ML18312A324

Public Rad Safety Inspection Doc Request

ML18312A324
Person / Time
Site:	Harris
Issue date:	10/24/2018
From:	Kellner R Division of Reactor Safety II
To:	Yarley C Progress Energy Carolinas
References
Download: ML18312A324 (6)

Text

ML # 18312A324 Kellner, Robert From: Kellner, Robert Sent: Wednesday, October 24, 2018 3:53 PM To: 'Yarley, Charles' Cc: Dykes, Carmen

Subject:

Shearon Harris Public RP Baseline Inspection - December 2018 Attachments: Harris 2018 Rad Safety Inspection Document Request.pdf

Chuck, Per your previous email, you will be the Harris Licensing point of contact for the NRC Radiation Safety Inspection scheduled for the week of December 10 - 14, 2018. Attached is the Initial Information Request and a Document Request List.

My previous email listing the inspectors that will be on the team was incorrect. Carmen Dykes replaced Bill Pursley, so it will be Carmen Dykes and myself who will be on-site during the inspection. Since we both were recently at McGuire, our Duke site access training should be current. I am pretty sure that the REMP air sample run is done on Monday mornings. If you can confirm that is correct as soon as you get a chance, it would be appreciated. One of us will need to adjust travel plans to be there early on Monday morning.

Please let me know that you received this request. I have your direct phone number as (919) 362-2477, and cell number, if I need to contact you. 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

Harris Nuclear Plant Radiation Safety Baseline Inspection Initial Information Request Inspection Report: 2018004 During the week of December 10 - 14, 2018, the NRC will perform a baseline Radiation Safety Inspection at Shearon Harris Nuclear Plant (NRC Inspection Procedures 71124.06, 71124.07 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 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 November 3, 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: Harris Nuclear Plant Docket Number: 50-400 Inspection Dates: December 10 - 14, 2018 Documents Due to Region II by: November 3, 2018 Inspection Procedures: IP 71124.06 Radioactive Gaseous and Liquid Effluent Treatment IP 71124.07 Radiological Environmental Monitoring Program IP 71151 Performance Indicator Verification Lead Inspector: Robert Kellner Senior Health Physicist USNRC/Region II/DRS/PSB1 Marquis One Tower, Suite 1200 245 Peachtree Center Ave, NE Atlanta, GA 30303-1257 (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 June 1, 2017 to the present, unless otherwise noted. This reflects the last time these areas were inspected. 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

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

2. Plant Chemistry, and Radiation Protection organizational charts, including personnel involved in effluent sampling and reporting, Radiological Environmental Monitoring Program (REMP) sampling and reporting.

3. Corrective Action Program procedures

4. Schedule of routine effluent and REMP sampling activities during the week of inspection (e.g., stacks sampled on Monday, REMP run Tuesday).

5. Results of the most recent 10 CFR Part 61 analytical results and characterization of major radioactive waste streams (e.g. Dry Active Waste (DAW), filters, primary resin, etc.)

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71124.06 - Radioactive Gaseous and Liquid Effluent Treatment (Last Inspected July 2017)

1. Site and corporate procedures associated with implementing the effluent monitoring and controls program. Procedures should include those that address:

a. Sample collection and analysis

b. Radiation monitor alarm and release set-point determinations

c. Release permit preparation

d. On and off-site dose evaluations and dose calculations

e. Calibration and quality control (QC) activities for sample counting instruments

f. Countroom High Purity Germanium Detector calibration and QC checks

2. Offsite Dose Calculation Manual (ODCM) and a list of changes included in the last revision.

3. List of permitted effluent release points, including release points from on-site surface water bodies (as applicable)

4. Methodology/procedure used for determining effluent stack/vent flow rates.

5. List of liquid and gaseous effluent monitors listed as out-of-service (OOS) for > 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> since June 1, 2017, including any special reports submitted to the NRC as a result of effluent monitor operability.

6. List of all unmonitored spills, leaks, or unexpected liquid/gaseous discharges since June 1, 2017. If applicable, provide the Licensee Event Report (LER), event report, and/or special report.

7. List of non-radioactive systems that have become contaminated and any 10 CFR 50.59 evaluations performed, since June 1, 2017.

8. List of any changes to the effluent release points or effluent treatment systems, and associated 10 CFR 50.59 documentation, since June 1, 2017.

9. Material condition surveillance records for liquid and gaseous effluent treatment system components not readily accessible, including those inaccessible due to radiological conditions (e.g. in-service & spent resin tanks, waste evaporator systems, waste gas hold-up tanks, etc.).

10. Effluent release permits for continuous gaseous, batch gaseous, continuous liquid, and/or batch liquid releases indicating the current and year to date off-site dose. Only provide permits for the latest release within each category.

11. Results of on-site counting lab inter-laboratory comparison program since June 1, 2017.

12. Results of the last two surveillances/tests of the Fuel Handling Building and Containment Building ventilation systems, including system flow monitoring instrumentation calibration, HEPA filter testing, and charcoal filter tests.

13. System health reports for radiological effluent/process monitoring systems since June 1, 2017.

14. The last two calibration records for the following effluent monitors:

Waste Processing Building exhaust (1WV-3546)

Main Steam Line Radiation Monitors (RM1MS-3591, 3592, 3593)

Waste Monitor Tanks Discharge Radiation Monitor (21WL-3541)

15. The last two calibration records for the following Post Accident/high range effluent monitors:

Plant Vent Stack Accident range, particulate and gaseous Radiation Monitor (RM21AV-3509)

In-Containment Post-Accident radiation monitors (RM-1CR-3589 and 3590)

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16. Calibration source certifications for sources used to calibrate the monitors in items 14 and 15 above, including traceability to NIST to the primary calibration.

17. Audit and self-assessment documents generated since June 1, 2017, related to liquid and gaseous effluent treatment and monitoring, unmonitored spills, leaks, or effluent discharges, or the groundwater monitoring program.

18. List of Corrective Action Program (CAP) documents (CRs, NCRs, PIPs, etc.) generated since June 1, 2017, related to liquid and gaseous effluent treatment and monitoring, unmonitored spills, leaks, or effluent discharges, or the groundwater monitoring program.

This should be a list of corrective action documents containing a CR number and brief description, not full CRs.

71124.07 - Radiological Environmental Monitoring Program (Last Inspected July 2017)

1. Site and corporate procedures associated with radiological environmental monitoring, including:

a. Collection, preparation, and analysis of environmental samples including air, Thermoluminescent Dosimeter (TLD) stations, ground and surface water, sediment, vegetation, milk, fish, etc.

b. Calibration and maintenance of air and water sampling equipment.

c. Land use census

d. Calibration and quality control (QC) activities for sample counting instruments.

e. Calibration, operation, maintenance, and routine surveillances of meteorological monitoring instruments (wind speed & direction, air temperature, etc.).

2. Site and corporate procedures associated with implementing the ground water monitoring program and the voluntary ground water protection initiative. Procedures should include those that address:

a. Groundwater monitoring and reporting of spills/leaks

b. Buried piping

c. Sampling and monitoring program to detect leaks from contaminated, or potentially contaminated, systems, structures, or components (SSCs).

3. List of SSCs that contain, or could contain, licensed material for which there is a credible mechanism for the radioactive material (RAM) to reach ground water (e.g. SSC risk ranking matrix).

4. Summary of any leaks and/or spills that have occurred since June 1, 2017, (i.e. additions to the 10 CFR 50.75(g) file).

5. List of changes to the REMP (sample locations, sample frequency, type of samples, etc.)

since June 1, 2017.

6. Calibration and maintenance records for REMP air and composite water samplers since June 1, 2017.

7. Inter-laboratory comparison program results since June 1, 2017 (in-house and vendor laboratory).

8. Most recent calibration/surveillance/maintenance records for the meteorological monitoring instruments (wind speed, wind direction, and air temperature).

9. Data recovery report for meteorological monitoring instruments since June 1, 2017.

10. Groundwater monitoring results since June 1, 2017.

11. Results of environmental TLD monitoring since June 1, 2017.

12. List of changes to the written groundwater monitoring program for identifying/controlling contaminated spills/leaks since June 1, 2017.

13. List of onsite surface water bodies (e.g., ponds, retention basins, lakes) that contain or potentially contain radioactivity.

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14. Audit and self-assessment documents generated since June 1, 2017, related to REMP.

The data should include any reviews conducted of vendor activities and their facilities (e.g., environmental lab).

15. List of CAP documents (CRs, NCRs, PIPs, etc.) generated since June 1, 2017, related to REMP. The data should include any reviews conducted of vendor activities and their facilities (e.g., environmental lab, out of service air sampler, missing environmental TLD, etc.). This should be a list of corrective action documents containing a CR number and brief description, not full CRs.

71151 - Performance Indicator Verification (Last inspected July 2017)

1. Procedures for gathering and reporting NRC Performance Indicator (PI) data, including any applicable desktop guides.

2. Monthly/Quarterly Performance Indicator (PI) reports and copies of associated CAP documents, for Occupational Exposure Control Effectiveness and Radiological Effluent Technical Specifications/ Offsite Dose Calculation Manual (RETS/ODCM) Radiological Effluent Occurrences since June 1, 2017.

3. Most recent gaseous effluent release permits and liquid effluent release permits, which specify the quarterly and annual curies released by isotope, and the associated public dose assessment.

4. List of all electronic dosimeter (ED) dose rate alarms and all ED dose alarms since June 1, 2017.

5. List of all CAP documents (CRs, NCRs, PIPs, etc.) since June 1, 2017 using keywords such as high radiation area (HRA), locked high radiation area (LHRA), very high radiation area (VHRA), unintended dose, unlocked LHRA door, etc.

6. Audit and self-assessment documents generated since June 1, 2017, related to Performance Indicators.

7. List of CAP documents (CRs, NCRs, PIPs, etc.) since June 1, 2017, using keywords such as abnormal, unmonitored, unplanned effluent release, etc. This should be a list of corrective action documents containing a CR number and brief description, not full CRs.

Assistance Requested During On-Site Inspection Notification of any routine or special effluent sampling activities to be completed during the inspection week.

Accompany sampling technician on the weekly REMP sample run.

2018 Land Use Census - Review and discuss if it has been completed.

Licensing or Health Physics assistance coordinating walkdowns of the meteorological tower, ventilation systems, and waste processing systems.

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