ML112860294

IR 05000302-11-005; 11/14-18/2011; Crystal River Unit 3, Notification of Inspection and Request for Information

ML112860294
Person / Time
Site:	Crystal River
Issue date:	10/12/2011
From:	Brian Bonser NRC/RGN-II/DRS/PSB1
To:	Franke J Crystal River, FL
References
Download: ML112860294 (9)

See also: IR 05000302/2011005

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

245 PEACHTREE CENTER AVENUE NE, SUITE 1200

ATLANTA, GEORGIA 30303-1257

October 12, 2011

Mr. Jon A. Franke

Vice President, Crystal River Nuclear Plant

Crystal River Nuclear Plant (NA2C)

15760 W. Power Line Street

Crystal River, FL 34428-6708

SUBJECT: CRYSTAL RIVER UNIT 3 - NOTIFICATION OF INSPECTION AND REQUEST

FOR INFORMATION

Dear Mr. Franke:

During the period of November 14 - 18, 2011, the NRC will conduct baseline radiation safety

inspection activities at the Crystal River 3 Nuclear Plant. The inspection will focus on both the

Occupational and Public Radiation Safety Inspection cornerstones using NRC Inspection

Procedure (IP) 71124.01, IP 71124.02, 71124.03, IP 71124.04, and IP 71124.05. The

inspection also will evaluate Occupational and Public Cornerstone Radiation Safety sections of

IP 71151 associated with Performance Indicator (PI) verification.

Experience has shown that this inspection is resource intensive both for the NRC inspectors

and your staff. In order to minimize the impact to your on-site resources and to conduct 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 in order to minimize the

number of additional documents requested during the preparation, and/or the onsite portions of

the inspection. The lead inspector has requested that the subject informational material be

made available to the NRC staff by November 4, 2011, to allow preparation for the upcoming

inspection.

We have discussed the schedule for these inspection activities with your staff and understand

that our regulatory on-site contact for this inspection will be Mr. Dennis Herrin 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.

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

FPC 2

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 Nos. 50-302

License Nos. DPR-72

Enclosure:

Radiation Protection Inspection Document Request

cc: w/encl.: (See page 3)

ML112860294 X SUNSI REVIEW COMPLETE X FORM 665 ATTACHED

OFFICE DRS/PSB1 DRS/PSB1

SIGNATURE RA RA

NAME G. KUZO B. BONSER

DATE 10/12/2011 10/12/2011

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

FPC 3

cc w/encl:

Kelvin Henderson Daniel R. Westcott

General Manager Supervisor

Nuclear Fleet Operations Licensing & Regulatory Programs

Progress Energy Crystal River Nuclear Plant (NA1B)

Electronic Mail Distribution Electronic Mail Distribution

Brian C. McCabe Joseph W. Donahue

Manager, Nuclear Oversight Vice President

Shearon Harris Nuclear Power Plant Nuclear Oversight

Progress Energy Progress Energy

Electronic Mail Distribution Electronic Mail Distribution

Terry D. Hobbs Jack E. Huegel

(Acting) Plant General Manager Manager, Nuclear Oversight

Crystal River Nuclear Plant (NA2C) Crystal River Nuclear Plant

Electronic Mail Distribution Electronic Mail Distribution

Stephen J. Cahill David T. Conley

Director - Engineering Nuclear Senior Counsel

Crystal River Nuclear Plant (NA2C) Legal Department

Electronic Mail Distribution Progress Energy

Electronic Mail Distribution

R. Alexander Glenn

General Counsel Mark Rigsby

Progress Energy Manager, Support Services - Nuclear

Electronic Mail Distribution Crystal River Nuclear Plant (NA2C)

Electronic Mail Distribution

Jeffrey R. Swartz

Director Site Operations Senior Resident Inspector

Crystal River Nuclear Plant U.S. Nuclear Regulatory Commission

Electronic Mail Distribution Crystal River Nuclear Generating Plant

U.S. NRC

Donna B. Alexander 6745 N Tallahassee Rd

Manager, Nuclear Regulatory Affairs Crystal River, FL 34428

(interim)

Progress Energy Attorney General

Electronic Mail Distribution Department of Legal Affairs

The Capitol PL-01

Thomas Sapporito Tallahassee, FL 32399-1050

Consulting Associate

(Public Correspondence Only) Bryan Koon, Director

Post Office Box 8413 Florida Division of Emergency Management

Jupiter, FL 33468 Electronic Mail Distribution

William A. Passetti Chairman

Chief Board of County Commissioners

Florida Bureau of Radiation Control Citrus County

Department of Health 110 N. Apopka Avenue

Electronic Mail Distribution Inverness, FL 36250

PUBLIC RADIATION PROTECTION INSPECTION

DOCUMENT REQUEST

SITE: Crystal River Unit 3 (CR3) Report Number: 05000302/2011005

INSPECTION DATES: November 14 - 18, 2011

NRC INSPECTORS: Ruben Hamilton, Ruben.Hamilton@NRC.GOV (404) 997-4672

George B. Kuzo, George.Kuzo@NRC.GOV (404) 997-4658

Robert Kellner Robert.Kellner@NRC.GOV (404) 997-4508

William Pursley William.Pursley@NRC.GOV (404) 997-4517

PRELIMINARY LICENSEE CONTACTS: Radiation Controls - Bryan Akins, (352) 464-4964[C]/

Kevin Hirsch, (352) 464-7261[C]; ALARA - Kenny Young , (352) 464-7462[C]; Transportation &

Radioactive Waste Processing, Randy Macko, (352) 795-6486 ext. 3610; Instrumentation -

Keith Shelton - (352) 464-7972 [C]; Counting Room Rudy Pinner (352) 795-6486 ext. 3141; and

Licensing - D. Herrin, (352) 563-4633.

Inspection Procedures: IP 71124.01 Radiological Hazard Assessment and Exposure

Controls

IP 71124.02 Occupational ALARA Planning and Controls

IP 71124.03 In-Plant Airborne Radioactivity Control and

Mitigation

IP 71124.04 Occupational Dose Assessment

IP 71124.05 Radiation Monitoring Instrumentation

IP 71151 Performance Indicator Verification

Note: This is a broad list of the documents the lead NRC inspector will be interested in

reviewing and obtaining during the pre-inspection visit. The current version of these documents

is expected unless specified otherwise. Electronic media is preferred, if readily available. (The

preferred file format is Word, WordPerfect, or searchable .pdf files on electronic media, e.g.

CD-ROM. Please provide 3 copies of each electronic device that is submitted.) Information in

the document lists should contain enough information to be easily understood by someone

who has knowledge of the subject. During the inspection, the inspectors may request additional

documents.

GENERAL INFORMATION NEEDED

Organization Charts and Contact Phone Numbers for:

Radiation Protection

Chemistry

Procedure for issuing Condition Report (CR) documents and assessing issues for risk

significance and follow-up actions.

Updated Final Safety Analysis Report Chapter 11, Effluents/Radwaste; and Radiation

Protection.

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

Schedule of major maintenance / operational activities during onsite inspection (Gantt chart

if available).

Enclosure

2

RADIOLOGICAL HAZARD ASSESSMENT AND EXPOSURE CONTROL [71124.01]

Provide Procedures/Guidance Documents for:

external dose monitoring, i.e., dosimetry issuance and use. The documents should

include: guidance for multi-badging; monitoring in steep/highly variable dose rate

gradients; high radiation area (HRA), locked-HRA (LHRA) and very high radiation area

(VHRA) controls for select operational / outage activities; personnel contamination events;

storage/care of personal dosimeters; use of electronic dosimeters including evaluation of

set-point determination; biases identified relative to TLD monitoring; remote monitoring

procedures; post shutdown, fuel movement, and/or diving operations.

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

suspect alpha particle exposures.

contamination control, i.e., procedures for release of contaminated individuals or

potentially contaminated materials from the radiologically controlled area (RCA).

Posting of areas, labeling of containers, and inventories of non-SNM materials maintained

within the spent fuel pools.

List five highest cumulative exposure or exposure rate tasks for on-going outage activities

since October 1, 2010.

Provide associated radiation work permit documents, if available.

List current outage tasks with significant potential for significant release of airborne

radioactive particulates.

List of all positive whole body count (WBC), in vitro, or air sampling analyses since

October 1, 2009, which resulted in an assigned CEDE equal to or exceeding 10 millirem

[Note, a listing should be provided for use by the inspectors to select a sample of issues for

in-depth review during the on-site inspection].

List of all personnel contamination events, dispersed contamination/discrete particles,

identified since October 1, 2009. [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]

Copies of all audits, self-assessments, and/or reviews related to internal or external

dosimetry issues generated since October 1, 2009. The documents provided should include

any reviews/evaluations conducted of vendor facilities, e.g., corporate or outside vendor and/

or corporate calibration facilities.

Provide a list of CR documents generated since October 1, 2009, for internal or external

dosimetry issues/events. [Note: only titles/summary statement should be provide for use by

the inspectors to select a sample of issues for in-depth review].

71124.02: OCCUPATIONAL ALARA PLANNING AND CONTROLS

Provide site and corporate procedures associated with maintaining occupational exposures.

ALARA. Include procedural guidance for processes used to estimate and track exposures

from specific work activities, method(s) of adjusting exposure estimates or re-planning work

when unexpected changes in scope or emergent work are encountered, and performance of

post-job reviews.

Documentation of plant collective exposure history, current exposure trends, and ongoing or

planned outage activities that present exposure challenges.

List of work activities ranked by actual or estimated exposure that (1) are in progress and/ or

(2) were completed during the current extended outage since October 1, 2010. The

Enclosure

3

inspectors will select activities from the list for review of ALARA work activity evaluations,

exposure estimates, and exposure mitigation requirements.

Historical trends and current status of plant source changes resulting from plant fuel

performance issues or chemical lay-up during the extended outage.

Audits and self-assessments performed of the ALARA program, including the previous

outages ALARA reviews/summaries.

List of CAP condition reports generated since October 1, 2009, related to ALARA

planning and controls.

71124.03: IN-PLANT AIRBORNE RADIOACTIVITY CONTROL AND MITIGATION

Provide site and corporate procedures associated with airborne radioactivity control and

mitigation. Procedures should include guidance for the following:

Maintenance, inspection, and use of respiratory protection equipment including self-

contained breathing apparatus (SCBA).

Use of installed plant systems including containment purge, spent fuel pool ventilation,

and auxiliary building ventilation.

Use of temporary ventilation systems (e.g. HEPA/charcoal NPUs, tents, etc.).

List recent activities in which respiratory protection equipment was used.

Provide air testing data (i.e. Grade D certification) for supplied-air devices and SCBA bottles

since October 1, 2009.

List of CAP condition reports generated since October 1, 2009, related to (1) the control and

mitigation of in-plant airborne radioactivity and (2) respiratory protection. Site and corporate

procedures associated with maintaining occupational exposures ALARA. Include procedural

guidance for processes used to estimate and track exposures from specific work activities,

method(s) of adjusting exposure estimates or re-planning work when unexpected changes in

scope or emergent work are encountered, and performance of post-job reviews.

OCCUPATIONAL DOSE ASSESSMENT [71124.04]

Provide Procedures/Guidance Documents for:

external dose monitoring, i.e., dosimetry issuance and use. The documents should

include: 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.

NVLAP accreditation documentation for current dosimetry used by site.

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 October 1, 2009. [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, dispersed contamination/discrete particles,

identified since October 1, 2009. [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]

Enclosure

4

List of declared pregnant workers [Note: do not provide this data - the documents will be

reviewed on-site, only have the data readily available during the onsite inspection].

Copies of all audits, self-assessments, and/or reviews related to internal or external

dosimetry issues generated since October 1, 2009. The documents provided should to

include any reviews/evaluations conducted of vendor facilities, e.g., corporate or outside

vendor/ or corporate calibration facilities.

Provide a list of Condition Report (CR) documents generated since October 1, 2009, for

Internal or external dosimetry issues/events. [Note: only titles/summary statement

should be provide for use by the inspectors to select a sample of issues for in-depth review].

RADIATION MONITORING INSTRUMENTATION [71124.05]

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 in-plant air monitoring equipment.

determination of set-points for Area Radiation Monitor (ARM), Air Monitoring, PCM, PM

and SAM equipment.

collection and analysis of high-range, post accident effluent samples.

QA program for count room instruments.

The last 2 calibration records for the following monitors:

RM-G14 . Fuel Storage Building

RM-G30 . Containment High Range Area Radiation Monitor

RM-A8 Auxiliary Building Exhaust

RM-A11.. Waste Gas Decay Tank Monitor

RM-L2. Plant Liquid Discharge Line

Personnel contamination and tool monitors at RCA exit point; and PM at Protected Area

exit (One to two monitors of each type will be selected and the records reviewed during

the onsite inspection)

Count room high-purity Germanium Detector and Liquid Scintillation Counter (Specific

equipment and/or geometries will be selected during the onsite inspection).

Certificates for the sources used to calibrate the above requested monitors showing

traceability to a national standard (NIST), as applicable.

The last 2 test records of the portable instrument calibrator (Shepherd validation testing), if

applicable.

Copies of all audits, self-assessments, and/or reviews of area and personnel monitoring

equipment and portable radiation survey instruments generated since October 1, 2009. The

records should include any reviews conducted of vendor facilities, e.g., outside calibration

laboratories, as applicable.

List of CRs generated since October 2009, related to portable instruments, effluent and area

monitors, CAMs, RCA release point monitors, WBCs, and count room instruments. This

should be a summary list of corrective action documents containing a CR number and brief

description, not full CRs.

Enclosure

5

PERFORMANCE INDICTOR VERIFICATION [71151]

Procedure/Guidance for collection and reporting of PI data.

Provide the following records:

CRs related to occupational and public radiation safety PI occurrences issued since

October 1, 2010.

Monthly/Quarterly Occupation and Public Radiation Safety PI reports since October 1,

2010.

List of Out of Service (OOS) Effluent Monitors and Length of Inoperability since October 1,

2010. [Note these data are part of the data requested under Inspection Procedure

7112405 above and do not have to be duplicated].

Procedure for issuing CRs and assessing issues for significance and action.

Updated Final Safety Analysis Report Chapters 11 (Effluents/Radwaste) and 12 (Radiation

Protection).

Enclosure