**NRC INSPECTION MANUAL** IOLB

INSPECTION PROCEDURE 83725

INTERNAL EXPOSURE CONTROL AND ASSESSMENT

PROGRAM APPLICABILITY: 2515

83725‑01 INSPECTION OBJECTIVE

To determine the adequacy of the licensee\'s control of internal
occupational exposure and the internal dosimetry program.

83725‑02 INSPECTION REQUIREMENTS

This procedure is implemented to independently assess licensee
conclusions regarding extent of condition of issues, when selected as a
part of supplemental inspections using IP 95002, ASupplemental
Inspection For One Degraded Cornerstone or Any Three White Inputs in a
Strategic Performance Area.@

Inspection requirements completed as part of the baseline need not be
repeated, at the discretion of the Regional Branch Chief.

02.01 [Audits and Appraisals]{.underline}. Review the results of audits
performed by or for the licensee since the last inspection and the
adequacy of the licensee\'s commitments and corrective action.

02.02 [Changes]{.underline}. Review changes in facilities, equipment,
personnel, respiratory protection training, and procedures that affect
internal exposure control and personal dosimetry.

02.03 [Planning and Preparation for Outages]{.underline}. Determine
whether necessary planning and preparation for maintenance and refueling
outages are adequate.

02.04 [Assessing Individual Intakes of Radioactive
Materials]{.underline}. Determine whether provisions for assessing
individual intakes of radioactive materials meet requirements.

02.05 [Engineering and Administrative Controls]{.underline}

a.  Determine whether process or other engineering controls are used to
    the extent practicable to limit concentrations of airborne
    radioactive materials.

b.  Determine whether administrative controls of internal radiation
    exposure meet requirements and maintain the total effective dose
    equivalent (TEDE)as low as is reasonably achievable (ALARA).

02.06 [Respiratory Protection Equipment]{.underline}

a.  Determine whether use of respiratory protection equipment meets
    requirements.

b.  Determine whether the respiratory protection equipment dedicated for
    emergency use meets regulatory requirements, and is operable,
    maintained, and readily available for emergency workers.

02.07 [Records, Reports, and Notifications]{.underline}. Determine
whether records, reports, and notifications of internal exposures during
normal and emergency operations meet regulatory requirements.

83725‑03 INSPECTION GUIDANCE

[General Guidance]{.underline}

Additional guidance can also be obtained by reviewing the EPRI
TR-107991,ARadiation-Field Control Manual - 1997 Revision and NCRP
report number 120, ADose Control at Nuclear Power Plants,@ (issued
December 30, 1994).

[Specific Guidance]{.underline}

03.01 [Audits and Appraisals]{.underline}

a.  Review reports of required audits since the last inspection. Verify
    timeliness and effectiveness of licensee corrective actions.

> Requirements for reviews and audits normally are contained in the
> technical specifications. Audit teams should include someone
> knowledge­able in internal dose control and evaluation (Regulatory
> Guide 1.146 and ANSI/AS ME N45.2.23‑1978, Section 2.2).

b.  Review reports of other audits, appraisals, assessments, evaluations
    etc., that may provide information on program quality.

03.02 [Changes]{.underline}

a.  By observation and discussion with cognizant management personnel,
    determine whether changes(facilities, equipment, personnel and
    procedures) have adversely affected the licensee\'s program for
    control of internal exposures. Determine whether changes are in
    accordance with 10 CFR 50.59.

b.  By direct observation and discussion, determine whether workers are
    aware of, and understand, the changes.

03.03 [Planning and Preparation for Outages]{.underline}. Determine
whether planning and preparation to control and limit intake of airborne
radioactive materials are adequate. Such planning and preparation should
include provisions for engineering control, such as auxiliary
ventilation systems, to minimize the need to use respiratory protection
equipment (Regulatory Guide 8.8).

03.04 [Assessing Individual Intakes of Radioactive
Materials]{.underline}

See the following references for technical information relative to this
inspection requirement. Note that the while NRC has not, as yet,
endorsed these consensus standards, these standards do provided useful
information. These include HPS N13.30-1996, APerformance Criteria for
Radiobioassay@; and N13.42-1997, AInternal Dosimetry for Mixed Fission
and Activation Products@. NUREG/CR-4884, AInterpretation of Bioassay
Measurements@ provides practical methods for establishing intakes from
bioassay data.

a.  Records of the results of bioassays, including whole body counting ,
    are the principal source of information for intakes of radioactive
    material. Consider the licensee=s comparisons of whole-body or
    organ-burden data obtained from bioassays with estimates based on
    air sampling data.

b.  During tours of the facility, observe work in progress to determine
    whether air sampling is representative of air in zones occupied by
    workers. (See ANSI N13.1 Section 4.2.1.1 and Section 6.) Observe
    techniques used to evaluate air samples for radiological hazards. As
    applicable, this may include observation of count room practices,
    DAC-hour correlations and assignment of DAC-hours, correlation to
    internal dose, or a determination that internal dose assignment is
    not necessary.

c.  During tours of the facility, observe work to determine if the
    licensee has implemented proper equipment, use of procedures, and
    appropriate locations of equipment to determine the adequacy of
    provisions for bioassays of workers.

d.  During whole body counting as part of site access processing,
    observe (whenever possible) whole body counting equipment operation
    and discuss counting and calibration methods with equipment
    operators.

e.  For selected individuals whose whole body counts exceed the
    licensee=s action level for investigation, review the results and
    corrective actions for such investigations.

f.  Review records to determine how the licensee complied with 10 CFR
    20.1502(b) in determining which individuals are required to be
    monitored for occupational intake of radioactive material.

g.  Intakes of radioactive material may result in the alarming of high
    sensitivity automated personal contamination monitors (used to
    detect external contamination). Workers who expect to have intakes
    that may be detected by these monitors should be prepared for these
    alarms. See question and answer #145 (under the heading for 10 CFR
    20.1702) in NUREG/CR- 6204 for additional guidance concerning
    situations of this type.

h.  Determine if the licensee=s program has provisions for transuranic
    airborne radioactive materials controls. Focus on work controls that
    alert and take into account the potential sources, and work
    activities that could produce these hazards. Review the licensee 10
    CFR Part 61 radionuclide scaling factor data to ensure
    hard-to-detect nuclides (transuranics and pure beta emitters) are
    included.

03.05 [Engineering and Administrative Controls]{.underline}. 10 CFR
20.1702 requires that the use of respiratory protection equipment (and
other controls) to limit intakes of radioactive material be consistent
with maintaining the TEDE ALARA. Evaluations and (records of these
evaluations) for the use of respiratory protection equipment made in
accordance with this requirement are acceptable if they are consistent
with the guidance provided in the answer to Question 60 (under the
heading for 10 CFR 20.1703) in the questions and answers on the new Part
20; however, other means of meeting this ALARA requirement may also be
acceptable.

> Note that 10 CFR 20.1702 now allows the licensee to consider
> non-radiological safety factors (industrial hygiene hazards) and their
> impact on worker safety, when performing TEDE ALARA evaluations(see
> C.2.1.3, R.G. 8.15, Rev.1)

03.06 [Respiratory Protection Equipment]{.underline}

a.  Guidance on use of respiratory protection equipment is given in
    Regulatory Guide 8.15, Rev. 1 and NUREG‑0041, Rev. 1(when
    published).

b.  Review procedures and selected records, hold discussions with
    cognizant individuals, and observe representative samples of
    equipment and any routine or special maintenance of equipment. Focus
    on any testing and maintenance of self-contained breathing apparatus
    (SCBA) and maintenance of air or oxygen supplies used for SCBA and
    air-supplied respirators. Ensure that the licensee has an adequate
    number of SCBAs and spare air cylinders available for emergency
    conditions.

03.07 [Records, Reports, and Notifications]{.underline}

a.  Review records of the results of evaluations and actions taken when
    an individual has been exposed to concentrations of radioactive
    material greater than licensee administrative limits.

b.  Based on a selected sample of records of individuals for whom
    individual monitoring of intakes of radioactive material was
    required, have the committed effective dose equivalent and total
    effective dose equivalent been properly assessed and recorded? See
    regulatory Guides 8.7 (Instructions for Recording and reporting
    Occupational Exposure Data) and 8.34 (Monitoring Criteria and
    methods to Calculate Occupational radiation doses) for additional
    guidance.

c.  Determine if minors have been permitted to work in restricted areas,
    and if so, review records to determine compliance with requirements.

d.  Determine if overexposures of individuals to radioactive materials
    have been appropriately reported to NRC and to the exposed
    individual.

83725-04 RESOURCE ESTIMATE

It is anticipated that 25 to 30 inspector-hours on-site will be needed
to complete the requirements of this procedure. Multiple-unit sites
require the same amount of time.

END