NISP-RP-05 Access Controls for High-Radiation Areas

 Chapter 5 is about access controls for high-radiation areas are essential safety measures implemented to protect individuals from excessive radiation exposure. High-radiation areas are locations where radiation levels are significantly elevated and can pose a serious health risk if not properly controlled. Here are some key aspects of access controls for high-radiation areas:

1. Restricted Access:

Access to high-radiation areas is strictly controlled and limited to authorized personnel who have received specific training and have a legitimate reason to enter these areas. Unauthorized personnel should be prevented from entering at all costs.

2. Posting and Signage:

High-radiation areas are clearly marked with warning signs and radiation symbols. These signs provide information about the radiation hazard, the required level of radiation protection, and any special precautions that must be taken.

3. Radiation Monitors:

Radiation monitors, such as Geiger-Muller counters or scintillation detectors, are often installed at access points to high-radiation areas. These monitors measure radiation levels in real-time and can trigger alarms if levels exceed predefined thresholds.

4. Dosimetry:

Personnel entering high-radiation areas are typically required to wear dosimeters, which are devices that measure and record their radiation exposure over time. Dosimeters provide a record of an individual's radiation dose and help ensure that exposure limits are not exceeded.

5. Access Control Devices:

Physical access to high-radiation areas may be controlled using access control devices such as key cards, PIN codes, or biometric systems. Only authorized personnel with the proper credentials can unlock doors or barriers to gain entry.

6. Training and Qualification:

Personnel who work in high-radiation areas undergo specialized training to understand the hazards, use protective equipment, and respond to radiation alarms or emergencies. Qualification and certification may be required before individuals are granted access.

7. Work Permits:

In some cases, individuals must obtain specific work permits before entering high-radiation areas. These permits outline the purpose of the work, the expected duration of exposure, and the safety measures to be followed.

8. Continuous Monitoring:

Continuous radiation monitoring is often in place within high-radiation areas. This monitoring provides real-time data on radiation levels, and any significant increase in levels triggers alarms and immediate actions to protect personnel.

9. Emergency Response Plans:

High-radiation areas should have well-defined emergency response plans in case of accidents, equipment failures, or other incidents that could lead to increased radiation levels. Personnel should be trained to respond to emergencies swiftly and safely.

10. Decontamination Procedures:

Procedures for decontaminating personnel and equipment leaving high-radiation areas are crucial to prevent the spread of radioactive contamination to other areas. Decontamination stations are often provided at exit points.

Access controls for high-radiation areas are put in place to protect the health and safety of workers and to ensure compliance with regulatory requirements. These controls are an integral part of radiation safety programs in nuclear facilities, research institutions, and industrial settings where elevated radiation levels are present.

Lesson:

This procedure describes the controls in place to access High Radiation Areas and Locked High Radiation Areas.   

1.1           Scope and Applicability

This procedure describes the processes to prevent unplanned personnel dose in High Radiation Areas (HRA) and Locked High Radiation Areas (LHRA).  Access controls for Very High Radiation Areas are not addressed by this procedure since such entries are infrequent and controlled by site-specific reviews and authorizations. 

The forms referenced by this procedure are examples used to describe the pertinent information that should be recorded for future reference.  Plant procedures may specify the use of equivalent forms or the use of electronic media for the same purposes. For sites that utilize an electronic LHRA key issuance, keycards are used for key accountability and steps pertaining to the use of attachment 2 are not applicable.  See site specific process for key issuance, return and transfer.

Member utilities are expected to use this standard to enable supplemental workers to transition between nuclear power plants with minimal site-specific training.  Compliance with these instructions is expected without additional site requirements or process deviations being imposed that may require additional training or challenge the performance of supplemental workers.

This procedure will be used to train and instruct supplemental radiological protection technicians.  Member utilities will implement these process requirements in site procedures and update site procedures whenever requirements or process steps in this Nuclear Industry Standard Process (NISP) are revised.  Current revisions are maintained on the INPO website.

Terms, acronyms, and definitions are provided in NISP-RP-13, Radiological Protection Glossary.

Clarifying notes for requirements and process steps are provided in Section 4.0 using superscript numbers in the preceding sections.

2.0         General Requirements

2.1         Provide each individual entering an HRA or LHRA with one of the following:

CAUTION Plant Technical Specifications may have requirements in addition to those listed below.  Comply with site procedures to enter an HRA or LHRA.

 

2.1.1            A radiation monitoring device that continuously indicates the radiation dose rate in the area.

2.1.2            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.

2.1.3            An individual qualified in radiation protection procedures with a radiation dose rate monitoring device; this individual is responsible for providing positive radiation protection control over the activities within the area and should perform periodic radiation surveillance at the frequency specified in the radiation protection procedures or the applicable RWP.

2.2         Conduct HRA/LHRA briefings for personnel entering the area to ensure an understanding of expected dose rates and protective measures. 

2.2.1            ANSI qualified RP technicians may be exempted from the briefing requirement when entering the area per section 2.1.3 of this procedure.

2.2.2            Individuals may be exempted from the briefing requirement in responding to either of the following conditions:

a.       A medical emergency.

b.       The Shift Manager has authorized entry for a time critical evolution such as response to:

1)         Abnormal plant conditions.

2)         A fire alarm.

3)         An event that could threaten nuclear safety such as a loss of shutdown cooling.

4)         A condition that needs to be evaluated for potential entry into an Emergency Action Level.

2.3         LHRA keys may be issued only by the following:

2.3.1            The site RPM.

2.3.2            The Operations Shift Manager.

2.3.3            Personnel authorized by the site RPM.

2.4         Issue keys to access LHRAs only to RP personnel who are ANSI qualified.

2.5         Key control programs to access LHRAs may vary among sites but should include the following elements:

2.5.1            Rules for positive custody that include:

a.       A formal checkout and return process.

b.       Locking the key cabinet following issuance or return of a key.

c.       A routine inventory that is performed at least daily.

d.       Attaching a device to keys to minimize the potential for misplacement.

e.       Established rules to transfer possession of a key in the plant.

2.5.2            A key for an LHRA should unlock only the access for that area.

2.5.3            Master keys may be used only for the following conditions:

a.       The site RPM has authorized issuance of a master key to perform multiple checks of locked doors/barriers that do not require entry past a door/barrier.

b.       A medical emergency.

c.       The Operations Shift Manager has authorized use of a master key for a time critical evolution as described in step 2.2.2.b.

2.5.4            A periodic review by an RP supervisor or designate to ensure the key log (Attachment 2) is properly maintained.

2.6         Control access into a LHRA while working inside the area by at least one of the following methods:

2.6.1            Lock the access only if workers can freely egress the area without the use of a key or attendant.

2.6.2            Maintain the access open with an Access Control Guard per NISP-RP-04.

2.6.3            Maintain the access open with a flashing light and barrier per NISP-RP-04 if authorized by plant technical specifications.

2.7         A HRA/LHRA does not require posting if the area is completely enclosed by a substantial physical barrier that does not have openings or portals that enable personnel access (referred to as “cocooning”).

2.7.1            If the enclosed area is not posted as an HRA/LHRA, post the enclosure with a warning sign such as “Warning, do not remove, high radiation levels may result,” or “Danger, do not remove, very high radiation levels may result.”

2.8         Prevent LHRA events that show degraded performance through the NRC reactor oversight process.  Examples of LHRA events include:

2.8.1            Failure to post the area.

2.8.2            Failure to secure the area against unauthorized access.

2.8.3            Failure to provide personnel dose monitoring or control.

2.8.4            Failure to maintain administrative control over a key to a barrier lock.

2.8.5            An occurrence involving an unauthorized or unmonitored entry.

2.8.6            Nonconformance with an RWP that results in a loss of control of access to or work within the area.

3.0         Process Instructions

The use of briefings, key controls, and source controls are summarized below.

1.1           Control Area Configurations

1.1.1            Install lock-wire, metal tie wraps, bolts, or other fasteners that would require a tool to remove or rearrange shielding if the removal or rearrangement of shielding could cause radiation levels to increase above the current area posting.

a.       Post the shielding or shielded access with a warning sign such as “Warning, do not remove, high radiation levels may result,” or “Danger, do not remove, very high radiation levels may result.”

1.1.2            Establish controls to prevent items from being raised near or above the surface of spent fuel pools, reactor vessels, and flooded refueling cavities by using one or more of the following controls if radiation levels could increase above the current area posting. 

a.       Protective interlocks on equipment required to raise the item.

b.       Locked access by Radiation Protection to equipment that may be used to raise the item.

c.       Tie offs that are locked and controlled by Radiation Protection.

d.       Procedural controls on the use of equipment that may be used to raise an item, e.g. a refueling bridge.

e.       An Access Control Guard to prevent commencement of activities that may result in a LHRA.

f.        Continuous job coverage by an ANSI qualified technician to monitor conditions and stop work if pre-established criteria are exceeded.

1.1.3            Prevent uncontrolled access paths into HRAs and LHRAs due to the construction of scaffolding.  Ensure postings and controls are established commensurate with scaffold construction per NISP-RP-04.

1.1.4            Ensure cranes and lifting devices in proximity to an LHRA are controlled per site procedures to prevent unauthorized entry into an LHRA or to prevent conditions resulting in a non-posted LHRA.

1.2           Conduct an HRA/LHRA Entry Briefing

1.2.1            Follow the instructions on Attachment 1 to conduct the briefing.

a.       Use the checklist as a job aid to brief personnel entering an HRA; signatures are not required.

b.       Complete the checklist and obtain signatures for entry into a LHRA.

c.       Retain completed checklists as directed by RP supervision.

1.3           Issue a Key to Access an LHRA

Performer	Action
Key Issuer	1.3.1            Issue a LHRA key only under the following conditions: a.       Access has been authorized by an RP supervisor or designee. b.       The key is issued only to RP personnel who are ANSI qualified. 1.3.2            Issue a master key for LHRA access only under the following conditions: a.       The RPM has approved issuance of a master key to perform multiple door/barrier checks that do not require entry past the door/barrier.     b.       The Operations Shift Manager has authorized use of a master key for a time critical response due to abnormal plant conditions, including investigation of a fire alarm. c.       A medical emergency. 1.3.3            Ensure the key possessor understands personal responsibilities to: a.       Follow the established protocol if key possession is transferred to another individual. b.       Ensure keys are maintained in positive custody by only ANSI qualified RP technicians and RP supervision. 1.3.4            Record the following on the “Key Issue” line on Attachment 2. a.       Date and time of issuance. b.       Print and sign name. c.       Key identification number. d.       Door/barrier identification number or location. e.       The RWP number or name of the RP Supervisor or Operations Shift Manager authorizing the entry.
Key Possessor	1.3.5            Print name and sign in the “Key Issued To” block on Attachment 2.

1.4           Transfer Possession of an Issued LHRA Key

Performer	Action
Key Possessor	1.4.1            Notify the authorized Key Issuer that an LHRA key is being transferred to another individual. a.       Provide the name of the person receiving the key to the Key Issuer. b.       Ensure the individual receiving the key is an ANSI qualified RP technician or RP supervision. c.       Ensure the individual has been briefed per section 3.2.
Key Issuer	1.4.2            Document the following on Attachment 2. a.       Date and time of the transfer. b.       Printed name of the person receiving possession. c.       Print Key Issuer name and sign.

1.5           Terminate Access into an LHRA and Return the Key

Performer	Action
Key Possessor	1.5.1            Ensure the LHRA door/barrier is locked after exiting the area for the final time. a.       Ensure the locked door/barrier is sufficient to prevent inadvertent, unauthorized access. b.       If the door/barrier cannot be secured and locked, maintain positive control over the entrance and notify RP supervision for assistance. 1.5.2            Obtain a peer check to provide additional verification that the door/barrier is locked to prevent inadvertent, unauthorized access. 1.5.3            Print name and sign on Attachment 2.
Peer Checker	1.5.4            Print name and sign on Attachment 2 that the door/barrier was verified to be locked.
Key Issuer	1.5.5            Return the key to the key cabinet. 1.5.6            Print name and sign on Attachment 2 to document return of the key to the key cabinet.

2.0         Clarifying Notes

None

3.0         References

3.1         NISP-RP-04, Radiological Posting and Labeling

3.2         NISP-RP-10, Radiological Job Coverage

3.3         NISP-RP-13, Radiological Protection Glossary

3.4         NRC Regulatory Guide 8.38, Control of Access to High and Very High Radiation Areas in Nuclear Power Plants

Attachment 1:  Checklist for an HRA/LHRA Briefing - Sample

Briefing Date/Time:

RWP#:

Rev#:

Room or Area to Enter:

Purpose of Entry:

NOTE Completion of this checklist is required for an LHRA entry.  Completion of the checklist is not required for an HRA entry but should be used as a guideline.

Ensure the briefing is conducted in an environment to minimize distractions.  Maintain formality; clearly announce that this briefing is being conducted in compliance with federal regulations.  Cover each of the topics listed below.  Suspend the briefing and notify RP supervision if conflicts exist in implementing RWP requirements.

¨

ENSURE the RWP allows access into the HRA/LHRA.

¨

ASK if entrants have read and understand the RWP.  If not, suspend the briefing until the RWP has been read by all entrants.

¨

DISCUSS the radiological conditions of the area using the most current survey.

¨

ENSURE the role of each entrant is understood and the expectations to minimize dose using low dose rate areas, and other ALARA measures as applicable.

¨

Verify dosimeter setpoints are appropriate for the work based on expected radiation levels and discussed work activities.

¨

ASK if anyone may have problems hearing dosimeter alarms.  If yes, provide ancillary devices as needed; establish monitoring by telemetry or monitor stay times.

¨

ENSURE entrants understand to check with RP to make sure conditions have not changed if they leave and then return to the area.

¨

EXPLAIN that additional briefings are required for either of the following conditions: ¨   Work scope changes. ¨   Work scope involves high radiological risk; a briefing is required each shift as a minimum.

Briefing Provided By:

/

(Print)

(Signature)

Briefing Received By:

(Print)

(Signature)

(Print)

(Signature)

 

Attachment 2:  Key Log for LHRA Keys – Sample

KEY ISSUE	Date & Time		Key Issued By (Print & Sign)		Key Issued To (Print & Sign)
	LHRA Key Number		Door Number or Location		Approval Authorization (RWP Number or Printed Name)
LHRA VERIFICATION & KEY RETURN	*LHRA Locked By (Print & Sign / Date & Time)			LHRA Verified Locked By (Print & Sign / Date & Time)		Key Returned to Cabinet By (Print & Sign / Date & Time)
KEY  TRANSFER	Date & Time	Key Transferred To (Print Name)			Transfer Recorded By (Print & Sign)
	Date & Time	Key Transferred To (Print Name)			Transfer Recorded By (Print & Sign)
	Date & Time	Key Transferred To (Print Name)			Transfer Recorded By (Print & Sign)

 

 

RP Supervisor/Designate Review (print/sign):

Date:

 

*If area is down-posted, record down-posted in this block and record n/a for verification.