ML24059A405

Document Request for Sequoyah Nuclear Plant - Radiation Protection Inspection - Inspection Report 2024-02

ML24059A405
Person / Time
Site:	Sequoyah
Issue date:	02/28/2024
From:	Adam Nielsen NRC/RGN-II/DRP/RPB3
To:	Mcneil A - No Known Affiliation
References
Download: ML24059A405 (1)

Text

From: Adam Nielsen To: McNeil, Andrew Clair Cc: McAdoo, Joseph Harold; Jack Bell

Subject:

Document request for upcoming RP inspection at Sequoyah Date: Wednesday, February 28, 2024 2:09:00 PM Attachments: SEQ_2024-02_RP_Doc_Request.pdf

Please see the attached document request for our upcoming baseline RP inspection scheduled for April 8 - 12 and April 22 - 26, 2024. 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 filter testing records, etc).

We would like to have the documents available by April 1, 2024. However, if you run into difficulty and need more time for certain items, just let us know and we can work with you.

It has been our experience that inspection procedure 71124.05 Instruments, item number 3 (calibration source traceability paperwork) has been challenging for licensees to produce.

I would encourage you to begin gathering those particular documents at your earliest convenience.

Also, please ensure that technical staff (knowledgeable in the areas of inspection) are available to answer questions from the inspection team. I.e. on day shift during the weeks of inspection if possible.

Please call or email me if you have any questions.

Thanks, Adam Nielsen Senior Health Physicist US NRC Region II (404) 997-4660 Sequoyah Nuclear Plant Radiation Safety Baseline Inspection Initial Information Request Inspection Report: 2024 002

During the weeks of April 8 - 12 and April 22 - 26, 2024, the NRC will perform a baseline radiation safety inspection at Sequoyah 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 April 1, 2024.

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 letter contains voluntary information collections that are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB) approved these information collections (approval number 3150- 0011). The burden to the public for these information collections is estimated to average 24 hours per response. Send comments regarding this information collection to the FOIA, Library and Information Collection Branch, Office of the Chief Information Officer, Mail Stop: T6-A10M, U.S. Nuclear Regulatory Commission, Washington, DC 20555- 0001, or by email to Infocollects.Resource@nrc.gov, and to the Desk Officer, Office of Information and Regulatory Affairs, NEOB- 10202, (3150- 0011) OMB, Washington, DC 20503.

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: April 8 - 12, 2024 April 22 - 26, 2024

Documents Due to Region II: April 1, 2024

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 Cornerstone)

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

2. Corrective action program procedure(s)

3. Offsite Dose Calculation Manual (ODCM)

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

5. Outage schedule showing work planned for the weeks of inspection.

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, etc.)

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

3. Procedures related to ALARA (e.g. temporary shielding, ALARA planning, source term reduction, etc.)

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

5. ALARA work plans for the top 3 dose jobs for the upcoming outage

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

7. Outage ALARA report from the previous 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.) created since April 1, 2023.

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 most recent in-place filter testing surveillance of the HEPA/charcoal banks for the Main Control Room emergency air filtration system, as specified in TS 5.5.9 items a, b, and c.

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 November 19, 2022.

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 November 19, 2022:

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

4. List of all management over-rides of administrative annual dose limits since November 19, 2022

5. List of all personnel contamination events identified since November 19, 2022

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

10. List of CRs generated since November 19, 2022, 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) U1 Containment High Range Monitor, 1-RE 271 b) U1 Containment High Range Monitor, 1-RE 274 c) Waste Disposal System Liquid Effluent, 0-RE 122 d) U1 Shield Building Vent Normal Range Noble Gas, 1-RE 400 e) U1 Accident Range Noble Gas, 1- RE-90-261 e) U1 Shield Building Vent Flow Monitor

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 Unit 1 Emergency Gas Treatment System (EGTS), Train A, as specified in TS 5.5.9 items a, b, and c.

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 (Shepherd 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 November 19, 2022 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 April 1, 2023 (dose and dose rate)