ML20040G427
| ML20040G427 | |
| Person / Time | |
|---|---|
| Issue date: | 01/21/1982 |
| From: | NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | |
| References | |
| TASK-OP-123-4, TASK-RE REGGD-08.XXX, REGGD-8.XXX, NUDOCS 8202120325 | |
| Download: ML20040G427 (77) | |
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li ORAFT REGULATORY GUIDE 8.XX
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I982A I4 STANDARD FORMAT AND CONTENT e
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NUCLEAR POWER REACTOR LICENSEES
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o INTRODUCTION Proposed Section 20.208 of 10 CFR Part 20 will, when promulgated, require nuclear power reactor licensees to prepare and implement radiation protection program descriptions including effective measures for maintaining occupational radiation exposures as low as is reasonably achievable (ALARA).
Section 50.34(b)(3) of 10 CFR Part 50 requires all applicants for a reactor license to submit a final Safety Analysis Report (FSAR) including a discussion of the means for controlling and limiting radiation exposures and radioactive effluents.
The purpose of this guide is to provide to NRC licensees and operating license applicants guidance necessary to develop a Radiation Protection Program Descrip-tion. This guide also outlines the staff's recommendations for criteria, concepts, and implementation schemes that should be included as part of opera-tional radiation protection programs for power reactors that will be described by the program description.
It is not meant to constrain a licensee or applicant from writing a program description and developing a program that is different from the one most appropriate for the facility and organization being addressed.
It is not intended that current station Health Physics Manuals be rewritten to meet the format presented in this guide.
An effective radiation protection program consists of all actions planned or taken to protect workers and the environment, to monitor radiation and radio-active materials, control distribution and releases of radioactive materials, and keep radiation exposures to individuals within the limits of 10 CFR Part 20 and at levels as low as is reasonably achievable (ALARA), during normal opera-tions, anticipated operational occurrences and accidents.
It includes facility protection policies, trained personnel, ficilities, equipment, and implementing procedures.
It should not be assumed that the responsibility for radiation protection rests solely with the radiation protection group. All levels of management must have a strong commitment to radiation protection, and each worker must take personal responsibility for actions necessary to implement a successful radiation protection program.
Licensees should review advances in the field of radiation protection continually, and implement as standard practices those elements which improve radiation protec-tion programs and provide a standard of excellence above minimum regulatory requirements.
Licensees and applicants should also implement radiation protection i
programs based on the guidance of the NRC in such information as regulatory guides, circulars, notices, bulletins, and staff positions.
The importance of and need for a strong, well-structured, well-integrated radia-tion protection program at reactor facilities became strongly evident from each of the special evaluations of the Three Mile Island accident.
This has since 1
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3' been reinforced by the NRC's Health Physics Appraisal Teams' findings, which have identified significant deficiencies in the radiation protection programs of many reactor facilities.
These findings have been integrated into this guide.
The practical goal of requiring a Program Description which meets the intent of this guide is to assure that each facility has a strong, self-improving radiation protection program with full and active participation on the part of each individual, facility managers and supervisors at all levels, and the radiation protection organization.
This guide is structured by major program areas to outline first what is to be contained in a Program Description (Program Description Contents), next to provide the primary criteria which the staff will use to review those contents and determine acceptaoility (Acceptance Criteria), and finally to provide specific information (Procedural Details) and outlines of some successful program contents for use as a development baseline or standard of measure.
The elements contained in " Procedural Details" sections are not intended to be included in the general RADIATION PROTECTION PROGRAM DESCRIPTION, although these or similar elements should be considered in the development of an overall program and in writing implementing procedures. Since the document is tailored to especially address weaknesses and deficiencies noted in the Health Physics Appraisal Program, the extent of detail provided varies. A definition section (Appendix G) provides functional definitions for new terms and applications unique to this guide. A reference section'provides documents the staff will use as the basis for its recommendations and acceptance criteria.
This guide, which is derived from draft NUREG-0761, " Radiation Protection Plans for Nuclear Power Reactor Licensees," includes comments received during the NUREG-0761 comment period from Radiation Protection Managers, radiation protection personnel, health physicists, utility personnel and professional groups, and regulatory staff and management, and incorporate elements from significant Health Physics Appraisal findings and operating reactors lessons-learned experience. The guide is being issued in draft form to encourage public input into the development of this guide, particularlf with regard to
" Acceptance Criteria" and " Procedural Details" sections.
Comments received as a result of the comment period will be incorporated to provide a standard of excellence for all radiation protection programs. Additionally, the guide is being developed to establish criteria that the NRC staff intends to use in determining whether an applicant or licensee meets the requirements of 10 CFR Part 20.208 and 10 CFR Part 50.34(b)(3). The use of criteria different from those set forth herein will be accepted by the staff only if the substitute I
criteria provide a basis for determining that the above-cited regulatory I
requirements have been met.
l An applicant oc licensee should implement a radiation protection program based on the criteria and concepts outlined in this guide, the essential elements of which should be described in the facility Radiation Protection Program Description.
In many instances, this Program Description could take the form of a Station Health Physics Manual (but will not include implementing procedures).
Also in many instances, many of the elements of the Program Description are incorporated into radiation protection program implementing procedures at operating facilities.
The Radiation Protection Program Descriptions, therefore, will be a concise statement of the station's radiation protection policy and program, available to all station personnel so that they can understand the 2
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4 program and know their responsibilities regarding radiation protection, and what is required of them to implement those responsibilities, j
Proposed 10 CFR Part 20.208 is intended to require licensees and applicants for operating licensees to prepare, implement and maintain a Radiation Protec-tion Program Description in accordance with the instructions in this guide.
i The program description should be reviewed by the Plant Operations Committee along with all implementing procedures, except for those detailed operating procedures governing work activities exclusively applicable to or performed by Radiation Protection Group personnel.
t It is expected that onsite appraisals of a facility's Radiation Protection Program Description will be conducted by the NRC.
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General Guidelines for Program Description Development 1
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Program Description Content Each section of the guide provides general elements of radiation protection programs which are deemed essential for the development of a basic radiation protection program, the successful implementation of a program and the optimum protection of workers and the public.
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The Program Description should generally describe the commitments and i
policies which implement radiation protection functions at the facility.
All acceptance criteria should be met and any alternative proposals justified.
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A statement that the Program Description is adequately addressed in existing station procedures is not acceptable since a primary objective of requiring i
development of a program description is to assure that a comprehensive review and assessment of the facility radiation protection policies, procedures and commitments is conducted and summarized.
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Acceptance criteria j
This section provides criteria for determining an' acceptable level of l
performance of the described radiation protection functions.
In many instances specific guidance such as existing Regulatory Guides or ANSI Standards are cited as criteria.
In some cases the criteria derive from the analysis of Health Physics Appraisal Program findings and in particular reflect areas where deficiencies and weaknesses were noted to be widespread.
3.
Procedural Details l
This se:ction provides examples of successful and comprehensive implementa-tion of radiation protection functions. While these details may provide a sound basis for program development or redevelopment, the examples are provided primarily as examples of existing practices and as comparison standards for alternative program directions. Many of the examples of l-proven effective procedures were chosen for areas where weaknesses and deficiencies were observed in the Health. Physics Appraisal Program, 3
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Several comments on Draft HUREG-0761 expressed concern that the examples provided under Procedural Details might be construed to be the required and only acceptable methods of performing radiation protection functions.
The examples provided are selected from effective radiation protection practices and are not intended as the sole means of complying with the guide objectives. Variety and flexibility in implementing the provisions of this guide are expected.
Scope of Response The scope of licensee response and the resources required to develop a Radiation Protection Program Description are expected to vary widely depending en the completeness of the existing radiation protection program at a facility. Where a strong, broad-based and well-documented radiation protection program already exists, little effort other than consolidation may be required and the Program Description might consist of a several page document with attachments of existing program descriptions.
Program descriptions completed to date have ranged from 20 to 200 pages. Those facilities with weak or minimum requirement radiation protection programs may require a major effort to develop comprehensive ALARA-integrated programs comparable to better performances in the industry.
This major effort could include:
the development of policies, programs and procedures; hiring more and better-trained health physics professionals and technicians; establishing work planning systems; providing training for management and other staff; and providing improved facilities and protection equipment.
It is expected that 0.5 person years would be required to write a Program Description, and 2 person years per year per site would be required to implement such a program. Facilities with strong radiation protection programs have demonstrated manpower savings and efficiencies as a result of improved job planning, exposure reduction, worker training, and feedback of results into new activities. These reductions in overall facility manpower requirements have not been factored into the above estimates.
STANDARD FORMAT AND CONTENT DRAFT CONTENTS OF RADIATION PROTECTION PROGRAM DESCRIPTIONS FOR NUCLEAR POWER REACTOR LICENSEES TABLE OF CONTENTS Section Topic 1.
Management Policy 6
2.
Radiation Protection Organization and Functions 7
3.
Radiation Protection Training and Qualification 18 4.
Dose Control 22 5.
Radioactive Materials Control 30 6.
Surveillance 33 4
e 9
Section Topic Pa2' 7.
Instrumentation 38 8.
Review and Audit 41 9.
Radiation Protection Trend Analysis 43 10.
Radiation Work Practices 45 11.
Radioactive Waste Monitoring and Control 47 REFERENCES 48 List of Appendixes Section Page Appendi? A Example Qualification Standard for Radiation Work Training 53 Appendix B Example Content for a Basic Radiation Work Training Program 55 Appendix C Example Responsibilities of All Workers 61 Appendix 0 Example Qualification Standards for Radiation Protection Technician Training 62 Appendix E Example Content for a Basic Radiation Protection Technician Training Program 65 Appendix F A Sample Metnod of Planning Radiation Work to Maintain Occupational Radiation Exposures ALARA 75 Appendix G Definitions 76 Table List of Tables Page 2-1 Operations and Support Group Functions 10 2-2 Radiation Protection Manager Functions 12 2-3 Radiation Protection Engineering Functions 13 2-4 Radiation Protection Training Functions 14 2-5 Radiation Protection Monitoring / Surveillance Functions 15 2-6 Radiation Protection Services Functions 16 2-7 Corporate or Additional Radiation Protection Staff Functions 17 4-1 Control of Access to Spent Fuel Transfer Tube Areas 29 5
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Management Policy 1.1 Program Description Content The RADIATION PROTECTION PROGRAM DESCRIPTION should describe the facility manage-ment policy on radiation protection.
1.2 Acceptance Criteria The radiation protection policy should include management commitment to:
1.2.1 Assure that each supervisor implements his or her responsibility to integrate appropriate radiation protection controls into all work activities; 1.2.2 Assure that each individual working at the facility understands and accepts the responsibility to follow all procedures and to maintain his or her radiation dose ALARA. A list of typical worker responsibilities is included in Appendix C; 1.2.3 Comply strictly with regulatory requirements, *adiation exposure limits, and limits regarding release of radioactive materials; 1.2.4 Maintain a comprehensive radiation protection program to keep indi-vidual and collective radiation doses to workers below regulatory limits and as low as is reasonably achievable (ALARA),
1.2.5 Provide sufficient resources and manpower to accomplish the objectives of the radiation protection program.
- 1. 2. 6 Establish quantitative and qualitative annual goals for program improvement.
1.3 Procedural Details Each facility should have a management system for implementing its ALARA-integrated radiation protection program. The commitments for various levels of management should be described.
Examples of concrete efforts and commitments to ALARA are:
1.3.1 A formal scheduling and work planning system that provides for radia-tion protection reviews and inputs on routine, special, and outage work.
1.3.2 Training and orientation seminars addressing interactions and respon-sibilities of supervisors and managers in effecting a successful ALARA-integrated radiation protection program.
1.3.3 Development of program goals and the means to track these goals, with provisions for incentives for meeting or exceeding these goals.
1.3.4 Development of criteria which define radiological work and which provide guidance for how systematic review and support of radiological work is conducted at the facility.
1.3.S' Development and enforcement of management actions to be taken where workers or supervisors fail to adhere to radiation protection program policies.
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a 2.
Radiation Protection Organization and Functions 2.1 Program Description Content This section of the Program Description should describe the plant organization, showing the titles and radiation protection functions and minimum staffing of each major position / function in the radiation protection organization and the operating and support organization during power operation.
Any differences in organizational structure, interface, or responsibilities during accidents or outages (such as the use of contractor services) should be similarly shown.
This section should also explain the methods used to implement management and radiation protection agreements with contractor services that process or handle radioactive materials for the facility outside the normal plant organization or perform functions integral to the radiation protection program.
Contractor services might include contaminated laundry processing, offsite repair of con-taminated equipment, radiography, thermoluminescent dosimetry (TLD) processing, instrument calibration, bioassay services, training of construction and main-tenance workers, and training of contract radiation protection technicians.
There should also be an organizational chart and written discussion which describes the radiation protection organization.
2.2 Acceptance Criteria The organizational structure should show clearly that the Radiation Protection Manager (RPM) has direct access to the Plant Manager in matters of radiation protection and is independent of operating divisions.
(See NUREG-0731, " Guide-lines for Utility Management Structure and Technical Resources," Regulatory Guide 8.8 Section C.-l.b.(3), and NUREG/CR-1280, " Power Plant Staffing").
The radiation protection organization should include:
2.2.1 The functions of individual components within the radiation protection organization.
(Note that radiation protection personnel should not be assigned multiple specialties, e.g., chemistry or instrument control, unless fully qualified in each specialty by virtue of training, experience, testing, and retraining).
Adequate staffing should be provided to effectively maintain and meet overall program goals.
The functional description should clearly specify that senior radiation protection technicians have the responsibility and authority to stop work or order an area evacuated (in accordance with approved procedures) when, in their judgment, the radiation protection conditions warrant such an action and such actions are consistent with plant safety.
It should be clear that only the Piant Manager, radiation protection management, or their designated representatives on backshifts, can overrule such a stop-work order.
2.2.2 Radiation protection functions of operations, engineering, and support organization (managers and supervisors) other than the radiation protection organization.
2.2.3 The minimum staffing, by shift, for each component in the radiation protection organization, specifying the numbers in terms of professionals, foremen, 7
A senior and junior technicians, and technicians in qualification.* Enough radiation protection personnei should be assigned to the station to ensure that all routine radiation protection functions can be completed in a timely manner and that all radiation protaction requirements can be met during normal operations, antici-pated operational cccurrences, unanticipated radiological events, and major accidents. Guidelines and criteria for both intermittent and full-time work coverage by radiatioa protection technicians and supervisors should be established and incorporated into radiological work procedures.
Sufficient staffing should be provided to assure that work is covered in accordance with these criteria for both normal operations and outages.
Plans for augmented staffing during outages and accidents should be described. As a minimum, there must be an individual with the qualifications specified in Regulatory Guide 1.8 for RPM assigned to the site. There should be a qualified substitute for the RPM available to the site when the RPM is not available for extended periods due to illness, travel, or vacation.
For short-term absences, a substitute qualified to carry out the RPM's emergency duties should be designated.
In addition, an individual qualified as a radiation protection technician (senior technician), as specified in Regulatory Guide 1.8, or a technician qualified in accordance with a qualification program specified in technical specifications should be onsite when there is fuel onsite after initial operation.
2.2.4 Those functions that are performed by contractor services, such as dosirastry or instrument calibration, identifying the contractors responsible (by position), specifying their responsibilities and how they meet the standards of this guide.
2.2.5 Those functions that are performed by a corporate or centralized licensee organization, identifying the responsible individuals (by position) and specifying their responsibilities.
2.2.6 Functions and assignments during emergencies.
(See NUREG-0654,
" Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Procedures in Support of Nuclear Power Plants).
Reference to an NRC reviewed Emergency Plan is acceptable.
2.3 Procedural (Functional) Details Figure 1 shows conceptual station radiation protection functions.
Table 2-1 shows facility management and supervisory functions.
Tables 2-2 through 2-6 show the functions for each group in the conceptual radiation protection organiza-tion. The organization and staffing may vary (with plant, age, size, and number of operating units) from plant to plant, but within the framework of a given organization, all essential functions of the organization must be specifically designated and assigned.
Table 2-7 lists examples of functions that may be assigned to the corporate or additional radiation protection staff.
The guidance outlines an idealized separation of radiation protection functions into training, engineering, monitoring, and services, but does not intend that RPMs be overburdened with the plethora of details associated with each function.
Successful management practices may dictate that the actual performance of many
- See Appendix 0 for criteria for junior and senior technicians and technicians in qualification.
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functions be delegated, tio subordinates (e.g., data compilation for trend analysis, work support scheduling, design or modificatior, reviews).
Local guidance should clearly indicate performance responsibilities and overview responsibilities.
RPMs must have sdequate) time for technical management, program overview, and s'
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1 Figure 1 Conceptual Radiation Protection Functions and Interfaces
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Corporate Staff
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Corpor' ate Radiation Plant Manager Protection (Table 2-7) 4 (Table 2-1) h (RPM] (Table 2-2)
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Radiation Radiation Radiat. ion '
Radiation r
Protection Protection Protection Protection Training
- Engineering Monitoring Services *
(Table 2-4)
(Table 2-3}
(Table 2-5)
(Table 2-6) s s,
This figure is intended to outline general radiation; protection functicns and is not necessarily a recommended organizational chart. s.The functions are generally distributed throughout a facility's admini' trative organization, and s
this may vary with the size of the facility and nuclear commitment of the utility.
The functions described in the various Tables should be correlated with the particular facility's actual organization to assure that all functions are clearly assigned and performed.
"Some of these functions may be within other organizations at some facilities (e.g., cour ting room - chemistry; instrument calibration - instrument and control; radiation protection training - training department).
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Table 2-1 Operations and Support Group Functions 5
4 Plant Manager Implement corporate radiation protection policy throughout operational organization.
Ensure overall commitment in plant organization to the Radiation Protection Program, the ALARA concept and radiation protection goals.
Interact with and support Radiation Protection Manager on implementation of the Radiation Protection Program.
Provide support to facility radiation protection /ALARA improvement and deficiency identification program.
Establish goals and objectives for radiation protection /ALARA aspects of the operations program.
Analyze and report formally the causes, concerns, and corrective actions associated with maintenance and operational radiation protection incidents.
Operational Shift Supervisors Provide direct interface with radiation protect'on foremen / supervisors in routine operations, corrective actions for radiation protection problems (such as spills), and in resolving radiological deficiencies associated with operations, procedures, systems, equipment, and work practices.
Notify radiation protection personnel promptly when radiation protection problems occur or when changes in facility operations or status may affect the radiation protection program or radiological conditions of the facility.
Engineering Group Manager Provide engineering work documents with radiation protection incorporated.'
Interact with Radiation Protection Engineering to assure the quality of radiation controls incorporated in work documents and assure that design changes and modifications receive a radiation protection /ALARA review.
Support facility programs for system and design changes for improved radia-tion protection.
Maintenance Supervisor Interface with radiation protection group to assure adequate work and proce-dural review and radiation protection technician support for both normal operations and outages.
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Table 2-1 (Continued)
Interface with the radiation protection group for preparation for maintenance and training.
Support Group Managers
-Ensure adequate numbers of personnel are properly trained to perform planned work.
Schedule radiation protection training time for worker qualification, requalification, advanced skills training, and proficiency training.
Support the RPM
.'n implementing and supporting the facility Radiation Protection Program.
Planning / Scheduling Manager Coordinate facility scheduling and temporary personnel requirements with RPM and other facility managers for the conduct of radiation protection technician (RPT) training, worker training, subcontractor training, and other radiation protection training.
Arrange for temporary personnel in conjunction with RPM to assure proper RPT monitoring of planned work for normal operations and outages.
First Line Supervisors Ensure that personnel assigned to work in radiation areas or with radioactive material are properly trained and briefed.
Identify radiation work procedures and practices that need improvement and arrange for upgrading.
Identify the optimum number of workers necessary to complete tasks involving occupational exposure.
Assign tasks to distribute radiation doses among exposed personnel to minimize the likelihood of overexposures and to maintain individual and collective doses ALARA.
Ensure that workers are prepared for tasks with tools, equipment, and training to minimize work time in radiation areas, Ensure that controlled area work has been reviewed and approved by the radiation protection staff prior to starting work and whenever the nature of the work or radiological conditions may have changed significantly.
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s Table 2-2 Radiation Protection Manager Functions Manage plant radiation protection program including establishing and implementing policies, and preparation, revision, and updating of the Radiation Protection Program Description.
Provide radiation protection input to facility design and operational planning (e.g., as a member of the Plant Operations Review Committee).
Follow and analyze trends in radiation work performance of station personnel, contamination and exposure control, and job exposures, and take necessary actions to correct adverse trends.
Assign organizational emergency duties and coordinate with site Emergency Plan.
Identify and review causes, concerns, and corrective actions of incidents associated with radiation protection.
Provide radiation protection overview of the programs and training for radioactive waste processing and control.
Provide technical expertise in all aspects of radiation protection.
Interface with operations and support group managers to establish and track ALARA goals and determine program success.
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Table 2-3 Radiation Protection Engineering Functions Review radiation work documents for jobs potentially involving significant doses and exposure to contamination and airborne radioactivity.
Review maintenance procedures for adequate radiation control.
Review plans for temporary shielding.
Review design of special tools that reduce job time or separate workers from radiation sources.
Provide technical analysis support of plants for radiation protection problems.
Arrange mockups for specific tasks where practice could significantly reduce doses.
Evaluate the effectiveness of the respiratory protection program.
Conduct audits.
Provide radiation protection support for accident evaluations (See NUREG-0654" Criteria for Preparation and Evaluatica of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants").
Plan drills.
Evaluate radwaste systems and procedures for radiation protection controls, ALARA objectives and volume raduction efforts.
Review designs and facility modifications which have radiological impact.
Estimate collective (person-rem) dose for specific tasks.
Write health physics procedures, modify as appropriate to incorporate '
ALARA considerations and lessons learned from experience.
Evaluate and select radiation protection instrumentation, calibration equipment and protective equipment and materials.
Develop and implement radiological work practices, procedures and engineering controls.
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4 Table 2-4 Radiation Protection Training Functions Develop and maintain qualification, training, and retraining programs, and program materials in radiation protection, with separate attention to emergency 6 raining.
Provide an additional capability to train Emergency Plan support personnel in the event of an accident.
Maintain Radiation Protection Manuals.
Provide support for the radiation protection aspects of all maintenance staff training programs.
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Table 2-5 Radiation Protection Monitorina/ Surveillance Functions Implement operational ALARA considerations in all monitoring functions.
Maintain and calibrate fixed and portable monitoring instruments.
Observe work practices to assure compliance with radiation protection and related procedures.
Assess radiation protection conditions and establish Radiation Work Permit (RWP) requirements for each activity in radiation areas, airborne radio-activity areas or controlled surface contamination areas.
Provide radiation protection assessment field teams for Emergency Plan support.
Assure adequate access control for posted areas.
Identify and post radiation, high radiation, lethal dose, and restricted areas, controll ed surface contamination areas, airborne radioactivity areas, and radioactive material areas.
Conduct radiation and radioactivity surveys, and keep accessible records.
Provide control over the identification, storage, mcvement, and shipment of radioactive materials, including radioactive sources.
Maintain environmental monitoring program (may be a corporate or contractor responsibility).
Identify, document, analyze, report, and follow up on deficiency trends noted during monitoring and surveillanca.
Provide workers and supervisors with direct access to radiation protection expertise through work briefings and routine on-the-job contacts.
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Table 2-6 Radiation Protection Services Functions Dosimetry Maintain and calibrate personnel monitoring equipment.
Provide adequate and appropriate monitoring equipment for normal operations, maintenance /cutages, and emergency conditions.
Provide whole-body counting and other bioassay services.
Maintain complete and readily accessible exposure records, maintained by job function to allow feedback into job planning.
Provide routine TLD readout / film processing capability.
Counting Room Operations Provide necessary services to determine quantities of gross or specific radionuclides in samples, as necessary.
Instrument Calibration Environmental Monitoring Radioactive Waste Control
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Provide necessary services to assure that radioactive waste is properly processed and packaged for shipment from the facility.
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Table 2-7 Corq_ orate or Additional Radiation Protection Staff Functions Coordinate review of major design changes (and design of new facilities).
Prepare long-term collective (person-rem) dose evaluations / projections to determine dose trends for ALARA planning and analyze the success of prior ALARA objectives.
Review relevant experience at other nuclear power plants and apply learned improvements.
Appraise in plant radiation and contamination control.
Conduct radiation protection inspections to evaluate the adequacy of the facility radiation protection program and technical capability of the staff.
Review plant operating problems, including ALARA aspects.
Recommend generic design solutions to specific problems.
Provide basic guidelines for implementation of ALARA concepts in all aspects and phases of facility construction and operation to implement corporate policy.
Coordinate such activities as personnel dosimetry, environmental monitoring, bioassay.
Review evaluations of exposures or releases in excess of regulatory limits.
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3.
Radiation Protection Training and Qualification 3.1 Program Description Content This section should identify, describe, and discuss the facility radiation protec-tion training, qualification, and retraining programs, and describe selection of personnel for these programs.
- 3. 2 Acceptance Criteria Training, qualification and retraining programs should be formally developed and implemented for the following functions and categories:
3.2.1 General employee training for restricted area access.
3.2.2 Radiation work training for access and work in radiation and/or high radiation areas, airborne radioactivity areas, and controlled surface con-tamination areas.
3.2.3 Respiratory protection training.
3.2.4 Radiation Protection Technician training.
3.2.5 Radiation Protection Supervisor / Foreman / Professional training.
3.2.6 Radiation Protection Manager training.
3.2.7 Emergency Plan training.
3.3 Procedural Details For the training categories listed, the Program Description should utilize specific implementing criteria such as the folicwing:
3.3.1 General employee training for restricted area access conducted for all facility personnel, visitor / transients, and subcontractors in accordance with:
(a) Regulatory Guide 8.27, " Radiation Protection Training ?vr Personnel at Light-Water-Cooled Nuclear Power Plant Personnel," (March 1981)
(b) Regulatory Guide 8.29, " Instruction Concerning Risk from Occupa-tional Radiation Exposure," (May 1981)
(c) Regulatory Guide 8.13, " Instruction Concerning Prenatal Radiation Exposure," (November 1975) 3.3.2 Radiation work training conducted for all facility personnel, visitors /
transients, and subcontractors who routinely have access to or work in radiation and/or high radiation areas, airborne radioactivity areas, and controlled surface contamination areas as follows:
(a) The licensee should implement a basic radiation work practices training and qualification program (see Appendix A for an example of a com-prehensive program).
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(b) A system for prompt instruction in changes in requirements, proce-dures, and equipment should be established to keep each worker's training current.
(c) Separate and detailed instruction in advanced radiation work practices, consistent with Appendix A, should be provided for those workers involved in maintenance or operations which require work in contamination control devices or areas; grinding, cutting, welding, or similar operations involving highly radioactive systems, components, or piping; and special complex radiation work which involves skills and training beyond that outlined for basic rcdia-tion work training. This would be an extension of basic radiation protection training which should be commensurate with expected radiological hazards.
(d) To be considered acceptable, training conducted at other facil-ities should meet the criteria outlined in this guide and should be so verified through quality assurance reviews of training and documented by such means as certification records or formal reciprocal agreements.
In such cases, only specific facility-oriented training as established by the Radiation Protection Manager would be necessary for previously trained individuals, provided all other timing and verification criteria are met.
(e) Training personnel should evaluate the test results of personnel who fail exams to determine if additional training is needed, if limited duty assignment is appropriate, or if disqualification is necessary. A formalized upgrading / retraining program should be established.
Pass / fail criteria for each course should be established.
3.3.3 Respiratory protection training should be conducted in accordance with:
(a) The requirements of 10 CFR 20.103(c)
(b) Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection" (c) NUREG-0041, " Manual of Respiratory Protection Against Airborne Radioactive Materials" This should include formal, documented training, with provisions for periodic requalification or reevaluation of training to verify that proficiency is maintained.
3.3.4 (a) Radiation Protection Technician training, qualification, and retraining should contain comprehensive elements such as those outlined in Appendices 0 and E, and should encompass both facility and subcontractor personnel assigned as Radiation Protection Technicians at the facility. Only an individual fully qualified as a Radiation Protection Technician may:
(1) Independently perform surveys or evaluations used to demonstrate compliance with regulatory requirements and determine the extent of radiological hazards; (2) Review sucn surveys performed by others; 19
(3)' Independently issue, sign or amend RWPs.
J (4) -Independently authorizes radwaste releases, f
Individuals qualified in radiation protection procedures-(as per technical specifications) may perform these functions on backshifts if their work is promptly reviewed by a fully qualified radiation protection technician or supervisor, the review taking place no.later than the next day shift.
Personnel performing limited aspects of Radiation Protection Technician Work, such as a Control Point Monitor, should not be considered Radiation Protection Technicians, and may receive specific, task-related training in a specialty program detailed and documented a manner such as advanced radiation work training of Appendix A.
Similarly, contractor personnel other than Radiation Protection Technicians should receive training appropriate to their responsibilities. Training conducted at other facilities may be considered acceptable'if it was conducted and documented in accordance with the provisions of this report (or a similar report developed by industry and approved by the NRC) and is qualitatively acceptable to the Radiation Protection Manager and is so documented.
(b) Specialized training should also be conducted for the following radiation protection specialists /special skill functions:
1.
Dosimetry Technicians 2.
Respiratory Protection Specialists 3.
Bioassay Technicians 4.
Counting Room Technicians 5.
Use of dose rata meters and swipes by Non-Radiation Protection To:hnicians 6.
Instrument Calibration Technician 7.
Environmental Monitoring Technician
- 8. Radiological Service Technician (Radwaste) 3.3.5 Radiation Protection Supervisor / Foreman / Professional training should specify the formal training and qualification criteria for such first-line supervisors and professionals to include:
(a) Initial qualification as a Radiation Protection Technician, or equivalent field monitoring experience, or education and site-specific training.
(b) Biennial requalification or recertification, continuous training and reexamination (practical, oral, and written) on selected aspects of the Radiation Protection Technician training and additional training approved by the Radiation Protection Manager (e.g., systems, current developments).
(c) Training in the supervisory and technical aspects of radiation protection engineering, monitoring, training, and dosimetry.
1-20
_ _ _ - - ~,.
(d) Facility design; organizational structure.
3.3.6 P.adiation Protection Manager training and qualification should include:
(a) Verification of prior education and experience as recommended by Regulatory Guide 1.8 (Note that exceptions are subject to NRC staff review and approval).
(b) An orientation on the specific design and systems of the facility and management organization and functions at the facility.
(c) Specific facility-oriented radiological centrols training.
(d) Training in specific emergency plan responsibilities as outlined in NUREG-0654, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."
(e) Periodic professional radiation protection training in the form of refresher courses, retraining, or continuing education which enable the Radia-tion Protection Manager to keep abreast of current developments in this field.
3.3.7 Emergency Response Plan Training shvuld be integrated with all racia-tion protection training and for all facility personnel in accordance with NUREG-0654, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."
3.3.8 All training-related records should be formally documented and made easily traceable.
Criteria for extension of training (e.g., during an outage) should be developed.
3.3.9 For each of the training categories listed, implementing procedures should describe the standards for qualification and the training program content.
The description should contain elements as detailed in the Appendices listed below (or their equivalents):
Appendix A Example Qualification Standards for Radiation Work Training Appendix B - Example Conten't for a Basic Radiation Work Training Program Appendix C - Example Responsibilities of All Workers i
Example Qualification Standards for Radiation Protection Technician Appendix D l
Training Example Content for a Basic Radiation Protection Technician Training Appendix E Program 21
4.
Dose Control 4.1 Program Description Content This section of the Program Description should describe a dose control system for evaluating, controlling, monitoring, and recording doses.
The Program Description should outline those programs, procedures, and policies which assure that occupational doses are within regulatory limits and that individual and collective occupational doses are ALARA.
4.2 Acceptance Criteria For this section of the Program Description to be acceptable, the following elements or equivalent alternatives should be discussed in the Program Description.
4.2.1 ALARA Coordination.
A qualified pro.essional individual (or committee) should be assigned the responsibility and authority to coordinate ALARA development and implementation, including risk benefit coordination of tasks (See Regulatory Guide 8.8, Section 8).
The actual implementation of specific.! ARA actions should be.vf a each individual line manager. ALARA a
considerations should, where appropriate, be incorporated into all aspects of daily work (See Section C.1.b of Regulatory Guide 8.8) through a formal work control system.
4.2.2 Radiation Protection Evaluations of Facilities, Desian, Equipment, and Procedures for ALARA Applications. All aspects of station operations should be reviewed to determine methods to keep exposure ALARA. These ALARA elements.
should be considered by appropriate line management in the planning of tasks.
Within the Program Description for a station, considerations applied in Radiation Protection ALARA reviews should include implementation of appropriate sections of Regulatory Guide 8.8 (see Section 4.3.1).
Each facility should have an administrative system and managerial guidelines for performing ALARA reviews and incorporating ALARA procedures into work planninc,.
1 4.2.3 Administrative Dose Control. There should be an administrative dose control system under purview of line management, which controls both planned and actual doses to individuals as they progressively (incrementally) approach limits of 10 CFR 20.101 or administrative limits established for the facility.
It is considered good practice and recommended by the staff that doses to personnel be maintained to the NCRP/ICRP/ EPA recommendation of 5 rems /yr.
Consideration should be given by licensees to voluntarily controlling individual doses to 5 rems /yr.
Such a practice is to be used to reduce the risk to those small number of people who may exceed this criteria while providing a-tool to reduce collective dose to the plant workers. The RPM should require review of all individual doses that exceed or are expected to exceed a specified investiga-tion level (for example 1.5 rems annual whole-body dose).
These approvals should be based on a determination that the dose to be received by the individual is ALARA.
Individual operations and support group managers, supervisors, and foreman should all strive actively to keep individual and group exposures at a minimum and-to keep the number of workers exposed at a minimum. Guidelines and policies governing emergency exposures and overexposures should be outlined.
This dose control system should be implemented via the Radiation Work Permit (RWP) system.
22
1 i'
l 4.2.4 ~ Dose Tracking By Job.
An accountability system that records doses for task analysis and ALARA dose reduction should be described.
This system should provide workers with their current dose status frequently.
For example, during outages this system should provide daily updates of worker doses.
Computerized systems are an effective means of providing such information.
y This dose tracking should be implemented via the RWP system.
i 4.2.5 Radiation Work Permits.
Radiation Work Permit (RWP) criteria should be specified.
The RWP should summerize the radiation protection controls established as part of job planning and which have been incorporated into procedures and should be detailed enough to deal with changing (or potentially changing) radiological conditions expected during the course of 4
the work. Where RWPs are used to record dose from tasks and/or radiological conditions encountereo on the job, these RWPs should be used as a data source for trend analysis.
For every task involving radiation work, sufficient j
radiation protection controls should be specified to meet all Federal and licensee requirements. Acceptable radiation work practices should also be described and sufficient Radiation Protection Technician coverage assigned to assure worker protection and ensure ALARA worker exposure. To the maximum extent possible, work procedures or engineering work tasks which fully l
incorporate radiation protection. controls should be developed and should specifically identify work steps which require Radiation Protection Technician coverage.
Section C.3.a(8) of Regulatory Guide 8.8 outlines information that should be included on an RWP.
RWPs should show or reference dose rate and f
contamination level maps so that workers can spend minimum time in the highest 1
dose rate locations.
Dose rate maps should identify localized high dose rate areas (hot spots).
The RWPs should document all information legibly in a clear, l
easy to comprehend format, and be posted in a readily accessible location.
4.2.6 Collective Oose Goal Approvals for Tasks. -Tasks that involve significant total exposure (see Appendix F for an example? should be reviewed by higher. level management.
Criteria for RPM or other management approvals for tasks involving specified collective doses should be established.~ These reviews and approvals should establish collective (person-rem) dose goals for such tasks. Appendix F contains an example of acceptable criteria for such reviews.
4.2.7 Monitoring for Gamma Dose.
Film badges and/or TLDs should be used to meet the personnel monitoring requirements of 10 CFR Part 20.
Situations where direct-reading pocket chambers should be worn in addition to TLDs or film badges to provide workers with dose tracking capability should be described.
4 Pocket chambers should be selected in accordance with Regulatory Guide 8.4,
" Direct Reading and Indirect Reading Pocket Dosimeters." Personnel monitoring devices should be worn on those parts of the body where radiation surveys show the potential for maximum exposure (e.g., chest, head).
In those cases where multiple devices may be required (e.g., steam generator entry-head, chest, gonads), the criteria for the use of multiple whole-body dosimetry should be described. Appropriate-monitoring devices should be worn on extremeties as required to meet the criteria of 10 CFR 20.202, and procedures for the evalua-tion and use of extremity dosimetry should be described. Otherwise, whole-body personnel monitoring results should be used as the limiting dose.
4.2.8 Monitoring for Neutron Oose. Monitoring for neutron dose should j
be in accordance with Regulatory Guide 8.14, " Personnel Neutron Dosimeters,"
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s Revision 2, (with the exception of the use of film badges for neutron dosimetry in nuclear power reactors) or an equivalent alternative should be described.
In cases where correction factors for personnel monitcring devices may.be required based on the neutron spectrum (e.g., albedo dosimeters),' neutron spectra in controlled areas around reactors should be determined so that appropriate correction factors may be applied to the read-out.
4.2.9 Monitorina for Beta Skin Dose.
Film badges and/or TLDs.should be used to monitor the dose to the skin of a person's body. The dose due to skin contamination should be calculated in accordance with methods in LA-4558-MS,
" Surface Contamination:
Decision Levels" (especially Section III.A) or Medical Internal Radiation Dose (MIRD) Pamphlet No. 11 published by the Medical Internal Radiation Dose Committee of the Society of Nuclear Medicine or an equivalent alternative should be specified.
The dose recorded should be the highest Jose received by any one square centimeter of skin.* Averaging techniques, such as those based on a suitably small probe area such as 15 cm3 may be acceptable for uniform low level skin contamination.
Levels below which dose calculations are not performed should be justified. Special procedures and guidelines for precluding beta exposure to the eyes and skin should be described.
4.2.10 Monitoring Surface Contamination Areas. The program to control and contain the spread of contamination (alpha, beta, gacma) should include use of engineering controls to limit airborne radioactivity and prevent the spread of radioactive materials to and buildup in uncontrolled areas. The Program Description snould specify contamination limits for demarcation of
" Controlled Surface Contamination Areas" (acceptable limits are listed in Regulatcry Guide 1.86, " Termination of Operating Licenses for Nuclear Reactors,"
or equivalent alternatives may be detailed), where a Controlled Surface Con-tamination Area is an area of loose radioactive surface contamination where acceptable limits are exceeded. Methods of posting and control, such as use of barriers and tape boundaries, where contamination levels exceed licensee.
control levels should be described.
Levels selected should be at or near background levels, detectable with available instrumentation, low enough to preclude buildup in the environment, and low enough to preclude an airborne radioactivity problem. The Program Description should also specify what protective clothing will be used in Controlled Surface Contamination Areas at licensee designated levels of contamination.
4.2.11 Controls For and Monitorina For Intake of Radioactivity into the Body.
Th.a air sampling program should provide measurements of concentration of radionuclides representative of workers' breathing zones in order to determine and control workers' intakes in accordance with 10 CFR 20.103. The control of workers' intakes should be implemented by the RWP system. The bioassay program should include baseline information for the internal monitoring program and should be in accordance with Regulatory Guide 8.21, " Application of Bioassay of Fission and Activation Products," or should be based on equivalent alternatives. A quality control program for the bioassay program should be established.
Requirements for engineering controls which minimize potential intake should be described.
Controls for alpha emitters should also be described.
- NCRP Report No. 39, " Basic Radiation Protection Criteria, "Section 208, ar.d ICRP Publication 26, " Recommendations of the, International Commission on Radiological Protection," Paragraph 183.
24
o 4.2.12 Quality Control for Oosimetry Badges. The quality control program for TLDs and film badges should meet the performance criteria of ANSI N13.11
" Criteria for Testing Personnel Dosimetry Performance."
4.2.13 Area Posting. Areas which are controlled because of radiation protection considarations should be identified and provisions made for routine review of their status.
Provisions for posting and control in accordance with 10 CFR Part 20.203 or technical specifications should be described in procedures.
The primary function of posting should be to inform workers of the radiological status and potential hazards in the work area.
General posting of large areas without specifying variations within those areas does not serve this function, nor does it enable workers to maintain exposures ALARA.
4.2.14 Radiation Work Practices.
Standarized procedures, engineering
~
controls, and practices which are frequently used to effect dose control measures should be established to provide consistent and effective field implementation of these measures.
Example of topics typically considered for work practices are provided in Section 10.
4.2.15 Use of Current Survey Information for Dose Control. The Program Description should describe how current surveillance information is used to establish dose control for work and how this is documented (e.g. RWPs).
Requirements for special surveillance prior to, during, and after tasks should be established.
Provisions for comparison of projected doses and actual doses received in performing special tasks should be included.
Provisions to provide current survey information to workers entering controlled areas should be described.
4.3 Procedural Details The following guidarce is provided for implementing the acceptance criteria into specific procedures for dose control:
4.3.1 ALARA.
Tne ALARA program should include the elements of Regulatory Guide 8.8 including the following work practices:
(a) Use of temporary or permanent shielding (see R.G. 8.8, Section C.2.b. (1), (2), (4), (5), (6), and (10).)
(b) Use of special tools, features chat permit prompt accessibility, remote monitors, or equipment (see R.G. 8.8, Sections C.2.a.(3),
C.2.t(2), (7), and (9); C.3.a(4); and C.3.c(1) and (2).
(c) Preoperational and postoperational briefings of personnel (see R.G. 8.8, section C.3.a(6); C.3.c(1).
(d) " Dry runs" on mockup equipment and involvement of workers in planning (see R>G. 8.8, Section C.3.a(12)).
(e) Use of portable temporary ventilation systems and contamination enclosures (see R.G. 8.8, Sections C.2.d(1), (2), (3), (4),
ard (6), and C.3.a(11) and (14)).
25
A (f) Use of auxiliary lighting and a working environment with comfortable temperature, humidity, and adequate space (see R.G. 8.8, Section C.3.a(13)).
=
(g) Use of communication systems (see R.G. 8.8, Section C.3.b(3)).
1 (h) Assignment of radiation protection personnel job coverage (see R.G. 8.8, Section C.3.b(1)).
^:
(i) Scheduling activities such as maintenance and inspections following significant decay of short-lived isotopes or after
?!
flushing or decontamination (see R.G. 8.8, Section C.3.a(16) and C.2.f(1), (2) and (3)).
(j) Controlling access to higher dose rate areas and routing traffic
$5 through lower dose rate areas (see R.G. 8.8, Section C.2.a).
il 1
(k) Establishing person-rem goals and determining effectiveness for the methods used and results achieved.
(1) Preplanning work (see Appendix F).
4.3.2 Radiation Protection for Tasks.
Radiation protection considerations for tasks should be incorporated into operational procedures or work documents to the maximum extent possible.
Individual steps which require Radiation Protec-1 tion Technician coverage should be clearly identified.
RWPs should be used to supplement work documents or address changing conditions. Where RWPs are the prime method of providing radiological work direction or controls, they should provide specific radiation protection controls pertinent to the radiological conditions which exist for a particular step or segment of the associated work 1
procedures.
This requires that radiation protection rev ewers perform a step-i by-step assessment of tasks to assure that adequate radiological controls are designated for the work.
RWPs should not be issued without a review of the task elements by a radiation protection reviewer as authorized in procedures.
" Standing RWPs" (RWPs continuously in force for routine tasks and which may nut require a daily update or processing) should be limited to such functions as conduct of radiation protection surveys, routine chemistry and operational a
tasks and routine tours of areas where radiological conditions are stable.
]
Starding RWPs should be approved by the Radiation Protection Manager.
Each facility should have a system and procedures for formally planning and scheduling i
tasks which provide for comprehensive radiation protection ALARA reviews to be conducted and appropriate radiological work controls and dose reduction methods to be determined and applied for these tasks.
Particularly for complex radio-logical tasks involving high radiation levels, airborne radioactivity, or con-a tamination levels, reviews should be conducted by professional radiological 4
engineers or ALARA coordinators experienced in protective work practices, proce-g ures, requirements, and facility systems and radiological conditions.
Informa-tion banks of radiological conditions (e.g., survey recorls, RWPs, work records) should be available for use in evaluation and planning.
Standardized radio-logical work practices which can be used for task planning and training should be developed (see Section 10 of this guide).
To evaluate for ALARA doses, a dose tracking system should be established.
This might include tracking individual doses, worker groups, major tasks, repetitive operations, or doses expended servicing systems or components.
26
.~
..~.
l 4.3.3 Monitorina for Gamma Dose, l-(a) Primary Dosimetry.
Personnel exposure records and' reports made pursuant to 10 CFR Part 20 should normally be based on TLD or film badge results;
-however, the use of pocket chamber results or results calculated from exposure rates and stay times may be appropriate whenever TLD or film bcdge.results are questionable.
Procedures should describe requirements for wearing the TLD or film badge on that portion of the whole body which is expected to receive the highest dose.
For example, when the main source of whole body radiation is-from below the feet, the pecper TLD position for measuring whole body dose for an adult would normally be in the area of the waist.
Due to adult red bone marrow distribution, the lower leg bones contain relatively little blood form-ing marrow.
In this case it is also~ required to monitor for feet and ankle dose with an additional TLD at ankle level. The whole body should include the gonads and lens of the eye. Where deses may vary greatly within small work areas such as inside a steam generator, several dosimeters should be worn t
(e.g., on the head, chest, and adjacent to the gonadal area) to assure that the maximum whole-body exposure is measured.
(b),Use of Pocket Dosimeters.
Pocket dosimeters should be read prior, to their use and periodically thereafter by the wearer.
Dosimeters (e.g.,
quartz filament type) should be periodically recharged or zeroed and doses recorded such as when indicated doses exceed three-fourths full scale. When a pocket dosimeter. reading is off-scale or a dosimeter is lost under conditions such that a high dose is possible, the person's TLD or film badge should be processed as soon as possible and the person removed from radiation areas until the dose has been determinea.
l-(c) Stay Time. Where work area radiation levels are so high that a worker can rapidly receive his allowable radiation dose, the worker's occupancy in the work area should be limited on the basis of exposure limits, allowable remaining dose, and stay t!me and predetermined readings on direct-reading pocket dosimeters, or alarming dosimeters set to alarm at a similarly based predeter-mined dose.
Pocket dosimeters covering both the expected exposure range and higher ranges should be used. The worker should promptly leave the work area whenever either the stay time or allotted pocket dosimeter reading is reached, whichever occurs first.
If upon exit, the pocket dosimeter reading is below the allowable dose, reevaluation of both pocket dosimeter reading and stay time l
based on remaining allowable exposure should be performed, and stay time and allowed exposure should be readjusted with each subsequent work area entry.
(d) Comparina Pocket Dosimeter and TLD or Film Badge Results.
/ocket l
dosimeter results should be compared routinely with TLD or film badge results and each discrepancy greater than 25% for exposures.over 100 mr should be thoroughly evaluated. The evaluation should include consideration ~of factors such as: energy dependence.of devices used, survey results, exposure times, doses of others performing similar work, location of devices worn on body, etc.
.Jhen TLD or film badge results are questionable, documentation of clarifying remarks should be required-(e.g., use of time / dose rate calculations, use of 1,
pocket dosimeter results, evaluation of doses of other workers on the same job).
Documentation should provide explanations in addition to the final dose valve.
2 (e) Special Processing of Dosimetry Devices.
To reduce the probability of exceeding dose limits, TLD or film badges should be processed frequently as limits are approached.
1 5
27
4.3.4 Monitoring for Beta Skin Oose.
Examples of areas of work where the skin may be a critical organ for radiation exposure are work inside steam generators, work under a reactor vessel head,.or work in decayed noble gas environments. Measurement of beta dose rates should be made prior to start of the work. Beta monitoring should be accomplished by placing a TLD or film badge in contact with that portion of the body expected to receive the highest dose.
4.3.5 Area Posting.
Controlled surface contamination areas, radioactive materials storage areas, radiation areas, high radiation areas, lethal dose areas (or very high radiation areas), hot spots, wait areas, airborne radioactivity areas, and restricted areas should be posted in such a manner that workers are aware of the approximate boundaries of the areas.
For example, posting an entire building as a radiation area would be inappropriate if the areas meeting criteria for posting wer, limited to individual rooms or discrete areas within the build-ing. Where large areas are posted crovisions should be made to identify the varying conditions within the area, especially where this could affect achiev-ing ALARA doses or lead to personnel contamination or exposure to airborne radio-activity (e.g., a radiation area where dose rates vary from 5 mR/L to 90 mR/hr should have the high dose rate areas identified for workers to avoid, and low dose rate are as identified and designated as work areas or wait areas.
Methods for clearly distinguishing radioactively contaminated systems should be explained, along with special precautions required for maintenance for such systems.
Controls for potentially lethal radiation fields such as might occur during spent fuel transfer or during other facility operations should be described in accordance with the Branch Position in Table 4-1.
4.3.6 Bioassays.
Procedures implementing the bioassay (in vivo counting, urinalysis, etc.) program should specify the people who will be in the program, the types of bioassay given them, frequencies, action levels, and actions to be taken.
4.3.7 Use of Protective Clothing.
Procedures for standardizing types of protective clothing in use at the facility and the preferred techniques for donning and removal should be described.
Situations requiring protective clothing should be defined, including levels requiring double clothing or gloves and use within the Controlled Area.
4.3.8 Annual Goals.
ALARA dose reduction and radiation protection program improvement can be enhanced by quantifying aspects of radiation protection (e.g.,
numbers of personnel contamination instances, numbers of exposures in excess of facility - or regulatory - dose limits, volume of radwaste), setting specific annual goals to reduce problems or provide qualitative improvements in these areas, and providing the commitment and manpower to achieve these goals.
The facility manager and each division manager should cooperatively establish specific goals for their groups and the facility.
By example, the facility goals might include reducing radwaste volume by 20%, reduce personnel contamina-tion instances by 50%, or reduce preventative maintenance time in high radiation areas by 10%. A crafts support group might commit to establish a valve repair /
testing mockup training facility (e.g., to reduce PORV maintenance time).
Radia-tion protection might plan to develop 5 new radiation work practice procedures.
Operations might seek to install remote maintenance equipment which eliminates some containment entries. 'Such goals should be cost effective and realistically reflect what can be achieved with resources allotted and facility status.
28
Table 4-1 Contral of Access to Spent Fuel Transfer Tube Areas All accessible portions of the spent fuel transfer tube and or canal must be shielded during fuel transfer. Use of removable shielding for this purpose is acceptable. This shielding shall be such that the resultant contact radiation levels shall be no greater than 100 rads per hour.
In addition, any area within the shielded enclosure where access could be gained by the removal of hatches or shielded doors should be provided with fail-safe interlocks in the fuel transfer system such that fuel cannot be loaded into the spent fuel transfer tube or canal when the hatches are removed or door open. All accessible portions of the spent ruel transfer tube shall be clearly marked with a sign stating that potentially lethal radiation fields are possible during fuel transfer. _If removable shielding is used for the fuel transter tubes, it must also be explicitly marked as above.
If other than permanent shielding is used, local audible and visible alarming radiation monitors must be installed to alert personnel if temporary fuel transfer tube shielding is removed during fuel transfer operations.
l l
i 29
5.
Radioactive Materials (RAM) Control 5.1 Program Oescription Content 5.1.1 The Program Description should describe the system for and the respon-sibilities for identification, accountability, control, movement, storage, and inventory of radioactive materials outside of controlled areas; for identification, control, movement and storage within controlled areas; for receipt and shipment of radioactive materials and criteria for the release and unrestricted use in uncontrolled areas of materials from controlled areas.
5.2 Acceptance Criteria 5.2.1 Procedures should specify controls and group and individual (by position) responsibilities for a radioactive materials control program which assures firm control over RAM so that unnecessary or inadvertent exposures do not occur and RAM is not released into uncontrolled areas (e.g., offsite or to dumps) where individuals not monitored for occupational radiation exposure could receive exposure.
The. criteria contained in IE Circular No. 81-07 should be addressed.
The procedures should include:
(a) For controlled areas, at least provisions for:
1.
how RAM is identified, 11.
how RAM is moved and stored, iii.
how RAM is prevented from being removed from controlled areas in an uncontrolled manner.
(b) For uncontrolled areas, provisions for:
i.
identification of RAM 11.
control of RAM iii.
accountability of RAM iv.
movement of RAM v.
storage of RAM vi.
inventory of RAM 5.2.2 Procedures for radioactive materials storage and laydown areas should include:
(a) criteria for posting and isolating (b) survey requirements (c) access requirements (d) special shielding and/or handling requirements 5.2.3 Radioactive material transfer and receipt to/from other facilities should ensure that DOT requirements are met, and local criteria should be established for:
(a) radiation level and contamination surveys 1.
when required 11.
types of surveys (e.g., a, S, E y) 30
O iii.
extent of surveys / documentation iv.
-identifying and reporting (or preventing) DOT violations (b) packaging (c) labelling 5.2.4 Procedures should describe local implementation of DOT requirements, criteria for release of materials from controlled areas (e.g., CSCAs), and include a program which ver.fies the absence of RAM from uncontrolled areas or outside of designated storage areas.
Criteria should be that in Regulatory Guide 1.86.
Area, equipment, and material decontamination criteria and proce-dures should be provided.
5.3 Procedural Details The following details should be addressed in implementing the acceptance criteria into specific procedures for radioactive material control:
5.3.1 Facility definition of radioactive materials (e.g., isotopes of concern; types of radiation considered; radiation considered; contamination levels; accessibility and removeability of contamination) 5.3.2 Proper marking and identification (a) radiation levels (b) contamination levels 5.3.3 Systems and procedures for RAM (this does not necessarily entail a complex tagging system):
(a) initial identification (b) movement and transfer outside of and within the controlled and the restricted areas, including guidelines for physical movement (c) shipment from facility, including application of basic DOT criteria (d) receipt from off-facility (e) long-term storage l
(f) liquid samples 5.3.4 Storage (and periodic inventory where required) 5.3.5 Loss of radioactive materials 5.3.6 Survey and packaging procedures, to include:
a.
thumb rules and estimates for determining handling requirements b.
use of identifying features and markings, such as yellow plastic bags and sheets / tagging with yellow and. magenta tags I
31 u.
y,
r-w.-
-r.-e--,
m
c.
identification of uncontaminated materials (e.g., surveyed and released) 5.3.7 Personnel authorized to handle radioactive materials (e.g., as designated by the RPM or authorized by specific training) 5.3.8 Segregation and reduction of radioactive waste:
a.
survey and release criteria b.
low-level waste c.
high-level waste d.
baleable/non-baleable 5.3.9 Special controls (e.g., inventory, encumberance, storage) for:
a.
sealed sources b.
fissile materials d.
source materials e.
radiography sources f.
highly radioactive materials of small size (e.g., pocketable with dose rates greater than 100 mrem /hr) 5.3.10 Radiation protection controls and special review criteria for lifting and rigging of radioactive materials when high dose rates, high contamination levels, or potential airborne radioactivity release may pose special problems.
5.3.11 Marking and storage of cor.taminated portable tools.
5.3.12 ALARA guidelines for radioactive material control.
5.3.13 Radioactive material control program responsibilities.
32
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y-,
6.
Surveillance 6.1 Program Description Content l
This section of the Program Description should describe the radiation protection surveillance program which will be conducted. The Program Description should specify that the frequencies of surveys for radiation, radioactive contamination.
l airborne radioactivity, and radioactive materials will be established in procedures; describe the situations where these surveys are required; describe the nature and extent of these surveys; describe the equipment used in the surveys; describe i
how these surveys verify the radiological status of all facility areas, and describe the uses of survey data in work planring, procedures, radiation work permits, and similar functions.
6.2 Acceptance Criteria 6.2.1 Routine Surveys - General (a) Radiation protection surveys as required by 10 CFR Part 20, Sec-tion 20.201 should include not only physical measurements and monitoring but also investigation and correction of abnormal radiological conditions which may be discovered.
(b) Frequencies of surveys and monitoring should be established based-on the potential hazard, probability of change in radiological conditions, and occupancy factors.
Surveys should be performed in both restricted and unrestricted areas to provide positive verification that radioactive materials are being adequately controlled and are not spreading to, or building up, in uncontrolled areas.
Surveys should be performed routinely (consistent with ALARA) to provide trend analysis and verify radiological conditions which can effect worker health and safety. Additional surveys should be performed as needed to determine the radiological status of areas for work planning and work monitoring.
(c) A mechanism should be established to assure that survey data are available and used for informing per sonnel of hazards, job evaluation, trend analysis, and ALARA preplanning.
6.2.2 Dose Rate Surveys (a) Dose rate surveys should be performed with instruments calibrated for the type and range of radiation being monitored, e.g., beta survey instruments should be calibrated for beta radiation.
(b) Surveillance performed within large areas posted as high radiation areas where whole-body dose rates vary significantly should include the posting of " hot spots" and identifying low dose rate areas as potential wait areas.
Criteria for designating " hot spots" should be established in procedures.
6.2.3 Contamination Surveys (a) Areas to be surveyed and frequencies of surveys should be estab-lished based on the potential radiological hazard, probability of change in conditions, and area occupancy factors.
33 l
l
o (b) Procedures should include requirements for alpha surveys based i
on potential problems such as fuel defects, fuel degradation, or radon.
6.2.4 Airborne Radionuclide Surveys 1
(a) Criteria for areas to be surveyed and monitored should be identi-fled in the Program Description, and frequencies of surveys and monitoring should be established in procedures based on the potential radiological hazard, probabil-ity of change in conditions, and area occupancy factors.
(b) Capabilities and procedures should be developed for prompt detec-tion of radioiodine in the presence of noble gases.
(c) Detection and measurent capability'for alpha emitters should be developed.
6.3 Procedural Details The following guidance is provided for criteria that should be incorporated into specific implementing ' procedures.
6.3.1 Surveys - General (a) Frequency of Surveys: Active work areas where radiological condi-c j
tions may change as a result of the work being performed should be surveyed for radiation and contamination at least once per shift, or more frequently if radiological conditions could change (e.g., upon opening a radioactive system).
Survey frequencies should be established and changed based on an evaluation of historical data and trends.
s Exit points from contamination controlled areas should be surveyed for contamination following use at least daily, and shiftly during frequent use, such as during outages.
Eating areas and drinking fountains used by individuals who have worked in controlled surface contamination areas should be surveyed for contamination at least weekly.during routine operations and at least daily during major outages; potable water supplies should be sampled at least weekly.
Storage areas for solid radioactive waste and irradiated / contaminated components and equipment should be surveyed at least weekly when materials are moved into or out of the area during the week.
Pathways within the storage areas should be surveyed for radiation and contamination; external perimeters should be surveyed for radiation.
r (b) Survey results should normally be posted on status sheets or l
the signs at entrances to controlled areas. The results should also be available for use in developing controls for procedures and RWPs.
Results may be specified as ranges.
l (c) Survey requirements for recurring, noncoutine jobs should be established by procedures.
For example, specific concerns and the type of data needed should be specified for jobs such as PWR steam generator work, in-service inspections of in-vessel components at BWRs, and work on in-core detector systems.
34 4
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= -+.
.~-..,=--w,,,mw--
- +
.m.
,e-,----
e,w w,.
---en,--
v-
(d) Criteria and action levels / responses should be established for abnormally high or unusual survey results (e.g., temporary shielding use for dose rate increases; decontamination for surface contamination level increases).
(e) Radiation Work Permits or other work documents incorporating radiological control requirements should specify when surveys or coverage by a Radiation Protection Technician is required.
(f) Surveys should be filed and maintained so that previous radio-logical condition; can be readily reconstructed and background data for engineering evaluations is readily available. The use of computers for storing and retrieval of survey / job experience data is helpful in that they allow prompt review of history for preplanning new activities.
Documentation should include reasons for performing survey (e.g., daily routine, support for RWP) to assist in task preparation or evaluation, and trend analysis.
6.3.2 Dose Rate Surveys (a) In addition to physical dose rate surveys, restricted areas which are frequently occupied should also be monitored by recording area monitors or fixed dosimetry badges which are replaced and processed on a periodic basis.
(b) Dose rate surveys should be pirformed on laundered / decontaminated personnel protective equipment prior to reuse.
Acceptable limits for respiratory protective gear is given in NUREG-0041.
Limits for laundered protective clothing should be established (e.g., 0.1 mrem /nr) for routinely used clothing, since higher levels on such clothing w'orn by individuals who are required to routinely and frequently wear protective clothing in low dose rate areas can provide a significant source of total dose.
Additionally, dosimetry placement and survey requirements may be such that small but locally intense residual contamination may go undetected.
For clothing to be used as the outside protective clothing in highly contaminated areas or high dose rate areas for short periods, higher dose rates than from clean clothing may be acceptable.
General limits or single-use limits should balance radioactive waste reduction and water piocessing waste generation with exposure reduction.
(c) " Hot spot" signs may be used to designate locally intense sources of radiation in an otherwise generally low dose rate area (e.g.,1/2, 5 Rem /hr in a 30 mrem /hr area).
(d) Unrestricted areas around the plant snould be periodically (e.g.,
annually) surveyed with sensitive scintillation detectors or micro-R meters.
6.3.3 Contamination Surveys (a) Monitoring procedures (frisking, etc.) should be established to check for personnel contamination and to control the release of potentially contaminated or activated materials for unrestricted use. Monitoring devices 2 beta-which are adequate to determine the presence of at least 1,000 dpm/100 cm gamma cctivity should be used (see Regulatory Guide 1.86).
(b) Contamination surveys should include clean waste dumps and landfills, salvage areas, plant warehouses, tool storage areas, the gate house, and contractor buildings.
35
(c) Any personnel contamination detected on hair or skin should be promptly removed, using licensee-approved procedures, under the supervision of trained radiation protection personnel, to the extent practicable.
If initial washings with soap and water are not effective, radiation protection supervisory personnel should be notified and further attempts to decontaminate should be by procedures approved by medical personnel knowledgeable in radiological matters.
(d) Records of personnel contamination and decontamination results should bi maintained to assist in dose evaluations and as indications of potential problem areas.
As a minimum, these records should include names of individuals involved, s:trvey results (including nasal swabs), decontamination methods, results of decontamination, areas worked, RWP numbers, investigation findings, and corrective actions.
(e) Calibrated personnel " friskers" should be provided at or near the exits to controlled surface contamination areas and personnel should be monitored or required to monitor themselves upon leaving the controlled area.
Personnel " friskers" should be capable of detecting total contamination levels of at least 5000 dpm/100 cm2 (750 dpm per 15 cm2 probe area) and preferably as 2
low as 3,000 dpm/100 cm (450 dpm per 15 cm2 probe area) s y contamination.
To achieve this detection range, low background monitoring areas are required.
If low background areas cannot be achieved through shielding or other actions, frisking to detect gross contamination levels may be performed initially, but final frisker locations may have to be shielded or moved to remote areas and additional controls implemented to control passage to the remote frisking location.
(f) Personnel frisking procedures should be established which specify the portions of the body that must be monitored (generally the entire body),
the distance between the body and the detector (within about 1/2 inch for sy),
and the speed with which the detector is moved (maximum of about 2 inches per second for sy).
Frisking rate should be reduced where background levels are not minimal. Where whole-body monitors are used, sensitivity should be equal to or better than friskers.
(g) Portal monitors and hand and foot monitors are useful instruments and may provide supplementary monitoring for personnel contamination but should not be used as the primary means of monitoring for personnel contamination.
Technological advances, such as liquid scintillation portal monitors, should be carefully evaluated for lower limits of sensitivity by each licensee in actual operational environments prior to use.
(h) Everything within a controlled surface contamination area should be considered and treated as contaminated.
All items removed from the area should be surveyed for contamination, bagged and labelled if contaminated.
6.3.4 Airborne Radioactivity Surveys (a) When continuous air monitoring is performed, periodic high volume grab samples or breathing zone air samples should be taken to verify that air monitoring is representative of the actual work area.
(b) Capabilities should be provided for exhausting grab sample.s back to their source when extremely high levels of activities are expected, 36
(c) A minimum detectable activity for the sampling and counting equip-ment and methods in use should be established.
(d) Collection efficiencies for particulate and iodine sampling media should be established.
(e) Periodic tests of major work areas should be conducted to assure pressure gradients and air flows are from areas of low potential airborne con-tamination to areas of higher potential contamination.
(f) Where work involving a high potential for airborne radioactivity is performed (such as steam generator tube repair or removing highly contaminated insulation) continuous local monitoring of the work area should be provided while work is in progress.
37
7.
Instrumentation 7.1 Program Description Content This section of the Program Description should describe the types, numbers, purpose, capabilities, and characteristics of the portable and non portable survey instruments and laboratory counting equipment used for performing radiation and radioactive contamination surveys. The responsibility for the instrumentation program should be clearly identified.
7.2 Acceptance Criteria A radiation protection Program Description should describe the radiation survey instrumentation that detects and measures all types of radiation over a wide range of dose rates, doses and energy for the various types of radiation encoun-tered.
For this section of the Program Description to be acceptable, the following features should be described:
7.2.1 Inventory (a) There should be a sufficient number of instruments available in operating condition to accommodate the need to monitor the number of, operations that may be required in contaminated areas, airborne radioactivity areas, radiation areas and high radiation areas throughout the plant, particularly during major maintenance and refueling outages and/or accidents.
In arriving at a total number, consideration should also be given to the number of survey instruments that may be out of service for calibration or maintenance, or inoperative during the outage or accident. A minimum inventory level should be established at which operations are limited due to inadequate surveying capability.
(b) For counting facilities, backup counting facilities should be available, if the primary system is lost.
For systems utilizing computer calcu-lations, a manual backup capability should be provided.
7.2.2 Calibration (a) Calibration of portable (hand carried) and non portable radiation protection survey instrumentation should be performed in accordance with Regula-tory Guide 8.25, ANSI N323-1978, ANSI N320-1979, ANSI N343-1978, or equivalent alternatives.
Unless there is reason to suggest that more frequent primary calibrations are required, the ANSI standard recommendations for annual primary calibrations are acceptable.
(b) A quality assurance program should be established as an integral part of the calibration procedures, using criteria contained in Regulatory Guide 1.144, Revision 1, " Auditing of Quality Assurance Programs at Nuclear Power Plants."
7.2.3 Operational (functional) Checks (a) Operational (functional or response) checks should be developed for each type of instrumentation.
Procedures for these checks should be incorporated into the station implementing procedures.
38
a (b) Operational (functional) checks of continuously operating iastruments (e.g., stack particulate, iodine and gas monitors, area radiation monitors, friskers) should be made daily; for other instrumentation, checks should be made prior to use.
(c) Emergency and special use instruments should be response checked regularly and maintained in accordance with ANSI S320-1979, " Performance Specifications for Reactor Emergency Radiological Monitoring Instrumentation."
7.3 Procedural Details The following guidance is provided for criteria that should be incorporated into specific implementing and training procedures.
7.3.1 Inventory (a) Instrumentation should include:
pocket dosimeters, dosimeter readers, portable survey meters, low level contamination / dose rate meters, area radiation monitors (fixed and portable), continuous air monitors (fixed and mobile), air samplers, personnel friskers, portal monitors, hand and foot monitors, laboratory counting instruments, whole body counters, flow rate measuring devices, and supporting calibration equipment and spare parts.
The invento:y description should include the requirements for selected ranges, sensitivities, types of radiation to be monitored, accuracy required, remote readout, alarm setpoints and conditions, and types of surveying or monitoring to be performed. A routine interval for inventory verification should be established.
Instrument storage areas should be assessed for postaccident accessibility.
(b) Instrumentation dedicated to specific uses should be identified.
The location and dedicated use should be specified, e.g., emergency kits, beta dose rate measurements, alpha or n'eutron measurements, etc. A mechanism for assessing operability of such instrumentation shculd be described in procedures.
(c) Implementing pi acedures should establish the criteria for frequencies of calibration. At least annually, a review of the maintenance l
and calibration history for each type of inst ument should be performed to determine instrument performance, and the frequency of calibration modified, if appropriate.
(d) Gamma high dose rate instruments with long or extendable probes should be maintained for routine use.
l (e) Whole-body countera or partial-body monitoring devices (body i
scanners) should be maintained onsite.
(f) Means should be established to readily identify special use or dedicated instruments which are capable of being used for other purposes.
7.3.2 Calibration (a) Portable (hand-carried) dose rate instruments should be calibrated routinely (e.g., quarterly or semiannually) unless there is evidence or experience
,to warrant more frequent calibrations.
Secondary calibrations may be defined as a procedure which follows directly after a primary calibration and periodically (e.g., quarterly or semiannually) thereafter to ensure that the instrument response 39
remains accurate within prescribed limits. When performing the secondary calibra-tion, the calibration source strength should be sufficient to encompass those dose rate ranges of the instrument to be calibrated that are normally used during normal plant operations.
Calibration of at least one point for each of these ranges should be included.
(b) Ccntinuous air sampling / monitoring devices and air sampling lines should be tested in accordance with Regulatory Guide 8.25 on a periodic basis to determine that samples are representative.
(c) Continuous air monitoring devices should be capable of detecting 1-MPC-hour in one hour (in a low background area).
I (d) Air flow measuring devices including those installed on radiation detection instrumentation should be calibrated against a standard reference i,wtrument at least semiannually, or as required in Technical Specifications.
7.3.3 Operational (functional) Checks (a) Operational (functional) checks which are performed using a radio-active source should check instrument response near the control level or within the range normally used.
(b) Daily operational checks following the guidance of ANSI N 323-1978 (Section 4.6, " Periodic Performance Test") should be performed on portable (hand-carried) dose rate instruments, except for the high-range scale of high-range instruments.
7.3.4 Records A system of records which documents instrument calibration and main-tenance should be maintained.
40
~
8.
Review and Audit 8.1 Program Description Content This section of the Program Description should describe the types and frequencies of reviews and audits established for the radiation protection program including:
8.1.1 Radiation protection supervisory reviews, 8.1. 2 Quality assurance audits, 8.1.3 Corporate or contract audits, 8.1. 4 Radiation protection deficiency identification.
8.2 Acceptance Criteria Reviews and audits should incorporate the following features to assess procedural compliance, technical performance, implementation, and results of the facility radiation protection program:
8.2.1 Radiation protection supervisory reviews Onsite radiation protection supervision and radiation protection engineering should frequently perform in plant reviews of radiation protection staff effectiveness in such areas as radiological work practices, work monitoring, procedural compliance, and survey adequacy.
8.2.2 Quality assurance audits Quality assurance audits should be performed by the onsite auditing group by personnel with sufficient radiation protection training or experience to enable them to assure that radiation protection functions are being pe.rformed as required. The quality assurance program audits should meet the requirements of Appendix B of 10 CFR Part 50.
8.2.3 Corporate or contract audits Offsite (corporate or contract) audits and evaluations should be performed to assure the compliance of the radiation protection program with regulations and requirements, to assure that station-wide objectives are being met, and to recommend program improvements.
8.2.4 Radiation protection deficiency identification A reporting system should be established to identify and correct defi-ciencies in radiation work practices, training, maintenance, systems operations, and materials.
It should include a tracking and analysis feature that can identify trends in exposure control, contamination control and airborne radio-activity control, so as to provide the capability to improve the radiation protection program.
8.2.5 Audits and reviews should function to:
(a) ideatify non-compliance with Federal and licensee radiation protection requirements, 41
(b) identify work practices which could be improved, particularly those which result in unnecessary exposure, (c) evaluate radiation protection training effectiveness, (d) identify radiation control problems and determine the root causes of radiation protection incidents, 8.3 Procedural Details 8.3.1 The following guidance is provided for criteria that should be incorporated into specific implementing procedures.
(a) Specific senior management positions should be designated as responsible for assuring that deficiency reports and audit findings are addressed in a timely manner and that corrective actions are completed.
(b) Offsite audits of technical adequacy and safety objectives should be conducted at least annually.
(c) Observation and review of radiation protection practices should be conducted by the radiation protection staff to assure station-wide compliance with radiation protection procedures. Administration and documentation should be practical and functional to promote in-situ fixes of deficiencies and track and correct adverse trends or wide-spread deficiencies.
(d) Quality assurance audits should be performed for the following areas of radiation protection (see Regulatory Guide 1.33):
Radiation Monitoring (Fixed and Portable)
Radioactivity Monitoring (Fixed and Portable)
Radioactivity Sampling (Air, Surfaces, Liquids)
Radioactive Contamination Measurement and Analysis Personnel Monitoring, Internal (e.g., whole-body counter) and external (e.g., TLD system)
Instrument Storage, Calibration and Maintenance Decontamination (Facilities, Personnel, and Equipment)
Respiratory Protection, including fit testing Containination Control Radiation Shielding 42
o 9.
Radiation Protection Trend Analysis 9.1 Program Description Content The Program Description should describe a system and criteria for identifying and tracking incidents, unusual occurrences and deficiencies related to radiation protection, evaluating the circumstances and causes of these events, and developing short-and long-term corrective actions which preclude recurrence of such incidents or the development of adverse trends.
9.2 Acceptance Criteria The system should integrate lessons learned from radiological occurrences and deficiencies, licensee experience, the experi nce of others, and trend analysis, and apply this to radiatior. protection program improvement.
Evaluations should be conducted by line supervisors and managers with the technical assistance of radiation protection personnel.
Facility ALARA goals should include management commitment to take actions on findings.
9.3 Procedural Details 9.3.1 The following are typical situations which might be evaluated for determining if undesirable trends exist at a facility and applying corrective actions:
radiation exposure which exceeds licensee's control levels any body burdens received in excess of the licensee's control levels, including any measureable but unexpected depositions below those control levels
~
all personnel contamination instances, with the degree and formality of the investigation consistent with the significance of the contamination levels instances of actual or potential exposure to airborne radioactivity above licensee's control levels spills or spread of radioactive materials which affect operations, cause increased risk of exposure to personnel, or which degrade facility radiation protection conditions significantly radioactive materials which may be lost, or those which are found in unauthorized areas improper wearing or use of dosimetry equiment, including unmonitored exposures improper control or access for posted areas, particularly High Radiation Areas failure to follow radiation protection procedures 9.3.2 Accumulation and analysis of data on actual and potential radiation protection problems (e.g., exposure control, contamination control, airborne 43
radioactivity control, radioactive material control, training, work practices, design and operational problems) can provide a quantitative assessment of a facility radiation protection program. Where problems are discovered, root causes should be sought tv prevent reoccurrence in the long term, in addition to dealing with the immediate problem. Where significant numbers and varieties of basic problems exist, the potential for more serious and threatening problems increases.
For instance, where large numbers of personnel contamination instances occur, the probability of significant contamination or inhalation greatly increases.
In this case, trend analyses can reveal circumstances, areas and individuals associated with the problem, and corrective actions can be planned. Additionally, especially where considerable commitment and effort may be required, annual goals should be established to correct problems diagnosed from trend analysis.
i l
l 44
10.
Radiation Work Practices 10.1 Program Description Content The Program Description should describe a system for providing standardized radiation work practices procedures and engineering controls. These procedures and controls might be included in procedures related to a particular Program Description area (such as temporary shielding is related to dose control) or as separate procedures and controls related to several Program Description areas (such as radioactive vacuum cleaner control is related to dose control, con-tamination control, airborne radioactivity control and radioactive material control).
10.2 Acceptance Criteria An acceptable Program Description should include a description of the radiation work practices essential to operations and how they are utilized with work documents such as RWPs.
10.3 Procedural Details Standard radiation work practices provide planners, workers, and training personnel with a common system for planning and conducting work which is especially useful as experience and proficiency in these practices grows at the facility. Work practice procedures should describe work methods and engineering controls which reduce actual or potential exposure to radiation and radioactive materials, and should provide details such as options and materials available for use.
Such procedures should discuss circumstances where use of such practices may be particularly beneficial or impractical or marginally useful (for example, where installation of temporary lead shielding for a task would increase the total dose for the task performed without any shielding). Action levels where a work practice should be considered should be developed (e.g., contamination levels at which contamination enclosures and HEPA filter local ventilation should be used).
Some typical work procedure topics are:
10.3.1 Radiation maintenance exposure reduction methods, 10.3.2 Radiation work performance methods, including preparation of work areas, grinding, welding, cutting of systems and components; venting and draining methods, component maintenance methods, and component removal methods, 1
10.3.3 Use of temporary shielding, 10.3.4 Contamination control equipment, 10.3.5 Work area ventilation, 10.3.6 Decontamination processes (e.g, for personnel, equipment, materials, areas),
10.3.7 Liquid and solid waste processing, 45 l
l
10.3.8 Control system for contaminated tools, 10.3.9 Methods of radiation protection area pesting, 10.3.10 Use of respiratory protection in accordance with Regulatory Guide 8.15 and NUREG-0041, 10.3.11 Description and functions of protective clothing.
46 1
11.
Radioactive Waste Monitoring and Control 11.1 Program Description Content The Program Description should describe radiation protection practices which effectively control internal and external exposure hazards associated with gaseous, liquid, and solid radioactive wastes.
11.2 Acceptance Criteria An acceptable Program Description should include those ALARA measures which are applied in procedures, design, and operations for the generation, processing, handling, storage, and disposal of radioactive waste.
The responsibilities of operational and support managers and the overview responsibilities of the radiation protection group should be delineated.
Criteria outlined in Regulatory Guides 8.8 and 1.143 or equivalent alternatives should be met.
11.3 Procedural Details Facility procedures and policy commitments should address such topics as the following in procedures, program objectives, annual goals, program evaluations, and QA/QC efforts:
11.3.1 Radwsste reduction / waste segregation 11.3.2 Systems and facility design and function 11.3.3 Area cleanliness and waste accumulation 11.3.4 Procedural evaluations
~
11.3.5 Spill control 11.3.6 Training 11.3.7 Fire control in radioactive material storage areas 11.3.8 Policies regarding radioactive liquid recovery and reuse, and gas decay 11.3.9 Shipping radwaste 11.3.10 Radiation protection work practi,ces for radwaste 11.3.11 Radwaste analyses - Procedures should describe representative methods for analyzing the contents of radioactive shipments to ensure they meet regulatory requirements.
Procedures should include analysis of alpha and beta emitters.
47
~
REFERENCES General Regulatory Guide 8.8 Information Relevant to Ensuring That Occupa-tional Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable 1 Regulatory Guide 8.10 Operating Philosophy for Maintai_nfqg Occupa-tional Radiation Exposures As Low As Is Reasonably Achievable 1 SECTION 2 Radiation Protection Organization and Function Regulatory Guide 1.8 Personnel Selection and Training 1 NUREG-0731 Guidelines for Utility Management Structure and Technical Resources (Draft)2 Regulatory Guide 8.8 Information Relevant to Ensuring That Occupa-tional Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable 1 NUREG/CR-1280 Power Plant Staffing2 NUREG-0654 Criteria for Preparation and Evaluation of Radiological Emergency Resporise Plans and Preparedness in Support of Nuclear Power Plants 9 ANSI /ANS 3.1 (Draft 1979)
Standard for Qualification and Training of Personnel for Nuclear Power Plants 3 ANSI 18.1-1971 Selection and Training of Nuclear Power Plant Personne13 SECTION 3 Radiation Protection Training and Qualification Regulatory Guide 1.8 Personnel Selection arid Training 1 Regulatory Guide 8.27 Radiation Protection Training at Nuclear Power Plants, (March 1981)1 Regulatory Guide 8.13 Instruction Concerning Prenatal Radiation Exposure 1 Regulatory Guide 8.29 Instruction Concerning Risk From Occupational Radiation Exposure, (July 1981)1 48
O O
SECTION 4 Dose Control Regulatory Guide 8.2 Guide for Administrative Practices in Radiation 1
Monitoring Regulatory Guide 8.4 Direct-Reading and Indirect-Reading Pocket Dosimetersi Regulatory Guide 8.7 Occupational Radiation Exposure Records Systems 1 Regulatory Guide 8.14 Persorn61 Neutron Dosimetersi Regulatory Guide 8.9 Acceptable Concepts, Models, Equations and Assumptions for a Bioassay Program 1 Regulatorv Guide 8.15 Acceptable Programs for Respiratory Protection 1 Regulatory Guide 8.20 Applications of Bioassay for I-125 and I-1311 Regulatory Guide 8.26 Applications of Bioassay for Fission and Activation Products 1 Regulatory Guide 1.86 Termination of Operation Licenses for Nuclear Reactors 1 ANSI N13.11
" Criteria for Testing Personnel Dosimetry Performance"3 ANSI N13.6-1966 (R1972)
" Practice for Occupational Radiation Exposure Records Systems"3 ANSI N343-1978
" Internal Dosimetry for Mixed Fission and Activation Products"8 ICRP 9, ICRP 26
" Recommendations of the International Commission on Radiological Protection."4 MIRD Pamphlet No. 11
'S', Absorbed Dose per Unit Cumulated Activity for Selected Radionuclides and Organs"7 i
LA-4558-MS
" Surface Contamination:
Decision Levels"s NCRP-39
" Basic Radiation Protection Criteria"8 SECTION 5 Radioactive Materials Control Regulatory Guide Measurement of Radiation Levels on Surfaces of Packages Containing Radioactive Materials, TP 914-4, December 19792 49
International Atomic Energy Agency (IAEA) Technical Report Series No. 12G,
" Monitoring of Radioactive Contamination on Surfaces," 1970.s IAEA Safety Series No. 38, " Radiation Protection Procedures," 1973.8 IAEA Safety Series No.1, " Safe Handling of Radionuclides," 1973 Edition, Code of Practice Sponsored by the International Atomic Energy Agency (IAEA) and the World Health Organization (WHO), 1973.s NCRP Report No. 57, " Instrumentation and Monitoring Methods for Radiation Protection,"a IE Circular No. 81-07:
Control of Radioactively Contaminated Material (May 14, 1981)2 R. Loevinger, " Discrete Radioisotope Sources," Radiation Oosimetry, G.J. Hine and G. L. Brownell, Eds., Academic Press, New York, 1956,
- p. 693.s 1978 ANSI N13.1-1969, " Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities."3 NCRP Report No. 58, "A Handbook of Radioactivity Measurement Procedures,"
1978.s C.B. Meinhold, " Facility Monitoring Programs Techniques, and Problem Solving,"
Health Physics Operational Monitoring, Vol.1, C. A. Willis and J. A. Handloser, Eds., Gordon and Breach, New York, 1972, p. 363.5 C.A. Willis, " Safe Specific Activity," A Useful Concept in Monitoring Areas Containing Activated Materials," Health Physics Operational Monitoring, Vol. 1, C.A. Willis and J. A. Handloser, Eds., Gordon and Breach, New York, 1972, p. 373.s H.J. Diegl, " Guidelines for Determining Frequency of Wipe Surveys," Health Physics Operational Monitoring, Vol. 1, C.A. Willis and J. A. Handloser, Eds., Gordon and Breach, N'.w York, 1972, p. 385.5 P.G. Voilleque, " Calculation of Expected Urinary and Fecal Excretion Patterns Using the ICRP Task Force Group Report on Human Respiratory Tract,"
Health Physics Operational Monitoring, Vol.1, C. A. Willis and J. A. Handioser, Eds., Gordon and Breach, New York, 1972, p. 773.s SECTION 6 Surveillance USAS N13.2-1969 Guide for Administrative Practices in 3
Radiation Monitoring ANSI N13.6-1966 (R-1972)
Practices for Occupational Radiation 3
Exposure Records Systems Regtlatory Guide 8 2 Guide for Administrative Practice in 1
Radiation Monitoring 50
1 Regulatory Guide 8.7 Occupational Exposure Records System Regulatory Guide 1.86 Termination of Operator Licenses for Nuclear Reactors 1 EPRI NP-858 Evaluation of PWR Radiation Fields and Out-of-Core Surface Activities, Westinghouse Electrio Corp.
SECTION 7 Instrumentation Regulatory Guide 8.25 Calibration and Error Limits of Air Sampling Instruments for Total Volume of Air Sampled 1 Regulatory Guide 8.28 Audible Alarm Dosimeters (August 1981)1 IAEA Technical Report Series No. 133, " Handbook on Calibration of Radiation Protection Monitoring Instruments," 1971.s ANSI N320-1979
" Performance Specifications for Reactor Emergency Radiological Monitoring Instrumentation"3 ANSI N323-1978
" Radiation Protection Instrument Test I
and Calibration"8 ANSI N343-1978
" Internal Dosimetry for Mixed Fission and Activation Products"3 R.L. Kathren, " Instruments in the Field Use, Abuse, and Misuse," Health Physics Operational Monitorina, Vol. 2, C.A. Willis and J.A. Handloser, Eds., Gordon and Breach, New York, 1972, p. 811.s W.P. Howell and R.L. Kathern, " Calibration and Field Use of Ionization Chamber Survey Instruments," Health Physics Operational Monitorina, Vol.
2, C.A. Willis, and J.A. Handloser, Eds., New York, 1972, p. 925.6 SECTION 8 Review and Audit Regulatory Guide 1.33 Quality Assurance Program Requirements (Operation)1 ANSI N18.7-1976 Administrative Controls and Quality Assurance For the Operational Phase of Nuclear Power Plants 3 SECTION 10 Radiation Work Practices Regulatory Guide 8.15 Acceptable Programs for Respiratory Protection 1 51
NUREG-0041 Manual of Respiratory Protection Against Radioactive MaterialsS SECTION 11 Radioactive Waste Monitoring and Control Regulatory Guide 1.143 Design Guidance for Radioactive Waste Management Systems, Structures and Compo-nents in Light-Water-Cooled Nuclear Reactor Power Plants 1 Regulatory Guide 8.8 Information Relevant to Ensuring That Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low 1
As Is Reasonably Achievable 1 Copies are available from U.S. Government Printing Office, Washington, D.C.
20402. ATTN:
Regulatory Guide Account.
2 Single copies are available from the USNRC Division of Technical Information and Document Control, Washington, D.C.
20555.
3Available from American National Standards Institute, 1430 Broadway, New York, NY 10018, Copyrighted.
4Available from Pergaman Press, Marwell House, Fairview Park, Elmsford, NY 10523, Copyrighted.
5Available in Public Technical Libraries.
6Available from UNIPUB, 34 Park Avenue South, New York, NY 10010 7Available from MIRD Committee, 404 Church Avenue, Suite 15, Maryville, TN 37801 8NCRP Publications P.O. Box 30175, Washington, D.C.
20014 9Available for purchase from National Technical Information Service, Springfield, Virginia 22161.
52
Appendix A Example Qualification Standard For Radiation Work Training A.
Levels of Training 1.
Basic Radiation Work Training - for individuals who r quire routine or frequent access to radiation areas, high radiation areas, airborne radioactivity areas, or controlled surface contamination areas, for such purposes as routine systems operations, inspections, administrative or safety functions, or routine maintenance.
2.
Advanced Radiation Work Training - for individuals who require additional training to enable them to use special skills or work training where high levels of radiation, radioactive surface contamination, airborne radioactivity, or other unusual and challenging radiation work conditions i
exist.
Such additional training should include radiation controls integrated with the following ope.'ations:
a.
Contamination containment device operations, (1) Construction, verification of integrity (2) Work practices (e.g., grinding, vacuum operations)
(3) Emergency procedures (e.g., punctures, flooding)
(4) Decontamination and disassembly b.
Radiation Controls for Sampling (e.g., Auxiliary operator sampling radioactive systems) c.
Radiation Controls for movement of low-level activity samples (e.g., < 1000 dpm per 100 ml) d.
Specialized training for personnel listed under Section 3.3.2(c),
3.3.4(a) who are not previously trained as Radiation Protection Technicians B.
Elements of Training l
1.
Written examination covering essential information from each of,the main functional elements of the training program, with a minimum passing grade (such as 80%) for essay-type exams.
Exams should minimize the use of True-False type questions. A key should be prepared for each exam.
Procedures to control exams and keys should be implemented to assure accurate testing and valid evaluation of training.
Short answer and multiple, choice egams may be acceptable if appropriately standardized (e.g., mean ~ median
- mode) and extensive enough to sufficiently 7
test all major topics.
Several exams should be available and should be periodically modified and updated to assure proper testing.
2.
Practical examination of asterisked items in Appendix B 3.
Formal documentation of training and examination results, with qualifica-tion and requalification verified by a designated representative of the Radiation Protection Manger.
53 l
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,.,e
--p
,,n,.
,e
,,----n---
n w...
o Appendix A (Continued) 4.
Trained instructors, meeting qualification standards approved by the Radiation Protection Manager, utilizing formal lesson plans, prepared visual aides and training aides, a prepared training facility for practical demonstrations and examinations, and utilizing a sufficient variety of approved written exams such that examination effectiveness will not be reduced by repeated use of the same exam.
5.
A periodic re-audit (written and/or practical) program adin.'nistered annually (on the average) for each individual on an unannounced basis to determine proficiency and identify weaknesses in radiation controls work practices and knowledge.
6.
Requalification of previously qualified individuals, at two year intervais following qualification, to the same extent as initial qualification.
Successful performance of practical abilities may be performed on-the-job if observed and formally documented for requali-fication by persons designated by the Radiation Protection Manager (e.g., Radiation Protection Supervisors, Radiation protection training personnel), if performed within six months of requali'ication.
7.
A topical outline for training which encompasses the topics listed in Appendix B, " Example Content for a Radiation Work Training Program."
I l
I 54
Appendix B Example Content For a Basic Radiation Work Training Program
- Asterisked topics are those for which personnel should demonstrate a practical ability to accomplish.
1.
RADIATION FUNDAMENTALS a.
Definition of Radioactivity b.
Sources of Radioactivity (1) Natural Background Sources (2) Man-made Sources c.
Types of Radiation and Their Characteristics d.
Differentiation of Radiation and Radioactive Contamination 2.
RADIATION EXPOSURE LIMITS AND CONTROLS / EXTERNAL EXPOSURE CONTROL a.
Definition of radiation and rem as a unit of biological dose from radiation b.
Basic limits for radiation exposure c.
Explanation of dose and dose rate d.
Explanation of " stay time" and application e.
Procedures and methods for minimizing exposure (1) Distance between people and radiation source (2) Exposure time limitation (3) Shielding effects and use for individual exposure reduction f.
Potential radiation sources associated with an individual's work functions g.
Seriousness and consequences and possible penalties for (1) violating radiation warning sign instructions (2) unauthorized passage through barriers h.
Types and functions. of dosimetry equipment i.
Instructions on the use, care, and proper wearing (on the body) of dosimetry equipment (e.g., TLD, film badge, pocket dosimeter, extremity monitors)
- j.
Individual should demonstrate the ability to read all types of dosimeters to be used
- To be demonstrated as a practical ability in addition to knowledge requirements.
55
Appendix B (Continued) k.
Tracking exposure and minimizing exposure as an individual's responsi-bility 1.
Meaning of radiation protection posting - restricted areas, radiation areas / high radiation areas, exclusion areas, controlled surface contamination areas, airborne radioactivity areas, radioactive material storage areas, other posted / labelled areas m.
Radiation measurement and survey instruments' purposes 3.
RADI0 ACTIVE CONTAMINATION LIMITS AND CONTROLS / INTERNAL EXPOSURE CONTROL a.
Definition of contamination and differentiation between " loose surface" contamination and " fixed" contamination.
b.
Surface contamination limits for beta gamma, beta, and alpha contam) nation, and the meaning of the units c.
Contamination control during radioactive work (e.g., containment in plastic bags and use of Contamination Containment Areas).
Procedures for preventing contamination of personnel and how contamina-tion is detected on personnel d.
How contamination is removed from contaminated objects and personnel e.
Potential sources of contamination associated with work performed by individuals
- f.
Each individual should demonstrate proper procedures for donning and removing a full set of anticontamination clothing'
- g.
Each individual should demonstrate proper procedures for entering and leaving a contaminated area, including proper procedures for self-monitoring
- h.
For personnel required to work in containment areas (e.g., glove bags or tents), each individual should demonstrate proper procedures for working in these areas.
(This ability could be demonstrated on a mock-up) 1.
Respiratory protective devices and their use.
Situations which require wearing masks, air-supplied respirators, or air-supplied hoods
- j.
For personnel who are likely to encounter airborne radioactivity, each individual should demonstrate the proper procedure for donning and removing the type of respiratory equipment the individual will be required to wear.
For personnel who are required to wear respiratory
- To be demonstrated as a practical ability in addition to knowledge requirements.
56
Appendix B (Continued) equipment with anticontamination clothing, this demonstration should be performed when donning and removing anticontamination clothing and should include any leak checks required to be made to test for proper operation of respiratory equipment.
Separate training in accordance with Regulatory Guide 8.15 may meet this requirement (Section 4.b(3)).
k.
Posting of controlled surface contamination areas, contamination zone barriers, signs, labels, and meanings 1.
Contamination measurement and survey instruments 4.
RADI0 ACTIVE MATERIALS CONTROL a.
Definition of radioactive materials (RAM)-origins, types and forms b.
Physical identification and systems of control of radioactive materials; storage, transfer, use c.
Personnel responsible for RAM control and accountability 5.
WASTE ASSOCIATED WITH RADIOLOGICAL WORK a.
Methods for identification and proper control of radioactive solid and liquid waste b.
Methods by which individual workers can reduce the amount of radio-active waste generated 6.
PREPARATIONS FOR EMERGENCIES - WORKER-RELATED INFORMATION AND ACTIONS a.
Plant Safety and Accident Control Features b.
Signals and Alarms (e.g., actual demonstrations or recordings) c.
Evacuation Routes and Procedures d.
Assembly Points e.
Communications l
l f.
Guidance and Directions g.
Emergency Equipment h.
First Aid and Contaminated Wounds i
1.
Radiation Incidents 57
Appendix B (continued)
(1) Need for consulting radiation protection control personnel when questions arise or incidents occur (2) Procedures to be followed after a spill of material (liquid or solid) which is or might be radioactive (3) Procedures to be followed when notified that airborne radioactivity is above the limit
- (4) Individual should demonstrate the acti.ons to be taken in event of a spill of radioactive liquid.
(This ability should be demonstrated during a drill)
(5) Actions to be taken when an individual discovers his dosimeter is off-scale, or has lost or damaged dosimetry 7.
BIOLOGICAL EFFECTS OF RADIATICN a.
Carcinogenesis d
b.
Genetic Effects c.
Acute Effects d.
Latent Effects e.
Collective Dose Concept
'~
(1) Group Total Man-Rem Risk (2) Individual Dose Risk f.
Oose-Effect Relationship (1) External Radiation (2) Internal Radiation g.
Biological risks of radiation exposure to the unborn child (Regulatory Guide 8.13) 8.
RADIATION PROTECTION PROGRAM a.
ALARA Program - Guidelines to keep personnel radiation exposure As low As Reasonably Achievable (Regulatory Guide 8.8) b.
(1) Management commitment to program
- To be demonstated as a practical ability in addition to knowledge requirements.
58
.o Appendix B (Continued)
(2) Provisions for dose management in facilities design and equipment selection (3) References / organizations which provide the radiation protection program, plans, and procedures (4) Supporting equipment, instrumentations and facilities with ALARA applications (5) Methods for keeping individual exposure ALARA (a) Planning (b) Work Procedures (c) Shielding (d) Work Coordination (e) Rehearsing and Briefing Workers (f) Work Performance 1
b.
Physical / Medical qualifications for workers (if required by licensee) c.
Location and availability of personal exposure records d.
Bioassay Techniques (1) Whole-Body Counting (2) Urinalysis (3) Fecal Analysis (4) Avoiding Sample Contamination e.
Investigation and Reporting of Abnormal Exposures f.
Air and Area Monitoring g.
Radiation Surveys -- Purpose and Methods h.
Rules and Procedures, including Radiation Work Permits.
i.
Pertinent NRC Regulations (1) Dose Limits (2) Concentration Values 59
4 Appendix B (Continued)
(3) Reporting Requirements (10 CFR Part 20)
(4) Reporting Responsibility (section 19.12 of 10 CFR Part 19) j.
Professional Guidance and Assistance k.
Radiation protection organization and functions 1.
Responsibility of the individual to inform his employer of previous or concurrent occupational radiation exposure received m.
Responsibility of the individual to adhere to training and follow instructions (see Appendix C).
l l
t I
l l
60
. _ - ~.
Appendix C Example Responsibilities Of All Workers 1.
Obey promptly "stop work" and " evacuate" instruction of radiation protection personnel.
2.
Follow all procedures.
3.
Wear TLD/ film badge and pocket dosimeter where required by procedures, signs or by radiation protection personnel.
4.
Keep track of your own radiation dose status and avoid exceeding dose limits.
5.
Remain in as low radiation areas as practicable to accomplish work.
6.
Do not loiter in radiation areas or airborne radioactivity areas, use
" wait areas" when designated.
7.
Do not smoke, eat, drink, or chew in controlled surface contamination areas.
8.
Wear anticontamination clothing and respirators properly and wherever required by signs, RWPs, radiation protection personnel, and procedures.
9.
Remove anticontamination clothing and respirators properly to minimize spread of contamination.
10.
Frisk yourself or be frisked for contamination as directed when leaving a controlled surface contamination area.
11.
For a known or possible radioactive spill, minimize its spread and notify radiation protection personnel promptly.
12.
Do not unnecessarily touch a contaminated surface or allow your clothing, tools, or other equipment to do so.
13.
Place contaminated tools, equipment, and solid wate on disposable surfaces (for example, sheet plastic) when not in use and inside plastic bags when work is finished.
14.
Limit the amount of material that has to be decontaminated or disposed of as radioactive waste.
15.
Report the presence of treated or open wounds to radiation protection personnel prior to work in areas where radioactive contamination exists and immediately exit if a wound occurs while in such an area.
16.
Promptly report unsafe or noncompliance situations to plant management.
17.
Report prior or concurrent occupational radiation exposure to the employer.
61
Appendix D Example Qualification Standards For Radiation Protection Technician Training A.
Levels of Qualification 1.
Senior 'adiation protection technician - individuals who have satis-factorily completed a radiation protection technician training program as outlined in this guide, and who have experience and/or education in accordance with the criteria for radiation protection technicians in Regulatory Guide 1.8 (ANSI /ANS-3.1 Draft 1979).
2.
Junior radiation protection technician - individuals who have satis-factorily completed a radiation protection technician traininq program as outlined in this guide, but do not meet the experience criteria referenced in Regulatory Guide 1.8 (ANSI /ANS-3.1 Draft 1979).
3.
Radiation protection technician in qualification - individuals in the process of completing a radiation protection technician training program as outlined in this guide.
4.
The titles " Senior Radiation Protection Technician" and " Junior Radia-tion Protection Technician" are used here because their use is common in industry.
It should be noted that an individual must meet the training and qualification criteria of each facility's technical specifications before he is a Radiation Protection Technician for the purposes of technical specification compliance. Thus Radiation Protection Technicians as used in technical specifications is eqdivalent to a Senior Radiation Protection Technician as used here.
B.
Elements of Training 1.
A lualification folder outlining each of the elements of training cortained in Appendix 0 of this guide and serving as a record of sigaature verification for accomplishing this training.
2.
Discussion and checkout of knowledge and ability level for qualifica-tion training program items which are verified by a variety of qualified more senior radiation protection technicians, foremen, supervisors, or instructors.
3.
Reading assignments (e.g., local procedures, Regulatory Guides, ANSI, 10 CFR, etc.), programmed instruction guides, computer-aided instruction (CAI), or other supplemental techniques for learning.
4.
Classroom lessons, seminars, demonstrations and problem-solving sessions using prepared lesson plans and qualified instructors.
5.
Supervised on-the-job experience and performance evaluation.
6.
Periodic written and oral examinations, including final comprehensive written and oral examinations, with cral examinations stressing abnormal, emergency, and incident situations.
A sufficient variety of exams 62
.J
Appendix 0 (Continued) and keys should be prepared and controlled so that valid results for testing and training evaluations are achieved.
A minimum passing grade should be assigned which reflects the qualification level of the personnel being examined (e.g., 70% for Junior Technician, 75%
for Senior Technicians, etc.), or exams of graded difficulty with the same passing score should be developed. Oral board composition should be specified, and members should exceed the qualification /
experience level of the candidate.
7.
Designation by the Radiation Protection Manager of personnel authorized to verify and conduct qualification training for each level of training (e.g., Jr., Sr., Supervisor).
8.
Demonstration of a practical ability to satisfactorily perform actions, operate equipment, and establish monitoring conditions as outlined in the attached Content of Training, Appendix E.
These practical performances (practical factors) would involve actual performance (e.g., control point set-up and operation) or realistic training scenarios (e.g., contaminated, injured man drill) which would be evaluated by senior, highly qualified health physics personnel.
9.
Requalification every 2 years, using a structured program approved by the Radiation Protection Manager, with a final written and oral examination, and demonstration of required practical abilities per-formed within 6 months of requalification.
Practical abilities may be accomplished on-the-job, if satisfactorily completed during actual operations, and observed and verified by an authorized individual.
10.
Regular, scheduled training cycles equivalent to 5% of technician time (i.e., equivalent to or averaging 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> /40-hour week, 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> /
month, etc.).
11.
The criteria for satisfactory knowledge and skill levels for signature verification should entail relative proficiency, competence, consistency, and a high knowledge level.
C.
Qualification and Requalification Records - For Each Individual 1.
Final written examination grade.
2.
Final oral examination summary and grade, with areas covered and signatures of examiners.
i 3.
Qualifications verification, by signature of trainers, of program training items, specifically including the individual's satisfactory 63
a o
Appendix D (Continued) demonstration of practical skills for each specific identified functional qualification element.*
4.
Certification of radiation protection technician training, to include the Radiation Protection Manager's concurrence and signature verifying that the individual has completed all the requirements and has passed the written and oral examinations as required.
i
(
- Individuals in qualification may perform work under the following conditions:
I a.
the work is performed under the immediate supervision of a fully qualified RPT who is responsible for and signs for the work accomplished, or l
b.
the individual has satisfactorily performed the work and has been veri-fied as proficient in a specific functional (qualification) element I
(e.g., signature verification of knowledge level and practical abili-l ties), and the work is reviewed and countersigned by a qualified foreman / supervisor.
For example, an individual may be qualified as a control point monitor without completion of the entire technical qualification program.
64
Appendix E Example Content for a Basic Radiation Protection Technican Training Program A.
Radiological Fundmentals 1.
Radiation and Radioactivity a.
Natural background radiation b.
Types of radiation (1) charge and mass (2) penetration power (3) sources (4) attenuation (5) methods of interaction c.
Ionization and the rem (1) Ionization (2) Rad, roentgen, quality factors (coulomb per kilogram)
(3) Rem - definition and units d.
Curie (1) Definition, units (2) Sub-units conversions (3) Curie / dose rate relationships e.
Dose, dose rate, mixed radiation field dose calculations f.
Radioactive Decay (1) Decay constants and half-life (2) Calculations / determinations (3) Biological and effective half-life (4) Airborne radioactivity equilibrium calculations 2.
Biological Effects of Ionizing Radiation a.
Effect of radiation on human tissue b.
Effect of acute and chronic doses on man c.
Biological and genetic effects of small doses on population d.
Whole body limits for penetrating radiation e.
Relative risk of radiation exposure and other environmental hazards f.
Internal exposure (1) Sources (a) Inhalation (b) Ingestion (c) Imbedding (d) Adsorption 65
e l
Appendix E (Continued)
(2) Target / critical organs (3) Body burden and body burden limits (4) Radionuclides of concern (5) Derivation of limits (6) Doses from internal radioactivity (a) calculations of dose (b) biological effects (7) MPC hours - derivation and use g.
Biological risks of radiation exposure to unborn child.
3.
Radiation and Shielding a.
Effect of shielding (e.g., tenth value or half-value thickness) b.
Shielding attenuation values for different types of radiation (a, p, y, q) and energies (1) Lead (2) Steel (3) Water (4) Polyethylene (5) Concretes 4.
Rcdiation Sources a.
Reactor and reactor system sources (fission and activation)
(1) Operations - isotopes, dose rates (2) Maintenance - isotopes, dose rates b.
Corrosion products (1) Crud traps (2) Hot spots (3) Beta dose during maintenance c.
Concept of buildup factors d.
Dose rate calcualtion involving time, distance, and shielding for:
(1) Point sources (2) Line sources (3) Cylindrical sources - thumb rulas (4) Plane sources - thumb rules e.
Shielding designs and materials in use at facility f.
Function and use of temperary shielding to reduce exposure during maintenance and operations 66
e Appendix E (Continued) g.
Airborne gaseous and particulate (1) Radionuclides (2) Limits (3) Detection and identificatior 5.
Radiation Detection a.
General principles of operation (1) Scintillation detectors (2) Dosimetry equipment (3) Neutron detection instruments (4) Gas ionization detectors (a) Ionization chambers (b) Proportional counters (c) Geiger-Muller counters (5) Solid state applications b.
For each type of portable radiation and radioactivity survey instrument, and semi portable and fixed instruments (including Constant Air Monitors, Area Radiation Monitors, and effluent and process monitors), in use at the facility:
(1) Type of detection
~
(2) Conversion of meter readings to appropriate units (3) Application of appropriate " thumb rules" (4) Minimum sensitivity / lower limit of sensitivity (5) Range, scale and limits of use (6) Effects of other types of radiation on indication
- (7) Proper field use (e.g., directional, head phones, beta shields)
(8) Calibration and repair requirements
- (9) Method of source checking and response checking
- (10) Physical checks prior to use (11) Additional functions (e.g., beta factor, directional meter)
(12) Normal background (13) Operating limits and restrictions 6.
Counting Statistics a.
Basic principles b.
Basic counting formula c.
Minimum detectable activity d.
Background-effects on results e.
Description, setup, use of equipment, and application of statistics for counting equipment in use at facility
- To be demonstrated as a practical factor by trainee in addition to knowledge requirements.
67
Appendix E (Continued)
B.
Functional Knowledge and Abilities 1.
Surveys - radiation, contamination, ariborne radioactivity a.
Reasons for surveys and their applications b.
Frequency of required surveys (alpha, beta, gamma, and neutron) c.
Procedures for surveys d.
Survey techniques e.
Proper logging and documentation of results f.
Review and interpretation of results (1) Normal levels / Abnormal levels (2) Expected results (3) Trends and trend analysis (4) Actions if limits are approached or exceeded
- g.
Routine surveys of representative areas of the facility and proper logging of results h.
Determination of radionuclide type and estimates of activity levels which can result from various incidents (e.g., spills, venting, discharge) 2.
Facility Design, Systems, and Components a.
Radioactive systems (e.g., primary coolant pathways) b.
Auxiliary systems (e.g., ventilation, radioactive waste processing, radiation monitors) c.
System interfaces d.
Integrated plant operations (e.g., discharge, venting) e.
Plant emergency shutdown systems (e.g., ventilating, RHR, ECCS, Radioactive waste, containment isolation) 3.
Contamination Control and Decontamination a.
Definition of contamination (1) Loose contamination (2) Fixed contamination (3) Limits for loose and fixed alpha, beta, and beta gamma (4) Sources of contamination b.
Controlled surface contamination areas
- (1) Work area preparation, isolation, and posting
- (2) Set-up and operation of an access control point
- (3) Requirements for area entry (4) Radiation Work Practices
- To be demonstrated as a practical factor by trainee in addition to knowledge requirements.
68
Appendix E (Continued)
(a) Prevention of equipment contamination (b) Transfer of items to clean area (c) Area work habits
- (5) Controls and monitoring required for contaminated filter removal from radioactive liquid systems, ventilation systems, and vacuum cleaners
- (6) Personnel surveys (frisking)
(7) Requirements for entry into high radiation areas / controlled surface contamination areas (8) Procedures and reasons for each step and technique in the above items (9) Methods of controlling internal contamination c.
Contamination / airborne radioactivity survey technique
- (1) Swipes / air samples 2
(a) Calculation of results for fixed crea (e.g., 100 cm,
2 3
3 im ) or volume (e.g., portable air samples of 3m, im )
(b) Calculation of results for large-area swipes or high-volume air samples (c) Techniques (d) Conversion factors and activity calculations (e) Thumb rules for swipes and air samples (2) Thumb rules for contamination level / dose rate conversions for meters in use.
(3) Personnel survey techniques (a) Detection of internal radioactivity (b) Detection of external radioactivity (alpha, beta, gamma) d.
Anticontamination clothing.
- (1) Proper procedures for donning and removing a complete set
- (2) Proper wearing and removing dosimetry equipment with anti-C clothing (3) Conditions and requirements for wearing anti-C clothing (4) Used anti-C control
- To be demonstrated as a practical factor by trainee in addition to knowledge requirements.
4 f
69
o Appendix E (Continued) e.
Respiratory protection (1) Proper procedures for putting on, using, and removing respiratory protection equipment (2) Conditions and requirements for donning respiratory protec-tion equipment; protection factors (3) Control of work to eliminate the need for respiratory equipment (4) Regulatory Guide 8.15/NUREG-0041 requirements and compliance
- (5) Respirator maintenance
- (6) Use of test booth / field checks (7) Use of MPC-hours f.
Contamination containment areas
- (1) Construction and use of containment areas, disposable glove boxes, tents, etc.
- (2) Verification of proper construction and set up, testing, and removal of containment areas (3) Corrective actions for leaks, tears, flooding g.
Routine systems operations (1) Valve disassembly (2) Venting and draining radioactive systems (3) Welding, grinding, and cutting radioactive pipe (4) Proper use of* portable HEPA ventilation systems h.
Decontamination (1) Techniques for decon and waste handling (2) Standards applicable to reactor systems components (3) Techniques and procedures for limiting contamination spread and reducing exposure (4) Personnel decontamination
- (a) basic skin decontamination techniques (simulated)
(b) evaluation of effectiveness / documentation of results 4.
Radioactive Material Control a.
Procedures and records for radioactive material control
- (1) Control and tracking
- (2) Shipment and receipt (facility procedures and 00T requirements)
(3) Storage - environmental and fire protection, dose reduction
- To be demonstrated as a practical factor by trainee in addition to knowledge requirements.
70
Appendix E (Continued) b.
Identification of radioactive materials (1) Definitions - Federal / licensee (2) Surveys and estimates of radioactivity and contamination levels (e.g., valves, liquid sample, drums)
(3) Physical identification (4) Criteria f.or liquids, solids with trace levels of radio-activity (5) Facility and DOT standards c.
Control of standard radioactive sources (e.g., instrument sources, check sources) d.
Control of source material, fissile, and special nuclear materials e.
Procedures in event of loss of radioactive materials
- f.
Solid waste compactor controls 5.
Oose Limits and Controls a.
Federal limits and licensee control levels (1) Whole-body penetrating radiation (2) Skin, forearms, extremities (3) Internal organs b.
Use and reasons for limits c.
Effects and exposures resulting from types of radiation d.
Emergency exposure guidelines
- e.
Stay time calculations involving extremi;j and whole-body dose rate f.
Definitions, controls, and requirements for access for (1) Restricted Areas (2) Radiation Area (3) High Radiation Area (4) Exclusion Area (5) Hot Spots (6) Wait Area g.
Controls for preventing personnel from exceeding licensee control levels and dose limits h.
Actions for individual dose exceeding internal, external, or skin contamination limits i.
Practical dose control (1) For work in moderate general area dose rates (e.g.,
100-200 mrem /hr)
(2) For high radiation area work in the vicinity of hot spots i
i l
- To be demonstrated as a practical factor by trainee in addition to knowledge.
requirements.
71
Appendix E (Continued) j.
ALARA applications for dose reduction (Regulatory Guides 8.8, 8.10) k.
Field dose control actions for (1) Individual with lost or off-scale pocket dosimeter (2) Lost or damaged personnel monitoring device 1.
Limits for release of radioactive or contaminated material from controlled surface contamination or restricted areas 6.
Radioactive Waste Control a.
Classifications (1) High/ low levels (2) Baleable and non-baleable (3) Liquid / solid / gas b.
Proper waste disposal (1) Segregation of waste (2) Survey and release of materials c.
Techniques for waste control and volume reduction d.
Waste sampling (1) Normal levels (2) Limits for discharge (e.g., processed liquids and gases)
(3) Calculations
- (4) Sampling procedures e.
Potential effects of uncontrolled discharges
- f.
Controls for replacement of radioactive filters or resins g.
Radwaste systems operations 7.
Environmental Monitoring i
a.
Reasons for environmental monitoring b.
Results of program c.
General techniques (e.g., for Emergency Monitoring) 8.
Counting Systems a.
Type of samples counted b.
Preparation for counting / equipment setups c.
Sample counting procedures
- To be demonstrated as a oractical factor by trainee in addition to knowledge requirements.
72
o Appendix E (Contini
)
d.
Documentation and reporting of resuits e.
Actions for high or unusual esult' 9.
Incident and Unusual Event Control a.
General incident analysis techniques (1) Evaluation of initial symptoms (2) Immediate actions (3) Supplemental actions (4) Analysis / problem identification b.
Symptoms of postulated accidents (1) Major reactor accidents (2) Primary to atmosphere leaks (3) Primary to secondary system (e.g., PWR steam generator) leaks c.
Ccntrol and corrective actions for major and minor categories of:
- (1) Radioactive spill (liquid or dry)
- (2) High airborne radioactivity (particulate and gaseous)
- (3) Contaminated, injured person
- (4) High radiation levels d.
Relative to above events (1) Reasons for actions taken (2) Radiological problems resulting (a) dose (b) dose rates (c) activity concentrations (d) radionuclides of concern (3) Possible causes (4) Consequences of improper actions e.
Radiation incident knowledge (1) Recent local events (2) Generic power reactor experiences
- f.
Emergency Response Plan - Training and Drills
- To be demonstrated as a practical factor by trainee in addition to knowledge requirements.
73
r 1
o l
Appendix E (Continued)
(1) Technician assignments and responsibilities
-(2) Walk-through training (3) Orills g.
Post-Accident sampling and analysis (1) Access / Work control (2) Exposure reduction (3) Sources of radiation / exposure (a) Gaseous radioactivity (b) Particulate radioactivity (c) Source terms (e.g., RHR system, ventilation filters, LPCI, etc.)
(4) Radiofodine (5) Emergency sampling and analysis procedures 10.
Facility Radiation Protection Program a.
ALARA programs guidelines and procedures b.
Facility radiation protection program procedures c.
Federal requirements, regulations, and guidelines (e.g.,
Regulatory Guides,10 CFR 19, 20, ANSI) d.
Radiation protection organization and reporting e.
Bioassay program f.
Radiation Protection deficiency reporting, follow-up and analysis s
system g.
Work functions of radiation protection technicians (e.g., Jr.,
Sr., In Qualification)
(1) Operations support functions / facility interfaces (2) Quality control functions (3) Interface with individuals and the public
- To be demonstrated as a practical factor by trainee in addition to knowledge requirements.
1 74
o Appendix F A Sample Method of Preplanning Radiation Work to Maintain Occupational Radiation Exposures ALARA Procedures developed for radiation exposure-related activities such as normal operations, maintenance, inservice inspection, radwaste handling, and refueling should be followed by workers to assure that work will be performed in a manner that will provide ALARA exposures. To accomplish this, all radiation work should be pre planned and action levels established in a manner such as the following:
A.
Any task
- that may cause an expected collective dose-equivalent exposure of 1 person-rem may not require special formal ALARA documentation other than instructions specified in the Radiation Work Permit (RWP) or radio-logical work package which is normally required for all radiation work.
For relatively minor exposure tasks, an RWP need only address general radiation protection (e.g., clothing requirements, stay time) and obvious instructions for minimizing exposures, e.g., documentation of high radia-tion sources (hot spots) in the work area, provided that workers have received formal training in routine ALARA practices as outlined in Appendix B.
B.
Any task that may cause an expected collective dose equivalent exposure of greater than 1 person-rem should specifically address ALARA concepts such as training, temporary shielding, use of special teols, and any other techniques that would be used to minimize exposures.
The individual preparing the task should state in the RWP (or other radiological work document) what techniques should be followed to keep exposures ALARA.
This RWP should be approved by the RPM or equivalent.
C.
Any task that may cause an expected collective dose equivalent exposure of greater than 10 person-rems should (in addition to item B. above) address (a) historical data, if any, and the effectiveness of any previous ALARA techniques used in similar type operations, e.g., temporary shielding, decontamination and (b) alternative actions that could be taken, but were not taken, to reduce exposures, and specifically document why these actions were not taken, from an ALARA basis.
D.
Any task that may cause an expected collective dose equivalent exposure of greater than 50 person-rems should (in addition to item C. above) be reviewed by the Facility Review Group.
Upon completion of the task, a written postoperation evaluation should be performed to document the degree of success (or failure) of ALARA techniques used.
E.
Any task that may cause an expected collective dose equivalent exposure of greater than 100 person-rems should (in addition to item D. above) be reviewed by th'e Corporate Health Physicist (or Group) and the ALARA Committee.
- A task is defined as an identifiable work package for which a specific, general procedure or set of related procedures is prepared.
For example, a task would be the inspection and repair of a steam generator, inspection or repair of BWR reactor vessel nozzles, reactor head removal.
75
o Appendix G Definitions The following list defines usage particular to the RADIATION PROTECTION PROGRAM DESCRIPTION:
1.
Restricted Area - As defined in 10 CFR 20.3(a)(14).
In common usage, this typically includes all areas within the facility fence where personnel are required to wear personnel monitoring dosimetry.
2.
Radiation Area - As defined in 10 CFR 20.202(b)(2).
3.
High Radiation Area - As defined in 10 CFR 20.202(b)(3).
4.
Radiologically Posted Area - Any area posted with a yellow and magenta sign with a three-bladed radiation warning symbol for the purpose of controlling or restricting access to that area for radiation protection purposes.
5.
Lethal Dose Area - Any area where the exposure limits of 10 CFR 20.101 could be exceeded in a very short time and a physiologically harmful or lethal dose could be recieved.
Such areas must be controlled to prevent personnel access and posted clearly (e.g., " Lethal Dose Area - Personnel Access Prohibited").
NOTE:
If operational conditions permit radiation conditions acceptable for essential temporary access then:
(a) the acceptable radiation level condition must be stable for the duration of access (e.g., no reactor startup).
(b) a radiation survey must be performed to verify acceptable radiation levels.
(c) the area must be deposted as a lethal dose area and reposted appropriately (e.g., as a high radiation area or radiation area),
then returned to its original status upon completion of access.
6.
Hot Spot - A locally intense source of radiation which exceeds general area radiation levels by about a factor of four.
Hot Spot postings are typically used to clearly mark the highest sources of radiation in a radiation or high radiation area to help keep worker exposure at a minimum.
7.
Wait Area - An area designated for workers to wait in the course of performing work in a radiologically posted area. Areas with exposure rates at background level should primarily be selected as wait areas.
In cases where passage from the work arez to minimally low background areas would lengtnen work time and increase overall job exposure, then minimum dose rate areas in radiation areas or high radiation areas should be designated as short-term wait areas.
8.
Radioactive Materials Storage Area - Any area where materials determined to be radioactive and/or contaminated are stored.
80undaries and posting 76
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l Appendix G (Continued) should be established to mark these areas. Additional / multiple posting in accordance with radiation levels, contamination levels and types, and airborne radioactivity may be simultaneously required.
9.
Controlled Surface Contamination Area - Any area where loose surface con-2 tamination levels exceed 1000 dpm per 100 cm.
Boundaries and posting should be established to mark these areas and a contamination control /
access control point and frisking station established to control personnel access and egress and prevent the spread of contamination.
Posting should additionally specify the contamination levels and types of protective clothing necessary for access.
10.
Radioactive Materials - The 10 CFR 20.3(a)(13) definition of radioactive materials (RAM) includes any parts, tools, waste, or removed system compo-nents or piping which contain accessible or inaccessible areas where levels of radioactive loose or fixed surface contamination, and/or activated portions meet Federal and licensee criteria for such materials.
11.
Controlled Area - Areas within rest;icted areas which feature positive control over access and egress.
Access is limited in accordance with operational requirements and individual training (in radiation protection).
Controlled areas may include radiation areas, high radiation areas, exclusion areas, controlled surface contamination areas, radioactive material storage areas, and airborne radioactivity areas.
12.
Engineering Controls - Physical controls involving the use of barriers, special equipment, or special materials to reduce actual or potential expo-sure to radiation and radioactive materials.
Some examples are:
temporary lead shielding, contamination control devices, tents, local HEPA ventilation systems, enclosed ventilation hoods.
13.
Radiation Protection (Radiological) Engineers - Individuals who apply practical engineering aspects of dose control, contamination control, and airborne radioactivity control to work practices, operations, maintenance, and facility design.
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