NRC Generic Letter 1995-09
K>j UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
WASHINGTON, D.C. 20555 APRIL 5, 1996 NRC GENERIC LETTER 95-09, SUPPLEMENT 1: MONITORING AND TRAINING OF SHIPPERS
AND CARRIERS OF RADIOACTIVE MATERIALS
Addressees
All U. S. Nuclear Regulatory Commission Licensees.
Purpose
to The U.S. Nuclear Regulatory Commission (NRC) is issuing this supplement and clarify the guidance provided in NRC Generic Letter 95-09, "Monitoring Training of Shippers and Carriers of Radioactive Materials,' issuedinformation November 3, 1995. It is expected that recipients will review the to for applicability to their facilities and consider actions, as appropriate, is avoid similar problems. However, no specific action or written response required.
DescriDtion of Circumstances on Generic Letter 95-09 was issued to provide NRC licensees with guidance by satisfying the training and monitoring requirements for personnel employed shippers and carriers making deliveries or picking up packages from the and licensee's facilities. After issue of the generic letter, NRC and carrier shipping companies received a large number of telephone calls and other correspondence from licensees inquiring as to the applicability of the guidance to their facilities. Shippers and carriers also received large numbers of requests from NRC licensees to provide evidence that had personnel picking up or delivering packages at the licensees' facilities been trained. Most of these requests came from licensees to whom the training requirements did not apply.
Analysis of the Inquiries and requests indicated that they resulted from of misunderstandings of current NRC regulations, and also a lack of awareness is the most recent NRC regulations in the affected areas. This supplement being issued in an attempt to clarify the issues that caused misunderstandings when Generic Letter 95-09 was issued.
Discuss-io
95-09 The misunderstandings that became apparent after issue of Generic Letter can be classified into the following issues.
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GL 95-09, Supp. 1 April 5, 1996 1. Who needs to be trained: The ol 10 CFR 19.12 stated, in part:
All individuals working in or frequenting any portion of a restricted area shall be kept informed of the storage, transfer, or use of radioactive materials or of radiation in such portions of the restricted area;
shall be instructed of the health protection problems associated with exposure to such radioactive materials or radiation, in precautions or procedures to minimize exposure, and in the purposes and functions of protective devices employed;...
In other words, this requirement stated that anyone entering the restricted area must be trained. A large number of licensees interpreted the generic letter in light of this regulation, and who therefore requested proof of training for any carrier personnel entered their restricted areas.
This part of the regulation has been changed, effective August 14, 1995, and the revised 10 CFR 19.12 states, in part:
(a)All individuals who in the course of employment are likely to receive in a Year an occupational dose in excess of 100 irem (lmSv) shall be-
(1)Kept informed of the storage, transfer, or use of radiation and/or radioactive material;
(2) Instructed in the health protection problems associated with exposure to radiation and/or radioactive material, in precautions or procedures to minimize exposure, and in the purposes and functions of protective devices employed;
Whereas under the old regulation, anyone who entered the lIcensee'straining restricted area had to be trained, the new regulation requires in excess only for those who are likely to receive an occupational dose of I mSv (100 mrem) in a year. Therefore, those workers, including carrier personnel, who are not likely to receive a dose in excess of I mSv (100 mrem) in a year, do not require training to satisfy the requirements of 10 CFR Part 19.
2. Where is the 1 mSv (100 mrem) in a year received: The revised 10 CFRof Part 19 sets a threshold of 1 mSv (100 mrem) in a year for training occupationally exposed personnel. Furthermore, the training requirement is no longer tied to entry into a restricted area; any worker who is
GL 95-09, Supp. 1 April 5, 1996 mrem) in likely to receive an occupational dose in excess of 1 mSv (100 in a year, inside or outside the restricted area, requires training
(100 mrem) in a year applies to accordance with 10 CFR 19.12. The 1 mSv doses likely to be received as a result of the licensee's activities, which usually means as a result of entry or work in the licensee's facility. It does not include doses received at other than the of a licensee's facilities, whether or not licensed by NRC. An employee dose of carrier company may, in the course of a year, receive a total as a well over I mSv (100 mrem). However, this dose will be received many NRC-licensed and other facilities, result of making deliveries at such as well as during transportation and loading activities outside person's facilities. Each NRC licensee, however, in evaluating that likely training requirements, should consider only that part of the dose to be received at that licensee's facility. If that part of the is person's dose exceeds 1 mSv (100 mrem) in a year, then training that required; otherwise, training is not required, regardless of person's total dose during the year.
The 1 mSv (100 mrem) in a year that may be received at a licensee's a result facility applies to the dose received by a given individual as year.
of one or many visits to the licensee's site during the calendar If each delivery or pickup during the year is made by a different of carrier person, then each person should be evaluated on the basis site. If doses likely to be received during his/her single visit to the the year, then the same person makes the deliveries or pickups during the the dose that is likely to be received would need to include person likelihood from the total of all the site visits made by that basis.
during the year. The training requirements are assessed on that The generic
3. To whom does the guidance in Generic Letter 95-09 apply:
letter stated the following:
NRC licensees may choose any method that they consider capable of providing assurance that carrier personnel have received the proper training and are being properly monitored for radiation exposure. In the case of carriers whose programs are established in compliance with DOT requirements, a letter from the carrier certifying that their personnel are training and monitored under the provisions of such a program would be sufficient to show compliance with the applicable sections of 10 CFR Parts 19 and 20.
Another method, applicable in cases where the carrier's program is not established in compliance with DOT requirements, would be to obtain and review copies of the carrier's programs to ensure their adequacy.
at their NRC licensees are responsible for implementing NRC requirements of facility. In the case of persons who may receive a dose in excess is responsible for ensuring
1 mSv (100 mrem) in a year, the licensee
GL 95-09, Supp. I
April 5, 1996 19, that the person has received the training specified in 10 CFR Part regardless of whether that person is or is not an employee of the licensee. The quote from the generic letter noted above states that, although it is the licensee's responsibility to ensure that the person affected by the regulations is trained, the licensee need not provide the training, as long as training is provided under an acceptableprograms training program. The generic letter also stated that training established to satisfy Department of Transportation (DOT) requirements the would be acceptable. This means that, if a worker is trained by then carrier to satisfy DOT radiation protection program requirements, that training is acceptable to NRC. Carrier training programs doOther not have to be established under DOT requirements to be acceptable.
as accredited radiation training programs would also be acceptable, such programs established under the Occupational Safety and Health Administration (OSHA) requirements, which apply to training of trans- portation workers. It should be noted, however, that training programs provided by carriers to their employees are normally of a general nature and do not include discussion of issues related to a specific licensee's the site. Should specific training be required because of the nature ofsite- hazards at the licensee's site, then the licensee must ensure that specific training is also provided to carrier personnel who may require such training.
in
4. Who needs to be monitored: Monitoring requirements are specified
10 CFR 20.1502. According to these requirements, in the case of external exposures, all persons likely to receive, in one year, a dose in excess of 5 mSv (500 mrem) must be monitored for radiation exposure.
This monitoring is the responsibility of the licensee in whose facility the dose is received. The same considerations discussed above in mrem)
connection with training also apply to monitoring. The 5 mSv (500
in a year applies to doses likely to be received at the licensee'sin facility and not to the dose that may be received by the persons other facilities. Monitoring implemented under recognized radiation or protection programs, such as those established in accordance with DOT
OSHA regulations, would be acceptable to satisfy the monitoring requirements in 10 CFR Part 20.
not It should be noted that provision of monitoring by the carrier does incurred at relieve the licensee of the responsibility for radiation exposures any their site. Specifically, the licensee is responsible for implementing appropriate, ALARA (as low as is reasonably achievable) measures that may be
N
GL 95-09, Supp. 1 April 5, 1996 as required by 10 CFR § 20.1101(b), for all persons exposed to radiation at the licensee's facility, h'respective of who provides the required training and monitoring for the exposed individuals.
If you have any questions about this matter, please contact the technical contact listed below or the appropriate regional office.
Donald A. Cool, Director Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards Attachment: List of Recently Issued Generic Letters Technical contact: Sami Sherbini, NMSS
(301) 415-7902 Internet:sxs2@nrc.gov
I
Attachment GL 95-09, Supp. 1 April 5, 1996 LIST OF RECENTLY ISSUED GENERIC LETTERS
Generic Date of I +t+er Subiect Issuance Issued To RELOCATION OF THE PRESSURE 01/31/96 ALL HOLDERS OF OLs
96-03 OR CPs FOR NPRs TEMPERATURE LIMIT CURVES
AND LOW TEMPERATURE OVER-
PRESSURE PROTECTION SYSTEM
LIMITS
RECONSIDERATION OF NUCLEAR 01/31/96 ALL HOLDERS OF OLs
96-02 OR CPs FOR NPRs POWER PLANT SECURITY
REQUIREMENTS ASSOCIATED
WITH AN INTERNAL THREAT
CONSIDERATION OF VALVE 01/24/96 ALL HOLDERS OF OLs
89-10, (EXCEPT THOSE LICENSES
Supp. 7 MISPOSITIONING IN
PRESSURIZED-WATER THAT HAVE BEEN AMENDED
REACTORS TO A POSSESSION ONLY
STATUS) OR CPs FOR NPRs TESTING OF SAFETY-RELATED 01/10/96 ALL HOLDERS OF OLs OR
96-01 CPs FOR NPRs LOGIC CIRCUITS
RELOCATION OF SELECTED 12/15/95 ALL HOLDERS OF OLs OR
95-10 CPs FOR NPRs TECHNICAL SPECIFICATIONS
REQUIREMENTS RELATED TO
INSTRUMENTATION
MONITORING AND TRAINING OF 11/03/95 ALL U.S. NRC LICENSEES
95-09 SHIPPERS AND CARRIERS OF
RADIOACTIVE MATERIALS
10 CFR 50.54(p) PROCESS FOR 10/31/95 ALL HOLDERS OF OLs &
95-08 CPs FOR NPRs CHANGES TO SECURITY PLANS
WITHOUT PRIOR NRC APPROVAL
OL - OPERATING LICENSE
CP - CONSTRUCTION PERMIT
NPR - NUCLEAR POWER REACTORS
GL 95-09, Supp. 1 April 5, 1996 as required by 10 CFR j 20.1101(b), for all persons exposedrequired to radiation at the licensee's facility, irrespective of who provides the training and monitoring for the exposed individuals.
If you have any questions about this matter, please contact the technical contact listed below or the appropriate regional office.
Donald A. Cool, Director Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards Attachment: List of Recently Issued Generic Letters Technical contact: Sami Sherbini, NMSS
(301) 415-7902 Internet:sxs2@nrc.gov Initials: 2/6/96 DIS
2/8/96 FCC
NMSS/EDITOR
EKRAUS
2/ 7 /96 ArnnelInI P-1 *Cpa nrw~g inlc -nnriurrPnce OFC I INS I INNS I * OGC* Ii l NAME I SSherbini GPangburn RFonner DCool DATE J 2/ 6 /96 2/ 6 /96 2/14/96 2/15/96
I/
GL 95-09, Supp. 1 March , 1996 as required by 10 CFR § 20.1101(b), for all persons exposed to radiation at the licensee's facility, irrespective of who provides the required training and monitoring for the exposed individuals.
If you have any questions about this matter please contact the technical contact listed below or the appropriate regional office.
Donald A. Cool, Director Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards Attachment: List of Recently Issued Generic Letters Technical contact: Samn Sherbini, NMSS
(301) 415-7902 Internet:sxs2Qnrc.gov Initials: 2/6/96 DIS
2/8/96 FCC
NMSS/EDITOR
EKRAUS
2/ 7 196
%I.nr' n CC *<an nrauintic cnneirrence OFC I INS I * INNS I * 0GC* I INNS I
NAME SSherbini GPangburn RFonner DCool DATE 2/ 6 /96 2/ 6 /96 2/14/96 j 3/ /96
GL 95-09, Supp. 1 February XX, 1996 If you have any questions about this matter please contact the technical contact listed below or the appropriate regional office.
Donald . Cool, Director Divisiq of Industrial and
-Medical Nuclear safety O)fice of Nuclear Material Safety
/ And Safeguards Technical contact: Sami Sherbini, NMSS
(301) 415-7902 Attachment: List of recently issued Generic Letters.
Initials: 2/6/96 DIS
2/8/96 NMSSIEDrTOR FCC
EKRAUS
2/7/96 n^^.,^"+. r - -vfw gocumeuz; .fl"
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- ,
OFC * I * 6 W JSI l22NS
NAME 'SSherbini GPangburn DATE 2/6/96 2/ 6/96 21//96 21( C196 I
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IN 96-XX
February XX, 1996 If you have any questions about this matter please contact the technical contact listed below or the appropriate regional office.
Donald A. Cool, Director Division of Industrial and Medical Nuclear safety Office of Nuclear Material Safety And Safeguards Attachment:
Generic Letter 95-09 Technical contact: Sami Sherbini, NMSS
(301) 415-7902 Initials:
NMSSAEDITOR
EKRAUS
21 /96 Document: G:GLIN.SS
OFC lDENS I BINS I l INS l IHNS I
NAME SSherbini Pig DCool DATE 2/16/96 2/ (/96 2/6/96 2/ /96