Regulatory Guide 8.27

(Task Oh 717-4), Radiation Protection Training for Personnel at Light-Water-Cooled Nuclear Power Plants

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Issue date:	03/31/1981
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March 1981 U.S. NUCLEAR REGULATORY COMMISSION

REGULATORY GUIDE

OFFICE OF STANDARDS DEVELOPMENT

REGULATORY GUIDE 8.27 (Task OH 717-4)

RADIATION PROTECTION TRAINING FOR PERSONNEL

AT LIGHT-WATER-COOLED NUCLEAR POWER PLANTS

A. INTRODUCTION

Every job entails the acceptance of some risk. Many of Section 19.12, "Instructions to Workers," of I0 CFR

these risks are obvious and easily recognized. Other hazards Part 19, "Notices, Instructions and Reports to Workers;

are more subtle and may not be recognized or appreciated Inspections," requires that individuals be given instruction without specific instruction. Radiation exposure is one of in radiation protection that is commensurate with the the subtle hazards. A person may be exposed to significant potential radiation protection problems they may en levels of radiation or to radioactive materials without know counter in restricted areas as defined in paragraph 19.3(e)

ing it since human senses will not detect ionizing radiation of 10 CFR Part 19. Paragraph 20.1(c) of 10 CFR Part 20,

until exposure levels greatly exceed regulatory standards.

"Standards for Protection Against Radiation," states that For these reasons, instruction in radiation protection and occupational radiation exposure should be kept "as low as an understanding of the occupational risks of work at is reasonably achievable" (ALARA). Appropriate training is nuclear power plants are essential.

an essential aspect of an ALARA program. This guide describes a radiation protection training program consistent Work at a nuclear power plant involves the potential with the ALARA objective and acceptable to the NRC staff for exposure to significant levels of ionizing radiation.

for meeting the training requirement of 10 CFR Part 19 The policy of the NRC is that radiation exposure should be with respect to individuals that enter restricted areas at kept "as low as is reasonably achievable" (ALARA).

nuclear power plants. Regulatory Guides 8.8, "Information (ALARA programs at nuclear power plants are covered in Relevant to Ensuring That Occupational Radiation Expo Regulatory Guide 8.8.) Proper training in radiation pro sures at Nuclear Power Stations Will Be As Low As Is tection is an essential part of an ALARA program.

Reasonably Achievable," and 8.10, "Operating Philosophy for Maintaining Occupational Radiation Exposures As Low It is not necessary for all plant personnel to become As Is Reasonably Achievable," should be consulted with experts in radiation protection. However, it is important respect to other aspects of training within a complete that every person receive training that is commensurate ALARA program. Regulatory Guide 1.70, "Standard with his or her duties and responsibilities in restricted areas.

Format and Content of Safety Analysis Reports for Nuclear Power Plants, LWR Edition," and Reference I should be con

C. REGULATORY POSITION

sulted with respect to the license application review process.

1. GENERAL

This guide does not cover training necessary to qualify Although training tailored to each individual's needs, an individual as a radiation protection technician or profes is not necessary, each individual's primary and secondary sional. Regulatory Guide 1.8, "Personnel Selection and duties and responsibilities as well as each individual's Training,"' should be consulted in this regard.

training and experience should be carefully considered in determining appropriate radiation protection training for that individual. It may be appropriate to determine the IIn response to lessons learned from the Three Mile Island Acci value of an individual's prior training and experience with dent, public comments, and additional staff review, a second proposed Revision 2 to Regulatory Guide 1.8 (Task RS 807-5) entitled "Person respect to the present job requirements by means of a test.

nel Qualification and Training" and its draft value/impact statement (See Regulatory Position 2.3.) The radiation protection were issued in September 1980 for public comment.

Comments should be sent to the Secretary of the Commission, USNRC REGULATORY GUIDES U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Attention: Docketing and Service Branch.

to the Regulatory Guides are issued to describe and make available public methods acceptable to the NRC staff of implementing The guides are issued in the following ten broad divisions:

regulations, to delineate tech specific parts of the Commission's or postu niques used by the staff in evaluating specific problems 1. Power Reactors 6. Products lated accidents or to provide guidance to applicants. Regulatory 2. Research and Test Reactors 7. Transportation Guides are no{ substitutes for regulations, and compliance with set

3. Fuels and Materials Facilities 8. Occupational Health them is not required. Methods and solutions different from those 4. Environmental and Siting 9. Antitrust and Financial Review the out in the guides will be acceptable if they provide a basis for or 5. Materials and Plant Protection 10. General findings requisite to the issuance or continuance of a permit license by the Commission. Copies of issued guides may be purchased at the current Government Printing Office price. A subscription service for future guides in spe Comments and suggestions for improvements in these guides are cific divisions is available through the Government Printing Office.

encouraged at all times, and guides will be revised, as appropriate, Information on the subscription service and current GPO prices may to accommodate comments and to reflect new information or be obtained by writing the U.S. Nuclear Regulatory Commission, experience. This guide was revised as a result of substantive com Washington, D.C. 20555, Attention: Publications Sales Manager.

ments received from the public and additional staff review.

knowledge and experience of a worker's supervisor and the reviewed 2 at least once every 3 years, and updated, as neces degree to which the supervisor's knowledge will be available sary, under the manager's direction. Changes to the pro to the worker in the performance of the worker's job may gram should be made promptly in response to changes in also be an important consideration.

operations, technical specifications, regulations, etc.

Training should include classroom and on-the-job instruction and performance testing to document adequate The training described in this guide may be obtained in combination with other training when appropriate, e.g., an understanding and skill. Such training should be provided industrial safety training session could cover radiation by qualified personnel whose knowledge of the subject they protection as well as other occupational safety areas.

are teaching exceeds that to be expected of workers com pleting the training. The radiation protection training

2. TRAINEES

should be conducted in such a way that the worker knows the specific objectives of the training and whether he or she 2.1 Who Should Receive Radiation Protection Training has satisfactorily completed the training.

The training program should include all personnel, including supervisors, whose duties require them to work in Although credit may be taken for applicable train ing received off site (its nature and applicability to or frequent restricted areas whether or not they are em onsite ployees of the licensee. This includes visitors and transient duties and responsibilities should be documented),

plant workers.

specific training should also be received with respect to appropriate aspects of those topics covered in Regulatory Position 3. Training may vary in length from a few minutes Visitors are defined as people who enter the plant for purposes other than to work for the licensee and who are for some visitors, through a few hours for onsite orientation of a radiation protection professional, to a week (40

not expected to receive significant radiation doses although hours) they may enter restricted areas incident to their activities or more for some workers without prior training in radiation (e.g., sales persons or students).

protection and radiation work techniques. It is considered likely that most individuals working in areas where sources Transient workers are defined as people who enter the of radiation or radioactive materials (contamination)

do not plant to work in restricted areas for a limited period of normally exist (e.g., clerical workers in restricted areas)

may time and are directly involved in plant operations, main be trained as required by § 19.12 of 10 CFR Part 19 in

4hours tenance or repair, or the direct support of these activities or less. Where more immediate potential hazards exist (e.g., (whether or not they are employees of the licensee).

in radiation or airborne radioactivity areas), it is considered Examples of transient workers are equipment manu likely that the most closely supervised workers with specific, narrow, well defined responsibilities may be trained in facturers' representatives; individuals employed in main about tenance work; nuclear steam supply system vendor person

14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> and that most workers operating independently nel who assist with refueling, startup, or maintenance;

under such conditions may be trained in 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> or less.

As vendor personnel employed to augment the radiation required in § 19.12 of 10 CFR Part 19, the extent of these protection staff; transport workers; and licensee employees instructions must be commensurate with potential radiation temporarily assigned to the nuclear power plant. Transient protection problems in the restricted area.

workers should receive onsite plant-specific training and should have a background of training in the more general The use of trained workers as escorts for those who have (non-plant-specific) areas of radiation protection, as well as not completed their radiation protection training or as a in the biological risks involved, of the same scope, depth.

substitute for the training should be avoided (see Regulatory and quality as is required under § 19.12 of 10 CFR Part 19 Position 2.2). Note that although providing a trained escort for full-time onsite radiation workers doing the same or may reduce required training for those being escorted, it similar work. (Full-time onsite radiation workers may have does not relieve the licensee from the requirement of knowledge and skills, perhaps as a result of working at more

§ 19.12 of 10 CFR Part 19 for appropriate training of the than one job at the plant, far exceeding the knowledge persons being escorted. However, only those individuals

"working in or frequenting.. .a restricted and skills that would be necessary to meet the training area" require requirement of § 19.12 of 10 CFR Part 19.)

training under § 19.12 of 10 CFR Part 19. If the individual being escorted is to be in a restricted area for long enough periods that training is required by § 19.12 of 10

2.2 When Training Should Occur CFR

Part 19, such training should be completed in a timely The radiation protection training program should be manner in order to avoid the need for an escort and the scheduled so that each individual is trained in radiation unnecessary exposure of the escort to radiation or radioactive protection prior to entering a restricted area. Every reason material.

able effort should be made to complete all training in a timely manner. In special cases where a worker or visitor The training program, including offsite, contractor conducted, and prior training, should be approved by must enter a restricted area prior to completion of the the training, the individual should be escorted by a fully trained nuclear power plant's radiation protection manager (see Regulatory Guide 1.81 for acceptable training and experi 2 The review should include an examination ence), conducted under the manager's continuing cognizance, of program effective ness as evidenced by training program records.

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and qualified person (such entries may be necessary for specialized procedures should be observed while using such3 on-the-job training, etc.). Those individuals who will equipment or facilities or implementing such procedures.

routinely be required to do site-specific work in restricted

,areas should receive onsite "field instruction" concerning All tests, including oral and practical tests, should the radiation protection aspects of their jobs prior to have carefully developed bases in order to ensure that working in such areas. appropriate areas of knowledge and skill are covered. In preparing a test, consideration should be given to the job The training program should include periodic refresher responsibilities, training received, and radiation protection training as necessary to maintain awareness of the need for, experience of the individual worker.

and each individual's responsibility for, maintaining expo sures ALARA and to update and renew each individual's Written tests will, of course, consist of a series of written knowledge of appropriate subjects as listed in Table 1. questions to be answered by the worker. Similarly, oral and Refresher training should occur annually, as a minimum. practical tests should, as a minimum, be based on check Such training should not consist of a simple repetition of sheets or outlines showing the areas to be covered by previous training without consideration of a worker's needs. the examiner. Oral and practical tests should be docu Adequate training program records will be helpful in this mented with respect to the questions asked, responses, regard. Meetings should be held as necessary to inform performance areas covered, and level of performance by the workers of important new developments in procedures, worker.

equipment, and regulations that have an immediate impact on the radiation protection aspects of their work. Recent plant radiation protection problems and the solutions to High grades (i.e., 80% or higher) should be required on such problems should also be discussed by the training staff written and oral tests since each person's training should with participation of the radiation protection staff at these cover only radiation protection information relevant to the meetings. Special meetings for this purpose will not be person's needs. The worker should be reinstructed and necessary if opportunities for such discussions arise at meet retested in any subject in which the worker's performance ings held for other purposes. is deficient. The combination of testing and reinstruction should establish that the worker has the knowledge, under Appropriate training and testing should also be provided standing, and skill to work in a safe manner. Practical or to those workers requiring new or refreshed knowledge on-the-job tests should be graded on a pass-fail basis. That because of reassignment. Reassignment to a new work area is, the worker performs the task satisfactorily or is given or job may present hazards of a different nature or degree additional training until satisfactory performance is obtained from those associated with their previous job or work area. or is found unsuited for the job with respect to the job's Similarly, reassignment to an area or job from which the radiological safety aspects.

worker has been absent for a substantial period of time may also call for additional training because of a loss of know The form of individual questions is the prerogative of ledge or skill with respect to that job or work area or the licensee. However, it should be noted that although changes in the radiation protection problems associated true-false and multiple-choice questions are easy to grade with the job or work area. Although reinstruction may be and preferred by those taking tests, they lend themselves justified after shorter periods, a worker reassigned to a job to guessing. Therefore, written tests may be most effec or area from which the worker has been absent for a year or tive if they include essay or calculational type questions.

more should be reinstructed and tested with respect to the Test questions should be of the types included in training radiation protection aspects of that job or work area. session exercises or homework. Situation-type questions are especially desirable. In this type of question, a hypothet ical (but credible) situation is described about which

2.3 How Trainees Should Be Evaluated the worker is asked questions based on actual case histories.

Each worker's knowledge, competency, and understand ing should be evaluated with regard to the radiation protec Practical or on-the-job tests should not only stress tion aspects of specific jobs to be performed. The evalua knowledge but also proper performance on the job. A

tion may consist of a written or oral test only but should, person may know what to do but be unable to do it in a in many cases, consist of a written test, an oral test, and a timely manner when faced with a situation demanding

"practical" or on-the-job performance test. The evaluation expeditious action without a trial-and-error procedure.

should include a written test whenever practicable. Practical tests should also give the examiner the opportunity to determine a trainee's attitude toward radiation protection Oral tests should not be substituted for written tests and the ALARA concept.

unless the impracticability of administering a written test is established and documented on an individual case-by-case 3 Such aspects of training are commonly referred to as "practical basis. However, oral and practical tests are a valuable factors." Examples of these include the individual's ability to read adjunct to written tests giving the examiner an additional all types of dosimeters to be used; properly don, use, and remove a full set of anticontamination clothing; properly enter, perform self measure of trainee skills and appraising skills not tested by monitoring while occupying, and leave a contaminated area; properly a written test. Everyone whose radiation protection de work in containment areas (e.g., glove bags, tents); properly don, use, and remove respiratory protection equipment; and take proper pends on his or her effective use of equipment, facilities, or action following a spill of radioactive liquid.

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Written and practical tests should be designed to do the many nuclear power plant licensees have committed to keep following: ing records of such training. A description of such records is included in technical specifications required by §50.36 of a. Measure the individual's ability to recognize and cope 10 CFR Part 50 in accordance with Regulatory Guide 1.70,

with radiation hazards that may be encountered on the job. "Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants, LWR Edition. "s Adequate train b. Stress the importance of being prepared for work ing records will help eliminate unnecessary repetition of in restricted areas. training and may also be used in determining the adequacy of an individual's training prior to each new work assignment.

c. Assess the individual's knowledge of and attitude Periodic refresher training is encouraged, but unnecessary toward his or her rights and obligations as a worker from repetition of training should be avoided. Some workers the standpoint of radiation protection. (especially transient workers) may work in and be trained at several different nuclear power plants. Therefore, in the d. Reinforce the key points of the training. interest of improving the effectiveness of training and eliminating redundancy, training programs should be struc Tests should cover all information presented to the worker tured so that site-specific training and non-site-specific but should emphasize knowledge and practices directly related training may be readily identified in training outlines, to the day-to-day radiation protection practices for each syllabuses, other training materials, and records.

worker's job. As plant operating experience is gained, test questions should reflect radiation protection problems Such trainee-specific training records normally include:

actually experienced at the plant.

a. The worker's name.

Requalification testing should be carried out in conjunction with refresher training (see Regulatory Position 2.2). Satisfac b. Inclusive dates for each segment of training or for tory performance by an individual on a requalification test each different training program.

when the test includes all topics treated in the refresher train ing may be substituted for refresher training for that individual. c. A specific description of all training completed satisfactorily, including references to pertinent lesson plans, Whenever a test is used to help evaluate the knowledge course outlines, syllabuses, and other subject-specific and ability of an individual whose training and experience descriptive information. Specific reference is usually made are not well known by the evaluator (e.g., the training and to such materials by date, edition, issue, etc., applicable to experience was not provided by the group performing the each worker.

evaluation), it is especially important to keep in mind the limitations of such a procedure. When taking a test, a d. A performance rating for each segment of training worker will not respond to the questions on the test by or each different training program satisfactorily completed revealing all of his or her knowledge and abilities since a by the worker. This rating normally consists of a numerical test that can be completed and evaluated in a reasonable or letter grade or a written evaluation.

period is not that comprehensive. The test simply samples the worker's knowledge and abilities. Therefore, the evalua e. The source of the training, i.e., the training facility tor should carefully consider the test content and worker and its location.

responses in light of the requirements of § 19.12 of 10 CFR Part 19 and the demands on the worker on the job. To help prevent needless retraining of personnel, a state ment containing the information described in items a, b, c, Although training is usually thought of and implemented d, and e above on training received that may be applicable in a highly structured way, it should be kept in mind that a to work at another nuclear power plant is usually given to worker's performance on the job, following training, is the the worker for use if the worker is employed at a different best measure of training effectiveness. In view of this, plant. This procedure allows the person responsible for supervisors and radiation safety personnel should always be training at the second nuclear power plant to take the on the alert for worker performance characteristics that worker's previous training into account and thereby avoid indicate the need for further instruction. Such experiences needless repetition. Such records may be most useful to the should also be considered when determining the training worker in the new position if they clearly and explicitly needs (both initial and refresher) of the workers and describe all training received and clearly identify non-plant designing or revising training programs. specific training segments that may be applicable to work in the new position.

2.4. What Records of Training Could Be Maintained In order that there may be an adequate basis for periodic Although NRC regulations do not require that records of radi evaluation of the training program, the following additional ation protection training at nuclear power plants be kept, 4 records may be considered:

4 However, records of radiation safety training, 5 included as part See, for example, subsection 6.10.2h of operator requalification training, must be kept as required by of Section 6, "Administra tive Controls," of NUREG-O1 23, "Standard Technical Specifications Appendix A to 10 CFR Part 55. for General Electric Boiling Water Reactors."

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ence documents covering essential facts, requirements, regu a. Training materials such as outlines, syllabuses, brochures, lations, procedures, and plant organization should be given to video tapes, texts, tests (including test questions and oral each trainee. In those cases where it is clearly impractical to and on-the-job checklists), or specific descriptions of these provide each trainee with a reference document, each trainee items to serve as a basis for determining the depth and scope should be informed in writing of the times and locations at of training given in each subject area. Specific reference may which the document will be readily and conveniently available.

be made to such materials by date, edition, issue, etc.

3.2.1 Measurement and Control of Exposure to Radia b. The name of each instructor and examiner involved in tion and Radioactive Material each segment of training or each different training program.

Each worker should be informed that radiation and

3. RADIATION PROTECTION TRAINING PROGRAM

radioactive materials can be measured at levels significantly below regulatory limits and controlled by means of suitable

3.1 Objectives design and procedural techniques. Workers and their super visors should understand the elements of radiation measure The primary objectives of the radiation protection ment and control well enough to participate in the measure training program should be to accomplish the following: ment and control programs in an effective manner con sistent with the ALARA principle. Emphasis in radiation a. Ensure that all involved personnel are instructed protection training should be on (a) sources of radiation about the biological effects of radiation, including both (including, where appropriate, plant systems), (b) contami immediate and latent radiation effects, the risks associated nation control, (c) use of time, distance, and shielding to with the acceptance of radiation exposure, and the basis for reduce doses, (d) proper use of dosimeters for measurement biological risk estimates. of beta, gamma, and neutron radiations, (e) the need for and proper use of respiratory protection equipment, and b. Provide the information needed to enable each (f) the need for and proper use of protective apparel.

person to comply with plant rules and respond properly to Special attention should be given to item (e). It is essential warnings and alarms under both normal and accident that personnel who are likely to require the use of respira conditions. tory protection devices be trained in the proper use of these devices prior to their use for respiratory protection pur c. Provide information that will enable individuals to poses. (See Regulatory Guide 8.15, "Acceptable Programs keep their own radiation exposures ALARA and effectively for Respiratory Protection," and Reference 2.)

apply ALARA considerations in making decisions that affect the radiation exposure of others. Personnel having essentially unlimited access to all plant areas (i.e., freedom to go anywhere in the plant d. Provide the information needed to enable each person without escort or special instruction (e.g., without a radia to comply with NRC regulations and license conditions. tion work permit) and, therefore, responsible for their own radiological safety) should acquire a detailed knowledge of Secondary objectives of the radiation protection training sources of radiation and radioactive materials associated program should be to accomplish the following: with all plant systems. Those areas, systems, and compo nents that have associated with them the potential for acute a. Ensure that the program can be reviewed and revised lethal exposures (e.g., the fuel transfer system during spent as needed to meet changing conditions, and that the instruc fuel transfer) should receive special attention.

tion is sufficiently well understood to permit its practical application. 3.2.2 Radiation Protection Program b. Ensure that (I) the status and extent of training of Each individual should understand the nature, scope, each individual may be determined in order to ensure that and objectives of the program, including pertinent portions workers are adequately trained for each job to which they of Federal regulations and plant radiation protection rules, are assigned and (2) training is not repeated needlessly on administrative controls, and operating procedures. Con site or at other facilities where the trained person may be trolling and minimizing occupational radiation exposure at employed (see Regulatory Position 2.4). a nuclear power plant in accordance with the ALARA

concept is highly dependent on the procedures, rules, and

3.2 Content administrative controls that implement the facility radia tion safety program. It is therefore important that each The radiation protection training program should, in individual be instructed in the latest versions of these general, include the subjects listed in Table 1 and discussed procedures, rules, and controls. The meaning and impor in Sections 3.2.1 through 3.2.6. The inclusion of topics and tance of posted instructions, including radiation warning the emphasis on each topic should be varied to meet the signs and tags, and the importance of following instructions needs of each individual or group requiring training (see should also be understood.

Regulatory Position 2.1). Instructors should consistently and closely adhere to lesson plans and outlines in order that Emphasis should be placed on ALARA objectives, training records (see Regulatory Position 2.4) accurately philosophy, and implementation within the radiation reflect the training given each worker. Appropriate refer-

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-I-

protection program (see Regulatory Guide 8.8). This emphasis The radiation protection training program should should include management's commitment to ALARA, the emphasize the emergency facilities and equipment as well as manner in which the radiation protection staff will implement emergency exits, escape routes, and safe assembly points.

ALARA, and the responsibilities of the individual worker Onsite instruction associated with appropriate plant areas is within the ALARA program. The importance of controlling especially important to this phase of training.

radiation doses to the worker and to others who may be exposed to radiation as a result of the worker's actions should

3.2.5 Special or Nonroutine Work be stressed.

Short-term training will be required from time to time The training should provide workers with an understand in association with special or nonroutine work. The work ing of the relationship between the radiation protection may be considered special because of the equipment to be program and their individual jobs and how and when they used, the procedures to be followed, or the radiation may or should request help from radiation protection protection problems involved. Such training would normally personnel. be very limited in scope and should be considered as a supplement to, rather than a substitute for, the training Pertinent license conditions, NRC regulations, and described above.

regulatory guides should be explained, not simply read or distributed, to those being trained.

3.2.6 Training with Mockups

3.2.3 Biological Effects of Radiation Experience has established that training effectiveness is greatly enhanced when equipment or facility mockups Appropriate topics under this subject include the soma are used, allowing workers to practice repair and maintenance tic and genetic risks to exposed individuals, their progeny, procedures in a realistic context prior to entering areas in and exposed embryos/fetuses (see Regulatory Guide 8.13, which a potential exists for exposure to high levels of

"Instructions Concerning Prenatal Radiation Exposure");

radiation or radioactive contamination. This type of training the collective dose concept of risk; 6 risks associated with is especially valuable in the case of repair and maintenance very high doses such as might occur in an accident; and the work involving tasks7 that could result in high radiation basis for biological risk estimates. To the extent practicable, doses to personnel in relatively short periods of time. When the magnitudes of radiation risks relative to other more practicable, the mockups should be made to full scale and familiar risks encountered in life should be explained. Refer should incorporate components similar to those to be ences 3 through 9 are some relevant sources of information.

encountered in work on the equipment to be serviced.

Persons who work in restricted areas or who make A mockup of each piece of equipment and facility on decisions affecting such work should be taught enough which or in which high-man-rem tasks are anticipated about radiation effects to permit appreciation of the should be used in plant-specific training for those workers importance and the implications of ALARA programs and who are to perform maintenance or repair work on the requirements. Such persons should also be informed about equipment or in the facility. Facility mockups are valuable the levels of radiation doses that persons working in re in those cases in which work on a piece of equipment stricted areas may normally receive (within the constraints (e.g.,

a valve) requires the worker to gain access to or work in of 10 CFR Part 20 and an appropriate ALARA program)

confined areas or areas containing complex equipment and and the risks associated with such doses. strong sources of radiation. A facility mockup will allow the worker to practice entry, egress, and positioning within

3.2.4 Preparationsfor Emergencies and Incidents the facility so as to perform the necessary work in accordance with the ALARA principle.

Workers should know the appropriate response to alarms and other signals and should be sufficiently familiar with Justification for the use of mockups in training should emergency procedures and preparations so as to know what be established on an ALARA basis. An onsite evaluation is is expected of them and from whom they can expect essential to such a determination. However, mockup guidance with respect to emergencies and incidents. Prep training should be carefully considered by management for arations for emergencies and incidents that may be antici those tasks where the collective dose may exceed one pated should be emphasized. Such emergencies and inci man-rem. This should not be taken as a recommendation to dents include accidents involving severe personal contami ignore the feasibility of mockup training for lower-man-rem nation, spills of radioactive material, unexpected high levels tasks. In the case of some lower-man-rem tasks, mockup of radiation or airborne radioactive materials, contaminated training may be justified by the ready availability of un wounds, and fires that could result in unusual exposure to complicated mockups and the small amount of additional radioactive material or radiation.

7For the purposes of this guide, a task is any work activity in restricted area that may be defined by readily identifiable a of initiation and completion. Tasks may be simple or complex points may extend over long or short time periods. For example, and

6The collective dose concept applies to refueling may be considered a long, complex task involving several doses received collectively smaller by all members of an exposed group. These doses, as well as individual tasks such as head removal, internals removal, and fuel transfer, each doses, must be given due consideration in any radiation control plan one of which could be defined and associated with an estimated and especially in a plan such as the plant ALARA program. collective (man-rem) dose, i.e., the doses received collectively members of an exposed grou

p. by all

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effort required to integrate them into training. The desir without escort or special instruction (e.g., without a radia ability of mockup training should also be considered in tion work permit) and, therefore, responsible for their own light of the repetitiveness of a task. For example, the use of radiological safety). Such individuals should have a detailed mockup training for a low-man-rem task may have the knowledge of and be thoroughly familiar with the type and potential for a small one-time man-rem saving, but a signifi magnitude of radiation protection problems associated with cantly larger potential dose saving may be anticipated if the each and every plant system.

task is to be repeated many times.

D. IMPLEMENTATION

4. RADIATION PROTECTION STAFF

The purpose of this section is to provide information The radiation protection staff should be thoroughly to applicants and licensees regarding the NRC staff's plan conversant with the materials discussed in Regulatory for using this regulatory guide. This guide reflects practices Position 3. Their knowledge should be of sufficient depth currently acceptable to the NRC staff. Except in those to qualify them to provide technical support to the training cases in which the applicant or licensee proposes acceptable staff in the development and conduct of the radiation alternative practices or methods for complying with specified protection training. Further, they must be prepared to portions of the Commission's regulations, the practices or develop, modify, and implement the radiation protection methods described herein will be used as a basis for evaluating program competently. Professional members of the staff applications for construction permits and operating licenses will normally bring to the job the knowledge specified in and (in conjunction with inspection of performance) for Regulatory Guide 1.8, "Personnel Selection and Training."'I evaluating training programs established by licensees.

In the case of training programs at operating reactors, Many members of the radiation protection staff will appropriate modifications to such programs should be made have essentially unlimited access to all areas of the nuclear consistent with this guide as soon as practicable and no power plant (i.e., freedom to go anywhere in the plant later than one year after publication of this guide.

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Table 1 *

APPROPRIATE SUBJECTS FOR A RADIATION PROTECTION TRAINING

PROGRAM

Radiation Fundamentals a. The Nature of Radioactivity b. Sources of Radioactivity

(1) Natural Background Sources

(2) Manmade Sources

2. Measurement and Control of Exposure to Radiation and Radioactive Material (Contamination)

a. Types of Radiation and Their Characteristics b. External Dosimetry**

C. Controlling Exposure

(1) Exposure Time Limitation

(2) Distance Between People and Radiation Sources

(3) Shielding

(4) Source Strength Reduction (e.g., decontamination)

(5) Use of Protective Apparel**

(6) Respiratory Protection Devices and d. Sources (Origins) of Radioactive Materials their Use**

(Contamination) and Radiations at the Plant e. Source Identification and Control f. Types and Forms of Radioactive Materials (Contamination)

g. Detection and Control of Contamination**

h. Radiation Measurement and Survey Instruments**

i. Radioactive Wastes, Their Origins, Storage, Handling, and Disposal

3. Radiation Protection Program a. Purpose-Relationship to Individual b. ALARA Program c. Radiation Areas d. Airborne Radioactivity Areas e. Controlled Surface Contamination Areas f. Signs and Labels g. High Radiation Area Control h. Personnel Monitoring and Exposure Control

i. Bioassay

(1) Whole Body Counting

(2) Urinalysis

(3) Fecal Analysis

(4) Avoiding Sample Contamination j. Investigation and Reporting of Abnormal Exposures k. Air and Area Monitoring

1. Radiation Surveys--Purpose and Methods in. Rules and Procedures, Including Radiation Work Permits n. Pertinent NRC Regulations

• This table is not a course outline or order of presentation.

understanding of the listed subjects are not included. Basic subjects (for example, vocabulary and basic math) necessary to an Also, subjects appropriate to a specific plant obviously are not included.

• • See Section 2.3 with respect to the importance of "practical factors."

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Table 1 (Continued)

(1) Dose Limits

(2) Concentration Values

(3) Reporting Requirements (10 CFR Part 20)

(4) Reporting Responsibility (§ 19.12 of 10 CFR Part 19)

o. Professional Guidance and Assistance p. Detection and Control of Radioactively Contaminated Equipment and Detection, Control, and Removal of Radioactive Contamination from Personnel and Equipment

4. Biological Effects of Radiation a. Carcinogenesis b. Genetic Effects c. Acute Effects d. Latent Effects e. Collective Dose Concept

(1) Group Total Man-Rem Risk

(2) Individual Dose Risk f. Dose-Effect Relationship

(1) External Radiation

(2) Internal Radiation

5. Preparations for Emergencies and Incidents a. Plant Safety and Accident Control Features b. Signals and Alarms c. Evacuation Routes and Procedures d. Assembly Points e. Communications f. Guidance and Direction g. Emergency Equipment h. First Aid and Contaminated Wounds i. Spills**

• • See Section 2.3 with respect to the importance of "practical factors."

8.27-9

A- -

REFERENCES

I. U.S. Nuclear Regulatory Commission, NUREG-75/087, 5. National Safety Council, "Accident Facts," published LWR Edition, "Standard Review Plan for the Review of annually, 444 N. Michigan Avenue, Chicago, Illinois 60611.

Safety Analysis Reports for Nuclear Power Plants."*

6. International Commission on Radiological Protection,

2. U.S. Nuclear Regulatory Commission, NUREG-0041, ICRP-27, "Problems Involved in Developing an Index of

"Manual of Respiratory Protection Against Airborne Harm," Pergamon Press, Maxwell House, Fairview Park, Radioactive Materials," October 1976.* Elmsford, New York 10523, May 1977.

3. National Academy of Sciences, National Research Council,

7. United Nations Scientific Committee on the Effects of

"The Effects on Populations of Exposure to Low Levels Atomic Radiation, United Nations Publication Sales No.

of Ionizing Radiation," Washington, D.C. 20418, July 1980.

E.77.IX.1, "Sources and Effects of Ionizing Radiation,"

New York, New York 10001, 1977.

4. International Commission on Radiological Protection, ICRP- 26, "Recommendations of the International Com

8. U.S. Department of Health, Education and Welfare (currently mission on Radiological Protection," Pergamon Press, the Department of Health and Human Services), "Report Maxwell House, Fairview Park, Elmsford, New York of the Interagency Task Force on the Health Effects of

10523, January 1977. Ionizing Radiation," Washington, D.C. 20201, June 1979.

NUREG-series documents are available at current rates and draft 9. U.S. Nuclear Regulatory Commission, Draft Regulatory regulatory guides are free upon request through the Distribution Services Section, Division of Technical Information and Document Guide OH 902-1, "Instruction Concerning Risk from Control, U.S. Nuclear Regulatory Commission, Washington, D.C. Occupational Radiation Exposure," under development,

20555. issued May 1980.*

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VALUE/IMPACT STATEMENT

1. THE ACTION The principal value to the staff of providing the guidance is that it seems the most cost-effective way of ensuring

1.1 Description adequate training programs.

Nuclear power plant personnel, in accordance with Impact - No impact is foreseen.

10 CFR Part 19, must receive training in radiation protection to ensure that they are aware of and prepared to cope with 1.3.2 Other Government Agencies radiological hazards. The training must be commensurate with the individual's duties and responsibilities. Para Not applicable, unless the government agency is an graph 20.1(c) of 10 CFR Part 20 states that occupational applicant or licensee.

radiation exposure should be kept "as low as is reasonably achievable" (ALARA). Appropriate training is an essential 1.3.3 Industry aspect of an ALARA program. Regulatory Guide 8.27,

"Radiation Protection Training for Personnel at Light-Water Value- The guidance is expected to benefit applicants Cooled Nuclear Power Plants," discussed in this statement, by reducing occupational radiation exposures. Experience will furnish guidance on the extent of training necessary in shows that exposure reduction is truly cost reduction.

radiation protection training programs. Secondary benefits expected include improved labor relations and, possibly, improved relations with the public.

1.2 Need Also, the preparation and maintenance of suggested training records** may result in the elimination of redundant training Available information indicates that radiation protection and, consequently, in reduced costs.

training programs exist at all nuclear power plants but that there are wide variations in program scope and depth among Impact - It will be necessary for applicants (or their plants. In some instances, programs include requirements contractors) to spend additional time describing their that are needlessly expensive and time consuming. In other programs in their safety analysis reports (SARs) if they cases, the need for guidance with respect to program content choose alternatives other than those provided in the guide.

is indicated by deficiencies in applicants' program descrip Because of training program variability, improvements in tions. This regulatory guide establishes the NRC staff posi licensee training programs may be necessary in some tion regarding acceptable training programs and provides a instances. However, the added cost from this action is not basis for the evaluation of such programs. expected to be great since (1) program descriptions are necessary for internal purposes (e.g., to ensure uniform and Training is a major factor in controlling exposure. In adequate training), (2) existing training programs are the action plan (SECY-77-54)* prepared by the NRC Task normally revised periodically, (3) the guidance is based Group on Occupational ALARA, guidance on training was on a regulatory requirement that has been in effect for given top priority. This regulatory guide will meet the rele several years, (4) the guidance represents current staff vant recommendation of the task group. practices, and (5) nothing in the guide is intended to increase current recordkeeping requirements.

1.3 Value/Impact

1.3.4 Workers

1.3.1 NRC

The guide should result in improved worker protection Value - This guide provides a basis for staff review of by helping to ensure that the individual worker has enough applicants' commitments to radiation protection training knowledge to work safely, use available protective measures, and licensees' radiation protection training programs and and obtain appropriate guidance in accordance with ALARA

provides a basis for NRC inspection of the programs to concepts.

ensure that they are conducted as approved.

1.3.5 Public Availability of the guide should result in more effective and efficient evaluation of training programs and acceptably Value - The general public should benefit to some extent small time and manpower requirements for evaluating the from a reduction in occupational exposure and heightened training programs. Without the guidance, program evaluation awareness of radiological hazards.

is ineffective or highly time consuming.

Training records are covered in standard technical specifica This Commission paper, dated February 4, 1977, is available for tions referenced in Regulatory Guide 1.70, "Standard Format and public inspection or copying for a fee at the NRC Public Document Content of Safety Analysis Reports for Nuclear Power Plants, LWR

Room, 1717 H Street NW., Washington, D.C. Edition," which is based on §50.36 of 10 CFR Part 50,

8.27-11

Impact -No direct impact on the public is foreseen. only until a more permanent mode of guidance can be issued.

2. TECHNICAL APPROACH

The issuance of a regulatory guide is the most appropriate Although there will be technical alternatives in .the alternative in terms of time, content, and application. Also, development and conduct of training programs based on the development of a regulatory guide provides for comments the guide, only procedural alternatives were available in by interested persons.

preparing the guide.

3.3 Decision on Procedural Approach

3. PROCEDURAL APPROACH

A regulatory guide based on discussions with and com

3.1 Procedural Alternatives ments from the various interested parties was determined to be the best approach.

Several methods of issuing the proposed guidance were considered, including an NRC regulation, an ANSI standard 4. STATUTORY CONSIDERATIONS

endorsed by a regulatory guide, a NUREG-series report, a branch position, and a regulatory guide. These are discussed 4.1 NRC Authority in Section 3.2.

Section 19.12 of 10 CFR Part 19 requires that personnel

3.2 Value/Impact of Alternatives be given instruction in radiation protection that is commen surate with the potential radiological health protection An NRC regulation requires a complex and time-consuming problems encountered by these personnel.

legal procedure that is more suitable for general requirements than specific guidance. Regulations do not generally contain 4.2 Need for NEPA Assessment the detail included in the guide. The difficulty involved in revising the guidance would be greater for this alternative The issuance of the guide is not a major action. The than for the others. An advantage would be that the regula guide merely explains and elaborates on an existing require tion would legally require conformance, whereas the other ment (§ 19.12 of 10 CFR Part 19). There will be no alternatives would not. In general, however, the relatively effect on the environment. Therefore, there is no need for a narrow subject matter does not warrant use of this alterna NEPA assessment.

tive.

5. RELATIONSHIP TO OTHER EXISTING OR PRO

POSED REGULATIONS OR POLICIES

No ANSI standard on the subject is known to be under preparation. This procedure could be logically undertaken When Regulatory Guide 1.70, "Standard Format and by the Health Physics Society as an addition to the ongoing Content of Safety Analysis Reports for Nuclear Power ANSI N13 Committee activities. However, past history of Plants, LWR Edition," is next revised, consideration should these working groups indicates that standards developed by be given to including at least those portions of this guide them cover a much broader base and usually require more that deal with information to be included in SARs.

than 2 years for development. Issuance of an endorsing regulatory guide would take an additional year or more. As This guide is consistent with and cross-references Regu with the regulation alternative, it is believed that the latory Guides 8.8, "Information Relevant to Ensuring that narrow subject matter and the time involved work against Occupational Exposures at Nuclear Power Stations Will Be use of this alternative. As Low As Is Reasonably Achievable," and 8.10, "Operating Philosophy for Maintaining Occupational Radiation Expo sures As Low As Is Reasonably Achievable." When these NUREG-series reports can be prepared and published two guides are revised, consideration should be given to more rapidly than can the other alternatives. By NRC referencing this guide.

practice, however, a NUREG-series report cannot contain regulatory positions. Since positions are an integral part of 6. SUMMARY AND CONCLUSION

the guidance, use of a NUREG-series report is not suitable.

The values and impacts of the action will vary widely The Office of Nuclear Reactor Regulation has not yet from plant to plant. In some cases, impacts may outweigh prepared a branch position on this subject and has indicated values; in others, the reverse will be true. In general, however, that a regulatory guide on the subject would be appropriate. it was the expert judgment of the ALARA task group that Also, branch positions have limited circulation and are the value will be greater, in general, than the impact.

considered to be temporary measures that are to be used Therefore, the regulatory guide has been issued.

8.27-12

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