ML23082A043

002 Radiation Safety Baseline Inspection Information Request Final

ML23082A043
Person / Time
Site:	Harris
Issue date:	03/23/2023
From:	Bob Kellner NRC/RGN-II
To:	Mcdaniel S Progress Energy Carolinas
References
IR 2023002
Download: ML23082A043 (1)

Text

From: Bob Kellner To: McDaniel, Sarah A

Subject:

NRC Radiation Safety Inspection at Harris - June 2023 Date: Tuesday, March 21, 2023 11:37:00 AM Attachments: Harris 2023-002 Radiation Safety Baseline Inspection Information Request.pdf

Sarah, Thank you for confirming that you will be the point of contact for the upcoming scheduled Radiation Safety Inspection at Harris.

Attached is a list of documents and information requested for the inspection. The request includes a list of the documents we routinely request for Inspection Procedures (IPs) 71124.01, 71124.08, and 71151. If you plan to upload the requested documents to CERTREC, using software to zip the numerous files into a single file prior to upload has proven to be very efficient.

As mentioned previously, the plan is to be onsite the week of June 26 - June 30, 2023.

As of right now, Jack Bell and I will be the inspectors of record coming onsite.

I would appreciate it if you would let me know if Harris has any COVID-19 restrictions in place. If I receive any information on restriction of travel from NRC management, I will you let you know.

Please let me know if you have any questions.

Regards, Bob Robert Kellner Senior Health Physicist USNRC/Region II/DRS/EB3 Marquis One Tower Suite 1200 245 Peachtree Center Ave, NE Atlanta, GA 30303-1257 (404) 997-4508

ML23082A043 Shearon Harris Nuclear Plant RP Radiation Safety Baseline Inspection Initial Information Request Inspection Report: 05000400/2023002 During the week of June 26 - 30, 2023, the U.S. Nuclear Regulatory Commission (NRC) will perform a baseline Radiation Safety Inspection at the Shearon Harris Nuclear Plant (NRC Inspection Procedures 71124.01, 71124.08, and 71151 (Occupational PIV).

To minimize the impact to your onsite resources during the inspection and ensure the inspectors have the necessary information to complete the inspection while on-site, 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 June 12, 2023.

If there are any questions about this inspection or the material requested, please contact the lead inspector, Robert Kellner at 404-997-4508, or the Engineering Branch 3 Chief, Binoy Desai at 404-997-4519.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public inspections, exemptions, requests for withholding: a copy of this document 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); accessible from the NRC Web site at http://www.nrc.gov/readingrm/adams.html..

PAPERWORK REDUCTION ACT STATEMENT This document 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 3150-0008, 3150-0011, 3150-0014, 3150-0044, and 3150-0135.

PUBLIC PROTECTION NOTIFICATION 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.

Document Request List Occupational and Public Radiation Safety Cornerstones Licensee: Shearon Harris Nuclear Plant Regulatory Affairs

Contact:

Sarah McDaniel (984) 229-2002, sarah.mcdaniel@duke-energy.com Docket Number: 050-00400 Inspection Dates: June 26 to 30, 2023 Documents Due to Region II by: June 12, 2023 NRC Inspection Procedures (IPs):

• 71124.01 - Radiological Hazard Assessment and Exposure Controls

• 71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage and Transportation

• 71151 - Performance Indicator Verification Note: Please provide the current version of these documents in an electronic format if possible (The preferred file format is MSWord, or searchable .pdf files). To the extent possible, please organize the information in directories as requested below and if possible, use a descriptive name for the files provided. Recent experience has demonstrated the most efficient method to transfer this information to the NRC is via CERTREC. It is best to upload all the requested information in one large zip file. If there are questions regarding the documents requested, or method of transfer, please do not hesitate to contact the lead inspector.

Documentation for IP 71124.01 should be from November 1, 2022, and from September 1, 2022, for IP 71151. Documentation for IP 71124.08 should be from November 1, 2020. These dates are approximate to the last time these inspections were conducted. Also, provide only a listing and title for NCRs requested for each inspection procedure and inspectors will select a sample from these for in-depth review during the inspection.

If you have any questions, please call Robert Kellner at (404) 997-4508. Thank you in advance for your effort in putting together this material.

71124.01 - Radiological Hazard Assessment and Exposure Controls (Last inspected in November 2022)

1. List of active Radiation Work Permits (RWPs) [including number, title, task (if RWPs contain multiple tasks), their dose and dose rate limits].

2. Site and Corporate procedures related to Health Physics (HP) controls (e.g., posting, labeling, surveys, RWPs, contamination control, high radiation area (HRA)/LHRA/VHRA control, key control, control of divers, special controls during fuel offload, hot spots, etc.).

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

4. List of non-fuel items stored in spent fuel pool (SFP) 1

5. List of locations, or plant maps indicating the location, of locked high radiation areas (LHRAs) and very high radiation areas (VHRAs), including areas with the potential to become a LHRA during routine operations or outages.

6. Most recent survey of LHRAs and VHRAs (as applicable).

7. Self-assessments or audits covering radiological hazard assessment and exposure controls and HP controls since last inspection (if none, then provide the most recent).

8. Corrective Action Program (CAP) documents (CR, NRC, AR, etc.) related to RP controls (e.g., radworker error, HP technician error, posting issues, radioactive source controls, HRA/LHRA/VHRA issues, survey problems, etc.) generated since November 1, 2022. This should be a list of corrective action documents containing a CAP document number and a brief description, not complete documents.

71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation (Last Inspected in November 2020)

1. Provide procedures/guidance documents describing licensee compliance with 10 CFR 20, 61, and 71, and 49 CFR 170-189. Procedures/manuals should include:

a. Solid and liquid radioactive waste (radwaste) processing procedures

b. Procedure(s) for transferring radwaste resin and sludge discharges into shipping/disposal containers

c. Waste stream mixing and/or sampling procedures, including:

i. waste concentration averaging, ii. use of scaling factors and calculations used to account for difficult-to-measure radionuclides, and iii. ensuring waste stream composition data accounts for changing operational parameters

d. Shipping/transportation procedures

i. Cask loading and closure procedures (licensee and vendor) applicable to last three cask transports ii. Monitoring impact of long-term storage of RAM iii. Process Control Program (PCP)

2. Site-specific and Corporate procedures related to 10 CFR Part 37 compliance (storage of RAM, 10 CFR Part 37 Security Plan, radiation protection and security procedures that identify radiation protection interaction with security, or requirements related to 10 CFR Part 37 compliance, etc.) Note: Please provide these documents if they are classified as Security Related Information-Official Use Only, NO Safeguards Information (SGI) or above should be provided via CERTREC.

3. List of locations where Category 1 and 2 materials are stored. Note: Please provide these documents if they are classified as Security Related Information-Official Use Only, NO Safeguards Information (SGI) or above should be provided via CERTREC.

4. Supporting calculations for determination of whether an aggregation of RAM meets the definition of Category 1 or Category 2 (e.g., warehouse calculation). Note: Please provide these documents if they are classified as Security Related Information-Official Use Only, NO Safeguards Information (SGI) or above should be provided via CERTREC.

5. List of Nationally Tracked Sources, and copies of any National Source Tracking System (NSTS) transaction documentation (e.g., annual reconciliation).

6. Copies of the two most recent sealed source inventory records.

7. Copy of the most recent radio-chemical sample analysis results (i.e., 10 CFR Part 61" analysis) for each of the radwaste streams (e.g., dry active waste (DAW), ion exchange resins, mechanical filters, and sludges and activated materials).

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8. List and documentation of any changes made to the radwaste processing systems (liquid and solid) and/or the PCP since the last inspection, and associated 10 CFR 50.59 documentation, as appropriate.

9. Copies of applicable transport cask Certificate of Compliance for the last three transport cask shipments

10. List of RAM storage areas, including satellite radiological controlled areas (RCAs)

11. Log of RAM shipments (LSA I, II, IIII; SCO I, II, Type A, or Type B) since the last inspection.

(The inspectors will select three to five packages to review in detail.)

12. Most recent self-assessment or audit of the RP program that included radioactive waste processing, radioactive material controls, shipping/radwaste processing, and RAM storage programs (excluding INPO).

13. List of CAP documents (AR, CR, NCR, etc.) related to involving radwaste and RAM processing and/or transportation (e.g., keyword searches for RAM, shipping, radwaste, 10 Part 61, etc.) issued since the last inspection. This should be a list of corrective action documents containing an (AR, CR, NCR, etc.) number and brief description, not full documents.

14. Available for onsite review during the inspection

a. Site drawing(s) showing the location of stored RAM and stored radwaste (include these also in the electronic documents provided if possible)

b. Plant drawings sufficient to permit the inspector to walkdown the liquid and solid radwaste processing systems, to verify current system configuration/ operation agree with the descriptions contained in the Updated Final Safety Analysis Report and in the PCP

c. Training and qualification records for personnel responsible for radwaste processing, packaging, and making shipments of radioactive material (RAM) and radwaste.

(include these also in the electronic documents provided if possible)

d. Training and qualification records for personnel responsible for implementation of the 10 CFR Part 37 security plan (e.g., security staff and health physics staff)

e. Documentation describing the status of any radwaste process equipment that is not operational and/or is abandoned in-place.

f. Discussion of the sites waste disposal volume and waste reduction program with staff.

71151 - Performance Indicator Verification (Occupational and Public Cornerstones)

(Last Inspected through September 2022)

1. Procedure(s) for gathering and reporting PI data

2. List of electronic dosimeter dose and dose rate alarms, including alarm setpoint and alarm received, since September 1, 2022

3. List of all CAP documents using search keywords such as: HRA, LHRA, VHRA, unintended dose, unlocked door, etc. since October 1, 2022. This should be a list of corrective action documents containing a CAP document number and a brief description, not complete documents.

General and Miscellaneous Information

1. List of primary site contact(s) for each inspection area including name(s), email, and telephone numbers.

2. Corrective Action Program procedures.

3. Plant Management and Radiation Protection organizational charts w/ contact numbers.

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4. Schedule of major maintenance/work activities during the week of the inspection (Gantt chart if available).

Assistance Requested During On-Site Inspection

1. Identification of radiological work activities available during the inspection week for observation, including notification of pre-job briefings, notification of risk significant work activities, and location of audio/visual surveillance for remote job coverage.

2. Health physics assistance in plant walk-downs and information concerning job coverage of ongoing activities to assess access controls.

3. Notification of any radioactive material shipping activities occurring during the inspection week for observation Inspector Contact Information: Mailing Address:

Robert Kellner U.S. Nuclear Regulatory Commission Sr. Health Physicist US NRC Region II (404) 997-4508 ATTN: Robert Kellner robert.kellner@nrc.gov 245 Peachtree Center Ave., N.E Suite 1200 Atlanta, GA 30303 4