ML24144A243

002 Radiation Safety Baseline Inspection Information Request

ML24144A243
Person / Time
Site:	Surry
Issue date:	03/08/2024
From:	Jonathan Rivera NRC/RGN-II/DRS/EB3
To:	Abbott J, Groshner M, Newman S, Terry W, True M Dominion Energy Co, Virginia Electric & Power Co (VEPCO)
References
IR 2024002
Download: ML24144A243 (1)

Text

ML24144A243

From: Jonathan Rivera (He/Him/His)

To: johnnie.abbott@dominionenergy.com; mike.true@dominionenergy.com; william.terry@dominionenergy.com; Stephen.C.Newman@dominionenergy.com; maria.s.groshner@dominionenergy.com Cc: Nick Eckhoff; Jack Bell; Jose Diaz; Darrell Neal; Adam Nielsen; Binoy Desai Bcc: Jonathan Rivera (He/Him/His)

Subject:

Surry NRC RP Inspection - April and May 2024 Date: Friday, March 8, 2024 8:00:00 AM Attachments: Surry 2024-002 RP RFI.pdf

Good morning,

Please find attached the document request for the upcoming NRC RP inspection at Surry. We are requesting documents be provided to us by April 8th, 2024. If you have any questions, please feel free to reach out to me. I will be the lead inspector.

Thank you, Jonathan

Jonathan Rivera Health Physicist NPAAC - Region II Lead Engineering Branch 3 Division of Reactor Safety U.S. NRC - Region II Office: 404-997-4646 Email: jonathan.rivera@nrc.gov Surry Power Station Radiation Safety Baseline Inspection Initial Information Request Inspection Report: 2024-002

During the weeks of April 15 - 19 and May 6 - 10, 2024, the NRC will perform a baseline Radiation Safety Inspection at the Surry Power Station (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. 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 these documents are up-to-date, and complete, thereby minimizing the number of additional documents requested during the preparation, and/or the onsit e portions of the inspection. The NRC requests that these documents be provided to the inspectors no later than April 8, 2024.

If there are any questions about this inspection or the material requested, please contact the lead inspector, Jonathan Rivera at 404-997-4646, or the Engineering Branch 3 Branch 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 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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 Occupational and Public Radiation Safety Cornerstones

Inspection Dates: April 15 - 19 and May 6 - 10, 2024

Documents Due to Region II by: April 8, 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

Lead Inspector Contact Information:

Jonathan Rivera U.S. Nuclear Regulatory Commission Health Physicist Region II US NRC Region II ATTN: Jonathan Rivera (404) 997-4646 245 Peachtree Center Ave., N.E Jonathan.Rivera@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. To the extent possible, please organize the information as it is arranged below. Pay attention to the date ranges for the items requested as they may change from item to item. Please redact all PII in any records submitted. 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.

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 select documents/areas from the list for on-site review.

Miscellaneous

1. Plant Management, Radiation Protection, and Chemistry organizational charts.

2. List of primary contacts for each inspection area with contact information.

3. Corrective Action Program (CAP) procedure(s).

4. List of radiation protection procedures, including title and number.

5. Most recent 10 CFR 61 analysis for the DAW waste stream.

6. Most recent copy of the Offsite Dose Calculation Manual (ODCM).

7. U1R32 outage schedule, including work activities to be conducted during the weeks of the inspection (e.g., Gantt chart or similar list).

Page 2 of 6 71124.01 - Radiological Hazard Assessment and Exposure Controls (Last inspected May 2023)

1. Site and corporate procedures related to RP controls (e.g., postings, labeling, surveys, survey frequency, Radiation Work Permits [RWPs], contamination control, HRA/LHRA/VHRA controls, key control, control of divers, special controls during fuel offload, hot spots, etc.).

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

3. List of planned outage & active online 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 the 3 highest dose jobs for the upcoming U1R32 refueling outage.

9. All self-assessments or audits covering radiological hazard assessment and exposure controls and HP controls since May 1, 2023.

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 issues, HRA/LHRA/VHRA issues, survey problems, ALARA, etc.) generated since May 1, 2023. This should be a list of corrective action documents containing a CAP document number and a brief description, not complete documents.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation (Last inspected November 2022)

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 two most recent HEPA filter DOP and charcoal test results for the Main Control Room ventilation system.

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

5. 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.

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

7. List of CRs related to airborne monitoring and respiratory protection since November 1, 2022. This should be a list of corrective action documents containing a CAP document number and a brief description, not complete documents.

8. Available for onsite review during inspection:

a) Inventory, inspection, and maintenance records for respiratory protection devices and SCBA equipment.

b) Access to electronic training records, including fit tests, for SCBA qualified individuals.

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

Page 3 of 6 d) List of site ERO personnel qualified to wear an SCBA.

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

f) Training/qualification certificates for all onsite and/or vendor personnel qualified to repair SCBAs that performed maintenance or repairs from November 1, 2022 to present.

71124.04 - Occupational Dose Assessment (Last inspected November 2022)

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 CY 2022, CY 2023, and the current year for worker 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 November 1, 2022. [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 Level III personnel contamination events identified since November 1, 2022.

[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 (including the ISFSI area).

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 November 1, 2022 for internal or external dosimetry issues/events. This should be a list of corrective action documents containing a CAP document number and a brief description, not complete documents.

71124.05 - Radiation Monitoring Instrumentation (Last inspected November 2022)

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

a) Calibration and functional test/source checks of portable radiation detection instruments.

b) 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.

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

d) Determination of set-points for area radiation monitor, CAM, PCM, PM, and SAM equipment used for area and personnel monitoring equipment.

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

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

a) Plant Vent Stack Monitors 130 A & B b) Radwaste Facility Liquid Waste Disposal Monitor 131 c) Unit 1 Containment High-Range Radiation Monitors 127 & 128

3. Documentation showing traceability to NIST and/or the primary calibration for the radioactive sources used to calibrate the instruments in item 2 above.

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4. Chart or procedure listing emergency action levels (EALs) associated with radiation monitors.

5. 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.]

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

7. Results of the counting room and whole-body counter Inter-Laboratory Comparison Program since November 1, 2022.

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

a) Reactor Auxiliary Building Ventilation System b) Waste Processing Building Ventilation

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

10. 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.

11. List of CAP documents (CR, NRC, AR, etc.) related to portable instruments, area monitors, CAMs, RCA release point monitors, WBCs, and count room instruments generated since November 1, 2022. This should be a list of corrective action documents containing a CAP document number and a brief description, not complete documents.

71151 - Performance Indicator Verification (Occupational and Public Cornerstones)

(Last inspected May 2023)

1. Site, Corporate, and radiation protection specific procedure(s) for identifying, reporting, tracking, and correcting performance indicator (PI) occurrences.

2. List of all CAP documents related to effluent dose/ODCM issues using search keywords such as RETS/ODCM, abnormal or unmonitored release, offsite dose, and effluent release, etc. since May 1, 2023. This should be a list of corrective action documents containing a CR number and brief description, not full CRs.

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

4. List of electronic dosimeter alarms since May 1, 2023 (dose and dose rate).

Assistance Requested During On-Site Inspection

x 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.

x Health physics assistance in coordinating observation of radiological job coverage activities and performing plant walk-downs.

x Identification of any installed radiation monitoring calibration activities planned that may be available for inspector observation during the inspection.

Page 5 of 6 Lead Inspector Contact Information: Mailing Address:

Jonathan Rivera U.S. Nuclear Regulatory Commission Health Physicist US NRC Region II (404) 997-4646 ATTN: Jonathan Rivera Jonathan.Rivera@nrc.gov 245 Peachtree Center Ave., N.E Suite 1200 Atlanta, GA 30303

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