Response to Region II Interpretation for Control of High Radiation Areas

HPPOS-068 PDR-9111210154

See the memorandum from E. L. Jordan to J. A. Olshinski dated November 7, 1983. For Standard Technical Specification 6.12.1 (c) regarding presence of an HP Tech with a work party in a high radiation field, continuous "eye-ball" coverage is not required. One hundred percent coverage of an HP Tech for all high radiation work is counter to ALARA requirements.

The health physics position was written in the context of 10 CFR 20.203, but it also applies to "new" 10 CFR 20.1601. IE was requested to review a Region II interpretation of STS Section 6.12.1, "High Radiation Control." In addition, IE was requested to consult with NRR and provide inspection and enforcement guidance. After review of the position with NRR, IE cannot support the STS interpretation because it is inconsistent with the intent of the specification.

A typical STS Section 6.12.1 states that any individual or group of individuals permitted to enter such areas will be provided with or accompanied by one or more of the following:

1. A radiation monitoring device which continuously indicates the radiation dose rate in the area, or 2. A radiation monitoring device which continuously integrates the radiation dose rates 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 rate levels in the area have been established and personnel have been made knowledgeable of them, or

2. An individual qualified in radiation protection procedures with a radiation dose rate monitoring device, who is responsible for providing positive control over activities within the area and shall perform periodic radiation surveillance at the frequency specified by the Radiation Protection Manager in the RWP.

Only provision (3) of STS 6.12.1 is causing problems for Region II. In part, "... Region II interprets positive control as continued visual contact between the accompanying HP Tech and those workers ...." The position to require continual, visual contact by the HP Tech is inconsistent with the specification. To require "eye-ball" coverage for each and every task performed within a high radiation area goes contrary to the intent of the STS to allow licensee management personnel to exercise their professional judgement in deciding what level of HP coverage is needed. This level covers a broad spectrum, ranging from a single visit to the work area (spot check of radiation conditions, compliance to RWP, etc.) up to continual, line-of-sight coverage (of those jobs with high potential for drastic, fast changing radiological conditions).

Several negative outcomes could result from the suggested "continual coverage" interpretation. Licensees, viewing it as an onerous choice, would probably be more apt to select "worker-self coverage" options (1) and (2). By increasing their reliance on these non-HP coverages, IE believes the overall quality of radiological protection provided to workers would decrease. Going in the other direction, another problem could be increasing the logistics / manpower burden.

To provide 100 percent job coverage for all high radiation area work may well be beyond the licensee's resource capability. The additional burden of increased radiation exposures to HP Techs would be counter to ALARA principles, and again could strain the finite resource pool of qualified HP Techs.

Additionally, care must be taken not to mix genuine ALARA concerns and STS 6.12.1 requirements. As an option for the high radiation control requirements of 10 CFR 20.203 (c) (2) [or 10 CFR 20.1601 (a)], the specification's basic purpose is to require licensees to maintain positive controls over entries / work activities in high radiation areas. Thus, the primary focus and objective of the inspection program in this STS 6.12.1 area should be directed toward ensuring that the licensee's positive controls program adequately minimizes the possibility of excessive exposures. Voluntary ALARA commitments made by the licensees for external exposure reduction should form the basis for ALARA inspection and enforcement activities, not STS 6.12.1.

Regulatory references: 10 CFR 20.203, 10 CFR 20.1601, Technical Specifications

Subject codes: 4.1, 8.5

Applicability: Reactors