**ATTACHMENT 71121.02**

INSPECTABLE AREA: ALARA Planning And Controls

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. The stochastic risk effect of
exposure is based on the linear non-threshold exposure model. Increasing
individual or collective exposures equates to increased risk of cancer
or genetic effects. Licensees are required to manage these risks to as
low as is reasonably achievable (ALARA) levels. The effectiveness of a
licensee's ALARA program is assessed by comparing the outcomes (in terms
of collective dose) to the dose that was intended (i.e., determined to
be ALARA) for individual work activities. A work activity is one or more
closely related tasks that the licensee has reasonably grouped together
as a unit of work for the purpose of ALARA planning and work controls.

LEVEL OF EFFORT: Inspect biennially

71121.02-01 INSPECTION OBJECTIVE

01.01 To assess performance with respect to maintaining individual and
collective radiation exposures as low as is reasonably achievable. This
inspection will determine whether the licensee has an adequate program,
including administrative, operational, and engineering controls, to
maintain occupational exposure ALARA.

71121.02-02 INSPECTION REQUIREMENTS

> NOTE: This inspection may be performed during plant operations, with
> respect to on-line maintenance (at-power operations), when the ALARA
> review time frame is compressed. This inspection may also be performed
> during outage conditions and prior to and following a significant
> maintenance or refueling outage to evaluate outage planning and
> post-outage performance results and lessons learned.

02.01 [Inspection Planning]{.underline}

a.  Review pertinent information regarding plant collective exposure
    history, current exposure trends, and ongoing or planned activities
    in order to assess current performance and exposure challenges.
    Determine the plant's current 3-year rolling average collective
    exposure[^1]. The overall collective exposure performance will be
    used as an input to establish the resources required to complete
    this inspection attachment and to provide a perspective of
    significance for any resulting inspection finding assessment.

b.  Review outage or on-line maintenance work scheduled during the
    inspection period and associated work activity exposure estimates or
    previous work activity history data. Select 5 to 10 work activities
    which are likely to result in the highest personnel collective
    exposures.

c.  Determine the site specific trends in collective exposures (using
    NUREG-0713 and plant historical data) and source-term (average
    contact dose rate with reactor coolant piping) measurements (using
    EPRI TR-108737 [^2] and/or plant historical data, when available).

d.  Review site specific procedures associated with maintaining
    occupational exposures ALARA. Include a review of processes used to
    estimate and track work activity specific exposures.

02.02 [Radiological Work Planning]{.underline}.

a.  Obtain from the licensee a list of work activities ranked by
    actual/estimated exposure that are in progress or that have been
    completed during the last outage and select the 3 to 5 work
    activities of highest exposure significance.

> b\. Review the ALARA work activity evaluations, exposure estimates,
> and exposure mitigation requirements. Determine if the licensee has
> established procedures, engineering and work controls, based on sound
> radiation protection principles, to achieve occupational exposures
> that are ALARA. Determine if the licensee has reasonably grouped the
> radiological work into work activities, based on historical
> precedence, industry norms, and/or special circumstances.
>
> c\. Compare the results achieved (dose rate reductions, person-rem
> used) with the intended dose established in the licensee's ALARA
> planning for these work activities. Determine the reasons (e.g.,
> failure to adequately plan the activity, failure to provide sufficient
> work controls, etc.) for any inconsistencies between intended and
> actual work activity doses.
>
> d\*[^3]. Evaluate the interfaces between operations, radiation
> protection, maintenance, maintenance planning, scheduling and
> engineering groups for interface problems or missing program elements.
>
> e\*. Review the integration of ALARA requirements into work procedure
> and RWP documents.
>
> f\*. Compare the person-hour estimates provided by maintenance
> planning and other groups to the radiation protection group with the
> actual work activity time requirements and evaluate the accuracy of
> these time estimates.
>
> g\*. Evaluate the radiation protection group generated shielding
> requests with respect to dose rate reduction problem definition and
> assigning value (dose savings or dollars). Evaluate engineering
> shielding responses for follow through.
>
> h\*. Determine if work activity planning includes consideration of the
> benefits of dose rate reduction activities such as shielding provided
> by water filled components/piping, job scheduling, and shielding and
> scaffolding installation and removal activities.
>
> i\*. Determine if post-job (work activity) reviews were conducted and
> if identified problems were entered into the licensee's corrective
> action program.

02.03 [Verification of Dose Estimates and Exposure Tracking
Systems]{.underline}

> a\. Review the assumptions and basis for the current annual collective
> exposure estimate. Review applicable procedures to determine the
> methodology for estimating work activity-specific exposures and the
> intended dose outcome. Evaluate both dose rate and man-hour estimates
> for reasonable accuracy.
>
> b\. Review the licensee's method for adjusting exposure estimates, or
> re-planning work, when unexpected changes in scope or emergent work
> are encountered. Are adjustments to estimated exposure (intended dose)
> based on sound radiation protection and ALARA principles or just
> adjusted to account for failures to control the work? Does the
> frequency of these adjustments call into question the adequacy of the
> original ALARA planning process?
>
> c\*. Review the licensee's exposure tracking system. Determine whether
> the level of exposure tracking detail, exposure report timeliness and
> exposure report distribution is sufficient to support control of
> collective exposures. For example, do RWPs cover too many work
> activities to allow work activity specific exposure trends to be
> detected and controlled? During the conduct of exposure significant
> maintenance work, look for evidence that licensee management was aware
> of the exposure status of the work and would intervene if exposure
> trends increased beyond exposure estimates.

02.04 [Job Site Inspections and ALARA Control]{.underline}

> NOTE: Job site inspection activities may be combined with Section
> 02.04 of 71121.01, "Access Control to Radiologically Significant
> Areas."
>
> a\. Based on scheduled work activities and associated exposure
> estimates, select about 3 to 5 work activities in radiation areas,
> airborne radioactivity areas, or high radiation areas for observation.
> Concentrate on work activities that present the greatest radiological
> risk to workers. For example, observe work that is estimated to result
> in the highest collective doses, involves diving activities in or
> around spent fuel or highly activated material, or that involves
> potentially changing (deteriorating) radiological conditions. Evaluate
> the licensee's use of ALARA controls for these work activities by
> performing the following:
>
> 1\. Evaluate the licensee's use of engineering controls to achieve
> dose reductions. Are the procedures and controls consistent with the
> licensee's ALARA reviews? Is sufficient shielding of radiation sources
> provided for? Did the dose expended to install/remove the shielding
> exceed the dose reduction benefits afforded by the shielding?
>
> 2\*. Determine if workers are utilizing the low dose waiting areas and
> are effective in maintaining their doses ALARA (e.g., do they remain
> in the work area or move to the low dose waiting area when subjected
> to temporary work delays).
>
> 3\*. Determine if workers receive appropriate on-the-job supervision
> to ensure the ALARA requirements are met. Determine if the first-line
> job supervisor ensures the work activity is conducted in a dose
> efficient manner (e.g., work crew size minimized, workers properly
> trained, proper tools and equipment available at start of job, etc.).
>
> b\*. Review exposures of individuals from selected work groups.
> Evaluate any significant exposure variations which may exist among
> workers and determine whether these significant exposure variations
> are the result of worker job skill differences or whether certain
> workers received higher doses because of poor ALARA work practices.

02.05 [Source-Term Reduction and Control]{.underline}

> a\. Utilizing licensee records, determine the historical trends and
> current status of tracked plant source terms. Determine if the
> licensee is making allowances or developing contingency plans for
> expected changes in the source term due to changes in plant fuel
> performance issues or changes in plant primary chemistry.
>
> b\*. Determine if the licensee has developed an understanding of the
> plant source-term, including knowledge of input mechanisms to reduce
> the source term. Determine whether the licensee has a source-term
> control strategy in place. This should include a cobalt reduction
> strategy and shutdown ramping and operating chemistry plan (designed
> to minimize the source-term external to the core) as a minimum. Other
> methods to control the source term would include preconditioning of
> primary system surfaces, component and system decontamination, and use
> of shielding. Some source-term control strategies may not be
> applicable to certain plants. If the licensee does not have a
> source-term control strategy in place, look for reasonable
> justifications for not pursuing such exposure reduction initiatives.
>
> c\*. If the licensee has a source-term control strategy in place,
> determine if specific sources have been identified by the licensee for
> exposure reduction actions and what priorities the licensee has
> established for implementation of these actions. Determine what
> results have been achieved against these priorities since the last
> refueling cycle. During the current 12 month assessment period,
> determine whether source reduction evaluations have been made and
> actions have been taken to reduce the overall source-term compared to
> the previous year.

02.06 [Radiation Worker Performance]{.underline}. Observe radiation
worker and RP technician performance during work activities being
performed in radiation areas, airborne radioactivity areas, or high
radiation areas. Concentrate on work activities that present the
greatest radiological risk to workers (see section 02.04). Determine if
workers demonstrate the ALARA philosophy in practice (e.g., are workers
familiar with the work activity scope and tools to be used, are workers
utilizing ALARA low dose waiting areas) and whether there are any
procedure compliance issues (e.g., are work activity controls being
complied with). Also, observe radiation worker performance to determine
whether the training/skill level is sufficient with respect to the
radiological hazards and the work involved.

02.07 [Declared Pregnant Workers]{.underline}. Determine if there have
been any declared pregnant workers during the current assessment period.
Review the exposure results and monitoring controls employed by the
licensee with respect to requirements of 10 CFR 20.

02.08 [Problem Identification and Resolutions]{.underline}

> a\. Review the licensee's self assessments, audits, and Special
> Reports related to the ALARA program since the last inspection.
> Determine if the licensee's overall audit program's scope and
> frequency (for all applicable areas under the Occupational
> Cornerstone) meet the requirements of 10 CFR 20.1101(c).
>
> b\*. Determine if identified problems are entered into the corrective
> action program for resolution. Review dose significant post-job (work
> activity) reviews and post-outage ALARA report critiques of exposure
> performance. Determine if identified problems are properly
> characterized, prioritized, and resolved in an expeditious manner.
>
> c\*. Review corrective action reports related to the ALARA program.
> Interview staff and review documents to determine if the follow-up
> 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 effective corrective actions.
>
> 7\. Resolution of non-cited violations (NCVs) tracked in the
> corrective action system.
>
> 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 program,
> and resolved.
>
> d\. 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.

71121.02-03 INSPECTION GUIDANCE

Situations where the unplanned, unintended collective dose for a work
activity does not exceed 50% of the planned, intended dose, should
normally be considered as minor issues and screened out from SDP
consideration (see appendix B to IMC 0612, formerly IMC 0610\*, for a
discussion of the screening process). This criterion reflects a
reasonable expectation of the accuracy of ALARA planning. In addition,
failures that exceed this 50% criterion for work activities where the
actual total collective dose is less than 5 person-rem should also
generally be considered as minor.

03.01 [Inspection Planning]{.underline}. The level of inspection
resources, and the number of onsite inspections, needed to complete this
attachment should be commensurate with the radiological challenge that
licensee is experiencing. In general, licensees whose current three-year
rolling average collective dose is in the lowest quartile (NRR will
calculate and disseminate plant quartile information for both PWRs and
BWRs to the Regions on an annual basis), when compared to reactors of
the same type (e.g., PWR or BWR), should be assigned the minimum
inspection hours. Licensees in the highest quartile should be assigned
the maximum inspection hours. However, factors such as the anticipated
scope of upcoming radiological work, and noted trends in the
performance, may also be considered in determining the level of
inspection resources.

03.02 [Radiological Work Planning]{.underline}. A work activity may have
benefitted from proper ALARA radiological work planning, yet overshot
its intended dose outcome due to unplanned, unexpected conditions or
emergent work. Although the pressures of outage scheduling may impact
the determination of what additional controls, etc., are reasonably
achievable, the licensee is still required to manage these activities
such that the resulting doses are ALARA. Occurrences of this type should
be entered into the licensee's corrective action program for a
determination whether these dose overruns were avoidable, and the
appropriate licensee organization(s) should be held accountable for
these breakdowns in work planning. Part 20 does not require licensees to
make every possible effort to demonstrate optimized exposure
performance. However, a high frequency of these ALARA deficiencies may
indicate a deficiency in the licensee's overall ALARA program in terms
of the ability of different work groups (e.g. operations, radiation
protection, maintenance, outage planning) to interface effectively with
each other.

03.03 [Verification of Exposure Estimate Goal Dose Estimates and
Exposure Tracking Systems]{.underline}. The ability to determine if
doses for a work activity are ALARA, or whether they need to be reduced
further, will often depend on the accuracy of exposure estimates made in
the planning process. These exposure estimates should be based on good
assumptions and correct calculations with some flexibility given with
regard to expected variability due to the limits of forecasting.

Accurate exposure estimates usually require a detailed task analysis of
the work activity. However, in cases of routine activities, the licensee
may rely on previous experience to establish the intended dose and
reasonable work controls, in lieu of detailed analysis. Look for
bottom-up (aggregation of individual task estimates) exposure estimates
corroborated by top-down (historical work activity dose rate times work
activity duration) estimating methods. Use of past outage experience
combined with additional industry experience can provide a reasonable
exposure estimate approach.

If exposure estimates appear questionable, use site-specific past
experience as the primary standard of comparison and utilize industry
data (as available) of actual work activity exposure data as a secondary
standard of comparison to determine the reasonableness of licensee
exposure estimates.

03.04 [Job Site Inspections and ALARA Control]{.underline}. Performing
surveys of high collective dose job locations can provide a means to
evaluate the results of the licensee's ALARA efforts. If the sources are
shielded to essentially background levels, then no significant dose
gradients should be detected and review of the licensee's shielding
efforts in this area may not be necessary.

Review the individual doses for workers associated with several high
exposure work activities or work activities performed in high radiation
areas. Notable variations in doses among workers in the same work group
(or between workers performing the same or similar work activities at
different times) may be due to poor or inconsistent work practices
(e.g., use of inadequate shielding, lack of mockup training, excessive
re-work rates). If such inconsistencies in worker doses are observed,
identify what measures the licensee has taken to improve these
practices.

03.05 [Source Term Reduction and Control]{.underline}. Consider
utilizing a survey instrument to walk down selected accessible areas of
the station to verify the accuracy and completeness of the licensee's
source tracking program. During plant tours, investigate any sources
that may affect collective exposures and which are not tracked by the
licensee.

For such radiation sources, determine how long the condition has
existed, whether postings and radiation surveys have been deficient,
whether any unplanned exposures have occurred or were likely to occur,
and whether the licensee has entered this information into its
corrective action program.

If a licensee identified radiation source is old (greater than 1 year),
determine how long the condition has existed. If this source may have
resulted in unnecessary exposures (such as during an outage), determine
how much exposure has resulted from (or was likely to have resulted
from) the source and compare those results with the licensee's exposure
evaluation assessment to encompass the extended time period.

If actions taken to reduce the source term have been ineffective,
determine if follow-up evaluations and additional actions have been
planned. If not, look for additional examples to establish whether there
is a pattern.

03.06 through 03.07 No inspection guidance provided.

03.08 [Problem Identification and Resolution]{.underline}. ALARA program
deficiencies noted should be documented consistent with the criteria in
IMC 0612 (formerly IMC 0610\*).

For applicable guidance on 20.1101(c) compliance, see Questions and
Answers 118, 134 and 380 (NUREG/CR 6204).

71121.02-04 RESOURCE ESTIMATE

For planning purposes, it is estimated to take, on average, 80 hours
biennially to perform the requirements of this attachment. A minimum of
64 hours should be assessed for the best performers, as determined by
the plants appearing in the top (lowest dose) quartile of the plant
ranking based on three-year rolling average collective dose. A maximum
of 96 hours should be assessed for the plants appearing in the bottom
(highest dose) quartile of three-year rolling average collective doses.
The plants in the second and third quartiles should receive an average
of 80 inspection hours biennially.

71121.02-05 COMPLETION STATUS

The minimum sample size for this attachment is fifteen (15) inspection
requirements (defined as the sum of all the inspection requirements
(Section 71121.02-02) without an asterisk). These fifteen non-asterisk
inspection requirements are the minimum required for plants which have a
three-year rolling average collective dose (TYRA) which is in the top
(lowest dose) quartile (NRR will calculate and disseminate plant
quartile information for both PWRs and BWRs to the Regions on an annual
basis). The inspection requirements with an asterisk following their
subsection number are optional and should be added, as deemed
appropriate by the Region, for higher quartile TYRA plants such that all
required areas (asterisk and non-asterisk inspection requirements) are
inspected for those plants in the bottom (highest TYRA) quartile. All
other sections of this procedure must be completed at all plants.

END

[^1]: 10 CFR Part 20.2206 (c) requires that licensees submit to the NRC
    an annual report containing the results of individual monitoring
    carried out by the licensee by April 30^th^ of each year for the
    previous year's collective exposure. The individual plant collective
    exposures, along with the three-year rolling average collective
    exposure for each operating commercial nuclear plant, are contained
    in NUREG-0713, "Occupational Radiation Exposure at Commercial
    Nuclear Power Reactors and Other Facilities". The inspector should
    use the most recent annual collective exposure data available for
    calculating the three-year rolling average collective exposure (if
    the licensee has submitted its 20.2206 (c) report for the previous
    year, use this data to calculate the three-year rolling average
    collective exposure if it is more recent than the data contained in
    the latest NUREG-0713 report).

[^2]: EPRI TR-108737 (Dec 1998), "BWR Iron Control Monitoring Interim
    Report" \[average BWR source-term based on this report is 220
    mrem/hr\]. EPRI TR-107566 (Feb 1997), "Evaluation of PWR Radiation
    Fields: 1991-1996\" \[average PWR source-term based on this report
    is 100 mrem/hr\]. Source-term as defined by EPRI means average
    contact dose rate with the vertical recirculation piping (for BWRs)
    and with the crossover loop elbow near the reactor coolant pump
    piping (SRMP pt C5) for PWRs.

[^3]: An asterisk indicates that this is an optional inspection
    requirement. (See 71121.02-05)