ML23027A012

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002 Radiation Safety Baseline Inspection Information Request
ML23027A012
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 01/26/2023
From: Kellner R
NRC/RGN-II/DRS/EB3
To: Kirkland W
- No Known Affiliation
References
Download: ML23027A012 (1)
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Text

ML23027A012 From: Bob Kellner To: WILLIAM KIRKLAND

Subject:

NRC Radiation Safety Inspection at V.C. Summer - April 2023 Date: Thursday, January 26, 2023 1:25:00 PM Attachments: SUM 2023002 RP Document Request List.pdf

Hank, Thanks for confirming that you will the licensing point of contact for the upcoming Radiation Safety Inspection at V.C. Summer in April.

Attached is a list of documents and information requested for the inspection. The request includes a list of the documents we routinely request for Inspection Procedures (IPs) 71124.01, 71124.08, and 71151. If you plan to upload the requested documents to CERTREC, using software to zip the numerous files into a single file prior to upload has proven to be very efficient.

As of right now, Jack Bell and I will be the inspectors of record coming onsite. I would appreciate it if you would let me know if Summer has any COVID-19 restrictions in place. If I receive any information on restriction of travel from NRC management, I will you let you know.

Please let me know if you have any questions.

Regards, Bob Robert Kellner Senior Health Physicist USNRC/Region II/DRS/EB3 Marquis One Tower Suite 1200 245 Peachtree Center Ave, NE Atlanta, GA 30303-1257 (404) 997-4508

V. C. Summer Nuclear Plant Radiation Safety Baseline Inspection Initial Information Request Inspection Report: 2023002 During the week of April 17 - April 21, 2023, the NRC will perform a baseline Radiation Safety Inspection at the V. C. Summer Plant (NRC Inspection Procedures 71124.01, 71124.08, 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 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 5, 2023.

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 17 - April 21, 2023 Documents Due to Region II by: April 5, 2023 Inspection Procedures: IP 71124.01 Radiological Hazard Assessment and Exposure Controls IP 71124.08 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation 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: 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 is requested from June 1, 2022 to present for IP 71124.01, and from April 1, 2022 for IP 71151. Documentation for IP 71124.08 is requested from July 1, 2021 to present.

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 may 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 (RP), and Chemistry organizational charts w/

contact numbers

3. Corrective action program procedure(s)
4. List of radiation protection procedures, including title and number
5. Outage schedule, including planned work activities to be conducted during the spring 2023 outage (e.g. Gantt chart or similar list).

Page 2 of 5

71124.01 - Radiological Hazard Assessment and Exposure Controls (Last inspected June 2022)

1. Site and/or corporate 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 planned outage & active online Radiation Work Permits (RWPs), including dose and dose rate limits.
4. List of locations, or plant maps indicating the location, of LHRAs and VHRAs. Include areas with the potential to become a LHRA during routine operations or outages.
5. List of all non-fuel items stored in spent fuel pool (e.g. used filters, irradiated hardware, etc.).
6. Technical basis documents (white paper, engineering calculation, etc.) related to the facility beta-gamma and alpha radiation characterization.
7. Outage ALARA report from the previous refueling outage.
8. ALARA planning packages for 3 highest dose jobs for the upcoming refueling outage.
9. All self-assessments or audits covering radiological hazard assessment and exposure controls and HP controls since June 1, 2022 (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, ALARA, etc.) generated since June 1, 2022. This should be a list of corrective action documents containing a CAP document number and a brief description, not complete documents.

71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation (Last inspected August 2021)

1. Provide procedures and guidance documents describing licensee compliance with 10 CFR 20, 61, and 71, and 49 CFR 170-189. Procedures/manuals should include:
  • Solid and liquid radioactive waste (radwaste) processing procedures
  • Procedure(s) for transferring radwaste resin and sludge discharges into shipping/disposal containers
  • Waste stream mixing and/or sampling procedures, including:
a. waste concentration averaging
b. use of scaling factors and calculations used to account for difficult-to-measure radionuclides
c. ensuring waste stream composition data accounts for changing operational parameters
  • Shipping/transportation procedures
  • Cask loading and closure procedures (licensee and vendor) applicable to last three cask transports
  • Monitoring impact of long-term storage of RAM
2. Site specific and corporate procedures related to 10 CFR Part 37 compliance (storage of RAM, 10 CFR Part 37 Security Plan, radiation protection and security procedures that Page 3 of 5

identify radiation protection interaction with security, or requirements related to 10 CFR Part 37 compliance, etc.)

3. List of locations of Category 1 and 2 material.
4. Supporting calculations for determination of whether an aggregation of RAM meets the definition of Category 1 or Category 2 (e.g., warehouse calculation).
5. List of Nationally Tracked Sources, and copies of any National Source Tracking System (NSTS) transaction documentation (e.g., annual reconciliation).
6. Copies of the two most recent sealed source inventory records.
7. Most recent radio-chemical sample analysis results (i.e., 10 CFR Part 61" analysis) for each of the radwaste streams (e.g., dry active waste (DAW), ion exchange resins, mechanical filters, and sludges and activated materials). For the most recent analyses of Dry Active Waste (DAW), include QA data (e.g. in-house vs. vendor lab comparisons, current results vs. database, etc.).
8. List and documentation of any changes made to the radwaste processing systems (liquid and solid) and/or the PCP since July 1, 2021, and associated 10 CFR 50.59 documentation, as appropriate
9. Plant drawings sufficient to permit the inspector to walkdown the liquid and solid radwaste processing systems, to verify current system configuration/ operation agree with the descriptions contained in the Updated Final Safety Analysis Report and in the PCP.
10. Copies of applicable transport cask Certificate of Compliance for the last three transport cask shipments
11. List of RAM storage areas, including satellite radiological controlled areas (RCAs)
12. Log of RAM and radwaste shipments (LSA I, II, IIII; SCO I, II, Type A, or Type B) since July 1, 2021. (The inspectors will select three to five packages to review in detail.)
13. Most recent self-assessment or audit of Shipping/radwaste processing and RAM storage programs
14. List of CAP documents (AR, CR, NCR, etc.) related to radwaste and RAM processing and/or transportation (e.g., keyword searches for RAM, shipping, radwaste, 10 Part 61, etc.) issued since July 1, 2021. This should be a list of corrective action documents containing an (AR, CR, NCR, etc.) number and brief description, not full documents.
15. Available for onsite review during the inspection
  • Site drawing(s) showing the location of stored RAM and stored radwaste
  • Training and qualification records for personnel responsible for radwaste processing, packaging, and making shipments of radioactive material (RAM) and radwaste.
  • Training and qualification records for personnel responsible for implementation of the 10 CFR Part 37 security plan (e.g., security staff and health physics staff)
  • Documentation describing the status of any radwaste process equipment that is not operational and/or is abandoned in place.
  • Discussion of the sites waste disposal volume and waste reduction program.

71151 - Performance Indicator Verification (Occupational and Public Cornerstones)

(Last inspected June 2022)

1. Site, Corporate, and radiation protection specific procedure(s) for identifying, reporting, tracking, and correcting performance indicator (PI) occurrences.
2. Monthly PI reports since April 1, 2022, and copies of associated condition reports for any Page 4 of 5

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 April 1, 2022. This should be a list of corrective action documents containing a CAP document number and a brief description, not complete documents.
4. Last liquid and gaseous effluent release permit for CY 2022 which specifies the quarterly and annual (year to date) curies released by isotope and the associated public dose assessment(s).
5. List of all electronic dosimeter (ED) dose and dose rate alarms since April 1, 2022.

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 coordinating observation of radiological job coverage activities and performing plant walk-downs.
  • Identification of any radioactive material packaging, shipping, or transportation activities available during the inspection for inspector observation.
  • Coordination with security to review and discuss the annual Access Authorization and Security Program reviews completed by the site as they relate to Part 37.
  • HP assistance in plant walkdowns of areas identified for storage of Category 1 and 2 materials.

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 5 of 5

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