Karla Petrová State Office for Nuclear Safety The control and regulation of occupational exposure through the inspection process in the Czech Republic Karla Petrová State Office for Nuclear Safety EAN Workshop, Uppsala 2004

CZECH REPUBLIC - General Information ~ 10 mil. of inhabitants ~ 8 000 licensees ~ 20 ths of monitored radiation workers ~ 13 000 radiation sources 2 NPPs Establishment of an independent regulatory body - the State Office for Nuclear Safety in 1993; Integration of nuclear safety and radiation protection regulatory activities to one governmental body in 1995; Preparation and enacting of new legislation - Atomic Act was put into force in 1997 followed by its implementing Regulations and other Legal Acts; Reliable operation of Dukovany NPP accompanied by thorough safety re-assessment and preparation and execution of several modernization programs; Temelín NPP safety re-assessment followed by design changes implementation ;

STATE OFFICE FOR NUCLEAR SAFETY - Regulatory and Legal Framework Legislative framework is based on Atomic Act (Law No. 18/1997 Coll. on peaceful utilization of nuclear energy and ionizing radiation) was put into the force in 1997 (new version in 2000). Altogether 14 Decrees follows the Atomic Act, Decree No.307/2002 on Radiation Protection Decree No. 315/2002 on Qualification Requirements in Radiation Protection and Nuclear Safety Decree No.419/2002 on Personal Radiation Passport Establishment of an independent regulatory body - the State Office for Nuclear Safety in 1993; Integration of nuclear safety and radiation protection regulatory activities to one governmental body in 1995; Preparation and enacting of new legislation - Atomic Act was put into force in 1997 followed by its implementing Regulations and other Legal Acts; Reliable operation of Dukovany NPP accompanied by thorough safety re-assessment and preparation and execution of several modernization programs; Temelín NPP safety re-assessment followed by design changes implementation ;

STATE OFFICE FOR NUCLEAR SAFETY - SUJB- an Independent Regulatory Authority State Office for Nuclear Safety (SÚJB) is an independent governmental body responsible for governmental administration and supervision in the fields of peaceful uses of nuclear energy and ionizing radiation. The Regulatory Body for nuclear and radiation safety, State Office of Nuclear Safety (SONS), was established on 1st of January 1993 after dissolution of Czechoslovakia. It retained the most of the previous staff of the former regulatory body and therefore did not have to go a major development stage as did Slovak Republic's NRA. SONS is an independent central body of the state administration with its own budget. It is headed by the Chairman appointed by the Czech Government. Deputy chairmen, directors of departments and heads of divisions are appointed by the Chairman of the SONS as well as nuclear safety and radiation protection inspectors. SONS (Chairman) reports to the government either directly or through the Vice Premier for Economics. SONS has its own QA-manual called Organizational Rules (VDS 01) which defines the organization, management responsibilities, tasks of individual units within the defined structure, and basic working methods, including definition how the internal procedures are documented. SONS is responsible for regulating, licensing and supervising of nuclear power plants. The legal framework of the SONS is given by Atomic Law No. 18/1997.

STATE OFFICE FOR NUCLEAR SAFETY - Structure The SÚJB has at present 162 employees (from 171 posts) from which approx. 110 are professionals, 60 radiation protection inspectors The SÚJB has at present two technical support organizations under its own control (in addition to a number of subcontractors): State Institute for Radiation Protection, State Institute for Nuclear, Chemical and Biological Protection. The Regulatory Body for nuclear and radiation safety, State Office of Nuclear Safety (SONS), was established on 1st of January 1993 after dissolution of Czechoslovakia. It retained the most of the previous staff of the former regulatory body and therefore did not have to go a major development stage as did Slovak Republic's NRA. SONS is an independent central body of the state administration with its own budget. It is headed by the Chairman appointed by the Czech Government. Deputy chairmen, directors of departments and heads of divisions are appointed by the Chairman of the SONS as well as nuclear safety and radiation protection inspectors. SONS (Chairman) reports to the government either directly or through the Vice Premier for Economics. SONS has its own QA-manual called Organizational Rules (VDS 01) which defines the organization, management responsibilities, tasks of individual units within the defined structure, and basic working methods, including definition how the internal procedures are documented. SONS is responsible for regulating, licensing and supervising of nuclear power plants. The legal framework of the SONS is given by Atomic Law No. 18/1997.

STATE OFFICE FOR NUCLEAR SAFETY - Structure Organisational changes in preparation in accordance with a new law on „Public Service“ coming into the force in 2005 (or 2007) The Regulatory Body for nuclear and radiation safety, State Office of Nuclear Safety (SONS), was established on 1st of January 1993 after dissolution of Czechoslovakia. It retained the most of the previous staff of the former regulatory body and therefore did not have to go a major development stage as did Slovak Republic's NRA. SONS is an independent central body of the state administration with its own budget. It is headed by the Chairman appointed by the Czech Government. Deputy chairmen, directors of departments and heads of divisions are appointed by the Chairman of the SONS as well as nuclear safety and radiation protection inspectors. SONS (Chairman) reports to the government either directly or through the Vice Premier for Economics. SONS has its own QA-manual called Organizational Rules (VDS 01) which defines the organization, management responsibilities, tasks of individual units within the defined structure, and basic working methods, including definition how the internal procedures are documented. SONS is responsible for regulating, licensing and supervising of nuclear power plants. The legal framework of the SONS is given by Atomic Law No. 18/1997.

Licensing and Occupational Exposure Control and Regulation Licensee shall: ensure that radiation protection is a matter of priority; ensure that his activities with sources of ionizing radiation are justified; maintain a level of radiation protection that the risk to life, health, environment shall be kept as low as reasonably achievable; perform of intervention if the exposure can approach levels of acute damage to health, or if such measures are expected to provide more benefit than harm; reduce exposure of people so that established limits are not exceeded ensure the security of sources

Licensing and Occupational Exposure Control and Regulation Basic limits of occupational exposure  E (external and internal exposure)  100 mSv/5 year;  E (external and internal exposure)  50 mSv/year; H  150 mSv/year in eye lens; average H  500 mSv/year in 1 cm2 of skin; average H  500 mSv/year to arms from fingers to forearms, for legs from feet to ankles, are not exceeded.

Licensing and Occupational Exposure Control and Regulation Optimisation ALARA principle in radiation protection for all activities is understood as implemented if at the same time: the total collective effective dose S  1 Sv/year, the individual effective dose of radiation workers E  1 mSv/year, the individual effective dose (for the critical group of people) E  50 Sv/year,

Licensing and Occupational Exposure Control and Regulation Optimisation If the values above may be exceeded than: the quantitative study – where is possible - shall be carried out to prove optimal radiation protection (monetary alfa values are defined in Decree on Rad.Prot.), the risk origins from activities, practice shall be assessed; its comparison to possible alternative approaches shall be made.

Licensing and Occupational Exposure Control and Regulation Optimisation During the licensing process SUJB approves the document called “proof” of optimisation as well as the monitoring programme where one necessary part is describing the personal monitoring system on the workplace. Also the quality assurance programme has to be approved by SUJB.

Personal Dose Registration and Reporting The Central state Register of Occupational Exposure – CROE keeps the history of workers’ doses and their employments – operates by SUJB from 1997 The licensee shall keep the personal identification and personal doses (including the characterisation of the exposure) of category A workers to their 75 years at least 30 years after the work termination.

Personal Dose Registration and Reporting The licensee reports to SUJB, directly or via personal dosimetric service, the personal data on each category A worker, and the data characterising his/her exposure, to the extent and in the form stipulated by SUJB (registration cards), within 1 month from the start of employment or in case of any change of registered data.

Personal Dose Registration and Reporting The data on personal doses are reported within 2 months of the termination of monitoring period, and the annual overview of personal doses for the preceding year by the end of April of current year. The person who carries out the personal dosimetry must archive the data at least one year after the year to which the data are related.

Personal Dose Registration and Reporting

Personal Dose Registration and Reporting Outside workers Since 2003 CROE includes also separate registration of outside workers and their personal doses received during contracted activities performed in any controlled area. Outside workers are equipped from the beginning of the year 2004 with the personal radiation passport issued by SUJB.

Personal Dose Registration and Reporting The radiation passport consists of two parts, one part is permanent with the possibility of ten years dosimetric results registration and second part with detailed registration of annual doses will be changed every year. The collected parts will be archived in SUJB and will be used also for the control of doses of outside workers registered in CROE. Recently SUJB has issued 2 550 personal radiation passports.

Personal Dose Registration and Reporting Higher Dose Investigation Following the legislation, the licensee is obliged to report to SUJB immediately each personal dose exceeding 20mSv in given monitoring period or after the evaluation of annual dose. The same duty is also on the side of personal dosimetric services. Licensee is obliged to report also the results of investigation of such event and the measures implemented.

Inspection procedure and regulation General procedure Three types of inspections are organised by SUJB: regional inspections, which are planned and organised by Regional Centres, inspections carried out by specialised groups of inspectors in specific activities (nuclear medicine, radiotherapy, industrial radiography, nuclear facilities, selected radiodiagnostics departments);

Inspection procedure and regulation - associated inspections (ad hoc inspection group is compiled from inspectors of different Regional Centres) which are planned and evaluated at SUJB headquarters and are concerned on such important facilities as NPP, rad-waste storage, large research centres, etc. or in the case of unexpected event connected with higher exposure in any facility

Inspection procedure and regulation Internal SUJB regulation VDS 043 ” Planning, preparation, execution and evaluation of inspections in Radiation protection” unifies the practice of execution and evaluation of inspections within the whole office as much as possible. The rights and duties of inspectors are given by general Law on State control. The inspection can be announced before but not necessarily.

Inspection procedure and regulation The evaluation system of the inspections consists of four degrees based on the following criteria: Degree 1 - only small inconsistencies were detected that neither impede performance of permitted activities nor endanger safety. Degree 2 – more serious defects, however the inspected person can, under certain conditions, continue with radiation activities. Degree 3 - big inconsistencies impeding safe operation; some activity resulting in exposure must usually be limited or suspended until corrective measures are taken. Degree N - the planned inspections was not executed or was not evaluated

Inspection procedure and regulation Control of occupational exposure The control of occupational exposure is managed principally through the control of personal monitoring program – approved documentation during the licensing process - and control of results of personal monitoring.

Inspection procedure and regulation Control of occupational exposure The guideline for the licensees has been worked out with the detailed recommendations how to fulfill the general requirements of the legislation regarding the personal monitoring management.

Inspection procedure and regulation Control of occupational exposure This guideline contains the basic rules for personal dose measurement, evaluation, registration, optimization, requirements but also recommendations of categorization of workers, definition and determination of reference levels, description and use of methods of personal dosimetry used in the country specific requirements for the personal monitoring of workers in selected workplaces – medicine, industry, NPP, uranium mines,…

Inspection procedure and regulation Control of occupational exposure evaluation and registration of personal doses of outside workers the requirements for registration and reporting of personal doses to the CROE the procedure for the higher doses investigation the basic requirements for personal dosimetric services and the list of dosimetric services approved by SUJB

Inspection procedure and regulation Control of occupational exposure In 2002 a total of 1,428 inspections were carried out, of which 1,225 inspections were executed by Regional Centers of SUJB. Separately, 132 inspections were performed by the specialized inspection groups on the field of natural sources, nuclear power, nuclear medicine, unsealed sources and radiotherapy.

Inspection procedure and regulation Control of occupational exposure 86,6% of the total inspections were evaluated by the degree 1 or 2. Only few cases ended by penalty paid by licensee – mainly cases when source or workplace is operated without valid licence.

Inspection procedure and regulation Regulation of Occupational Exposure RADIATION PROTECTION SECTION The Department of Regulation of Exposure Occupational Medical Natural

Inspection procedure and regulation Responsibilities on the field of occupational exposure to license and control all dosimetric services operating in the country, to organize the national comparisons in personal dosimetry, to register and to investigate the cases of higher personal doses, to ensure methodically the approval of personal monitoring programmes, to issue personal radiation passports.

Inspection procedure and regulation Responsibilities to organise the seminars focused to the exposure regulation (e.g. for radiographers and radiologists) to secure the co-operation with the Ministry of Health in the case of significant overexposure (with the danger of deterministic effects) of workers or in the case of suspicion for such overexposure to co-ordinate the participation of SUJB in ISOE and in EAN and also in the model projects organised by the IAEA and relating to the occupational exposure control and optimisation.

Inspection procedure and regulation INSPECTIONS – control of occupational exposure the routine control of the personal monitoring the specialised inspections groups focused to certain workplaces and to specific requirements concerned to the personal monitoring ad hoc inspection team in the case of overexposure

Inspection procedure and regulation Frequent failures found during inspections in the system of personal monitoring could be divided into two groups - administrative or systematic.

Inspection procedure and regulation As administrative could be seen for example - not regular record keeping of personal doses, - not investigated doses exceeding investigation level - not updated reports on investigation of higher doses to SUJB, - the weak system of information of workers about their personal doses, - not summarised doses during the year

Inspection procedure and regulation As systematic could be mentioned - the failures in the work management (planning of activities in advance, information of workers on specific conditions on workplace, preparation of works), - insufficient use of protective tools, - incorrect use of personal dosemeters, - inadequate monitoring period, - improper categorisation of workers

CONCLUSIONS The role of the regulatory authority in the process of optimisation could be seen mainly in the methodological guidance and management of the control and regulation of personal doses. The general requirements are established in the legislation, the monetary value of averted dose serves as a specific tool for the quantification analyse (e.g. calculation of the thickness of shielding).

CONCLUSIONS SUJB issues the guidelines appointed to the licensees and serving for the creation of effective and practical monitoring programmes. SUJB also provides with the consultations on this field when necessary and acts also as an instructor and educator in selected areas. .

CONCLUSIONS Subsequently, operating the central register of occupational exposure SUJB monitors and regulate the trends of personal doses and their compliance with the limits and reference levels established. In the frame of the routine controls SUJB performs the control of the fulfilment of the monitoring programme and all relevant documentation and requires remedy of found inconsistencies.

CONCLUSIONS The recent problems identified in personal dose management Medicine – the lack of financial resources – decrease of category A workers and personal dosemeters used, the worse situation in education of workers and their informing, responsibilities not sufficiently defined, the lack of medical physicists,

CONCLUSIONS Industrial radiography – decrease of average individual doses but at the same time increase of so called non-personal doses – how to control ? – how statistics is valid – are the personal dosemeters really regularly used? - summarisation of doses when more employers (no outside workers)

CONCLUSIONS Services - if not licensed – who is responsible for radiation protection? (painting, cleaning, technical service – computers, elevators, etc..) NPP and Uranium industry - specific tasks and problems but very good and developed management of dose regulation NORM workplaces - inspection guidance in preparation

CONCLUSIONS ICRP 2005 (190) Optimisation is a frame of mind, always questioning whether the best has been done in the prevailing circumstances. It also requires the commitment from all levels of all concerned organisations as well as adequate procedures and resources. Both the operators and the appropriate national authority have responsibilities for optimisation. Operators design, propose and implement optimisation, and then use experience to further improve it. Authorities require and promote optimisation and may verify that it has been effectively implemented.

CONCLUSIONS ICRP 2005 (191) The exposures that result from the continuous optimisation process are the levels with which, at a point in time, all parties involved are in agreement as a way to move forward. The numerical results of optimisation of protection will demonstrate that the process has been complementary to the use of the constraints and its application has led to a higher level of protection.

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