ML20309A201

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Radiation Safety Baseline Inspection Information Request
ML20309A201
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 11/04/2020
From: Kellner R
NRC/RGN-II
To:
References
IR 2020004
Download: ML20309A201 (6)
v • d • e


Text

ML20309A201 Harris Nuclear Plant Radiation Safety Baseline Inspection Initial Information Request Inspection Report: 2020004 During the week of November 16 - 20, 2020, the Nuclear Regulatory Commission (NRC) will perform a baseline Radiation Safety Inspection at the Harris Nuclear Plant (NRC Inspection Procedures 71124.01, 71124.06, 71124.07, 71124.08, and 71151).

Experience has shown that this inspection is resource-intensive for both the NRC inspectors and your staff. In order to minimize the impact to your onsite resources and to ensure a productive inspection, we are requesting in advance documents needed for this activity. It is important that these documents are up-to-date, and complete, thereby minimizing the number of additional documents requested during the preparation, and/or the onsite portions of the inspection. The NRC requests that these documents be provided to the inspectors no later than November 6, 2020.

If there are any questions about this inspection or the material requested, please contact the lead inspector, Robert Kellner, at Robert.Kellner@nrc.gov, or 404-997-4508, or the Engineering Branch 3 Chief, Binoy Desai at 404-997-4519.

In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this document will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRC's Agencywide Document Access and Management System (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.

PAPERWORK REDUCTION ACT STATEMENT This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, control number 3150-0008, 3150-0011, 3150-0014, 3150-0044, and 3150-0135.

PUBLIC PROTECTION NOTIFICATION The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Office of Management and Budget control number.

Document Request List Occupational and Public Radiation Safety Cornerstones Inspection Dates: November 16-20, 2020 Documents Due to Region II by: November 6, 2020 Inspection Procedures: IP 71124.01 Radiological Hazard Assessment and Exposure Controls IP 71124.06 Gaseous and Liquid Effluent IP 71124.07 REMP IP 71124.08 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation IP 71151 Performance Indicator Verification Lead Inspector and Mailing Address:

Robert Kellner U.S. Nuclear Regulatory Commission Senior Health Physicist Region II US NRC Region II ATTN: Robert Kellner (404) 997-4508 245 Peachtree Center Ave., N.E Robert.Kellner@nrc.gov Suite 1200 Atlanta, GA 30303 Note: The current version of these documents is expected unless specified otherwise. Secure file server access (Certrec, SharePoint, etc.), or electronic media (CD/DVD), is preferred. To the extent possible, please organize the information as it is arranged below. Experience has shown that poorly organized files can lead to a less efficient inspection and places additional burden on licensee staff. During the inspection, the inspectors may request additional documents. If there are questions regarding the documents requested, or if the documents cannot be provided by the due date, please do not hesitate to contact the lead inspector. To the extent possible, please organize the information as it is arranged below. Pay attention to the date ranges for the items requested as they may change from item to item. If there are questions regarding the documents requested, or if the documents cannot be provided by the due date, please do not hesitate to contact the lead inspector.

Documentation for these inspection procedures, are requested from April 1, 2018 to present, unless otherwise specified. Pay attention to the date ranges for the items requested as they may change from item to item. For those items requesting a list of documents/areas, the inspector will select documents/areas from the list for on-site review. The NRC requests that these documents be provided to the inspectors no later than November 6, 2020.

Miscellaneous

1. Plant Management, Radiation Protection, and Chemistry organizational charts with contact telephone numbers Page 1
2. List of primary contacts for each inspection area w/phone numbers
3. Corrective Action Program (CAP) procedure(s)
4. List of radiation protection procedures including title and number 71124.01 - Radiological Hazard Assessment and Exposure Controls (Last inspected November 2019)
1. List of active Radiation Work Permits (RWPs) (including dose and dose rate limits).
2. Site and corporate procedures related to health physics (HP) controls (e.g., posting, labeling, surveys, RWPs, contamination control, high radiation area (HRA)/LHRA/VHRA control, key control, control of divers, special controls during fuel offload, hot spots, etc.)
3. Procedures related to release of personnel and materials (e.g. release surveys, decontamination, guidance for alarm follow-up, etc.)
4. List of non-fuel items stored in spent fuel pool (SFP)
5. List of locations, or plant maps indicating the location, of locked high radiation areas (LHRAs) and very high radiation areas (VHRAs), including areas with the potential to become a LHRA during routine operations or outages
6. Most recent survey of LHRAs and VHRAs (as applicable).
7. Self-assessments or audits covering radiological hazard assessment and exposure controls and HP controls since November 1, 2019 (if none, then provide the most recent).
8. Corrective Action Program (CAP) documents (CR, NRC, AR, etc.) related to RP controls (e.g., radworker error, HP technician error, posting issues, radioactive source controls, HRA/LHRA/VHRA issues, survey problems, etc.) generated since November 1, 2019. This should be a list of corrective action documents containing a CAP document number and a brief description, not complete documents.

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment (Last inspected December 2018)

1. Procedures for sampling and controlling radioactive gaseous and liquid effluents to include:

collection, analysis, release, alarm setpoints, offsite dose calculation and evaluation.

2. Provide a list of changes made to the Offsite Dose Calculation Manual (ODCM),

meteorological dispersion or deposition factors, and radioactive effluent processing/discharge systems since December 1, 2018.

3. List of out of service (OOS) effluent monitors and duration since December 1, 2018.
4. Most Recent 10 CFR Part 61 analyses for the Dry Active Waste (DAW) including QA data (e.g. in-house vs. vendor lab comparisons, current results vs. database, etc.)
5. List of unmonitored spills, leaks, or unexpected liquid/gaseous discharges since December 1, 2018.
6. Provide a schedule of expected or planned routine effluent sampling activities (e.g. weekly main vent stack, groundwater sampling, etc.) during the planned inspection week.
7. Material condition surveillance records for effluent treatment system components not readily accessible for any reason (e.g. in-service & spent resin tanks, waste gas hold-up tanks, etc.).
8. The last two inter-laboratory comparison program results (for the onsite counting lab).
9. Most recent audit, self-assessment, and/or review of the radioactive effluent monitoring program Page 2
10. List of CAP documents generated since December 1, 2018, as a result of gaseous and liquid effluent processing and/or ODCM related activities. This should be a list of documents containing a CAP document number and a brief description, not complete documents.

71124.07 - Radiological Environment Monitoring Program (REMP)

(Last inspected December 2018)

1. Procedures for radiological environmental monitoring, including but not limited to:
  • Collection, preparation and analysis of environmental samples
  • Calibration and maintenance of REMP air and/or water samplers
  • Calibration of meteorological monitoring instruments
  • Periodic meteorological instrumentation surveillance requirements
  • Land use census
  • Calibration and quality control of for sample counting instruments
2. Procedures associated with the NEI/industry groundwater protection initiative.
3. 2018, 2019, and 2020 Land Use Census Results Evaluation or Report.
4. Collection schedule for REMP samples to be obtained during the planned inspection week, and contact information for collection staff.
5. Last two calibration records for ALL REMP air and water sampling equipment.
6. Last two calibration records for meteorological monitoring instrumentation on the primary tower (wind speed & direction, and air temperature).
7. Data recovery report for meteorological monitoring instruments since December 1, 2018.
8. List of systems, structures and components identified as credible mechanisms for the potential release of licensed material to the groundwater (e.g. SSC risk ranking matrix)
9. List of any non-radioactive system that has become contaminated since December 1, 2018.
10. Summary of any leaks and/or spills that have occurred since December 1, 2018 (e.g. copy of 10.75g file).
11. Copies of any reports to the NRC regarding abnormal onsite spills/leaks or radioactive material since December 1, 2018.
12. Groundwater monitoring results since December 1, 2018.
13. Environmental TLD results since December 1, 2018.
14. List of onsite surface water bodies (e.g. ponds, retention basins, lakes) that contain or can potentially contain radioactivity
15. Most recent audit/self-assessments of REMP activities, including audits of vendor activities.
16. List of CAP documents related to REMP activities or groundwater, including leaks or spills since December 1, 2018. This should be a list of documents containing a CAP document number and a brief description, not complete documents.

71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation (Last inspected April 2018)

1. Provide procedures/guidance documents describing licensee compliance with 10 CFR 20, 61, and 71, and 49 CFR 170-189. Procedures/manuals should include:
  • Solid and liquid radioactive waste (radwaste) processing procedures
  • Procedure(s) for transferring radwaste resin and sludge discharges into shipping/disposal containers
  • Waste stream mixing and/or sampling procedures, including:

Page 3

a. waste concentration averaging
b. use of scaling factors and calculations used to account for difficult-to-measure radionuclides
c. 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
  • Monitoring impact of long-term storage of RAM
2. Site specific and corporate procedures related to 10 CFR Part 37 compliance (storage of RAM, 10 CFR Part 37 Security Plan, radiation protection and security procedures that identify radiation protection interaction with security, or requirements related to 10 CFR Part 37 compliance, etc.)
3. List of locations of Category 1 and 2 material.
4. Supporting calculations for determination of whether an aggregation of RAM meets the definition of Category 1 or Category 2 (e.g., warehouse calculation).
5. List of Nationally Tracked Sources, and copies of any National Source Tracking System (NSTS) transaction documentation (e.g., annual reconciliation).
6. Copies of the two most recent sealed source inventory records.
7. Most recent radio-chemical sample analysis results (i.e., 10 CFR Part 61" analysis) for each of the radwaste streams (e.g., dry active waste (DAW), ion exchange resins, mechanical filters, and sludges and activated materials).
8. List and documentation of any changes made to the radwaste processing systems (liquid and solid) and/or the PCP since April 1, 2018, and associated 10 CFR 50.59 documentation, as appropriate
9. Copies of applicable transport cask Certificate of Compliance for the last three transport cask shipments
10. List of RAM storage areas, including satellite radiological controlled areas (RCAs)
11. Log of RAM shipments (LSA I, II, IIII; SCO I, II, Type A, or Type B) since April 1, 2018. (The inspectors will select three to five packages to review in detail.)
12. Most recent self-assessment or audit of Shipping/radwaste processing and RAM storage programs
13. List of CAP documents (AR, CR, NCR, etc.) related to involving radwaste and RAM processing and/or transportation (e.g., keyword searches for RAM, shipping, radwaste, 10 Part 61, etc.) issued since April 1, 2018. This should be a list of corrective action documents containing an (AR, CR, NCR, etc.) number and brief description, not full documents.
14. Available for onsite review during the inspection
  • Site drawing(s) showing the location of stored RAM and stored radwaste
  • Plant drawings sufficient to permit the inspector to walkdown the liquid and solid radwaste processing systems, to verify current system configuration/ operation agree with the descriptions contained in the Updated Final Safety Analysis Report and in the PCP
  • Training and qualification records for personnel responsible for radwaste processing, packaging, and making shipments of radioactive material (RAM) and radwaste.
  • Training and qualification records for personnel responsible for implementation of the 10 Page 4

CFR Part 37 security plan (e.g., security staff and health physics staff)

  • Documentation describing the status of any radwaste process equipment that is not operational and/or is abandoned in place.
  • Discussion of the sites waste disposal volume and waste reduction program.

71151 - Performance Indicator Verification (Occupational and Public Cornerstones)

(Last inspected November 2019)

1. Site and corporate procedure(s) for gathering and reporting PI data.
2. Copy of the most recent gaseous and liquid effluent release permits indicating the current dose to the public (year-to-date doses).
3. List of CAP documents since November 1, 2019, using keywords such as: HRA, LHRA, VHRA, unintended dose, unlocked LHRA door, etc. This should be a list of corrective action documents containing a CR number and brief description, not full CRs.
4. List of CAP documents related to effluent dose/ODCM issues since November 1, 2019, using keywords such as: abnormal/ unmonitored effluent release, etc. This should be a list of corrective action documents containing a CR number and brief description, not full CRs.
5. List of ED dose and dose rate alarms since November 1, 2019 Onsite Assistance During Inspection
  • Health physics assistance with plant walk-downs of meteorological tower, and gaseous and liquid waste processing systems.
  • Health physics /Chemistry coordination for observation of REMP and effluents sampling activities (REMP Run and on-site effluent samples).
  • Identification of work activities available during the inspection for inspector observations, including notification of pre-job briefings, notification of risk significant work activities, and audio/visual surveillance for remote job coverage
  • Identification of any transportation activities available during the inspection for inspector observations
  • Coordination with security to review the annual access authorization program and security program reviews competed by the site.
  • HP assistance in plant walkdowns of areas identified for storage of Category 1 and 2 materials.

Inspector Contact Information: Mailing Address:

Robert Kellner U.S. Nuclear Regulatory Commission Sr. Health Physicist US NRC Region II (404) 997-4508 ATTN: Mr. Robert Kellner robert.kellner@nrc.gov 245 Peachtree Center Ave., N.E Suite 1200 Atlanta, GA 30303 Page 5

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