ML090430143
| ML090430143 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 02/12/2009 |
| From: | Scott Shaeffer NRC/RGN-II/DRP/RPB2 |
| To: | Tynan T Southern Nuclear Operating Co |
| Shared Package | |
| ML090430130 | List: |
| References | |
| IR-08-005 | |
| Download: ML090430143 (17) | |
See also: IR 05000424/2008005
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
SAM NUNN ATLANTA FEDERAL CENTER
61 FORSYTH STREET, SW, SUITE 23T85
ATLANTA, GEORGIA 30303-8931
February 12, 2009
Mr. Tom E. Tynan
Vice President
Southern Nuclear Operating Company, Inc.
Vogtle Electric Generating Plant
7821 River Road
Waynesboro, GA 30830
SUBJECT: ERRATA LETTER - VOGTLE ELECTRIC GENERATING PLANT - NRC
INSPECTION REPORT 05000424/2008005 AND 05000425/2008005
Dear Mr. Tynan:
By letter dated January 20, 2009, we transmitted the results of the routine baseline inspections
for the fourth quarter of 2008 (ML090200064). This report is being revised to provide additional
information typically provided regarding radiation dose rates as discussed on pages 17 and 18
of the report. This revision does not change the inspection results. Please replace pages 17
through 22 of the report transmitted on January 20, 2009, with the enclosed revision.
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 NRCs document system
(ADAMS). ADAMS is accessible from the NRC Web site at www.nrc.gov/reading-rm/adams.html
(the Public Electronic Reading Room).
I regret any inconvenience this omission may have caused. Please contact me at (404) 562-
4521 if you have any questions.
Sincerely,
/RA/
Scott M. Shaeffer, Chief
Reactor Projects Branch 2
Division of Reactor Projects
Docket Nos.: 50-424, 50-425
Enclosures: 1. Revised Pages
2. Removed Pages
cc w/encl: (See next page)
_________________________ XG SUNSI REVIEW COMPLETE
OFFICE RII:DRP RII:DRP RII:DRS RII:DRS
SIGNATURE CWR1 SMS BRB1 AND
NAME CRapp SShaeffer BBonser ANielson
DATE 02/11/2009 02/11/2009 02/11/2009 02/11/2009 2/ /2009 2/ /2009
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO
SNC 2
cc w/encl: Mr. N. Holcomb
Angela Thornhill Commissioner
Managing Attorney and Compliance Officer Department of Natural Resources
Southern Nuclear Operating Company, Inc. Electronic Mail Distribution
Electronic Mail Distribution
Dr. Carol Couch
N. J. Stringfellow Director
Manager Environmental Protection
Licensing Department of Natural Resources
Southern Nuclear Operating Company, Inc. Electronic Mail Distribution
Electronic Mail Distribution
Cynthia Sanders
Jeffrey T. Gasser Program Manager
Executive Vice President Radioactive Materials Program
Southern Nuclear Operating Company, Inc. Department of Natural Resources
Electronic Mail Distribution Electronic Mail Distribution
L. Mike Stinson Jim Sommerville
Vice President (Acting) Chief
Fleet Operations Support Environmental Protection Division
Southern Nuclear Operating Company, Inc. Department of Natural Resources
Electronic Mail Distribution Electronic Mail Distribution
Michael A. MacFarlane Mr. Steven M. Jackson
Southern Nuclear Operating Company, Inc. Senior Engineer - Power Supply
40 Inverness Center Parkway Municipal Electric Authority of Georgia
P.O. Box 1295 Electronic Mail Distribution
Birmingham, AL 35201-1295
Mr. Reece McAlister
David H. Jones Executive Secretary
Vice President Georgia Public Service Commission
Engineering Electronic Mail Distribution
Southern Nuclear Operating Company, Inc.
Electronic Mail Distribution Office of the Attorney General
Electronic Mail Distribution
Bob Masse
Resident Manager Office of the County Commissioner
Vogtle Electric Generating Plant Burke County Commission
Oglethorpe Power Corporation Electronic Mail Distribution
Electronic Mail Distribution
Arthur H. Domby, Esq.
Moanica Caston Troutman Sanders
Vice President and General Counsel Electronic Mail Distribution
Southern Nuclear Operating Company, Inc.
Electronic Mail Distribution (cc w/encl contd - See next page)
Laurence Bergen
Oglethorpe Power Corporation
Electronic Mail Distribution
SNC 3
cc w/encl contd:
Director
Consumers' Utility Counsel Division
Govenor's Office of Consumer Affairs
2 M. L. King, Jr. Drive
Plaza Level East; Suite 356
Atlanta, GA 30334-4600
Senior Resident Inspector
Southern Nuclear Operating Company, Inc.
Vogtle Electric Generating Plant
U.S. NRC
7821 River Road
Waynesboro, GA 30830
Susan E. Jenkins
Director, Division of Waste Management
Bureau of Land and Waste Management
S.C. Department of Health and
Environmental Control
Electronic Mail Distribution
SNC 4
Letter to Tom E. Tynan from Scott M. Shaeffer dated February 12, 2009
SUBJECT: ERRATA LETTER - VOGTLE ELECTRIC GENERATING PLANT - NRC
INSPECTION REPORT 05000424/2008005 AND 05000425/2008005
Distribution w/encl:
C. Evans, RII EICS (Part 72 Only)
L. Slack, RII EICS (Linda Slack)
OE Mail (email address if applicable)
RIDSNRRDIRS
PUBLIC
R. Martin, NRR (PM: HAT, SUM)
17
Section 12; TS Sections 5.4 and 5.7; 10 CFR Parts 19 and 20; and approved licensee
procedures. Documents reviewed are listed in the report Attachment. The inspectors
completed 21 of the required line-item samples described in Inspection Procedure (IP)
Problem Identification and Resolution. The inspectors reviewed corrective action
program (CAP) documents associated with access control to radiologically significant
areas. This included review of selected CRs related to radworker and HPT
performance. The inspectors evaluated the licensees ability to identify, characterize,
prioritize, and resolve the identified issues in accordance with procedure NMP-GM-002.
The inspectors also evaluated the scope of the licensees internal audit program and
reviewed recent assessment results. Documents reviewed are listed in the Attachment.
b. Findings
Introduction: Two examples of a Green, self-revealing, non-cited violation (NCV) of TS 5.7.1, High Radiation Area, were identified for unauthorized entries into HRAs.
Inadequate communication between workers and HP resulted in licensee personnel
breaching HRA boundaries without prior knowledge of the radiological condition.
Description: On May 9, 2007, a Shift Operator (SO) performed a visual inspection in the
Unit 2 Residual Heat Removal Pump Room A. This room contained both a Radiation
Area (RA) and a posted and barricaded HRA. The SO contacted HP prior to entering
the room, but failed to communicate that entry into the HRA might be required. As a
result, HP briefed the SO on current radiological conditions outside the rope barricade
and not on conditions inside the HRA. The assigned RWP did not allow entry into HRAs
without first obtaining a briefing on the HRA radiological conditions. Typically, this
inspection does not require the SO to pass the HRA boundary, however insulation
obstructed the SOs view from outside the HRA. Without knowledge of dose rates in the
HRA, the SO proceeded past the HRA boundary and subsequently received an ED dose
rate alarm. Dose rates inside the area were as high as 160 mrem/hr.
On August 16, 2007, two Facilities personnel entered the Unit 2 Fuel Handling Building
room 2-FHB-A-01 to perform cleaning duties and replace light bulbs. This area
contained a Contaminated Area (CA), RA, and a posted and barricaded HRA. Prior to
starting work, the personnel were briefed by HP on radiological conditions in the CA and
RA, but not on dose rates in the HRA. There was no clear understanding between the
two groups that a HRA entry would be required. The assigned RWP did not allow entry
into HRAs without first obtaining a briefing on the HRA conditions. Without knowledge of
dose rates in the HRA, one worker proceeded past the HRA boundary in room 2-FHB-A-
01 to continue the housekeeping activities and received an ED dose rate alarm. Dose
rates in the area were as high as 238 mrem/hr at 30cm.
Analysis: The inspectors determined that the unauthorized entries into HRAs were
performance deficiencies. This finding is greater than minor because it is associated
with the Occupational Radiation Safety Cornerstone attribute of Human Performance
and adversely affects the cornerstone objective of ensuring adequate protection of
worker health and safety from exposure to radiation from radioactive material during
routine civilian nuclear reactor operation. Workers who enter HRAs without prior
knowledge of current radiological conditions could receive unintended occupational
exposures. The finding was evaluated using the Occupational Radiation Safety SDP
Enclosure 1
18
and determined to be of very low safety significance (Green). The finding was not
related to ALARA planning, nor did it involve an overexposure or substantial potential for
overexposure, and the ability to assess dose was not compromised. This finding
involved the cross-cutting aspect of Human Performance, Work Practices H.4.a]
because the HRA events were a direct result of poor communications during pre-job
briefings and a willingness on the part of licensee personnel to proceed in the face of
uncertainty.
Enforcement: TS 5.7.1, High Radiation Area, requires individuals entering HRAs to
meet one or more of the following criteria: 1) carry a survey meter; 2) wear an ED and be
made aware of radiological conditions in the area; or 3) be escorted by a HP technician.
Contrary to the above, on May 9, 2007, and on August 16, 2007, plant personnel
entered HRAs without a survey meter, without being aware of radiological conditions in
the area, or without HP technician escort. Because the violation is of very low safety
significance and has been entered into the licensees CAP (CR 2007105476 and CR
2007108830), this violation is being treated as an NCV, consistent with Section VI.A of
the NRC Enforcement Policy: NCV 05000424/425, 2008005-01, Unauthorized Entries
Into High Radiation Areas.
2OS2 ALARA Planning and Controls
a. Inspection Scope
The inspectors reviewed ALARA program guidance and its implementation for ongoing
2R13 job tasks. The inspectors evaluated the accuracy of ALARA work planning and
dose budgeting, observed implementation of ALARA initiatives and radiation controls for
selected jobs in-progress, assessed the effectiveness of source-term reduction efforts,
and reviewed historical dose information.
ALARA planning documents and procedural guidance were reviewed and projected
dose estimates were compared to actual dose expenditures for the following high dose
jobs: scaffolding installation/removal, reactor vessel head work, steam generator
maintenance activities, motor operated valve (MOV) testing and maintenance, and
installation of the external neutron monitoring system inside containment. Differences
between budgeted dose and actual exposure received were discussed with cognizant
ALARA staff. Changes to dose budgets relative to changes in radiation source term
and/or job scope were also discussed. The inspectors attended pre-job briefings and
evaluated the communication of ALARA goals, RWP requirements, and industry
lessons-learned to job crew personnel.
The inspectors made direct field or closed-circuit-video observations of outage job tasks
involving work inside Unit 2 containment. For the selected tasks, the inspectors
evaluated radworker and HPT job performance, individual and collective dose
expenditure versus percentage of job completion, surveys of the work areas,
appropriateness of RWP requirements, and adequacy of implemented administrative
and physical controls.
Implementation and effectiveness of selected program initiatives with respect to source-
term reduction were evaluated. Chemistry program ALARA initiatives and their effect on
containment and auxiliary building dose rate trends were reviewed.
Enclosure 1
19
Plant exposure history for 2005 through 2008 year-too-date, and data reported to the
NRC pursuant to 10 CFR 20.2206 were reviewed, as were established goals for
reducing collective exposure during the current 2R13 outage. The inspectors reviewed
procedural guidance for dosimetry issuance and exposure tracking. The inspectors also
examined dose records of declared pregnant workers to evaluate assignment of
gestation dose.
ALARA program activities and their implementation were reviewed against 10 CFR Part
20, and approved licensee procedures. In addition, licensee performance was evaluated
against guidance contained in Regulatory Guide (RG) 8.8, Information Relevant to
Ensuring that Occupational Radiation Exposures at Nuclear Power Stations will be As
Low As Reasonably Achievable, and RG 8.13, Instruction Concerning Prenatal
Radiation Exposure. Documents reviewed are listed in of the Attachment. The
inspectors completed 20 samples of specified line-items in IP 71121.02 to close the
procedure.
Problem Identification and Resolution. The inspectors reviewed selected CR and Action
Item (AI) data in the area of exposure control. The inspectors evaluated the licensees
ability to identify, characterize, prioritize, and resolve the identified issues in accordance
with NMP-GM-002. The inspectors also evaluated the scope of the licensees internal
audit program and reviewed recent assessment results. Documents reviewed are listed
in the Attachment.
b. Findings
No findings of significance were identified.
Cornerstone: Public Radiation Safety
2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems
a. Inspection Scope
Groundwater Monitoring. The inspectors discussed current and future programs for
onsite groundwater monitoring with chemistry specialists and corporate staff, including
number and placement of monitoring wells and identification of plant systems with the
greatest potential for contaminated leakage. The inspectors also reviewed procedural
guidance for identifying and assessing onsite spills and leaks of contaminated fluids. In
addition, the inspectors reviewed records of historical and recent contaminated spills
retained for decommissioning purposes as required by 10 CFR Part 50.75(g).
The licensee has installed a number of onsite groundwater monitoring wells; optimally
located to detect contamination based on recent hydrological studies. The sample
results from these wells were included in the Annual Radiological Environmental
Monitoring Program Report. For the period reviewed, all monitoring well results were
below reporting limits (20,000 pCi/L for drinking water and 30,000 pCi/L for non-drinking
water).
b. Findings
No findings of significance were identified.
Enclosure 1
20
2PS2 Radioactive Material Processing and Transportation
a. Inspection Scope
Waste Processing and Characterization During inspector walk-downs, accessible
sections of the liquid and solid radwaste processing systems were assessed for material
condition and conformance with system design diagrams. Inspected equipment included
floor drain tanks; resin transfer piping; resin and filter packaging components; and
abandoned evaporator equipment. The inspectors discussed component function,
processing system changes, and radwaste program implementation with licensee staff.
The 2007 Effluent Report and radionuclide characterizations from 2007 - 2008 for each
major waste stream were reviewed and discussed with radwaste staff. For primary
filters and Dry Active Waste (DAW) the inspectors evaluated analyses for hard-to-detect
nuclides, reviewed the use of scaling factors, and examined comparison results between
licensee waste stream characterizations and outside laboratory data. Waste stream
mixing and concentration averaging methodology for spent resin and primary filters were
evaluated and discussed with radwaste operators. The inspectors also reviewed the
licensees procedural guidance for monitoring changes in waste stream isotopic
mixtures.
Radwaste processing activities and equipment configuration were reviewed for
compliance with the licensees Process Control Program and UFSAR, Chapter 11.
Waste stream characterization analyses were reviewed against regulations detailed in
10 CFR Part 20, 10 CFR Part 61, and guidance provided in the Branch Technical
Position on Waste Classification and Waste Form. Reviewed documents are listed in
Section 2PS2 of the report Attachment.
Transportation The inspectors directly observed preparation activities for a shipment of
contaminated laundry. The inspectors noted package markings and placarding,
observed dose rate measurements, and interviewed shipping technicians regarding
Department of Transportation (DOT) regulations.
Five shipping records were reviewed for consistency with licensee procedures and
compliance with NRC and DOT regulations. The inspectors reviewed emergency
response information, DOT shipping package classification, radiation survey results, and
evaluated whether licensees in receiving were authorized to accept the packages.
Procedures for opening and closing Type B shipping casks were compared to Certificate
of Compliance requirements. In addition, training records for selected individuals
currently qualified to facilitate the shipment of radioactive material were reviewed.
Transportation program implementation was reviewed against regulations detailed in 10
CFR Part 20, 10 CFR Part 71, 49 CFR Parts 172-178; as well as the guidance provided
in NUREG-1608, Categorizing and Transporting Low Specific Activity Materials and
Surface Contaminated Objects. Training activities were assessed against 49 CFR Part
172 Subpart H. Documents reviewed are listed in the Attachment. The inspectors
completed 6 of 6 samples as required by IP 71122.02.
Problem Identification and Resolution Selected CRs in the area of radwaste processing
and transportation were reviewed in detail and discussed with licensee personnel. The
Enclosure 1
21
inspectors assessed the licensees ability to characterize, prioritize, and resolve the
identified issues in accordance with licensee procedure NMP-GM-002. The inspectors
also evaluated the scope of the licensees internal audit program and reviewed recent
assessment results. Licensee CAP documents reviewed are listed in Section 2PS2 of
the report Attachment.
b. Findings
No findings of significance were identified.
4. OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
a. Inspection Scope
The inspectors sampled licensee submittals for the listed PIs during the period from
July 1, 2007 through June 30, 2008, for Unit 1 and Unit 2. The inspectors verified the
licensees basis in reporting each data element using the PI definitions and guidance
contained in procedure 00163-C, NRC Performance Indicator and Monthly Operating
Report Preparation and Submittal, and Nuclear Energy Institute document NEI 99-02,
Regulatory Assessment Indicator Guideline.
Cornerstone: Mitigating Systems
C Mitigating Systems Performance Index (MSPI), Cooling Water Systems
C MSPI, Emergency AC Power Systems
C Safety System Functional Failures
The inspectors reviewed Unit 1 and Unit 2 operator log entries, the Vogtle Electric
Generating Plant Unit 1 and Unit 2 NRC Mitigating System Performance Index Basis
Document, the monthly operating reports and monthly PI summary reports to verify that
the licensee had accurately submitted the PI data.
Cornerstone: Occupational Radiation Safety
- Occupational Exposure Control Effectiveness
The inspectors reviewed PI data collected from January 1, 2007, through September 30,
2008. For the reviewed period, the inspectors assessed CAP records to determine
whether HRA, VHRA, or unplanned exposures, resulting in TS or 10 CFR 20 non-
conformances, had occurred during the review period. In addition, the inspectors
reviewed selected personnel contamination event data, internal dose assessment
results, and ED alarms for cumulative doses and/or dose rates exceeding established
set-points. Documents reviewed are listed in the Attachment.
Cornerstone: Public Radiation Safety
- Radiological Control Effluent Release Occurrences
The inspectors reviewed the PI results for the period of January 1, 2007, through
September 30, 2008. For the assessment period, the inspectors reviewed cumulative
and projected doses to the public, out-of-service effluent radiation monitors and
compensatory sampling data. The inspectors also reviewed licensee procedural
Enclosure 1
22
guidance for collecting and documenting PI data. Documents reviewed are listed in the
Attachment.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
.1 Daily Condition Report Review. As required by Inspection Procedure 71152,
Identification and Resolution of Problems, and in order to help identify repetitive
equipment failures or specific human performance issues for follow-up, the inspectors
performed a daily screening of items entered into the licensees corrective action
program. This review was accomplished by either attending daily screening meetings
that briefly discussed major CRs, or accessing the licensees computerized corrective
action database and reviewing each CR that was initiated.
.2 Focused Review
a. Inspection Scope
The inspectors performed a detailed review of the work-around lists for Unit 1 and 2 that
were in effect on October 28. The inspectors reviewed the licensees list to determine
whether any items would adversely affect the operators ability to implement abnormal or
emergency operating procedures. The inspectors reviewed proposed corrective actions
and schedule for each item on the work-around list. The inspectors reviewed the
compensatory actions and cumulative effects on plant operation. The inspectors verified
each item was being dispositioned in accordance with plant procedure 10025-C, Work
Around Program. Documents reviewed are listed in the Attachment.
b. Findings and Observations
No findings of significance were identified.
Enclosure 1
17
Section 12; TS Sections 5.4 and 5.7; 10 CFR Parts 19 and 20; and approved licensee
procedures. Documents reviewed are listed in the report Attachment. The inspectors
completed 21 of the required line-item samples described in Inspection Procedure (IP)
Problem Identification and Resolution The inspectors reviewed corrective action
program (CAP) documents associated with access control to radiologically significant
areas. This included review of selected CRs related to radworker and HPT
performance. The inspectors evaluated the licensees ability to identify, characterize,
prioritize, and resolve the identified issues in accordance with procedure NMP-GM-002.
The inspectors also evaluated the scope of the licensees internal audit program and
reviewed recent assessment results. Documents reviewed are listed in the Attachment.
b. Findings
Introduction. Two examples of a Green, self-revealing, non-cited violation (NCV) of TS 5.7.1, High Radiation Area, was identified for unauthorized entries into HRAs.
Inadequate communication between workers and HP resulted in licensee personnel
breaching HRA boundaries without prior knowledge of the radiological condition.
Description On May 9, 2007, a Shift Operator (SO) performed a visual inspection in the
Unit 2 Residual Heat Removal Pump Room A. This room contained both a Radiation
Area (RA) and a posted and barricaded HRA. The SO contacted HP prior to entering
the room, but failed to communicate that entry into the HRA might be required. As a
result, HP briefed the SO on current RA radiological conditions. The assigned RWP did
not allow entry into HRAs without first obtaining a briefing on the HRA radiological
conditions. Typically, this inspection does not require the SO to pass the HRA boundary;
however, insulation obstructed the SOs view from outside the HRA. Without knowledge
of dose rates in the HRA, the SO proceeded past the HRA boundary and subsequently
received an ED dose rate alarm.
On August 16, 2007, two Facilities personnel entered the Unit 2 Fuel Handling Building
room 2-FHB-A-01 to perform cleaning duties and replace light bulbs. This area
contained a Contaminated Area (CA), RA, and a posted and barricaded HRA. Prior to
starting work, the personnel were briefed by HP on radiological conditions in the CA and
RA. There was no clear understanding between the two groups that a HRA entry would
be required. The assigned RWP did not allow entry into HRAs without first obtaining a
briefing on the HRA conditions. Without knowledge of dose rates in the HRA, one
worker proceeded past the HRA boundary in room 2-FHB-A-01 to continue the
housekeeping activities and received an ED dose rate alarm.
Analysis The inspectors determined that the unauthorized entries into HRAs were
performance deficiencies. This finding is greater than minor because it is associated
with the Occupational Radiation Safety Cornerstone attribute of Human Performance
and adversely affects the cornerstone objective in that workers who enter HRAs without
prior knowledge of current radiological conditions could receive unintended occupational
exposures. The finding was evaluated using the Occupational Radiation Safety SDP
and determined to be of very low safety significance (Green). The finding was not
related to ALARA planning, nor did it involve an overexposure or substantial potential for
overexposure, and the ability to assess dose was not compromised. This finding
involved the cross-cutting aspect of Human Performance, Work Practices H.4.a]
Enclosure 2
18
because the HRA events were a direct result of poor communications during pre-job
briefings and a willingness on the part of licensee personnel to proceed in the face of
uncertainty.
Enforcement TS 5.7.1, High Radiation Area, requires individuals entering HRAs to meet
one or more of the following criteria: 1) carry a survey meter; 2) wear an ED and be
made aware of radiological conditions in the area; or 3) be escorted by a HP technician.
Contrary to the above, on May 9, 2007, and on August 16, 2007, plant personnel
entered HRAs without a survey meter, without being aware of radiological conditions in
the area, or without HP technician escort. Because the violation is of very low safety
significance and has been entered into the licensees CAP (CR 2007105476 and CR
2007108830), this violation is being treated as an NCV, consistent with Section VI.A of
the NRC Enforcement Policy: NCV 05000424/425, 2008005-01, Unauthorized Entries
Into High Radiation Areas.
2OS2 ALARA Planning and Controls
a. Inspection Scope
The inspectors reviewed ALARA program guidance and its implementation for ongoing
2R13 job tasks. The inspectors evaluated the accuracy of ALARA work planning and
dose budgeting, observed implementation of ALARA initiatives and radiation controls for
selected jobs in-progress, assessed the effectiveness of source-term reduction efforts,
and reviewed historical dose information.
ALARA planning documents and procedural guidance were reviewed and projected
dose estimates were compared to actual dose expenditures for the following high dose
jobs: scaffolding installation/removal, reactor vessel head work, steam generator
maintenance activities, motor operated valve (MOV) testing and maintenance, and
installation of the external neutron monitoring system inside containment. Differences
between budgeted dose and actual exposure received were discussed with cognizant
ALARA staff. Changes to dose budgets relative to changes in radiation source term
and/or job scope were also discussed. The inspectors attended pre-job briefings and
evaluated the communication of ALARA goals, RWP requirements, and industry
lessons-learned to job crew personnel.
The inspectors made direct field or closed-circuit-video observations of outage job tasks
involving work inside Unit 2 containment. For the selected tasks, the inspectors
evaluated radworker and HPT job performance, individual and collective dose
expenditure versus percentage of job completion, surveys of the work areas,
appropriateness of RWP requirements, and adequacy of implemented administrative
and physical controls.
Implementation and effectiveness of selected program initiatives with respect to source-
term reduction were evaluated. Chemistry program ALARA initiatives and their effect on
containment and auxiliary building dose rate trends were reviewed.
Plant exposure history for 2005 through 2008 year-too-date, and data reported to the
NRC pursuant to 10 CFR 20.2206 were reviewed, as were established goals for
reducing collective exposure during the current 2R13 outage. The inspectors reviewed
procedural guidance for dosimetry issuance and exposure tracking. The inspectors also
Enclosure 2
19
examined dose records of declared pregnant workers to evaluate assignment of
gestation dose.
ALARA program activities and their implementation were reviewed against 10 CFR Part
20, and approved licensee procedures. In addition, licensee performance was evaluated
against guidance contained in Regulatory Guide (RG) 8.8, Information Relevant to
Ensuring that Occupational Radiation Exposures at Nuclear Power Stations will be As
Low As Reasonably Achievable, and RG 8.13, Instruction Concerning Prenatal
Radiation Exposure. Documents reviewed are listed in of the Attachment. The
inspectors completed 20 samples of specified line-items in IP 71121.02 to close the
procedure.
Problem Identification and Resolution. The inspectors reviewed selected CR and Action
Item (AI) data in the area of exposure control. The inspectors evaluated the licensees
ability to identify, characterize, prioritize, and resolve the identified issues in accordance
with NMP-GM-002. The inspectors also evaluated the scope of the licensees internal
audit program and reviewed recent assessment results. Documents reviewed are listed
in the Attachment.
b. Findings
No findings of significance were identified.
Cornerstone: Public Radiation Safety
2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems
c. Inspection Scope
Groundwater Monitoring. The inspectors discussed current and future programs for
onsite groundwater monitoring with chemistry specialists and corporate staff, including
number and placement of monitoring wells and identification of plant systems with the
greatest potential for contaminated leakage. The inspectors also reviewed procedural
guidance for identifying and assessing onsite spills and leaks of contaminated fluids. In
addition, the inspectors reviewed records of historical and recent contaminated spills
retained for decommissioning purposes as required by 10 CFR Part 50.75(g).
The licensee has installed a number of onsite groundwater monitoring wells; optimally
located to detect contamination based on recent hydrological studies. The sample
results from these wells were included in the Annual Radiological Environmental
Monitoring Program Report. For the period reviewed, all monitoring well results were
below reporting limits (20,000 pCi/L for drinking water and 30,000 pCi/L for non-drinking
water).
d. Findings
No findings of significance were identified.
Enclosure 2
20
2PS2 Radioactive Material Processing and Transportation
a. Inspection Scope
Waste Processing and Characterization During inspector walk-downs, accessible
sections of the liquid and solid radwaste processing systems were assessed for material
condition and conformance with system design diagrams. Inspected equipment included
floor drain tanks; resin transfer piping; resin and filter packaging components; and
abandoned evaporator equipment. The inspectors discussed component function,
processing system changes, and radwaste program implementation with licensee staff.
The 2007 Effluent Report and radionuclide characterizations from 2007 - 2008 for each
major waste stream were reviewed and discussed with radwaste staff. For primary
filters and Dry Active Waste (DAW) the inspectors evaluated analyses for hard-to-detect
nuclides, reviewed the use of scaling factors, and examined comparison results between
licensee waste stream characterizations and outside laboratory data. Waste stream
mixing and concentration averaging methodology for spent resin and primary filters were
evaluated and discussed with radwaste operators. The inspectors also reviewed the
licensees procedural guidance for monitoring changes in waste stream isotopic
mixtures.
Radwaste processing activities and equipment configuration were reviewed for
compliance with the licensees Process Control Program and UFSAR, Chapter 11.
Waste stream characterization analyses were reviewed against regulations detailed in
10 CFR Part 20, 10 CFR Part 61, and guidance provided in the Branch Technical
Position on Waste Classification and Waste Form. Reviewed documents are listed in
Section 2PS2 of the report Attachment.
Transportation The inspectors directly observed preparation activities for a shipment of
contaminated laundry. The inspectors noted package markings and placarding,
observed dose rate measurements, and interviewed shipping technicians regarding
Department of Transportation (DOT) regulations.
Five shipping records were reviewed for consistency with licensee procedures and
compliance with NRC and DOT regulations. The inspectors reviewed emergency
response information, DOT shipping package classification, radiation survey results, and
evaluated whether licensees in receiving were authorized to accept the packages.
Procedures for opening and closing Type B shipping casks were compared to Certificate
of Compliance requirements. In addition, training records for selected individuals
currently qualified to facilitate the shipment of radioactive material were reviewed.
Transportation program implementation was reviewed against regulations detailed in 10
CFR Part 20, 10 CFR Part 71, 49 CFR Parts 172-178; as well as the guidance provided
in NUREG-1608, Categorizing and Transporting Low Specific Activity Materials and
Surface Contaminated Objects. Training activities were assessed against 49 CFR Part
172 Subpart H. Documents reviewed are listed in the Attachment. The inspectors
completed 6 of 6 samples as required by IP 71122.02.
Problem Identification and Resolution Selected CRs in the area of radwaste processing
and transportation were reviewed in detail and discussed with licensee personnel. The
inspectors assessed the licensees ability to characterize, prioritize, and resolve the
Enclosure 2
21
identified issues in accordance with licensee procedure NMP-GM-002. The inspectors
also evaluated the scope of the licensees internal audit program and reviewed recent
assessment results. Licensee CAP documents reviewed are listed in Section 2PS2 of
the report Attachment.
b. Findings
No findings of significance were identified.
4. OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
a. Inspection Scope
The inspectors sampled licensee submittals for the listed PIs during the period from
July 1, 2007 through June 30, 2008, for Unit 1 and Unit 2. The inspectors verified the
licensees basis in reporting each data element using the PI definitions and guidance
contained in procedure 00163-C, NRC Performance Indicator and Monthly Operating
Report Preparation and Submittal, and Nuclear Energy Institute document NEI 99-02,
Regulatory Assessment Indicator Guideline.
Cornerstone: Mitigating Systems
C Mitigating Systems Performance Index (MSPI), Cooling Water Systems
C MSPI, Emergency AC Power Systems
C Safety System Functional Failures
The inspectors reviewed Unit 1 and Unit 2 operator log entries, the Vogtle Electric
Generating Plant Unit 1 and Unit 2 NRC Mitigating System Performance Index Basis
Document, the monthly operating reports and monthly PI summary reports to verify that
the licensee had accurately submitted the PI data.
Cornerstone: Occupational Radiation Safety
- Occupational Exposure Control Effectiveness
The inspectors reviewed PI data collected from January 1, 2007, through September 30,
2008. For the reviewed period, the inspectors assessed CAP records to determine
whether HRA, VHRA, or unplanned exposures, resulting in TS or 10 CFR 20 non-
conformances, had occurred during the review period. In addition, the inspectors
reviewed selected personnel contamination event data, internal dose assessment
results, and ED alarms for cumulative doses and/or dose rates exceeding established
set-points. Documents reviewed are listed in the Attachment.
Cornerstone: Public Radiation Safety
- Radiological Control Effluent Release Occurrences
The inspectors reviewed the PI results for the period of January 1, 2007, through
September 30, 2008. For the assessment period, the inspectors reviewed cumulative
and projected doses to the public, out-of-service effluent radiation monitors and
compensatory sampling data. The inspectors also reviewed licensee procedural
Enclosure 2
22
guidance for collecting and documenting PI data. Documents reviewed are listed in the
Attachment.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
.1 Daily Condition Report Review. As required by Inspection Procedure 71152,
Identification and Resolution of Problems, and in order to help identify repetitive
equipment failures or specific human performance issues for follow-up, the inspectors
performed a daily screening of items entered into the licensees corrective action
program. This review was accomplished by either attending daily screening meetings
that briefly discussed major CRs, or accessing the licensees computerized corrective
action database and reviewing each CR that was initiated.
.2 Focused Review
a. Inspection Scope
The inspectors performed a detailed review of the work-around lists for Unit 1 and 2 that
were in effect on October 28. The inspectors reviewed the licensees list to determine
whether any items would adversely affect the operators ability to implement abnormal or
emergency operating procedures. The inspectors reviewed proposed corrective actions
and schedule for each item on the work-around list. The inspectors reviewed the
compensatory actions and cumulative effects on plant operation. The inspectors verified
each item was being dispositioned in accordance with plant procedure 10025-C, Work
Around Program. Documents reviewed are listed in the Attachment.
b. Findings and Observations
No findings of significance were identified.
Enclosure 2