ML22223A119

RP Inspection Document Request Letter Final

ML22223A119
Person / Time
Site:	Surry
Issue date:	08/14/2022
From:	Diaz-Velez J NRC/RGN-II/DRS/EB3
To:	Virginia Electric & Power Co (VEPCO)
References
IR 2022004
Download: ML22223A119 (7)

Text

Surry Nuclear Power Station Baseline Radiation Safety Inspection Initial Information Request Inspection Reports: 050-00280 and 050-00281/2022004

During the weeks of October 17-21, 2022, and November 14-18, 2022, the U.S. Nuclear Regulatory Commission (NRC) will perform a Baseline Radiation Safety Inspection at the Surry Nuclear Power Station (NRC Inspection Procedures 71124.01, 71124.03, 71124.04, 71124.05 and 71151).

To minimize the impact to your onsite resources during the inspection and ensure the inspectors have the necessary information to complete the inspection while on site, we have enclosed a request for documents needed for this activity. The NRC requests that these documents be provided to the inspectors no later than October 3, 2022.

If there are any questions about this inspection or the material requested, please contact the lead inspector, José M. Díaz-Vélez at 404-997-4736, 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/readingrm/

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 Licensee: Surry Nuclear Power Station Docket Number: 050-00280 and 050-00281 SNPS Licensing

Contact:

Maria S. Groshner (757) 365-2593 maria.s.groshner@dominionenergy.com

Inspection Dates: October 17-21, 2022, and November 14-18, 2022 Documents Due to Region II by: October 3, 2022

NRC Inspection Procedures (IPs):

71124.01 - Radiological Hazard Assessment and Exposure Controls 71124.03 - In-Plant Airborne Radioactivity Control and Mitigation 71124.04 - Occupational Dose Assessment 71124.05 - Radiation Monitoring Instrumentation 71151 - Performance Indicator Verification

Note: Please provide the current version of these documents in an electronic format if possible (The preferred file format is MSWord, or searchable.pdf files). To the extent possible, please organize the information in directories as requested below and if possible, use a descriptive name for the files provided. Recent experience has demonstrated the most efficient method to transfer this information to the NRC is via Certrec. It is best to upload all the requested information in one large zip file. If there are questions regarding the documents requested, or method of transfer, please do not hesitate to contact the lead inspector.

Documentation for inspection procedure 71124.01, should be from April 20, 2021.

Documentation for inspection procedures 711124.03, 71124.04, and 71124.05, should be from July 7, 2020, and 71151 should be from June 1, 2021. These dates are approximate to the last time these inspections were conducted. Also, provide only a listing and title for Condition Reports (CRs) requested for each inspection procedure and the inspectors will select a sample from the list for in-depth review during the inspection. Note that some of the items may be outside RPs purview, so some coordination with other groups might be required (e.g. rad monitor calibration records, ventilation testing records, etc.).

If you have any questions, please call José M. Díaz-Vélez at (404) 997-4517. Thank you in advance for your effort in putting together this material.

General and Miscellaneous Information

1. List of primary site contact(s) for each inspection area including name(s), e-mail address, and telephone number(s).

2. Corrective Action Program procedures.

3. Plant Management and Radiation Protection organizational charts w/ contact numbers.

4. Schedule of major maintenance/work activities during the weeks of the inspection (Gantt chart if available).

5. Internal and external assessments and audits of the RP program since July 7, 2020 (excluding INPO).

1 Assistance Requested During On-Site Inspection

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

2. Health physics assistance in plant walk-downs and information concerning job coverage of ongoing activities to assess access controls.

71124.01 - Radiological Hazard Assessment and Exposure Controls (Last inspected on April 30, 2021)

1. Site and Corporate procedures related to Radiation Protection (RP) controls (e.g.,

posting, labeling, surveys, RWPs, contamination control, high radiation areas (HRA/LHRA/VHRA) control, key control, ALARA, control of divers, special controls during fuel offload, hot spots, etc.)

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

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

4. 10 CFR Part 61 samples that help describe your plant source term (e.g., DAW, Resins, filters, etc.)

5. List of non-fuel items stored in spent fuel pool (SFP); and a list of areas where radioactive materials are used or stored. Note: These items will be used by the inspectors while on-site and should not be uploaded to the document sharing mechanism

6. List of locations, or plant maps indicating the location, of locked high radiation areas (LHRAs) and very high radiation areas (VHRAs), including areas with the potential to become a LHRA during routine operations or outages

7. Most recent surveys of LHRAs and VHRAs (as applicable).

8. Self-assessments or audits covering radiological hazard assessment and exposure controls and HP controls since last inspection (if none, then provide the most recent).

9. Technical basis documents (white papers, engineering calculation, etc.) related to the facility beta-gamma and alpha radiation characterization. Please, provide copy of this item under NRC IP 71124.04, Occupational Dose Assessment request listed below.

10. Outage ALARA report from the previous outage.

11. ALARA planning packages for the 3 highest dose jobs for the upcoming refueling outage.

12. List of Corrective Action Program (CAP) documents (CR, NRC, AR, etc.) related to RP controls (e.g., radworker error, HP technician error, posting issues, radioactive source controls, HRA/LHRA/VHRA issues, ALARA, survey problems, etc.) generated since last inspection (May 2021). This should be a list of corrective action documents containing a CAP document number and a brief description, not complete documents.

2 71124.03 - In-Plant Airborne Radioactivity Control and Mitigation (Last Inspected on July 7, 2020)

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.), as applicable

2. Procedures related to the use of respiratory protection devices, (e.g., SCBA, TEDEALARA guidance, PAPRs, storage, maintenance, training, QA, fit-testing, etc.)

3. Copy of the last 2 grade D air testing certificates for each supplied air system and SCBA filling station

4. Documentation of the last 2 surveillances performed on SCBAs and negative pressure respirators available for emergency use, and negative pressure respirators designated as in storage but available for use.

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

a. Reactor Auxiliary Building Ventilation System

b. Surry Radwaste Facility Ventilation System

c. Fuel Handling Building Exhaust System

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

a. Control Room Area Ventilation System (Emergency Filtration System)

b. Reactor Auxiliary Building Ventilation System

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

8. List of CRs related to airborne monitoring and respiratory protection since July 7, 2020.

This should be a list of corrective action documents containing a CR number and brief description, not full CRs.

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

c. List of all licensed operators qualified to wear an SCBA

d. List of site ERO personnel qualified to wear an SCBA

e. List of all RP personnel qualified to wear an SCBA

10. Training/qualification certificates for all onsite and/or vendor personnel qualified to repair SCBA that performed maintenance or repairs from July 7, 2020, to present.

3 71124.04 - Occupational Dose Assessment (Last Inspected on July 7, 2020)

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

2. NVLAP accreditation documentation for years 2020-2021, and the current dosimetry used by the site

3. List of all positive whole-body counts, in vitro, or air sampling analyses which resulted in a CEDE equal to or exceeding 10 millirem since July 7, 2020. [Note:

only a listing should be provided for use by the inspectors to select a sample of issues for review during the onsite inspection]

4. List of all facial contamination(s) and Level III personnel contamination events identified since July 7, 2020. [Note: only a listing should be provided for use by the inspectors to select a sample of issues for review during the onsite inspection.]

5. Most recent neutron characterization.

6. Last 18 months of area TLD results for general plant areas (not REMP TLDs)

7. Copies of current WBC libraries (e.g., routine, medical, investigative, etc.)

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

9. List of CRs generated since July 7, 2020, for internal or external dosimetry issues/events. This should be a list of corrective action documents containing a CR number and brief description, not full CRs.

71124.05 - Radiation Monitoring Instrumentation (Last Inspected on July 7, 2020)

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

2. Calibration and functional test/source checks of installed and portable radiation detection instruments

3. 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

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

5. Determination of set-points for used for area radiation and personnel/equipment monitoring (e.g., area radiation monitors, CAMs, PCMs, PMs, SAMs, etc.)

6. QA program (inter-laboratory comparison program) for count room instruments

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7. The last 2 calibration records for each of the following instruments:

a. Main Control Room (1-RM-RMS-157)

b. Surry Radwaste Facility (1-RRM-RE-126-HIC storage and handling Area)

c. CTMT high range radiation monitors (1/2-RM-RMS-127/227 & 128/228)

d. Fuel Pit Bridge (RM-RI-153)

e. Containment Gas (RM-RI-( )60)

f. Plant Vent #2 (1-VG-RI-131 B or C)

g. Process Vent (1-GW-RI-130 B or C)

8. Documentation showing traceability to NIST and/or the primary calibration for the radioactive sources used to calibrate the instruments in item 7 above.

9. Chart or procedure listing EALs associated with radiation monitors

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

11. 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.)

12. Most recent test record of the instrument calibrator (e.g., Shepherd validation testing/dose rate curves).

13. 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

14. Results of the Inter-Laboratory Comparison Program from July 7, 2020, to year-to-date.

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

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

17. List of CRs related to portable instruments, area monitors, CAMs, RCA release point monitors, WBCs, and count room instruments generated since July 7, 2020.

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

5 71151 - Performance Indicator Verification (Occupational and Public Cornerstones)

(Last Inspected on June 1, 2021)

1. Procedure(s) for gathering and reporting PI data

2. List of all CRs related to effluent dose/ODCM issues since June 1, 2021. This should be a list of corrective action documents containing a CR number and brief description, not full CRs.

3. List of all CRs related to LHRA/VHRA issues or significant (>100 mrem) unintended doses since June 1, 2021. This should be a list of corrective action documents containing a CR number and brief description, not full CRs.

4. 2021 Annual Effluent Report

5. Most recent gaseous and liquid effluent evaluation of dose to the public (year-to-date doses).

6. List of electronic dosimeter alarms since June 1, 2021 (include dose and dose rate).

Inspector Contact Information: Mailing Address:

José M. Díaz-Vélez U.S. Nuclear Regulatory Commission Sr. Health Physicist US NRC Region II (404) 997-4736 ATTN: José M. Díaz-Vélez jose.diaz-velez@nrc.gov 245 Peachtree Center Ave., N.E Suite 1200 Atlanta, GA 30303

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