ML25022A034

02 Radiation Safety Baseline Inspection Information Request

ML25022A034
Person / Time
Site:	Turkey Point
Issue date:	01/21/2025
From:	Jonathan Rivera NRC/RGN-II/DFRSS
To:	Bazan B Florida Power & Light Co
References
IR 2025002
Download: ML25022A034 (1)

Text

From:

Jonathan Rivera (He/Him/His)

To:

Bazan, Boris Cc:

Adam Nielsen; Jack Bell

Subject:

Document request letter - Turkey Point RP inspection.

Date:

Tuesday, January 21, 2025 3:45:36 PM Attachments:

Turkey Point RP RFI_2025-002.pdf.pdf image001.png Good afternoon Boris,

Please find attached the document request letter for our upcoming RP inspection at Turkey Point.

The inspectors will be myself (lead) and Jack Bell. Feel free to reach out to me if you have any questions.

Thanks, Jonathan

Jonathan Rivera (He / Him / His)

Health Physicist Radiological Safety Branch (RSB)

Division of Fuels, Radiological Safety, & Security (DFRSS)

U.S. Nuclear Regulatory Commissions - Region II Office: 404-997-4646 Email: jonathan.rivera@nrc.gov

Turkey Point Nuclear Plant Radiation Safety Baseline Inspection Initial Information Request Inspection Report: 050-00250 and 050-00251/2025002 During the weeks of March 3 - 7, 2025 and March 31 - April 4, 2025, the US Nuclear Regulatory Commission (NRC) will perform a baseline Radiation Safety Inspection at the Turkey Point Nuclear Plant Units 3 and 4 (NRC Inspection Procedures 71124.01, 71124.03, 71124.04, 71124.05, and 71151).

To minimize the impact to your on-site resources during the inspection and ensure the inspectors have the necessary information to complete the inspection while on site, we have enclosed a request for documents needed for this activity. The NRC requests that these documents be provided to the inspectors no later than February 21, 2025.

If there are any questions about this inspection or the material requested, please contact the lead inspector, Jonathan Rivera, at 404-997-4646 or jonathan.rivera@nrc.gov, or the Acting Radiological Safety Branch Chief, Adam Nielsen, at 404-997-4660 or adam.nielsen@nrc.gov.

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 website at http://www.nrc.gov/readingrm/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 Oce 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, Oce of the Chief Information Ocer, 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 Ocer, Oce of Information and Regulatory Aairs, 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 Oce of Management and Budget control number.

1 Document Request List Licensee: Turkey Point Nuclear Plant Cornerstones: Occupational and Public Radiation Safety Licensing

Contact:

Boris Bazan, Regulatory Aairs Engineer; 305-246-7381; Boris.Bazan@fpl.com Lead Inspector: Jonathan Rivera, Health Physicist; 404-997-4646; jonathan.rivera@nrc.gov Docket Numbers: 050-00250 and 050-00251 Inspection Dates: March 3 - 7, 2025 and March 31 - April 4, 2025 Documents Due to Region II by: February 21, 2025 NRC Inspection Procedures (IPs):

71124.01 - Radiological Hazard Assessment and Exposure Controls 71124.03 - In-Plant Airborne Radioactivity Control and Mitigation 71124.04 - Occupational Dose Assessment 71124.05 - Radiation Monitoring Instrumentation 71151 - Performance Indicator Veri"cation (Occupational and Public Cornerstones)

Note: Please provide the current version of these documents in an electronic format if possible (The preferred "le format is MSWord, or searchable.pdf "les). To the extent possible, please organize the information in directories as requested below and if possible, use a descriptive name for the "les provided. Recent experience has demonstrated the most ecient method to transfer this information to the NRC is via CERTREC. If there are questions regarding the documents requested, or method of transfer, please do not hesitate to contact the lead inspector.

71124.01 - Radiological Hazard Assessment and Exposure Controls

1. List of active and upcoming Unit 4 outage Radiation Work Permits (RWPs), including their dose and dose rate limits.

2. ALARA planning packages for the 3 highest dose jobs for the upcoming Unit 4 outage.

3. Post-outage ALARA reports for the previous Unit 3 and Unit 4 outages.

4. Site and corporate procedures related to Health Physics (HP) controls [e.g., postings, labeling, surveys, RWPs, contamination control, high radiation area (HRA) / locked high radiation area (LHRA)

/ very high radiation area (VHRA) controls, key controls, control of divers, special controls during fuel ooad, hot spots, etc.].

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

6. List of non-fuel items stored in spent fuel pool (SFP).

7. List of locations, or plant maps indicating the locations, of LHRAs and VHRAs, including areas with the potential to become LHRAs during routine operations or outage activities.

8. Most recent self-assessment or audit covering radiological hazard assessment and exposure controls.

9. List of Corrective Action Program (CAP) documents related to radiological hazard assessment and exposure controls (e.g., radworker error, HP technician error, posting issues, radioactive source controls, HRA/LHRA/VHRA issues, survey issues, etc.) generated since October 1, 2024. This should

2 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

1. Site and corporate procedures related to airborne monitoring and control [e.g., use of purge systems, use of portable high-eciency particulate air (HEPA) / charcoal units, temporary ventilation enclosures, use of continuous air monitors (CAMs), air sampling guidance, alpha air sampling, etc.].

2. Site and corporate procedures related to the use of respiratory protection devices, [e.g., self-contained breathing apparatus (SCBA), TEDE-ALARA guidance, powered air purifying respirators (PAPRs), storage, maintenance, training, QA, "t-testing, etc.].

3. Copies of the last two Grade D air testing certi"cates for each supplied air systems and SCBA "lling stations.

4. Documentation of the last two surveillances performed on SCBAs available for emergency use, and negative pressure respirators designated as in storage but available for use.

5. Two most recent surveillances that verify the "ow rates for the Unit 4 Control Room Emergency Ventilation System (CREVS).

6. Two most recent HEPA "lter Dispersed Oil Particulate (DOP) testing and charcoal test results for the Unit 4 Main Control Room Environmental Control System.

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

8. List of CAP documents related to airborne monitoring and respiratory protection 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.

71124.04 - Occupational Dose Assessment

1. Site and corporate procedures related to occupational dose assessment [e.g., dosimetry issuance and use, unusual dosimetry occurrences, multi-badging/extremity dosimetry/badge relocation, Eective Dose Equivalent (EDEX), 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, etc.].

2. NVLAP accreditation documentation for years 2023, 2024, and 2025.

3. List of all positive whole-body counts, in vitro or air sampling analyses which resulted in a committed eective dose equivalent (CEDE) equal to or exceeding 10 millirem since May 1, 2023. [Note: only a listing should be provided for use by the inspectors to select a sample of issues for review during the on-site inspection].

4. List of all facial contamination and Level III personnel contamination events identi"ed since May 1, 2023. [Note: only a listing should be provided for use by the inspectors to select a sample of issues for review during the on-site inspection].

5. Most recent neutron and alpha characterizations.

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

7. Copies of current whole-body counter (WBC) libraries (e.g., routine, medical, investigative, etc.).

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

9. List of CAP documents related to internal or external dosimetry issues/events since May 1, 2023 (e.g., dosimetry, DLR, TLD, EDEX, Multi-Badge, electronic dosimeter, etc.). This should be a list of

3 corrective action documents containing a CAP document number and a brief description, not complete documents.

71124.05 - Radiation Monitoring Instrumentation

1. Site and corporate procedures related to calibration and functional tests / source checks of portable radiation detection instruments, small article monitors (SAMs), personnel contamination monitors (PCMs), portal monitors (PMs), counting room equipment, electronic alarming dosimeters, whole-body counting equipment, and CAMs; collection and analysis of high-range post-accident euent samples; determination of setpoints for ARMs, CAMs, PCMs, PMs, and SAMs.

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

a. Units 3 and 4 Containment High-Range Radiation Monitoring System (CHRRMS)

b. Plant Vent Stack Radiation Monitoring System

c. Plant Liquid Radwaste Euent Radiation Monitor

d. Unit 4 Containment Purge

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

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

5. Provide a current list of in-service SAMs, PCMs, PMs, air samplers, CAMs, portable radiation detection instruments, count room (RP and Chemistry) instruments, and whole body counters (Note:

This list will be used to select instruments for evaluation during the on-site inspection).

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

7. Results of the inter-laboratory comparison program for count room (RP and Chemistry) instrumentation since May 1, 2023.

8. Most recent self-assessment or audit of the instrumentation program.

9. List of CAP documents related to instrumentation 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.

71151 - Performance Indicator (PI) Veri"cation (Occupational and Public Radiation Safety Cornerstones)

1. Site and corporate procedures for identifying, reporting, tracking, and correcting PI occurrences.

2. Monthly PI reports since October 1, 2024, in the Occupational and Public Cornerstones.

3. List of all CAP documents related to euent dose/ODCM issues using search keywords such as RETS/ODCM, abnormal or unmonitored release, osite dose, and euent release, etc. since October 1, 2024. This should be a list of CAP documents containing a CAP number and brief description, not full documents.

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

5. List of electronic dosimeter dose and dose rate alarms since October 1, 2024.

General and Miscellaneous Information

1. List of primary site contacts for each inspection area, including email and telephone numbers.

2. CAP procedures.

3. Plant Management and RP organizational charts with contact numbers.

4

4. Most recent 10 CFR Part 61 analysis for dry active waste (DAW).

5. Schedule of major outage maintenance/work activities during the weeks of the inspection.