module 7.0: health physics inspection activities · the purpose of the radiation protection program...

MODULE 7.0: HEALTH PHYSICS INSPECTION ACTIVITIES

Introduction Welcome to Module 7.0 of the General Health Physics Practices for Fuel Cycle Facilities Directed Self-Study Course! This is the seventh of seven modules in this self-study course. The purpose of this module is to assist the trainee in determining whether the licensee is complying with regulatory requirements related to radiation protection. This self-study module is designed to assist you in accomplishing the learning objectives listed at the beginning of the module. There are three learning objectives in this module. The module has self-check questions to help you assess your understanding of the concepts presented in the module.

Before You Begin

It is recommended that you have access to the following materials:

◙ Trainee Guide

◙ 10 CFR Part 19, Notices, Instructions, and Reports to Workers: Inspection and Investigations*

◙ 10 CFR Part 20, Standards for Protection Against Radiation*

◙ 10 CFR Part 40, Domestic Licensing of Source Material, Appendix A – Criterion 8

◙ NRC Form 3, Notice to Employees

◙ NRC Information Notice 93-60, Supplement 1: Reporting Fuel Cycle and Materials Events to the NRC Operations Center*

◙ NRC Form 5, Occupational Exposure Record for a Monitoring Period

◙ NRC Inspection Procedure 83822, Radiation Protection*

◙ NRC Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Reasonably Achievable

Complete the following prerequisites:

◙ Module 1.0 Health Physics Fundamentals

◙ Module 2.0 Radiological and Chemical Properties of Uranium

◙ Module 3.0 Contamination Control

◙ Module 4.0 Internal Dose Control

◙ Module 5.0 External Dose Control

◙ Module 6.0 Accidents and Emergencies at Fuel Cycle Facilities

*Excerpts are included at the end of this module.

How to Complete this Module

1. Review the learning objectives.

2. Read each section within the module in sequential order.

3. Complete the self-check questions and activities within this module.

4. Check off the tracking form as you complete each activity within the module.

5. Contact your administrator as prompted for a progress review meeting.

6. Contract your administrator as prompted for any additional materials and/or specific assignments.

7. Complete all assignments related to this module. If no other materials or assignments are given to you by your administrator, you have completed this module.

8. Ensure that you and your administrator have dated and initialed your progress on your tracking form.

9. Go to the Trainee Guide and review the steps for course completion.


USNRC Technical Training Center i 6/10 Rev 4 Health Physics Directed Self-Study Course

TABLE OF CONTENTS

Introduction ...................................................................................................................................... i Before You Begin .............................................................................................................................. i How to Complete this Module ........................................................................................................ ii LEARNING OBJECTIVES ................................................................................................................ 7-1 RADIATION PROTECTION PROGRAM .......................................................................................... 7-1 RADIATION PROTECTION PROGRAM AND PROCEDURES ........................................................... 7-3 Self-Check Questions 7-1 ............................................................................................................. 7-5 INSTRUMENTS AND EQUIPMENT ................................................................................................ 7-7 Self-Check Questions 7-2 ........................................................................................................... 7-10 EXPOSURE CONTROLS ............................................................................................................... 7-11 Self-Check Questions 7-3 ........................................................................................................... 7-14 POSTING, LABELING, AND CONTROL (Security) ........................................................................ 7-15 Self-Check Questions 7-4 ........................................................................................................... 7-17 Self-Check Questions 7-5 ........................................................................................................... 7-19 Self-Check Questions 7-6 ........................................................................................................... 7-22 Self-Check Questions 7-7 ........................................................................................................... 7-25 Surveys ....................................................................................................................................... 7-26 Self-Check Questions 7-8 ........................................................................................................... 7-27 NOTIFICATIONS AND REPORTS .................................................................................................. 7-28 To the NRC ................................................................................................................................. 7-28 To the Individual ........................................................................................................................ 7-30 Self-Check Questions 7-9 ........................................................................................................... 7-32 As Low As Reasonably Achievable ............................................................................................. 7-33 Self-Check Questions 7-10 ......................................................................................................... 7-40 Progress Review Meeting Form ................................................................................................. 7-42 MODULE SUMMARY .................................................................................................................. 7-45 SUPPLEMENTAL READING ...................................................................................................... SRIII-1

LIST OF TABLES Table 7-1. Radiation Protection Program and Procedures ......................................................... 7-3 Table 7-2. Instruments and Equipment ...................................................................................... 7-8 Table 7-3. Exposure Controls .................................................................................................... 7-11 Table 7-4. Posting, Labeling, and Control (Security) ................................................................ 7-15 Table 7-5. Labeling .................................................................................................................... 7-18 Table 7-6. Control ..................................................................................................................... 7-20 Table 7-7. Posting Notices ........................................................................................................ 7-23 Table 7-8. Surveys ..................................................................................................................... 7-26 Table 7-10. Notification and Reports ........................................................................................ 7-29 Table 7-11. Notification and Reports ........................................................................................ 7-30 Table 7-12. ALARA .................................................................................................................... 7-35


USNRC Technical Training Center ii 6/10 Rev 4 Health Physics Directed Self-Study Course

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USNRC Technical Training Center 10/10 Rev 4 Health Physics Directed Self-Study Course

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LEARNING OBJECTIVES

7.1 Upon completion of this module, you will be able to determine non-compliance with regulatory requirements related to radiation protection.

7.1.1 Discuss regulatory requirements and inspection activities related to radiation

protection. 7.1.2 List non-compliance with regulatory requirements related to radiation protection in

the following areas:

◙ Radiation protection program and procedures

◙ Instruments and equipment

◙ Exposure controls

◙ Posting, labeling, and control

◙ Surveys

◙ Notifications and reports

◙ As low as reasonably achievable (ALARA)

RADIATION PROTECTION PROGRAM

The purpose of the radiation protection program (RPP) is to protect the radiological health and safety of the occupational workers and the public, and to comply with the regulatory requirements imposed by the Nuclear Regulatory Commission in 10 CFR, Parts 19 and 20; 40 CFR, Part 61 (Subpart I and T); 40 CFR, Parts 141, 190, and 192. The areas of review and inspection include:





◙ Surveys



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◙ ALARA

This module presents the inspection activities for each of the areas of review. Note: Inspection activities for this module were extracted from NRC Inspection Procedure

83822, Radiation Protection. In addition, there are extractions from 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations and 10 CFR Part 20, Standards for Protection Against Radiation.



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Learning Objective

When you finish this section, you will be able to: 7.1.1 Identify non-compliance with regulatory requirements in the Radiation Protection

Program (RPP).

RADIATION PROTECTION PROGRAM AND PROCEDURES

The table below describes the regulations, requirements and related inspection activities regarding the radiation protection program and procedures. Table 7-1. Radiation Protection Program and Procedures

Regulation Requirement Inspection Activity

10 CFR Part 20.1101- Subpart B Radiation Protection Programs

Each licensee shall develop, document, and implement a radiation protection program commensurate with the scope and extent of licensed activities and sufficient to ensure compliance with the provisions of this part.

Verify that a radiation protection program commensurate with the licensee's activities is implemented and documented. In practice, this means the facility has a management endorsed program that is sufficient in scope to ensure there are adequate procedures, monitoring devices, and equipment to support the scope of the program.

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

Verify that changes in the radiological protection procedures made since the last inspection are consistent with regulations and license requirements.



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reasonably achievable (ALARA). The licensee shall ensure that no member of the general public would receive an annual TEDE of 10 mrem due to air emissions (excluding Radon-222)

Verify there are operating procedures in place and that these have been reviewed and approved by management.

The licensee shall periodically (at least annually) review the radiation protection program content and implementation. The licensee shall be able to present records of these annual inspections. Inspection findings from these reviews should be addressed, and the results of these annual inspections should be addressed to management

Verify that the program is being reviewed at least annually, both for content and implementation.

Conduct the following health physics activities as appropriate:

◙ Review radiation protection program documentation.

◙ Check written procedures for accomplishing health physics functions.

◙ Review the licensee’s health physics log book or file on health physics problems to identify areas deserving special attention.

◙ Review procedural changes. Ensure procedural changes reflect commitment and requirements in license.

◙ Check to see if an annual audit has been conducted. How independent is the audit? Has a review of significant areas been accomplished? Is the program being reviewed for both content and implementation?

◙ Identify trends and ascertain whether corrective actions are directed toward the cause and not merely the symptoms.

◙ Verify that changes in the radiological protection procedures made since the last inspection are consistent with regulations and license requirements.

◙ Is there use of an administrative whole-body limit in a procedure that is higher than that specified in the license?



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Self-Check Questions 7-1: INSTRUCTIONS: Complete the following question. Answers are located

in the answer key section of the Trainee Guide.

1. Review the regulation, requirements, and inspection activities for this section. Provide

examples of non-compliance with 10 CFR Part 20.1101-Subpart B.

You have completed this section.

Please check off your progress on the tracking form. Go to the next section.



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Learning Objective

When you finish this section, you will be able to: 7.1.2. Identify non-compliance with regulatory requirements in instruments and equipment.

INSTRUMENTS AND EQUIPMENT

According to Section 20.1502 of 10 CFR Part 20, persons who are likely to receive an occupational dose in one year in excess of 10% of the applicable limits and persons in high radiation areas must use individual monitoring devices. The usual personnel monitoring devices are film badges or thermoluminescent dosimeters (TLDs) that are furnished and processed by commercial suppliers. It is possible for qualified licensees to process their own film badges or TLDs, but this is seldom done. The reports furnished by processors of these devices provide a permanent record of exposures to personnel. These different devices may have different intervals for processing and more frequent processing may be required in the case of workers making high radiation area entries. The processors of these devices must be NVLAP accredited (1501 (c)(1). Likewise, personnel who are likely to receive 500 mrem (i.e., 10% of ALI) or more of internal exposure are required to be "monitored." This monitoring may take the form of bioassays, the use of lapel samplers, or the use of general area samplers whose locations have been shown to be representative of those occupied by workers performing routine operations.



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Table 7-2. Instruments and Equipment


10 CFR Part 20.1501 General

Each licensee shall ensure that instruments and equipment used for quantitative radiation measurements (e.g., dose rate and effluent monitoring) are calibrated periodically for the radiation measured. All personnel dosimeters (except for direct and indirect reading pocket ionization chambers and those dosimeters used to measure the dose to the extremities) that require processing to determine the radiation dose and that are used by licensees to comply with § 20.1201, with other applicable provisions of this chapter, or with conditions specified in a license must be processed and evaluated by a dosimetry processor – holding current personnel dosimetry accreditation from the National Voluntary Laboratory (Continued) Accreditation Program (NVLAP) of the National Institute of Standards and Technology (NIST); and approved in this accreditation process for the type of radiation or radiation(s) included in the NVLAP program that most closely approximates the type of radiation or radiations for which the individual wearing the dosimeter is monitored.

Verify that radiation protection instruments and equipment are operable, have the proper alarm settings (if applicable), and are calibrated in accordance with license requirements and licensee procedures.


◙ Randomly select instruments of each major type and examine them to verify operability and proper alarm settings, if alarm settings are applicable.

□ Portable survey instruments

□ Fixed monitoring equipment



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□ Constant air monitors

□ Portable air samplers

□ Film badges and TLDs

□ Pocket dosimeters

□ Alarm dosimeters

◙ Check to see if employees are wearing lapel samplers properly, improperly, or not at all (if required per the activity’s program or SOP).

◙ Review the most recent calibration records of the instrument(s) selected for inspection to ensure that the calibration and surveillance program for these instruments are being accomplished in accordance with license requirements or licensee procedures.

◙ Ensure employees are not using radiation detection instruments beyond calibration due date.

Verify that the licensee has a system (a schedule, card file, etc.) that identifies all of the instruments and identifies when they are due for calibration or functional testing. Is there a failure to perform a daily source check of instruments in use?



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Self-Check Questions 7-2: INSTRUCTIONS: Complete the following question. Answers are located in

the answer key section of the Trainee Guide.


examples of non-compliance with 10 CFR Part 20.1501.





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Learning Objective

When you finish this section, you will be able to:

7.1.3 Identify non-compliance with regulatory requirements in exposure controls.

EXPOSURE CONTROLS

The table below describes the regulations, requirements and related inspection activities regarding exposure controls.

Table 7-3. Exposure Controls


10 CFR Part 20.1201 (Occupational dose limits for adults) Derived air concentration (DAC) and annual limit on intake (ALI) values are presented in table 1 of appendix B to 20.1001-20.2401 and may be used to determine the individual's dose (see 20.2106) and to demonstrate compliance with the occupational dose limits.

The licensee shall control the occupational dose to individual adults, except for planned special exposures under 20.1206, to the following dose limits. Annual limit, which is the more limiting of –

i. The total effective dose equivalent being equal to 5 rems (0.05 Sv); or

ii. The sum of the deep-dose equivalent and the committed dose equivalent to any individual organ or tissue other than the lens of the eye being equal to 50 rems (0.5 Sv).

The annual limits to the lens of the eye, to the skin, and to the extremities which are:

i. An eye dose equivalent of 15 rems (0.15 Sv), and

ii. A shallow-dose equivalent of 50 rems (0.50 Sv) to the skin or to any extremity.

Determine compliance with the regulatory requirements.



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Table 7-3. Exposure Controls


The assigned deep-dose equivalent and shallow-dose equivalent must be for the part of the body receiving the highest exposure. The deep-dose equivalent, eye dose equivalent and shallow-dose equivalent may be assessed from surveys or other radiation measurements for the purpose of demonstrating compliance with the occupational dose limits, if the individual monitoring device was not in the region of highest potential exposure, or the results of individual monitoring are unavailable. In addition to the annual dose limits, the licensee shall limit the soluble uranium intake by an individual to 10 milligrams in a week in consideration of chemical toxicity (see footnote 3 of Appendix B to 20.1001-20.2401). The licensee shall reduce the dose that an individual may be allowed to receive in the current year by the amount of occupational dose received while employed by any other person (see 20.2104[e]).


◙ Examine the type of monitoring devices used, the period of use or exchange period, and the number used to determine if these aspects seem consistent with the monitoring program.

◙ Determine who the supplier is, and if the service has been changed since the last inspection. If changed, determine the reasons for the change.

◙ Is there follow-up by the licensee concerning monthly film badge results? For example, a monthly film badge result from processor returned with 6 rem DDE. Did the licensee follow up on the result?

◙ Does licensee survey personnel or items out of contamination control area?



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◙ Examine any changes made in procedures for control and use of personnel monitoring equipment; verify that limits, precautions, controls, etc., specified in the procedures are consistent with regulations and license requirements.

◙ Did licensee ask contractor for prior dose data?

◙ Review all NRC Forms 5 to determine compliance.

◙ Does the licensee account for occupational radiation dose to personnel resulting from exposures to licensed material and other unlicensed radiation sources (e.g., x-ray machines)?

◙ Evaluate the adequacy of the licensee's procedures or system for evaluating and using personnel monitoring data to control and minimize exposures.

◙ Review reports of exposure summaries generated since the last inspection to determine compliance.

◙ Determine that exposure histories are on file for individuals.

◙ During review of exposure evaluations, determine compliance with the internal exposure limits.

◙ Review randomly selected air sampling and bioassay records and independently verify airborne concentrations as appropriate.

◙ Did license operator provide nasal swipes after exposure to airborne U3O8?

◙ Review documentation of evaluations performed as the result of suspected overexposures or exposures over any applicable administrative limits.

◙ Did the license operator's current DDE exceed restriction limit without any evaluation by licensee?

◙ Verify the appropriateness of preventive measures instituted following an overexposure or exposure over an administrative limit.

◙ Look for exceedances of bioassay action levels and response.



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the answer key section of the Trainee Guide. 1. Review the regulation, requirements, and inspection activities for this section. Provide






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Learning Objective


7.1.4 Identify non-compliance with regulatory requirements in posting, labeling and control.

7.1.5 Identify non-compliance with regulatory requirements in surveys.

7.1.6 Identify non-compliance with regulatory requirements in notifications and reports.

POSTING, LABELING, AND CONTROL (SECURITY)

The table below describes the regulations, requirements and related inspection activities regarding posting to identify radiation areas.

Table 7-4. Posting, Labeling, and Control (Security)


10 CFR Part 20.1902(a) (Radiation Area)

The licensee shall post each radiation area with a conspicuous sign or signs bearing the radiation symbol and the words "CAUTION, RADIATION AREA."


10 CFR Part 20.1902(b) (High Radiation Area)

The licensee shall post each high radiation area with a conspicuous sign or signs bearing the radiation symbol and the words "CAUTION, HIGH RADIATION AREA" or "DANGER, HIGH RADIATION AREA."


10 CFR Part 20.1902(c) (Very High Radiation Area)

The licensee shall post each very high radiation area with a conspicuous sign or signs bearing the radiation symbol and words "GRAVE DANGER, VERY HIGH RADIATION AREA."




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Table 7-4. Posting, Labeling, and Control (Security)


10 CFR Part 20.1902(d) (Airborne Radioactivity Area)

The licensee shall post each airborne radioactivity area with a conspicuous sign or signs bearing the radiation symbol and the words "CAUTION, AIRBORNE RADIOACTIVITY AREA" or "DANGER, AIRBORNE RADIOACTIVITY AREA."


10 CFR Part 20.1902(e) (Radioactive Material Area)

The licensee shall post each area or room in which there is used or stored an amount of licensed material exceeding 10 times the quantity of such material specified in Appendix C to 20.1001- 20.2401 with a conspicuous sign or signs bearing the radiation symbol and the words "CAUTION, RADIOACTIVE MATERIAL(S)" or "DANGER, RADIOACTIVE MATERIAL(S)."



◙ Review survey records and check facility postings to ensure there has been no failure.

◙ Inspect representative areas to verify compliance; pay particular attention to "temporary" work areas that may be required for maintenance activity, newly established work areas, etc.

◙ Check process vessels or piping where physical or chemical change occurs and uranium daughters are deposited.

◙ Review air sample results and observe facility postings to verify there are no cases where the area is misclassified or controlled inappropriately."

◙ Did the licensee fail to properly post an area with more than 10x Appendix C quantity?

◙ Check instrument calibration facilities.



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1. Review the regulation, requirements, and inspection activities for this section. Provide an

example of non-compliance for the following regulations.

10 CFR Part 20.1902(a)

10 CFR Part 20.1902(d)

10 CFR Part 20.1902(e)





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The table below describes the regulations, requirements and related inspection activities regarding labeling. Table 7-5. Labeling


10 CFR Part 20.1904 (Container labeling) Other posting and labeling requirements specified in the license or licensee procedures.

The licensee shall ensure that each container of licensed material bears a durable, clearly visible label bearing the radiation symbol and the words "CAUTION, RADIOACTIVE MATERIAL" or "DANGER, RADIOACTIVE MATERIAL." The label must also provide sufficient information (such as the radionuclide(s) present, an estimate of the quantity of radioactivity (or concentration), the date for which the activity is estimated, radiation levels, kinds of materials, and mass enrichment) to permit individuals handling or using the containers, to take precautions to avoid or minimize exposures. Labeling is not always required; for example, when the contents of the container are below the concentrations listed in Appendix B of Part 20 or below the activity levels of Schedule B or Part 30. Each licensee shall, prior to removal or disposal of empty uncontaminated containers to unrestricted areas, remove or deface the radioactive material label or otherwise clearly indicate that the container no longer contains radioactive material.



◙ Check to see if a container with a quantity of material greater than Appendix C is labeled.

◙ Check to see if licensee has posted entry for Radiation Work Permit (RWP) requirement.

◙ Check to see if licensee has posted a contamination area.

◙ Inspect a random sampling of containers in work or storage areas.



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example of non-compliance with 10 CFR Part 20.1904.





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Table 7-6. Control The table below describes the regulations, requirements and related inspection activities regarding control.


10 CFR Part 20.1801 (Security of stored material)

The licensee shall secure from unauthorized removal or access licensed materials that are stored in controlled or unrestricted areas.


10 CFR Part 20.1802 (Control of material not in storage)

The licensee shall control and maintain constant surveillance of licensed material that is in a controlled or unrestricted area and that is not in storage.

Control implies physical control and constant surveillance requires visual surveillance and guarding access to licensed material.

Radiological Work Permit (RWP) system specified in license requirements or licensee procedures

Controls for radioactive or contaminated areas and equipment specified in license requirements or licensee procedures


◙ Check to see if the RWP requires review and sign-off before entry.

◙ Inspect areas where radioactive material is located or stored in an unrestricted area.

◙ Review a random selection of RWPs on file and those currently in effect.

◙ Review a random selection of records and inspect work areas to determine compliance with controls.

◙ Are workers in area without signing the RWP log?



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◙ Are workers in RWP area without shoe covers and gloves?

◙ Are workers in RWP area without protective clothing?



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the answer key section of the Trainee Guide. 1. Review the regulation, requirements, and inspection activities for this section. Provide an

example of non-compliance for the following regulations. 10 CFR Part 20.1801 10 CFR Part 20.1802





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Table 7-7. Posting Notices The table below describes the regulations, requirements and related inspection activities regarding posting notices to workers.


10 CFR Part 19.11 Posting of Notices to Workers (e) (1) 10 CFR Part 40.7 Employee Protection

Each specific licensee, each applicant for a specific license, and each general license subject to part 19 shall prominently post the revision of NRC Form 3, "Notice to Employees," referenced in 10 CFR Part 19.11(c). The posting of NRC Form 3 must be at locations sufficient to permit employees protected by this section to observe a copy on the way to or from their place of work. Premises must be posted no later than 30 days after an application is docketed and remain posted while the application is pending before the Commission, during the term of the license, and for 30 days following license termination.

(a) Each licensee (except for a holder of an early site permit under subpart A of part 52 of this chapter, or a holder of a manufacturing license under subpart F of part 52 of this chapter) shall post current copies of the following documents:

(1) The regulations in this part and in part 20 of this chapter;

(2) The license, license conditions, or documents incorporated into a license by reference, and amendments thereto;

(3) The operating procedures applicable to licensed activities;

Determine compliance with 10 CFR Part 19.11. Verify that documents are posted in areas easily accessible to employees; if there are legitimate reasons (e.g., security concerns) to not post the documents in these areas, verify that the licensee has posted a notice in areas easily accessible by employees that



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Table 7-7. Posting Notices (continued)

(4) Any notice of violation involving radiological working conditions, proposed imposition of civil penalty, or order issued pursuant to subpart B of part 2 of this chapter, and any response from the licensee.

Caveat: (d) If posting of a document specified in paragraphs (a)(1), (2) or (3), or (b)(1) or (2) of this section is not practicable, the licensee or regulated entity may post a notice which describes the document and states where it may be examined.

describes the documents and where they may be seen


◙ Does licensee post NRC Form 3 in sufficient locations?

◙ Does licensee post 10 CFR Parts 19 and 20, and license where they may be viewed?

◙ Does licensee post notices of violation?

◙ Determine, by questioning of management, how the licensee complies with the requirements of 10 CFR Part 19.11.

◙ Inspect bulletin boards or other places where notices are posted.

◙ Question a few individuals to determine if they are aware of the posting of notices.



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SURVEYS

Paragraph 20.1501(a) of 10 CFR Part 20, "Standards for Protection Against Radiation," requires that each licensee make or cause to be made such surveys as may be necessary for compliance with the regulations in that part. As used in 10 CFR Part 20, the term "survey" is defined as an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions. Specific licensee commitments for surveys and survey frequencies are provided in the license application. Surveys are considered to be part of a comprehensive protection program established by the licensee according to the philosophy and principles of NRC Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Reasonably Achievable. Surveys are necessary supplements to personnel monitoring, in which devices worn by the workers measure individual external radiation exposures, and to various forms of bioassay to determine intake of radioactive material by the workers. Table 7-8. Surveys


10 CFR Part 20.1501(a) Each licensee shall make or cause to be made surveys that – may be necessary for the licensee to comply with the regulations in this part; and are reasonable under the circumstances to evaluate – the extent of radiation levels; and concentrations or quantities of radioactive material; and the potential radiological hazards that could be present.



◙ Determine whether due consideration is given to alpha, beta, and gamma exposures.

◙ Does licensee release liquid effluents without analysis of uranium concentration?

◙ Verify that the licensee has established schedules for periodic surveys of work areas of the plant and facility site.

◙ Does the licensee survey areas where radioactive materials are used or stored?

◙ Does the licensee conduct surveys at required frequencies?



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◙ Verify that surveys are conducted using approved procedures.

◙ Verify that the survey results are reviewed by appropriate supervision.

◙ Verify that corrective actions have been taken, as appropriate.

◙ Attempt to observe surveys in progress by licensee personnel.




examples of non-compliance with 10 CFR Part 20.1501(a).





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NOTIFICATIONS AND REPORTS

The table below describes the regulations, requirements and related inspection activities regarding notifications and reports.

To the NRC Table 7-9. Notifications and Reports

Regulation Requirements Inspection Activity

10 CFR Part 20.2201 (Reports of theft or loss of licensed material)

Immediate notification is required when it becomes known to the licensee, any lost, stolen, or missing licensed material in an aggregate quantity equal to or greater than 1,000 times the quantity specified in appendix C to part 20 or within 30 days after the occurrence of any lost, stolen, or missing licensed material becomes known to the licensee, all licensed material in a quantity greater than 10 times the quantity specified in appendix C to part 20 that is still missing at this time

Telephone reports to the NRC Operations Center are required immediately for theft or loss equal to or greater than 1,000 times the quantity specified in appendix C to part 20. Telephone reports are required within 30 days for theft or loss greater than 10 times the quantity specified in appendix C to part 20.

Determine compliance with 10 CFR Part 20.2201. Examine reports to ensure that telephone and written reports have been made as required, including the report elements as listed in 10 CFR Part 20.2201



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Table 7-9. Notifications and Reports


Written reports to the NRC Operations Center are required within 30 days after the telephone report for both theft or loss quantities listed above.

See 10 CFR Part 20.2201. Conduct the following health physics activities as appropriate:

◙ Determine if the licensee is reporting all the events and data required by the regulations and the license.

◙ Review reports submitted since the last inspection.

Table 7-10. Notification and Reports


10 CFR Part 20.2202 (Notification of incidents)

Immediate notification. Twenty-four hour notification.

Determine compliance with 10 CFR Parts 20.2202, 20.2203, 20.2205, and 20.2206.

20.2203 (Reports of exposures, radiation levels, and concentrations of radioactive material exceeding the limits) 20.2205 (Reports to Individuals of Exceeding Dose Limits) 20.2206 (Reports of Individual Monitoring)

Reportable events. See 10 CFR Parts 20.2202, 20.2203, 20.2205, and 20.2206.


◙ Determine whether events have occurred that have not been reported.

Note: A discussion with management, operating personnel, maintenance, and health physics personnel, and review of RWPs, log books, and other data during the course of the inspection should aid in this determination.



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To the Individual Table 7-11. Notification and Reports Regulation Requirements Inspection Activity

10 CFR Part 19.13 (Notifications and reports to individuals)

Radiation exposure data for an individual, and the results of any measurements, analyses, and calculations of radioactive material deposited or retained in the body of an individual, shall be reported to the individual. Each licensee shall advise each worker annually of the worker's dose as shown in records maintained by the licensee pursuant to the provisions of § 20.2106 of 10 CFR Part 20. See article 19.13 for occasions on which the licensee shall provide a report to the individual. At the request of a worker formerly engaged in licensed activities controlled by the licensee, it shall furnish to the worker a report of the worker's exposure to radiation and/or to radioactive material. When a licensee is required to report to the Commission any exposure of an individual to radiation or radioactive material, the licensee shall also provide the individual a report on his or her exposure data included therein. At the request of a worker who is terminating employment with the licensee that involved exposure to radiation or radioactive materials, each licensee shall provide a written report regarding the radiation dose received by that worker from operations during the current year or fraction thereof.

Determine compliance with 10 CFR Part 19.13.



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◙ Does the operator know what his annual dose is and has he ever been informed of such by the licensee?

◙ Determine by discussion with individuals selected at random (identified during the course of inspection of other requirements) whether they were notified in accordance with 10 CFR Part 19.13.

Note: Licensee reports to the NRC Operations Center under NRC Bulletin 91–01.



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example of non-compliance for the following regulations. 10 CFR Part 20.2201 10 CFR Part 20.2202 10 CFR Part 20.2203 10 CFR Part 20.2205 10 CFR Part 20.2206 10 CFR Part 19.13





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Learning Objective


7.1.7 Identify non-compliance with regulatory requirements in doses As Low As Reasonably Achievable (ALARA).

AS LOW AS REASONABLY ACHIEVABLE

Paragraph 20.1101(b) of 10 CFR Part 20 states that persons engaged in NRC-licensed activities shall, to the extent practicable, maintain occupational doses and doses to members of the public as low as is reasonably achievable. In order to achieve this goal, licensees must control the way radioactive material is handled from receipt through disposal. The licensee should establish ALARA policy and procedures that are issued and supported by the highest level of management. All employees should be made aware of the ALARA policy through training. Regulatory Guide 8.10, "Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Reasonably Achievable," provides the NRC staff position on ALARA. For uranium mining and recovery facilities, ALARA programs are part of the license application. The programs are audited periodically and the results reported to the Radiation Safety Committee for action. However, for materials licensees there may be very active ALARA programs for the higher inspection priorities that are identified in the license applications or license conditions. The depth of the ALARA programs will depend on the quantities of radioactive materials possessed and used, and whether the potential for radiation exposures can be significant. According to 10 CFR Part 40 Appendix A – Criterion 8, milling operations must be conducted so that all airborne effluent releases are reduced to levels as low as is reasonably achievable. The primary means of accomplishing this must be by means of emission controls. Institutional controls, such as extending the site boundary and exclusion area, may be employed to ensure that offsite exposure limits are met, but only after all practicable measures have been taken to control emissions at the source. Notwithstanding the existence of individual dose standards, strict control of emissions is necessary to assure that population exposures are reduced to the maximum extent reasonably achievable and to avoid site contamination.



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The greatest potential sources of offsite radiation exposure (aside from radon exposure) are dusting from dry surfaces of the tailings disposal area not covered by tailings solution and emissions from yellowcake drying and packaging operations. During operations and prior to closure, radiation doses from radon emissions from surface impoundments of uranium or thorium by-product materials must be kept as low as is reasonably achievable. Checks must be made and logged hourly of all parameters (e.g., differential pressures and scrubber water flow rates) that determine the efficiency of yellowcake stack emission control equipment operation. The licensee shall retain each log as a record for three years after the last entry in the log is made. It must be determined whether or not conditions are within a range prescribed to ensure that the equipment is operating consistently near peak efficiency; corrective action must be taken when performance is outside of prescribed ranges. Effluent control devices must be operative at all times during drying and packaging operations and whenever air is exhausting from the yellowcake stack. Drying and packaging operations must terminate when controls are inoperative. When checks indicate the equipment is not operating within the range prescribed for peak efficiency, actions must be taken to restore parameters to the prescribed range. When this cannot be done without shutdown and repairs, drying and packaging operations must cease as soon as practicable. Operations may not be restarted after cessation due to off-normal performance until needed corrective actions have been identified and implemented. All these cessations, corrective actions, and restarts must be reported to the appropriate NRC regional office as indicated in Criterion 8A, in writing, within ten days of the subsequent restart. To control dusting from tailings, that portion not covered by standing liquids must be wetted or chemically stabilized to prevent or minimize blowing and dusting to the maximum extent reasonably achievable. This requirement may be relaxed if tailings are effectively sheltered from wind, such as may be the case where they are disposed of below grade and the tailings surface is not exposed to wind. In planning tailings disposal programs, consideration must be given to methods that would allow phased covering and reclamation of tailings impoundments because this will help in controlling particulate and radon emissions during operation. To control dusting from diffuse sources, such as tailings and ore pads where automatic controls do not apply, operators shall develop written operating procedures specifying the methods of control which will be utilized.



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Table 7-12. ALARA


10 CFR Part 20.1101(b) (Radiation Protection Programs)

Persons engaged in NRC-licensed activities shall, to the extent practicable, maintain occupational doses and doses to members of the public as low as is reasonably achievable. In order to achieve this goal, licensees must control the way radioactive material is handled from receipt through disposal.

Determine if high-level management has made a commitment to minimize exposure to workers and has clearly defined procedures and policies to implement the ALARA philosophy. Determine that licensee personnel are made aware of management's commitment to keep occupational exposures ALARA.

The licensee should establish ALARA policy and procedures that are issued and supported by the highest level of management. All employees should be made aware of the ALARA policy through training. Regulatory Guide 8.10, "Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Reasonably Achievable," provides the NRC staff position on ALARA.

Ascertain that the radiation protection staff has been given authority to make certain that ALARA policies are carried out and that workers have been adequately trained to understand the ALARA philosophy and how it should be implemented at their workplaces. Determine that management and its designees perform periodic (at least annually) audits to find out how exposures (both external and internal) might be lowered. Also determine that effluents released are ALARA.



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Table 7-12. ALARA


(Continued) Determine compliance with 10 CFR Part 19.12 with respect to workers' understanding of radiation protection in their workplace, and how the training received includes an understanding of ALARA as it pertains to the work place. Note: The recent revision to 10

CFR Part 19.12 requires licensees to train workers only if it is likely that their dose will exceed 100 mrem in a year. Individual licenses could conceivably specify something different.

10 CFR Part 20.1101(b) (Radiation Protection Programs) (Continued

Determine whether modifications to equipment, facilities, and procedures, have been made to significantly reduce exposures at a reasonable cost. The benefits gained should outweigh the cost of modifications. Also determine if the licensee has considered the ALARA philosophy during the engineering phase for changes in facilities, equipment, or processes and whether an ALARA review was performed during initial implementation of changes. Determine if the radiation safety officer (RSO) and radiation protection staff have:



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Table 7-12. ALARA


(Continued) ◙ Identified the origins of radiation exposures by location and job category and have noted trends in the amounts of radiation at the locations.

◙ Considered ways to reduce exposures in those locations where exposure to personnel are significant.

◙ Periodically reviewed operating procedures that affect radiation safety and have made surveys of operations to identify situations where radiation exposures can be reduced.

Determine if there exists a program in which workers can make suggestions on radiation protection (feedback). Determine if adequate equipment and supplies are available for radiation protection, and if procedures are available for proper use of these supplies and equipment.

◙ Decontamination supplies

◙ Survey meters

◙ Protective clothing

◙ Ventilation systems

◙ Air sampling equipment

◙ Supplies used for posting areas, such as radiation areas



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◙ Does the ALARA commitment appear in:

□ Policy statements?

□ Instructions to personnel?

□ Documents?

◙ Can workers explain what the commitment is, what ALARA means, why it is recommended, and how they have been advised to implement it on their jobs?

◙ Examine a selection of policy standards and instructions (if they exist) and interview workers to determine if they understand the ALARA philosophy and what it means at the workplace.

◙ As a minimum, management should be able to discuss:

□ Which operating procedures were reviewed

□ In which locations most exposures are being received

□ What groups of workers are receiving the highest exposures

□ What discussions they have had with the radiation protection staff or outside consultants

□ What steps have been taken to reduce exposures

◙ Examine a random sample of records and interview personnel to determine what has been done to reduce exposures.

◙ Radiation workers should understand how radiation protection relates to their jobs and should be tested on this understanding at least annually, or as otherwise stated in the license application.

◙ Training should be sufficient to ensure that workers can correctly answer questions on radiation protection as it relates to their jobs.

◙ Interview workers (consistent with the size of the program) to determine if the workers understand radiation protection as it relates to their jobs and if they have an opportunity to discuss radiation safety with the radiation protection staff.

◙ Inquire if modifications have been made to facilities and equipment to reduce exposures.

◙ Randomly examine any procedures or records that reflect modifications and attempt to determine the extent of the benefits gained through modifications. (For example, modifications may have been beneficial if exposures of 50 mrems/hour were reduced by a factor of 10 to 5 mrems/hour).



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Note: It may not be beneficial to reduce 1 mrem/hour to 0.1 mrem/hour, considering cost and risk. In both of the above examples, consideration must be given to costs of modification and risk to the population.

◙ Examine Radiation Safety Committee records or other records on ALARA policies to determine whether source-term surveys have been conducted and actions taken to reduce significant exposures.

◙ Are facility personnel aware of management's commitment to keep exposures to workers ALARA?

◙ Radiation workers should understand how radiation protection relates to their job and should be tested on this understanding at least annually, or as otherwise stated in the license application.

◙ Examine equipment and supplies to determine if they adequately protect personnel from unnecessary radiation.



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examples of non-compliance with 10 CFR Part 20.1101(b).



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It's time to schedule a progress meeting with your administrator. Review the progress meeting form on the next page. In Part III, as a Regulator, write your specific questions to discuss with the administrator.



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PROGRESS REVIEW MEETING FORM Date Scheduled: ________________________________Location:______________________ I. The following suggested items should be discussed with the administrator as to how they

pertain to your current position:

◙ NRC Inspection Procedure 83822





◙ Surveys


◙ NRC Information Notice 93-60, Supplement 1: Reporting Fuel Cycle and Materials Events to the NRC Operations Center

◙ As Low As Reasonably Achievable (ALARA)



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II. Use the space below to take notes during your meeting.



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III. As a Regulator:

◙ Show me an example of a radiation protection program. Tell me why it does or does not reflect the scope and extent of the licensed activities.

◙ Tell me about instruments and equipment and how to verify operability and proper settings.

◙ What should I look for when I review calibration records of instruments?

◙ Tell me about NRC Form 5 and how I should review it to determine compliance.

◙ Show me an exposure summary report and discuss how I determine compliance with it.

◙ Tell me some lessons learned regarding posting, labeling, and control.

◙ Tell me about the importance of NRC Form 3.

◙ Concerning surveys, how do I determine if due consideration is given to alpha, beta, and gamma exposures?

◙ Show me a report that has been submitted to the NRC regarding an event that has happened.

◙ Show me an example of good ALARA documentation.

Use the space below to write your specific questions.



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IV. Further assignments? If yes, please note and complete. If no, initial completion of progress meeting on tracking form.

Suggested reading may include:

◙ 10 CFR Part 40, Appendix A – Criterion 8

◙ NRC Information Notice 93-60, Supplement 1: Reporting Fuel Cycle and Materials Events to the NRC Operations Center

◙ NRC Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Reasonably Achievable

Ensure that you and your administrator have dated and initialed

your progress on your tracking form for this module. Go to the module summary.

MODULE SUMMARY

Health physics inspection activities are essential for the protection against ionizing radiation resulting from operations conducted under licenses issued by the Nuclear Regulatory Commission. Determining whether the licensee is complying with regulatory requirements related to radiation protection involves an ongoing comprehensive health physics inspection program.

Congratulations! You have completed the final module of the General Health Physics Practices for Fuel Cycle Facilities Directed Self-Study Course. Go to the Directed Self-Study

Course Process in the Administrator/Trainee Guide. Ensure completion of steps H and I.



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Module 7—Supplemental Reading


SRIII-1

Supplemental Reading 10 CFR PART 19 10 CFR PART 20

NRC INFORMATION NOTICE 93-60, SUPPLEMENT 1 NRC INSPECTION PROCEDURE 83822

Module 7—Supplemental Reading


SRIII-2
