment purge, spent fuel pool ventilation,
and auxiliary building ventilation.
Use of temporary ventilation systems (e.g. HEPA/charcoal NPUs, tents, etc.).
List recent activities in which respiratory protection equipment was used.
Provide air testing data (i.e. Grade D certification) for supplied-air devices and SCBA bottles
since October 1, 2009.
List of CAP condition reports generated since October 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.
OCCUPATIONAL DOSE ASSESSMENT [71124.04]
Provide Procedures/Guidance Documents for:
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.
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 October 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 onsite inspection].
List of all personnel contamination events, dispersed contamination/discrete particles,
identified since October 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 onsite inspection]
Enclosure
4
List of declared 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 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 Condition Report (CR) documents generated since October 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]
Procedures/Guidance Documents for:
use of portable instrument calibrators (e.g. Shepherd calibrator).
calibration and functional test/source checks of portable radiation detection.
instrumentation calibration and functional tests of small article monitor (SAM), personnel
contamination monitor (PCM), portal monitor (PM), whole body counting (WBC)
equipment; and in-plant air monitoring equipment.
determination of set-points for Area Radiation Monitor (ARM), Air Monitoring, PCM, PM
and SAM equipment.
collection and analysis of high-range, post accident effluent samples.
QA program for count room instruments.
The last 2 calibration records for the following monitors:
RM-G14 . Fuel Storage Building
RM-G30 . Containment High Range Area Radiation Monitor
RM-A8 Auxiliary Building Exhaust
RM-A11.. Waste Gas Decay Tank Monitor
RM-L2. Plant Liquid Discharge Line
Personnel contamination and tool monitors at RCA exit point; and PM at Protected Area
exit (One to two monitors of each type will be selected and the records reviewed during
the onsite inspection)
Count room high-purity Germanium Detector and Liquid Scintillation Counter (Specific
equipment and/or geometries will be selected during the onsite inspection).
Certificates for the sources used to calibrate the above requested monitors showing
traceability to a national standard (NIST), as applicable.
The last 2 test records of the portable instrument calibrator (Shepherd validation testing), if
applicable.
Copies of all audits, self-assessments, and/or reviews of area and personnel monitoring
equipment and portable radiation survey instruments generated since October 1, 2009. The
records should include any reviews conducted of vendor facilities, e.g., outside calibration
laboratories, as applicable.
List of CRs generated since October 2009, related to portable instruments, effluent and area
monitors, CAMs, RCA release point monitors, WBCs, and count room instruments. This
should be a summary list of corrective action documents containing a CR number and brief
description, not full CRs.
Enclosure
5
PERFORMANCE INDICTOR VERIFICATION [71151]
Procedure/Guidance for collection and reporting of PI data.
Provide the following records:
CRs related to occupational and public radiation safety PI occurrences issued since
October 1, 2010.
Monthly/Quarterly Occupation and Public Radiation Safety PI reports since October 1,
2010.
List of Out of Service (OOS) Effluent Monitors and Length of Inoperability since October 1,
2010. [Note these data are part of the data requested under Inspection Procedure
7112405 above and do not 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).
Enclosure