ML18283A733

Rad Safety Inspection RFI

ML18283A733
Person / Time
Site:	Surry
Issue date:	10/01/2018
From:	Kellner R Division of Reactor Safety II
To:	Cuthriell T Dominion Energy Co
References
Download: ML18283A733 (7)

Text

ML#

Kellner, Robert From: Kellner, Robert Sent: Monday, October 01, 2018 10:45 AM To: Terri S Cuthriell (terri.s.cuthriell@dominionenergy.com)

Subject:

Upcoming NRC Radiation Safety Inspection - November 2018 Attachments: Surry 2018004 RP Document Request List_Final.pdf

Terri, Per your previous email, you will be the licensing point of contact for the upcoming NRC Radiation Safety Inspection scheduled for the weeks of November 5 - 9, 2018 and November 26 - 30, 2018 at Surry Power Station. Attached is the Initial Information Request and a Document Request List.

The NRC inspectors that will be on-site during the inspection are myself, William Pursley, and Wade Loo. Bill and I will be there the first week, and all of us will be there the second week. Wade and I should be up to date on our Dominion training, I dont know if Bill is current on his training.

Please let me know that you received this request. I have your direct phone number as (757) 365-2161 if I need to contact you. If there are any questions about this inspection, or the material requested, please contact me via email, or at the phone number or address included below.

Regards, Bob Robert Kellner Senior Health Physicist USNRC/Region II/DRS/EB3 Marquis One Tower Suite 1200 245 Peachtree Center Ave, NE Atlanta, GA 303031257 (404) 9974508 1

Surry Power Station Radiation Safety Baseline Inspection Initial Information Request Inspection Report: 2018004 During the weeks of November 5 - 9, 2018 and November 26 - 30, 2018, the NRC will perform a baseline Radiation Safety Inspection at Surry Nuclear Power Station (NRC Inspection Procedures 71124.01, 71124.02, 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. In order 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 of these documents are up-to-date, and complete, thereby minimizing the number of additional documents requested during the preparation, and/or the onsite portions of the inspection. The NRC requests that these documents be provided to the inspectors no later than November 1, 2018.

If there are any questions about this inspection or the material requested, please contact the lead inspector, Robert Kellner at Robert.Kellner@nrc.gov, at 404-997-4508, or the Plant Support Branch 1 Chief, Brian Bonser at 404-997-4653.

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 Inspection Dates: November 5 - 9, 2018, and November 26 - 30, 2018 Documents Due to Region II by: November 1, 2018 Inspection Procedures: IP 71124.01 Radiological Hazard Assessment and Exposure Controls IP 71124.02 Occupational ALARA Planning and 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 & Mailing Address:

Robert Kellner U.S. Nuclear Regulatory Commission Sr. Health Physicist Region II US NRC Region II ATTN: Robert Kellner (404) 997-4508 245 Peachtree Center Ave., N.E Robert.Kellner@nrc.gov Suite 1200 Atlanta, GA 30303 Note: The current version of these documents is expected unless specified otherwise.

Electronic media is preferred (CD or DVD) if readily available. [Please DO NOT provide data on a USB or flash drive due to NRC IT security policies.] To the extent possible, please organize the information as it is arranged below. Experience has shown that a poorly organized CD can lead to a less efficient inspection and places additional burden on licensee staff. Pay particular attention to the date ranges for the items requested as they may change from item to item. 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.

Miscellaneous

1. List of primary contacts for each inspection area including names and telephone numbers

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

3. Corrective action program procedure(s)

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

5. Most recent 10 CFR 61 analysis for the DAW waste stream 71124.01 - Radiological Hazard Assessment and Exposure Controls (Last inspected May 2017)

1. Timeline of major outage activities (e.g. Gantt chart or similar list)

2. Procedures related to RP controls (e.g. Posting, labeling, surveys, RWPs, contamination control, HRA/LHRA/VHRA control, key control, control of divers, special controls during fuel offload, hot spots, ISFSI Controls, etc.)

Page 2 of 6

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

4. List of outage & active Radiation Work Permits (RWPs) with dose limits.

5. List of locations, or plant maps indicating the location, of all LHRAs and VHRAs. Include areas with the potential to become a LHRA during routine operations or outages.

6. List of Nationally Tracked Sources and copies of any National Source Tracking System transaction documentation (e.g., annual reconciliation, source transfers, etc.)

7. Most recent sealed source inventory record

8. List of all non-fuel items stored in spent fuel pool

9. Independent Spent Fuel Storage Installation (ISFSI) information, to include the last two (2) surveys and as low as reasonably achievable (ALARA) planning and reviews conducted for the last two ISFSI campaigns

10. All self-assessments or audits covering radiological hazard assessment and exposure controls and HP controls since May 1, 2017 (if none, then provide the two most recent).

11. List of CRs related to RP controls (e.g., radworker error, HP technician error, posting issues, Nationally Tracked Sources issue, HRA/LHRA/VHRA issues, survey problems, etc.) issued since May 1, 2017. This should be a list of corrective action documents containing a CR number and a brief description, not full documents.

71124.02 - Occupational ALARA Planning and Controls (Last inspected November 2016)

1. All procedures related to ALARA (e.g. temporary shielding, ALARA planning, source term reduction, etc.)

2. List of top 5 dose jobs for the upcoming refueling outage and ALARA planning packages (including dose estimates, work hour estimates, special RP controls, and dose reduction initiatives), if available

3. ALARA trending point data for last two outages (last two for both units)

4. Source term reduction strategic plan, if available

5. Minutes from the four (4) most recent Plant ALARA Committee Meetings

6. Outage reports for the two (2) most recent outages

7. Completed ALARA packages (including post-job reviews) for the five work activities that were completed during the last outage that had the greatest collective dose, and/or presented significant radiological risk

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

9. List of CRs related to ALARA since November 1, 2016. This should be a list of corrective action documents containing a CR number and brief description, not full CRs 71124.03 - In-Plant Airborne Radioactivity Control and Mitigation (Last inspected November 2016)

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.)

2. Procedures related to the use of respiratory protection devices (e.g., self-contained breathing apparatus (SCBA), total effective dose equivalent-ALARA guidance, powered air purifying respirators (PAPRs), storage, maintenance, training, quality assurance (QA), and fit-testing).

3. The last two (2) grade D air testing certificates for each supplied air system and SCBA filling station Page 3 of 6

4. Documentation for last two (2) surveillances performed on SCBA stored for emergency use

5. Two most recent HEPA filter DOP and charcoal test results for the following ventilation systems:

a) TSC Ventilation b) Unit 2 Auxiliary Building Ventilation system c) Radwaste Facility Ventilation

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, 2016. This should be a list of corrective action documents containing a CR number and brief description, not full CRs.

8. Available for onsite review by inspector 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

i. List of all licensed operators qualified to wear an SCBA ii. List of site ERO personnel qualified to wear an SCBA iii. List of all HP personnel qualified to wear an SCBA c) Training/qualification certificates for all onsite and/or vendor personnel qualified to repair SCBA that performed maintenance or repairs since November 2016.

71124.04 - Occupational Dose Assessment (Last inspected November 2016)

1. Procedures related to occupational dose assessment (e.g. external dose monitoring, dosimetry issuance and use, unusual dosimetry occurrences, multi-badging/extremity dosimetry/badge relocation, Effective Dose Equivalent (EDE), personnel contamination events PCEs, storage/care of personal dosimeters, use of electronic dosimeters, in-vivo and in-vitro internal dose assessment, skin dose assessment, QC for whole body counter, use of passive monitoring, if applicable, and declared pregnant workers)

2. NVLAP accreditation documentation for 2016, 2017, and current dosimetry used by thesite

3. ISFSI perimeter monitoring data (e.g. perimeter TLDs) for the last monitoring period in 2016 through the most recent monitoring period.

4. List of all positive air-sampling, whole body count, or in vitro analyses which resulted in a CEDE equal to or exceeding 10 millirem since November 1, 2016. [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. List of all PCEs identified since November 1, 2016. [Note: only a listing should be provided for use by the inspectors to select a sample of issues for review during the onsite inspection.]

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

7. List of CRs generated since November 1, 2016, for internal or external dosimetry issues/events. This should be a list of corrective action documents containing a CR number and brief description, not full CRs.

Page 4 of 6

71124.05 - Radiation Monitoring Instrumentation (Last inspected November 2016)

1. Procedures/Guidance Documents for:

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, 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 for count room instruments

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

a) Post-accident Containment High Range Area Monitors (both Units) (1-RM-RMS-127 &

128, 2-RM-RMS 227 & 228) b) Technical support center (1-RM-RMS-136 & 137) c) Main Control Room (1-RM-RMS-157)

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

4. Provide a current list of SAMs, PCMs, PMs, portable radiation detection instruments, counting room, and Whole Body Counters. [Note: The list will be used to select monitors for evaluation of their calibration/functional check surveillances during the onsite inspection.)

5. Most recent calibration/test record for the instrument calibrator (Shepherd validation testing/dose rate curves)

6. 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

7. Chart or procedure identifying emergency action levels and actions associated with radiation monitors (if applicable).

8. Most recent Radiation Monitoring System engineering performance review/evaluation or system health report

9. Most recent audit or self-assessment covering RP instruments (e.g. portables, RCA exit point, WBC, count room). Include any reviews conducted of vendor facilities, as applicable

10. List of CRs generated since November 1, 2016 related to portable instruments, area monitors, CAMs, RCA release point monitors, WBCs, and count room instruments. This should be a list of corrective action documents containing a CR number and brief description, not full CRs.

71151 - Performance Indicator Verification (Occupational and Public Cornerstones)

(Last inspected November 2017)

1. Procedure(s) for identifying, notification, tracking, and correcting performance indicator (PI) occurrences.

2. Monthly PI reports since November 2017, and copies of associated condition reports for any Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual (RETS/ODCM) Radiological Effluent occurrences.

3. List of all CAP documents using search keywords such as: HRA, LHRA, VHRA, unintended dose, unlocked door, RETS/ODCM, abnormal or unmonitored release, offsite Page 5 of 6

dose, and effluent release, etc. since November 1, 2017. This should be a list of corrective action documents containing a CR number and brief description, not full CRs.

4. Most recent liquid and gaseous effluent release permits which specify the quarterly and annual (year to date) curies released by isotope and the associated public dose assessments.

5. List of all electronic dosimeter (ED) alarms, for dose and dose rate, since November 1, 2017 Page 6 of 6