ML090500141

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Notification of Inspection and Request for Information
ML090500141
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 02/19/2009
From: Brian Bonser
NRC/RGN-II/DRS/PSB1
To: Campbell W
Tennessee Valley Authority
References
Download: ML090500141 (10)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II SAM NUNN ATLANTA FEDERAL CENTER 61 FORSYTH STREET, SW, SUITE 23T85 ATLANTA, GEORGIA 30303-8931 February 19, 2009 Mr. William R. Campbell, Jr.

Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

SEQUOYAH NUCLEAR POWER PLANT, NOTIFICATION OF INSPECTION AND REQUEST FOR INFORMATION Dear Mr.

On March 30-April 3, 2009 and April 13-17, 2009, the NRC will perform the baseline Occupational Radiation Safety Inspection at Watts Bar, (NRC Inspection Procedures 71121.01, 71121.02, 71122.01, 71122.02, and Radiation Safety Sections of 71151, 60855.1). 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 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, in order to minimize the number of additional documents requested during the preparation and/or the onsite portions of the inspection. There will not be a pre-inspection visit associated with this inspection. We request that the documents described in the attachment be provided to the inspectors for pre-inspection review by 3/9/2009.

The preferred format for electronically readable media is portable document format (PDF) or Microsoft Office 2003 or earlier.

We have discussed the schedule for these inspection activities with your staff and understand that our regulatory contact for this inspection will be Rusty Proffitt of your organization. If there are any questions about this inspection or the material requested, please contact the lead inspector, Ruben Hamilton at (404) 562-4672.

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 Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS).

TVA 2 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.: 50-327, 50-328 License No.: DPR-77, DPR-79

Enclosure:

Pre-Inspection Document Request cc w/encl.: (See page 3)

TVA 3 cc w/encl: John C. Fornicola Ashok S. Bhatnagar General Manager Senior Vice President Nuclear Assurance Nuclear Generation Development and Tennessee Valley Authority Construction Electronic Mail Distribution Tennessee Valley Authority Electronic Mail Distribution General Counsel Tennessee Valley Authority Ludwig E. Thibault Electronic Mail Distribution General Manager Nuclear Oversight & Assistance Beth A. Wetzel Tennessee Valley Authority Manager Electronic Mail Distribution Corporate Licensing Tennessee Valley Authority William R. Campbell, Jr. Electronic Mail Distribution Chief Nuclear Officer and Executive Vice President James D. Smith Tennessee Valley Authority Manager, Licensing and Industry Affairs 3R Lookout Place Sequoyah Nuclear Plant 1101 Market Street Tennessee Valley Authority Chattanooga, TN 37402-2801 Electronic Mail Distribution Christopher R. Church Larry E. Nicholson Plant Manager General Manager Sequoyah Nuclear Plant Licensing & Performance Improvement Tennessee Valley Authority Tennessee Valley Authority Electronic Mail Distribution Electronic Mail Distribution Tom Coutu Michael A. Purcell Vice President Senior Licensing Manager Nuclear Support Nuclear Power Group Tennessee Valley Authority Tennessee Valley Authority 3R Lookout Place Electronic Mail Distribution 1101 Market Street Chattanooga, TN 37402-2801 Senior Resident Inspector U.S. Nuclear Regulatory Commission Michael J. Lorek Sequoyah Nuclear Plant Interim Vice President 2600 Igou Ferry Road Nuclear Engineering & Projects Soddy Daisy, TN 37379-3624 Tennessee Valley Authority Electronic Mail Distribution Lawrence Edward Nanney Director Timothy P. Cleary Division of Radiological Health Site Vice President TN Dept. of Environment & Conservation Sequoyah Nuclear Plant Electronic Mail Distribution Tennessee Valley Authority Electronic Mail Distribution (cc w/encl: Continued on Page 4)

TVA 4 (cc w/encl: Continued from Page 3)

County Mayor Hamilton County Hamilton County Courthouse Chattanooga, TN 37402-2801 James H. Bassham Director Tennessee Emergency Management Agency Electronic Mail Distribution Ann Harris 341 Swing Loop Rockwood, TN 37854

Pre-Inspection Document Request Occupational Radiation Safety Cornerstone Licensee: Sequoyah Nuclear Plant Docket Numbers: 50-327, 328 Inspection Dates: 3/30-4/3/2009 and 4/13-17/2009 Inspection Procedures to be performed:

71121.01 Access Controls to Radiologically Significant Areas 71121.02 ALARA Planning and Controls 71122.01 Radioactive Gases and Liquid Effluent Treatment & Monitoring Systems [limited scope, Sections 02.01(e), 2.02 (d & e)]

71122.02 Radioactive Material Processing and Transportation 71151 Performance Indicator Verification 60855 Operation of an Independent Spent Fuel Storage Installations (ISFSI)

The most recent inspection completed for the listed inspection procedures was performed on 10/1-5/2007 and 10/22-26/2007. Documentation is requested from November 2007 to the present.

We would prefer as much of the information as possible in electronic form. An index to the CD contents is also helpful. For those items requesting a list of documents/areas, the inspectors will select documents/areas from the list for on-site review. If any of the requested information is too burdensome to provide electronically or as hard copies during the bagman trip, simply indicate that the requested material is available for onsite review by the inspectors.

If you have any questions, please call Ruben Hamilton at 404-562-4672. Thank you in advance for all your effort in putting together this material.

Assistance Requested During On-Site Inspection G Identification of work activities during the inspection for inspector observations, including notification of pre-job briefings, notification of diving activities, audio/visual surveillance for remote job coverage.

G Health physics assistance in plant walk-downs assessing access controls, e.g. verifying the posting and locking of entrances to HDR-HRA and VHRA, and spent fuel pool controls.

Enclosure

2 G Health physics assistance in plant walk-downs/job coverage of ongoing outage activities to assess access controls and ALARA practices.

G Assistance in plant walk-downs of the solid and liquid radwaste processing systems.

G Discussions with appropriate individuals regarding access controls and ALARA planning.

G Schedule of transportation shipments during the inspection and notification of opportunities for observations of shipment preparation/receipt; discussions with appropriate individuals regarding the transportation program.

General Information Request G Telephone numbers of contacts G Plant and Radiation Protection organizational charts, including personnel involved in solid radwaste processing and transportation of radwaste/radioactive materials.

G Electronic copy of applicable chapters of UFSAR (e.g. radiation protection program, liquid and solid radioactive waste program, etc.)

G Outage schedule, including work activities to be conducted during the week(s) of the inspection G List of active radiation work permits, including those specific to outage activities, with their administrative limits, electronic dosimeter dose rate limit, and dose limit.

G List of radiation protection procedures G Corrective Action Program procedures G Procedure(s) for identifying, notification, tracking, and correcting PI occurrences.

G List of all Performance Indicators (PIs) and copies of associated corrective action reports for Occupational Exposure Control Effectiveness and RETS/ODCM Radiological Effluent Occurrences G Audits and self-assessments performed since the last inspection that encompass the areas of (1) access controls, (2) the ALARA program and implementation, (3) liquid and solid radwaste processing, and (4) transportation of radioactive material/radwaste.

60855.1 Operation of an Independent Spent Fuel Storage Installations G Provide procedure/guidance for Area and removable contamination surveys conducted in and around ISFSI Dosimetry results (annual/quarterly) for the ISFSI since last inspection in this area 71122.01 Radioactive Gases and Liquid Effluent Treatment & Monitoring Systems G Procedures for onsite/offsite surface/groundwater monitoring activities and leak detection

3 G Summary of spill, leak, or unexpected liquid discharge data documented in the sites 10 CFR 50.75(g) files. Note: Only provide summary, 50.75(g) file details may be reviewed during onsite inspection G List of PERs issued since April 2008 for H-3 or other radioisotopes in ground water wells, or identification of spills or leaks from contaminated systems, structures, and components.

G Audits and self assessments conducted since April 2008 for groundwater monitoring.

71121.01 Access Controls to Radiologically Significant Areas G Site and corporate procedures associated with the access control program.

Procedures should include:

< Radiological surveys, postings, and radiation control barricades

< Security and control of high radiation sources/objects stored in pools

< Radiation Work Permits

< Radiological Job-Coverage

< Controlling access to High Radiation Areas (HRAs), High Dose Rate High Radiation Areas (HDR-HRAs), and Very High Radiation Areas (VHRAs)

< Key controls for all high radiation areas

< Radioactive material control, including contamination and hot particles

< Dosimetry monitoring (electronic dosimeters, multi-badging, etc.)

< Calculations of internal exposures G List of the 10 most exposure significant work areas within radiation areas, high radiation areas (<1R/hr), or airborne radioactivity areas in the plant. This may include areas with low dose rates but high collective dose. Identify any high radiation areas with significant dose gradients (factor of five or more), including underwater diving activities.

G List of HRAs, LHRAs, HDR-HRAs (>25 rem in one hour @ 30 cm), and VHRAs.

Include areas with the potential to become a HRA during routine operations or outages.

G Internal dose assessments, including calculations, for any internal exposures greater that 50 mrem CEDE since the last inspection.

G List of corrective action reports generated since the last inspection related to access controls, including the following:

Enclosure

4

< Access controls, including high radiation area radiological incidents

< Radiological events caused by radiation worker errors

< Radiological events caused by radiation protection technician errors G Available for onsite review during inspection:

< Elevation maps with most recent operating and outage radiation survey levels.

< RWPs for the top five dose rate areas or tasks.

71121.02: ALARA Planning and Controls G Site and corporate procedures associated with maintaining site dose ALARA, including those involving ALARA work activities. These procedures should include:

< ALARA program implementation, including ALARA committee activities and ALARA planning, briefing, and reviews

< Radiation work permit preparation and worker compliance

< Processes used to estimate and track work activity specific exposures

< Making changes to dose estimates during task performance

< Work controls

< Engineering controls

< Exposure mitigation requirements G Most recent annual ALARA report and most recent refueling outage report.

G Annual ALARA goals for 2008, and 2009 and the methodology utilized to make the projections.

G Historic trends and current status of plant source term.

G List approximately 10-15 work activities planned during the inspection likely to result in the highest personnel collective exposures and those which present the greatest radiological risk to workers (e.g. work in HRAs, diving, potentially changing radiological conditions). Include the dose projections and ALARA package numbers.

G ALARA Committee activity summaries (e.g. meeting minutes) for three months or 3 meetings after the last refueling outage and the three months or 3 meetings prior to the upcoming refueling outage.

G Completed ALARA packages (including post-job reviews) for the five work activities that were completed during the last outage which had the greatest collective dose and/or presented significant radiological risk.

G List of five activities (including ALARA package number) from the previous outage in which the work scope changed or was extended and alternative ALARA measures were taken to respond to the emergent conditions.

Enclosure

5 G List of five activities from the previous outage in which the estimated work hours were significantly different than the actual hours expended. List five activities in which the estimated and actual hours expended were accurate.

G Outline of the source term reduction strategy. Information should include:

< Historic trends and current status of plant source term

< Factors that affect the source term

< Activities employed to reduce the source term

< Specific sources identified for reduction actions

< Source term reduction evaluation

< Results achieved since last inspection G List of activities since that last inspection that were reviewed for ALARA problems and actions taken to prevent recurrence. Include corrective action report number(s) if applicable.

G List of corrective action reports generated since the last inspection related to the ALARA program, including the following:

< 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 G Available for onsite review during the inspection:

ALARA planning packages for jobs being performed during the outage

< Temporary shielding requests generated for the outage.

< Records of personnel monitored for radiation exposure that show the total TEDE to date for each person. If possible, sort individuals by work group.

< Records for declared pregnant workers since the last inspection, listing their monthly radiation exposure during the term or year-to-date.

71122.02 Radioactive Material Processing and Transportation G Site and corporate procedures/manuals describing licensee compliance with 10 CFR Parts 20, 61, and 71 and 49 CFR Parts 170-189. Procedures/manuals should include:

< Solid and liquid radwaste processing procedures

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

< 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

< Shipping/transportation procedures

< Cask loading and closure procedures (licensee and vendor) applicable to last three cask transports Enclosure

6 G Process Control Program (PCP).

G Most recent Annual Radioactive Effluents Release Report.

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

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

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

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

G Copy of the Radioactive Shipping Log for the last 12 months. (The inspector will select transportation shipping packages for review during the inspection.)

G List of corrective action reports generated since the last inspection involving radioactive waste and radioactive material/waste transportation.

G Available for onsite review during the inspection:

< Site drawing(s) showing the location of all stored radioactive materials and all stored radioactive waste.

< Plant drawings sufficient to permit the inspector to walk-down the liquid and solid radioactive waste processing systems to verify current system configuration/operation agree with the descriptions contained in the UFSAR and in the PCP.

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

< Information concerning the sites waste disposal volume and waste reduction program.

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

Enclosure

_________________________ X SUNSI REVIEW COMPLETE OFFICE RII:DRS RII:DRS RII:DRP SIGNATURE /RA/ /RA/

NAME B. Bonser R. Hamitlon DATE 2/ /2009 2/ /2009 2/ /2009 2/ /2009 2/ /2009 2/ /2009 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO