Introduction and ALARA Philosophy Radiological Safety and
Response RPT-243 -1
Slide 3
The following Learning Outcomes are addressed in Session 1
Slide 4
Learning Outcomes Upon completion of this lesson, the student
will be able to: Explain the four common stages of team formation
and growth (PE). As assigned by the Instructor, participate as a
contributing team member on an RPT Student team (PE). Demonstrate
the use of the SLAPPS mnemonic to exercise situational awareness
(PE). Demonstrate the proper use of the 3 part communication model
including the use of the phonetic alphabet and numeric
communication (PE). Demonstrate the proper use of the STAR acrostic
to exercise self-checking (PE).
Slide 5
The following Learning Outcomes are addressed in Session 2
Slide 6
Learning Outcomes (contd) Upon completion of this lesson, the
student will be able to: Define and discuss the interrelationship
among the following: regulation regulatory guide NUREG
recommendation (health physics position papers) license condition
technical specification
Slide 7
Identify the scope, explain the principles and the use of the
following standards: 10CFR19, Notices, Instructions, and Reports to
Workers 10CFR20, Standards for Protection Against Radiation 10
CFR835, Occupational Radiation Protection regulatory guides
applicable to power reactor radiological protection (such as RG
8.38, RG 8.13, and RG 8.15) Identify the ALARA philosophy for
collective personnel exposure and individual exposure. Discuss why
radiation exposures to individuals and to groups of workers are to
be kept as low as reasonably achievable (ALARA). Learning Outcomes
(contd) Upon completion of this lesson, the student will be able
to:
Slide 8
Describe the assumptions on which the current ALARA philosophy
is based. Identify the scope of an effective radiological ALARA
program. Explain how exposure goals can be used to reduce
individual and collective exposures for specific radiological jobs,
for work groups, and for the plant. Explain the ALARA concept and
how it is applied to radiological work at the plant (for example,
time, distance, shielding, engineering controls, and source
reduction). Learning Outcomes (contd) Upon completion of this
lesson, the student will be able to:
Slide 9
Describe the total risk concept as it applies to the
prescription of radiological work controls. Describe special
precautions to be used when practical to control or reduce
exposures during certain radiological conditions, such as:
assignment of stay times and timekeepers, continuous radiological
protection technician coverage, use of alarming dosimeters or dose
rate meters, use of temporary shielding, availability of low dose
rate waiting areas, and removal of high dose rate sources. Learning
Outcomes (contd) Upon completion of this lesson, the student will
be able to:
Slide 10
Describe work time reduction techniques that can be used to
reduce worker radiation exposure, such as the following: pre-job
planning and preparation pre-job mockup training for worker
familiarity review of procedures for workability and efficiency use
of special tools to improve worker efficiency improvement of worker
comfort by controlling the environment (temperature, lighting,
humidity, space) prefabrication of equipment in low-dose or no-dose
areas decontamination to reduce protective clothing requirements
Learning Outcomes (contd) Upon completion of this lesson, the
student will be able to:
Slide 11
Describe techniques by which increased distance can be used to
reduce worker radiation exposure, such as: positioning workers away
from hot spots or high dose areas, using remote operators or
special tools to increase worker distance from a source, and
removing equipment to low dose areas for maintenance. Discuss
factors that determine the ultimate effectiveness of installing
temporary shielding, such as the cost of installation (dollars and
person-rem) versus benefit, physical space limitations, 10CFR50.59
review constraints, floor loading constraints, and pipe and pipe
hanger load constraints. Learning Outcomes (contd) Upon completion
of this lesson, the student will be able to:
Slide 12
Describe the consequences of removing permanent or temporary
shielding without proper review and authorization. Explain the
responsibilities of the following personnel regarding specifying,
complying with, monitoring, and enforcing radiological protection
and ALARA requirements: worker workers supervisor radiological
protection technician radiological protection supervisor Learning
Outcomes (contd) Upon completion of this lesson, the student will
be able to:
Slide 13
Outline Session 1 Introduction Team Dynamics Human Performance
Improvement Session 2 Regulatory Hierarchy and Relationships ALARA
Philosophy and Why Implementing ALARA Total Risk Concept Use of
Goals Time Distance Shielding Responsibilities Questions
Slide 14
Introduction RPT-243-1 Session 1
Slide 15
Introduction A shift in approach: Up to this point classes have
been largely theoretically based with some guided instruction in
practical hands-on competencies Now we move to largely hands-on
instruction culminating in performance for evaluation. That is we
will revisit some of the tasks you have been exposed to and coached
through and will provide an evaluation of your performance as a
team and as an individual.
Slide 16
Introduction Additionally, we will introduce new aspects of
previous topics, such as: Regulatory hierarchy and relationships
More details from the regulations regarding and implementation of
controls for: Limits Postings Access Control Contamination Control
Emergency Response ALARA and Radiological Planning Use of the BIG
Three TDS
Slide 17
Introduction However, first we will introduce some tools that
will help you start to acclimate yourself to the day-to-day life of
an RP technician: Team Dynamics Human Performance Improvement
Slide 18
Team Dynamics
Slide 19
Team Together Everyone Achieves More Many different ways to
look at TEAM function and TEAM theory exist. Arguably, the most
popular model is one put forward by Bruce Tuckman in an article
first published in 1965. He described four stages of team formation
and growth: Forming Storming Norming Performing
Slide 20
Forming Team members meet each other. Individual expectations
as being part of the team are defined. The leaders ability to guide
the team most likely is tested during the forming stage. Notes: In
a high turnover organization, or one that has undergone
reorganization, teams are in some stage of forming on a frequent
basis New employees or new team members always start in this
stage
Slide 21
Forming Tips for moving through this stage: Recognize where you
and your team mates are Step out and introduce yourself to each
other Take time to get to know each other Seek out a clear
definition of: The teams mission Expectations on the team
Individual members roles and responsibilities Recognize that not
everyone will become comfortable on the team at the same rate
Slide 22
Storming The team begins to understand what the end goal is.
However, each member may have a different idea as to how best to
proceed toward that goal. Team members personal agendas may become
clear as each vies for credit for ideas. Members may start to
compete with each other. They may discount each others ideas.
Generally, they avoid collaboration. Storming is usually the most
difficult stage for the team.
Slide 23
Storming Tips for moving through this stage: Stay on task help
remind each other what that is Learn and use compromising and
negotiating skills Ensure goals are achievable and realistic Use
the good days to share positive feelings and experiences and
celebrate successes Use appropriate humor to dampen tension Keep it
positive and upbeat
Slide 24
Norming Team members: Agree on the focus Are enthusiastic Are
goal-driven Accept each other Tips: Encourage continued
graciousness in giving and receiving constructive criticism Stay
focused Establish internal rules and guidelines
Slide 25
Performing Team members: Identify and solve problems Implement
changes Make measurable progress toward the goal Tips: Do not take
advantage of each others strengths or weaknesses Look within
yourself when problems are encountered Where do I need to change?
Work through problems within the team Encourage each other in
taking bite sized chunks Seek to continue to bond as team
members
Slide 26
Mature Teams Recognize that actions speak louder than words
Understand that self-respect is a strong motivating force Agree
that placing a high value on integrity builds support within the
team Have learned that flexibility develops deep trust Recognize
the need to renew themselves from time to time.
Slide 27
Four Stages of Team Growth
Slide 28
Teams in Summary Forming We are watchful, polite, and guarded.
We dont really know or understand the boundaries or the rules.
Storming and Norming We get organized, develop skills as a team,
establish procedures, give and receive feedback, and confront
issues after we learn how. Performing We are close and supportive.
We tend to be flexible, open, and synergistic. Together Everyone
Achieves More
Slide 29
Expectations RPT Students will be split into teams by the
Instructor. The Teams will stay intact over the semester until the
Instructor decides otherwise. The Teams shall perform all Labs and
Practical Exercises (PE) as directed by the Instructor. The Teams
will be coached by the Instructor on improving team
performance.
Slide 30
Human Performance Improvement Tools
Slide 31
Definition According to Purdue University one definition of
Human performance improvement is: the systematic process of
discovering and analyzing important human performance gaps planning
for future improvements in human performance, designing and
developing cost-effective and ethically justifiable interventions
to close performance gaps, implementing the interventions, and
evaluating the financial and non-financial results.
Slide 32
What that means For the nuclear worker it means: An
acknowledgement that using radioactive material involves humans
That humans make mistakes (performance gaps) Consequences of
mistakes using radioactive material can have significant impact on
the worker, the general public and the environment Therefore, those
performance gaps must be studied and tools implemented that will
minimize the frequency of the occurrence of the gaps. Good News the
tools have been already been developed
Slide 33
Fundamental Tools Four Fundamental Tools exist that should
become part of how you do business. Integrating these tools into
your routine work habits will help ensure a high level of
performance in everyday tasks and will assist you in responding to
off normal and emergency occurrences. The four tools to be reviewed
are: Situational Awareness Communications Self-Checking Procedure
Use and Adherence
Slide 34
Situational Awareness
Slide 35
Clearly, the workers mindset toward the task at hand sets the
stage for excellence. Situation awareness tools help the worker
form an accurate understanding of the work and equipment situation
fostering an attitude sensitive to the presence of hazards and the
possible consequences of a mistake. Situation Awareness Tools to be
Considered: Task Preview Job-Site Review Questioning Attitude
Stopping Work
Slide 36
Task Preview Just as the name implies it is a review of a task
prior to attending a pre-job briefing or starting to work. Also it
should be used after extended delays in performing an activity
Review procedures and related documents Walk down the work site
(may not be feasible because of dose or contamination)
Slide 37
Task Preview Talk to workers that have done the job Look at old
job packages for the same task (job history) Provides a structured,
risk-based review from a human performance perspective Consider
using the SAFER mnemonic to stay on track
Slide 38
SAFER S summarize the critical steps A anticipate errors for
each critical step and relevant error precursors F foresee probable
and worse-case consequences should an error occur during each
critical step E evaluate controls or contingencies at each critical
step to prevent, catch, and recover from errors and to reduce their
consequences R review previous experience and lessons learned
relevant to the specific tasks and critical steps
Slide 39
Job-Site Review Sometimes referred to as Take Two Used to
improve situational awareness upon initial arrival at a work site.
Take time to look at and understand critical indicators, equipment
condition, work environment hazards, and team members condition and
location. Helps establish a healthy sense of uneasiness, raising
the questioning attitude and accuracy of your situational
awareness. Based on review, hazards should be addressed prior to
proceeding
Slide 40
Questioning Attitude By definition Attitude is a state of mind
or feeling toward a subject or object of interest. A questioning
attitude then would a state of mind or feeling toward a subject
that involves questioning what might be assumed or otherwise
perceived about a job or task at hand. A questioning attitude
fosters situational awareness prompting thought before action. Use
the following main steps to facilitate a questioning attitude.
Slide 41
SLLAPS Stop, Look, and Listen Stop at the beginning and
periodically to search the work situation for warning signs such
as, uncertainty, confusion, and doubts. Listen for danger words
such as, I assume, probably, I think, maybe, should be, might be,
etc. Ask Questions What are the knowns and unknowns? What are the
points of confusion and uncertainties? Are the conditions and
situations what you expected and were briefed on?
Slide 42
SLLAPS Proceed - only if you are sure. Have your uncertainties
be resolved with facts? Otherwise, do not proceed in the face of
uncertainty! Stop when you are unsure and when uncertainties,
confusion and doubts persist. Stop the work Place the job site and
equipment in a safe condition Notify your supervisor
Slide 43
Stop Work Every worker has the authority and responsibility to
stop any job in which they are engaged where they are uncertain and
unclear about what is happening with the task. Additionally,
Radiation Protection Technicians have the responsibility and
authority to stop any job where, in their opinion, continuation
with the work will result in an unsafe radiological situation.
(Actual company guidelines will dictate the specifics of exercising
that authority.)
Slide 44
Expectations RPT Students are expected to use the tools and
techniques discussed here during all Labs and PEs. Specifically the
SLLAPS mnemonic is to be used when participating in PEs using the
scenario-based training approach. Students should use the thinking
out loud techniques encouraged in the RPT-113 course. Students will
be graded on the proper use of the SLLAPS mnemonic.
Slide 45
Communications
Slide 46
Communnication The process by which information is exchanged
between individuals, departments, or organizations The lifeline of
the team Most effective when it permeates every aspect of an
organization
Slide 47
Barriers to Communication Language cultural, professional
jargon, generational Distractions noise, adjacent secondary
activities, multi- tasking Physical proximity geographical, spatial
Personalities Otter, Spaniel, Lion, Retriever Workload overloaded
schedule, collateral duties Varying communication styles Conflict
at work, at home, at school, wife, husband Lack of information
verification communicating information w/o verifying accuracy or
validity Shift change loss of focus, distractions
Slide 48
Standards for Effective Communication Complete Communicate all
relevant information. Clear Convey information that is plainly
understood. Brief Communicate the information in a concise manner.
Timely Offer and request information in an appropriate timeframe.
Verify authenticity. Validate or acknowledge information.
Slide 49
Tools for Effective Communication Use common language
professional, technical information, should be standardized. Use
numeric pronunciation that is, one five vs. fifteen (can sound like
fifty) Use phonetic alphabet alpha, bravo, charlie, delta Using the
phonetic alphabet is unnecessary when using standard approved
acronyms, such as RHR (residual heat removal).
Slide 50
Phonetic Alphabet A - Alpha B - Bravo C - Charlie D - Delta E -
Echo F - Foxtrot G - Golf H - Hotel I - India J - Juliet K - Kilo L
- Lima M - Mike N - November O - Oscar P - Papa Q - Quebec R -
Romeo S - Sierra T - Tango U - Uniform V - Victor W -Whiskey X -
X-ray Y - Yankee Z - Zulu
Slide 51
Tools for Effective Communication Active Listening - a way of
listening that focuses entirely on what the other person is saying
and confirms understanding of both the content of the message and
the emotions and feelings underlying the message to ensure that
understanding is accurate.
Slide 52
Tools for Effective Communication Use closed loop communication
(three-part communication model) - in all critical communications
involving: the operation or alteration of plant equipment the
condition of plant equipment or the value of an important parameter
the performance of steps or actions using an approved procedure
task assignments that impact plant equipment or plant activities
the safety of personnel, the environment, or the plant Focus
Slide 53
Closed Loop Communication
Slide 54
Roles and Responsibilities The person originating the
communication is the sender and is responsible for verifying that
the receiver understands the message as intended. The receiver
makes sure he or she understands what the sender is saying. First,
the sender gets the attention of the receiver and clearly states
the message. Second, the receiver repeats the message in a
paraphrased form, which helps the sender know if the receiver
understands the message. (Many organizations required verbatim
repeat-backs.)
Slide 55
Roles and Responsibilities During this exchange, the receiver
restates equipment-related information exactly as spoken by the
sender. In the event the receiver does not understand, they will
indicate it with Say Again. Third, the sender informs the receiver
whether the message is properly understood, or corrects the
receiver and restates the message.
Slide 56
Scenario One of the shift RPTs is in the RCA and identifies a
leak on the CVCS. The RPT, using the radio, calls the SS in the
Unit 2 CR to report the leak. Listen to the conversation and see if
you can identify some of the tools weve named and the closed loop
communication model.
Slide 57
3 Part Communication Dialogue RPT Shift Supervisor, this is the
Shift Radiation Protection Technician. SS Shift RP, this is the SS
go ahead. RPT SS, I have identified a Chemical Volume Control
System leak on the 3-3-5 elevation of the Unit 2 Auxiliary Building
room 2-2-5-2. SS Shift RP, I understand you have a Chemical Volume
Control System leak on the 3-3-5 elevation of Unit 2 Auxiliary
Building in Room 2-2-5-2. RPT- That is correct. SS Shift RP, what
is the approximate leak rate and component identification for the
leak.
Slide 58
3 Part Communication Dialogue RP- SS, the leak rate is
approximately fifteen drops per minute coming from the packing
gland on the 2P-32D Charging Pump SS I understand fifty drops per
minute from 2D-52B packing gland. RP That is not correct. The leak
rate is one five drops per minute from two papa three-two delta
packing gland. SS I understand, the leak rate is one five drops per
minute from two papa three-two delta packing gland. RP That is
correct.
Slide 59
Critique Sender Receiver Phonetic Alphabet Numeric
Communication Feedback Verbatim Repeat Back Confirmation
Slide 60
Expectations The three part communication model will be used in
all Labs and Practical Exercises for the RPT Program. Students will
be graded on use of the model. The phonetic alphabet will be used
when communicating alpha characters during all Labs and Practical
Exercises for the RPT Program. Students will be graded on use of
the phonetic alphabet. Numeric communication will use the
pronunciation of the number, i.e. one-five vs. fifteen. Students
will be graded on use of numeric communication.
Slide 61
Self-Checking
Slide 62
Self-checking enables the worker to focus their attention on a
specific step of the task at hand to: Think about the intended
action and Understand the expected outcome before acting and then,
To verify expected results are obtained after the action has been
taken.
Slide 63
Self-Checking Used most often when: manipulating plant
equipment entering data into a computer recording data on a form
performing a calculation when assembling components with similar
parts Use the STAR acrostic
Slide 64
STAR Stop Pause and focus attention on performing the
self-check Think engage your mind to consider: do you understand
what you are going to do? what the expected result will be? a
contingency if the expected result does not occur ? are there
questions that need to be answered?
Slide 65
STAR Act perform the correct action on the intended component
Look at, touch, and read the component label Compare what is there
with documentation Maintain contact and perform the action Review
verify the expected result was achieved If not, perform the
contingency action Notify the supervisor as appropriate
Slide 66
Expectations RPT Students will be expected to employ the STAR
acrostic during those Labs and Exercises which require:
manipulating plant equipment entering data into a computer
recording data on a form performing a calculation The students
should use the thinking out loud techniques encouraged in RPT-113
PEs. Students will be graded on the use of the STAR acrostic.
Slide 67
Procedure Use and Adherence
Slide 68
Every organizations procedure hierarchy and expectations
regarding the use of the procedures at different levels within that
hierarchy will vary considerably. However, most facilities using
radioactive materials will have a procedure structure similar to
the following: Administrative Procedures describe the manner in the
organizations departments fulfill the vision and mission of the
organization as well as satisfying regulatory requirements.
Slide 69
Procedure Use and Adherence Most facilities using radioactive
materials will have a structure similar to the following:
Administrative Procedures- Implementing Procedures describe the
step by step means by which the requirements of the Administrative
Level Procedures are satisfied. They may be categorized by the
discipline to which they apply. These may have different kinds of
procedures: Surveillance Procedures Maintenance Procedures
Operating Procedures
Slide 70
Procedure Use and Adherence Adherence means understanding the
intent and purpose of a procedure and following its direction. The
user follows the steps of the procedure as they are sequenced and
as they are written. However, if it can not be followed as written,
the work is stopped and the procedure is corrected. The expectation
is not BLIND compliance but THINKING compliance. Use means the
frequency or degree of reference by the user versus dependence on
the users memory or recall.
Slide 71
Procedure Use and Adherence Within the categories discussed
above, the level of use for the procedure will typically be
designated as one of the following: Continuous Use for complex or
infrequently performed tasks where an improper action would result
in an immediate impact on safety, production, or reliability.
Reference Use for complex or infrequently performed tasks where the
consequences of an improper action may not be immediate.
Slide 72
Procedure Use and Adherence Within the categories discussed
above, the level of use for the procedure will typically be
designated as one of the following: Information Use - for
activities, usually administrative in nature, that do not require
direct contact with plant equipment or components and do not have
immediate consequences when performed incorrectly
Slide 73
Procedure Use and Adherence How? Continuous Use Read and
understand each step before performing the step Complete each step
before moving to the next step Complete in the sequence provided
Use a place keeping technique Keep the procedure document in the
presence of the user continuously
Slide 74
Procedure Use and Adherence Reference Use Review and understand
segments before performing any steps, periodically, and as each
segment is completed Segments can be performed from memory Use
place keeping as needed Keep the document at the work site Review
the document at the completion of the task
Slide 75
Procedure Use and Adherence Information Use Activity can be
done from memory Review the procedure before use Keep the document
available and review as needed
Slide 76
Expectations As they are made available RPT Students are
expected to adhere to the proper use of the procedure as described
here and as directed by the Instructor.
Slide 77
RPT-243 Practical Exercise - 1
Slide 78
ALARA RPT-243-1 Session 2
Slide 79
Learning Outcomes Upon completion of this lesson, the student
will be able to: Define and discuss the interrelationship among the
following: regulation regulatory guide NUREG recommendation (health
physics position papers) license condition technical
specification
Slide 80
Identify the scope, explain the principles and the use of the
following standards: 10CFR19, Notices, Instructions, and Reports to
Workers 10CFR20, Standards for Protection Against Radiation 10
CFR835, Occupational Radiation Protection regulatory guides
applicable to power reactor radiological protection (such as RG
8.38, RG 8.13, and RG 8.15) Identify the ALARA philosophy for
collective personnel exposure and individual exposure. Discuss why
radiation exposures to individuals and to groups of workers are to
be kept as low as reasonably achievable (ALARA). Learning Outcomes
(contd) Upon completion of this lesson, the student will be able
to:
Slide 81
Describe the assumptions on which the current ALARA philosophy
is based. Identify the scope of an effective radiological ALARA
program. Explain how exposure goals can be used to reduce
individual and collective exposures for specific radiological jobs,
for work groups, and for the plant. Explain the ALARA concept and
how it is applied to radiological work at the plant (for example,
time, distance, shielding, engineering controls, and source
reduction). Learning Outcomes (contd) Upon completion of this
lesson, the student will be able to:
Slide 82
Describe the total risk concept as it applies to the
prescription of radiological work controls. Describe special
precautions to be used when practical to control or reduce
exposures during certain radiological conditions, such as:
assignment of stay times and timekeepers, continuous radiological
protection technician coverage, use of alarming dosimeters or dose
rate meters, use of temporary shielding, availability of low dose
rate waiting areas, and removal of high dose rate sources. Learning
Outcomes (contd) Upon completion of this lesson, the student will
be able to:
Slide 83
Describe work time reduction techniques that can be used to
reduce worker radiation exposure, such as the following: pre-job
planning and preparation pre-job mockup training for worker
familiarity review of procedures for workability and efficiency use
of special tools to improve worker efficiency improvement of worker
comfort by controlling the environment (temperature, lighting,
humidity, space) prefabrication of equipment in low-dose or no-dose
areas decontamination to reduce protective clothing requirements
Learning Outcomes (contd) Upon completion of this lesson, the
student will be able to:
Slide 84
Describe techniques by which increased distance can be used to
reduce worker radiation exposure, such as: positioning workers away
from hot spots or high dose areas, using remote operators or
special tools to increase worker distance from a source, and
removing equipment to low dose areas for maintenance. Discuss
factors that determine the ultimate effectiveness of installing
temporary shielding, such as the cost of installation (dollars and
person-rem) versus benefit, physical space limitations, 10CFR50.59
review constraints, floor loading constraints, and pipe and pipe
hanger load constraints. Learning Outcomes (contd) Upon completion
of this lesson, the student will be able to:
Slide 85
Describe the consequences of removing permanent or temporary
shielding without proper review and authorization. Explain the
responsibilities of the following personnel regarding specifying,
complying with, monitoring, and enforcing radiological protection
and ALARA requirements: worker workers supervisor radiological
protection technician radiological protection supervisor Learning
Outcomes (contd) Upon completion of this lesson, the student will
be able to:
Slide 86
Outline Session 2 Regulatory Hierarchy and Relationships ALARA
Philosophy What Where When Who Why Implementing ALARA the How Use
of Goals Time Distance Shielding Responsibilities
Slide 87
Definitions Regulation For our purpose we will define
regulation as it applies to our industry. In order to do that, we
need a little background. Congress has authorized the formation of
the various regulatory commissions by the Executive Branch which
exist for the purpose of overseeing highly specialized or technical
endeavors. In our case the Nuclear Regulatory Commission (NRC). The
Department of Energy and other departments serve at the cabinet
level to advise the President in specific areas of our society and
oversee the administration of the departments.
Slide 88
Definitions Regulation All of the agencies, departments and
commissions promulgate rules for operating. The Administrative
Procedure Act (APA) is the United States federal law that governs
the way in which those administrative agencies of the federal
government may propose and establish the rules or regulations.
Under the APA, the various agencies and commissions are permitted
to promulgate detailed rules and regulations through a public
"rulemaking" process where the public is allowed to comment.
Slide 89
Definitions Regulation After a period of time, the rules and
regulations are usually published in the Federal Register as The
Code of Federal Regulation (CFR) and carry the full force of
administrative law (regulations). The CFR is divided into 50 titles
that represent broad areas subject to Federal regulation. The Title
that we will focus on here is Title 10 EnergyEnergy Other Titles
used in our profession would be: Title 29 Labor (OSHA) Title 49
Transportation (RAM Shipping)
Slide 90
Definitions Regulatory Guide Regulatory Guides (RG) provides:
guidance to licensees and applicants on implementing specific parts
of the NRC's regulations, techniques used by the NRC staff in
evaluating specific problems or postulated accidents, and data
needed by the staff in its review of applications for permits or
licenses. May be used by DOE when referenced in their implementing
guides.
Slide 91
Definitions Regulatory Guide Interestingly enough, RGs are not
regulations and do not have to be followed. However, best be sure
that you know that you are satisfying regulation with the method(s)
you are using.
Slide 92
Definitions NUREG Reports or brochures on regulatory decisions,
results of research, results of incident investigations, and other
technical and administrative information. Publications Prepared by
NRC Staff NUREG-(nnnn) Brochures Prepared by NRC Staff
NUREG/BR-(nnnn) Conference Proceeding Prepared by NRC Staff or
Contractors NUREG/CP-(nnnn) Publications Prepared by NRC
Contractors NUREG/CR-(nnnn)
Slide 93
Definitions NUREG Publications Resulting from International
Agreements NUREG/IA-(nnnn) Publications Available in the Agencywide
Documents Access and Management System (ADAMS) Drafts for Comment
Not regulation, rather a communication tool.
Slide 94
Definitions Health Physics Position Papers The Health Physics
Positions (HPPOS) Database (NUREG/CR- 5569, Rev. 1, 1994) is a
compilation of NRC staff positions on a wide range of topics
involving radiation protection (health physics). It consists of
over 300 documents in the forms of letters, memoranda, and excepts
from technical reports. The HPPOS Database was developed by NRC
Headquarters and Regional Offices to help ensure uniformity in
inspections, enforcement, and licensing actions. Again not
regulation, but very valuable to help understand what the
regulations mean to accomplish.
Slide 95
Definitions License Condition and Tech Specs 10CFR50 DOMESTIC
LICENSING OF PRODUCTION AND UTILIZATION FACILITIES is the federal
regulation that stipulates the application and licensing process to
be followed for a nuclear power plant. DOMESTIC LICENSING OF
PRODUCTION AND UTILIZATION FACILITIES The regulation requires that
the applicant provide a description and safety assessment of the
site and a safety assessment of the facility.
Slide 96
Definitions License Condition and Tech Specs It is expected
that reactors will reflect through their design, construction and
operation an extremely low probability for accidents that could
result in the release of significant quantities of radioactive
fission products.
http://www.nrc.gov/reading-rm/doc-collections/cfr/part050/part050-0034.html
http://www.nrc.gov/reading-rm/doc-collections/cfr/part050/part050-0034.html
10CFR50 also specifies that as part of the application process, the
plant must submit a set of technical specifications for the plant.
http://www.nrc.gov/reading-rm/doc-collections/cfr/part050/part050-0036.html
Slide 97
Definitions License Condition and Tech Specs The process also
requires the applicant develop a detailed Emergency Plan that
becomes part of their license. http://www.nrc.gov/reading-rm/doc-
collections/cfr/part050/part050-0047.html
http://www.nrc.gov/reading-rm/doc-
collections/cfr/part050/part050-0047.html Each licensee is required
to develop and implement policies and procedures as necessary to
ensure that the plant is operated in a manner that maintains the
integrity of the license requirements. This includes Abnormal and
Emergency Operating Procedures (AOPs and EOPs) Additional License
Conditions may be stipulated in the actual License issued.
Slide 98
Specific Regulations and Guides Scope, Principles and Use
Slide 99
10 CFR 19, Notices, Instructions, and Reports to Workers
Workers rights, responsibilities, and protection NRCs obligations
regarding inspections and reports Licensees rights and
responsibilities Addressed in station procedures Applies to NRC
Licensed Operations
http://www.nrc.gov/reading-rm/doc-collections/cfr/part019/part019-0001.html
Slide 100
10 CFR 20, Standards for Protection Against Radiation Establish
standards for protection against ionizing radiation resulting from
activities conducted under licenses issued by the Nuclear
Regulatory Commission. It is the purpose of the regulations in this
part to control the receipt, possession, use, transfer, and
disposal of licensed material by any licensee in a manner that
prevents the limits from being exceeded. Implemented by station
procedures.
http://www.nrc.gov/reading-rm/doc-collections/cfr/part020/
Slide 101
10 CFR 835, Occupational Radiation Protection The rules in this
part establish radiation protection standards, limits, and program
requirements for protecting individuals from ionizing radiation
resulting from the conduct of DOE activities. Implemented by
directives, implementation guides, and site procedures.
http://ecfr.gpoaccess.gov/cgi/t/text/text-
idx?c=ecfr&sid=a0ed5212bc08d5c0c423998a161a577d&rgn=div5&view=text&node=10:4.0.2.5.27&idno=10#1
0:4.0.2.5.27.1.82.1
https://www.directives.doe.gov/directives/current-directives/441.1-EGuide-1c/view
Slide 102
Power Reactor RP Regulatory Guides RG- 8.13 - Instruction
Concerning Prenatal Radiation Exposure - This regulatory guide is
intended to: provide information to pregnant women, and other
personnel, to help them make decisions regarding radiation exposure
during pregnancy. This Regulatory Guide 8.13 supplements Regulatory
Guide 8.29, Instruction Concerning Risks from Occupational
Radiation Exposure, which contains a broad discussion of the risks
from exposure to ionizing radiation.
Slide 103
Power Reactor RP Regulatory Guides RG- 8.10 - Operating
Philosophy For Maintaining Occupational Radiation Exposures As Low
As Is Reasonably Achievable - This regulatory guide describes to
licensees a general operating philosophy acceptable to the NRC
staff as a necessary basis for a program of maintaining
occupational exposures to radiation as low as is reasonably
achievable. Establishes: The equivalence of collective and
individual doses as it pertains to ALARA philosophy Two main
conditions for any organizations ALARA program to be effective
(discussed later)
Slide 104
Power Reactor RP Regulatory Guides RG- 8.38 - Control Of Access
To High And Very High Radiation Areas In Nuclear Power Plants -
This regulatory guide describes methods that the NRC staff finds
acceptable for implementing the specific requirements applicable to
controlling access to high radiation areas in 10 CFR 20.1601, and
additional requirements to prevent unauthorized or inadvertent
entry into very high radiation areas which are in 10 CFR
20.1602.
Slide 105
ALARA What, Where, When, Who, and Why
Slide 106
What is ALARA? According to 10 CFR 835 - ALARA means "As Low As
is Reasonably Achievable," which is the approach to radiation
protection to manage and control exposures (both individual and
collective) to the work force and to the general public to as low
as is reasonable, taking into account social, technical, economic,
practical, and public policy considerations.
Slide 107
What is ALARA? According to 10 CFR 835 As used in this part,
ALARA is not a dose limit but a process which has the objective of
attaining doses as far below the applicable limits of this part as
is reasonably achievable.
Slide 108
What is ALARA? According to 10 CFR 20 ALARA (acronym for as low
as is reasonably achievable) means making every reasonable effort
to maintain exposures to radiation as far below the dose limits in
this part as is practical consistent with the purpose for which the
licensed activity is undertaken, taking into account the state of
technology, the economics of improvements in relation to benefits
to the public health and safety, and other societal and
socioeconomic onsiderations and in relation to utilization of
nuclear energy and licensed materials in the public interest.
Slide 109
What is ALARA? So according to the regulations it is an acronym
that refers to: an approach, a process, and making every reasonable
effort to keep individual and collective operational doses and
doses to the general public as low as is reasonably
achievable.
Slide 110
Where and When is ALARA Required? As noted previously, ALARA is
applicable to any activity performed by a licensee while conducting
activities associated with that license or while engaged in
approved DOE activities. Within 10 CFR 20.1101(b) Radiation
Protection Programs The licensee shall use, to the extent
practicable, procedures and engineering controls based upon sound
radiation protection principles to achieve occupational doses and
doses to members of the public that are as low as is reasonably
achievable (ALARA).
Slide 111
Where and When is ALARA Required? Within 835.101(c) Radiation
Protection Programs, The content of each Radiation Protection
Program shall be commensurate with the nature of the activities
performed and shall include formal plans and measures for applying
the as low as reasonably achievable (ALARA) process to occupational
exposure. 10CFR835 also requires that ALARA be considered in the
design and modification of facilities
Slide 112
Where and When is ALARA Required? Both make application of the
ALARA requirement to Planned Special Exposures (addressed in the
next lecture). 10 CFR 20 specifically makes application of ALARA to
include TEDE (that is internal as well as external dose equivalent)
as well as deactivation and termination of a licensed facility. In
daily application, ALARA can be engaged in every activity
associated with radiation protection including contamination
control and radioactive waster generation.
Slide 113
Who Does ALARA Apply To? Both 10 CFR 20 and 10 CFR 835 includes
occupational exposure (workers) and exposure to members of the
general public. Both include the concept of individual and
collective doses. Each individual is tasked with the responsibility
for maintaining their dose ALARA Each organization is tasked with
keeping their collective doses ALARA Usually taken down to the
department and even the section level. Treated as a dose
budget
Slide 114
Why ALARA? As we will study later, the regulations establish
limits on personnel exposure well below that which will cause
noticable effects. So why have additional requirements to keep the
dose received ALARA below those limits? Remember from RPT-103 the
various Dose versus Risk Models? Several theories exist regarding
at what point dose imposes measurable risk.
Slide 115
Dose vs Risk Relationships Risk 10 rem Dose All statistically
significant results involve >10 rem
Slide 116
Risk Dose Linear-quadratic, no threshold. Dose vs Risk
Relationships
Slide 117
Risk Dose Linear-quadratic, threshold. Dose vs Risk
Relationships
Slide 118
Risk Dose Linear, threshold. Dose vs Risk Relationships
Slide 119
Risk Dose Linear, non-threshold (LNT). Dose vs Risk
Relationships
Slide 120
Hormesis Dose Risk
Slide 121
Dose Linear, non-threshold (LNT). Basis for regulation, ALARA.
Dose vs Risk Relationships
Slide 122
Why ALARA? Although the risks and biological effects to human
exposures have been shown to not conclusively exist at lower doses
(
RWP The degree of detailed ALARA planning is normally
determined by calculating the total person-rem estimated (dose
assessment) for the job. Typical values might be: < 1 person-rem
- normal planning process > 1person-rem but < 10 person-rem
ALARA Planning Group planning process > 10 person-rem ALARA
Group Planning plus review and approval by ALARA Committee
Slide 142
RWP General RWPs (sometimes called Standing RWPs) are for
routine tasks with low radiological impact into areas where
radiological conditions are usually considered to be static.
Usually dont allow entry into High Radiation, Contaminated, or
Airborne Areas. Although the total estimated dose is high, the
effective dose rate will be very low. These are usually written for
long periods of time, quarterly or annually in some cases.
Slide 143
RWP Specific RWPs are for tasks: in areas not permitted by a
General RWP requiring the breech of a radioactive system that may
change the radiological conditions of the area Involve detailed job
planning through the ALARA process
Slide 144
Dose Assessment Determine effective dose rate for the work area
(in rem/hour). Use historical data where available. Determine
estimated person-hour for the job in the dose rate area. Use
historical data where available. Multiple the two together to
obtain the person-rem estimate for the job. This will determine the
level of additional review required (if any).
Slide 145
Cost-Benefit Analysis for ALARA Actions Both 10CFR835 and
10CFR20 talk in terms of substantial reduction of doses at a
reasonable cost. The obvious question to answer is How much is a
person-rem worth when doing a cost benefit analysis? Depending on
which plant and whether you are DOE or NRC you will come up with
differing answers. The average number is placed somewhere around
$13,000 per person-rem.
Slide 146
Cost-Benefit Analysis for ALARA Actions - Scenario Lets say
that based on the dose assessment, you have a recurring job that
will cost 15.0 person-rem to perform every year when it is done. If
you install permanent shielding, it will reduce the person-rem
received to 10.0 person-rem every year. What is the maximum dollar
value for the shielding project to be cost effective from an ALARA
perspective. Use $13,000 per person- rem.
Slide 147
Cost-Benefit Analysis for ALARA Actions - Scenario What is the
maximum cost dollar value for the shielding project to be cost
effective from an ALARA perspective. Use $13,000 per person- rem. 5
person-rem saved every year $13,000 per person-rem = $85,000
Slide 148
ALARA Big Three The most effective tools in the ALARA arsenal
are still the fundamental ones. Time -anything that can be done to
reduce the amount of time spent in a dose rate field WILL reduce
the dose received. For example: Pre-planning Detailed plans and
procedures Tool lists Scrubbing the task to identify the best way
Pre-fab outside of dose area Decontaminate area to reduce clothing
requirements (improves efficiency)
Slide 149
ALARA Big Three Time -anything that can be done to reduce the
amount of time spent in a dose rate field WILL reduce the dose
received. For example: Dry Runs Mock-ups Use experienced workers
Automated processes versus manual ones Stay time assignment and
tracking Improve physical environment (temperature and humidity),
increases worker efficiency.
Slide 150
ALARA Big Three Distance Obviously, the further from the source
of radiation, the less dose will be received. More effective than
time Remember the inverse square law? If the source is a point
source, the dose change is inversely proportional to the square of
the distance from the source Use remote handling devices Use
long-handled tools Remove the work to a low dose rate area Position
worker away from source Robotics (time and distance)
Slide 151
ALARA Big Three Shielding reduce the dose rate reduce the dose.
Watch the dose required to install it and, if its temporary, to
remove it you must be able to show it is a cost-effective
installation. Ensure it is the proper shielding dont use lead for
high beta dose rates Bremsstrahlung. For temporary shielding
engineering evaluations are required for system components and
piping.
Slide 152
ALARA Big Three Shielding reduce the dose rate reduce the dose.
For permanent installations station modification process must be
followed with requisite engineering and safety evaluations
performed. May require a station license amendment. Since all
shielding serves such a critical role in enabling dose reduction,
unauthorized removal or tampering with it is a major offense and is
dealt with as such. RP must approve and be present for any
alteration of shielding.
Slide 153
Source Term Reduction / Removal System decontamination chemical
cleaning Flushing crud from hot spots Component replacement
Strippable coatings Engineering Initial Design and subsequent
design changes Containment huts, glovebags, gloveboxes Installed or
temporary ventilation ALARA Beyond the Basics
Slide 154
Administrative addressed earlier Personal Protective Equipment
(PPE) Industrial Safety Fall protection Hearing protection Eye
protection Radiological safety Protective clothing Respiratory
protection Bag the source, not the worker. James Tisaranni ALARA
Beyond the Basics
Slide 155
Whos Job Is It Anyway? The short answer is everyones. Each has
a specific role. The individual worker is responsible to conduct
their business as described by the procedures, policies, and work
documents and to own their dose. The work group supervisor is
responsible for ensuring the worker is informed, equipped, and
empowered to do their tasks in a manner that controls dose. The
supervisor also facilitates tracking and managing the work group
dose budget.
Slide 156
Whos Job Is It Anyway? The RP Technician is responsible for the
planning, implementation, and monitoring that contributes to the
overall safest work environment for the worker. Also responsible
for protecting the environment, and the general public from the
harmful effects of radiation. The RP Supervisor is responsible for
ensuring that the radiological conditions of the facility are
monitored and that the appropriate procedures, policies and
postings are enacted that communicates the hazards to the working
population.
Slide 157
Whos Job Is It Anyway? The RP Supervisor is also responsible
for ensuring that the RP technicians are well trained and properly
equipped as well as working with the work group supervisors in
monitoring and keeping their groups dose ALARA.