Need Help!! HRA/LHRA controls inside Drywells & Drywell control points

[Dustball]

I have been tasked to find out how plants are controlling access to their Drywells.  More specifically if they are posting LHRA at the entrance or local areas inside of the well. If anyone knows of a good plant that you currently work at or have worked in the past please let me know.  I have to do a benchmark and come up with some posting and control options for our plant.  We are also looking at upgrading our control point, drywell access personnel control, cameras, MG telemetry, etc.  If you know of good BWR's with an awesome viewing gallery with all of the fixin's (telemetry, cameras, telex, etc) please share.  Thank you!!

Dustin J. Wright
Radiation Protection Specialist
Nuclear Management Company
Monticello Nuclear Generating Plant
2807 West Hwy 75
Monticello, MN 55362
Dustin.Wright@nmcco.com

[RRhoads]

Kind of an odd question from such an old plant.....How have you been doing business???
Places i've been post at the "hatch" or entrance as a LHRA & then flush & shield to reduce dose rates to HRA conditions or less & if there still LHRA conditions...EG..around the nozzels & clean-up & such....lock & post those.
Does your entire Drywell meet LHRA conditions???
Why would you want to make your whole Drywell a LHRA for regular outage business (if this is in fact the case??) when it prob isn't ALL LHRA conditions?
What are your requirements for entering a LHRA???

[Dustball]

We have always posted the entrance as LHRA.  That way we have physical control of the LHRA.  Everyone gets briefed, everyone is on timekeeping via computer, more recently.. most are on telemetry.  I'm not saying it is right, this is just what we have done over the years.  We're moving to everyone on Telemetry, hopefully next outage.  We're in the processing from switching from Rados to MG so we plan on it anyway.  We have permanent shielding on our recirc lines.  We have one LHRA on a bottom head drain line that would have to be shielded and some how "locked".   How are plants "locking" shielding.
Anyway... our questions also come in as to how to control things like CRD pulls and satellite working area LHRA's like the nozzle windows.  We're also doing a RCP replacement again next outage so we run into some temporary LHRA areas there too.  You definetly do not want to get hit on a LHRA violation and that is why we have been reluctant to change our ways.  Our drywell is small and tight and there are lots of opportunities for climbing.  Depending on how we post and control these LHRA's somehow we have to ensure nobody mistakingly enters.

Thanks for the feedback.  Any feedback is greatly apreciated.  What BWR's have you been to that you would say are doing it right?  I'm also looking for plants that are on the right track with a good viewing gallery and preferrably using MG telemetry.

We did get questioned from INPO in regards to posting the drywell all the way out as a LHRA.  Our low dose rate area is inside the LHRA.  There are other issues in regards to passing items/tools over a LHRA boundary, taking out laundry, trash, etc.  Did the worker "break the plane" of the LHRA??  Is that an entry?  In INPO's eyes is there ever a proof positive way to do things?  If we all did it the right way, they wouldn't have a job.
Thanks again!

[RRhoads]

well..plants i've been to, physically lock the shielding in place with a chain & pad-lock w/ a key..
As for the whole Drywell a LHRA...
I've been to tight Drywells too but i don't believe that we kept the whole thing a LHRA.
That must be a real pain in the butt trying to brief EVERYONE to LHRA controls & ensure that they are on the correct RWP, when they are not even entering into a LHRA(dose rate wise)?
Sounds like you need to push back to the regulators a bit....passing a tool across a LHRA barrier??? Trash & laundry run in a LHRA? use a RP tech & the correct RWP & you'd be covered??right?? you can't do everything VIA computer.
Wouldn't you have a RP/HP tech in pulling CRDs & the recirc motor pull???
Plants do this type of stuff all the time & really don't run into the Posting "issues" you bring up...In my opinion posting the entire drywell would be very cumbersome
Sounds like you need to make a field trip.

[Already Gone]

It can go either way.  If your drywell has a lot of little areas that qualify as LHRA, you may be better off posting the whole thing or entire elevations.  That will please the regulators a lot more than if you post each area individually and they find one barricade down or one flashing light not lighted every day.   A lot of PWR's can't post their containments because they are just too large compared to the size of the actual LHRA's.  This leaves them with a whole bunch of little LHRA's with temporary barricades and battery powered lights.  They are constantly getting LHRA violations for a barricade being left down or a dead light.
Then there is the laundry/trash issue.  If you don't post the whole DW as a LHRA, you have to keep checking all those containers inside, and you have to have tighter monitoring over the removal of the bags.  I think RRhoads missed the fact that you do have different allowable dose rates on open bags inside LHRA than bags in HRA.  If you pull laundry from LHRA and put it in a HRA, you may have created another LHRA that isn't posted.  So, you have to bring a meter every time if the DW isn't posted at the door.  The pasing tools across boundaries is a bit much though.  As long as the contamination posting is the same on both sides, this shouldn't be an issue.

OTOH, you really don't want LHRA controls over dozens of workers who are in relatively low dose rates.  If you post the DW at the door, and half or more of the people on your telemetry are in <15 mR/hr, it's just going to clog up your monitoring of the ones who really need it.
You also have to consider that it may not be ALARA to brief everyone for LHRA when they are not working near the higher dose rates.  Essentially, that would be the same as giving a license for a worker to go anywhere in the area when his job is in a low dose area.  Without physical boundaries, postings, locks, or lights to stop them, they are just going to wander into higher dose rates than their jobs require.  That means that you have to babysit them with the telemetry - taking your attention away from those who really need it.

There is a compromise.  Post whole elevations - especially the ones that are harder to get to or are smaller.  Most BWR's will post the higher elevations LHRA and leave the larger lower levels as HRA or RA.  OR - you can post at the door, but put up warning signs and flashing lights to keep people clear of the higher rates.  Some places use these "information" postings within posted areas to remind people to stay away from areas where they don't need to be.  I think your neighbors at PI use somthing with an owl on it.  Others use an additional "STOP" sign on postings that have changed.
Do you guys still have the High High Radiation Areas, or the Strange Areas?  Those were kind of cool.

Does this muddy the water for you?  It should.  What works elsewhere will probably not work for you.  "Benchmarking" (a term I hate with every fiber of my being) only works when you remember that you aren't going to find the perfect answer in someone else's sandbox.  That's what they pay you for - aren't you glad??  If there were one definitive procedure fot Rad Protection that covered all plants, there wouldn't be any need for intelligent people to do this job.  Basically, one RPM and an army of monkeys could cover the whole country.

[Dustball]

Does this muddy the water for you?  It should.  What works elsewhere will probably not work for you.  "Benchmarking" (a term I hate with every fiber of my being) only works when you remember that you aren't going to find the perfect answer in someone else's sandbox.  That's what they pay you for - aren't you glad??  If there were one definitive procedure fot Rad Protection that covered all plants, there wouldn't be any need for intelligent people to do this job.  Basically, one RPM and an army of monkeys could cover the whole country.

Thanks for the insight Beercourt.  I hear you loud and clear on a few of the items.  One procedure for all of us RP's would take away our abilities to actually do some occasional thinking.  I don't mind trying to make things better, but it's tough to always convince everyone that a particular answer is "better".   Benchmarking isn't a bad thing.... it's the proceduralized follow up that's going to hurt. 

[RAD-GHOST]

We have always done it that way! 

I believe that is your first and prime obstacle to over come!

[SloGlo]

an ole thumb rule from back in the day; if it's posted as a lhra, then it had better be locked or an hp in attendance.  befour yinz all start, i know about flashing lights 'n udder disco signs.  they are all fine 'n dandy, but when the thumb rule is followed, the fluff is good for show and not for citations 'n other write-ups.

[cairnit]

Dustball.........are you guys still using lead blankets for all of your shielding needs? If so, you may want to look into the hard shell insulation that wraps around the pipes. It can also take the plase of insulation. May help in the drywell but temperature COULD be a limiting factor.
We used some we called RADCLAD in containment at Oconee but you can find some others through the search engines.

[stownsend]

Quote from Beercourt "They are constantly getting LHRA violations for a barricade being left down or a dead light."

How about a warning strobe light on 110 with a battery back up.
If not already available someone should look into having one manufactured.Cheaper than a violation.

[Already Gone]

Those go dead even more often than the battery-only ones.  Problem is, nobody ever checks them like you would if you were changing batteries on a regular basis.  110 goes out (or gets pulled by a worket who needs to plug in a tool) battery lasts 4-8 hours, and then it dies.  Even if you catch it one minute later, you are technically still in violation.

[workinman]

Dustball,  although I work at a PWR we recently found out the hard way that all of a sudden out RHRA (aka LHRA) controls were deemed unacceptable by the residents even though they had been in place for all the previous inspections.  Following the NOV's we benchmarked several utilities both PWR and BWR and found we were consistent with industry controls.  Not at all to say that this topic is viewed differently region by region? The NRC has recently tightened it's tolerance for HRA >1000 controls and it seems things are about to change not only in the USA but the boys across the pond are also researching this issue!  Beercourt had some great comments about the flashing lights, although they may be deemed acceptable they are not failsafe which seems to be the way of the future as painful as it may get.  Might I recommend some light reading---Reg guide 8.38 Control of HRA's/VHRA's.  The reg's offer many alternatives but if your sites technical specifications require specific controls then that's where the rubber meets the road! 

[Dustball]

Workinman,

Loud and Clear.  We have been questioned quite a bit lately by regulators in regards to several of our posted areas.  On the TB floor we have a 10ft block wall that was being questioned as adequate protection from entering a LHRA.  A simple step ladder and they are over the wall.  I heard snow fencing is no longer acceptable.  We never used snow fencing, but we do use steel fencing.  We had to make sure it was all adequate at what I believe was an 8ft height. (but our 10ft concrete wall was being questioned?!)  We finally changed our tech specs in the last 2 years to allow flashing lights.  But using them scares our management due to the issues Beercourt brings up.  With the changes and pressure management is getting recently they live there lives in fear.  So, a possible LHRA violation could mean they aren't working near home any more.  It's easy to say "push back on the regulators".  But that will only carry you so far.  I really appreciate everyone's feedback.  I received many emails and spoke to a good handful of plants.  What we are planning on doing is writing up a justification letter.  I'll use all of the feedback I've received.  Then when people ask why you do it this way we have something better than "That's the way we've always done it."  Right now, for the people following this, we are looking at only scaling our LHRA back to the hatch.  So the entire DW is posted as a LHRA.  We've found a couple others that do that.  Our RPM doesn't like the associated risks with going back inside to satellite areas.  I'm just the info gatherer not the rule maker.  I understand his concerns. (hot sumps, unidentified crud traps....) What I have found is that there is definetly more than one way to skin this cat.

[TENN-1]

This is an interestng post - Here's another two cents from a region III PWR. We recently underwent a peer eval and an INPO visit, both determined our LHRA boundaries were insufficient with respect to original construction of walls and gates. A site design was processed and the gates/fences that were questioned have been enlarged both in height and location. The locks changed from tumblers with a "like" key to a "unique" key for each area. We are also re-evaluating the practice of posting at the door vs the actual area. Our T/S lead us down the flashing light/constantly monitored path for unlockable areas. Nothing new here, just more of the same struggles you are experiencing.

We benchmarked other plants and found a variety of approaches: some stricter, some more lenient. Time will tell what is acceptable.

On a different note, we are now locking all HRAs too. The access key is maintained by RP for a more controlled entry then verified closed and posted after the exit - we do not accompany every entry, just monitor it after the brief.  This has it's own set of problems and we are working through them as they arise.

As they said in the "X" files - you are not alone. Good luck.

[Dustball]

Wow. Locking HRA's too?  All HRA's?  That sure would be interesting to say the least.  We're strapped right now for staff.   

[TENN-1]

That's right. We are locking all our HRAs with a "like" set of tumblers. It is interesting having Locked High Rad Areas and High Rad Areas that are locked. The verbiage was very confusing to the workers but now seems all too familiar. We too are strapped for people most days but we manage. The key is checked out to an RP when the work group receives the HRA briefing. The RP verifies, three-way communication of course, the responsibilities with the work group at the door and unlocks it allowing entry. Upon exit the work group calls us and we verify the closure, lock and posting. Several bumps during implementation but we are growing through it. If it applies at all to your question: we continue to post where the plant construction allows us the best control. Doors, gates, etc.. Very rarely do we post LHRA without a physical barrier such as a gate and if so, always with an RP as a guard. Good Luck!

[Dustball]

    Thanks, your setting the precedent for the rest of us!

I can see the ease of locking some of our HRA's.  Some are in rooms with doors.  But we have some that are just posted out and about in the plant.  Thinking about it.... we don't really make entries into these small posted areas on any type of routine frequency.  But we have no way to lock them right now.  We'd have to build enclosures around them.  Very interesting concept.  I'll make sure I don't reference this in my final benchmark draft! 

[PWHoppe]

I am pleased to see by TENN-1's response that the "Cookie Farm" is now at the forefront of doing things in Region III. For many years they were the exception to whatever anyone else was doing. Whether or not their way of control is the best way is always open to interpretation , but if it works for them, then good. What works at one plant may not work at another, either because of culture, physical contraints, or a myriad of other issues. Just keep plugging away, and take what you can use, and discard what you can't. Huddle up with the other folks in your Region and see what the inspectors have been OK with. Sort "getting your stories straight", then you'll all have a somewhat united front. Good Luck.