ML20137G173
| ML20137G173 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 03/20/1997 |
| From: | Quennoz S PORTLAND GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20137G158 | List: |
| References | |
| TPP-20-2, NUDOCS 9704010346 | |
| Download: ML20137G173 (91) | |
Text
m Portland General Electric Company Trojan Nuclear Plant Level 1 Controlled Distribution QUALITY-RELATED Mointained by Document Control Do not remove this document for field work )
l TROJAN PLANT PROCEDURE TPP 20-2 RADIATION PROTECTION PROGRAM l,
Revision 6 THIS PROCEDUREIS A 1 PDTS 5.7.1.1 i IMPLEMENTING PROCEDURE Responsible Department: Radiation Protection i I
Approved By: - # ;" W - h> Date: !'N 97 General Manager, Trojan P4dnt Effective Date: 3/.2o/97 9704010346 970320 PDR ADOCK 05000344 W PDR
i RADIATION PROTECTION PROG 3AM i l
TABLE OF CONTENTS SECTION PAGE 1.0 INTENT . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.0 SCOPE
. . . . . . . . . . . . . . . . . . . . . . . . . 3 1
{
3.0 DEFINITIONS . . . . . . . . . . . . . . . . . . . . . . 3 1
4.0 PROCEDURE . . . . . . . . . . . . . . . . . . . . . . . 13 4.1 Management Policy . . . .. . . . . . . . . . . . . 13 4.2 Radiation Protection Program Procedures . . . . . . 13 4.3 Radiation Protection Training and Qualification . . 15 4.4 ALARA Program . . . . . . . . . . . . . . . . . . . 18 4.5 Dose Controls . . . . . . . . . . . . . . . . . . . 26 4.5.1 Administrative Dose Control . . . . . . . 26 4
4.5.2 Radiation Work Permits (RWPs) . . . . . . . 31
- 4.5.3 Area Postings . . . . . . . . . . . . . . 33 4
4.5.4 External Dosimetry . . . . . . . . . . . 39 4.5.5 Internal Dose Control and Monitoring . . . . . . . . . . . . . . . 42 4
j 4.5.6 Dose Control for the Declared Pregnant Woman . . . . . . . . . . . . . 44
, 4.5.7 Dose Control for Minors . . . . . . . . . 46 [
4.6 Respiratory Pro,tection Program . . . . . . . . . . 46 '
4.7 Radioactive Material Controls . . . . . . . . . . . 51 i 4.8 Radiological Surveys . . . . . . . .. . . . . . . . 66 l 4.9 Instrumentation . . . . . . . . . . . . . . . . . . 72 !
4.10 Control of Exposure to the Public . . . . . . . . . 76 4.11 Review, Audit, and Performance Analysis . . . . . . 77 4.12 Reports and Records . . . . . . . . . . . . . . . . 85 4.13 Planned Special Exposures (PSE) . . . . . . . . . . 88
5.0 REFERENCES
. . . . . . . . . .N . . . . . . . . . . . . 88 5.1 External Commitments . . . . . . . . . . . . . . . 88 5.2 Standards, Regulations, and Guidelines . . . . . . 89 5.3 Procedures . . . . . . . . . . . . . . . . . . . . 90 ;
5.4 Calculations . . . . . . . . . . . . . . . . . . . 91 5.5 Source Documents . . . . . . . . . . . . . . . . . 91 6.0 RESPONSIBILITIES . . . . . . . . . . . . . . . . . . . . 91 4
7.0 RECORDS . . . . . . . . . . . . . . . . . . . . . . . . 91 TPP 20-2 Revision 6 Page 2 of 91
, RADIATION PROTECTION PROGRAM 1.0 INTENT
- The Trojan Nuclear Plant Radiation Protection (RP) Program documents.the program for controlling and minimizing ionizing radiation exposure to Portland General Electric Company (PGE) personnel and members of the general public within the Plant. This procedure represents the radiological guides, limits, and procedures established at the Trojan Nuclear Plant to maintain radiation exposures As Low As Reasonably Achievable (ALARA). These guides and "
limits are based upon the Code of Federal Regulations, applicable Nuclear Regulatory Commission (NRC) Regulatory Guides, and PGE management policy. This Trojan Plant ,
Procedure (TPP) 20-2 and Trojan Plant Directive (TPD) 20-1, -
Radiation Protection Program Policies, are used as the basis documents for RP Program implementing procedures.
TPD 20-1 and TPP 20-2 establish the policies, standards, and responsibilities for ensuring that these guides, limits, and procedures are adhered to.
2.0 SCOPE The requirements of this procedure apply to all personnel !
in the Nuclear Divi.sion and others performing work under (
the purview of the Trojan Nuclear Plant RP Program.
t 3.0 DEFINITIONS For the purposes of this document and the RP procedures, the following terms are defined:
3.1 Airborne Radioactivity Area Any room, enclosure or area in which airborne radioactive materials exist either in concentrations in excess of 30%
(0.3) of the Derived Air Concentrations (DAC) specified in Appendix B to 10'CFR 20, or to such a degree that an individual present in the area without respiratory protective equipment could exceed, during the hours an individual is present in a week, an intake of 0.6% of the Annual Limit on Intake (ALI), or 12 DAC-Hours.
TPP 20-2 Revision 6 Page 3 of 91
3.2 ALARA ALARA is an acronym for "as low as is reasonably achievable" and means making every reasonable effort to maintain exposures to radiation as far below the dose limits in 10 CFR 20 as is practical consistent with the purpose for which the activity is undertaken, taking into account the state of technology, the economics of improvements in relation to the state of technology, the economics of improvements in relation to benefits to the public health and safety, and other societal and socioeconomic considerations, and in relation to the use of radioactive materials in the public interest.
3.3 Analysis To study or determine the nature and relationships of a whole to its component parts by quantitative measurement.
3.4 Annual Limit on Intake (ALI)
The derived limit for the amount of radioactive material taken into the body of an adult worker by inhalation or ingestion in a year. ALI is the smaller value of intake of a given radionuclide in a year by the reference man that would result in a committed effective dose equivalent of 5 rems, or a committed dose equivalent of 50 rems to any individual organ or tissue. ALI values for intake by ingestion and by inhalation of selected radionuclides are given in Appendix B to 10 CER 20. .
3.5 Annual Performed at least once every 365 days 125 percent.
3.6 Bioassay The determination of kinds, quantities or concentrations, and, in some cases, the locations of radioactive material in the human body, whether by direct measurement (in vivo counting) or by analysis and evaluation of materials excreted or removed from the human body (in-vitro analysis).
3.7 Biweekly Performed at least once every 14 days 125 percent.
TPP 20-2 Revision 6 Page 4 of 91
3.8 Calendar Quarter A period of time equal to one-fourth of the calendar year (approximately 13 consecutive weeks), providing that the beginning of the first quarter in a year coincides with the ,
starting date of the year and that no day is omitted or I duplicated in consecutive quarters.
3.9 Calibration l A comparison of the response of a piece of equipment with a standard or another piece of equipment of equal or tighter tolerance to detect, quantify, and record inaccuracies, and '
to eliminate those inaccuracies by adjustment. Also, it is i the strength or activity of a radiation source relative to a standard. I i
3.10 Certify To attest as meeting a standard, condition, or status by using judgment based on measurement, actions, records, or opinion.
3.11 Checks The act of inspecting for satisfactory condition, accuracy, safety, or performance of a piece of equipment.
Documentation may or may not be necessary. ;
3.12 Check Source A radioactive source, not necessarily calibrated, which is used to confirm the continuing satisfactory operation of an instrument.
I Committed Dose Equivalent (CDE) 3.13 The dose equivalent to organs or tissues of reference that will be received from an intake of radioactive material by an individual during the 50-year period following the intake.
3.14 Committed Effective Dose _ Equivalent (CEDE)
The sum of the products of the weighting factors applicable to each of the body organs or tissues that are irradiated and the committed dose equivalent to these organs or tissues.
TPP 20-2 Revision 6 Page 5 of 91
3.15 Continuous Radiation' Protection Technician Covarage Assignment of a specific technician to oversee and be responsible for providing positive control over the {
activities of a specific job. A technician may be required to perform continuous coverage on two or more jobs in the same general area provided he/she is familiar with RP !
requirements, radiological conditions, and scope of the job (s) being worked. This does not mean line-of-sight coverage is required at all times.
3.16 Controlled Area i An area, outside of a restricted area but inside the site l boundary, access to which can be limited by PGE for any reason. '
3.17 Daily Performed at least once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> +25 percent.
J 3.18 Declared Pregnant Woman A radiation worker who has voluntarily informed RP, in writing, of her pregnancy and the estimated date of conception.
3.'19 Deep Dose Equivalent (DDE)
The DDE, which applies to external whole body exposure, is the dose equivalent at a tissue depth.of I cm (1000 mg/cm),
2 1
3.20 Derived Air Concentration (DAC)
The concentration of a given radionuclide in air which, if breathed by the reference' man for a working year of 2,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> under conditions of light work (inhalation rate 1.2 cubic meters of air per hour), results in an intake of one ALI. DAC values are given in Appendix B to 10 CFR 20, 3.21 Derived Air Concentration Hour (DAC-hour) '
The product of the concentration of radioactive material in air (expressed as a fraction or multiple of the DAC for each radionuclide) and the time in hours of exposure to that radionuclide. 2,000 DAC-hours represents one ALI, equivalent to a CEDE of 5 rems.
TPP 20-2 Revision 6 Page 6 of 91
3.22 Discrete Radioactive Particle )
1 A discrete radioactive particle (DRP) is a small, loose, I highly radioactive particle originating either from irradiated fuel or activated corrosion products. A level of activity considered significant in RP procedures is that which provides 15,000 dpm or greater at 1/2 inch (approximately 1 cm) from the particle with an HP-210 or HP-260 pancake probe.
3.23 Engineering Controls ,
Engineering controls is the term used for the general class of devices and associated methods used to reduce the exposure of personnel to radiation and radioactive material.
3.24 Entrance (Access Point)
Any location through which an individual could gain access to radiation areas or to radioactive materials. This includes entry or exit portals of sufficient size to permit human entry, irrespective of intended use.
3.25 Entry To enter into an area with any portion of the body. If entry into an area is prohibited, this includes a !
prohibition against' reaching into the area, or placing one's head into the area. ;
~
3.26 Evaluation l Generally used to describe the act of determining the significance of worth of a specific entity by careful appraisal and study, such as the status or quantity of contamination or radiation associated with an item or area.
The determination may be quantitative or may be judgmental based on available documentation and known operations.
Documentation of an evaluation is not always required.
3.27 External Dose That portion of the dose equivalent received from radiation .
sources outside the body. '
3.28 Extremity !
An extremity is a hand, elbow, arm below the elbow, foot, knee, or leg below the knee.
TPP 20-2 Revision 6 Page 7 of 91 I
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_ . . . - . . . _ . - . - . = - - - -- - -- - - -
3.29 Eya (Lons) Doso Equivalent (LDE)
The LDE applies to the external dose to the . lens of the eye, and'is taken as the dose equivalent at a tissue depth >
of 0.3 cm (300 mg/cm )2 .
3.30 Fixed Contamination Area An area where fixed radioactive contamination levels exceed 5,000 dpm/100 cm r (1,000 dpm/20 cm ), and the contamination 2
is the only need for radiological controls. -
3.31 Functional Check ,
A quantitative check of the instrument to a known exposure '
rate on the instrument range normally used. Response should be within +20 percent of expected response. '
3.32 High Radiation Area An area, accessible to individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of 100 mrem in one hour at "
30 centimeters (12 inches) from the radiation source i or from any surface that the radiation penetrates. J 3.33 High Radiation Exclusion Area ,
Any area in which t'he general area dose rate is or could become greater than 25 rad / hour.
3.34 Hot Spots Components or items having combined beta gamma contact readings greater than 100 mrem /hr and more than five times the general area dose rates (12 inches from the source) .
3.35 Internal Dose That portion of the dose received from radioactive material taken into the body.
3.36 Measurement Standard An instrument, source, or other system or device maintained and promulgated by or traceable to the National Institute of Science and Technology.
TPP 20-2 Revision 6 Page 8 of 91
3.37 M mbar of the Public An individual in a controlled or unrestricted area. An individual is NOT a member of the public during any period that the individual receives occupational dose.
3.38 Monitor / Monitoring The measurement of radiation levels, concentrations, surface area concentrations or quantities of radioactive material, and the use of the results of these measurements to evaluate potential exposures and doses.
3.39 Monthly Performed at least once every 31 days +25 percent.
3.40 Operational Check A qualitative comparison of an instrument response to a check source or field.
3.41 Periodic Radiation Protection Technician Coverage Assignment of a technician or technicians to provide less than continuous coverage of a job or jobs. Coverage may be at critical job steps, at routine intervals, or at randen intervals.
3 42 Qualify Is generally applied to RP personnel who have met certain predetermined criteria to permit them to perform specific tasks.
3.43 Quarterly Performed at least once every 92 days + or - 25%.
3.44 Radiation Area An area, accessible to individuals, in which radiation levels could result in an individual receiving a dose in excess of 5 mrem in one hour at 30 cm (12 inches) from the radiation source or from any surface that the radiation penetrates.
3.45 Radiological Decommissioning Related Records Radiological decommissioning related records are defined by 10CFR50.75(g) as: " Records of spills or other unusual TPP 20-2 Revision 6 Page 9 of 91
occurrences involving the spread.of contamination in and f around tho. facility, equipment, or site. These records may !
be limited to instances when significant contamination '
remains after any cleanup procedures or when there is
-reasonable. likelihood that contaminants may have spread to ;
inaccessible areas as in the case of possible seepage into '
porous materials such'as concrete. These records must >
include any known information on the identification of '
involved nuclides, quantities, forms, and concentrations." !
These records shall be maintained in accordance with ;
TPP 18-4, Trojan Quality Assurance Records Management !
Program, as discussed in Section 8.1.4 of this procedure. '
3.46 Radiologically Controlled Area (RCA)
Any restricted area where access is controlled for the i purpose of protecting individuals from exposure to ;
radiation or radioactive material; this includes any areas '
which could reasonably become a Radiation Area, High Radiation Area, Airborne Radioactivity Area, Surface Contamination Area, Fixed Radioactivity Area, or Radioactive Material Storage Area. The Main RCA normally includes the Containment Building, pipe facade, Fuel Building, and Auxiliary Building. Local areas outside of this area could also be designated as RCAs.
3.47 Radioactive Material Storage Area i Any area (indoor or' outdoor) or room in which licensed i material is used or stored and which contains any radioactive material in an amount exceeding 10 times the ]
quantity specified in Appendix C to 10 CFR 20. C-vans and transport trailers where closed radioactive material containers are stored, as defined'in RP procedures, are considered radioactive material storage areas, not containers.
3.48 Radiation Worker An individual receiving or expected to receive occupational dose as defined in 10 CFR 20, 3.49 Restricted Area An area, access to which is limited by RP for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive materials. j l
TPP 20-2 Revision 6 Page 10 of 91 1
3.50 Ravicws Describes the act of examination of documents, records, procedures, or operations.
3.51 Shallow Dose Equivalent (SDE)
The SDE, which applies to the external dose of the skin or an extremity, is the dose equivalent at a tissue depth of 0.007 cm (7 mg/cm ) averaged over an area of 1 square 2
centimeter.
3.52 Semiannually Performed at least once per six months 125 percent. An exception to this definition shall be applied in the case of sealed sou~rce leak testing which shall be performed in accordance with license and regulatory requirements.
3.53 Shiftly .
Performed at least once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 125 percent.
3.54 Ship Movement of items to off-site locations.
3.55 Smear A procedure in which a piece of dry cloth, paper (filter paper), or masslin is rubbed on a surface, and its 3
radioactivity measured to determine if the surface is I contaminated with loose radioactive material (synonym for I swipe).
3.56 Surface Contamination Area An area containing loose surface contamination in excess of 1,000 dpm/100 cm2 (50 dpm/100 cm2 for alpha).
3.57 Survey An evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioact've material or other sources of radiation. When appropriate, such an evaluation includes a physical survey of the location of radioactive material and measurements or calculations of levels of
! radiation, or concentrations or quantities of radioactive
! material present.
l TPP 20-2 Revision 6 Page 11 of 91
3.58 Total Effectiva Dosa Equivalent (TEDE)
The sum of the deep dose equivalent (DDE for external exposures) and the committed effective dose equivalent (CEDE for internal exposures).
3.59 Train To impart knowledge through any of several communication techniques.
3.60 Transfer .
Movement of items on-site.
3.61 Unrestricted Area Any area at or beyond the Site Boundary access to which is not controlled by PGE for purposes of protection of individuals from exposure to radiation and radioactive material.., or any area within the Site Boundary used for residential quarters or for industrial, commercial, institutional, and/or recreational purposes.
3.62 Very High Radiation Area (VHRA)
An area,. accessible to individuals, in which radiation lovels could result.in an individual receiving an absorbed dose in excess of 500 rads in one hour at one meter from a radiation source or from any surface that the radiation penetrates.
3.63 Week Seven (7) consecutive days starting on Sunday.
3.64 Weekly Performed at least once every seven calendar days I
+25 percent.
3.65 Whole Body Whole body means, for purposes of external exposure, head, l trunk (including male gonads), arms above the elbow, or {
legs above the knee.
TPP 20-2 l Revision 6 '
Page 12 of 91
3.66 Yonr The period of time, beginning January 1 and ending December 31, used to determine compliance with the provisions of 10 CFR 20.
3.67 Other terms used for RP purposes are defined in applicable regulations of 10 CFR and 49 CFR.
1 NOTE 4.0 Individual steps of this procedure need not be completed in any i specific order. ;
4.0 PROCEDURE 4.1 Management Policy The primary objective of the RP Program is to be prepared to protect the workers, visitors, and the general public l from radiological hazards that have the potential of '
developing during Plant activities. PGE shall provide sufficient qualified staff, facilities, and equipment to maintain the Trojan Nuclear Plant in a radiologically safe manner. PGE is committed to strict compliance with i regulatory requirements, radiation dose limits, and limits l regarding release o'f radioactive materials. In addition, PGE will make every reasonable effort to maintain radiation doses and releases of radioactive materials in effluents to unrestricted areas ALARA. The ALARA philosophy is incorporated into all activities conducted in RCAs and has full management support.
4.2 Radiation Protection Program Procedures 4.2.1 The RP Program should be integrated into all applicable work activities. The RP Program shall be specifically defined and implemented using TPD 20-1, this procedure, and specific implementing procedures.
4.2.2 RP procedures shall be prepared consistent with 10 CFR 20 requirements and shall be approved, maintained, and adhered to for all activities involving personnel radiation exposures.
4.2.3 The development and control of RP procedures shall be in accordance with Trojan Quality Assurcnce Program and applicable TPDs and TPPs.
TPP 20-2 Revision 6 Page 13 of 91
4.2.4 Proccdure Compliance and Stop Work Authority l a. Strict compliance with RP procedures is mandatory. Violation of the RP Program, RP procedures, or any sound RP practice should be identified and handled according to established Plant corrective action systems.
Corrective actions may be taken and may i include, but not be limited to:
- 1) Instruction on corrective actions to prevent reoccurrence.
- 2) Temporary restriction from the RCA.
- 3) Additional RP training including successful completion of applicable exams.
- 4) Permanent restriction from the RCA.
- b. RP personnel may immediately stop work, cancel a Radiation Work Permit (RWP), or remove personnel from the RCA when:
- 2) Personnel are using unsafe RP practices.
- 3) Personnel are in danger of exceeding administrative dose guidelines.
- 4) Unexpected radiological conditions are discovered.
4.2.5 Procedure Designation
- a. RP procedures applicable to other departments should be designated as TPPs.
- b. RP procedures applicable only to RP personnel should be designated as RP procedures or guidelines.
- c. Additional information for procedures and guidelines is provided in Plant implementing procedures.
TPP 20-2 Revision 6 Page 14 of 91
.4. 3 Re.distion Protection-Training and Qualification 4.3.1 General Considerations Personnel who require access to RCAs at the Trojan Nuclear Plant shall receive RP Training in i accordance with 10 CFR 19 and commensurate with the individual's responsibility. The training process and requirements are-addressed in Plant implementing procedures.
4.3.2 Specialized ALARA Training
- a. In addition to Radiation Worker. Training, separate and detailed instructions in advanced radiation work practices should be provided to those workers performing tasks that involve significant exposure to radiation or quantities of radioactive material. This training should typically include workers involved in:
- 1) Activities which involve handling highly radioactive components _that have the potential for creating a significant airborne hazard.
- 2) Activities which. require work in contamination containment devices.
- 3) Grinding, cutting, or similar' operations on highly radioactive systems, components, or piping.
- 4) Work activities that require the use of special tools and equipment for reducing exposures.
I
- 5) Special complex radiation work which j involves skills and training beyond that covered in Radiation Worker Training.
- b. Specialized ALARA Training may include mock-ups, dry runs, prejob briefings, and other special training classes. This training l should be attended by all personnel involved with the task, including craft supervision and jl RP Technicians. The need for specialized I ALARA training should be evaluated during {
ALARA reviews or RWP preparation. i TPP 20-2 !
Revision 6 :
Page 15 of 91 !
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4.3.3 Raspiratory Procection Training j
- a. Specialized respiratory protection. training i
shall be required for all radiation workers who use respiratory protection devices.
- b. Respiratory protection training shall be 2
conducted in accordance with 10 CFR.20, and Plant implementing procedures.
l 4.3.4 RP Technician Training and Qualification a 1
- a. As used in this procedure RP Technician means Chemistry and RP Technician and/or RP Technician. '
i
- b. RP Technicians shall be selected, trained, and ;
i qualified to ensure that they have sufficient knowledge and practical abilities to implement !
the RP Program effectively. !
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- c. RP Technicians may be required to participate l in classroom, self-study, and specific 4
on-the-job (OJT) training. i
- d. Qualification shall include the following:
4
- 1) Re. view and verification of resumes by the RP Manager (RPM) to ensure that personnel have sufficient education and/or experience in the job functions which I
they will be assigned. RP Technicians
' shall, as a minimum, meet the education and experience levels specified in ANSI 18.1 (see reference section), and the qualification requirements for technicians specified in ANS 3.1 will be used as a goal.
- 2) Contract RP Technicians should comply
' with the above qualification requirement
'and should participate in applicable RP Technician training.
4.3.5 Radioactive Waste Management Training Personnel assigned to the task of packaging, loading, and shipping radioactive materials shall be required to attend periodic training commensurate with their assigned duties. This training shall be in conformance with NRC TPP 20-2 Revision 6 Page 16 of 91
Bulletin 79-19, Packaging of Low-Level Radioactive Wasto for Transport and Burial and RP implementing procedures. The training shall include instructions in all applicable federal, state, and local regulations and burial site requirements for classification, packaging, loading, and shipping of radioactive materials.
4.3.6 Radiation Protection Supervisor Training and Qualification RP Supervisors should be trained and qualified in their positions. Minimum qualifications should meet that for comparable position specified-in ANSI N18.1 (see reference section). Additional qualification and training should include:
- a. Supervisors designated as the alternate RPM should meet the education and experience requirements established in NRC Regulatory Guide 1.8 (see reference section).
- b. Training in RP procedures associated with their area of responsibility.
- c. Training in emergency response duties.
- d. Periodic professional training in the form of refresher courses, retraining, conferences, or continuing education to keep abreast of current developments in the. field.
4.3.7 RPM Training and Qualification The RPM qualification and. training should include:
- a. Prior education and experience as required by NRC Regulatory Guide 1.8 (see reference section).
- b. Orientetion on site-specific-programs, management organization and procedures.
- c. Training in. emergency response duties.
i
- d. Periodic professional training in the form of l refresher courses, retraining, conferences, or '
continuing education to keep abreast of current developments in the field.
l TPP 20-2 Revision 6 i Page 17 of 91 en, -
4.3.8 RP Technical Support (RPTS) Personnel Training and Qualification All RPTS Supervisors, Health Physicists, and Engineers should be-trained and qualified in their positions. Minimum qualifications should meet that for comparable position specified in ANSI N18.1 (see reference section). Job descriptions should include qualification criteria and responsibilities. Additional qualification and training should include the following:
- a. Personnel designated as the alternate RPM -
should meet the eddcation and experience l requirements established in NRC Regulatory '
Guide 1.8 (see reference section).
- b. Training in radiation protection and procedures associated with their area of responsibility.
- c. Training in emergency response duties.
- d. Periodic professional training in the form of refresher courses, retraining, conferences, or continuing education to keep abreast of current developments in the field.
4.4 ALARA Program 4.4.1 ALARA Program Organization and Responsibilities
- b. The actual implementation of specific ALARA actions, as incorporated into daily work l activities, should be the responsibility of l each.indiv Jeal manager, supervisor, and ,
worker. ,
4.4.2 ALARA Training and Instruction
- b. General Employee Training (GET) and General Employee Retraining (GERT) courses should be reviewed by the RPM to ensure that ALARA principles are incorporated into lesson plans.
l TPP 20-2 Revision 6 Page 18 of 91
_ _ __ .. _._ . _ = - - . . _ . - _ _ - - . - - - -
I I
1
- c. A dascription of tha various lovels of RP I i
training which incorporates ALARA principles is provided in Subsection 4.3.2. ,
4.4.3 Engineering Controls
- a. Temporary shielding should be evaluated during the planning phase for activities involving high dose rates. Temporary shielding may !
require engineering and safety evaluations as '
specified in implementing procedures. The use of temporary shielding should continue to be evaluated during the implementation phase.
The decision of whether to use temporary shielding should be based on considerations f such as:
- 1) The effectiveness of providing shielding for the component (radiation source) or shielding between the source and the worker (shadow shields).
- 2) The effectiveness of providing partial shields such as for " radiation streaming", or "high-level" sections of piping, drains, sumps, etc.
- 3) Estimated dose savings by the use of shielding.
, 4) Estimated dose expended during shielding installation and removal.
- 5) Projected cost of installing and removing shielding, including the cost due to d
delay the task / project, if applicable.
l b. Engineered ac'ess c control should be evaluated and used to limit access to High Radiation !
Areas where it is not practical to provide ,
continuous positive control. Examples of !
engineered access controls include: ;
4
- 1) Inaccessible barriers.
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- 2) Locked gates or doors.
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- 3) A combination of the above.
- c. Process instrumentation for new j systems / components should be reviewed by TPP 20-2 Revision 6 Page 19 of 91
Engineering for instrument location and layout, including such concerns as:
- 1) General accessibility and associated radiation exposure.
- 2) Potential radiation exposure due to l operation of the system. .
- 3) . Potential radiation exposure due to servicing and maintaining the system / process.
- d. Control of airborne radiation sources should be considered for work activities that have the potential for producing airborne radioactivity (e.g. , cutting and grinding operations). Engineering controls to confine ;
and/or control the source should be evaluated.
Examples of engineering controls for airborne radiation sources include:
- 1) Existing Plant ventilation / filtering systems.
- 2) Auxiliary ventilation / filtering systems !
for contaminated components and for machining and grinding.
- 3) Contamination control containments.
- 4) Purification systems.
- 5) Decontamination equipment.
- 6) Wet handling of highly contaminated
~
equipment.
- 7) Air sampling / monitoring instruments located to provide a quick indication of elevated airborne levels.
- e. Remote surveillance equipment should be evaluated for use during activities performed in high radiation areas or high radioactive airborne areas. Such equipment, when used, should allow the RP Technician or the worker to evaluate the radiation or airborne levels,
! the layout of the area, and activities in the i area without being exposed to the radiological l conditions of the affected area, i
TPP 20-2 Revision 6 Page 20 of 91 l
l f.
Control of curface contemination should ba ovaluated and cppropriato methods employed to prevent, control, and contain the spread of contamination. Examples of methods used to control the spread of contamination include: {
l
- 1) Containments.
- 2) Glove bags.
- 3) Surface decontamination.
- 4) Drip pans.
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- 5) Plastic coverings.
- 6) Leak control.
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- 7) Strippable coatings. '
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- g. Other engineering controls that may promote work efficiency and reduce radiation dose to workers should be evaluated. Examples of other engineering controls include:
I
- 1) Adequate lighting.
- 2) Adequate ventilation.
- 3) Adequate working space.
Ease and quickness for installing /
- 4) j dismantling temporary equipment, such as scaffolding and insulation.
- 5) Means of accessibility, such as working l platforms, catwalks, and fixed ladders. '
- 6) Removal of com;anents to remote areas, where shielding and special. tools are available in low radiation areas.
4.4.4 ALARA Program Goals
- a. The RPM is responsible for coordinating input to the General Manager, Trojan Plant for ALARA program goals and objectives.
- b. Major activities / tasks should be evaluated during the planning phase. This should involve input from engineers (where TPP 20-2 Revision 6 Page 21 of 91
i applicable), RP staff, job coordinctors, and maintenance personnel to determine an estimated ALARA goal for the task. ALARA goals should be adjusted as additional job
- reviews, ALARA reviews, and task modifications i 'are performed.
1
- c. The estimated dose from major tasks'should be t
j combined with minor and/or . routine tasks- (if ;
necessary) to determine the annual dose goals '
for the Trojan site.
4 i
- d. Plant exposure records,. job history records, and work plans should be used as a basis'to set specific annual goals for reducing and ,
l maintaining exposures ALARA.
, e. Total Plant exposures 1should be reviewed at i least semiannually to assess Plant compliance 5
with the ALARA goals, and significant deviations from Plant goals should be evaluated.
4.4.5 ALARA Job Reviews
, a. During specific work-planning operations, work activities having significant exposure I
- expendi.ture, or having significant potential for reduction of personnel. exposure, should be identified. These activities should be reviewed for ALARA input (see .
4 Subsection 4.5.2).
, b. Cost benefit should be considered in ALARA job l reviews where significant costs may be incurred to reduce the estimated dose. These costs may be incurred by such factors as f
temporary shielding, remote tools and/or
) surveillance, ventilation controls, ;
decontamination, etc. A realistic j cost-benefit analysis often involves complex i 4
trade-offs not easily quantified. In order to provide guidance with respect to the determination of what is an acceptable monetary expenditure when performing 5
cost-benefit analysis, the following " dollar per person-rem" guidelines have been '
y established to be used in accordance with l
1 L l i.
TPP 20-2
. Revision 6 i Page 22 of 91 l
,--v -
- opplicablo regulatory guidance snd industry stendards
[
- 1) When considering the cost benefit of an effluent control system, which may expose a hypothetical member or group of members of the general public to radiation, a value of $1,000 per person-rem should be i utilized in a manner consistent with 10 CFR 50, Appendix I.
- 2) When considering the cost benefit of a system, component, or technique utilized in the Plant and involving occupational exposure to Plant personnel, a value of dollars per person-rem equal to average annual salary plus benefits, divided by 5.0 rem, should be used. This figure, as of 1992-1993 equals $11,000 per person-rem. This figure is based, in part, on a recognized responsibility to PGE employees and consideration for potential lost time due to workers being unable to perform in their area of responsibility or craft due to having exceeded an administrative exposure level established by this plan.
- c. Prejob briefings and mock-up training should be conducted for complicated or high-dose jobs, as required by implementing procedures '
and/or the specific RWP.
- d. In progress ALARA reviews should be required if radiological conditions change significantly, are unexpected, or if the projected accumulated dose significantly exceeds the estimated value (e.g., greater !
than 25 percent). The job or activity should {
be temporarily suspended while these ALARA !
reviews are performed. I
- e. Post-job ALARA reviews should be conducted at the completion of activities / tasks for which significant ALARA planning measures were required or accumulated person-rem exceeded specified action levels. Jobs should have a post-job ALARA evaluation for the following conditions:
- 1) Total accumulated exposure >l person-rem.
TPP 20-2 Revision 6
. Page 23 of 91
.. . . . _ . ~ . _ _ . _ _ _ __ ~. . _ _ ___. ___ _
- 2) The total accumulated exposure is
>25 parcent of the estimated exposure and the estimated exposure is 20.5 person-rem.
- 3) The total accumulated exposure is
<50 percent of the initial estimate, and i
the initial estimate is 20.5 person-rem.
- 4) When determined necessary by the RPM.
,j
- f. Post-job reviews should encourage all {
personnel involved in the task to provide
' input regarding the effectiveness of methods used to perform the work. The post-job ALARA evaluation should be performed by RP and the job coordinator to document any problem areas encountered, to determine possible ways to improve exposure management, and to detail reasons that the initial exposure estimate was in error (if applicable). This input should be evaluated for future work activities.
4.4.6 Design Changes
- a. Design changes and modifications, should be l evaluated for radiation exposure costs (installation, use, maintenance, and/or removal) prior to approval to proceed with the detailed engineering design. Once approved, Engineering should integrate exposure reduction techniques in the design phase.
During the approval and installation phases, reviews to ensure that exposure reduction i techniques have been incorporated, should be !
conducted. Personnel providing these reviews should be trained in applying exposure reduction techniques to design and construction / installation.
- b. Plant Engineering Management is responsible for: !
- 1) Ensuring that all planned engineering activities, including design modifications will result in ALARA radiation exposures during the modification, installation, and subsequent' operation, and/or removal.
TPP 20-2 Revision 6 Page 24 of 91
. . - - _ = _ . . .. = _.. - _ - - ._ _ - - .
- 2) Ensuring that an ALARA review is completed'for all design modifications involving work in the RCA, per applicable l Plant procedures.
- 3) Ensuring that exposure estimates are '
performed for each design option considered during the modification conceptual phase. The exposure estimates should be considered in selecting the ;
design option to be pursued. '
i
- 4) Ensuring that exposure estimates are performed for each non-modification job l option considered during the conceptual !
stage. The exposure estimates should be j
considered in selecting the design option '
(e.g., scope of inspection) to be pursued.
- 5) Ensuring that worx-time estimates are
~
realistic and of sufficient detail to i allow accurate dose estimates. j
- c. RP is responsible for:
I
- 1) Providing person-rem estimates for each j de. sign modification option, based on i information from Engineering and available Plant dose rate data.
- 2) Completing the ALARA design review, proposing specific exposure reduction considerations and, in cooperation with Engineering, establishing dose reduction goals for work.
- 3) Developing a final person-rem estimate for the final design or activity which includes all exposure reduction considerations.
4.4.7 Administrative Controls i i
- a. 'RP should review relevant procedures and I specific work packages to ensure that adequate ,
radiological controls and hold points are !
~ included as stipulated in ALARA implementing i procedures. Relevant new procedures and l revisions should be reviewed and Maintenance !
TPP 20-2 Revision 6 Page 25 of 91
R2 quests (MRs) should be reviewed prior to implemantation. ,
, b. Work activities that have the potential for general area dose rates >500 mrem /hr or total +
estimated dose >10 person-rem, should be reviewed and approved by the RPM.
- c. Work activities that have the potential for general area dose rates >10 rem / hour, or the total estimated' dose exceeds 25 person-rem, should be reviewed and approved by the RPM and ,
the Plant General Manager should be notified.
4.4.8 ALARA Program Evaluation and Appraisal i
- a. The adequacy and effectiveness of the ALARA i Program should be assessed and evaluated by l tracking ALARA performance indicators and by periodically reviewing ALARA review documentation and follow-up actions.
- b. ALARA performance indicators should include the following:
- 1) Respirator usage as compared to the j number of RCA entries. i
- 2) Pe'rsonnel contaminations as compared to the number of RCA entries.
- 3) Collective and individual doses.
- 4) Number of positive bioassay results.
- 5) Comparison of estimated and actual doses.
4.5 Dose Controls Radiation dose control and " exposure management" are l general terms used to describe the compilation of activities and programs that are used to maintain radiation doses ALARA. Elements of dose control used at Trojan are addressed in this section.
4.5.1 Administrative Dose Control
- a. Federal Radiation Dose Limits.
The NRC has established dose limits in 10 CFR 20, Standards for Protection Against TPP 20-2 Revision 6 Page 26 of 91
Radiation. A Licensea Event Report (LER)
(where applicable) and a Corrective Action Request (CAR) shall be initiated when any of the following federal dose limits are exceeded:
- 2) The sum of the Deep Dose Equivalent (DDE) and the Committed Dose Equivalent (CDE) to any individual organ or tissue other than the lens of the eye is limited to 50 rem per year.
~
- 5) The annual occupational dose limits for minors are 10 percent of the annual dose limits specified for adult workers.
- 6) The dose to an embryo / fetus during the entire pregnancy, due to occupational exposure of a declared pregnant woman, is limited to 500 mrem. An additional 50 mrem is allowed if the declared pregnant woman's TEDE is equal to or greater than 450 mrem at the time of declaration.
- 7) The TEDE to an individual member of the
, public is limited to 100 mrem per year.
- 8) . The dose in any unrestricted area from external sources is limited to 2 mrem in any one hour.
- b. Administrative dose guidelines (limits) for TEDE shall be implemented to ensure personnel do not exceed regulatory dose limits, to ensure equitable dose distribution among workers, and to ensure the collective dose to workers is ALARA. A CAR shall be initiated when a TEDE administrative guideline is exceeded.
TPP 20-2 Revision 6 Page 27 of 91
- 2) The TEDE administrative guideline may be increased from 1 through 3 rem with the approval of the RPM as directed by Plant procedures.
- 3) The TEDE administrative guideline may be increased from 3 through 4.5 rem with the approvals of the RPM and the Plant General Manager, as directed by Plant procedures.
- c. The administrative dose guidelines for skin dose, extremity dose, and dose to the lens of the eye shall be the same as the regulatory limits; however, these doses should be reviewed by RP Supervision when they exceed 10% of the applicable regulatory limit to determine if additional monitoring is required.
- d. The administrative guideline for the summation of DDE plus CDE to any individual organ or tissue other than the lens of the eye is the same as the regulatory limit..
- e. An administrative guideline of 50 mrem TEDE per month should be applied to a declared pregnant woman for the duration of the pregnancy, and not to exceed the regulatory limit for the embryo / fetus for the entire gestation.
- f. A woman, who is attempting to become pregnant, may request that her TEDE be administratively limited to 50 mrem per month.
- g. Internal Dose Guidelines:
TPP 20-2 Revision 6 Page 28 of 91
'2) The~TEDE shall not exceed 1 rem without an administrativo dose _ guideline increase.
i
if internal monitoring should be I required.
I
- 4) DAC-Hr tracking should be used, where-applicable, to monitor an individual's !
exposure to airborne. radioactivity. !
DAC-Hr action levels, for bioassay and j for internal dose assessment, should be defined in-RP procedures. t
- 5) The CEDE should be maintained below 1 rem. Whenever the CEDE exceeds 1 rem, the CDE shall be evaluated. i
- 6) The airborne tritium concentration above I the spent fuel. pool should be maintained -
below 5.0E-06 pCi/cc. &
)
i NOTE 4.5.1.h '
l All contamination levels listed below are for beta gamma i emitters. Alpha limits-are 0.05 times the beta-gamma limit. i
)
- h. Trojan Contamination' Limits. .
- 1) Personnel. i Personnel will not be allowed'to have
>1,000 dpm/20 cm2 radioactive contamination remain on their skin or hair. Decontamination will be mandatory to reduce contamination levels to less '
than the above limit before leaving an RCA unless. specific authorization is
- received from the RPM or designee.
- 2) Personal Belongings.
l L The contamination limits for personal i
belongings (such as clothing,_ watches, glasses, etc.) should be <1,000 dpm/
20 cm2 . If these limits cannot be 3
i obtained after reasonable efforts to l'
l TPP 20-2
- Revision 6 Page 29 of 91 l
,,,,," _., . . . I l
1 decontaminate, the conteminated items should be handled as radioactive / '
contaminated material. ,
- 3) Materials and Equipment.
The contamination limits for materials- )
and equipment released from RCAs should be <1,000 dpm/20 cm2 fixed and l
<1,000 dpm/100 cm2 loose. j
\
The contamination limits for materials and equipment released for use in RCAs outside contaminated areas should be
<15,000 dpm/20 cm2 fixed and
<1,000 dpm/100 cmr loose.
Materials and equipment that cannot be decontaminated to these levels will be stored and controlled as radioactive /
contaminated material and can be used inside contaminated areas.
- 4) Laundered Protective Clothing.
Laundered protective clothing should be surveyed by random sampling after laundering. Clothing that exceeds the i
following contamination limits will be returned for further laundering, set aside for special use, or disposed as radioactive waste.
Loose Contamination: <1,000 dpm/100 cm2 Fixed Contamination:
Coveralls: <15,000 dpm/20 cm2
-Cloth booties: <15,000 dpm/20 cm2 Hoods: <15,000 dpm/20 cm2 l Boots: <50,000 dpm/20 cm2 !
' Gloves: <15,000 dpm/20 car j Wet suits: <15,000 dpm/20 cm2 Wet sleeves: <15,000 dpm/20 cmr Lab coats: < 1,000 dpm/20 cmr Modesty garments: < 1,000 dpm/20 cm2 Rags / towels: <15,000 dpm/20 cm2 TPP 20-2 Revision 6 Page 30 of 91
4.5.2 Rcdiation Work Permits (RWPs)
The RWP Program ensures that work in RCAs is properly controlled by informing the worker of the '
radiological conditions and of the protective clothing or other radiological requirements for the job.
- a. An RWP should be required for the following:
- 1) Entry into or work in an RCA.
- 2) Activities involving equipment, controls, or instrumentation containing or suspected of containing radioactive material which are located outside an RCA.
l
- b. The RWP process should provide a systematic !
method to evaluate radiological conditions under which work activities should be ;
accomplished, specify RP requirements, and !
ensure that required worker briefings are i given.
- c. Acceptable radiation work practices should be described and sufficient RP Technician I coverage assigned to assure worker protection and to ensure that worker dose is maintained ALRRA.
- d. RWPs should also provide a method to record doses for each individual by major job or task. The recorded RWP doses should also allow dose trend analysis and should frequently provide workers with their current dose status. The specific methods used for dose' accountability and trending should be 1 prescribed in implementing procedures.
- e. ' Appropriate management approvals for RWPs involving significant total dose or dose rate should be established in conjunction with the ALARA program. RWP preparation, approval, and retention are specified in Plant procedures.
TPP 20-2 Revision 6 Page 31 of 91
- f. RWPs should provide the following information:
- 1) Description of job or activity to be 1 l performed. !
- 2) Anticipated radiological conditions including, as applicable, contamination
, levels, radiation levels, airborne !
radioactivity levels, hot spot locations. ;
- 3) Reference to, or a copy of, dose rate and i contamination level survey maps.
- 4) Number and identification of personnel l assigned to the job or activity (if ;
appropriate). )
- 5) Monitoring requirements during the job, !
such as constant-RP coverage,. !
intermittent coverage, air monitoring, !
etc. 1 i
- 6) Special instructions and equipment to ;
minimize exposure to radiation and '
contamination.
i i
- 7) Protective clothing and equipment l re,quirements. j
- 8) Personnel dosimetry requirements.
- 9) Estimated exposure time and dose (person-rem) to complete the task.
- 10) Type and frequency of surveys required in addition to routine surveys.
- g. RWPs should normally be requested by the group responsible for the job to be performed. The RWP request should typically include the following information:
- 1) Job description, work package number, and, if appropriate, the purpose of the l task.
- 2) Location (s) of work.
- 3) Estimated time to complete the job including, if appropriate, crew size and '
work location.
TPP 20-2 Revision 6 Page 32 of 91
}
4)- ALARA evaluation check list.
- h. RWPs should be documented in a legible and
~
t
~
easy to comprehend format, and should be readily accessible for workers' review. All i personnel assigned to an RWP should be-1 required to read the RWP verifying they will
. comply with its requirements.
?
! i. Radiation workers should comply with RWP l requirements. . Willful or habitual disregard
- of RWP instructions should be cause for corrective action.
i
- j. RWPs should be classified as " Extended" or
" Specific" as determined by RP Supervision. )
- 1) Extended RWPs should be used for the
. performance of routine activities such as
[ observation, inspection, operator rounds, j laundry. operations where radiological 4
conditions are stable, or maintenance 1
activities that have little radiological l' significance.
2
- 2) Specific RWPs should be used for the performance of a defined activity in specific locations.
4.5.3 Area Postings
) Radiological postings andLsigns shall be provided
!- at the entrance and boundaries of radiological
) areas to' define the areas and. advise workers of
. radiological hazards. Radiation workers shall
- 1. comply with posting requirements.
I ~
a.
An RCA shall'be posted with.the following l
- minimum requirements for entry.
! 1) Radiation Work Permit (RWP). l l
, 2) Thermoluminescent Dosimeter (TLD). ;
- 3) Digital Alarming Dosimeter (DAD) or a Pocket Ionization Chamber (PIC). ;
1 i
3 Additional postings shall be provided as
, necessary to define the applicable area and 1 associated potential hazards.
4 TPP 20-2 Revision 6
. Page 33 of 91 i
- b. Radiation Areas.
- 1) All radiation areas shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words " CAUTION RADIATION AREA".
- 2) Specific areas equal to or exceeding 5 mrem /hr at 12 inches shall be !
individually posted as radiation areas. I RCAs occurring outside the RCA will be posted as a radiation area when radiation levels are >2 mrem /hr measured at 12 inches.
1
- 1) An area shall be posted as a high radiation area when the radiation level at 30 cm (about 12 inches) from the source is >100 mrem /hr.
- 2) In accordance with Technical Specifications, each high radiation area in which the intensity of radiation is
>100 mrem /hr but <1,000 mrem /hr shall be barricaded and conspicuously posted with
- a. sign or signs bearing the radiation caution symbol and the words " CAUTION HIGH RADIATION AREA". Entrance to such areas shall be controlled by an RWP and entry in the area shall require a radiation monitoring device which continuously indicates the radiation dose rate in the area.
- 3) In accordance with Technical Specifications, in' addition to the controls above, each high radiation area in which the radiation level is
>1,000 mrem /hr shall be provided with locked doors to prevent unauthorized entry to such areas. These controls shall be established in such a way that no individual will be prevented from leaving a high radiation area. The keys to such areas shall be maintained under the administrative control of the Shift Manager. In the case of a >1,000 mrem /hr high radiation area established for a period of 30 days or less, direct TPP 20-2 Revision 6 Page 34 of 91
survaillance to prevent unauthorized entry may be substituted for the locked door.
- 4) High radiation exclusion areas shall be barricaded and conspicuously posted with a sign or signs bearing _the radiation
' caution symbol and the words " CAUTION HIGH RADIATION AREA", and " EXCLUSION AREA".
- 5) The RPM or designee should review and approve the RWP for entries into areas I where the radiation levels are '
>1,000 mrem /hr. In the absence of the RPM, the Shift Manager may approve entries into areas >1,000 mrem /hr for urgent work.
l
- 6) Entry into any high radiation area ;
requires a radiation monitoring device l which continuously indicates the radiation dose rate in the area. Entry into high radiation areas where radiation ,
levels are >1,000 mrem /hr requires that a j RP Technician be present to monitor the '
entry. 1
- d. Very High Radiation Areas (VHRA).
- 1) Each VHRA shall be posted with a conspicuous sign or signs bearing the radiation symbol and words " GRAVE DANGER {
VERY HIGH RADIATION AREA." l
- 2) In addition to controls and access requirenents for high radiation areas, very high radiation areas shall have these additional requirements:
(a) Physical barriers should completely enclose a VHRA sufficiently to ;
prevent undetected circumvention of the barrier.
(b) Entryways shall be welded shut, or otherwise permanently and securely closed, where practical.
(c) Entryways to areas that cannot be permanently shut shall be double TPP 20-2 Revision 6 Page 35 of 91
locked shut. A padlock (and' chain) or equivalent, in addition to the installed entryway lock, may be used to meet this requirement.
(d) One key shall be under the exclusive control of RP and the other shall be under the exclusive control of the Shift Manager.
(e) Entry into a VHRA should be prohibited unless there is a sound operational or safety reason for l entering. i l
(f) Each entry into VHRAs shall require i the concurrence of both the Shift l Manager and the RPM.
(g) Radwaste processing and storage containers such as High Integrity Containers (HIC) that could meet or exceed VHRA control radiation levels should be pre-staged inside a shield cask so that radiation levels outside the shield cask are LESS THAN VHRA control levels.
- e. Hot Spots.
Hot spots should be conspicuously posted with labels bearing the radiation caution symbol.
The highest contact radiation level at the hot spot will be recorded on the label.
- f. Low-Exposure Areas (LEAS) are established to identify selected' areas where dose rates are lower than other locations within the work area. When practical, workers should be directed to remain in an LEA unless they are actually needed at the work location. LEAS should be posted " LOW EXPOSURE AREA" or identified by posting areas with low dose rates. I
- g. Surface Contamination Areas.
- 1) Surface contamination areas should be barricaded and conspicuously posted with a sign or signs bearing the radiation i
TPP 20-2 '
Revision 6 Page 36 of 91
caution symbol cnd the words " CAUTION CONTAMINATION AREA".
- 2) Loose surface contamination should be maintained as low as practicable according to the area and job involved; however, it shall be kept below 1,000 dpm/100 cm2 outside of an RCA.
- 3) If loose surface contamination exceeds 1,000 dpm/100 cmr in an uncontrolled area, that area shall be established as an RCA. j
- 4) In an RCA that requires routine access, decontamination should be performed if loose contamination reaches 100,000 dpm/100 cm 2. If decontamination below 100,000 dpm/100 cmr cannot be achieved, other engineering controls or respiratory protection should be considered. i 1
- h. DRP Control Areas.
DRP control areas are established to identify where discrete particles with high specific activity are located.
- 1) Red Zone.
A red zone is an area where DRPs are suspected or known to exist, or where DRPs may be released during planned activities.
- 2) Yellow Zone.
A yellow zone is a buffer area adjacent to a red zone established to prevent migration of DRPs from red zones. A yellow zone buffer may not be required if
'a physical boundary / barrier separates the red zone from other areas.
- 1. Airborne Radioactivity Areas.
- 1) Airborne Radioactivity Areas shall be posted with a conspicuous sign or signs bearing the radiation symbol and the words " CAUTION AIRBORNE RADIOACTIVITY TPP 20-2 Revision 6 Page 37 of 91
AREA" or " DANGER AIRBORNE RADIOACTIVITY AREA," and "DAC-HOUR TRACKING REQUIRED."
- 2) The time any individual ent'ers and leaves an Airborne Radioactivity Area should be recorded.
- 3) Surveys of airborne radionuclides should be performed at least daily in any posted Airborne Radioactivity Area that is J accessed.
- 4) Air sample results that are j representative of the breathing zone should be used for DAC-Hour assignments for individuals working in Airborne Radioactivity Areas.
1
- j. Fixed Contamination Area. l l
- 1) Fixed contamination areas should be barricaded and conspicuously posted with a sign or signs bearing the radiation caution symbol and the words " CAUTION FIXED CONTAMINATION AREA". l t
- 2) Radiological controls are established to reduce the prcbability of the production
.of. loose surface contamination and to i prevent the inadvertent migration of l
radioactivity to uncontrolled areas. ;
1
- k. Radioactive Material Storage Areas.
1
- 1) Each area or room that meets the !
I definition of a radioactive material storage area shall be posted with a conspicuous sign or signs bearing the radiation symbol and the words " CAUTION, RADIOACTIVE MATERIAL (S)".
TPP 20-2 Revision 6 Page 38 of 91
.. - - ~ .. - . . - . .- _ _ - .
- 1. Exception to Posting Requirements.
- 1) Caution signs _are NOT required in areas _
or rooms containing radioactive. materials for periods of LESS THhN 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> when:
(a) The materials are constantly attended during these periods by an individual who takes the precautions necessary to prevent exposure of 1 individuals to radiation or .
radioactive materials in excess of the regulatory limits; and (b) The area or room is under RP j control.
1
- 2) A room or area is not required to be posted with a caution sign because of the presence of a sealed source provided the radiation level at 30 cm (about '
12 inches) from the surface of the source container or housing does not exceed 5 mrem per hour.
4.5.4 External Dosimetry
- a. Monitor.ing Whole Body Dose (DDE).
- 1) All personnel whose external doses are likely to exceed 10 percent of the occupational dose limits, or who enter a high or very radiation area, shall be required to use individual monitoring devices.
(a) This includes all personnel who have access to any RCA.
(b) Personnel who require monitoring for external dose shall wear TLDs as the primary dosimeter, and self-reading dosimeters (SRDs) as a secondary dosimeter when entering RCAs.
- 2) Personnel who are issued dosimetry devices are required to have the devices in their possession while in an RCA and I are responsible for the safekeeping of the devices. If the device (s) alarm, become damaged, or are lost, the TPP 20-2 Revision 6 Page 39 of 91
individus1 to whom the dsvice (s) waro 3 issued should notify RP ctaff ,
immediately. l 1
and waist in close proximity to each l other and in plain view. Under certain l
conditions, where the chest or trunk may l not be the location of highest whole-body dose, dosimetry devices may be relocated (or multiple TLD packets used) by the RP i Technician, or as directed on the RWP.
- 4) If an SRD is off-scale or lost under I conditions such that it is the only SRD i being worn and a significant dose (e.g.,
l 50 mrem or greater) was possible, the '
individual's TLD should be promptly processed and the individual should be denied access to RCAs until an exposure investigation is completed.
- 5) The use of multiple dosimetry should be i evaluated whenever work is to be l performed in a nonuniform radiation '
field, and that portion of the body which should receive the highest dose is not easily determined. In these cases, dosimeters should be worn on those parts i of the body expected to receive the
{
highest dose. RWPs should be used to '
communicate dosimetry requirements to the workers.
- 6) Personnel dosimetry devices should not be I taken from the Trojan Nuclear Plant but should be returned to the point of issuance at each exit. Specific exceptions for individual jobs may be granted by the RPM or designee on a case-by-case basis.
- 7) TLDs are normally retained in the TLD rack, located on the wall next to the RP office area (45 ft Control Building).
Personnel should pick up their TLD badge before entering the RCA and return it after exiting. Secondary dosimeters (DADS and PICS) should be obtained and TPP 20-2 Revision 6 Page 40 of 91
l returned at the same location, or et other locations as authorized by RP.
- b. Monitoring Neutron Dose.
With the Plant permanently defueled, there are NO sources of neutron radiation exposure for which special neutron monitoring would be required with albedo dosimeters. Any neutron monitoring will be by calculation based on i stay time.
l l
- c. Monitoring Extremity Dose. l The use of additional dosimetry devices to monitor the extremities should be considered, !'
at a minimum, under the following conditions:
- 1) Extremity dose is expected to exceed 5 rem; or
- 2) Extremity dose is expected to be: 1 (a) Five (5) times greater than the I whole-body, and {
(b) Greater than 1 rem for the task.
- 3) RP personnel should determine the extremity monitoring requirements on a ,
case-by-case basis,
- d. Monitoring Skin Dose (SDE) .
- 2) Dose resulting from radioactive contamination, or other exposure not monitored by the TLD, should be calculated and added to.the individual's
' dose record when-the SDE exceeds 200 mrem.
- 3) Dose from exposure to DRPs may be recorded as SDE to the skin, with a note in the comment section of the individual's NRC Form 5.
TPP 20-2 Revision 6 Page 41 of 91
,e
(a) The SDE should be calculated for all DRPs with activities GREATER THAN 15,000 dpm.
i (b) DRP exposures that exceed the regulatory SDE limit shall be reported to the NRC.
- e. Monitoring Eye Dose.
Eye dose (LDE)_is normally monitored by the primary dosimeter (TLD).
'f. Dosimetry Quality Control. j
- 1) Periodic quality assurance checkslof dosimetry shall be conducted in accordance with implementing procedures.
results and each discrepancy greater than values specified by implementing ;
procedures should be evaluated. '
4.5.5 Internal Dose Control and Monitoring I
- a. Monitoring for internal exposure is normally i NOT required at Trojan Nuclear Plant..
- b. RP personnel shall perform prospective evaluations of the potential.for individuals requiring monitoring for internal exposures, as part of the ALARA review process. '
- 1) When monitoring for internal exposure is determined to be required, The CEDE shall be recorded and reported even if the individual has been exposed to LESS THAN '
10 percent of the applicable ALIs listed ,
in Appendix B to 10 CFR 20.
- 2) IJ[ an individual's monitoring ;
classification changes during the year, !
from a classification that did not require monitoring for internal exposure l to one that does, THEN all internal l exposures for that part of the year for which no monitoring was performed, shall be estimated, recorded and reported.
TPP 20-2 Revision 6 Page 42 of 91
. . - ~ . - .-. -. _
- 3) IF cn individual's CEDE is GREATER THAN
~
1 rcm, THEN the CDE chall ba calculated, recorded and reported,
- c. Personnel contamination monitors (PCMs), whole body counts and air sample results are used to demonstrate that internal monitoring is not required, and to monitor internal exposure for those individuals who require it.
- 1) Personnel who alarm a PCM due to internal l contamination shall receive a whole body count to determine the need for an i internal dose assessment.
- 2) Personnel with sufficient internal contamination to alarm a PCM should not be allowed entry into the RCA until they are able to pass through the monitors without alarming them.
- 3) Whole Body Counts should be required: )
(a) For individuals in-processing for access to RCAs.
(b) When a PCM alarms due to internal contamination.
(c) After an individual has received 4 DAC-Hr in a 24 hout period, and/or 10 DAC-Hr in a 7 day period, and/or 80 DAC-Hr cumulative exposure.
(d) When an individual with access to i RCAs terminates employment at Trojan.
(e) Annually for radiation workers.
(f) When a radiation worker declares her pregnancy.
(g) When required by RP Supervision.
- 4) When applicable, in-vitro bioassay should be performed to monitor for non-gamma emitting radionuclides. '
- d. DAC-Hour tracking should normally be used as the method for tracking CEDE; however, whole TPP 20-2 Revision 6 Page 43 of 91
body count rosults or other calculated results '
may reploco DAC-Hours after RP cvoluation.
4
- 1) DAC-Hours should be tracked'for personnel [
entering Airborne Radioactivity Areas.
- 2) Records of DAC-Hours should be kept for each individual working in an Airborne Radioactivity Area. -
- 3) RP procedures should specify DAC-Hour action levels for internal dose
- assessment. ,
and should be the stochastic ALI or DAC. WHEN :
specific information concerning the chemical J
form of the contaminants are known, THEN lung !
classifications other than the most :
restrictive may be used to calculate internal '
dose.
l
- f. Tritium analyses should be performed on urine ;
samples collected from fuel handlers during !
fuel movement activities in accordance with implementing procedures. Tritium analyses of personnel will also be performed when the conditions and work activities provide a ,
potential for tritium uptake. !
- g. The RPM or designee may require special physical examinations, whole body counts and/or urinalyses for individuals involved in ,
radiological incidents. Personnel awaiting ,
the results of exposure ir.vestigations should i not be assigned work in an RCA.
- h. Each employee should notify RP of any exposures received from therapeutic radiation treatments, especially if radionuclides are used internally. Routine diagnostic X-rays need not be reported.
4.5.6 Dose Control for the Declared Pregnant Woman
- a. It shall be the radiation worker's responsibility to declare her pregnancy, to not declare her pregnancy, or to retract her i declaration of pregnancy if she so chooses. l 1
TPP 20-2 i Revision 6 Page 44 of 91 l
- b. IF c radiation worker does not declare har prGgnoney, THEN no spacial arrangcments should be made to limit the dose to her embryo / fetus..
- c. When a radiation worker declares her pregnancy:
- 1) An estimate of the dose to the embryo / fetus, from the date of conception to the date of declaration shall be made, both from the mother's DDE and from any radionuclides (other than naturally 1
occurring) that may be present in the 4
mother's body since conception.
Regulatory Guide 8.36 should be consulted
, for this estimate.-
- 2) The dose to an embryo / fetus during the entire pregnancy, from occupational exposure to the mother, shall not exceed 500 mrem TEDE, or shall not exceed 50 mrem for the remaining duration of the
- pregnancy, if the mother's TEDE is 450 mrem or more at the time of the declaration of pregnancy.
- d. A declared pregnant woman should have an administrative dose limit of 50 mrem per month.
- e. A declared pregnant woman should not be allowed entry into high radiation, very high radiation,. contamination, or airborne radioactivity areas.
- f. The declared pregnant woman should be monitored for external exposure with an individual monitoring device when frequenting the restricted area.
- g. Internal exposure for a declared pregnant woman should be monitored by whole body counting every 30 days.
- h. It should be the responsibility of the declared pregnant woman to inform RP Supervision of the termination of her pregnancy in order to revise her administrative dose limit to normal occupational levels.
TPP 20-2 Revision 6 Page 45 of 91
i.
IF o radittion worker docidas that sha doas not want any additional exposure to her embryo / fetus after she has declared her pregnancy, THEN a reasonable attempt should be made to find her work, of an equivalent nature, outside of the restricted area.
4.5.7 Dose Control-for Minors
- a. The dose limits for minors (age less than 18) who frequent the Restricted Area are 10 percent of the applicable occupational dose limits for adults.
- b. Minors shall normally not require monitoring for external or internal dose while in the Restricted Area.
- c. Minors shall normally NOT be allowed entry into any RCA.
- d. If a minor is likely to receive more than 50 mrem DDE while in the Restricted Area, or is granted access to the RCA by the RPM, monitoring shall be provided, i 4.6 Respiratory Protection Program 4.6.1 The Respiratory Protection Program shall be established in accordance with 10 CFR 20.
- a. The primary objectives of the Respiratory Protection Program are personnel safety and maintaining the TEDE AIARA.
- b. Engineering controls should be applied to !
minimize concentrations of radioactive materials whenever practical.
- c. When engineering controls are not practical, other controls such as' increased surveillance, '
limitations of working times, or use of respiratory protection equipment may be appropriate.
- d. Respirators are available for routine, nonroutine, and emergency use. Emergency-use respirators are controlled by the Defueled Emergency Plan and implementing procedures.
Respiratory protection for hazardous chemicals TPP 20-2 Revision 6 Page 46 of 91
1 and fire protection are separate from this '
program.
t
- e. The written policy statement on. respiratory l protection is provided in TPD 20-1, Radiation !
Protection Program Policies. !
4.6.2 Program Administration
- a. The RPM is responsible for development, '
implementation, and control of the Respiratory ;
Protection' Program for radiation' protection. l
- Day-to-day implementation should be performed by RP Technicians.
t
- b. Program administrative responsibilities should i include the following: '
i
- 1) Provide overall program development, i technical direction, and-the evaluation l'
of program effectiveness.
1
- 2) Provide technical guidance for the control of airborne radiological {
contaminants. l l
- 3) Develop procedures, training materials, !
and directives related to the program. j t
- 4) Conduct routine overviews of the program !
for compliance with policy, procedures, -
and regulations. l' l
4.6.3 Respiratory Protection Equipment Description and ;
Selection
/
i
- a. Respiratory protection should be considered '
only after other methods, such as engineering controls, have been evaluated for reducing exposure to airborne radioactive materials.
- b. The selection of respiratory protection equipment should be based on work area survey data and/or expected airborne contamination levels, and the lack of availability of engineering controls.
- c. The need for respiratory protection should normally be determined and prescribed by RWPs.
TPP 20-2 Revision 6 Page 47 of 91 ,
l i
1
- d. Respiratory protection equipmsnt shall be i selected to provida~a protection factor greater than that required for the expected peak concentration of airborne radioactive ;
materials in the work area.
- e. Assigned protection factors shall not exceed those specified'in Appendix A to-10 CFR 20.
- f. If the selection of a respiratory protection device is inconsistent with the goal of keeping TEDE ALARA, consideration should be given to alternative approaches to performing required work.
4.6.4 Respirator User Qualification Respirators should be issued only to personnel qualified to use the respirator. Qualifications consist of:
- a. Medical evaluation to establish physical and psychological capabilities necessary to perform tasks using a respirator. A medical evaluation shall be performed annually (all types of respirators). ;
- b. Successful completion of Respiratory Protection Training, as described in Subsection 4.3.3.
- c. Successful quantitative fit test prior to the use of respirators that require a facepiece-to-face seal.
- d. No facial hair between the face and the sealing surface of.the respirator'and no facial hair interfering with valve function of the respirator.
4.6.5 Bioassay Bioassay techniques should be used to determine the amount and type of radionuclides in the body as an evaluation of the effectiveness of the Respiratory Protection Program. ;
4.6.6 Equipment Inspection and Maintenance
- a. Requirements and techniques for inspection and maintenance of respiratory protection i
TPP 20-2 I Revision 6 Page 48 of 91
)
equipmant should be contained in implementing ;
procedures, and should ba performed in '
accordance with manufacturers' and regulatory requirements.
l
- b. Respirators shall be maintained and issued in a National Institute of Occupational Safety and Health (NIOSH)-certified configuration. ,
The certification for a respirator shall be ,
automatically voided if the respirator is not ;
the same in all respects as certified by NIOSH or if the respirator is not maintained in a certified condition.
- c. Acceptable methods of cleaning respiratory !
equipment shall be performed in accordance with manufacturers' specifications and implementing procedures.
4.6.7 Designating Respirator Use on an RWP ;
- a. A formal evaluation should be performed for a .
job / task for which respiratory protection is specified if the TEDE exceeds 120 mrem for the individual or 1 person-rem for the job / task.
- b. A formal evaluation should be performed for a job /tas.k for which respiratory protection is not specified if the CEDE equals or exceeds 20 mrem (about 8 DAC-Hours) for the individual.
- c. In new job situations, with no history of previous similar jobs, for which there is a large uncertainty in the magnitude of the projected airborne concentra*. ions, an evaluation is not required prior to using respiratory p'otection.
r 4.6.8 Respirator Use
- a. Implementing procedures should include provisions for testing of respirators for operability immediately prior to each use.
- b. Individuals using respirators shall be advised concerning the periods of respirator use and relief from respirator use.
- c. A user of a respiratory protection device may seek relief at any time that the respiratory TPP 20-2 Revision 6 Page 49 of 91
~
protection davice affects the health snd safety of the user.
d._ Respiratory-equipment should be used within the limitations for type and mode of use and provide proper visual, communication, and other special capabilities when needed.
4.6.9 Quality Assurance (QA) f
- a. Periodically, respirators shall be randomly selected to verify they have been properly cleaned and inspected.
- b. Respirator users should also be randomly selected for whole body counts to verify program effectiveness,
- c. If there is an indication of equipment failure or improper use (e.g., positive nasal smear),
the respirator user should receive a whole body count.
4.6.10 DAC-Hour Tracking ,
- a. Administrative and engineering controls should limit the intake of radioactive materials to ,
levels.that are ALARA. ;
- b. Personnel should not exceed the administrative )
guideline of 4 DAC-Hr in any.one day and I 10 DAC-Hr in any one week. l
- c. Planned exposures of >4 DAC-Hr per day and
>10 DAC-Hr per week should be approved by the RPM.
- d. DAC-Hr should be evaluated and tracked as specified in implementing procedures.
4.6.11 Supplied Air Respiratory Equipment Breathing air may be supplied to respirators from compressed air cylinders, air compressors, or the Plant breathing air j system. All sources of compressed breathing air shall meet the requirements for Grade D breathing air as specified in ANSI /CGA G-7.1, Commodity Specification for Air, 1989.
TPP 20-2 Revision 6 Page 50 of 91
. -- . _ ~. _ _ - . . - . _. .. -
4.7 Rtdionctivo Material Controls l
All personnel assigned to the Trojan Nuclear Plant are responsible for ensuring complete control of radioactive /
contaminated material associated with their area (s) of responsibility. Radioactive / contaminated material shall be received, stored, transferred, and shipped in accordance l with applicable federal, state, and Plant requirements. j 4.7.1 Violations, Discrepancies, or Incidents The RPM should ensure that applicable reports are initiated for all instances of shipping regulations 1
I violations. Plant procedures contain guidance for reporting discrepancies or incidents regarding shipments of radioactive material.
4.7.2 Receipt of Radioactive Material
- a. Prior to ordering or requesting radioactive material, the request, purchase order, etc.,
shall be reviewed by the RPM.
- b. Personnel,who initiate purchase orders for radioactive materials should specify that ,
shipments be marked " Attention: Manager, l Radiation Protection". i l
- c. The RPM should ensure that current records are maintained, showing all receipts of radioactive material at the Plant.
- 1) RP personnel should,be informed of any receipts of radioactive material upon ;
arrival.
l
- 2) The Receiving Warehouse and/or Security should call the RP supervisor or designee whenever any shipment of material arrives on-site with any radiation warning label or tag.
- 3) Radioactive material shipments should not be allowed into the Restricted Area until 3
l surveyed in accordance with implementing I procedures and authorized by the RP ;
Supervisor. ;
- 4) Plant personnel who may be expecting a ,
shipment containing radioactive material i should inform the RPM in advance. .
TPP 20-2 Revision 6 l Page 51 of 91 l l
- d. Radioactivo material. receipts shell be '
completed and documented in accordance with ,
implementing procedures as soon as practical '
after the material arrives on-site, but NO LATER TRAN 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> after the package is received at the warehouse, if it arrives l during normal working hours, or NOT-LATER THAN !
3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> from the beginning of the next working l day, if it arrives after normal working hours. ;
- 1) RP personnel shall take possession of a package of radioactive material expeditiously upon notification of the I arrival of the material at a carrier's !
terminal.
- 2) The external surfaces of radioactive material packages shall be surveyed for radiation levels and/or. contamination, except for:
(a) Packages that contain only radioactive material in the form of a gas or in special form as defined in 10 CFR 71.
(b) Packages that contain quantities of radioactive material that are LESS l TRAN OR EQUAL TO Type A quantities J defined in 10 CFR 71. l
- 3) Radioactive material packages shall be surveyed for radioactive contamination and radiation levels if there is evidence of degradation of package integrity, such as packages that are crushed, wet, or damaged.
- e. Any actual or apparent shipping discrepancy noted during the receipt of radioactive material should be reported, as a minimum, to the RPM and additional notifications or i reports made as required by implementing i procedures. !
4.7.3 Identification of Radioactive Material
- a. A radioactive material container is any holder l that contains licensed material in quantities equal to or greater than the applicable quantities listed in Appendix C to 10 CFR 20 i TPP 20-2 l Revision 6 Page 52 of 91
or in concentrations equal to or greater than tho applictble concentrations listed in Appendix B to 10 CFR 20.
- b. Radioactive material containers shall be labeled with the radiation caution symbol and the words " CAUTION RADIOACTIVE MATERIAL".or
" DANGER. RADIOACTIVE MATERIAL". The label should also_ provide sufficient information to permit individuals handling or using the containers, or working in the vicinity thereof, to take precautions to avoid or minimize exposures.
- c. Unless exempted from labeling (see below), any container reading >5 mrem /hr at 12 inches
(>2 mrem /hr at 12 inches outside the RCA) shall have the following information on the container:
- 1) The contact and 12-inch dose rates.
- 2) Technician initials and date of survey.
h
- 3) General contents, as applicable, i
- d. Labeling is not required:
- 1) For containers holding radioactive material in quantities less than the applicable quantities listed in Appendix C to 10 CFR 20, or in concentrations less than the applicable concentrations listed in Appendix B to 10 CFR 20.
- 2) For containers when they are attended by an individual who takes the precautions 1 necessary to prevent the exposure of any l individual to radiation or radioactive !
materials in excess of the limits j established in 10 CFR 20,
- 3) For containers when they are in transport 1 and packaged and labeled in accordance !
with regulations of the Department of ;
, Transportation (DOT).
- 4) For containers which are accessible only to individuals authorized to handle or I use them, or to work in the vicinity TPP 20-2 Revision 6 Page 53 of 91
l l
l thorcof, provided that the contents are l idantificd to cuch individuals by a l readily available written record.
- 5) For installed manufacturing or process equipment, such as nuclear reactors, reactor components, piping, and tanks.
- e. All items free-released from an RCA shall have l
" RADIOACTIVE MATERIAL" labels, markings, !
and/or special designators such as paint, removed or defaced prior to release.
4.7.4 Control and Movement of Radioactive Material Within RCAs
- a. Radioactive material should be transferred )
within the confines of the RCAs in accordance j with the following guidelines:
- 1) Radioactive materials removed from ,
contaminated areas should be contained, l surveyed, and labeled to allow I appropriate control of radioactive l material. I
)
- 2) Radioactive liquid samples or sources )
should be properly contained and should l be transported by, or under the l cognizance of RP.
- 3) Transfers should be made by the most practical direct route and care should be exercised to avoid administrative areas.
- 4) Material or equipment being transferred from one location to another location within an RCA should meet the radiation and loose contamination limits of each area through which it passes or.be under the control of RP personnel.
- b. Radioactive material should be controlled in accordance with the following guidelines:
- 1) Uncontaminated materials should be separated from contaminated materials and the containers should be labeled appropriately.
I TPP 20-2 I
Revision 6 Page 54 of 91
l
- 2) Tools and portable equipment that are used only in the RCA or have fixed contamination (and should not be permitted to leave the RCA without RP approval) should be identified by magenta color coding.
NOTE 4.7.4.b.3)
Specialized tools need not be decontaminated if the tools are
]
to be used in areas with expected contamination levels greater '
than the listed limits. However, the tools should be l decontaminated to the level of the area where they will be used. The contaminated specialized tools should be stored as !
radioactive material. l
- 3) After each use where there is a potential for contamination, tools should be surveyed for levels of contamination and subsequent controls as specified in implementing procedures. The limits for contamination on tools and equipment to be used in the RCA is:
<1,000 dpm/100 cm2 loose
<l5,000 dpm/20 cm2 fixed
- 4) All hot shop tools and equipment used in RCAs should be taken to the decontamination shop for decontamination and survey prior to returning to shelf stock.
- 5) Special-use tools may be identified and stored in marked plastic containers if j authorized by RP.
4.7.5 Control and Movement of Radioactive Material Outside RCAs
- a. Radioactive material being transferred from one RCA through non-RCAs to another RCA should be properly surveyed and contained and should be escorted by RP personnel.
TPP 20-2 Revision 6 Page 55 of 91
._ _ - __ . _ _ _ _ . . _ . _ _ . . . . - _ . _._ _ . ___._____._m__..
i i
4 NOTE 4.7.5.b i 1
- Radioactive material should not be stored outside'of the !
) Restricted Area unless specifically approved by the RPM, and ;
reported to the Plant General Manager. i I
- b. Radioactive materials removed from an RCA to I be shipped off-site shall be packaged and l labeled for shipment in accordance with NRC ,
] and DOT regulations. j a
i 1) Such material may be transferred'only to '
facilities licensed to receive the type '
of radioactive material (s) being shipped. j j 2) Areas containing radioactive material j
[
waiting to be shipped should be 4
" established RCAs, or be attended by an !
- individual who takes the precautions i
necessary to prevent exposure of i individuals in excess of the limits i j established in 10 CFR 20. '
l 3) When radioactive materials are taken to I j unlicensed. facilities away from the j Trojan site, they shall be transferred in j i accordance with Oregon License ORE-0328-2 ;
j- and RP procedures. i
- c. Radioactive materials removed from an RCA that are not designated to be shipped should be: i d
- 1) Properly contained to minimize radiation levels and/or prevent spread of j contamination ~.
~
i
- 2) Surveyed'to determine radiation and contamination levels, and ensure there is
- no removable contamination on exterior and accessible surfaces.
- 3) Labeled in accordance with 10 CFR 20 as l radioactive materials indicating the l l radiation and contamination levels.
! Adequate features and markings shall be
, used to clarify the physical and l radiological parameters of the material.
4 1
i 1' i
h
, TPP 20-2 L
! Revision 6
/ Page 56 of 91 J
- 4) Controlled by RP personnel (e.g., stored in a locked area and not used or moved without RP permission and/or presence).
NOTE 4.7.6 Interim radioactive material storage and liquid processing i
areas may require a safety evaluation to ensure compliance with NRC Generic Letter 81-38. '
[CTL 21942]
4.7.6 Storage of Radioactive Material
- a. RP is responsible for the establishment and control of storage areas for radioactive material. All designated storage areas should
- be approved by the RPM or designee. j
- b. Radioactive material storage areas located t inside the Restricted Area should require access to be controlled by RP personnel.
- c. Storage areas should be regularly surveyed and '
inspected in accordance with RP procedures. l
- d. All radioactive material storage areas shall be posted with the appropriate radiological warning' signs in accordance with 10 CFR 20 and RP procedures.
- e. The number of radioactive material storage '
areas and the volume in each one should be kept to a reasonable minimum.
- f. The placement or removal of radioactive material to or from storage areas should be coordinated through RP.
- g. Temporary' radioactive material storage areas within the restricted area may be established for up to 90 days by RP personnel with the possibility for extension.
- h. Radioactive material should not be stored outside except for short periods during transit, or if packaged in accordance with DOT requirements while awaiting shipment, in accordance with Plant procedures.
TPP 20-2 Revision 6 Page 57 of 91
- i. When storing radioactive material in areas exposed.to the environmant, all tags, signs, and placards should be weatherproofed or placed in weatherproof envelopes to ensure readability.
- j. Items with loose surface contamination should be sealed-in marked leakproof bags.
Information on the bag or container shall include the radiation caution symbol, the words " CAUTION RADIOACTIVE MATERIAL", contact and 12-inch dose rates, contamination levels inside the container, and the technician's initials and date.
- k. Radioactive material should not be stored outside of the Restricted Area unless specifically approved-by the RPM and reported to the Plant General Manager. All storage criteria should be met, including those of an applicable written safety evaluation.
- 1. Radioactive material found uncontrolled and outside the Restricted Area or outside an RCA should be brought to the immediate attention of RP Management. Action should be taken to ensure that the radioactive material is surveyed, labeled, and properly dispositioned.
The incident should be investigated by RP and corrective action (s) initiated.
- m. Radioactive material storage containers shall not be opened in outside storage areas.
Opening of containers may be done only inside the Main RCA (i.e., Fuel / Auxiliary Building).
Any exemption requires a specific RWP approved by the RPM.
4.7.7 Accountability and Inventory of Radioactive Material
- a. Implementing procedures should specifically address the accountability of radioactive materials. Radioactive material storage areas
'should be controlled and periodically '
surveyed. The status of radioactive material storage areas should be periodically reviewed and should include:
- 1) A list of storage areas to evaluate the continued need for the storage areas TPP 20-2 Revision 6 Page 58 of 91 I
1 5
and/or the' materials and the types and radiological paramators of the areas (e.g., high radiation material, contaminated material, activated
- material, etc.).
1
- 2) Inspection of materials stored to evaluate the status of materials and area controls (e.g., physical condition of containers, access control, posting, etc.).
! b. Radioactive sources used for calibration, i standardization, and instrument checks should !
- be received as indicated in Section 4.7.2.
l
- 1) Implementing procedures should l specifically address inventory ani ~j accountability requirements. J
- 2) Sources should be inventoried at least .
semiannually, taking into consideration- i radioactive decay, comparison to- !
! Certificates of Compliance, and use and j l disposal of liquid and gaseous sources. ;
l' 3) Source Inventories should be documented j and reported to RP Supervision. ,
4
- c. Sealed Sources. '
i Sealed sources are defined as any by-product j material that is encased in a capsule designed 4
i to prevent leakage or escape of the by-product !
, material. Special nuclear material that is encased for the purpose of providing alpha radiation for. calibrating radiation detection 1-instruments shall also be considered a sealed
, source.
i 6
1
- 1) Sealed sources shall be controlled in
! 'accordance with 10 CFR 30 through 34 and
- implementing procedures.
1
- 2) Sealed sources shall be leak tested with ,
i the frequencies and criteria for results l based on activity level and type of
, source. '
- I (a) The test shall be documented and shall be capable of detecting a ;
i
)
4 TPP 20-2 Revision 6 !
l Page 59 of 91 I
l' r .. _ _ _ _ - . ,
\
l I
minimum of 0.005 microcurie of {
contamination. l (b) If leakage is detected based on i established criteria, the RPM shall i be notified and reports shall be !
submitted as indicated in Section 4.7.1.
- 3) Sealed sources that are specified in the ,
Technical Specifications shall.be >
controlled and tested in accordance with ]
the Technical Specifications as directed 1 in implementing procedures.
- 4) Sources shall be maintained, locked, or otherwise controlled for usage. A source i usage log shall be maintained. If a source cannot be accounted for during a periodic inventory or at any other time, actions should be taken to include the following:
(a) Describe the physical and radiological characteristics of the missing source and evaluate -
potential hazards to radiation workers and the public. ;
(b) Report the missing source as required by applicable implementing procedures and state and federal ,
regulations. ;
(c) Initiate investigations to locate the source and/or to determine the l reason for loss.
(d) Prepare CARS as directed in Plant procedures.
- 5) 'The following sealed sources are excepted '
from semiannual leak test and inventory:
(a) Sources which have activities equal to or below the limits specified in 10 CFR 30.71, Schedule B. i (b) Ionizing radiation reasuring instruments containing, for purposes of internal calibration or TPP 20-2 Revision 6 Page 60 of 91
standardization, one or more sources of by-product material provided that:
1
- Each source contains no more-than one exempt quantity set forth in
, 10 CFR 30.71, Schedule B, and Each instrument contains no more than 10 exempt quantities.
(c) Sources installed in gas or aerosol detectors used to warn of fire or airborne hazards.
4.7.8 Contamination Controls The primary means of preventing the spread of cLntamination is to contain contamination at its I
source and to minimize the number of contaminated areas and the amount of loose surface radioactivity contained'in each of the contaminated areas.
i
- a. Source Minimization.
The sources of radioactive contamination should be controlled to minimize the number
, and extent of contaminated areas. Elements to be included in contamination source control
, procedures are:
- 1) Control of radioactive leaks.
- 2) Ensuring proper radiological work practices.
- 3) Prevention and prompt cleanup of radioactive spills.
- 4) Decontamination of areas.
- b. Protective Clothing.
- 1) Protective clothing requirements are established on the assumption that the worker will follow approved radiation worker practices to avoid being contaminated and to prevent spreading contamination.
TPP 20-2 Revision 6 Page 61 of 91
" l
{ 2) When parsonnel are required to woar I
. protective clothing in RCAs,-the items l
] should be specified dependent upon the :
~
duties of the individual and existing !
radiological conditions. ;
I
- 3) Protective clothing shall not be used for L
work in uncontrolled areas with.the exception of noncontaminatedfprotective j clothing which may be'used for training l
( purposes. ;
i c.
Personnel Decontamination.
- i 1). LRP personnel should be notified of any ;
radioactive contamination found'on )
personnel or their= clothing (modesty j 4 garments included). j i .
(a) A Personnel / Clothing Contamination )
- Report should be completed as )
' required by implementing procedures.
- l. (b) Each report should determine the cause of the contamination event-and recommend corrective action (s) to
- prevent recurrence.
[ Dose assessments should be performed
( c') . where applicable per implementing .
j procedures. j i
- j. 2) Personnel decontamination should be i performed under the direction of RP j_ personnel.
) 3) The RPM or designee should be notified
- immediately when: l (a) Personnel decontaminations cannot be i-easily performed to releasable l- levels.
I (b) Personnel contaminations result in a L skin exposure >750 mrad.
- (c) Personnel contaminations involve tritium.
~
(d) Personnel contaminations are suspected of being internal.
i.
TPP 20-2 2 Revision 6
- Page 62 of 91 e
4.7.9 Spweial Controls Special circumstances may arise that will require special handling considerations for radioactive
{
materials. Examples of radioactive materials ;
requiring special handling are radiography sources, j and high activity radioactive waste (e.g., I
>10 rem /hr gamma radiation levels). ;
- a. Receipt of "special" types of materials or sources require the following actions: !
l
- 1) Notification of the RPM prior to bringing the radioactive material or source inside the restricted area. i
- 2) Development and approval by the RPM of a ,
plan of action for control, safe storage, i and release of the radioactive material i or source (e.g., .use existing procedures, develop temporary procedures, etc.) prior ,
i to bringing it inside the RCA.
1
- 3) Notificatian of the Shift Manager prior !
to use of a source (e.g., radiography). '
- b. Special nuclear material, fissile material, and high-level radioactive waste should be addressed on a case-by-case basis in accordance with administrative procedures and l applicable regulations. Specific control, accountability and storage, if applicable, i should be specified by the RPM. These details !
should be addressed by the RWP implementing 1 procedures and/or temporary procedures and )
action plans, and should include the following l considerations: '
- 1) Use of special containers and/or shielding.
- 2) 'Use of special rigging and lifting devices for moving the radioactive material / source including any containers !
as applicable. )
i
- 3) Temporary evacuation of nonessential l personnel and suspension of activities in j the area, l i
l TPP 20-2 L Revision 6 Page 63 of 91 l l
- 4) Temporary implementation of cdditional security measures. '
. e
- 5) Other special considerations for ALARA l
purposes as indicated in Section 4.4. 1 4.7.10 Release of Materials for Unrestricted Use All material and equipment that has entered an RCA
- shall require a survey adequate to assure thr.t no i loose or fixed contamination exists prior to removal to a non-RCA.
- a. All surfaces should be surveyed for loose and/or fixed contamination in accordance with .
Plant implementing procedures to ensure the ,
limits of Subsection 4.5.1.h are met. ,
4.7.11 Control of Materials Entering RCAs s
Materials entering RCAs should require the following controls ~
- a. Chemicals that may cause the generation of I
" mixed wastes" (e.g., chemicals that can potentially produce hazardous waste) should be i controlled to prevent contamination with radioactive material, e
- b. Packing material and unnecessary items should not be allowed into RCAs, unless the packing !
material is required to protect the integrity of the item (s).
'4.7.12 Controls Specific to Radioactive Waste
- a. Radioactive wastes'from the Trojan Nuclear
- Plant shall be controlled by the regulations specified in 10 CFR 20 and the conditions of l the facility license.
i
- b. Shipments of radioactive wastes shall be in i accordance with the applicable NRC and DOT l regulations.
- c. Records of shipments for off-site burial shall be maintained as permanent records.
TPP 20-2 Revision 6 Page 64 of 91 i
- d. Solid R;dioactiva Westo.
- 1) Solid wastes include spent demineralizer resin, expended filter cartridges, and other miscellaneous contaminated solid refuse.
- 2) Solid radioactive wastes may be handled by the Solid Waste Systems. These systems provide for storage, shipping, and disposal of solid wastes.
- 3) All solid radioactive waste shall be processed and disposed of in accordance with the license provisions of the Yadwaste contractor, the NRC and DOT regulations, and the conditions set forth in this procedure and implementing procedures.
- e. Solid Waste Drumming System.
Radioactive solid wastes conforming to the above criteria for shipment and burial site requirements may be processed for disposal in standard 55 gallon drums or other suitable containers. Solid radioactive waste will normally be placed in leakproof marked plastic bags.
4.7.13 Preparation of Radioactive Materials for Shipment i
- a. Packages prepared for shipment, which upon inspection do not meet DOT requirements, shall be evaluated for repackaging and/or storage.
Received packages which do not meet DOT requirements shalf be reported in accordance with NRC and DOT regulations.
- b. Radioactive material shall be packaged and transferred to, and received from, other facilities in accordance with applicable DOT requirements and implementing procedures,
- c. Radiological surveys shall be conducted prior to shipping and when receiving radioactive materials to verify that the radiation and removable contamination levels are in compliance with regulatory requirements and are described on shipping labels and documentation.
TPP 20-2 Revision 6 Page 65 of 91
l
- d. Elcm:nts that should ba includ.id in implementing procedures are as follows:
- 1) Contamination surveys for packages received and packages shipped to ensure i that they meet the DOT requirements for smearable contamination levels.
- 2) Radiation surveys (e.g., package contact, vehicle contact, specified distances from i the package and the vehicle, and normally 1 occupied positions in the vehicle cab) I for the material and package and for the ;
transport vehicle depending on the type i of shipment (e.g., low-specific activity (LSA), exclusive-use LSA, etc.).
- 3) Sorting and segregation of materials and processing to an acceptable form.
- 5) Receipt survey of vehicles used to transport radioactive waste.
- 6) Packaging, labeling and marking of material in accordance with 10 CFR, 49 CFR, and disposal site criteria.
- 7) Shipment of material in accordance with 49 CFR and 10 CFR.
- 8) Disposal and off-site volume reduction arrangements.
4.8 Radiological Surveys 4.8.1 Categories Radiological surveys are generally categorized as routine or nonroutine, where both categories may include all types such as dose-rate surveys, contamination surveys, etc. Survey results are used by RP staff and other support groups for:
- a. Procedure / work instruction development, as applicable.
- b. Engineering design criteria.
TPP 20-2 Revision 6 Page 66 of 91
- c. RWP cnd work packages preparation. l
- d. Pre-job ALARA planning.
- e. Pre-job and post-job briefings. !
4- _
- f. Radiation, contamination, and airborne !
i
, radioactivity trend analysis, 9 ,
4.8.2 Survey Intervals Each survey requirement shall be performed within i the specified time interval with a maximum allowable extension not to exceed 25 percent of the survey interval.
- 4. 8. 3 ' Routine Surveys
- a. Survey frequencies shall be specified in 1
implementing procedures with consideration given to hazards which may be encountered, potential for changing radiological conditions and frequency of occupation,
- b. Routine radiation, contamination, and airborne radioactivity surveys shall be performed to evaluate radiological conditions and to verify radioactive materials are being adequately controlled. Appropriate survey instruments !
and-techniques should be use'd for the survey ;
being performed. l
- c. Appropriate posting and associated responses shall be established for abnormally high or i unusual survey results,
- d. Survey results should be made available to workers entering radiologically controlled areas. ,
l
- e. Locations where routine surveys and monitoring should be conducted include, but are not limited to:
- 1) Active work areas where radiological conditions may change as a result of work being performed.
- 2) Entry and exit points from contaminated areas (e.g., step-off pads).
TPP 20-2 Revision 6 Page 67 of 91
- 3) Officds, trailers, shops, and trash !
- receptacles outside RCAs.
- 4) Major pathways inside RCAs.
l
- 5) Radiation area boundaries for-4 verification of_ posting adequacy. l
- 6) Storage areas for radioactive-wastes.
e i
- 7) Entrances to locked high radiation areas. !
- 8) RP and Radiochemistry laboratories.
- 9) Eating and break areas used by personnel {
who have been working in RCAs. :
- 10) Selected unrestricted areas, if !
- appropriate. '
1
- intermittent) and surveys required.
{
- g. RP supervision should routinely' review surveys i with regard to necessity and frequency '
consistent with good radiological protection r practices and regulatory requirements.
- h. Routine' surveys should not normally be conducted in high-radiation areas except as directed by RP supervision. These surveys 1should be' coupled with, or prior to, planned work activities in those areas in order to E maintain personnel exposure ALARA.
4.8.4 Nonroutine Surveys 1
Nonroutine surveys are those which are not !
performed at a scheduled frequency but are !
performed on an "as required" basis. Nonroutine surveys include radiological assessments for I specific jobs such as initial system opening, I equipment release to uncontrolled' areas, response to radiation alarms, etc. Nonroutine surveys 4
should be documented on appropriate survey maps.
4.8.5 Personnel Contamination Monitoring --
- a. Adequate personnel contamination monitoring instrumentation should be available to control l TPP 20-2 Revision 6 Page 68 of 91
, - - - - .-m --
1 the sproad of contamination and hot particlos to uncontrolled areas. ,
- b. All personnel who have been in an RCA are l responsible for monitoring themselves for i contamination prior to exiting the RCA. !
l
)
- 1) Initial monitoring of the individual's '
hard hat should be performed with a hand-held frisker. ,
- 2) Whole-body contamination monitors (e.g.,
Eberline PCM-1B) should be used at
)
radiological controlled area exits, as appropriate.
l
- 3) Sensitivities of contamination monitoring I instruments should be set to detect
- contamination levels equal to or better i than conventional hand-frisking methods.
I
- c. In areas where whole-body contamination ;
monitors are not used, a hand-held frisker ;
should be used to monitor personnel ;
contamination. Typical frisking techniques j that should be used include: .
- 1) Maintain frisking speed of <2 inches per second. l
- 2) Maintain detector to body distance at ,
<1/2 inch. '
- 3) Pause (approximately 5 seconds) at the nose and mouth area to check for indications of inhalation / ingestion of radioactive material.
'4 ) Pay particular attention to feet (shoes),
elbows, knees, or other areas with a high potential for contamination.
- 5) Ensure a total frisking time of
>2 minutes to cover at least 10 percent i of the body.
i
- 6) Maintain backgrounds for frisking at
<100 cpm for release from radiologically controlled areas and at <300 cpm for all other frisking areas.
TPP 20-2 Revision 6 Page 69 of 91
- 7) If the count rate incrossos or the !
frisker alarms, resurvey the area carefully and, if contamination is evident, notify RP personnel,
- d. When background levels are unacceptable (e.g.,
>300 cpm) for personnel frisking, actions should be taken that include one or more of the following:
- 1) Move the whole-body frisker and/or the hand-held frisker (and the contamination control point) to an area that has an acceptable background level (e.g., around the corner, behind a column, etc.).
- 2) Shield the frisking area and equipment to reduce background.
- 3) Frisk for gross contamination levels in the high background area, but locate the equipment for final frisking at a remote area, and provide contamination control for the passage to the remote frisking location.
l
- e. Personnel contamination detected on hair or l skin should be promptly removed under the ;
supervision of trained RP personnel. l
- f. A final check for contamination should be performed at the Access Control Facility >
before exiting the Plant. This check should be performed by a portal monitor. If the alarm indicates that contamination may be present, the individual shall perform a second check, and notify'RP if contamination is indicated the second time.
4.8.6 Survey Documentation and Review
- a. RP supervision should review completed survey documentation to ensure appropriate, adequate, and complete information is recorded. The supervisor reviewing the survey should ensure that the recorded results are legible, in accordance with implementing procedures and consistent with anticipated levels, and should TPP 20-2 Revision 6 Page 70 of 91
datermine the reason for any variances.
Information that should typically be included on survey maps or forms is:
- 1) Date and time of survey.
- 2) Location of survey.
- 3) A sketch or description of the area or component surveyed, including location of barriers, radioactive materials and other applicable information to describe the radiological status.
- 4) Instrument type and serial numbers.
- 5) Instrument calibrat.cn due date (or date of last calibration).
- 6) Name and signature, of surveyor.
- 7) RWP number and reason for survey,
- b. The results of evaluations should be documented on approved survey forms and should be made available to personnel entering RCAs.
Survey data should contain enough detail to provide. personnel with adequate information concerning radiological conditions existing in the area surveyed. Survey maps should include, as applicable:
- 1) Contact and general areas dose rates.
- 2) Contamination levels.
- 3) Airborne radi'oactivity levels, if applicable.
- 4) Identification of specific hazards (i.e.,
hot spots).
- 5) Location of radiological boundaries,
- c. Personnel contamination forms should include such items as:
- 1) Names of individuals involved.
- 2) Survey results.
TPP 20-2 Revision 6 Page 71 of 91 l
- 3) Dacontemination methods.
- 4) Results of decontamination.
- 5) Area where contaminated.
- 6) Areas worked. i
- 7) RWP number.
- 8) Root cause of event.
t
- 9) Corrective action to help prevent recurrence of contamination. ;
- d. Survey records should be filed and maintained so that previous radiological conditions can be determined. Survey records shall be maintained and retained in accordance with 10 CFR 20. Survey records shall be processed as.QA records in accordance with TPP 18-4, Nuclear Division Qualify Assurance Records Management Program.
4.8.7 The following types of survey records shall be identified as decommissioning related records and ,
retained in accordance with TPP 18-4:
- a. Secondary systems (identified es 4 cross-contaminated through the site l characterization) that have been opened or modified.
i
- b. Radiological spills both inside and outside '
the RCA.
- d. Components / systems removed as part of Plant dismantling / decommissioning.
1
- e. Areas being decontaminated for exclusion from the RCA.
- f. Routine Radiation and Contamination Surveys (Daily, Weekly, Monthly, and Quarterly). !
4.9 Instrumentation i
TPP 20-2 ,
Revision 6 l Page 72 of 91
i Colibratod-instrumentation shall be available for the datection~end mansurement of alpha, bata, and gamma radiation. Air sampling equipment'should be.available for ;
i i
general area and breathing zone air samples. Implementing ;
procedures should address instrument inventory and control, instrument calibration, and instrument operations.
4.9.1 Area Radiation Monitoring System (ARMS) '
- a. The ARMS is provided to supplement personnel i and area radiation monitoring. The primary l objectives of the ARMS are.
l t
- 1) To immediately alert Plant personnel i
entering or working in normally ;
accessible areas of increasing or l i abnormally high radiation levels, which, L if unnoticed, might result in inadvertent L overexposures. :
- 2) To inform the Control Room of the occurrence and approximate location of ;
i abnormal events resulting in the release of radioactive materials.or the i degradation of shielding structures. ;
- 3) To provide, in the event of an accident '
leading to the contamination of the Plant, a means of remotely determining external dose rates in those areas most likely to be contaminated, prior to entry by personnel.
- 4) To_ provide a continuous record of external dose rates at selected locations, .thereby ensuring detection of transient increases in dose which are attributable to rapid changes in the radioactivity content of equipment and i process streams.
, b. Each' monitor channel is provided with a 1 j
l- triple-level alarm that does not impair !
j indicator movement. -i l 1) One alarm is set below the background l
i-radiation level to act as a circuit I failure alarm.
i
- 2) The second alarm is set at an alert radiation level.
i 4-TPP 20-2
{ Revision 6 i
, Page 73 of 91
. - . _ _ _ - ~ - . . _ -
i
- 3) Tho third alarm is set at a radiation level that is higher than the alert alarm ;
to warn of rapidly increasing radiation '
l levels.
- 4) These setpoints are based on design objective dose rates and occupancy factors and are subject to revision 1
during Plant operation.
i 4
- c. ARM Policies and Group Responsibilities. .
t
- 1) RP responds to alarms and reviews
' operational test data. '
- 2) Operations monitors ARM operability in accordance with implementing procedures i l and informs RP of alerts, alarms, or failure.
- 3) Maintenance: 1 (a) Perform calibrations per implementing procedures.
l (b) R'eview calibration results. l I
(c) Review setpoint changes for high
- alarms and alerts prior to approval.
(d) Change setpoints per approved setpoint change procedure.
j 4.9.2 Portal and Personnel Contamination Monitors These monitors are used to detect radioactive material on a person. Each monitor is capable of sensing entry into the frame and then counting for !
a predetermined time. When a person leaves before the elapsed time, the recount light and alarm will initiate. Any time a radiation alarm activates, perform a' recount. If a radiation alarm activates on the recount the individual should remain in the immediate area and notify RP (Control Room if RP personnel not present) for subsequent action.
4.9.3 Instrument Inventory and Control
- a. Implementing procedures should ensure that instruments are calibrated at the required frequency and are functioning properly.
TPP 20-2 Revision 6 Page 74 of 91
Adequate instruments should be available for radiation surveillance and associated measurements.
- b. Instruments that are broken or require calibration should be tagged "out of service".
4.9.4 Instrument Calibration
- a. Procedures for calibration and source checks of radiation monitoring equipment and air sampling equipment should be prepared consistent with guidance provided in ANSI N-323 and other applicable industry standards,
- b. The primary calibration frequency for commonly used portable radiation monitoring instruments and portable air sampling equipment should be at least every six months, after repairs or modifications or when malfunctions are suspected.
- c. Semiportable and fixed instrumentation should be calibrated at least annually, after repairs or when malfunctions are suspected.
- d. Instrument source checks should be conducted as prescribed in implementing procedures.
- e. A review of historical maintenance and calibration trends should be< performed periodically for each instrument type. The review should evaluate instrument performance and the adequacy of calibration frequencies.
- f. Calibration procedures should include the following:
- 1) Instrument specifications.
- 2) Frequency of calibration. l
- 3) Description of operating settings / l parameters.
- 4) Environmental limitation (if appropriate).
1
- 5) References (e.g., instruction manuals, other related procedures, regulatory guidance, etc.).
TPP 20-2 Revision 6 Page 75 of 91
- 6) Required equipment for calibration (e.g.,
sources, tools, jigs, test equipment, etc.).
- 7) Applicable drawings and schematics.
- 8) Calibration data forms may be in a separate document.
- g. Laboratory analysis equipment shall be calibrated using National Institute of Science and Technology traceable sources of appropriate geometries and energies.
Documentation of calibrations and applicable cross-checks shall be maintained as quality records in accordance with TPP 18-4.
4.9.5 Instrument Procedures I
- a. Operating procedure (s) should provide the means by which RP instruments are accepted for use, maintained in calibration and maintained in proper working order.
- b. Vendor technical manuals should be available to provide specific user information on each i instrument.
4.10 Control of Exposure to the Public '
4.10.1 Doses to Members of the Public j Trojan activities shall be conducted such that the dose to individual members of the public does not exceed 100 mrem TEDE in a year, and the dose in any unrestricted area from external sources does not i exceed 2 mrem in any one hour. j
- a. Compliance with the limits for dose to members of the public shall be demonstrated by measurement and calculation.
- 1) The highest dose to any individual member of the public should be calculated using the highest occupancy factor and the highest dose rate from external exposure and from effluents in the applicable area (if any).
- 2) Calculations and measurements shall be performed in accordance with the Off-Site TPP 20-2 Revision 6 Page 76 of 91
l Dose Calculation Manual'(ODCM)
(PGE-1021).
- 3) Calculations used to demonstrate compliance with the dose limits for members of the public should take into account radioactive material stored or in transit in the controlled area.
- b. The dose limits for members of the public shall apply to individuals who work in or frequent the Controlled Area but do not enter the Restricted Area as part of their duties.
1
- c. Individuals who work in or frequent the Restricted Area are subject to the occupational dose limits specified in 10 CFR 20.
4.10.2 Radioactive Liquid and Gaseous Control Liquid and gaseous effluent releases shall be monitored and controlled using installed Plant equipment and guidance provided in the Technical Specifications, the Off-Site Dose Calculation Manual, and in implementing procedures.
4.10.3 Radiologica1 Environmental Sampling and Analysis
- a. The PGE Radiological Environmental Monitoring l Program (REMP) should be periodically reviewed
- to address changing regulations and Plant conditions where applicable.
- b. Specific environmental sample types and locations are provided in the ODCM.
! (CTL 44096) c. Reductions in the scope of the REMP shall be discussed with the Oregon State Health Division before implementing the reduction.
- d. Records of any radioactivity detected in shoreline soil monitoring or terrestrial l
vegetation monitoring shall be retained as a
- Decommissioning Related Record in accordance with TPP 18-4.
4.11 Review, Audit, and Performance Analysis i
, To ensure the RP Program is effectively implemented and
- maintained, an organized system of review and audits should TPP 20-2 Revision 6 Page 77 of 91
I be implcmsnted-in accordance with the Trojan Nuclear l Quality Assurance Program and this section. !
4.11.1 Radiation Protection Self Assessment and Review j i
- a. The RPM should be responsible for the quality !
of work performed by RP personnel. The RPM or !
designee should review for adequacy and j approve completed radiation survey ,
documentation on a day-to-day basis. :
i
- b. RP reviews should be planned and conducted by ;
RP Supervisors, Managers, Radwaste '
Specialists, and Health Physicists on a l routine basis. These self assessment reviews '
should be conducted in accordance with Plant policies and should include walkdowns to l directly observe the effectiveness of the RP Program including, but not limited to, the j following:
- 1) RP staff effectiveness. i l
- 2) Facilities and equipment allocation and l use. i
-l
- 3) Worker radiological work practices. l
- 4) Compliance with RP procedures, policies, ;
and specifications.
l
- 6) Conformance with quality goals such as j person-rem dose, radioactive waste j minimization,. etc. l
- 7) Implementing procedures are adequate to l implement the RP Program policies. l
- 8) The RP Program and implementing
' procedures are adequate to meet-the applicable regulations.
- 9) The work completed is in accordance with the Trojan Nuclear Quality Assurance ]
Program. j
- c. Deficiencies and other findings should be documented and addressed in accordance with implementing procedures.
TPP 20-2 Revision 6 Page 78 of 91
- d. RP shall parform an annual review of the Radiation Protection Program content and t implementation as required by 10 CFR 20. ,
4.11.2 Corrective Action Recuests The-RP staff should use the CAR system as the ;
primary means to identify radiological incidents '
and significant radiological deficiencies in order :
to determine root causes, when applicable, and to correct errors that cause radiological performance '
problems. t 4.11.3 Radiological Deficiencies
- a. Radiological deficien.cies are occurrences involving poor radiological work practices with relatively minor consequences, but ;
require supervisory action for proper resolution.
- b. Examples of occurrences attributable to radiological deficiencies include, but are not s limited to, the following: !
- 1) Failure to comply with radiological '
postings. ;
- 2) Failure to comply with RP procedures. l
- 3) Lost dosimetry.
- 4) Improper frisking. -
- 5) Personnel contamination instances above a l designated level.
l
- 6) Poor radiological work practices.
- 7) Improper use of, or problems with, respiratory protection e.wtpment.
i
- 8) Eating, drinking, smoking, or chewing in
, the RCA. ;
- 9) Failure to comply with RWP requirements.
- 10) Unnecessary generation of radioactive or mixed waste.
TPP 20-2 Revision 6 Page 79 of 91
.. ._. _ _ . _ _ . ~ _ ~ . _ . _ . . _ _ . _ _ . - - . _ - _ . _ _ . _ .. . . . _
l 1 I )
- 11) Oparation and maintenance of equipment.in a radiologically unsafe manner. {
l 4.11.4 Radiological Incidents ;
- a. Radiological incidents are occurrences that have or could have the potential for violating federal regulations and TTSs or involve a ;
L serious breakdown in the effectiveness of the ,
RP Program.
i 1
- b. Radiological incidents such as. spills, L personnel overexposures, contaminated ;
j injuries, severe illness or injury in an RCA, i i abnormal radiation levels, etc., should M+
l immediately reported to the Control Room. a l
p 1) The Control Room should notify RP . )
L personnel and take the necessary steps to '
! confine the hazard and assist injured i personnel. i l
- 2) Specific actions for local on-site, i
general on-site, and off-site incidents are given-in Emergency Plan Implementing !
l Procedures (EPIPs). Each situation must j
! .be evaluated as it occurs and action '
taken accordingly. !
- j. c. Radiological incidents are discussed below, ,
j but are not limited to the following: i
- 1) Overexposures. (
1 In the event that an-individual receives '
I a radiation dose in excess of an i authorized gdideline or regulatory limit, l the following measures should be taken:
t (a) The individual should be removed l
from the RCA and restricted from work within any RCAs until authorized by the RPM.
l (b) The Shift Manager, RPM or designee,
! and Plant General Manager should be immediately notified if personnel exceed their administrative guideline.
i l TPP 20-2 Revision 6 Page 80 of 91
_ . . . ._ _ .- _ ~ _ .- . _ _ _ _ - . . _
l (c) If the overexposure is of a magnitude which endangers the i individual's health and well-being, 3 he/she should be placed under l
- medical care. I (d) An incident. investigation should be i a
conducted, and a CAR should be !
! initiated. l 4 e
- 2) Unexpected High Radiation Levels. ;
L Unusual or unexpected high radiation l
levels will normally be detected by i routine monitoring and/or abnormal :
readings on the ARMS. Should this occur, i the following procedure should be ;
implemented: l (a) All personnel leave the area immediately.
(b) Notify the Control Room who will i notify RP personnel and the Shift Manager.
(c) Individuals should read their SRDs to quickly assess their radiation dose.
(d) Work may be resumed in the affected area when authorized by the Manager, RPM or designee.
- 3) Continuous Air Monitor (CAM) Alarm.
Unusual or unexpected high airborne radioactivity levels will normally be detected by the portable CAM operating in the RCA. Should a CAM alarm occur, the following procedure should be
' implemented: j (a) All personnel leave the area immediately.
(b) Notify the Control Room who will notify RP personnel and the Shift Manager.
TPP 20-2 Revision 6 Page 81 of 91
(c) Individuals should check for l j
facial / nasal contamination-and perform a whole-body frisk.
(d) Work may be resumed in the affected i area when authorized by the RPM or
! designee.
s' 4) Radioactive' Spills. !
Caution should be exercised when dealing with radioactive spills since it is I relatively easy for even a small spill to ;
become an airborne radioactivity hazard. <
Airborne radioactivity may result when i either the contamination is dry,.or dries ;
i; and becomes airborne, or.when a liquid containing dissolved radioactive gasses is spilled. Personnel involved in a ;
i-major radioactive spill should comply ,
with.the following guidelines:
(a) The spill should be confined j immediately and covered if no i serious additional exposure,to '
personnel will result. '
~ '
1 (b) Personnel should clear the immediate area as quickly as possible and ;
I monitor themselves for i contamination. .
(c) The person discovering the spill should notify the Control Room who .
will immediately notify the RP- j personnel office and the Shift !
i Manager. >
(d) RP personnel will direct the additional monitoring of all 1 personnel involved, as well as the I area of the spill, and determine the ;
action required for resolving radiological problems.
(e) Work may resume in the affected area j when it has been determined that rua l uncontrolled radiological hazard 2
exists.
1 TPP 20-2 Revision 6 1 Page 82 of 91 I
- 5) Injury or Illness in the RCA.
(a) Personnel who are injured or become seriously ill in a radiologically controlled area should normally be removed from areas of contamination or high radiation before administering first aid.
(b) In general, all protective clothing should be removed at the barrier and the individual decontaminated, if necessary. In severe cases, first aid will take precedence over decontamination.
(c) In cases of injury involving an open wound that is contaminated, the RPM or designee should be notified immediately.
(d) If the emergency is serious enough to require hospitalization and there are radiological complications, the patient will be taken to the hospital specified in the EPIPs.
- d. Investigations.
An investigation should be initiated and a report completed for any of the following incidents:
- 1) Personnel receiving a radiation dose, either planned or unplanned, in excess of their administrative dose guidelines.
- 2) Personnel receiving in excess of allowable exposure to airborne radioactivity (excluding submersion dose nuclides), or a positive internal uptake
'>10 percent of an ALI.
- 3) Incidents af*ecting the results of personnel dosimetry devices such as off-scale PICS, malfunctioning DADS, and lost dosimetry.
- 4) Incidents involving significant contamination of personnel, as addressed in implementing procedures.
TPP 20-2 Revision 6 Page 83 of 91
4.11.5' Notific.ation of Off-site Groups
- a. Formal notification of vard us governmental agencies may be required in the event of a serious radiation incident or emergency. All communications with federal and state agencies should be handled by those persons specifically assigned such duties in the EPIPs.- Notification should contain as complete and accurate information concerning the events and progress of the recovery operation as possible.
- b. Reportable Radiological Incidents.
- 1) Reporting of radiological incidents shall be performed in accordance with the applicable Plant implementing procedure.
- 2) IMMEDIATE notification of the NRC shall be performed for any of the following conditions:
(a) A TEDE of 25 rems or more to any individual.
(b) An LDE of 75 rems or more to any individual.
(c) An SDE of 250 rads or more to the skin or an extremity of any individual.
(d) The release of radioactive material, inside or outside of a restricted area, such that, had an individual '
been pre ~sent for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the individual could have received an intake five times the applicable ALI. ]
- 3) ' Notification of the NRC shall be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery for any of the following conditions:
(a) A TEDE to any individual exceeding 5 rems in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.
(b) An LDE to any individual exceeding 15 rems in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.
TPP 20-2 Revision 6 Page 84 of 91
i (c) An SDE to the skin or en extrcmity of any individual exceeding 50 rems in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.
(d) The release of radioactive material, inside or outside of a restricted area, such that, had an individual been present for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the l
' individual could have received an intake in excess of one ALI.
- 4) Required written reports shall be provided to the NRC Region Administrator within 30 days using a Licensee Event Report (LER) as required by 10 CFR 50.73 and the applicable Plant implementing procedure.
4.12 Reports and Records 4.12.1 RP Program reports and/or records required by 10 CFR, 49 CFR, and Technical Specifications shall be retained as quality-related records in accordance with TPP 18-4. Such reports and/or records should be identified in implementing I procedures. The following RP Program areas / provisions produce such reports / records:
l a. Radiation Worker Training.
- b. ALARA Reviews.
- c. Radiation Work Permits.
i
- d. Respiratory Protection.
- e. External Dose Asssssment/ Assignment.
- f. Internal Dose Assessment / Assignment.
- g. Declaration of Pregnancy.
- h. Radioactive Material Receipts and Shipments.
- 1. Radiological Surveys,
- j. Radiological Environmental Monitoring.
l TPP 20-2 Revision 6 Page 85 of 91
l l 4.12.2 Units.of Radiation and Radioactivity 1
- a. The units curie, rad and rem, including !
. multiples and subdivisions, shall be used on ;
records required by 10 CFR-20. j l
- b. The units of all quantities shall be clearly indicated on records. ,
- c. A clear distinction among the dose quantities I CDE, CEDE, DDE, LDE, SDE skin, SDE extremity, l and TEDE shall be made when entered on dose L . records.
- d. The units Roentgen (R), mR, and mR/hr may be l used on survey and calibration records since l- an R is approximately equal to a rem for beta-and gamma radiation of the energies found at l Trojan; however,- the units of R may NOT be L used on dose records or in conjunction with
!' any of the quantities for dose.
4.12.3 Occupational Dose' Records
- a. RP shall obtain the current year occupational doses for in-processing radiation workers.
). 1) A written signed statement from the l individual, or from the individual's most l recent employer for work involving
! radiation exposure, that discloses the l . nature and the amount of any occupational dose that the individual may have received during the current year, may be accepted as a record of the occupational-l dose that the individual received during the current ear.
- 2) A reasonable attempt should be made to {
l: obtain written confirmation of j occupational dose from the facilities )
' involved, following the guidance of i l
Regulatory Guide 8.7'(see reference l section). I
- b. RP should attempt to obtain the records of lifetime cumulative occupational doses for j
, in-processing radiation workers, following the l L guidance of Regulatory Guide 8.7 (see i reference section).
I TPP 20-2 Revision 6 Page 86 of 91
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- c. For those individuals who require monitoring i for both internal and external doses, the CEDE !
and the.DDE shall be summed to determine the TEDE. !
I
- d. For those individuals who do not require :
internal monitoring, but for whom a CEDE is !
recorded, the CEDE and the DDE may be summed to determine the TEDE.
- e. A radiation exposure file shall be maintained for each individual for.whom monitoring is required. The file shall contain applicable ,
records as follows: i
- 1) Previous occupational dose history.
- 2) Bioassay reports.
l
- 3) Record of individual monitoring results I l
required by 10 CFR 20.
- 4) Results of radiation exposure i investigations and dose assessments.
- 5) Record of annual and/or termination dose reports required by 10 CFR 19.
- f. A computer radiation dose record may also be maintained for each individual for whom monitoring is required.
- 1) The computer dose record should contain the individual's. previous years occupational doses, current' year occupational doses, and monitoring periods..
- 2) The computer dose record may be used to generate the individual dose reports required by 10 CFR 19.
- g. Individual dose records shall be maintained !
and stored in such a way as to protect the privacy of individuals.
- h. Records of dose to the embryo / fetus of a 4 declared pregnant woman, and the written '
declaration of pregnancy shall be maintained mother's exposure file.
TPP 20-2 Revision 6 Page 87 of 91
4.12.4 Occupational Dose Reports
- a. The results of individual monitoring shall be reported to the NRC annually, for each individual for whom monitoring was performed, ;
using an NRC Form 5, equivalent form, or l electronic media containing all the NRC Form 5 information. These reports shall be made pursuant to 10 CFR 20.
)
- b. The following dosimetry reports shall be generated and disseminated to the applicable j
individuals and orgaajzations: )
. i
- 1) NRC Form 5 or equivalent reports listing l the external and internal (if ,
-appropriate) radiation doses received at '
PGE facilities will be sent to each l individual who terminates monitoring I during a calendar year. This includes employees, visitors, vendors, and contractors.
- 2) Annual reports on an individual's I r
radiation dose shall be provided to the individual as required by 10 CFR 19.
- 3) Annual reports will be sent to the NRC as required by Technical Specifications.
4.13 Planned Special Exposures (PSE) e With the Trojan Plant in a SAFSTOR condition, Planned -
Special Exposures will not be allowed. When Plant ;
conditions warrant consideration of using the regulatory l
- option of a PSE, a program consistent with Regulatory .
Guide 8.35 will be implemented'. '
l
5.0 REFERENCES
Y 5.1 External Commitments a
5.1.1 Provide guidance for designating Radioactive
~
Material Storage Areas. (CTL 21942] Applicable Section: 4.7.6.
5.1.2 Include a requirement to discuss reductions in the scope of the Radiological Environmental Monitoring
, Program with the State Health Division before s
TPP 20-3 Revision 6 i Page 88 of 91
-1 implemanting the roduction. [CTL 44096) Applicable Section: 4.10.3.c. {
t I
, 5.2 Standards, Regulations, and Guidelines !
5.2.1 10 CFR 19, Notices, Instructions and Reports to ;
1
, Workers: Inspection and. Investigations. !
5.2.2 10 CFR 20, Standards for Protection Against
- Radiation.
5.2.3 10 CFR 30, Rules of General Applicability to 4
Domestic. Licensing of Byproduct Material.
5.2.4 10 CFR 31, General Domestic Licenses for Byproduct
- Material.
5.2.5 10 CFR 32, Specific Domestic Licenses to Manufacture or Transfer Certain Items Containing i Byproduct Material.
i 5.2.6 10 CFR 33, Specific Domestic Licenses of Broad
- Scopes for Byproduct Material.
5.2.7 10 CFR 34, Licenses for Radiography and Radiation Safety Requirements for Radiographic Operations.
5.2.8 10 CFR 50, Domestic Licensing of Production and Utilization Facilities. ;
5.2.9 10 CFR 61, Licensing Requirements for Land Disposal
! of Radioactive Waste.
5.2.10 Oregon License ORE 0328-2. '
5.2.11 NRC Regulatory Guides (RG):
~
4
- a. RG 1.8-1977, Personnel Selection and Training
- (with exceptions).
- b. RG 8.7-1992, Instructions for Recording and
, Reporting Occupational Exposure Data,
- c. RG 8.9-1993, Acceptable Concepts, Models,
- Equations, and Assumptions for a Bioassay Prop am.
T 4
TPP 20-2
, Revision 6 Page 89 of 91 t
, -..y + .c . , - - , ,.m., - ., e
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- o. RG 8.34-1992, Monitoring Criteria and Methods to Calculate Occupational Radiation Doses,
- f. RG 8.35-1992, Planned Special Exposures.
- g. RG 8.36-1992, Radiation-Dose to the Embryo / Fetus.
- h. RG 8.38-1993, Control of Access to High and Very High Radiation Areas in Nuclear Power Plants.
- i. Refer to the Trojan Defueled Safety Analysis Report, Table 3.5-1, for other regulatory guide commitments and exceptions.
5.2.12 NRC Generic Letter 81-38, Storage of Low-Level Radioactive Wastes at Power Reactor Sites.
5.2.13 NRC Bulletin 79-19, Packaging of Low Level Radioactive Waste for Transport and Burial.
5.2.14 ANSI N-323, Radiation Protection Instrumentation f Test and Calibration, 1978.
5.2.15 ANSI N18.1, Selection and Training of Nuclear Power j Plant Personnel, 1971. t 5.2.16 ANS 3.1, Selection, Training, and Qualification of Personnel for Nuclear Power Plants, 1981. 1 i 5.3 Procedures I 5.3.1 TPD 20-1, Radiation Protection Program Policies. !
5.3.2 TPP 12-1, Nuclear Division Manual Procedure Use and Organization.
5.3.3 TPP 14-11, ALARA Review.
5.3.4 TPP 14-12, Radiation Work Permits.
5.3.5 TPP 17-1, Corrective Action Program.
5.3.6 TPP 18-4, Nuclear Division Quality Assurance Records Management Program.
5.3.7 TPP 20-1, Rules for Working in Radiologically l Controlled Areas.
5.3.8 TPP 20-3, Conduct of Radiation Protection.
TPP 20-2 Revision 6 l Page 90 of 91 1
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I 5.3.9 TPP 20-12, Access Control for High and Very High Radiation Areas.
, 5.3.10 TPP 20-14, Personnel and Clothing Contamination.
5.3.11 TPP 20-15, Radioactive Material Receipt Control.
5.3.12 TPP 20-16, Declared Pregnant Women.
5.3.13 TPP 20-19, Release of Materials for Radiologically Controlled Areas. ~
l 5.3.14 TPP 20-30, Administrative Dose Guideline Extension.
5.4 Calculations None.
5.5 Source Documents 5.5.1 Trojan Defueled Safety Analysis Report (DSAR),
Section 5, Radiation Protection.
I l
6.0 RESPONSIBILITIES 6.1 The Trojan Plant General Manager has the ultimate l responsibility for assuring that an effective RP Program is I implemented. The RP Manager has overall responsibility for the RP Program. j 7.0 RECORDS Records and reports should be maintained and'provided in t accordance with 10 CFR, 49 CFR, Technical Specifications, I and TPP 18-4, as applicable (s'e'e Section 4.12). {
)
TPP 20-2 Revision 6 Page 91 of 91
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