ML20205N574

Summary of 990330 Meeting with NEI in Washington,Dc Re Performance Indicators for Assessing Radiation Protection Programs & Assessment of Radiation Protection Insp Findings

ML20205N574
Person / Time
Issue date:	04/14/1999
From:	Wigginton J NRC (Affiliation Not Assigned)
To:	Essig T NRC (Affiliation Not Assigned)
References
NUDOCS 9904190015
Download: ML20205N574 (25)

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UNITED STATES i.(11' j NUCLEAR REGULATORY COMMISSION jQ c

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April 14, 1999 MEMORANDUM TO. Thomas H. Essig, Chief Emergency Preparedness and Health Physics Section Division of inspection Program Management Office of Nuclear 7eactor Reguiation-k FROM:

James E. Wigginton, Senior React Nealth P

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Emergency Preparedness and HM Physics Section Division of Inspection Program Management Office of Nuclear Reactor Regulation SUBJECT-

SUMMARY

PUBLIC MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) REGARDING PERFORMANCE INDICATORS FOR ASSESSING RADIATION PROTECTION PROGRAMS AND ASSESSMENT OF RADIATION PROTECTIC'N INSPECTION FINDINGS On March 30.1999. representatives of the Nuclear Energy Institute (NEl) and nuclear power plant radiation protection managers and senior technical staff met with representatives of the Nuclear Regulatory Commission (NRC) at NEl's office in Washington. D.C. provides a hst of workshop attendees.

The purpose of the workshop was to continue discussion and development oi performance indicators (PI) to be used by the NRC to help assess the iicensee's radiation protection programs at power reactors. The NEl Senior Project Manager noted that the power plants were well represented by the large turnout and good cross-section of radiation protection professionals.

The meeting commenced with discussion in the public cres which inc: 1es transportation, radioactive matenal release, and effluents. Attachment 2 (NEl's draft * >lic radiation safety cornerstone Pts ) and Attachment 3 (NEl's draft RETS/ODCM Pl queduons) were exchanged among the meeting participnts. After some discussion, the NRC staff and stakeholders egreed to the markups on Attachment 2. The questions on Attachment 3 were discussed and consensus was reached on tne marked-up answers. Industry and NEl provided comments on (NP.C's Public Radiation Safety logic diagram). The major industry cornment on the diagram concerned (in the rad matenal control leg) the need for a low threshold dose value f

for low risk events. The NRC staff agreed to consider a possib!e "deminimis" dose threshold to f

incorporate for the >1 Event of <0.025 rem" box - add a 'but greater than' dose consequence.

I in the environmental mon:toring event leg. the industry questioned the relative risk significance of missing >2 samples. The NRC staff will concider industry's comment.

.4 CONTACT: James E. W;gginton IOHB/NRR Y

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The last area of discussion in the public radiation safety cornerstone covered transportation and Part 61 issues. With the NARC logic diagram under development, the discussion focused on the ccmpanion risk significance matrix to be used to categorize NRC inspection findings in this area (Attachment 5). The NRC staff noted that some changes were likely, based on early feedback from NRC Regional and NMSS staff. These changes would generally lead to more severe findings determinations in the " breach" category. Industry will be providing comments at a future date.

In the occupational radiation safety area, the discussion started on section 2.5 of the NEl Pl Manual (Attachment 6). All comments on the manual section were resolved, and Attachment 7 was discussed. These general principles (examples) for what is (yes) and what is not (no) a Pi hit were found acceptable and will be used for the Pilot training in mid-April. A specific example scenario was offered where multiple i nlocked dars were discovarod because of the same root cause (on the same HP technician shift tour), with the question how many PI hits would result.

All parties would support only one PI hit should be scored (e.g., a single worker visited multiple locked high radiation areas and failed to secure the doors upon exit). For very high radiation areas (VHRA), NEl proposed that a licensee should not take a PI hit for non-conformances with governing procedures that are non-consequental and administrative in nature, relative to access controls for VHRA. The NRC repres 1atives noted that this view was consistent with the intent of the Pl concept. Attachment 8 au more NEl examples of scenarios involving HRAs, which will be discussed at the Pilot training, as will Attachment 9 (examples developed by the NRC). As gerieral feedback from high level NEl and NRC management meetings, it was noted that all parties would have opportunities to modify the Pl and supporting documentation at various point during and at the end of the pilot inspections.

The NRC staff presented the occupational exposure logic diagram and supporting risk matnx (Attachments 10 and 11) to be used by the NRC inspectors to consistently categorize individual inspection findings as to their risk signif.; oce. The staff fielded questions from industry concerning relative importance of reportmg requirements and need for more information related to the " compromises ability to assess Dose" diamond. The staff agreed to provide background information on that area, as well as other blocks on the diagram. The final area of discussion focused on the as low as reasonaoly achievable (ALARA) area in occupational exposure (Attachment 12). This proposed logic diagram drew several industry comments and suggestions, including the need to define what an ALARA finding is, need to use publically available dose data, and the benefits of simplifying the flow logic. The NRC agreed to consider this input.

The meeting was adjourned.

DISTRIBUTION: See attached page DOCUMENT NAME:P:\\MTSM0330 hf OFFICE 10 @

IOHB JWkgNon NAME TESSIG DATE l 04//'f/99 04/ \\k199 OFFICIAL RECORD COPY

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The last area of discussion in the pubhc radiation safety cornerstone covered transpor1ation and Part 61 issues. With the NARC logic diagram under deveigment, the discussion focused on the companion nsk significance matrix to be used to categorize NRC inspection findings in this area (Attachment 5). Tne NRC staff noted that some chances were likely, based on early feedback from NRC Regional and NMSS stLff. These changes would generally lead to more l

severe findings determinations in the " breach" category. Industry will be providing comments at a future date.

in the occupational radiation 5 afety area, the discussion started on section 2.5 of the NEl PI Manuai(Attachment 6). All comments on the manual section were resolved, and Attachment 7 was discussed. These general principles (examples) for what is (yes) ana what is not (no) a Pi hit were found acceptable and will be used for the Pilot training in mid-April. A specific cxample scenano was offered where multiple unlocked doors were discovered because of the same root t

cause (on the same HP technician shift tour), with the question how many Pl hits would result.

All parties would supoort only one Pl hit should be scored (e.g., a single worker v. sited multple locked high radiation areas and failed to secure the doors upon exit). For very high radiation J

l areas (VHRA) NEl proposed that a hcensee should not take a PI hit for non conformances with l

governing procedures that are non consequental and administrative in nature, relative to access controls for VHRA. The NRC representatives noted that this view was consistent with the intent of the PI concept. Attachment 8 are more NEl examples of scenarios involving HRAs, wnich will be discussed at the Pilot training, as will Attachment 9 (examples developed by the NRC). As general feedback from high level NEl and NRC management meetings,it was noted that all parties would have opportunities to modify the P. and supporting documentation at vanous point during and at the end of the pilot inspections.

The NRC staff presented the occupational exposure logic diagram and suppcrting risk matrix I

(Attachments 10 and 11) to be used by the NRC inspectors to consistently categorize individual inepection findings as to their risk significance. Tne staff fielded questions from industry concerning relative importance of reporting requirements and need for more information related to tne " compromises abihty to assess Dose" diamond. The staff agreed to provide background information on that area, as well as other blocks on the diagram. The final area of discussion focured on the as low as reasonably achievable (ALARA) area in occupational exposure (Attachment 12). This proposed logic diagram drew several industry comments and suggestions, mcluding the need to define what an ALARA finding is, need to ure publically availalle dose data, and the benefits of simphfying the flow logic. The NRC agreed to consider this inpiit.

The mee ing was adjourned.

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Attachments: as Stated cc w%tt: See n(xt page l

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r-i t-g Distribution: Mtg. Summary w/. Dated April 14, 1999 Hard Conv citMtC PERB R/F SMagruder JWigginton CHinson TEssig JNoggle RGallo JWhite, R1 KBarr, R2 GShear, R3 GGood, R4 C.Posiusny G.Kuzo R.Pedersen S.Klementowicz 190001

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.s Distribution Mig. Summary w/ Dated

pril 14, 1990 1

Hard Copy PUBLIC PERB R/F SMagruder JWigginton CHinson TEssig i

JNoggle RGallo 4

JWhite. R1 KBarr. R2 GShear. R3 GGood, R4 C.Poslusny i

G.Kuzo R.Pedersen S.Klementowicz l

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Nuclear Energy Institute Project No. 689 cc:

Mr. Ralph Beedle Ms. Lynnette Her.dricks. Director Senior Vice President Plant Support and Chief Nuclear Officer Nuclear Energy Institute Nuclear Energy Institute Suite 400 Suite 400 1776 l Street, NW 1776 l Street. NW Washington, DC 20006-3708 Washington. DC 20006-3708 Mr. Steven Driscol Radiation Protection INPO 700 Gallena Parkway

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Mr Alex Manon D; rector Atlanta, Georgia 30339-5957 Programs Nuclear Energy Institute Suite 400 1776 i Street. NW l

Washington, DC 20006-3708 j

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l Radiation Protection Performance Indicator: Inspection Findings Meeting 3> 30r99 List of Attendees I

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Name Oraanization Charles Hinson USNRC Steve Klementowicz USNRC Roger Pedersen USNRC Jim Wigginton USNRC Ralph Anaerson NEl Paul Genoa NEl Alice Clamp NEl William Harns PECO Kit Weaver Comed Mike Russell SCE & G F.L. Thamasson Virginia Power Wayne Carr Southern Nuclear Travis Beard Northern States Power Terry Cellmer P.G. & E Tim Chard Nebraska PP Distnct Richard Doty PP & L 1

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,- %.,;M<ul'_.A NEl 99-02 (Draft)

Apnl 1999 1

2.6

. PUBLIC RADI ATION SAFETY CORNERSTONE 2

3 RETS/ODCM RADIOLOGIC AL EFTLt ENT OcCL RRENCE 4

Purm ;

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5 To assess the performance of the radiological efiluent momtoring program.

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6 7

, Indicator Definition 8

.ladiological efnuent release occurrences that exceed the salues listed below:

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9 m/

R diological effluent releases in excess of the following(limits:)() A(uf C, Liquid Ef0uents Whole Body 1.5 mrem qtr Organ 5 mrem-qtr Gaseous E0luents Gamma Dose 5 mrads qtr Beta Dose 10 mrads'qtr Organ Doses from I-7.5 mrems'qtr 131.1-133. H-3

& Particulates 10

)

11 Note: Values are derived from the Radiological Effluent Technical Specifications (RETS) or 12 similar reporting provisions in the Offsite Dose Calculation hianual (ODChi). if applicable 13 RETS hase been mosed to the ODChi in accordance with Generic Letter 89-01.

14 15 Data Reportine Elements 16 Number of RETS<ODCN1 Radiological F pent Oc urrences each quarter involving assessed 17 dose in excess of the indicator effluen

.s 18 YM S 19 Calculation 20 Number of RETS'ODChi Radiological Ef0uent Occurrences in the previous four quarters.

21 22 Definition of Terms lc5 23 RETS'ODChi Radiologic p Occurrences are defined as those releases that exceed any 24 one of the five identified imi outlined in the abo.e table. These are the whole body and organ 25 dose limits for liquid ef0uents and the gamma dose. beta dose. and organ dose limits for gaseous 26 effluents.

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NEl 99-02 (Draft)

April 1999 1

Clarifyine Notes 2

3 Provisions on reporting occurrences involving abnormal releases and out-of-service process 4

and ef0uent radiation monitors are excluded from this performance indicator.

5 PcJw)

The RETS ODChi Radiological Ef0uent Occurrence PI imit are on a per reactor basis. The 6

7 thresholds are based on the number of occurrences per site.

8 9

Data Examnies 10 11 Ef0uent releases that count acainst the RETS ODCN1 Radiolocical Ef0uent Occurrence:

12 Liquid ef0uent releases in one quarter which total a calcu!ated dose to the public of 1.6 mrem 13 14 whole body or 5.1 mrem to any organ.

15 Gaseous effluent releases in one quarter which total a calculated ganuna air dose of 5.1 16 e

17 mrads. a beta air dose of IU.1 mrads. or a calculated organ dose from I-131,1-133 H-3, and 18 particulates of 7 6 mrems.

19 20 21 Ef0uent release occurrences that do not count acainst the RETS ODCN1 Radiolocical Ef0uent 22 Occurrence:

23 Abnormal release issues 24 25 Liquid or gaseous monitor operability issues g mk 26 e

27 g'*

Liquid or gaseous releases in excess RE,5 ODCN! concentra6on limits 28 e

29 Liquid or gaseous releases without treatment but that do not exceed values in the table 30 92

f rnu n u t w i' T RETSiODCM RADIOLOGICAL EFFLUENT OCCURRENCE QUESTIONS Are the values in the table per reactor or per site?

Are the thresholds listed per reactor or p r site?

How do you apportion effluent releases from multi-unit sites with common discharge points?

The tech spec limits on concentrations are not listed in the table-do they count?

I The tech spec limits on dose rates are not listed in the table-do they Count?

l The tech spec limit on dose without treatment systems in operation occurs, does it count?

If an unplanned release occun (valve line-up error causes the wrong j

waste gas decay tank to be released) and it exceeds the table values, does it count?

. bc n An abnormal release (not through any I[SAR described effluent discharge point) occurs and the calculation shows that the dose exceeds the table values. does it count?

5 A projected dose for a period would exceed the table values, does it count?

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3/24/99 DRAFT EXAMPLES OF THE RISK SIGNIFICANCE OF INSPECTION FINDINGS IN i

PUBLIC CORNERSTONE: TRANSPORTATION AND PART 61 ISSUES AT NUCLEAR 1

POWER PLANTS l

GREEN

( Licensee Response Band)

NRC or hcensee-identified non conformance invoNing waste shipment with surface contamination levels greater than 10 CFR Part 71 cr 49 CFR 173 dose limits.

Breach doss of containment integntyi cf Type A packqe dunng transit.

WHITE (Increased Regulatory Response Band)

NRC or licensee-identifieo rion conformance involving waste shipment with surface contamination levels greater than five times 10 CFR Part 71 or 49 CFR 173 dose limits.

NRC or licensee" cent 1f tea non-conformance involving waste shipment with external dose rates greater than 10 CFR Part 71 or 49 C.' R 173 " se hmits.

Failure to comply 'vith 10 CFR Part 71 by making waste shipment (shipment enters State boundary) without making required advance notification.

Failure to p' ovide emergency response informat on as required by 49 CFR 172.602 or r

49 CFR 172.604.

Breach of Type B or fissile shipping package during transit.

NRC or licensee identified non conformance that results in a non-conservative waste classification as required by 10 CFR Part 61.

YELLOW

( Required Regulatory Response Band)

NRC or hcensee-iderafied non-conformance involving waste shipment with surface contamination levels greater than fifty times 10 CFR Part 71 or 49 CFR 173 dose limits.

NRC or licensee-identified non-conformance involving waste shipment with external dose rates greater than five times 10 CFR Part 71 or 49 CFR 173 dose limits.

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Breach of package dunng transit resulting in a loss of control of the contents which results in a estimated dose to a member of the public greater than 10 mrem TEDE or an occupation dose greater than 200 mrem TEDE.

Low Level waste bunal ground denies Licensee access -- authonty will not accept licensee waste as result of deficiencies in transportation activities or Part 61 non-conformances.

NRC or hcenseendentified non c iformance with package's certificate of compliance j

resulting in sn:pping waste in an unanalyzed configuration (beyond the package's design basis rating).

RED

< Loss c: acntidence n HP program s abikty to provice assurance of worker safety)

NRC or hcenseeadentified non-conformance involving waste shfoment with surface contamination levels greater +han one-hundred times 10 CFR Part 71 or 49 CFR 173 dose hmits and resulting in con

• amination of the unrestricted area.

NRC or hcensecodentified non-conformance involving waste shipment with external dose rates greater than ten times 10 CFR Part 71 or 49 CFR 173 dose limits.

Breach of cackage cunng transit resulting in a loss of control of the contents which results in a cose to a member of the Dubbc greater that 25 mrem TEDE or an occupation dnse greater inan 500 mrem TEDE.

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NEl 99-02 (Draft)

April 1990 1

2.5 OCCl'PATIONAL RADI ATION SAFETY CORNERSTONE 2

The objectives of this cornerstonc are to:

3 4

(1) keep occupational dose to individual workers below the limits specified in 10 CFR 20 5

Subpart C: and 6

7 (2) use. to the extent practical. procedures and engineering controls based upon sound 8

radiation protection principles to achieve occupational doses that are as low as is 9

reasonably achies able ( ALARA) as speci6ed in 10 CFR 20.110ltb) 10 11 There is one indicator for this cornerstone:

12 Occupational Exposure Control Effectiveness 13 14 15 Occupational Esposure Control Effectis eness 16 Purpose 17 The purpose of this performance indicator is to address the first objective of the occupational 18 radiation safety cornerstone. The indicator monitors the control of access to and work activities 19 within radiologically-significant areas of the plant and occurrences involving degradation or 20 failure of radiation safety barriers that resu!r in readily-identitiable unintended dose.

21 22 The indicator includes dose-rate and dose criteria that are risk-informed. in that the indicator 23 encompc.sses events that might represent a substantial potential for exposure in excess of 24 regulatory limits. The perfonnance indicator also is considered " leading" because the indicator:

25 encompasses less-significant occunences that represent precursors to events that might 26 27 represent a substantial potential for exposure in excess of regulatorv limits, based on industry 28 experience; and 29 employs dose criteria that are set at small fractions of applicable dose limits (e.g.. the criteria 30 31 are generally at or below the levels at which dose monitoring is required in regulation).

32 33 Indicator Dennition 34 35 The performance indicator for this cornerstone is the sum of the following:

36 Technical speci0 cation high radiation areas occurrences 37 Very high radiation area occurrences 38 Unintended exposure occurrences 39 40

(

5 41 Data Reporting Elements:

86

1

.1 NEl 99-02 (Drafu Apnl 1999 1

2 The following data are reported for each site:

3 The number of technical specitication high radiation area occurrences during the 4

5 previous quarter 6

The number of sery high radiation area occurrences during the previous quarter e

7 The number of unintended exposure occurrences during the previous quarter 8

9 Calculation:

10 11 The indicator is detenmned by summing the reponed number of occurences for each of the three 12 data elements during the previous 12 quarters.

13 14 Definition of Terms:

15 16 Technical Speci6 canon Hieh Radianon.4rca Occurrence - A nonconfom,ance (or concurrent 17 nonconfomiances) with technical speci6 cations tordicensee procedures if the technical 18 specitications do not include provisions for high radiation areast of comparable requirements in 19 10 CFR 20 applicable to technical speci6 cation high radiation areas that results in the loss of 20 radiological control os er access to or work activities within the respective high-radiation area.

21

" Technical speci6 cation high radiation areas" includes any area, accessible to individuals,in 22 which radiation levels from radiation sources extemal to the body could result in an individual 23 receiving a dose equivalent in excess of 1 rem (10 mS- )in I hour at 30 centimeters from the 24 radiation source or 30 centimeters from any surface that the radiation penetrates, and excludes 25 very high radiation areas.

26

" Radiological control er access to technical speci6 cation high radiation areas" refers to 27 e

28 measures that provide assurance that inads ertent entry into the technical speci6 cation high 29 radiation areas by unauthorized personnel wil! ' e prevented.

30 31

" Radiological control os er work activities" refers to measures that provide assurance that 32 dose to workers performing tasks in the area is monitored and controlled.

33 34 Examples of occurrences that would be counted against this indicator include a failure to secure 35 an area against unauthorized access, a failure to provide a means of personnel dose monitoring or 36 control required by technical speci6 cations, or an actual unauthorized or unmonitored entry into 37 an area.

38 39 l' err High Radiarion.4rca Occurrence - A nonconformance (or concurrent nonconformances) 40 with 10 CFR 20 andfor licensee procedural requirements that results in the loss of radiological 41 control over access to or work activities within a very high radiation area. "Very high radiation 42 area" is de6ned as any area the respective high-radiation area, accessible to individuais, in which 43 radiation levels from radiation sources extemal to the body could result in an individual receiving r

~

NEl 99-02 (Draft)

Apnl 1999 1

an absorbed dose in excess of 500 rads (5 grays)in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at I meter from a radiation source or 1 2

meter from any surface that the radiation penetrates 3

" Radiological control over access to very high radiation areas" refers to measures to ensure 4

e 5

that an individual is not able to gain unauthorized or inadsertent access to very high radiation 6

areas.

7

" Radiological control over work activities" refers to measures that provide assurance that 8

+

9 dose to workers perforrr.ine tasks in the area is monitored and controlled.

10 11 Unimended Exposure Occurrence - A single occurrence of the degradation or failure of one or 12 more radiation safety barriers resulting in unintc'ded occupational exposure (s) equal to or 13 exceeding any of the following dose criteria from a single occurrence:

14 2 o of the stochastic limit in 10 CFR 20.1201 on total effectise dose equivalent. The 2?b 15 e

16 value is 0.1 rem.

17 18 10 oo of the non-stochastic limits in 10 CFR 20.1201. The 109o values are as follows:

19 5 rem the sum of the deep-dose equivalent and the committed dose equivalent to any individual organ or tissue i

1.5 rem the lens dose equisalent to the lens of the ese 5 rem the shallow-dose equivalent to the skin or any extremity, other than dose receised from a discrete radioactive particle 20 209 of the limits in 10 CFR 20.1207 and 20.1208 on minors and declared pregnant women.

21 e

22 The 20?o value is 0.1 rem.

23 100 o of the limit on shallow-dose equivalent from a discrete radioactive particle; The value 24 e

25 is 50 rem.51 26 27 The dose criteria are established at levels deemed to be readily identifiable, based on industry 28 experience. The dose criteria should not be taken to represent levels of dose that are " risk-29 significant." In fact, the criteria are generally at or below dose levels that are required by 30 regulation to be monitored or to be routinely reported to the NRC as occupational dose record 31 I

i 5 The NRC is currently proceeding with rulemaking to propose a 500 rem limit on shallow-dose equivalent from a discrete radioactive particle. At the time a final rule is issued the performance indicator s alue will be revised to continue J

to reflect "1009b of the established regulatory limit."

88

NEl 99-02 (Draft)

Apnl 1099 1

Examples of" degradation or failure of radiation bamers" that could potentially count against this 2

indicator include the following (i.e., if the degradation or failure directly results in unintended l

3 dose equal to or greater than the respectis e criteria):

4 failure to identify and post a radiological area l

5 e

failure to implement required phy sical controls os er access to a radiological area 6

e 7

e failure to survey and identify radiological conditions failure to train or instruct workers on radiological conditions and radiological work controls 8

e 9

e failure to implement radiological work controls (e.g.. as part of a radiation work permit) 10 11 Clarifvine Notes:

12 13 Occurrences that potentially meet the definition of more than one element of the performance 14 indicator will only be counted once. In other words. an occurrence will not be double counted 15 (or triple-cc,untedi against the performance indicator.

16 1

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p i n ] ~;2-9 Tech Spec HRAs (>1000 mrem /hr) and VHRAs General Principles

1. Tech Spec liR.\\- P1000 mrem /hr) l j

.\\. iYe.-> Unaut horized acce,- occur- <e.e.. individual not authorized for acces3 or preregt!!31te-to acce.- regtllred by TS or Part 20 not fulfilled).

N. lyes).-\\rea fintild Linsecurt'd (ir 1101 -ufficient to prevent Inadvertent acet'4-) and tinguarded.

C tYes) Controlled key issued to unauthorized personnel or determined to he 1111.-3111R (with area access.-tat ti-not :ibh to be determined).

It Go.\\lonitoring or dose control measures required by TS or Part 20 not unplemented in conjunction with access or work within the area.

E iNm.\\ctual do-e rates les-t han 1000 mrem / hour F 30 cm.

F iNio.\\rea phy-icallv secured or cuarded against inadvertent access by U11aut hiirized per.-onnel iir recardine access cont rol i3 sues).

tl. INot Controlled key leinporarlly misplaced (with determination able to be Illade that area was not or would not reasonably have been expected to be accessed).

11, 8 Sol.\\Inllitoring alid do-e control men-ure required by TS or Part 20 unplemented m conjunction with acce.<s or work within the area.

1. iNo) Prerequisites to access required by TS or Part 20 fulfilled.

J. (No).\\ctions in rerponse to changes in radiation levels taken in accordance with procedures and training (for situations involving areas with transient radiolouical conditions).

K. <No) Workers trained and instructed on radiological conditions in accordance with HWP. procedures and programs (with regard to knowledge of workers of radiological conditions).

1. (No) Non compliance witn procedural or RWP requirements that are in addition to what i-required by TS or Part 20.

.\\l. (No) Helated similar occurrences found in conjunction with follow-up investigation O[111itial occurrence.

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2. VHRAs

~d. (Yes) Phy ical barrier, <>r -eeuritv ineasure ilot ade<iu.ite i.> prevent unauthorized or inadvertent acce-.

O. (Yes) Iletjulred po'tInc not in p}. lee C. (Yes) Preret{ul-Ite.- for acee-3 retjulred hy Part 20 or })rocedures not fulfilled.

D. (Ye.4).\\lonitoring and dose control mea ures required by Part 20 and

})rocedures not Inip}emented for access or work within the area.

E. (Yes) Worker not knowledgeable of radiation levels within the VHRA.

F. (Yes) Controlled key issued to unauthorized personnel or determined to be missing.

G. (No) Act ual do.-e rat e-le,. t han 310 rads / hour # 1 meter.

3. Unintended Dore

d. (YUM Degradation or inlure ofinne or Inore barrier * (3.- described in the PI) and unintended dose m excess of the criteria in the Pl.

IL (No) No failure of a barrier ta-dercribed in the PI).

C (No) Unintended do-e does is lew than the criteria in the PI.

D. Unintended do-e to more than one individual resulting from a single occurrence of degradatmn or failure of one or more barriers shall be Counted as a single occurrence.

E. The " unintended dore" shall be determined based on the indicated value resulting from the active dose monitoring / control method (e.g.,

electronic or relf-readine dosimeter. remote monitoring. or timekeeping) as compared with the planned dose or e.stablished dose control value established for the individual worker (s).

F Dose goals and do-e e-timates are not within the scope of this Pl.

F s

1. Routine checking of doors / barriers results in a door that " pops open:

a) locking mechanism found defective b) door not secured from previous accer, C) locking mecham-m defeated xg.. taped, veri l

2. Sign and/or rope found down for nusingt but area is recured again-t inadvertent entry.

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3. Area with Gashing lights and barricade:

a) Da.shing light found inoperable (e.g. burnt out liciu). but posting and barricade in place b) posting and/or barricade found not in place

4. Dose rates in area greater than indicated ie.e..

a RWP or posting):

a) [ouild as part of-urvelllance by HP

{

h) determined dlirillg course of access Work activitie- (e.g.. a-a result of alarnung donimeter or unmtended do-o re-ult).

5. Area inot po.-ted and cont rolled a-a TS HItA) wah transient dose rates found to I

be equal to or greater than 1000 mrem / hour J 30 cm:

al found a.- re-ult of surveys in conjunction with planned evolution or ope ra t io n.

hl found a-re-ult of.-urveys folk) wing transient condition c) found during routme -urveys (i.e. unanticipated finding) d) found by means ot her t han survey. e.g.. worker ED alarm.

6. Worker properly trained and instructed -however does not correctly respond to question on rad conditions or controls.

7. Individual signs in on " wrong" RWP and acceses area.

8. Non compliance wah additional procedural or RWP regturements for access or work in an area that are beyond those in TS or Part 20.

9. ED fails or malfunctions during acceu or work in area.

10. Door fails to lock as indicated by remote monitoring mean. such as indication in control room or alarm.

11. Worker becomes " locked in" area.

12. Keys -(a) left on stepoff pad, while mdividual frisks. 0 ) key left in PCs (retrieved by individual or discovered in laundry and returned). C key found missing during inventory. (d) key inued to unauthorized individual. (e) uncontrolled key determined to be able to ui lock area doorto.

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ACCESS CONTROL. P1 EXANIPLES 1.

Worker unable to exit a llRA. N1ust tlag down someone outside the llRA to open door.

Total dose for the entry was 50 mrem. Ilow about ifit resulted in an excess 100 mrem?

1 Area of the plant that hi< dose rates in excess of one rem hr. at 30 cm is controlled by eacooning in chain-link fencing. Worker cuts through the fencing and gains access without authon/ation resuhing in a siolation of I ech. Specs. and llRA posting requirements.

3.

Indisidual enters a locked ilRA. RWP specifies the maximum Jose rate in the area is 150 mrem hr. but not close to his intended work site. Indisidual has a hand held sursey meter as specified by l ech. Specs. But nes er turns it on. Ilow about if he turns it on but doesn't find a 500 mrem hr. < a 30cm.) hotspot in his job site? 5 rem'br. hotspot?

IIP tech. In possession of a llRA key they were assi ned last outage (several months ago) g 4.

when they suren ised a control point at the llRA. A check of the key inventory indicates the key in question is considered lost and has t,een replaced.

5 A IIP Foreman at a P\\\\ R that has been permanently assigned a master key to llRAs by the RP.\\l. gis es it to a llP tech and tells him to unlock and enter the reactor cavity to serify temporary lighting has been in3talled. Doesn't know the thimbles were withdrawn from the core.

Digital alanning dosimeter t DADi issued a worker entering a llRA per Tech. Specs.

6.

Ilowever. DAD only has audible alarm that could.would not be heard because of high backgrounJ noise or other hearing obstructions.

7.

The self-elosing (suingingi barricade access to a llRA (less than 1000 mrem /hr) sticks and does not close after someone exits the area. Found by IIP tech. later. Repeated history of this problem?

8.

Activated components stored in the Spent Fuel Pool by hardng them on lines are controlled by a locked cos er where the lines are tied off. Cover for the line of a component that reads greater than 500 rad at a meter is found unlocked but no indication that ansone has tried to pull hanger since last authorized access.

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. n Failure to sign RWP, as required by plant procedures. Plant has " standard", vintage 1.

8.38 style STS for HRAs.

NRC finds HRA door locked with chain, but door has sufficient gap for worker to reach 2.

in and unlock door witnout a key.

Locked Access door to VHRA (with fuel movement in progress) stands 6 feet, with 5-3.

foot gap f rom door top to concrete overhead.

Licensee discovers in the overhead. dose rates of > 1000 mR/h at 30 4.

been posted as a HRA, <1000mR,h.

fr spector discovers no one at !he drywell Control point, dunng a forced outage ', Work 5.

only in drywell). After a couple of r,1:nutes, the HPT #1 exits the drywell after taking the routine tour survey. Work in ongoing inside the drywell and the HPT #2 (normally at the control point desk near the drywell entrance was not present.

Inside the drywet. a multi-elevation level HRA greater than 1000mR/h was posted and had 3 accessible entrances. One flashing red light was used as a warning device, as 6.

required by STS The light coldd only oe seen from two of the entry points.

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1 DRAFT EXAMPLES OF THE RISK SIGNIFICANCE OF INSPECTION FINDINGS IN OCCUPATIONA.L EXPOSURE CORNERSTONE (3/29/99) l GREEN l

l (Licensee Response Band)

NRC or hcensee-identified nc' conformance that resulted in an ur: planned occupational exposure less than 10 CFR Part 20 dose limits, with no substantial potential for overexposure.

NRC or licensee-identified non-conformance involving personal dosimetry or surveying that does not comoromise the hcensee's abikty to assess dose.

l WHITE (locreased Regulatory Response Band)

NRC or hcensee-identified finding that resulted in a substantial potential for an occupational exocsure greater than 10 CFR Pa-t 20 dose hmits.

Fadure to make the notification of incidents which are required by 10 CFR Part 20 2202to!.

Any cond< tion trat comorcmises the hcensee's abnity to assess occupational dose.

YELLOW (Required Regulatory Response Band)

NRC or hcensee-identified finding that resulted in a substantial potential for an occupational exposure greater than 5 rem deep dose equivalent (DDE) while working in an area with external exposure rates greater than 25 R'h.

l NRC or hcenseendentified non-conformance that resulted in an occupational TEDE in excess of 5 rem, or greater than 10 CFR Part 20 dose limits.

Failure to make the immed: ate notification of incidents which are required by 10 CFR Part 20.2202(a).

RED (Loss of confidence ;n HP program's abihty to prcvide assurance of worker safety)

NRC or hcensee identified non-conformance that resulted in an occupational TEDE in excess of 25 rem, or greater than five times 10 CFR Part 20 dose limits.

NRC or hcensee-ident.fied finding that resulted in a substantial potential for an occupational exposure greater than 5 rem DDE while working in an area with external exposure rates greater tnan 500 Rads h at one meter.

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