ML060230011

Draft COL Application Regulatory Guide, Part 1, Chapter 12, Radiation Protection

ML060230011
Person / Time
Issue date:	03/13/2006
From:	NRC/NRR/ADRA/DNRL/NRBA
To:
Klump, M K, NRR/ADRA/DNRL/NRBA, 415-1446
References
DG-1145, TAC MC8945
Download: ML060230011 (15)

Text

DG-1145, Section C.I.12 - Radiation Protection C.I.12. Radiation Protection Chapter 12 of the safety analysis report (SAR) should provide information on radiation protection methods and estimated occupational radiation exposures of operating and construction personnel during norm al operation and anticipated operational occurren ces. (In particular, anticipated operational occurrences may include refueling; purging; fuel handling and storage; radioactive material handling, processing, use, storage, and disposal; maintenance; routine operational surveillance; inservice inspection; and calibration.) Specifically, this chapter should provide information on facility and equipment design, planning and procedures programs, and techniques and practices employed by the applicant to meet the radiation protection standards set forth in 10 CFR Part 20, and to be consistent with the guidance given in the appropriate regulatory guides, where the practices set forth in such guides are used to implement NRC regulations. As warranted, this chapter should specifically reference needed information that appears in other chapters of the SAR.

The information that generic design control documents (DCDs) typically present in Chapter 12, Radiation P rotection, includes a discussion of h ow radiation practices will be incorporated into plant policy and design decisions; a general description of the radiation source terms; radiation protection design features, including a description of plant shielding, ventilation systems, and area radiation and airborne radioactivity monitoring instrumentation; a dose assessment for operating and construction personnel; and a discussion of the design of the health physics facilities. The COL application may incorporate this information by reference.

C.I.1 2.1 En suring tha t Occup atio nal Ra diation Ex po sures Are As L ow As Is Re ason ably Achievable (ALARA)

C.I.12.1.1 Policy Considerations Describe the management policy and organizational structure related to ensuring that occupational radiation exposures are ALARA. Describe the applicable responsibilities and related activities to be performed by management personnel who have responsibility for radiation protection and the policy of maintaining occupational exposures ALARA.

Describe the ALARA policy with respect to designing and constructing the plant, as well as the ALARA policy as it will be applied to plant operations. Indicate whether and, if so, how the plant will follow the ALARA policy guidance given in Regulatory Guides 1.8 and 8.10, as well as Section C.1 of Regulatory Guide 8.8.1 Conversely, if the plant will not follow that ALARA policy guidance, describe the specific alternative approaches to be used. In addition, indicate how the plant will meet the requirements of 10 CFR Part 20.

Describe the implementation of policy, organization, training, and design review guidance provided in Regulatory Guides 1.8, 8.8, and 8.10, as well as any proposed alternatives to the guidance provided in those regulatory guides.

1 See Section C.I.12.6 for all references cited in Section C.I.12 of this guide.

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DG-1145, Section C.I.12 - Radiation Protection C.I.12.1.2 Design Considerations Describe how experience from past designs and operating plants is used to develop an improved radiation protec tion design to ensure tha t occupational rad iation exposures are AL AR A. D escribe the A LA RA design guidance and training (both general and specific) that is given to the individual designers and engineers during initial plant design, and describe provisions for continuing ALARA facility design reviews once the plant is operational (e.g., for plant changes and/or modifications). Describe how the design is directed toward reducing the need for equipment ma intenance and reducing radiation levels and time spent where maintenance and other operational activities are necessary. These descriptions should be detailed in the SAR, including an indication of whether and, if so, how the plant will implement and follow the design consideration guidance provided in Section C.l of Regulatory Guide 8.8, as we ll as oth er industry-developed design guidance th at in cludes A LA RA c riteria. Converse ly, if the plant will not follow such guidance, describe the specific alternative approaches to be used.

Describe the design considerations implemented to minimize the production, distribution, and retention of activated corrosion products throughout the primary system. In accordance with the requirements in 10 CF R 2 0.1406, describe the design approaches im plemented to minim ize, to the extent practicable, contam ination of th e fa cility and the environment; facilitate eventual decommissioning; and minimize, to the extent practicable, the generation of radioactive waste. Also, describe the design considerations implemented to ensure that occupational radiation exposures during decommissioning will be ALARA.

Include a general discussion of the plants approach to meeting the requirements by specifying the selected design concept and the supporting design bases and criteria. Demonstrate that the design concept is technically feasible and within the state-of-the-art, and that reasonable assurance exists that the requirements will be properly implemented prior to the issuance of operating licenses.

Section 12.3.1 of the SAR should address the detailed facility design features for radiation protection and ensuring that occupational radiation exposures will be ALARA.

C.I.12.1.3 Operational Considerations Describe the methods to be used to develop the detailed operational plans, procedures, and policies for ensuring that occupational radiation exposures are ALARA. Describe how these operational plans, procedures, and policies will impact the design of the facility, and how such planning has incorporated information from operating plant experience, other designs, and so forth. Describe how operational requirements are reflected in the design considerations described in Section 12.1.2 of the SAR, as well as in the radiation protection design features described in Section 12.3.1 of the SAR. Indicate the extent to which the plant will follow the guidance on operational considerations give n in Re gulatory Guides 8.8 and 8.10. Co nversely, if the plant will not follow that guidance, describe the specific alternative approaches to be used.

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DG-1145, Section C.I.12 - Radiation Protection Provide the criteria and/or conditions under which the plant will implement various operating procedures and techniques for ensuring that occupational radiation exposures are AL AR A for all systems that contain, collect, store, or transport radioactive liquids, gases, and solids [including, for e xample, the turbine system for b oiling-water rea ctors (B W Rs ); the nuclear steam supply system; the residual heat removal systems; the spent fuel transfer, storage, and cleanup systems; and the radioactive waste treatment, handling, and storage systems]. Describe the implementation of specific exposure control techniques. Describe means for planning and developing procedures for such radiation exposure-related operations as maintenance, inservice inspection, radwaste handling, and refueling in a manner that will ensure that the exposures are ALARA. Describe the methods of planning and accomplishing work, including interfac es between radiation protection, operations, maintenance, planning, and scheduling.

Describe any changes in operating procedures that result from the ALARA operational procedures review.

Indicate how the plant will follow the guidance provided in Regulatory Guides 8.2, 8.7, 8.9, 8.13, 8.15, 8.20, 8.25, 8.26, 8.27, 8.28, 8.29, 8.34, 8.35, 8.36, and 8.38. Co nversely, if the plant will not follow that guidance, describe the specific alternative approaches to be used.

C.I.12.2 Radiation Sources C.I.12.2.1 Contained Sources Describe the sources of radiation, during normal plant operations and accident conditions, that are the bases for the radiation protection design. These sources should be described in the manner needed for input to the shield design calculation. This description should include isotopic composition, source strength and source geometry, and the bases for all values. Those sources that are contained in equipment of th e radioactive w aste m anagem ent system s should also be described. In this section, provide descriptions of other sources, such as the reactor core, spent fuel storage pool, and various auxiliary systems, equipment, and piping containing activation product sources. For BW Rs, describe the sources of N16 during operation, including the steam lines and turbine system (including reheaters, moisture separators, etc.). For the reactor core, describe the source as it is used to determine radiation levels external to the biological shield at locations where occupancy may be necessary. Describe the contribution of neutron and gamma streaming to radiation levels in these potentially occupied areas of containment. Relevant experience from operating reactors may be used. For other sources, tabu late sources by isotop ic composition or gam ma ray energy groups, strength (cu rie conten t),

and geometry, and provide the bases for all values. For all sources identified above, including activation product sources, provide the models and parameters used to calculate the source magnitudes. Indicate whether and, if so, how the applicant has followed the applicable guidance provided in ANSI/ANS 18.1-1999. Conversely, if the applicant has not followed that guidance, describe the specific alternative methods used. Describe any required radiation sources containing byproduct, source, and special nuclear material that may warrant shielding design consideration. Pro vide a listing of isotope, quantity, form , and use of a ll sources in this latter category that exceed 100 millicuries. Describe any additional contained radiation sources that are not identified above, including radiation sources used for instrument calibration or radiography.

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DG-1145, Section C.I.12 - Radiation Protection C.I.12.2.2 Airborne Radioactive Material Sources Describe the sources of airborne radioactive material in equipment cubicles, corridors, and operating areas that are norm ally occupied by operating personnel. Th ese sources should be described in a manner appropriate for use in designing protective measures and for performing dose assessments. Describe, and identify by location and magnitude, those airborne radioactive material sources in the plant that are considered in designing the ventilation system s and specifying appropriate m onitoring systems. T his description should include those airborne sources that are created by leakage, opening formerly closed containers, storage of leaking fu el elem ents, and so forth . Th ose airborne radioactivity sources that have to be co nsidered for their contributions to the plants effluent releases through the radioactive waste management system or the plants ventilation systems should be described in Chapter 11 of the SAR. By contrast, Section 12.2.2 of the SAR should include a listing and description of all other sources of airborne radioactivity in the areas mentioned (those not covered in Chapter 11). In particular, this section should include airborne sources resulting from reactor vessel head removal, relief valve venting, and movement of spent fuel. Tabulate the calculated concentrations of airborne radioactive material by nuclides expected during normal operation, anticipated operational occurrences, and accident conditions for equipment cubicles, corridors, and operating areas normally occupied by operating personnel. Provide the models and parameters used for calculating airborne radioactivity concentrations.

C.I.12.3 Radiation Protection Design Features C.I.12.3.1 Facility Design Features Describe equipment and facility design features used to ensure that occupational radiation exposures are ALARA. Indicate whether and, if so, how the applicant has followed the design feature guidance given in Section C.2 of Regulatory Guide 8.8. Conversely, if the applicant has not followed that guidance, describe the specific alternative approaches used. Also describe the design features provided to control access to radiologically restricted areas (including potentially very high radiation areas), such as the reactor cavity and the fuel transfer tube during refueling operations. Describe each very high radiation area and refer to its location on plant layout diagrams. Provide detailed drawings showing isometric views of each very high radiation area and indicate physical access controls and radiation monitor locations for each of these areas.

Pro vide illustrative exam ples of the facility design features of the equipment and com ponents associated with the systems listed in Section 12.1.3. The description should include those features that reduce the need for maintenance and other operations in radiation fields, reduce radiation sources in areas where operations may be performed, allow quick entry and easy access, provide remote operation capability, or reduce the time spent working in radiation fields, as well as any other features that reduce radiation exposure of personnel. Also, include descriptions of methods for reducing the production, distribution, and retention of activation products through design, material selection, water chemistry, decontamination procedures, and so forth. Provide an illustrative example of each of the following components (including equipment and piping layouts), when applicable, and describe any associated design features intended to m inim ize personnel dose during operation or m aintenance of th e com ponent: liquid DRAFT W ORK-IN-PROGRESS Page C.I.12 -4 DATE: 03/13/2006

DG-1145, Section C.I.12 - Radiation Protection filters, demineralizers, absorber beds, particulate filters, recombiners, tanks, evaporators, pumps, steam generators, valve operating stations, and sampling stations. Describe how sampling ports, instrumentation, and control panels are located to facilitate use and m inimize personnel exposure.

Provide scaled layout and arrangement drawings of the facility. On these drawings, show the locations of all sources described in Section 12.2 of the SAR and identify those sources in a manner that can eas ily be related to tables containing the pertinent and nece ssary quantitative source parameters. Accurately locate positions, indicating the approximate size and shape of each source. On the layout drawings, provide the radiation zone designations, including zone boundaries for normal operations, refueling outages, and post-accident conditions (based on the applicable guidance in Regulatory Guides 1.3, 1.4, 1.7, and 1.183). Reference other chapters of the SAR, as appropriate. The layout drawings should show shield wall thicknesses; traffic patterns (including post-accident access routes to and from vital areas); and locations of controlled access areas (including locked high and very high radiation areas), personnel and equipment decontamination areas, personnel locker and changeout rooms, contamination control areas, radiation protection facilities, airborne radioactivity, area and portal radiation monitors, the solid radwaste processing area and control panels for radwaste equipment and components, the onsite laboratory for analysis of chemical and radioactive samples, the independent spent fuel storage installation (where applicable), the counting room, and the control room and Technical Support Center. Specify the design-basis radiation level in the counting room during normal operation and anticipated operational occurrences. Describe the facilities and equipment (such as hoods, glove boxes, filters, special handling equipment, and special shields) related to the use of sealed and unsealed special nuclear, source, and byproduct material.

C.I.12.3.2 Shielding Provide information regarding the shielding for each radiation source identified in Chapter 11 and Section 12.2 of the SAR, including the criteria for penetrations; shielding materials used; the method used to determine the shield parameters (cross-sections, buildup factors, etc.); and the assumptions, code s, and tech niques used in the calculations. De scribe spe cial protective fea tures that use shielding, geom etric arra ngem ent (including equipment separation), or rem ote handling to ensure that occupational radiation exposures will be ALARA. Include a description of the features/shielding used to preclude radiation streaming from the annulus between the reactor vessel and the biological shield into containm ent areas that may be occupied. Indicate whether and, if so, how the applicant has followed the guidance provided in Regulatory Guide 1.69, as it relates to concrete radiation shields, and Regulatory Guide 8.8, as it relates to special protective features. Conversely, if the applicant has not followed that guidance, describe the specific alternative methods used.

Verify that the plant shielding is sufficient to ensure adequate access to all vital areas, following an accident, in accordance with the requirements in 10 CF R 5 0.34(f)(2)(vii) and the criteria in Item II.B.2 of NUREG-0737.

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DG-1145, Section C.I.12 - Radiation Protection C.I.12.3.3 Ventilation De scribe the personnel protection fe atures incorporated in the ventilation system design.

No te that C hapter 11 of th e S AR should describe those aspects of the design that relate to removing airborne radioactivity from equipment cubicles, corridors, and operating areas normally occupied by operating personnel and transporting it into the effluent control systems.

By contrast, Section 12.3.3 of the S AR shou ld describe a ny ventilation system protective features that are not addressed in Chapter 11 or described in Chapter 9. Include those system aspects which relate to controlling the concentration of radioactivity in the areas mentioned above. Provide illustrative examples of the air cleaning system design, including a representative layout of an air cleaning system housing, showing filter mountings; access doors; aisle space; service galleries; and provisions for testing, isolation, and decontamination. Also, describe the radiation protection features incorporated for system maintenance and the change-out of air filters and adsorbers in the air cleaning system. In addition, indicate whether and, if so, how the applicant has followed the applicable guidance in R egulatory G uide 1.52.

Con versely, if the applicant has not followed that guidance, describe the sp ecific alternative methods used.

C.I.12.3.4 Area Radiation and Airborne Radioactivity Monitoring Instrumentation Describe the fixed area radiation monitoring instrumentation and the continuous airborne radioactivity monitoring instrumentation, as well as the criteria for selection and placement of the instrumentation in accordance with ANSI/ANS-HPSSC-6.8.1. Provide information regarding the auxiliary and/or emergency power supply and the range, sensitivity, accuracy, precision, calibration methods and frequency, alarm setpoints, recording devices, and locations of detectors, readouts, and alarms for the monitoring instrumentation. Consider normal operation, anticipated operational occurrences, accident conditions, and any other conditions with the potential need fo r high-ra nge instrumentation. Provide the locations of a irborne monitor sam ple collectors and give details of sampling lines and pump locations.

De scribe the criteria and methods for obtaining representative in-plant airborne radioactivity concentrations, including airborne radioiodines and other radioactive materials, from the work areas being sampled. Describe the use of portable instruments, and the associated training and procedures, to accurately determine the airborne iodine concentration in areas within the fa cility wh ere plant personnel may be present during an accident, in accordance with the requirements of 10 CF R 5 0.34(f)(2)(xxvii) and the criteria in Item III.D.3 .3 of NUR EG -0737.

Describe procedures for locating suspected high activity areas.

If complying with the requirements of 10 CFR 70.24 in lieu of 10 CFR 50.68(b), describe the radiation instrumentation that will be used to meet the criticality accident monitoring requirements of 10 CFR 70.24 for the new fuel storage area. Describe the in-containment high-range radiation m onitoring capability follow ing an accident, in accordance with the requirements of 10 CFR 50.34(f)(2)(xvii), and the criteria in Attachment 3 to Item II.F.1 of NUREG-0737 and Regulatory Guide 1.97.

Indicate whether and, if so, how the applicant has followed the guidance provided in Regulatory Guides 1.2 1, 1 .97 , 8.2 , an d 8.8, as we ll as AN SI N13.1-1993. Converse ly, DRAFT W ORK-IN-PROGRESS Page C.I.12 -6 DATE: 03/13/2006

DG-1145, Section C.I.12 - Radiation Protection if the applicant has not followed that guidance, describe the specific alternative methods used.

C.I.12.3.5 Dose Assessment Pro vide the objectives and criteria for th e design dose rates in the various plant areas.

In accordance with the provisions of Regulatory Guide 8.19, provide an estimate of the annual person-S ieve rt (person-re m) doses associated with operation, norm al m aintenance, radwaste handling, refueling, inservice inspection, and special maintenance (e.g., maintenance that goes beyond routine scheduled maintenance, m odification of equipment to upgrade the p lant, repairs to failed components). For each of these work categories, provide a listing of typical job activities that would normally be performed under this work category, along with the associated annual collective dose estimate. Include listings of the expected num bers of pe rsonnel, occupancy times, and average dose rates used to determine the annual collective dose estimate for each of these job categories. W hen applicable, actual exposure and occupancy data from similar operating plants may be used for the dose assessment. W hen used, operating data from other plants should be modified to account for any improvements in plant design and operating procedures. For areas with expected airborne radioactivity concentrations (discussed in Section 12.2.2) during normal operation and anticipated operational occurrences, provide estimated person-hours of o ccupancy and estimated personnel inhalation exposures.

Also, provide the bases, models, and assumptions for the above values.

Pe rform a review of a ll plant vital areas (areas that m ay require occupancy to enable an operator to aid in mitigating or recovering from an accident), subject to the requirements of 10 CFR 50.34(f)(2)(vii), and the criteria in Item II.B.2 of NUREG-0737. For each vital area, provide the mission dose (dose to access the area, perform the necessary fu nction(s), and exit the area), and verify that the dose guidelines of General Design Criterion (GDC) 19, Control Room, are not exceeded during the course of an accident. Specifically, GDC 19 requires that adequate radiation protection must be provided, such that the dose to personnel should not exceed 0.05 Sievert (5 rem) total effective dose equivalent (TEDE) for the duration of the accident. Provide the bases, models, and assumptions for the above vital area mission doses, including the occupancy time spent in each vital area and the post-accident dose rates for the vital area and access route at time of access.

Provide the estimated annual whole body dose and maximum organ dose to a member of the public, in accordance with the dose requirements of 40 CFR Part 190. Provide the bases, models, and assumptions for each of those values, including the estimated dose from each applicable radioactive gaseous and liquid effluent and any contributions to the whole body dose from direct radiation (including sky shine) from contained radioactive sources within the facility.

For each contained source that contributes to the direct radiation dose component of this annual dose estimate, provide a description of the source along with its associated direct dose contribution.

For multi-unit plants, provide estimated annual doses to construction workers in a new unit construction area, as a result of radiation from onsite radiation sources from the existing operating plant(s). Examples of typical onsite radiation sources include the turbine systems (for BW Rs), stored radioactive wastes, the independent spent fuel storage facility, auxiliary and reactor buildings, and radioactive effluents (direct radiation from the gase ous rad ioactive DRAFT W ORK-IN-PROGRESS Page C.I.12 -7 DATE: 03/13/2006

DG-1145, Section C.I.12 - Radiation Protection effluent plume). Provide the annual person-Sievert (person-rem) doses associated with such construction areas. Include bases, models, assumptions, and input data. Describe any additional dose-reducing measures taken as a result of the dose assessment process for specific functions or activities. Indicate whether and, if so, how the applicant has followed the guidance in Regulatory Guide 8.19. Conversely, if the applicant has not followed that guidance, describe the specific alternative methods used.

C.I.12.5 Operational Radiation Protection Program To achieve the goal of maintaining occupational and public doses both below regulatory lim its and ALAR A, the radiation protection program should include the following components:

(1) a documented management commitment to keep exposures ALARA (2) a trained and qualified organization with sufficient authority and well-defined responsibilities (3) adequate facilities, equipment, and procedures to effectively implement the program Dem onstrate the development, organization, and implementation of these components.

Discuss how the radiation protection program will be im plemented on a phased basis, prior to each of the following implementation milestones:

(1) Prior to initial receipt of by-product, source, or special nuclear materials (excluding Exem pt Qua ntities as described in 10 C FR 30.18), and thereafter, when such radioactive materials are possessed under this license, the following radiation protection program elements will be in place:

(a) Organization - A radiation protection supervisor and at least one (1) radiation protection technician, each selected, trained and qualified consistent with the guidance in Regulatory Guide 1.8. Conversely, if the applicant has not followed that guidance, describe the specific alternative methods used.

(b) Facilities - A facility or facilities to support the receipt, storage and control of non-exempt radioactive sources in accordance with 10 CFR 20.1801, 20.1802, and 20.1906.

(c) Instrumentation and Equipment - Adequate types and quantities of instrumentation and equipment will be selected, maintained, and used to provide for th e appropriate detection capabilities , ranges, sensitivities, and accuracies to conduct radiation surveys and monitoring (in accordance with 10 CFR 20.1501 and 20.1502) for the types and levels of radiation anticipated for the non-exempt sources possessed under this license.

(d) Procedures - Procedures will be established, implemented and maintained sufficient to maintain adequate control over the receipt, storage, and use of radioactive m aterials posse sse d under this license and as necessary to assure compliance with 10 C FR 19.11 and 19.12 and 10 CF R P art 20, com mensurate DRAFT W ORK-IN-PROGRESS Page C.I.12 -8 DATE: 03/13/2006

DG-1145, Section C.I.12 - Radiation Protection with the types and quantities of radioactive materials received and possessed under this license.

(e) Training - Initial and periodic training will be provide d to individu als responsible for the receipt, control or use of non-exempt radioactive sources possessed under this license in accordance with 10 CFR 19.12 and consistent with the guidance in Regulatory Guides 1.8, 8.13, 8.27, and 8.29. Conversely, if the applicant ha s not followed that guidance, describe the spe cific alternative methods used.

(2) Prio r to receiving reactor fue l under this license, and thereafter, w hen reactor fu el is possessed under this lice nse, radiation monitoring will be provide d in accordance with 10 CFR 50.68, in addition to the radiation protection program elements specified under item 1, above.

(3) Prior to initial loading of fuel in the reactor, the program described in this section will be fully im plemented, with the exception of the organization, fa cilities, equipment, instrumentation, and procedures necessary for transferring, transporting or disposing of radioactive materials in accordance with 10 CF R P art 20, S ubpart K, a nd applicable requirements in 10 CFR Part 71. In addition, at least one (1) radiation protection tech nician, se lected, trained and qualified consistent with the guidan ce in Regulatory Guide 1.8, will be onsite and on duty when fuel is initially loaded in the reactor, and thereafter, whenever fuel is in the reactor. If the applicant has not followed the guidance in Regulatory Guide 1.8, describe the specific alternative methods used.

(4) Prior to initial transfer, transport or disposal of radioactive materials, the organization, facilities, equipm ent, instrum entation, and procedures will be in place as necessary to assure com pliance with 10 C FR Pa rt 20, Su bpart K , and applicable requirements in 10 CFR Part 71.

Identify the staffing levels, instrumentation and equipment, facilities, procedures, and training necessary to ensure radiation safety of workers and the public for each phase of implementation.

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DG-1145, Section C.I.12 - Radiation Protection C.I.12.5.1 Organization Describe the administrative organization of the radiation protection program, including the authority and responsibility of each identified position.2 Indicate whether and, if so, how the applicant has followed the guidance in R egulatory G uides 1.8, 8.2, 8.8, and 8.10.

Con versely, if the applicant has not followed that guidance, describe the sp ecific alternative approaches used. Describe the experience and qualification of the personnel responsible for various aspects of the radiation protection program and for handling and monitoring radioactive materials, including special nuclear, source, and byproduct materials. Also, describe management and staff authorities and responsibilities for implementing and documenting radiation protection program reviews, as required by 10 CFR 20.1101 and 20.2102. Reference Chapter 13 of the SAR as appropriate.

C.I.12.5.2 Equipment, Instrumentation, and Facilities Equipment and Instrumentation Provide the criteria for selecting portable and laboratory technical equipment and instrumentation for use in performing radiation and contamination surveys, monitoring and sampling in-plant airborne radioactivity, area radiation monitoring, and for personnel monitoring (including audible alarming and electronic dosimeters) during normal operation, anticipated operational occurren ces, and accident conditions. Include the locations and quantity of each type of instrument, considering the amount of instrumentation and the fact that equipment may be unavailable at any given time as a result of periodic testing and calibration, maintenance, and repair. The equipment and instrumentation should provide detection capabilities, ranges, sensitivities, and accuracies appropriate for the types and levels of radiation anticipated at the plant and in its environs during routine operations, major outages, abnormal occurrences, and postulated accident conditions.

Describe the types of detectors and monitors, as well as the quantities, sensitivities, ranges, alarms, and calibration frequencies and methods for all portable and laboratory technical equipment and instrumentation m entioned above. Include a description of th e portable air sampling and analysis system to determine airborne radionuclide concentrations during and fo llowing an accident, in accordance with the requirements of 10 CF R 5 0.34(f)(2)(xxvii) and the criteria in Item III.D.3.3 of NUREG-0737. Types of equipment and instrumentation to be described include the following:

(1) laboratory and fixed instrumentation 2

Key positions include the plant manager, plant organization manag ers and supervisors, radiation protection manager, radiation protection technicians, and radiation protection superviso ry and technical staff. Pro vide equiva lent information regarding personnel with radiation protection responsibility who are assigned outside the radiation protection department (e.g., respiratory protection, personnel dosimetry, bioassay, instrument calibration and maintenance, radioactive source control, effluents and environmental monitoring and assessment, radioactive waste shipping, radiation work permits, job coverage, and radiation monitoring and surveys).

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DG-1145, Section C.I.12 - Radiation Protection (2) portable monitoring instrumentation and equipment (3) personnel monitoring instrumentation and equipment (4) personnel protective equipment and clothing Facilities This section of the SAR need not include facilities that were previously described and reviewed in an applicable design control docum ent. In addition, on the basis of com pany and site-specific information, this section may be modified to indicate offsite facilities and functions that may be carried out at another location or throu gh a vendor.

De scribe the instrum ent storage, calibration, and maintenance facilities. T hese facilities should be able to support program implementation during routine operations, refueling and other outages, abnormal occurrences, and accident conditions.

De scribe and identify the location of rad iation protection fa cilities (including mens and womens locker and shower rooms, offices, and access control stations); laboratory facilities for radioactivity analyses; decontam ination facilities (for both equipment and personnel); portable instrument calibration facility; facility for issuing and storing protective clothing; facility for issuing, storing, and maintaining respiratory protection equipment; machine shop for work on activated or contaminated components and equipment; area for storing and issuing contam inated too ls and equipment; area for storing radioactive m aterials; facility for dosimetry processing and bioassay; laundry facility; and other contamination control equipment and areas.

Indicate whether and, if so, how the applicant has followed the guidance provided in Regulatory Guides 1.9 7, 8 .4, 8.6 , 8.8 , 8.9 , 8.1 5, 8 .20 , 8.2 6, a nd 8.2 8. C onverse ly, if the applicant has not followed that guidance, describe the specific alternative methods used.

C.I.12.5.3 Procedures For each of the categories listed below, describe the radiation protection procedures and methods of operation that have been developed to ensure that occupational radiation exposures are AL AR A. R adiation protection procedures should provide means for a dequate control over the receipt, handling, possession, use, transfer, storage, and disposal of sealed and unsealed byproduct, source, and special nuclear material, and should ensure compliance with applicable requirements in 10 CFR Parts 19, 20, 50, 70 and 71. Regulatory Guides 1.8, 1.33, 8.2, 8.7, 8.8, and 8.10 and the applicable portions of NUREG-1736 provide guidance for use in developing procedures for radiation protection. Indicate whether and, if so, how the plant will follow that guidance. Conversely, if the plant will not follow that guidance, describe the specific alternative approaches to be used. Reference Chapter 13 of the SAR as appropriate.

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DG-1145, Section C.I.12 - Radiation Protection Radiological Surveillance De scribe the policy, methods, fre quencies, and procedures for c onducting radiation surveys.

De scribe the procedures that provide for u se of p ortable monitoring systems to sample and analyze for rad ioiodine in plant areas during and following an accident, in accordance with the requirements of 10 CF R 5 0.34(f)(2)(xxvii) and the criteria in Item III.D.3 .3 of NUR EG -0737.

Also, indicate compliance with 10 CFR 20.1501, and consistency with Regulatory Guides 8.2, 8.8 and 8.10.

Access Control De scribe the physica l and adm inistrative measures for c ontrolling access to and work within radiation areas, high radiation areas, and very high radiation areas. This discussion may reference Section 12.1 of the SAR, as appropriate. Include a description of the additional administrative controls for restricting access to each very high radiation area, as required by 10 CFR 20.1902. Also, describe how these measures comply with 10 CFR 19.12, Subpart G of 10 CFR Part 20, and 10 CFR 20.1903, as well as how they are consistent with the guidance of Regulatory Guides 8.13, 8.27, 8.29 and 8.38. Conversely, if the plant will not follow such guidance, describe the specific alternative a pproaches to be used.

Ra diation W ork Permits De scribe the information included in radiation work permits, as well as the criteria for th eir issuance. Also, indicate whether the permit contents and issuance criteria are consistent with Regulatory Guide 8.8. Conversely, if the plant will not follow such guidance, describe the specific alternative approaches to be used.

Contamination Control Describe the bases and methods for monitoring and controlling surface contamination (including loose discrete radioactive particles) for personnel, equipment, and surfaces. This description should include the surveillance program to ensure that licensed materials will not inadvertently be released from the controlled area. Describe decontamination procedures for personnel and areas, as well as decontamination and/or disposal procedures for e quipm ent.

In accordance with the requirements of 10 CFR 20.1406, describe how operating procedures will m inim ize, to the extent practicable, contam ination of th e fa cility and the environment, facilitate eventual decommissioning, and minimize, to the extent practicable, the generation of radioactive waste.

Describe how contamination control measures comply with 10 CFR 20.1406, 20.1701, and 20.1801.

Personnel Monitoring and Dose Control Describe the methods and procedures for internal and external personnel monitoring, including methods to record, report, and analyze results. Describe the program for assessing internal DRAFT W ORK-IN-PROGRESS Page C.I.12-12 DATE: 03/13/2006

DG-1145, Section C.I.12 - Radiation Protection radiation exposure (whole body counting and bioassay), including the bases for selecting personnel who will be included in the program, the frequency of their whole-body counts and bioassays, and the basis for any non-routine bioassays that will be performed.

De scribe the methods and procedures to ensure that personnel doses are maintained within the dose limits established in 10 CFR 20.1201 for adult workers; 10 CFR 20.1207 and 20.1208 for minors and declared pregnant workers, respectively; and 10 CFR 20.1301 for members of the public. Describe the procedures for permitting an individual to participate in a planned special exposure, in accordance with the requirements of 10 CFR 20.1206 and 20.2104, and consistent with the guidance in Regulatory Guide 8.35.

Describe the procedures and methods of operation that have been developed to ensure that occupational radiation exposures will be ALARA. Include a description of the procedures used in refueling, inservice inspection, radwaste handling, spent fuel handling, loading and shipping, normal operation, routine maintenance, and sampling and calibration, where such procedures are specifically related to ensuring that radiation exposures will be ALARA.

Describe how personnel monitoring and dose control measures comply with 10 CFR Parts 19 and 20, and are consistent with Regulatory Guides 8.2, 8.7, 8.8, 8.9, 8.10, 8.13, 8.20, 8.26, 8.32, 8.34, 8.35, and 8.36. Conversely, if the plant will not follow such guidance, describe the specific alternative approaches to be used.

Respiratory Protection Describe the engineering controls to limit airborne radioactivity. Describe the methods and procedures for evaluating and controlling potential airborne radioactivity concentrations.

Discuss any provisions for special air sampling, and the issuance, selection, use, and maintenance of respiratory protection devices, including training and retraining programs and programs for fitting respiratory protection equipment. Discuss the use of process and engineering controls in lieu of respirator use to limit intakes.

Describe the methods and procedures for the following activities:

- monitoring, including air samplin g and bioassays

- supervision and training o f respirator use rs

- fit-testing

- respirator selection, including provisions for vision correction, adequate comm unications, extreme temperature conditions, and concurrent use of other safety or radiological protection equipment

- breathing air quality

- inve ntory, control, storage, issuance, use, m aintenance, repair, testing, and quality assurance of respiratory protection equipment, including self-contained breathing apparatuses

- recordkeeping

- limitations on periods of use and relief from respirator use DRAFT W ORK-IN-PROGRESS Page C.I.12-13 DATE: 03/13/2006

DG-1145, Section C.I.12 - Radiation Protection Describe how respiratory protection measures comply with Subpart H of 10 CFR Part 20, as well as how they are consistent with Re gulatory Guides 8.15 and 8.25 and NU RE G/CR -0041.

Con versely, if the plant will not follow su ch gu idance, describe the specific alternative approaches to be used.

Radioactive Material Control Describe the procedures governing the accountability and storage of radioactive sources that are not affixed to, or installed in, plant systems. Describe the procedures governing the packaging and transportation of licensed radioactive materials and the transfer of low-level radioactive was te. Describe the proced ures to en sure po sition co ntrol of licensed radioactive material so that unnecessary or inadvertent exposures do not occur and such material is not released into uncontrolled areas in a manner that is not authorized by NRC regulations or the license.

Describe how radioactive material control measures comply with 10 CFR §§ 20.1801-1802, 20.1902, 20.1904-1906, 20.2001, and 20.2005-2007, and 10 CFR Part 71, Subpart G and 10 CFR 71.5.

Posting and Labeling De scribe the criteria and procedures for p osting areas and m arking item s (e.g., tools and equipment) to indicate the presence of fixed or removable surface contamination.

Describe how posting and labeling will comply with 10 CFR §§ 20.1901-20.1903, and 20.1905.

Radiation Protection Training Describe the procedures that ensure the selection, qualification, training, and periodic retraining of radiation protection staff and radiation workers.

Describe how radiation protection training will comply with 10 CFR Parts 19, 20, and 50 (10 CFR 50.120), and will be consistent with the guidance of Regulatory Guides 1.8, 8.13, 8.15, 8.27, and 8.29. C onversely, if the plant will not follow such guidance, describe the specific alternative approaches to be used.

Quality Assurance De scribe the quality assurance procedures that im plement the applicable requirem ents of 10 CFR 20.1101, Appendix B to 10 CFR Part 50, Subpart H of 10 CFR Part 71, and the guidance in Regulatory Guide 1.33. Reference Chapter 17 of the SAR as appropriate.

C.I.12.6 References (1) Regulatory Guide 1.3, Assumptions Used for Evaluating the Potential Radiological Co nsequences of a Loss-of-Co olant A ccident fo r Bo iling-W ater Reactors, available DRAFT W ORK-IN-PROGRESS Page C.I.12-14 DATE: 03/13/2006

DG-1145, Section C.I.12 - Radiation Protection in ADAMS under Accession #ML003739601 3.

(2) Regulatory Guide 1.4, Assumptions Used for Evaluating the Potential Radiological Co nsequences of a Loss-of-Co olant A ccident fo r Pressurized-W ater Reactors, available in ADAMS under Accession #ML003739614.

(3) Regulatory Guide 1.7, Control of Combustible Gas Concentrations in Containment Following a Loss-of-Coolant Accident, available in ADAMS under Accession

1. ML003739927.

(4) Regulatory Guide 1.8, Qualification and Training of Personnel for Nuclear Power Plants.

(5) Re gulatory Guide 1.21, Me asuring, E valuating, and R eporting R adioactivity in So lid W astes and R eleases of R adioactive Ma terials in Liquid and G aseous Effluents from Light-W ater-Cooled Nuclear Power Plants, available in ADAMS under Accession

1. ML003739960.

(6) Re gulatory Guide 1.33, Quality Assurance Program Re quirem ents (O peration).

(7) Regulatory Guide 1.52, Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup System s in Light-W ater-Cooled Nu clear P ower P lants.

(8) Re gulatory Guide 1.69, Concrete R adiation S hields for N uclear Po wer Pla nts, available in ADAMS under Accession #ML003740235.

(9) Re gulatory Guide 1.97, Instrum entation fo r Light-W ater-Cooled Nu clear P ower P lants To A ssess Plant and E nvirons C onditions Du ring and Following an A ccident, available in ADAMS under Accession #ML003740282.

(10) Regulatory Guide 1.183, Alternative Radiological Source Terms for Evaluating Design-3 All regulatory guides listed in this s ection were published by the U.S . Nuclear Regulatory Comm ission. W here an ADAMS accession number is identified, the specified regulatory guide is available electronically through the NRCs Agencywide Documents Access and Management System (AD AM S) a t http://www.nrc.gov/reading-rm/adams.html. All other regulatory guide s are available electronically through the Public Electronic Reading Room on the NRCs public Web site, at http://www.nrc.gov/reading-rm/doc-collections/reg-guides/ . Sing le copies of regulatory guides may also be obtained free of charge by writing the Reproduction and Distribution Services Section, ADM, USNRC , W ashington, DC 20555-0001, or by fax to (301)415-2289, or by email to DISTRIBUTION@nrc.gov. Active guides may also be purchased from the National Technical Information Service (NTIS)on a standing order basis. Details on this service may be obtained by contacting NTIS at 5285 Port Royal Road, Springfield, Virginia 22161, online at http://www.ntis.gov, or by telephone at (703) 487-4650. Copies are also available for inspection or copying for a fee from the NRCs Public Document Room (PDR), which is located at 11555 Rockville Pike, Rockville, Maryland; the PDRs mailing address is USNRC PDR, W ashington, DC 20555-0001. The PDR can also be reached by telephone at (301) 415-4737 or (800) 397-4205, by fax at (301) 415-3548, and by email to PDR@ nrc.gov.

DRAFT W ORK-IN-PROGRESS Page C.I.12-15 DATE: 03/13/2006

DG-1145, Section C.I.12 - Radiation Protection Ba sis Accidents at Nu clear P ower R eactors.

(11) Re gulatory Guide 8.2, G uide fo r Ad ministrative Pra ctices in R adiation M onitoring.

(12) Re gulatory Guide 8.4, D irect-Reading and Indirect-Reading P ocket Do sim eters.

(13) Re gulatory Guide 8.6, S tandard T est Pro cedure fo r Geiger-M ueller C ounters.

(14) Regulatory Guide 8.7, Instructions for Recording and Reporting Occupational Radiation Exposure D ata.

(15) Regulatory Guide 8.8, Information Relevant to Ensuring That Occupational Radiation Exposures at N uclear Po wer Sta tions W ill Be as Low as Is Re asonably Achievable.

(16) Re gulatory G uide 8.9, A cce ptab le Concepts, M odels, E quations, an d Assu mptions for a Bioassay Program.

(17) Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposures as Low as Is Re asonably Achievable.

(18) Re gulatory Guide 8.13, Instruction Co ncerning Pre natal R adiation Exposure.

(19) Re gulatory Guide 8.15, Ac ceptable Pro grams for Respiratory Protection.

(20) Regulatory Guide 8.19, Occupational Radiation Dose Assessment in Light-W ater Re actor P ower P lants De sign S tage M an-Rem Estimates.

(21) Re gulatory Guide 8.20, Ap plications of B ioassay for I-125 and I-131, available in ADAMS under Accession #ML003739555]

(22) Re gulatory Guide 8.25, Air S am pling in the W orkplace.

(23) Re gulatory Guide 8.26, Ap plications of B ioassay for Fission and Activation P roducts, available in ADAMS under Accession #ML003739617]

(24) Re gulatory G uide 8.27 , Radiation Protec tion T raining for Personnel at Light-W ater-Cooled Nuclear Power Plants, available in ADAMS under Accession #ML003739628]

(25) Re gulatory Guide 8.28, Au dible-A larm Do sim eters.

(26) Regulatory Guide 8.29, Instruction Concerning Risks from Occupational Radiation Exposure.

(27) Re gulatory Guide 8.32, Criteria for E stablishing a Tritium Bioassay Program, available in ADAMS under Accession #ML003739479]

(28) Regulatory Guide 8.34, Monitoring Criteria and Methods To Calculate Occupational Ra diation Do ses.

DRAFT W ORK-IN-PROGRESS Page C.I.12-16 DATE: 03/13/2006

DG-1145, Section C.I.12 - Radiation Protection (29) Re gulatory Guide 8.35, Planned Sp ecial Exposures.

(30) Re gulatory Guide 8.36, Radiation D oses to the E mbryo/Fetus.

(31) Regulatory Guide 8.38, Control of Access to High and Very High Radiation Areas in N uclear Po wer Pla nts.

(32) 10 CFR Part 19, Notices, Instructions, and Reports to Workers: Inspection and Investigations, available electronically through the NRCs public Web site, at http://www.nrc.gov/reading-rm/doc-collections/cfr/part019/ .

(33) 10 CF R P art 20, S tandards for P rotection A gainst Ra diation, available electronically through the N RC s public W eb site, at http://www.nrc.gov/reading-rm/doc-collections/cfr/part020/.

(34) 10 CFR Part 30, Rules of General Applicability to Dom estic Licensing of Byproduct Material, available electronically through the NRCs public Web site, at http://www.nrc.gov/reading-rm/doc-collections/cfr/part030/ .

(35) 10 CF R P art 50, D om estic Licensing of P roduction and U tilization Facilities, a vailable electronically through the NR Cs public W eb site, at http://www.nrc.gov/reading-rm/doc-collections/cfr/part050/.

(36) 10 CF R P art 70, D om estic Licensing of S pecial Nu clear M aterial, available electronically through the NR Cs public W eb site, at http://www.nrc.gov/reading-rm/doc-collections/cfr/part070/.

(37) 10 CF R P art 71, P ackaging and Transportation of R adioactive Ma terial, ava ilable electronically through the NR Cs public W eb site, at http://www.nrc.gov/reading-rm/doc-collections/cfr/part071/ .

(38) 40 CFR Part 190, Environmental Radiation Protection Standards for Nuclear Power Operations, issued by the U.S . En vironm ental Protection A gency, ava ilable electronically through the GPOAccess W eb site maintained by the U.S. Government Prin ting Office , at http://www.gpoaccess.gov/cfr/index.html .

(39) General De sign Criterion 19, Control Room , as specified in Ap pend ix A to 10 CFR Part 50, available electronically through the NRCs public Web site, at http://www.nrc.gov/reading-rm /doc-collections/cfr/p art050/part050-appa.html/

DRAFT W ORK-IN-PROGRESS Page C.I.12-17 DATE: 03/13/2006

DG-1145, Section C.I.12 - Radiation Protection NU RE G/CR -0041, Ma nual of Respiratory Protection A gainst Airborne R adioactive Ma terials, January 2001, available in ADAMS under Accession #ML010310331.

NUREG -0737, Clarification of TMI Action Plan Requirements, November 1980.4 NUR EG-1736, Consolidated Guidance: 10 CFR Part 20 Standards for Protection Against Radiation, October 2001.

ANSI/ANS 18.1-1999, Radioactive Source Term for Normal Operation for Light-W ater Re actors.5 AN SI N 13.1-1993, G uide to Sa mpling A irborne Ra dioactive M aterials in N uclear Fa cilities.

ANSI/ANS-HPSSC-6.8.1-1981, Location and Design Criteria for Area Radiation Monitoring System s for Light-W ater Nuclear Reactors. 6 4

All NUR EG -series reports listed in this s ection were published by the U.S . Nuclear Regulatory Co mmission. W here an A DA MS accession number is identified, the specified report is available electronically through the NRCs Agencywide Documents Access and Management System (AD AM S) a t http://www.nrc.gov/reading-rm /adam s.html/. All other rep orts are available electronically through the Public Electronic Reading Room on the NRCs public Web site, at http://www.nrc.gov/reading-rm/doc-collections/nuregs/. Copies are also available for inspection or copying for a fee from the NRCs Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDRs mailing address is USNRC PDR, W ashington, DC 20555; telephone (301) 415-4737 or (800) 397-4209; fax (301) 415-3548; email is PDR@ nrc.gov. In addition, cop ies are available at current rates from the U.S. Government Printing Office, P.O. Box 37082, W ashington, DC 20402-9328, telephone (202) 512-1800; or from the National Technical Info rmation S ervice (NTIS), 5 285 P ort R oyal Ro ad, Sp ringfield, VA 22161, http://www.ntis.gov/ ,

telephone (703) 487-4650.

5 Copies may be purchased from the American Nuclear Society (ANS), 555 North Kensington Avenue, La Grange Park, IL 60526 [phone: 703-352-6611/fax: 703-352-0499]. Purchase information is available through the W eb-based A NS online store at http://www.ans.org/store/vi-240238/.

6 Copies may be purchased from the American Nuclear Society (ANS), 555 North Kensington Avenue, La Grange Park, IL 60526 [phone: 703-352-6611/fax: 703-352-0499]. Purchase information is available through the W eb-based A NS online store at http://www.ans.org/store/vi-240089/.

DRAFT W ORK-IN-PROGRESS Page C.I.12-18 DATE: 03/13/2006

DG-1145, Section C.I.12 - Radiation Protection

- NU REG/CR -0041, Manua l of Resp iratory Protection Against Airborne Rad ioactive Materials, January 2001, available in ADAMS under Accession #ML010310331.

- NUREG -0737, Clarification of TMI Action Plan Requirements, November 1980.7

- NUREG -1736, Consolidated Guidance: 10 CFR Part 20 Standards for Protection Against Radiation, October 2001.

- ANSI/ANS 18.1-1999, Radioactive Source Term for Normal Operation for Light-W ater Re actors.8

- ANSI N13.1-1993, Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities.

- ANSI/ANS-HPSSC-6.8.1-1981, Location and Design Criteria for Area Radiation Mo nitoring System s for Light-W ater Nuclear Reactors. 9 7

All NUR EG -series reports listed in this s ection were published by the U.S . Nuclear Regulatory Co mmission. W here an A DA MS accession number is identified, the specified report is available electronically through the NRCs Agencywide Documents Access and Management System (AD AM S) a t http://www.nrc.gov/reading-rm /adam s.html/ . All other rep orts are available electronically through the Public Electronic Reading Room on the NRCs public Web site, at http://www.nrc.gov/reading-rm/doc-collections/nuregs/. Copies are also available for inspection or copying for a fee from the NRCs Public Document Room at 11555 Rockville Pike, Rockville, MD; the PDRs mailing address is USNRC PDR, W ashington, DC 20555; telephone (301) 415-4737 or (800) 397-4209; fax (301) 415-3548; email is PDR@ nrc.gov. In addition, cop ies are available at current rates from the U.S. Government Printing Office, P.O. Box 37082, W ashington, DC 20402-9328, telephone (202) 512-1800; or from the National Technical Info rmation S ervice (NTIS), 5 285 P ort R oyal Ro ad, Sp ringfield, VA 22161, http://www.ntis.gov ,

telephone (703) 487-4650.

8 Copies may be purchased from the American Nuclear Society (ANS), 555 North Kensington Avenue, La Grange Park, IL 60526 [phone: 703-352-6611/fax: 703-352-0499]. Purchase information is available through the W eb-based A NS online store at http://www.ans.org/store/vi-240238/.

9 Copies may be purchased from the American Nuclear Society (ANS), 555 North Kensington Avenue, La Grange Park, IL 60526 [phone: 703-352-6611/fax: 703-352-0499]. Purchase information is available through the W eb-based A NS online store at http://www.ans.org/store/vi-240089/.

DRAFT W ORK-IN-PROGRESS Page C.I.12-19 DATE: 03/13/2006

DG-1145, Section C.I.12 - Radiation Protection Section C.I.12 Radiation Protection ADAMS Accession Numb er: ML060230011 COG P roject Manager: MKKlump, 415-1446

• See previous concurrence OFFICE TECH ED DNRL/NRR DNRL/NRR IHPB/NRR OGC NAME PG arrity* PM agnanelli (LA)- MKKlump* TFrye* RW eisman JColaccino for: (PM)

DATE 02/28/06 03/03/06 2/23/06 2/24/06 03/13/06 OFFICIAL RECORD COPY DRAFT W ORK-IN-PROGRESS Page C.I.12-20 DATE: 03/13/2006