ML21253A233

Request for Information: Comanche Peak Nuclear Power Plant, Units 1 and 2 (05000445 and 05000446); Occupation Radiation Safety (71124.01, 71124.02, 7511)

ML21253A233
Person / Time
Site:	Comanche Peak
Issue date:	09/09/2021
From:	NRC Region 4
To:
References
IR 2021004
Download: ML21253A233 (5)

Text

The following items are requested for the Occupational Radiation Safety Inspection at Comanche Peak Dates of Inspection: 10/18/2021 to 10/22/2021 Integrated Report 2021004 Inspection areas are listed in the attachments below.

Please provide the requested information on or before Tuesday, October 05, 2021.

Please submit this information using the same lettering system as below. For example, all contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled 1-A, applicable organization charts in file/folder 1-B, etc.

The information should be provided in electronic format or a secure document management service. If information is placed on a secured document management system, please ensure the inspection exit date entered is at least 30 days later than the onsite inspection dates, so the inspectors will have access to the information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which file the information can be found.

If you have any questions or comments, please contact Bernadette Baca at 817-200-1235 or via e-mail at Bernadette.Baca@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT 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, control number 3150-0011.

1. Radiological Hazard Assessment and Exposure Controls (71124.01) and Performance Indicator Verification (71151)

Date of Last Inspection, to include 71151 data: November 1, 2020 A. List of contacts and telephone numbers for the Radiation Protection Organization Staff and Technicians, as well as the Licensing/Regulatory Affairs staff. Please include area code and prefix. If work cell numbers are appropriate, then please include them as well.

B. Applicable organization charts including position or job titles. Please include as appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),

Engineering, and Emergency Protection. (Recent pictures are appreciated.)

C. Copies of audits, self-assessments, LARs, and LERs written since the last inspection date, related to this inspection area D. Procedure indexes for the radiation protection procedures and other related disciplines.

E. Please provide procedures related to the following areas noted below. Additional procedures may be requested by number after the inspector reviews the procedure indexes.

1. Radiation Protection Program

2. Radiation Protection Conduct of Operations, if not included in #1.

3. Personnel Dosimetry

4. Posting of Radiological Areas

5. High Radiation Area Controls

6. RCA Access Controls and Radiation Worker Instructions

7. Conduct of Radiological Surveys

8. Radioactive Source Inventory and Control

9. Fuel Pool Inventory Access and Control F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently committed to relative to this program. Please include the revision and/or date for the commitment and where this may be located in your current licensing basis documents.

G. Please provide a summary list of corrective action documents (including corporate and sub-tiered systems) since the last inspection date.

1. Initiated by the radiation protection organization

2. Assigned to the radiation protection organization NOTE: These lists should include a description of the condition that provides sufficient detail that the inspectors can ascertain the regulatory impact, the significance level assigned to the condition, the status of the action (e.g., open, working, closed, etc.) and the search criteria used. Please provide in document formats which are sortable and searchable so that inspectors can quickly and efficiently determine appropriate sampling and perform word searches, as needed. (Excel spreadsheets are the preferred format.) If codes are used, please provide a legend for each column where a code is used.

H. List of radiologically significant work activities scheduled to be conducted during the inspection period. (If the inspection is scheduled during an outage, please also include a list of work activities greater than 1 rem, scheduled during the outage with the dose

estimate for the work activity.) Please include the radiological risk assigned to each activity.

I. Provide a summary of any changes to plant operation that have resulted or could result in a significant new radiological hazard. For each change, please provide the assessment conducted on the potential impact and any monitoring done to evaluate it.

J. List of active radiation work permits and those specifically planned for the on-site inspection week.

K. Please provide a list of air samples taken to verify engineering controls and a separate list for breathing air samples in airborne radiation areas or high contamination work areas. Please include the RWP the breathing air sampling supports.

L. Please provide the current radioactive source inventory, listing all radioactive sources that are required to be leak tested. Indicate which sources are deemed 10 CFR Part 20, Appendix E, Category 1 or Category 2. Please indicate the radioisotope, initial and current activity (w/assay date), and storage location for each applicable source.

M. Please provide the last two leak test results for all required/applicable radioactive sources. Please specifically indicate the sources that have failed its leak test within the last two years. Provide any applicable condition reports.

N. A list of all non-fuel items stored in the spent fuel pools, and if available, their appropriate dose rates (Contact / @ 30cm)

O. A list of radiological controlled area entries greater than 100 millirem, since the last inspection date. The list should include the date of entry, some form of worker identification, the radiation work permit used by the worker, dose accrued by the worker, and the electronic dosimeter dose alarm set-point used during the entry (for Occupational Radiation Safety Performance Indicator verification in accordance with IP 71151).

P. A list describing VHRAs and TS HRAs (> 1 rem/hour) that are current and historical.

Include their current status, locations, and control measures.

Q. Temporary effluent monitor locations and calibrations (AMS-4) used to monitor normally closed doors or off-normal release points (e.g., equipment hatch or turbine heater bay doors). Include any CRs associated with this monitoring or instrumentation.

2. Occupational ALARA Planning and Controls (71124.02)

Date of Last Inspection: May 17, 2021 A. List of contacts and telephone numbers for ALARA program personnel, as well as the Licensing/Regulatory Affairs staff. Please include area code and prefix. If work cell numbers are appropriate, then please include them as well.

B. Applicable organization charts including position or job titles. Please include as appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),

Engineering, and Emergency Protection. (Recent pictures are appreciated.)

C. Copies of audits, self-assessments, LARs, and LERs, written since the date of last inspection, focusing on ALARA D. Procedure index for ALARA Program procedures and other related disciplines.

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews the procedure indexes.

1. ALARA Program

2. ALARA Planning

3. ALARA Reviews

4. ALARA Committee

5. Radiation Work Permit Preparation F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently committed to relative to this program. Please include the revision and/or date for the commitment and where this may be located in your current licensing basis documents.

G. Please provide a summary list of corrective action documents (including corporate and sub-tiered systems) written since the date of last inspection, related to the ALARA program, including exceeding RWP Dose Estimates.

NOTE: These lists should include a description of the condition that provides sufficient detail that the inspectors can ascertain the regulatory impact, the significance level assigned to the condition, the status of the action (e.g., open, working, closed, etc.) and the search criteria used. Please provide in document formats which are sortable and searchable so that inspectors can quickly and efficiently determine appropriate sampling and perform word searches, as needed. (Excel spreadsheets are the preferred format.) If codes are used, please provide a legend for each column where a code is used.

H. List of work activities (RWPs) greater than 1 rem, since date of last inspection, including the original dose estimates and actual doses accrued. (Excel format preferred). Please provide all revisions/changes, as well as any related RWPs that support the work activity.

I. List of active work activities (RWPs) that will be in use while we are onsite, including the dose and dose rate settings, and if available, the planned dose. Include planning documents and surveys. Include radiological risk assessments and proposed control measures.

J. Site dose totals for the past 3 years (based on dose of record). Also provide the current year-to-date (YTD) collective radiation exposure (CRE). In addition, please provide another document that separates the online and outage doses for the past 3 years.

K. Most recent assessment of your isotopic mix, including the hard-to-detect radionuclides and alpha hazards. Include a list of new and historical exposure issues (radiological source term or high exposure areas/activities).

L. If available, provide a copy of the lessons learned from the most recently completed outage for each unit. Include a summary list of any associated corrective action documents and the current status of any corrective actions assigned.

M. Please provide the methods/reports that are in your process to meet the requirements of 10 CFR 20.1101(c) for periodic review of your RP program.

N. Current exposure trends (BRAC dose rates and/or source term information).

3. 71151 Performance Indicators: Occupational and Public Radiation Safety Cornerstone A. For the Occupational Radiation Safety Cornerstone, items have been requested under the 7221.01 request.

B. For the Public Radiation Safety Cornerstone, please provide the following data since November 1, 2020:

1. Chemistry or other department quarterly effluent release comparison to ODCM and regulatory limits review; i.e. data as included in your Annual Effluent Report Table 9.1, Liquid and Gaseous Batch Release Summary; Tables 9.3, Gaseous Effluents - Summation of All Releases; Table 9.4, Gaseous Effluents - Ground Level Releases; Table 9.5, Liquid Effluents - Summation of All Releases; Table 9.6, Liquid Effluents; Table 9.7, Dose Due to Liquid Releases; and Table 9.8, Air Dose Due To Gaseous Releases.

2. A summary list of corrective action documents related to (a) potentially unmonitored release pathways, as well as plant incidents involving leaking radioactive liquids or gases that are not bounded by plant collection systems and could be potential unmonitored release paths and (b) Radiological effluent release occurrences per reactor unit that exceed the ODCM and Part 50 Appendix I values.