ML20056E304

VC Summer 2020-002 Radiation Safety Baseline Inspection Information Request

ML20056E304
Person / Time
Site:	Summer
Issue date:	02/25/2020
From:	Kellner R NRC/RGN-II/DRS/EB3
To:	Bennett B Dominion Energy Co
References
IR 2020002
Download: ML20056E304 (7)

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ML20056E304 Summer Nuclear Station Radiation Safety Baseline Inspection Initial Information Request Inspection Reports: 2020002 During the week of April 20 - 24, 2020, the NRC will perform a baseline Radiation Safety Inspection at VC Summer Nuclear Station (NRC Inspection Procedures 71124.01, 71124.03, 71124.04, 71124.05, 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 April 3, 2020.

If there are any questions about this inspection or the material requested, please contact the lead inspector, Robert Kellner at Robert.Kellner@nrc.gov, at 404-997-4508, or the Engineering Branch 3 Chief, Binoy Desai at 404-997-4519.

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 Cornerstones Inspection Dates: April 20 - 24, 2020 Documents Due to Region II by: April 3, 2020 Inspection Procedures: IP 71124.01 Radiological Hazard Assessment and Exposure Controls IP 71124.03 In-plant Airborne Radioactivity Control and Mitigation IP 71124.04 Occupational Dose Assessment IP 71124.05 Radiation Monitoring Instrumentation IP 71151 Performance Indicator Verification Lead Inspector & Mailing Address:

Robert Kellner U.S. Nuclear Regulatory Commission Senior Health Physicist Region II US NRC Region II ATTN: Robert Kellner (404) 997-4508 245 Peachtree Center Ave., N.E Robert.Kellner@nrc.gov Suite 1200 Atlanta, GA 30303 Note: The current version of these documents is expected unless specified otherwise. Secure file server access (Certrec, SharePoint, etc.), or electronic media (CD/DVD), is preferred. To the extent possible, please organize the information as it is arranged below. Experience has shown that poorly organized files can lead to a less efficient inspection and places additional burden on licensee staff. 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 1, 2019 to present, unless otherwise specified. Pay particular attention to the date ranges for the items requested as they may change from item to item. We would prefer as much of the information as possible in electronic form. An index of the files 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. List of primary contacts for each inspection area including names and telephone numbers

2. Plant Management, Radiation Protection, and Chemistry organizational charts w/ contact numbers

3. Corrective action program procedure(s)

4. List of radiation protection procedures, including title and number

5. Most recent 10 CFR 61 analysis for the DAW waste stream

6. Outage schedule, including work activities to be conducted during the week of the inspection (e.g. Gantt chart or similar list).

Page 2 of 6

71124.01 - Radiological Hazard Assessment and Exposure Controls (Last inspected August 2019)

1. Procedures related to RP controls (e.g. Posting, labeling, surveys, survey frequency, RWPs, contamination control, HRA/LHRA/VHRA control, key control, control of divers, special controls during fuel offload, hot spots, ISFSI Controls, etc.)

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

3. List of outage & active Radiation Work Permits (RWPs) including dose and dose rate limits.

4. List of locations, or plant maps indicating the location, of all LHRAs and VHRAs. Include areas with the potential to become a LHRA during routine operations or outages.

5. List of Nationally Tracked Sources and copies of any National Source Tracking System transaction documentation (e.g., annual reconciliation, source transfers, etc.)

6. Most recent sealed source inventory record.

7. List of all non-fuel items stored in spent fuel pool (e.g. used filters, irradiated hardware, etc.).

8. The following Independent Spent Fuel Storage Installation (ISFSI) information:

a) Last two (2) routine radiological surveys b) As low as reasonably achievable (ALARA) planning and post reviews conducted for the last two ISFSI campaigns.

9. All self-assessments or audits covering radiological hazard assessment and exposure controls and HP controls since August 1, 2019 (if none, then provide the two most recent).

10. List of Corrective Action Program (CAP) documents (CR, NRC, AR, etc.) related to RP controls (e.g., radworker error, HP technician error, posting issues, Nationally Tracked Sources issue, HRA/LHRA/VHRA issues, survey problems, etc.) generated since August 1, 2019. This should be a list of corrective action documents containing a CAP document number and a brief description, not complete documents.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation (Last inspected November 2018)

1. Procedures related to airborne monitoring and control (e.g. use of purge systems, use of portable HEPA/charcoal units, temporary ventilation enclosures, use of CAMs, air sampling guidance, Alpha air sampling, etc.)

2. Procedures related to the use of respiratory protection devices (e.g., self-contained breathing apparatus (SCBA), total effective dose equivalent-ALARA guidance, powered air purifying respirators (PAPRs), storage, maintenance, training, quality assurance (QA), and fit-testing).

3. The last two (2) grade D air testing certificates for each supplied air system and SCBA filling station

4. Documentation of the last two (2) surveillances performed on SCBAs available for emergency use.

5. Two most recent surveillances that verify the flow rates for the following ventilation systems:

a) Auxiliary Building Main Exhaust Systems b) Reactor Building Exhaust System

6. Two most recent HEPA filter DOP and charcoal test results for the following ventilation systems:

a) Reactor Building Purge Exhaust System Page 3 of 6

b) Auxiliary Building HEPA and Charcoal Exhaust Systems

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

8. List of CAP documents (CR, NCR, AR, etc.) related to airborne monitoring and respiratory protection generated since November 1, 2018. This should be a list of corrective action documents containing a CAP document number and a brief description, not complete documents.

9. Available for onsite review during inspection a) Inventory, inspection and maintenance records for respiratory protection devices and SCBA equipment b) Training records, including fit tests, for SCBA qualified individuals

i. List of all licensed operators qualified to wear an SCBA ii. List of site ERO personnel qualified to wear an SCBA iii. List of all RP personnel qualified to wear an SCBA c) Training/qualification certificates for all onsite and/or vendor personnel qualified to repair SCBA that performed maintenance or repairs from November 2018 to present.

71124.04 - Occupational Dose Assessment (Last inspected November 2018)

1. Procedures related to occupational dose assessment (e.g. external dose monitoring, dosimetry issuance and use, unusual dosimetry occurrences, multi-badging/extremity dosimetry/badge relocation, Effective Dose Equivalent (EDE), personnel contamination events PCEs, storage/care of personal dosimeters, use of electronic dosimeters, in-vivo and in-vitro internal dose assessment, skin dose assessment, QC for whole body counter, use of passive monitoring, if applicable, and declared pregnant workers).

2. NVLAP accreditation documentation for the 2019, and current dosimetry used by the site as the dose of record.

3. ISFSI perimeter monitoring data (i.e. perimeter TLDs) from November 2018 through the most recent monitoring period.

4. Copy of the current facility alpha characterization and prospective dose evaluation, if available.

5. List of all positive air-sampling, whole body count, or in vitro analyses which resulted in a CEDE equal to or exceeding 10 millirem since November 1, 2018. [Note: only a listing should be provided for use by the inspectors to select a sample of issues for review during the onsite inspection]

6. List of all PCEs identified since November 1, 2018. [Note: only a listing should be provided for use by the inspectors to select a sample of issues for review during the onsite inspection.]

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

8. List of CAP documents (CR, NRC, AR, etc.) related to internal or external dosimetry issues/events generated since November 1, 2018. This should be a list of corrective action documents containing a CAP document number and a brief description, not complete documents.

71124.05 - Radiation Monitoring Instrumentation (Last inspected November 2018)

1. Radiation Protection and Maintenance procedures/guidance documents, as applicable, for the following:

a) Calibration and functional test/source checks of portable radiation detection instruments Page 4 of 6

b) Calibration and functional tests of small article monitor, personnel contamination monitor, portal monitor, counting room equipment, electronic alarming dosimeters, whole body counting equipment, and continuous air monitors c) Collection and analysis of high-range, post-accident effluent samples d) Determination of set-points for area radiation monitor, CAM, PCM, PM, and SAM equipment used for area and personnel monitoring equipment e) QA program (inter-laboratory comparison program) for count room instruments

2. The last two (2) calibration records for each of the following instruments:

a) Reactor Building High Range Radiation Monitors (RM-G7 and RM-G18) b) Reactor Building Air Sample (RM-A2) c) Auxiliary Building Ventilation Monitor (RM-A11) d) Sampling Room (RM-G3)

3. Documentation showing traceability to NIST and/or the primary calibration for the radioactive sources used to calibrate the instruments in item 2 above.

4. Emergency plan documents identifying which radiation monitors are used to determine emergency action levels (EALs).

5. Chart or procedure identifying emergency action levels (EALs) and actions associated with radiation monitors (if applicable).

6. Provide a current list of in service (available for use) SAMs, PCMs, PMs, air samplers, continuous air monitors (CAMs), portable radiation detection instruments, counting room (RP and Chemistry), and Whole Body Counters. [Note: The list will be used to select monitors for evaluation during the onsite inspection.)

7. Most recent calibration/test record for the instrument calibrator (e.g. Shepherd validation testing/dose rate curves)

8. Design documents and/or calculations showing how the alarm setpoints for the following instruments are determined:

a) PCMs and PMs at the RCA and Protected Area exit points b) CAMs

9. Result of the Inter-Laboratory Comparison Program since November 1, 2018.

10. Most recent Radiation Monitoring System engineering performance review/evaluation or system health report, if applicable.

11. Most recent audit or self-assessment covering RP instruments (e.g. portables, RCA exit point, WBC, count room). Include any reviews conducted of vendor facilities, as applicable

12. List of CAP documents (CR, NRC, AR, etc.) related to portable instruments, area monitors, CAMs, RCA release point monitors, WBCs, and count room instruments generated since November 1, 2018. This should be a list of corrective action documents containing a CAP document number and a brief description, not complete documents.

71151 - Performance Indicator Verification (Occupational and Public Cornerstones)

(Last inspected August 2019)

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

2. Monthly PI reports since July 1, 2019, and copies of associated condition reports for any Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual (RETS/ODCM) Radiological Effluent occurrences.

3. List of all CAP documents using search keywords such as: HRA, LHRA, VHRA, unintended dose, unlocked door, RETS/ODCM, abnormal or unmonitored release, offsite dose, and effluent release, etc. since July 1, 2019. This should be a list of corrective action documents containing a CAP document number and a brief description, not complete documents.

4. Most recent liquid and gaseous effluent release permits which specify the quarterly and Page 5 of 6

annual (year to date) curies released by isotope and the associated public dose assessments.

5. List of all electronic dosimeter (ED) alarms, for dose and dose rate, since July 1, 2019 Assistance Requested During On-Site Inspection

• Identification of radiological work activities available during the inspection week for observation, including notification of pre-job briefings, notification of risk significant work activities, and location of audio/visual surveillance for remote job coverage.

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

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 6 of 6