ML13158A027
| ML13158A027 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 06/07/2013 |
| From: | Brian Bonser NRC/RGN-II/DRS/PSB1 |
| To: | Gatlin T South Carolina Electric & Gas Co |
| Linda K. Gruhler 404-997-4633 | |
| References | |
| Download: ML13158A027 (10) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 June 7, 2013 Mr. Thomas D. Gatlin Vice President - Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station P.O. Box 88 Jenkinsville, SC 29065
SUBJECT:
VIRGIL C. SUMMER NUCLEAR STATION - NOTIFICATION OF INSPECTION AND REQUEST FOR INFORMATION
Dear Mr. Gatlin:
During the weeks of August 26 - 30 and September 9 - 13, 2013, the U.S. Nuclear Regulatory Commission (NRC) will perform a baseline Radiation Protection Inspection at the Virgil C.
Summer Nuclear Station, (NRC Inspection Procedures (IP) 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, and 71151 Performance Indicator Verification (Occupational and Public Radiation Safety Cornerstones)).
To minimize the impact to your onsite 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, 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 compact disk (CD) format on or before August 5, 2013.
We have discussed the schedule for these inspection activities with your staff and understand that our regulatory contact for this inspection will be Susan Reese at (803) 345-4591 of your organization. If there are any questions about this inspection or the material requested, please contact the lead inspector Robert Kellner at (404) 997-4508 (robert.kellner@nrc.gov), or the Plant Support Branch 1 Chief, Brian Bonser, at (404) 997-4653.
In accordance with Title 10 of the Code of Federal Regulations (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 component of NRC's Agencywide Documents Access and Management System (ADAMS).
ADAMS is accessible from the NRC web site at http://www.nrc.gov/reading-rm/adams.html.
2 T. Gatlin 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 number 3150-0011, 3150-0014, 3150-0044, and 3150-0135. 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.
Sincerely,
/RA/
Brian Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket No. 50-395 License No. NPF-12
Enclosure:
Pre-Inspection Document Request cc: (See page 3)
2 T. Gatlin 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 number 3150-0011, 3150-0014, 3150-0044, and 3150-0135. 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.
Sincerely,
/RA/
Brian Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket No. 50-395 License No. NPF-12
Enclosure:
Pre-Inspection Document Request cc: (See page 3)
DISTRIBUTION:
C. Evans, RII EICS L. Douglas, RII EICS RIDSNRRDIRS PUBLIC RidsNrrPMSummer Resource X PUBLICLY AVAILABLE NON-PUBLICLY AVAILABLE SENSITIVE X NON-SENSITIVE ADAMS: X Yes ACCESSION NUMBER:
ML13158A027 X SUNSI REVIEW COMPLETE X FORM 665 ATTACHED OFFICE RII:DRS/PSB1 RII:DRS/PSB1 SIGNATURE RXK3 BRB1 NAME R. Kellner B. Bonser DATE 6/ 5 /2013 6/ 6 /2013 E-MAIL COPY YES NO YES NO OFFICIAL RECORD COPY DOCUMENT NAME:
G:\\DRSII\\PSB1\\RFI INFORMATION REQUEST LETTERS\\SUMMER\\SUMMER 2013004 PSB1 RP RFI LETTER.DOCX
3 T. Gatlin cc:
J. B. Archie Senior Vice President Nuclear Operations and Chief Nuclear Officer South Carolina Electric & Gas Company Electronic Mail Distribution George A. Lippard, III General Manager Nuclear Plant Operations South Carolina Electric & Gas Company Electronic Mail Distribution Andy T. Barbee Director Nuclear Training South Carolina Electric & Gas Company Electronic Mail Distribution Wayne D. Stuart (Acting) General Manager Engineering Services South Carolina Electric & Gas Company Electronic Mail Distribution Robin R. Haselden General Manager Organizational Development &
Effectiveness South Carolina Electric & Gas Company Electronic Mail Distribution Shaun M. Zarandi General Manager Nuclear Support Services South Carolina Electric & Gas Company Electronic Mail Distribution Robert L. Justice Manager Nuclear Operations Bruce L. Thompson Manager Nuclear Licensing (Mail Code 830)
South Carolina Electric & Gas Company Electronic Mail Distribution Donna W. Railey Licensing Technician Nuclear Licensing South Carolina Electric & Gas Company Electronic Mail Distribution Susan E. Jenkins SC Department of Health & Environmental Control Bureau of Land and Waste Management Electronic Mail Distribution Sandra Threatt, Manager Nuclear Response and Emergency Environmental Surveillance Bureau of Land and Waste Management Department of Health and Environmental Control Electronic Mail Distribution Kathryn M. Sutton, Esq.
Morgan, Lewis & Bockius LLP Electronic Mail Distribution Division of Radiological Health TN Dept. of Environment & Conservation 401 Church Street Nashville, TN 37243-1532 Senior Resident Inspector Virgil C. Summer Nuclear Station U.S. NRC 576 Stairway Road Jenkinsville, SC 29065 South Carolina Electric & Gas Company Electronic Mail Distribution
Enclosure Pre-Inspection Document Request Occupational and Public Radiation Safety Cornerstones Licensee:
Virgil C. Summer Nuclear Station Docket Number:
50-395 Inspection Dates:
August 26-30 and September 9-13, 2013 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, Occupation Dose Assessment 71124.05, Radiation Monitoring Instrumentation 71151, Performance Indicator Verification Note: 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. An index to the contents is also helpful. For those items requesting a list of documents/areas, the inspectors will select documents/areas from the list for onsite review. If any of the requested information is too burdensome to provide electronically, simply indicate that the requested material is available for onsite review by the inspectors. Experience has shown that a well-organized CD leads to a more efficient inspection and lessens additional burden on licensee staff. During the inspection, the inspectors may request additional documents. If the licensee wishes to use an electronic document service such as CERTRAC or a Shareware portal, the inspectors will try to accommodate for the documentation requested onsite. The initial documents should not require an internet connection to be reviewed.
Documentation is requested from the dates identified in each inspection area, to the present.
For Inspection Procedure (IP) 71151, documentation is requested from September 1, 2012, to present.
If you have any questions, please call Robert Kellner at (404) 997-4508. Thank you in advance for all your effort in putting together this material.
Assistance Requested During Onsite Inspection Identification of work activities available during the inspection for inspector observations, including notification of pre-job briefings.
Health physics assistance in plant walkdowns assessing radiological hazards and exposure controls. (e.g., verifying the posting and locking of entrances to locked-high radiation areas and very high radiation areas, spent fuel pool controls, and radioactive material storage areas.)
Assistance of Health Physics or radiation monitoring system engineer in performing plant walkdowns of effluent, process, and area radiation monitoring systems.
Health physics assistance in scheduling observations of routine source/performance checks of radiation monitoring instruments (portable and installed HP instrumentation)
2 General Information Needed Telephone numbers of contacts for each inspection procedure.
Radiation Protection organizational chart.
Electronic copy of applicable chapters of the Updated Final Safety Analysis Report (UFSAR). (e.g., radiation protection program, ventilation test program, area and process radiation monitors, etc.)
Corrective Action Program (CAP) procedures.
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 July 1, 2011, that encompasses the areas of (1) radiation protection, (2) access controls, (3) ALARA occupational dose assessment, (4) internal dosimetry, (5) external dosimetry, and (6) radiation monitoring instrumentation.
List of radiation protection procedures.
Procedure(s) for identifying, notification, tracking, and correcting PI occurrences.
10 CFR 61.55 analysis results for dry active waste (DAW) and other waste streams.
71124.01 - Radiological Hazard Assessment and Exposure Controls Site 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.)
List of current active RWPs.
Site procedures related to release of personnel and materials. (e.g., release surveys, decontamination, guidance for alarm follow-up, etc.)
List of Nationally Tracked Sources and any change-of-ownership transactions.
Inventory list of all sealed sources stored onsite.
List of all non-fuel items stored in spent fuel pool.
Most recent self-assessment or audit covering hazard assessment and exposure controls.
List of corrective action reports generated since October 2012 related to HP controls.
(e.g., radworker error, HP technician error, posting issues, HRA/LHRA/VHRA issues, survey problems, etc.). This should be a list of corrective action documents containing the corrective action document number and a brief description, not complete documents.
71124.02 - Occupational ALARA Planning and Controls Site 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.
3 o Making changes to dose estimates during task performance.
o Work controls.
o Engineering controls.
o Exposure mitigation requirements.
Annual ALARA goals for 2011, 2012, and 2013, and the methodology utilized to make the projections.
Completed ALARA packages (including post-job reviews) for the five highest collective dose work activities completed during the 2012 refueling outage (including dose estimates, work hour estimates, special HP controls, and dose reduction initiatives), if available.
List of temporary shielding requests generated during the 2012 refueling outage.
List of five activities (including ALARA package number) from the 2012 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 2012 outage in which the estimated work hours were significantly different than the actual hours expended.
List five activities from the 2012 outage in which the estimated and actual hours expended were accurate.
ALARA trending point data for the last two outages.
Annual ALARA Report for 2011 and 2012.
Source term reduction strategic plan, if available.
Minutes from the last four Plant ALARA Committee Meetings.
Post-outage ALARA report for the 2012 refueling outage.
Most recent self-assessment or audit of ALARA program.
List of corrective action reports generated since July 2011 related to ALARA. (e.g.,
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) This should be a list of corrective action documents containing the corrective action document number and a brief description, not complete documents.
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.)
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 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.
4 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.
o SCBA maintenance activities, including vital components. (e.g., regulators) o Determination/verification of Grade D air for SCBA.
Site and corporate procedures/manuals related to airborne monitoring and control (e.g.,
use of containment purge, use of portable HEPA/charcoal units, temporary ventilation enclosures, use of CAMs, air sampling guidance, Alpha air sampling, etc.), as applicable.
Site and corporate procedures/manuals related to the use of respiratory protection devices. (e.g., SCBA, TEDE-ALARA guidance, PAPRs, storage, maintenance, training, QA, fit-testing, etc.)
Records of the last two certifications of air quality for equipment used to provide breathing air for air-supplied respirators and SCBA bottles.
Documentation for last two surveillances performed on SCBA stored for emergency use.
Most recent audit, or self-assessment, covering airborne controls and respiratory protection.
Records of the last two calibrations/tests (charcoal, HEPA DOP, and system flow rate) for the following ventilation systems:
o Control Room Ventilation o Fuel Handling Building Ventilation o Reactor Building Purge Ventilation List of corrective action reports generated since July 2011 related to airborne monitoring and respiratory protection. (e.g., continuous air monitors, respiratory protection equipment, and program implementation, etc.) This should be a list of corrective action documents containing the corrective action document number and a brief description, not complete documents.
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 Site procedures, manuals, and technical documents related to occupational dose assessment. The documents should include guidance for:
o Multi-badging; monitoring in steep/highly variable dose rate gradients.
o 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.
o 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.
5 NVLAP accreditation documentation for the current dosimetry used by the site.
List of all positive whole body counts, in vitro, or air sampling analyses that resulted in an assigned CEDE equal to, or exceeding, 10 millirem since July 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.]
List of all personnel contamination events identified since July 2011. Include full documentation for any PCEs requiring skin dose assessment. [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, however, please include full dose assessment documentation as applicable.]
Most recent audit or self-assessment of the dosimetry program and the most recent audit of the lab that processes site dosimetry.
List of corrective action reports generated since July 2011 for internal or external dosimetry issues/events. This should be a list of corrective action documents containing the corrective action document number and a brief description, not complete documents.
71124.05 - Radiation Monitoring Instrumentation Site procedures/manuals associated with radiation monitoring instrumentation.
Procedures/manuals should include:
o use of portable instrument calibrators (e.g., Shepherd calibrator) 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), whole body counting (WBC) equipment; and continuous air monitors (CAMs) o determination of set-points for Area Radiation Monitor (ARM), CAM, PCM, PM and SAM equipment o collection and analysis of high-range, post-accident effluent samples o QA program for count room instruments (e.g., laboratory inter-comparison data) o Maintenance or surveillance test guidance for the specific process and effluent Radiation Monitors (RM) requested below.
The last two calibration records for the following monitors:
o Containment High Range Radiation Monitors (RM-G7 and RM-G18) o Main Plant Vent Exhaust Monitor (RM-A3) and Associated Sample Line Flow Rate Monitor(s) o Main Plant Vent Exhaust High Range Gas Monitor (RM-A13) o Condenser Exhaust Radiation Monitor (RM-A9) o Liquid Radwaste Effluent Radiation Monitor (RM-L5) o Component Cooling Water Monitors (RM-L2A and RM-L2B) o Reactor Building Purge Exhaust Particulate and Noble gas monitors (RM-A4) o WBC systems in Dosimetry List of the portable instruments currently in service and available for use. Several will be selected for onsite review of the calibration records.
List of the following radiation monitors. Several will be selected for onsite review of the calibration records.
o Portal Monitors used in Dosimetry for Passive Monitoring o SAMs at RCA exit point
6 o Whole Body Contamination Monitors at RCA exit point o Portal Monitors at RCA exit point o Countroom High-purity Germanium Detectors Documentation for the radioactive sources used to calibrate the above requested monitors showing traceability to a national standard (NIST) and traceability to the primary calibration, as applicable.
The last two surveillances performed on the Post-accident Sampling System, as applicable.
Chart or procedure listing EALs for radiation monitoring equipment.
The latest test record of the instrument calibrator (Shepherd validation testing/dose rate curves).
Two most recent system health reports or Maintenance Rule reports for Radiation Monitoring systems (effluent and ARM).
Most recent audit or self-assessment covering HP instruments (portables, RCA exit point, WBC, count room, effluent); include any reviews conducted of vendor facilities, as applicable.
List of corrective action reports generated since July 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 the corrective action document number and a brief description, not complete documents.)
71151 - PI Verification (occupational and public cornerstones)
Site procedures/manuals for gathering and reporting PI data.
Monthly/Quarterly PI reports since September 1, 2012, and copies of associated Condition Report documents for any Occupational Exposure or RETS/ODCM Radiological Effluent PI events occurrences.
Liquid and gaseous effluent release permits that specify the quarterly and annual curies released by isotope, and associated public dose assessments, for the fourth quarter CY 2012, and the most recent permits in 2013.
List of all corrective action reports generated since September 1, 2012, using keywords such as: HRA, LHRA, VHRA, unintended dose, unlocked LHRA door, etc.
List of all corrective action reports generated since September 1, 2012, using keywords abnormal/ unmonitored effluent release, etc.
List of all electronic dosimeter (ED) dose rate alarms and ED dose alarms since September 1, 2012.