**ATTACHMENT 71121.01**

INSPECTABLE AREA: Access Control To Radiologically Significant Areas

CORNERSTONE: Occupational Radiation Safety

INSPECTION BASIS: This inspectable area focuses primarily on
verification of aspects of the Occupational Radiation Safety cornerstone
not measured by performance indicators. However, NRC oversight is
maintained for risk significant high and very high radiation areas. The
Occupational Radiation Safety performance indicator (PI) measures
non-conformances involving high radiation areas (HRAs) greater than 1
R/hr and very high radiation areas (VHRAs), and unintended personnel
exposures (resulting from one or more radiation barrier failures)
greater than 100 mrem TEDE, 10% of the non-stochastic limits in 10 CFR
20.1201, 50 rem SDE from a discrete hot particle or 100 mrem to the
embryo/fetus of a declared pregnant woman. The PI for minors is 20% of
the dose limits in 10 CFR 20.1207. Controls for high radiation areas
below 1 R/hr and airborne radioactivity areas are not covered by the PI
and are a major focus of the baseline inspection program.

LEVEL OF EFFORT: Inspect Annually

71121.01-01 INSPECTION OBJECTIVES

01.01 To review and assess licensee's performance in implementing
physical and administrative controls for airborne radioactivity areas,
radiation areas, high radiation areas (HRAs), and worker adherence to
these controls.

01.02 To observe access controls to radiation and high radiation areas
\<1000 mrem/hr and areas that are subject to significant transient dose
rates. Review the controls that have been established and confirm that
workers follow established rules. Review the high radiation area
incidents found in the performance indicators (PIs) and in the
licensee's corrective action program during the current assessment
period.

01.03 To verify that the licensee is maintaining adequate controls over
HRAs (with dose rates greater than 25 rem/h) and all VHRAs.

71121.01-02 INSPECTION REQUIREMENTS

02.01 [Inspection Planning]{.underline}. Review all licensee PIs for the
Occupational Exposure Cornerstone for followup.

02.02 [Plant Walk Downs and RWP Reviews]{.underline}

a.  Identify exposure significant work areas (about 2-3) within
    radiation areas, high radiation areas (\<1 R/hr), or airborne
    radioactivity areas in the plant and review associated licensee
    controls and surveys of these areas to determine if controls (e.g.,
    surveys, postings, barricades) are acceptable.

b.  With a survey instrument, walk down these areas or their perimeters
    to determine: whether prescribed RWP, procedure, and engineering
    controls are in place, whether licensee surveys and postings are
    complete and accurate, and whether air samplers are properly
    located.

c.  Review radiation work permits (RWPs) used to access these and other
    high radiation areas and identify what work control instructions or
    control barriers have been specified. Use plant-specific Technical
    Specification HRA requirements as the standard for the necessary
    barriers. Review electronic personal dosimeter (EPD) alarm set
    points (both integrated dose and dose rate) for conformity with
    survey indications and plant policy. Verify that workers know what
    actions are required when their EPD noticeably malfunctions or
    alarms.

d.  Review RWPs for airborne radioactivity areas with the potential for
    individual worker internal exposures of \>50 mrem CEDE (20 DAC-hrs).
    For these selected airborne radioactive material areas, verify
    barrier integrity and engineering controls performance (e.g., HEPA
    ventilation system operation). Focus on any work areas with a
    history of, or the potential for, airborne transuranics. The
    inspector should review up to three RWPs, as available.

e.  Review and assess the adequacy of the licensee's internal dose
    assessment for any actual internal exposure greater than 50 mrem
    CEDE (limit these assessments to no more than two intake events with
    similar radionuclide mixes). Note that Attachment 03, Section
    02.04(a) has a similar inspection requirement; if NRC assessments
    were done under that Attachment, do not duplicate that effort for
    this section during the same inspection cycle.

f.  Examine the licensee's physical and programmatic controls for highly
    activated or contaminated materials (non-fuel) stored within spent
    fuel and other storage pools.

02.03 [Problem Identification and Resolution]{.underline}

a.  Review the licensee's self assessments, audits, Licensee Event
    Reports, and Special Reports related to the access control program
    since the last inspection. Determine if identified problems are
    entered into the corrective action program for resolution.

b.  Review corrective action reports (up to 15) related to access
    controls. Include in this review 2-3 high radiation area
    radiological incidents (non-PIs, identified by the licensee) in high
    radiation areas \<1R/hr that have occurred since the last inspection
    in this area. 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, 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.

d.  Review licensee documentation packages for all PI events occurring
    since the last inspection. Determine if any of these PI events
    involved dose rates \>25 R/hr at 30 centimeters or \>500 R/hr at 1
    meter. If so, determine what barriers had failed and if there were
    any barriers left to prevent personnel access. For unintended
    exposures \>100 mrem TEDE (or \>5 rem SDE or \>1.5 rem LDE),
    determine if there were any overexposures or substantial potential
    for overexposure? If any of the above conditions were met, then
    document the PI as a significant inspection finding, in accordance
    with IMC 0612 (formerly IMC 0610\*) guidance.

02.04 [Job-In-Progress Reviews]{.underline}

> NOTE: This section should be combined with Section 02.02 of this
> procedure.
>
> a\. 1. Based on the licensee's schedule of work activities, select two
> to three jobs being performed in radiation areas, airborne
> radioactivity areas, or high radiation areas (\<1 R/hr) 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. During the time of inspection, if there are no
> radiologically significant work activities being performed in the
> areas described above (areas of \< 1 R/hr, diving activities, or work
> involving potentially changing (deteriorating) radiological
> conditions), then the inspector should observe work being performed in
> high radiation areas having dose rates \> 1 R/hr for purposes of PI
> supplementation and verification.
>
> 2\. Review all radiological job requirements (RWP requirements and
> work procedure requirements). When practical, attend RWP job
> briefings.
>
> 3\. Observe job performance with respect to these requirements.
> Determine if radiological conditions in the work area were adequately
> communicated to workers through briefings and postings.
>
> b\. During job performance observations, verify the adequacy of
> radiological controls, such as: required surveys (including system
> breach radiation, contamination, and airborne surveys), radiation
> protection job coverage(including audio and visual surveillance for
> remote job coverage), and contamination controls.
>
> c\. For high radiation work areas with significant dose rate gradients
> (factor of 5 or more), review the application of dosimetry to
> effectively monitor exposure to personnel. Focus on any underwater
> diving activities, where the dose rate gradients are severe, thereby
> increasing the necessity of providing multiple dosimeters and/or
> enhanced job controls. Verify licensee controls are adequate.

02.05 [High Risk Significant, High Dose Rate HRA and VHRA
Controls]{.underline}. Focus on verifying aspects of the licensee PI
activities for high risk, high dose rate (HDR) HRAs (\>25 rem in one
hour \@30 cm) and for all VHRAs. These areas provide the potential for
significant worker overexposures, and in some cases, potentially lethal
acute exposures.

a.  Discuss with the Radiation Protection Manager (RPM) HDR-HRA, and
    VHRA controls and procedures. Focus on any procedural changes since
    the last inspection. Verify that any changes to licensee procedures
    do not substantially reduce the effectiveness and level of worker
    protection.

b.  Discuss with no more than two first-line HP supervisors (or
    equivalent positions having backshift HP oversight authority) the
    controls in place for special areas that have the potential to
    become VHRA during certain plant operations. Determine if these
    plant operations (e.g., PWR thimble withdrawal into the reactor
    cavity sump) require communication beforehand with the HP group, so
    as to allow corresponding timely actions to properly post and
    control the radiation hazards.

c.  Verify adequate posting and locking of all entrances to all HDR-HRA,
    and VHRA (if reasonably accessible).

02.06 [Radiation Worker Performance]{.underline}

a.  During job performance observations, observe radiation worker
    performance with respect to stated radiation protection work
    requirements. Determine if they are aware of the significant
    radiological conditions in their workplace, and the RWP
    controls/limits in place, and that their performance takes into
    consideration the level of radiological hazards present.

b.  Review up to ten radiological problem reports since the last
    inspection which find that the cause of the event was due to
    radiation worker errors. Determine if there is an observable pattern
    traceable to a similar cause. Determine if this perspective matches
    the corrective action approach taken by the licensee to resolve the
    reported problems. Discuss with the RPM any problems with the
    correction actions planned or taken.

02.07 [Radiation Protection Technician Proficiency]{.underline}

a.  During job performance observations, observe radiation protection
    technician performance with respect to all radiation protection work
    requirements. Determine if they aware of the radiological conditions
    in their workplace and the RWP controls/limits, and if their
    performance is consistent with their training and qualifications
    with respect to the radiological hazards and work activities.

b.  Review a maximum of ten radiological problem reports since the last
    inspection that finds that the cause of the event was radiation
    protection technician error. Determine if there is an observable
    pattern traceable to a similar cause. Determine if this perspective
    matches the corrective action approach taken by the licensee to
    resolve the reported problems.

71121.01-03 INSPECTION GUIDANCE

03.01 No inspection guidance provided.

03.02 [Plant Walkdowns and RWP Reviews]{.underline}

> a.,b., c and e. No guidance provided.
>
> d\. Continuous air monitors positioned throughout the power plant are
> often used as initial trending indicators of increasing airborne
> radioactive material levels . While identified increases in airborne
> levels may not be dose significant (as indicated by the directly
> measurable beta-gamma emitting radionuclides), power plants with known
> transuranic contamination problems should consider and assess this
> transuranic component when appropriate. This focus is especially vital
> during certain maintenance activities in known transuranic
> contaminated areas. See Information Notice 97-36, "Unplanned Intakes
> by Worker of Transuranic Airborne Radioactive Materials and External
> Exposure Due to Inadequate Control of Work" for discussion of previous
> problems and guidance in this area.
>
> f\. Licensees may store highly activated materials (e.g.,fuel
> channels, and LPRM sources,) underwater on short-hangers, which could
> be inadvertently raised to the pool surface. If unshielded, these
> materials could create a HRA or VHRA. For applicable guidance and a
> history of previous events, see Regulatory Guide 8.38, "Control of
> Access to High and Very High Radiation Areas In Nuclear Plants",
> Section C. 4. 2; Information Notice 90-33, "Sources of Unexpected
> Occupational Radiation Exposure at Spent Fuel Storage Pools"; and
> Health Physics Positions (HPPOS)016 and 245 (NUREG/CR-5569, Rev.1)and
> HPPOS 333 (Miller-Joyner memorandum, et al, January 30, 1995), and
> Questions and Answers 447 and 448 (NUREG/CR-6204).

03.03 No inspection guidance provided.

03.04 Job-In-Progress Review

> a\. -- b. No guidance provided;
>
> c\. Dosimeter selection and placement criteria: adequacy of criteria
> for utilization and placement of whole body and extremity dosimeters
> including use in non-uniform radiation fields. Part 20.1201(c) does
> not exempt any work areas from the requirement to measure dose (DDE)
> at the part of the body receiving the highest exposure. However (while
> not a focus of this inspection), the licensee's procedure should have
> reasonable criteria for complying with 20.1201(c) for workers where
> dose rates are greater than 10 mrem/h. Additionally, assuming a dose
> gradient of 1.5 or more, it would not be reasonable to move the
> personal dosimeter (or provide for additional dosimeters), unless an
> individual's dose missed by not moving the dosimeter was "significant"
> (e.g, 30 mrem for an individual for the work shift). From a collective
> dose perspective (assuming a dose gradient of 1.5 or more), a "missed"
> collective dose of 250 mrem or more for a job is a reasonable
> threshold action criterion for the licensee to provide additional
> personal monitoring (or move the dosimeter) to measure the highest
> DDE, consistent with 20.1201(c).

03.05 [High Risk Significant, High Dose Rate HRA and VHRA
Controls]{.underline}. Because of the potential high risk radiation
environment these areas can present, an annual baseline, independent NRC
verification of the performance indicators is needed. The intent of this
limited inspection oversight/requirement is to maintain a continued NRC
vigilance of the licensee's program and procedural controls, and plant
staff awareness of these special, accessible areas where the potential
for lethal overexposure exist.

a.  This HP inspection requirement should not be repeated during the
    site-wide, annual PI verification team inspection.

b.  Determine if entries are made into areas controlled as VHRAs. For
    example, PWRs can control primary containments as VHRAs during power
    operations. Discuss with licensee management the required procedural
    controls and HP technician coverage during such entries.

c.  See Regulatory Guide 8.38, Section C. 4., Appendix A & B for
    guidance for specific work areas and activities that have documented
    histories of worker overexposures.

See applicable Questions and Answers (NUREG/CR-6204) and HPPOS
(NUREG/CR-5569).

71121.01-04 RESOURCE ESTIMATE

For planning purposes, it is estimated to take, on average, between 24
hours and 40 hours annually to perform the requirements of this
attachment.

71121.01-05 COMPLETION STATUS

Inspection of the minimum sample size (MSS) 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 six
(a-f); Section 02.03 is 4 (a-d); 02.04 is 3 (a-c); Section 02.05 is 3
(a-c); Section 02.06 is 2 (a-b); and Section 02.07 is 2 (a-b).

The total inspection requirements and MSS is twenty-one. During the
inspection if no opportunity is available (e.g., no intakes \>50 mrem,
02.(e)), count that inspection requirement completed for purposes of the
MSS reporting.

END