ML20100A911

Rev 0 to QA Program Station Administrative Order 301, Radiation Protection Plan

ML20100A911
Person / Time
Site:	Indian Point
Issue date:	11/20/1984
From:	Bile K, Miele M, Quinn S CONSOLIDATED EDISON CO. OF NEW YORK, INC.
To:
Shared Package
ML20100A903	List: ML20100A901 ML20100A911
References
NUDOCS 8412040132
Download: ML20100A911 (21)

Text

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APPENDIX E

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NUCLEAR POWER

-INDIAN POINT STATION STATION ADMINISTRATIVE ORDER NO.: 301 REV. O CENTRAL OPERATIONS PROCEDURE NO.: NA TITLE: Radiation Protection Plan REVIEWED BY: / ,, a

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~ SNSC giTG. NO. ' D MT E q - -t APPROVED BY: ( /' '

?w IlflOfD VICE PRES,LDENT, TUCLEAR POWER EFFECTIVE DATE: November 26, 1984 CONTROLLED COPY NO.

8412040132 841121 QUA ASS RANCE l'ROGRAM DOCUMENT PDR ADOCK 05000247 P PDR

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RADIATION PROTECTION PLAN TABLE OF CONTENTS SECTION PACE I. ' Intent.

1 II. Action Required A. Radiation Protection Program Basis, Plans 1 and Policies B. Individual Responsibilities 3 C. Organizational Responsibilities 5

.D. Radiation Protection Training 9 E. Dose Control 11 F. Contamination Control 14 G. Radioactive Material Control 14 H. Radioactive Waste Control 15

1. Reviews of the Radiation Protection Program ~16 III. Reports Required 17 IV. Supercession/ Cancellation '

17 V. Attachments 17

1. Respiratory Protection Policy Statement e

2. ALARA Policy (later)

3. Prenatal Exposure Policy (later)

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1. INTENT This SAO establishes the administrative plan for the Radiation Protection Program at the Indian Point Station.

II. ACTION-REOUIRED A. Radiation Protection Program Basis and Policies.

1. The Radiation Protection Program has been developed to provide for the radiological = safety of personnel at Indian Point I and 2 and to ensure comp 1.snce with all regulatory requirements. In addition to complying with federal regulations, the Consolidcted Edison Company is committed to maintaining personnel radiation doses as low as reasonably achievable (ALARA). This is done in keeping with the philosophy that any exposure to radiation has-a potential for biological effects.

Maintaining radiation exposures ALARA minimizes any potential effects that may occur due to ex-posure to low levels of radiation. It is on this basis and the requirements specified-in Title 10 of the Code of Federal Regulations, Parts 19, 20, 50 and 71, and appropriate NRC Regulatory Guides that the Indian Point Radiation Protection Progran ,

has been developed.

2. The Radiation Protection Program consists of this Radiation Protection Plan, the Station Radiation Protection Manual and the Station Procedures.

The Radiation Protection Manual establishes the requirements under which the Radiation Protection Program will be operated.

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The program elements contained in the radiation protection manual and briefly. described in this document are:

a. Organization and Responsibilities

b. Radiation Protection Training and Qualifications

c. Dose Control

d. Contamination Control

e. Radioactive Material Control '

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f. Radwaste Control

g. Reviews of the Radiation Protection Program Psge 1 of-17

SAO 301 R v. 0

.s Station procedures are developed which implement the requirements of the Radiation Protection Manual. These procedures provide adequate guid-ance and specify appropriate methods or techniques to ensure that the performance of each activity is in accordance with sound radiological control, principles, and is in compliance with applicable regulatory provisions. STRICT COMPLIANCE WITH THESE PROCEDURES IS MANDATORY. In the event work cannot be performed in accordance with procedure requirements, the work effort shall be stopped and shall not be restarted until the procedure require-ments can be met. Procedures and the procedure control system are developed and implemented in accordance with SAO-102, " Procedure / Procedure Change Approval". Records and documentation generated by procedures shall be maintained in

, accordance with SAO 121, " Nuclear Power Station Quality Assurance Record 1:anagement Program".

3. Consolidated Edison management policies are established in the Corporate Policy Manual and in Policy Directives issued by the Vice-President Nuclear Power. Policy Directives establishing fundamental management, policy on the Radiation Protection Program activities are appended to this SAO and considered an integral part of this document. The current Policy Directives are

a. Respiratory Protection Policy

b. ALARA Policy (later)

c. Prenatal Exposure Policy (later)

In addition to the specifications outlined in the appended policies, Health Physics Technicians and their supervisors have the responsibility and authority to stop work or order an aren evacuated when in their judgement the radiological condi-tions warrant such an action and such actions are consistent with plant safety. Only the Vice President, Nuclear Power, the General Manager, Nuc1 car Power Generation or their designated representatives on back shifts, can countermand such a stop work order.

4. The requirements of the Radiation Protection Program are to be fully integrated into every work 7 activity performed at the Indian Point Station.

To meet this objective, the Program requirements must be adhered to by each pornon and group

' involved in Indian Point radiological work Page 2 of 17

S'A0 301 Rov. '0 activities including contractors and company' i support groups such as Power Ceneration Mainten-ance, ' Nuclear Engineering and Nuclear. Quality Assurance and Reliability. Failure by any person or group to recognize this responsibility will not be tolerated. A progressive counseling and disciplinary. system will be instituted to ensure appropriate corrective actions are implemented for radiological controla violation. An effective'and sound Radiation Protection Program can only be

.# conducted if each individual recognizes and exercises their respective responsibilities.

B. Individual Responsibilities Although personnel specially trained in radiation protection functions provide surveillance of i

radiological work activities, each individual in/olved '

in this work must continuously remain aware of potential radio 3ngical problems associated with.the work activity. Individuals by their actions can  ;

directly affect-the radiation and contamination '

exposures of their co- workers and themselves. The following rules shall be followed by individuals working at the Indian Point Stations i 1. Prompt 1'y obey " evacuate" and "stop work" orders from radiation protection personnel. ,

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2. Obey posted, written, and oral radiation protection instructions and procedures, including instructions on Radiation Work Permits. j

3. Do not smoke, eat, drink, or chew in a Radiologi-cally Controlled Area unless specifically authorized in writing by the Radiation Protection Manager.

4. Assure a mentally alert and physically sound .

condition for performing assigned work. I

5. Wear personnel monitoring devices where required j by signs. RWPs or as specified by Radiation l Protection personnel. Report immediately a lost,  !

damaged, or offscale dosimeter to Radiation Protection personnel.

6. Notify radiation protection personnel of the presence of open wounds prior to entry.into'an area where radioactive contamination exists, and exit immediately if a wound occurs while in such an area.

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SAO~301 Rov. 0

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7. Limit the amount of material taken into the Radio--

logically Controlled Area to minimize radioactive waste and decontamination.

8. Wear protective clothing and respiratory protec -

tion equipment properly whenever required by Radiation Work Permits, postings, or by Radiation '.

Protection personnel.

9. Keep track of personal radiation exposure status and avoid exceeding administrative. exposure control levels.

10. Do not loiter in radiation areas and while in'an area remain in the lowest exposure rate area practicable to accomplish the work.

11. Ensure that your activities do not create radiological problems for others and be alert'for the possibility that.the activities'of others may change the radiological conditions to which you are exposed.

12. Miniaize the spread of potentially radioactive spills and notify Radiation Protection personnel and Operation's personnel promptly of a spill.

13. In the event of continuous Air Monitor or Area Radiation Monitor alarms, secure your work, leave the work area. and notify Radiation Protection personnel and Operation's personnel.

14. Avoid unnecessary contact between contaminated surfaces and portions of the body, clothing, tools or other equipment. ,

15. Place contaminated tools, equipment and solid' '

waste on disposable surfaces (for example, plastic  :

sheets) when not in use, and inside plastic bags when work is finished.

16. Remove respiratory protection equipment and j' protective clothing'preperly to minimize the spread of contaminatioa. '

17. Frisk or be frisked for contamination when leaving a contaminated area or at a radiological control point. Notify Radiation Proteccion personnel if contamination is found on any part of the body, clothing,'or dosimetry. Remain in general area if possible to minimize the spread of contamination.

18. Notify Radiation Protection personnel upon returning to the site after medical administration of radiopharmaceuticals.

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- 19. Notify dosimetry personnel following visits to other nuclear facilities so that individual dosimetry records can be updated.

C. Organizational Responsibilities This section describes the major functional -

, responsibilities associated with the Radiation Protection Program at the Indian Point Station. These responsibilities may be delegated through the respective departments. <

1. Vice President, Nuclear Power The Vice, President, Nuclear Power is responsible for facility activities at the Station including radiation protection. The Vice President, Nuc1 car Power has the authority to enforce compliance with rules, regulations, policies and procedures '

established for personnel safety. The Vice

, President, Nuclear Power has the authority to remove any individual from the site for failure to comply with radiological work instructions or procedures. The functional responsibilities of the Vice President, Nuclear Power in relation to radiation protection include:

a. Ensuring, through the managers reporting to him, the implementation of radiation protection policies for all personnel on site.

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b. Ensuring the establishment of goals and objectives for radiation protection related procrams.

c. Providing support to the General Manager, Environmental Health & Safety for implementation of the policies, programs, and procedures that support the Radiation Protection Plan.

2. General Manager Nuclear Power Generation The General Manager, Nuclear Power Generation reports to the Vice President, Nuclear Power and is responsible for facility operations. The ,

General Manager, Nuclear Power Generation is responsible for ensuring the following radiation protection related activities are implemented;

a. Providing direct interface with EH&S supervisory personnel for routine operations; instituting corrective actions for radiation Page 5 of 17

SAO 301 10av. 0

_d' protection problems (such as spills);.and resolving radiological deficiencies associated with plant operations, procedures, systems, equipment, and work practices.

b. Notifying appropriate EH&S personnel when plant operational activities, conditions, or events occur which may impact radiation protection efforts.

c. Reviewing and approving Radiation Work Permits prior to issuance to ensure that plant conditions do not cause unanticipated radiation protection problems.

d. Incorporating radiation protection principles into routine operations and maintenance work.

e. Coordinating maintenance activities with EH&S personnel.

f. Resolving radiation protection problems associated with maintenance activities.

g. Providing support and personnel for-maintenance of radiation protection facilities and equipment,

h. Identifying those components or systems which require decontamination and implement-measures to ensure decontamination.

3. General Manager, Technical Support The General Manager. Technical Support reports to the Vice President, Nuclear Power and is responsible for engineering, scheduling, testing {

and chemistry support for' plant operations. The '

3 General Manager, Technical Support.is responsible for ensuring the following radiation protection related activities are implemented.

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a. Providing proposed design changes to EH&S for review to ensure incorporation of ALARA principles.

b. Providing outage work lists to EH&S to ensure 1 a timely ALARA review, i

c. Developing and implementing a chemistry program that minimizes radioactive material deposition in plant components and systems. I l

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Ensuring _that' outage sch"edules and plans

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s (4. ("fCene ral Manager. . Adminis t rat ive Services 2

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The General Manager, Administrative Services q repor,ts to<the Vice President, Nuclear Power and

( , ,is' y e' sponsible for training, security and safety.

iiThe General Manager,[ Administrative Services-is t s ' responsible for ensuring the following_ radiation protection related activities are implemented.

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a. Scheduling and conducting 1 radiation pro-tection training for worker qualification and requalification.

'n b. Incorporating'ra'diation protection principles

-into appropriate training documents and i

security procedures.

l S. General Manager [ Environmental Health & Safety The General Manager, Environmental Health &' Safety reports to the Vice_ President, Nuclear; Power and is responsible for. implementation and management of the Radiation Protection, Radwaste, Nuclear Environmental Monit_oring and Emergency Planning

- a, programs. Duties and'responsi,bilities for the'

Emergency Planning Program 'ar e . outlined in the

'[!

Emergency Plan. The General Manager, Environmental. Health & Safety is responsible for

./ J ensuring the following:

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n. P roviding 3 radiation protection input to~ plant procedures, design, and operational and l outage planning.

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b. and analyzing trends

ta- Collecting associateddata with(sork performance .in

', Radiologically Controlled Areas.

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c. Ensuring that Health Physics staffing, facilities and: equipment.are adequate.

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d. Approving the content of'all training related to, radiation l protection.

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., e. Identify'ing and reviewing causes,. concerns, i'

s and corrective actions'for radiological r

1 y matters.

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SAO 301 ' Rov. 0

f. Providing a radiation protection overview of radioactive waste processing and control.

g. Stopping any job in Radiologically Controlled Areas when the radiation protection controls are not sufficient or are not followed.

h. Conducting periodic reviews of the various elements.of the Radiation Protection Program.

i. Providing support to the Training Section for the conduct of HP Technician qualification and specialized radiological training such as ALARA Engineering Training.

j. Providing assistance to Section Managers and supervisors in radiological work planning and ALARA goal (s) development.

6. Section Managers Section Managers are responsible for incorporating radiation protection considerations into the operation of their section. These responsibilities include:

a. Ensuring that their personnel adhere to radiological safety requirements,

b. Ensuring personnel attend required radiation protection training.

c. Ensuring that qualified personnel performing work in the Radiologically Controlled Areas have received appropriate training.

d. Informing the General Manager, EH&S of changes in section or group functions which may impact radiation safety.

e. Providing man-hour estimates f or j obs requiring a Radiation Work Permit.

g. Developing work procedures and practices-which incorporate appropriate radiological controls.

f. Developing Man-Rom goals for the section.

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7. First Line Supervisors Responsibilities of first line supervisors include:

a. Ensuring that their personnel adhere to radiological safety requirements,

b. Ensuring. personnel attend. required radiation protection training.

c. Ensuring that individuals assigned to work in Radiologically Controlled Areas are properly badged, trained and briefed prior to starting work.

d. Ensuring that personnel under their supervision do not exceed administrative exposure control levels.

e. Initiating and terminating Radiation Work Permits in a timely manner for work in Radiologically Controlled Areas and providing sufficient and clear information about work and locations for radiological evaluation,

f. Identifying radiation work procedures or practices.that need improvement and initiating measures to. implement improve-ments.

g. Ensuring that workers are prepared with the proper procedures, tools and equipment to perform the work assigned,

h. Identifying and selecting the minimum number.

of workers necessary to accomplish tasks involving occupational exposure to radiation.

i. Inspecting work areas to ensure that radia-tion protection requirements are being.

implemented.

j. Informing Radiation Protect' ion personnel of changes in work that could adversely affect radiological conditions.

D. Radiation Protection Training and Qualification

1. The objective-of the radiation protection training program is to ensure each person understands the radiological environment he might encounter, understands his responsibility to the station and Page 9 of 17 L

SAO 301 Rev. 0 the public for the safe handling of; radioactive materials, and understands his1 responsibility to minimize his own exposure.

2. Each individual should understand the nature, scope and objectives of the radiation protection program includini pertinent portions of federal regulations and Station radiation protection policies, administrative cont ols and operating procedures. Additionally, the training includes:

a. Practical demonstrations on the use of dosimetry, proper frisking techniques and use of protective clothing.

b. Selection, use and control of respiratory protection devices.

c. Instruction on the biological effects of radiation and the risks associated with radiation exposure.

d. Instructions concerning prenatal exposure risia to the developing embryo and fetus,

e. Techairues for minimizing the generation of dry raciocctive waste, contaminated material and equipment.

f. An overview of plant radiological conditions,

g. A written or oral examination.

h. An annual requalification.

3. "Self monitoring" training is provided for selected personnel to allow these individuals to enter High Radiation and Contamination Areas without continuous Radiation Protection Technician surveillance.

4. Supplemental craining consisting of ALARA engineering design and operational instruction, mockup'walkthroughs, and pre-j ob briefings is also available for designated work groups.

5. A general radiological indoctrination shall be provided to personnel who routinely work outside the Radiologically Controlled Areas and within the Security Protected Area. This training shall include an overview of plant radiological conditions in order to prevent inadvertent entry into Radiologically Controlled Areas.

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6. Each member of the Radiation Protection staff shall meet or exceed the minimum-qualifications of-ANSI.18.1-1971 except for the Radiation Protection Manager who shall meet or exceed the minimum qualifications of Regulatory Guide 1.8, September 1975.

7. Training and qualification of Radiation. Protection Personnel will include:

a. Formal classroom instruction.

b. On-the-job training.

c. Written or oral exams.

d. Practical ability demonstrations.

e. Two year requalification.

8. Emergency Response Training shall be provided in accordance within the provisions of the Emergency.

Plan.

E. Dose Control

1. External '

b a. The objective of the radiation protection-dose control system-is to maintain personnel-  ;

and collective doses ALARA and prevent individual exposures from exceeding-regulatory-limits. The three maj or -

[ components of the dose ~ control _ system that-l aid in meeting this objective are1theLALARA Program, Access Control System and-External '

Monitoring System.

! b. The ALARA Program is integrated into work L planning and radiological-access activities and includes'the following:

o Established goals f orimajor jobs and

, sections,

o. Engineering design' reviews that

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incorporate. radiation protection considerations.

o Pre-j ob brie fings and mock-up -t raining.

o Written work procedures that incorporate radiation protection considerations.

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. , . .t o Procedures specifying conduct of ALARA reviews-for radiological work activities.

o A review and evaluation of progress in meeting stated goals with' feedback to future goal develcpment.

c. The Access Control System prevents unauthor-ized entries into radiological areas and-provides instructions to workers authorized to enter Radiolcgically Controlled Areas.

This system includes the following pro-visions:

o Radiation Work Permits for entries into High Radiation, Contamination or Airborne Radioactivity Areas and work conducted within a Radiation Area. The primary purpose of the RWP is to control personnel entries into areas containing radiation or radioactive materials. The RWP identifies the work activity, the associated radiological. conditions and the protective measures necessary to perform the work ALARA.

o Periodic surveys of accessible locations within the Radiologically Controlled Areas. Surveys are made of radiation, contamination and airborne radioactivity levels. _ Surveys are performed to monitor the suitability of control measures. evaluate the need for and type of radiological controls, and evaluate trends for ALARA purposes, o Each High Radiation Area, within Unit II, in which the intensity of radiation is. greater than 100 mrem /hr but less than 1000 mrem /hr shall be barricaded and conspicuously posted as a High l Radiation Area and entrance thereto shall be controlled by issuance of-a Radiation Work Permit and any individual or group of individuals permitted'to enter such areas-shall be provided with a radiation monitoring device which continuously indicates the radiation dose rate in the area.

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SA0 301. Rev. O e-j o Each High Radiation. Area, within Unit II, in-which the intensity.of radiation is greater than 1000 mrem /hr shall be subject to the provisions,specified in the preceeding' paragraph, and in addition locked doors shall be provided to prevent . unauthorized entry into such areas and the keys shall be maintained-under the administrative control ~of the Watch Supervisor on duty.

o Each High Radiation Area, within Unit I, in which the intensity of radiation is greater than 100 mR/hr shall be locked except during periods when access to the area is required .with positive control and use of a Radiation Work Permit for each entry,

d. The External Monitoring System provides a timely and accurate measurement of.occupa-tional exposures at the Station. This system includes the following provisions, o Personnel monitoring devices that meet-Federal and ANSI Standards guidance for use and accuracy.

o A computerized record keeping system that tracks exposures for individuals and jobs and alerts management to exposures approaching pre-determined control levels.

o Administrative exposure control levels

• are established to ensure whole body doses to personnel do not exceed 3-rem / calendar quarter and 5 rem / year.

2. Internal Exposure Control

a. The objective of.the Internal Exposure Control System is to prevent the internal deposition;of radioactive materials within individuals.

b. To meet this objective the following controls and measures'are established:

o A contamination control system that contains and minimizes the amount and spread of

-contamination and airborne radioactivity.

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SAO 301 Rev. O E

o An Airborne Radioactivity Measurement System-that collects and measures airborne radio-activity in a timely and accurate manner.

o A Respiratory Protection Program that meets the requirements of 10CFR20.103 and is effective in preventing radioactive material uptake in radiological work situations.

o A Bioassay Program that verifies the effectiveness of the Respiratory Protection Program ~and Contamination Control System.

Bioassays consist of direct counting methods, such as Whole Body Counts and indirect methods such as fecal and urine analysis.

F. Contamination Control

1. The obj e c tive of contamination cont ol is to minimize the internal deposition of radioactivity and the buildup of radioactivity-in the Radiologically Controlled Areas and prevent the unauthorized release of radioactivity to the

.. environment.

2. Measures shall be taken to minimize the number and extent of contaminated areas to prevent unnecessary personnel radiation exposure to minimize the need for protective clothing and respiratory protection equipeent, and to facilitate subsequent decontamination efforts.

3.

The surface contamination limits for unrestricted release of materials are as follows:

Total (Fixed Smearable and Smearable)

Beta-Gamma 1000 dpm/100 cm 5000 dpm/100 cm 2 Alpha 20 dpm/100 cm 2 200 dpm/100 cm

4. Emphasis shall be placed on minimizing the number *~

of occurrences and concentrations of radioactivity involved in personnel and area contamination incidents. Such occurrences shall be reviewed in detail to identify and correct deficiencies.

G. Radioactive Material Control

1. The radioactive material Control Program has.the following objectives:

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a. Strict control of radioactive material to-minimize exposure.during transit and storage and to prevent loss.

b. Prevention of the unauthorized release o f.

radioactive material to the environment.

c. Minimization of the volume of radioactive waste generated.

d. Minimization of the number of radioactive items and radioactive material storage areas.

2. Radioactive material, in addition ~to the definitions of 10CFR20 and Regulatory Guide 1.86, is equipment, parts, material and waste which have been exposed to radioactive _ contamination or the neutron flux from an operating reactor and exhibits-radioactivity levels greater than the release criteria as specified in the station Radiation Protection Manual.

3. The radioactive material control program includes the following:

a. An inventory and control cystem for licensed quantities of radioactive material.

b. The authorization and control of radioactive material storage areas by the Radwaste Manager.

c. The survey of all material and equipment prior to release from the Radiologically Controlled Area,

d. Written procedures'for the collection, handling, storage and disposition of radioactive materials.

e. Techniques and controls for minimizingfthe introduction of unnecessary materials in.to the Radiologically Controlled Area.

H. Radioactive Waste Control

1. Paramount to the effective control of radioactive material is the concept of minimizing its generation. Individual participation in, and conformance to radioactive waste management procedures _and policies that specify strict Page 15 of 17

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SAO 301 ~ Rev. (f E- *

. controls.to; minimize the volumes of waste materials requiring treatment, handling, temporary storage and controlled disposal is mandatory.

2. The-principal objectives of radioactive waste controls shall be to minimize radiation exposures to workers and the general'public by strictly controlling waste volumes and effluent' releases. The following criteria shall.be the

, basis for these controls:

a. Striving f or zero discharge of processed liquid wastes through effective water management and equipment leakage control,

b. Minimizing dry active waste volume though effective controls on the introduction of unnecessary materials into this waste cycle.

c. Maintaining strict controls on, and verification of radioactive waste accounting, processing, packaging, handling, transporting and controlled disposal activities.

I. Reviews of the Radiation Protection Program-

1. The obj ec tive of reviews of the Radiation Pro-tection Program is to evaluate the effectiveness of program implementation, ensure compliance with station procedures, license requirments and federal regulations and identify deficiencies in the working program.

2. The following reviews are conducted during program implementation:

a. Health Physics-personnel provide direct surveillance of and feedback to radiation workers during conduct of-work within the~-

Radiologically Controlled Area.

b. Health Physics Supervisors review the activities and performance of the Health Physics Technicians,

c. Radiation program-assessments are made by a Radiological Assessor who reports to the Vice President,, Nuclear Power. The Assessor conducts daily reviews of department and contractor radiological work activities ~and-provides monthly written summaries of the review findings. The assessor has the authority and is required to stop work as necessary to ensure a radiologically safe work environment.

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d. Periodically, the service's of an independent *

" (non-Consolidated Edison employee) consultant.

will be utilized to review the program and.

g provide' guidance-in needed program improvements.

3. The following. audits, inspections, or evaluations of the program are conducted throughout the year: -

a. Corporate Quality Assurance Audits.

b. AmericancNuclear Insurers Audits.

c. Institute for Nuclear Power Operations Evaluation.

d. Nuclear Regulatory Commission Inspections and Appraisals.

4. In addition to reviews, audits, and inspections, a system to identify radiological protection deficiencies such as violations of. approved procedures or work practices is established and includes the following provisions:

a. Feedback to the worker and his supervisor to ensure appropriate corrective actions are taken.

b. Tracking of deficienc'ies to identify'tre'nds in conduct of work'within Radiologically Controlled Areas.

3 III. Reports Required None IV. Supercession/ Cancellation This SAO supercedes and cancels SAO-103, Rev. 7 and is

-issued to reflect the Consolidated Edison Management plans and. policies concerning the Radiation Protection Program.

i .V. Attachments A. Attachment 1, " Respiratory Protection Policy" 4

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' ATTACHMENT 1 s

Page 1 of 2-RESPIRATORY PROTECTION POLICY APPLICATION This policyfapplies to all-Consolidated Edison and contractor's employeesLwho require the use'of respiratory protection devices with protection ~ factors applied to prevent-the. inhalation lof radioactive materials while working Power' Station.- This policy does not at the Indian Point Nuclear apply to local or government support agencies, such as fire companies, which provide assistance during casualtyaor accident situations.

POLICY a-  ?

1.0 The use of respirators as a substitute for practica'ble engineering controls in routine operations is inappropriate.

Routine operations presenting respiratory hazards should be identified so that respiratory protection may be accomplished by the use engineering controls such as

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process, containment, or' ventilation equipment or by preplanning of work. The General Manager, EH&S shall recommend to-the Vice President, Nuclear Power, changes to routine operations to reduce. respiratory hazards.

2.0 Non-routine operations requiring respiratory protection shall be identified wherever possible. In-those operations:

where process, containment, or ventilation controls are not reasonably feasible or. effective, the'use of respirators to=

limit the exposure of employees to airborne radioactive materials is appropriate.

3.0 Potential emergency situations involving the use of respiratory. protection shall be identified and protective measures for these situations ~ formulated in the-Station Emergency Plan and implementing procedures.

14.0 Personnel requiring respiratory protection. devices shall be:

respirator qualified which shall include the-following:

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[ ' 4 .' l medical evaluation by a physician to determine the C

individual is physically and psychologically capable of

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performing work involving the use of respiratory

.- protective equipment.

! 4.2 satisfactory completion of training on re s pira t o ry -

hazards'and protective equipment.

'4. 3 satisfactory completion of a respirator fit' test.

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ATTACHMENT 1 Page 2 of 2 5.0 Requalification of respirator users consisting of a medical clearance, respirator fit, and' respirator-retrainitg shall be conducted on an annual basis.

6.0 Special equipment such as corrective lenses or communciation equipment, necessary to perform the work while wearing a respirator shall be available.

7.0 .All_ personnel, except visitors, entering the Radiologically Controlled Area, shall be c?ean shaven. Clean shaven means no stubble, beards, goatees, or mustaches that extend into the seal area or that can interfere with valve function.

8.0 Respirator users shall be provided adequate relief from wearing respirators at reasonable intervale and total time of use shall be kept to a minimum.

9. 0 - the An Internal Dosimetry Program shall.be established to ensure respiratory protection program is protecting against internal exposures to radioactive material.

10.0 The responsiblity and authority for the Respiratory Protection Program shall be assigned to a single individual.

The responsiblity and authority shall be vested in the Radiation Protection Manager.

E Nfze 5't Gener 1 anagef,'EH&S / Date II/to/t4 VP - Npblear Power / Nate e