Regulatory Guide 8.38

(Draft Was Issued as DG-8006), Control of Access to High and Very High Radiation Areas in Nuclear Power Plants

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Issue date:	06/30/1993
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U.S. NUCLEAR REGULATORY

COMMISSION

June 1993) REGULATORY

GUIDE OFFICE OF NUCLEAR REGULATORY

RESEARCH REGULATORY

GUIDE 8.38 (Draft was issued as DG-8006) CONTROL OF ACCESS TO HIGH AND VERY HIGH RADIATION

AREAS IN NUCLEAR POWER PLANTS

A. INTRODUCTION

Section 20.1101, "Radiation Protection Pro grams," of 10 CFR Part 20, "Standards for Protection Against Radiation," requires licensees to develop and implement a radiation protection program appropriate to the scope of licensed activities and potential haz ards. Section 20.2102 requires licensees to document these programs.

An important aspect of a radiation protection program at nuclear power plants. is the in stitution of a system of controls that includes proce dures, training, audits, and physical barriers to pro tect workers against unplanned exposures in high and very high radiation areas. Specific requirements appli cable to controlling access to high radiation areas are in 10 CFR 20.1601, and additional requirements to prevent unauthorized entry into very high radiation areas are in 10 CFR 20.1602. This regulatory guide describes methods acceptable to the NRC staff for im plementing these requirements.

Underwater divers are being used more often for inspections and maintenance in reactor cavities and spent fuel pools. These underwater operations require careful planning, proper work methods, and specific procedures because of the potential for significant overexposures from irradiated fuel elements and irra diated reactor components and structures that act as high-level radiation source

s. USNRC REGULATORY

GUIDES Regulatory Guides are issued to describe and make available to the pub lic such information as methods acceptable to the NRC staff for Imple menting specific parts of the Commission's regulations, techniques used by the staff in evaluating specific problems or postulated acci dents, and data needed by the NRC staff in its review of applications for permits and licenses.

Regulatory Guides are not substitutes for regula tions, and compliance with them Is not required, Methods and solutions different from those set out in the guides will be acceptable if they pro vide a basis for the findings requisite to the issuance or continuance of a permit or license by the Commission.

This guide was Issued after consideration of comments received from the public. Comments and suggestions for Improvements in these guides are encouraged at all times, and guides will be revised, as ap propriate, to accommodate comments and to reflect new Information or experience.

Appendix A to this guide contains procedures for good operating practices for underwater divers that are recommended for licensees.

These practices have evolved, in part, from instances in which propez con trols were not in place or were not implemented.

Ap pendix B summarizes past experiences with very high and potentially very high radiation areas so that his torical, yet pertinent, information is readily accessible to users, especially to newer personnel.

Any information collection activities mentioned in this regulatory guide are contained as requirements in 10 CFR Part 20, which provides the regulatory ba sis for this guide. The information collection require ments in 10 CFR Part 20 have been approved by the Office of Management and Budget, Approval No. 3150-0014.

B. DISCUSSION

Requirements intended to prevent inadvertent, unwarranted, and potentially dangerous overexpo sures of individuals at facilities licensed by the NRC are provided in 10 CFR 20.1601 and 20.1602. A framework of graded radiation protection procedures is recommended in this guide to ensure that the con trols for access to high and very high radiation areas at nuclear power plants are appropriate to the radia tion hazard during both normal operations and ab normal operational occurrences.

Dose rates in areas of nuclear power plants acces sible to individuals can vary over several orders of Written comments may be submitted to the Regulatory Publications Branch, DFIPS, ADM, U.S. Nuclear Regulatory Commission, Washing ton, DC 20555. The guides are Issued in the following ten broad divisions:

1. Power Reactors 6, Products 2. Research and Test Reactors

7. Transportation

3. Fuels and Materials Facilities

8. Occupational Health 4. Environmental and Siting 9, Antitrust and Financial Review S. Materials and Plant Protection

10. General Copies of issued guides may be purchased from the Government Printing Office at the current GPO price. Information on current GPO prices may be obtained by contacting the Superintendent of Documents, US. Government Printing Office, Post Office Box 37082, Washington, DC 20013-7082, telephone

(202)512-2249 or (202)512-2171.

Issued guides may also be purchased from the National Technical Infor mation Service on a standing order basis. Details on this service may be obtained by writing NTIS, 5285 Port Royal Road, Springfield, VA 22161.

magnitude.

High radiation areas, where personnel can receive doses in excess of the regulatory limits in a relatively short time, require special controls.

Very high radiation areas require much stricter monitoring and controls since failure to adequately implement ef fective radiological controls can result in radiation doses that result in a significant health risk. For the purpose of this guide, a high radiation area is defined as an area, accessible to individuals, in which radiation levels could result in an individual receiving a deep dose equivalent in excess of 0.1 rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radia tion source or from any surface that the radiation penetrates.

A very high radiation area means an area, accessible to individuals, in which radiation lev els could result in an individual receiving 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 1 meter from a radiation source or from any surface that the radiation penetrates.

An accessible area is defined as one that can reasonably be occupied by a major portion of an individual's whole body, which is defined in 10 CFR 20.1003.

C. REGULATORY

POSITION 1. PROGRAM ELEMENTS Licensees are required by 10 CFR 20.1101 to de velop and implement a radiation protection program appropriate to the potential radiation hazards in their facility.

Because of the potential for overexposure in high and very high radiation areas, it is important that licensees have effective programs for controlling ac cess to these areas. There have been instances of per sonnel inadvertently entering these areas because of inadequate controls on access. The following elements should be included in the plant procedures and practices for access control to be sure that personnel are protected in high and very high radiation areas. 1.1 Management Control Facility management has the responsibility for de veloping, implementing, and enforcing access control procedures for high and very high radiation areas. 1.2 Procedural Controls 1.2.1 Access control procedures for high and very high radiation areas should address at least the following areas: 1. Job planning, 2. Radiation protection coverage, 3. Survey techniques and frequencies, 4. Training of workers, 5. Prework briefing, 6. Frequency for updating radiation work per mits (RWPs) or their equivalent, and 7. Placement of measuring and alarming do simeters.

1.2.2 Administrative procedures should address the management oversight and specific control meas ures needed for entry into high and very high radia tion areas. The procedures should include the process for gaining entry to these areas, such as the control and distribution of keys. 1.2.3 Procedures for activities that can greatly in crease in-plant radiation levels (i.e., the withdrawal of in-core detectors, thimble tubes, or transversing in core probes from the reactor) should provide for noti fication of personnel likely to authorize or have ac cess to affected areas. 1.2.4 Procedures should provide for timely sur veys to identify and post with precautionary notices the areas and systems that may become high or very high radiation areas, especially when in-plant changes (e.g., spent fuel transfer operations)

could alter the ambient radiation levels. 1.2.5 Procedures should be provided to verify, at least on a weekly basis, that proper controls such as posting and barriers are in place for restricting access to high and very high radiation areas. 1.3 Training The types of controls required for entry into high and very high radiation areas should be included in training for radiation workers (both initial and re qualification training).

Areas in the plant that are known to have the potential for becoming very high radiation areas should be specifically identified.

1.4 Communications Good communication is essential among all de partments concerned with entry into high and very high radiation areas to prevent excessive and unwar ranted radiation exposures.

This communication is especially important among personnel in known po tential or existing very high radiation areas, such as reactor cavities, spent-fuel transfer areas, spent-fuel pools, and other reactor components and tanks. The access control program should include procedures and provisions for the use of equipment to ensure adequate communication.

The group or department responsible for radiation protection should be notified prior to any entry into a very high radiation area. 1.5 Physical Controls Physical barriers (such as chain-link fencing or fabricated walls) may be used to prevent unauthor ized personnel access to high and very high radiation areas. Physical barriers surrounding high radiation ar eas should be sufficient to prevent inadvertent entry (e.g., a 2-meter [6-foot] fence, with worker training 8.38-2 and signs or procedures to deter climbing, may be adequate for controlling access to a high radiation area). Physical barriers should, to the extent practica ble, completely enclose very high radiation areas suf ficient to thwart 1 undetected circumvention of the barrier (i.e., fencing around very high radiation areas should extend to the overhead and preclude anyone from climbing over the fencing).

Entrances or access points to these areas should be controlled, as de scribed in Regulatory Positions

2 through 4. Physical controls should be established that do not preclude personnel access to these areas when access is re quired to respond to emergencies.

Implicit in the definition of an entrance or access point to a high radiation area is that the opening (or portal) itself is accessible to personnel.

Openings in physical barriers around a high radiation area are not required to be controlled as entrances if exceptional measures are needed to access them. Examples of ar eas that do not need to be controlled as entrances are the manway to a tank or vessel that has its cover bolted in place or an opening in a shield wall that is physically difficult to access without a ladder or mo bile platform.

An acceptable method of excluding personnel from areas with dose rates greater than 1 mSv (100 mrem) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is to provide a substantial physical barrier (e.g., chain-link fencing) that completely en closes the area and has no openings or portals. This type of control is commonly called cocooning.

Since these areas are not accessible, the control of access and posting requirements in 10 CFR Part 20 for high and very high radiation areas do not apply. However, the requirements in 10 CFR Part 19 to instruct the worker on the radiological hazards in these areas are applicable.

Note: When an inaccessible portal to a high ra diation area is made accessible (e.g., a manway cover is removed or scaffolding is erected) or when a portal is created in a physical barrier (i.e., a cocoon is breached), the applicable controls for a high or very high radiation area must be provided.

Controls must be established that prevent person nel from being locked in a high radiation area (10 CFR 20.1601(d)).

For example, if chains and pad locks are used, the procedural controls must prevent the area from being locked with personnel in the area. If doors are self-locking, personnel must be able to open them from the inside without a key (10 CFR 20.1601(d)).

1.6 Shielding Shielding may be used to make a high or very high radiation area, or a potentially very high radia 1 Determined circumvention of a physical barrier, with wire cutters or other tools, cannot be prevented absolutely.

Such instances should be addressed with appropriate disciplinary action.tion area, inaccessible.

The following guidelines apply to shielding used for the purpose of controlling ac cess. 1. The shielding should not be readily removable.

Blankets, bricks, or other portable shielding that could be moved by hand would be readily remov able; however, shielding requiring a hoist or crane to move would not be considered readily removable.

2. If the shielding is removable, it should be posted with a warning sign such as: "Warning, do not remove. Dangerous radiation levels may result." 3. If the shielding is removable, local radiation monitors with audible and visible alarms should be installed to warn personnel of the high expo sure rates created by removal of the shielding.

2. HIGH RADIATION

AREAS 2.1 Options for Access Control Of the options for access control provided in 10 CFR 2 0.1601(a), the most widely used procedure at nuclear power plants is keeping high radiation areas locked. Although licensees have the option to control high radiation areas with the use of a control device to reduce radiation levels when an individual enters the area or the use of an alarm to alert the individual and the supervisor to an entry into a high radiation area, experience has shown that these options have limited practical application at nuclear power plants. In addition to the provisions of 10 CFR 2 0.1601(a), a nuclear power plant licensee may apply for Commis sion approval of alternative methods for control un der 10 CFR 2 0.1601(c).

See Regulatory Position 2.4 below. 2.2 Positive Access Control Positive control over each individual entry is re quired by 10 CFR 20.1601(a)

(3) when access is re quired to a high radiation area that is normally con trolled by being locked. In a large facility such as a nuclear power plant, appropriate positive access con trols can be instituted through the use of radiation work permits (RWPs) or an equivalent program. Such a system ensures appropriate supervision through spe cific procedures that establish requirements for con trol and delegate responsibility to qualified individu als. Procedures for establishing positive control over each entry should provide for: 1. Surveys that identify the radiation hazards in the area should be made and the results docu mented; 2. An appropriate level of supervision to determine that exposure of the individual to the hazards is warranted;

8.38-3

3. Communication of the nature and extent of the radiation hazards to each individual entering the area; 4. Protective measures (e.g., shielding, time limits, protective clothing, monitoring)

to protect the in dividual from excessive or unnecessary radiation exposure;

and 5. Permission for only authorized individuals to en ter the high radiation area with all entries and exits documented.

2.3 Direct or Electronic Surveillance Direct or electronic surveillance is identified in 10 CFR 20.1601(b)

as a substitute for the controls required in 10 CFR 20.1601(a).

The direct or elec tronic surveillance should have the following capabili ties as a minimum.

1. Detect attempted unauthorized entry, 2. Warn individuals that their attempted entry is un authorized, and 3. Alert the proper authority about an unauthorized entry so that action can be taken to correct the situation.

2.4 Alternative Methods for Access Control The requirements in 10 CFR 20.1601(a)

for ac cess to high radiation areas may, in some instances, cause unnecessary restrictions on plant operations.

According to 10 CFR 20.1601(c), licensees may ap ply to the Commission for approval to use alternative methods for control. The following method is accept able to the NRC staff as an alternative to the require ments in 10 CFR 20.1601(a)

for the control of access to high radiation areas. Each high radiation area as defined in 10 CFR Part 20 should be barricaded

2 and conspicuously posted as a high radiation area, and entrance thereto should be controlled by requiring issuance of a radia tion work permit (RWP) or equivalent.

Individuals trained and qualified in radiation protection proced ures (e.g., a health physics technician)

or personnel continuously escorted by such individuals may be ex empted from this RWP requirement while performing their assigned duties in high radiation areas where ra diation doses could be received that are equal to or less than 0.01 Sv (1.0 rem) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (measured at 30 centimeters from any source of radiation)

pro vided they are otherwise following plant radiation pro tection procedures, or a general radiation protection RWP, for entry into such high radiation areas. Any individual or group of individuals permitted to enter 2 A barricade can be a rope, ribbon, or other firmly secured, conspicuous obstacle that (by itself or used with physical bar riers such as existing walls or hand railings)

completely sur rounds the area and obstructs inadvertent entry.such areas should be provided with or accompanied by one or more of the following:

"* A radiation monitoring device that continuously indicates the radiation dose rate in the area, " A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received.

Entry into such areas with this monitoring device may be made after the dose rates in the area have been determined and personnel have been made knowledgeable of them, " An individual qualified in radiation protection procedures with a radiation dose rate monitoring device. This individual is responsible for provid ing positive radiation protection control over the activities within the area and should perform pe riodic radiation surveillance at the frequency specified in the radiation protection procedures or the applicable RWP. In addition, areas that are accessible to personnel and that have radiation levels greater than 0.01 Sv (1.0 rem) (but less than 500 rads at 1 meter) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 cm from the radiation source, or from any surface penetrated by the radiation, should be pro vided with locked doors to prevent unauthorized en try, and the keys should be maintained under the ad ministrative control of the shift supervisor on duty or health physics supervisor.

Doors should remain locked except during periods of access by personnel under an approved RWP that specifies the dose rates in the immediate work areas and the maximum allow able stay time for individuals in that area. In lieu of a stay time specification on the RWP, direct or remote continuous surveillance (such as closed circuit TV cameras) may be made by personnel qualified in ra diation protection procedures to provide positive ex posure control over the activities being performed within the area. Individual high radiation areas that are accessible to personnel, that could result in radiation doses greater than 0.01 Sv (1.0 rem) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and that are within large areas where no enclosure exists to enable locking and where no enclosure can be rea sonably constructed around the individual area should be barricaded and conspicuously posted. A flashing light should be activated as a warning device whenever the dose rate in such an area exceeds or is expected to exceed 0.01 Sv (1.0 rem) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 cm from the radiation source or from any surface penetrated by the radiation.

2.5 Controls for High Radiation Areas (Control Points and Barriers)

Controls (e.g., locked doors, access control, and posting) for high radiation areas may be established at locations beyond the immediate boundaries of the high radiation areas to take advantage of natural or existing barriers.

The use of one locked door, or one 8.38-4 control point where positive control over personnel entry is exercised, to establish control over multiple high radiation areas is acceptable provided the follow ing conditions are met: 1. The individual high radiation areas are barri caded and posted separately to identify the actual areas of concern, 3 2. Control points are established sufficiently close to the high radiation areas that adequate supervision of access to the areas can be assured, and 3. The required protective measures and other re quirements for entering the high radiation areas (e.g., dosimetry, monitoring)

are enforced at the control point.4 2.6 Control of Keys The shift supervisor or the radiation protection manager (or their respective designees)

should ad ministratively control the issuance of keys to person nel requiring access to high radiation areas and the return of the keys.

3. VERY HIGH RADIATION

AREAS Because of the potential danger of life-threaten ing overexposures to individuals, extremely tight con trol must be maintained over any entry to very high radiation areas. According to 10 CFR 20.1602, licen sees must institute additional measures to ensure that an individual is not able to gain unauthorized or inad vertent access to very high radiation areas. To the ex tent possible, entry should be forbidden unless there is a sound operational or safety reason for entering.

Special consideration should be given to areas that become very high radiation areas when the plant changes operational modes, such as shutdowns or startups.

3.1 Entrances Entrances to very high radiation areas should be kept locked except during periods when access to the areas is required (see 10 CFR 20.1601(a)(3)).

Post ing of very high radiation areas is required by 10 CFR 20.1902.

Multiple very high radiation areas may be con trolled with one locked entrance to take advantage of natural or existing barriers.

For example, several very 3 Relatively small areas with several discrete high radiation ar eas (i.e., near several valves or components)

do not require separate barricades and posting for each if the whole room (or area) is considered a high radiation area. 4 Protective measures for access to an area not posted and bar ricaded as a high radiation area, but which is within a room or area controlled as a high radiation area, may be relaxed commensurate with the radiological hazards existing in the area.high radiation areas inside the containment, with the reactor at power, may be controlled by locking the containment access port. However, each very high ra diation area within these areas should also be con spicuously posted and barricaded separately.

Controls for personnel access to very high radiation areas should be established at the locked entrance.

Authorized entries to very high radiation areas may be monitored by continuous direct electronic surveillance.

Unauthorized entries to very high radia tion areas inside a PWR containment at power can be controlled by locking containment access. However, during authorized entry of the containment at power, electronic surveillance is an acceptable method to en sure that unauthorized entries do not occur into posted and barricaded very high radiation areas within the containment.

3.2 Control of Keys The following procedures should govern the ad ministrative control of keys to very high radiation ar eas. 1. Procedures should be established so that (1) there are stricter requirements for issuance of keys to very high radiation areas than keys to high radiation areas, and (2) the responsible op erations and radiation protection supervisors are notified prior to personnel entry to very high or potentially very high radiation areas. 2. A key for access to a very high radiation area should unlock only that area. Master keys that unlock more than one area may be established for use during emergency situations provided their distribution is limited and they are not used for normal personnel access. 3.3 Radiation Work Permits Entries to very high radiation areas should be controlled by issuance of a specific RWP or equiva lent. General, standing, or blanket RWPs should not be used for controlling entries to very high radiation areas. 3.4 Radiation Protection Technician A person entering a very high radiation area should be accompanied to the entryway to that area by a radiation protection technician who can deter mine the radiation exposure conditions at the time of entry and render assistance if necessary.

4. SPECIAL AREAS Special hazards may arise in areas that usually are not very hazardous but have the potential to be come very high radiation areas during certain normal plant operations.

For example, a PWR reactor cavity sump can change from a radiation area to a very high 8.38-5 radiation area as a result of withdrawal of the retract able incore detector thimble tubes (see Appendix B). 4.1 Administrative Procedures Administrative procedures should be established to identify these "special" plant areas and ensure that appropriate control measures for potentially very high radiation areas are implemented prior to starting any operation that could create very high radiation areas. 4.2 Materials Because of high radioactivity levels from activa tion and contamination, materials in the spent fuel pools, reactor vessel, and refueling cavities could cre ate a very high radiation area when unshielded.

These materials are normally covered with more than 10 feet of water and are inaccessible to personnel per forming duties above the pool surface. Therefore, these pool areas do not have to be controlled as high or very high radiation areas solely because of the ma terials in them provided that: 1. Control measures are implemented to ensure that activated materials are not inadvertently raised above or brought near the surface of the pool water, 2. All drain line attachments, system interconnec tions, and valve lineups are properly reviewed to prevent accidental drainage of the water, and 3. Controls for preventing accidental water loss and drops in water levels that may create high and very high radiation areas are incorporated into plant procedures.

4.3 Procedures Written procedures for any diving operations into pools, tanks, or cavities, or for access to plant compo nents that contain or may contain highly radioactive materials, should be established to ensure proper ra diological controls.

Appendix A discusses some radio logical considerations for conducting diving opera tions that should be incorporated into the plant pro cedures for diving operations.

4.4 Potential Very High Radiation Areas Areas of the plant that are known to have a high potential for becoming very high radiation areas dur ing certain operational occurrences should be con trolled to provide for ready evacuation of the area. An example would be the upper drywell in a BWR if an activated fuel bundle is dropped during fuel han dling.

D. IMPLEMENTATION

The purpose of this section is to provide informa tion to applicants and licensees regarding the NRC staff's plans for using this regulatory guide. Except in those cases in which the applicant or licensee proposes an acceptable alternative method for complying with specified portions of the Commis sion's regulations, the methods described in this guide will be used in the evaluation of compliance with 10 CFR Part 20 on control of access to high and very high radiation areas in nuclear power plants.8.38-6 APPENDIX A PROCEDURES

FOR DIVING OPERATIONS

IN HIGH AND VERY HIGH RADIATION

AREAS 1. A special radiation work permit (RWP), or equivalent, containing detailed requirements for the work should be written.

2. Continuous observation of diving operations should be provided by qualified radiation protec tion (RP) personnel that have stop-work author ity. Clear management guidance on when to exer cise this control function should be included in radiation protection and diving procedures (see additional discussion on diving in Appendix B). 3. The location of the fuel assemblies and other ir radiated objects that produce dose rates greater than 0.01 Sv (1 rem) per hour at their surface should be documented, and the location of these items should be made known to the divers. 4. Radiation surveys of diving areas should be con ducted before all diving operations.

Those prework surveys should be conducted using two independent radiation survey instruments.

Conf irmatory surveys of the work area may be per formed by the diver if the diver is properly trained to perform such surveys. If irradiated fuel or other highly radioactive objects are moved, an underwater survey should be conducted before any diving operations resume. A survey map of the diving area should be prepared and updated to reflect the current status. 5. When practical, physical barriers should be pro vided to prevent divers access to irradiated fuel elements and other high radiation items or areas. Each diver should be equipped with a safety line and continuous voice communication with sur face personnel.

Emergency procedures for diver rescue should be provided and understood by everyone involved in the diving operation.

6. Divers should be equipped with a calibrated do simeter that will function and provide an alarm underwater.

This dosimeter should be checked for operability each day before diving operations begin. Each diver should also be equipped with a remote-readout radiation detector that is continu ously monitored by RP personnel.

A-1 APPENDIX B EXPERIENCE

WITH VERY HIGH AND POTENTIALLY

VERY HIGH RADIATION

AREAS The following NRC documents provide informa tion on past incidents in high and very high radiation areas and present means for preventing their recur rence. They are summarized here so that pertinent historical information is readily accessible to users, es pecially to newer personnel.

IE Circular 76-03, "Radiation Exposures in Re actor Cavities" IE Bulletin 78-08, "Radiation Levels from Fuel Element Transfer Tubes" IE Information Notice 82-31, "Overexposure of Diver During Work in Fuel Storage Pool" IE Information Notice 82-51, "Overexposures in PWR Cavities" IE Bulletin 84-03, "Refueling Cavity Water Seal" IE Information Notice 84-19, "Two Events In volving Unauthorized Entries into PWR Reactor Cavi ties" IE Information Notice 84-61, "Overexposure of Diver in Pressurized Water Reactor (PWR) Refueling Cavity" IE Information Notice 84-93, "Potential for Loss of Water from the Refueling Cavity" IE Information Notice 86-107, "Entry into PWR Cavity with Retractable Incore Detector Thimbles Withdrawn" IE Information Notice 87-13, "Potential for High Radiation Fields Following Loss of Water from Fuel Pool" NRC Information Notice 88-63 and its supple ments, "High Radiation Hazards from Irradiated In core Detectors and Cables" NRC Information Notice 88-79, "Misuse of Flashing Lights for High Radiation Area Controls" NRC Information Notice 90-33, "Sources of Un expected Occupational Radiation Exposure at Spent Fuel Storage Pools" These documents are available for inspection and copying for a fee from the NRC Public Document Room, 2120 L Street NW., Washington, DC. The PDR's mailing address is Mail Stop LL-6, Washing ton, DC 20555; phone (202)634-3273;

fax (202) 634-3343.

An Electric Power Research Institute document also provides information on past incidents: "Residual Heat Removal Experience Review and Safety Analy sis: Pressurized Water Reactors," NSAC-052, Janu ary 1983. Some of the areas mentioned in the above docu ments have the potential to become high and very high radiation areas during certain periods of opera tion, most frequently during refueling outages. Poten tial radiation fields for certain operations are listed in Table B-1 below. These are general ranges, and ac tual numbers may be higher or lower because of plant-specific factors.

Without proper controls and monitoring, person nel entering these areas when the indicated radiation fields are present could receive radiation exposures with severe or life-threatening consequences.

A study of the above documents indicates generic reasons for repeated incidents.

In general, improper entry into these areas is caused by a lack of aware ness, indicating insufficient training and administra tive controls.

Some of the causes are discussed below. Entry into Reactor Cavities When In-Core Detectors Are Withdrawn At times during refueling or maintenance, the re tractable in-core detectors and associated thimble tubes are withdrawn from the reactor. While in the reactor core, parts of the detector system such as the thimble tubes become highly radioactive.

These parts can create radiation fields within the reactor cavity where annual occupational dose limits can be ex ceeded within a few seconds. These extremely haz ardous areas can present life-threatening radiation situations in which acute exposures, sufficient to cause serious radiation injury, are possible after just a few minutes of exposure.

This hazard is compounded by limited visibility and access to equipment within the reactor cavity. The cavity is also a hostile physical environment in which accidents and mishaps can occur. In the vicinity of the thimbles, general area dose rates can be greater than 20 gray per hour (2,000 rads per hour), with dose rates at the surface of the guide tubes as high as 200-400 gray per hour (20,000 to 40,000 rads per hour). Acute exposures to these high dose rates are sufficient to cause clinical radia tion injury effects (or possibly death) within just a few minutes (e.g., 20 Gy/hr or 0.3 Gy/min [2,000 rads/hr or 30 rads/min]). (See Figure B-i.) In the past, personnel from the operations de partments at several plants have entered the reactor cavity without radiation work permits, adequate sur veys, or knowledge of the condition of the retractable in-core detectors and their thimble tubes. Personnel have bypassed the lock systems and ignored posted B-1 TABLE B-i Spent fuel transfer tube Letdown IX/filter Spent fuel (in pool) Radwaste resin tank Traversing in-core probe detectors (TIPS) and cables, source and intermediate range monitor detectors and cables (SRMs,IRMs)

2 Reactor cavity with thimbles, withdrawn Thimbles Reactor cavity (in core) Steam generator channel head 3 100-500 Gy/hr (10,000-50,000

rads/hrl)10-100 Gy/hr (1,000-10,000

rads/hr) 1000-10,000

Gy/hr (100,000-1,000,000rads/hr)

-50 Gy/hr (-5,000 rads/hr)0.01-1000

Gy/hr (1-100,000

rads/hr) 2-20 Gy/hr (200-2,000

rads/hr) -500 Gy/hr (-50,000 rads/hr) >10 Gy/hr (>1,000 rads/hr) 0.1-0.4 Gy/hr (10-40 rads/hr)'This is the dose rate during spent fuel transfer.

2 These doses vary considerably depending on the time after withdrawal from the core. Immediately upon with drawal, dose rate of >100 Gy/hr (10,000 rads/hr) may be experienced, while decay can reduce the contact dose rates to -0.01-0.1 Gy/hr (1-10 rads/hr) after about 3 days.3 Although this is not a very high radiation area, it is personnel.

warning signs on the special conditions required for entry. These personnel include managers, shift engi neers, shift supervisors, reactor operators, and health physics technicians.

There have been overexposures exceeding established limits, and several near overex posures.

Fuel Movement in BWR Drywells During certain spent fuel handling operations, very high dose rates can exist in BWR drywells.

All drywell containment types (Mark I, II, and III) lack complete shielding.

Fuel handling must be controlled to prevent potentially fatal exposure to drywell work ers from mishaps with irradiated fuel. Unshielded ir radiated fuel can create radiation fields of 102 to 104 gray per hour (104 to 106 rads per hour) at a distance of 1 foot. Figure B-2 shows dose rates in several areas of the drywell resulting from spent fuel in various con figurations.

In 1987 and 1988, the NRC conducted reviews of the radiological controls for BWR drywells during spent fuel movement.

The licensees'

use of temporary shielding for transfer of spent fuel to the storage pool (see Figure B-3), operational considerations (e.g., re stricting access to the upper drywell or evacuation pr ocedures for the drywell during fuel movement), and employee training were all reviewed.

The following conditions have been found in the past: important because it is an area frequently accessed by 1. Personnel were not aware of the hazards to a worker in the drywell resulting from a dropped spent fuel element.

2. Personnel were not aware of the special shielding requirements.

3. Radiological controls, procedures, and personnel training needed improvement.

4. There was a lack of communication between fuel operators and personnel at radiological control points. Divers in the Spent Fuel Pool and Reactor Cavity Divers are used for an increasing number of maintenance and inspection tasks. The operations these individuals perform require careful and thor ough planning.

The use of proper underwater work techniques can result in substantial savings of time and reductions in radiation doses. The gear that divers wear makes their out-of water movements awkward and makes seeing and hearing more difficult, thereby hindering communica tions. Control of a diver's location in the pool is im portant to keep the diver away from areas of high radiation levels. Careful planning and execution of divers' work in the spent fuel pool, reactor cavity, and reactor vessel and piping are extremely important, as a single spent fuel element can create radiation fields of 102 to 104 B-2 Gy per hour (104 to 106 rads per hour) at close prox imity. Other irradiated objects in the pool or cavity can produce contact dose rates from ten to hundreds f rads per hour. Past experience shows that surveys and- radiation work permits have sometimes been inadequate for the special nature of the work environment for divers. Continuous readout dosimeters and dose rate survey instruments have not been widely used. Dosimeters with alarms have failed for lack of proper controls and checks of instruments.

Dose rate monitoring de vices that warn of unexpected changes in dose rates in the work area have not been used. Procedures de tailing special precautions for diving operations in these areas have been inadequate in some cases. Visi bility, lighting, and the performance of underwater survey instrumentation in the fuel pool have been poor. Loss of Water from the Fuel Pool, Fuel Transfer Canal, and Reactor Cavity Complete or partial loss of water from the spent fuel pool, fuel transfer canal, or reactor cavity can result in very high radiation areas. In some instances, a refueling cavity water pneumatic seal and a transfer canal pneumatic seal have failed, causing a rapid drop in the water level in the spent fuel pool. These large water losses can expose spent fuel in the fuel pool or uncover other highly radioactive objects in the fuel pool (such as irradiated control rod blades and neutron detectors)

within a few minutes. These large water losses could also result in high radiation levels from components that have been suspended at insuf ficient depth in the spent fuel pool. Other mechanisms that can cause water losses in the spent fuel pool, fuel transfer canal, and reactor cavity include certain misalignments of valves in the residual heat removal system while the reactor is in the shutdown cooling mode (assuming shutdown cool ing is in use when the cavity is filled), leaking steam generator nozzle dams, and slow-draining lines at tached to the refueling cavity. Resin Tanks, Systems, and Chemical Decontamination Resin tanks may accumulate large inventories of radionuclides from the processing of various coolants or wastes. Resins may flow through piping in the reac tor facilities because of improper valve lineups, mal functions, etc., and may result in new high radiation areas. Chemical decontamination of systems may result in the movement of large quantities of radioactive materials.

Activities in these areas must be carefully observed because of the potential for the areas to be come very high radiation areas. Other Very High Radiation Areas Portions of the reactor piping, such as valves and loops, may become collection points for radionuclides over time. Activities in these areas must be carefully observed because of the potential for the areas to be come very high radiation areas.B-3 R/hr PLATFRM/ =50-200 R/hr PLATFORM/

GUIDES SE L SUMP (a) Radiation Dose Rates With Incore Instrument Thimbles Withdrawn THIMBLE GUIDES ,CORE PLATE PEN ETRATION THIMLE i TUBES GUIDES-7 (b) Detail of Thimble Guides Figure B-1 Pressurized Water Reactor Cavity B-4

.- 30' ELEVATION 0.*-- 0' ELEVATION Dose Rates During Refueling (R/hr without/with moveable shield) Fuel Position Location 1 2 3 4 A 30/0.3 8x10 4/15 / B 1 10/- -1- -/- -I C2 50/--/---D -/- 3/3x10-2 2x10 3/1.5 -E -/- 0.13/lx1o-

4 5x10 2/0.15 F -I- -1- 3/Foot Note: 1. Measured 2 It. from reactor vessel 2. Measured on contact wit reactor vessel Figure B-2 Dose Rates in BWR Drywell During Spent Fuel Transfer B-5 TOWARD SPENT FUEL POOL FUEL CHUTE SHIELD Figure B-3 Portable Radiation Shield B-6 REGULATORY

ANALYSIS A separate regulatory analysis was not prepared for this. regulatory guide. The regulatory analysis prepared for 10 CFR Part 20, "Standards for Protection Against Radiation" (56 FR 23360), provides the regulatory basis for this guide and examines the costs and benefits of the rule as implemented by the guide. A copy of the "Regulatory Analysis for the Revision of 10 CFR Part 20" (PNL-6712, November 1988), is available for inspection and copying for a fee at the NRC Public Document Room, 2120 L Street NW., Washington, DC, as an enclosure to Part 20.Federal Recycling Program RA- I

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