ML24277A073
| ML24277A073 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 10/03/2024 |
| From: | Bell J NRC/RGN-II/DRS/EB3 |
| To: | Hubbard M Duke Energy |
| References | |
| IR 2024004 | |
| Download: ML24277A073 (1) | |
See also: IR 05000261/2024004
Text
From:
Jack Bell
To:
Hubbard, Mark J.; miles.norton@duke-energy.com
Cc:
John Zeiler; Jose Diaz; Darrell Neal
Subject:
Document request for Robinson RP inspection, report number 2024-04
Date:
Thursday, October 3, 2024 9:00:00 AM
Attachments:
Robinson_DRL.pdf
Please see the attached document request for our upcoming baseline RP inspection
scheduled for November 18-22 and December 9-13, 2024. Note that some of the items
may be outside RPs purview, so coordination with other groups might be required (e.g.
Maintenance/I&C).
We would like to have the documents available by November 8, 2024. However, if you run
into difficulty and need more time for certain items, just let us know and we can work with
you.
Please call or email me if you have any questions.
Robinson Nuclear Plant
Radiation Safety Baseline Inspection
Initial Information Request
Inspection Report: 2024004
During the weeks of November 18-22 and December 9-13 2024, the NRC will perform a
baseline Radiation Safety Inspection at Robinson Nuclear Plant (NRC Inspection Procedures
71124.01, 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 8, 2024.
If there are any questions about this inspection or the material requested, please contact the
lead inspector, Jack Bell at 404-997-4638, 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 letter contains voluntary information collections that are subject to the Paperwork Reduction Act of
1995 (44 U.S.C. 3501 et seq.). The Office 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, Office of the Chief Information Officer, 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 Officer, Office of Information and Regulatory Affairs,
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 Office of Management and Budget control number.
Document Request List
Inspection Dates:
November 18 - 22, 2024
December 9 - 13, 2024
Documents Due to Region II:
November 8, 2024
Inspection Procedures:
Radiological Hazard Assessment and
Exposure Controls
In-Plant Airborne Radioactivity Control
and Mitigation
Occupational Dose Assessment
Radiation Monitoring Instrumentation
Performance Indicator Verification
(Occupational and Public Cornerstones)
Lead Inspector:
Jack Bell
Sr. Health Physicist
US NRC Region II
(404) 997-4638
jack.bell@nrc.gov
(Mailing address available upon request)
Note: The current version of these documents is expected unless specified otherwise.
Secure file server access (Certrec, SharePoint, etc.), or electronic media (CD/DVD), is
preferred. Please organize the information as it is arranged below to the extent possible.
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 w/phone numbers
2. Corrective action program procedure(s)
71124.01 - Radiological Hazard Assessment and Exposure Controls
1. Timeline of major outage activities for 2R34 (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, etc.)
3. Procedures related to release of personnel and materials (e.g. release
surveys, decontamination, guidance for alarm follow-up, etc.)
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 outage RWPs
6. List of all non-fuel items stored in spent fuel pool(s)
7. Technical basis documents (white paper, engineering calculation, etc.) related to the
facility beta-gamma and alpha radiation characterization.
8. Most recent self-assessment or audit covering RP controls
9. Outage ALARA report from the previous (most recent) refueling outage
10. ALARA planning packages for top 3 highest dose jobs for the 2R34 refueling outage
11. List of CRs related to RP controls/ALARA (e.g. radworker error, RP technician error, ALARA
issues, posting issues, HRA/LHRA/VHRA issues, survey problems, etc.) created since July
14, 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
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 last 2 grade D air testing certificates for each supplied air system and SCBA filling
station
4. SCBA qualification records
a)
List of all licensed operators qualified to use SCBA
b)
List of all RP personnel qualified to use SCBA
5. The last 2 surveillances performed on SCBA stored for emergency use (typically monthly)
6. The two most recent in-place filter testing surveillances of the HEPA/charcoal banks for the
Main Control Room Emergency ventilation system, as specified in TS 5.5.11 items a, b, c,
and d. Please include the two most recent tests of each TS item for each train.
7. Most recent audit or self-assessment covering airborne controls and respiratory protection
8. List of CRs related to airborne monitoring and respiratory protection since November 18,
2022.
71124.04 - Occupational Dose Assessment
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, use of
passive monitoring if applicable, declared pregnant workers)
2. Current NVLAP accreditation certificate for lab used to process dosimetry
3. List of all dosimetry events that resulted in the following doses since November 18, 2022:
CEDE > 10 mrem
SDE> 500 mrem
Neutron dose > 50 mrem
4. List of all management over-rides of administrative annual dose limits since November 18,
2022
5. List of all personnel contamination events identified since November 18, 2022
6. Most recent alpha source term plant characterization
7. Area TLD results for general plant areas (not REMP TLDs), going back two years
8. The most recent DLR/SRD correlation analysis
9. Most recent audit or self-assessment of the dosimetry program
10. Most recent plant neutron characterization
11. Copies of current WBC libraries (e.g. routine, medical, investigative, etc.)
12. List of CRs generated since November 18, 2022, for internal or external dosimetry
issues/events.
71124.05 - Radiation Monitoring Instrumentation
1. Procedures for:
a)
calibration and source checks of portable radiation detection instruments
b)
calibration and source checks of small article monitor, personnel contamination
monitor, portal monitor, whole body counting equipment, and continuous air
monitors
c)
QA program for count room instruments
2. The two most recent calibration records for each of the following in-plant instruments:
a)
U2 Containment High Range Monitor, R-32A
b)
U2 Containment High Range Monitor, R-32B
c)
U2 Control Room, Radiation Monitor R-1
d)
Waste disposal system liquid effluent monitor R-18
e)
Plant vent radiation monitoring system R-14 C, D and E
3. Radioactive source paperwork for the sources used to calibrate the instruments in item 2
above. This paperwork should include NIST/NBS certificates, as applicable, and traceability
to the primary (factory) calibration
4. The two most recent in-place filter testing surveillances of the HEPA/charcoal banks
performed on the Unit 2 Spent Fuel Building ventilation system, as specified in TS 5.5.11
items a, b, c, and d. Please include the two most recent tests of each TS item for each train.
5. The last 2 calibration records for each of the following RCA exit point instruments:
a)
All Portal Monitors located at RCA exit
b)
All Small Article Monitors located at RCA exit
c)
All Whole body contamination monitors (ARGOS or equivalent) at RCA exit
6. Two most recent calibration records of the Whole Body Counter used by Dosimetry
7. Two most recent calibration records for all gamma spectroscopy detectors in the count room
8. Two most recent calibration records for all liquid scintillation detectors in the count room
9. Two most recent test records of the instrument calibrator (Shepherd validation testing/dose
rate curves)
10. Interlaboratory comparison results for the onsite count room, going back two years.
11. Most recent audit or self-assessment covering RP and count room instruments (portables,
RCA exit point, WBC, count room).
12. Most recent Radiation Monitoring System health report, if applicable.
13. Chart or procedure listing EALs associated with radiation monitors
14. List of CRs generated since November 18, 2022 related to portable instruments, area
monitors, effluent monitors, CAMs, RCA release point monitors, WBCs, and count room
instruments.
71151 - Performance Indicator (PI) Verification (Occupational and Public Cornerstones)
1. Procedures for gathering and reporting NRC PI data
2. List of electronic dosimeter alarms since July 14, 2023 (dose and dose rate)
3. List of CRs related to ODCM/effluent monitoring issues since July 14, 2023. This should be
a list of corrective action documents containing a CAP document number and a brief
description, not complete documents.
4. Most recent liquid release permit and most recent gaseous release permit