ML21082A304

Request for Information: Columbia Generating Station, Dated March 11, 2021, Inspection Report 05000397/2021-002, Occupational Radiation Safety Inspection-1,2,3,PI

ML21082A304
Person / Time
Site:	Columbia
Issue date:	03/23/2021
From:	NRC Region 4
To:
References
IR 2021002
Download: ML21082A304 (7)

See also: IR 05000397/2021002

Text

(ML21082A304)

The following items are requested for the

Occupational Radiation Safety Inspection

at Columbia

Dates of Inspection: 05/17/2021 to 05/21/2021

Integrated Report 2021002

Inspection areas are listed in the attachments below.

Please provide the requested information on or before Monday, May 03, 2021.

Please submit this information using the same lettering system as below. For example, all

contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled

1-A, applicable organization charts in file/folder 1-B, etc.

The information should be provided in electronic format or a secure document management

service. If information is placed on a secured document management system, please ensure

the inspection exit date entered is at least 30 days later than the onsite inspection dates, so the

inspectors will have access to the information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed

below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the

entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found.

If you have any questions or comments, please contact Natasha Greene at 817-200-1154 or via

e-mail at Natasha.Greene@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT

This letter 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,

control number 3150-0011.

1 Attachment 2

1. Radiological Hazard Assessment and Exposure Controls (71124.01) and

Performance Indicator Verification (71151)

Date of Last Inspection: May 20, 2019

A. List of contacts and telephone numbers for the Radiation Protection Organization Staff

and Technicians, as well as the Licensing/Regulatory Affairs staff. Please include area

code and prefix. If work cell numbers are appropriate, then please include them as well.

B. Applicable organization charts including position or job titles. Please include as

appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),

Engineering, and Emergency Protection. (Recent pictures are appreciated.)

C. Copies of audits, self-assessments, LARs, and LERs written since the last inspection

date, related to this inspection area

D. Procedure indexes for the radiation protection procedures and other related disciplines.

E. Please provide procedures related to the following areas noted below. Additional

procedures may be requested by number after the inspector reviews the procedure

indexes.

1. Radiation Protection Program

2. Radiation Protection Conduct of Operations, if not included in #1

3. Personnel Dosimetry

4. Posting of Radiological Areas

5. High Radiation Area Controls

6. RCA Access Controls and Radiation Worker Instructions

7. Conduct of Radiological Surveys

8. Fuel Pool Inventory Access and Control

F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently

committed to relative to this program. Please include the revision and/or date for the

commitment and where this may be located in your current licensing basis documents.

G. Please provide a summary list of corrective action documents (including corporate and

sub-tiered systems) since the last inspection date.

1. Initiated by the radiation protection organization

2. Assigned to the radiation protection organization

NOTE: These lists should include a description of the condition that provides

sufficient detail that the inspectors can ascertain the regulatory impact, the

significance level assigned to the condition, the status of the action (e.g.,

open, working, closed, etc.) and the search criteria used. Please provide in

document formats which are sortable and searchable so that inspectors

can quickly and efficiently determine appropriate sampling and perform word

searches, as needed. (Excel spreadsheets are the preferred format.) If

codes are used, please provide a legend for each column where a code is

used.

H. List of radiologically significant work activities scheduled to be conducted during the

inspection period. (If the inspection is scheduled during an outage, please also include a

list of work activities greater than 1 rem, scheduled during the outage with the dose

estimate for the work activity.) Please include the radiological risk assigned to each

activity.

I. Provide a summary of any changes to plant operation that have resulted or could result

in a significant new radiological hazard. For each change, please provide the

assessment conducted on the potential impact and any monitoring done to evaluate it.

J. List of active radiation work permits and those specifically planned for the on-site

inspection week.

K. Please provide a list of air samples taken to verify engineering controls and a separate

list for breathing air samples in airborne radiation areas or high contamination work

areas. Please include the RWP the breathing air sampling supports.

L. A list of all non-fuel items stored in the spent fuel pools, and if available, their

appropriate dose rates (Contact/@ 30cm).

M. A list of radiological controlled area entries greater than 100 millirem, since the last

inspection date. The list should include the date of entry, some form of worker

identification, the radiation work permit used by the worker, dose accrued by the worker,

and the electronic dosimeter dose alarm set-point used during the entry (for

Occupational Radiation Safety Performance Indicator verification in accordance with

IP 71151).

N. A list describing VHRAs and TS HRAs (> 1 rem/hour) that are current and historical.

Include their current status, locations, and control measures.

O. Temporary effluent monitor locations and calibrations (AMS-4) used to monitor normally

closed doors or off-normal release points (e.g., equipment hatch or turbine heater bay

doors). Include any CRs associated with this monitoring or instrumentation.

2. Occupational ALARA Planning and Controls (71124.02)

Date of Last Inspection: May 20, 2019

A. List of contacts and telephone numbers for ALARA program personnel, as well as the

Licensing/Regulatory Affairs staff. Please include area code and prefix. If work cell

numbers are appropriate, then please include them as well.

B. Applicable organization charts including position or job titles. Please include as

appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),

Engineering, and Emergency Protection. (Recent pictures are appreciated.)

C. Copies of audits, self-assessments, LARs, and LERs, written since the date of last

inspection, focusing on ALARA.

D. Procedure index for ALARA Program procedures and other related disciplines.

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews

the procedure indexes.

1. ALARA Program

2. ALARA Planning

3. ALARA Reviews

4. ALARA Committee

5. Radiation Work Permit Preparation

F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently

committed to relative to this program. Please include the revision and/or date for the

commitment and where this may be located in your current licensing basis documents.

G. Please provide a summary list of corrective action documents (including corporate and

sub-tiered systems) written since the date of last inspection, related to the ALARA

program, including exceeding RWP Dose Estimates.

NOTE: These lists should include a description of the condition that provides

sufficient detail that the inspectors can ascertain the regulatory impact, the

significance level assigned to the condition, the status of the action (e.g., open,

working, closed, etc.) and the search criteria used. Please provide in document

formats which are sortable and searchable so that inspectors can quickly and

efficiently determine appropriate sampling and perform word searches, as needed.

(Excel spreadsheets are the preferred format.) If codes are used, please provide a

legend for each column where a code is used.

H. List of work activities (RWPs) greater than 1 rem, since date of last inspection,

including the original dose estimates and actual doses accrued. (Excel format

preferred). Please provide all revisions/changes, as well as any related RWPs that

support the work activity.

Provide any post evaluations, lessons learned, and/or corrective action documents

generated as a result of this work activity. If available, provide any justifications/reasons

for actual dose exceedances of the initial dose estimate.

I. List of active work activities (RWPs) that will be in use while we are onsite, including the

dose and dose rate settings, and if available, the planned dose.

J. Site dose totals for the past 3 years (based on dose of record). Also provide the current

year-to-date (YTD) collective radiation exposure (CRE). In addition, please provide

another document that separates the online and outage doses for the past 3 years.

K. Most recent assessment of your isotopic mix, including the hard-to-detect radionuclides

and alpha hazards. Include a list of new and historical exposure issues (radiological

source term or high exposure areas/activities).

L. If available, provide a copy of the ALARA outage report or evaluation for the two most

recently completed outages for each unit.

M. Please provide the methods/reports that are in your process to meet the requirements of

10 CFR 20.1101(c) for periodic review of your RP program.

N. Current exposure trends (BRAC dose rates and/or source term information).

3. In-Plant Airborne Radioactivity Control and Mitigation (71124.03)

Date of Last Inspection: September 10, 2018

A. List of contacts and telephone numbers for the following areas. Please include area

code and prefix. If work cell numbers are appropriate, then please include them as well.

1. Respiratory Protection Program

2. Self-contained breathing apparatus

3. Ventilation Systems for breathing air (not effluents)

4. Licensing/Regulatory Affairs

B. Applicable organization charts including position or job titles. Please include as

appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),

Engineering, and Emergency Protection. (Recent pictures are appreciated.)

C. Copies of audits, self-assessments, vendor or NUPIC audits for contractor support

(SCBA), LARs, and LERs, written since the date of last inspection related to:

D.

1. Installed air filtration systems

2. Self-contained breathing apparatuses

E. Procedure index for Radiation Protection, Maintenance, I&C, and other related

disciplines.

1. Use, operation, and maintenance of installed and portable continuous air monitors

Use operation, and maintenance of installed air filtration units for breathing air (e.g.,

for airline respirators, emergency ventilation systems).

2. Use, operation, and maintenance of temporary air filtration units and vacuums.

3. Respiratory protection and other related disciplines.

F. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews

the procedure indexes.

1. Respiratory protection program.

2. Use and maintenance of self-contained breathing apparatuses.

3. Air quality testing for SCBAs or other compressed or supplied air systems.

4. Use and testing of installed plant air cleaning systems used for breathing air, such as

control room emergency ventilation, technical support center, operations support

center, and emergency operations facility (When containment purge is not used as

an effluent system, then it can be considered as a breathing air system used prior to

outages during RCS breach and flood up.)

G. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently

committed to relative to this program. Please include the revision and/or date for the

commitment and where this may be located in your current licensing basis documents.

H. Please provide a summary list of corrective action documents (including corporate and

sub-tiered systems) written since the date of last inspection, related to the Airborne

Monitoring program including:

1. In-plant continuous air monitors (installed or portable), not effluent monitors

2. Self-contained breathing apparatus

I. Air Cleaning systems (not effluent)

3. Respiratory protection program

NOTE: These lists should include a description of the condition that provides

sufficient detail that the inspectors can ascertain the regulatory impact, the

significance level assigned to the condition, the status of the action (e.g., open,

working, closed, etc.) and the search criteria used. Please provide in document

formats which are sortable and searchable so that inspectors can quickly and

efficiently determine appropriate sampling and perform word searches, as needed.

(Excel spreadsheets are the preferred format.) If codes are used, please provide a

legend for each column where a code is used.

J. List of SCBA qualified personnel - reactor operators and emergency response

personnel. For the control room individuals, please indicate their normally scheduled

shift and specific mask size, as well as note if they are permitted/fitted for eyewear.

K. Inspection records for self-contained breathing apparatuses (SCBAs) staged in the plant

for use since the date of last inspection.

L. SCBA training and qualification records for control room operators, shift supervisors,

STAs, and OSC personnel for the last year.

M. A selection of personnel may be asked to demonstrate proficiency in donning, doffing,

and performance of functionality check for respiratory devices

N. List of respirators (available for use) by type (APR, SCBA, PAPR, etc.), manufacturer,

model, quantity by size, and location. Be prepared to demonstrate that these respirators

are NIOSH certified.

O. Include in the list the specific quantities and sizes staged for emergency use.

P. Provide one-line drawings of the supplied air and air cleaning systems identified in E.3

and E.4 above.

Q. List work activities requiring respiratory protection and the type of respirator used

(include PAPRs).

R. Please have available, on-site, the records demonstrating the compressed air for SCBAs

or supplied air for a breathing air system is at least Grade D.

S. A list of the technical specification-required air cleaning systems with the two most

recent surveillance test dates of in-place filter testing (of HEPA filters and charcoal

adsorbers) and laboratory testing (of charcoal efficiency) and the work order numbers

associated with the surveillances (and their system number/name).