ML20147C840
| ML20147C840 | |
| Person / Time | |
|---|---|
| Issue date: | 07/06/1978 |
| From: | Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | |
| Shared Package | |
| ML20147C808 | List: |
| References | |
| RTR-REGGD-8.027, TASK-OH-717-4, TASK-OS REGGD-08.XXX, REGGD-8.XXX, NUDOCS 7810130133 | |
| Download: ML20147C840 (17) | |
Text
I DRAFT 1 O
7/6/78 1
REGULATORY GUIDE 8.JB 2
RADIATION PROTECTION TRAINING FOR LWR NUCLEAR 3
POWER PLANT PER5ONNEL A.
INTRODUCTION 4
5 Section 19.12 of 10 CFR Part 19, " Notices, Instructions and Reports to 6
Workers; Inspections," requires that individuals be given instruction in 7
radiation protection that is commensurate with the potential radiological 8
health protection problems they may encounter in restricted areas.
Para-9 graph 20.1(c) of 10 CFR Part 20, " Standards for Protection Against Radiation,"
10 states that occupational radiation exposure should be kept "as low as is 11 reasonably achievable" (ALARA).
Appropriate training is an essential 12 aspect of an ALARA program.
This guide describes an acceptable radiation 13 protection training program for meeting the training requirement of 10 CFR 14 Part 19 and the ALARA objective with respect to individuals that enter 15 restricted areas at nuclear power plants (NPPs).
Regulatory Guides 8.8 16 and 8.10 (References 1 and 2) should be consulted with respect to training 17 within a complete ALARA program.
18 8.
DISCUSSION 19 Almost every job entails the acceptance of some risk.
Many of these 20 risks are obvious and easily recognized.
Other hazards are more subtle 21 and may not be recognized or appreciated without specific instruction.
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22 Radiation exposure is one of the subtle hazards.
A person may be exposed 23 to significant levels of radiation or radioactive materials without knowing 24 it, since human senses will not detect ionizing radiation.
For these 25 reasons, instruction in basic radiation protection is essential to the 26 understanding of the occupational risks of NPP work.
27 Work at a nuclear power plant involves the potential for exposure to 28 significant levels of ionizing radiation.
The policy of the NRC is that 29 radiation exposure should be kept "as low as is reasonably achievable" 30
( ALARA).
(ALARA programs at NPP's are covered in Regulatory Guide 8.8, 31 reference 1.) Proper training in radiation protection is an essential 32 part of an ALARA program.
33 It is not necessary for all NPP personnel to become experts in radia-34 tion protection.
However, it is important that every person receive 35 training that is commensurate with his or her duties and responsibilities 36 with respect to restricted areas.
37 C.
REGULATORY POSITION 38 1.
General 39 Each individual's primary duties and responsibilities as well as any 40 se'condary duties and responsibilities should be carefully considered in 41 determining appropriate training for that individual.
42 Training should include both classroom and on-the-job instruction and 43 experience.
Such training should be provided by instructors and examiners 44 whose knowledge of the subject they are teaching is far in excess of the 45 knowledge to be expected of trainees completing the training.
Personnel 8.JB-2
46 qualifications are covered by reference 3, Regulatory Guide 1.8, " Personnel 47 Selection and Training."
48 Although credit may be taken for applicable training received offsite 49 (when such training is documented with respect to its nature and applica-50 bility to onsite duties and responsibilities) plant-specific training 51 should also be received with respect to those topics listed in Section C.S.
52 Minimum training may vary from a few minutes for a visitor, through a few 53 hours6.134259e-4 days <br />0.0147 hours <br />8.763227e-5 weeks <br />2.01665e-5 months <br /> for onsite orientation of a radiation protection professional, to a 54 week (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />) or more for workers without prior training in radiation 55 protection and radiation work techniques.
56 The training program should be approved by the NPP radiation protec-57 tion manager (see reference 3), conducted under the manager's continuing 58 cognizance, and reviewed and updated at least once every 3 years under 59 the manager's direction.
60 2.
Who Should Receive Radiation Protection Training 61 The radiation protection trai'ing program should include all person-62 nel who may enter restricted areas whether or not they are employees of 63 the licensee.
This includes visitors and transient workers.
64 Visitors are defined as people who enter the plant for purposes other 65 than work for the lice.nsee and who are not expected to receive significant 66 radiation doses although they may occasionally enter restricted areas 67 (e.g., sales persons or students).
Transient workers are defined as l
68 people who enter the plant to work in restricted areas for a limited 69 period of time (whether or not they are employees of the licensee).
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70 Examples are equipment manufacturers' representatives; individuals employed 71 in maintenance work; NSSS vendor personnel who assist with refueling, 72 startup or maintenance; and licensee employees temporarily assigned to the 73 NPP.
Transient workers should receive onsite plant-specific training and
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74 should have a background of training in the more general (non plant-specific) 75 areas of radiation protection, and the biological risks involved, of the 76 same scope, depth and quality as full-time onsite radiation workers doing 77 the same or similar work.
8 3.
Objectives 79 The primary objectives of the radiation protection training program 80 (RPT) should be to:
81 a.
Ensure that all personnel involved are instructed about the 82 biological effects of radiation (including both immediate and latent 83 radiation effects) and the risks associated with the acceptance of radia-84 tion exposure.
85 b.
Provide the information needed to enable each person to comply 86 with plant rules and respond properly to warnings and alarms under both 87 normal and accident conditions.
88 c.
Provide the information needed to ensure that individuals can 89 keep their own exposures ALARA and ensu.e that ALARA considerations can be 90 appropriately reflected in decisions which affect the exposure of others.
91 d.
Provide the information needed to enable each person to comply 92 with NRC regulations and license conditions.
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93 Secondary objectives of the RPT program should be to:
94 a.
Ensure that the program is fully documented (see Section C.8) 95 so that it can be reviewed and revised as needed to meet changing conditions.
96 b.
Produce evidence that the instruction is sufficiently well 97 understood to permit its practical application.
98 c.
Result in evidence of training completed by each individual so 99 that training is not repeated needlessly onsite or at other facilities 100 where the trained person may be employed (see Section C.8).
101 4.
Timing 102 The RPT program should be scheduled so that each individual is trained 103 in radiation protection prior to working in a restricted area.
A worker 104 required to enter any restricted area prior to completion of the training 105 should be escorted by a fully trained and qualified person (such entries 106 may be necessary for on-the-job training, etc.).
Those individuals who 107 will routinely be required to work in restricted areas should receive 108 onsite " field instruction" concerning the radiation protection aspects of 109 their jobs prior to working in such areas.
110 The RPT program should include periodic refresher training as neces-111 sary to maintain awareness of the need for, and each individual's role in, 112 ALARA activities, and to update and renew each individual's knowledge of 113 appropriate subjects as listed in Table 1.
Refresher training should 114 occur annually, as a minimum.
Also, frequent (e.g., once per month),
115 brief discussions should be held to furnish an opportunity for workers to 8.JB-5
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116 get answers to radiation protection questions and to discuss recent develop-117 ments in radiation protection procedures, equipment, and regulations.
118 Recent plant radiation protection problems and the solutions to such 119 problems should be discussed at these meetings.
120 5.
Radiation Protection Training Program Content 121 The RPT program should include the general topics listed in Table 1 122 and discussed below.
Emphasis on each topic should be varied to meet the 123 needs of each individual or group as mentioned in Section C.2.
Appropriate i
124 docur,1ents covering essential facts, requirements, regulations, procedures, 125 and plant organization should be given to each trainee for future reference
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126 and guidance.
127 a.
Biological Effects of Radiation 128 Each trainee should be informed about the somatic and genetic 129 risks to exposed individuals, their progeny, and exposed embryos / fetuses j
130 (see Reference 4), and should be given instruction with respect to the 131 collective dose concept of risk.* Further, each should be informed of the 132 risks associated with very high doses, which might occur in an accident.
133 To the extent practicable, each individual should be informed of the 134 magnitudes of radiation risks relative to other more familiar risks encountered 135 in life.
References 5 through 7 are some appropriate sources of information.
136 137 The collective dose concept applies to total man rem doses to exposed 138 groups.
These doses, as well as individual doses, must be given due 139 consideration in any radiation control plan, and especially a plan such 140 as the plant ALARA program.
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141 Individuals who work in restricted areas or who make decisions 142 affecting such work should be taught enough about radiation effects to 143 permit appreciation of the importance and the implications of ALARA programs 144 and requirements.
Such persons should also be informed about the levels 145 of radiation doses that individuals working in restricted areas may normally 146 receive (within the constraints of 10 CFR Part 20 and an appropriate ALARA 147 program) and the risks associated with such doses.
148 b.
Radiation Exposure Measurement and Control 149 Each trainee should be informed that radiation can be measured 150 at levels significantly below regulatory limits and controlled by means of 151 suitable design and procedural techniques.
Workers and their supervisors 152 should understand the elements of radiation measurement and control well 153 enough to implement the measurement and control programs in a manner 154 consistent with the ALARA principle.
Emphasis in RPT should be on (1) 155 proper use of dosimeters for measurement of beta, gamma, and neutron 156 radiations, (2) use of time, distance, and shielding to reduce doses, (3) 157 sources of radiation, and (4) contamination control.
The importance of 158 performing work in accordance with preplanned procedures so as to minimize 159 radiation doses to the worker and others who may be exposed to radiation 160 as a result of the worker's actions should be stressed.
161 c.
Radiation Protection Program 162 Each trainee should understand that personnel outside restricted 163 areas should not be significantly affected by activities involving radio-164 active materials or radiation in restricted areas.
The meaning and importance 8.JB-7 l
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165 of posted instructions, including radiation warning signs and tags, and 166 the importance of following instructions should also be understood.
167 Workers and their supervisors should nave a thorough under-168 standing of the program, including applicable Federal regulations and
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169 plant radiation protection rules and operating procedures.
Emphasis 170 should be placed on ALARA concepts, philosophy, and implementation within 171 the radiation protection program (see References 1 and 2).
This <amphasis 172 should include management's commitment to ALARA, the manner in which the 173 radiation protection staff will implement ALARA concepts and philosophy, 174 and the responsibilities of the individual worker within the ALARA program.
175 RPT should include special attention to the use of respiratory protection 176 devices and procedures.
It is essential that workers be trained in the 177 proper use of these devices prior to their use.
(See Reference 8.)
i 178 d.
Emergency Preparations 179 Each trainee should know the appropriate response to alarms and 180 signals.
181 Workers and their supervisors should be familiar with the details 182 of emergency procedures and preparations so they will know what is expected 183 of them and from whom they can expect guidance.
Preparations for emergencies 184 that may be anticipated should be emphasized; these include accidents such as 185 those involving severe personal contamination combined with injury and 186 localized fires in restricted areas.
187 The RPT should emphasize the emergency facilities and equipment 188 as well as emergency exits, escape routes, and safe assembly points.
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189 e.
Special or Nonroutine Work 190 Short-term training will be required from time to time in associa-191 tion with special or nonroutine work.
The work may be considered special 192 because of the equipment to be used, the procedures to be followed, or the 193 radiation protection problems involved.
Such training would normally be 194 very limited in scope and should be consluered as a supplement to, rather 195 than a substitute for, the training described above.
196 f.
Training with Mockups 197 Experience has established that training effectiveness is greatly l
198 enhanced when equipment or facility mockups are used, allowing trainees to 199 practice repair and maintenance procedures in a realistic context prior to 200 entering areas in which high radiation levels exist.
This type of training 201 is especially valuable in the case of repair and maintenance work involv-202 ing tasks that may result in high doses to personnel in relatively short 203 periods of time.
204 A mockup of each piece of equipment and facility on which, or in 205 which, high man rem tasks may be anticipated should be used in plant-specific 206 training for those workers who are most likely to perform maintenance or 207 repair work on the equipment or in the facility.
Facility mockups are 208 valuable in those cases in which work on a piece of equipment (e.g., a 209 valve) requires the worker to gain access to, or work in, confined areas 210 or areas containing complex equipment and strong sources of radiation.
A 211 facility mockup will allow the worker to practice entry, egress, and 212 positioning within the facility so as to perform the necessary work in 213 accordance with the ALARA principle.
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214 When practicable, the mockups should be made to full scale and 215 incorporate components similar to those to be encountered in work on the 216 equipment to be serviced.
217 6.
Evaluation of Trainee Performance 218 Each trainee's knowledge, competency and understanding should be 219 tested, specifically with regard to the radiation safety aspects of specific 220 jobs to be performed.
This may consist of a written test only, but should, 221 in most cases, consist of a written test, an oral test, and a " practical" 222 or on-the-job performance test.
Requalification test:ing should be carried 223 out in conjunction with refresher training (see Section C.4).
224 High test grades (80% or higher) should be required since tests 225 should cover only radiation protection information relevant to the individual's 226 needs.
The trainee should be reinstructed and-retested in any areas in 227 which the trainee's knowledge is shown to be deficient.
228 Tests should cover all information presented in a training course, 229 but should emphasize knowledge and practices directly related to the 230 day-to-day radiation protection practices for a particular worker's job.
231 As plant operating experience is gained, test questions should reflect 232 radiation protection problems actually experienced at the plant.
233 True-false and multiple choice questions are easy to grade and pre-234 ferred by those taking tests, but lend themselves to guessing.
Therefore, 235 at least 50% of any written test should consist of essay or calculational 236 questions.
Questions should be of the type included in training session 237 exercises or " homework".
" Situation" type questions are especially desirable.
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238 In this type question a hypothetical (but credible) situation is described 239 and questions based on actual case histories are asked.
240
" Practical" or on-the-job tests should not only stress knowledge, but 241 also proper performance on the job.
An individual ray know what to do but 242 be unable to do it in a timely manner when faced with a situation demanding 243 expeditious action without a trial-and-error procedure.
Practical tests 244 should also give the examiner the opportunity to determine a trainee's 245 attitude toward radiation protection and the ALARA concept.
In preparing 246 a test, consideration should be given to individual job responsibilities, 247 training received, and radiation protection experience.
248 All tests should be designed to:
249 a.
Measure the individual's ability to recognize and cope with 250 radiation hazards that may be encountered on the job.
251 b.
Stress the importance of being prepared for work in restricted 252 areas.
253 c.
Assess the individual's knowledge of, and attitude toward, the 254 individual's rights and obligations as a worker.
255 7.
Radiation Protection Staff 256 The radiation protection staff, both professionals and technicians, 257 should be thoroughly conversant with the materials discussed in Section C.S.
258 Their knowledge should be of such depth as to qualify the radiation pro-259 tection staff to develop and conduct the RPT for all others.
- Further, 260 they must be prepared to develop, modify, and implement the radiation 261 protection program competently.
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s 262 8.
Records 263 Except for periodic refresher type training, it is desirable to avoid 264 repetition of training.
Adequate training records will help eliminate 265 unnecessary repetition.
Also, some workers (especially transient workers) 266 may work in several different NPP's at different times.
Because of this, 267 and in the interest of improving the effectivenss of training and elimi-268 nating redundancy, training programs should be structured so that site-269 specific training and non-site-specific training may be readily identified 270 in' training outlines, syllabuses, other training materials, and records.
271 Training records should include:
272 a.
The student's name, 273 b.
Inclusive dates for each segment of training or for each dif-274 ferent training program, 275 c.
A specific description of all training completed satisfactorily, 276 including references to pertinent course outlines, syllabuses, and other 277 subject-specific descriptive information, 278 d.
A performance rating for each segment of training or each dif-279 ferent training program satisfactorily completed by the student.
This 280 rating should consist of a numerical or letter grade and/or a written 281 evaluation.
282 In order to help prevent needless retraining of personnel, a statement 283 containing the information described in items a, b, c, and d above on 284 training received that may be applicable to work at another NPP should be i
285 given to the student for use when and if work is to be done by the student 286 at a different NPP.
This procedure will allow the person responsible for 8.JB-12 l
287 training at the second NPP to take the student's previous training into 288 account and thereby avoid needless repetition.
In order that such records 289 may be most useful to the worker in the new position, they should clearly 290 and explicitly describe all training received and clearly identify training 291 segments that may be applicable to work at the new position.
292 In order that there may be an adequate basis for periodic evaluation 293 of the training program, the following additional records should be maintained:
294 a.
Training materials such as outlines, syllabuses, brochures, 295 video tapes, texts, etc., or specific descriptions of these, to serve as a 296 basis for determining the depth and scope of training given in each subject 297 area.
298 b.
The name of each instructor and examiner involved in each segment 299 of training or each different training program.
300 D.
IMPLEMENTATION 301 The purpose of this section is to provide information to applicants 302 regarding the NRC staff's plans for using this regulatory guide.
303 Except in those cases in which the applicant proposes an acceptable 304 alternative method for complying with Section 19.12 of 10 CFR Part 19 of 305 the Commission's regulations, the method described herein will be used in 306 the evaluation of submittals in connection with operating license or con-307 struction permit applications docketed after unless 308 this guide is revised as a result of suggestions from the public or addi-309 tional staff review.
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310 If an applicant wishes to use this reguitory guide in developing 311 submittals for applications docketed on or before 312 the pertinent portions of the application will be evaluated on the basis 313 of this guide.
314 In the case of training programs at operating reactors, appropriate 315 modifications to such programs should be made, consistent'with this guide, 316 as soon as practicable and no later than one year after publication of 317 this guide.
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a 318 REFERENCES 319 1.
U.S. Nuclear Regulatory Commission, Regulatory Guide 8.8, "Information 320 Relevent to Ensuring that Occupational Radiation Exposures at Nuclear 321 Power Stations Will Be As Low As Is Reasonably Achievable."
322 2.
U.S. Nuclear Regulatory Commission, Regulatory Guide 8.10, " Operating 323 Philosophy For Maintaining Occupational Radiation Exposures As Low As 324 Is Reasonably Achievable."
325 3.
U.S. Nuclear Regulatory Commission, Regulatory ~,uide 1.8, " Personnel 326 Selection and Training."
327 4.
U.S. Nuclear Regulatory Commission, Regulatory Guide 8.13, "Instruc-328 tions Concerning Prenatal Radiation Exposure."
329 5.
National Academy of Sciences, National Research Council, "The Effects 330 on Populations of Exposure to Low Levels of Ionizing Radiation," November 331 1972.
332 6.
ICRP-26, " Recommendations of the International Commission on Radio-333 logical Protection," January 1977.
334 7.
National Safety Council, " Accident Facts."
335 8.
U.S. Nuclear Regulatory Commission, Regulatory Guide 8.15, " Acceptable 336 Programs for Respiratory Protection," and NUREG-0041, " Manual of 337 Respiratory Protection Against Airborne Radioactive Materials," October 338 1976.
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339 9.
U.S. Nuclear Regulatory Commission, NUREG 75/087, LWR Edition, " Standard 340 Review Plan for the Review of Safety Analysis Reports for Nuclear Power 341 Plants," September 1975.
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342 10.
U.S. Nuclear Regulatory Commission, Regulatory Guide 1.70, " Standard 343 Format and Content of Safety Analysis Reports for Nuclear Fower Plants."
344 11.
ICRP-27, " Problems Involved in Developing an Index of Harm," May 1977 345 12.
Title 10, Code of Federal Regulations, Part 20, " Standards for Protec-346 tion Against Radiation."
347 13.
Title 10, Code of Federal Regulations, Part 19, " Notices, Instructions 348 and Reports to Workers; Inspections."
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l 349 TABLE 1 350 TOPICS TO BE COVERED IN THE RADIATION 351 PROTECTION TRAINING PROGRAM 352 Radiation Biology 353 Carcinogenesis 354 Genetic Effects 355 Acute Effects 356 Latent Effects 357 Collective Dose Concept 358 Group Total Man-Rem Risk 359 Individual Dose Risk 360 Dose-Effect Relationship 361 External Radiation 362 Internal Radiation 363 Radiation Exposure and Radioactive Material Measurement and Control 364 Types of Radiation and Their Characteristics 365 External Dosimetry 366 Exposure Time Limitation 367 Distance Between People and Radiation Sources 368 Shielding 369 Source Identification and Control 370 Source Strength Reduction 371 Types and Forms of Radioactive Materials 372 Sources (Origins) of Radioactive Materials and Radiations 373 Detection and Control of Contamination 374 Radiation Measurement and Survey Instruments 375 Bioassay: Whole Body Counting, Urinalysis, and Fecal Analysis 376 Radiation Protection Program 377 ALARA Program 378 Radiation Zones 379 Signs and Labels 380 Personnel Monitoring 381 Air and Area Monitoring 382 Protective Apparel 385 Respiratory Protective Devices 384 Rules and Procedures 385 NRC Regulations 8.JB-16
386 TABLE 1 (continued 387 Dose Limits 388 Concentration Values 389 Reporting Requirements 390 Professional Guidance and Assistance 391 Control and Removal of Contamination and Contaminated Equipment 392 Emergency Preparations 393 Plant Safety and Accident Control Features 394 Signals and Alarms 395 Evacuation Routes and Procedures 396 Assembly Points 397 Communications 398 Guidance and Direction 399 Emergency Equipment 8.JB-17