ML13163A079

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Notification of Inspection and Request for Information
ML13163A079
Person / Time
Site: Watts Bar Tennessee Valley Authority icon.png
Issue date: 06/12/2013
From: Brian Bonser
NRC/RGN-II/DRS/PSB1
To: James Shea
Tennessee Valley Authority
Linda K. Gruhler 404-997-4633
References
Download: ML13163A079 (10)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 June 12, 2013 Mr. Joseph W. Shea Vice President, Nuclear Licensing Tennessee Valley Authority 1101 Market Street, LP 3D-C Chattanooga, TN 37402-2801

SUBJECT:

WATTS BAR NUCLEAR PLANT - NOTIFICATION OF INSPECTION AND REQUEST FOR INFORMATION

Dear Mr. Shea:

From July 22-26, 2013, and April 12-16, 2013, the U.S. Nuclear Regulatory Commission (NRC) will perform a baseline Occupational and Public Radiation Safety inspection at the Watts Bar Nuclear Plant, (NRC Inspection Procedure 71124.01 Radiological Hazard Assessment and Exposure Controls, 71124.02 Occupational ALARA Planning and Controls, 71124.03 In-Plant Airborne Radioactivity Control and Mitigation, 71124.04 Occupational Dose Assessment, 71124.05 Radiation Monitoring Instrumentation, and 71151 Performance Indicator Verification (Occupational and Public Radiation Safety Cornerstones)).

To minimize the impact to your onsite 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, thereby minimizing the number of additional documents requested during the preparation and/or the onsite portions of the inspection. The inspector has requested that the subject informational material be provided in compact disk (CD) format on or before July 8, 2013.

We have discussed the schedule for these inspection activities with your staff and understand that our regulatory contact for this inspection will be Tommy Morgan (423) 365-1401 of your organization. If there are any questions about this inspection or the material requested, please contact the lead inspector Ruben Hamilton at (404) 997-4672 (ruben.hamilton@nrc.gov).

In accordance with Title 10 of the Code of Federal Regulations (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 Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm.html (the Public Electronic Reading Room).

2 J. Shea 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, under control number 3150-0011, 3150-0014, 3150-0044, and 3150-0135. 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.

Sincerely,

/RA by Steven Rudisail Acting for/

Brian Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket No: 50-390 License No: NPF-90

Enclosure:

Pre-Inspection Document Request cc: (See page 3)

ML13163A079 X SUNSI REVIEW COMPLETE X FORM 665 ATTACHED OFFICE RII:DRS/PSB1 RII:DRS/PSB1 SIGNATURE RKH1 SBR for BRB1 NAME R. Hamilton B. Bonser DATE 6/ 11 /2013 6/ 12 /2013 E-MAIL COPY YES NO YES NO

3 J. Shea cc:

Mr. T. P. Cleary Site Vice President Watts Bar Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution David H. Gronek Plant Manager Watts Bar Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution Donna K. Guinn Manager, Site Licensing Watts Bar Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution Mr. E. D. Schrull Manager, Corporate Licensing Watts Bar Nuclear Plant Tennessee Valley Authority 1101 Market Street, LP 4B-C Chattanooga, TN 37402-2801 Edward J. Vigluicci Associate General Counsel, Nuclear Tennessee Valley Authority Gordon P. Arent Senior Manager, Licensing WBN Unit 2 Watts Bar Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution County Mayor Watts Bar Unit 1 P.O. Box 156 Decatur, TN 37322 County Executive Watts Bar Unit 1 375 Church Street Suite 215 Dayton, TN 37321 Tennessee Department of Environment &

Conservation Division of Radiological Health 401 Church Street Nashville, TN 37243 Ann Harris 341 Swing Loop Rockwood, TN 37854 Electronic Mail Distribution Senior Resident Inspector U.S. Nuclear Regulatory Commission Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, TN 37381-2000

Enclosure Pre-Inspection Document Request Occupational and Public Radiation Safety Cornerstones Licensee:

Watts Bar Nuclear Plant Docket Number:

50-390 Inspection Dates:

July 22-26, 2013 and August 12-16, 2013 Procedures:

71124.01, Radiological Hazard Assessment and Exposure Controls 71124.02, Occupational ALARA Planning and Controls 71124.03, In-Plant Airborne Radioactivity Control and Mitigation 71124.04, Occupation Dose Assessment 71124.05, Radiation Monitoring Instrumentation 71151, Performance Indicator Verification Note: Electronic media is preferred if readily available (The preferred file format is Word, WordPerfect, or searchable.pdf files on CDROM). Note that the inspectors cannot accept data provided on USB or flash drives due to NRC IT security policies. An index to the contents is also helpful. For those items requesting a list of documents/areas, the inspectors will select documents/areas from the list for onsite review. If any of the requested information is too burdensome to provide electronically, simply indicate that the requested material is available for onsite review by the inspectors. Experience has shown that a well organized CD leads to a more efficient inspection, and lessens additional burden on licensee staff. During the inspection, the inspectors may request additional documents. If the licensee wishes to use an electronic document service such as CERTRAC or a Shareware portal, the inspectors will try to accommodate for the documentation requested onsite. The initial documents should not require an internet connection to be reviewed.

Documentation is requested from the dates identified in each inspection area, to the present.

For IP 71151 documentation is requested from July 1, 2012, to present.

If you have any questions, please call Ruben Hamilton at (404) 997-4672. Thank you in advance for all your effort in putting together this material.

Assistance Requested During Onsite Inspection Identification of work activities available during the inspection for inspector observations, including notification of pre-job briefings.

Health physics assistance in plant walkdowns assessing radiological hazards and exposure controls. (e.g., verifying the posting and locking of entrances to locked-high radiation areas and very high radiation areas, spent fuel pool controls, and radioactive material storage areas)

Assistance of Health Physics or radiation monitoring system engineer in performing plant walkdowns of effluent, process, and area radiation monitoring systems.

Health physics assistance in scheduling observations of routine source/performance checks of radiation monitoring instruments. (portable and installed HP instrumentation)

2 General Information Needed Telephone numbers of contacts for each inspection procedure.

Radiation Protection organizational chart.

Electronic copy of applicable chapters of the UFSAR. (e.g., radiation protection program, ventilation test program, area and process radiation monitors, etc.)

Corrective Action Program (CAP) procedures.

List of all Performance Indicators (PIs) and copies of associated corrective action reports for Occupational Exposure Control Effectiveness and RETS/ODCM Radiological Effluent Occurrences.

Audits and self-assessments performed since September 16, 2010, that encompass the areas of (1) radiation protection, (2) access controls, (3) ALARA occupational dose assessment, (4) internal dosimetry, (5) external dosimetry, and (6) radiation monitoring instrumentation.

List of radiation protection procedures.

Procedure(s) for identifying, notification, tracking, and correcting PI occurrences.

10 CFR 61.55 analysis results for dry active waste (DAW) and other waste streams.

71124.01 - Radiological Hazard Assessment and Exposure Controls List of current active RWPs.

Site and corporate procedures related to HP 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.)

Site and corporate procedures related to release of personnel and materials. (e.g.,

release surveys, decontamination, guidance for alarm follow-up, etc.).

List of Nationally Tracked Sources and any change-of-ownership transactions.

Inventory list of all sealed sources stored onsite.

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

Most recent self-assessment or audit covering hazard assessment and exposure controls.

List of corrective action reports generated since August 2012 related to HP controls.

(e.g., radworker error, HP technician error, posting issues, HRA/LHRA/VHRA issues, survey problems, etc.) This should be a list of corrective action documents containing an AR number and brief description, not full documents.

71124.02 - Occupational ALARA Planning and Controls Site and corporate procedures associated with maintaining site dose ALARA, including those involving ALARA work activities. These procedures should include:

o ALARA program implementation, including ALARA committee activities and ALARA planning, briefing, and reviews.

o Radiation work permit preparation and worker compliance.

o Processes used to estimate and track work activity specific exposures.

o Making changes to dose estimates during task performance.

o Work controls.

3 o Engineering controls.

o Exposure mitigation requirements.

Annual ALARA goals for 2011, 2012, and 2013, and the methodology utilized to make the projections.

Completed ALARA packages (including post-job reviews) for the five highest collective dose work activities completed during the 2012 refueling outage (including dose estimates, work hour estimates, special HP controls, and dose reduction initiatives), if available.

List of temporary shielding requests generated during the 2012 refueling outage.

List of five activities (including ALARA package number) from the 2012 outage in which the work scope changed, or was extended, and alternative ALARA measures were taken to respond to the emergent conditions.

List of five activities from the 2012 outage in which the estimated work hours were significantly different than the actual hours expended.

List five activities from the 2012 outage in which the estimated and actual hours expended were accurate.

ALARA trending point data for the last two outages.

Annual ALARA Report for 2011 and 2012.

Source term reduction strategic plan, if available.

Minutes from the last four Plant ALARA Committee Meetings.

Post-outage ALARA report for the 2012 refueling outage.

Annual ALARA goals for 2012 and 2013, and the methodology utilized to make the projections.

ALARA package for the Unit 2 transfer tube/canal work activities currently in progress.

Most recent self-assessment or audit of ALARA program.

List of corrective action reports generated since June 2011 related to ALARA. (e.g.,

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, etc.). This should be a list of corrective action documents containing the corrective action document number and a brief description, not complete documents.

Available for onsite review during the inspection: (Please do not provide any records which contain personally identifiable information such as social security number and name on the CD) o Records of personnel monitored for radiation exposure that show the total TEDE to date for each person. If possible, sort individuals by work group.

71124.03 In-Plant Airborne Radioactivity Control and Mitigation Site and corporate procedures/manuals associated with airborne radiation monitoring instrumentation and respiratory protection. Procedures/manuals should include:

o Operation, calibration, and maintenance of air sampling instrumentation, including set-point determination. (e.g., low-vols, high vols, goosenecks, AMS 4s, etc.)

o Calibration and maintenance of portable instruments.

4 o Actions to be taken when air sampling instrumentation is found to be significantly out of tolerance/calibration.

o Issuance and use of respiratory protective equipment. (emphasis on SCBA and air-supplied equipment) o Training, including fit-testing, for use of SCBA and supplied-air systems.

o SCBA maintenance activities, including vital components. (i.e., regulators) o Determination/verification of Grade D air for SCBA.

Site and corporate procedures/manuals related to airborne monitoring and control (e.g.,

use of containment purge, use of portable HEPA/charcoal units, temporary ventilation enclosures, use of CAMs, air sampling guidance, Alpha air sampling, etc.), as applicable.

Site and corporate procedures/manuals related to the use of respiratory protection devices. (e.g., SCBA, TEDE-ALARA guidance, PAPRs, storage, maintenance, training, QA, and fit-testing, etc.)

Records of the last two certifications of air quality for equipment used to provide breathing air for air-supplied respirators and SCBA bottles.

Documentation for last two surveillances performed on SCBA stored for emergency use.

Most recent audit, or self-assessment, covering airborne controls and respiratory protection.

Records of the last two calibrations/tests (charcoal, HEPA DOP, and system flow rate) for the following ventilation systems:

o Control Room Ventilation.

o Spent Fuel Pool Ventilation.

o Radioactive Waste Processing Ventilation.

List of corrective action reports generated since June 2011 related to airborne monitoring and respiratory protection. (e.g., continuous air monitors, respiratory protection equipment and program implementation, etc.) This should be a list of corrective action documents containing the corrective action document number and a brief description, not complete documents.

Available for onsite review by inspector during inspection:

o Inventory, inspection, and maintenance records for SCBA equipment.

o Training records, including fit-testing, for SCBA-qualified individuals.

o Training records/certification for individuals qualified to perform maintenance on vital components (e.g., regulators) on SCBA.

71124.04 - Occupational Dose Assessment Site and corporate procedures, manuals, and technical documents related to occupational dose assessment. The documents should include guidance for:

o Multi-badging; monitoring in steep/highly variable dose rate gradients.

o Personnel contamination events, storage/care of personal dosimeters, use of electronic dosimeters including evaluation of any biases identified relative to TLD monitoring.

o Internal dose assessment. (i.e., both in vivo and in vitro bioassay and air sampling capabilities) o Calibration/QC and use of whole body counter (WBC); release of contaminated individuals, use of passive monitoring as screening method for evaluations, and special in vitro sample collection and analysis, and actions for declared pregnant workers.

5 NVLAP accreditation documentation for the current dosimetry used by the site.

List of all positive whole body counts, in vitro, or air sampling analyses which resulted in an assigned CEDE equal to, or exceeding, 10 millirem since August 2010. [Note: Only a listing should be provided for use by the inspectors to select a sample of issues for in-depth review during the onsite inspection.]

List of all personnel contamination events identified since August 2010. Include full documentation for any PCEs requiring skin dose assessment. [Note: Only a listing should be provided for use by the inspectors to select a sample of issues for in-depth review during the onsite inspection, however please include full dose assessment documentation as applicable.]

Most recent audit or self-assessment of the dosimetry program and the most recent audit of the lab that processes site dosimetry.

List of corrective action reports generated since August 2010 for internal or external dosimetry issues/events. This should be a list of corrective action documents containing the corrective action document number and a brief description, not complete documents.

71124.05 - Radiation Monitoring Instrumentation Site and corporate procedures/manuals associated with radiation monitoring instrumentation. Procedures/manuals should include:

o Use of portable instrument calibrators. (e.g., Shepherd calibrator) o Calibration and functional test/source checks of portable radiation detection instrumentation.

o Calibration and functional tests of small article monitor (SAM), personnel contamination monitor (PCM), portal monitor (PM), whole body counting (WBC) equipment, and continuous air monitors (CAMs).

o Determination of set-points for Area Radiation Monitor (ARM), CAM, PCM, PM, and SAM equipment.

o Collection and analysis of high-range, post-accident effluent samples.

o QA program for count room instruments. (e.g., laboratory inter-comparison data) o Maintenance or surveillance test guidance for the specific process and effluent Radiation Monitors (RM) requested below.

The last two calibration records for the following monitors:

o Containment High Range Monitor.

o Main Stack Monitor and Associated Sample Line Flow Rate Monitor(s).

o Condenser Exhaust Radiation Monitor.

o Liquid Radwaste Effluent Radiation Monitor.

o Auxiliary Building Vent.

o Containment Particulate and Noble gas monitors.

o WBC systems in Dosimetry.

List of the portable instruments currently in service and available for use. Several will be selected for onsite review of the calibration records.

List of the following radiation monitors. Several will be selected for onsite review of the calibration records.

o Portal Monitors used in Dosimetry for Passive Monitoring.

o SAMs at RCA exit point.

o Whole Body Contamination Monitors at RCA exit point.

6 o Portal Monitors at RCA exit point.

o Countroom High-purity Germanium Detectors.

Documentation for the radioactive sources used to calibrate the above requested monitors showing traceability to a national standard (NIST) and traceability to the primary calibration, as applicable.

The last two surveillances performed on the Post-accident Sampling System, as applicable.

Chart or procedure listing EALs for radiation monitoring equipment.

The latest test record of the instrument calibrator. (Shepherd validation testing/dose rate curves)

Two most recent system health reports or Maintenance Rule reports for Radiation Monitoring systems. (effluent and ARM)

Most recent audit or self-assessment covering HP instruments (portables, RCA exit point, WBC, count room, effluent), include any reviews conducted of vendor facilities, as applicable.

List of corrective action reports generated since August 2010 related to portable instruments, effluent and area monitors, CAMs, RCA release point monitors, WBCs, and count room instruments. This should be a list of corrective action documents containing the corrective action document number and a brief description, not complete documents.

71151 - PI Verification (occupational and public cornerstones)

Site and corporate procedures/manuals for gathering and reporting PI data.

Monthly/Quarterly PI reports since July 1, 2012, and copies of associated Condition Report documents for any Occupational Exposure or RETS/ODCM Radiological Effluent PI events occurrences.

Liquid and gaseous effluent release permits which specify the quarterly and annual curies released by isotope, and associated public dose assessments, for the fourth quarter CY 2012, and the most recent permits in 2013.

List of all corrective action reports generated since July 1, 2012, using keywords such as: HRA, LHRA, VHRA, unintended dose, unlocked LHRA door, etc.

List of all corrective action reports generated since July 1, 2012, using keywords abnormal/ unmonitored effluent release, etc.

List of all electronic dosimeter (ED) dose rate alarms and ED dose alarms since July 1, 2012.