ML12023A267

PSB1 RP Catawba 2012 002 Doc Req Ltr

ML12023A267
Person / Time
Site:	Catawba
Issue date:	01/20/2012
From:	Brian Bonser NRC/RGN-II/DRS/PSB1
To:	Morris J Duke Energy Carolinas
References
Download: ML12023A267 (10)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 January 20, 2012 Mr. J. R. Morris Site Vice President Duke Energy Carolinas, LLC Catawba Nuclear Station 4800 Concord Road York, SC 29745-9635

SUBJECT:

CATAWBA NUCLEAR POWER STATION, NOTIFICATION OF INSPECTION AND REQUEST FOR INFORMATION

Dear Mr. Morris:

From March 19 - 23, 2012, the NRC will perform a baseline Occupational Radiation Safety Inspection at the Catawba Nuclear Power Station for NRC Inspection Procedures 71124.01, 71124.02, 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 on-site 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 in order to minimize the number of additional documents requested during the preparation, and/or the onsite portions of the inspection.

We have discussed the schedule for these inspection activities with your staff and understand that our regulatory contact for this inspection will be Adrienne Driver at (803) 701-3445 of your organization, and that the material be available for review by March 1, 2012. If there are any questions about this inspection or the material requested, please contact the lead inspector, Wade Loo at (404) 997-4727.

In accordance with 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 document system(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Brian R. Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket Nos.: 50-413, 50-414 License Nos.: NPF-35, NPF-52

Enclosure:

Inspection Document Request cc w/encl: (See page 2)

January 20, 2012 Mr. J. R. Morris Site Vice President Duke Energy Carolinas, LLC Catawba Nuclear Station 4800 Concord Road York, SC 29745-9635

SUBJECT:

CATAWBA NUCLEAR POWER STATION, NOTIFICATION OF INSPECTION AND REQUEST FOR INFORMATION

Dear Mr. Morris:

From March 19 - 23, 2012, the NRC will perform a baseline Occupational Radiation Safety Inspection at the Catawba Nuclear Power Station for NRC Inspection Procedures 71124.01, 71124.02, 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 on-site 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 in order to minimize the number of additional documents requested during the preparation, and/or the onsite portions of the inspection.

We have discussed the schedule for these inspection activities with your staff and understand that our regulatory contact for this inspection will be Adrienne Driver at (803) 701-3445 of your organization, and that the material be available for review by March 1, 2012. If there are any questions about this inspection or the material requested, please contact the lead inspector, Wade Loo at (404) 997-4727.

In accordance with 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 document system(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Brian R. Bonser, Chief Plant Support Branch 1 Division of Reactor Safety Docket Nos.: 50-413, 50-414 License Nos.: NPF-35, NPF-52

Enclosure:

Inspection Document Request cc w/encl: (See page 2)

Distribution w/encl See page 3 X PUBLICLY AVAILABLE G NON-PUBLICLY AVAILABLE G SENSITIVE X NON-SENSITIVE ADAMS: X Yes ACCESSION NUMBER: ML12023A267 X SUNSI REVIEW COMPLETE X FORM 665 ATTACHED OFFICE RII: DRS/PSB1 RII: DRS/PSB1 SIGNATURE RA RA NAME W. LOO B. BONSER DATE 01/20/2012 01/20/2012 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO OFFICIAL RECORD COPY DOCUMENT NAME: G:\DRSII\PSB1\INFORMATION REQUEST LETTERS\CATAWBA\PSB1 RP CATAWBA 2012 002 DOC REQ LTR REV1.DOCX

DPC 2 cc w/encl:

George T. Hamrick David A. Cummings Station Manager Associate General Counsel Catawba Nuclear Station Duke Energy Corporation Duke Energy Carolinas, LLC Electronic Mail Distribution Electronic Mail Distribution Beth J. Horsley Tanya M. Hamilton Wholesale Customer Relations Engineering Manager Duke Energy Corporation Catawba Nuclear Station Electronic Mail Distribution Duke Energy Carolinas, LLC Electronic Mail Distribution Sandra Threatt, Manager Nuclear Response and Emergency Steven B. Putnam Environmental Surveillance Safety Assurance Manager Bureau of Land and Waste Management Catawba Nuclear Station Department of Health and Environmental Duke Energy Carolinas, LLC Control Electronic Mail Distribution Electronic Mail Distribution Randy D. Hart Division of Radiological Health Regulatory Compliance Manager TN Dept. of Environment & Conservation Duke Energy Carolinas, LLC 401 Church Street Electronic Mail Distribution Nashville, TN 37243-1532 David A. Baxter Senior Resident Inspector Vice President, Nuclear Engineering U.S. Nuclear Regulatory Commission General Office Catawba Nuclear Station Duke Energy Carolinas, LLC U.S. NRC Electronic Mail Distribution 4830 Concord Road York, SC 29745 M. Christopher Nolan Fleet Safety Assurance Manager David A. Repka Duke Energy Carolinas, LLC Winston Strawn LLP Electronic Mail Distribution Electronic Mail Distribution Charles J. Thomas County Manager of York County Fleet Licensing Manager York County Courthouse Duke Energy Carolinas, LLC P. O. Box 66 Electronic Mail Distribution York, SC 29745-0066 Luellen B. Jones Piedmont Municipal Power Agency Fleet Licensing Engineer Electronic Mail Distribution Duke Energy Carolinas, LLC Electronic Mail Distribution Vanessa Quinn Federal Emergency Management Agency Lara S. Nichols Radiological Emergency Preparedness Vice President-Legal Program Duke Energy Corporation 1800 S. Bell Street Electronic Mail Distribution Arlington, VA 20598-3025

DPC 3 Letter to J. R. Morris from Brian Bonser dated January 20, 2012.

SUBJECT:

CATAWBA NUCLEAR POWER STATION, NOTIFICATION OF INSPECTION AND REQUEST FOR INFORMATION Distribution w/encl:

C. Evans, RII EICS (Part 72 Only)

L. Douglas, RII EICS (Linda Douglas)

OE Mail (email address if applicable)

RIDSNRRDIRS PUBLIC A. Adams, NRR RidsNrrPMCatawba Resource

PRE-INSPECTION DOCUMENT REQUEST OCCUPATIONAL RADIATION SAFETY CORNERSTONE Licensee: Catawba Nuclear Plant Docket Numbers: 05000413, 05000414 Inspection Dates: March 19 - 23, 2012 Inspection Procedures: 71124.01 Radiological Hazard Assessment and Exposure Controls 71124.02 Occupational ALARA Planning and Controls 71151 Performance Indicator Verification (Public and Radiation Safety Cornerstones)

Documentation is requested from August 1, 2011, to present for IPs 71124.01 (Radiological Hazard Assessment and Exposure Controls), and 71151 (Performance Indicator Verification);

and from October 1, 2010, to present for IP 71124.02 (ALARA Planning and Controls).

We would prefer as much of the information as possible in electronic form. 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 on-site review. If any of the requested information is too burdensome to provide electronically or as hard copies, simply indicate that the requested material is available for on-site review by the inspectors.

If you have any questions, please call Wade Loo at (404) 997-4727. Thank you in advance for all your effort in putting together this material.

Assistance Requested During On-Site Inspection

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

• Health physics assistance in plant walk-downs assessing access controls, e.g. verifying the posting and locking of entrances to HDR-HRA and VHRA, and spent fuel pool controls.

• Health physics assistance in plant walk-downs/job coverage of ongoing outage activities to assess access controls and ALARA practices.

• Discussions with appropriate individuals regarding access controls and ALARA planning.

General Information Request

• Telephone numbers of contacts.

• Radiation Protection organizational chart.

Enclosure

2

• Electronic copy of applicable chapters of UFSAR (e.g. radiation protection program, liquid and solid radioactive waste program, etc.).

• Corrective Action Program (CAP) procedures.

• Procedures associated with the ISFSI facility. Procedures should include:

o Radiological surveys, postings, and radiation control barricades.

o Environmental monitoring (including TLDs).

o Loading of casks.

o Routine activities.

• Radiation surveys of the ISFSI since the last inspection.

• List of corrective action reports related to the ISFSI with respect to radiation protection (i.e. access controls, ALARA, contamination, radiation levels, etc.) since the last inspection.

• ALARA reviews and planning and associated RWPs for cask loading activities.

• Records of contamination incidents since the last inspection.

• Audits and self-assessments performed since the last inspection that encompass the areas of (1) Access Control, and (2) ALARA program and implementation.

• Outage schedule to include work activities that will be conducted during the weeks of the inspection.

• List of active radiation work permits with their administrative limits, electronic dosimeter dose rate limit, and dose limit.

• List of Site and Corporate radiation protection procedures.

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

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

71124.01 Radiological Hazard Assessment and Exposure Controls

• Site and corporate procedures associated with the access control program. Procedures should include:

o Radiological surveys, postings, and radiation control barricades.

o Security and control of high radiation sources/objects stored in pools.

o Posting of areas, labeling of containers, and inventories of non-SNM materials maintained within the spent fuel pools.

Enclosure

3 o Radiation Work Permits.

o Radiological Job-Coverage.

o Controlling access to High Radiation Areas (HRAs), High Dose Rate High Radiation Areas (HDR-HRAs), and Very High Radiation Areas (VHRAs).

o Key controls for all high radiation areas.

o Radioactive material control, including contamination and hot particles.

o 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; high radiation area (HRA), locked-HRA (LHRA) and very high radiation area (VHRA) controls for select operational/outage activities; personnel contamination events; storage/care of personal dosimeters; use of electronic dosimeters including evaluation of set-point determination; biases identified relative to TLD monitoring; remote monitoring procedures; post shutdown, fuel movement, and/or diving operations.

o Internal dose assessment, i.e., both in vivo and in vitro bioassay and air sampling capabilities. The documents should include guidance for 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 suspect alpha particle exposures.

o Contamination control, i.e., procedures for release of contaminated individuals or potentially contaminated materials from the radiologically controlled area (RCA).

• List five highest cumulative exposures or exposure rate tasks for current outage activities. Provide associated radiation work permit documents, if available.

• List of all positive whole body count (WBC), in vitro, or air sampling analyses since August 1, 2011, which resulted in an assigned CEDE equal to or exceeding 10 millirem

[Note, a listing should be provided for use by the inspectors to select a sample of issues for in-depth review during the on-site inspection].

• List of all personnel contamination events, dispersed contamination/discrete particles, identified since August 1, 2011. [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 current outage tasks with significant potential for significant release of airborne radioactive particulates.

• List of LHRAs, HDR-HRAs (>25 rem in one hour @ 30 cm), and VHRAs. Include areas with the potential to become a LHRA during routine operations or outages.

• Copies of all audits, self-assessments, and/or reviews related to internal or external dosimetry issues generated since August 1, 2011. The documents provided should to include any reviews/evaluations conducted of vendor facilities, e.g., corporate or outside vendor/ or corporate calibration facilities.

Enclosure

4

• List of corrective action reports generated since the last inspection related to access controls, including the following:

o Access controls, including high radiation area radiological incidents.

o Radiological events caused by radiation worker errors.

o Radiological events caused by radiation protection technician errors.

o Internal or external dosimetry issues/events.

• Available for onsite review during inspection:

o Elevation maps with most recent operating and outage radiation survey levels.

o National Source Tracking System documentation including source inventory and administrative data from National Source Tracking System.

71124.02: ALARA Planning and Controls

• Site and corporate procedures associated with maintaining site dose ALARA, including those involving ALARA work activities. These procedures should include:

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

< Radiation work permit preparation and worker compliance.

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

< Making changes to dose estimates during task performance.

< Work controls.

< Engineering controls.

< Exposure mitigation requirements.

• Most recent annual ALARA report and most recent refueling outage report.

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

• Historic trends and current status of plant source term.

• List approximately 10-15 work activities planned during the inspection likely to result in the highest personnel collective exposures and those which present the greatest radiological risk to workers (e.g. work in HRAs, diving, potentially changing radiological conditions). Include the dose projections and ALARA package numbers.

• ALARA Committee activity summaries (e.g. meeting minutes) for three (3) months or 3 meetings after the last refueling outage, and the three (3) months or 3 meetings prior to the upcoming refueling outage.

• Completed ALARA packages (including post-job reviews) for the five (5) work activities that were completed during the last outage which had the greatest collective dose and/or presented significant radiological risk.

Enclosure

5

• List of five (5) activities (including ALARA package number) from the previous 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 previous outage in which the estimated work hours were significantly different than the actual hours expended. List five (5) activities in which the estimated and actual hours expended were accurate.

• Outline of the source term reduction strategy. Information should include:

< Historic trends and current status of plant source term

< Factors that affect the source term

< Activities employed to reduce the source term

< Specific sources identified for reduction actions

< Source term reduction evaluation

< Results achieved since last inspection

• List of activities since that last inspection that were reviewed for ALARA problems and actions taken to prevent recurrence. Include corrective action report number(s) if applicable.

• List of corrective action reports generated since the last inspection related to the ALARA program, including the following:

< 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.

• Available for onsite review during the inspection:

< ALARA planning packages for jobs being performed during the outage.

< Temporary shielding requests generated for the outage.

< Records of personnel monitored for radiation exposure that show the total TEDE to date for each person. If possible, sort individuals by work group.

IP 71151: Performance Indicator Verification Monthly/Quarterly PI reports since August 1, 2011, 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 (July 2011 -

February 2012), and annual CY 2011, curies released by isotope and associated public dose assessments.

Enclosure

6 List of all PIP documents since August 1, 2011, using keywords such as: HRA, LHRA, VHRA, unintended dose, unlocked LHRA door, etc.

List of all CAP documents since August 1, 2011, using keywords abnormal/ unmonitored effluent release, etc.

List of all electronic dosimeter (ED) dose rate alarms and all ED dose alarms since August 1, 2011.

Inspector Contact Information Mr. Wade Loo (404) 997-4727 wade.loo@nrc.gov Mailing Address US Nuclear Regulatory Commission, Region II Attention: Mr. Wade Loo 245 Peachtree Center Ave., N.E Suite 1200 Atlanta, GA 30303 Enclosure