IP 71124.01, Radiological Hazard Assessment and Exposure Controls
January 1, 2020
- https://www.nrc.gov/docs/ML1925/ML19253D198.pdf - 1-1-2020
- https://www.nrc.gov/docs/ML1728/ML17286A284.pdf - 12-21-2017
text
Issue Date: 12/23/19 1 71124.01
NRC INSPECTION MANUAL ARCB
INSPECTION PROCEDURE 71124 ATTACHMENT 01
RADIOLOGICAL HAZARD ASSESSMENT AND EXPOSURE CONTROLS
Effective Date: January 1, 2020
PROGRAM APPLICABILITY: IMC 2515 App A
CORNERSTONES: Occupational Radiation Safety
INSPECTION BASES: See IMC 0308 Attachment 2
SAMPLE REQUIREMENTS:
Sample Requirements Minimum Baseline Sample
Completion Requirements
Budgeted Range
Sample Type Section(s) Frequency Sample Size Samples Hours
Radiological Hazard
Assessment
03.01 Annual* 1 per site 1 per site 36 +/- 4 per site
Instructions to
Workers
03.02 Annual* 1 per site 1 per site
Contamination and
Radioactive Material
Control
03.03 Annual* 2 per site 2-3 per site
Radiological
Hazards Control
and Work Coverage
03.04 Annual* 3 per site 3-5 per site
and Very High
Radiation Area
Controls
03.05 Annual* 2 per site 2-5 per site
Radiation Worker
Performance and
Radiation Protection
Technician
Proficiency
03.06 Annual* 1 per site 1 per site
- Inspections should be performed during a refueling outage or when radiologically significant
work is being performed. When appropriately risk-informed samples are not available for
inspection follow completion guidance of IMC 0306 section 06.08.f.3.
71124.01-01 INSPECTION OBJECTIVES
01.01 Review and assess licensee performance in assessing the radiological hazards in the
workplace associated with licensed activities and the implementation of appropriate
radiation monitoring and exposure controls.
01.02 Verify that the licensee is properly identifying and reporting Performance Indicators
(PIs) for the Occupational Radiation Safety Cornerstone.
01.03 To conduct a routine review of problem identification and resolution activities per
Inspection Procedure (IP) 71152, “Problem Identification and Resolution.”
71124.01-02 GENERAL GUIDANCE
Inspections should be scheduled to coincide with refueling outages or other radiologically
significant plant activities so as to maximize the opportunities for the inspector to verify licensee
performance through direct observation.
Walk-downs and work activity observations required by the procedure should be performed
together, to the extent practical.
Review licensee PIs for the Occupational Radiation Safety Cornerstone. For more information
on Performance Indicators, see NEI 99-02, “Regulatory Assessment Performance Indicator
Guideline” (ML13261A116) and information on changes in Frequently Asked Questions at
http://www.nrc.gov/reactors/operating/oversight/program-documents.html#pi.
Review the results of radiation protection program audits and review any condition reports
related to occupational radiation safety since the last inspection. The results of the radiation
protection program audit (e.g., licensee’s quality assurance audits or other independent audits)
and condition report reviews should be used to gain insights into overall licensee performance
and focus the inspector’s inspection activities on areas that are most likely to yield safetysignificant results, consistent with the principle of “smart sampling.” Annual radiation protection
program audits are required by 10 CFR 20.1101(c). NUREG/CR-6204, “Questions and
Answers Based on Revised 10 CFR Part 20,” (ML12166A179) provides further guidance on
annual program audits in Q&A #118, #134, and #380.
Per IP 71152, it is expected that routine reviews of PI&R activities should equate to
approximately 10 to 15 percent of the resources estimated for the associated baseline
cornerstone procedures, this is a general estimate only based on the overall effort expected to
be expended in each strategic performance area. It is anticipated that the actual hours required
to be expended may vary significantly from attachment to attachment, depending on the nature
and complexity of the issues that arise at the particular facility. Overall, an effort should be
made to remain within the 10 to 15 percent estimate on a strategic performance area basis.
Inspection time spent assessing PI&R as part of the baseline procedure attachments should be
charged to the corresponding baseline procedure.
71124.01-03 INSPECTION REQUIREMENTS
03.01 Radiological Hazard Assessment Sample
Verify that the licensee is identifying the magnitude and extent of radiation levels;
concentrations and quantities of radioactive materials; and is adequately assessing
radiological hazards.
Specific Guidance
a. Survey protocol should consider the current and historical isotopic mix and isotopic
percent abundance, including current and historical presence of hard-to-detect
radionuclides and potential alpha hazards. See IP 71124.04 for further guidance on
source term determination.
b. Consider if, since the last inspection, there have been changes to plant operations that
may result in a significant new radiological hazard for onsite personnel. If a new hazard
is identified, consider if the licensee has assessed the potential impact of these
changes and has implemented adequate surveys to detect and quantify the radiological
hazard.
Changes in plant operations that may result in changes to the scope of radiological
hazards include but are not limited to the following:
1. Degraded reactor fuel integrity that can result in hot particle contamination, or the
presence of transuranic nuclides (or other hard-to-detect radionuclides), for work
activities previously unaffected,
2. Changes in reactor water chemistry (e.g., hydrogen injection in a BWR) that can
result in significant changes to the in-plant radiation source term,
3. Significant onsite spills, or contamination of uncontaminated systems,
4. Storage of radioactive materials in the owner-controlled area (e.g., remote or
satellite RCAs within the plant site).
c. Consider if the thoroughness and timing of the surveys is appropriate for the provided
radiological hazard. The results of the audit and condition report reviews should be
used to gain insights into overall licensee performance and focus the inspector’s
inspection activities on areas that are most likely to yield safety-significant results,
consistent with the principle of “smart sampling.” An appropriate survey should be of
the right type, sensitivity and technique and the survey should enable adequate
quantification of the radiological hazard and establishment of protective measures.
d. During walkdowns of the radiological control area (RCA)—including temporary
radioactive material processing, storage, and handling areas—and other areas of the
facility, evaluate material conditions and potential radiological conditions. Other areas
to evaluate during walkdowns can include the protected area, restricted area,
contaminated tool storage, contaminated machine shops, satellite RCAs, and
infrequently accessed HRAs of the plant.
e. For systems used to monitor and warn of changing airborne concentrations in the plant
consider if alarms and set points are sufficient to prompt licensee/worker action to
ensure that doses are maintained within the limits of 10 CFR Part 20 and ALARA, and
determine whether they are appropriately positioned relative to the radiation source(s)
or area(s) they are intended to monitor.
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- and 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.
General area air samples are typically used by licensees to verify the effectiveness of
engineering controls to mitigate airborne radiological hazards at the work site.
Breathing zone air samples are necessary when the licensee assigns individual internal
doses from airborne concentrations of radioactive material.
03.02 Instructions to Workers Sample
Verify that workers are instructed in plant-related radiological hazards and the radiation
protection requirements intended to protect workers from those hazards.
Specific Guidance
a. Review radiation work permits (RWPs) and other documentation the licensee uses to
control access to radiological hazards and evaluate instructions and controls. Note, the
radiological controls (e.g., RWPs) for entry into high radiation areas (HRAs) may be
plant specific. Review plant Technical Specifications to determine the requirements for
entry and work in HRAs (e.g., authorization to enter into HRAs, electronic alarming
dosimter (EAD) set points, pre-job briefings, continuous job coverage, and stay time
limitation).
b. Consider reviewing survey maps and attending pre-job briefings to observe instructions
to workers. Workers should be able to remember their work restrictions established on
the RWPs and as instructed in pre-job briefs (i.e., where they are allowed to work, what
they are allowed to do and what they are not allowed to do). In addition, workers
should be knowledgable of stop work conditions (e.g., contact HP prior to system
breach or worker actions that may cause a change in radiological conditions) and
location of low-dose waiting areas.
c. During tours of the facility and review of ongoing work, evaluate if ambient radiological
conditions are consistent with radiological postings.
d. Consider if the licensee informs workers of changes in plant operations/conditions that
could significantly impact radiological hazards.
e. Select containers holding nonexempt, licensed radioactive materials that may cause
unplanned or inadvertent exposure of workers. Consider if they are labeled and
controlled in accordance with 10 CFR 20.1904, or meet the requirements of
03.03 Contamination and Radioactive Material Control Sample
Verify the licensee controls radioactive material and prevents the spread of
contamination.
Specific Guidance
a. Observe locations where the licensee monitors potentially contaminated material
leaving the RCA. Consider if the work is performed in accordance with plant procedures
and whether the procedures are sufficient to control the spread of contamination and
prevent the unintended release of radioactive materials from the site. 10 CFR Part 20
does not contain release limits for the release of contaminated material to unrestricted
areas; thus, the licensee’s criteria should be that no detectable licensed radioactive
material (radioactive gaseous and liquid effluents excepted) is released for unrestricted
use or as waste into an unrestricted area.
b. Review the licensee’s criteria for the survey and release of personal items (e.g., using
small article monitors (SAMs)).
c. Observe workers exiting the RCA and performing contamination monitoring. Consider if
the applicable guidance is adequate and if workers are knowledgeable on how to
respond to an alarm that indicates the presence of radioactive material. If workers are
permitted to frisk personal items on their own, consider observing one or two control
points to ensure that workers are complying with applicable guidance and training.
d. During plant walk-downs, consider background dose rates; they should not excessively
interfere with the sensitivity of contamination monitoring equipment (e.g., friskers,
personnel contamination monitors). Contamination monitoring equipment for free
release of equipment and materials should be in a low background area. The licensee
should not have established an artificial release threshold by degrading the instrument’s
detection sensitivity through such methods as raising the energy discriminator level or
locating the instrument in a high-radiation background area.
e. Evaluate the licensee’s physical and programmatic controls for highly activated or
contaminated materials (non-fuel) stored within spent fuel pool and other storage pools.
Consider if appropriate controls (i.e., administrative and physical controls) are in place
to preclude unintended doses from materials stored in pools and the inadvertent
movement of these materials.
03.04 Radiological Hazards Control and Work Coverage Sample
Verify the licensee controls radiological hazards during radiological work.
Specific Guidance
a. Consider if radiological controls are implemented commensurate with the radiological
hazard. Adequate radiological controls include performing required surveys (e.g.,
radiation, contamination and airborne), radiation protection job coverage (e.g., audio
and visual surveillance for remote job coverage), contamination controls and stop work
criteria.
b. Consider if EAD dose and dose rate alarm set points are based on current radiological
survey data and plant procedures. Initial EAD set points (e.g., pre-outage) for EAD
dose and dose rate alarms are commonly set based on historical data. The EAD alarm
set points should be adjusted as needed based on actual dose rates and for changes in
radiological conditions (e.g., during an outage).
c. During job performance observations, consider if personnel radiation monitoring
devices are placed on the individual’s body consistent with the method the licensee is
employing to monitor dose from external radiation sources and applicable regulatory
requirements.
d. If available, evaluate the work controls and dosimetry used for activities where dose
rate gradients can be severe (i.e., underwater diving, steam generator entries, work
under the reator head, etc.), thereby increasing the necessity of providing multiple
dosimeters and/or enhanced job controls.
e. When possible, observe work in potential airborne areas, and consider if air samples
are representative of the breathing air zone when used to assess dose. As available,
review RWPs for work within airborne radioactivity areas to guide inspection scope.
Consider airborne radioactivity controls and monitoring, for jobs with the potential for
significant airborne levels (e.g., grinding, grit blasting, system breaches, entry into
tanks, cubicles, reactor cavities).
When possible, observe work in Alpha Level II and III areas as these areas are more
risk significant from an internal exposure perspective. Substantial internal dose may be
received from alpha contamination prior to detection by instrumentation designed to
detect betta and gamma radiation, which is typically in use. Procedures and work
instructions should address if/when contamination surveys and airborne radioactivity
surveys require alpha analysis, respiratory protection requirements, internal monitoring
requirements, and contamination/airborne radioactivity minimization controls (i.e.
grinding in an alpha II area may require more controls than a work evolution not
expected to create an airborne hazard and work instructions may require wiping down
of the area frequently to prevent buildup of contamination).
03.05 High Radiation Area and Very High Radiation Area Controls Sample
Verify the licensee controls HRAs and VHRAs per applicable requirements.
Specific Guidance
a. Review the circumstances of Technical Specification High Radiation Area Occurrences,
as defined by NEI 99-02. Focus on verifying aspects of the licensee PIs associated
with high-risk HRAs (greater than 25 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 centimeters from the source)
and for all VHRAs. Do not repeat this HP inspection requirement during the site wide
annual PI verification team inspection.
b. Inspect posting and physical controls for all VHRAs and for a risk-informed selection of
HRAs.
The intent of this limited inspection oversight/requirement is to maintain continued NRC
vigilance of the licensee’s program and procedural controls and plant staff awareness of
these special, accessible areas where the potential for overexposure exists.
c. Review procedural changes since the last inspection to determine the adequacy of
access controls for HRAs/VHRAs, consider if changes to licensee procedures will result
in inadequate controls of these areas (i.e., violation of T.S. or site-specific alternate
controls requirements).
03.06 Radiation Worker Performance and Radiation Protection Technician Proficiency
Sample
Verify adequate radiation worker and radiation protection technician performance with
respect to radiation protection requirements.
Specific Guidance
a. Consider if workers observe applicable radiation protection requirements and are
knowledgeable of instructions provided by the licensee (e.g., Part 19 instructions and
information relayed during pre-job briefs).
b. Consider if workers are aware of their EAD dose and dose rate set points, and
allowable stay times or permissible dose for radiologically significant work under each
RWP.
c. Consider if workers are aware of how to respond to EAD alarms in accordance with
plant procedures. Note, some EAD alarms are anticipated (e.g., for workers traversing
a high dose rate work area).
d. Consider if radiation protection technicians are aware of the radiological conditions in
their workplace, including applicable RWP controls/limits, and if their performance is
consistent with the licensee’s training and procedures
e. Consider if appropriate pre-work and job coverage surveys were performed for
radiologically risk significant work activities.
f. Observe radiation protection technicians performing radiation surveys and consider if
the instruments are being used correctly (i.e., survery technique and correct instrument
for application). Consider discussing with radiation protection staff (supervisors and
technicians) the procedures, equipment, and performance of radiation surveys for both
routine and non-routine activities. Technicians should be knowledgeable about when
and how to survey areas for:
1. Hot particles,
2. Alpha emitters,
3. Loose surface contamination,
4. Neutron radiation,
Issue Date: 12/23/19 8 71124.01
5. Airborne radioactivity, including the potential presence of transuranic
radionuclides and/or other hard-to-detect radionuclides,
6. Work activities that could suddenly and significantly increase radiological
conditions such as in-core detector movement, fuel moved in affected areas of
drywell or auxiliary building, movement of irradiated materials in the spent fuel
pool, and
7. Severe radiation field dose gradients that can result in non-uniform exposures.
71124.01-04 REFERENCES
RG 1.21, “Measuring, Evaluating, and Reporting Radioactive Material in Liquid and Gaseous
Effluents and Solid Waste”
RG 8.38, “Control of Access to High and Very High Radiation Areas in Nuclear Power Plants”
NRC Information Notice 1985-92, “Surveys of Wastes Before Disposal from Nuclear Reactor
Facilties”
NRC Information Notice 1990-33, “Sources of Unexpected Occupational Radiation Exposures at
Spent Fuel Storage Pools”
NRC Information Notice 1997-36, “Unplanned Intakes by Worker of Transuranic Airborne
Radioactive Materials and External Exposure Due to Inadequate Control of Work”
NRC Circular 1981-07, “Control of Radioactively Contaminated Material”
NUREG-1736, “Consolidated Guidance: 10 CFR Part 20 – Standards for Protection Against
Radiation”
NUREG/CR-5569, Revision 1, “Health Physics Positions Data Base,” (ML093220108)
NUREG/CR-6204, “Questions and Answers Based on Revised 10 CFR Part 20”
NUREG/CR-6204, “Questions and Answers Based on Revised 10 CFR Part 20”
(ML12166A179), Question 447
NUREG/CR-6204, “Questions and Answers Based on Revised 10 CFR Part 20”
(ML12166A179), Question 448
HPPOS-016, “Applicability of Access Controls for Spent Fuel Pools,” (ML103420144)
HPPOS-221, “Lower Limit of Detection (LLD) for Potentially Contaminated Oil,” (ML103470158)
HPPOS-245, “Access Controls for Spent Fuel Pools,” (ML11192A127)
Issue Date: 12/23/19 9 71124.01
HPPOS-250, “Monitoring at Nuclear Power Plants for Contamination by Radionuclides that
Decay by Electron Capture,” (ML11192A132)
HPPOS-333, “Labeling of Radioactive Materials Stored Under Water,” (ML15027A277)
Nuclear Energy Institute 99-02, “Regulatory Assessment Performance Indicator Guideline”
END