ML17349A106

RP Inspection Document Request

ML17349A106
Person / Time
Site:	Hatch
Issue date:	12/15/2017
From:	Kellner R NRC/RGN-II/DRS/EB3
To:	Collins C Southern Nuclear Operating Co
References
IR 2018001
Download: ML17349A106 (6)

Text

ML# XXXXXXXXXX Kellner, Robert From: Kellner, Robert Sent: Friday, December 15, 2017 6:59 AM To: 'Collins, Carl James'

Subject:

Hatch RP Inspection Document Request - February 2018 Attachments: HATCH 2018001 Rad Haz & Trans Document Request.pdf

Jimmy, Per your response to my previous email, you will be the licensing point of contact for the upcoming NRC Radiation Safety Inspection scheduled for the week of February 12 - 16, 2018 at the Hatch Nuclear Plant. Attached is the Initial Information Request and a Document Request List.

The NRC inspectors that will be on-site during the inspection are myself, and William Pursley. Both of us should be up to date on our Southern Company training.

Please let me know that you received this request. If there are any questions about this inspection, or the material requested, please contact me via email, or at the phone number or address included below.

Regards, Bob Robert Kellner Senior Health Physicist USNRC/Region II/DRS/EB3 Marquis One Tower Suite 1200 245 Peachtree Center Ave, NE Atlanta, GA 303031257 (404) 9974508 1

E. I. Hatch Nuclear Plant Radiation Safety Baseline Inspection Initial Information Request Inspection Report: 2018001 During the week of February 12 - 16, 2018, the NRC will perform a baseline Radiation Safety Inspection at the Hatch Nuclear Plant (NRC Inspection Procedures 71124.01, and 71124.08).

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 all of 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 February 2, 2018.

If there are any questions about this inspection or the material requested, please contact the lead inspector, Robert Kellner at 404-997-4508, or the Plant Support Branch 1 Chief, Brian Bonser at 404-997-4653.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 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 Documents Access and Management System (ADAMS); accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.

PAPERWORK REDUCTION ACT STATEMENT This document 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 under control numbers 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 Cornerstone Licensee: E. I. Hatch Nuclear Plant Docket Number: 05000321, 366 Inspection Dates: February 12 - 16, 2018 Documents Due to Region II by: February 2, 2018 Inspection Procedures: IP 71124.01 Radiological Hazard Assessment and Exposure Controls IP 71124.08 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation Lead Inspector: Robert Kellner Sr. Health Physicist US NRC Region II (404) 997-4508 robert.kellner@nrc.gov Note: The current version of these documents is expected unless specified otherwise.

Electronic media is preferred if readily available. [Note that the inspectors cannot accept data provided on USB or flash drives due to NRC IT security policies.] Please organize the information as it is arranged below to the extent possible. 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.

Documentation for these inspection procedures, are requested from February 2017 to present, unless otherwise specified. We would prefer as much of the information as possible in electronic form. An index of the CD contents is also helpful. For those items requesting a list of documents/areas, the inspector will select documents/areas from the list for on-site review.

Miscellaneous

• Listing of primary site contact(s) for each inspection area including name(s) and telephone numbers.

• Corrective Action Program procedures

• Schedule of major maintenance/work activities during the week of the inspection (Gantt chart if available).

Page 2 of 5

71124.01 - Radiological Hazard Assessment and Exposure Controls (Last Inspected February 2017)

1. List of active routine and outage related Radiation Work Permits (RWPs), including their administrative limits, electronic dosimeter dose rate limit, and dose limit.

2. Procedures related to Radiation Protection (RP) controls (e.g. Posting, labeling, surveys, RWPs, contamination control, HRA/LHRA/VHRA control, key control, control of divers, special controls during fuel offload, hot spots, etc.).

3. List of locations, or plant maps indicating the location, of all Locked High Radiation Areas (LHRAs) and Very High Radiation Areas (VHRAs). Include areas with the potential to become a LHRA during routine operations or outages.

4. Copies of the most recent survey of all LHRAs and VHRAs (as applicable).

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

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

7. Copy of the most recent sealed source inventory record.

8. List of all non-fuel items stored in spent fuel pool.

9. All self-assessments and audits covering RP controls since February 1, 2017.

10. List of Corrective Action Program (CAP) documents (CRs, NCRs, PIPs, etc.) related to RP controls (e.g. keyword searches for radworker error, RP technician error, posting issues, HRA/LHRA/VHRA issues, survey problems, etc.) generated since February 1, 2017. This should include CAP nonconformance reports where the cause was listed as human performance. This should be a list of corrective action documents containing a (CR, NCR, etc.) number and brief description, not full documents.

11. All CAP nonconformance reports (AR, CR, NCR, etc.) related to Nationally Tracked Sources since February 1, 2017.

71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation (Last Inspected February 2016)

1. Provide Procedures/Guidance Documents 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.

• List of radioactive material (RAM) storage areas, including satellite radiological controlled areas (RCAs).

• Monitoring impact of long-term storage (e.g., buildup of gases produced by waste decomposition, chemical reactions, container deformation).

• Process Control Program (PCP).

Page 3 of 5

2. Provide a list of RAM storage areas, including satellite radiological controlled areas (RCAs)

3. Provide Liquid and solid radwaste system diagrams and detailed system descriptions (e.g., information that might be contained in curricula for training new system engineers)

4. Provide the 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, sludges, and activated materials).

5. List and documentation of any changes made to the radioactive waste processing systems (liquid and solid) and/or the Process Control Program (PCP) since the June 1, 2015, and associated 10 CFR 50.59 documentation, as appropriate.

6. Provide a log of RAM shipments (LSA I, II, IIII; SCO I, II, Type A, or Type B) since February 1, 2016. (The inspectors will select three to five packages to review in detail.)

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

8. List of CAP documents (CRs, NCRs, PIPs, etc.) involving radioactive waste and RAM processing and/or transportation (e.g., keyword searches for RAM, shipping, radwaste, 10 Part 61, etc.) generated since February 1, 2016. This should be a list of corrective action documents containing a (CR, NCR, etc.) number and brief description, not full documents.

9. Available for onsite review during the inspection:

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

• Plant drawings sufficient to permit the inspector to walkdown 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 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 and qualification records for personnel responsible for radioactive waste.

• 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 Part 172.

Assistance Requested During On-Site Inspection

• Identification of work activities available during the inspection for inspector observations, including notification of pre-job briefings, diving activities, radiologically risk significant work activities, and audio/visual surveillance for remote job coverage.

• An inspector will need to observe any shipments or receipts of RAM.

• Health physics assistance to coordinate plant walk-downs and observation of job coverage activities to assess access controls.

• Coordination of discussions with appropriate individuals regarding access controls.

Page 4 of 5

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 of 5