ML21147A080

2021-001 Radiation Safety Baseline Inspection Document Request Letter

ML21147A080
Person / Time
Site:	North Anna
Issue date:	01/20/2021
From:	Jose Diaz NRC/RGN-II
To:	Page R Dominion Energy Co
References
Download: ML21147A080 (5)

Text

Diaz, Jose From: Diaz, Jose Sent: Wednesday, January 20, 2021 2:51 PM To: robert.page@dominionenergy.com

Subject:

Document Request Letter for 2021001 RP Inspection Attachments: 2021001 North Anna Nuclear Power Station Document Request Letter.pdf Importance: High

Bob, As discussed over the phone call today, here is the promised document request letter. Thanks for your support. Feel free to call me at 404-997-4736 or e-mail me at jose.diaz@nrc.gov if you have any questions.

Respectfully, José 1

ML21147A080 North Anna Power Stations Units 1 and 2 Radiation Safety Baseline Inspection Initial Information Request Inspection Reports: 05000338/2021001 and 05000339/2021001 During the weeks of Mar 15th-19th, 2021, the U.S. Nuclear Regulatory Commission (NRC) will perform a baseline Radiation Safety Inspection at the North Anna Nuclear Plant (NRC Inspection Procedures 71124.01, 71124.08 and 71151).

To minimize the impact to your onsite 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 March 1, 2021.

If there are any questions about this inspection or the material requested, please contact the lead inspector, Jose M. Diaz-Velez at 404-997-4736, 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 Licensee: North Anna Power Station Units 1 and 2 NAPS Licensing

Contact:

Robert Page (540) 894-2575) robert.page@dominionenergy.com Docket Number: 05000338 and 05000339 Inspection Dates: Mar 15th-19th, 2021 Documents Due to Region II by: March 1, 2021 NRC Inspection Procedures (IPs):

71124.01 Radiological Hazard Assessment and Exposure Controls 71124.08 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation 71151 Performance Indicator Verification Note: Please provide the current version of these documents in an electronic format if possible (The preferred file format is MSWord, or searchable .pdf files). To the extent possible, please organize the information in directories as requested below and if possible, use a descriptive name for the files provided. Recent experience has demonstrated the most efficient method to transfer this information to the NRC is via Certrec. It is best to upload all the requested information in one large zip file. If there are questions regarding the documents requested, or method of transfer, please do not hesitate to contact the lead inspector.

Documentation for IPs 71124.01, and 71151 should be from September 2020, and for IP 71124.08 should be from September 2019. These dates are approximate to the last time these inspections were conducted. Also, provide only a listing and title for NCRs requested for each inspection procedure and inspectors will select a sample from these for in-depth review during the inspection.

If you have any questions, please call José M. Díaz-Vélez at (404) 997-4517. Thank you in advance for your effort in putting together this material.

General and Miscellaneous Information List of primary site contact(s) for each inspection area including name(s), e-mail and telephone numbers.

Corrective Action Program procedures.

Plant Management and Radiation Protection organizational charts w/ contact numbers.

Internal and external assessments and audits of the RP program since September 2019.

(excluding INPO).

71124.01 - Radiological Hazard Assessment and Exposure Controls

1. List of active Radiation Work Permits (RWPs) (including their dose and dose rate limits).

2. Site and Corporate procedures related to Health Physics (HP) controls (e.g., posting, labeling, surveys, RWPs, contamination control, high radiation area (HRA)/LHRA/VHRA control, key control, control of divers, special controls during fuel offload, hot spots, etc.)

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

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

5. List of locations, or plant maps indicating the location, of locked high radiation areas (LHRAs) and very high radiation areas (VHRAs), including areas with the potential to become a LHRA during routine operations or outages

6. Most recent survey of LHRAs and VHRAs (as applicable).

7. Self-assessments or audits covering radiological hazard assessment and exposure controls and HP controls since last inspection (if none, then provide the most recent).

8. Corrective Action Program (CAP) documents (CR, NRC, AR, etc.) related to RP controls (e.g., radworker error, HP technician error, posting issues, radioactive source controls, HRA/LHRA/VHRA issues, survey problems, etc.) generated since last inspection. 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

1. Provide procedures/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, and

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 Process Control Program (PCP)

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 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).

8. List and documentation of any changes made to the radwaste processing systems (liquid and solid) and/or the PCP since the last inspection, and associated 10 CFR 50.59 documentation, as appropriate.

9. Copies of applicable transport cask Certificate of Compliance for the last three transport cask shipments

10. List of RAM storage areas, including satellite radiological controlled areas (RCAs)

11. Log of RAM shipments (LSA I, II, IIII; SCO I, II, Type A, or Type B) since the last inspection.

(The inspectors will select three to five packages to review in detail.)

12. Most recent self-assessment or audit of Shipping/radwaste processing and RAM storage programs

13. List of CAP documents (AR, CR, NCR, etc.) related to involving radwaste and RAM processing and/or transportation (e.g., keyword searches for RAM, shipping, radwaste, 10 Part 61, etc.) issued since the last inspection. This should be a list of corrective action documents containing an (AR, CR, NCR, etc.) number and brief description, not full documents.

14. Available for onsite review during the inspection Site drawing(s) showing the location of stored RAM and stored radwaste (include these also in the electronic documents provided if possible)

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 Training and qualification records for personnel responsible for radwaste processing, packaging, and making shipments of radioactive material (RAM) and radwaste. (include these also in the electronic documents provided if possible)

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 with staff.

71151 - Performance Indicator Verification (Occupational Radiation Safety Cornerstone only)

1. LIST of all CRs related to LHRA/VHRA issues or significant (>100 mrem) unintended doses since September 2020. This should be a list of corrective action documents containing a CR number and brief description, not full CRs.

2. LIST of electronic dosimeter alarms since September 2020 (dose and dose rate).