Radiological Safety and Response RPT-243 -1 Introduction and ALARA Philosophy Radiation Protection Technology The following Learning Outcomes are addressed in Session 1 Radiation Protection Technology.
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Radiological Safety and Response RPT-243 -1 Introduction and ALARA Philosophy Radiation Protection Technology The following Learning Outcomes are addressed in Session 1 Radiation Protection Technology 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). Radiation Protection Technology The following Learning Outcomes are addressed in Session 2 Radiation Protection Technology Learning Outcomes (cont’d) 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 Radiation Protection Technology Learning Outcomes (cont’d) Upon completion of this lesson, the student will be able to: • 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). Radiation Protection Technology Learning Outcomes (cont’d) Upon completion of this lesson, the student will be able to: • 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). Radiation Protection Technology Learning Outcomes (cont’d) Upon completion of this lesson, the student will be able to: • 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. Radiation Protection Technology Learning Outcomes (cont’d) Upon completion of this lesson, the student will be able to: • 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 Radiation Protection Technology Learning Outcomes (cont’d) Upon completion of this lesson, the student will be able to: • 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. Radiation Protection Technology Learning Outcomes (cont’d) Upon completion of this lesson, the student will be able to: • 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 Radiation Protection Technology 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 Radiation Protection Technology RPT-243-1 Session 1 Introduction Radiation Protection Technology 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. Radiation Protection Technology 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 Radiation Protection Technology 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 Radiation Protection Technology Team Dynamics Radiation Protection Technology 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 Radiation Protection Technology Forming • Team members meet each other. • Individual expectations as being part of the team are defined. • The leader’s 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 Radiation Protection Technology 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 team’s mission • Expectations on the team • Individual member’s roles and responsibilities – Recognize that not everyone will become comfortable on the team at the same rate Radiation Protection Technology 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 other’s ideas. • Generally, they avoid collaboration. • Storming is usually the most difficult stage for the team. Radiation Protection Technology 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 Radiation Protection Technology 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 Radiation Protection Technology Performing • Team members: – Identify and solve problems – Implement changes – Make measurable progress toward the goal • Tips: – Do not take advantage of each other’s 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 Radiation Protection Technology 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. Radiation Protection Technology Four Stages of Team Growth Radiation Protection Technology Teams in Summary • Forming – We are watchful, polite, and guarded. We don’t 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 Radiation Protection Technology 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. Radiation Protection Technology Human Performance Improvement Tools Radiation Protection Technology 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. Radiation Protection Technology 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 Radiation Protection Technology 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 Radiation Protection Technology Situational Awareness Radiation Protection Technology Situational Awareness • Clearly, the worker‘s 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 Radiation Protection Technology 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) Radiation Protection Technology 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 Radiation Protection Technology 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 Radiation Protection Technology 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 Radiation Protection Technology 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. Radiation Protection Technology 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? Radiation Protection Technology 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 Radiation Protection Technology 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.) Radiation Protection Technology 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. Radiation Protection Technology Communications Radiation Protection Technology 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 Radiation Protection Technology 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 Radiation Protection Technology 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. Radiation Protection Technology 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). Radiation Protection Technology Phonetic Alphabet • • • • • • • • • • • A - Alpha B - Bravo C - Charlie D - Delta E - Echo F - Foxtrot G - Golf H - Hotel I - India J - Juliet K - Kilo Radiation Protection Technology • • • • • • • • • • • 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 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. Radiation Protection Technology 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 Radiation Protection Technology Closed Loop Communication Radiation Protection Technology 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.) Radiation Protection Technology 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. Radiation Protection Technology 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 we’ve named and the closed loop communication model. Radiation Protection Technology 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.” Radiation Protection Technology 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.” Radiation Protection Technology Critique • • • • • • • Sender Receiver Phonetic Alphabet Numeric Communication Feedback Verbatim Repeat Back Confirmation Radiation Protection Technology Expectations • The three part communication model will be used in all Labs and Practical Exercises for the RPT Program. Student’s 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. Radiation Protection Technology Self-Checking Radiation Protection Technology Self-Checking • 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. Radiation Protection Technology 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 Radiation Protection Technology 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? Radiation Protection Technology 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 Radiation Protection Technology 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. Radiation Protection Technology Procedure Use and Adherence Radiation Protection Technology Procedure Use and Adherence • Every organization’s 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 organization’s departments fulfill the vision and mission of the organization as well as satisfying regulatory requirements. Radiation Protection Technology 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 Radiation Protection Technology 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 user’s memory or recall. Radiation Protection Technology 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. Radiation Protection Technology 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 Radiation Protection Technology 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 Radiation Protection Technology 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 Radiation Protection Technology 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 Radiation Protection Technology 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. Radiation Protection Technology RPT-243 Practical Exercise - 1 Radiation Protection Technology RPT-243-1 Session 2 ALARA Radiation Protection Technology 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 Radiation Protection Technology Learning Outcomes (cont’d) Upon completion of this lesson, the student will be able to: • 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). Radiation Protection Technology Learning Outcomes (cont’d) Upon completion of this lesson, the student will be able to: • 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). Radiation Protection Technology Learning Outcomes (cont’d) Upon completion of this lesson, the student will be able to: • 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. Radiation Protection Technology Learning Outcomes (cont’d) Upon completion of this lesson, the student will be able to: • 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 Radiation Protection Technology Learning Outcomes (cont’d) Upon completion of this lesson, the student will be able to: • 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. Radiation Protection Technology Learning Outcomes (cont’d) Upon completion of this lesson, the student will be able to: • 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 Radiation Protection Technology 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 Radiation Protection Technology 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. Radiation Protection Technology 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. Radiation Protection Technology 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 – Energy – Other Titles used in our profession would be: • Title 29 – Labor (OSHA) • Title 49 – Transportation (RAM Shipping) Radiation Protection Technology 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. Radiation Protection Technology 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. Radiation Protection Technology 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) Radiation Protection Technology 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. Radiation Protection Technology 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. Radiation Protection Technology 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. • The regulation requires that “…the applicant provide a description and safety assessment of the site and a safety assessment of the facility.” Radiation Protection Technology 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 • 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 Radiation Protection Technology 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 • 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. Radiation Protection Technology Specific Regulations and Guides Scope, Principles and Use Radiation Protection Technology 10 CFR 19, Notices, Instructions, and Reports to Workers • Workers rights, responsibilities , and protection • NRC’s obligations regarding inspections and reports • Licensee’s 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 Radiation Protection Technology 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/ Radiation Protection Technology 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/textidx?c=ecfr&sid=a0ed5212bc08d5c0c423998a161a577d&rgn=div5&view=text&node=10:4.0.2.5.27&id no=10#10:4.0.2.5.27.1.82.1 https://www.directives.doe.gov/directives/current-directives/441.1-EGuide-1c/view Radiation Protection Technology 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. Radiation Protection Technology 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 organization’s ALARA program to be effective (discussed later) Radiation Protection Technology 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. Radiation Protection Technology ALARA What, Where, When, Who, and Why Radiation Protection Technology 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. Radiation Protection Technology 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. Radiation Protection Technology 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. Radiation Protection Technology 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. Radiation Protection Technology 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). Radiation Protection Technology 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 Radiation Protection Technology 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. Radiation Protection Technology 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” Radiation Protection Technology 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. Radiation Protection Technology Dose vs Risk Relationships Risk All statistically significant results involve >10 rem 10 rem Dose Radiation Protection Technology Dose vs Risk Relationships Risk Linear-quadratic, no threshold. Dose Radiation Protection Technology Dose vs Risk Relationships Risk Linear-quadratic, threshold. Dose Radiation Protection Technology Dose vs Risk Relationships Risk Linear, threshold. Dose Radiation Protection Technology Dose vs Risk Relationships Risk Linear, non-threshold (LNT). Dose Radiation Protection Technology Dose vs Risk Relationships Hormesis Risk Dose Radiation Protection Technology Dose vs Risk Relationships Risk Linear, non-threshold (LNT). Basis for regulation, ALARA. Dose Radiation Protection Technology Why ALARA? • Although the risks and biological effects to human exposures have been shown to not conclusively exist at lower doses (<10 rem), there is some uncertainty in the models. • Therefore, the most conservative model is used to express the concept of ALARA – the linear no thresehold model. • This is the model used by regulators in setting the requirements of regulation. Radiation Protection Technology ALARA How (Implementing ALARA) Radiation Protection Technology Regulatory Guide 8.10 DOE G 441.1-1C Radiation Protection Technology Guidance • Both the NRC and DOE provide “guidance” on what is to be considered when determining if compliance with the regulations is obtained by the Radiation Protection Program’s ALARA Program. • RG-8.10 states there are two basic conditions necessary for any program keeping occupational exposure ALARA: – Management Commitment – Vigilance by the Radiation Safety Officer (RSO)and the Radiation Protection (RP) Staff Radiation Protection Technology RG-8.10 Management Commitment • Plant personnel are to be made aware of the commitment via clear policy statement and instructions to personnel, etc. Usually achieved with: – Administrative Procedures – Program Implementing Procedures • Management should periodically perform formal program audits to determine the effectiveness in maintaining doses ALARA. • Must have a well defined Radiation Protection Organization with clear roles and responsibilities Radiation Protection Technology RG-8.10 Management Commitment • Plant workers must receive initial and annual training in keeping with requirements of 10 CFR 19.12 for radiation protection. • The RSO (Radiation Protection Manager) must have authority to ensure safe radiological operations. • Changes to maintenance and operating procedures and to plant equipment and facilities must be made when they will substantially reduce doses at a reasonable cost. (discussed later) Radiation Protection Technology RG-8.10 - Vigilance by the RSO and the RP Organization • The RSO and RP Staff will conduct surveillance and investigations to ensure doses are ALARA below the limits. • They are also to be vigilant in searching out new and better ways to perform work with less dose. Radiation Protection Technology RG-8.10 - Vigilance by the RSO and the RP Organization • Includes: – A thorough understanding of the source term within the facility. That is, where is the radiation, what is causing it, and what is happening to the magnitude over time. – An inquisitive and intrusive approach to understanding unusual doses for particular jobs and tasks. Always looking for effective ways to reduce the dose received. – Periodic review of procedures and plant operations that might impact radiation safety. Radiation Protection Technology RG-8.10 - Vigilance by the RSO and the RP Organization • Includes: – Provision of adequate supplies and equipment for radiation protection activities maintained in good condition. – Provision of written procedures for equipment operation. Radiation Protection Technology DOE G 441.1-1C • Very similar to RG-8.10 in that it addresses the following major topics for Implementation Guidance: – Policy and Management Commitment – ALARA Training – Plans and Procedures – Internal Assessments and Audits – ALARA Design review – Radiological Work/Experiment Administration and Planning – Records • Much greater detail in connecting it to 10CFR835 implementation. Radiation Protection Technology ALARA Process • Both NRC and DOE facilities implement a formal Radiation Protection Program with an embedded ALARA Program. • These ALARA programs incorporate the following key components: – Annual Collective Dose Goals – ALARA Job Planning Group – ALARA Committee Formation and Operation – RWP Radiation Protection Technology ALARA Process • These ALARA programs incorporate the following key components: – Annual Collective Dose Goals • Station • Departmental • Individual Dose Goals By establishing and tracking these ALARA dose goals, accountability is established for every mrem spent at every level in an organization. This brings ALARA into focus for everyone involved. Radiation Protection Technology ALARA Process • These ALARA programs incorporate the following key components: – ALARA Job Planning Group • Review all jobs for ALARA action • For pre-screened jobs requiring ALARA review: – Initiate Radiological Work Permit (RWP) (later) – Collective Dose Assessment (later) – Determine if additional ALARA review is indicated – collective or individual dose above an action threshold. Radiation Protection Technology ALARA Process • These ALARA programs incorporate the following key components: – ALARA Job Planning Group • Cost-Benefit Analysis for ALARA Actions (later) • Additional ALARA Pre-Job Planning – Shielding – System Flushing – Additional Dosimetry – Specialized Training (Mock-Up Training) – Innovative, specialized, tooling and equipment – Stay times and time-keeper requirements Radiation Protection Technology ALARA Process • These ALARA programs incorporate the following key components: – ALARA Job Planning Group • In-Progress ALARA Reviews • Post-Job reviews • Maintain Dose-Tracking Records • Maintain Job History Files • “Total risk” consideration – when planning a job, the total cumulative risk for individuals must be considered. Radiation Protection Technology ALARA Process • These ALARA programs incorporate the following key components: – ALARA Job Planning Group • “Total risk” consideration – when planning a job, the total cumulative risk for individuals must be considered. • For example, a respirator may be indicated, but if the combined effects of wearing the respirator and the protective clothing actually poses more of a risk for personnel injury, then the path of lesser risk must be chosen. Radiation Protection Technology ALARA Process • These ALARA programs incorporate the following key formal components: – ALARA Committee Formation and Operation • Representatives from every department • Chaired by member of management (typical) • Joint review and approval of: – station goals including dept. level goals, – major work packages, station modifications – procedures which impact station collective dose – temporary and permanent shielding installations Radiation Protection Technology RWP • Radiological Work Permit (sometimes called a Radiation Work Permit) both are RWPs. • RWPs are used to control work performed in a radiologically controlled area or activities associated with the use of radioactive material. • This is achieved by specifying: – protective clothing requirements for a job, – contamination control requirements, – respiratory protection requirements, – dosimetry requirements, – type of RPT coverage required, – work restrictions, Radiation Protection Technology RWP • This is achieved by specifying (cont’d): – Time keeping for stay times – Continuous RP coverage – either locally or remotely – Stipulation of low dose waiting areas – Use of temporary shielding – Removal of source term from work area Radiation Protection Technology 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 Radiation Protection Technology 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 don’t 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. Radiation Protection Technology 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 Radiation Protection Technology 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. rem person rem person hour hr • This will determine the level of additional review required (if any). Radiation Protection Technology 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. Radiation Protection Technology Cost-Benefit Analysis for ALARA Actions - Scenario • Let’s 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. Radiation Protection Technology 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 dollars 5person rem 13,000 $85,000 person rem Radiation Protection Technology 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) Radiation Protection Technology 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. Radiation Protection Technology 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) Radiation Protection Technology ALARA “Big Three” • Shielding – reduce the dose rate – reduce the dose. • Watch the dose required to install it and, if it’s temporary, to remove it – you must be able to show it is a “cost-effective” installation. • Ensure it is the proper shielding – don’t use lead for high beta dose rates – Bremsstrahlung. • For temporary shielding – engineering evaluations are required for system components and piping. Radiation Protection Technology 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. Radiation Protection Technology ALARA Beyond the Basics • 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 Radiation Protection Technology ALARA Beyond the Basics • 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 Radiation Protection Technology Who’s Job Is It Anyway? • The short answer is “everyone’s”. 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. Radiation Protection Technology Who’s 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. Radiation Protection Technology Who’s 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 group’s dose ALARA. Radiation Protection Technology Video Ways to Save a Millirem Radiation Protection Technology What Are Your Questions? Radiation Protection Technology RPT-243 Practical Exercise - 2 Radiation Protection Technology