ML19253A476

Forwards Plans for Implementing ALARA Occupational Exposure at Operating Reactors,Per Reg Guide 8.8,Revision 3

ML19253A476
Person / Time
Site:	Crane
Issue date:	05/10/1979
From:	Office of Nuclear Reactor Regulation
To:	Jay Collins, Knighton G, Vollmer R Office of Nuclear Reactor Regulation
References
RTR-REGGD-08.008, RTR-REGGD-8.008 NUDOCS 7909100097
Download: ML19253A476 (10)

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SUBJECT:

ALARA OCCUPATIONAL EXPOSURE

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.i Attached are our plans for implementing ALARA Occupational Exposure at operating reactors, D

i.e., irnplementation of Regulatory Guide 8.8, Rev. 3.

This infor:,.ation ray be of use to you for the interim TMI technical specifications, f,I[

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n A Sample Method of Pre-plannino Radiation Work 5

to Maintain Occupational Radiation Exposures ALARA l

d Procedures developed for radiation exposure relat' d activities such as nomal e

operations, maintenance, inservice inspection, radwaste handling and refueling j:

o should be followed by workers to assure that work w;ii be perfonned in a manner f

11 that will provide ALARA exposures.

To accomplish this, radiation work should 4.

be pre-planned in the foJ10 wing manner:

jj Ic (1) The preplanning for any task

• that may cause an expected col-(

lective dose-equivalent exposure of <1 man-rem need only address the instructions specified in the radiation Work Pemit (RWP) lli which is normally required for all radiation work.

For relatively b

minor exoosure tasks, the RWP need only address general radiation j

protection (e.g., clothing requirements, stay time) and obvious

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instructions for minimizing exposures, e.g., documentation of f

high radiation sources (hot spots) in tbe work area.

(2) The preplanning for any task that may cause an expected collective 1

dose equivalent exposure of greater than 1 man-rem should specific-3 I

ally address ALARA concepts such as training, temporary shielding, lf.i use of special tools and any other techniques that are to be used to minimize exposures.

The Health Physics staff should state in

i the RWP (or other document) what techniques should be followed to I,

keep exposures ALARA.

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A task is defined as an identifiable work package for which a specific, general procedure or set of related procedures is prepared.

For example, i

a task would be the inspection and repair of a steam generator, inspec-4 tion or repair of BWR reactor vessel nozzles, reactor head removal, BWR 3

turbine overhaulf reactor water cleanup system, or MSIV repairs.

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1 (3) The preplanning for any task that may cause an expected col-l 1ective dose equivalent exposure of greater than 10 man-rems 1,

1-should (in addition to item (2) above) address the following:

1 l-(a) Historical data, if any, and the effectiveness of any pre-

,j 11-vious ALARA techniques used in similar type operations, e.g.,

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[f temporary shielding, decontamination; (b) Dose reduction alter-

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!I natives that were considered but rejected should be specif!cally j,I l'

documented with an explanation why these alternatives were not

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's taken.. from an ALARA basis, j

!I it (4) 'The preplanning for any task that may cause an expected col-

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I lective dose equivalent exposure of greater than 50 man-rems j

should (in addition to item (3) above) have, upon completion of jI!

the task, a written post-operacion evaluation that documents the

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degree of success (or failure) of ALARA techniques used for N

future reference.

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EEB Position Paper for Implementation of Regulatory Guide 8.8 i

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at Operati.10 Reactors 11 Introduction J

.i The Comission's regulations,10 CFR 20.l(c), state that licensees should make every reasonable effort to nuintain occupational exposures as.ow as is I

reasonably achievable (ALARA).

Consistent with this regulation, hn ;latory t

1 Guide 8.8, Revision 3, "Infomation Relevant to Assuring that Occupational J

Radiation Exposures at Nuclear Foxer Stations Will Be as low as Reasonably

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Achievable" was developed to provide specific information that should br-

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considered by nuclear power reactor applicants and licensees in their ALARA

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program.

Regulatory Guide 8.8 recomends that reactor licensees develop,

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I imr'ement, and nuintain a current description of a program for mintaining 1

exposures of workers as low as is reasonably achievable at nuclear power

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reactors (i.e., an ALARA program).

It is the staff's position that each re-actor licensee's program include, as a minimum, the following features in i

that pmgram to maintain radiation exposures ALARA.

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I Position Licensees should establish a pmgram to ensure that occupational radiation ex-l posures of workers will be kept as low as is reasonably achievable (ALARA).

The program should cover the guidance of tha position.

As appropriate. the program may encompass :xisting station documents such as plant Standard Opera-i ting Procedures and the Radiation Protection Manual.

The ALARA program should 1

2 incorporate, a. a minimum, the objectives of Regulatory Guide 8.8, Section C,

,l Regulatory Position, and the amplification of these positions as described

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below.

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C.1 Program for Maintaining Station Personnel Radiation Ooses ALARA

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All itens in Reg. Guide 8.8, C.l are considered appitcable to oper-i

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ating reactors. These items should be incorporated into the ALARA

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program.

q C. 2 Facility and Equipment Desien Features 1

All facility and equipment design features of R. G. 8.8, C.2 are ap-l plicable for all future plant modifications, including equipment re-(

placement and repairs and should be incorporated into the ALARA program.

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Many of the features of C.2 should be considered for installation at existing facilities.

Consequently, the ALARA program should include

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a design review of the existing facility to evaluate the effectiveness I

i and determile if the installation of the design features listed below

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No substantive design changes are necessary unless the

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change can prevent or substantially reduce tran-rem exposures wilich can-

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1 not be prevented or reduced by procedural measures and is consistent with the~ cost-effectiveness principle of the ALARA philosophy.

(SeeRegula-tory Guide 8.8, Paragraph C.l.d.).

The following features of C.2 should be considered for installation at operating reactors.

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(a)

(1),(2),(3)

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(1), (2), (Sb), (7), (9) f (c)

(ll. (2), (3)

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i Ili C3 Radiation Protection Procram f

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All items of Reg. Guide 8.8. C 3 are,spplicable to operating reactors.

J' These items should be incorporated into the ALARA program.

In addi-tion, the program should include the following specific comitments, d:

3.1 Radiation Work Pre-Planning 2

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Section 3a states that before entering radiation areas where '4nificant b

doses could be received, station personnel should have the beaei.it of.

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Y' preparations and plans to maintain exCosures ALARA while perfonning the required services.

In general, all radiation work should be pre-a planned; however, the utilization of resources should be proportion-j

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al to the expected benefit. Therefore, the arount of pre-planning j)',

for a certain tast should be allocated based upon the amount of radi-ation exposure expected.

For example, tasks which have. low expected collective exposures, i.e., less than one man-rem, need only address I

the basic ALARA instructions specified in the radiation work permit j

(RWP), e.g., survey results (documentation of hot spots to avoid),

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.5 stay t1mes, protect 1ve clotning.

For tasks witn greater collect 1ve 4

i exposures, the pmgram should require that the degree of pre-planning

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1 be keyed to the amount of expected exposurq.

At the lower exposure g

range, the licensee should at least assure that ALARA concepts such as additional training, temporary shielding and use of special tools have i'

been %1sidered i1 preparing the RWP.

As expected exposures for a task t

increase, so should the degree of pre-planning.

Pre-planning for

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higher exposure tasks should consider historical information, e.g.,

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previous man-rer.: exposure, radiation data, effectiveness of ex-i Pi.

E posure reduction methods.

In addition, higher exposure tasks should also consider alternatives such as additional shielding, i

flushing, use of mock-ups and decontamination.

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in pre-Effective use of historical information can be very useful d

Experi-Q planning future radiation work to maintain exposures ALARA.

h ence gained with various exposure reduction techniques in previous q

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radiation work is inYaluable for pre-planning future work, of the past experiences permits optimization of effective exposure

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reduction techniques and deletion or revision of ineffective ones.

Consequently, documentation of the results of various methods used

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f to reduce exposures should be perforned if the information would be pertinent to future work.

Like pre-planning, the degree of post operationdl documentation for a task should be proportional to the amount of exposure received from the task and the usefulness of that information for future work.

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Special ALAFA considerations should be made for mutine repetitive tasks which, when considered singly, may, not result in a significant exposure but when considered over the life of the facility may re-sult in significant collective exposures. is an example of one possible acceptable method of proportionalizing the degree of pre-planning with expected cellective exposures.

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.1 C.4 Radiation Protection Facilities

1 All items of Regulatory Guide 8.8, C.4 are applicable for operating f,

reactors. These items should be incorporated into the ALARA program.

,i As in C.2 above, no substantive design changes are required.

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SAMPLE LETTER - BC; DOR TO LICENSEE ON IMPLEMENTATION OF REG. GUIDE 8.8_

h, The Comission's regulations,10 CFR 20'.l(c), require that licensees should f

.,.l' make every reasonable. effort to maintain occupational exposures as low as is reasonably achievable (ALARA).

Consistent with this regulation, Regulatory j

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Guide 8.8, Revision 3. "Infomation Relevant to Assuring that Occupational d

I Radiation Exposures at Nuclear Power Stations Will Be as Low as Reasonably Achievable" was developed to provide specific information that should be L

considered by nuclear power reactor applicants and licensees in their ALARA h

1 program. Enclosure 1 is a copy of this guide.

Although the implementation g

n section of the guide does not specifically address operating reactors, all licensees should keep occupational radiation exposure ALARA.

Consequently, the staff is requesting that all operating reactor licensees develop, imple-j 1

ment and maintain a program for assuring that exposures to workers will be

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To this end we have identified specific portions of Regulatory Guide ALARA.

1 8.8 which we consider applicable to operating reactors ALARA program (see i, ).

l Section C.1 of the Regulatory Guide specifically states that reactor licensees I

develop a program for maintaining exposures to workers ALARA. The program shodld describe how the objectives applicable to. operating reactors of Regula-tory Guide 8.8, Section C, Regulatory Position, will be achieved.

Specific guidance is provided in Enclosure 2.

Consequently, we request that you pro-vide a written connitment within 60 days of the date of this letter to develop, implement and maintain an ALARA occupational radiation exposure program at your facility. Your ALARA program should be impicmented at your facility within six f

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months of the date of this letter.

The content and implementation of your i

program, as compared to Ecclosure 2, will be subject to review by the re-gional OIE inspector at any tfine after six months from the date of this s

it letter.

Regional seminars to answer specific questions on this subject are l

planned to be held in the near future.

Your regional office will contact d

you regarding details.

ff Branch Chief 00R l

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