Issue Date: 12/31/91 - 1 - 83729

NRC INSPECTION MANUAL PRPB

INSPECTION PROCEDURE 83729

OCCUPATIONAL EXPOSURE DURING EXTENDED OUTAGES

PROGRAM APPLICABILITY: 2515

SALP: Radiological Controls

83729-01 INSPECTION OBJECTIVE

To determine the adequacy of the licensee's occupational radiation

protection program during extended outages (major maintenance and

refueling).

83729-02 INSPECTION REQUIREMENTS

02.01 Audits and Appraisals. 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 actions.

02.02 Changes. Review changes since the last inspection in

organization, personnel, facilities, equipment, programs, and

procedures that may affect occupational radiation protection.

02.03 Planning and Preparation. Determine whether planning and

preparation for the outage are adequate.

02.04 Training and Qualifications of New Personnel

a. Review the applicable education, experience, qualifications

and training of selected members of the licensee's (and its

contractor's) radiation protection and plant chemistry

organization(s).

b. Review applicable radiation protection worker education,

qualification, and training of selected members of other

organizations (including contractor employees).

02.05 External Exposure Control

a. Determine whether personal dosimetry for external exposure

meets requirements.
83729 - 2 - Issue Date: 12/31/91

b. Determine whether administrative controls of external

radiation exposure meet requirements and are designed to

maintain exposures ALARA.
Issue Date: 12/31/91 - 3 - 83729

c. Determine whether records, reports, and notifications of

external exposures meet regulatory requirements.

02.06 Internal Exposure Control

a. Determine whether assessment of individual intakes of

radioactive materials meets requirements.

b. Determine whether process or other engineering controls are

used to the extent practicable to limit concentrations of

airborne radioactive materials.

c. Determine whether administrative controls of internal

radiation exposure meet requirements and maintain exposures

ALARA.

d. Determine whether use of respiratory protection equipment

meets requirements.

e. Determine whether records, reports, and notifications of

internal exposures meet requirements.

02.07 Control of Radioactive Materials and Contamination,

Surveys, and Monitoring

a. Determine whether survey and monitoring activities are

performed as required.

b. Determine whether control of radioactive materials and

contamination meets requirements.

02.08 Maintaining Occupational Exposure ALARA

a. Workers Awareness and Involvement. Determine whether workers

are aware of, and involved in, the ALARA program.

b. ALARA Goals and Objectives. Determine whether the licensee

is establishing and tracking ALARA goals and objectives.

c. ALARA Results. Review measures of the effectiveness of the

ALARA program and determine whether the program is effective.

83729-03 INSPECTION GUIDANCE

03.01 Audits and Appraisals

a. Review reports of required audits since the last inspection.

Look particularly for those audits that probe for programmatic

weaknesses and assess the quality of the program. Focus upon

licensee followup actions for identified deficiencies. Are

corrective actions timely and technically acceptable?

Requirements for reviews and audits normally are contained in

the technical specifications. Audit teams should include

someone with experience or training commensurate with the

scope, complexity, or special nature of the activities
83729 - 4 - Issue Date: 12/31/91

audited. (Regulatory Guide 1.146 and ANSI/ASME 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

a. By observation and discussion with cognizant supervisory and

management personnel, determine whether changes have adversely

affected the licensee's program for control of radiation

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. Review representative records

and discuss outage planning with licensee representatives, and

observe activities to verify necessary planning and preparations.

Examples of areas that may be examined include:

a. Increased health physics staff, including plant's method of

ensuring supervisory control over contract technicians.

b. Special training, including use of mockup training.

c. Increased supplies, including clothing, temporary shielding

materials, etc.

d. ALARA considerations, including work package review by health

physics personnel, dose reduction methods, and radwaste

reduction.

e. Adequacy of licensee controls and monitoring of contractor

work standards, equipment, and practices.

f. Early involvement of health physics group and knowledge of

work to be performed.

g. Provisions for engineering controls, such as auxiliary

ventilation systems to minimize the need to use respiratory

protection equipment (Regulatory Guide 8.8, Section C.2.d).

03.04 Training and Qualifications of New Personnel

a. Review representative training records and briefly discuss

with workers and supervisors.

b. Emphasis should be on training provided to the increased work

force required for the outage. Discuss with plant management

and the RPM.

03.05 External Exposure Control
Issue Date: 12/31/91 - 5 - 83729

a. By direct observation, discussion, and review of records,

determine whether personal dosimetry is used effectively and

in accordance with requirements for monitoring external

exposure.

Aspects of personal dosimetry that may be examined include:

1. Improper wearing or use of dosimeters.

2. Exposure records and reports.

3. Use of pocket dosimeters and comparison of their measurements with TLD or film badge results; procedures for

investigating overexposures and lost/off-scale dosimeters.

4. Special processing of dosimetry devices.

5. Quality assurance of personal dosimetry measurements.

6. Photon, beta, and neutron exposures.

7. Extremity exposures.

8. Timely dissemination of current dose status.

9. Review of workers' dose status by managers.

b. By direct observation, discussion, and review of records and

procedures, determine whether administrative controls are

adequate.

1. Practices and Procedures

Aspects of administrative controls that may be considered

include:

(a) Planning work to maintain exposures ALARA and within

limits.

(b) Use of current survey and personal dosimeter data for

dose control.

(c) Use of control/action levels.

(d) Radiation work permit (RWP) program.

(e) Controlling access to high exposure areas.

(f) Radiation work practices.

(g) Management reviews of exposure data trends and

discrepancies.

2. Posting and Labeling
83729 - 6 - Issue Date: 12/31/91

While touring the plant, determine by direct observation

and radiation measurements of representative areas,

whether posting and labeling requirements are met. If

convenient, this may be done by accompanying a health

physics technician on a routine daily survey.

c. 1. Review exposure summary reports to determine compliance

with the regulation.

2. Review exposure summary records to verify compliance with

10 CFR 20.101(b) limits. Select a sampling of individuals who have current exposures in excess of 10 CFR

20.101(a) limits and verify that Forms NRC-4 were

completed prior to exceeding the 10 CFR 20.101(a) limits.

Review exposure records to verify that the licensee is

complying with provisions of 10 CFR 20.102 (transient

worker rule).
Issue Date: 12/31/91 - 7 - 83729

3. Determine if minors have been permitted to work in

restricted areas, and if so, review records to determine

compliance with 10 CFR 20.104(a).

4. Review selected Forms NRC-5 to determine compliance with

the regulations.

5. Determine if overexposures of individuals to external

radiation have been appropriately reported to NRC (10 CFR

20.403 and 20.405) and to the exposed individual [10 CFR

19.13(d)].

03.06 Internal Exposure Control

a. 1. Review calculations for intakes greater than 40 MPC-hr.

Consider the licensee's comparisons of whole-body or

organ-burden data obtained from bioassays with estimates

based on air-sampling data.

2. 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.)

3. Review equipment, procedures, and locations of equipment

to determine the adequacy of provisions for bioassays of

workers.

b. See 10 CFR 20.103(b)(1) and Regulatory Guide 8.8, Section

C.2.d.

c. Review and discuss the licensee's evaluations of suspected

exposures or exposures exceeding the 40 MPC-hour control

values. Consider the use of proper equipment, use of proper

protection factors, appropriateness of preventive measures

following exposure greater than 40 MPC-hours, and proper use

of 2 and 10 MPC-hour exclusions.

d. Guidance on use of respiratory protection equipment is given

in Regulatory Guide 8.15 and NUREG-0041.

e. 1. Review records of the results of evaluations and actions

taken when an individual has been exposed to concentrations of radioactive material greater than 40 MPC-hours.

2. Review records of the results of bioassays, including

whole-body counting.

3. Determine if minors have been permitted to work in

restricted areas, and if so, review records to determine

compliance with the regulations.

03.07 Control of Radioactive Materials and Contamination,

Surveys, and Monitoring

a. Aspects of surveys and monitoring that may be examined

include:
83729 - 8 - Issue Date: 12/31/91

1. Adequacy of supply, maintenance, and calibration and

performance

checks of survey and monitoring instruments.

2. Proper use of portal monitors and friskers.

3. Adequacy of surveys necessary to assess personnel

exposure due to skin contamination.

4. Adequacy of survey practices, including technician

awareness of limitations of the survey instruments.

5. Timely dissemination of survey data and information on

plant conditions for use in work planning and dose

control.

6. Records of surveys and review of survey results by health

physics supervision/management.

Note: Process and effluent monitors are covered in other

inspection procedures.

b. Aspects of radioactive materials and contamination controls

that may be examined include:

1. Evaluation of personal contamination.

2. Proper contamination control work techniques and prompt

correction and cleanup of contamination.

3. Efforts to reduce the volume of contaminated trash

including steps to minimize introduction of uncontaminated material into contaminated areas.

4. Surveys, monitoring, and releases of potentially contaminated material to unrestricted areas. (See IE Bulletin

80-10, IE Circular 81-07, and IE Information Notice

80-22.)

03.08 Maintaining Occupational Exposures ALARA

a. Worker Awareness and Involvement. Discuss the ALARA program

with several workers to determine whether they understand the

program, understand their role in the program, and are

actively involved in the program.

b. ALARA Goals and Objectives. Goals and objectives may be

qualitative and quantitative. Means should be provided to

track progress toward the goals and to take action on the

findings. Goals may be set for the facility as a whole and

for different divisions or groups within the facility.

Facility goals might include a total annual collective dose

(person-rem) value, and a percentage reduction in preventive

maintenance time in high radiation areas.

c. ALARA Results. As a minimum, consider the total annual

collective dose (person-rem) for the facility. Determine
Issue Date: 12/31/91 - 9 - 83729

whether that collective dose is increasing or decreasing, and

whether it is higher or lower than the collective dose for

other facilities of the same type and generating capacity.

Consider reasons for increases or higher-than-average doses

and discuss licensee's plans in relation to relatively high

doses or upward dose trends.

Successes in meeting ALARA goals and objectives provide

measures of ALARA program effectiveness.

03.09 Corresponding Inspection Requirements in Other Inspection

Procedures. Completion of the inspection requirements of this

outage procedure satisfies the corresponding requirements in other

operational ("minimum/basic") procedures as follows:

83729 Inspection Requirement

Corresponding

Inspection

Requirements 

Procedure Requirement

02.01 Audits and Appraisals 83722 02.05

83723 02.03

83724 02.01

83725 02.01

83726 02.01

83728 02.01

02.02 Changes 83722 02.01

83723 02.01

83724 02.02

83725 02.02

83726 02.02

83728 02.02

02.03 Planning and Preparation83724 02.03

83725 02.03

02.04 Training and

Qualification of

83723 02.02

02.05 External Exposure Control83724 02.04

02.05

02.06

02.06 Internal Exposure Control83725 02.04

02.05

02.06

02.07

02.07 Control of Radioactive

Materials and

Contamination, Surveys,

83726 02.03

02.04
83729 - 10 - Issue Date: 12/31/91

02.08 Maintaining Occupational

Exposures ALARA

83728 02.03

02.04

02.05

83729-04 REFERENCES

See references in corresponding inspection procedures listed in

03.09.

END