**ATTACHMENT 71121.03**

INSPECTABLE AREA: Radiation Monitoring Instrumentation and Protective
Equipment

CORNERSTONE: Occupational Radiation Safety

INSPECTION BASIS: This inspectable area verifies aspects of the
Occupational Radiation Safety cornerstone for which there are no
indicators to measure performance. Protection of personnel involved in
plant operations or work activities associated with transient high
radiation areas, very high radiation areas, or airborne radioactivity
areas depends on the accuracy, operability, and proper use of radiation
monitoring instruments and other personnel protective equipment.

LEVEL OF EFFORT: Inspect biennially

71121.03-01 INSPECTION OBJECTIVES

01.01 To determine 1) the accuracy and operability of radiation
monitoring instruments that are used for the protection of occupational
workers; and 2) the adequacy of the program to provide self-contained
breathing apparatus (SCBA) for personnel entering and working in areas
of unknown radiological hazards and/or potential immediately dangerous
to life and health (IDLH) areas.

71121.03-02 INSPECTION REQUIREMENTS

02.01 [Inspection Planning]{.underline}. Review the plant FSAR to
identify applicable radiation monitors associated with transient high
and very high radiation areas including those used in remote emergency
assessment. For example, include area radiation monitors associated with
in-core instrumentation, transverse in-core probes, radwaste resin
transfer piping and polyethylene liner fill and cask loading areas.
Emergency assessment instrumentation includes the high-range containment
radiation monitor and the post-accident sample system (containment
atmosphere, containment sump and reactor coolant sampling capability).
Do not repeat any NRC inspection activity for any radiation monitor
instrumentation that is included under the Maintenance Rule program.

> Note: Applicable instruments include area radiation monitors,
> continuous air monitors (CAM), criticality monitors, and portable
> radiation instruments that are used to identify changing radiological
> conditions such that actions to prevent an overexposure may be taken.

02.02 [Identify Additional Radiation Monitoring
Instrumentation]{.underline}. Identify the types of portable radiation
detection instrumentation used for job coverage of high radiation area
work, other temporary area radiation monitors currently used in the
plant, and continuous air monitors associated with jobs with the
potential for workers to receive 50 mrem CEDE. If the site is required
to monitor for internal exposures, include whole body counter equipment
in the review. Identify types of radiation detection instruments
utilized for personnel release from the radiologically controlled area.

02.03 [Verify Calibration, Operability, and Alarm Setpoint (if
applicable) of Several Types of Instruments and Equipment]{.underline}.
Verification methods include: review of calibration documentation,
observation of licensee source check or calibrator exposed readings, or
comparison of source readings using an NRC survey instrument. When
applicable, review the detector measurement geometry, calibration method
and appropriate selection of calibration sources to closely represent
the actual measurement conditions in the plant. When possible, observe
electronic and radiation calibration of these instruments if the
calibration facility is onsite. Include a review of the alarm set point
determinations. Observe in-field source checks. Determine what actions
are taken when, during calibration or source checks, an instrument is
found significantly out of calibration (\>50%). Determine possible
consequences of instrument use since last successful calibration or
source check. Determine if the out of calibration result was entered
into the corrective action program. The inspector should cover at least
four instruments, including at least one portable hand-held survey
instrument, and one personal monitoring device (e.g., electronic alarm
dosimeter, breathing-zone air sampler, etc.).

The licensee's 10 CFR Part 61 source term reviews may be reviewed to
determine if the calibration sources used are representative of the
plant source term. If scaling factors are used for calibrations, the
Part 61 data may be used as a reference to determine if the licensee is
properly scaling (e.g., for hard-to-detect radionuclides).

> Note: Types of instruments are: ion chamber, G-M, underwater detector,
> CAM, electronic alarm dosimeters, pocket dosimeters, teledosimetry,
> personnel contamination monitors, and whole body counters.

02.04 [Problem Identification and Resolution]{.underline}

a.  Review licensee self-assessments, audits, and Licensee Event Reports
    and focus on radiological incidents that involved personnel
    contamination monitor alarms due to personnel internal exposures.
    For internal exposures \>50 mrem CEDE, determine if the affected
    personnel were properly monitored utilizing calibrated equipment and
    if the data was analyzed and internal exposures properly assessed in
    accordance with licensee procedures. Do not duplicate inspection
    efforts to assess internal dose assessments, taken under Attachment
    01, Section 02.02(e). Determine if identified problems are entered
    into the corrective action program for resolution. The number of
    events reports examined should not exceed thirty, but should include
    all event reports involving internal exposures \>50 mrem CEDE.

b.  Review corrective action program reports related to exposure
    significant radiological incidents that involved radiation
    monitoring instrument deficiencies since the last inspection in this
    area. Interview staff and review documents to determine if the
    following activities are being conducted in an effective and timely
    manner commensurate with their importance to safety and risk:

    1.  Initial problem identification, characterization, and tracking

    2.  Disposition of operability/reportability issues

    3.  Evaluation of safety significance/risk and priority for
        resolution

    4.  Identification of repetitive problems

    5.  Identification of contributing causes

    6.  Identification and implementation of corrective actions which
        will achieve lasting results

    7.  Resolution of non-cited violations (NCVs) tracked in corrective
        action system(s)

    8.  Implementation/consideration of risk significant operational
        experience feedback

> Emphasis should be placed on ensuring problems are identified,
> characterized, prioritized, entered into a corrective action, and
> resolved.

c.  For repetitive deficiencies or significant individual deficiencies
    in problem identification and resolution identified above, determine
    if the licensee's self-assessment activities are also identifying
    and addressing these deficiencies.

02.05 [Radiation Protection Technician Instrument Use]{.underline}.
Verify the calibration expiration and source response check currency on
radiation detection instruments staged for use. Observe radiation
protection technicians for appropriate instrument selection and
self-verification of instruments operability prior to use. NOTE: This
inspection requirement may be performed during the job site inspections
accomplished under IP 71121.01

02.06 [Self-Contained Breathing Apparatus (SCBA) Maintenance and User
Training]{.underline}

a.  Based on FSAR, Technical Specifications and Emergency Operating
    Procedures requirements, review the status and surveillance records
    of SCBA staged and ready for use in the plant. Inspect the
    licensee's capability for refilling and transporting SCBA air
    bottles to and from the control room and operations support center
    during emergency conditions. Determine if control room operators and
    other emergency response and radiation protection personnel
    (assigned in-plant search and rescue duties or as required by EOPs
    or Emergency Plan) are trained and qualified in the use of SCBA
    (including personal bottle change-out). Determine if personnel
    assigned to refill bottles are trained and qualified for that task.

> The inspector should include verification of at least three
> individuals on each control room shift crew, and at least three
> individuals from each designated department currently assigned
> emergency duties (e.g., onsite search and rescue duties).

b.  Only personnel who possess manufacturer-certified
    training/qualifications are allowed to perform maintenance and
    repairs on SCBA components vital to the unit's function. These vital
    components typically are the regulator and the low-pressure alarm.
    Review the qualification documentation for onsite personnel
    designated to perform maintenance on the vendor-designated vital
    components, and the vital component maintenance records for three
    SCBA units currently designated as "ready for service". For the same
    three units, ensure that the required, periodic air cylinder
    hydrostatic testing is documented and up to date, and the DOT
    required retest air cylinder markings are in place. Review the
    onsite maintenance procedures governing vital component work, and
    identify any inconsistencies between licensee procedures and the
    SCBA manufacturer's recommended practices. The review should include
    qualification verification for at least 50% of the designated repair
    personnel; check three SCBA units maintenance records over the past
    5 years; and review procedures covering the low-pressure alarm and
    pressure-demand air regulator (vital components).

71121.03-03 INSPECTION GUIDANCE

Findings made as a result of problems with SCBAs (used for emergency
response, including radiological, fires, etc.) or emergency assessment
instrumentation (installed radiation monitors) normally should be
processed using the significance determination process (SDP) for
emergency preparedness. For example, a failure to properly train a
designated SCBA user (e.g., a control room operator with no "hands-on"
training for changing air cylinders) is a finding contrary to the
training requirement in Part 20, Subpart H. Typically this
non-compliance would result in a GREEN finding, using the EP SDP logic
branch \-- Is this finding a "Failure to Meet Regulatory Requirement" ?
Any proposed findings more significant than GREEN relate to whether an
EP planning standard was met or not (the next SDP logic gate), and these
must be discussed with the appropriate Regional manager.

03.01 and 03.02. No inspection guidance.

03.03 [Verify Calibration, Operability, and Alarm Setpoint (if
applicable) of Instruments From Selected Instrument Types]{.underline}.
Risk informed insights should be a key factor in selection of which
instruments are examined by the inspector. For example, instruments used
in high dose rate areas should be of higher priority than personal
friskers. Teledose, remote alarming area radiation monitors, and survey
and dose alarm devices used for diving activities should be high
priority items for inspection. If electronic alarm dosimeters are used
to satisfy a HRA technical specification requirement, then these devices
should be examined periodically. Try to avoid any duplication of NRC
inspection efforts, when looking at EP-related equipment.

If an instrument is not calibrated correctly, determine generic
applicability, actual and potential exposure impact, and assess the
impact with respect to control or emergency preparedness. Verify the
deficiency was entered into the licensee corrective action program.

If an instrument is not operable, determine what backup instrumentation
or other exposure control barriers exist (e.g., teledosimetry used with
electronic pocket dosimeter, or RP technician with survey instrument
providing additional coverage). If no backup exists and no other
exposure control barriers, determine how long the condition has existed
and what was the exposure consequence. Verify the deficiency was entered
into the licensee corrective action program and evaluate the corrective
actions taken.

03.04 and 03.05. No guidance provided.

03.06 [Respiratory Protection - SCBA]{.underline}

a.  For recent examples of licensee problems in this area, refer to NRC
    Information Notices (IN) 98-20 and 99-05. These two INs summarize
    the recent industry problems with qualification of respirator users,
    shortcomings in training, inadequate evaluations of emergency
    conditions and impact on control room operators, and other problems.
    Inspection findings in this area note shortcomings in control room
    operator training, focusing on lack of adequate hands-on training
    (e.g., no practice in changing air cylinders). Note that 10 CFR
    20.1703(c)(4) requires respiratory training and Regulatory Guide
    8.15 (Rev.1), Section 5.2 describes the staff's position in this
    area (e.g., user training should include hands-on training, and
    should demonstrate competency in donning, using and removing the
    device). Note that it may be necessary to request the licensee to
    perform a demonstration of SCBA bottle change-out to ensure that the
    licensee's training program maintains this capability.

b.  See pertinent sections of Regulatory Guide 8.15 (Rev. 1), and
    NUREG-0041 (Rev. 1), for current staff guidance on SCBA acceptable
    maintenance training, practices and activities for vital respirator
    components. The respirator manufacturer (vendor) provides required
    written literature, as well as WEB sites on specific SCBA use and
    maintenance/repair, specifying required surveillances to ensure
    continued unit operability. Discuss any differences between the
    vendor's and the licensee's procedures and practices, and determine
    their potential impact on unit operability/NIOSH certification.

71121.03-04 RESOURCE ESTIMATE

For planning purposes it is estimated to take 40 hours, on average (with
a range of 34 to 45 hours) to perform the requirements of this
attachment.

71121.03-05 COMPLETION STATUS

Inspection of the minimum sample size will constitute completion of this
procedure in the RPS. MSS for this attachment is defined as the sum of
all the inspection requirements. Therefore, all the inspection
requirements of the procedure should be completed. The number of
inspection requirements in Section 02.01 is one; Section 02.02 is one;
Section 02.03 is one; 02.04 is 3 (a-c); Section 02.05 is one; and
Section 02.06 is 2 (a-b). The total inspection requirements and MSS is
nine. During the inspection if no opportunity is available (e.g., no
related corrective action reports (02.04(b)), count that inspection
requirement completed for purposes of the MSS reporting.

END