ML12264A033

Notification of Inspection and Request for Information Sequoyah Nuclear Plant

ML12264A033
Person / Time
Site:	Sequoyah
Issue date:	09/14/2012
From:	Brian Bonser NRC/RGN-II/DRS/PSB1
To:	James Shea Tennessee Valley Authority
References
Download: ML12264A033 (10)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 September 14, 2012 Mr. Joseph W. Shea Manager, Corp. Nuclear Licensing Programs Tennessee Valley Authority 1101 Market Street, LP 4B-C Chattanooga, TN 37402-2801

SUBJECT:

NOTIFICATION OF INSPECTION AND REQUEST FOR INFORMATION -

SEQUOYAH NUCLEAR PLANT

Dear Mr. Shea:

On October 22-26, 2012, and November 5-9, 2012, the NRC will perform a baseline Radiation Safety Inspection at Sequoyah Nuclear Plant, (NRC Inspection Procedures 71124.01, 71124.02, 71124.03, 71124.04, 71124.05, and Radiation Safety Sections of 71151).

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 activity. It is important that all of these documents are up to date and complete, thereby minimizing the number of additional documents requested during the preparation and/or the onsite portions of the inspection. The inspector has requested that the subject informational material be provided in CD or DVD format on or before October 8, 2012.

We have discussed the schedule for these inspection activities with your staff and understand that our regulatory contact for this inspection will be Mr. Rusty Proffit 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, or the Plant Support Branch 1 Chief, Brian Bonser, at (404) 997-4653.

This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget under control numbers 3150-0044, 3150-0014, 3150-0011, and 3150-0008. The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Office of Management and Budget control number.

J. Shea 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,

/RA/

Brian R. Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket No. 50-327, 50-328 License No. DPR-77, DPR-79

Enclosure:

Document Request List cc w/encl: (See page 3)

ML12264A033 X SUNSI REVIEW COMPLETE X FORM 665 ATTACHED OFFICE RII: DRS/PSB1 RII: DRS/PSB1 SIGNATURE RA/RH RA/BB NAME R.HAMILTON B. BONSER DATE 09/14/2012 09/14/2012 E-MAIL COPY?

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

J. Shea 3

cc w/encl:

J. T. Carlin Site Vice President Sequoyah Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution P. R. Simmons Plant Manager Sequoyah Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution G. M. Cook Manager Licensing Sequoyah Nuclear Plant Electronic Mail Distribution C. D. Mackaman Tennessee Valley Authority Electronic Mail Distribution Edward J. Vigluicci Assistant General Counsel Tennessee Valley Authority Electronic Mail Distribution County Mayor Hamilton County Hamilton County Courthouse 208 Courthouse 625 Georgia Avenue Chattanooga, TN 37402-2801 Tennessee Department of Environment & Conservation Division of Radiological Health 401 Church Street Nashville, TN 37243 Senior Resident Inspector U.S. Nuclear Regulatory Commission Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, TN 37379-3624 Ann Harris 341 Swing Loop Rockwood, TN 37854

Enclosure Pre-Inspection Document Request Occupational Radiation Safety Cornerstone Licensee:

Sequoyah Nuclear Plant Docket Number(s):

50-327, 50-328 Inspection Dates:

October 22-26, 2012, and November 5-9, 2012 Inspection Procedures:

71124.01 Radiological Hazard Assessment and Exposure Controls 71124.02 Occupational ALARA Planning and Controls 71124.03 In-Plant Airborne Radioactivity Control and Mitigation 71124.04 Occupational Dose Assessment 71124.05 Radiation Monitoring Instrumentation 71151 Performance Indicator Verification Note: Unless specified otherwise, the current version of these documents is expected.

Electronic media is preferred if readily available (The preferred file format is MSWord, 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. To the extent possible, please organize the information in the order shown below. 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.

Documentation for the inspection procedures from October 18, 2010, to the present is requested, unless otherwise identified. We would prefer as much of the information as possible in electronic form, preferably either a CD or DVD. An index to the CD contents is also helpful.

For those items requesting a list of documents/areas, the inspector will select documents/areas from the list for on-site review.

If you have any questions, please call Ruben Hamilton at (404) 997-4672. Thank you in advance for all of your effort in putting together this material.

Assistance Requested During On-Site Inspection Identification of work activities available 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 high and very high radiation areas (HRA and VHRA), and SFP controls Health physics assistance in plant walk-downs/job coverage of ongoing activities to assess access controls Discussions with appropriate individuals regarding access controls

2 General Information Request Plant Management, Radiation Protection, and Chemistry organizational charts w/ contact numbers Telephone numbers and name(s) of site contact(s) for each Inspection Procedure List of active radiation work permits with their administrative limits, electronic dosimeter dose rate limit, and dose limit Electronic copy of relevant UFSAR chapters (e.g., access controls, and radiation protection program)

List of radiation protection procedures that includes title and number Outage schedule, including work activities to be conducted during the week(s) of the inspection Most recent DAW 10 CFR Part 61 analytical results 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 October 18, 2010, that encompass the areas of (1) the ALARA program and implementation, (2) respiratory protection, and (3) airborne radioactivity, monitoring and/or mitigation-engineering controls 71124.01 - Radiological Hazard Assessment and Exposure Controls

1.

List of active Radiation Work Permits (RWPs), including outage RWPs.

2.

Most recent survey of all Locked HRAs and VHRAs (as applicable).

3.

Most recent survey of Independent Spent Fuel Storage Installation (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.

7.

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

8.

All self-assessments and audits covering HP controls since October 18, 2010.

9.

LIST of CRs related to HP controls where the cause was listed as human performance (radworker error) or human performance (HP technician error) issued since January 2011. This should be a list of corrective action documents containing an CR number and brief description, not full CRs.

10.

All CRs related to Nationally Tracked Sources since October 18, 2010.

71124.02 - ALARA Planning and Controls

1.

Site and corporate procedures associated with maintaining site dose ALARA, including those involving ALARA work activities. These procedures should include:

ALARA program implementation, including ALARA committee activities and ALARA planning, briefing, and reviews Radiation work permit preparation and worker compliance Processes used to estimate and track work activity specific exposures Making changes to dose estimates during task performance Work controls Engineering controls

3 Exposure mitigation requirements

2.

Most recent annual ALARA report and most recent refueling outage report.

3.

Annual ALARA goals for 2010, 2011, and 2012, and the methodology utilized to make the projections.

4.

Historic trends and the current status/characterization of plant source term.

5.

ALARA Committee activity summaries (e.g. meeting minutes) for three months or 3 meetings prior to, and after the last refueling outage.

6.

ALARA Committee activity summaries (e.g. meeting minutes) discussing activities associated with the upcoming refueling outage.

7.

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.

8.

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.

9.

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.

10.

Outline of the source term reduction strategy. Information should include:

Historic trends and current status of plant source term Factors that affect the source term Activities employed to reduce the source term Specific sources identified for reduction actions Source term reduction evaluation Results achieved since October 18, 2010

11.

List of activities since October 18, 2010, that were reviewed for ALARA problems and actions taken to prevent recurrence. Include corrective action report number(s) if applicable.

12.

List of corrective action reports generated since October 18, 2010, related to the ALARA program, including the following:

ALARA planning Post-job review identified problems Radiation worker practices Occurrences where the collective exposure was greater than intended dose determined to be ALARA for the individual work activities

4

13.

Available for onsite review during the inspection: (Please do not provide any records which contain personally identifiable information such as social security number and name on the CD)

ALARA planning packages for jobs performed during the outage Temporary shielding requests generated for the outage 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

1.

Site and corporate procedures/manuals associated with airborne radiation monitoring instrumentation and respiratory protection. Procedures/manuals should include:

Operation, calibration, and maintenance of air sampling instrumentation, including set-point determination (e.g., low-vols, high vols, goosenecks, AMS 4s, etc.)

Calibration and maintenance of portable instruments Actions to be taken when air sampling instrumentation is found to be significantly out of tolerance/calibration Issuance and use of respiratory protective equipment (emphasis on SCBA and air-supplied equipment)

Training, including fit-testing, for use of SCBA and supplied-air systems SCBA maintenance activities, including vital components (i.e. regulators)

Determination/verification of Grade D air for SCBA

2.

Two most recent calibrations for the following Continuous Air Monitoring (CAM) equipment:

Control Room Ventilation Spent Fuel Pool Radioactive Waste Processing

3.

Records of certification of air quality for equipment used to provide breathing air for air-supplied respirators and SCBA bottles since October 18, 2010.

4.

List of corrective action reports generated since October 18, 2010 involving radiation monitoring and protective equipment deficiencies, including the following:

Continuous air monitors Respiratory protection equipment and program implementation

5.

Available for onsite review by inspector during inspection:

Inventory, inspection, and maintenance records for SCBA equipment Training records, including fit-testing, for SCBA-qualified individuals Training records/certification for individuals qualified to perform maintenance on vital components (e.g. regulators) on SCBA 71124.04: Occupational Dose Assessment

1.

Provide Procedures/Guidance Documents for external dose monitoring, i.e. dosimetry issuance and use. The documents should include:

5 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

2.

NVLAP accreditation documentation for current dosimetry used by the site.

3.

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 June 1, 2011.

[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, dispersed contamination/discrete particles, identified since June1, 2011. [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.

Copies of all audits, self-assessments, and/or reviews related to internal or external dosimetry issues generated since June 1, 2011. The documents provided should include any reviews/evaluations conducted of vendor facilities, e.g., corporate or outside vendor/ or corporate calibration facilities.

6.

Provide a list of Condition Report (CR) documents generated since June 1, 2011, for Internal or external dosimetry issues/events. [Note: only titles and a summary statement should be provided for use by the inspectors to select a sample of issues for in-depth review].

71124.05 - Radiation Monitoring Instrumentation

1.

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 continuous air monitors (CAMs) determination of set-points for Area Radiation Monitor (ARM), CAM, PCM, PM and SAM equipment collection and analysis of high-range, post accident effluent samples QA program for count room instruments (e.g. laboratory inter-comparison data)

2.

The last 2 calibration records for the following monitors:

0-RE-90-118, Waste gas effluent monitor 0-RE-90-101B, Auxiliary Building Vent 0-RE-90-122, Liquid Waste Disposal

6 0-RE-90-212, Station Sump Discharge Monitor 1-RE-90-99, Condenser Exhaust Radiation Monitor 1-RE-90-106 A, Upper Containment Particulate 1-RE-90-112 B, Lower Containment Noble Gas 1-RE-90-273, Lower Containment High Range

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 calibration records of the portable instrument calibrator (Shepherd validation testing).

5.

List of any Emergency Action Level (EAL) value associated with installed or portable radiation monitoring instrument indication(s).

6.

Copies of all audits, self-assessments, and/or reviews of area and personnel monitoring equipment and portable radiation survey instruments generated since June 1, 2011.

The records should include any reviews conducted of vendor facilities, e.g., outside calibration laboratories, as applicable.

List of CRs generated since June 1, 2011, 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 a CR number and brief description, not full CRs.

71151 - Performance Indicator (PI) Verification

1. Monthly PI reports since June 1, 2011, and copies of associated condition reports for any RETS/ODCM Radiological Effluent occurrences.

2. Liquid and gaseous effluent release permits which specify the monthly, quarterly, and annual curies released by isotope and associated public dose assessments since June 1, 2011.

3. List of all corrective action documents since June 1, 2011, using keywords such as: HRA, LHRA, VHRA, unintended dose, unlocked door, etc.

4. List of all electronic dosimeter (ED) dose rate alarms > 1 R/hr and all ED dose alarms since June 1, 2011.

Inspector Contact Information:

Ruben Hamilton (404) 997-4672 ruben.hamilton@nrc.gov Mailing Address US Nuclear Regulatory Commission, Region II ATTN: Ruben Hamilton 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303