RC-16-0112, NRC Request Information Baseline Radiation Safety Inspection

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NRC Request Information Baseline Radiation Safety Inspection
ML16193A058
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 07/07/2016
From: Thompson B
SCANA Corp, South Carolina Electric & Gas Co
To: Carmen Dykes
NRC/RGN-II
References
CR-16-02989, RC-16-0112
Download: ML16193A058 (6)


Text

Bruce L. Thompson Manager, Nuclear Licensing 803.931.5042

"(_ SCE&G@ A SCANA COMPANY July 7, 2016 U. S. Nuclear Regulatory Commission, Region II Attn: Carmen Dykes 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257

Dear Ms. Dykes:

Subject:

VIRGIL C. SUMMER NUCLEAR STATION UNIT 1 DOCKET NO. 50-395 OPERATING LICENSE NO. NPF-12 NRG REQUEST FOR INFORMATION BASELINE RADIATION SAFETY INSPECTION

Reference:

Brian R. Bonser, Chief, NRG Plant Support Branch 1, letter to George Lippard, June 9, 2016, ML16161A850 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 July 18-22, 2016.

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,

~ Bruce L. Thompson ~

SBR/BLT/rp Enclosure (CD - VCSNS 2016 Baseline NRG Radiation Protection Inspection) c: (without enclosure unless noted)

M. Coleman RTS (CR-16-02989)

Document Control Desk File (815.01)

NRG Resident Inspector PRSF (RC-16-0112)

S. A. Williams V. C. Summer Nuclear Station

  • P. 0. Box 88
  • Jenkinsville, SC* 29065
  • F(803) 941-9776

i

~

NRC, Region II CR-16-02989 RC-16-0112 Page 1 of 5 Licensee: V.C. Summer Nuclear Station Docket Number(s): 50-395 Inspection Dates: July 18-22, 2016 Inspection Procedures:

71124.06 Radiological Hazards Assessment and Exposure Controls 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 Tl 2800/041 Title 10 CFR Part 37 Materials Security Review - At Facilities with a Title 10 CFR Part 73 Physical Protection Program A. 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 to also include effluent sampling and reporting procedures and REMP sampling and reporting procedures, including title and number.

e Current Part 61 Analysis Results and Dry Active Waste (DAW),

a 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 (Pl) occurrences.

" Annual Radiological Environmental Operating Report (AREOR) for Calendar Year (CY),

CY 2014 and CY 2015.

" Annual Radiological Effluent Release Report (ARERR) documents for CY 2014, and CY 2015.

e List of all Pis an_d copies of associated corrective action reports for Occupational Exposure Control Effectiveness and Radiological Effluent Technical Specifications (RETS)/ODCM Radiological Effluent Occurrences in the past year.

"' Audits and self-assessments performed since July 2015 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.

NRG, Region II CR-16-02989 RC-16-0112 Page 2 of 5

8. 71124.01 - Radiological Hazard Assessment and Exposure Controls
  • List of active Radiation Work Permits (RWPs), including outage RWPs, with their administrative limits, electronic dosimeter dose rate limit, and dose limit.

., List of locations, or plant maps indicating the location, of all LHRAs and VHRAs. Include areas with the potential to become a LHRA during routine operations or outages.

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

e Independent spent fuel storage installation information to include surveys, exposure data, as low as reasonably achievable (ALARA) planning and reviews conducted for the last two moves. Also, the last two routine surveys of the facility and any Thermoluminescent Dosimeter area monitoring results of the facility.

0 Procedures related to HP controls (e.g. Posting, labeling, surveys, RWPs, contamination ANHRA control, key control, control of divers, special controls during fuel offload, hot spots, etc.).

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

s List of Nationally Tracked Sources, change of owner ship and copies of any National Source Tracking System transaction documentation (e.g., annual reconciliation).

  • Most recent sealed source inventory record.
  • List of all non-fuel items stored in spent fuel pool.
  • All self-assessments a_nd audits covering HP controls since July 1, 2015.
  • List of Corrective Action non-cqnformance documents (e.g. NCRs, CRs, etc.) related to HP controls where the cause was listed as human performance (radworker error) or human performance (HP technician error) generated since July 1, 2015. This should be a list of corrective action documents containing a CR number and brief description, not full CRs.

" All CRs related to Nationally Tracked Sources since July 1, 2015.

C. 71124.06 - Radioactive Gaseous and Liquid Effluent Treatment

.- Provide Procedures/Guidance Documents for:

a. Collection, analysis, release and dose evaluations for gaseous and/or liquid effluents, including guidance for both batch and continuous modes.
b. Determination of set-points for main plant gaseous and liquid effluent discharge p~hways. *
c. Groundwater monitoring program.
  • Provide a list of any significant changes to the ODCM since July 2015.

s Provide a list of significant changes to the radioactive effluent processing systems since July 2015. .

  • Provide a list of any non-radioactive systems that have become contaminated since July 2015,
  • Provide a list of any unmonitored, unplanned, or otherwise abnormal gaseous or liquid releases identified since July 2015.
  • Provide last two gaseous effluent permits and last two liquid effluent permits.
  • Provide system health reports for radiological effluent/process monitoring systems since July 2015.

NRC, Region II CR-16-02989 RC-16-0112 Page 3 of 5 a Provide a list of the main liquid and gaseous effluent pathway process monitors listed as out-of-service (OOS) since July 2015. [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 />.]

o List of significant changes to the effluent monitoring program sirice July 2015, as documented within the ODCM.

  • Provide groundwater monitoring results since July 2015.

" Inter-laboratory comparison program results (onsite count room) since July 2015.

a 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 July 2015. The data should include any reviews conducted of vendor activities and their facilities.

o List of condition reports (CRs) generated since July 2015, 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.]

D. 71124.07 - Radiological Environmental Monitoring

  • Provide Procedures/Guidance Documents for: *
a. Collection and analysis of environmental samples.
b. Calibration and maintenance of REMP air and/or water samplers.
c. Calibration of meteorological monitoring instrument loop (wind speed & direction, air temperature sensors currently in use).
d. Monthly/quarterly meteorological instrumentation surveillance requirements (control room and local tower activities).
  • Records for the last two calibrations of the following:
a. REMP air and water sampling equipment (as applicable)
b. Meteorological monitoring instruments (wind speed & direction, air temperature).
  • Detailed inter-laboratory comparison program results (environmental lab) since July 2015.
  • Copies of all audits, self-assessments, and/or reviews of REMP activities since July 2015. 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 July 2015.
  • List of sampling stations that were OOS and dates for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> since July 2015.
  • List of CRs generated as a result of REMP activities since July 2015. [Note: Only titles/summary statement should be provided for use by the inspectors to select a sample of issues for in-depth review.

I NRC, Region II CR-16-02989 RC-16-0112 Page 4 of 5 E. 71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation

  • Provide Procedures/Guidance Documents describing licensee compliance with 1O*CFR Parts 20, 61, and 71, and 49 CFR Parts 170-18_9. Procedures/manuals should include:
a. Solid and liquid radwaste processing procedures.
b. Procedure(s) for transferring radioactive waste 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-tomeasure radionuclides iii. ensuring waste stream composition data accounts for changing operational parameters.
d. Shipping/transportation procedures.
e. Cask loading and closure procedures (licensee and vendor) applicable to last three cask transports .

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

g. 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).
h. 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).

11 Liquid and solid radwaste system diagrams and detailed system descriptions (e.g.,

information that might be contained in curricula for training new system engineers).

  • List and documentation of any changes made to the radioactive waste processing systems (liquid and solid), and/or the PCP since July 2015, and associated
a. 10 CFR Part 50.59 documentation, as appropriate.
i. Copies of applicable transport cask Certificate of Compliance for the last three transport cask shipments.

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

iii. Log of RAM shipments (LSA I, 11, 1111; SCO I, II, 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 July 2015, involving radioactive waste and RAM/waste transportation.

e Available for onsite review during the inspection:

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

NRG, Region II CR-16-02989 RC-16-0112 Page 5of5

b. Plant drawings sufficient to permit the inspector to wafkdown 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.

c. Documentation describing the status of any radioactive waste process equipment that is not operational and/or is abandoned in place.
d. Information concerning the site's waste disposal volume and waste reduction program.
e. 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.

F. 71151 - Performance Indicator Verification

  • Monthly Pl reports since July 2015 and copies of associated CRs for any RETS/ODCM Radiological Effluent occurrences.
  • Liquid and gas'eous effluent release permits which specify the monthly, quarterly, and annual curies released by isotope and associated public dose assessments since July 2015.
  • List of all electronic dosimeter (ED) dose rate alarms > 1 R/hr and all ED dose alarms since July 2015.

G. Technical Instruction 2800/041 - Title 10 CFR Part 37 Materials Security Review-At Facilities with a Title 10 CFR Part 73 Physical Protection Program (Radiation Protection portions only)

  • List of all known/designated locations of Category 1 and 2 material.

e All supporting calculations for determination of whether an aggregation of RAM meets the definition of Category 1 or Category 2 (e.g., warehouse calculation).

  • Any additional radiation protection procedures that identify radiation protection interaction with security, or requirements related to 10 CFR Part 37 compliance.
  • Please do not include Safeguards or Official Use Only information in the submittal. That information can be reviewed onsite.