Re: Training of individuals in "restricted" areas

[sandy_perle@email.fpl.com]

     I agree with Mark's comments, that not everyone needs be trained. 
     However, some individuals who are projected "not" to meet the 100 mrem 
     training requirement should, based on the rule, receive the 
     appropriate training. The following is a summary of the rule that was 
     put together for discussions with management. It is focused towards 
     power plant environments, however, the rule is pertinent to any NRC 
     licensee.
     
     Skip it if not interested.
     
     Sandy Perle        
     Supervisor Health Physics                            
     Florida Power and Light Company
     Nuclear Division
     Juno Beach, FL
     
     (407) 694-4219 Office
     (407) 694-3706 Fax
     
     sandy_perle@email.fpl.com
     
     homepage: http://www.lookup.com/homepages/54398/home.html
     
     DISCLAIMER: The comments and opinions are mine alone, and do not 
     necessarily reflect those of my employer
     
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     What The Rulemaking Change Says:
     
     1. Clarifies the definition of an occupationally exposed worker as an  
        individual whose assigned duties involve exposure to radiation,     
        and, that they are likely to receive a dose in excess of 100 mrem   
        in a year. 
     2. A member of the public is defined based on not where they work, but 
        with respect to the dose they are likely to receive.
     3. Plant workers who do not meet the criteria stated above will be     
       considered as members of the general public, as stated below in item 
     4. Clerical workers or other individuals similar in nature, who access 
        the radiation controlled areas, but are not exposed to levels       
        whereby they are likely to exceed 100 mrem in a year, are not       
        required to be trained.
     5. The rule allows individuals (members of the general public - such   
        as truck drivers and repair service employees) who occasionally     
        enter a restricted area to not be required to receive occupational  
        training, merely because they entered a restricted area when the    
        potential to exceed 100 mrem in a year does not exist.
     6. 10 CFR 20.1101(b) requires that licensees adopt procedures and      
        engineering controls to achieve occupational doses and doses to     
        members of the public that are as low as reasonably achievable      
        (ALARA). Radiation protection training programs continue to be an   
        important element of an ALARA program.
     7. The NRC expects that individuals who do not require training under  
        this rule, since their normal job does not require them to work in  
        areas where they are likely to exceed 100 mrem in a year, but are   
        classified as an emergency worker according to the plant emergency  
        plan, that they would still be required to receive regulatory       
        required training.
     
     What does the Rulemaking mean:
     
     1. This rule change is analogous to the requirement when to monitor an 
        individual for exposure to radiation. The current requirement       
        states that monitoring is required for an individual if they are    
        likely to receive in excess of 500 mrem in a year.
     2. The issue evolves around "regulatory required training" versus      
        "common sense training."
     3. The plants can determine who will and who will not be trained.
     4. Common sense dictates that while training is not required per the   
        regulations, some scaled down training might be prudent to inform   
        individuals who access the radiation controlled areas that they are 
        in fact being exposed to levels of radiation, and what impact that  
        might have on them. More than anything else, it should allay any    
        fears that they might have, and, mitigate a future litigation issue 
        by the utility that they were in an area where they could be        
        exposed to radiation.
     
     NEI Discussions:
     
     1. Benefit clarifies the definition of an occupationally exposed       
        worker versus a member of the general public.
     2. Prior to this rulemaking change, it was vague as to who should      
        receive training. Plants generally opted to train everyone on site. 
        This is unnecessary.
     3. NEI's position is in line with what is found in the section below,  
        entitled Recommendations and Action Plan.
     
     Issues:
     
     1. Potential litigation if certain work groups are determined to be    
        "members of the general public" and not as "occupationally exposed  
        workers" per the criteria that the individual is not likely to      
        receive in excess of 100 mrem in a year.
     2. This issue, one that workers, even those deemed to be               
        occupationally exposed workers, state later that they were not      
        informed of all the hazards, risks or requirements for working in   
        an environment whereby they were exposed to radiation.