U.S. Nuclear Regulatory Commission

Response to Region II Interpretation for Control of High Radiation Areas

HPPOS-068 PDR-9111210154

Title: Response to Region II Interpretation for Control of

High Radiation Areas

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

3. 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