ML15051A053

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Notification of Inspection and Request for Information
ML15051A053
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 02/19/2015
From: Brian Bonser
NRC/RGN-II/DRS/PSB1
To: Waldrep B
Duke Energy Carolinas
Linda K. Gruhler 404-997-4633
References
Download: ML15051A053 (9)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 February 19, 2015 Benjamin C. Waldrep Vice President Shearon Harris Nuclear Power Plant 5413 Shearon Harris Rd New Hill, NC 27562-0165

SUBJECT:

HARRIS NUCLEAR PLANT - NOTIFICATION OF INSPECTION AND REQUEST FOR INFORMATION

Dear Mr. Waldrep:

During the weeks of April 13 - 17, 2015, and April 27 - May 1, 2015, the U.S. Nuclear Regulatory Commission (NRC) will perform a baseline Radiation Safety Inspection at the Harris Nuclear Plant (NRC Inspection Procedures 71124.01, 71124.02, 71124.03, 71124.04, 71124.05, and the Radiation Safety sections of 71151).

In order to minimize the impact to your onsite resources and to ensure a productive inspection, we have enclosed a request for documents needed for this activity. It is important that all of these documents are up-to-date, and complete, in order to minimize the number of additional documents requested during the preparation and/or the onsite portions of the inspection. The NRC requests that the subject informational material be provided in CD format on or before March 27, 2015.

We have discussed the schedule for these inspection activities with your staff, and understand that our regulatory contact for this inspection will be Ingrid Nordby of your organization. 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 Chief of Plant Support Branch 1, Brian Bonser at 404-997-4653.

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); accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room)

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 numbers 3150-0008, 3150-0011, 3150-0014, 3150-0044, and 3150-0135. The NRC may not conduct or

2 B. Waldrep 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/

Brian Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Dockets No. 50-400 License No. NPF-63

Enclosure:

Document Request List cc: Distribution via Listserv

ML15051A053 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DRS/PSB1 RIILDRS/PSB1 SIGNATURE RXK3 BRB1 NAME R. Kellner B. Bonser DATE 2/ 19 /2015 2/ 19 /2015 E-MAIL COPY YES NO YES NO

Enclosure Document Request List Inspection Dates:

April 13 - 17, 2015 and April 27 - May 1, 2015 Documents Due to Region by:

March 27, 2015 Inspection Procedures:

71124.01 Occupational As Low As Reasonably Achievable and Controls 71124.02 Occupational As Low As Reasonably Achievable Planning and Controls 71124.03 In-Plant Airborne Radioactivity Control and Mitigation 71124.04 Occupational Dose Assessment 71124.05 Radiation Monitoring Instrumentation 71151 Performance Indicator Verification (Radiation Safety cornerstones only)

Lead Inspector:

Robert Kellner 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. Experience has shown that a poorly organized CD leads to a less efficient inspection and places additional burden on licensee staff.

Please pay particular attention to the date ranges for the items requested, as they may change from item to item. 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 August 2014 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 onsite review.

General Information Listing of primary site contact(s) for each inspection area including name(s) and telephone numbers List of radiation protection procedures, including title and number 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.)

Corrective Action Program (CAP) procedures Outage schedule of major activities (Gantt chart if available).

2 71124.01 Radiological Hazard Assessment and Exposure Controls (Last Inspected 8/22/2014)

1. List of outage Radiation Work Permits (RWPs).
2. 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.
3. 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).
4. List of the 10 most exposure significant work areas within radiation areas, HRAs (<1R/hr), or airborne radioactivity areas in the plant. This may include areas with low dose rates, but high collective dose. Identify any HRAs with significant dose gradients (factor of five or more), including underwater diving activities.
5. Procedures related to release of personnel and materials (e.g., release surveys, decontamination, guidance for alarm followup).
6. List of Nationally Tracked Sources, and copies of any National Source Tracking System (NSTS) transaction documentation.
7. Most recent sealed source inventory record.
8. List of all non-fuel items stored in spent fuel pool (SFP).
9. All self-assessments or audits covering hazard assessment and exposure controls since August 2014 (if none, then provide the most recent).
10. List of CAP nonconformance reports (NCRs), action requests (ARs), condition reports (CRs), etc., related to HP controls (e.g., radworker error, HP technician error, posting issues, Nationally Tracked Sources, HRA/LHRA/VHRA issues, survey problems) issued since August 2014. This should be a list of corrective action documents containing an (ARs, CRs, NCRs, etc.) number and brief description, not full documents.

71124.02 As Low As Reasonably Achievable Planning and Controls (Last Inspected 5/18/2012)

1. Site and corporate as low as reasonably achievable (ALARA) program governing documents and implementing procedures associated with maintaining exposure ALARA, and estimating and tracking dose from specific work activities, source term reduction, temporary shielding, etc.
2. Most recent annual ALARA report, most recent refueling outage report and bases for the site ALARA dose goals for the current year.
3. Information on the current status/characterization of plant source term, any relevant plans or actions, to reduce it.
4. Summaries of the last four ALARA Committee Meetings (e.g., meeting minutes).
5. Completed ALARA packages (including post-job reviews) for the five work activities that had the greatest collective dose and were completed during the previous outage.
6. ALARA packages for the five work activities expected to have the greatest collective dose, and are scheduled for completion during the upcoming outage.
7. List of shielding packages for the upcoming outage.
8. Shutdown survey results for the last two outages.
9. Self assessments/audits of the ALARA program since May 2012.
10. List of corrective action reports related to ALARA generated since May 2012. (An AR number and brief description is all that is necessary.)

3 71124.03 In-Plant Airborne Radioactivity Control and Mitigation (Last Inspected 5/18/2012)

1. Procedures related to airborne monitoring and control (e.g., use of containment purge, use of portable HEPA/charcoal units, temporary ventilation enclosures, use of continuous air monitors (CAMs), air sampling guidance, Alpha air sampling).
2. Procedures related to the use of respiratory protection devices, (e.g., self-contained breathing apparatus (SCBA), Total Effective Dose Equivalent (TEDE)-ALARA guidance, powered air purifying respirators (PAPRs), storage, maintenance, training, quality assurance (QA), fit-testing).
3. Two most recent HEPA filter Dioctyl phthalate (DOP) and charcoal test results; for the following ventilation systems:

Control Room Ventilation Fuel Handling Building Ventilation Auxiliary Building Ventilation

4. All records of grade D air certification for supplied air system, and SCBA filling equipment since May 2012.
5. SCBA qualification records
a. Vendor training certificates for all individuals qualified to repair SCBA
b. List of all licensed operators qualified to use SCBA
c. List of all maintenance personnel qualified to use SCBA
6. Documentation for last two surveillances performed on SCBA stored for emergency use.
7. Most recent audit or self-assessment covering airborne controls and respiratory protection.
8. List of corrective action reports generated since May 2012 involving airborne monitoring, and respiratory protection deficiencies. [This should be a list of corrective action documents containing a CR number and brief description, not full CRs.]
9. Available for onsite review by inspector during inspection:
  • Inventory, inspection, and maintenance records for SCBA equipment
  • Training records, including fit-testing, for SCBA-qualified individuals 71124.04 Occupational Dose Assessment (Last Inspected 5/18/2012)
1. Provide Procedures/Guidance Documents for internal and external dose monitoring (i.e., dosimetry issuance and use). The documents should include:
  • Guidance for multi-badging; monitoring in steep/highly variable dose rate gradients
  • Personnel contamination events; storage/care of personal dosimeters; use of electronic dosimeters (EDs) including evaluation of any biases identified relative to Thermoluminescent dosimeters (TLD) monitoring
  • Internal dose assessment (i.e., both in-vivo and in-vitro bioassay and air sampling capabilities). The documents should include guidance for calibration/quality control (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.

2. National Voluntary Laboratory Accreditation Program (NVLAP) accreditation documentation for current dosimetry used by the site.
3. List of all positive WBCs, in-vitro, or air sampling analyses that resulted in an assigned committed effective dose equivalent (CEDE) equal to or exceeding 10 millirem since May 2012. [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].

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4. List of all personnel contamination events identified since May 2012. Include full documentation for any personnel containment events (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.]
5. A list of personnel who have received approved dose extensions since May 2012.
6. Most recent audits or self-assessment of the dosimetry program, and/or reviews related to internal or external dosimetry issues generated since May 2012. The documents provided should include any reviews/evaluations conducted of vendor facilities (e.g., corporate or outside vendor/ or corporate calibration facilities).
7. Provide a list of CR documents generated since May 2012, for internal or external dosimetry issues/events. [Note: Only titles and a summary statement should be provided for use by the inspectors to select a sample of issues for in-depth review].

71124.05 Radiation Monitoring Instrumentation (Last Inspected 5/18/2012)

1. Procedures/Guidance Documents for:
  • Use of portable instrument calibrators (e.g., Shepherd calibrator)
  • Calibration and functional test/source checks of portable radiation detection instrumentation
  • Calibration and functional tests of small article monitor (SAM), personnel contamination monitor (PCM), portal monitor (PM), WBC equipment; and CAMs
  • Determination of set-points for Area Radiation Monitor (ARM), CAM, PCM, PM and SAM equipment
  • Collection and analysis of high-range, post accident effluent samples
  • QA program for count room instruments (e.g., laboratory inter-comparison data)
2. The last two calibration records for the following radiation monitors:
  • Condenser Air Ejector - REM-1TV-3534 and RM-TV-3536-1
  • Plant Vent Monitor - RM21AV-3509 and REM-1AV-3532A/B
  • Liquid Radioactive Waste - REM-21WS-3542 and REM-21WL-3541
  • WBC in Dosimetry area (and PM if passive monitoring used)
3. List of the following monitors (including serial number, location, and model information):

(Specific calibration records will be selected for review during the onsite inspection)

  • All SAMs at radiological controlled area (RCA) exit points
  • All PMs at RCA exit points and the protected area (PA) exit
  • All count room high-purity Germanium Detector and Liquid Scintillation Counters
  • All in service portable radiation survey instruments available for use (including air samplers, friskers, telepole/teletectors, dose rate instruments, etc.)
4. Documentation for the sources used to calibrate the above requested monitors showing traceability to a national standard, National Institute of Standards & Technology/National Bureau of Standards (NIST/NBS), and to the primary calibration, as applicable.
5. Last two calibration records of the portable instrument calibrator (e.g., Shepherd validation testing/dose rate curves).
6. List of any Emergency Action Level (EAL) value associated with installed or portable radiation monitoring instrument indication(s).

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7. Last two system health reports for the Radiation Monitoring system(s).
8. Copies of all audits, self-assessments, and/or reviews of area and personnel monitoring equipment, and portable radiation survey instruments generated since May 2012. The records should include any reviews conducted of vendor facilities (e.g., outside calibration laboratories) as applicable.
9. Discussion of any modification(s), upgrade(s), or replacement(s) performed on installed radiation monitoring instrumentation (e.g., effluent and area monitors, CAMs, RCA release point monitors, WBCs, and count room instruments) since May 2012.
10. List of CRs generated since May 2012 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 a CR number and brief description, not full CRs.)

71151 Performance Indicator Verification (Last Inspected 8/22/2014)

1. Procedure for gathering and reporting performance indicator (PI) data.
2. Monthly/Quarterly PI reports since August 2014, and copies of associated CR documents for any Occupational Exposure or Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual (RETS/ODCM) Radiological Effluent PI events occurrences.
3. Most recent gaseous and liquid effluent release permits showing year-to-date curies released by isotope and associated public dose assessments, and the last CY 2014 gaseous and liquid effluent release permits showing year-to-date curies released by isotope and associated public dose assessments
4. List of all corrective action documents since August 2014, using keywords such as: HRA, LHRA, VHRA, unintended dose, unlocked LHRA door, etc.
5. List of all corrective action documents since August 2014, using keywords abnormal/

unmonitored effluent release, etc.

6. List of all ED dose rate alarms, and all ED dose alarms since August 2014.

Inspector Information:

Robert Kellner Health Physicist US NRC Region II 404-997-4508 robert.kellner@nrc.gov Mailing Address US Nuclear Regulatory Commission Region II Attention: Mr. Robert Kellner 245 Peachtree Center Ave, NE Suite 1200 Atlanta, GA 30303

6 LIST OF ACRONYMS ALARA As Low As Reasonably Achievable ARs Action Requests ARM Area Radiation Monitor CAMs Continuous Air Monitors CAP Corrective Action Program CEDE Committed Effective Dose Equivalent CRs Condition Reports CY Calendar Year DAW Dry Active Waste DOP Dioctyplthalate EAL Emergency Action Level ED Electronic Dosimeter HP Health Physics HRAs High Radiation Areas LHRA Locked High Radiation Area NCRs Nonconformance Reports NIST/NBS National Institute of Standards and Technology/National Bureau of Standards NVLAP National Voluntary Laboratory Accreditation Program PA Protected Area PAPRs Powered Air Purifying Respirators PCE Personnel Containment Event PCM Personnel Contamination Monitor PIs Performance Indicators PM Portal Monitor QA Quality Assurance QC Quality Control RCA Radiological Controlled Area RETS/ODCM Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual RWPs Radiation Work Permits SAM Small Article Monitor SCBA Self-contained Breathing Apparatus SFP Spent Fuel Pool TEDE Total Effective Dose Equivalent TLDs Thermoluminescent Dosimeters VHRA Very High Radiation Area WBC Whole Body Counter

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