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CALLAWAY - SA12.0-iTABLE OF CONTENTSCHAPTER 12.0RADIATION PROTECTION Section Page12.1ENSURING THAT OCCUPATIONAL RADIATION EXPOSURE S ARE AS LOW AS REASONABLY ACHIEVABLE (ALARA).........
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........................12.1-112.1.1POLICY CONSIDERATIONS.....
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...................12.1-112.1.1.1Management Policy............
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.....................12.1-112.1.1.2Organizational Structure...
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.....................12.1-112.1.1.3Application of the Un ion Electric ALARA Policy to Plant Operations.12.1-112.4DOSE ASSESSMENT................
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.....................12.4-112.5RADIATION PROTECTION PROGRAM..................
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.....................12.5-112.5.1ORGANIZATION.......
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.....................12.5-112.5.1.1Radiation Protection Program Objectives...........
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.................12.5-112.5.1.2Organization of the R adiation Protection Department
........................12.5-212.5.1.3Personnel Training.........
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.....................12.5-212.5.2EQUIPMENT, INSTRUMENTATION AND FACILITIES.....
.....................12.5-212.5.2.1Equipment and Instrumentation..............
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..........................12.5-212.5.2.1.1Installed Radiation Monitoring Equipment...........
..........................12.5-312.5.2.1.2Radiation Protection Laboratory Instrumentation..
........................12.5-312.5.2.1.3Portable Radiation Detection Instrumentation.....
..........................12.5-312.5.2.1.4Portable Air Sampling Equipment............
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.....................12.5-312.5.2.1.5Instrument Calibration..
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.....................12.5-412.5.2.1.6Protective Clothing..................
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.....................12.5-412.5.2.1.7Respiratory Protection Equipment.........
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........................12.5-512.5.2.1.8External Dosimetry......
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.....................12.5-512.5.2.1.9Internal Dosimetry.....
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.....................12.5-512.5.2.2Facilities...........
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.....................12.5-612.5.2.2.1Radiation Protection Facilities...............
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........................12.5-612.5.2.2.2Access Control Facilities
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.....................12.5-612.5.2.2.3Equipment Decontamination Facilities................
..........................12.5-612.5.2.2.4Personnel Decontamination Facilities.......
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.....................12.5-712.5.2.2.5Radiation Protection Count Room......
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..........................12.5-7 CALLAWAY - SATABLE OF CONTENTS (Continued)
Section Page12.0-ii12.5.2.2.6Laundry Decontamination Facility ....
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.................12.5-712.5.2.2.7Radiation Protection Office...............
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.................12.5-712.5.2.2.8Locker and Change Facilities...........
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.................12.5-712.5.2.2.9Calibration Facilities...
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.....................12.5-712.5.2.2.10Dosimetry Processing Facilities........
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.................12.5-812.5.2.2.11Respiratory Protection Facilities............
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........................12.5-812.5.2.2.12Respirator Issue and Storage Area...................
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.................12.5-812.5.3PROCEDURES............
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..........................12.5-812.5.3.1Radiation Surveys..........
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.....................12.5-812.5.3.1.1Radiation - Surveys.....
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.....................12.5-812.5.3.1.2Surface Contamination Surveys............
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........................12.5-912.5.3.1.3Airborne Radioactivity Surveys..............
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........................12.5-912.5.3.2Radiation Exposure Control.
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.............................12.5-1012.5.3.3Contamination Control......
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...................12.5-1212.5.3.4Radiation Protection Training..............
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.................12.5-1212.5.3.5Personnel Dosimetry........
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...................12.5-1312.5.3.5.1External Radiation Dosimetry................
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......................12.5-1312.5.3.5.2Internal Radiation Dosimetry............
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.............................12.5-1312.5.3.6Airborne Radiation Evaluation and Control..............
........................12.5-1312.5.3.7Respiratory Protection Program.................
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......................12.5-1312.5.3.8Radioactive Materials Handling.............
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.............................12.5-14 CALLAWAY - SA12.0-iiiRev. OL-1412/04LIST OF TABLES NumberTitle12.5-1Radiation Protecti on Laboratory Equipment12.5-2Portable radiati on protection Equipment CALLAWAY - SA12.0-ivRev. OL-1412/04LIST OF FIGURES NumberTitle12.5-1Deleted CALLAWAY - SA12.1-1Rev. OL-21 5/15CHAPTER 12RADIATION PROTECTION12.1ENSURING THAT OCCUPATIONAL RADIATION EXPOSUR ES ARE AS LOW AS REASONABLY ACHIEVABLE (ALARA)12.1.1POLICY CONSIDERATIONS12.1.1.1Management PolicyUnion Electric Company is co mmitted at the corporate level to maintaining occupational radiation as low as reasonably achievable.
This policy is promul gated in general terms by the Senior Vice President and Chief Nuclear Officer and is implemented by specific procedures and directives at the plant level by the Senior Director, Nuclear Operations. Implementation of the ALARA program will be in accordance with the requirements of 10CFR19 and 10CFR20 and will follow the intent of the guidance prov ided in applicable sections of Regulatory Guides 1.8, 8.8 and 8.10.12.1.1.2Organizational StructureThe Senior Director, Nuclear Operations, th rough the Radiation Protection Department staff, is ultimately responsible for development, implementation, and continuing conduct of the overall plant Radiation Protection program of which the ALARA program is a part. The Manager, Radiation Protection directs the Radiation Protection Department and is responsible to the Plant Di rector for the ALARA program. The Manager, Radiation Protection has the responsi bility and authority for de veloping, impl ementing and managing the plant ALARA program.
The organization of the Radiaton Protection Department is described in Section 12.5.1
.ALARA reviews can be performed by qualif ied nuclear engineeri ng personnel (i.e., Design Engineering, Technica l Support Engineering, Systems Engineering, or Radiation Protection) for plant modifications or maintenance activities.12.1.1.3Application of the Union Electric ALARA Po licy to Plant Operations The Callaway Plant ALARA program is implemented throug h the adherence to Administrative and Radiation Pr otection procedures which cover, but are not limited to, the following subjects:a.Qualifications of and the conduct of operations of the plant radiation protection department.b.ALARA program administration - re viewing job planni ng, job exposure data, radiation work permit comparisons wit h personnel exposure, CALLAWAY - SA12.1-2Rev. OL-21 5/15 procedure reviews, review of design change packages for installation and long term operations and maintenance concerns, and trends of dose data for potential progr ammatic changes.c.Training of personnel in the fundamentals of ra diation protection and in health physics exposur e control procedures.d.Radiation Work Permit Programe.Internal Pers onnel Monitoringf.External Personnel Monitoring g.Area Postingh.Radioactive Material Controli.Radiological Surveys j.Instrumentationk.Radiological Incidentsl.Radiation Work Practices m.Environmental Monitoringn.Respiratory Protection CALLAWAY - SA12.4-1Rev. OL-13 5/0312.4DOSE ASSESSMENTThis section contained the dose assessment to the constructi on workers during the construction of Callaway Plant Un it 2. With the ca ncellation of Callaway Plant Unit 2 in October 1981, this secti on is no longer applicable.
CALLAWAY - SA12.5-1Rev. OL-21 5/1512.5RADIATION PROTECTION PROGRAM12.5.1ORGANIZATION12.5.1.1Radiation Protecti on Program ObjectivesThe objective of the radiation protection program for the Callaway Plant is to maintain the occupational radiation exposure of personnel working at the pl ant as low as is reasonably achievable (ALARA). This objecti ve is accomplished by adherence to the requirements of Title 10 of t he Code of Federal R egulations, Part 20, by following the intent of guidance given in USNRC Regulatory Guides 8.2, 8.8, 8.10, 8.34, 8.35, 8.36 and 1.8, and by using industry acce pted radiation protection practices.
The radiation protection pr ogram is administered by t he organization described in subsections 12.5.1.2 and 13.1.2.2.2 to accomplish the following:a.Identify and review radiation protection training requirements for personnel assigned to work in radiological cont rolled areas commens urate with their duties, responsibilities, and the degree of radiation hazards anticipated.
Inform these personnel of methods for maintaining occupational radiation exposure ALARA and assist them in carrying out t heir radiation safety responsibilities.b.Evaluate and review the radiological status of the plant by monitoring radiation, contamination and airborne radioactivity levels to control or eliminate radiological hazards.c.Control external and in ternal radiation exposure of perso nnel through the implementation of radiological controls during operations and maintenance.d.Review and evaluate radiation prot ection records and appropriate plant operating and maintenance procedures fo r methods to reduce radiation exposure to personnel.e.Maintain and evaluate personnel exposure reco rds to ensure that occupational radiation exposures are maintained ALARA.f.Maintain control of radioactive mate rials on-site and maintain releases of radioactive materials in effluent s to unrestricted areas ALARA.g.Evaluate and review t he swipe samples from instruments containing radioactive sources that other Union Electric fossil power plants have provided.
CALLAWAY - SA12.5-2Rev. OL-21 5/1512.5.1.2Organization of the Radiation Protection Department The experience and qualificatio ns of the personnel respons ible for administering the radiation protection pr ogram are presented in Section 13.1.3.1. The responsibilities of the personnel are discussed in Section 13.1.2.2.2
.The Radiation Protection Department is comprised of personnel in the following classifications:a.Manager, Radiation Protectionb.Supervising Health Physicist c.Health Physicists/Nuclear Scientists d.Radiation Protection Supervisorse.Radiation Protection Techniciansf.Radiation/Chemical Helpers 12.5.1.3Personnel Training The training of plant per sonnel in radiation prot ection is described in Section 12.5.3.4. 12.5.2EQUIPMENT, INSTRUMENTATION AND FACILITIES12.5.2.1Equipment and InstrumentationRadiation Protection instrumentation and equipment will be availabl e for the assessment of plant radiological conditions and to support the oper ation of the Ca llaway Plant Radiation Protection Program.
The three classifications of equipment that will be utilized in radiological monitoring and su rveillance activities include:a.Installed Equipmentb.Laboratory Equipmentc.Portable EquipmentInstalled equipment includes bot h the in-plant area radiat ion monitoring system and the process and effluent radioacti vity monitoring system. Laboratory equipment consists of analytical instrumentation used to analyze and quantify radioactivity. Portable equipment includes portable radiation detection instrumentation, ai r samplers and personnel dosimetry used for performing radiation and contaminat ion surveys, airborne radioactivity monito ring and sampling and personnel monitoring.
CALLAWAY - SA12.5-3Rev. OL-21 5/15Portable and laboratory instrumentation used in the radiation protecti on program will be selected in accordance with the following criteria:a.Ability to measure the quantity of interest to an acceptable degree of precision and accuracy.b.Ease of operation, ma intenance, and calibration.c.Appropriate sensitivity and range for various operati onal situations, including normal operations, anticipated operati onal occurrences and accident conditions, as determined by the requirements of applicable regulations.d.Operational reliability.12.5.2.1.1Installed Radiat ion Monitoring EquipmentInstalled area radiation monito rs and continuous air monitors are described in Section 12.3. Process and effluent monitors are described in Section 11.5.12.5.2.1.2Radiation Protection Laboratory Instrumentation Radiation protection laboratory instrumentation will in clude a gamma spectroscopy system, a liquid scintillation counter, a gas flow pr oportional c ounter and a geiger-mueller type counting system. Additional info rmation on radiation protection laboratory equipment is provided in Table 12.5-1. The primary loca tion of radiation protection laboratory equipment will be the count room, 1984' elevati on of the Control Building. However, additi onal counting equipment will be available at other plant locations including the Emergency Operations Facility. 12.5.2.1.3Portable Radiation Detection InstrumentationPortable radiation detection instrumentation is described in Table 12.5-2 which includes information on the type, range, accuracy and typical quantities of instruments. Survey instruments will be available in-plant to facilitate access. Instruments requiring calibration or repair will be identified as out-of-service and segregated from in-use equipment.12.5.2.1.4Portable Ai r Sampling EquipmentPortable air sampling equipment includes high and low-volume air samplers capable of accepting particulate filters and charcoal cartridges for grab samp les of radioactive particulates and iodine. In addition, portable continuous air monitors, typical of that described in Table 12.5-2 , will be used for continuous surveill ance of airborne radioactivity levels. Air sampling instruments are calibrat ed periodically in accordance with an established calibration program.
CALLAWAY - SA12.5-4Rev. OL-21 5/1512.5.2.1.5Instrument CalibrationCalibration of portable and laboratory radi ation protection instrumentation will be performed in accordance with an established calibration program. Requirements of this program include as a minimum:a.written procedures for operation a nd calibration of each instrument.b.a mechanism for tracking and recall of instruments for calibration.c.established calibration frequencies fo r each instrument and recalibration following maintenance and repair that could change the instrument performance characteristics establishe d during the prev ious calibration.d.use of calibration standar ds which are traceable to the National Institute of Standards and Tec hnology (NIST).e.required calibration a ccuracies and tolerances.f.periodic response checking of instruments to verify continuing proper operation.g.maintenance of records document ing calibration activities.h.tagging and labeling of instruments.12.5.2.1.6Protective Clothing Protective clothing is prescribed and issued to plant personnel by the radiation protection staff based upon the actual or potential radiological condit ions expected for the job assignment. Protective clothing stations are established at strategic loca tions within the plant as required to ensure efficient operations and to preclude the spreading of contamination. Protective clothing avai lable at the plant in cludes the following:a.Coveralls.b.Caps and hoods.c.Shoe covers.
d.Plastic, rubber, and cotton gloves.
e.Plastic suits.f.Face shields/masks CALLAWAY - SA12.5-5Rev. OL-21 5/1512.5.2.1.7Respiratory Protection Equipment Respiratory protection equipment is available to plant personnel and is also prescribed and issued to individuals as required by actual or potentia l radiological conditions of the work assignment. The Callaway Plant Resp iratory Protection Pr ogram follows the guidance of Regulatory Guide 8.15 and complies with the requirements of 10 CFR Part
- 20. Respiratory devices av ailable at the Callaway Plant include th e following:a.Full-face respirators with high-efficiency partic ulate and/or charcoal filters.b.Full-face respirators with supplied air.c.Hoods with supplied air.d.Full-face respirators in self-contained breathing apparatuses. e.Half-face respirators with HEPA and/or charcoal filters.Purchases of respiratory protection equipment such as air purifying respirators, supplied air respirators, self-contained breathing apparatuses and accessory equipment are made following the guidance given by 30 CFR Part 11 and the NIOSH Certified Equipment Manual.12.5.2.1.8External Dosimetry
All personnel entering the plant's Radiological Controll ed Area (RCA), are monitored for occupational radiation dose in accordance with the requirements of 10CFR20. Optical Stimulated Luminescent Dosi metery (OSL) is the primar y method of monitoring occupational radiation dose from exposure to beta and photon radiat ion. CR-39 is the primary method of monitoring occupational radiation dose from ex posure to neutron radiation. Primary dosimetry is processed by a vendor that is accredited by the National Voluntary Laboratory Accr ediation Program (NVLAP) in accordance with the requirements of 10CFR20. An appropriate secondary moni toring device is issued to each individual who enters the RCA. Portable neutron survey instruments and stay time calculations are used as a secondary method for determi ning neutron dose. Exposure records for each individual will be maintained in accor dance with Regulatory Guide 8.7. 12.5.2.1.9Inter nal Dosimetry Internal radiation exposure is assessed using either in vi vo counting, sp ecimen analysis or calculational techniques based on surveillance program data. The methodology for internal radiation exposure assessment will follow the guidance of the International Commission on Radiological Pr otection (ICRP). The concepts, models, equations and assumptions used for internal radiation exposure assessment will reflect th e appropriate recommendations of the ICRP.
CALLAWAY - SA12.5-6Rev. OL-21 5/15An in vivo counter is located at the plant for measurement of plant per sonnel, visitors, or support personnel. The in vivo counter will provide prelim inary background information, periodic evaluation, and emergency capability for detecting internal exposure conditions. Assessment of internal radiation exposure of those individuals who regularly enter areas where the potential exists for inhalation, inges tion, or absorption of radioactive material will be performed annually.12.5.2.2Facilities12.5.2.2.1Radiation Protection Facilities The radiation protection facili ties consist of a radiation protection office, counting room, hot laboratory, and personnel decontamination shower lo cated at elevation 1984' of the Control Building.12.5.2.2.2Access Control Facilities Radiation protection facilities at the 1984' level of the Cont rol Building are designed to function as the primary access point for entry to the radiological c ontrolled areas of the plant. The plant arr angement is such that traffic between radiological controlled areas and uncontrolled areas is routed through this access cont rol area. The purpose of the access control point is to prov ide positive control over acce ss to radiologica l controlled areas for exposure control purposes and to prevent the spread of contamination to uncontrolled areas of the plant. Contamination control features of access control include controlled entrance and exit locations with contamination m onitoring provisions at the exit of the radiologi cally controlled area.
In addition to the pr imary access control point described above, auxiliary radiological control points can be establis hed at necessary loca tions within the pl ant for the purpose of personnel and contaminati on control. These radiological control points are equipped with protective clothing, portable survey equipment and other radiation protection materials and are established at locations of strategic importance for contamination and exposure control.12.5.2.2.3Equipment Decontamination Facilities Equipment used for the cleaning and maintenance of contaminated parts, instruments and equipment is located at elev ation 2000' adjacent to the Auxiliary Building. When hand decon is not practical (such as for high level of contam ination or ALARA constraints), special cleaning equipmen t will be used for removing radioactive contamination from items requiring repair or maintenance.
CALLAWAY - SA12.5-7Rev. OL-21 5/1512.5.2.2.4Personnel Decontamination FacilitiesA personnel decontamination area separated from normal showerin g facilities is provided on the 1984' leve l of the Control Building in the access control area. Facilities provided include decontamination sinks, shower, and a drying and monitoring area.12.5.2.2.5Radiation Pr otection Count RoomA counting room is located near access control and is used for radioactivity analyses. A separate hot laboratory is provided for sample preparation. The count room is equipped to perform routine analyses required for per sonnel protection, su rveys, and related radiation protection functi ons. The counting room is equipped with the necessary instrumentation to perform r outine counting on plant radioactivity samples (water, air, swipe survey, etc.). 12.5.2.2.6Laundry Decont amination Facility The laundry decontamination fa cility is located on the 2 000 elevation adjacent to the Auxiliary Building. It is equipped with washer-extractors, dryers, a clean laundry monitor and clothes sorting tables.12.5.2.2.7Radiation Protection OfficeThe radiation protection office is located adjacent to the entrance to the access control area and will allow radiati on protection personnel to obse rve personnel entering and leaving the radiological controlled area. The radiation protection office provides work space for radiation protection personnel to perform routine administrativ e activities such as completing survey records and generating RWP'
- s. It also provi des a location from which plant radiation protec tion activities can be coordi nated and plant personnel can obtain information concerning work activi ties or plant radi ological conditions.12.5.2.2.8Locker an d Change Facilities Change areas consisting of lockers and ben ches are provided with in the plant. A storage area for protective clothing is prov ided adjacent to t he change areas, thus allowing personnel to dress-out for activities near the contaminated areas.12.5.2.2.9Calibration Facilities Instrument calibration faciliti es are provided for the calibration, rout ine maintenance and storage of portable radiation protection instrumentatio
- n. The radiation protection calibration facilities will be equipped with fixed and portable calibr ation sources of sufficient range and strength to allow calibration of most portable radiation detection instruments and personnel dosimetry devic es used at the Callaway Plant.
CALLAWAY - SA12.5-8Rev. OL-21 5/1512.5.2.2.10Dosimetry Pr ocessing Facilities Primary dosimetry is processed by a vendor.12.5.2.2.11Respiratory Protection Facilities On-site facilities se t aside for respiratory protec tion functions in clude areas for conducting quantitative fit te sting and an area for adminis tering pulmonary function testing as part of the medical qualific ation program for respirator users.
Other on-site areas ar e set aside for washing, drying, repair and storage of respirators which are used for supporting day to day work. The plant wa rehouse serves as the bulk storage point for receiving and storing respiratory protec tion equipment held in reserve for future use.12.5.2.2.12Respirator Issue and Storage Area A Respirator Issue Area is provided within the Access Control Area for issuing of respirators to individua ls as required by actual or potent ial radiological conditions of the work assignment.12.5.3PROCEDURES The radiation protection administrative, departmental and technical procedures used at the Callaway Plant are an integral part of the plant ALARA program. The provisions and guidance of Regulatory Guides 8.2, 8.7, 8.8, 8.10, 8.13, 1.8, and 1.39, are used in the development of the plant radiation protection procedures. Exception to Reg. Guide 1.33 has been submitted under separate correspondence to the NRC.
Procedures for personnel radiat ion protection shall be prep ared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving pers onnel radiation exposure.12.5.3.1Radiation Surveys Radiological surveys are per formed periodically during operation and shutdown at the Callaway Plant for the assessm ent of radiation-fields, radioactive contamination, and airborne radioactivity levels. Portable instruments, equi pment, and techniques for surveys are addressed in depart ment and technical procedures.12.5.3.1.1Radiation - Surveys Routine measurements of radiation field intensities are performed in accessable areas of the plant, using portable instrumentation appropriate for the type of radiation present.
These surveys are performed on a schedule which is determined by:
CALLAWAY - SA12.5-9Rev. OL-21 5/15a.Actual or potentia l radiation levels.b.The variability of radiation level.c.The occupancy fact or of the location.
Radiation surveys are con ducted to monitor and detect any significant changes in radiation levels and to evaluate the effectiveness of radiolog ical controls. High radiation areas are usually surveyed upon entry and periodically thereafte r while work in the area is in progress. Additional radiation surveys are performed as necessary to evaluate and minimize personnel radiatio n exposure during operationa l and maintenance functions.Records are maintained of the results of these surveys, by location, so that trends in the radiation level are readi ly identified. Result s of these radiation surveys are correlated with the readings of the Area Radiation Monitoring System, where appropriate.
Prior to the initiation of any operation for which a radiation work permit is required, a survey will be made of the r adiation field in the vicinity where the operat ion is to be performed. The results of this survey are recorded on the r adiation work permit.12.5.3.1.2Surface Contamination SurveysContamination surveys are per formed on a regularly schedul ed basis in all accessible areas during operation and shutdown to evaluate the hazard due to removable and non-removable radioactive cont amination. Locations of importance for controlling the potential spread of contaminat ion are surveyed at a frequ ency commensurate with the contamination hazard present using the "smear" technique or an appropriate portable instrument. These survey frequencies could increase or decrease depending on factors such as the actual or potential radioactive concentration, occupancy factor, location, and plant status.Contamination surveys are also made on personnel, equipment, and materials from time to time as necessary to ensure complete control over the levels and spread of removable contamination. Appr opriate techniques, instruments, and frequen cy of surveys will be delineated in the radiati on protection procedures.The results of these surveys are recorded and tabulated by location so that trends in the data may be readily observed.12.5.3.1.3Airborne Radioactivity Surveys Surveys to assess airborne r adioactivity levels are perform ed to ensure 10 CFR Part 20 limits are not exceeded, engine ering controls are functioning, and resp iratory protection techniques are adequate.
CALLAWAY - SA12.5-10Rev. OL-21 5/15The results of routin e airborne radioactivity surveys ar e recorded by location so that trends in the radiation leve ls can be readily identified.
Air sampling surveys are performed on a routi ne basis in areas with both a high occupancy factor and a high potential for the existence of airborne radioactivity. Ot her locations are surveyed periodically depending on the significance of the location as a source of occupational radiation exposure from airborne radioactivity. These survey frequencies could increase or decrease depending on factors such as the actual or potentia l radioactive concentration, occupancy factor, location, and plant status.
Airborne samples are collect ed and analyzed for operations and maintenance activities which are expected to produce airborne radioactivity.12.5.3.2Radiation Exposure ControlIn order to control occupa tional radiation exposures and the spread of radioactive contamination, varyin g degrees of access to plant areas will be established. Area access and exposure time for personnel will be determined by the necessity for such access and by radiation and contamination levels.Areas of the plant are subject to access control restrictions proprortionate to the potential for radiation exposu re in each area. The particular access control requirements for each area will be specified by Radiation Protection Supervision. A radiological controlled area is any area where actual or potential radiological hazards exis t in the form of radiation, contamination, airborne radioactivity, or stored r adioactive materials.
Radiation areas, contamination areas, high radiation areas, very high radiation area, airborne radioactivity areas and radioactive material areas will be cons idered radiological controlled areas.
Radiological controlled areas will be posted and controlled in accordance with the requirements of 10CFR20. A ccess to such areas is cont rolled as warranted by the degree of radiological hazard involved via use of access control, auxiliary radiological control points a nd the radiation work permit program.
The plant arrangement is such that traffi c between radiol ogical controlled areas and uncontrolled areas is r outed through access c ontrol. The access control facilities for normal traffic are located in the control building where peopl e entering and leaving all controlled areas will check for contamination. Within t he controlled area, access is controlled by utilizing lock ed and/or annunciated doors and gates, fences, alarms, rope barriers, and the posting of signs.
High radiation areas in whic h the radiation field is greater than 100 mrem/hr but less than 1000 mrem/hr wil l be posted as a high radiation area and entrance into the area will be controlled by the radiation work permit program. High radiation areas in which the radiation fiel d is greater t han or equal to 1000 mr em/hr will be provided with locked doors to prevent unauthorized entry.
For individual areas accessible to personnel that are lo cated within large areas, such as the Containment, where no enclosure exists for purpose of locking , and where no enclosure can be reasonably constructed, the individual area shall be barricaded, conspicuously posted and a flashing CALLAWAY - SA12.5-11Rev. OL-21 5/15 light activated as a warning de vice. The flashing light may be omitted if positive control of access to the area is provided.Very high radiation areas with radiation levels in excess of 500 rads in one hour at one meter from the radiation sour ce will be conspicuously posted as a very high radiation area. Entrances to these areas will be barr icaded and locked.
Administrative measures for access cont rol in high radiat ion areas include the requirement for issuance of a radiation work permit for any operation to take place in such an area. Depending upon the operation, a radiation protection technician may be assigned to supervise stay-tim e and make appropriate surve ys while the operation is in progress.The radiation work permit (RWP) program will be established as an integral part of the ALARA policy implementation.
This program will be the responsibility of the Manager, Radiation Protection. In addi tion to entries into and work performed in high radiation areas, RWP's may be required for the following type activities:a.Entries into designated airborne radi oactivity areas, r adiation areas, contamination areas and radioacti ve material storage areas. b.Work involving maintenance or other adjustments to any system or component which contains, stores, transports or collects radioactive materials.c.Other activities which in the judgement of Radiation Protection Supervision warrant the issuance of a radiation wo rk permit prior to initiating the operations.
The radiation work permit st ipulates the purpose of entry , work location, radiation conditions, surveillance and dosimetry requirements, stay-t ime, protective clothing and equipment, and other procedural requirement s and precautions.
The primary objectives of the radiation wo rk permit program are to insure that:a.Radiological conditions are k nown as accurately as possible.b.Proper protective measures are taken to safely perform the r equired duties.c.Each person involved in these operations acknowledges his understanding of the radiation condition s, the protective and sa fety measures required, and his willingness to follow the radiation work permit requirements.d.Appropriate supervisors are aware of the task being performed, the radiation conditions, and the prescribed pr otective measures.
CALLAWAY - SA12.5-12Rev. OL-21 5/15e.A means for maintaining the account ability of personnel is provided.12.5.3.3Contamination ControlAreas that may be contaminat ed with radioactive material will be decontaminated to a level that is reasonably achi evable using available met hods and techniques. Since the complete removal of surface contamination from parts of the plant is a practical impossibility, certain plant areas may be designated as "contamination areas". These areas will be posted with the proper warni ng placards and barricaded.
Entry to these areas will be contro lled by radiation prot ection personnel and allowed only through the issuance of an appr opriate radiation work permit. Personnel, equipm ent, and material exiting from contaminated areas will be monitored to prevent the spread of contamination to clean areas. All contam inated equipment will be properly packa ged and identified before removal from a contami nated area. At access contro l facilities near the radiation protection office, a final survey will ensur e that all per sonnel, material, and equipment are free of significant contam ination, and thus will provide assurance that no radioactive material will spr ead to the uncontrolled areas of the plant.12.5.3.4Radiation Protection TrainingThe Manager, Technical Training is responsi ble for the radiation protection training program at the Callaway Plant. Plant personnel, both permanently assigned and temporary, receive training in the principles of radiation protecti on commensurate with the individual's job function and the anticipat ed radiation hazards.
The radiation protecti on training program will include as a minimum the following topics:a.Fundamentals of radiation and radioactivity.b.Biological effects of radiation on humans.c.Measurement of radiation and radioactivity.d.Principles and techniques of radiation protection.e.Use of protective clothing and equipment.f.General regulatory and s pecific facility license radiation protection requirements.g.Emergency planning.
h.ALARA program - concepts and methods.
The radiation protecti on training program will maintain the proficiency of these employees through periodic retr aining lectures and exercises.
CALLAWAY - SA12.5-13Rev. OL-21 5/1512.5.3.5Personnel Dosimetry12.5.3.5.1External Radiation Dosimetry See Section 12.5.2.1.8
.12.5.3.5.2Internal Ra diation Dosimetry See Section 12.5.2.1.9
.12.5.3.6Airborne Radiati on Evaluation and Control Airborne radioactivity will be routinely assessed using local sampling, portable continuous air monitors , and the fixed radiation monitoring system. Airborne radioactive materials (particulates, noble gases, halogens, tritium) will be sampled and analyzed using appropriate techniques. Since local sampling will provide better estimates of airborne contamination levels existing in a work area than wi ll a monitor reading, such special air sampling will be us ed in the radiation work per mit program to keep radiation exposure due to airborne radioactivity ALARA. Portable continuous air monitors and fixed airborne radioactivity monitors will be used to provide alarm indications and additional information which will be used wit h local sampling for the assessment of airborne radioactivity.
Control of airborne radioactivity levels wi ll be assured through the use of the plant's heating, ventilation, and air conditioning (HVAC) systems, portable air movers and filters. The HVAC systems provide contro lled air movement and filtra tion for those areas with a high potential for airborne radioactivity problems. Specia l control techniques can be used, such as plastic enclosu res which isolate and vent ai rborne radioactivity arising from special work projects. Respiratory pr otection equipment will be available for use in those situations where airbor ne radioactivity hazards exis t and other cont rol measures are inadequate at t he location and time.12.5.3.7Respiratory Protection ProgramThe respiratory protection program will be developed through the guidance of Regulatory Guide 8.15 and will satisfy the requirements of 10CFR20. As a minimum, the respiratory protection program will provide the following:a.Procedures to implement the selection, use, maintenance and storage of respiratory protection devices.b.Adequate facilities to support the storage, issue, cleaning and maintenance of respiratory protection devices.c.Use of only NIOSH certified or NRC approved equipment.
CALLAWAY - SA12.5-14Rev. OL-21 5/15d.Medical certification prog ram for respirator users.e.Periodic review of the overall effectiveness of the respiratory protection program via the inter nal dosimetry program.12.5.3.8Radioactive Materials Handling Methods and procedures will be developed to control, handle, and store by-product, source, and special nuclear material in accordance with regulatory requirements.Subjects to be covered by these procedures will incl ude the following:a.Storage of radioactive material in appropriately shielded, labeled and secured containers.b.Minimizing the distance that radi oactive samples are transported by personnel and the use of special ex tension and remote handling tools when applicable.c.Use of shielded sample transporters as appropriated.Periodic testing to verify the integrity of the sealed material.e.Emergency procedures which detail the proper actions to be taken in the event of leakage and spills.f.Accountability of any by-produ ct or special nuclear material.
CALLAWAY - SA Rev. OL-18 12/10TABLE 12.5-1 RADIATION PROTEC TION LABORATORY EQUIPMENTINSTRUMENTRADIATIONDETECTEDDETECTOR TYPICAL QUANTITYLOCATIONREMARKSGamma Spectroscopy SystemGammaHPGe w/graded shield4Counting Room and/or Maintenance Training Annex/
Operations Support FacilityProvides Gamma Isotopic analysis capabilities Gas Proportional CounterAlpha, Beta, Gamma Gas Flow Proportional1Counting RoomUsed for counting smears, effluent and radio chemistry
samples.Liquid Scintillation CounterBeta---1Counting LabTritium determinationIn Vivo CounterGammaNaI (TI) and/or HPGe1In Vivo Count Room Central Processing FacilityPersonnel In Vivo Counting; MultidetectorsNote:Sensitivities of this analytical instrumentation are dependent upon counting parameters such as sample geometry, count time and background, however, equipm ent from various manufacturers will be evaluated to ensure that the equipment when purchased will be sufficiently sensitive to perform the tasks for which it was intended. Instruments will be selected to satisfy m easurement and reporting requirements in effect at the ti me the equipment is ordered.
CALLAWAY - SA Rev. OL-15 5/06TABLE 12.5-2 PORTABLE RADIATION PROTECTION EQUIPMENT TYPE TYPICAL DETECTOR TYPE 1APPROXIMATE RANGE ACCURACY TYPICAL QUANTITYLOCATIONPortable Count Rate Meter/
Frisker Geiger-Mueller/ Scintillation 0-500,000 CPM 10% FS10See Note 3Low-Range Survey MeterGeiger-Mueller/
IIonization Chamber 0-2 R/hr/
0-5 R/hr 10% FS25 High-Range Extendable Probe Survey MeterGeiger-Mueller0-1000 R/hr 10% FS 4Mid-Range Survey MeterIGeiger-Mueller/
IIonization Chamber 0-50 R/hr 0-100 R/hr 10% FS5High-Range Survey MeterIGeiger-Mueller/
IIonization Chamber 0-1000 R/hr IIndication 20% FS3Neutron Survey MeterBF Tube Inside Polyethylene Sphere 0.2 mrem/hr 10rem/hr 10% FS4 Ultra-High Range Survey Meter Geiger-Mueller/
IIonization Chamber 0-10,000 R/hr 10% FS2Alpha Count Rate Meter/
FriskerScintillation0-500,000 CPM 10% FS5Portal Monitor/Personnel Contamination Monitor Gamma Scintillation/
Gas Flow ProportionalVariable-----6Beta-Gamma Count Ratemeter/FriskerGeiger-Mueller0-500,000 CPM 10% FS20Electronic DosimeterSolid State0-100 R/hr/ 0-1000R 10% FS250 CALLAWAY - SATABLE 12.5-2 (Sheet 2)
Rev. OL-15 5/06 Electronic Dosimeter ReaderNot ApplicableNot ApplicableNot Applicable 8See Note 3Calibration Transfer InstrumentIIonization ChamberVarious 5%1Portable Area MonitorIGeiger-Mueller/
Ionization Chamber/Solid State 0-2 R/hr 0-100 R/hr 25% Max.5Gamma Survey MeterNaI0-500k CPM 10%2High Volume Air SamplerNot Applicable> 15 CFM 20% 5Low Volume Air SamplerNot Applicable0-3 CFM 20%15Portable Continuous Air Monitor (3 channel type)NaI (I-131); Beta Scintillation (Particulate and
Gaseous)1E-11 to 1E-5 (I-131 and particulate) 1E-11
to 1E-1 (gaseous) 20% of Indication 4Note 1:The detector types listed are typical of the instrumentation used. As instrumentati on technology improves, an equivalent or better type of instrumentation may be substituted.Note 2:The quantities listed for each type of instrumentation ar e the typical numbers calibrated and ready for use.Note 3:Instrumentation is located in the RP Facilities on 1984' elevation of the Control Building, the Calibration Facilities, Dosimetry Processing Facilities or at specific work lo cations in the pl ant while in use.Note 4:The above information is referenc ed in the Radiological Em ergency Response Plan, Sect ion 6.7.3, and complies with Regulatory Guide 1.97.
TYPE TYPICAL DETECTOR TYPE 1APPROXIMATE RANGE ACCURACY TYPICAL QUANTITYLOCATION