ML20246F341

Forwards Response to Request for Addl Info Re Decommissioning of Triga Reactor

ML20246F341
Person / Time
Site:	05000294
Issue date:	05/04/1989
From:	Wilkinson R MICHIGAN STATE UNIV., EAST LANSING, MI
To:	Michaels T Office of Nuclear Reactor Regulation
References
NUDOCS 8905120205
Download: ML20246F341 (33)

Text

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l MICHIGAN STATE UNIVERSITY 1

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,- - VICE PRESIDENT FOR FIN.WT AND OPERATIONS AND TREASURER _

412 ADMINISTRATION BUILT ANG EAST LANSING

• MICHIGAN

• 48824 May 4, 1989 Mr. Theodore S. Michaels, Project Manager Standardization and Non-Power. Reactor Project Directorate E

Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Reference Docket No. 50-294, License R-114

Dear Mr. Michaels:

This is in response to your request for additional information concerning the decommissioning of the Michigan State University TRIGA Reactor. The attachment provides a remonse to each of the requests for additional information.

If you have any questions regarding these responses, please feel free to contact Dr. Bruce W. Wilkinson at 517/355-3444.

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Si erely, STATE OF MICHIGAN)~

M o r Wilkinson COUNTY OF INGHAM j

't Vice-President, Finance & Operations subscribed and sworn to before me, a Nota " Pyblic, thij gh day of May, 1989.

RW:BW/flp / -

Attachment 4M -

.NIA STONART c: Office of the Mayor 7 Notary PubH, Ingha n Co., Mi My Comm. Expires Dec. 13,1992 '

US N C Doc. Control Deck-410 Abbott Road Washington, DC 20555 East ~ Lansing, MI 48823 Dr. Bruce Wilkinson Special Assistant to the Governor Reactor Supervisor Office of the Governor College of Engineering Room I - Capitol Building Michigan State University Lansing, MI 48909 East Lansing, MI 48824 US NRC Region III Chief 799 Roosevelt Road Division of Radiological Health Glen Ellyn, IL 60137 Department of Public Health P.O. Box 30035 Lansing, MI 48909 O

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890512O205 890504 i PDR ADOCK 05000294 P PDC .,sv a a. g~ru, sau.%.a onort..as 1.nausw.

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.6 3 CHEM NUCLEAR SYSTEMS.lNC. .

(.. I l I r j RESPONSE DOCUNENT TO NRC ADDITIONAL INFORMATION REQUEST ON THE MICHIGAN STATE UNIVERSITY TRIGA REACTOR FACILITY DECOMMISSIONING PLAN

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NRC LICENSE NO. R-114 DOCKET NO. 50-294 MICHIGAN STATE UNIVERSITY l

ENGINEERING BUILDING i.

l EAST LANSING, MICHIGAN I

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l , )). la. As requested by the NRC, the specific-identity (names) of the key D decommissioning personnel are as follows:

Michiaan State University Responsible Individual (s)

Reactor Supervisor B.W. Wilkinson Radiation Safety Officer W.H. Malchman Safety M.W. Mitchell J. Parmer C. Eigenauer Chem-Nuclear Project Manager: M.R. Manning Corporate Health Physicist M.S. Whittaker Personal qualifications of the above individuals are contained in Attachment A.

Because of the uncertain decommissioning start date, it is not possible-(' '

to identify all of the Chem-Nuclear personnel to be assigned at this

' time. The Project Manager (M.R. Manning) with the concurrence of the

!- Corporate Health Physicist is responsible to ensure'that selected individuals possess the necessary qualifications as required by the contractor's Radiological Control Program (CNSI Procedure FS-RP-001, attached). Each individual will be made aware of and be required to i understand the responsibilities that are associated with his/her position on the Project (as outlined in Section 1.5.2 of the '

Decommissioning Plan).

Ib. Statements from each of the above individuals acknowledging their understanding regarding their position with respect to decommissioning and decontamination as well as the individual's understanding of the duration of his/her commitment and the percentage of full-time employment anticipated in the fulfillment of these duties have been provided as Attachment A.

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2. Hot' particles are not expected to be generated during the L decommissioning of the MSU reactor. The nature of materials which will remain on site after fuel has been removed is such that high specific  !

activity microscopic radioactive particles are not expected to be ..

present'or generated.

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Despite this,.the Contractor will implement steps to ensure that the presence of hot particles is detected early on and that monitoring and -

control of any particles which may be generated is performed in accordance with ALARA principles to minimize personnel exposures to hot particles. .The specific detailed requirements necessary to implement

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these steps are contained in a site-specific Radiological Control Work Plan which is being prepared as a supplement to the already established Radiological Control Procedure (CNSI FS-RP-001 - attached ). Key aspects of this Work Plan that address the control of Hot Particles are as follows:

(~ o Surveys for hot part'icles will be conducted in pro. ject areas

( using tape, treated cloths, double sided taped paint rollers, and/or other materials capable of entrapping particles. After-use of the survey materials to collect any particles which may be present, they will be monitored using a thin-window GM

" pancake" probe and an Eberline RM-14 (or equivalent) rate meter to determine the presence or absence of hot particles.

, Particles discovered using these survey methods will be evaluated for activity content / relative size and an attempt made to determine the source or origin. If possible, the particle (s) will be retained and analyzed by gamma spectroscopy to determine isotopic content. ,

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i A o Hot particle zones will be established where the potential

'l exists for the presence or generation of hot particles. -Any zone so designated by the Radiation Safety Officer / Radiation Control' Supervisor shall be identified as' a " Hot Particle Zone" .

and shall be pcsted to' describe the possible level of hot particle contamination. A control point will be set-up at the zone boundary where detailed personnel monitoring will be

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performed prior to exiting that area. Additional monitoring will be required at the work area control point which will be located between the Hot Particle Zone control point and the exit from the facility.

o If personnel contamination due to hot particles is found, appropriate dose calculations will be done in accordance with NUREG/CR-4418 (PNL 3610), " Dose Calculations for Contamination of the Skin using the Computer Code VARSKIN" and NM/MIRD pamphlet No. 7, " Distribution of Absorbed Dose around Point f 's Sources of Electrons and Beta Particles in Water and other

! Media".

o Personnel exposures will be monitored / controlled as discussed in Section 2.1.3 of the Decommissioning Plan to ensure that the limits specified in 10 CFR 20 are not exceeded.

3. The NRC staff has advised MSU that unless the acceptance criteria are met with the dose rate measurements taken at 1-meter from the bottom of the tank, filling the reactor tank with concrete would be an exercise i of the entombment option which requires appropriate and continuing surveillance program under a possession-only license.

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.3 As discussed in Section 1.4 of the Decommissioning Plan, Michigan State i b University proposes to implement the DECON method for facility decommissioning. No entombment options are contemplated nor requested at this time.

MSU will conduct the additional radiological surveys as advised by the NRC in your letter dated April 5,1989. This will include surveys for surface contamination on the floor and walls _ of the reactor tank cavity. I as well as exposure-rate measurements which will be taken at approximately 1-meter above the center of the cavity floor. Surface contamination will be reduced to within the limits specified_in Table I of Reg. Guide 1.86. The nominal limit of 5 micro-Roentgen /hr above background will be applied to the exposure-rate measurement.

Background will be established by taking the same measurement in areas where similar geometric conditions and materials of construction are j found. i i

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U 4. Beta exposure rates will be nieasured as part of the routine and ,

task-specific radiological surveys performed per Section 2.1.4 of the Decommissioning Plan (DP), " Implementing the Radiological Protection Program" and the Contractor's Radiological Control Procedure (CNSI FS-RP-001 - attached). The instruments that will be used to perform these surveys are discussed in Section 2.1.5b of the DP, " Radiological Protection Facilities, Instrumentation, and Equipment - Instruments".

Figure 2.1 ef the DP provides specific technical information regarding manufacturer, model numbers, and detector types that will be used for beta exposure rate surveys. The beta exposure rates will be measured by taking both open and closed probe readings during the survey. The difference between the readings will be multiplied by a correction factor based on the response of the particular detector to a beta field I

with similar characteristics. This will provide an estimate of the  !

true beta exposure rate value.

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l m General information regarding the control of skin exposure is given in r

'v) Section 2.1 of the DP, " Radiation Protection Program". Section 2.1.4 of the DP, " Implementing the Radiation-Protection Program" describes detailed ALARA procedures that will be implemented during the dismantling and decommissioning activities, and which represent the i initial exposure control measures. Detailed exposure control procedures are contained in the contractor's Radiological Control Procedure (provided - see CNSI FS-RP-001). Chapter 6 of this 5-procedure, " Guidelines for Controlling Radiation Exposure" includes sections regarding minimizing radiation exposure, procedures and work instructions, radiation work permits, and temporary shielding. All radiation exposure is minimized by careful pre-planning, routine area l

surveys, tracking of personnel exposures, and a strong commitment to ALARA goals.

The radiation work permit (RWP) system will provide a key mechanism for ;

controlling skin exposures. The RWP includes information regarding q radiological conditions in the work area. A pre-job conference is kJ required prior to initiation of work, and includes a discussion of the work scope, dosimetry and protective clothing requirements, survey results, stay time limits, and emergency actions. In addition, specific requirements designed to monitor and control " Hot Particles",

which were described in response to question #2, include specific procedures designed to measure and control personnel skin exposures.

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5. A copy of the Contractor's Radiological Control Procedure (CNSI FS-RP-001, " Radiological Control Procedure for Field Projects") is )

attached. As specified in this procedure, the Project Radiological Control Supervisor is responsible for the implementaf.:on of the j Radiological Control Program. This includes ensuring that all project  !

personnel are properly trained prior to beginning any radiation work (see Section 3.0, " Requirements"). The specific requirements for this 3 training are discussed in CNSI FS-RP-001 Appendix A, Section 106

" Radiological Control Training Requirements". The appropriate degree of training for personnel on this particular Project is as follows: )

Function / Responsibility Trainina Requirement / Level  !

Project Staff (Supervisory) Personnel Section 108, " Radiological and Radiological Control Technicians Control Personnel Training Standard" f) Decontamination Technicians Section 107, " Radiation Worker Training Standard" All records pertaining to personne1' training will be maintained as part of the permanent Project file.

6. Although not specifically described in the Decommissioning Plan, it is i our plan to utiliza a shielded handling device to latch onto, raise,  ;

and remove the Rotary specimen rack (RSR) from the reactor tank (a fabrication drawing showing this device is attached as Figure 1). This device is designed to provide sufficient shielding of the top surface of the rotary specimen rack while it is being withdrawn from the pool.

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i An assessment (verification) will be made on-site once the fuel has

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been removed from the tank to check actual vs. calculated exposure  !

rate (s) from the various reactor components (including the rotary specimen rack). Based upon these surveys, the shielding afforded by the handling device will be re-evaluated to ensure that it is adequate for this operation (in keeping personnel exposure ALARA - e.g. <200 mR/hr 0 IM from the top of the rack). Additional shielding will be

) added as necessary on top of the handling device before removal of the RSR from the reactor tank.

Once the RSR has been brought near the surface of the pool, a temporary shield will be formed at the SE corner of the reactor pit opening using lead bricks. This will form an extension to the existing pool ledge which is approximately 10" high (refer to Figure 1.ll in the Decommissioning Plan). The RSR will then be brought just above the o surface of the pool and positioned into the shielded " alcove". This step is necessary to allow disassembly of the last section of the (3 drive and sample tube assemblies from the RSR. Adequate shleiding will l be provided/ positioned to reduce the exposure rate to approximately

<200mR/hr 0 Ift during this operation.

Following the removal of the RSR drive and sample tube assemblies, the shielded shipping container will be positioned at a location adjacent to the reactor pool and under the garitry crane. Using the remote crane pendant, the shielded handling device attached to the lazy susan will be lifted up and over the shield wall, and placed directly into the shielded shipping container. At this point dose rates exterior to the box will be minimal, permitting manual placement of the lid on the shipping box.

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k fs A task specific work plan detailing this operation will be prepared by b the contractor and approved by MSU prior to performing these operations. Personnel performing these operations will be trained using mock-ups, review of the drawings, and practice as required prior to the actual removal of the RSR. l It is expected that removal of the drive and sample tube from the RSR l will result in extremity and personnel exposures well below quarterly I limits.

7. The criteria that will be used is that specified in 10CFR20.303,

" Disposal by Release into Sanitary Sewerage Systems". MSU will j ascertain that these limits will not be exceeded for such disposal.

8. In general, the techniques that will be employed to decontaminate e

various surfaces are described in the contractor's Radiological Control I It is anticipated that since Procedure (CNSI FS-RP-001, Chapter 12).

the reactor components themselves are to be re-used in a similar application, only a gross decontamination of such items will be  ;

performed.

Most radioactive contamination can be removed by normal cleaning.

Wiping with a damp rag soaked with detergent will usually provide satisfactory surface decontamination. If large variations in surface contamination levels exist on highly contaminated surfaces, cleaning will be from less contaminated to more contaminated areas. During decontaminating operations, every caution shall be taken to limit the spread of contamination, such as by taking care not to splash solution, by properly wearing anti-contamination clothing, and by wearing i respiratory protection as necessary. In some cases, filtered exhaust i ventilation may be required to minimize the possibility of airborne contamination spread or personnel exposure.

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p. Activated concrete will be removed / excavated as required using normal j V- mechanical means to meet the release criteria. This is discussed in  ;

Section 3.3.8 of the Decommissioning Plan.

9. The contractor's respiratory protection program is contained in the

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Radiological Control Procedure (CNSI FS-RP-001) Chapter 7, " Limits and -4 Procedures for Controlling Airborne Radioactivity". The administrative limit for occupational exposure to airborne radioactivity is set at 2 MPC-hours per day. The applicable MPC limit is determined from 10 CFR 20, Appendix B, Table 1. In addition, the contractor requires the use of respiratory protection equipment as a supplementary control to. keep personnel exposure ALARA.

Specific instructions for implementing the respiratory protection program are found in CNSI FS-RP-001, Section 703 " Procedures for Controlling Personnel Exposure to Airborne Radioactivity", and Section f3 705 " Monitoring for Airborne Radioactivity". This Section also V describes when monitoring is required, and what instruments and procedures to use. Section 703 includes a short discussion regarding - l the use of respiratory protection in areas with surface contamination j which might become airborne, reviews possible engineering alternatives, l and specifies posting requirements.

The specific requirements for the respiratory protection programs are based on control of internal exposure, and are an integral part of the contractor's overall radiation control program. Constant monitoring of the radiological conditions in the work areas will provide the data necessary to evaluate the need for respiratory protection. Workers who may be required to use protective equipment will be trained in accordance with CNSI FS-RP-001, Section 708 " Procedure for Use of Respiratory Equipment". This includes review of the function, ,

operation, and proper use of the equipment. Following satisfactory i

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f completion of.a medical examination including respiration fitness evaluation, a fit' test will

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be performed by MSU for each individual who will be-required to wear such equipment. All procedures will: be

. performed in accordance with ANSI Z88.2, " Practices for Re'spiratory j Protection". A worker who.is- unable to qualify under this program will not be allowed to enter a controlled area where respiratory protection is required.

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10. Section 3.3.9 of the Decommissioning Plan gives a brief de'scription of L the containment system that will be ' installed over the reactor. tank f cavity prior to performing concrete demolition or other dust or airborne activity producing operations. The primary purpose of this system is.to prevent the spread of dust and radioactive particles i

produced from these operations. In order to maintain' proper

[ ventilation in.the enclosed tank cavity, a air handling system will be 4-installed as part of the containment system. The outlet.of potentially contaminated air occurs through a duct.which extends down near the bottom of the tank. _ Makeup air is drawn in through inlet filters installed in the wall of the containment enclosure at the top of the tank cavity. This system allows. clean air to'be drawn down from the top of the tank, past the workers, and into the outlet duct located near their feet.

A dust collector unit and High Efficiency Particulate Air Filter will be installed upstream of the ventilation blower to remove particulate matter from the air stream. The discharge of this system will be directed into existing duct work that extends to the roof of the engineering building. This system will maintain a slight negative pressure inside the containment (tank cavity), which will provide ,

additional control of contamination.  !

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Personnel working inside the containment enclosure will _be required to-

-don appropriate protective equipment prior to entering this area.-

-. l Monitoring of radiological conditions, including air monitoring and contamination surveys, will' provide the necessary data to determine j specific requirements.for' protective equipment in accordance with the-- i contractor's Radiological Control Procedures. These requirements will be posted at the control point and will be incorporated-into the g appropriate RWP's.

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11. The criteria that will apply to these materials for release is that specified in U.S. N.R.C Reg. Guide 1.86, Table I, " Acceptable Surface l Contamination Levels". This Table is presented in the Decommissioning Plan as Figure 1.6 and.is referenced in Section l'.6.7, " Release Criteria".

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ATTACHMENT A

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Statements from Key Project Personnel and their Personal Qualifications  !

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'l MSU TRIGA Reactor Decommissioning Project t

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MICHIGAN STATE UNIVERSITY COLLEGE Of ENGINEERING EAST LANSING

• MICHIGAN

• 48824-1226 DEPARTMENT Of CllEMICAL ENGINEERING 517/355 5135 April 14, 1989 Mr. Theodore S. Michaels, Project Manager Office of Nuclear Reactor Regulation i U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Docket 50-294, License R-il4.

Reply to question 1, Letter of ,

March 21, 1989.

Dear Mr. Michaels:

As the designated Michigan State University Nuclear Reactor Supervisor, it is my understanding that I will be responsible for the overall coordination of decommissioning and decontamination of the MSU Triga nuclear reactor.

This will include the interface with the contractor (Chem. Nuclear Systems, Inc.) as well as with the NRC and the University Administration. It is

, further understood that the estimated duration.of the decommissioning and

('v; decontamination project will be approximately 3 months from the start of the effort and that the activities required of me will require approximately 50%

of my time during that period.

Sincerely, ruce W. Wilkinson h ^

Nuclear Reactor Supervisor Professor of Chemical Engineering BWW/lm

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Af.Sl]h en Nprmasses Actum/l: qual Opparsunay instusasion

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.:gas WILKINSON, BRUCE W., b. Shelby, Ohio, August 9, 1928 l g 280-26-9939-Education

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Ph.D.,10hio State University,-1958, Chemical Engineering I M.S.,; Ohio State University, 1951, Chemical Engineering B.S., Ohio State University, 1951, Chemical Engineering l

Professional-Experience  !

I 1981 - Associate Director, Division of Engineering a Research, Michigan State University 1977 - Professor, Chemical Engineering, Faculty Advisor, and Supervisor, Nuclear Reactor l Facility, Michigan State University 1975 - 1977 Associate Professor, Chemical Engineering

-and Faculty Advisor, Nuclear Reactor Facility, Michigan State: University <

1968 - 1975 . Associate Professor, Chemical Engineering l and Nuclear Reactor Supervisor, Michigan State University 1965 - 1968 Assistant Professor, Chemical Engineering, Michigan State University 1964 - 1965 Project Coordinator,' Nuclear Fuels, Dow i Chemical Company 1 1960 - 1964 Staff Assistant, Dow Chemical Company

['N 1959 - 1960 Process. Engineer, Dow Chemical Company j h i 1954 --1959 Chemical Engineer, Nuclear and Basic

, Research, Dow Chemical company Technical and Professional Societies American Nuclear Society American Institute of Chemical Engineers American Society for Engineering Education Tau Beta Pi

. Phi Lambda Upsilon Omega Chi Epsilon National Society of Professional Engineers Sigma Xi Registered Professional Engineer (Ohio, Michigan)

Professional Activities Consultant to:

Dow Chemical Co., Argonne National Lab, Air Products and Chemical Co., National Academy of Science (Energy storage and Hydrogen technology), State of Michigan (nuclear energy).

Participant in:

NSF, ORNL sponsored studies on cogeneration.

O Governor's Task Force on Nuclear Waste, 1977, 1980.

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MICHIGAN STATE UNIVERSITY -

,Y j 4

., OFFICE Of RADIATION. CHEMICAL AND BIOLOGICAL SAFETY EAST LANSING

• MICHIGAN

• 48824 1326 q$

Cl24 RESEARCH COMPLEX-ENGINEERING

'i ~ . TELEPHONE (517) 355 0153 i'

- March 31,1989-- _

. Theodore S. Michaels; Project Manager Standardization and Nor-Power

- ReactorProject Directorate.

Z. Division of Reactor Projects - III, IV, V and SpecialProjects Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 -

F' Re: . Docket No. 50-294 h Reactor License No. R-114

' Dear Mr. Michaels; With reference to the above docket number, this is to certify that I acknowledge understanding of my position at Michigan State University with respect to decommissioning and decontamination. Additionally, I am'a full time employee of the q University and estimate that up to ten percent of my work schedule may be myolved with

,I the decommissioning and decontamination process. I understand that my involvement with the project will be a long as necessary in order to satisfactorily complete the project.-

-If any ' additional information is needed please let me know, or feel free to contact me ty telephone at 517/355-0153.

Sincerely, l Warren H. Malchman,h/ :6 4>W c-Dimetor and Radiation Safety Officer O

r htSUis an Affsemaswr Action /TyualOpportunity inmoution

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Warmn H. Malchman 2835 Southwood Drive E. Lansing, MI 48823 i SS# 058-32-0664 (517) 355-0153 office 332-4918 home Present - Director. Office of Radiation. Chemical & Biological Safetv-Michigan State University, March 1979-present.

). Responsible for the development and implementation of a comprehensive radiation, chemical and biological safety program for Michigan State University.

Implement numerous training programs and seminars in radiation, chemical and biological safety on the Michigan State University campus. Responsible for University compliance with applicable state and federal regulations.(see enclosure for specific job j, msponsibilities and program descriptions)

Present -University F~iiation Safety Officer- Michigan State University. Aucust 1964 to present. Responsible.for the development and implementation of a comprehensive radiation pmtection program for Michigan State University.

Radiation Safety Officer for byproduct material licenses assigned to Michigan State i University NRC Licenses 21-00021-29 and 21-00021-30.

Radiation Protection Officer for all analytic and diagnostic machine producing ionizing radiation units at Michigan State University.

, Chairperson, MSU Radiation, Chemical & Biosafety Committee Chairperson, MSU Environmental Oversight Committee

. Member, MSU Radiation Safety Subcommittee - Non-Medical Member, MSU Medical Radiation Safety Committee Member, MSU Nuclear Reactor Safety Committee Member, MSU Institutional Biosafety Subcommittee Member, MSU Hazardous Chemical Subcommittee d

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MICHIGAN STATE UNIVERSITY Ig of71CE of RADIATION. C11EMICAL AND DioloGICAL S AFETY EAST LANSING

• MICilIGAN + 48824 1326 ct24 RESEARCil COMPLEX-ENGINEERING

'IILEPiloNE ($17) 355 0l$3 April 3,1989 Mr. Theodore S. Michaels, Project Manager Division of Reactor Projects Office of Nuclear reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ,

Dear Mr. Michaels:

l The following is submitted in response to question #1 of your letter to Dr. R.E.

l Wilkinson, dated March 21, 1989.

l RE: Mr. Mark Mitchell

! Senior Reactor Operator- MSU Triga Reactor Reactor Safety Committee Member -

University Health Physicist t Exoerience Mark Mitchell has been a Health Physicist for Michigan State University's Materials

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Broad License for the last two years. He is involved in laboratory surveys, instrument N calibrations, leak checks, and materials accountability. Auditing and revising :

existing records and procedures- is a major activity. The position requires conducting radiation safety training seminars, answering queries from University radiation workers and the general public and responding to radiation emergency situations.

During the. proceeding four years he was employed at the MSU Triga Nuclear Reactor as a Senior Reactor Operator (License SOP-30482). He was involved in formulating the Emergency Plan various safety analysis and the process of re-licensing the facility.

He is. a member of the reactor safety committee and the on-call reactor emergency group.

Statement of Understanding I understand that during the reactor decommissioning, I have been called upon to be a member of the Reactor Safety Committec and provide advise to the Reactor Supervisor, Bruce Wilkinson when called upon to do so. It is anticipated that this task will involve less that 10% of my full-time employment. My commitment to the project is for its duration and additional time commitment (above 10%) can be arranged as needed.

Signed: ,

Mark Mitchell 1 Respectfully s bmi ,

&$&MP fark Mitchell  ;

AISUh an Affermaths Actnan/Equalopportunioy insestution l

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(" MICHIGAN STATE UNIVERSITY f~f.

1 OmCE Of RADIATION. CHIMICAL AND BIOLOGICA!. SAlm EAST LANSING e MICHIGAN

• 48824-1326

, . C124 RESEARCH COMPLEX-ENGINEERING .

TELEPHONE (517) 355-0153 April 3,1989

' Mr. Theodore S. Michaels, Project Manager

= Division of Reactor Projects b' Office of Nticlear Reactor Regulations k, U.S. Nuclear Washington, D.Red.ulatory 20555. Commission

Dear Mr. Michaels,

The following is submitted in response to question #1 of your letter to Dr. R.E. Wilkinson, dated March 21,1989.

RE: Mr. John D. Parmer Chemical and Biohazard Safety Officer Michigan State Univen;ity Exnerience:

Mr. Parmer has served as the Chemical and Biohazard Safety Officer for Michigan State University for the past four years. He also serves as the Respirator Program Administrator for the campus .

( Respiratory Protection Program which currently includes approximately 450 respirator wearers. As

. Chemical and Biohazard Safety Officer, Mr. Parmer supervises the Industrial Hygiene division of the Office of Radiation, Chemical and Biological Safety and is a Certified Hazard Control Manager.

).

Statement of Understanding:

I understand that during the reactor decommissioning, I have been called upon to be a member of the Reactor Safety Committee and provide advise to the Reactor Supervisor, Dr. Bruce Wilkinson when called upon to do so. It is my anticipation that this task willinvolve less than 10% of my full-time employment. My commitment to the project is for its duration and additional time commitment (above 10%) can be arranged as needed.

Signed: . p# h-J D. Parmer Respectfully) bmitte L.. -

Y 5 fin D. Parmer

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ht5Uis en Affseneaties Action /E4ualOpporteuntylastututson

MICHIGAN STATE UNIVERSITY

l. [ DEPARTMENT OF PUBilC SAFEW EAST LANSING

• MICHIGAN

• 48824 1219 l

COMMITWD TO COURWSY AND EXCEU2NCE April 20,1989 Mr. Theodore S. Michaels, Project Manager 3

Office.'of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Docket 50-294, License R-114, Reply to Question 1 Letter of March 21, 1989.

n Dear Mr. Michaels It is nty understanding that I will be responsible for reviewing industrial safety aspects of the proposed reactor decommissioning as requested by the Reactor Supervisor. This will include the review of the procedures proposed by

.g - the contractor (Chem. Nuclear Systems, Inc.) and consultation on the industrial 5 safety precautions to be taken to protect both employees and the public. It is further understood that the duration of the decommissioning and decontamination project will be approximately 3 months from the start of the project and that the activities required of me will require approximately 10% of my time during that period.

My resume is attached.

Sincerely, bC > A" m w Carl Eigenauer Fire and Safety Offi er CJE/ph Enclosure cc: Dr. Bruce Wilkinson O

MSUss en Nfermathw Action /E 4 salOpportunityinsentutoon

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Name: Carl J. Eigenauer l Address: 435 N. Putnam Williamston, Michigan 48895 )

,, Birthdate: January 14, 1928 {

( ) Birthplace: West Pittston, Pennsylvania

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Education: Kurtz Elementary School (Beecher School District) Flint, Mich.

Beecher High School, Flint, Mich, l Co.llege Preparatory graduate of 1946 Michigan College of Mining and Technology, Houghton, Michigan l Electrical Engineering Major  !

September 1948 to December 1949 a Flint Junior College, Flint, Michigan Psychology Major February 1950 to June 1950 Michigan State College, East Lansing, Michigan Psychology Major  !

Secondary Education Minor March 1952 to June 1954 Awarded B. A. Degree in Psychology in June,1954 lowa State College, Ames, Iowa Psychology Major in Graduate School Traffic Safety Research Minor (under Fellowship)

Secondary Education Minor June 1954 to June 1955

\ Military United States Army, Quartermaster Corp, Fort Lee, Virginia Service: June 28, 1946 to June 28, 1948 United States Army, Combat Engineers, United States, Japan and Korea October 21, 1950 to August 10, 1951 i Major Buick Motor Division, Flint, Michigan Employment November 1955 to January 1957 Experience: Employed in new car distribution section.

Anchor Motor Freight, Inc. of Michigan, Flint, Michigan January 1957 to November 1959 Employed as Safety Director for Flint, Michigan terminal.

City of Flint, Michigan l

November 1959 to March 1961 Employed as Assistant Referee Administrator in the Traffic Violations Bureau of Municipal Court.

l City of Flint, Michigan l March 1961 to April 30, 1964 Employed as Safety and Training Coordinator for City of l \

(' Flint. Set up and maintained personnel and vehicle l

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Resume of Carl J. Eigenauer Page 2 safety programs involving 1400 employees and 450 vehicles. Made inspections of construction sites (sewer and water), buildings and machinery. Made recommendations concerning safety improvements and operations. Gave safety lectures. Investigated personnel injury accidents invol-ving City employees.

AC Spark Plug Division, General Motors Corporation, Flint, Michigan 7

May 1, 1964 to January 27, 1967 Employed in the Safety Department as a Floor Safety Inspector. Observed work areas for safe working con-ditions and employees for safe work practices, in December of 1965 was assigned as Worker's Compensation Adjustor. Investigated personnel injury accidents, took wirtten reports and prepared forms to notify the Michigan Worker's Compensation Department. Prepared cases for presentation by the Corporation attorney at formal hearings.

Gibson Refrigerator Division, Hupp Corporation, 515 Gibson Drive, Greenville, Michigan January 30, 1967 to February 9,1968 Employed in the Personnel Department as Safety Director for two plants, one manufacturing home air conditioners, the 3 other manuf acturing refrigerators. Responsibility included (V setting up and maintaining a safety program for both plants, inspecting all areas and making recommendations concerning I safe working conditions and working practices, counseling with department heads, conducting training sessions for foremen on all aspects of safety, including fire safety.

Chairman of Union-Management Safety Committee.

Michigan State University, East Lansing, Michigan February 12, 1968 to Present Employed in the Department of Public Safety as Supervisor of Environmental Health and Safety. Areas supervised are Fire Safety, Safety Equipment Maintenance (fire extinguishers, fire hoses, sprinkler systems, fire detection systems, evacuation alarms, fire blankets, safety showers and self-contained breathing apparatus).

Responsibilities include accident prevention through presen-tations (written and oral), inspections of facilities and investigation of incidents and accidents. Counsel with University employees regarding hazardous experiments. ,

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RESUME MARK R. MANNING PROJECT SPECIALIST JANUARY,1989 EDUCATION e

Project Management Training -' American Management Association -WELCOM. Software p Corporation L- A.S. Degree - New York State University,1985 y

U.S. Navy: - Leadership and Management Education & Training LevelI Sub-Safe Quahty Assurance School p , Engineering Laboratory Technician School Naval Nuclear power School and Prototype Training

. Machinist Mate "A" School J. F. Kennedy High School, Bloomington, Minnesota (Graduate) -

CERTIFICATIONS 1986 Chem-Nuclear Systems, Inc. Senior Radiological Controls Technician

-V ' 1985 Chem Nuclear Systems, Inc. NRC/ DOT Hazardous Materials Certified Shipping Broker 1-EXPERIENCE

SUMMARY

Mr. Manning has ten years of experience in the Nuclear Industry, currently functioning as a Project Manager, Senior Radiological Technician and Certified Chem-Nuclear NRC/ DOT Hazardous Materials Shipping Broker. Mr. Manning has experience in developing, scheduling l- operationalHealth and supervising project Physics, project activities, budget in addition control, and proper handling, to implementing packaging, and mo

' shipping and ultimate disposal of various radioactive materials. Recent expenence includes the total decommissioning of two research reactor facilities to uncontrolled release, and shipments of irradiated reactor fuels. Collateral duties include assisting in scoping, bid preparation, data analysis and assistance, preparing procedures and work packages to support various field projects. Mr. Mannmg has six years of nuclear experience in the U.S.

Navy and had qualified as a Lead Engineering Laboratory Technician (LELT). Specific experience includes direction and supervision of personnel responsible for radiological and chemistry control of primary and secondary nuclear reactor systems and maintenance

. activities associated with primary reactor systems aboard a fast-attack nuclear submarine, health physics program supervision and radwaste packaging.

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V WORK HISTORY 1988 - Present - Acting Project Manager - Chem-Nuclear Systems, Inc. - Responsible for overall planning, control, execution and timely completion of all project activities. This requires a comprehensive knowledge of State and Federal regulations, applicable technology application, radiological and safety practices, and project management fundamentals.

Duties include developing and preparirg project plans, procedures and schedules; implementation of safety, radiological and quality control requirements; procurement of equipment, supplies, and subcontractors; selection and training of project personnel; and 3

timely reporting of project status. Collateral duties include providing technical assistance in developing, planning and organizing departmental (field) projects; performing CPM / PERT scheduling and budge control management using various computer programs; and, in addition, supporting ongoing projects as a Senior Radiological Control Supervisor and/or Hazardous Materials Shipping Specialist.

o Decommissioning of the 250 KW TRIGA research reactor facility located at Michigan State University, Lansing, Michigan.

1987 - 1988 - Radiological Control Supervisor, field projects - Chem-Nuclear Systems, Inc.

- Responsibilities include supervision of radiological control technicians and implementation of project radiological and health-safety programs. Generally, this involves directing of daily project activities in order to minimize radiation exposure,. conducting radiological and safety surveys, operating and performing maintenance on various radiological instruments, and maintaining all project records pertaining to health safety, o of the Aerojet depleted uranium weapons Decontamination /decommissioninbompton, manufacturing facility located in California.

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o Tank desludging operations, Brookhaven National Laborr ,ory, Long Island, New York - waste characterization, solidification, and shippit g/ disposal documentation.

1986 - 1987 - Project Superintendent - Chem-Nuclear Systems, Inc. - Responsible for supervision of overall project operations, implementation of safety requirements and maintenance costs, schedule, and regulatory requirement.

o Decommissioning of the 100KW Argonaut reactor facility located at Virginia Polytechnic Institute and State University, Blacksburg, Virginia.

I 1985 - 1986 - Senior Radiological Controls Technician /Ilazardous Materials Shipp,m' g Specialist Chem-Nuclear Systems, Inc. - Responsible for performance of radiological monitoring, survey, sam of operational personnel.pling, As NRC/ DOT sample analysis, Broker, acts decontamination as the Company's activities and su legal representative for verifying that hazardoas material shipments are in compliance with all federal and state laws, rules and regulations, and burial criteria. Supervises projects for the proper handling, packaging, shipping, and ultimate disposal of various radioactive materials. This includes supervismg work activities, scheduling and personnel utilization, and providing technical guidance.

o Remedial Action Project under EPA Superfund/Riedell - Removal of Cobalt-60 contamination from various private and commercial properties.

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o. ' Site ' characterization, assessment, and gross decontamination -of the Hot Cel Facility located at Fort McClellan, Alabama.

o. Defueling of the University of Kansas .TRIGA: reactor, shipping of irradiated reactor fuel.

o decommissioning of the Northrop 1MW TRIGA reactor facility located ~ at Hawthorne, California.

3 1982 - 1984 - Radiological Division Tending Petty Officer, Engineroom Supervisor - U.S.

3 Navy, USS Tautog (SSN-639,' Fast Attack submarine) - Primary responsibility was to supervise radiological division technicians and administer the entire ship's radiological and chemistry control program.' This involved maintaining Primary and Secondary system water chemistry; all facets of radiological control; reactor plant maintenance operations; as well as reviewing logs, determining trends, reactor plant maintenance operations; as well as reviewing logs, determining trends, and submitting appropriate documentation for required-data reports. As Engineroom Supervisor, coordinated efforts of up to 'seven remote '

propulsion plant watch stations during steady-state, transient, and casualty operating

. conditions.

1980 - 1982 - Engineering Laboratory Technician, Mechanical Operator - U.S. Navy, USS 8

Tautog the slup ('e,5N-639, Fast Attack Submarine) - Performed all operations necessa training +..nd repair parts officer.

1978 - 1980 - Student - U.S. Navy Nuclear Power Program - Training for qualification as a Nuclear Power Plant Engineering Laboratory Technician and Mechanical Systems Operator. Gained a thorough knowledge of reactor plant operations, reactor and steam plant chemistry, radiological controls, and reactor / propulsion plant mechanical maintenance.

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1 MICHIGAN STATE UNIVERSITY TRIGA REACTOR DECOMMISSIONING PROJECT-Q/

Personal Statement  !

Date 1 May 89 Position Project Manager i

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1 Responsible Individual Mark R. Manning Acknowledgement of Understanding I Mark R. Manning do hereby acknowledge that I have been assigned as the Project Manager for the Michigan State University TRIGA Reactor

'. ! Decommissioning Project.

I am aware of and~ understand the responsibilities associated with this position (as outlined in the Decommissioning Plan, Section 1.5.) have been discussed'with me and are understood. The expected duration of this commitment is approximately 3 months (min)*during which time I anticipate that approximately 100  % of my full-time employment will be directed toward the fulfillment of my duties.

• - On-site activities are expected to begin on or about 3 July 89.

Signed k d. b Date 1 May 89 D

Mark R. Manning Full Name (Typed or printed) e.

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1 l (~) RESUME l V HARK S. HHITTAKER, CHP CORPORATE HEALTH PHYSICIST JANUARY, 1989 EDUCATION b M.S., University of Michigan, Ann Arbor, Michigan, Major: Health Physics, 1980 B. A., University of Michigan, Ann Arbor, Michigan, Major: Physical Sciences, 1972 r

" Radioactive Haste Management", Rensselaer Polytechnic Institute, 1981

" Health Physics in Radiation Accidents," REAC/TS, Radiation Emergency Assistance Center / Training Site, Oak Ridge Associated Universities and U.S.

Department of Energy, Oak Ridge, Tennessee, 1982 CERTIFICATION Certified Health Physicist, Comprehensive, American Board of Health Physics, p) 1985 I

EXPERIENCE

SUMMARY

g Management, radiological and environmental monitoring; emphasis on training and certification, health physics, and emergency response actions. Experience in radiological measurements, project management, radiological and hazardous substances shipment, transportation, and decontamination and decommissioning field operations management. Experience in health physics and science training; text and audiovisuoi aid evaluation and selection.

HORK HISTORY 1985 - Present - Corporate Health Physicist - Chem-Nuclear Systems, Inc. - i Responsible for the development and implementation of CNSI policies and  ;

procedures for the safe transport, handling, and disposal of radioactive material. Overall responsibility for CNSI radiation protection programs.

Major tasks include:

o. Chair CNSI ALARA and Emergency Response Committees.

o Perform HP audits / reviews of all CNSI projects.

o Preparation / review of CNSI radiation protection procedures.

o ALARA review of equipment and facility designs.

o Chair CNSI LLRH Broker Committee

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I MARK S. WHITTAKER Page 2 1984 - 1985 - Director, Licensing -

Chem-Nuclear Systems, Inc. -

Direct preparation of license applications for new disposal sites and radioactive material handling and processing facilities. Provide direction to company personnel to ensure compliance with all CNSI licenses for operations outside South Carolina. Major tasks include:

3 o Direct preparation of the license renewal application for the Barnwell LLH Site License and the Experimental Testing Laboratory License.

o Direct preparation of supporting documents for the Nell, Texas SM Site License Application.

o Assist in preparation of proposal / license application for the California t LLH Site.

1983 - 1984 - Manager, Radiological Programs and Vicinity Properties, UMTRA Project Albuquerque Office - Develop and implement plans for assessment of uranium mill tailings contamination at millsites and at vicinity properties and for radiological control during remedial action at mill sites and vicinity properties. .

Major tasks included:

o Hire, train, and direct field staff performing assessment of O, contamination and maintaining radiological control during remedial action.

1 o Develop the Vicinity Property Plan for the Remedial Action Contractor l

detailing the assessment and remedial action plans for vicinity p aerty work at all the UMTRA Sites.

o On-site management of radiological control during start-up of the first mill site remedial action work at the Canonsburg, PA mill site, o Development and calibration of an on-site system for the measurement of radium concentration in soil.

1981 - 1983 - Manager, Compliance Assistance and Technical Services (CATS) - .

Chem-Nuclear Systems, Inc. - Direct and supervise a department which provides technical services primarily in health physics and other areas such as chemical waste management and industrial hygiene. Group assignments include:

o Gamma ray shielding, design, and testing.

o Radiation protection program development for reactor facilities, low-level waste sites, and decontamination and decommissioning projects.

o Health physicist training development and implementation primarily for reacter facilities.

o Radioactive waste management studies.

o Decontamination and decommissioning guidance in the areas of techniques, regulations, and release surveys.

1980 - 1981 - Project Engineer, Compliance Assistance and Technical Services

- Managed CNSI Broker Certification Program, including training and O c(CATS) ertifying inspectors for radwaste shipments and transportation; performed radwaste packaging and transportation audits, radiolc,gical assessments and shielding calculations; prepared health physics and radiation safety procedures and manuals; provided licensing assistance.

MARK S. WHITTAKER Page 3 1

1979 - Assistant Health Physicist -

Palisades Nuclear Plant, Covert, Michigan -

Performed area surveys, dosimeter testing and calibration respirator fitting; reviewed health physics procedures.

1974 -

1978 - Physical Science Instructor - Flushing Junior High School, Flushing, Michigan - Taught and evaluated 180 students per year; assisted in development of science programs; selection and design of appropriate text and audiovisual materials.

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PROFESSIONAL AFFILIATIONS Member, American Nuclear Society Member, Health Physics Society

^

PUBLICATIONS M. S. Whittaker, May, 1985. " Overview of Technologies for Low-Level Haste Disposal" Hashington Conference on Low-Level Nuclear Haste Disposal and Cleanup, Arlington Virginia D. G. Ebenhack, M. S. Whittaker, June, 1985. " Complying with the Low Level Haste Policy Act - An Operators Perspective". Transactions of the American Nuclear Society, 1985 Annual Meeting, Boston, Mass.

J.E. Till, M. S. Whittaker, R. E. Moore, February, 1985. " License i Termination Using a Simplified Pathway Analysis Approach for Establishing Limits for Soil Contamination", Proceedings of the Nineteenth Midyear Topical Symposium pf the Health Physics Society, Knoxville, Tenn.

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MICHIGAN STATE UNIVERSITY TRIGA REACTOR DECOMMISSIONING PROJECT Personal Statement Date May 4,1989 Z' Position Corporate Health Physicist Responsible Individual Mark's. Whittaker

~ Acknowledgement of Understanding I Mark S. Whittaker do hereby acknowledge that I have been assigned as the Corp. Health Physicist for the Michigan State University TRIGA Reactor bq -

Decommissioning Project.

I am aware of and understand the responsib'ilities associated with this position ~ (as outlined in the Decommissioning Plan, Section 1.5.) have been discussed with me and are understood. The expected duration of this commitment is approximately- 3* months (min) during which time I anticipate that approximately 1-5 % of my full-time employment will be directed toward the fulfillment of my duties.

SignedM W1M 1.% Date May 4, 1989 Full Name Corporate Health Physicist j (Typed or printed)

• 0n-site operations are expected to begin on or about July 3, 1989.

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-[ f CHEM NUCLE AR SYSTEMS,1NC I  !

I RADIOLOGICAL CONTROL PROCEDURE FOR FIELD PROJECTS (CNSI FS-RP-001) i i

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, cEvaONs 7 SRB APPROVAL RE V. DESCRIPTION DATE APPROVED

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I-I UNCOTROLiB C04 Wl 10" Bi U)DA~iD l

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I CNSI SAFETY REVIEW "4 BY }

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1 REVISION STATUS SHEET 1 2 3 4 5 l R E V. - - - - -

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PREPARED DATE g p.gy $@ CHEM - NUCLEAR SYSTEMS, INC.

ALARA / a TITLE F))A M (6 I i ENslNEER f./M2/,, ~

f RADIOLOGICAL CONTROL PROCEDURE FOR FIELD PROJECTS I OUALITY f$YrstMi '

3-464A APP O SAF y DOCUMENT NO.

, (( + 5[#/t( MM4 /g FS-RP-001 R E V.

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, m I TABLE OF CONTENTS 1

PAGE NO.

i.0 SC0,E . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

2.0 REFERENCES

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.I; DETAILED PROCEDURES . . . . . . . . . . . . . . . . . . . . . . 3 p 4.0 RECORDS . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 APPENDIX A - Radiological Control Manual for Decontamination and Decommissioning Type Field Projects . . . . . . . . . . . 5 (

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00CUh4ENT R E V. SHEET FS-RP-001 -

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I 1.0 SCOPE i

t 1.1 Purpose This procedure describes the Radiological Control methods that  !

I will be instituted on Decontamination and Decommissioning (D&D) type Field Projects at temporary job sites.

1.2 Applicability This procedure applies to all CNSI personnel and CNSI contractor

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personnel working at Field Project temporary job sites.

2.0 REFERENCES

t 2.1 CNSI Procedure, CN-AD-020, " Health Physics Policy Manual" 2.2 CNSI Procedure, CN-AD-019, " Chem-Nuclear Systems, Inc. (CNSI)

I ALARA Policy" 4 I

2.3 CNSI Procedure, FS-AD-005, " Field Projects Administration and Control Procedure" 3 l

2.4 CNSI Procedure, CN-AD-026, " Radiation Exposure Records and Procedures"

.. 2.5 CNSI Procedure, FS-RP-002 " Portable Instrument / Survey Record Procedure for Field Projects".

!l 3.0 REQUIREMENTS 3.1 I

CNSI personnel, both permanent, and temporary, and contractor, shall be trained in radiation safety, in accordance with Appendix A " Radiological Control Manual for Decontamination and Deconnissioning type Field Projects" prior to beginning radiation work.

3.2 Radiological instruments in sufficient quantities to adequately l perform the monitoring required by this procedure shall be available on the job site prior to beginning work.

3.3 An ALARA briefing, as described in References 2.2 & 2.3, shall be held prior to job mobilization.

4.0 DETAILED PFOCEDURE 4.1 A Radiological Control Supervisor (RCS), designated by Field Services management and approved by the Corporate Health Physicist (CHP), shall be responsible for the implementation of I_ the Radiological Control (Rad Con) program. The RCS shall report to the CHP on radiological niatters.

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, 3 4.2 Personnel Dosimetry 4.2.1 Personnel dosimetry shall be provided, reported, and worn as specified in Ref. 2.4 and Appendix A.

4.7.2 On projects where self-reading dosimeters (SRDs) are used, SRD results shall be reported to the Barnwell.

-I Exposure Records Technician weekly (Nonday for previous week).

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- I 4.3 Instruments shall be set up, checked, and used as specified in Reference 2.5.

4.4 Radiological Control Program 4.4.1 The RadCon program will be designed and implemented in accordance with Reference 2.1, 2.2, and Appendix A.

I. Any changes to Appendix A will be approved by the ALARA committee prior to implementation.

I 4.4.2 Site specific RadCon procedures, as required, will be developed in accordance with the guidance in Appendix A.

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, 5.0 PEPORTS AND RECORDS a

- 5.1 The RCS shall submit a weekly written report to the CHP

(~ detailing current Radiological conditions, personnel exposure, and job progress.

A 5.2 Records shall be maintained throughout the duration of the project, and then retained in the permanent Project file.

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APPENDIX A

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RADIOLOGICAL CONTROL MANUAL FOR DECONTAMINATION AND DECOMMISSIONING TYPE FIELD PROJECTS (118 PAGES) ig

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APPENDIX A TABLE OF CONTENTS i i

CHAPTER 1--GENERAL i

101 Purpose . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 l 102 Related Instructions ...................... 4 103 Sumary of Radiological Control Procedures ........... 5 ,

104 Sumary of Responsibilities . . . . . . . . . . . . . . . . . . . 5 105 Radiological Control Inspections ................ 8 106 Radiological Control Training Requirements ........... 8 107 Radiation Worker Training Standard ............... 14  ;

108 Radiological Control Personnel Training Standard ........ 17 109 Radiological Incident Reports . . . . . . . . . . . . . . . . . . 30 CHAPTER 2--REFERENCES 201 CNSI Procedures . . . . . . . . . . . . . . . . . . . . . . . . . 31 202 Regulations and Licenses .................... 31 CHAPTER 3--RADIATION EXPOSURE LIMITS 3 01 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 l

302 CNSI Exposure Limits ...................... 32 303 Radiation Exposure Limits for the Unborn Child ......... 32 304 Radiation Exposure to the Public ................ 33 CHAPTER 4--RADIATION SURVEY AND POSTING REQUIREMENTS 401 Calibration and Maintenance of Survey Instruments . . . . . . . . 34 402 Safety Precautions ....................... 34 403 Radiation Surveys . . . . . . . . . . . . . . . . . . . . . . . . 35 404 Control of Radiation Areas ................... 37 CHAPTER 5--PERSONNEL MONITORING FOR RADIATION EXPOSURE 501 CNSI Dosimetry Program ..................... 40 502 Personnel Monitoring ...................... 40 503 Self-Reading Dosimeters (SRDs) ................. 41 504 Exposure Records ........................ 43 505 Visitors ............................ 44 506 Internal Exposure Monitoring .................. 45 CMPTER 6--GUIDELINES FOR CONTROLLING RADIATION EXPOSURE . -

601 Minimizing Radiation Exposure . . . . . . . . . . . . . . . . . . 47 c 602 Procedures and Work Instructions ................ 48 603 Radiation Work Permit . . . . . . . . . . . . . . . . . . . . . . 48 604 Te mpo ra ry Sh i e l d i n g . . . . . . . . . . . . . . . . . . . . . . . 52 FS-RP-001, APPENDIX A PAGE 1 April 86

I TABLE OF CONTENTS I ( CHAPTER 7--LIMITS AND PROCEDURES FOR CONTROLLING AIRBORNE RADI0 ACTIVITY ta, 701 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53 702 Limits for Ai rborne Radioactivity . . . . . . . . . . . . . . . . 54 703 Procedures for Controlling Personnel Exposure to Airborne Ra d i o a c ti v i ty . . . . . . . . . . . . . . . . . . . . . . . . . 54 704 High Airborne Radioactivity Procedure . . . . . . . . . . . . . . 57 705 Monitoring for Airborne Radioactivity . . . . . . . . . . . . . . 61 I 706 Ai r Sampl e Counting . . . . . . . . . . . . . . . . . . . . . . . 66 707 Determination of MPC-Hours ................... 68 708 Procedure for Use of Respiratory Equipment ........... 69 3 709 High Efficiency Particulate Air (HEPA) Filter Requirements ... 71 I 710 711 Portabl e Ventil ation System . . . . . . . . . . . . . . . . . . .

Procedures for Controlling Release of Airborne Radioactivity to the Environment . . . . . . . . . . . . . . . . . . . . . . . .

72 72 CHAPTER 8--SURFACE CONTAMINATION LIMITS 801 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 73 802 Surface Contamination Limits in Uncontrolled Areas. . . . . . . . 74 803 Controlled Surface Contamination Areas (CSCAs) ......... 76 CHAPTER 9--CONTROLLING SURFACE CONTAMINATION 901 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79 hg 902 Contamination Control Point . . . . . . . . . . . . . . . . . . . 79 gt 903 Ventilation . . . . . . . . . . . . . . . . . . . . . . . . . . . 81 904 Enclosures for Containing Contamination . . . . . . . . . . . . . 83 I

l CHAPTER 10--MONITORING FOR SURFACE CONTAMINATION 1 001 Method for Measuring Surface Contamination ........... 85 '

I 1002 1003 1004 Method for Taking Swipes for Loose Contamination ........

Method for Monitoring Fixed Contamination . . . . . . . . . . . .

Method for Monitoring Personnel Contamination . . . . . . . . . .

85 86 87 1005 Freuency of Surveys for Monitoring Surface Contamination 88 I

1006 Instructions for Controlling Radioactive Spills . . . . . . . . . 90 1007 Records of Contamination .................... 94 1008 Requirements and. Procedures for Releasing Previously Contaminated Facilities and' Areas for Unrestricted Use . . . 4 ...... 95 ~ -

CHAPTER 11--ANTI-CONTAMINATION CLOTHING AND EQUIPMENT 1101 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99 1102 Requirements for Wearing Anti-Contamination Clothing ...... 99 1103 Procedure for Donning Anti-Contamination Clothing . . . . . . . . 101 I 1104 Procedure for Removing Anti-Contamination Clothing .......

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TABLE OF CONTENTS CHAPTER 12--RADIOACTIVE DECONTAMINATION 1201 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 104 1202 Decontamination of Tools and Equipment ............. 105

, 1203 Decontamination of Areas .................... 106 l 1204 Decontamination of Clothing . . . . . . . . . . . . . . . . . . . 107 1205 Decontamination of Personnel .................. 108 j_

1 CHAPTER 13--PROCEDURES FOR HANDLING RADI0 ACTIVE MATERIALS I l 1301 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 110 l 1302 Receipt of Radioactive Material . . . . . . . . . . . . . . . . . 110 1303 Packaging Radioactive Materials . . . . . . . . . . . . . . . . . 112 1304 Radioactive Material Storage .................. 113 1305 Shipping Radioactive Materials ................. 116 1306 Actions and Reporting in Case of Loss of Radioactive Material . . 116 CHAPTER 14--ENVIRONMENTAL MONITORING 1401 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 117 l 1402 Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 117 1403 Requirements .......................... 118 1404 Records . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 118 I

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l TABLE OF CONTENTS CHAPTER 12--RAD 10 ACTIVE DECONTAMINATION 1201 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 104 1202 Decontamination of Tools and Equipment ............. 105 1203 Decontamination of Areas .................... 106 1204 Decontamination of Clothing . . . . . . . . . . . . . . . . . . . 107 1205 Decontamination of Personnel .................. 108 CHAPTER 13--PROCEDURES FOR HANDLING RADI0 ACTIVE MATERIALS 1301 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 110 1 302 Receipt of Radioactive Material . . . . . . . . . . . . . . . . . 110 1303 Packaging Radioactive Materials . . . . . . . . . . . . . .. 112 1304 Radioactive Material Storage .................. 113 )

'1305 Shipping Radioactive Materials ................. 116 -l 1306 Actions and Reporting in Case of Loss of Radioactive Material . . 116 CHAPTER 14--ENVIRONMENTAL MONITORING j 1401 1402 sener 1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . m Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 117

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l 1403 Requirements .......................... 118 -1 1404 Records . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 118 1

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l CHAPTER 1 GENERAL 1 01 PURPOSE Discussic" l

This manual presents relevant ifmits and protective measures applicable to ionizing radiation and radioactivity which may be associated with Chem-Nuclear Systems, Inc. (CNSI) operations at temporary job sites.

3 The procedures and limits in this manual do not apply to CNSI operations at NRC-licensed facilities that have procedures and limits meeting the intent of this document.

Radioactive materials in several forms are utilized during various CNSI operations. These materials must be carefully har.dled to avoid any inadvertent contact by operating personnel and the general public. Unnecessary radiation exposure could be caused through mishandling of radioactive materials by personnel who are either unaware of its presence or nature, or who are not instructed in the

' proper methods of handling.

l The addition of the problems of radiation exposure and radioactive contamination to otherwise normal jobs has required the establishment of numerous radiological controls. The major purpose of this manual l is to provide procedures to assure that satisfactory control is exercised over personnel raciation exposure and radioactive contaminations. The limits and procedures of this manual are -

applicable to radioactive material, and should be implemented for all operations.

102 RELATED INSTRUCTIONS ,

This manual has been developed to provide guidance for corripliance

' with CNSI radiation control policy. Thispolicyisstatedin$NSI FS-RP-001, APPENDIX A I

PAGE 4 April 86

procedures CN-AD-019 (Ref. 201.3), CN-AD-020 (Ref. 201.4), and CN-AD-026 (Ref. 201.5). ,

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SUMMARY

OF RADIOLOGICAL CONTROL PROCEDURES Radiological controls are required by CNSI in areas where radioactive materials are handled or stored, in areas traversed by potentially j contaminated personnel and materials, and in other areas where radioactive work is performed. ..

The radiological controls requirements of this manual include: (1 )

control of external radiation exposure to personnel by means of personnel monitoring, area monitoring, installed shielding, and planning and execution of radiological work; (2) control of internal radiation exposure to personnel by monitoring for contamination in l, air and on surfaces, through use of anti-contamination clothing and respiratory protective equipment, and through control of contaminated areas; (3) control of radioactive wastes by means of specified procedures and radiochemical analyses; (4) decontamination; and (5) g instructions for receiving, transferring, storing, shipping, and E accounting for radioactive materials.

The instructions in subsequent sections are those required to assure radiological safety under most situations. In unusual situations, personnel are expected to perform additional measurements and take l

other additional precautions as deemed necessary to provide adequate protection. ]

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SUMMARY

OF RESPONSIBILITIES Requirements

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The following notice to personnel should be conspicuously posted in a sufficient number of places to permit employees working in or frequentingradiationareasorradiologicalcontrolareas.;tohave  !

access to a copy on the way to or from their place of work." I 7 g I

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FS-RP-001, APPENDIX A PAGE 5 April 86 I

NOTICE TO PERSONNEL RADIOLOGICAL CONTROL. STANDARDS

' STANDARDS Standards for protection of personnel against ionizing radiation which may be associated with CNSI operations are contained in the Radiological Protection Manual for Decontamination and Decoenissioning," and shall be utilized for CNSI appropriate operations. This manual is available upon your request from the on-site CNSI employee responsible for the project.

YOUR RESPONSIBILITIES Each individual must constantly remain aware of potential radiological problems. Each of your actions could directly affect your exposure to

. ionizing radiation. The following rules shall be followed by individuals to maximize radiological control safety:

1. . Obey posted, verbal, and written radiological control. instructions.

2. Wear TLD and dosimeters as required by signs or if so instructed by radiological control personnel.

3. Keep track of your own radiation exposure status and avoid exceeding limi ts.

4. In all situations, remain in .as low a radiation area as practicable.

k._ . 5. Do not eat, drink, chew, or smoke in areas where radioactive contamination may be present.

6. Promptly follow health physics direction to prevent contamination spread.

7. Follow all requirements to wear respiratory protective devices. Wear anti-contamination clothing, including respiratory protective devices, properly whenever required by signs or when instructed to do so by radiological control personnel.

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8. Remove anti-contamination clothing and respiratory protective devices properly to minimize spread of radioactive contamination.

9. Frisk yourself or be frisked with the proper equipment for contamination when leaving a contaminated area.

10. Minimize the possibility of a radioactive spill by carefully following procedures.

11. For a known or possible radioactive spill, minimize its spread and notify radiological control personnel promptly.

FS-RP-001, APPENDIX A PAGE 6 April 86

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12. Do not unnecessarily touch a contaminated surface or allow your clothing, t ols, or other equipment to do so.

13. As practical, place all contaminated equipment such as tools and '

sampling bottles on disposable surfaces (e.g., sheet plastic) when not in use and inside plastic bags when woric is finished.

14. Follow good " housekeeping" practices to minimize the amount of material that has to be decontaminated or disposed of as radioactive waste. ,

15. Report the presence of open wounds to radiological control personnel j prior to work in areas where radioactive contamination exists. If a wound occurs while in such an area, report imediately to 3 (l l radiological control personnel.

YOUR EMPLOYER'S RESPONSIBILITIES 3{

l Your employer is required to: .

1. Provide training, equipment, and the necessary measures to maintain exposures ALARA ( As Low As _ Reasonably _ Achievable).

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2.

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Maintain records of your occupational radiation exposure and, upon your written request, advise you of your recorded occupational radiation exposure. li

3. Notify you imediately of any radiation exposure which exceeds the quarterly or lifetime cumulative limits.

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4. Provide you, after termination of employment, upon your written request and within thirty (30) days after the request, with a written sumary of your cumulative recorded occupational radiation exposure received during your period of employment.

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5. Notify personnel of the above procedures by posting this Notice conspicuously INSPECTIONS Work involving radiological controls may be subject to periodic inspection by the Nuclear Regulatory Comission, State Regulatory Agency, or any Cognizant  !

Radiological Controls Group.

INQUIRIES I 4

Inquiries concerning radiological controls should be' addressed to your g' supervisor. Additional inquiries may be addressed to:

3 Chem-Nuclear Systems, Inc.

220 Stoneridge Drive Columbia, South Carolina 29210. .

FS-RP-001, APPENDIX A i PAGE 7 April 86

105 RADIOLOGICAL CONTROL INSPECTIOK", s During the performance of any field job which is expected to last more than 3 months, and for which CNSI has the responsibility for maintaining radiological controls, CNSI Corporate Health Physicist (CHP) or designee shall perform an inspection of the radiation control program. The inspection shall include:

1. A review of dosimetry records of CNSI persennel I .

2.

3.

A review of training records of CNSI persennel A review of the radiation control log

4. An in:pection of the facility S. A review of compliance with the radiation protection program

6. A review of the operating license requirements 106 RADIOLOGICAL CONTROL TRAINING REQUIRD4ENTS Discussion Periodic radiological control training is necessary to ensure that each person understands the general and specific radiological aspects which he might encounter, understands his responsibility to his i empMer and the public for safe handling of radioactive materials, and understands his responsibility to minimize his own exposure to ,

radfation.

The appropriate degree of training for each individual necessary for I the project shall be determined during the ALARA review in accordance with reference 201-9. Personnel need be trained in one of the l following categories.

Requirements

1. Personnel Authorized to Receive Radiation Exposure'in the I Course of their Work: (Radiation Worker):

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a. Personnel who require frequent or routine access to or f

I FS-RP-001, APPENDIX A PAGE 8 April 86 I _- -

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work in high radiation areas, radiation areas, or radiologically controlled areas, shall have met the Radiation Worker Training Standard (Section 107) prior to being issued dosimetry equipment. If it is l

l necessary to issue a person dosimetry equipment prior to completing this qualification, this person must be )

escorted by a qualified individual when in radiological l areas,

b. This training shall be verified by written examination (s) which include questions concerning arear i of required knowledge and questions concerning action required by the individual in event of an unusual

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radiological control situation (e.g., puncture of a contamination containment area). Knowledge, understanding, and practical abilities shall be g verified by signature of a designated individual. Such ni

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designated individuals may be supervisory personnel, training personnel, or radiological control personnel. j

2. Radiological Control Personnel (Individuals responsible for maintaining the Radiological Control Program) j

a. Qualified radiological control personnel shall have met the Radiological Control Personnel Training Standard g (Section 108), and shall be able to apply this know- B 1 edge to situations they might encounter during work.

b. A Radiological Control Supervisor (RCS) shall have at I

least the same level of technical knowledge and ability as radiological control personnel. However, passing l ,

scores fm radiological control supervisor examinations shall bc higher than those required for radiological control personnel; or supervisor examinations shall be g more rigorcus than radiological control personnel E examinations. Experience shall also be considered in the selection of an RCS. - t f

I FS-RP-001, APPENDIX A PAGE 9 April 86 I

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c. Training shall be performed in accordance with References 201.12 and 201.13. Practical ~ abilities shall be verified by signature of designated individuals.. Upon completion of this verification, final comprehensive written and oral examinations shall be given. Written examinations shall include questions requiring evaluation of radiological consequences of a

. postulated incident. Written examination results L should be available to the examiner prior to administering the oral examination so that weaknesses indicated by the written examination can be further investigated during the oral examination. The final comprehensive oral examination shall include questions j involving evaluation of symptoms of unusual-radiological control situations. The examinee, during the oral examination, should be required to evaluate initial symptoms, state innediate corrective action required, state what additional measurements are required,-and do a final analysis of the measurements to identify the' specific problem.

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3. Visitor Personnel Management, technical, and other personnel who require ,

occasional access to radistion areas, high rediation areas, radiologically controlled areas, or areas where radioactive materials are stored and who enter these areas for observation i or similar purposes shall have the radiological control training necessary for the radiological conditions expected to be encountered or shall be escorted by appropriately qualified personnel at all time. For areas other than high radiation areas or radiologically controlled areas, a continuous escort is not required if the visitor is in contir.uous view of '

facility personnel. The presence of personnel normally l assigned to these areas fulfills this function. The RCS shall determine the visitor training requirements and shall re. cord the decision.

FS-RP-001, APPENDIX A PAGE 10 April 86

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4 Recoids '

l The following records of personnel training and training verification shall be maintained in the permanent project file.

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a. All final written examinations.

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b. .For radiological control personnel a sumary statement  ;

of each person's performance during-the final comprehensive oral examination and the areas covered by a the examination. This statement shall be signed by the person (s) conducting the examination,

c. Training records for each individual which indicate the  ;

performance of practical abilities. Verification of i more than one practical ability with a single signature is acceptable provided the practical abilities are  !

verified by the same person in a single training session. This is pemitted provided the verification fom used clearly states what group of spectfic practical abilities the single signature veriffes. For .

. example, an individual's practical abilities could be i verified with a single signature, if all practical abilities were performed in the same examination session. However, a single verification signature for these practical abilities could not be used if they were performed in several separate examination sessions.

A signature for a practical ability indicates the individual has correctly performed the operation or demonstrated a certain ability to the person signing.

The individual sust actually perfor:n the practical task or function. Discussion of the practical task or i function with the person signing does not constitute satisfactory accomplishment.

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The training records shall also contain a signed statement certifying that the person has completed all requirements for the qualification level indicated (i.e., passed written and oral examinations and has all og a the signatures on the record card). For radiological control personnel, this certification shall be by a l certified Health Physicist. For other employees, this certification shall be signed only by persons approved by the Manager of Field Services.

d. A new training record shall be completed for each I veri fication.

5. Reverification of Training l Reverification of radiological control training of all personnel shall be accomplished annually to requalify as a Radiological Control Person.

Re-verification of training shall include a comprehensive I written re-examination. Personnel shall also demonstrate that they retain the practical abilities. Performance of practical abilities during radiological control work in the six months prior to qualification expiration is considered satisfactory ,

demonstration of these practical abilities.

The CNSI Training Review Board (TRB) shall review the duties of personnel who fail to requalify and, based on this review, either disqualify these personnel or limit the duties of these personnel until they satisfactorily requalify.

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I FS-RP-001 APPENDIX A l PAGE 12 April 86

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6. Implementation l The RCS shall ensure that the training requirements of this Section are implemented. Personnel designated to verify practical abilities, conduct classroom and practical training, and conduct oral examinations shall be designated in writing by the CHP or designee.

7. Instruction on Radiation Exposure to a Project to the Unborn Child l The requirements of this Section apply whenever female j personnel are to be employed as radiation workers (authorized I to receive radiation exposure). Prior to being issued dosimetry equipment, all personnel authorized to receive radiation exposure, and all females authorized to receive j radiation exposure as visitors shall be given specific instruction about prenatal exposure risks to the developing embryo and fetus. This instruction shall include both orally and in writing the applicable information in the appendix to U.S. Nuclear Regulatory Commission Regulatory Guide 8.13

" Instruction Concerning ' Prenatal Radiation Exposure," (Ref.

202.5). Instruc, tion concerning prenatal exposure to the unborn child shall be given during initial and re-verification training. All personnel receiving instruction in accordance with this paragraph shall sign the following statement prior to being issued dosimetry equipment:

1 "The recommendation of the National Council on Radiation j Protection and Measurements to limit radiation exposure to the unborn child to the very lowest practicable level, not to exceed 0.5 rem during the entire period of pregnancy have been explained to me."

Signature ,

Typed or Printed Name ",  ;

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Date ( b I

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FS-RP-001, APPENDIX A PAGE 13 April 86 1

The signed statements shall be kept with the training records. Statements signed by visitors shall be retained for three years.

g- 107 RADIATION WORKER TRAINING STANDARD Requirements ,

l Personnel authorized to receive radiation exposure in the course of their work shall receive training in the following topics. Each a topic is followed by a brief description of each subtopic.

l Subtopics identified by an asterisk (*) are practical abilities which must be demonstrated.

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! 1. Radioactivity

a. Atomic structure

b. Radioactive material, natural and by-product h c. Radiation types

d. Biological effects of radiation

e. Radiation detection

2. Radiation Exposure Control l

a. Whole body penetrating radiation limits. Discussion of the rem as a unit of biological dose from radiation.

b. How " stay times" are used.

c. Seriousness of violating instructions on radiation I warning signs and unauthorized passage through barriers.

s-4.c FS-RP-001, APPENDIX A PAGE 14 April 86

d. Procedures and methods for cinimizing exposure such as working at a distance from a source, reducing time in a radiation area, and shielding.

e. Potential sources of radiation associated with work performed by individual's trade or specialty.

f. Where dosimetry equipment should be placed on an individual's body.

g. Various types of self-indicating dosimeters in use.

h. Importance of the individual keeping track of his own expcsure. l

1. Actions to be taken when an individual discovers his pocket dosimeter is off-scale, or loss of TLD or pocket dosimeter.

3. Contamination Control

a. How contamination is controlled during radioactive work (e.g., containment in plastic bags and use of Contamination Containment Areas).

• b. Procedures for preventing radioactive contamination of personnel and how radioactive contamination is detected on personnel,

c. How contamination is removed from contaminated objects l and personnel.

l d. Potential sources of contamination associated with work performed by individual's trade or specialty.

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e. Beta-gama surface contamination limit and be meaning of the units of the limit.

I FS-RP-001, APPENDIX A PAGE 15 April 86

• f. Procedures for d:nning and removing a full set of j anti-contamination clothing.

• g. Procedures for entering and leaving a contaminated area including proper procedures for telf-monitoring.

h. What radioactive contamination is and the difference between radiation and radioactive contamination.

1. Procedures for working in containment areas.

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• j . Procedures for donning and removing the respiratory equipment.

k. Conditions which require wearing masks, air supplied respirators, or air supplied hoods.

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4. Incidents

( a. Consulting radiological control personnel when questions or incidents occur.

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b. Procedures to be followed after a spill of material (liquid or solid) which is or might be radioactive.

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l c. Procedures to be followed when notified that airborne I radioactivity is above the limit.

d. Procedures to be followed when personnel injury occurs.

5. Responsibilities of Individuals Actions required in order to fulfill the responsibilities of individuals includes the responsibility of the individual to

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inform his employer of previous or concurrent occup.ational radiation exposure received prior to employment.

• 4 FS-RP-001, APPENDIX A PAGE 16 April 86

.108 RADIOLOGICAL CONT't0L PERSONNEL TRAINING STANDARD Discussion This standard outlines the minimum theoretical and practical abilities requirements for radiological control personnel after training. Subtopics identified by an asterisk (*) are practical abilities which must be demonstrated in accordance with Section l

106. 2.c .

Requirements

1. Units of Radiation and Radioactivity

a. Define the rem and explain how it differs from the rad and the roentgen.

b. Explain the meaning of " quality factor" and give the approximate quality factor for each type of radiation,

c. Define %e curie and explain that the enrie is a unit of radioactivity.

d. Explain the unit "dpm," how it is used, and use of appropriate conversion factors, thumb rules.

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e. Convert numerical amounts of radioactivity between curies, millicuries, microcuries, picoeuries, and dpm. i

f. Explain the difference between dose and dose rate. j

g. Define half-life. Demonstrate an understanding of the half-life concept by solving various problems.

h. Discuss biological half-life, ef fective half,-life, and how they are determined. .

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FS-RP-001, APPENDIX A PAGE 17 April 86 li

i. Show ability to equate quantities of activity to exposure rate by solving various problems. This shall

,h include both the use of applicable formulae and thumb rules.

2. Types of Radiation ( j Shielding 1

a. Define the different types of radiation (alpha, beta, gama, proton, neutron) by d,iscussing:

) (1) Source (s) of each type (2) Charge and relative mass of each, and

'I (3) Relative penetrating power of each in air and tissue.

(4) Simple mechanisms and materials used for their attenuation.

(5) Method of interaction of each with matter. l

b. Explain tenth-thickness and half-value layer concepts.

c. Solve various shiciding proble:S involving different ]

I. types and thicknesses of shield material by using app 11 cable formulae and thumb rule (s).

d. Describe basic shielding materials and why each type of material is used.

e. Present and explain the shielding thicknesses of water, iron, polyethylene, and lead for gamma radiation and of j polyethylene and water for neutron radiatio'n. Know how to use these various thicknesses to predict lr,adiation j attenuation.

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FS-RP-001, APPENDIX A

( PAGE 18 April 86

f. Describe how radiation exposure is controlled by the I !

use of temporary shielding. Determine the amount, type, location,' etc., of temporary shielding required for various maintenance problems. g g,

g. Explain how radiation levels decrease from a point ,

source, line source, and plane source.

h. Solve radiation level problems involving line and plane and point sources. State and explain applicable l j fonnulce.

1. Explain the relationship between time in a radiation g field and total dose; solve problems involving this E relationship.

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3. Radiation Detection .

a. Explain the general principles of operation of gas ionization detectors.

b. Explain the general principles of operation of g scintillation detectors. E

c. Explain the general principles of operation of ,

personnel dostmetry equipment. i

d. Explain how neutrons, which have no charge, are detected with an instrument which depends on ionization.

e. Identify and explain the various types of det" tion itistruments used: (beta-gansna survey meterk t.g.

Eberline E-520; frisker, e.g. RM-14 with HP-2iG probe; alpha survey meter, e.g. PAC-4G). j

f. Explain the type of detection employed in each type of instrument above. Y b I'

FS-RP-001, APPENDIX A PAGE 19 April 86 l

30 Demonstrate how to convert meter readings to appropriate units.

h. Explain the minimum sensitivity of each instrument and explain how this limits the use of the meter.

.l Describe the effect of various types of radiation on i.

indication of a specific radiation detection instrument.

j. Explain how the type of detector used affects the techniques of operation (e.g., directional probe vs.

7l non-directional probe).

k. Explain the devices used for personnel monitoring and the way in which radiation is detected by each device and the range of each device.

1. Explain the tenn drift" as applied to a pocket g

dosimeter and how often a pocket dosimeter should be read and recharged.

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m. Explain the types, uses, and requirements for various i personnel dosimetry devices.

n. Explain why dry swipes are used.

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o. Explain why 100 cm is the area swiped when possible.

p. Explain how a correction factor is used for converting l swipe activity to a specific isotope basis and why is this correction factor is used.

q. Describe how friskers and beta-gamma survey meters are used to measure surface contamination. State the I minimum sensitivity of each instrument and e,xplaining how this sensitivity changes with background radiation levels. Y I FS-RP-001, APPENDIX A PAGE 20 April 86 j

r. Explain under what conditions headsets or speakers should be used with survey instruments.

4. Biological Effects of Radiation and Radioactivity

a. Explain the general effects of various levels of acute exposures; for example,100 mrem,10 rem,100 rem,1000 rem.

b. Explain the effects of acute and chronic exposures to radiation.

c. Give the basic Ifmit to which external exposures of g

whole body penetrating radiation is controlled and E explain the basis for this limit.

. d. Discuss the factors on which the effect of internal I  !

radioactivity on the body depends. Explain " body g

burden" and " critical organ".

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e. Discuss the calculation of the dose to the whole body which results over a few years from breathing air with I{

a given Co-60 concentration for a given number of minutes.

f. Explain the significance of personnel radiation I

exposure.

g. Compare 1 spc-hr of internal exposure to 2.5 mrem external dose equivalent.

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5. Instrument Counting Statistics

a. Identify and explain each of the required counter-sealer instrument checks. Show how differerjt conditions affect counting results. ".

I FS-RP-001, APPENDIX A I'

b. Define cinitum detectable activity,

c. Discuss how varying radiation background can affect accuracy' of results.

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d. Discuss and explain the basis for various means for increasing the accuracy of a given measurement.

6. Radiation Surveys a a. Demonstrate an ability to use and care for all l radiation detection instruments (i.e., field check, etc.).

b. Explain how routine surveys are conducted in radiation areas for alpha, beta, gamma, and neutron, and how to properly log the results and perform a representative demonstration. Pre-determined locations will be

l. identified where the ability is to be demonstrated so that time in the area can be reduced.

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.; *c. Explain how a radiation survey using high and low-range gansna survey meters is conducted and how to properly log the results and perform a representative ,

demonstration. Pre-detennined locations will be I determined where the ability is to be demonstrated so that time in the area can be reduced.

d. Discuss the specific procedures for performing each of l the radiation surveys and the reason for each of the steps and techniques. -

I e. Explain how to review and interpret the results of radiation surveys. Explain the normal levels to be I expected and what action must be taken if ac,tual reading exceeds the expected readings or the . limits.

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f. Describe how beta radiation is detected by beta-gansna I

survey instruments, and discuss the relationships l; between the meter reading and actual beta field.

Explain why this difference exists.

1 9 Explain how to check detect?on equipment for proper

! response to radit. tion, g

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h. Explain what infomation is obtained using the i

battery-check position on the instruments. State how often the instruments are to be calibrated.

7. Airborne Radioactivity Surveys

a. Explain how to conduct an airborne particulate activity measurement with a portable air particulate sampler and i how to properly los the results. Demonstrate as appropriate.

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b. Discuss in detail the specific procedures for perfoming each of the measurements and the reasons for {

j each of the steps and techniques. I

c. Explain how to review and interpret results of an airborne survey. State what levels are normally expected and what action must be taken if actual readings exceed the expected readings or the limits.

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d. Estimate the airborne activity levels which will result g

from various casualties or incidents.

e. Explain how internal contamination of personnel is controlled.

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f. Discuss MPC Hours and how calculated. ~

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g. Discuss the determination of CAM alarm set points b I

I FS-RP-001 APPENDIX A PAGE 23 April 86

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8. Contamination Surveys I a. Explain how to conduct routine contamination surveys and how to properly log the results. Demonstrate as i I. appropriate,

b. Discuss in detail the specific procedures for performing each of the contamination surveys and the reasons for each of the steps and techniques.

c. Explain how to review and interpret the results of contamination surveys. .j

d. Explain how counting statistics affect the determination of swipe activity.

9. Anti-contamination ( Anti-C) Clothing i a. Demonstrate proper procedure for donning and removing a full set of anti-C clothing.

b. Demonstrate the proper method of wearing and removing dosimetry equipment with anti-C clothing.

c. Discuss in detail the specific procedures for performing each of the above items and the reasons for l each of the steps and techniques.

', d. Explain what anti-C clothing should be worn under various circumstances,

e. State and explain the requirements for donning  !

respiratory protection.  !

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I FS-RP-001, APPENDIX A PAGE 24 April 86

f.- Demonstrm% the proper procedure for putting on and removing masks, air-supplied respirators, and l air-suppl):d hoods, including leak checks for masks and air-supplied resp!rators. For personnel who are required to wear respiratory equipment with anti-contamination clothing, this demonstration shall '

be performed when donning and removing ,

y anti-contamination clothing as required. l

g. State the conditions which require wearing masks, i air-supplied respirators, or air-supplied hoods.

Discuss the need for controlling radioactive work so that respiratory equipment need not be worn.

10. Contamination Control I;J

a. Explain the set-up of a typical control point.

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b. Establish requirements for entry into a radiologically j controlled area,

c. Demonstrate the procedure for surveying personnel with g an alpha and beta-gamma low-range survey meter and with E a frisker.

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d. Demonstrate how to isolate and post a radiologically controlled area. lj I

e. Establish the necessary radiological controls for removing a contaminated filter from a ventilation gI system. 2

f. Discuss in detail the specific procedures for 1 performing each of the above items and the ' reasons for each of the steps and techniques.

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FS-RP-001, APPENDIX A PAGE 25 April 86 4

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ ._ 1

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g. Describe the construction and proper use of the several )

different types of containment areas. Certify proper l setup of a containment area.

h. Describe the proper method for removing contaminated I piping or ductwork.

Describe the proper method for venting radioactive

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systems. )

t I j. Describe " controlled surface contamination area."

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k. Explain the difference between fixed and loose contamination end explain that fixed contamination is I controlled on the basis of radiation levels.

1. Explain why a swipe technique is not normally used for surveying personnel for contamination.

i I m. Explain the radiological control requirements for making an actual entry into a high radiation and 1

controlled surface contamination area.

11. , Decontamination 4

a. Discuss the different techniques of decontaminating an area, tool, or component, and properly handling the l waste.

b. Explain the technique used when decontaminating areas g

where large variations exist .in contamination levels.

I c. Describe provisions for proper disposal of the removed radioactivity, isolation of area, steps to limit spread of surface contamination, adequate ventilation, use of high efficiency filtered vacuum cleaners, and use of

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respiratory protection. $

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FS-RP-001, APPENDIX A PAGE 26 April 86 I

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d. Describe ti.e procedures for decontamination of personnel and the reasons for each of the steps and ,

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l techniques.

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12. Exposure Control l

a. State the appropriate limits for whole body penetrating l f radiation. State where the limits established for ]

I skin, forearms, and extremity doses are found and when to use them.

b. Explain why limits for doses to the skin, forearms, and extremities are set at higher levels than external Il whole body exposure Ifmits.  ;

c. Explain what types of radiation result in whole body or skin doses.

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d. Discuss the guidelines which should be used for j radiation exposures during emergency situations. gf E l

e. Explain the significance of " stay time" and how it is determined. Consider situations involving limiting radiation levels to extremities as well as situations involving only whole body radiation levels.

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f. Define the term "High Radiation Area," describe how these areas are marked, and list and explain the precautions required, l l

g. Define the term " Radiation Area." Describe how these areas are marked, and list and explain the precautions l required.  :

h. Describe the personnel exposure " alert" system procedure and explain how and why it is used.- ,

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. 6 FS-RP-001, APPENDIX A PAGE 27 April 86 gi

f. ' i. Discuss the action which should be taken if an l individual exceeds exposure limits for external or

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internal radiation.

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j. Discuss the procedures for exposure control in various I. practical' situations similar to the following:

1. Transfer of a multicurie Co-60 or CS-137 l source from a storage well to a shipping container.

2. Decontamination of a building containing 2

500-2000 dpm/cm removable contamination.

k. Explain who established the CNSI radiation exposure l control levels and the approvals which must be obtained before exceeding the levels.

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1. Discuss procedures and methods for minimizing the

( radiation exposure of all persons associated with radioactive work.

m. Discuss proper procedures and methods for handling and storage of radioactive components so as to minimize .

l personnel radiation exposure.

l n. Explain what action is required when an individual discovers that his pocket dosimeter is "off-scale" or TLD or pocket dosimeter is lost.

13. CNSI Procedures Discuss the following procedures.

CN-AD-001 SAFETY REVIEW BOARD CN-AD-003 PROCEDURE FOR DOCUMENT PREPARATION ,

CN-AD-005 INCIDENT REPORTING PROCEDURE r;.

I FS-RP-001, APPENDIX A PAGE 28 April 86

CN-AD-019 CHEM-NUCLEAR (CNSI) ALARA POLICY CN-AD-020 CHEM-WUCLEt.R (CNSI) HEALTH PHYSICS POLICY MANUAL i CN-AD-026 RADIATION EXPOSURE RECORDS AND PROCEDURES CN-EM-001 CNSI ENERGENCY RESPONSE PLAN CN-SF-019 REPORTING ON THE JOB INJURIES FS-RP-002 PORTABLE INSTRUMENT / SURVEY RECORD PROCEDURE FOR E FIELD PROJECTS 5 FS-AD-005 FIELD PROJECT SET UP PROCEDURE FO-AD-005 NUCLEAR SERVICES PERSONNEL TRAINING IMPLEMENTATION PROCEDURE F0-AD-006 TRAINING REVIEW BOARD

14. Incidents

a. Discuss performing corrective action for the following I

incidents:

l (1 ) Spill of radioactive liquid; (2) High airborne radioactivity; l (3) Contaminated, injured man; g'

(4) High radiation casualty; Et (5) Loss of radioactive material.

b. Explain the reasons for each imediate and I '

supplementary action taken for the above incidents.

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c. Discuss the radiological problems resulting from the above incidents. Estimate the total dose, dose rates, activity concentrations, etc., which will result from g

the incidents. E 5

d. Indicate possible causes for he above incidents.

Discuss the limitations imposed by the casualty and the i

consequences of failure to take proper corrective actions.

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I FS-RP-001, APPENDIX A PAGE 29 April 86 l

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i I- 15. Responsibility of the Individual ,

Discuss the individual's responsibility to inform his employer of any previous or concurrent occupational radiation exposure received outside CNSI. l g 109 RADIOLOGICAL INCIDENT REPORTS Discussion The procedure for incident reporting is CNSI Procedure CN-AD-005

" Incident Reporting Procedures" (Ref. 201.2). This procedure describes the circumstances and reporting requirements for incidents.  ;

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I I FS-RP-001, APPENDIX A PAGE 30 April 86

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CHAPTER 2-This chapter contains lists of CNSI procedures, Federal ( and State)

Regulations, and Radioactive Materials Licenses with which the ll '

Radiation Control Supervisor (RCS) shall be familiar prior to beginning a project. Copies of these documents should be available J

l at the job site, as applicable.

l 201 CNSI PROCEDURES REFERENCES .

l 1. CN-AD-003 Procedure for Document Preparation

2. CN-AD-005 Incident Reporting Procedure g

3. CN-AD-019 CNSI ALARA Policy B4

4. CN-AD-020 CNSI Health Physics Policy Manual

5. CN-AD-026 Radiation Exposure Records and Procedures

6. CN-EM-001 CNSI Emergency Response Plan 7 FS-RP-002 Portable Instrument / Survey Record Procedure for Field Projects

8. RA-0P-001 Brokering of Radioactive Materials at Comercial Facilities '

9. FS-AD-005 Field Project Administrative and Control gl Procedure B

10. CN- AD-001 Safety Review Board

11. FS-0P-015 Shipment of Radioactive Materials for the U.S. Government by Unit 571.

12. F0-AD-005 Nuclear Services Personnel Training Implementation Procedure l

13. F0-AD-006 Training Review Board i

202 REGULATIONS AND LICENSES

1. 10 CFR 20 Standards for Protection Against Radiation )

2. 49 CFR 172-178 Hazardous Materials Shipping and Handling Regulations 3.

4.

USNRC License 39-23004-01 State Regulations (as applicable) ,'

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5. USNRC Regulatory Guide 8.13, " Instruction Concerning'P.renatal Radiation Exposure 't h l

I FS-RP-001, APPENDIX A PAGE 31 April 86 i

- ___________ _ _____ ____ __________ __ J

CHAPTER 3 RADIATION EXPOSURE LIMITS GENERAL I

301 Discussion Exposure limits are established to control personnel exposure to ionizing radiation. Federal and State Regulations outline the l maximum exposures that a person may receive. These radiation 3 protection regulations stress maintaining personnel exposures As Low

_As _ Reasonably Achievable (ALARA).

302 CNSI EXPOSURE LIMITS CNSI has established administrative exposure limits for exposure of personnel to ionizing radiation below the Federal and State limits.

CNSI procedure CN-AD-020 " Chem-Nyclear Systems (CNSI) Health Physics Policy Minual" (Reference 201.4) provides the general control procedures and exposure limits for personnel working on CNSI

- projects. During a field project, a current copy of Reference 201.4 will be available.

303 RADIATION EXPOSURE LIMITS FOR THE UNB0RN CHILD "During the entire gestation period, the maximum pemissible dose equivalent to the fetus from occupational exposure of the expectant l- mother should not exceed 0.5 rem."

I CNSI policy is that particular efforts chall be made to keep to the very lowest practicable level exposure to the unborn chf1d from I radiation associated with CNSI operations.

Personnel shall be trained on the biological risks to the embryo and fetus from radiation in accordance with Section 106.

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FS-RP-001, APPENDIX A PAGE 32 April 86

l p 304 RADIATION EXPOSURE TO THE PUBLIC CNSI personnel shall ensure that as a result of CNSI operations i

1. No member of the public shall receive whole body dose in one l year exceeding 0.5 Rem, and

2. radiation levels in unrestricted areas shall not occur that could cause an individual continuously present in the area to receive 2 mrem in one hour or 100 mrem in seven consecutive days.

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FS-RP-001, APPENDIX A E PAGE 33 April 86 5

CHAPTER 4 RADIATION SURVEY AND POSTING REQUIREMENTS I 4 01 CALIBRATION AND MAINTENANCE OF RADIATION DETECTION INSTRUMENTS I This section provides the minimum calibration and maintenance requirements for radiation detection instruments. Only instruments I with a current calibration label shall be used for conducting surveys. Instruments suspected of providing incorrect measurements should be removed from service and tagged pending a satisfactory

) response check.

I The requirements for instrument set up and checks are found in ,

Reference 201-7. When this manual is used in the field a current ,

copy of Reference 201-7 is to be available.

402 SAFETY PRECAUTIONS Requirements The following safety precautions should be observed by personnel using radiation detection equipment.

I 1. Only personnel trained in the use of portable radiation monitoring equipment should be allowed to use this equipment.

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2. Damage to or loss of a radioactive source may result in the spreading, inhaling, or ingesting of contamination. If a source is lost, immediate steps should be taken to recover the source and minimize radiation exposure to or contamination of personnel as a result of the lost source.

I 3. In order to prevent sources from being inadvertently lost, all sources should be held under signature custody. These I procedures are in addition to and do not supercede the accountability requirements for sources controlled under Nuclear Regulatory Commission or Agreement State Licenseh'.

I FS-RP-001, APPENDIX A PAGE 34 April 86 I

4. Except for sources which are permanently attached to detection I

instruments (e.g., check sources), check sources which are not in use shall be kept in a Ircked cabinet. The number of keys to the cabinet and the number of personnel having access to the keys should be kept at a minimum.

403 RADIATION SURVEYS Requirements Radiation surveys are performed as necessary to ensure personnel do not exceed radiction exposure 11mf+, and to meet requirements for posting radiation areas. These st<veys are performed to determine g

whe.,er abnormal radiation levels exist and to determine the extent E e.nd magnitude of radiation levels. The surveys in this section shall be the minimum performed. Surveys are to be performed and documented as stated in Reference 201.7.

1. Facilities Containing Radioactive Material

a. Radiation surveys shall be performed to control  ;

radiation exposure whenever operations are performed I that might be expected to change existing radiation levels. Examples of such operations include movement or removal of shielding, radioactive waste processing, and relocation of radioactive materials.

b. Temporary boundaries (e.g., rope boundaries) of radiation areas shall be surveyed daily to ensure radiation areas do not extend beyond posted boundaries.

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c. Gamma surveys shall be performed at least weekly in occupied posted radiation areas, high radiation areas, and in radioactive material short-term storage areas.

Long-term storage areas should be surveyed a least l

monthly.

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FS-RP-001, APPENDIX A PAGE 35 April 86 l;1

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d. When highly radioactive cquipment (i.e., ccntact l radiation level greater than 100 mrem /hr) is moved, I gama surveys should be performed in spaces surrounding work areas (including the spaces above and below them if applicable) where personnel are likely to be exposed to radiation.

I e. Potentially contaminated ducts, piping, and hoses outside radiologically controlled areas shall be I I surveyed at least monthly for gama radiation when in use or at least annually when not in use (e.g.,

3 deactivated systems).

l f. Beta-gama surveys of ventilation filters shall be performed whenever work is performed on these filters.

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g. Other surveys should be performed as necessary to control personnel exposure to gamma, beta, and alpha radiation. Such surveys should include: (1) a gama

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survey during initial entry into a tank containing potentially radioactive piping; (2) gama surveys in spaces where significant radiation levels might exist l from an adjacent operating facility; (3) beta as well as gamma (use of open-window G-N detectors is accepta-ble) measurements when pe: sonnel might come in contact g with surfaces exposed ta beta-emitting contamination.

I h. Surveys shall be conducted when performing operations which could result in personnel being exposed to small intense beams of radiation. These operations include working with spent fuel handl.ing containers, when l removing shielding, or when opening shipping / storage Il containers of radioactive equipment. When surveying areas or equipment where intense small beams of g-radiation could be present, the instrument s,hould be used with an audible response (e.g., earphone,s).

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FS-RP-001, APPENDIX A PAGE 36 April 86 1 - - -___ - _ ___

An audible response is necessary since the visible meter response is usually considerably slower. The probe should be moved slowly enough so that the instru-ment has a chance to give an audible increase for a large radiation level increase. If an audible increase is noted, the probe should be moved to the location producing maximum response and the meter read. If general dose rates are high such that a change in audible response is not detectable, slower surveys should be performed so that beams will be detectable by observing the meter. The speed of moving the probe is determined by considering the size of the probe, the instrument response time, the possible intensity of the beam, and the general dose rates in the arc a. Particu-lar attention shall be given to thoroughly scanning sus-pected areas such as portable shield sections and areas which are or are likely to be occupied. For equipment with complex shield design, surveyors should be briefed i on the equipment design so that areas most likely to have small beams can be given special attention. .g B>

i. Gamma radiation surveys shall be performed monthly on a revolving basis in the areas of the work site where radioactive saterials are not stored or handled. The ll survey should consist of a scan of accessible areas and lockers with aither a G-M dose rate meter or a portable gama sciistillation survey meter (if available). g 404 CONTROL OF RADIATION AREAS Requirements Specified below are requirements for the posting of radiation areas.

It is pemissible to cover (but not remove) permanently posted signs if the area referred to by the sign is not a radiation area. When such signs are temporarily covered, positive control must be i, t FS-RP-001, APPENDIX A PAGE 37 April 86

i established to ensure the signs are uncovered prior to subsequent i operations that require the area to be posted.

1. High Radiation Areas  ;

l Accessible areas where a major portion of the body could l receive a dose in excess of 100 mrem in one hour shall be designated as high radiation areas. Major portions of the body include any portion of the head and trunk. Such areas shall be

'I posted and locked or guarded. The requirement to lock or guard )

a posted high radiation area does not apply to tanks or voids posted as high radiation areas if entry requires the remova'l of complex closures. Positive control shall be established for

l l each individual entry into a high radiation area and shall be established in such a way that no individual is prevented from leaving the high radiation area. Prior to locking an unoccupied high radiation area, the area shall be inspected to ensure that no personnel remain inside. No loitering or entry I by unauthorized personnel shall be allowed in these spaces.

! High radiation areas shall be posted at all entrances into the area. Signs shall contain the conventional esgenta three-bladed symbol on yellow background and the words l " CAUTION: HIGH RADIATION AREA". In addition, " DOSIMETRY BADGE REQUIRED" and " CONTACT RCS, PRIOR TO ENTRY" shall be posted. .

Instances in which high radiation areas are not controlled in accordance with the requirements of this paragraph (e.g.,

locking personnel in a high radiation area or failure to lock I or guard a high radiation area), shall be reported to the CHP.

2. Radiation Area l Any area accessible to personhel in which there exists radiation at such levels that a major portion of the body could receive in any one hour a dose in excess of 5 mrem, or in a 5 consecutive day period a dose in excess of 100 mrem, shall be posted as a radiation area. To mark such areas, signs sgall be 4

FS-RP-001, APPENDIX A PAGE 38 April 86

conspicuously posted; signs shall contain the conventional magenta three-bladed symbol on yellow background and the words

" CAUTION RADIATION AREA"; signs are permitted to state the l

general area radiation level. In addition, " DOSIMETRY BADGE REQUIRED" shall be posted. No loitering is allowed in these spaces.

3. Radioactive Materials Area Entrances to areas where radioactive materials are handled or stored shall be posted with signs having the conventional magenta three-bladed symbol on yellow background and the words

" CAUTION: RADI0 ACTIVE MATERIAL." This posting is in addition to posting required for control of radiation area, high radiation areas, and radiologically controlled areas.

4. Exclusion Areas Areas where access would result in personnel exceeding the radiation exposure limits of Section 302 in a very short titz shall be designated Exclusion Areas and personnel access strictly controlled. Areas where general area radiation levels exceed one R/ hour shall be operated using a written procedure, approved by the Safety Review Board (SRB), which provides positive control of personnel entering this area.

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I CHAPTER 5 PERSONNEL MONITORING FOR RADIATION EXPOSURE I 501 CNSI DOSIMETRY PROGRAM 1

I The monitoring of personnel radiation exposure with all CNSI activities is centrally controlled by the CNSI Exposure Records Section at Barnwell, South Carolina. CNSI procedure CN-AD-026 " Radiation Exposure Records and Procedures" provides the procedures for the issue, ,

"g processing, and recording of personnel radiation exposures of all personnel working on CNSI projects.

I Personnel dosimetry requirements for each project (in addition to those defined in this Section) shall be detemined and approved by the CHP in the ALARA briefing conducted in accordance with Reference 201.9.

In this manual, "TLD" means a themoluminescent dosimeter or equivalent personnel monitoring device.

502 PERSONNEL MONITORING ,

I a. TLD's shall be worn on the area of the body expected to receive the highest radiation dose; under most circumstances this will '

be on the frontal area of the chest or waist. Wen the location of the body which will receive the maximum dose is not certain, l for instance, trunk of the body or head, additic,nal TLD's shall be worn; radiological control personnel shall specify the location of these additional TLD's. When exposure to g

extremities (hands and wrists, feet and ankles) or forearms is expected to exceed 25 percent of the administrative limits of I Section 302, additional TLD's and pocket dosimeters shall be worn on the expo:ed extremity or forearm. When additional TLO's are worn, results of TLD processing for all TLD's shall be incluoed in individual personnel exposure records. Care 1,

FS-RP-001, APPENDIX A PAGE 40 April 86

shall be taken to ensure separate recording of exposures for extremities or forearms and for the whole body radiation exposure,

b. In situations where beta radiation is significant, personnel shall be shielded from the beta radiation using masks or eye protection, and/or anti-contamination clothing. If the beta l radiation cannot be shielded, methods for controlling beta radiation exposure shall be evaluated and implemented to l control exposures to established limits from skin exposures.

l c. (ertain radioactive isotopes given to personnel for medical ,

diagnostic purposes can result in measurable radiation levels l for some period af ter receiving the treatment. If such a situatioi, becomes apparent, the person shall be restricted from wearing TLDs until the medical isotope is eliminated from the body to the extent that it will not affect TLD measurements.

l Tt,e only purpose of restricting this individual from wearing a T:3 is to avoid including radiation exposure from the medical isotope to that received from CNSI operations. Such personnel shall also be restricted from entering areas requiring i monitoring for radiation until the medical isotope is eliminated from the body to the extent that it will not affect personnel monitoring,

d. Lost TLDs or SRDs shall be reported as specified in Reference 201.5. I I

e. TLD measurements shall be made available to personnel en re-I quest so as to enable them to keep track of their own exposure.

503 SELF-READING DOSIMETERS (SRDS)

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1. Requirements SRDs shall be worn to control radiation exposure accumulated

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between readouts of TLDse The fo11 ewing personnel shall be monitored with a SRD.

a. All personnel entering a high radiation area or in .l radiation areas where they could receive a dose in I excess of fifteen (15) arem in one day shall be monitored by a SRD worn at the same location on the body as the TLD. The above does not preclude use of l 3RDs for other exposure monitoring.

)' b. An individual reaching 80% of the appropriate l akinistrative limit of Reference 201.4 shall be placed on an Alert List and shall additionally wear a SRD.

The Radiological Control Supervisor (RCS) shall closely observe the exposure of individuals on the alert list to prevent exceeding akinistrative limits.

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c. Additional SRDs are required if the location of the maximum dose on the body is not certain. This is i discussed in paragraph 1.d above for TLDs.

I 2. SRD Records

a. In addition to the requirements of the Alert System of

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paragraph b. above, the RCS shall maintain a log of all SRD resets between routine TLD readouts. Before the pocket dosimeter is re-zeroed, the measured radiation exposure is recorded, and the individual's quarterly and yearly exposure totals are detemined. The individual is thereby prevented from inadvertently exceeding the control levels.'-

b. SRD exposure results shall be reported to the Barnwell Exposure Records Technician (ERT) weekly.

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I FS-RP-001, APPENDIX A April 86 PAGE 42

3. Reading SRDs a, SRDs, whether low or high range types, shall be read by the wearer prior to entering radiation or high radiation areas and periodically thereafter to control his own radiation exposure while in these areas.

b. To prevent an off-scale reading, higher range dosimeters shall be read, recharged, and doses recerded i whenever the reading exceeds three-fourths of full scale.

c. When a pocket dosimeter reading is off-scale or a dosimeter is lost ur..er conditions such that a high f I

exposure is possibir. the person's TLD shall be processed imediately and the person removed frcm Radiological areas until his exposure has been detemined. Notify the ERT for appropriate dosimeter processing and reporting. l

4. SRD Testing Requirements SRDs in use shall be tested at least every six months to ensure accuracy and drift standards. If dosimeters do not meet i

standards or fail in use, the RCS shall initiate action to j correct the problem. )

504 EXPOSURE RECORDS )

The RCS shall keep records of personnel exposure and shall forward j those records and data as required by Reference 201.5 to the Exposure j Records Technician.

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505 VISITORS Requirements l 1. Visit' ors shall not receive radiation doses which when added to previous doses will cause limits of Section 302 to be exceeded. Before receiving exposure, a visitor shall be questioned to detennine his known or estimated dose for the current calendar quarter and year; unless a written record of his previous cwnulative dose and the dose for the current b calendar quarter and year is obtained, he shall not be allowed to exceed (1) a dose of 100 mrem per week (or 100 mrem per visit if the visit is shorter than one week) or (2) limits l allowed by Section 302 if this requires less than 100 mrem per week. Visitors shall also be questioned to provide some assurance that visitors with medical disqualifications (such as personnel undergoing extensive radiation treatments) do not receive significant radiation exposure. In view of the above, I visitors should be requested to fill in and sign the following statement before issue of dosimetric equipment.

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"My known or estimated occupational radiation exposure l is and mrem for the current calendar quarter mrem for the calendar year. I know of no medical disqualifications which should prevent sty receiving a radiation dose within prescribed Federal Standards."

2. The radiation standards of Section 301 through 304 shall be shown or explained to the visitor.

3. When the exposure received by a visitor is greater than zero, a l report of the exposure should be sent to the individual's organization promptly. Reports of zero exposures should be provided upon request. All records of visitors' exposures shall be retained in the project file.  ;

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506 INTERNAL EXPOSURE MONITORING

1. Requirements Internal contamination monitoring shall be performed when personnel are regularly exposed to airborne contamination exceeding 0.25 MPC as defined in Appendix B, Table I of 10 CFR 20. This requirement is in addition to the internal dosimetry program of Reference 201-5.

Additionally, suspected intakes of radioactive materials, such as may occur when there is significant external contamination, should be investigated by internal monitoring.

The RCS shall contact the CHP or the Director, Regulatory Affairs for direction if the need for internal monitoring is uncertain. The need for routine internal monitoring shall be established during the ALARA briefing.

P. Methods i

The selection of internal monitoring technique shall be made by I the CHP or Directer, Regulatory Affairs.

a. Bioassay - the amount of internal contamination is estimated by measuring the radioactivity in collections of urine, blood, breath, or feces and relating the excretion rete to body burden by the use of biological models.

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b. Whole body counting - An estimate of the amounts of

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internal contamination by gama-emitting nuclides is  !

obtained by counting the gamma rays emitted from the body and analyzing the pulse-height spectrum. This ,

l technique can also be used to measure the .- '

bremsstrahlung from energetic beta emitters.':

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I FS-P.P-001, APPENDIX A PAGE 45 April 86 I

3. Procedures The procedures for collection of bioassay samples shall be specified by the CHP; Director, Regulatory Affairs; or an approved vendor who has contracted to perfom the analysis.

Sample analysis shall be performed by the Barnwell Dosimetry l

Laboratory or by an approved vendor. Whole body counting shall be performed at the Barnwall Dosimetry Laboratory or by an approved vendor.

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4. Reports All reports of internal contamination monitoring shall be maintained in the permanent project file with copies to the Director, Regulatory Affairs and the CHP for evaluation, and as required by References 201.2 and 201.5.

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I CHAPTER 6 l

GUIDELINES FOR CONTROLLING RADIATION EXPOSURE i

601 MINIMIZING RADIATION EXPOSURE ,

Requirements CNSI activities shall maintain personnel radiation exposure ALARA. A continuing effort is required to meet this goal by developing and implementing improvements to work procedures and work performance.

Procedures for managing the ALARA Policy is found in CNSI Procedure CN-AD-019 " Chem-Nuclear Systems, Inc. (CNSI) ALARA policy",

(Reference 201.3). The following are to assist fr. meeting this goal.

1. Work shall only be performed in a radiologically controlled area under the direction of an approved procedure, approved work instruction, or RWP.

2. Individual work precedures shall specify applicable actions (e.g... mockup training or removal of equipment from high radiation areas) to be used to minimize radiation exposure while working.

3. Supervisory personnel and radiological control personnel shall ensure that personnel are not waiting unnecessarily in radiation areas.

4. Before entering controlled areas, a worker shall receive specific job training and/or briefings necessary to enable him to perform his work with minimum radiation exposure. Examples include mockup training in shops for spect fic jobs or periodic briefings by supervisory personnel for routine work. j t' k \

j FS-RP-001, APPENDIX A l PAGE 47 April 86 1

5. Radiation levels in high radiation areas shall be identified by )

the use of signs which clearly show the areas with the high and low radiation levels.

6. CNSI shall maintain records of the cumulative radiation l

! exposure involved 'r. grforming work as necessary to improve methods to minimize personnel radiation exposure in future work.

602 PROCEDURES AND WORK INSTRUCTIONS ,

a 1. Major work in a radiologically controlled area shall be j performed under the guidance of a task specific procent e written in accordance with Reference 201.1 and approved by the Determination of the need for a specific approved I SRB.

procedure shall be made by the CHP.

2. Work in radiologically controlled areas may be performed under the direction of a written work instruction as authorized by the CHP. l

3. Work instructions shall describe the task, radiological conditions, and radiological controls, and shall be approved by l the CHP or designee.

4. A pre-job briefing shall be held prior to beginning work perfonned under a procedure or work instruction to ensure all personnel understand the task, radiological conditions, and l radiological controls.

603 RADIATION WORK PERMIT Discussion I

The Radiation Work Permit (RWP) shall be used to delineate conditions and protective measures to prevent inadvertent exposure of, personnel to radiation or radioactive contamination. A procedure app' rov % by the SRB or written work instruction approved by the CHP that includes FS-RP-001, APPENDIX A PAGE 48 April 86

necessary radiological controls may be substituted for the RWP. The I1 radiological conditions associated with the work to be performed shall be recorded in the procedure or on the RWP. Also specified are l

the protective meascres required by personnel entering the designated area. The following requirements are established to assist in the proper use of the Radiological Work Permit.

Requirements

1. The RWP shall be obtained for work operations not specifically l covered by an approved procedure or work instruction that are performed in an area where any of the following conditions exist or could be produced: ,

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a. Airborne radioactivity resulting in greater than 2 MPC-hours daily intake.

b. Surface contamination in excess of the amount specified for clean areas.

c. Radiation levels that would require posting of the area, as specified in Section 404.1 or 404.2.

d. Whenever the need for an RWP is in question, such as when soil is to be excavated adjacent to a radiologically controlled facility, the RCS shall be j contacted to determine if potential radiological problems may be encountered. The RCS will then detemine if an RWP is required.

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2. Signs indicating the need for the RWP should be conspicuously posted at the entrances to areas where the RWP is required.

l 3. It is the responsibility of supervisors proposing t'o conduct work activities within posted radiation / contamination areas to initiate the issuing of RWP's. Generally, the initia' tor ,will be the supervisor in charge of proposed activities. ' k

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FS-RP-001, APPENDIX A April 86 PAGE 49

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4. RCS shall complete the RWP after discussion of proposed work activities with the supervisor and performance of appropriate surveys.

( 5. Prior to beginning work, the RCS shall hold a pre-job conference with the supervisor and all personnel working under I the RWP; items discussed shall include: work scope, dosimetry and protective clothing requirements, survey results, stay time limits, and emergency actions. The workers shall sign the RWP 5

I to indicate an understanding of the requirements. Werkers added to the RWP after initiation of work shall be briefed by the RCS prior to starting work and shall sign the RWP.

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6. During operations under valid RWPs, if radiological conditions change, the scope of work is changed or expected to change, another RWP will be required and a pre-job conference will be performed.

7. The RCS shall determine the degree of monitoring required for a specific operation. This determination should be based on the s potential for radiological problems and the experience of the rersonnel conducting the operation.

8. An RWP shall terminate five calendar days following its initiation. If the work is to be continued, a new RWP shall be initiated.  !

9. The total dose received by each individual, as indicated by SRD, shall be recorded by the RCS (or designee) on each l terminated RWP. ,,

10. The RCS (or designee) shall monitor that all RWP's are teminated within the time allotted by paragraph 8.above, and shall maintain copies of all terminated RWPs in the permanent I project file. .,

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FS-RP-001, APPENDIX A PAGE 50 April 86 I -_

CHEN-WUCLEAR SYSTEMS. INC. _ RADIATION WORK PERMIT (RWP)

Project / Location Initiating Supervisor Date/ Time Description of Work Special Work Instructions Il MINIMLN REQUIREMENTS FOR WORKING IN THIS AREA:

Protective Clothing (Anti-Cs)

Head Covering Body Covering Hands Feet Hood Coveralls Surg. Gloves Shoe Covers Cap Plastic Suit Rubber Gloves Rubbers Other: Other: Other: Other:

1 Dosimeters Respirator Protection Other Requ4ements TLD Particulate Half Face SRD Yapor Full Face Other: Other: Air Fed RADIATION / CONTAMINATION CONDITIONS IN THE WORK AREA:

General Area Radiation Levels " Hot Spots" i

mR/hr Location mR/hr Location ]

mR/hr Location mR/hr Location Typical Loose Contam. (dpe/100 cm2 ) Maximum Contam. (dpa/100 e$ )

Beta /Gama Alpha Beta /Gama Alpha Note (s ) Location (s)

PERSONNEL AUTHORIZED TO WORK IN THE AREA AND ACCEPTANCE OF RESPONSIBILITY:

Worker's Name Signa ture Total Dose Worker's Name Signature Total Dose l 4

Signing the RWP indicates that you have had a pre-job conference and fully understand all requirements related to this job.

Pre-Job Conference Held: Date/ Time Health Physics Tech. RC5 Approval l

TERJ41 NATION OF RWP: Date/ Time Si gnature Coments __

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PAGE 51 April 86

I~ 604 TD4PORARY SHIELDING

• Requirements Sinct incorrect installation, unauthorized movement, or removal of temporary shielding can result in large changes in work area

! ' radiation levels, control of tenporary shielding is essential.

1. Temporary shielding installation and removal shall be controlled by written procedures. These procedures shall

?g specify locations and amounts of temporary shielding. These B procedures shall require the approval of appropriate technical and radiological control personnel.

2. Af ter installation, temporary shielding shall be inspected to ensure it is properly located.

3. Periodic radiation sw veys conducted in accordance with Section 403 shall be reviewed to ensure that shielding maintains its

,- effectiveness in reducing radiation dose rates. In reviewing ggL m these surveys, particular attention shall be paid to components -

which had radiation levels greater than 1 R/hr prior to shielding, since personnel could receive high radiation exposure in a short time if the shielding has lost its j-effectiveness.

4. Lead shot may be used for temporary shielding, but is not recomended.

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1 CHAPTER 7 l

! LIMITS AND PROCEDURES FOR CONTROLLING AIRBORNE RADI0 ACTIVITY I

701 GENERAL l

Discussion l

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The basic criterion used for control of airborne radioactivity is that internal radiation exposure resulting from inhalation of l

airborne radioactivity should be minimized.. Levels of internal I exposure to airborne radioactivity are measured in units of MPC-hours (Maxinum Permissible Concentration multiplied by hours of exposure).

Radioactivity in the fonn of radioactive particles, gases, or both can become airborne through sources such as (1) radioactive system leaks, (2) grinding or welding a contaminated component, (3) decontamination operations, (4) disturbing surface contamination in a work area, (5) improper use of containment enclosures, (6) inadequate vacuurn citaner and ventilation system control, (7) inadequate application of procedures for venting and draining radioactive systems or components, (8) damage or defect in radioactive instrumentation calibration and check sources, and (9) radon from radin sources and from trace amounts of natural radiun impurities in construction materials.

The Radiological Control Supervisor (RCS) or designee will provide the continuous or periodic sampling required to detect and evaluate l' the tevels of sirborne radioactivity in work areas and exhaust air systems.

It should be noted that this monitoring is primarily concerned with the control of particulate airborne activity. For operations or l materials which may result in the discharge of gaseous airborne activity, contact the Corporate Health Physicist for spect,fic" guidance.

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702 LIMITS FOR AIRBORNE RADI0 ACTIVITY Requirements The CNSI limit for occupational exposure to airborne radioactivity is set at 2 MPC-hrs per day. The MPC can be found by referring to i Appendix B Table I, air concentration limits of Reference 202.1.

1. Limit for Occupied Areas

> Airborne radioactivity in occupied areas resulting from CNSI l operations should be controlled so that personnel are not exposed to radioactivity levels that would require use of respiratory protection equipment.

2. Investigation Levels Any measurement of airborne radioactivity (e.g., continuous air monitor, or portable air monitor san.ple) which indicates the airborne radioactivity concentration to be in excess of 25% of h the applicable MPC shall be investigated to detemine the cause of the airborne radioactivity levels and appropriate controls shall be implemented to maintain the airborne radioactivity levels ALARA.

703 PROCEDURES FOR COW 1 ROLLING PERSONNEL EXPOSURE TO AIRBORNE RADI0 ACTIVITY Discussion Personnel exposure to airborne radioactivity is controlled using contamination containments and respiratory equipment as required g

below. In addition, seny organizations have required use of l respiratory equipment for work in areas with high levels'of surface I 2 contamination (e.g., 50,000 dpm/100 cm ) because of the likelihood that this surface contamination could become airborne. Iri some.

e.

r I FS-RP-001, APPENDIX A PAGE 54 April 66 I

/ circumstances, respiratory equipment might be necessary for work in g areas where surface contamination exists at lower levels. 5 Requirements I

1. Contamination containments shall be used to the maximum extent practicable to prevent personnel from being exposed to airborne l

radioactivity above the limits of Section 702. These >

containments are required during radioactive work which has been known to cause or is expected to cause airborne radioactivity.

2. The need for personnel to wear respiratory equipment in accordance with Section 707 in areas where airborne l

radioactivity exceeds the applicable limits of Section 702 shall be evaluated and documented prior to area entry.

3. Personnel shall not be regularly exposed to airborne radioactivity such that their daily intake exceeds 2 MPC-hours.

4. Signs shall be posted at entrances to areas t!here akborne radioactivity levels exceed 25% of an MPC. These signs shall contsin the conventional three-bladed magenta symbol on yellow l

background and the words " CAUTION: AIRBORNE RADI0 ACTIVITY AREA." These requirements to wear respiratory equipment shall also be included on a sign with the anti-contamination clothing requirements. Radiological Work Permits or work procedures may be required in these areas.

When personnel not wearing respiratory equipment may be exposed I d 5.

to airborne radioactivity above the limit of Section 702, a ventilation system should be operated which will remove l

airborne particulate radioactivity to a controlled ventilation system or other system with a high efficiency filter. For example, during such operations as machining contaminated surfaces, vacuum cleaners fitted with high efficiency filters, g

l I FS-RP-001, APPENDIX A Ei PAGE 55 April 86 E

er flexible ducts connected to a filtered ventilation exhaust shall take suction from within about one foot of the work.

Experience has shown that some operations within containments, such as grinding on highly contaminated components, require exhausting the containment through a ventilation system with an

• installed high efficiency filter, such as by using a vacuum  ;

cleaner, to prevent high airborne radioactivity outside the cor.tainment. Exceptions to this requirement are permitted with approval of the RCS when use of a ventilation system will cause spread of radioactive contamination.

3

6. a. High efficiency particulate air (HEPA) filters defined in Section 708 should be installed in the ventilation l exhaust from radioactive work areas in which work in progress could cause the discharge of airborne radioactivity to the environment.

b. HEPA filters shall be installed in the exhaust from contamination containments to prevent personnel from

_ being exposed to high airborne radioactivity.

c. HEPA filters should be installed in vacuum cleaners

} used around loose surface contamination.

I 7. 2nitoring for airborne radioactivity shall be performed in acardance with Section 705.

8. Positive pressure breathing apparatus, air supply masks, or hoods shall be worn when airborne particulate activity exceeds 100 times the MPC limit of 10 CFR 20, Appendix B. Table I. The filter mask which does not have an air supply shall not be worn in this situation since it is only 99 percent efficient and the one percent penetration would be at concentrations. greater than the one MPC of 10 CFR 20, Appendix B, Table !. ,

'.4 g

FS-RP-001, APPENDIX A PAGE 56 April 86

I l

1 I) l Personnel shall not enter areas where the airborne particulate activity level exceeds 1000 times the limit of MPC of 10 CFR i 20, Appendix B. Table I. This restriction applies even to I

personnel wearing oxygen breathing apparatus or air supply respirators. If personnel entry is required to these areas, containment or filtered ventilation shall be used to reduce airborne radioactivity levels to below 1000 times the MPC of 10 CFR 20, Appendix B, Table I.

Respirators shall be selected such that the ratio of the Protection Factor from Reference 201.4 to the airborne level (in MPCs) does not exceed one (1).

704 HIGH AIRBORNE RADI0 ACTIVITY PROCEDURE I

I; Discussion High airborne particulate radioactivity associated with CNSI operations can result from any of the causes in Section 701. It can E

be indicated by an continuous air monitor (CAM), by a portable air 5 sample exceeding the applicable limit of Section 702, by an airborne radioactivity measurement using a portable radiation survey meter, or by an indication of a radioactive system leak or rupture. General procedures for t:entrolling personnel exposure to airborne radioactivity are contained in Section 703.

Requirements The procedures in this article shall be followed for controlling high airborne radioactivity in locations as indicated below:

I

6 FS-RP-001, APPENDIX A PAGE 57 April 86

I- 1. Particulate Radioactivity Above the Lidts of Section 702 in Occupied Areas

I .

i

a. ,

Immediate Action--These actions should be performed l

nearly simultaneously.

(1 ) Don respiratory equipment in affected areas in accordance with Section 707.

(2) Stop operations which might be causing high

)

airborne radioactivity until adequate control of airborne radioactivity is established.

(3) Evacuate unnecessary personnel from affected areas.

I (4) Secure unfiltered ventilation from the affected spaces *o other spaces. Secure unfiltered ventilation to the environment from affected spaces. Ventilation systents whic' contain high efficiency filters in ext - ducts need not be secured.

!I (5) Determine the extent of the airborne ,

l radioactivity by sampling the affected area and adjacent areas using portable air samplers.

(6) Measure gamma radiation at the CAM to determine if the CAM alarm was caused by high radiation levels external to the CAM. If l radiation levels are high, deteruine the source of the high levels by conducting additional surveys and confirm airborne radioactivity is below the Ifmit of Section 702 by taking portable air samples. - (Action FS.RP-001, APPENDIX A PAGE 58 April 86

I in the subsequent steps need not be taken if the alarm was caused by high external gamma radiation levels.)

(7) If the high airborne radioactivity is indicated by an CAM alarm, the recorder chart does not show circuit failure and the meter indiation is above the alarm point, steps (3) through (8) shall be initiated simul- l taneously and completed as soon as possible.

If the high airborne radioactivity is indicated by a portable air sample, steps (4) g through (8) shall be initiated simultaneously E and completed as soon as possible.

(8) If the high airborne radioactivity is I

indicated by alann of a CAM monitoring a ventilation exhaust or a work area, check t' ? l recorder chart on the CAM panel and the meter indication to determine that the CAM alarm is not the result of circuit failure or an g electrical transient. If the recorder chart 5 shows circuit failure or if the meter indication is below the alarm setting, confirm airborne radioactivity is below the Ifmit of Section 702 by taking a portable air sample. The subsequent actions of this l procedure need not be carried out if the airborne radioactivity is confirmed to be 1

below the limit of Section 702. -

l

b. Supplementary Action (1 ) Attempt to identify the radionuclides causing I

I the airborne radioactivity, for example, by promptly measuring the sample for alpharr-l I

FS-RP-001, APPENDIX A PAGE 59 April 86

radioactivity and determining the approximate half-life or by ganna energy analysis. '

o I. (2) In order to minimize the need for respiratory l '

equipment, and reduce personnel exposures to airborne radioactivity, consideration shall be given to ventilating the facility with additional HEPA filtered ventilation systems. When ventilating, avoid spreading I airbo*ne radioactivity to other spcces.

? Periodically monitor radiation levels on ventilation filters. To minimize contamination of the ventilation system while ventilating, operate the ventilation system in accordance with applicable procedures using the minimum number of fans to achieve stable conditions in the affected spaces.

(3) Perform genna surveys of ventilation filters o , and ducts and measure surface contamination in the vicinity of the ventilation exhaust discharge point.

i I (4) Measure and control surface contamination in areas affected by high airborne radioactivity.

g (5) When resuming operations, take portable air I samples to verify that the cause of high airborne radioactivity is corrected. l (6) hitor evacuated p'ersonnel for contamination l ar.d decon as necessary. A check of personnel exposed to high particulate radioactivity for internal radioactivity may be required.

r, FS-RP-001, APPENDIX A PAGE 60 April 86 I -_

I

2. Reports A report of any incident involving high airborne radioactivity (above the limits of Section 702), in areas occupied by personnel not wearing respiratory equipment shall be made in accordance with Reference '

2 01 . 2. This report shall include the results of I monitoring personnel for internally deposited radioactivity as required.

705 MONITORING FOR AIRBORNE RADIOACTIVITY Requirements

1. The system used for monitoring airborne radioactivity shall l have an MDA not greater than 10% of the applicable MPC. Refer to Reference 201.7 for MDA calculations. l

2. Air particle surseys shall be performed with portable air

sanplers as follows

a. At least every four hours (1) in radiological facilities when radioactive work is performed in these

! facilities, (2) during radioactive work which has been known to cause or is expected to cause airborne radio-activity, and (3) in occupied areas where surface con-2 tamination exceeds 20,000 dpm/100 cm beta or 5,000 2

dpm/100 cm alpha. These portable samples are not required if continuous monitoring is performed in ac-cordance with paragraph 4 following. If the installed continuous air particle detector for a ventilation ex-haust is inoperative and radioactive work is being per-formed, portable sampling every four hours is required.

b. Before initially entering tanks or voids conhaining potentially radioactive piping. y 4

( FS-RP-001, APPENDIX A PAGE 61 April 86

c. Whenever airborne radioactivity levels above the limit of 702 are suspected.

2. Records of the above airborne radioactivity surveys may be l required to serve legal purposes and therefore shall be maintained neatly and retained in the permanent project file.

These records should include at least the following information, as specified in Reference 201.4.

a. Date and time of measurement.

b. Location.

l c. Reason for measurement (e.g., 4 hr. CAM).

d. Instrument used (e.g., portable sample measured with I MS-2).

e. Results of most recent efficiency, MA, and background measurements.

f. Airborne radioactivity in uti/ml.

I

g. Remarks.

h. Signature of surveyor.

1. Signature of persons reviewing records.

3. Portable air particulate sampling equipment shall be immediately available to sample air during abnormal conditions. The following outline procedures for taking air samples with high and low volume samplers.

f(

FS-RP-001, APPENDIX A PAGE 62 April 86

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a. High Volume Air Samples

1. Obtain a calibrated high volume air sampler.

g W >

2. Insert a filtcr paper on the sampler.

3. Determine the time necessary to sample a I

volume sufficient to ensure that an adequate MDA is obtained. ,

4. If. entering a high contamination area, .

protect the sampler by wrapping it in plastic  !

(do not cover intake or exhaust of the sampler). i

5. Turn on the sampler and note the time started. I!)

l

6. At the completion of the sampling time remove f the sample from the sampler and place it in an envelope. Label it with the sampling I time, flow rate and location of the sample.

b. Low Volume Sample I

l

1. Ensure that the low volume sampler has been  !

calibrated.

2. Determine the time necessary to sample a volume sufficient to ensure that an adequate I'y MDA is obtained. .

3. Turn the sampler on and ensure that the flow I rate is approximately 80 to 851pm.

l

4. If entering a high contamination area, protect the sampler by wrapping it in plastic l FS-RP-001, APPENDIX A ,

PAGE 63 April 86 '

I (do not cover intake or exhaust of the sampler).

5. At the start of sampling note the start time I and flow rate.

6. At the completion of sampling note the time and flow rate. Remove the filter and place l it in an envelope; record the sampling time, beginning and ending flow rate, and area sampled.

Continuous Air Monitors (CAMS) shall be used to continuously

g 4.

monitor air particle radioactivity if portable air sampling W

described in paragraph 3.b above is not performed. Continuous air monitoring shall be conducted in accordance with the f following requirements:

a. Continuous air monitor alarm points shall be set as j

close to the limits of Section 702 as practicable

(

' without causing excessively frequent spurious alarms.

b. In the following instances, it is pemissible to temporarily increase the CAM alarm setting. The ,

purpose of this higher setting is to provide warning of further increases in airborne radioactivity or to l prevent spurious alarms.

setting is temporarily increased, it shall be promptly In each case where the alarm returned to the previous alarm setting when the i condition necessitating the increase subsides.

1 (1) If an CAM continues to alarm because of radioactivity associated with operations, it is pemissible to temporarily increase the alarm setting to 50 percent above Me indicatedreadingwiththeapprovalbf'fe 1

Radiological Control Supervisor (RCS).

I FS-RP-001, APPENDIX A l

PAGE 64 April 86

I (2) If the indicated reading of an CAM approaches or exceeds the alarm set point and the increase if confirmed to be a result of radon daughter products from an atmospheric temperature inversion, it is permissible to temporarily increase the alarm setting to 50 percent above the present alarm set point with the approval of the RCS, Confirmation that the increase in airborne radioactivity is a result of radon daughter products shall include all of the following three indica-tions: (1) detection of alpha radioactivity on a portable air sample, (2) an indication of noticeable decay of the radioactivity on a

~

portable air sample filter in a short period of time (i.e., several hours), and (3) an indication of equivalent levels of airborne radioactivity on a portable air sample taken outdoors upwind of ventilation exhausts.

c. Meter indications of CAMS should be recorded at least every four hours when a CAM is operating. When continuous recorders are used, reading and separate recording of indications is not necessary. Use of continuous recorders is not required. Records of meter indications and recorders should be retained as specified in Section 705.2.

d. Extension tubing on the CAM inlet is permitted to monitor a work area. However, this , .v ing should be less than ten feet in length, smooth and without sharp bends or internal obstruction to minimize radioactive particle deposition in the tubing which will, cause the meter to read lower than actual concentration.s.

f FS-RP-001, APPENDIX A PAGE 65 April 86

l' I

e. CAMS monitoring work areas from ventilation exhaust j shall sample from an area where concentrations are representative of the work area.

f. The CAM shall be located in low background radiation levels or shielded such that the CAM alarm can be set l as near the limit of Section 702 as practicable,

g. When sampling areas where airborne radioactivity exceeding 1,000 times the Ifmits or Section 702 is likely, the exhaust of portable air samplers or I continuous monitors shall be exhausted through a high j efficiency filter, returned to the monitored area, or l returned to a controlled exhaust system to prevent 1 contamination of uncontaminated areas.

706 AIR SAMPLE COUNTING

• General When handling air samples collected from areas known or suspected of containing airborne radioactivity care should be taken to prevent the spread of contamination and cross contamination of samples taken.

The samples shall be initially counted and again 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> later to .

determine the actual long 1tved alpha activity if significant radon

-l daughter concentrations are expected.

I Counting Activitie_s,

1. Scaler-Counters used for counting air. activity shall be set up in accordance with manufacturers instr'uction and CNSI procedure FS-RP-002 " Portable Instrument / Survey Record Procedure for Field Projects," Reference 201.7.

2. The following steps shall be followed for calculating, Air Sample Concentrations. '(

l FS-RP-001, APPENDIX A PAGE 66 April 86

a. Determine the air volume drawn through the filter (v).

I V = Tt, where Y =

total air volume (ml)

T = average flow rate (ml/ min)

(fg+f) f z

f4= initial flow rate ff= final flow rate t, = sampling time (min.)

b. Determine the activity on the filter (A).

A . (Cn+t)xF 8 6

(E) x (2.22 x 10 )

where A = activity on the filter (mC1)

C n

= net counts on the filter ~

=, C 5 C C

g

= gross counts on the filter U3 = average background counts t = counting time (min.) l F, = filter absorption factor

= 1.25 for alpha counting with a glass fiber filter

= 1.00 for other counting E = counter ef ficiency 2.22 x 106= conversion factor from dpm to mCf I

I i FS-RP-001, APPENDIX A pag 1 GF (?rg7CD 8@

I. c. Determine the airborne radioactivity concentration [A).

[A] =f

[A] = concentration of airborne radioactivity (in mCf/ml)

A = activity (mci)

V = sir volume (m1) 707 DETERMINATION OF MPC-HOURS Discussion a

An MPC-hour is a quantity of radioactive material equal to the quantity of material that would be inhaled if an individual occupied an area containing airborne activity at a concentration of one MPC (Maximum Permissible Concentration), as found in Appendix B, Table I (air) of Reference 202-1, for a period of one hour.

Requirements g

( ,

1. ' Prior to entry by an individual to an airborne radioactivity 4 t area, the RCS shall detemine the individual's expected daily intake, in MPC-hours, to ensure that the Ifmit of 2 MPC-hours is, not exceeded.

2. The airborne concentration [A)MPC of an airborne area, in MPC, shall be detemined by dividing the measured airborne concentration [A] by the concentration which equals one MPC.

[A3MPC = A) e MPC l

3. An individual's expected daily fetakebl,) shall be

( detemined by multiplying the planned nun 6er of hours worked in an airborne area (t,) by the measured airborne level,

[A)gpg. ,

I, " EA3MpC x t, 1

I FS-RP-001, APPENDIX A ,

PAGE 68 April 86 l l

4. If (1,) might exceed two (2) and [A] cannot be reduced, respiratory protection equipment shall be used or the working time shall be reduced.

5. The actual daily intake (I,), of each individual entering a posted airborne radioactivity area shall be recorded in the HP '

f log and reviewed daily by the RCS.

708 PROCEDURE FOR USE OF RESPIRATORY EQUIPMENT

1. Discussion 10 CFR 20 Appendix B lists concentration limits for continuous exposure to airborne radioactivity of personnel occupationally exposed to radiation. Additionally, Nuclear Regulatory Comission regulations permit upward adjustment of these limits for exposure periods of less than 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week. When airborne radioactivity exists above the limits of Section 702, l

the actions of Section 704 Ifmit its duration to short periods of time.

Even though it should rarely be required by regulation, CNSI requires the use of respiratory equipment as a supplementary control to keep personnel exposures ALARA.

2. Requirements

a. Prior to the use of respiratory protection equipment each individual shall be certified by a licensed t

physician as capable of wearing respiratory protective E

devices. E

b. Prior to wearing a mask, air-fed respirator., or hood in an area where airborne radioactivity exceeds the limit

?f Section 702, personnel shall be trained 10 the use of this equipment and shall have passed a respirator i FS-RP-001, APPENDIX A PAGE 69 April 86

i fit test as described in ANSI Z88.2, Practices for Respiratory Protection. As part of this training, personnel should j demonstrate the proper procedure for putting on and removing masks., air-fed respirators or hoods, including leak checks for masks and air-supplied respirators.

i

c. The RCS is responsible to ensure the above requirements are met and documented for personnel using respirators.

3 3. Use of Respirators

a. To assure that a proper seal between the individual's face and the mask of the respiratory equipment is ob-tained, the wearer should check the mask fit with a negative pressure test each time a mask is donned. A I test, for example, consists of covering the inlet opening, inhaling gently so that the face piece col-lapses slightly, and holding the breath for approxi-mately ten seconds. If the face-piece remains in its slightly collapsed condition and no inward leakage is

, detected, the tightness of the mask is satisfactory.

b. Respiratory equipment shall normally be specifically assigned to an individual for daily use.

I

4. Cleaning and Inspection

a. Assigned respiratory equipment shall not be used for more than one day without cleaning and inspection.

b. Used respiratory equipment, e.g. masks, shall be cleaned, surveyed, and inspected prior to re-use.

Equipment exceeding the following ifmits shall not be I used:

t I

I _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ .

FS-RP-001, APPENDIX A PAGE 70 April 86

1 Al pha Beta-Gamma Loose: 22 dpm/100 cm 2 Loose: 220 dpm/100 cm 2 Fixed: 100 dpm/100 cm 2 Fixed: 0.10 mR/hr Acceptable equipment shall have a new or re-certified l

filter attached as appropriate and shall be tagged and begged and may be issued for re-use.

l

c. Used filter canisters shall be inspected and surveyed after use. Filters with no physical damage and radio-activity levels not exceeding those in 4.b above, may be re-certified by DOP (or equivalent) testing. Only certified (new) or re-certified filter canisters shall '

be used.

d. Half-face respirators shall not be used for radioactive work without prior approval of the RCS.

709 HIGH EFFICIENCY PARTICULATE AIR (HEPA) FILTER REQUIREMENTS ,

Requirements The following requirements for high efficiency particulate air filter I

systems apply:

l

a. HEPA filtered systems shall be tested prior to use following each set up and after each filter change.

Acceptance criteria is a transmission of 0.05% or less I dioctyl phthalate (DOP) particulate per applicable D0P test procedure. 1

b. Great care shall be used in installing HEPA filters to I)l assure the filter material separators are in the vertical position, tight seals are made around the l

edges of the filters, and that filters are nyt damaged

!l i FS-RP-001, APPENDIX A PAGE 71 April 86

~

during installation. Minor damage will greatly reduce the efficiency of these filters.

t

c. Used filters shall be disposed of as radion:tive waste since loose surface contamination could be present on interior pleats.

l

d. Instructions in manufacturers' manuals shall be

{

followed for use and filter change-out.  !

710 PORTABLE VENTI ( ATION SYSTEM I

Discussion A portable ventilation system can be constructed by adapting a portable electric blower with a high efficiency filter. Such a system can be used during maintenance or a high airborne l radioactivity condition to reduce airborne radioactivity without contaminating installed ventilation systems.

A vacuum cleaner with installed high efficiency filter can also be used effectively to reduce airborne radioactivity in a space by recirculating the air in the space through the high efficiency filter.

Such a system must be DOP tested prior to use.

l 711 PROCEDURES FOR CONTROLLING RELEASE OF AIRBORNE RADI0 ACTIVITY TO THE ENVIRONMENT Requirements I The requirements for environmental monitoring shall be determined as j part of the ALARA briefing conducted per reference 201-9. l r

I FS-RP-001, APPENDIX A I

PAGE 72 April 86

l CHAPTER 8 l

SURFACE CONTAMINATION LIMITS 1

801 GENERAL l Radioactive contamination of surfaces (such as floors, equipment, clothing and skin) may result from work operations, leaks of radioactive fluids, or gradual precipitation of airborne radioactive contamination onto exposed surfaces. The primary reason for limiting surface contamination is to minimize possible ingestion or inhalation

of radioactivity. In addition, surface contamination is limited to minimize buildup of radioactivity in the environment. In case of very high levels of surface contamination, control of external radiation exposure from this contamination may be necessary. Surface contamination is divided into two classes in this section

(1) loose contamination can be removed frcm surfaces by dry swipes, and (2) fixed contamination remains on affected surfaces and is not further reduced by normal decontamination techniques.

Swipes are usually pieces of dry filter paper which are wiped over a surface and then measured for radioactivity. Materials which have become radioactive through exposure to neutrons are treated similarly I to those with fixed contamination when performing operations, (e.g.,

machining) which may spread radioactivity.

l l Chapter 8 states the limits for surface contamination. Chapters 9, 10 and 11 describe monitoring procedures, anti-contamination clothing ,

and decontamination procedures, respectively. Procedures for g controlling contamination during radioactive work are contained in u 1 these chapters. Contamination control procedures should be N considered in planning and performance of all jobs. However, the l extent of the contamination control procedures used should be consistent with the amount of radioactivity being handled. The extent of contamination control procedures shall be established during the ALARA briefing required in Reference 201.9. .

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I FS-RP-001, APPEND 1X A PAGE 73 April 86

802 SURFACE CONTAMINATION LIMITS IN UNCONTROLLED AREAS Radioactive loose and fixed contamination limits are dependent upon (1) the scope of work to be performed, (2) Nuclides most likely to be encountered (3) Engineering and customer considerations.

Limits for loose and fixed contamination will be established during the pre-job ALARA briefing, usually based on release limits in the following table taken from NRC Reg. Guide 1.86.

Il Selection of the limit for loose surface contamination in 802 was based on consideration of the following:

l

)

I 1. The limit should be low enough that personnel do not ingest significant amounts of radioactivity from normal contact with I areas or parts contaminated at the limit.

• l

2. The limit should be low enough that significant levels of airborne radioactivity.do not result.

3. The Ifmit should be near background levels of surface

! contamination to prevent an increase in environmental radioactivity over large areas. This consideration is the most restrictive.

.I ,

4. The limit should be such that measurements are as convenient as practicable.

l The standard area for swipes of 100 cm 2has been selected because (1) filter paper tends to disintegrate when wiped over a larger area, (2) this is a convenient area to swipe, (3) this aree gives an optimum efficiency for collecting and measuring contamination.

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FS-RP-001, APPENDIX A PAGE 74 April 86

I

' TABLE I A&C[PTABLE SURrACE CONTAHl AA110N LEV [L5 8

NUCLIDES AvtRAGibcf ggggggg bdf REmmb ' f ,

U-nat U-23b, U-238, and 5,000 dpm o/100 cm 2 15,000 dpm o/100 cm 2 associated ceCay products 1,000 ope o/100 cm2 f ransuranics, Ra-226. Ra 228, 100 dpm/100 cm 2 300 dpm/100 cm2 1h 230, Th-228, Pa-231 20 dpm/luo cm2 Ac 227,1-12b,1-129 Th-nat, Th-232, Sr-90, 1,000 dpm/100 cm 2 3,000 dpm/100 cm 2 Ra-223 Ra-224, U-232, 1-126, 200 dpm/100 cm2 1-131, 1-133 g Beta-gama emitters (nuclides g

5,000 dpm ey/100 cm 2 15,000 dpm et/100 cm 2 1,000 dpm ev/100 cm2 with decay modes other than alpha emission or spontaneous fission) except $R 90 and oth3rs noted above.

.Mhere surface Contamination by both alpha- and beta-gamma-emitting nuClldes exists, the limits establishe and be,ta-gante-emitting nuclides should apply independently.

I As used in this table, ope (disintegrations per minute) means the rate of emission by radioactive material as de.

termined metric f actors by correcting the with associated counts theper minute observed by an appropriate detector for background, ef ficiency, and geo-instrumentation, E C

Measurements area, the average should of everage contaminant be derived for each suchshould object.not be averaged over more than I square meter. For (,bjects d g The mestaua contamination level applies to an area of not more than 100 cm2 .

'The amount of removable radioactive material per 100 cm2 of surface area should be deteref r.ed by wiping that area with dry filter or sof t absorbent paper, epplying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency.

area is deterstned, the pertinent levels should be reduced proportionally and the entire surface should be w The average and maatsum radiation levels associated with surface contamination resulting from beta-gamma emitters should not eaceed 0.2 erad/hr at 1 cm and 1.0 mead /hr at I cm, respectively, measured through not more than 7 milli-grams per square centimeter of total absorber.

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I FS-RP-001, APPENDIX A L_ - - - - - - - - - - - - - -

PAGE 75 April 86

I 803 CONTROLLED SilRFACE CD5?TAMINATION AREAS (CSCAs) l I 1. Areas where surface contamination exceeds the established limits and areas where equipment or materials are handled with l exposed parts exceeding these levels shall be designated Controlled Surface Contamination Areas (CSCAs) until such areas, equipment, or materials have been adequately covered or l decontaminated to meet these limits.

2. Access to a CSCA shall be limited to allow only personnel in appropriate anti-contamination clothing to enter. Choice of appropriate clothing is discussed in Section 1002.

3. Open wounds shall be adequately protected from contamination prior to a person's working in a CSCA.

4. Entrances to CSCAs and potentially contaminated areas shall be posted conspicuously with signs, stating the access restrictions, requirements for anti-contamination clothing and maskro levels of loose surface contamination and radiation dose

g rates (or permissible stay times). These signs shall contain a the conventional magenta three-bladed syntol on yellow background. If the entrance to a controlled surface contamination area is not at a door, barriers shall be used to mark the affected area clearly.

5. Smoking, eating, drinking and chewing shall not be permitted in CSCAs, or potentially contaminated areas. This provision is essential to minimize the possibility of transferring contami-nation frpm the hands or other areas to the mouth. For the I same reason, hands should be kept away from the face, nose, mouth, and ears when in controlled surface contamination areas. Drinking shall be prohibited in controlled surface contamination areas.

. t' I

FS-RP-001, APPENDIX A PAGE 76 April 86

6. Where operations such a grinding or machining are being performed without containment on contaminated components or equipment, the areas of the operations shall be considered subject to the spread of loose contamination and shall be posted as a controlled surface contamination area.

7. Where surveys for loose contamination have not been made, but contamination is suspected, the area shall be posted as a controlled surface contamination area pending the results of contamination surveys.

8. Levels and extent of loose surface contamination inside controlled surface contamination areas shall be limited to control possible airborne radioactivity to facilitate limiting the spread of contamination, to simplify subsequent decontamination, and to minimize personnel radiation exposure.

9. Personnel leaving a controlled surface contamination area shall (a) remove their anti-contamination clothing and (b) monitor or be monitored for surface contamination in accordance with 1204 at the exit of the controlled surface contamination area. Ex-l ceptions to these provisions are pennitted in special circum-stances in accordance with paragraphs 803.10 and 803.11 following.

10. If radiation levels do not permit personnel monitoring at the exit of the controlled surface contamination area (such as tents in high radiation areas) personnel exiting may be permitted to cross areas where personnel are not waring anti-contamination clothing provided: 4

a. Personnel remove all anti-contamination clothing (outer set if double anti-Cs are worn) at the exit of the controlled surface contamination area. ,

i h l

l FS-RP-001, APPENDIX A g April 86 g PAGE 77

___ = ___ _ _ ._ 1

b. Personnel go directly by designated passageways to the I,

nearest monitoring station.

11. In order to minimize areas which are designated controlled surface contamination areas and the potential that contamination will be spread throughout these areas, it is nomally desirable to establish small controlled surface contamination areas within the radiological facility. To 3

, promote work efficiency, it ray be desirable to permit personnel to move between suen small controlled surface contamination areas without completely removing -

anti-contamination clothing.

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FS-RP-001, APPENDIX A PAGE 78 April 86

II CHAPTER 9 CONTROLLING SURFACE CONTAMINATION i

901 GENERAL This part identifies some of the problems which may be encountered in attempting to institute efficient, detailed instructions for control of radioactive contamination. The following describes procedures l

applicable inside and outside radiologically controlled areas. In order that personnel will have the necessary training and skills in controlling contamination, particular attention will be given to training personnel in operations such as working in glove bags or

)

containments.

902- CONTAMINATION CONTROL POINT A contamination control point is a location on the perimeter of a I

controlled surface contamination area or surrounding area through which all entries and exits are made and where attention is taken to prevent the spread of radioactive contamination to adjacent uncon-g taminated areas. The dimensions and material requirements depend on E the type of work to be performed, the number of personnel involved, and the location of the work. The following items outline the basic h considerations for establishing a contamination control point.

1. Determine the extent of the area to be isolated and the location where entry and exit will be controlled.

2. Plan for physical boundaries to prevent inadvertent or unauthorized access to the contaminated area. BouNaries shall be marked. Existing walls and equipment may effectively be used as boundaries.

3. Cover the floor of the contamination control point using paper or plastic sheet or other material provided for this purppse.

FS-RP-001, APPENDIX A PAGE 79 April 86 e .

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I The intent is to provide an easily removal walking surface within the contamination control point to prevent tracking of contamination from the area. Maintain a supply of the material to replace floor covering as necessary.

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4. Provide a " step-off pad" at the exit from the contamination control point. This is to be used when removing clothing during exit from the area.

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5. Provide easily accessible receptacles for radioactive waste and contaminated clothing at the contamination control point. A

, supply of plastic bags shall be available as necessary for receiving contaminated equipment and tools.

6. Provide radiation detection instruments for monitoring personnel and equipment. Frisking should be performed in a low I radiation background and where the audible response of the frisker can be heard.

7. Provide means of recording stay times, as may be required, at the entrance of the areas for personnel. It may be necessary to provide a record of previous radiation exposure received by personnel entering a radiation area so that maximum allowable ,

time in the radiation area can be determined.

8. Radiation tags or labels should be available to identify contaminated items being removed from the area.

9. At the entrance to the contamination control point, infomation shall be posted concerning radiation.and contamination condi-tions, precautions for entry, precautions for exit, step-off points, clothing and waste receptacles, and personnel survey.

I 10. The control point is maintained by Radiological Control. The Radiological Control Supervisor (RCS) shall assign a. qualified person to the control point to ensure that personnel and' I

FS-RP-001, APPENDIX A PAGE 80 April 86

l equipment are adequately surveyed prior to leaving the area and that all logging requirements of Reference 201.4 are met.

11. In some instances where high level contamination exists, it may be necessary to wear two sets of anti-contamination clothing.

The outer garments should be removed at a designated location l

close to the contaminated work to minimize tracking to the '

contamination control point.

12. When adequately trained, personnel may be permitted to assist ll in frisking other personnel and themselves.

903 VENTILATION The RCS shall consider the following when using ventilation systems in a contaminated irea.

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1. Ventilation should be controlled during operations involving radioactivity to prevent spreading the radioactive contaminants through an area. The basic methods of controlling contamination by ventilation are by preventing supply air or recirculated air from blowing into the contaminated work area and by providing filtered exhaust ventilation close to the work or from a containment enclosure erected around it.

2. High efficiency filters are normally installed in permanent ventilation systems servicing radioactive work areas. These filters may become contaminated so that dropping a used filter may spread contamination. Therefore, great care should be exercised when removing used filters.. Filters may require replacement because of plugging (high differential pressure),

high radiation level (in some areas contamination levels may cause significant personnel radiation exposure), or lack of effectiveness in removing radioactivity (usually caused by damage during or prior to installation). .

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FS-RP-001, APPENDIX A PAGE 81 April 86 i

.I L , Filters may be significantly contaminated even though never used for radioactive work. Contamination has been neasured in high efficiency filters frun natural radioactivity in the air.

Contaminated used filters are normally removed into plastic bags. Contamination in the adjacent duct shall be wiped up.

before it spreads during the subsequent new filter installation.

3. A butidup of detectable levels of surface contamination can

. I- occur through the deposition of activity from the air without 3 having significant levels of airborne radioactivity.

Therefore, even though the air particle detector has never alarmed, ventilation exhaust ducts or ventilation system ducts l from radioactive work areas should be considered potentially contaminated. When opening these potentially contaminated systems, they should be monitored with swipes and decontaminated as practical. One method of decontamination is to use a vacuum cleaner with high efficiency filter. For similar reasons, if a portable exhaust blower is used in a contaminated space, surface contamination should be checked on surfaces exposed to tM filtered exhaust of this blower.

4. Exhaust blowers are normally used to exhaust air from many work areas, particularly when welding or grinding. To prevent ,

spread of radioactive contamination when using a blower in a controlled surface contamination area, the intake to the blower shall be filtered through a high efficiency filter. A high efficiency filter is best installed at the intake side of the blower so that air is filtered prior to being exhausted and positive pressures upstream of the filter are avoided. It may be preferable to locate the filter inside the areas to minimize the amount of ducting which becomes contaminated. The blower exhaust should be directed so as to prevent stirring up contamination in the area in which it is used. When removing these blowers, flexible ducts and filters, precautions are required to prevent spilling contamination from them, I _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _

FS-RP-001, APPENDIX A PAGE 82 April 86

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5. When high efficiency filters are installed in ventilation systems for radioactive service, labels should be prominently affixed verifying proper installation of the filters. These labels should be located so that they are destroyed when the filters' are removed.

6. Potentially contaminated air that has not passed through a high I '

efficiency filter should not be discharged to locations occupied by personnel or where supply ventilation can return it l

to an occupied area.

7. Consideration should be given to controlling contamination which has been collected in ventilation equipment and systems not normal'.y used for radioactive work including those systems in adjacent spaces which may become contaminated in event of a spill . Prior to work on these items, radiation measurements should be taken, the items treated as contaminated, and radiological control precautions established to prevent spreading contamination.

904 ENCLOSURES FOR CONTAINING CONTAMINATION The most effective means of controlling radioactive surface I

contamination is through use of enclosures around the contaminated item to keep the radioactive material inside. Containment should be used as much as practicable when working on the surfaces of c ompo-nents which have been exposed to radioactive contamination. Plastic sheet, bags, or Contamination Containment Areas may be used to en-close clean material and prevent contamination of clean items inside the enclosure. The following specific requirements shall be followed when working or handling contaminated equipment and materials.

1. Maximum practical use shall be made of containment enclosures when working on contaminated systems or contaminated equipment and material. .

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PAGE 83 April 86

9

2. Instructions for using containment enclosures shall be readily I. available.

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3. Containment enclosures shall be inspected by the RCS prior to use to determine if they are properly constructed and ready for use. Enclosures shall then be marked to certify this inspection was completed. In addition, containment enclosures ,

shall be inspected daily when in use and the marking updated.

Personnel using containment enclosures shall inform b' radiological control personnel of any damage to containment enclosures which occurs during work. When a containment enclosure is damaged or is unfit for use, the enclosure shall '

be conspicuously tagged to prevent its inadvertent use by personnel unaware of the problem. Containment enclosures shall not be removed or altered without approval of the RCS.

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I FS-RP-001, APPENDIX A PAGE 84 April 86

I CHAPTER 10 MONITORING FOR SURFACE CONTAMINATION l

1001 METHOD FOR MEASURING SURFACE CONTAMINATION Requirements

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A rate meter with an HP-210 probe or equivalent will detect radioactive beta-gamma surface contamination on materials and person-g nel by slowly scanning the probe held within about 1/2 inch of the surface. A rate meter with the HP-210 or equivalent, should be used E{

i with a background radiation level of less than 300 counts per  !

minute. If background levels are above 300 cpm, equipment or person- l nel to be monitored for release shall be relocated to an area of 1ower radiation levels or the area shielded to lower background l

levels. A reading of 100 cpm above background indicates contamina- <

tion. Alpha-emitting contamination is normally monitored using the PAC 4G or equivalent. A reading of 20 cpm above background indicates contamination.

When monitoring personnel, any indications above background shall be investigated as possible contamination.

1002 METHODS FOR TAKING SWIPES FOR LOOSE CONTAMINATION Requirements

1. A swipe should be taken by firmly wiping a piece of dry swipe material over about one hundred square centimeters (an area about four inches by four inches) of the surface being monitored. In controlled surface contamination areas and where contamination is suspected, rubber gloves shall be worn when taking swipes to limit contamination of the hands. ., Rubber gloves need not be worn in uncontrolled areas for taking swipes if contamination is not expected.

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FS-RP-001, APPENDIX A E PAGE 85 April 86 m, a

2. The swipe should be counted in the field with a scaler-counter using a HP-210 probe or equivalent in a planchet holder for beta-gama wipes and an alpha counter such as an Eberline SAC-4 l for counting alpha contamination. An Eberline " Rascal" provid' es the capability for counting both beta-gamma and alpha

' using the same scaler with different probes for each type of I radiation. The detectors shall be set up and checked as required in Reference 201.7.

> 3. When the item to be swiped has less than 100 square centimeters of surface area, the entire item should be swiped and the contamination level reported as "dpm/ swipe" instead of "dpm/100 cm2 . " Since the efficiency of collecting loose contamination f

with a swipe varies considerably with the size of the area swiped, contamination measured with one size swipe area cannot be directly multiplied by the ratio of areas to obtain the result for a different swipe area. For example, if a swipe area from a 100 cm2 area measures 2,500 dpm, a swipe of ten times the area (1,000-cm2) of the same surface might measure only four times the activity (10,000 dpm). In meeting limits 2

of Section 802, swipes from less than 100 cm , the measured dpm/ swipe results s all be used and shall not be multiplied by

'l the ratio of 100 cm to the area swiped.

I 4. Dry swipes are normally used to measure loose surface contamination since the results are more representative of the I spread of contamination by personnel brushing past these surfaces than if wet swipes were used.

1003 METHOD FOR MONITORING FIXED CONTAMINATION I Fixed contamination may be measured with an E-120 r6temeter with HP-210 probe or equivalent for beta / gamma contamination, and the PAC-4G or equivalent for alpha contamination. Since these survey instruments alone do not differentiate between fixed and Joose I E contamination, the measured fixed contamination levels are act'u ally

-v I FS-RP-001, APPENDIX A PAGE 86 April 86

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the total radioactivity and may include some loose contamination.

For fixed beta-gama contamination, levels are usually expressed in dpm per probe. When searching for fixed contamination, or when I trying to find the most highly contaminated portion of contaminated l materials or areas. earphones or audible instrument response should be used. Visual meter indications respond more slowly than audible indication. When surveying to demonstrate lack of residual l

contamination, a portable scaler, such as the Eberline PRS-1, is recomended to reduce the MDA for the measurement.

I 1004 METHOD FOR MONITORING PERSONNEL CONTAMINATION

1. Personnel monitoring (frequently referred to as

• frisking")

I shall be performed when leaving controlled areas in accordance with Section 1202 and after personnel decontamination. Moni -

toring of personnel for surface contamination should be done with an alarming rate meter and 94 pancake probe (RM 14 and HP-210) or equivalent in accordance with Section 901 and the established limits used for such frisking. The probe should be moved slowly over the body with the probe within about one-half inch of the body surface, giving special attention to the face, throat, chest, back and abdomen in order to obtain an indication of any internal deposited radioactivity When monitoring personnel, searching for fixed contamination, or when trying to find the most highly contaminated portion of contaminated materials or areas, e,trphones or audible instrument response should be used. Visual meter indications respond more slowly than audible indications. Frisking for alpha contamination is performed using an alpha probe in a manner similar to that described above except that Ifght contact between the probe and surfaces being monitored should be maintained. Alpha friskers should have an alarm set point indicating the reading corresponding to the contamfoation limit.

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FS-RP-001, APPENDIX A PAGE 87 April 86

2. Monitoring of personnel by taking swipes for loose surface contamination on the skin or clotMng shall not be done since i swipes may tend to imbed radioactive particles.

3. When personnel have been adequately trained in frisking L procedures, requiring personnel to frisk themselves may be desirable. Self-frisking can reduce the number of radiological monitors required to perform a job. When self-frisking is used, arrangements should be made such that personnel do not

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rely on meter response which may be slow.

4. If facial contamination is detected, or it is suspected that radioactive nuclides have been taken into the body even though no facial contamination is evident, the individus1 shall be monitored for internal radioactivity. Measurements of the radioactivity of nose and throat swabs have sometimes been

.l used. However, the radioactivity of these swabs cannot accu-rately be correlated to the amount of radioactivity in the body.

( 1005 FREQUENCY OF SURVEYS FOR MONITORING SURFACE CONTAMINATION Routine surveys of surface cor.tamination should be performed with the frequencies indicated below, or more often if necessary. .

1. During Routine Operations

a. Surveys shall be performed at least daily in occupied areas surrounding controlled surface contamination areas and particularly in the vicinity of exhs from controlled surface contamination areas. Surveys shall I be performed at least daily in occupied, controlled surface contamination areas.

b. Surveys shall be performed at : cast weekly in all l occupied radioactive material areas where there is frequent handling or short-term storage of radioactive FS-RP-001, APPENDIX A PAGE 88 April 86

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materials. Long-term radioactive material storage l areas shall be swipe surveyed at least monthly.

c. Surveys shall be performed monthly on a revolving basis in work and storage areas outside areas where )

radioactive materials are stored or worked on.

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2. Ser ied radioactive test sources (licensable quantities) are j leak-tested by swiping quarterly. For a sealed source that is i stored in a container designated to minimize radiation levels from the source or in a comp 12x device requiring extensive dis-assembly to expose the source, it is pemissible to perfom the required leak test on the outside of the container or complex .

device. In this case, the source shall be tested by swiping when the container or device is next opened for other reasons.

3. In addition, operations such as the following require surveys:

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a. Decontamination of equipment.

b. Inspection or maintenance on components and piping or radioactive or potentially radioactive systems.

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c. Areas where radioactive liquid leaks have occurred or where airborne radioactivity has exceeded the concentrations of Section 702. Surveys are required to j determine the need for anti-contamination clothing and to detemine the extent of contaminated areas.

d. Upon initial entry into tanks or voids containing d

potentially radioactive piping and when opening ventilation exhaust ducting from radioactive work areas. l

e. In additien, any nomally uncontaminated system which is suspected of radiotetive contamination s, hall be surveyed when opened for inspection, maintenance or l

'r: h Il FS-RP-001, APPENDIX A l April 86 i

PAGE 89 E

repair. Contamination control procedures should be I. used until the portion of the system being worked on is proven to be unconti.minated. Water drained or flushed from these systems shall be treated as radioactive.

f. Contamination surveys should be taken in plenums downstream of high efficiency particulate air filters during routine filter replacement or at least annually I to check on radioactivity buildup in ducts downstream

) of filters,

g. Prior to replacing filters on inlet ducts to the l radiological work areas, these filters should be surveyed to determine if radioactivity is present.

Such radioactivity can result from fallout and naturally occurring radioactivity.

h. Surveys for contamination fixed in paint should be performed prior to removal of paint in potentially k

contaminated areas. These surveys should be performed by counting paint scrapings for gross activity.

1006 INSTRUCTIONS FOR CONTROLLING RADI0 ACTIVE SPILLS ,

This article contains general procedures to be followed in the event of small spills of radioactive liquids or solids (including finely I divided particles which may disperse rapidly in air).

1. Since each spill will require different detailed actions for effective control and recovery, personnel shall be trained to l take appropriate supplementary actions depending on the location and potential consequences of the specific incident.

For locations where spills are most probable or would have the worst consequences, each facility should train appropriate personnel in controlling and recovering from radioac.tive I spills. Equipment for containing spills should be prepaFed in advance and located in work areas.

I FS-RP-001, APPENDIX A PAGE 90 April 86

2. The following steps shall be followed in the event of a lI radioactive spill:

a. Imediate Action lI (1 ) Stop the spill.

If the spill is from a system which may have

{

, more material (either airborne particulate J radioactivity or fluids) to leak out, prompt-ly stop the leak if possible. If the spill 15 from an overturned container, try to set l .

{

it upright if all the contents have not es- '

caped. The cmount of time spent stopping a difficult leak should depend upon the radia-tion levels involved, the possibility of inhaling airborne radioactivity from the i spill, and the consequences of not making a prompt closure. In some cases, a prompt closure may not be necessary.

l.

(2) Warn other personnel.

Other personnel who may become contaminated by the spill or who may be able to help control it shall be warned immediately.

Ensure radiological control personnel and area supervisor are notified of the spill. ,

l (3) Isolate the spill prea.

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Keep unnecessary people away from the area affected by the spill to minimize spread of contamination. This action may require closing doors, roping off the area, and verbally warning approaching person"nel, g I

FS-RP-001, APPENDIX A g PAGE 91 April 86 g

(4) Minimize personnel exposure to contamination and radiation.

Personnel in the spill area should remain at the edge of the area until radiological control personnel advise otherwise.

Personnel should keep to the edge of the affected area taking care to minimize spread I of contamination. It may be advisable to set j

a up recovery operations outside the area where a spill occurred and close the access.

j (5) Secure ventilation in the spill area other than filtered exhausts.

I It may be desirable also to shut down exhaust systems in adjacent areas to ensure that air does not flow out of the spill area.

Filtered exhausts in the spill area should s also be shuf fown if necessary to minimize spread of high levels of radioactive I l contamination. Ventilation supplies should be shut down when exhausts are turned off. ,

If the spill is minor (for example, a few milliliters of water with low radioactivity spilled on a smooth surface), innediately cover the spill with the most -

- convenient absorbent material available, such as -

absorbent paper or rags to soak up the liquid. For minor spills involving small. amounts of radioactivity.

l wiping up the spill, even though gloves are not available, probably will not result in additional contamination of the individual. Personnel shall be surveyed and decontaminated as necessary. ,

The senior man in each area is in charge until relieved by the Radiological Control Supervisor (RCS). The man FS-RP-001, APPENDIX A PAGE 92 April 86

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in charge should organize the personnel available and initiate action to control and correct the spill. It is important that this individual makes both his presence and the fact that he is in charge known to all others at the scene. On arrival of the RCS, the status of corrective action taken or in progress shall be inrnediately brought to his attention. The person in l charge shall perform or designate available personnel to perfonn the following imediate actions:

b. Supplementary Action l

Steps (1) and (2) below are actions to evaluate the 4 extent of the problem and to recover from the spill.

The designated supervisor shall consult with Radiological Control personnel to ensure the performance of specific portions of the steps below.

(1 ) hasure radioactivity levels.

Measure contamination on personnel who may have been affected, make contamination surveys in the area adjacent to the spill, measure airborne radioactivity inside and outside the spill area, and measure radiation levels in affected areas, particularly on ventilation filters. Monitor ventilation l' systems to detemine if the spill has caused I them to be contaminated. If it is suspected  !

that radioactive nuclides have been taken j into the body or if' facial contamination is detected, the personnel monitoring procedures shall be followed (see Section 904).

(2) Take subsequent radiological contN1 an_d cleanup actions in accordance with 6ther ,

appropriate articles in this manual.

• FS-RP-001, APPENDIX A PAGE 93 April 86

The designated supervisor shall minimize personnel radiation exposure and generation of radioactive waste consistent with the requirements to recover the spill.

1007 RECORDS OF CONTAMINATION

1. Records of he following abnormal spreads of radioactive b contaminatius should be maintained in the permanent project file and wi?1 be reported in accordance with Reference 201-2.

Any occurrence which results in loose surface hl a.

contamination greater than 1000 dpm/100 cm 2 2

I beta-gama or 50 dpm/100 cm alpha in uncontrolled areas with unlimited personnel access (such as office areas, shops and corridors).

b. Any spread of contamination in radiologically f- controlled areas or controlled surface contamination areas which result in work being stopped for more than four hours or take more than four hours to clean up.

2. Records of surface contamination surveys shall be retained in the pennanent project file. The survey information shall be recorded on a standard form in accordance with reference 201.7 I and will include the following information:

a. date and time of survey;

b. location (may be shown on a survey map or listed in a ll table);

c. reason for survey and type of radiation measured (e.g.,

daily beta-gama swipe survey); .,

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I __ _ _________-____ _ ____ _ ____ _

FS-RP-001, APPENDIX A PAGE 94 April 86

d. instrument set-up, efficiency checks and minimum detectable activity (MDA);

e. background beta gamma radiation level where measurements were made;

f. remarks;

g. signature of surveyor;

h. signature of persons reviewing logs (e.g., RCS).

l 1008 REQUIRD4ENTS AND PROCEDURES FOR RELEASING PREVIOUSLY CONTAMINATED FACILITIES AND AREAS FOR UNRESTRICTED USE

1. The requirements and procedures of this Section shall be applied when releasing previously contaminated areas or radiologically controlled facilities for unrestricted use (e.g., use of the area is not controlled by radiological control procedures). Typical areas and facilities include facilities used for decontamination and repair or assembly of l

contaminated equipment, radioactive waste processing facilities and systems, exhaust ventilation systems for radioactive work areas, radioactive material storage areas, and outside areas accidentally contaminated.

Criterton 1 A Decommissioning plan will be approved by the customer and the Corporate Health Physicist (or his designee) prior to releasing l

any facilities or areas. 1 Criterion 2 '

1 Equipment, parts, waterials, and waste which have been exposed to radioactive contamination shall not be released for rr ,

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FS-RP-001, APPENDIX A E PAGE 95 April 86 3

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.g, unrestricted use until they are surveyed and meet the criteria E of Section 802.

l Criterion 3 Earth (e.g., sand or soil), ground covering (e.g., asphalt or porous concrete), paint (which may have absorbed radioactive contamination), etc., shall not be released for unrestricted I use until the area is inspected and samples do not exceed a a

concentration in pCi/ gram for the radioactivity in question using the criteria established in the approved decommissioning plan.

I 2. Procedures I In order to ensure compliance with the criteria above, the following procedures shall be followed as tpplicable:

a. General Prior to initiation of final surveys, records should be l reviewed and investigations made to detemine if contamination existed in any area and was covered over .

.g to prevent its spread, such as by wall boarding, floor tiling, or paving. Such identified areas should be

, inspected, action shall be taken to decontaminate the area below the criteria of 1 above, or dispose of the contaminated material as radioactive waste.

b. Facilities '

I In certain areas where a potential existed for only low levels of radioactivity (less than 1,000 dpm/100 cm2) l to be deposited un small areas as a result of acciden-tal low-level spills such as in radioactive storage I areas, controlled corridors and passageways, and con-l l

l FS-RP-001, APPENDIX A PAGE 96 April 86

! l trolled areas where only contained contaminated I. material was handled, it can be assumed that radioactivity normally would not be deposited or spread l to inaccessible locations, such as in crevices, under ,

floor tile, or in wall or ceiling joints to a degree to warrant detailed and complete examination. As a minimum, a complete survey should be made with particular attention to potential areas of contamination, such as along walls at shoulder and waist height, and over floor areas.

l In other areas where a potential existed for higher levels of loose contamination (between 1,000 and 10,000 g 2

dpm/100 cm ) to be deposited at times on larger areas 5 as a result of work on uncontained contaminated mate-rial such as in contaminated welding and machine shops, it might be expected that radioactivity could be deposited or spread to a few inaccessible locations.

As a minimum, a thorough survey should be made of all surfaces. Selected floor tile should be removed and -

selected wall joints should be opened for survey along the heavy traffic routes and at the previous work stations.

For highly contaminated areas, such as decontamination '

rooms and liquid waste storage and processing areas, it is necessary to completely strip all floor coverings other than coverings without crevices, such as stainless steel, and open up and expose all wall and floor crevices and joints in order to perform a satisfactory survey.

I

c. Ventilation Ducting usually can be surveyed internally.

An adequate survey of internal surfaces may tonsist of I

spot checking (1) the first few feet of the inlet,and g FS-RP-001, APPENDIX A PAGE 97 April 86

l d

outlet ductwork, (2) a few feet upstream and downstream  !

of a filter (after filter removal), and (3) in the vicinity of handhole openings. If contamination is found, a more complete survey is required.

d. Equipment Equipment such as drains, piping, tanks and hoses which have been previously exposed to radioactive liquids 3 ,

usually shall be removed and discarded as radioactive waste if no longer useful since it is highly improbable that such equipment can be economically decontaminated.

I e. Outside Earth or Ground coverings I Outside earth or ground coverings should be slowly scanned over the entire area surface with a gamma survey meter and representative samples should be counted for gross activity. If the contamination has been covered over, it should be re-exposed for a proper survey.

I 3. Records A record of these surveys shall be retained in the permanent project file for all facilities and outside areas released for  !

unrestricted 6se.

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FS-RP-001, APPENDIX A PAGE 98 April 86 l

CHAPTER 17, I

ANTI-CONTAMINATION CLOTHING AND EQUIPMENT 1101 GENERAL Anti-contamination clothing (often referred to as anti-C clothing) is used to help keep personnel from spreading radioactive contamination outside controlled surface contamination areas and to keep the wearer's body free from contamination. Anti-contamination clothing is required when either surface contamination or airborne radioactive contamination may exceed prescribed limits. In the following section, the recommended type of anti-contamination clothing is described, and instructions for wearing it are given. In addition, miscellaneous equipment used for the control of radioactive contamination is described.

1102 REQUIREMENTS FOR WEARING ANTI-CONTAMINATION CLOTHING

.RCS shall determine the appropriate requirements for anti-contamination clothing based on the following.

1. When first entering an area which may be contaminated, prior to determining the extent and level of contamination, full g anti-contamination clothing shall be worn. Full 5 anti-contamination clothing consist of hoods, coverall, rubber and cloth gloves and shoe covers.

2. Full anti-contamination clothing shall be worn when working in highly contaminated areas (greater than 20,000 dpm/100 cm2 ),

Full anti-contamination clothing may be required in areas with less contamination if personnel contamination is probable. In 1 addition, if contamination may seep through openings such as at g wrists and ankles, these openings should be sealed with tape. 5 Full anti-contamination clothing is also necessary is other 4 g Iii FS-RP-001, APPENDIX A PAGE 99 April 86 i I

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I- situations, such rs when initially opening a radioactive system without containment.

3. A face shield, waterproof apron and rubber gloves should be worn during operations such as sampling of radioactive waste l tanks and processed water tanks.

4. a. When working in very highly contaminated areas (greater '

than 50,000 dpm/100 cm ) double suits of 3

g anti-contamination clothing should be worn. Double E suits limit the contamination which may penetrate the material during work, and they also improve the ease of controlling spread of high levels of contamination.

The outer suit is normally removed prior to leaving the region of very high contamination and the inner suit is normally removed at the boundary of the controlled j surface contamination area.

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b. When only the hands and arms are in contaminated areas such as glove box, rubber gloves attached to the glove box may substitute for the anti-contamination clothing.

c. When working in a contaminated wet area or when .

contaminated liquid is likely to spray on the clothing, the outer coveralls shall be waterproof (e.g., when entering a contaminated liquid waste collection tank, g

disconnecting a used demineralized or resin column, or l when opening a radioactive liquid system).

5. f contamination is confined to floors, or if personnel can pass through a controlled surface contamination area without touching other contaminated surfaces, it may suffice for j

l personnel to wear shoe covers and rubber gloves (wi'thout the other anti-contamination clothing). If wearing gloves without lg anti-contamination coveralls, care should be taken not to ,

transfer contamination from the gloves to personal clothing.

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FS-RP-001, APPENDIX A PAGE 100 April 86

6.

I1 It may be desirable to remave personal clothing before putting on anti-contamination clothing for comfort when working in high temperature spaces. Removing personal clothing is not usually l required for adequate radiological control as long as the anti-contamination coveralls do not tear and the anti-contamination clothing is taken off properly after use.

7. Masks should be worn in conjunction with anti-contamination I

clothing if the concentration of airborne radioactive particles may exceed the limits of Section 702. Masks or face shields shall be worn if covering is needed to avoid contamination of  ;

the face.

8. When reading a pocket dosimeter in a contamination area, provisions should be made so that the dosimeter does not become contaminated. Use of a transparent plastic bag has been effective for this purpose.

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1103 PROCEDURE FOR DONNING ANTI-CONTAMINATION CLOTHING I

The anti-contamination coveralls, hood, shoe covers, and gloves should be donned in accordance with the following:

1. Plastic shoe covers should be put on first. They should extend ,

up over the worker's lower pant leg.

2. Long cotton gloves are put on next and drawn up the foreann.

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3. Don the coverall making sure they fit over the plastic shoe cover. ,

4. Rubber overshoes are put on over the plastic shoe covers.

5. The hood is put on next and secured at the neck.

6. Rubber gloves should be put on last. r;.

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PAGE 101 April 86 l(

7. Tape openings as necessary. I i

1104 PROCEDURES FOR REMOVING ANTI-CONTAMINATION CLOTHING  !

Procedures for removing anti-contamination clothing shall be posted at exists from controlled surface contamination areas or surrounding I areas where radiological control personnel are not personally present to direct the removal. The following procedure shall normally be 1 used for removing full anti-contamination clothing starting prior to l

) leaving the area:

1

1. Remove tape (if used) and place in waste container. (Some j l types of garments still in use might require taping.)

2. Remove rubber gloves (inside out) and place in designated lgE container. Leave on cloth gloves.

l

! 3. Remove hood and mask and place in designated containers. To remove mask, grasp mask by canister or air inlet connection, k-. bend head down and remove by pulling out and away from body.

.! 4. Remove rubber overshoes and place in designated container.

5. Remove coveralls inside out to avoid transferring contamination I

from the outside of the coveralls to personal clothing. Place coveralls in designated container. If feasible, considering design of coveralls and shoe covers, remove shoe covers as in steps 6 and 7 simultaneously with coveralls.

I 6. Remove shoe cover from one foot and then place this foot on a designated step-off area. Shoe cover' s should not touch out-side, and clean shoes should not touch inside the controlled area.

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I FS-RP-001, APPENDIX A PAGE 102 April 86

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7. Remove shoe cover from other foot and step on step-off area.

Place shoe cover in designated container.

8. Remove cloth gloves (inside out) and place in designated container.

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9. Frisk ,yourself or be frisked by radiological control personnel, paying particular attention to shoes, elbows, knees, palms and g head. E i

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FS-RP-001, APPENDIX A gl PAGE 103 April 86 E

CHAPTER 12 RADIOACTIVE DECONTAMIljATION 1201 GENERAL ,

l Decontamination may be required for components, tools and equipment, work areas, clothing or personnel. Each of these subjects is discus-l l sed in the following sections. Alternatives to decontamination are also discussed in these sections. These include, in some cases, storage for decay, disposal without decontamination, or restricted use without complete decontamination. By the very nature of decon-tamination operations, the disposal of the waste radioactivity must I b> considered. Volumes of both solid and liquid wastes shall be m'nfmized. Unauthorized chemicals shall not be usea These may cause difficulties in waste processing. Most radioactive contamination can be removed by normal cleaning. Vfaing with a damp l rag soaked with detergent will usually provide satisfactory decontamination. ,

f' If I wge variations in surface contamination levels exist on highly contaminated surfaces, cleaning shall be from less contaminated I toward more contaminated areas (otherwise radioactivity might spread to less contaminated areas). Cleaning solutions and cloths used in these decontamination operations shall be disposed of as radioactive waste. During decontamination operations, precautions shall be taken l to limit the spread of contamination, such as by taking care not to splash solutions, by properly wearing anti-contamination clothing, and by wearing masks as necessary. Filtered exhaust ventilation is also nomally required to minimize the possibility of contamination

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being breathed by personnel performing the decontamination.

1202 DECONTAMINATION OF TOOLS AND EQUIPMENT l In decontaminating tools and equipment, appropriate radiological' l control shall be exercised for spread of contamination, airborne I FS-RP-001, APPENDIX A l PAGE 104 April 86

radioactivity, and radiation exposure. The following procedures I

apply to decontaminating tools and equipment.

1. Tools and equipment which may be used again in contaminated areas may be temporarily stored in the contaminated area or in a contaminated tool room without decontamination. If certain g

tools are to be used solely in controlled surface contamination Bi area, such as a set of hand tools for the decontamination room, these tools should be durable and distinctively marked to .

indicate they are always treated as potentially contaminated.

Heavily contaminated tools can spread significant surface contamination within a controlled area. Therefore, such tools should nomally be partially decontaminated, such as by wiping i with a cloth. Heavily contaminated tools can be readily identified without taking swipes by measuring their radiation level. Heavily contaminated tools can be decontaminated separately in an ultrasonic tank or treated as in the following paragraphs.

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2. Many lightly contaminated tools may be treated together in 1 ultrasonic tank without time-consuming scrubbing by hand.

These tools need to be swiped or frisked at completion of decontamination to verify the effectiveness of the treatment.

3. In some cases, the need for decontaminating tools may be minimized by taping some portions such as the handles prior to use and stripping off the contaminated tape after use. Large tools are often wrapped in plastic instead of tape. If tape is l

used to cover parts of tools, after tape removal, the residual adhesive shall be removed to minimize. contamination that may be ,

picked up it, future uses of the tool.

4. Tools which are used solely in controlled surface contamination areas can normally be surveyed after decontamination with a beta gama or alpha survey meter instead of swipes. . The.

purpose of decontaminating these tools will usually be' ta r g

I FS-RP-001, APPENDIX A PAGE 105 April 86

reduce their radiation levels rather than to remove all loose surface contamination.

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5. When only a few tools require decontamination, wipe with cloths soaked in detergent is a convenient, effective procedure. This method is also useful when only a portion of a tool is contaminated. A disadvantage of wiping procedures is the large amount of solid radioactive waste produced.  !

6. Dishwashers have proven effective for tool decontamination.

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Provisions must be made for disposal of contaminated wash water.

Mechanical decontamination methods, such as using abrasives I 7.

which remove some of the surface of the tool, can be useful in  :

special circumstances where contamination is not removed by chemical cleaning. In such cases, control of possible airborne radioactivity is essential.

8. The cost of some tools may not justify efforts to decontaminate the tools. In such cases, disposal as radioactive waste may be

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warranted or the tools may be retained solely for use in controlled surface contamination areas.

9. In decontaminating oily or greasy tools or equipment, consideration should be given to the fact that oil or grease will inhibit waste processing. Therefore, initial degreasing with rags, or with degnasing solutions which are disposed of by solidification, may be necessary.

l I 1203 DECONTAMINATION OF AREAS Contaminated areas shall first be isolated and radioactivity then removed while being careful to avoid spreading contamination. In I some cases, tape may be used to lift loose contamination 'from the surfaces. Wiping with damp rags soaked in sudsless detergent is l generally the most effective decontamination method. If r/

I-FS-RP-001, APPENDIX A PAGE 106 April 86

I contamination levels are not 'sufficiently reduced, use of solven.

Il I strong chemicals, or mechanical removal of some of the surface may a '

necessary. In all cases where liquids are used in decontamination, care shall be exercised to avoid spreading radioactivity. The areas shall be surveyed by direct survey with the HP-210 and PAC-4G and by swiping or by other methods detailed in the decommissioriing plan j prior to release to ensure surface contamination is below the j established limit. On painted or covered surfaces, if washing will not remove the contamination, the paint or covering shall be removed and the surface repainted or recovered. During the process of paint l

removal, control of the spread of airborne and surface contamination in dust and paint chips will be necessary.

Because of these radiological control problems, and because paint can chip or wear off exposing underlying contamination, painting is not nomally considered an acceptable substitute for decontamination in controlling loose surface contamination.

Contamination areas should be decontaminated as soon as practica_ie to minimize spread of contamination and to facilitate removal before i the contamination is fixed on the surface. Nomally, areas are decontaminated by starting at the edge and working toward the area of g highest contamination. If high radiation levels from the R contamination contribute significantly to personnel radiation exposure during cleanup, it may be desirable to decontaminate the most heavily contaminated area first.

1204 DECONTAMINATION OF CLOTHING I

Anti-contamination clothing shall normally be laundered and/or surveyed before reuse to minimize the possibility of spreading radioactive contamination to the wearer.

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PAGE 107 April 66

1205 DECONTAMINATION OF PERSONNEL I' 1. Objectives f The objectives of skin decontamination are to remove as much of the radionuclides as practicable in order to reduce the surface dose rate and to prevent activity from entering the body. An over-aggressive skin decontamination effort must be avoided since it may injure the natural barriers in the skin and so 3

increase absorption.

2. Techniques 2.1 Carefully survey the area to determine the extent of contamination.

2.2 Mix a mild solution of soap and warm water.

1 2.3 Wash only the contaminated areas. Indiscriminate washing may spread contamination.

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l 2.4 Gently wash contaminated area two to three minutes.

Monitor and repeat if necessary. Dab skin dry before

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monitoring.

2.5 If contamination persists, wash two more times using a soft bristle brush. Do not brush hard enough to cause skin abrasion.

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' I 2.6 If contamination on the skin , persists, contact the RCS

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, or Corporate Health Physicist.

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l 2.7 If contamination is in the hair, wash the hair away l from the face into a collection basin for further analysis. If the contamination cannot be rehved, contact the RCS or Corporate Health Physicist. y I

FS-RP-001, APPENDIX A l

PAGE 108 April 86

208 If contamination exists near the eyes or other body orifices, always wipe contamination away from these areas to prevent internal contamination. If contamination in these areas persists, contact the RCS or Corporate Health Physicist.

3. Wound Decontamination l

Imraediate flushing of a minor wound is usually desirable to g

minimize absorption of radioactivity. Upon decontamination, EI the wound area should be monitored for internally deposited radioactivity and results of this survey recorded. An incident report shall be filed in accordance with Reference 201.2.

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PAGE 109 April 86 1

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I CHAPTER 13 I

PROCEDURES FOR HANDLING RADIOACTIVE MATERIALS 1301 GENERAL 1

l Discussion This chapter presents procedures applicable to radiological safety considerations for controlling radioactive material associated with

? CNSI operations. Strict radiological control procedures are mandatory for such material to minimize the external and internal ,

radiation exposure received by personnel and to prevent the uncontrolled spread of radioactivity to areas tihere the public might I be affected.

1302 RECEIPT OF RADIOACTIVE MATERIAL I Discussion ,

Radioactive material shall be received in accordance with the opplicable operating license.

Radioactive material received by CNSI requires special control l procedures to ensure that adequate radiological safety precautions are observed, both in unpacking and in subsequent use of the i

material. Potential radiological problems can include external exposure, surface contamination and airborne radioactivity. Some packaging material requires disposal as radioactive waste, In I addition, special precautions are required if dauge has occurred during shipment. -

Requirements The following procedures shall be used for radioactive material received at CNSI work sites. .

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FS-RP-001, APPENDIX A PAGE 110 April 86

1. The RCS shall be familiar with the applicable radioactive l material receipt conditions of the operating license.

2. When received, the material shall be inspected. T .is inspection shall be performed no later than three hours after receipt if received during normal working hours or eighteen hours if received af ter normal working hours. This inspection shall consist of verifying radiation levels on the outside of the package and verifying that the package was properly

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1 transferred. For packages which are shipped, this inspection '

shall verify that the package was shipped in accordance with state and Federal regulations.

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3. The package shall not be opened solely for survey purposes unless the package shows signs of damage. If damage to the radioactive material package has occurred, the RCS shall report i the incident per Reference 201.2.

4. Received packages shall be inventoried as soon as possible.

Inconsistency between the observed contents and the conter*

indicated on the shipping document shall be brought to the attention of the shipper of the material. If the possibility exists that radioactive material has been lost in shipment the RCS shall report this incident per Reference 201.2.

5. Care shall be taken in unpacking to ensure that all radioactive I items in the package are accounted for and to ensure radiological control requirements are followed. Unpacking is sometimes performed in an are; which is not a radiologically controlled area, but shipping containers, if suspected to be contaminated, and packing material shall be surveyed end meet i the criteria of Section 802 to release for unrestricted handling.

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6. Folicwing a satisfactory inventory, a receipt shall be returned promptly to the organization transferring or shipping the item, l whether a receipt is requested or not.

1303 PACKAGING RADIOACTIVE MATERIALS Requirements Radioactive materials shipped for disposal or to another location shall be appropriately packaged and treated as required by applicable g Federal and State regulations and applicable disposal site criteria.

Decisions on radioactive material packaging shall be made with the

, approval of a CNSI Broker.  !

j Precautions for Waste Shipments Shipments of radioactive material must be properly packaged in order to meet all applicable Federal and State regulations. Radioactive wastes being shipped for disposal, in addition to meeting Depart'nent of Transportation regulations, must meet the acceptance criteria (and/or license) of the receiving disposal site. The following waste characteristics shall be considered during decision making on waste l packaging.

Free liquids - Free liquids are generally prohibited in wastes.

011 - 011 in excess of trace quantities is generally prohibited.

Stabilization - Certain wastes require stabilization; determined by radionuclides concentration.

Transuranic - The concentration of transuranic in waste may and SNM require stabilization or exceed acceptance limits.

Pyrophoric - These materials are generally prohibit'ed for Haterial disposal . I I FS-RP-001, APPENDIX A PAGE 112 April 86 E

The RCS shall contact'a CNSI Broker for specific requirements in dealing with wastes being shipped for disposal.

1304 RADI0 ACTIVE MATERIAL STORAGE Storage of radioactive material should be in accordance with the I

following:

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1. Fire Protection Practices Proper selection of a fire resistant storage area for radioactive material will minimize release of radioactivity to the environment in the event of a fire. The safety briefing in Reference 210.7 shall include discussion of fire -

protection. However, the following additional fire protection practices shall be considered for storage of radioactive material to minimize the possibility of a fire and spread of contamination in the event of a fire.

a. Storage of radioactive material in fire-resistant containers is desirable to minimize contamination spread. In addition, containers of highly flammable radioactive materials such as plastic bags of radioactive waste shall be stored in areas segregated l

from other storage to reduce the risk of spreading a fi re.

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b. Smoking shall not be permitted in radioactive storage I areas because radioactive materials are frequently wrapped in combustible materials.

c. An up-to-date list of locations where radioactive materials are stored shall be available to personnel l

who might be called to fight a fire in such areas..

This list shall also identify unusual problems which may be present. -

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PAGE 113 April 6C l

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d. Pericdic inspections of radioactive material storage areas shall be made to identify fire hazards.

Deficiencies shall be promptly corrected.

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e. Fire drills should be performed periodically with both fire fighting and radiological control personnel participating.

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f. Combustible materials shall be minimized inside radioactive material storage areas and should not be 3

stored next to surrounding walls. Welding, burning, or l' other operations which may cause a fire shall not be conducted inside or next to radioactive material

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l storage areas without prior authorization of the RCS or his designated representative.

2. Contamination Control Contaminated items are often stored in plastic bags which 4

might break. Liquid . inadvertently left in a container might leak out, and condensation of moisture from the atmosphere might drip on exposed, contaminated surfaces. Unless all contaminated surfaces of stored materials are appropriately wrapped or contained to prevent the spread of contamination, the storage location shall be considered potentially I contaminated. personnel in these areas, particularly if they handle contaminated material, shall wear necessary anti-contamination clothing. Reasonable care shall be taken in packaging and storing contaminated items to prevent the l spread of contamination and to ensure that entry to areas where such storage is permitted does not result in the contamination of personnel or other areas.

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3. Radiation Exposure Control Storage of radioactive materials can result in possible personnel radiation exposure in the storage area and surrounding areas. For example, a component or bag of contaminated waste measuring one rem per hour, if stored at l

the entrance to the storage area would expose everyone who entered to high radiation levels. If stored in a far corner of the area, high radiation levels might be caused in g surrounding areas. Facilities should store radioactive 5 materials so as to minimize the radiation exposure of personnel entering or working in the area and of personnel in surrounding spaces. Radiation surveys of the storage area l

and of spaces inrnediately around the storage area shall be perfomed to ensure proper posting of radiation areas and prevent inadvertent exposure of personnel in the storage space or surrounding spaces. When necessary, temporary shielding should be used to reduce radiation levels.

Outdoor Storage I

4.

Radioactive materials should be stored where they are I

protected from adverse weather. Normally, radioactive material should not be stored outdoors except during short periods. However, protection from adverse weather should be considered in selection of these temporary storage q locations. Large items which are designed for outdoor use, {

such as radioactive liquid collection tanks, may be stored outdoors. However, mechanical joints or capped pipes which may leak radioactive liquids shall be wrapped with weather resistant materials.

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5. Minimize Radioactive Material in Storage I! i In order to minimize the complexities of accounting for a large amount of -adioactive material and possibility of. I

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PAGE 115 April 86 l l

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losing radioactive material, it shall be consolidated in as few areas as practicable &nd minimize the amount of l radioactive material in storage.

1305 SHIPPING RADIOACTIVE MATERIALS Requirements I All shipments or transfers of radioactive material over public areas (i.e., public highways, waterways, airways, etc. ) incidding shipments made with private or government vehicles, must comply with appropriate Federal, State and local transportation regulations.

The Radiological Control Supervisor (RCS) shall be r~esponsible for maintaining cognizance of the regulations for transportation of radioactive material. Shipments of radioactive material shall be '

performed by a CNSI Certified Broker in compliance with RA-0P-001, ,

" Operating Procedure for Brokering of Radioactive Materials at l Commercial Facilities" (Reference 201.8) or FS-0P-015, " Shipment of Radioactive Material for the United States Government by Unit 571 (Field Services)" (Reference 201.11).

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L 1306 ACTIONS AND REPORTING IN CASE OF LOSS OF RADIOACTIVE MATERIAL m -

Requirements _

l If radioactive material associated with CNSI operaN$s is lost, these procedures shall be followed:

1. Immediately conduct a search for the lost $terial. A

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primary purpose of tnis search is to ascertIin'that no I persons will receive inadvertent internal or external radiation exposure from this material.

2. Notify CNSI Regulatory Affairs in accordance with , Reference a n.  !

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I FS-RP-001, APPENDIX A PAGEF116; April 86 a

CHAPTER 14 ENVIROMiENTAL MONITORING 1401 GENERAL l

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! Environmental monitoring consists of measurements, sample collection and analysis, and dose assessment to detennine if radionuclides are being released to the environment from a facility or site and, if so, what the effect is on the surrounding population. An environmental l monitoring program generally consists of measurements and sample collection at the site boundary and at off-site locations. The types of samples and analyses are dependant on the radionuclides at the site and the possible release mechanisms. All potential exposure pathways should be monitored. The CHP and the customer shall specify the environmental monitoring requirements in the decommissioning plan for the project.

1402 METHODS A typical environmental monitoring program provides for monitori of direct radiation, air, water, and soil.

Direct radiation is typically monitored by TLDs placed at the site boundary and at off-site locations.

Air monitoring usually consists of taking air samples for particulate concentrations at the site boundary and at off-site locations. The techniques used are typically the same as those used to monitor occupational airborne activity.

Water monitoring is usually performed by taking water samples of surface runoff and from wells both on-and off-site followed by an analysis for radionuclides content.

I Surface soil samples are usually collected and analyzed for radioac tivity.' '

FS-RP-001, APPENDIX A PAGE 117 April 86

A compreh:nsive progism may also include flora and fauna sampling.

1403 REQUIREMENTS For those CNSI projects where the potential exists for releases to the environment exceeding the limits of 10 CFR 20, an environmental monitoring program shall be designed and implemented. The needdor an environmental monitoring program shall be discussed during the ALARA briefing (Reference 201.9).

3 If an environmental monitoring program is required, i,t shall be i designed and implemented with the approval of the CHP- or Director, Regulatory Affairs, and shall include: 7 Sampling Locations Types of Samples ,;g3,c.

Sampling Frequency ,

Types of Analyses .

3 Action Levels .,,

t Required Actions 3 1414 RECORDS All records of samples collected, analyses performed, results,t.gpdr actions taken shall be maintained in the permanent projectJ,ife.

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