ML23017A006

Initial Information Request Inspection Report: 2023001

ML23017A006
Person / Time
Site:	Browns Ferry
Issue date:	01/12/2023
From:	Adam Nielsen NRC/RGN-II
To:	Garner J Tennessee Valley Authority
References
Download: ML23017A006 (1)

Text

From: Adam Nielsen To: Garner, Justin Keith Cc: Eggart, Jason Warren; Bob Kellner; Brian Bowker

Subject:

Browns Ferry 2023-01 RP inspection Document Request Date: Thursday, January 12, 2023 2:44:00 PM Attachments: BF_2023-01_RP_doc_request.pdf Please see the attached document request. Note that some of the items may be outside RPs purview, so coordination with other groups might be required (e.g. rad monitor calibration records, ventilation testing records, etc.).

We would like to have the documents available by February 17, 2023. However, if you run into difficulty and need more time for certain items, just let us know and we can work with you.

Please call me with any questions.

Thanks, Adam Nielsen Senior Health Physicist US NRC Region II (404) 997-4660

ML23017A006 Browns Ferry Nuclear Plant Radiation Safety Baseline Inspection Initial Information Request Inspection Report: 2023001 During the weeks of February 27 - March 3, and March 13 - 17, 2023, the NRC will perform a baseline Radiation Safety Inspection at the Browns Ferry Nuclear Plant (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 February 17, 2023.

If there are any questions about this inspection or the material requested, please contact the lead inspector, Adam Nielsen at 404-997-4660, 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 Inspection Dates: February 27 - March 3 and March 13 - 17, 2023 Documents Due to Region II: February 17, 2023 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 (Occupational and Public Cornerstones Only)

Lead Inspector: Adam Nielsen Sr. Health Physicist US NRC Region II (404) 997-4660 Adam.Nielsen@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. Pay particular attention to the date ranges for the items requested as they may change from item to item. 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.

Miscellaneous

1. Timeline of major outage activities for U2R22 (e.g. Gantt chart or similar list)

2. List of primary contacts for each inspection area w/phone numbers

3. Corrective action program procedure(s)

4. Most recent 10 CFR 61 analysis for the Dry Active Waste (DAW) waste stream

5. Offsite Dose Calculation Manual 71124.01 - Radiological Hazard Assessment and Exposure Controls

1. Procedures related to RP controls (e.g. Posting, labeling, surveys, 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 followup, etc.)

3. List of outage RWPs

4. List of all non-fuel items stored in spent fuel pool

5. Most recent self-assessment or audit covering RP controls

6. Outage ALARA report from the previous (most recent) refueling outage

7. ALARA planning packages for top 3 highest dose jobs for the U2R22 refueling outage

8. List of CRs related to RP controls/ALARA (e.g. radworker error, RP technician error, ALARA issues, posting issues, HRA/LHRA/VHRA issues, survey problems, etc.) issued since March 5, 2022.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

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, TEDE-ALARA guidance, PAPRs, storage, maintenance, training, QA, fit-testing, etc.)

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

4. SCBA qualification records a) List of all licensed operators qualified to use SCBA b) List of all RP personnel qualified to use SCBA

5. The last 2 surveillances performed on SCBA stored for emergency use (typically monthly)

6. The last 2 in-place filter testing surveillances of the HEPA/charcoal banks for the Unit 3 Main Control Room emergency air filtration system (typically every 18 months)

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 April 17, 2021.

71124.04 - Occupational Dose Assessment

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, use of passive monitoring if applicable, declared pregnant workers)

2. Current NVLAP accreditation certificate for lab used to process dosimetry

3. List of all dosimetry events that resulted in the following doses since April 17, 2021:

CEDE > 10 mrem SDE> 500 mrem Neutron dose > 50 mrem

4. List of all management over-rides of administrative annual dose limits since April 17, 2021

5. List of all personnel contamination events identified since April 17, 2021

6. Most recent alpha source term plant characterization

7. Area TLD results for general plant areas (not REMP TLDs), going back two years

8. The most recent DLR/SRD correlation analysis

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

10. Most recent audit or self-assessment of the dosimetry program

11. List of CRs generated since April 17, 2021, for internal or external dosimetry issues/events.

71124.05 - Radiation Monitoring Instrumentation

1. Procedures for:

a) calibration and source checks of portable radiation detection instruments b) calibration and source checks of small article monitor, personnel contamination monitor, portal monitor, whole body counting equipment, and continuous air monitors c) QA program for count room instruments

2. The last 2 calibration records for each of the following in-plant instruments:

a) Unit 3 Drywell High-range Area Radiation Monitors (last two cals for all detectors) b) Unit 3 Main Control Room Area Radiation Monitor c) Liquid Radwaste System Effluent Monitor d) Main Stack (normal range and wide range, last two cals for each)

e) Unit 3 Turbine Building Roof Ventilation Exhaust Monitor. (please contact the lead inspector if this particular request is confusing)

3. Radioactive source paperwork for the sources used to calibrate the instruments in item 2 above. This paperwork should include NIST/NBS certificates, as applicable, and traceability to the primary (factory) calibration

4. The last two surveillances (in-place filter tests and charcoal tests) performed on the Standby Gas Treatment System (last two for all trains)

5. The last 2 calibration records for each of the following RCA exit point instruments:

a) All Portal Monitors located at RCA exit b) All Small Article Monitors located at RCA exit c) All Whole body contamination monitors (ARGOS or equivalent) at RCA exit

6. Most recent calibration record of the Whole Body Counter used by Dosimetry

7. Most recent calibration record for all gamma spectroscopy detectors in the count room

8. Most recent calibration record for all liquid scintillation detectors in the count room

9. Most recent test record of the instrument calibrator (gamma irradiator validation testing/dose rate curves)

10. Interlaboratory comparison results for the onsite count room, going back two years.

11. Most recent audit or self-assessment covering RP and count room instruments (portables, RCA exit point, WBC, count room).

12. Most recent Radiation Monitoring System health report, if applicable.

13. List of CRs generated since April 17, 2021 related to portable instruments, area monitors, effluent monitors, CAMs, RCA release point monitors, WBCs, and count room instruments.

71151 - Performance Indicator (PI) Verification

1. Procedures for gathering and reporting NRC PI data, including any applicable desktop guides

2. List of electronic dosimeter alarms since March 5, 2022 (dose and dose rate)

3. List of CRs related to ODCM/effluent monitoring issues since March 5, 2022

4. 2022 Annual Effluent Report or 2022 year-end public dose totals if report is not yet available

5. 2023 year-to-date effluent public dose summary