Let me continue with practical radiation protection. This time the topic is a seemingly ordinary part of the job: personnel leaving the controlled access area (CAA) and radioactive contamination monitoring.

For someone who has worked at an NPP for many years, the route through the sanitary checkpoint seems self-evident: monitoring of work clothing, removal of PPE, a shower if needed, then skin monitoring and passage to the clean side. Disputes arise not over the monitoring itself but over the details. Where exactly should a person be stopped when a monitor alarms? Should the turnstile lock automatically? And what in this scheme is really required by a regulatory document, and what has been chosen by the design?

1. The first question is practical: what must be in place if contamination above the established level is detected on work clothing or skin?
2. The second is a design question: must the installation itself physically block the passage on a “Contaminated” signal, or is it sufficient that bypassing the monitoring is prevented by the layout, doors and administrative arrangements?

I separate these issues deliberately below. For operations, what matters is not an argument about the word “interlock” but a clear chain of actions: detect the contamination, prevent it from being carried further, provide for a change of clothing and decontamination, re-monitor the person, and keep the exit functional even in the event of equipment failure or evacuation.

How the exit from the CAA is organized

Russian rules build the sanitary access regime around the separation of flows. Under para. 7.1 of SP AS-03, NPP buildings and structures are divided into the CAA and the free access area, and entry into the CAA is arranged through a sanitary checkpoint. The point of this arrangement is not the turnstile or door as such, but ensuring that a person cannot accidentally carry radioactive contamination from the controlled area to the outside.

Para. 16.3 of SP AS-03 explicitly sets out the purpose of the sanitary checkpoint: complete change of clothing, sanitary treatment, radiation monitoring of the body and work clothing, and collection of contaminated work clothing and its dispatch for decontamination. The layout must ensure one-way flow and prevent “dirty” and “clean” flows from crossing.

At the level of personnel actions, the sequence is clearly set out in para. 4.7 of PRB AS-99 (Radiation Safety Rules for the Operation of Nuclear Power Plants):

1. place the personal dosimeter in the dosimeter rack cell;
2. on entering the “dirty” section, check the contamination of work clothing, work footwear and exposed parts of the body on the radiation monitoring installation. If the contamination exceeds the established level, contact the on-duty radiation safety personnel;
3. at the disciplinary barrier marked “Remove work footwear”, remove the work footwear;
4. undress in the “dirty” section, put the work clothing into a locker and go to the shower room;
5. in the shower room, carry out sanitary treatment if necessary: hands, head, body;
6. at the exit from the shower room, check body contamination on the radiation monitoring installation. If the permissible level is exceeded, contact the on-duty radiation safety personnel;
7. in the absence of a prohibiting signal, go to the “clean” section, change into personal clothing and leave.

SP AS-03 supports this with layout requirements. Hand and body contamination monitoring points after sanitary treatment are located between the drying room and the personal clothing wardrobe (para. 16.2), and the showers are located between the “dirty” and “clean” zones (para. 16.8).

Separate monitoring is also provided further along the route: personal clothing is monitored at the exit through access control points (SP AS-03, para. 6.6.4; PRB AS-99, para. 4.16).

Regulatory framework and status of documents

It is important not to mix up the legal force of documents here. Russian standards are binding within their national scope; for a project in Türkiye, their status depends on whether they are included in the licensing and design basis of the specific facility. The Turkish Regulation is a national requirement. IAEA documents serve as an international normative basis and reference: Safety Requirements use “shall” and Safety Guides use “should”, but IAEA standards do not automatically become legally binding on a State merely by virtue of their status. They become binding through national regulation, licence conditions, design commitments or other adopted mechanisms. Therefore, below I distinguish between a “national document requirement”, an “IAEA Safety Requirements requirement” and a “Safety Guide recommendation”.

Russia

NRB-99/2009 (SanPiN 2.6.1.2523-09) (Radiation Safety Standards). For this topic, the permissible contamination levels in Table 8.9 and the requirements for setting reference (control) levels in para. 7.4 are important.

OSPORB-99/2010 (SP 2.6.1.2612-10) (Basic Sanitary Rules for Radiation Safety). Three blocks are of practical use: sanitary checkpoints and sanitary locks, radiation monitoring, and requirements for PPE and personal hygiene of personnel.

SP AS-03 (SanPiN 2.6.1.24-03) (Sanitary Rules for the Design and Operation of Nuclear Power Plants) sets out the plant-level logic: radiation monitoring of contamination spread, the zone regime, “clean zones”, sanitary treatment and the arrangement of sanitary and amenity rooms.

PRB AS-99 (SP 2.6.1.28-2000) (Radiation Safety Rules for the Operation of Nuclear Power Plants) are particularly useful because they describe in detail the sanitary access regime and the sequence of personnel actions.

NP-001-15 (General Provisions for Ensuring the Safety of Nuclear Power Plants) is important as a general NPP safety document: it treats radiation monitoring systems as part of the safety-related systems and components, and the design must provide radiation monitoring for the plant’s intended operating modes.

Türkiye

In Türkiye, the basic document for this topic is the Nükleer Tesislerde Radyasyondan Korunma Yönetmeliği (Regulation on Radiation Protection in Nuclear Facilities, Resmî Gazete No. 30435 of 29.05.2018). For the issue at hand, the relevant provisions concern the duties of radiation protection personnel, rules for controlled areas, PPE, monitoring and record keeping.

IAEA

GSR Part 3: para. 3.90 sets out general requirements for controlled areas and the equipment of exits.

SSR-2/1 (Rev. 1): paras 6.82–6.83 contain requirements for fixed monitors at the main exits and for personnel monitoring equipment.

GSG-7: paras 7.244–7.250 deal with skin contamination, and paras 9.28–9.52 with contamination control and decontamination of personnel.

SSG-90 (2024): the most useful paragraphs for this topic are 3.48, 5.7–5.15 and 8.24–8.26. This is a new dedicated guide on radiation protection design for NPPs.

Permissible contamination levels (NRB-99/2009, Table 8.9)

The unit in the table is particles/(cm²·min). For skin, work clothing, work footwear and PPE, total contamination (removable and fixed) is regulated. For room surfaces, removable contamination is regulated (para. 8.8 and the note to Table 8.9).

Contaminated object	Alpha, specific*	Alpha, other	Beta
Intact skin, special underwear, towels, inner surface of PPE face pieces	2	2	200 (for ⁹⁰Sr + ⁹⁰Y — 40)
Main work clothing, inner surface of additional PPE, outer surface of work footwear	5	20	2000
Surfaces of rooms with permanent personnel occupancy and the equipment in them	5	20	2000
Surfaces of rooms with periodic personnel occupancy and the equipment in them	50	200	10 000
Outer surface of additional PPE removed in sanitary locks	50	200	10 000

* “Specific” alpha-emitting nuclides are those for which the annual average permissible volumetric activity in the air of work rooms (DOA) is < 0.3 Bq/m³.

For skin, these levels take into account possible intake of the radionuclide through the skin into the body; para. 8.8 separately specifies the assumption of a contaminated area of no more than 300 cm².

It is easy to make a methodological error here: the values in Table 8.9 are permissible levels, not ready-made monitor setpoints. The plant establishes its own reference levels for contamination of PPE and skin. It is exceeding the reference level that should trigger the established procedure and analysis of causes (NRB-99/2009, para. 7.4; OSPORB-99/2010, para. 3.13.9; SP AS-03, para. 15.10).

The IAEA approach is formulated differently. GSG-7 does not suggest simply translating the 500 mSv/year limit into an instrument setpoint. For routine monitoring, skin contamination is averaged over an area of about 100 cm² and the result is compared with a derived level, usually expressed in Bq/cm². Such a level is set taking into account the relevant dose limits and possible exposure pathways. If contamination persists or is high from the outset and an equivalent dose assessment is required, the dose is then averaged over an area of 1 cm² (GSG-7, paras 7.248–7.249).

What must be ready in case of contamination

A monitor alarm is not the end of the procedure but its beginning. By that moment the responsible person, the place for changing clothes, the decontamination procedure, re-monitoring and recording of the result must already be defined. Otherwise even a good monitor becomes merely a source of signals at the door.

1. Procedure and responsible person. Under PRB AS-99, personnel contact the on-duty radiation safety staff when the established level is exceeded. The Turkish Regulation assigns to radiation protection personnel the performance of decontamination and the establishment of investigation levels with actions in case they are exceeded (Art. 22(1)(ı), 22(1)(i)). GSG-7, para. 9.49, also recommends informing the radiation protection officer and assessing the significance of the contamination.
2. Removal of contaminated work clothing. If the established level is exceeded, the clothing and underwear must not continue in normal circulation: they are sent for decontamination or to a special laundry in accordance with the adopted scheme. The worker undergoes sanitary treatment if necessary (OSPORB, paras 3.14.9, 3.14.12; SP AS-03, para. 15.14).
3. Sorting and containers. Contaminated work clothing is sorted by material and contamination level, and appropriate containers are provided for collection, with separate containers for items subsequently managed as radioactive waste (SP AS-03, para. 16.13). PRB AS-99, para. 4.10, divides PPE into three groups:
   • group 1 — within permissible levels;
   • group 2 — exceeding them by no more than a factor of 10;
   • group 3 — exceeding them by more than a factor of 10.
4. Rooms. The “dirty” part of the sanitary checkpoint must be designed not only for the passage of people but also for actual handling of contaminated clothing: collection, temporary storage, sorting and monitoring. SP AS-03, para. 16.14, sets requirements for the rooms and equipment of the sorting area; OSPORB, para. 3.10.6, requires the contaminated clothing store to be located near the radiometric monitoring points and prohibits moving such clothing through clean rooms in open containers.
5. Stock of clean work clothing and detergents. It is needed not “just in case” but so that a contaminated person can change immediately without creating a new route through the CAA. PRB AS-99, para. 4.9, provides for an emergency stock of PPE and detergents; during outages and accidents it must remain possible to change work clothing more frequently.
6. Sanitary locks at work sites. The earlier contamination is stopped, the lower the load on the main sanitary checkpoint. Therefore, for work involving opening of equipment, temporary or permanent sanitary locks, change of work clothing and monitoring on leaving the work area are used (SP AS-03, paras 9.9, 16.19).
7. Skin decontamination. Proper conditions are required, not an improvised spot next to the turnstile: washbasins, showers, suitable detergents and an approved instruction. Decontamination agents must not increase the intake of radionuclides through the skin (OSPORB, para. 3.14.14; SP AS-03, para. 15.12).
8. Re-monitoring and medical assistance. After treatment, the person is monitored again. If local contamination persists, Russian rules provide for referral to the medical unit; GSG-7 specifically notes that invasive decontamination methods require medical assistance, and that for some contaminants, such as radioactive iodine, ordinary washing may be insufficient.
9. Dose assessment. The equivalent dose limit for the skin of workers is 500 mSv per year, averaged over the most highly exposed 1 cm² area. According to GSG-7, dose assessment becomes particularly important if the contamination persists or was high from the outset. If the assessed equivalent dose exceeds one tenth of the relevant limit, it should be entered in the individual record. The risk of internal intake of the radionuclide is assessed separately.
10. Investigation and records. An alarm is meaningful only if it allows the picture to be reconstructed: where the person worked, what was contaminated, which instrument detected it, what measures were taken and what the re-monitoring showed. Russian documents require analysis of exceedances and investigation of specified cases; the Turkish Regulation requires records of measurements, maintenance, calibration and repair of instruments.
11. Operability and redundancy. Monitoring must not disappear because of the failure of a single installation. PRB AS-99 requires showers and radiation monitoring installations to be in constant operation, and, in case individual instruments fail, back-up instruments and brief instructions at the monitoring points.

The Turkish Regulation formulates this quite clearly. Article 27(1)(f) requires that the means needed under the specific conditions be provided at the exits from controlled areas: monitoring of skin and clothing contamination, monitoring of items being taken out, showers and washbasins, storage for contaminated clothing and equipment, and, where necessary, means for their decontamination and other measures against the spread of contamination.

Is an automatic interlock on the monitor signal required?

What the documents explicitly say

Document, paragraph	Wording (essence)	Status
OSPORB-99/2010, para. 3.14.12	On leaving rooms where work with radioactive substances is carried out, the cleanliness of work clothing and PPE is checked; if the level is exceeded, the clothing is sent for decontamination and the worker undergoes sanitary treatment.	Mandatory requirement, Russia
OSPORB-99/2010, para. 3.10.2	Passage between zones bypassing the sanitary checkpoint is excluded; flows in personal and work clothing must not cross.	Mandatory requirement, Russia
SP AS-03, para. 16.3	Entry into and exit from the CAA bypassing the sanitary checkpoint must be excluded.	Mandatory requirement, Russia
SP AS-03, para. 6.6.4	Contamination of work clothing, footwear and skin is monitored with portable and fixed instruments in sanitary checkpoints and sanitary locks; personal clothing — at the exit through access control points.	Mandatory requirement, Russia
SP AS-03, para. 9.9	It is prohibited to leave a repair work area in work clothing contaminated above the established level of 2000 β-particles/(min·cm²).	Mandatory requirement, Russia, for the relevant work
PRB AS-99, para. 4.4	Passages between the “dirty” and “clean” sections are fitted with doors with locks or latches preventing uncontrolled exit.	Mandatory requirement, Russia; link to the monitor not specified
PRB AS-99, para. 4.7	Passage to the clean section is allowed in the absence of a prohibiting signal from the body monitoring installation.	Mandatory requirement, Russia; a signal is not the same as an automatic interlock
PRB AS-99, para. 4.8	It is prohibited to leave the CAA or to pass from the “dirty” part to the “clean” part bypassing the radiation monitoring installations.	Mandatory requirement, Russia
PRB AS-99, para. 4.9	Contamination monitoring installations and showers must be kept in constant readiness for operation.	Mandatory requirement, Russia
GSR Part 3, para. 3.90(e), (g)	For controlled areas, barriers are provided and, as necessary, equipment for monitoring contamination of skin, clothing and items taken out at the exit.	IAEA Safety Requirement (shall); not automatically a rule of national law
SSR-2/1 (Rev. 1), para. 6.82	Fixed monitors, such as portal monitors or hand and foot monitors, are provided at the main exits from controlled and supervised areas.	IAEA Safety Requirement (shall); applicability determined by the national/licensing basis
SSG-90, para. 5.8	Interlocking of exit doors with contamination monitors is recommended; it should be possible to override the interlock in case of evacuation.	IAEA Safety Guide recommendation (should)
GSG-7, para. 9.30	A person leaving a contaminated area should monitor surface contamination with a suitable portable or automatic instrument; if the background interferes, the monitoring point is relocated.	IAEA Safety Guide recommendation
Türkiye, 2018 Regulation, Art. 27(1)(b), (f)	The necessary means for monitoring skin and clothing contamination and items taken out, showers and decontamination means are provided at the exits; locking mechanisms are mentioned separately for restricting entry.	Mandatory requirement, Türkiye; a link between the exit door and the monitor is not explicitly stated

The short answer

If the mandatory nature of the monitoring itself is separated from the specific way it is implemented, the picture becomes fairly clear. Russian rules make the following mandatory:

• monitoring of work clothing, work footwear and exposed skin at the exit (OSPORB, para. 3.14.12; SP AS-03, paras 6.6.4, 16.2–16.4; PRB AS-99, para. 4.7);
• physical exclusion of bypassing the sanitary checkpoint (SP AS-03, para. 16.3; OSPORB, para. 3.10.2) and a prohibition on entering the “clean” section past the monitoring installations (PRB AS-99, para. 4.8);
• doors between sections preventing uncontrolled exit (PRB AS-99, para. 4.4).

In other words, the mandatory outcome is defined unambiguously: a person must not bypass the monitoring and must not carry contamination further along the route. If the established level is exceeded, the contaminated work clothing is sent for decontamination and the worker undergoes the prescribed sanitary treatment.

Specific automation, however, is not named in the Russian sanitary rules. I have not found a requirement that the monitor signal must directly lock a turnstile, an electromagnetic lock or an exit gate. The standards require monitoring, exclusion of bypass and controlled passage between zones; the technical implementation of this outcome is determined by the design and operating documentation.

The logic of the Turkish Regulation is similar. Article 27(1)(f) requires the necessary monitoring and decontamination means at the exit. Locking mechanisms are mentioned in Art. 27(1)(b) in the context of restricting entry into the controlled area. There is no direct requirement in this text to link the exit door to the monitor signal.

For the IAEA, two levels of documents must be distinguished. SSR-2/1 (Rev. 1), para. 6.82, requires fixed monitors to be provided at the main exits from controlled and supervised areas. SSG-90, para. 5.8, as a design guide, recommends interlocking exit doors with contamination monitors while providing for the interlock to be overridden in an evacuation. This is a strong international recommendation, but not a self-standing rule of national law.

It is therefore more accurate to say that monitoring and the exclusion of uncontrolled exit are mandatory. An automatic interlock of the passage based on the measurement result is a separate engineering decision. In Russia and Türkiye, its mandatory nature must follow from the specific design, licensing basis, technical specification or operating documentation, and not from a single general provision on contamination monitoring.

Where to place the interlock so that it helps rather than hinders

The most controversial option is to automatically deny a person entry to the “dirty” part of the sanitary checkpoint immediately after the work clothing monitor alarms. Such a scheme can only work if the design has provided in advance an alternative controlled location where the person can be safely received, changed and decontaminated if necessary. Without such a location, the result is a dead end.

The reason is simple: the sanitary checkpoint exists precisely to localize such cases. It has a place to remove work clothing, showers, decontamination means, re-monitoring and collection of contaminated clothing:

• it is intended for complete change of clothing, sanitary treatment of personnel, radiation monitoring of the body and work clothing, and collection and dispatch of contaminated work clothing for decontamination (SP AS-03, para. 16.3);
• it includes a radiometric monitoring point, showers and a store for dirty work clothing (OSPORB, para. 3.10.1). Rooms for collecting and sorting dirty work clothing and containers for it are located in the “dirty” zone of the sanitary checkpoint (SP AS-03, paras 16.13, 16.14);
• if contamination exceeds the level, the work clothing is sent for decontamination and the worker is required to wash in the shower (OSPORB, para. 3.14.12). The showers, in turn, are located between the “dirty” and “clean” zones of the sanitary checkpoint (SP AS-03, para. 16.8);
• PRB AS-99, para. 4.7, requires a person who exceeds the level on entering the “dirty” section to contact the on-duty radiation safety staff. The subsequent logic of the route is to remove the work clothing, undergo sanitary treatment if necessary and then body monitoring.

If the only entrance to the “dirty” part is simply locked and the design provides no alternative controlled route, a poor operational situation arises:

1. the person remains in the CAA in contaminated work clothing, waiting for a decision at the monitoring point;
2. changing and initial treatment have to be moved to a place that may lack a shower, ventilation, containers and proper monitoring;
3. the likelihood of secondary transfer of contamination to the floor, equipment and other people increases;
4. the barrier no longer localizes the contamination and in effect holds the person back in front of the very place where the means for removing it are provided.

For a typical sanitary checkpoint layout, it is more logical to tie the strict restriction of passage to the “dirty → clean” boundary, i.e. to the stage after removal of work clothing and skin monitoring. Here PRB AS-99 already requires doors preventing uncontrolled passage and allows passage in the absence of a prohibiting signal from the body monitoring installation. If the design uses a different scheme, it must ensure the same outcome: the contaminated person remains on a controlled route and immediately has access to a change of clothing, decontamination and re-monitoring.

What is a requirement and what is a design decision

Element	Requirement (where)	Good practice	Design decision (VVER-1200, etc.)
Monitoring of work clothing, footwear and skin at the exit	Yes: Russia — OSPORB 3.14.12, SP AS-03 6.6.4, PRB AS-99 4.7; Türkiye — Art. 27(1)(f); IAEA — GSR Part 3 3.90(g)	—	Type, number, algorithm and arrangement of installations
Fixed monitors at main exits	IAEA: SSR-2/1 (Rev. 1) 6.82; Russia: fixed instruments in sanitary checkpoints — SP AS-03 6.6.4	—	Portal, booth-type, hand and foot monitors, combination of types
Exclusion of bypassing the sanitary checkpoint	Yes: SP AS-03 16.3; OSPORB 3.10.2	—	Layout, doors, access control system
“Dirty → clean” doors with locks or latches	Yes: PRB AS-99 4.4	—	Lock type and its logic
Automatic interlock on monitor signal	No direct requirement in the Russian and Turkish standards reviewed	SSG-90 5.8	Yes, if provided for by the design, technical specification, licensing basis or operating documents
Interlock override in evacuation	In SSG-90 5.8 — a recommendation as part of the interlock scheme; mandatory details are determined by applicable fire codes and the design	Fail-safe approach	Emergency opening, fire system integration, failure monitoring
Temporary sanitary locks at repair sites	Russia: SP AS-03 9.9, 16.19	GSG-7 9.28	Mobile/temporary modules and their equipment
Stock of work clothing	Russia: PRB AS-99 4.9	—	Storage location and prompt issue
Back-up instruments	Russia: PRB AS-99 6.17	—	Number and redundancy scheme
Additional monitors during outages	—	SSG-90 3.48	Number, connection points, temporary flow scheme
Transmission of results to the upper level	General requirements for the radiation monitoring system do not by themselves specify a particular interface for each personnel monitor	Useful for investigations and trend analysis	Integration with ASRK (automated radiation monitoring system)/access control system, archive and personnel identification

Practical points that make all the difference in operation

Types of installations

Several classes of installations are used at exits from controlled areas. Each has its strengths and weaknesses, so choosing a monitor type without reference to the nuclide composition, background and personnel flow is pointless.

Hand and foot monitors with a remote probe. For example, the RZB-04m is designed to monitor beta contamination and to signal when set thresholds are exceeded. Hands and footwear are monitored by fixed detector units, other areas by a remote unit. This option is convenient for targeted monitoring but requires discipline in positioning the person.

Portal and booth-type monitors automatically check most of the body surface. Examples include the RZS-02A and the RZBA-09D.

• RZS-02A — a measuring booth with entry and exit gates. Monitoring covers the front and back surfaces of the body; the installation can identify the person, store results and transmit them to the upper level of the radiation monitoring system.
• RZBA-09D — a whole-body surface contamination monitor with alpha and beta channels and a gamma detection function. The manufacturer specifies automatic compensation of external gamma background, alarms and the ability to control passage when set levels are exceeded.

SSR-2/1 gives portal monitors and hand and foot monitors as examples of fixed equipment at the main exits. International standardization is also used for equipment of this class, in particular IEC 61098, which is referenced in GSG-7.

Portable radiometers are still needed: they are used to localize the contaminated area, carry out follow-up surveys and check the person after sanitary treatment.

Background

The background around a monitor is part of the measurement system. Beta detectors can respond to external gamma radiation; if this effect is not accounted for, the background starts to distort the result. GSG-7, para. 9.30, explicitly recommends relocating the monitoring point if local conditions do not allow reliable detection of surface contamination, and SSG-90, para. 8.26, recommends reducing background in monitoring rooms. The practical conclusion is simple: there should be no temporary storage of contaminated clothing, activated equipment or other sources that noticeably change the background next to the monitor.

False alarms and “misses”

Frequent false alarms quickly erode monitoring discipline: personnel begin to perceive the signal as a nuisance rather than as an event. Therefore what matters is not only the sensitivity of the installation but also a stable background, clean detectors and control of the person’s correct position. Typical causes of false alarms:

• changes in background when contaminated or activated equipment is carried past;
• contamination of the detectors themselves: the installation must be able to diagnose this;
• incorrect positioning of hands and feet.

There are limitations that cannot be “tuned out” by software. GSG-7, para. 9.31, notes that skin contamination by certain radionuclides, including tritium, cannot be reliably detected by ordinary hand-held or automatic monitors; in such cases greater weight is given to bioassay programmes, air monitoring and general contamination control. For alpha measurements, rough and uneven surfaces and self-absorption in the contamination layer are problematic (GSG-7, para. 9.36).

Monitor setpoints must be linked to the reference levels adopted at the plant and to the actual sensitivity of the measuring channel. Converting readings to surface contamination requires calibration for the radionuclides and measurement geometry actually encountered at the facility (GSG-7, paras 9.37–9.41).

Throughput at shift change

If an automatic interlock is introduced, throughput is no longer a secondary issue. Peak flow occurs at shift change and especially during outages, when the number of contractors rises sharply. SSG-90, para. 5.13, recommends providing a sufficient number of exit monitors and space that prevents cross-contamination in the queue; para. 3.48 separately suggests considering additional monitors for outage periods.

It is reasonable to determine the number of installations by calculation: the maximum flow of people in a short interval after the shift, the actual duration of one measurement cycle, the proportion of repeat measurements and a margin for failures. PRB AS-99, para. 6.17, separately requires back-up instruments in case skin and work clothing contamination monitoring equipment fails. The standards give no universal number of monitors for any plant.

What to do after a “Contaminated” signal

The procedure must be written before the first real alarm. Then the person does not argue with the turnstile, and the radiation safety staff do not have to decide on the spot where to take them. A workable sequence looks like this:

1. a repeat measurement to rule out a false alarm due to positioning;
2. calling the on-duty dosimetrist (PRB AS-99, para. 4.7) using a button or telephone next to the installation;
3. localization of the contamination with a portable instrument, removal of the contaminated work clothing and issue of a replacement set on the spot, in the “dirty” section;
4. sanitary treatment of the skin according to the instruction (SP AS-03, para. 15.12), re-monitoring, and, if unsuccessful, referral to the medical unit (para. 15.13);
5. recording the result: who was monitored, where they worked, what was found to be contaminated, which instrument confirmed it and what measures were taken. These data are needed both for the investigation and, if necessary, for dose assessment;
6. lifting the passage restriction after a confirmed clean result or by a decision of the responsible personnel as provided for in the procedure, with mandatory recording of that decision.

An interlock must not become a locking device without a safe failure mode. SSG-90, para. 5.8, recommends the ability to disable the interlock in an evacuation. The specific emergency opening scheme, its link to fire automation and fail-safe requirements must be determined by applicable fire safety codes and the design.

How to prevent bypassing the monitoring

A reliable scheme starts not with the turnstile but with the layout:

• one-way flow without crossing flows (SP AS-03, para. 16.3);
• no open passages between sections (PRB AS-99, para. 4.4);
• a minimum number of entrances to and exits from the controlled area (SSG-90, para. 5.7);
• a physical barrier between the clean and potentially contaminated parts (SSG-90, para. 5.13);
• “Remove work footwear” disciplinary barriers (PRB AS-99, para. 4.7).

A technical interlock is useful as an additional line of defence, but by itself it does not solve the problem. If there is an uncontrolled door nearby, if it is possible to follow another person through, or if a faulty sensor is simply switched off, a formally strict system quickly turns into window dressing. Therefore, the following are particularly useful in operation:

• monitoring of emergency doors with alarms in the radiation safety service;
• an installation event log transmitted to the ASRK;
• analysis of “passed without measurement” cases using access control system data;
• review of each case to find the cause and corrective actions, not just the name of the violator.

Clean and potentially contaminated zones

The monitoring boundary does not begin at the main sanitary checkpoint. It must be formed already at the workplace: fencing off the work area, a temporary sanitary lock, a change of work footwear or clothing, monitoring when leaving a local contaminated zone. The less contamination reaches the main exit from the CAA, the more robust the whole system and the less temptation there is to bypass the monitor because of queues and repeated alarms.

What most often goes wrong

1. Monitor setpoints are mechanically set equal to the NRB permissible levels, without linking them to the plant’s reference levels and the actual calibration of the instrument.
2. The monitor is placed where the background changes noticeably due to equipment, transport of radioactive materials or temporary storage of contaminated clothing.
3. The number of installations is calculated for a normal shift, but the outage mode and mass exit of contractors are not checked.
4. The interlock has no safe failure mode, no emergency opening and no clear fault signalling.
5. The “dirty” part has no accessible stock of clean work clothing and no place where a person can calmly change after confirmed contamination.
6. There is no short and clear alarm procedure. As a result, radiation safety staff learn about the problem only when a queue has formed at the installation.
7. Events are not recorded or analysed, so the same source of contamination at the workplace continues to cause repeated alarms.
8. The automatic interlock is mistaken for the entire monitoring system, although without proper flow, physical separation of zones and measurement discipline a single turnstile guarantees nothing.

Conclusion

Contamination monitoring at the exit from the CAA is not a matter of choice. Russian rules require monitoring of work clothing, work footwear and skin, exclusion of bypassing the sanitary checkpoint and prevention of uncontrolled passage from the “dirty” part to the “clean” part. The Turkish Regulation likewise requires the necessary contamination monitoring and decontamination means at exits from controlled areas.

The dispute begins elsewhere: whether the automation itself must lock the passage based on the measurement result. In the Russian and Turkish standards I reviewed, I found no direct requirement for such a “monitor → lock” link. At the same time, SSG-90, para. 5.8, explicitly recommends interlocking the exit door with the contamination monitor, and SSR-2/1, para. 6.82, requires fixed monitors at the main exits. For a specific plant, therefore, whether an automatic interlock is mandatory must be checked not only against general standards but also against the licensing basis, design documentation, technical specification and approved operating procedures.

Another important point is where the interlock is placed. If a person is stopped before entering the “dirty” part of the sanitary checkpoint, the design must give them another controlled route to change and decontaminate. Without such a route, the interlock creates a dead end and may increase the risk of secondary transfer of contamination. In a typical layout, it is more logical to keep the person within the sanitary access route and not let them into the clean part until a satisfactory monitoring result is obtained.

So I would not formulate the conclusion as “forced monitoring is not mandatory”. The monitoring itself and the exclusion of its bypass are mandatory. What is not always directly mandatory is an automatic interlock triggered by the instrument signal. This is a more accurate distinction, from both the regulatory and the operational point of view.

A well-designed interlock strengthens the system. A poorly designed one creates queues, false alarms and the urge to find a way around it. Ultimately, what is judged is not the presence of a turnstile but whether the main task is accomplished: contamination does not leave the established boundaries, and a person who triggers an alarm quickly gets to where they can be safely changed, treated and re-monitored.

It is this outcome that should be the starting point for design decisions.

Sources

1. NRB-99/2009 (SanPiN 2.6.1.2523-09) (in Russian). GARANT: https://base.garant.ru/4188851/
2. OSPORB-99/2010 (SP 2.6.1.2612-10) (in Russian). GARANT: https://base.garant.ru/12177986/
3. SanPiN 2.6.1.24-03 (SP AS-03) “Sanitary Rules for the Design and Operation of Nuclear Power Plants” (in Russian). GARANT: https://base.garant.ru/12130991/
4. SP 2.6.1.28-2000 (PRB AS-99) “Radiation Safety Rules for the Operation of Nuclear Power Plants” (in Russian). GARANT: https://base.garant.ru/71618122/
5. NP-001-15 “General Provisions for Ensuring the Safety of Nuclear Power Plants” (in Russian). SEC NRS: https://docs.secnrs.ru/documents/nps/%D0%9D%D0%9F-001-15/%D0%9D%D0%9F-001-15.html
6. Type description of the measuring instrument “RZB-04m personnel radioactive contamination monitors”, State Register No. 54359-13 (in Russian): https://grmetr.ru/gosreestr/366803-54359-13-rzb-04m
7. Type description of the measuring instrument “RZS-02A NPP personnel radioactive contamination monitors”, State Register No. 49307-12 (in Russian): https://all-pribors.ru/opisanie/49307-12-rzs-02a
8. RZBA-09D personnel surface contamination monitor (State Register No. 83216-21), manufacturer’s page (in Russian): https://www.doza.ru/catalog/contamination_monitors/ustanovki-kontrolya-zagryaznennosti-vsego-tela/RZBA-09/
9. Nükleer Tesislerde Radyasyondan Korunma Yönetmeliği (Resmî Gazete No. 30435, 29.05.2018) (in Turkish): https://www.resmigazete.gov.tr/eskiler/2018/05/20180529-17.htm
10. NDK, Akkuyu NPP page: https://www.ndk.gov.tr/akkuyu-nukleer-santrali
11. IAEA GSR Part 3. Radiation Protection and Safety of Radiation Sources: International Basic Safety Standards (2014): https://www-pub.iaea.org/MTCD/Publications/PDF/Pub1578_web-57265295.pdf
12. IAEA SSR-2/1 (Rev. 1). Safety of Nuclear Power Plants: Design (2016): https://www-pub.iaea.org/MTCD/Publications/PDF/Pub1715web-46541668.pdf
13. IAEA GSG-7. Occupational Radiation Protection (2018): https://www-pub.iaea.org/MTCD/Publications/PDF/PUB1785_web.pdf
14. IAEA SSG-90. Radiation Protection Aspects of Design for Nuclear Power Plants (2024): https://www-pub.iaea.org/MTCD/Publications/PDF/p15554-PUB2078_web.pdf
15. IAEA. Status of IAEA Safety Standards: the standards are not automatically legally binding on Member States and may be adopted through national regulation: https://www.iaea.org/topics/iaea-safety-standards-on-emergency-preparedness-and-response

I will continue looking at radiation safety not as it appears in textbooks, but as it looks in real work. This time the subject is the radiation protection programme. It seems a straightforward document — until you start agreeing it with designers, operations staff and the regulator.

At a Russian facility, the term “radiation protection programme” itself is not the centre of the whole documentation system. There is a radiation monitoring programme, instructions, regulations, orders, emergency documents and industrial control. In Türkiye the approach is different: for a nuclear facility, the Radiation Protection Programme is explicitly required by a regulatory document and has a mandatory minimum content. On the Akkuyu project, this difference quickly stops being a matter of terminology — the structure of the entire set of documents depends on it.

So my aim here is not simply to list the standards. The key question is practical: what should remain in the programme itself, what should be moved to procedures and instructions, how detailed the description of responsibilities should be, and how to make the document something that can actually be used rather than just shown during an inspection.

First things first: a programme is not a big instruction

For the IAEA, a Radiation Protection Programme is not “a volume containing all the radiation safety rules”. The purpose of the programme is different: management must show how the protection of workers is organized, who is responsible for what, which measures are applied, how their effectiveness is monitored and how the system is reviewed. GSG-7 explicitly links the programme to management structures, policies, procedures and organizational arrangements commensurate with the radiation risk.

An important conclusion follows. The programme can be issued as a single controlled document with a system of references, while the practical implementation is set out in procedures, regulations and instructions. There is usually no need to put measurement methods, logbook forms, step-by-step donning of PPE or the way each work permit is filled in into the main text. That belongs to the lower level of documents.

The opposite extreme does not work either. The phrase “radiation monitoring is carried out in accordance with the applicable documents” explains nothing. The programme should make at least four things visible: what is done, who is responsible, against what criterion it is done, and where the working procedure is described.

Where a programme should start

Before the structure and a neat table of contents, there is a step that is often underestimated: the prior radiological evaluation. GSG-7 treats it as the first stage in defining the programme. It is necessary to understand the sources of normal and potential exposure, possible doses, contamination, failure scenarios, and the need for monitoring and protective measures. The depth of this evaluation should depend on the risk: it will obviously differ between a simple installation and an NPP unit.

This is also where the correct hierarchy of protective measures is set. Engineered solutions first, then administrative measures, and only after that PPE. This is not a matter of document formatting. If a programme starts straight away with dosimeters, respirators and briefings but does not show how the risk has been reduced by design and work organization, the logic of radiation protection has already been turned upside down.

Another fundamental point is optimization. GSG-7 specifically emphasizes that at most facilities doses are well below the limits, so the programme should be built not around the idea of “not exceeding 20 mSv” but around continuously reducing exposure as far as reasonably achievable. The dose limit is the boundary of what is acceptable. The target for normal operation lies below it.

Russia, Türkiye and the IAEA: a similar goal, different documentation

IAEA

In GSR Part 3, Requirement 24 establishes the need for organizational, procedural and technical arrangements within the radiation protection programme for occupational exposure — for controlled and supervised areas, local rules and workplace monitoring. These are Safety Requirements.

GSG-7 goes further and sets out the recommended content of the programme. It is important not to confuse the status of the documents here: GSR Part 3 contains IAEA requirements, whereas GSG-7 is a Safety Guide, i.e. guidance and international good practice. For a specific plant, what remains legally binding is what has been introduced by national legislation, the licence and the applicable regulatory requirements.

Paragraph 3.60 of GSG-7 lists 14 elements: responsibilities, qualified experts, links with other areas of safety, inventory of sources, area designation, local rules, PPE, monitoring of workers and the workplace, records and reporting, training, periodic review of the programme, emergency preparedness, health surveillance, and quality assurance with process improvement.

Türkiye

For nuclear facilities, the picture is much stricter and clearer. The 2018 Nükleer Tesislerde Radyasyondan Korunma Yönetmeliği (Regulation on Radiation Protection in Nuclear Facilities) explicitly requires the operating organization to prepare a radiation protection programme and to start applying it when the facility is put into operation. Article 12 separately obliges the organization to prepare and implement the programme, to periodically assess its effectiveness and to take operating experience into account.

Article 19 sets the minimum content. The programme must cover the radiation protection organization, outside workers, classification of areas and personnel, radiation work permits, PPE, health surveillance, area and individual monitoring, control of releases, calibration and maintenance, training, and interfaces with other plans and programmes. Moreover, the Regulation refers not only to topics but also to the procedures associated with them.

Article 40 separately requires the links with the environmental monitoring programme, the emergency plan, the radioactive waste management plan and other applicable documents to be shown. In other words, in the Turkish system the RPP really is a top-level document that must bring the system together into a single whole.

Russia

For the Russian system, I would not write that “there is no equivalent of an RPP at all”. It is more accurate to put it differently: the basic sanitary standards do not gather all the elements of occupational radiation protection into a single mandatory document called a “radiation protection programme”. These requirements are distributed among several documents.

OSPORB-99/2010 (Basic Sanitary Rules for Radiation Safety) requires a radiation monitoring programme that takes into account the specifics of the work. The monitoring system must define the types of monitoring, instruments, measurement points and frequency. Radiation safety instructions, organizational documents, reference (control) levels, individual dose monitoring and emergency measures are required separately. For NPPs, the requirements of SP AS-03 and the operating documentation are added.

The quality assurance programme (QAP) under NP-090-11 also needs to be placed here with care. A QAP is important for management, documentation, responsibilities, audits and improvement, but it is not the Russian equivalent of a radiation protection programme. It is a different document with a different purpose. It supports the system but does not replace the radiation protection programme in terms of content.

Therefore, on an international project it is quite reasonable to have a single framework RPP structured according to the licensing country and the IAEA, and to use Russian programmes, regulations and instructions as lower-level documents. In my view, this is far more honest than trying to declare one of the Russian programmes a full equivalent of something it essentially is not.

Comparison of approaches

Question	Russia	Türkiye (NDK)	IAEA
Is there a single document called an RPP?	Not in the basic sanitary standards; the functions are distributed among several documents	Yes. The programme is explicitly required by the 2018 Regulation	Yes, a radiation protection programme is required by GSR Part 3; its content is set out in GSG-7
What defines the content	OSPORB, SP AS-03, radiation monitoring programmes, instructions, organizational and emergency documents	Art. 19 — minimum content; Art. 40 — interfaces with other programmes	GSR Part 3 — requirements; GSG-7 — recommended content and practice
Level of detail	Depends on the specific document and the risk	Commensurate with the potential risk	Appropriate level of detail, graded approach
Contractors	Duties are allocated through organizational documents, work authorizations and instructions	Responsibilities of outside workers are a separate element of the RPP	The division of responsibilities between employer and licensee must be defined
Revision	According to the requirements of the management system and specific documents; when conditions and standards change	Operating experience, changes to the facility and legislation, periodic safety review	Periodic review/audit and improvement of the programme
Procedures	Usually separate lower-level documents	The Regulation explicitly links RPP elements to the corresponding procedures	GSG-7 assumes a system of local rules, procedures and controlled documentation

Dose limits: an important difference, but not the programme itself

Comparing dose limits is useful because it clearly shows that the same radiation protection architecture does not yet mean the same numerical requirements. For a project that uses Russian design solutions but is licensed in Türkiye, this has practical significance.

Parameter	Russia	Türkiye	IAEA
Effective dose, workers	20 mSv/year averaged over 5 consecutive years; no more than 50 mSv in any single year	20 mSv/year; up to 50 mSv in a single year is allowed provided the 5-year average does not exceed 20 mSv	20 mSv/year averaged over 5 years; no more than 50 mSv in any single year
Lens of the eye, workers	150 mSv/year under NRB-99/2009	20 mSv/year averaged over 5 years; no more than 50 mSv in any single year	20 mSv/year averaged over 5 years; no more than 50 mSv in any single year
Skin, hands and feet, workers	500 mSv/year	500 mSv/year	500 mSv/year
Effective dose, public	1 mSv/year averaged over 5 years; no more than 5 mSv in any single year	1 mSv/year; a higher value is possible with NDK approval provided the 5-year average is 1 mSv	1 mSv/year; higher in special circumstances provided the 5-year average is 1 mSv

The most notable discrepancy is the lens of the eye. Türkiye uses the modern limit of 20 mSv averaged over five years, while the Russian NRB-99/2009 (Radiation Safety Standards) retain 150 mSv/year. But it does not follow that every worker automatically needs a separate Hp(3) dosimeter. The need for and scope of monitoring should follow from an assessment of exposure conditions and the likely lens dose. And that is exactly what the programme should explain.

What I would definitely keep in a working programme

If you set aside the formal list of clauses and look at the programme as a system, I would build it around the following questions.

• Who is responsible for radiation protection. Not just the organizational chart of the unit, but also authority, boundaries of responsibility, deputizing arrangements, and interaction with management and contractors.
• On the basis of which radiological evaluation the areas, types of monitoring, dosimetry, PPE and restrictions were chosen.
• How areas and personnel are classified, and who reviews the classification and when.
• How radiologically hazardous work is organized: work permits, dose restrictions, ALARA planning, supervision, stopping work in the event of deviations.
• Which engineered protective features are used and in which cases administrative measures or PPE supplement them.
• How workplace and individual monitoring is organized: external and internal exposure, contamination, and, where necessary, the lens of the eye and extremities.
• How releases are controlled and how the RPP is linked to environmental radiation monitoring.
• How instruments are managed: selection, verification/calibration, functional checks, maintenance, back-up.
• How training, authorization and maintenance of qualification are organized.
• What records are kept, who checks them, and how the results of individual dose monitoring and investigations are stored.
• How the RPP is linked to the emergency plan and the radioactive waste management system.
• How the effectiveness of the programme is assessed: dose indicators, contamination, exceedances of investigation levels, events, nonconformities, audit results and corrective actions.

Responsible persons: positions or names?

In practice, this is one of the most awkward questions. If all the names are written into the main text, the programme starts to become outdated after every staff change. If only the phrase “responsible persons are appointed by order” is left, it is difficult for the regulator to check who exactly is responsible today.

Article 20 of the Turkish Regulation requires the programme to define the authority, responsibilities and allocation of duties of radiation protection personnel. GSG-7, referring to GSR Part 3, specifically states that the organization should document the names and responsibilities of the designated persons. This does not mean, however, that every name must be placed in the main text of the RPP.

The workable option that I consider most robust is to state positions, functions and reporting lines in the main section, and to keep the current names in a controlled appendix or in a separate order/list to which there is a precise reference. If the regulator requires names to be visible directly in the RPP, that appendix becomes part of the programme and is updated through a simplified procedure, without rewriting the whole main body.

Programme and instruction are different levels

Criterion	Radiation protection programme	Instruction / procedure
Purpose	Show how the radiation protection system is organized as a whole	Establish a specific procedure for performing work or for personnel actions
Key question	What we do, who is responsible, against which criteria, and where the procedure is described	How exactly to perform the operation safely
Audience	Management, the radiation safety service, process owners, the regulator, auditors	Workers, work supervisors, dosimetrists
Level of detail	Systemic and sufficient for traceability of requirements	Step-by-step, with conditions, prohibitions, setpoints and actions in case of deviation
Changes	When the system, responsibilities, risks, requirements or links between documents change	When technology, equipment, the working procedure or the requirements for the operation change
Link between documents	Refers to procedures and establishes their place in the system	Implements a specific requirement of the programme

Confusion begins when people try to make the programme “self-sufficient”. The result is a document hundreds of pages long in which the same requirements are repeated in several places. After the first major upgrade, it almost inevitably begins to diverge from the working procedures.

How detailed to be

I would not tie a good programme to a page count at all. A statement such as “a proper RPP should be 30–60 pages” has no regulatory basis. For one facility that will be too much, for another too little. Both the Turkish Regulation and GSG-7 proceed from the same principle: the level of detail should correspond to the potential risk and the complexity of the activity.

For each element of the programme there should be enough information to follow the chain from the requirement to actual implementation during an inspection. For example: who performs individual dose monitoring, for which groups of workers, by what criterion the type of monitoring is assigned, where the frequency is established, in which document the method is described, where the results are stored and who reviews deviations. The measurement method itself does not need to be rewritten into the programme.

Cross-references: a detail on which a document often falls apart

A reference “in accordance with the applicable procedures” looks convenient only until the first inspection. It does not show which document implements the requirement and which revision is considered current. As a result, the programme formally refers to the system, but the system cannot be traced.

For key requirements, I would give a reference to at least the title of the document, its identifier and the specific section or clause where the procedure is set out. For frequently changing documents, a controlled register of references can be used, but it must be part of the document management system. This makes it easier to survive the reissue of procedures without an avalanche of uncoordinated changes.

It is especially important to avoid circular references: the RPP sends you to a procedure, the procedure sends you back to the RPP, and who must do what is not written anywhere. Every requirement must have an owner document.

How the programme should be reviewed

A formal review “every few years” guarantees nothing by itself. For an RPP, triggers are more important: a change to the facility or technology, a new work organization, a change in the structure of responsibilities, new regulatory requirements, results of dosimetry and monitoring, an event or contamination, audit results, outage experience, a change in the contracting model.

The Turkish Regulation explicitly links updating the RPP to operating experience, changes to the facility and in national legislation, and periodic safety review. GSG-7 calls for methods for periodic review and audit of the programme’s effectiveness. In the Russian system, similar logic is distributed across the requirements for specific documents and the management system. It is therefore better not to transfer the review frequency of one programme — for example, the QAP — to the RPP as a universal rule.

Typical mistakes I would remove before submission to the regulator

• The programme restates the standards but says little about how they are implemented at this particular facility.
• There is an organizational chart, but no authority or boundaries of responsibility between operations, the radiation safety service and contractors.
• Responsible persons are mentioned in the abstract, and the current list of individuals cannot be shown quickly.
• Area designation, classification of personnel and types of dosimetry are not linked to the initial radiological evaluation.
• ALARA is reduced to the phrase “doses do not exceed the limits”. That is compliance checking, not optimization.
• The programme duplicates instructions and quickly diverges from them after changes.
• References point to documents without a section/clause number or to revisions that have already been withdrawn.
• The link with environmental monitoring, the emergency plan and radioactive waste management exists in practice but is not shown in the RPP itself.
• There are no measurable effectiveness criteria: the programme exists, but it is impossible to prove whether radiation protection has become better or worse.
• Differences between Russian and Turkish requirements are simply “closed by taking the stricter value” without analysing the scope and basis of the requirement.

A working RPP structure for an NPP

What follows is not the “only correct” table of contents, but a structure that I find convenient specifically for an NPP in Türkiye: it covers Art. 19 of the Turkish Regulation, maps well onto GSG-7 and allows Russian lower-level documents to be linked in.

1. General provisions: purpose, scope, life-cycle stages, terms, regulatory basis.
2. Radiation protection policy and principles: justification, optimization, dose constraints and investigation levels.
3. Radiation protection organization: structure, authority, responsibilities, deputizing, interaction between departments and contractors.
4. Radiological evaluation and graded approach: main sources of risk and the logic for selecting protective measures.
5. Classification of radiation areas and workers, criteria and revision procedure.
6. Organization of radiologically hazardous work: permits, dose restrictions, ALARA, supervision and stopping work.
7. Engineered protective features and PPE, including selection criteria and condition monitoring.
8. Radiation monitoring of workplaces and contamination.
9. Individual monitoring: external and internal exposure, skin/extremities and lens of the eye — based on the results of the evaluation.
10. Control of radioactive releases and the link with the environmental monitoring programme.
11. Measuring instruments: calibration, verification, checks, maintenance and back-up.
12. Health surveillance.
13. Training, information and authorization of personnel.
14. Records and reporting, including individual doses and investigations.
15. Emergency preparedness and the link with the on-site emergency plan.
16. Interfaces with the radioactive waste management plan and other safety programmes.
17. Effectiveness assessment, internal audits, operating experience, corrective actions and improvement.
18. Appendices: compliance matrix, register of referenced documents, list of responsible persons — if this is the practice in the document management system.

A few observations from practice

When you build up radiation monitoring at a large facility, the instruments and methods are far from the hardest part. It is much more difficult to make sure that documents do not contradict each other and that everyone understands the boundary of their own responsibility. A dosimetrist must know when they are obliged to stop work. A shift supervisor — when they cannot continue it without a radiation protection decision. A contractor — which rules apply to them and who is responsible for their dose and authorization.

The Russian system is strong in its detailed sanitary requirements and working instructions. The Turkish model forces you to assemble them into a single structure and show the links. I see this as its main advantage. But simply writing yet another top-level document is not enough. If the RPP lives separately from work permits, dosimetry, training, emergency procedures and the real authority of the radiation safety service, it will remain a nice-looking folder.

So I formulate the criterion for myself simply: after reading the programme it should be clear not only what the organization promises to do, but also where exactly this is actually done, by whom, under what rules and how the result is verified.

Conclusion

A radiation protection programme is neither a substitute for instructions nor a collection of excerpts from standards. It is a map of the system. It links risk, responsibility, work organization, monitoring, training, emergency preparedness, records and improvement into a single manageable structure.

In Türkiye such a programme is explicitly mandatory, and its minimum content is set by the 2018 Regulation. In the IAEA standards, the programme is part of the occupational radiation protection system, with GSG-7 providing recommendations on its content. In Russia the same functions are largely distributed among several mandatory documents, so on an international project it is especially important not to mix different levels and not to present a radiation monitoring programme or a QAP as a full equivalent of an RPP.

A good RPP does not have to be the biggest document. It should be the clearest entry point into the radiation protection system: who is responsible, why exactly these measures were adopted, where the working procedure is established and how we make sure that it really works.

Sources

The regulatory references and wording in this version have been checked against the published texts of the documents. For use in official documentation, the facility’s list of regulatory documents and the status of a specific revision must still be verified against the current regulatory document management system.

1. Federal Law No. 3-FZ of 09.01.1996 “On Radiation Safety of the Population” (in Russian). https://www.consultant.ru/document/cons_doc_LAW_8797/
2. NRB-99/2009 (SanPiN 2.6.1.2523-09) “Radiation Safety Standards” (in Russian). https://base.garant.ru/4188851/
3. OSPORB-99/2010 (SP 2.6.1.2612-10) “Basic Sanitary Rules for Radiation Safety” (in Russian). https://base.garant.ru/12177986/
4. SanPiN 2.6.1.24-03 “Sanitary Rules for the Design and Operation of Nuclear Power Plants (SP AS-03)” (in Russian). https://base.garant.ru/12130991/
5. NP-090-11 “Requirements for Quality Assurance Programmes for Nuclear Facilities” (in Russian). https://www.consultant.ru/document/cons_doc_LAW_127397/
6. Nükleer Düzenleme Kanunu No. 7381 (Law on Nuclear Regulation) (in Turkish). https://www.mevzuat.gov.tr/MevzuatMetin/1.5.7381.pdf
7. Nükleer Tesislerde Radyasyondan Korunma Yönetmeliği (Regulation on Radiation Protection in Nuclear Facilities), Resmî Gazete No. 30435, 29.05.2018 (in Turkish). https://www.resmigazete.gov.tr/eskiler/2018/05/20180529-17.htm
8. IAEA GSR Part 3. Radiation Protection and Safety of Radiation Sources: International Basic Safety Standards. https://www-pub.iaea.org/MTCD/Publications/PDF/Pub1578_web-57265295.pdf
9. IAEA GSG-7. Occupational Radiation Protection. https://www-pub.iaea.org/MTCD/Publications/PDF/PUB1785_web.pdf
10. IAEA GSR Part 2. Leadership and Management for Safety. https://www-pub.iaea.org/MTCD/Publications/PDF/Pub1750web.pdf
11. ICRP Publication 103. The 2007 Recommendations of the ICRP. https://www.icrp.org/publication.asp?id=ICRP%20Publication%20103