RC-15-0116, Response to NRC Request for Information Baseline Radiation Safety Inspection

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Response to NRC Request for Information Baseline Radiation Safety Inspection
ML15201A068
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 07/13/2015
From: Thompson B
South Carolina Electric & Gas Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
815.01, CR-15-03044, RC-15-0116
Download: ML15201A068 (6)


Text

Bruce L. Thompson Manager,Nuclear Licensing 803.931.5042 A SCANA COMPANY July 13, 2015 U. S. Nuclear Regulatory Commission, Region 1I Attn: Robert Kellner 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257

Dear Mr. Kellner:

Subject:

VIRGIL C. SUMMER NUCLEAR STATION UNIT I DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 NRC REQUEST FOR INFORMATION BASELINE RADIATION SAFETY INSPECTION

Reference:

Brian R. Bonser, Chief, NRC Plant Support Branch 1, letter to Thomas D.

Gatlin, June 12, 2015.

As requested in the referenced letter, South Carolina Electric & Gas Company hereby submits the requested information required to support the Virgil C. Summer Nuclear Station (VCSNS) baseline radiation safety inspection scheduled for June 27-31, 2015.

The requested items have been organized and provided on the enclosed disk.

Should you have any questions, please contact Susan Reese at (803) 345-4591.

Very truly yours, SBR/BLT/ts Enclosure (1 Disk- VCSNS 2015 Baseline NRC Radiation Protection Inspection) c: (without enclosure unless noted)

M. Coleman RTS (CR-15-03044)

Document Control Desk File (815.01)

NRC Resident Inspector PRSF (RC-15-0116)

S. A. Williams

"-R (ý1"10-1 V.C.Summer Nuclear Station - P.O. Box 88. Jenkinsville, Sc. 29065. F(803) 941-9776

NRC, Region II CR- 15-03044 RC-15-0116 Page 1 of 5 Information Request V. C. Summer Baseline Radiation Safety Inspection Licensee: V.C. Summer Nuclear Station Docket Number(s): 50-395 Inspection Dates: July 27-31, 2015 Procedures:

71124.06 Radioactive Gaseous and Liquid Effluent Treatment 71124.07 Radiological Environmental Monitoring Program 71124.08 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage and Transportation 71151 Performance Indicator Verification General Information Needed

  • Telephone numbers of contacts for the identified inspection areas.
  • Plant, Chemistry, and Radiation Protection organizational charts, including personnel involved in effluent sampling and reporting, Radiological Environmental Monitoring Program (REMP) sampling and reporting, and solid radwaste processing and transportation of radwaste/radioactive materials (RAM).

" List of radiation protection procedures.

  • List of effluent sampling and reporting procedures.

" List of REMP sampling and reporting procedures.

" Current Part 61 Analysis Results for Dry Active Waste (DAW).

" Procedures for issuing and assessing issues for risk significance and followup actions (i.e., Corrective Action Program procedures).

" Procedure(s) for identifying, notification, tracking, and correcting performance indicators (PI) occurrences.

" Annual Radiological Environmental Operating Report (AREOR) for Calendar Year (CY) 2012, CY2013, and CY 2014.

  • List of all PIs and copies of associated corrective action reports for Occupational Exposure Control Effectiveness and Radiological Effluent Technical Specifications (RETS)/ODCM Radiological Effluent Occurrences.
  • Audits and self-assessments performed since September 2012 that encompass the areas of (1) effluent monitoring program and implementation; (2) REMP monitoring program and implementation; (3) liquid and solid radwaste processing; and (4) transportation of RAM/radwaste.

NRC, Region II CR-1 5-03044 RC-15-0116 Page 2 of 5 71124.06 - Radioactive Gaseous and Liquid Effluent Treatment

  • Provide Procedures/Guidance Documents for:

o collection, analysis, release and dose evaluations for gaseous and/or liquid effluents, including guidance for both batch and continuous modes.

o determination of set-points for main plant gaseous and liquid effluent discharge pathways.

o groundwater monitoring program.

  • Provide a list of any significant changes to the ODCM since September 2012.
  • Provide a list of significant changes to the radioactive effluent processing systems since September 2012.
  • Provide a list of any non-radioactive systems that have become contaminated since September 2012.

" Provide a list of any unmonitored, unplanned, or otherwise abnormal gaseous or liquid releases identified since September 2012.

  • Provide last two gaseous effluent permits and last two liquid effluent permits.

" Provide a list of 10 CFR 50.75(g) entries made since September 2012.

  • Provide system health reports for radiological effluent/process monitoring systems since September 2012.
  • Provide a list of the main liquid and gaseous effluent pathway process monitors listed as out-of-service (OOS) since September 2012. [Note: Do not include monitors listed as OOS for less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.]

" List of significant changes to the effluent monitoring program since September 2012, as documented within the ODCM.

  • Provide groundwater monitoring results since September 2012.
  • Inter-laboratory comparison program results (onsite count room) since September 2012.
  • Results of last two filtration system (HEPA/Charcoal) surveillances for gaseous effluent pathways.
  • Copies of all audits, self-assessments, and/or reviews of liquid and gaseous effluent monitoring program activities since September 2012. The data should include any reviews conducted of vendor activities and their facilities.
  • List of condition reports (CRs) generated since September 2012, because of gaseous and liquid effluent processing, and/or ODCM related activities. This should be a list of corrective action documents containing a CR number and brief description, not full CRs.

[Note: Only titles/summary statement should be provided for use by the inspectors to select a sample of issues for in-depth review.]

NRC, Region II CR- 15-03044 RC-15-0116 Page 3 of 5 71124.07 - Radiological Environmental Monitoring Program Prior to the Onsite Inspection

  • Provide Procedures/Guidance Documents for:

o collection and analysis of environmental samples.

o calibration and maintenance of REMP air and/or water samplers.

o calibration of meteorological monitoring instrument loop (wind speed & direction, air temperature sensors currently in use).

o monthly/quarterly meteorological instrumentation surveillance requirements (control room and local tower activities).

  • Records for the last two calibrations of the following:

o REMP air and water sampling equipment (as applicable).

o meteorological monitoring instruments (wind speed & direction, air temperature).

  • Detailed inter-laboratory comparison program results (environmental lab) since September 2012.
  • Copies of all audits, self-assessments, and/or reviews of REMP activities since September 2012. The data should include any reviews conducted of vendor activities and their facilities (e.g., environmental lab).

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

" List of significant REMP changes (sample locations, sample frequency, type of samples, etc.) documented within the ODCM since September 2012.

  • List of CRs generated as a result of REMP activities since September 2012. [Note:

Only titles/summary statement should be provided for use by the inspectors to select a sample of issues for in-depth review.]

71124.08- Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation Provide Procedures/Guidance Documents describing licensee compliance with 10 CFR Parts 20, 61, and 71, and 49 CFR Parts 170-189. Procedures/manuals should include:

o Solid and liquid radwaste processing procedures.

o Procedure(s) for transferring radioactive waste resin and sludge discharges into shipping/disposal containers.

o Waste stream mixing and/or sampling procedures, including: (1) waste concentration averaging; (2) use of scaling factors and calculations used to account for difficult-to-measure radionuclides; and (3) ensuring waste stream composition data accounts for changing operational parameters.

o Shipping/transportation procedures.

o Cask loading and closure procedures (licensee and vendor) applicable to last three cask transports.

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

NRC, Region II CR-1 5-03044 RC-15-0116 Page 4 of 5 71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation continued...

o Monitoring impact of long-term storage (e.g., buildup of gases produced by waste decomposition, chemical reactions, container deformation, loss of container integrity, rerelease of free-flowing water).

o Process Control Program (PCP).

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

" List and documentation of any changes made to the radioactive waste processing systems (liquid and solid), and/or the PCP since September 2012, and associated 10 CFR Part 50.59 documentation, as appropriate.

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

  • Training and qualification records for personnel responsible for radioactive waste processing and RAM material shipment preparation activities.

" Log of RAM shipments (LSA 1,11, 1111; SCO 1,11, Type A, or Type B) since September 2012. (The inspectors will select three to five packages to review in detail.)

  • List of corrective action reports generated since September, 2012, involving radioactive waste and RAM/waste transportation.
  • Available for onsite review during the inspection:

o Site drawing(s) showing the location of all stored RAM and all stored radioactive waste.

o Plant drawings sufficient to permit the inspector to walkdown the liquid and solid radioactive waste processing systems, to verify current system. configuration/

operation agree with the descriptions contained in the Updated Final Safety Analysis Report (UFSAR) and in the PCP.

o Documentation describing the status of any radioactive waste process equipment that is not operational and/or is abandoned in place.

o Information concerning the site's waste disposal volume and waste reduction program.

o Training curriculum and primary lesson plans for qualifying persons, including vendors, for radwaste processing, packaging, and making shipments of RAM and radioactive waste as specified by 49 CFR 172.

NRC, Region II CR-15-03044 RC-15-0116 Page 5 of 5 71151 - Performance Indicator Verification

" Monthly PI reports since May 1, 2014, and copies of associated CRs for any RETS/ODCM Radiological Effluent occurrences.

  • Liquid and gaseous effluent release permits which specify the monthly, quarterly, and annual curies released by isotope and associated public dose assessments since May 1, 2014.

o List of all electronic dosimeter (ED) dose rate alarms > I R/hr and all ED dose alarms since May 1, 2014.