ML24145A173

002 Radiation Safety Baseline Inspection Information Request

ML24145A173
Person / Time
Site:	Harris
Issue date:	02/26/2024
From:	Jonathan Rivera NRC/RGN-II/DRS/EB3
To:	Mcdaniel S Duke Energy Progress
References
IR 2024002
Download: ML24145A173 (1)

Text

From: Jonathan Rivera (He/Him/His)

To: McDaniel, Sarah A Cc: Binoy Desai; Darrell Neal; Bob Kellner; Jose Diaz Bcc: Jonathan Rivera (He/Him/His)

Subject:

Harris RP inspection document request.

Date: Monday, February 26, 2024 1:48:00 PM Attachments: Harris 2024-002 RP RFI.pdf

Hello Sarah,

Please find attached the document request for our upcoming RP inspection at Harris. Feel free to reach out to me with any questions.

Thanks, Jonathan

Jonathan Rivera Health Physicist Engineering Branch 3 Division of Reactor Safety U.S. NRC - Region II Office: 404-997-4646 Email: jonathan.rivera@nrc.gov Document Request List Occupational and Public Radiation Safety Cornerstones

Licensee: Harris Nuclear Plant License 50-400

Licensing

Contact:

Sarah McDaniel Regulatory Affairs Office: (984) 229-2002 sarah.mcdaniel@duke-energy.com

Inspection Dates: April 1 - 5 and April 22 - 26, 2024

Documents Due to Region II by: March 27, 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.

Page 2 of 6 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. H1R25 outage schedule, including work activities to be conducted during the weeks of the inspection (e.g., Gantt chart or similar list).

8. Procedures associated with the Surveillance Frequency Control Program.

71124.01 - Radiological Hazard Assessment and Exposure Controls (Last inspected June 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 H1R25 refueling outage.

9. All self-assessments or audits covering radiological hazard assessment and exposure controls and HP controls since June 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 June 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 October 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

Page 3 of 6 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 October 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) 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.

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

71124.04 - Occupational Dose Assessment (Last inspected October 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 October 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 October 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. Most recent alpha characterization.

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

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

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

10. List of CRs generated since October 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 October 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.

Page 4 of 6 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 Monitor (RM-21AV-3509) b) Waste Monitor Tanks Discharge Monitor (21WL-3541) c) Containment High-Range Radiation Monitors (RM-1-3589SA and RM 3590SB) d) Sample Room Area Radiation Monitors (RM-1-3605A and 3605B) e) Fuel Handling Building Normal and Emergency Exhaust Radiation Monitors (1FL-3506, 3507, 3508A, & 3508B) f) Whole Body Counter

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

4. Chart or procedure listing EALs associated with radiation monitors.

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

6. 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.]

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

8. 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.

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

10. 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

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

12. 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.

13. 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 October 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 June 2023 - Occupational and July 2023 - Public)

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

2. Monthly PI reports since March 1, 2023, and copies of associated condition reports for any

Page 5 of 6 Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual (RETS/ODCM) Radiological Effluent occurrences.

3. 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 March 1, 2023. This should be a list of corrective action documents containing a CR number and brief description, not full CRs.

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

5. List of all CAP documents related to occupational radiological controls using search keywords such as HRA, LHRA, VHRA, unintended dose, unlocked door, ALARA, 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.

6. 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 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.

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.

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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