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PLN-5513 Rev. 2

Radiation Protection Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project

U.S. Army Corps of Engineers Buffalo District, Buffalo, New York

Applicability: Luckey FUSRAP Remediation

Effective Date: 09/19/2016 Owner: Project Manager

Signature

RADIATION PROTECTION PLAN FOR THE LUCKEY FORMERLY UTILIZED SITES REMEDIAL ACTION

PROGRAM REMEDIATION PROJECT

Identifier: Revision: Page:

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History of Revisions

Revision Issue Date Action Description

0 06/08/2016 New document Initial issue.

1 08/02/2016 Revise document Edits and comments from USACE Buffalo District tech editor(s).

2 09/19/2016 Revise document. Comments from the Stakeholder review, resulting in revisions to RPO-106 and RPO-404.




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Table of Contents

OVERVIEW ....................................................................................................................................7

1. PURPOSE ............................................................................................................................12

2. SCOPE .................................................................................................................................12

3. ADMINISTRATION ...........................................................................................................12

3.1 Policy ........................................................................................................................12

3.2 Internal Audits ..........................................................................................................14

3.3 As Low As Reasonably Achievable .........................................................................14

3.4 Design Criteria .........................................................................................................14

3.5 Written Authorizations, Safety Plans, and Operating Procedures ...........................14

4. RADIATION PROTECTION STANDARDS .....................................................................15

4.1 Occupational Dose Limits ........................................................................................15

4.2 Occupationally Exposed Minors ..............................................................................15

4.3 Fetal Exposure Minimization Policy ........................................................................15

4.4 Planned Special Exposures .......................................................................................16

5. POSTING REQUIREMENTS .............................................................................................16

6. INDIVIDUAL EXPOSURE MONITORING ......................................................................17

7. MONITORING THE WORK ENVIRONMENT ................................................................17

7.1 Portable Radiation Detection Instruments ................................................................18

8. ACCESS CONTROLS .........................................................................................................18

8.1 Radiological Areas ...................................................................................................18

8.2 High Radiation Areas ...............................................................................................19




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8.3 Very High Radiation Areas ......................................................................................19

9. TRAINING ...........................................................................................................................19

10. RECORDS ...........................................................................................................................20

11. RESPONSIBILITIES ...........................................................................................................20

11.1 Project Radiation Safety Officer ..............................................................................20

11.2 Project Manager .......................................................................................................20

11.3 Health Physics Technician .......................................................................................20

11.4 Radiological Workers ...............................................................................................21

12. REFERENCES .....................................................................................................................21

APPENDIX A Glossary of Plan and RPO Terms .........................................................................22

Attachments

ATTACHMENT 1 RPO-101, Radiation Protection Program Overview

ATTACHMENT 2 RPO-103, Radiation Protection Audits, Assessments, and Oversight

ATTACHMENT 3 RPO-104, Routine Radiation Protection Surveys and Inspections

ATTACHMENT 4 RPO-106, Training and Qualification

ATTACHMENT 5 RPO-201, Operation of Portable Radiological Survey Instruments

ATTACHMENT 6 RPO-204, Calibration and Quality Control of Portable Radiological Survey Instruments

ATTACHMENT 7 RPO-205, Counting System Operations

ATTACHMENT 8 RPO-208, Operation and Calibration of Portable Air Samplers

ATTACHMENT 9 RPO-209, Operation and Calibration of Lapel Air Samplers

ATTACHMENT 10 RPO-301, Radiological Surveys




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ATTACHMENT 11 RPO-303, Area Air Sampling

ATTACHMENT 12 RPO-401, Radiation Work Permits

ATTACHMENT 13 RPO-402, Radiological Posting and Labeling

ATTACHMENT 14 RPO-403, Access to Radiological Areas

ATTACHMENT 15 RPO-404, Sealed Source Accountability and Leak Checks

ATTACHMENT 16 RPO-405, Respiratory Protection

ATTACHMENT 17 RPO-406, Internal and External Personnel Monitoring

ATTACHMENT 18 RPP Forms

Tables

Table 1. Radionuclides and Concentrations at Luckey Site. .......................................................... 7 Table 2. Air Monitoring Limits. ..................................................................................................... 8 Table 3. Radiological Screening Levels for Clearance. .................................................................. 9 Table 4. Project Occupational Dose Limits. ................................................................................. 11




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ACRONYMS

ALARA as low as reasonably achievable

CFR Code of Federal Regulations

DOE Department of Energy

FUSRAP Formerly Utilized Sites Remedial Action Program

HPT health physics technician

NRC Nuclear Regulatory Commission

PSE planned special exposure

RPO radiation protection operating procedure

RPP radiation protection plan

RSO radiation safety officer

RSSO radiation safety staff officer

RWP radiation work permit

TEDE total effective dose equivalent

USACE U.S. Army Corps of Engineers




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OVERVIEW

This radiation protection plan (RPP) outlines the processes and means to be used in the day-to-day control and management of radioactive materials encountered during the performance of the Luckey Formerly Utilized Sites Remedial Action Program (FUSRAP) Remediation Project. Relevant RPP information and procedures required to begin field activities are provided in or attached to this plan.

Relevant radiation protection operating procedures (RPOs) are included as attachments to this plan and provide the details of how elements within the plan are implemented. Appendix A of the plan is a glossary defining radiation protection terms used in the RPOs.

Planned activities will require the control and management of radioactive materials encountered during site remediation activities. Site-specific radiological controls will be implemented as described by this plan. Radiological controls will be conducted by trained and qualified personnel, with oversight by the radiation safety officer (RSO).

Project control and management of radioactive materials include the following:

Perform specific oversight of radioactive materials encountered during the performance of site activities.

Act as a primary point of contact for site-specific activities involving radioactive materials.

Establish administrative controls to manage radioactive materials.

Table 1 identifies the radionuclides and levels Portage expects to encounter during project activities. These are based on the remedial investigation report (U.S. Army Corps of Engineers [USACE] 2000).

Table 1. Radionuclides and Concentrations at Luckey Site.

Parameter Maximum Value Average Value Background Units

Radium-226 4,000 17.62 2.97 pCi/g

Thorium-230 88.5 4.27 3.2 pCi/g

Uranium-234 52.3 2.9 2.61 pCi/g

Uranium-238 280 6.85 2.63 pCi/g




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During the performance of the work, Portage will use the following action levels to manage potential radiation hazards:

Air monitoring and additional contamination controls for surface disturbance when levels greater than 10,000 dpm/100 cm2 removable contamination are present.

Air monitoring and additional contamination controls for soil disturbance when concentrations greater than 100 pCi/g uranium-238 are present.

Additional contamination controls for surface contamination levels greater than 1,000 dpm/100 cm2 removable (alpha/beta) or 5,000 dpm/100 cm2 total (alpha/beta).

Assessment of direct radiation hazards and controls for dose rates greater than 0.5 mrem per hour.

Radiological air monitoring will be based on the derived air concentration (DAC) for occupational exposures or the effluent limits for perimeter air monitoring. The ALARA limit for the perimeter is 20 percent of the limit values (action level) as shown in Table 2.

Table 2. Air Monitoring Limits.

Radionuclide Location Limit Action Level Units

Radioactivity (DAC) Work area/BZ 6.0E-12 6.0E-12 µCi/mL Radioactivity Perimeter 3.0E-14 6.0E-15 µCi/mL Ra-226 (DAC) Work area/BZ 3.0E-10 3.0E-10 µCi/mL Ra-226 Perimeter 9.0E-13 1.8E-13 µCi/mL Th-230 (DAC) Work area/BZ 6.0E-12 6.0E-12 µCi/mL Th-230 Perimeter 3.0E-14 6.0E-15 µCi/mL U-234 (DAC) Work area/BZ 2.0E-11 2.0E-11 µCi/mL U-234 Perimeter 5.0E-14 1.0E-14 µCi/mL U-238 (DAC) Work area/BZ 2.0E-11 2.0E-11 µCi/mL U-238 Perimeter 6.0E-14 1.2E-14 µCi/mL

As a mixture of radionuclides will most likely be present, the sum of fractions may be applied for perimeter monitoring using the ratio of radionuclides from the area/materials being handled or established concentrations from additional sampling/analysis. In addition, gross alpha/beta air filter analysis may be used for initial assay to demonstrate no significant concerns with air monitoring results. In this case either the most restrictive (Th-230) or an established ratio of radionuclides may be used as the basis.

Radiological limits for acceptable levels of surface contamination (U.S. Army [2015], Table 5-3, “Screening levels for clearance”) are presented in Table 3. As a general practice, Army organizations will not release volumetric-radioactively contaminated materials or items for unrestricted use.




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Table 3. Radiological Screening Levels for Clearance.

Radionuclide Groups1

Screening levels (S.I. Units)2

(Bq/cm2 or Bq/g)3

Surface screening (Conventional

Units)2

(dpm/100 cm2)

Volume screening (Conventional

Units)2

(pCi/g)

Group 1 Radium, Thorium, and Transuranics: Po-210, Pb-210, Ra-226, Ra-228, Th-228, Th-230, Th-232, Np-237, Pu-239, Pu-240, Am-241, Cm-244 and associated decay chains4, and others1

0.1 600 3

Group 2 Uranium and Selected High Dose Beta-Gamma Emitters: Na-22, Mn-54, Co-58, Co-60, Zn-65, Sr-90, Nb-94, Ru-106, Ag-110m, Sb-124, Cs-134, Cs-137, Eu-152, Eu-154, Ir-192, U-234, U-235, U-238, Natural Uranium5, and others1

1 6,000 30

Group 3 General Beta-Gamma Emitters: Na-24, Cl-36, Fe-59, Cd-109, I-131, I-129, Ce-144, Au-198, Pu-241, and others1

10 60,000 300

Group 4 Other Beta-Gamma Emitters: H-3, C-14, P-32, S-35, Ca-45, Cr-51, Fe-55, Ni-63, Sr-89, Tc-99, In-111, I-125, Pm-147, and others1

100 600,000 3,000

1. To determine the specific group for radionuclides not shown, a comparison of the effective dose factors, by exposure pathway, listed in Table A.1 of National Council on Radiation Protection and Measurements (NCRP) Report No. 123 (NCRP 1996) for the radionuclides in question and the radionuclides in the general groups above shall be performed and a determination of the proper group made, based on similarity of the factors.

2. Rounded to one significant figure.

3. The screening levels shown are used for either surface activity concentration (in units of Bq/cm2), or volume activity concentration (in units of Bq/g). These groupings were determined based on similarity of the scenario modeling results, as described in Annex B of ANSI N13.12

4. For decay chains, the screening levels represent the total activity (that is, the activity of the parent plus the activity of all progeny) present.

5. Where the natural uranium activity equals 48.9 percent from U-238, plus 48.9 percent from U-234, plus 2.25 percent from U-235.

Note: Radionuclides were assigned to groups that were protective of 10 µSv/y (1.0 mrem/y) and were limited to four groups for ease of application, as discussed in Annex B of ANSI N13.12.




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Exposures to members of the public are limited in accordance with RPO-101, “Radiation Protection Program Overview,” and will not be monitored using external dosimetry. Dose evaluation for the public will not be specifically performed; however, general area monitoring performed for excavation or other contamination disturbance activities will be evaluated to determine if there is a potential off-site public dose impact. Airborne radiological monitoring will be performed in accordance with RPO-303, “Area Air Sampling.” Air samplers will be operated and calibrated in accordance with RPO-208, “Operation and Calibration of Portable Air Samplers.” If it is determined that air monitoring with lapel air samplers is necessary, operation and calibration of the lapel air samplers will be performed in accordance with RPO-209, “Operation and Calibration of Lapel Air Samplers.”

During the performance of the Luckey work, the project management team will implement a modified occupational dose limit approach. This is to ensure the project will comply with EM 385-1-80, Radiation Protection (USACE 2013). Portage does not anticipate that conditions and remediation activities at the Luckey Site will result in significant personal radiation doses. Therefore, workers’ exposure levels will be maintained at a maximum annual level of 0.1 rem total effective dose equivalent (TEDE), equivalent to the USACE Tier 3 suggested as low As reasonably achievable (ALARA) limits listed in EM 385-1-80. However, training will be performed commensurate with the radiation hazard present at the site to allow exposures equivalent to the USACE Tier 2 annual limit of 0.5 rem TEDE. If Portage encounters unexpected conditions and a potential to exceed 0.5 rem TEDE exists, workers will undergo additional training commensurate with the radiation hazards at the site, to allow exposures equivalent to the USACE Tier 1 annual limit of 5.0 rem TEDE, with the approval of the USACE radiation safety staff officer (RSSO).

The project dose limits are listed in Table 4.

In accordance with the underlying philosophy of ALARA, there should be no contact with radioactive material or exposure to ionizing radiation unless there is an expected benefit to be realized (e.g., remediation of environmental sites to make them safe for general public use). All contact with radioactive materials and exposures to ionizing radiation will be maintained ALARA and consistent with technology, cost, and operational requirements. If necessary, Portage will post and label radiologically controlled areas, equipment, and material in accordance with RPO-402, “Radiological Posting and Labeling.” This procedure also identifies the requirements for documenting and inspecting these posted areas.




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Table 4. Project Occupational Dose Limits.1

Body part Annual limits with

RSSO approval (Tier 1)

Annual limits without RSSO

approval (Tier 2)

Suggested ALARA limits

(Tier 3)

Whole body 50 mSv (5 rem) 5 mSv (0.5 rem) 1 mSv (0.1 rem)2 Individual organ 500 mSv (50 rem) 50 mSv (5 rem) 5 mSv (0.5 rem)

Lens of eye 150 mSv (15 rem) 15 mSv (1.5 rem) 1.5 mSv (0.15 rem) Skin or extremity 500 mSv (50 rem) 50 mSv (5 rem) 5 mSv (0.5 rem)

1. Occupational limits are equal to those listed in EM 385-1-80, Table 4-1, Occupational Dose Limits. 2. Equal to exposure limit for a member of the public.

Luckey project managers, supervisors, contractors, and other individuals who work in radiologically controlled areas will adhere to the training and qualification requirements specified in RPO-106, “Training and Qualification.” In some cases – such as with support zone work and short-duration, specialized contractor work – Portage will provide radiation awareness training commensurate with the radiation hazard present. The RSO will determine the substitution of awareness training for more site-specific training on a case-by-case basis.

Portage will conduct radiological surveys and field measurements according to RPO-301, “Radiological Surveys.” Field instruments will be operated in accordance with RPO-201, “Operation of Portable Radiological Survey Instruments.” Field instruments will be in good working condition and in calibration in accordance with RPO-204, “Calibration and Quality Control of Portable Radiological Survey Instruments.”

Smears/wipes samples analyzed at the on-site laboratory will be counted using instrumentation in good working condition, within calibration, and in accordance with RPO-205, “Counting System Operations.” Soil/volumetric material samples analyzed at the on-site laboratory will be measured using instrumentation in good working condition and within calibration.

According to RPO-401, “Radiation Work Permits,” if radiological work activities have the potential for personnel exposure and/or the spread of radioactive contamination to personnel, the site, or the environment, a radiation work permit (RWP) is required. These RWPs will be prepared, distributed, used, administered, revised, and terminated in accordance with RPO-401. Materials generated during this remediation project classified as “radioactive waste” will be handled, containerized, moved, and labeled in accordance with the Waste Management, Transportation, and Disposal Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project (USACE 2016).




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1. PURPOSE

This RPP establishes guidelines and standards for protection against ionizing radiation when developing work site or job-specific radiation protection manuals or procedures for contract activities conducted for the Department of Energy (DOE), Department of Defense/USACE, under a Nuclear Regulatory Commission (NRC) license or an agreement state. It is intended to control the receipt, possession, use, transfer, and disposal of radioactive material in such a manner that the total dose to an individual is maintained ALARA and does not exceed the standards for protection against radiation prescribed by applicable regulations.

2. SCOPE

This RPP applies to all Luckey Site personnel whose work involves handling or exposure to radioactive materials or who enter control or exclusion zones. While Portage conducts the project with USACE oversight under FUSRAP, and no radioactive material license is required, the RPOs for this plan will be based on those typically used for licensed radioactive materials work.

No one may act (or cause others to act) in a manner inconsistent with this RPP. However, nothing in this RPP shall be construed as limiting actions that may be necessary to protect health and safety.

The limits in this RPP do not apply to doses caused by:

Background radiation.

Exposure to radiation for medical diagnosis or therapy.

Exposure from individuals medically administered radioactive material and released in accordance with 10 CFR 35.75.

Exposure from voluntary participation in medical research programs.

Consumer products emitting nominal amounts of radiation.

Activities conducted under the Nuclear Explosives and Weapons Surety Program (relating to the prevention of accidental or unauthorized nuclear detonations).

3. ADMINISTRATION

3.1 Policy

Portage’s policy is to conduct its radiological operations in a manner that ensures the health and safety of all its employees, contractors, and the general public. To meet this objective, Luckey project managers shall ensure that radiation exposures to Portage’s workers and the general




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public and releases of radioactivity to the environment stay below regulatory limits. Portage will act deliberately to further reduce exposures and releases ALARA. Project management is fully committed to implementing a radiation protection program of the highest quality that consistently reflects this policy. Portage shall:

Establish and implement the radiation protection program, which includes plans and procedures reflective of federal and/or state radiation protection standards and recommendations.

Ensure that personnel who perform radiological work activities are appropriately trained. Portage shall establish standards to ensure the technical competency of its workforce through implementation of radiological training and professional development programs.

Ensure the technical competence of personnel who implement and oversee the radiation protection program. Portage shall establish qualification requirements for technical and professional radiation protection program positions. Portage shall also, at a minimum, be consistent with applicable industry standards and promote professional development and excellence in radiological performance goals.

Establish and maintain, at all levels, management involvement and accountability for radiological performance. The responsibility for compliance with radiological protection requirements and for minimizing personnel radiation exposure, starts at the worker level and broadens as it progresses upward through the line organization. Managers are fully responsible for radiological performance within their programs and the field activities and sites assigned to them. They shall take necessary actions to ensure that requirements are implemented and performance is monitored and corrected as necessary.

Ensure that radiological measurements, analyses, worker monitoring results, and estimates of public exposures are accurate and appropriately made.

Conduct radiological operations in a manner that controls the spread of radioactive materials and reduces exposure to the workforce and the general public, and uses a process that seeks exposure levels that are ALARA.

Incorporate dose reduction, contamination reduction, and waste minimization features into the design and significant modification of facilities in the earliest planning stages. Wherever possible, facility design features shall be directed toward controlling contamination at the source, eliminating airborne radioactivity, maintaining personnel exposure and effluent releases below regulatory limits, and using a process that seeks exposure levels and releases that are ALARA. Radiological design criteria shall reflect appropriate consensus recommendations of national and international standards setting groups.




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Conduct oversight to ensure that all requirements are being complied with, and appropriate radiological work practices are being implemented. All radiological operations shall be conducted in a manner consistent with the above policies and objectives.

3.2 Internal Audits

Internal audits of the radiation protection program to identify its strengths and weaknesses, areas of vulnerability, and noncompliance shall be conducted periodically – at least annually for this project. The audits shall include examination of the program’s content and implementation.

3.3 As Low As Reasonably Achievable

The ALARA philosophy is based on the supposition that radiation doses increase one’s risk of cancer – the smaller the dose, the smaller the risk. The ALARA concept is an approach to radiation protection to manage and control individual and collective doses to employees, visitors, the public, and the environment to levels that are as low as reasonable, taking into account social, technical, economic, practical, and public policy considerations. With ALARA, there are no dose limits, but there is a process for maintaining doses as far below the applicable limits as is reasonably achievable. Portage will use, to the extent practical, procedures and engineering controls based on sound radiation protection principles to limit occupational doses and doses to members of the public to ALARA levels. Portage’s ALARA program contains formal plans and measures for applying the ALARA process to occupational radiation exposure.

3.4 Design Criteria

During routine operations, Portage shall implement a combination of physical design features and administrative controls to ensure that any anticipated occupational dose does not exceed allowable dose limits.

3.5 Written Authorizations, Safety Plans, and Operating Procedures

Portage shall develop and implement written plans and procedures as necessary to ensure compliance with this RPP. These plans and procedures shall be commensurate with the radiological hazards created by project activity and consistent with the education, training, and skills of the individuals exposed to those hazards. Such written plans and procedures are generally written to apply to one site or activity.




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4. RADIATION PROTECTION STANDARDS

4.1 Occupational Dose Limits

Table 2 in the Overview provides the dose limits to be used for the Luckey project. The following provisions amplify the specifications for the limits in Table 2:

Doses received in excess of the annual limits, including doses received during accidents, emergencies, and planned special exposures, must be subtracted from the limits for planned special exposures that the individual may receive during the current year and during the individual’s lifetime.

The assigned deep dose equivalent and shallow dose equivalent must be for the part of the body receiving the highest exposure. The deep dose equivalent, lens dose equivalent, and shallow dose equivalent may be assessed from surveys or other radiation measurements to show compliance with the occupational dose limits, if the individual monitoring device was not in the region of highest potential exposure, or the results of individual monitoring are unavailable.

In addition to the annual dose limits and in consideration of chemical toxicity, soluble uranium intake by an individual shall be limited to 10 milligrams in a week.

The allowable occupational exposure to an individual in the current year shall be reduced by the amount of occupational exposure received while employed by any other company or organization.

4.2 Occupationally Exposed Minors

Portage does not expect to employ minors on the Luckey project. If a minor is employed, however, the RSO will evaluate the work and radiological conditions for the assigned work and determine what restrictions, if any, need to be applied.

4.3 Fetal Exposure Minimization Policy

All women working in an environment where exposure to radiation or radioactive materials is possible or occurring shall be provided with the following:

Pregnancy-related information, such as in NRC Regulatory Guide 8.13, Instruction Concerning Prenatal Radiation Exposure (NRC 1999).

An interview with the RSO to discuss the ramifications of exposure to the embryo/fetus and determine the potential for occupational exposure to workplace hazards in their current assignment.




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Information on how to voluntarily declare a pregnancy in writing and limit radiation exposure to 0.5 rem during the gestational period, and an evaluation of their current work assignment.

Supervisors of women workers will also be provided with the above information.

All women who will be occupationally exposed shall sign a Fetal Exposure Minimization Policy Training Acknowledgement Form, or equivalent, that acknowledges they have received information concerning exposure to the embryo/fetus and the process for declaring a pregnancy.

4.4 Planned Special Exposures

The expected levels of radioactivity and radiation are insufficient to create a task or situation where planned special exposures will be needed.

5. POSTING REQUIREMENTS

In accordance with approved procedures, only personnel qualified in radiation protection shall conduct or direct posting, de-posting, or altering of signs containing the radiation trefoil symbol.

Applicable implementing procedures contain approved radiological signs and labels as well as guidance for when and where they should be posted.

All radiological postings shall be in accordance with 10 CFR 20, applicable state regulations, or specific license conditions.

When posting access points to an area, the following apply:

All access doors that can be opened from the outside must be posted, even if the door remains locked. (This posting protects individuals such as security guards, firefighters, and other emergency responders who may enter the area using master keys.) Individuals who allow others to access an area through such doors must ensure that those entering the area abide by the access control requirements.

Doors that cannot be opened from the outside (e.g., high-bay rollup doors or emergency exits) are considered access points only if they are left open and unattended.

Side-by-side doors do not have to be individually posted if it is obvious that both doors provide access to the same area and an appropriate sign is clearly and conspicuously posted.




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Posting requirements may be waived for periods of less than eight continuous hours when the area is placed under the continuous observation and control of an individual knowledgeable of and empowered to implement required access and exposure control measures.

6. INDIVIDUAL EXPOSURE MONITORING

Because the radiation dose rates and exposure durations are expected to be low, the total external dose will be well below 5 mSv (0.5 rem). This is the prescribed regulatory limit for personal monitoring. Consequently, no individual external dose monitoring, such as thermoluminescent dosimeter use, will be required. Air samples will be collected to assess potential internal exposures.

Portage shall maintain dose records for all individuals for whom monitoring is required. Where an individual may exceed 5 mSv (0.5 rem) in a calendar year, documentation of previous occupational doses will be obtained and recorded on an NRC Form 4 or equivalent. If an individual’s records are estimates or incomplete, the RSO shall make reasonable efforts (at least two written attempts) to obtain complete records of each individual’s prior years’ occupational dose. If complete records cannot be obtained, a written estimate signed by the individual may be accepted to demonstrate compliance with Portage’s radiation protection procedures.

Dosimetry records, including detailed information identified with a specific individual, shall be readily available to that individual and to others on a need-to-know basis (e.g., the individual’s supervisor, management, and safety personnel). Individuals can request their dosimetry records from the RSO.

Upon request, the RSO shall provide dose records to an individual terminating employment as soon as the data are available, but not later than 90 days after termination. If requested, a written estimate of the radiation dose received by that employee (based on available information) shall be provided at the time of termination.

7. MONITORING THE WORK ENVIRONMENT

Monitoring of work areas will:

Demonstrate compliance with federal and/or state regulations.

Document radiological conditions.

Detect changes in radiological conditions.

Detect the gradual buildup of radioactive material.




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Verify the effectiveness of engineered and administrative controls for containing radioactive materials and reducing radiation exposure.

Identify and control potential sources of individual exposure to radiation and radioactive materials.

Monitoring shall be done in accordance with written procedures.

7.1 Portable Radiation Detection Instruments

Instruments and equipment used for radiological monitoring shall be:

Periodically maintained and calibrated on an established frequency (typically, annually).

Appropriate for the types, levels, and energies of the radiation.

Appropriate for existing environmental conditions.

Routinely tested for operability.

8. ACCESS CONTROLS

Access controls to areas where radiological hazards exist include training (see Section 9) and the controls listed in Sections 8.1, 8.2, and 8.3.

8.1 Radiological Areas

Portage shall maintain personnel entry control for each radiological controlled area and radiological area. The degree of control shall be commensurate with existing and potential radiological hazards in the area. Portage shall use one or more of the following control methods:

Signs and barricades.

Control devices on entrances.

Conspicuous visual and/or audible alarms.

Locked entrance ways.

Administrative controls.

Controls that would prevent rapid evacuation of personnel under emergency conditions shall not be installed at any radiological area exit.




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8.2 High Radiation Areas

There is no likelihood that high radiation areas, as defined in 10 CFR 20, are present at the Luckey Site. Consequently, this document does not address controls for high radiation areas.

8.3 Very High Radiation Areas

There is no likelihood that very high radiation areas, as defined in 10 CFR 20, are present at the Luckey Site. Consequently, this document does not address controls for very high radiation areas.

9. TRAINING

Portage shall conduct radiological training in accordance with written procedures applicable to the project, location, or level of hazard. Each individual shall complete radiation safety training commensurate with the hazards in the area and required controls before:

Being permitted unescorted access to radiologically controlled areas.

Receiving occupational dose during access to radiologically controlled areas.

Furthermore, Portage will provide radiation safety refresher training to individuals:

At intervals not to exceed 12 months.

When there is a significant change to radiation protection policies and procedures that may affect the individual.

Depending on an individual’s prior training, work assignments, and degree of exposure to potential radiological hazards, radiation safety training should include the following topics:

Risk of exposure to radiation and radioactive materials, including prenatal radiation exposure.

Basic radiation fundamentals and radiation protection concepts.

Controls for both routine and emergency actions implemented at the local level to manage and maintain doses ALARA (e.g., physical design features, administrative controls, limits, policies, procedures, alarms, and other measures).

The individual’s rights and responsibilities for implementing the radiation protection program.

The individual’s responsibilities for implementing ALARA measures.




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Reports the individual may request.

If an escort is used in lieu of training, the escort shall have completed the training required for unescorted access to the area and must ensure that all escorted individuals comply with the safety requirements of this document and its attachments.

Portage shall maintain records to demonstrate its compliance with these training requirements.

10. RECORDS

Portage shall retain records generated as a result of this RPP until the applicable regulation authorizes their disposition.

11. RESPONSIBILITIES

Project responsibilities have been established to ensure effective implementation of the RPP. This section designates individual and organization responsibilities for radiation protection.

11.1 Project Radiation Safety Officer

The RSO is responsible for developing, maintaining, overseeing, and implementing the radiation protection program at the Luckey Site.

11.2 Project Manager

The Luckey project manager is responsible for providing logistical and policy support to ensure compliance with this RPP during task execution. To meet this requirement, management shall ensure that appropriate authority, commitment, support, and resources are assigned to all levels of the organization to implement the radiation protection program and achieve its goals.

11.3 Health Physics Technician

The health physics technician assists project, facility, and service workers with implementing the compliance requirements specified in this document and related implementing procedures; fulfills the posting and monitoring requirements of federal regulations; informs workers and supervisors of actions or operations inconsistent with procedures or best management practices; and responds to radiological alarms, spills, accidents, and emergencies.




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11.4 Radiological Workers

Radiological workers shall comply with all written radiation protection program and procedure requirements, minimize personal radiation exposure, and minimize the spread of radioactive contamination by adhering to all radiological safety requirements, reporting any radiological problems, and following established work practices.

12. REFERENCES

10 CFR 20, “Standards for Protection against Radiation,” Code of Federal Regulations, U.S. Nuclear Regulatory Commission.

10 CFR 35.75, “Release of Individuals Containing Unsealed Byproduct Material or Implants Containing Byproduct Material,” Code of Federal Regulations, U.S. Nuclear Regulatory Commission.

10 CFR 835, “Occupational Radiation Protection, Final Rule,” Code of Federal Regulations, U.S. Department of Energy.

NRC, 1999, Instruction Concerning Prenatal Radiation Exposure, NRC Regulatory Guide 8.13, U.S. Nuclear Regulatory Commission, Revision 3, June 1999.

USACE, 2016, Waste Management, Transportation, and Disposal Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5507, U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York.

USACE, 2000, Luckey Site, Luckey, Ohio, Final Remedial Investigation Report, Luckey Site, prepared for U.S. Army Corps of Engineers, Buffalo District, prepared by Science Applications International Corporation, Dublin, Ohio, September 2000.

U.S. Army, 2015, The Army Radiation Safety Program, Pamphlet DA PAM 385-24, U.S. Army, November 30, 2015.




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APPENDIX A Glossary of Plan and RPO Terms

The terms and definitions provided in this appendix are specific to their use in this document and the related RPOs.

As low as reasonably achievable (ALARA)

An approach to radiation protection to manage and control individual and collective dose to the work force and to the general public to as low as is reasonable, taking into account the state of technology; the economics of improvements in relation to state of technology; the economics of improvements in relation to benefits to the public health, safety, and other societal and socioeconomic considerations; and in relation to using nuclear energy and licensed materials in the public interest. An ALARA is not a dose limit but a process with the objective of attaining doses as far below the applicable limits as reasonably achievable.

Background radiation Radiation from: Naturally occurring radioactive materials that have not been

technologically enhanced. Cosmic sources. Global fallout as it exists in the environment (such as from the

testing of nuclear explosive devices). Radon and its progeny in concentrations or levels existing in

buildings or the environment that have not been elevated as a result of current or prior activities.

Consumer products containing nominal amounts of radioactive material or producing nominal amounts of radiation.

Calibrate To adjust or determine either: The response or reading of an instrument relative to a standard

(e.g., primary, secondary, or tertiary) or to a series of conventionally true values.

The strength of a radiation source relative to a standard (e.g., primary, secondary, or tertiary) or conventionally true value.

Committed dose equivalent (HT,50)

The dose equivalent calculated to be received by a tissue or organ over a 50-year period after intake of a radionuclide into the body. It does not include contributions from radiation sources external to the body. Committed dose equivalent is expressed in units of rem.




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Committed effective dose equivalent (CEDE)

The sum of the committed dose equivalent to various tissues in the body (HT,50), each multiplied by the appropriate weighting factor (wT) – that is, HE,50 = wTHT,50. The CEDE is expressed in units of rem.

Contamination Area Any area accessible to individuals where removable surface contamination levels exceed or are likely to exceed the removable surface contamination values specified in the site or project’s implementing procedures.

Controlled area Any area where access is managed to protect individuals from exposure to radiation or radioactive material.

Declared pregnant worker

A woman who has voluntarily informed the licensee in writing of her pregnancy and the estimated date of conception. The declaration remains in effect until the declared pregnant woman withdraws the declaration in writing or is no longer pregnant.

Deep dose equivalent The dose equivalent derived from external radiation at a depth of 1 cm in tissue.

Dose A general term for absorbed dose, dose equivalent, effective dose equivalent, committed dose equivalent, committed effective dose equivalent, or total effective dose equivalent.

Dose equivalent (H) The product of absorbed dose (D) in rad in tissue, a quality factor (Q), and other modifying factors (N). Dose equivalent is expressed in units of rem.

Effective dose equivalent (HE)

The summation of the products of the dose equivalent received by specified tissues of the body (HT) and the appropriate weighting factor (wT) – that is, HE = wTHT. It includes the dose from radiation sources internal and external to the body. For purposes of compliance with the CFR, deep dose equivalent to the whole body may be used as effective dose equivalent for external exposures. The effective dose equivalent is expressed in units of rem.

External dose or exposure That portion of the dose equivalent received from radiation sources outside the body (i.e., external sources).

Extremity Hands and arms (below the elbow) or feet and legs (below the knee).

High Radiation Area Any area, accessible to individuals, where radiation levels from radiation sources external to the body could result in an individual receiving a deep dose equivalent in excess of 0.1 rem in one hour at 30 cm from the radiation source or from any surface that the radiation penetrates.




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Internal dose or exposure That portion of the dose equivalent received from radioactive material taken into the body (i.e., internal sources).

Member of the public An individual who is not a general employee. An individual is not a member of the public during any period in which he/she receives an occupational dose.

Minor An individual younger than 18 years of age. Monitoring The measurement of radiation levels, concentrations, surface area

concentrations, or quantities of radioactive material and the use of the results of these measurements to evaluate potential exposures and doses.

Occupational dose The dose received by an individual in the course of employment in which the individual's assigned duties involve exposure to radiation or to radioactive material from licensed and unlicensed sources of radiation, whether in the possession of the licensee or other person. Occupational dose does not include doses received from background radiation, from any medical administration the individual has received, from exposure to individuals administered radioactive material and released, from voluntary participation in medical research programs, or as a member of the public.

Radiation Ionizing radiation: alpha particles, beta particles, gamma rays, X-rays, neutrons, high-speed electrons, high-speed protons, and other particles capable of producing ions. Radiation, as used here, does not include nonionizing radiation (e.g., radiowaves, microwaves, or visible, infrared, or ultraviolet light).

Radiation Area Any area, accessible to individuals, where radiation levels could result in an individual receiving a dose equivalent in excess of 0.005 rem (5 mrem) in one hour at 30 centimeters from the source or from any surface that the radiation penetrates.

Radioactive material transportation

The movement of radioactive material by aircraft, rail, vessel, or highway vehicle that is governed by DOT regulations or DOE orders. Radioactive material transportation does not include preparation or packaging of material for transportation, monitoring required by the CCR, storage of material awaiting transportation, or application of markings and labels required for transportation.

Radiological Area Any area within a controlled area defined as a Radiation Area, High Radiation Area, Very High Radiation Area, Contamination Area, High Contamination Area, or Airborne Radioactivity Area.




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Radiological worker A general employee whose job assignment involves working with radioactive materials, or who is likely to receive a total effective dose equivalent above 0.1 rem per year from routine occupational exposures.

Shallow dose equivalent The dose equivalent deriving from external radiation at a depth of 0.007 cm in tissue.

Total effective dose equivalent

The sum of the effective dose equivalent (for external exposures) and the committed effective dose equivalent (for internal exposures).

Very High Radiation Area

Any area accessible to individuals, in which radiation levels from radiation sources external to the body could result in an individual receiving an absorbed dose in excess of 500 rads in one hour at 1 meter from a radiation source or 1 meter from any surface that the radiation penetrates.

Weighting factor (wT) For an organ or tissue (T), the proportion of the risk of stochastic effects resulting from irradiation of that organ or tissue to the total risk of stochastic effects when the whole body is irradiated uniformly. Weighting factors are provided in applicable regulations.

Whole body For the purposes of external exposure, any exposure to the head, trunk (including male gonads), arms (above and including the elbow), or legs (above and including the knee).

ATTACHMENT 1 RPO-101, Radiation Protection Program Overview

RPO-101 Rev. 0

Radiation Protection Program Overview for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project




Signatur

RADIATION PROTECTION PROGRAM OVERVIEW FOR THE LUCKEY FORMERLY UTILIZED SITES

REMEDIAL ACTION PROGRAM REMEDIATION PROJECT


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Revision Issue Date Action Description 0 06/08/16 New document Initial issue.




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Table of Contents

1. PURPOSE ..............................................................................................................................5

2. APPLICABILITY ..................................................................................................................5

3. RESPONSIBILITIES/PREREQUISITES .............................................................................5

3.1 Responsibilities ..........................................................................................................5

3.2 Prerequisites ...............................................................................................................5

4. GENERAL .............................................................................................................................5

4.1 Equipment ..................................................................................................................5

4.2 Safety Considerations .................................................................................................6

4.3 Precautions and Limitations .......................................................................................6

4.4 Revisions ....................................................................................................................6

5. DEFINITIONS .......................................................................................................................6

6. PROCEDURE ........................................................................................................................6

6.1 Introduction ................................................................................................................6

6.2 Organization and Administration ...............................................................................7

6.3 Radiation Protection Procedures ................................................................................8

6.4 Licensed Material and Accountability .......................................................................9

6.5 Audits .........................................................................................................................9

6.6 Training ....................................................................................................................10

6.7 Exposure Control and Monitoring ............................................................................11

6.8 Radiation Monitoring Instrumentation .....................................................................13




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6.9 Access Controls and Radiological Postings .............................................................14

6.10 Waste Management ..................................................................................................15

7. QUALITY ASSURANCE ...................................................................................................15

8. RECORDS ...........................................................................................................................15

9. REFERENCES .....................................................................................................................16

10. APPENDIXES .....................................................................................................................16

Tables

Table 1. Annual dose limits. ......................................................................................................... 12




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1. PURPOSE

This procedure provides an overview of the Portage Radiation Protection Program that governs radiological work performed by Portage personnel at the Luckey Formerly Utilized Sites Remedial Action Program (FUSRAP) Remediation Project.

2. APPLICABILITY

This procedure applies to Portage management, supervisors, individuals, contractors, and subsidiary employees who handle radioactive materials or may be exposed to ionizing radiation, where their work assignment is controlled by Portage.

The limits in this procedure do not apply to exposure/dose caused by the following:

• Background radiation • Exposure of patients to radiation for the purpose of medical diagnosis or therapy • Exposure from individuals administered radioactive material and released in

accordance with 10 CFR 35.75 • Exposure from voluntary participation in medical research programs • Consumer products emitting nominal amounts of radiation • Activities conducted under the Nuclear Explosives and Weapons Surety Program

(relating to the prevention of accidental or unauthorized nuclear detonations).

3. RESPONSIBILITIES/PREREQUISITES

3.1 Responsibilities

Performer Responsibilities

Radiation safety officer or designee

Responsible for the implementation of this procedure.

3.2 Prerequisites

Not applicable.

4. GENERAL

4.1 Equipment

Not applicable.




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4.2 Safety Considerations

No one may act (or cause others to act) in a manner inconsistent with this procedure. However, nothing in this procedure shall be construed as limiting actions that may be necessary to protect health and safety.

4.3 Precautions and Limitations

Not applicable.

4.4 Revisions

This procedure shall be reviewed at least every 2 years, with documentation to support the completion of such review.

5. DEFINITIONS

See Radiation Protection Plan Glossary.

6. PROCEDURE

6.1 Introduction

6.1.1 It is the policy of Portage to conduct its radiological operations in a manner that ensures the health and safety of its employees, contractors, and the general public and protects the environment and facilities from the effects of ionizing radiation.

6.1.2 Through the use of Portage policies, procedures, and a knowledgeable and experienced workforce, radiation exposures to workers and to the general public and releases of radioactivity to the environment will be maintained below regulatory limits and as low as reasonably achievable (ALARA).

• The ALARA philosophy is based on the supposition that radiation dose increases one’s risk of cancer—the smaller the dose, the smaller the risk.

• ALARA is an approach to radiation protection to manage and control individual and collective dose to employees, visitors, the public, and the environment to levels that are as low as reasonable, taking into account social, technical, economic, practical, and public-policy considerations.

• ALARA is not a dose limit, but a process for maintaining doses as far below the applicable limits as is reasonably achievable.




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• Portage will use, to the extent practical, procedures and engineering controls based upon sound radiation protection principles to limit occupational doses and doses to members of the public to ALARA levels and ensure that no exposure to workers will occur without the expectation of an overall benefit from the activity.

6.1.3 Portage’s Luckey project radiation protection operating procedures (RPOs) are an integral part of radiological work activities performed. Project radiological operations shall be conducted in a manner consistent with the RPOs.

6.1.4 Portage shall prominently post copies of the following documents where licensed material is received, possessed, used, or transferred:

• The regulations of 10 CFR Parts 19 and 20 • The license, license conditions, or documents incorporated into a license by

reference, and amendments thereto • The operating procedures applicable to licensed activities • Any notice of violation involving radiological working conditions, proposed

imposition of civil penalty, or order issued • The latest versions of NRC Form 3, “Notice to Employees.”

6.1.5 If posting of a document specified above is not practicable, a notice shall be posted that describes the document and states where it may be examined.

6.2 Organization and Administration

6.2.1 Corporate Radiation Safety Officer (CRSO) – Responsible for the overall content and implementation of this RPP at company-controlled sites and projects where Portage is the licensee or where Portage is charged by contract with implementation of a radiation protection program. The CRSO provides direction and guidance on the development and implementation of site- or project-specific radiation protection procedures and programs. The CRSO also:

• Interprets federal regulations and DOE Orders. • Obtains and allocates resources to the RPP projects. • Coordinates RPP projects to minimize overlap and maximize cost

effectiveness. • Delegates the day-to-day operations of RPP projects to qualified individuals.




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• Assigns appropriate authority, commitment, support, and resources to all levels of the organization to implement the program and to achieve desired goals.

6.2.2 Site radiation safety officer (SRSO) – Responsible for aspects of the day-to-day radiological operations and activities conducted at the site, including the implementation of the RPOs, as direct by the CRSO.

6.2.3 Certified health physicist (CHP) – Evaluates radiological operations; ensures that safety plans describe the magnitude of radiological hazards, the physical and administrative controls required for maintaining personnel doses, effluent discharges, and contamination levels ALARA; responds to radiological spills, accidents, and emergencies; provides radiological safety oversight; provides technical support to program and facility organizations that is consistent with the ALARA process; identifies area monitoring requirements; and conducts workplace evaluations for minors and workers with pregnancy-related medical restrictions.

6.2.4 Health physics technician – Assists program, facility, and service workers with implementing the compliance requirements specified in the RPOs, fulfills the posting and monitoring requirements of federal regulations, informs workers and supervisors of actions or operations that are inconsistent with procedures or best management practices, and responds to radiological alarms, spills, accidents, and emergencies.

6.2.5 Work supervisor or responsible individual – Ensures that requirements and controls specified in the Radiation Protection Program and its associated procedures, along with any additional requirements identified by ES&H, are integrated into radiological operations; that workers follow established safety plans and procedures; and that workers are provided appropriate tools and protective equipment.

6.2.6 Radiological worker – Performs day-to-day routine radiological work while minimizing personal radiation exposure and the spread of radioactive contamination. This is accomplished by adhering to radiological safety requirements, reporting any radiological problems, and following established work policies and good work practices.

6.3 Radiation Protection Procedures

6.3.1 Activities involving licensed materials shall be conducted in accordance with




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approved, written RPOs and/or radiation work permits (RWPs).

6.3.2 RPOs shall be developed and implemented as necessary to ensure compliance with this RPO.

• These procedures shall be commensurate with the radiological hazards present at the site and consistent with the education, training, and skills of the individuals exposed to those hazards.

6.3.3 Changes, deletions, or additions to RPOs shall be accomplished under the cognizance of, and with the approval of, the CRSO and SRSO.

6.3.4 RPOs shall be reviewed and re-approved, at a minimum, biennially.

6.4 Licensed Material and Accountability

6.4.1 Inventory control and accountability is accomplished by documenting receipts and transfers of licensed material in accordance with approved procedures.

• Inventory balances are maintained to ensure that possession limits are not exceeded.

• Purchases of licensed calibration standards shall be from licensed vendors only.

6.4.2 A physical inventory of sources and/or devices possessed under the license shall be performed every six months and in accordance with applicable RPO procedures.

6.5 Audits

6.5.1 Audits, inspections, and/or assessments shall be performed to determine if radiological operations are being conducted in accordance with applicable license conditions, regulatory requirements and applicable RPO procedures.

6.5.2 Internal audits of the Radiation Protection Program shall be conducted to identify its strengths and weaknesses, areas of vulnerability, and noncompliance.

6.5.3 Internal audits shall be conducted on every major program element no less frequently than every 36 months and shall include examination of the Radiation Protection Program content and implementation.




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6.5.4 Program management shall participate in the project's internal audits.

6.5.5 Records shall be maintained to document the results of internal audits and other reviews of the Radiation Protection Program content and implementation.

6.6 Training

6.6.1 Each individual shall complete radiation safety training, commensurate with the hazards in the area and the required controls.

6.6.2 Radiation safety training requirements are described in detail in RPO-106 and in other project procedures.

6.6.3 If an escort is used in lieu of training, the escort shall have completed the training required for unescorted access to the area and must ensure that escorted individuals comply with safety requirements.

6.6.4 Records shall be maintained to demonstrate compliance with training requirements. Documentation of courses, course materials, and attendance is contained in the Portage Training and Records and Information Network.

6.6.5 Institutionally Required Training

• Programs or facilities may require additional radiological training for access or work in specific facilities.

• The definitive list of institutionally required courses and their alternates is controlled and maintained by the SRSO.

• Except where otherwise stated, retraining is required every 24 months.

6.6.6 General Employee Radiological Training

• Portage employees and subcontractors who have access to radiological controlled areas at the site shall complete General Employee Radiological Training.

6.6.7 Radiological Worker Training

• Radiological Worker Training is required before performing independent work as a radiological worker and before being permitted unescorted access to Radiological Areas.




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6.6.8 Site-Specific Required Training

• Additional training (i.e., training beyond that which is provided institutionally) is required where individual ALARA goals are established, area radiation alarms are installed, or safety plans are used to control radiological operations.

• The Responsible Individual shall ensure that site-specific training requirements are identified, workers requiring site-specific training are identified, and that required training is completed and documented as such.

6.7 Exposure Control and Monitoring

6.7.1 Portage employees and subcontractors who are likely to receive a dose of 100 mrem in one year and/or enter a posted radiation, high radiation, or very high radiation area are required to wear a whole-body dosimeter.

6.7.2 Portage shall maintain dose records for individuals for whom monitoring is required.

6.7.3 Documentation of previous occupational doses received shall be documented on an NRC Form 4 or equivalent.

6.7.4 Dosimetry records, including detailed information, identified with a specific individual shall be readily available to that individual and to others on a need-to-know basis.

6.7.5 Upon request, Portage shall provide dose records to an individual terminating employment as soon as the data are available, but not later than 90 days after termination.

6.7.6 Air sampling, bioassay sampling, and/or approved dose calculations shall be used to assess and monitor workers’ internal dose.

6.7.7 The total effective dose equivalent shall be calculated in accordance with 10 CFR 20 using a combination of personal lapel air sampling data and/or bioassay measurement data, and personnel external monitoring measurements.

• The assigned deep-dose equivalent and shallow-dose equivalent must be for the part of the body receiving the highest exposure. The deep-dose equivalent, lens dose equivalent, and shallow-dose equivalent may be assessed from surveys or other radiation measurements for the purpose of




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demonstrating compliance with the occupational dose limits (see Table 1), if the individual monitoring device was not in the region of highest potential exposure, or the results of individual monitoring are unavailable.

• In addition to the annual dose limits, soluble uranium intake by an individual shall be limited to 10 milligrams in a week in consideration of chemical toxicity.

• The occupational exposure that an individual may be allowed to receive in the current year shall be reduced by the amount of occupational exposure received while employed by any other company or organization.

Table 1. Annual dose limits.

Category Annual Limit (rems) Body Part/Type of Dose

General Employees

5 Whole body (internal plus external)

50 Any organ other than eye (internal plus external)

15 Lens of the eye 50 Extremities and skin

Embryo/fetus of a declared pregnant worker 0.5 Internal plus external (evenly

distributed throughout gestation)

Occupationally exposed minors

0.1 Whole body (internal plus external) 1.5 Lens of the eye 5 Extremities and skin

Members of the public 0.1 Whole body (internal plus external)

6.7.8 Occupationally Exposed Minors

• The CRSO shall evaluate radiological work that is proposed to be performed by minors.

• Minors shall be permitted to perform only tasks that are unlikely to result in a significant exposure.

6.7.9 Fetal Exposure Minimization Policy

• Women working in an environment where exposure to radiation or radioactive materials is possible or occurring shall be provided with the following: o Pregnancy-related information, such as in NRC Regulatory Guide 8.13,

Instruction Concerning Prenatal Radiation Exposure




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o An interview with the RSO to discuss the ramifications of exposure to the embryo/fetus, and determine the potential for occupational exposure to workplace hazards in their current assignment

o Information on how to declare a pregnancy in writing and limiting radiation exposure to 0.5 rem during the gestation period, and an evaluation of their current work assignment.

• Supervisors of women workers will also be provided with the above information.

• All women who will be occupationally exposed shall sign a Fetal Exposure Minimization Policy Training Acknowledgement Form, or equivalent, that acknowledges that they have received information concerning exposure to the embryo/fetus and the process for declaring a pregnancy.

NOTE: The appropriate members of ES&H will conduct a workplace evaluation when requested. The workplace evaluation, which can be conducted on a confidential basis if requested by the employee, helps ensure that the embryo/fetus is afforded maximum protection. At any time, the employee may direct that the medical restriction (and any associated work or workplace modifications) be rescinded by providing written notification to the RSO.

6.7.10 Provisions for planned special exposures, which are in addition to and accounted for separately from routine occupational doses, shall be authorized by the Portage Corporate CHP.

• Planned Special Exposures should only be authorized in exceptional situations when alternatives which might avoid the higher exposure are unavailable or impractical.

6.8 Radiation Monitoring Instrumentation

6.8.1 An adequate number of radiological survey and monitoring instruments of sufficient accuracy and sensitivity and appropriate for the types, levels, and energies of the radiation shall be available to ensure compliance with monitoring requirements.

6.8.2 Hand-held portable radiation survey instruments utilized for radiation protection purposes shall be calibrated at least annually or following instrument maintenance, repair, or adjustment likely to affect the primary calibration.




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6.8.3 Laboratory instruments used for radioactivity measurements shall be evaluated daily, when in use.

6.9 Access Controls and Radiological Postings

6.9.1 Personnel entry control shall be maintained for each radiologically controlled area.

• The degree of control shall be commensurate with existing and potential radiological hazards within the area.

6.9.2 Controls that would prevent rapid evacuation of personnel under emergency conditions SHALL NOT be installed at any exit.

6.9.3 Access to High Radiation Areas shall be monitored as necessary to determine the exposure rates to individuals in the area.

• Additional controls shall be used for each access point to a High Radiation Area.

6.9.4 Additional control measures, beyond those used for High Radiation Areas, shall be implemented to ensure individuals are not able to gain unauthorized or inadvertent access to Very High Radiation Areas.

6.9.5 Posting a radiologically controlled area, or altering a radiological posting sign containing the radiation trefoil symbol, shall be performed only by a qualified individual.

6.9.6 Radiological postings shall be in accordance with the regulatory requirements contained in 10 CFR 20, 10 CFR 835, applicable state regulations, and/or specific license conditions.

6.9.7 When posting access points to a radiologically controlled area, the following requirements apply:

• Access doors that can be opened from the outside must be posted, even if the door remains locked. (This posting protects individuals such as security guards, firefighters, and other emergency responders who may enter the area using master keys.) Individuals who allow others to access an area through such doors must ensure that those entering the area abide by the access control requirements.




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• Doors that cannot be opened from the outside (e.g., highbay rollup doors or emergency exits) are considered access points only if they are left open and unattended.

• Side-by-side doors do not have to be individually posted if it is obvious that both doors provide access to the same area and an appropriate sign is clearly and conspicuously posted.

6.10 Waste Management

6.10.1 Collection of radioactive material classified as radioactive waste shall be accomplished using written procedures.

6.10.2 Radioactive waste produced as a result of site operations shall be collected, packaged, surveyed, and stored in a location prescribed by the RSO.

6.10.3 Radioactive waste shall be transferred to a recipient who is properly licensed to receive such waste in accordance with applicable regulations.

6.10.4 Radioactive waste may be transferred to a licensed broker or shipped directly to an authorized radioactive waste disposal facility or other authorized waste processor in accordance with the Waste Management, Transportation, and Disposal Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project.

7. QUALITY ASSURANCE

Documents generated during the performance of this procedure shall be audited in accordance with the Uniform Federal Policy Quality Assurance Project Plan for the Luckey FUSRAP Site Remediation Luckey, Ohio, Sampling and Analysis Plan.

8. RECORDS

Records pertaining to the Radiation Protection Program, unusual occurrences, inspections, audits, ALARA, personnel exposures, radiation and contamination surveys, effluent monitoring, environmental monitoring program, calibrations, and decommissioning are retained and maintained to demonstrate compliance with the conditions of the site’s license(s) and with applicable federal, state, and local regulations.

Radiological records must be retained until NRC authorizes their disposition.




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9. REFERENCES

10 CFR 19, “Notices, Instructions and Reports to Workers,” Code of Federal Regulations, U.S. Nuclear Regulatory Commission.


10 CFR 35.75, “Release of Individuals Containing Unsealed Byproduct Material or Implants Containing Byproduct Material,” Code of Federal Regulations, U.S. Nuclear Regulatory Commission.


USACE, 2016a, Radiation Protection Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5513, U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York.

USACE, 2016b, Uniform Federal Policy Quality Assurance Project Plan for the Luckey Formerly Utilized Sites Remedial Action Program Site Remediation, Luckey, Ohio, Sampling and Analysis Plan, PLN-5503, U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York.

USACE, 2016c, Waste Management, Transportation, and Disposal Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5507, U.S. Army Corps of Engineers, Luckey, Ohio.

10. APPENDIXES

None

ATTACHMENT 2 RPO-103, Radiation Protection Audits,

Assessments, and Oversight

RPO-103 Rev. 0

Radiation Protection Audits, Assessments, and Oversight for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project




Signature

RADIATION PROTECTION AUDITS, ASSESSMENTS, AND OVERSIGHT FOR THE LUCKEY FORMERLY UTILIZED SITES REMEDIAL ACTION PROGRAM

REMEDIATION PROJECT


RPO-103 0 2 of 10




REMEDIATION PROJECT


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Table of Contents

1. PURPOSE ..............................................................................................................................4

2. SCOPE ...................................................................................................................................4



3.2 Prerequisites ...............................................................................................................5

4. GENERAL .............................................................................................................................5

4.1 Equipment ..................................................................................................................5



4.4 Revisions ....................................................................................................................5

5. DEFINITIONS .......................................................................................................................5

6. PROCEDURE ........................................................................................................................5

6.1 General .......................................................................................................................5

6.2 Internal Audits and Assessments ................................................................................6

6.3 External Audits and Assessments ..............................................................................8

6.4 Audit Results and Tracking ........................................................................................8

7. QUALITY ASSURANCE .....................................................................................................9

8. RECORDS .............................................................................................................................9

9. REFERENCES .......................................................................................................................9

10. APPENDIXES .....................................................................................................................10


REMEDIATION PROJECT


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1. PURPOSE

This procedure establishes requirements and instructions for the performance of audits and assessments regarding the Portage Radiation Protection Program that governs radiological work performed at the Luckey Formerly Utilized Sites Remedial Action Program (FUSRAP) Remediation Project. This procedure also applies to audits and assessments performed in support of radiological work activities.

2. SCOPE

This procedure applies to Portage management, supervisors, individuals, and contractors where their work assignment is controlled by Portage.




Radiation safety officer (RSO) or designee

• Develop and maintain a Radiation Protection/Health Physics Audit & Assessment Plan that complies with applicable regulatory requirements.

• Coordinate and conduct internal audits of the Luckey Radiation Protection Program and radiological work activities.

• Assist auditors/assessors during the performance of their audit/assessment.

• Schedule independent audits as necessary. • Ensure audit/assessor personnel have the proper training,

qualifications, dosimetry, PPE, etc., prior to entering radiologically controlled areas in the performance of their audits and assessments.

• Respond to audit/assessment non-compliance issues and findings, as appropriate.

• Keep Portage Executive Management informed of the status of the audit program including audit schedules, findings, and corrective actions required and performed


REMEDIATION PROJECT


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3.2 Prerequisites

A written audit plan shall be established to identify the scope and areas to be audited prior to the performance of an internal audit.

4. GENERAL

4.1 Equipment

Not applicable


Not applicable


Not applicable

4.4 Revisions


5. DEFINITIONS

Audit – An independent formal review/examination performed to verify that radiological activities are being conducted in accordance with established procedures, protocols, regulations, and regulatory requirements.

For other definitions, see Radiation Protection Plan Glossary.

6. PROCEDURE

6.1 General

6.1.1 Audits/assessments shall be performed to determine if radiological operations are being conducted in accordance with established procedures, protocols, regulations, and regulatory requirements.

6.1.2 To ensure a comprehensive evaluation, both institutional and facility-specific audits shall be conducted.


REMEDIATION PROJECT


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6.1.3 Audits/assessments of the Luckey Radiation Protection Program shall be conducted as required by the RSO.

6.1.4 Radiation Protection Program audits, assessments, inspections, and independent assessments may be conducted at any time by an outside agency of regulatory agency, where work is being performed under the jurisdiction of that regulatory agency (e.g., NRC or DOE).

6.2 Internal Audits and Assessments

6.2.1 Portage shall conduct internal audits of the Radiation Protection Program to identify its strengths and weaknesses, areas of vulnerability, and noncompliance.

6.2.2 Audits of the Radiation protection program shall be conducted no less frequently than every 12 months and shall include examination of the radiation protection program’s content and implementation.

6.2.3 To ensure a comprehensive evaluation, both institutional and facility-specific audits shall be conducted during an audit cycle (no less frequently than every 36 months).

6.2.4 Institutional audits shall focus on (but are not limited to) the following program elements:

• Management and administration. • The ALARA Program. • Radiological training. • Internal dosimetry. • External dosimetry. • Instrument calibration and maintenance. • Radiation-generating devices. • Sealed source accountability.

6.2.5 Facility audits shall focus on (but are not limited to) the following program elements:

• Radiation protection written program and procedure documents. • Implementation of the ALARA Program. • Individual monitoring, including appropriate use of dosimeters and enrollment

and participation in bioassay programs.


REMEDIATION PROJECT


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• Area monitoring, including air monitoring, contamination monitoring, and radiation monitoring.

• Access controls. • Radioactive material controls. • Posting and labeling. • Training. • Records. • Design and control of facility modifications and equipment.

6.2.6 The RSO shall schedule a pre-audit meeting with the audit team and appropriate members of the Health Physics Staff prior to the audit/assessment.

6.2.7 The RSO shall ensure the audit team is knowledgeable and qualified to conduct a radiation protection audit/assessment.

• The RSO shall allow the audit team to familiarize themselves with the site’s license requirements and operational procedures prior to conducting the audit/assessment.

6.2.8 The RSO and audit team shall develop a specific audit/assessment plan, focusing on the primary intent of the audit/assessment, as described in steps 6.2.4 and 6.2.5 above.

6.2.9 The RSO and health physics staff shall provide support to the audit team, as necessary.

6.2.10 The RSO shall schedule an exit meeting with the audit team, select member of the Health Physics Staff upon completion of the audit/assessment.

6.2.11 Upon completion of the exit meeting, a written report shall be generated by the RSO.

• The report shall present the results of the audit/assessment, if available, including all non-compliances and pertinent comments made by the audit/assessment team.

6.2.12 A written corrective action plan shall be prepared to address any non-compliance issues discovered by the audit team.

6.2.13 Corrective actions shall be tracked to completion in accordance with Section 6.4.


REMEDIATION PROJECT


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6.3 External Audits and Assessments

6.3.1 The RSO shall request an entrance meeting with the audit team prior to the audit/assessment.

6.3.2 The RSO and staff shall provide support to the audit team, as necessary.

6.3.3 The RSO shall request an exit meeting with the audit team upon completion of the audit.

6.3.4 Upon completion of the exit meeting, a written report shall be generated by the RSO. The report shall present the results of the audit/assessment, including all non-compliances and pertinent comments made by the audit/assessment team.

6.3.5 A written corrective action plan shall be prepared to address any non-compliance issues discovered by the audit team.

6.3.6 All corrective actions shall be tracked to completion in accordance with Section 6.4.

6.4 Audit Results and Tracking

6.4.1 All audits and assessments shall be documented.

• Findings or non-compliance issues shall be recorded and tracked, including corrective actions.

6.4.2 A permanent tracking system (electronic database, paper log, etc.), for the performance of audit/assessments and their results, shall be generated and maintained by the RSO.

6.4.3 If the Audit/Assessment Tracking Log is not used for audit tracking purposes, the tracking system used shall include (as a minimum) the following information:

• A sequential tracking number • Date(s) of the audit/assessment • Audit/assessment number • Type of audit/assessment (Internal, Independent, NRC, INPO, etc.) • Corrective action plan number • Date corrective action plan was written • Closure report number


REMEDIATION PROJECT


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• Date closure report was written • Comments.

6.4.4 An active audit and inspection database shall be reviewed monthly by the RSO.

6.4.5 Once all corrective actions listed in the corrective action plan have been completed, a written closure report shall be prepared and distributed to management documenting the completion of the corrective actions.

6.4.6 Management shall respond to findings or non-compliance issues and, as necessary, report non-compliance issues to the appropriate regulatory agency.

6.4.7 At the end of each 3-year audit cycle, the RSO shall prepare and present a comprehensive audit report to Portage management.


The RSO shall review the Audit/Assessment Tracking Log monthly. Open entries remaining on the Audit/Assessment Tracking Log for a period greater than 3 months shall be brought to the attention of management for review.

8. RECORDS

Audit/assessment-related documents and/or records shall be stored, arranged, indexed, retained, retrieved, and disposed of in accordance with this procedure and all applicable document regulations and requirements.

Completed Forms FRN-0002, Audit/Assessment Tracking Log, can be associated with this procedure.

9. REFERENCES



RPO-101, “Radiation Protection Program Overview for the Luckey Formerly Utilized Sites Remedial Action Program FUSRAP Remediation Project,” U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York, 2016.


REMEDIATION PROJECT


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RPO-106, “Radiological Training and Qualification for the Luckey Formerly Utilized Sites Remedial Action Program FUSRAP Remediation Project,” U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York, 2016.

RPO-201, “Operation of Portable Radiological Survey Instruments for the Luckey Formerly Utilized Sites Remedial Action Program FUSRAP Remediation Project,” U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York, 2016.

USACE, 2016, Radiation Protection Plan for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project, PLN-5513, U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York.

10. APPENDIXES

None

ATTACHMENT 3 RPO-104, Routine Radiation Protection

Surveys and Inspections

RPO-104 Rev. 0

Routine Radiation Protection Surveys and Inspections for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project




Signature

ROUTINE RADIATION PROTECTION SURVEYS AND INSPECTIONS FOR THE LUCKEY FORMERLY

UTILIZED SITES REMEDIAL ACTION PROGRAM REMEDIATION PROJECT


RPO-104 0 2 of 11






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Table of Contents

1. PURPOSE ..............................................................................................................................5

2. APPLICABILITY ..................................................................................................................5



3.2 Prerequisites ...............................................................................................................6

4. GENERAL .............................................................................................................................6

4.1 Equipment ..................................................................................................................6



4.4 Revisions ....................................................................................................................6

5. DEFINITIONS .......................................................................................................................7

6. PROCEDURE ........................................................................................................................7

6.1 Routine Inspections ....................................................................................................7

6.2 Routine Radiological Surveys ....................................................................................8

6.3 Other Inspections/Checks ...........................................................................................9

6.4 General Requirements ..............................................................................................10

6.5 Inspection Results and Tracking ..............................................................................10

7. Quality Assurance ................................................................................................................11

8. RECORDS ...........................................................................................................................11

9. REFERENCES .....................................................................................................................11




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10. APPENDIXES .....................................................................................................................11




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1. PURPOSE

This procedure establishes requirements for, and provide guidance during, the performance of routine radiation protection surveys, inspections and operational checks. This procedure also provides guidance on the performance and schedule of routine activities (routines) conducted in support of radiological work activities.

2. APPLICABILITY

This procedure applies to Portage management, supervisors, individuals and contractors that conduct inspections and surveys, where their work assignment is controlled by Portage.




RSO or designee • Implement this procedure.

• Develop and maintain a radiation protection inspection plan/schedule that is in compliance with the site’s license(s) and applicable regulations.

• Assist inspectors/surveyors during the performance of their inspection.

• Ensure inspector/surveyor personnel have the correct training, qualifications, dosimetry, and PPE to enter health physics Restricted Areas and/or radiological areas.

• Respond to inspection findings, as appropriate.

• Complete scheduled reviews/inspections.

• Notify Portage management of any unusual or non-compliance items identified during routine inspection, surveys, or other operations.




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Health physics staff • Comply with this procedure.

• Conduct surveys, inspection, and quality control checks in accordance with applicable procedures and good health physics/safety practices.

• Exercise appropriate contamination control techniques in the performance of radiological surveys.

• Comply with entry requirements for the areas to be surveyed.

• Operate radiological survey instrumentation in accordance with approved operating procedures.

• Notify the RSO of abnormal radiological conditions or safety issues

3.2 Prerequisites

Not applicable

4. GENERAL

4.1 Equipment

Not applicable


Not applicable


Not applicable

4.4 Revisions





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5. DEFINITIONS

Inspection – A routine review performed to assure that operations and activities are conducted in compliance with regulatory and procedural requirements.

For other definitions, see Radiation Protection Plan Glossary.

6. PROCEDURE

6.1 Routine Inspections

6.1.1 Routine inspections shall be conducted in and around radiologically controlled areas.

6.1.2 Individuals conducting the inspection(s) shall indicate the completion of each inspection task by initialing the initials’ block on the appropriate inspection checklist (Forms FRN-0045, a-d).

6.1.3 The RSO shall be immediately notified of any inspection deficiency or identified safety hazard discovered during the inspection process.

6.1.4 All inspection deficiencies, or identified safety hazards, shall be noted on the appropriate inspection checklist.

6.1.5 Any easily repaired deficiency shall be corrected (repaired) on the spot, and an entry made on the inspection checklist noting the deficiency and the repair performed.

6.1.6 Any safety hazard(s), identified during an inspection (that are not immediately corrected), shall be controlled by preventing unauthorized access (e.g., using rope, safety tape barricades, or any other appropriate means) to the hazard area(s).

6.1.7 Daily inspections shall be conducted in accordance with Form FRN-0045, a.

6.1.8 Weekly inspections shall be conducted in all outdoor areas containing licensed or FUSRAP radioactive material. The inspection results shall be documented on the Inspection Checklist - Weekly Routines, Form FRN-0045, b. The inspection shall include, as a minimum:

Inspecting perimeter fencing, gates and ropes around posted areas.




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6.1.9 A monthly inspection shall be conducted to verify that all radiological postings are present and in good physical condition. The inspection results shall be documented in accordance with RPO-402, Attachment 8, Radiological Posting Inspection.

6.2 Routine Radiological Surveys

6.2.1 Routine radiological surveys shall be performed to determine general radiological conditions of work areas and areas accessible to members of the general public.

6.2.2 As a minimum, routine radiological survey shall be performed to identify loose surface contamination. Additional surveys may be required, as determined by the RSO, to identify fixed contamination activity or general area dose rates.

6.2.3 Radiological survey results shall be documented in accordance with RPO-301 and documented on the appropriate Inspection Checklist.

6.2.4 Daily contamination surveys shall be performed in buffer zone type areas.

These areas are generally access/egress areas that workers utilize as transition points between radiologically controlled areas and clean areas.

Buffer zone survey locations are identified on the appropriate Inspection Checklist.

NOTE: Additional daily surveys may be performed to support site operations. Scheduling and documentation of those surveys are beyond the scope of this procedure.

6.2.5 Weekly surveys shall be performed in areas where active work with radioactive material is being performed.

Typical areas requiring weekly surveys may include, but are not limited to; health physics labs, environmental sampling labs, etc.

Weekly survey locations are identified on the appropriate Inspection Checklist.

6.2.6 Monthly radiological surveys shall be performed in areas where access is restricted to occupational workers or in (or around) areas where loose surface contamination is known to be located.




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Monthly survey locations are identified on the appropriate Inspection Checklist.

6.2.7 Quarterly surveys shall be performed in areas generally accepted to be clean areas, but may contain low levels of contamination in discrete locations. Contamination surveys shall also be performed in secured laboratories that are not in use.

Quarterly survey locations are identified on the appropriate Inspection Checklist.

6.2.8 Quarterly source leak checks are required for sealed sources that emit alpha radiation. Leak checks are to be performed and documented in accordance with RPO-404.

6.3 Other Inspections/Checks

6.3.1 Other health physics operations are required to comply with the Radiation Protection Program, as well as license and regulatory requirements. This section identifies (but is not limited to) routine checks that may be required.

6.3.2 Daily routine checks:

Quality control check of the alpha/beta counting system (when in use). Quality control check of the gamma spectroscopy system (when in use). Operational checks of stack and general area air samplers. Change out of stack and general area air samplers (when required). Personnel frisker response checks (when in use). Review of Lapel air sampler results.

6.3.3 Weekly routine checks:

Review instrument calibration list. Change general area air sampler filters.

6.3.4 Monthly routine checks:

Review active and terminated RWPs. Review open items from the audit and inspection lists. Review radiological training list. Inspect respiratory protection equipment.




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6.3.5 Quarterly routine checks:

Environmental TLD change out. Personnel monitoring TLD change out. Leak check of alpha emitting sealed sources. Semi-annually leak check of beta-gamma emitting sealed sources.

6.4 General Requirements

6.4.1 Perform health physics routines in accordance with Forms FRN-0045, a-d, and as required by the RSO.

Initial the appropriate area of the inspection checklist to indicate inspection/performance of the area/item completed satisfactory.

Record “NA” to indicate an inspection/performance was not applicable and not performed.

If other than “satisfactory” or “NA” is recorded, note the condition/action taken in the Comments Section of the checklist and notify the RSO immediately.

Add or delete inspection areas/items to the checklist as site conditions warrant, or as procedural requirements dictate. This can be a pen and ink change and does not require a formal procedure revision.

NOTE: Additions or deletions to any forms required by this procedure, must be approved by the RSO, but does NOT require a formal procedure revision. When a formal revision to this procedure is made, pen and ink additions or deletions to the forms (FRN-0045) shall be updated at that time, as a part of the formal procedure revision.

6.4.2 Any findings identified during the health physics routines shall be recorded and the RSO immediately notified.

6.5 Inspection Results and Tracking

6.5.1 Document the completion of various health physics inspections/routines on Forms FRN-0045, a-d.

6.5.2 Track all health physics routine inspection findings (Form FRN-0045, e) until the recommended corrective actions have been completed. This tracking system (log) shall be created and maintained by the RSO. The tracking system shall include the following minimum information:




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A sequential tracking number Date of the health physics routine inspection Description of finding Description of the corrective action planned and tentative correction date Date corrective action completed Comments.


The RSO shall review the various Inspection Checklists when completed and the Inspection Tracking Log monthly. Open findings remaining on the Inspection Tracking Log for a period greater than 3 months shall be brought to the attention of Portage management for review.

This procedure and all related documents shall be made available as part of the annual Health Physics audit program

8. RECORDS

Inspection records/checklists shall be stored, arranged, indexed, retained, retrieved, and disposed of in accordance with this procedure and all applicable document regulations and requirements.

9. REFERENCES



Various RPOs.

10. APPENDIXES

None

ATTACHMENT 4 RPO-106, Training and Qualification

RPO-106 Rev. 1

Training and Qualification for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project




Signature

TRAINING AND QUALIFICATION FOR THE LUCKEY FORMERLY UTILIZED SITES REMEDIAL ACTION



RPO-106 1 2 of 11



1 09/19/16 Revise document. Edits and comments from the Stakeholder review.




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Table of Contents

1. PURPOSE ..............................................................................................................................4

2. APPLICABILITY ..................................................................................................................4


4. GENERAL .............................................................................................................................5

5. DEFINITIONS .......................................................................................................................5

6. PROCEDURE ........................................................................................................................5

7. QUALITY ASSURANCE .....................................................................................................9

8. RECORDS .............................................................................................................................9

9. REFERENCES .......................................................................................................................9

10. APPENDIXES .....................................................................................................................10

APPENDIX A Radiological Training Requirements List .............................................................11




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1. PURPOSE

The purpose of this procedure is to define the radiological training requirements necessary for radiological workers to perform unescorted work in the various radiologically controlled areas.

2. APPLICABILITY

This procedure applies to Portage management, supervisors, individuals and contractors that work in radiologically controlled areas (Restricted Areas and radiological areas) where their work assignment is controlled by Portage.





• Ensure individuals are qualified to perform this procedure.

• Ensure that non-radiological workers complete General Employee Radiological Training (GERT), as applicable.

• Ensure that radiological workers complete Radiological Worker Training (RWT).

• Ensure that radiological workers and members of the Health Physics Staff receive appropriate job-specific radiological training, as applicable.

Radiological workers

• Complete required radiological worker training as prescribed by this procedure and the RSO.

• Have a current radiological worker qualification to access and perform work in radiologically controlled areas.

Non-radiological workers

• Complete GERT, as applicable.




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3.2 Prerequisites

Not applicable

4. GENERAL

4.1 Equipment

Not applicable


Not applicable


Radiological workers who are required to use respiratory protection devices for protection against airborne radiological hazards, shall be trained in accordance with the company respiratory protection training program, as required by Reference 3.4, and as required by the RSO.

4.4 Revisions

This procedure shall be reviewed at least every two years, with documentation to support the completion of such review.

5. DEFINITIONS

See RPO Glossary.

6. PROCEDURE

6.1 Radiological Training – Minimum Requirements

6.1.1 Personnel shall complete the appropriate radiation safety training, in accordance with Attachment 1, before being:

• Permitted access to any radiologically controlled area. • Occupationally exposed to ionizing radiation.

6.1.2 All radiological training requirements, commensurate with the hazards, shall be completed before personnel are allowed access to radiologically posted areas.




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6.1.3 Workers shall complete the appropriate level of radiological worker training prior to:

• Unescorted access to radiologically controlled area. • Occupational exposure to ionizing radiation. • Performing unescorted assignments as radiological workers.

NOTE: The level of radiological worker training required, as well as job-specific radiological training, depends upon the types of radiological hazards or radiological areas that individuals may encounter while performing assigned activities.

6.1.4 Radiological worker training qualifications shall be valid for a period not to exceed one year.

6.1.5 Radiological workers shall have access to their radiological qualification cards, and be available to present their qualifications (as requested by radiation protection staff) prior to gaining access and performing work in radiologically controlled areas.

6.1.6 Personnel who have completed comparable radiological worker training may apply for training equivalency. For determination of training equivalency, contact the RSO.

6.1.7 Contract personnel or visitors, being brought on site for their expertise in the field of health physics and radiation protection (e.g., experience, education, or certification), may apply for a training equivalency waiver from the RSO. Site specific training shall be administered by the RSO, or designee, prior to taking the appropriate radiation worker examination.

6.1.8 Current qualification as a Health Physics Technician (HPT) satisfies the requirements for RWT as well as GERT.

6.2 Radiological Training for Non-Radiological Workers

6.2.1 Non-radiological workers, who require unescorted access to radiologically controlled areas, shall complete GERT.

6.2.2 RSO may authorize non-radiological workers, who have completed GERT, access to Radioactive Material Areas, Fixed Contamination Areas (without disturbing the fixed contamination), and certain Radiation Areas.




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6.2.3 Non-radiological workers who have completed GERT may be authorized to:

• Operate/use devices, equipment, etc., that contain inaccessible radioactive material.

6.3 Radiological Training for Radiological Workers

6.3.1 Personnel whose job assignments require routine, unescorted access to radiologically controlled area shall complete RWT.

6.3.2 RWT is required for personnel:

• that use, or work with, radioactive material; • that operate or use of devices, equipment, etc., that contain accessible

radioactive material; • whose job assignments involve the transport of radioactive material; • whose job assignments require receiving more than 100 mrem in a year from

occupational exposure; • directly involved with the modification of, or invasive maintenance on,

equipment containing normally inaccessible radioactive material; • whose work involves direct contact with radioactive material that could result

in contamination of the worker or property; and/or • whose job assignments require unescorted access to radiologically controlled

areas.

6.4 Job-Specific Radiological Worker Training

6.4.1 Radiological workers shall complete appropriate job-specific radiological training.

• This training shall include, as a minimum, reading and understanding all technical work documents applicable to their work assignments.

• This training should also include appropriate on-the-job training (OJT), such as mentoring and/or vendor-provided training.

• Based upon the complexity of the task(s) and/or the experience of the worker, the manager/supervisor (with RSO approval) may exempt an individual worker from job-specific radiological training requirements.

6.4.2 Managers/supervisors of radiological workers shall be responsible for providing training on job-specific technical work documents (i.e., operating procedures, operating instructions, etc.), and for providing any additional training (i.e.,




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equipment manufactures' training, specialized radiological training), as necessary, to qualify their personnel for the assigned radiological work.

6.4.3 Managers/supervisors, in conjunction with the RSO, shall be responsible for the following, for each radiological worker in their organization:

• Determining appropriate job-specific radiological training. • Documenting completion of job-specific radiological training and forwarding

such documentation to the RSO.

6.5 Radiological Worker Retraining

6.5.1 Radiological workers shall complete radiation safety retraining (i.e., RWT) annually in conjunction with the HAZWOPER 8-hour refresher and when there are significant changes to radiation protection policies and procedures that may affect them.

6.6 Health Physics Technician Training

6.6.1 HPTs are responsible for all radiological surveys of record (i.e., release surveys, surveys performed in support of evaluating radiological hazards and establishing radiological control requirements). Surveys of record (i.e., legal records) shall be performed only by personnel who are trained and qualified as HPTs.

6.6.2 An industry accepted health physics and radiation protection qualification standard shall be used to define the requirements for satisfactory HPT training and qualification. HPTs shall be trained to the level of knowledge and skills commensurate with their job duties and responsibilities.

6.6.3 HPTs shall complete training on procedures specific to their job assignment and facilities they assist. The level of training shall be commensurate with the HPTs’ assignments.

6.6.4 HPTs shall complete health physics retraining at intervals not to exceed 24 months and when there are significant changes to radiation protection policies and procedures that may affect them.

6.7 Health Physics Staff Fundamental Training

6.7.1 The Radiological Engineer shall obtain and maintain (when required by site or facility procedures) the following minimum training qualifications:




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• GERT • RWT • Specialized health physics training commensurate with their duties and

professional development curriculum.

6.8 Other Training

6.8.1 Managers/supervisors who are responsible for tours (or visitors) shall be responsible for:

• Being familiar with the current radiological conditions of the areas to be visited.

• Awareness of current work activities for the areas to be entered and required safety equipment (e.g., hardhats, safety shoes, etc.)

• The applicable training requirements for areas to be entered. • Obtaining approval from the RSO, or designee, for any tour in any

radiological type area.


The RSO shall review the Radiological Training Program and training materials on an annual basis. If discrepancies are noted in the training material or in the training programs, the RSO shall update the training material(s) or program(s) to correct the noted discrepancies.

8. RECORDS

Related documents and/or records shall be stored, arranged, indexed, retained, retrieved, and disposed of in accordance with this procedure and all applicable document regulations and requirements.

9. REFERENCES

10 CFR 20, “Standards for Protection against Radiation.”

10 CFR 835, “Occupational Radiation Protection.”

RPO-101, “Radiation Protection Program Overview.”

RPO-405, “Respiratory Protection.”




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10. APPENDIXES

Appendix A, Radiological Training Requirements List




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APPENDIX A Radiological Training Requirements List

Affected Personnel/Activity Minimum Training Required

Access to Radiologically Controlled Areas GERT

Access to Radioactive Material Areas GERT

Access to Radiation Areas RWT

Access to High Radiation and Very High Radiation Areas RWT

Access to Contamination Areas RWT

Access to Airborne Radioactivity Areas RWT

Access to Fixed Contamination Areas to perform work that disturbs fixed contamination RWT

Radiological emergency response team members RWT

Users of radioactive sources or material: • Accessible radioactive material

• Inaccessible radioactive material

RWT GERT

Personnel who transport radioactive material RWT

ATTACHMENT 5 RPO-201, Operation of Portable Radiological Survey

Instruments

RPO-201 Rev. 0

Operation of Portable Radiological Survey Instruments for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project




Signatur

OPERATION OF PORTABLE RADIOLOGICAL SURVEY INSTRUMENTS FOR THE LUCKEY

FORMERLY UTILIZED SITES REMEDIAL ACTION PROGRAM REMEDIATION PROJECT


RPO-201 0 2 of 12






RPO-201 0 3 of 12

Table of Contents

1. PURPOSE ..............................................................................................................................5

2. APPLICABILITY ..................................................................................................................5



3.2 Prerequisites ...............................................................................................................5

4. GENERAL .............................................................................................................................6

4.1 Equipment ..................................................................................................................6



4.4 Revisions ....................................................................................................................6

5. DEFINITIONS .......................................................................................................................7

6. PROCEDURE ........................................................................................................................7

6.1 Pre-Operational Check ...............................................................................................7

6.2 Instrument Operation ..................................................................................................8

6.3 General Background Check .......................................................................................8

6.4 Source Response Check .............................................................................................9

6.5 Instrument Use .........................................................................................................10

6.6 Instrument Failure ....................................................................................................11


8. RECORDS ...........................................................................................................................11




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9. REFERENCES .....................................................................................................................11

10. APPENDIXES .....................................................................................................................12




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1. PURPOSE

The purpose of this procedure is to provide instruction for the operation of portable radiological survey instruments.

2. APPLICABILITY

This procedure applies to Portage management, supervisors, individuals and contractors that operate portable radiological survey instruments where their work assignment is controlled by Portage.






• Ensure an adequate number of radiological survey and monitoring instruments of sufficient accuracy and sensitivity are available for use.


• Exercise appropriate contamination control techniques in the performance of radiological surveys and while handling sample media.


• Operate radiological survey instrumentation in accordance with this procedure and the instrument’s operating manual.

3.2 Prerequisites

HPT shall ensure that the portable radiation monitoring instrument being used is current in regard to calibration.




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HPT shall ensure that instruments are operated with the probe it was calibrated with, or that the instrument is designed to be operated with a variety of other calibrated “smart” type probes.

HPT shall be properly qualified to operate the portable survey instrument prior to use.

4. GENERAL

4.1 Equipment

Various portable radiation and contamination survey instruments

Various radioactive sources and source jigs


Not applicable.


Direct probe contact with the radioactive check source surface can damage or disturb the protective coating and/or radioactive material of the radioactive check source surface and/or spread radioactive material to the detector/probe.

Unexplainable or out of character changes in background count or dose rates may be the result of a damaged or contaminated detector/probe or unidentified radiation interference.

Instruments that are out of calibration may function improperly or respond falsely. Do not use an instrument that is out of calibration. Contact the RSO if an instrument is used that is out of calibration.

If maintenance is performed on a survey meter, other than allowed by the manufacturer in the field (e.g., battery change out or mylar film repair/replacement), an instrument calibration shall be performed prior to use.

4.4 Revisions





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5. DEFINITIONS

See RPO Glossary.

6. PROCEDURE

6.1 Pre-Operational Check

6.1.1 If at any time an instrument is damaged during use, fails any of the steps listed in this procedure, or is recalled by the RSO:

Stop using the instrument Return the instrument to the Instrument Lab or designated storage location

immediately.

6.1.2 Prior to using a portable survey instrument, verify that the instrument’s calibration is current and the instrument is properly suited for the survey type (i.e., type, level, and energies of radiation encountered).

6.1.3 Inspect the instrument for physical damage. Look for areas of damage to include (as a minimum):

Damage to the body of instrument. Damage to the meter face. Damage to the detector cable. Damage to the detector surface (i.e., broken detector window covering,

scratches in the detector window covering, dents in the detector, etc.) Broken or loose fasteners, handles, or switches.

6.1.4 Verify that instruments with analog meter indications read zero (with the instrument turned off).

6.1.5 Verify instrument electrical features are acceptable and in proper working order. Check for (if installed):

Battery self-test or battery OK indication. Instrument high voltage self-test indication. Automatic adjustment of electronic zero.

6.1.6 Inform the RSO of any problems found that cannot be corrected by the user.




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6.2 Instrument Operation

6.2.1 Ensure that peripheral equipment (i.e., instrument’s detector/probe, gas supply system, external speaker, data cable, etc.) is properly attached or connected, as required.

6.2.2 Turn the instrument on.

If the instrument performs automatic start up checks (i.e., battery check, high voltage check, etc.) during the start-up process, verify that automatic checks are performed and the results are acceptable.

If the instrument is manufactured such that the battery and/or detector high voltage check is performed during the manual start up process of the instrument (i.e., rotating the On/Off/Range Selector switch towards the ON position), manually perform the required checks as described below and verify that the results are acceptable.

6.2.3 Perform a battery check (if not previously performed).

6.2.4 If required for the instrument, perform a detector high voltage check and adjust as necessary (if not previously performed).

6.2.5 Initiate and adjust gas flow to the detector, if required.

NOTE: Gas flow detectors must be purged with counting gas to ensure proper response. Check the manufactures technical manual or operating procedure to determine appropriate purge times.

6.2.6 If any other pre-operational checks are required by the instrument manufacturer or operating procedure, perform those checks at this time.

6.3 General Background Check

6.3.1 Perform an instrument background check in the same area where the instrument will be source response checked (i.e., the instrument lab or storage area). For some instruments used for environmental monitoring, instrument background checks may be required to be performed in similar type areas consistent with the areas where actual surveys will be conducted. In addition, job specific instrument background determinations may be required during radiological surveys. The site-specific survey plan will indicate requirements for additional background checks as necessary.




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6.3.2 Select the lowest scale (as applicable) on the instrument which will allow a response from a normal background reading.

6.3.3 Obtain background reading for the instrument.

NOTE: The background reading for instruments with only rate-meter mode may be estimated by the user based on a continuous observation of the meter reading over a 20 to 30 second observation. For instruments that operate in a scaler mode, a background count time of 1 minute is nominally sufficient. Some background count times may have to be increased (greater than 1 minute) to meet detector MDAs. Consult the site-specific sampling or surveying plan for background counting requirements.

NOTE: The background for dose rate instruments which do not have a scale low enough to properly indicate the actual background levels should be written as less than (<) the lowest reading obtainable by the instrument (i.e., < 0.1 mrem/h).

6.3.4 Record the instrument’s background reading on the Portable Instrument Response Check Sheet assigned to that instrument.

6.4 Source Response Check

6.4.1 Perform the instrument source response check in the same area where the instrument’s background reading and QC check were performed. If additional instrument background checks are required prior to or during the actual survey, response checks are not required to be performed during those times.

6.4.2 Obtain the Portable Instrument Response Check Sheet assigned to the instrument/probe to be used. Source reference readings for alpha and beta are available from the Instrument QC Check Sheet (FRN-0006), if necessary.

6.4.3 If the Portable Instrument Response Check Sheet is to be continued to another response check sheet, obtain a blank check sheet and write “Continuation” in the comments section of the sheet.

Indicate the correct page of page number. Transfer applicable information to the new sheet.

6.4.4 Record the date and time of the source response check in the applicable block on the next available line.




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6.4.5 Obtain the source(s) identified on the Portable Instrument Response Check Sheet. Use of a source jig system (if available) is preferred over a non-jigged source.

6.4.6 If applicable, select the desired scale on the instrument.

6.4.7 Place the detector next to the source (or source jig). Detector to source alignment (geometry of the detector to source) is critical, and shall duplicate the alignment used during the initial QC check of the instrument.

6.4.8 Obtain a source reading.

6.4.9 Record the source reading in the correct “Reading” box.

6.4.10 Move the detector away from the source.

6.4.11 If the instrument’s source reading is outside of the Acceptable Range:

Record “unsat” in the remarks section of the form. Notify the RSO.

6.4.12 Sign your initials under the “Initials” block for each row of readings you have recorded on the form.

6.4.13 Return source(s) to their designated storage location.

6.5 Instrument Use

6.5.1 Operate the instrument in accordance with the manufacturer’s operation manual and the applicable RPOs.

6.5.2 If the instrument is damaged during use, appears to be functioning improperly, or is being used while out of calibration:

Leave the area where the survey is being performed immediately. Stop using the instrument. Notify the RSO immediately. Return the instrument to the instrument lab or designated storage location.

6.5.3 When finished using the instrument (for the shift):

Verify the instrument is radiologically clean.




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Perform a source response check. If the instrument fails the “post-operational” source response check, contact the RSO immediately.

Ensure the instrument is turned off and return it to the Instrument Lab or designated storage location.

6.6 Instrument Failure

6.6.1 If a portable radiological survey instruments fails to pass any pre-operational check, post-operational check, or fails during use:

Do NOT use the instrument. Place a tag on the instrument identifying it as “out-of-service” or “out-of-

calibration.” Report the out of service condition to the RSO.

6.6.2 Return the instrument to the Instrument Lab or designated storage location.

6.6.3 Terminate the Portable Instrument Response Check Sheet for that instrument by drawing a diagonal line through the remaining blank lines on the form. Sign and date the diagonal line.


The RSO shall review Portable Instrument Response Check Sheets at least monthly. Any errors found shall be brought to the attention of the HPT making the entry and corrected.

8. RECORDS

Portable survey instrument and instrument calibration/QC documents and/or records shall be stored, arranged, indexed, retained, retrieved, and disposed of in accordance with this procedure and applicable document regulations and requirements.

Form FRN-0005, Portable Instrument Response Check Sheet can be associated with this procedure.

9. REFERENCES






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ANSI N323A, “Radiation Protection Instrumentation Test and Calibration, Portable Survey Instruments,” 1997.


RPO-103, “Radiation Protection Audits, Assessments and Oversight.”

RPO-106, “Radiological Training and Qualification.”

RPO-201, “Operation of Portable Radiological Survey Instruments.”

RPO-204, “Calibration and Quality Control of Portable Radiological Survey Instruments.”

RPO-301, “Radiological Surveys.”

10. APPENDIXES

None

ATTACHMENT 6 RPO-204, Calibration and Quality Control of Portable

Radiological Survey Instruments

RPO-204 Rev. 0

Calibration and Quality Control of Portable Radiological Survey Instruments for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project




Signature:

CALIBRATION AND QUALITY CONTROL OF PORTABLE RADIOLOGICAL SURVEY

INSTRUMENTS FOR THE LUCKEY FORMERLY UTILIZED SITES REMEDIAL ACTION PROGRAM

REMEDIATION PROJECT


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REMEDIATION PROJECT


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Table of Contents

1. PURPOSE ..............................................................................................................................4

2. APPLICABILITY ..................................................................................................................4



3.2 Prerequisites ...............................................................................................................4

4. GENERAL .............................................................................................................................5

4.1 Equipment ..................................................................................................................5



4.4 Revisions ....................................................................................................................5

5. DEFINITIONS .......................................................................................................................5

6. PROCEDURE ........................................................................................................................6

6.1 General Information ...................................................................................................6

6.2 Calibration of Portable Survey Instruments ...............................................................6

6.3 Quality Control Limits ...............................................................................................6

7. Quality Assurance ..................................................................................................................8

8. RECORDS .............................................................................................................................8

9. REFERENCES .......................................................................................................................8

10. APPENDIXES .......................................................................................................................9



REMEDIATION PROJECT


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1. PURPOSE

The purpose of this procedure is to provide instruction for the calibration and quality control of portable radiological survey instruments.

2. APPLICABILITY

This procedure applies to Portage management, supervisors, individuals and contractors that perform calibration or Quality Control (QC) checks of portable radiological survey instruments where their work assignment is controlled by Portage.






• Ensure portable survey instruments are calibrated per this procedure and the manufacturer’s operating manual.

• Ensure that quality control limits are accurately calculated and documented.


• Exercise appropriate ALARA techniques when using radioactive sources.

• Not use portable survey instruments that fail calibration or do not meet QC check requirements.

3.2 Prerequisites

Portable radiation monitoring instrument being QC checked shall be in calibration.

HPT shall ensure that the instrument is operated with the probe it was calibrated with, or that the instrument is designed to be operated with a variety of other calibrated “smart” type probes.



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4. GENERAL

4.1 Equipment

Various portable radiation and contamination survey instruments

Various radioactive sources and source jigs


Not applicable.


Direct probe contact with the radioactive check source surface can damage or disturb the protective coating and/or radioactive material of the radioactive check source surface and/or spread radioactive material to the detector/probe.

Unexplainable or out of character changes in background count or dose rates may be the result of a damaged or contaminated detector/probe or unidentified radiation interference.

Instruments that are out of calibration may function improperly or respond falsely. Do not use an instrument or detector that is out of calibration.

Radioactive sources that are not permanently attached to the instrument shall be removed prior to shipment.

Disconnect the battery or secure the power switch in the off position prior to shipment.

Upon receipt of new instruments, after instrument repair or calibration; new quality control limits shall be established in accordance with Section 6.3 of this procedure prior to instrument use.

4.4 Revisions


5. DEFINITIONS

See RPO Glossary.



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6. PROCEDURE

6.1 General Information

6.1.1 Calibrate portable survey instruments, utilized for radiation protection purposes, at least annually or following instrument maintenance, repair, or adjustment likely to affect the primary calibration.

6.1.2 Perform instrument calibration and QC checks according to this procedure and instructions or other guidance documents reviewed and approved by the RSO.

6.1.3 Perform instrument calibrations using standard sources traceable to NIST.

6.1.4 A list of all portable survey instruments shall be maintained. The list shall contain the following information, as a minimum:

• Instrument Manufacturer • Instrument Model • Instrument Type • Instrument Serial No. • Calibration Due Date • Instrument Status

6.2 Calibration of Portable Survey Instruments

6.2.1 Return portable survey instruments due for calibration to the instrument lab/locker for calibration.

6.2.2 Perform a contamination survey on all portable survey instruments that will be sent off site if there is a potential for the instrument to be contaminated.

6.2.3 Send portable survey instruments to a commercial calibration service, or perform calibration in accordance with approved procedures.

6.2.4 Upon return of calibrated portable survey instrument, establish QC limits in accordance with Section 6.3 of this procedure.

6.3 Quality Control Limits

6.3.1 Complete the upper section of the Instrument QC Check Sheet.



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6.3.2 Select an appropriate counting source and place it in the proper geometry for counting.

NOTE: For certain instruments, a jig must be utilized. If a jig is utilized, indicate its use on the QC check sheet.

6.3.3 For instruments with scaler counting features, place the instrument probe over the QC source and initiate the counting cycle (minimum of 1 minute). Record the results on the Instrument QC Check Sheet. Repeat the count for a total of five readings.

6.3.4 For instruments with an analog readout, place the instrument probe over the QC source, allow the meter reading to stabilize, and record the reading on the QC Check Sheet. Repeat the count for a total of five readings.

6.3.5 Obtain an average of the five readings and record on the Instrument QC Check Sheet.

6.3.6 Establish an upper and lower QC response value by multiplying the average by 20%. Add the results to the average to obtain an upper QC limit and subtract the value from the average to obtain the lower QC limits.

6.3.7 Record the QC values and the source used on the Portable Instrument Response Check Sheet used for the instrument.

6.3.8 Record the QC values on an indelible label and attach the label to the instrument.

6.3.9 Attach the instrument QC Check Sheet to the calibration certificate and place in the appropriate instrument file.

6.3.10 Complete all other required information on the Portable Instrument Response Check Sheet:

• Instrument Model • Instrument Serial Number • Probe Type • Probe Serial Number • Instrument Calibration Date • Instrument Calibration Expiration (Due) Date



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• Response Check Location • Check Source(s) Identification Number

6.3.11 Place the Portable Instrument Response Check Sheet in the Response Check Logbook or designated location.

6.3.12 Perform the QC check with the source that will be used during source response checks. For guidance on source selection, contact the RSO.

6.3.13 If more than one source is required to be used for an instrument, repeat step 6.3.2 through 6.3.9 for each source used.

6.3.14 Return source(s) to their proper storage location.


The RSO shall review QC Instrument Check Sheets. Any errors found shall be brought to the attention of the HPT making the entry and corrected.

The RSO shall review the instrument list quarterly to verify all instruments in use are calibrated.

8. RECORDS

Instrument calibration/QC or related documents and/or records shall be stored, arranged, indexed, retained, retrieved, and disposed of in accordance with this procedure and all applicable document regulations and requirements.

Form FRN-0006, Instrument QC Check Sheet can be associated with this procedure.

9. REFERENCES








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ANSI N323A-1997, “Radiation Protection Instrumentation Test and Calibration, Portable Survey Instruments.”

Regulatory Guide 8.21 “Health Physics Surveys for Byproduct Material at NRC Licensed Processing and Manufacturing Plants.”

10. APPENDIXES

None

ATTACHMENT 7 RPO-205, Counting System Operations

RPO-205 Rev. 0

Counting System Operations for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project




Signatu

COUNTING SYSTEM OPERATIONS FOR THE LUCKEY FORMERLY UTILIZED SITES REMEDIAL

ACTION PROGRAM REMEDIATION PROJECT


RPO-205 0 2 of 13






RPO-205 0 3 of 13

Table of Contents

1. PURPOSE ..............................................................................................................................5

2. APPLICABILITY ..................................................................................................................5



3.2 Prerequisites ...............................................................................................................5

4. GENERAL .............................................................................................................................5

4.1 Equipment ..................................................................................................................5



4.4 Revisions ....................................................................................................................6

5. DEFINITIONS .......................................................................................................................6

6. OTHER ...................................................................................................................................6

7. PROCEDURE ........................................................................................................................6

7.1 Chi-Square Test ..........................................................................................................6

7.2 Instrument Background Determination ......................................................................7

7.3 Determination of Counting Efficiencies ....................................................................8

7.4 Acceptable Source Range Calculation .......................................................................9

7.5 Counting System Source Response Checks .............................................................10

7.6 Minimum Detectable Activity (MDA) .....................................................................12


9. RECORDS ...........................................................................................................................13




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10. REFERENCES .....................................................................................................................13

11. APPENDIXES .....................................................................................................................13




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1. PURPOSE

The purpose of this procedure is to provide instruction for the performance of post-calibration and daily operational tests and checks for counting system instruments.

2. APPLICABILITY

This procedure applies to Portage management, supervisors, individuals and contractors that manage and use alpha/beta-gamma counting instrumentation where their work assignment is controlled by Portage.







• Ensure that the alpha/beta-gamma counting system is calibrated prior to use.

• Review instrument test results and control charts monthly or as they are completed.

3.2 Prerequisites

The alpha/beta-gamma counting instrument must be calibrated and in proper functioning condition prior to the performance of post-calibration and daily operational tests and checks.

4. GENERAL

4.1 Equipment

Applicable alpha/beta-gamma counting system instrument and ancillary operational equipment.

Applicable radioactive sources used for instrument plateau determination, efficiency determination and source response checks.




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Not applicable.


None.

4.4 Revisions


5. DEFINITIONS

See RPO Glossary.

6. OTHER

The Chi-Squared test is used to determine if fluctuations in the counting system measurements are statistical in nature or are caused by a counting system malfunction; and are performed monthly on counting system instrumentation that is in use.

The detector efficiency and acceptable source range determinations are performed monthly on counting system instrumentation that is in use.

Instrument background determinations and source response checks are performed daily on counting system instrumentation that is in use. Instrument background determinations and source response checks are not required when counting system instrumentation is not used.

7. PROCEDURE

7.1 Chi-Square Test

7.1.1 Select an appropriate radioactive check source that will produce greater than 500 cpm and is similar in geometry, activity and energy to the media that is being counted on the counting system.

7.1.2 Place the source in the counting system sample holder and load the sample into the counting system.




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7.1.3 Perform 20 1-minute counts to obtain ( ix ).

7.1.4 Sum the 20 results and divide by 20 to obtain the count average ( x ).

7.1.5 Subtract ( x ) from each of the 20 1-minute counts ( ix ) and square the differences [( ix- x )2].

7.1.6 Sum the squares [S( ix - x )2].

7.1.7 Divide the sum of the differences of the squares by the average cpm to determine 2χ .

xxxi∑=

22 ) - (

χ

7.1.8 Verify that the acceptable chi-square value is between: 8.91 to 32.85.

a. IF the Chi-Squared value is outside the 8.91 to 32.85 values, THEN repeat the Chi-Squared test.

b. IF the repeat test does not fall within the 8.9 to 32.9 values, THEN remove the instrument from service and contact the RSO, AND have the instrument repaired/calibrated prior to use.

7.1.9 Record Chi-Squared test data on FRN-0049a, Counting System Chi-Squared Test Data Sheet or equivalent data sheet.

7.1.10 Remove the source(s) from the counting system.

7.2 Instrument Background Determination

7.2.1 Place a clean smear or air sample filter (counting medium) into an empty planchette holder or onto the counting system sample holder, if a planchette is not designed to be used for the counting system (e.g., for the Eberline HandECount).

7.2.2 Position the clean counting medium into the counting system.

7.2.3 Count the blank counting medium for 20 minutes.

7.2.4 Calculate the background count rate (in cpm) by dividing the gross count rate by 20 minutes for the instrument.




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7.2.5 Record the alpha/beta-gamma background count rates on FRN-0049b, Counting System Set-up Data Sheet (or equivalent data sheet) for initial counting system setup or on FRN-0049c/d, Alpha Counting System Daily Check Data Sheet and Beta-Gamma Counting System Daily Check Data Sheet (respectively) during daily routine counting operations.

7.2.6 Graph the results of the alpha/beta-gamma background count rates on FRN-0049e/f, Alpha Background Control Chart and Beta-Gamma Background Control Chart, respectively on the day of the month the count was performed.

a. IF the background count is the first count for the instrument (i.e., returned from calibrations, instrument moved to new counting location, or not used within the past month), THEN write the count result adjacent to the bolded-black line in the “Write in ALPHA BACKGROUND COUNTS” area and place a legible dot on the bolded-black line at the corresponding day of the month the count was performed. OTHERWISE, place a legible dot on the corresponding count result (“Y” axis) and day on the graph.

b. IF the “Y” axis of the graphs have not been divided up and labeled (cpm), THEN label each non-bolded horizontal line by adding an additional 5 percent of the original count result to each line for the graph lines located above the bolded-black line and subtracting an additional 5 percent of the original count result to from each line of the original count result for the graph lines located below the bolded-black line.

7.2.7 Remove the blank counting medium from the counting system.

7.3 Determination of Counting Efficiencies

NOTE: If the Chi-Squared test and efficiency calculation are being performed at the same time, then use the source count data obtained in Step 6.1.4 and omit Steps 6.3.1 through 6.3.3 below.






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7.3.3 Count the source for 20 minutes.

7.3.4 Record the gross 20 minute source count from Steps 7.3.1 through 7.3.3 or the Step 7.4.1 value on FRN-0049b, Counting System Set-Up Data Sheet or equivalent.

7.3.5 Calculate the gross count rate (in cpm) by dividing the gross counts by 20 minutes for the instrument and record the alpha/beta-gamma count rates on FRN-0049b, Counting System Set-Up Data Sheet.

7.3.6 Subtract the background count rate obtained in Step 7.2.4, from the gross count rate (cpm) to obtain the net count rate (cpm) and record on FRN-0049b, Counting System Set-Up Data Sheet.

7.3.7 Record the source activity in dpm (2.22 x 106 dpm/uCi) on FRN-0049b, Counting System Set-Up Data Sheet.

7.3.8 Divide the net count rate (cpm) by the source activity (dpm) to obtain counting system efficiency.

7.3.9 Record the efficiency of the counting system on FRN-0049b, Counting System Set-Up Data Sheet.


7.4 Acceptable Source Range Calculation

NOTE: If the counting system efficiency and acceptable source ranges are being determined at the same time, then the source count data obtained in Steps 6.3.4 may be used for Rg in this procedure and Steps 6.4.1 through 6.4.4 may be omitted.Quality Assurance



7.4.3 Count the source for 20 minutes and record the gross 20 minute source count results on FRN-0049b, Counting System Set-Up Data Sheet or equivalent.

7.4.4 Calculate the gross count rate ( gR ) by dividing the gross count rate by 20 minutes for




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the instrument and record the alpha/beta-gamma count rates on FRN-0049b, Counting System Set-Up Data Sheet.

7.4.5 Calculate one standard deviation (+ 1σ) as follows:

201bg RR

+=σ

where: σ = standard deviation of the net count rate

gR = source gross count rate (cpm)

bR = background count rate (cpm)

7.4.6 Calculate two standard deviations (+ 2σ) by multiplying the + 1σ by 2.

7.4.7 Calculate the net count rate (cpm) by subtracting the background count rate from the gross source count rate and record on FRN-0049b, Counting System Set-up Data Sheet.

7.4.8 Calculate the + 1σ acceptable source ranges by subtracting the 1σ value from the net count rate (cpm) to determine the lower limit and by adding the 1σ value to the net count rate (cpm) to determine the upper limit.

7.4.9 Calculate the + 2σ acceptable source ranges by subtracting the 2σ value from the net count rate (cpm) to determine the lower limit and by adding the 2σ value to the net count rate (cpm) to determine the upper limit.

7.4.10 Record the results of the calculations on FRN-0049b, Counting System Set-Up Data Sheet.


7.5 Counting System Source Response Checks

7.5.1 Select an appropriate check source that will produce greater than 500 cpm and is similar in geometry, activity and energy to the media that is being counted on the counting system.

a. IF counting system source response checks have been performed and the average source count rates and the 1σ and 2σ + limits have been established for the instrument,




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THEN use the same check source to perform concurrent response checks. 7.5.2 Place the source in the counting system sample holder and load the sample into the

counting system.

7.5.3 Perform a 1-minute count or longer, as required by the project Radiological Engineer.

7.5.4 Record the alpha and/or beta-gamma source counts on FRN-0049c/d, Alpha Counting System Daily Check Data Sheet and Beta-Gamma Counting System Daily Check Data Sheet (respectively).

7.5.5 Calculate the alpha and/or beta-gamma source count rates (cpm) by dividing the gross count by the number of minutes the source was counted and record the alpha and/or beta-gamma count rates (cpm) on FRN-0049c/d, Alpha Counting System Daily Check Data Sheet and Beta-Gamma Counting System Daily Check Data Sheet (respectively).

7.5.6 Verify that the source count rates are within the +2σ source range limit identified on FRN-0049c/d, Alpha Counting System Daily Check Data Sheet and Beta-Gamma Counting System Daily Check Data Sheet (respectively).

a. IF the source count rate is within the +2σ source range limit, THEN write “SAT” in the SAT/UNSAT column of FRN-0049c/d, Alpha Counting System Daily Check Data Sheet and Beta-Gamma Counting System Daily Check Data Sheet (respectively).

7.5.7 IF the source count rate is between the +1σ and +2σ source range limit for greater than three days in a row,

THEN perform a Chi-Squared check on the instrument.

7.5.8 IF the source count rate is outside the +2σ source range limit, THEN count the source two more times.

a. IF two of the three counts rates are greater than the +1σ source range limit, THEN perform a Chi-Squared check on the instrument.

b. IF two of the three counts rates are within the +1σ source range limit, THEN write “SAT” in the SAT/UNSAT column of FRN-0049c/d, Alpha Counting System Daily Check Data Sheet and Beta-Gamma Counting System Daily Check Data Sheet (respectively). OTHERWISE, write “UNSAT” in the SAT/UNSAT column of FRN-0049c/d, Alpha Counting System Daily Check Data Sheet and Beta-Gamma Counting




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System Daily Check Data Sheet (respectively), tag the instrument out of service and inform the project Radiological Engineer/RSO.

7.5.9 Graph the results of the alpha/beta-gamma source count rates on FRN-0049g/h, Alpha Source Response Check Control Chart and Beta-Gamma Source Response Check Control Chart, respectively, on the day of the month the count was performed by placing a legible dot on the corresponding “Y” axis count result (cpm) on the graph.

a. IF the source response count is the first count for the instrument (i.e., returned from calibrations, instrument moved to new counting location, or not used within the past month), THEN write the average source count rates and the 1σ and 2σ + limits on the “Y” axis of the graph taken from FRN-0049b, Section 6.4 above.


7.6 Minimum Detectable Activity (MDA)

7.6.1 Calculate the MDA for counting instrumentation using the formula below unless previously determined for specific counting system instrumentation.

))((

)1(29.33

s

b

ssb

tefftt

tCMDA

++

=

where:

st = sample count time (min)

bt = background count time (min)

bC = background count rate (cpm) eff = instrument efficiency (cpm/dpm)

7.6.2 Record counting system MDA for counting system on FRN-0049c/d, Alpha Counting System Daily Check Data Sheet and Beta-Gamma Counting System Daily Check Data Sheet (respectively).




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The RSO shall review the various counting system data sheets created as a result of this procedure. Any errors found shall be brought to the attention of the HPT making the entry and corrected.

Counting system data sheets created as a result of this procedure shall be retained in accordance with Reference 3.3

This procedure and all related documents shall be made available as part of the annual Health Physics audit program.

9. RECORDS

Alpha/beta-gamma counting system documents and/or records shall be stored, arranged, indexed, retained, retrieved, and disposed of in accordance with this procedure and all applicable document regulations and requirements. Records that are generated as a result of the requirements of federal regulations must be retained until the federal regulation authorizes their disposition.

10. REFERENCES




NUREG-1507, “Minimum Detectable Concentrations With Typical Radiation Survey Instruments for Various Contaminants and Field Conditions,” June 1998.

11. APPENDIXES

None

ATTACHMENT 8 RPO-208, Operation and Calibration of Portable Air Samplers

RPO-208 Rev. 0

Operation and Calibration of Portable Air Samplers for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project




Signatur

OPERATION AND CALIBRATION OF PORTABLE AIR SAMPLERS FOR THE LUCKEY FORMERLY



RPO-208 0 2 of 12






RPO-208 0 3 of 12

Table of Contents

1. PURPOSE ..............................................................................................................................4

2. APPLICABILITY ..................................................................................................................4



3.2 Prerequisites ...............................................................................................................4

4. GENERAL .............................................................................................................................5

4.1 Equipment ..................................................................................................................5



4.4 Revisions ....................................................................................................................5

5. DEFINITIONS .......................................................................................................................5

6. PROCEDURE ........................................................................................................................5

6.1 Portable Air Sampler General Information ................................................................5

6.2 Portable Air Sampling Operation ...............................................................................6

6.3 Portable Air Sampler Calibration ...............................................................................8

6.4 Temperature and Pressure Calculations ...................................................................11


8. RECORDS ...........................................................................................................................11

9. REFERENCES .....................................................................................................................11

10. APPENDIXES .....................................................................................................................12




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1. PURPOSE

The purpose of this procedure is to provide general instruction for the operation and calibration of portable air samplers.

2. APPLICABILITY

This procedure applies to Portage management, supervisors, individuals and contractors that calibrate and operate portable air samplers where their work assignment is controlled by Portage.






• Ensure portable air samplers are calibrated at a frequency not to exceed six months.

• Review the Portable Air Sampler Certificate of Calibration as they are completed.

• Perform periodic air flow measurements and calculations to verify the air sampler is operating in the isokinetic mode when a building’s effluent exhaust stack is being monitored with a portable air sampler.


• Exercise appropriate contamination control techniques during the calibration of internally contaminated air samplers.

3.2 Prerequisites

Not applicable.




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4. GENERAL

4.1 Equipment

Air sampling instrumentation.

Air sample filter media/material.

Appropriate air flow calibrator unit.

Thermometer and barometer (for measuring barometric pressure) as necessary.


Not applicable.


Air monitoring and sampling equipment that has the potential for being contaminated internally shall be properly labeled (e.g., "Caution: Internal Contamination" or "Potential Internal Contamination") and treated/handled with accordingly.

4.4 Revisions


5. DEFINITIONS

See RPO Glossary.

6. PROCEDURE

6.1 Portable Air Sampler General Information

6.1.1 If using the portable sampler for breathing zone coverage, ensure the filter/cartridge location will be in an area which is representative of the breathable air in the work location. Contact the RSO for guidance.

6.1.2 Obtain approval from the RSO if an extension sampling tubing is to be used when sampling.




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6.1.3 For general area sampling, the sampler may be operated using the same filter for several days as needed. If used for breathing zone sampling, the sampler should be operated only when work is being performed and should not be operated longer than a single work-shift time frame.

6.1.4 For sampling operations, the sample flow rate should not be allowed to drop below 50% of the initial sampling value. If the sampling flow rate drops below 50% of initial sampling flow rate, stop the sampler and investigate the cause of the low flow rate.

• If the sampler filter medium is clogged, change the sampler filter and verify correct flow rate after restart.

• If the cause is unknown or cannot be corrected, discontinue use of the sampler and notify the RSO immediately.

• Analyze the filter medium removed from the unit as appropriate.

6.1.5 Ensure the flow rate of the sampler will be adequate to meet the required sampling volume for the radionuclide(s) of concern and the expected job duration. Contact the RSO or Radiological Engineer as needed.

6.1.6 When a building’s effluent exhaust stack is being monitored with a portable air sampler, the sampler should normally be operated so that it is sampling in an isokinetic mode. Contact the RSO or Radiological Engineer as needed.

6.1.7 When in continuous use, air samplers shall be inspected daily and the inspection shall be recorded on the Portable Air Sampler Inspection Log (form FRN-0017).

6.2 Portable Air Sampling Operation

6.2.1 Obtain air sampling equipment.

6.2.2 Perform a pre-operational check of the air sampler using the guidance below:

• Inspect the sampler, including power cord for physical damage. If damage is found, DO NOT use the sampler.

• Verify sampler calibration is current. If the calibration sticker is missing or the calibration date has expired, DO NOT use the sampler.

• Inspect any rubber O-rings on the sampler. If damaged or missing, replace with new O-rings or DO NOT use the sampler.




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• Inspect the sampler head filter backing screen for damage. If damaged excessively, replace the sampler head.

6.2.3 If the sampler does not pass the pre-operational checks listed above, place an out-of-service tag on it and return it to the instrument lab or instrument check out locker.

6.2.4 Log completed checks in the Portable Air Sampler Inspection Log.

6.2.5 Install the appropriate filter media in the sampler head. Contact the RSO for guidance, as necessary.

6.2.6 Connect the sampler to an AC power supply if AC operated.

6.2.7 Turn the power switch ON.

6.2.8 Verify proper air flow through the filter media by observing air flow indication on the samplers flow rate meter.

6.2.9 Prior to placing the air sampler in service, check for air in-leakage into sampling lines and connection unions by momentarily blocking the sampler’s inlet after starting the unit.

• Air flow indication should drop towards “zero” on the air flow indicator (roto-meter or electronic flow indicator integrated into the unit’s display panel). If air flow does not drop when the inlet is blocked, investigate for source of air in-leakage and correct.

• If air in-leakage problem cannot be corrected, place an out-of-service tag on the sampler and inform the RSO.

6.2.10 Document completed checks on the Portable Air Sampler Inspection Log.

6.2.11 Obtain required air sample.

6.2.12 When finished air sampling, observe the air flow rate prior to turning off the air sampler. If the air sampler has an integrated timer/flow recorder, obtain the volume of air moved through the sampler air filter medium. Turn the power switch to the OFF position and observe the time the unit was turned off.

6.2.13 Remove the filter media and process in accordance with established Site or Field Procedure requirements. Contact the RSO for guidance, as necessary.




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6.2.14 Document air sample information and results in accordance with RPO-303 or with established Site or Field Procedure requirements.

6.2.15 Return air sampling equipment to its proper location.

NOTE: Air sample equipment may be externally or internally contaminated after use in an Airborne Radioactivity Area or potential Airborne Radioactivity Area. If air sampler contamination is possible or suspect, treat the air sampler as a contaminated piece of equipment until proven otherwise.

6.3 Portable Air Sampler Calibration

6.3.1 Obtain a Portable Air Sampler Certificate of Calibration sheet (form FRN-0016). Record pre-calibration information on the form.

6.3.2 Remove the filter head from the air sampler being calibrated and connect the air flow calibrator to it.

6.3.3 Install a new sample medium filter in the filter head and reinstall the filter head on the inlet to the air flow calibrator (see simplified flow calibrator setup diagram below). Turn on the air flow calibrator but do not turn on the air sampler at this time.

Air Flow

6.3.4 For the F&J Calibrator Model D-812 or similar calibrators, press the select button to read temperature (F) and barometric pressure (mmHg). Record the readings on the Certificate of Calibration. For calibrators that do not have this feature, measure the temperature and barometric pressure of the area where the calibration is being performed, and record these readings on the Certificate of Calibration.

Calibrator Air Sampler

Filter Head




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NOTE: Most air flow calibrators read accurately only at 70 (+/-5) deg. F and 760 (+/-5) mmHg. If the air flow calibrator does not automatically correct for temperatures and pressures outside of the 70 (+/-5) deg. F and 760 (+/-5) mmHg range, manual corrections to the air flow rate indicated must be made to adjust for temperatures and pressures (see Section 6.4).

6.3.5 Select the appropriate flow units (lpm/cfm) on the air flow calibrator.

6.3.6 Start the air sampler.

NOTE: Calibration of the air sample flow meter is performed by comparing three flow rate points to the calibrator’s three reference flow rate points.

6.3.7 To determine the high, midrange, and low flow rate points:

• Adjust the airflow on the air sampler pump to its maximum flow rate.

• Observe the air sampler’s flow rate on the calibrator and choose the next lower whole number as the high flow rate calibration point (i.e., if maximum flow is 4.8 cfm, then choose 4.0 cfm as the high flow rate calibration point).

• Record on the Certificate of Calibration sheet.

• Determine the low flow rate calibration point by choosing the lowest positive (i.e., not zero) value clearly readable on the air sample flow meter. Record on the Certificate of Calibration sheet.

• Determine the midrange flow rate calibration point by subtracting the low flow rate calibration point value from the high flow rate calibration point value, divide by two (2), then add to the low flow rate calibration point value. Record on the Certificate of Calibration sheet.

NOTE: Due to flow meter fluctuations at low flow conditions, it may be necessary to select a higher low flow rate calibration point value to obtain a more accurate calibration. Contact the RSO for guidance if necessary.

6.3.8 Adjust the air sampler’s flow rate on the air sampler until the calibrator reads the high flow rate calibration point selected in 6.3.7. Record the air flow rate value from the air sampler’s flow meter on the Certificate of Calibration in the as-found column.

6.3.9 Adjust the air sampler’s flow rate on the air sampler until the calibrator reads the midrange flow rate calibration point selected in 6.3.7. Record the air flow rate




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value from the air sampler’s flow meter on the Certificate of Calibration in the as-found column.

6.3.10 Adjust the air sampler’s flow rate on the air sampler until the calibrator reads the low flow rate calibration point selected in 6.3.7. Record the flow reading from the air sampler’s flow meter on the Certificate of Calibration in the as-found column.

6.3.11 Compare the recorded as-found flow rates to the calibrator flow rate values.

• The as-found flow rates must be +/- 20% of the calibrator flow rate values for an acceptable calibration.

• Notify the RSO if the as-found values are outside of the +/-20% calibrator flow rate values.

6.3.12 If the as-found values are acceptable and no adjustments are necessary, record the as-found values in the as-left column of the Certificate of Calibration form and complete the form. Attach a new calibration label to the air sampler’s flow rate meter, indicating the date of calibration and the new calibration due date.

6.3.13 If the air sampler’s flow rate meter has a mechanical adjustment, and the calibration as-found values are outside the +/-20% of the calibrator flow rate values (or if as found value is acceptable but adjustment to the flow meter would provide a more accurate reading), adjust the air sampler’s flow rate meter to match the calibrator’s flow rate values and perform steps 6.3.8 – 6.3.10. Record these new flow rates in the as-left column of the Certificate of Calibration and attach a new calibration label to the air sampler’s flow meter indicating the date of calibration and the new calibration due date.

6.3.14 If you are unable to adjust the air sampler’s flow rate meter to within +/- 20% of the calibrator’s flow rate identified values, remove the instrument from service and have it repaired or replaced.

6.3.15 Update the master instrument calibration spreadsheet to reflect the new calibration date.

6.3.16 Complete the Certificate of Calibration and forward to the RSO for review.

6.3.17 If not previously performed, attach a calibration label to the side of the flow meter indicating the air sampler number, date of calibration, and calibration due date (nominally 6 months.)




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6.4 Temperature and Pressure Calculations

6.4.1 If calibration of the air sampler is performed in an area where the temperature and pressure are not within recommended environmental values (70 +/-5 deg. F and 760 +/-5 mmHg), calculate the calibrator’s actual flow rate for standard temperature and pressure (STP) conditions using the following equation:

STP Flow Rate = Displayed Flow Rate 0( ) 460 760

530 ( )ActualTemp F mmHg

actualP mmHg+

× ×

Use this STP corrected flow rate during the calibration process (steps 6.3.8 – 6.3.13).

6.4.2 Note any temperature/pressure corrections made on the Certificate of Calibration sheet.


The RSO shall review the Portable Air Sampler Certificate of Calibration as they are completed.

8. RECORDS

Air sampler calibration documents and/or records shall be stored, arranged, indexed, retained, retrieved, and disposed of in accordance with this procedure and applicable document regulations and requirements.

9. REFERENCES




NRC Regulatory Guide 8.25 “Air Sampling In the Workplace.”

F&J Technical Manual for Calibrator Model D-812.




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10. APPENDIXES

None

ATTACHMENT 9 RPO-209, Operation and Calibration of

Lapel Air Samplers

RPO-209 Rev. 0

Operation and Calibration of Lapel Air Samplers for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project




Signature

OPERATION AND CALIBRATION OF LAPEL AIR SAMPLERS FOR THE LUCKEY FORMERLY



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Table of Contents

1. PURPOSE ..............................................................................................................................5

2. APPLICABILITY ..................................................................................................................5



3.2 Prerequisites ...............................................................................................................5

4. GENERAL .............................................................................................................................6

4.1 Equipment ..................................................................................................................6



4.4 Revisions ....................................................................................................................6

5. DEFINITIONS .......................................................................................................................6

6. OTHER ...................................................................................................................................6

7. PROCEDURE ........................................................................................................................7

7.1 Victoreen Personal Air Sampler Calibration Preparation ..........................................7

7.2 Mini-Buck Calibrator Preparation ..............................................................................7

7.3 Calibration Setup ........................................................................................................7

7.4 Initial Calibration .......................................................................................................8

7.5 Victoreen Personal Air Sampler Battery Check .........................................................9

7.6 Final Calibration .........................................................................................................9

7.7 Calibration Criteria ...................................................................................................10




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7.8 Documentation and Labeling ...................................................................................10

7.9 Victoreen Personal Air Sampler Operation ..............................................................10


9. RECORDS ...........................................................................................................................12

10. REFERENCES .....................................................................................................................12

11. APPENDIXES .....................................................................................................................12

APPENDIX A General Sampler and Calibrator Information ........................................................13




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1. PURPOSE

The purpose of this procedure is to provide instruction for the operation and calibration of lapel air samplers.

2. APPLICABILITY

This procedure applies to Portage management, supervisors, individuals and contractors that operate or calibrate lapel air samplers where their work assignment is controlled by Portage.






• Ensure that all survey documentation is reviewed in a timely manner.

• Determine the radiological instrumentation to be utilized to perform radiological surveys, if necessary.

• Ensure lapel air samplers are calibrated prior to use.

• Review the Lapel Air Sampler Certificate of Calibration as they are completed.




3.2 Prerequisites

Not applicable.




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4. GENERAL

4.1 Equipment

Lapel air samplers and associated filter media

Lapel air sampler calibrator and associated equipment/supplies


Not applicable.


This procedure is specifically written for the Victoreen Personal Air Sampler (Model 08-430) and the Mini-Buck Calibrator (Model M-30). If other lapel air sampling equipment is used, it must be operated and calibrated in accordance with the manufacturer’s operating instructions.

Lapel air samplers are used to determine the quality of the air breathed for only the wearer, they are not for general area air sampling/monitoring.

4.4 Revisions


5. DEFINITIONS

See RPO Glossary.

6. OTHER

6.1.1 Use lapel air samplers:

• As required by the RWP.




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7. PROCEDURE

NOTE: This procedure is specifically written for the Victoreen Personal Air Sampler (Model 08-430) and the Mini-Buck Calibrator (Model M-30). If other lapel air sampling equipment is used, it must be operated and calibrated in accordance with the manufacturer’s operating instructions.

7.1 Victoreen Personal Air Sampler Calibration Preparation

7.1.1 Turn the lapel sampler switch to the “ON” position and note any abnormal noises or vibration. If abnormal noises or vibrations are noted, label the lapel sampler “Out of Service” and notify the RSO.

7.1.2 Discharge the lapel sampler battery pack until you notice the pump is barely running, then turn the switch off.

7.1.3 Recharge the lapel sampler batteries for at least 15 hours. Make sure the lapel sampler switch is turned to the “OFF” position while charging the batteries.

7.2 Mini-Buck Calibrator Preparation

7.2.1 Visually inspect the calibrator flow cell for any abnormal objects (i.e., small dirt particles) that might interfere with the bubble test. If abnormal objects are noted notify the RSO.

7.2.2 Remove the hose fitting covers (black caps) from the lower and upper ports of the calibrator.

7.2.3 Verify that the bottom of the flow cell is covered with calibrator soap. If more soap is required, pour a small amount of calibrator soap through the lower port to cover the bottom of the flow cell.

7.2.4 Connect the calibrator to an outlet using the calibrator A/C adapter charger.

7.2.5 Press the “ON” button and verify the flow rate display is showing “0000”. If “0000” is not displayed notify the RSO.

7.2.6 Turn the calibrator off by pressing the “OFF” button.

7.3 Calibration Setup

7.3.1 Disconnect the lapel sampler charger from the lapel sampler and turn the lapel




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sampler switch to the “ON” position, allow the pump to run for approximately five minutes to stabilize. Perform this step prior to connecting the lapel sampler to the calibrator because air flow can dry the calibrator center tube.

7.3.2 Turn the lapel sampler off after the five minute run time is complete.

7.3.3 Attach a short length of 1/4” hose, with a standard lapel sampler filter head and filter, to the lower port of the air flow calibrator.

7.3.4 Connect the lapel sampler to the upper port of the calibrator using 1/4” hose.

7.4 Initial Calibration

7.4.1 Turn on the calibrator by pressing the “ON” button.

7.4.2 Turn on the lapel sampler by pressing the “ON” button.

7.4.3 Document the time you started the calibration in the Initial Calibration row of Section III of form FRN-0044.

7.4.4 Using a stopwatch, determine the elapsed time (in seconds) required for the lapel sampler to register 100 digits and record the time in the initial calibration line of Section III of form FRN-0044.

7.4.5 Depress the calibrator plunger into the cell and quickly release. Different flow rates can require quicker or slower release of the button.

7.4.6 Carefully observe the bubble passing through the sensor zone.

• A single straight bubble is required for an accurate test.

• The calibration will be invalid if bubbles, going up the center tube, are not horizontal.

7.4.7 Wait until the test result on the display stops flashing and record the flow rate (in LPM) on a separate sheet of paper.

7.4.8 Repeat steps 7.4.5 through 7.4.7 four additional times and calculate the average flow rate for five tests. Record the average flow rate on the initial calibration line of Section III of form FRN-0044.




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NOTE: If a series of “EEEE” is displayed while performing the lapel sampler calibration, the test is invalid and steps 6.4.5 through 6.4.7 must be repeated. If the error “EEEE” occurs three times for a single calibration, notify the RSO.

7.4.9 Calculate the conversion factor (ml/digit) using the equation below:

Conversion factor (ml/digit) = (FxT)/6 Where F = Average flow rate (LPM) T = Elapsed time (seconds)

7.4.10 Round up the calculated conversion factor to the nearest 1/10 and document it in Section III of FRN-0044.

7.5 Victoreen Personal Air Sampler Battery Check

7.5.1 Turn the lapel sampler off and disconnect the hose from the upper port of the calibrator.

7.5.2 Load a filter on the filter head and verify the filter is centered properly.

7.5.3 Place the grill and cap on the filter head and connect it to the lapel sampler using a 1/4” hose.

7.5.4 Turn on the lapel sampler and allow it to run for a minimum of six hours. A filter and filter head must be connected to the lapel sampler to simulate the actual load on the lapel sampler.

7.5.5 At the completion of the six hours battery check, repeat steps 7.3.3 and 7.3.4 and proceed with Section 7.6.

7.6 Final Calibration

7.6.1 Repeat all steps of Section 7.4 and log in the results in the Final Calibration row in Section III of FRN-0044.

7.6.2 Calculate the average flow rate (LPM) from the Initial and Final Calibration average flow rates and record it in Section III of FRN-0044.

7.6.3 Calculate the average conversion factor from the Initial and Final Calibration average conversion factors and record it in Section III of FRN-0044.




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7.7 Calibration Criteria

7.7.1 The lapel sampler can be placed back in service if the calibration results meet the following criteria:

• The average lapel sampler flow rate is > 4 LPM for the Final Calibration test.

• The difference between the Initial and Final Calibration average flow rates is < 20%.

• No unusual vibrations or noises are noted.

7.7.2 Check the ACCEPTED box on the Certificate of Calibration if the lapel sampler meets the calibration criteria.

7.7.3 Check the REJECTED box on the Certificate of Calibration if the lapel sampler does not meet the calibration criteria and notify the RSO.

7.8 Documentation and Labeling

7.8.1 Complete all applicable sections of the Certificate of Calibration (FRN-0044). Only the non-shaded sections need to be completed.

7.8.2 Attach to the front of the unit a calibration sticker with a calibration due date of three months from the date of calibration.

7.8.3 Attach to the top of the unit a sticker indicating the lapel sampler ID number and the average of the conversion factors (ml/digit).

7.8.4 Submit the Certificate of Calibration to the RSO.

7.9 Victoreen Personal Air Sampler Operation

7.9.1 Obtain a fully charged and calibrated Victoreen personal air sampler and associated sample tubing, head and filter media.

7.9.2 Install the appropriate filter media in the sampler head. Contact the RSO for filter selection guidance, as necessary.

7.9.3 Record the Air Sample Number, Wearer’s Name, and the initial Sampler Air Volume Register Number on form FRN-0009

7.9.4 Have the worker don the sampler and filter head. The sample pump should be




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attached to the user at waist level. The sampler head should be located within one (1) foot of the workers mouth/nose area.

NOTE: Use care to ensure the sample hose is not kinked or place such that it restricts the users movements.

7.9.5 Ensure the sampler head is not covered by any protective equipment (i.e., respirators, bubble hoods, coveralls, etc).

7.9.6 If anti-contamination clothing is being worn, have the worker locate the pump under the clothing (if possible) to protect it from external contamination, with the filter head protruding outside in the lapel.

7.9.7 Instruct the wearer to operate the sampler only during the time the wearer is in the work area.

NOTE: Multiple entries may be made during a shift without changing the filter media. Perform a survey of the lapel sampler head and filter prior to removing from the health physics Restricted Area.

NOTE: The Lapel sampler is calibrated for a maximum total run time of 6 hours, and shall not be used for a period of greater than 6 hours without recharging.

7.9.8 Instruct the worker to start the air sampler pump just prior to entering the work area and turn it off immediately upon exiting the work area.

7.9.9 Record the Sampler Start Time, Sampler End Time, and Sampler Air Volume Register Number start and end numbers.

7.9.10 When the worker is finished using the lapel air sampler, remove the filter media and process in accordance with RPO-303. Record applicable information to complete form FRN-0009.

7.9.11 Perform a contamination survey of the external surface of the lapel air sampler and associated equipment prior to removal from the radiological area. If the sampler is suspect, or contains internal contamination, control the sampler.




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CAUTION: While handling used filter media, take care not to disturb the radioactive material collected on the media. Inappropriate handling will result in inaccurate sample results and the potential or actual spread of radioactive contamination.


The Mini-Buck Calibrator shall be calibrated on yearly basis.

The Lapel Sampler shall be calibrated on quarterly basis.

The RSO shall review the lapel air sampler Certificate of Calibration as they are completed.

9. RECORDS

Lapel air sampler calibration documents and/or records shall be stored, arranged, indexed, retained, retrieved, and disposed of in accordance with all applicable NRC document regulations and requirements.

10. REFERENCES




“Mini-Buck Calibrator (Model M-30) Instruction Manual.”

“Victoreen Personal Air Sampler (Model 08-430) Operating Manual.”

NRC Regulatory Guide 8.25, “Air Sampling in the Workplace.”

RPO-303, “Area Air Sampling.”

11. APPENDIXES

Appendix A, General Sampler and Calibrator Information




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APPENDIX A General Sampler and Calibrator Information

Victoreen Lapel Air Sampler (Model 08-430)

The lapel air sampler is used for sampling the atmosphere breathed by the wearer. It consists of a motor driven pump, battery housing, filter holder/air intake which can be clipped to the lapel, connecting hose, and rechargeable Ni-Cad batteries.

When the lapel air sampler is not in use, it should be connected to the battery charger. Approximately 15 hours is required for a full battery charge. A full battery charge can provide, at a minimum, 6 hours before recharging is required. Prior to calibration, the battery should be discharged and then recharged for at least 15 hours.

The mini-Buck Calibrator (Model M-30)

The mini-Buck calibrator uses the soap film bubble test for measuring the flow rate of gases over a fixed volume per unit time. The flow rate is measured by the time it takes the frictionless soap film to travel from one infrared sensor to the other infrared sensor. The mini-Buck has an automatic shut down within approximately 7 minutes of non-use. The calibrator can be used for sequential tests (averaging readings) or individual tests. During sequential tests, the previous reading is added to the current reading, divided by two, and displayed. If the previous reading differs from the current reading by more than +/- 5%, a series of “EEEE” will appear on the calibrator display, and therefore the test is invalid. Individual tests can be performed by pressing the “ON” button to reset the display to “0000” following each test.

ATTACHMENT 10 RPO-301, Radiological Surveys

RPO-301 Rev. 0

Radiological Surveys for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project




Signature

RADIOLOGICAL SURVEYS FOR THE LUCKEY FORMERLY UTILIZED SITES REMEDIAL ACTION



RPO-301 0 2 of 18






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Table of Contents

1. PURPOSE ..............................................................................................................................5

2. APPLICABILITY ..................................................................................................................5



3.2 Prerequisites ...............................................................................................................5

4. GENERAL .............................................................................................................................6

4.1 Equipment ..................................................................................................................6



4.4 Revisions ....................................................................................................................7

5. DEFINITIONS .......................................................................................................................7

6. PROCEDURE ........................................................................................................................7

6.1 Radiological Survey Techniques ................................................................................7

6.2 Radiation Surveys ......................................................................................................8

6.3 Removable Surface Contamination Survey ...............................................................9

6.4 Large Area Wipe Survey ..........................................................................................10

6.5 Surface Contamination Survey .................................................................................10

6.6 Volumetric Sampling ...............................................................................................12

6.7 Unconditional Release Surveys ................................................................................13

6.8 Personnel Monitoring ...............................................................................................13

6.9 Radiological Survey Documentation .......................................................................13




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8. RECORDS ...........................................................................................................................16

9. REFERENCES .....................................................................................................................17

10. APPENDIXES .....................................................................................................................17

APPENDIX A Personnel Frisking Instructions .............................................................................18




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1. PURPOSE

The purpose of this procedure is to provide instruction for the performance of radiological surveys. These surveys include both radiation and contamination surveys, either routine or special, performed before, during and after radiological work. This procedure also describes the methodology used to document the results of radiological surveys.

2. APPLICABILITY

This procedure applies to Portage management, supervisors, individuals and contractors that perform radiological surveys where their work assignment is controlled by Portage.







• Determine the radiological instrumentation to be utilized to perform radiological surveys, if necessary.





3.2 Prerequisites

Review available survey data if unfamiliar with the facility or area you intend to survey.




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Select and operate portable radiation survey instruments in accordance with applicable RPOs and manufacturer’s operating manuals.

4. GENERAL

4.1 Equipment

Portable and laboratory radiological survey and counting equipment.

Smear/wipe media.

Various anti-contamination clothing used for protection from contamination while performing surveys.


All radiological surveys shall be performed in accordance with ALARA policies and practices, governing work documents, and contamination control practices.

If work area hazards are unknown, or may have changed, obtain current work area hazard information prior to initiation of radiological surveys.


4.3.1 Ensure that instruments and equipment used for quantitative radiation measurements (i.e., dose rate and effluent monitoring) are properly calibrated and quality control checked for the radiation being measured.

4.3.2 When entering areas of unknown radiation levels, select the highest scale available on the survey instrument prior to entry.

4.3.3 If needed for protection against contamination, instruments may be placed in plastic bags or similar devices. For alpha/beta frisking or beta dose rates surveys, insure the plastic protective cover doesn’t interfere with the instrument detector or window.

4.3.4 Only individuals qualified in accordance with Reference 3.5 shall be allowed to perform radiological surveys of record.

4.3.5 Wear appropriate protective clothing when performing surveys in known or suspected Contaminated Areas or when handling potentially contaminated samples or materials.




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4.3.6 Obtain a sufficient number of radiological survey points to adequately characterize the radiological conditions of the area or item. Inaccessible surfaces shall be considered potentially contaminated until proven otherwise. Contact the RSO or Radiological Engineer for clarification, as needed.

4.3.7 Surfaces containing significant amounts of dirt, dust or moisture may result in erroneous survey results. Alpha emitting isotopes present under dirty or painted surfaces will not be detected using standard surveying techniques. Consult with the RSO or Radiological Engineer when there is a potential for these conditions to occur.

4.3.8 Immediately report any abnormal radiological conditions encountered to the RSO.

4.3.9 To make corrections on radiological survey maps, forms, or logs; use a single line strikeout with an initial and date. Enter the correct information beside the strikeout.

NOTE: The use of white-out or other similar material to make corrections on survey forms is not authorized.

4.4 Revisions


5. DEFINITIONS

See RPO Glossary.

6. PROCEDURE

6.1 Radiological Survey Techniques

6.1.1 Perform general area radiation surveys with the instrument’s detector held at waist level.

6.1.2 Perform on-contact radiation surveys with the instrument’s detector held as close as possible to the item being surveyed, without touching the instrument or detector to the item or surface.

6.1.3 When performing radiation surveys, do not make corrections or subtractions for background radiation levels.




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6.1.4 Allow sufficient time for the instrument to respond while conducting radiological surveys. See the instrument’s operating manual or operating procedure for response wait times.

6.1.5 For surface contamination surveys; hold the alpha probe within ¼ inch of the surface and moved at a rate of no greater than one inch per second, and the beta/gamma probe within ½ inch of the surface and moved at a rate of no greater than two inches per second.

6.1.6 Whenever possible, select an instrument with an audible response.

6.1.7 Perform environmental dose rate monitoring using an appropriate dose rate survey meter, reporting dose rate values in micro rem or micro Roentgen per hour.

6.1.8 Report/record radiation dose rate survey results (except as otherwise stated) in millirem per hour (mrem/hr).

6.1.9 Use an instrument with an audible response when monitoring personnel.

6.1.10 Smears containing significant amounts of dirt, dust or moisture may result in erroneous survey results. Consult with the RSO or Radiological Engineer when there is a potential for these conditions to occur.

6.2 Radiation Surveys

6.2.1 General Area Dose Rate (Beta/Gamma)

• Select the appropriate survey instrument(s) necessary to perform the survey. • Obtain radiation dose rates for each anticipated type of radiation in the area(s)

of interest. Dose gradient measurements may need to be obtained to determine special dosimetry requirements or to characterize the work area(s).

• Document survey results in accordance with Section 6.9.

6.2.2 Contact Dose Rate (Beta, Gamma)

• Select the appropriate survey instrument(s) necessary to perform the survey. • Obtain contact dose rate measurements for each item of interest. Repeat dose

rate measurements to characterize the item, as necessary. • If radiation levels are found to be above background levels, obtain dose rate

measurements at the distance(s) indicated by the governing procedure or the distance(s) that is/are determined by the RSO.




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• To determine the beta dose rate in a mixed beta-gamma radiation field, obtain an open window (OW) dose rate measurement and a closed window (CW) dose rate measurement for each item or area of interest. Readings shall be obtained at approximately 1 inch from the surface at the location of the highest reading. If calculation corrections are necessary to determine a true beta dose rate, make corrections in accordance with manufactures operating instructions, calibration values, or contact the RSO or Radiological Engineer for guidance.


6.2.3 Low-energy Photon Radiation Field

• Select the appropriate low-energy photon radiation survey instrument(s) necessary to perform the survey.

• Obtain low-energy photon radiation measurements for each item or area of interest. Repeat dose rate measurements to characterize the item or area, as necessary.


6.3 Removable Surface Contamination Survey

6.3.1 Select the appropriate type of smear media necessary to perform a removable contamination survey. If necessary, consult the RSO or Radiological Engineer for guidance on the proper selection of smear media.

6.3.2 Label each smear container with a unique number to provide accountability. This number shall also be used to identify (on the radiological survey map) the location of where the smear is taken.

6.3.3 Swipe the surface of interest with the smear. Apply moderate pressure to the smear media to ensure proper transfer of radioactive material. Unless otherwise specified, the area sampled shall be 100 square centimeters (cm2). For items with an accessible surface area of less than 100 cm2, swipe the entire accessible surface.

6.3.4 Place smear in a clean coin envelope or other suitable container.

NOTE: Take precautions to prevent cross contamination of individual smears or loss of sample activity while handling and processing.

6.3.5 Repeat the previous steps, as necessary, to characterize the area or item.




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NOTE: If contamination levels in excess of 10,000 cpm are suspect or identified, field count the smear(s) and consult with the counting laboratory personnel or the RSO on methods for analyzing the smear(s). Do not bring these smears into the counting laboratory without permission from lab personnel. This does not apply to samples in closed containers prepared for analysis by liquid scintillation or gamma spectroscopy counting.

6.3.6 Deliver smear(s) to the counting laboratory for analysis, or analyze smear(s) using the appropriate counting instrument. Field counting may be performed for work area indications.

6.3.7 Document survey results in accordance with Section 6.9.

6.4 Large Area Wipe Survey

6.4.1 Select the appropriate type(s) of media (e.g., Masslinn®) for performing large area wipe (LAW) surveys.

6.4.2 Wipe an area with the selected media, applying moderate pressure.

6.4.3 Monitor the wipe using the appropriate contamination monitoring instrument.

6.4.4 If any unexpected contamination is detected, determine removable surface contamination levels in accordance with Section 6.3.

NOTE: LAW surveys shall not be performed to obtain unconditional release of items or materials.

6.4.5 Document wipe results in accordance with Section 6.9.

6.5 Surface Contamination Survey

6.5.1 Use large area (100 cm2) detectors, capable of detecting the radiation(s) of concern, to perform surface contamination surveys (if available). If larger surface area (>100 cm2) or multi-detector instruments are used, seek operational guidance from the RSO or Radiological Engineer.

6.5.2 Obtain instrument background reading(s), in appropriate units, for each instrument used prior to performing surveys. Perform instrument background readings in areas where natural background radiation levels are lowest.




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NOTE: Some contamination surveys (e.g., environmental surveys) will require that background readings be performed in a pre-determined area and not where natural background radiation levels are lowest.

6.5.3 Scan the surface of the item or area of interest for each potential type of radiation. For optimum detection sensitivity, use the instrument’s audible response rather than observing meter fluctuations. Avoid contact of the instrument’s detector with the surface being monitored.

6.5.4 If an increased count rate is observed, reposition the probe over the area of increased activity and perform a static one minute count.

6.5.5 Repeat the previous steps, as necessary, to characterize the item or area.

6.5.6 As necessary, determine the surface activity (dpm/100 cm2) by subtracting the background count rate from the surface contamination count rate and dividing by the detector efficiency (assuming the detector size is 100 cm2):

Total surface activity = Surface activity (cpm) - Background activity (cpm) (dpm/100 cm2) Detector efficiency (counts/disintegration)

6.5.7 As necessary, determine the fixed surface activity level by subtracting the surface activity from the removable surface contamination:

Fixed surface activity = Total surface activity - Removable surface activity

(dpm/100 cm2)

6.5.8 If a 100 cm2 surface area probe is not used during the survey, correct the survey results to a 100 cm2 surface area result as follows:

• For an area of contamination ≥ 100 cm2:

a) Determine the maximum measurement within a representative area of 100 cm2.

b) Correct the measurement to 100 cm2 by multiplying by the appropriate correction factor: 6.5 (for the standard 15.5 cm2 GM pancake probe).

c) Record as xx dpm/100 cm2.

NOTE: If using a probe other than the standard 15.5 cm2 GM pancake probe, determine the appropriate correction by dividing 100 by the effective area of the probe.




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• For an area of contamination < 100 cm2 but > the area of the probe:

a) Determine the maximum measurement within the contaminated area. b) Record as dpm/probe area and indicate the area of contamination (i.e.,

700 dpm/probe over 45 cm2).

• For an area of contamination < the area of the probe:

a) Determine the measurement. b) Record as dpm over probe area (i.e., 700 dpm/15.5 cm2).

6.5.9 Record surface activity in units of dpm/100 cm2 alpha or beta.


6.6 Volumetric Sampling

6.6.1 Perform volumetric sampling to determine activity levels when required by facility specific sampling plans or if there is a potential for contamination to be present in volumetric media (e.g., absorbed in insulating materials or building materials).

6.6.2 For painted or coated surfaces that may be volumetrically contaminated, collect volumetric samples using appropriate methods to remove the surface materials (chemical or mechanical stripping). Remove a sufficient amount of material to meet the laboratories analytical requirements. Contact the RSO or Radiological Engineer for additional guidance, as necessary.

6.6.3 For painted or coated surfaces, accurately measure the size of the area from which the sample is obtained. Determine the number of square centimeters sampled. Based on laboratory analysis, calculate the activity and report in units of dpm/100 cm2 alpha or beta.

6.6.4 Volumetric samples obtained to quantify the activity of soil or other similar media shall be determined by project procedures, protocols, or by the RSO.


NOTE: Standard radiological protection practices shall be followed when sampling known or suspected contaminated materials. Care must be taken to ensure that the external surfaces of the sampling containers are free of radiological and other contaminates.




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6.7 Unconditional Release Surveys

6.7.1 Perform both a removable and fixed surface contamination survey on items requiring unconditional release, in accordance with Sections 6.3 and 6.4.

NOTE: Isotopic identification must be performed to determine free release criteria.

6.7.2 Compare the survey results with the applicable regulatory release limits or contractual release limits. If the survey results are greater than the release limits, DO NOT release the item.


6.8 Personnel Monitoring

6.8.1 Personnel shall perform a whole-body frisk when exiting a Contamination or Airborne Radiological Area, and as directed by the RWP and/or the RSO, in accordance with Appendix A or as directed by the posted RWP.

6.8.2 Inform individuals to notify the HPT or RSO if the instrument reading is greater than background and/or the instrument alarms.

6.9 Radiological Survey Documentation

6.9.1 Document all radiological surveys (except airborne radiological surveys and personnel frisking) in accordance with this procedure, using standard radiological survey forms.

NOTE: Radiological Survey Maps are not required for every survey, but should be used to add clarity to a survey or help record exact locations where surveys are performed.

6.9.2 Assign a unique survey number to each survey performed. If a site-specific numbering system is not used, use the following format, YY-MMDD-XX where:

YY = Last two digits of the current year

MM = The numerical equivalent of the current month (i.e., April = 04)

DD = The day of the month (i.e., 04, 15, 28)

XX = Sequential survey number (i.e., 01, 02, 03, etc.)




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6.9.3 Document all radiological surveys with sufficient information and clarity to provide a clear understand of the scope, contents, and results of the survey.

6.9.4 Maintain a survey log (database) to document all radiological surveys. At a minimum, the log shall contain:

• Survey Number. • Location of survey. • Date and time of survey. • Purpose of survey. • Name of individual(s) performing the survey.

6.9.5 Enter the following information on all Radiological Survey Form(s) used:

• Survey number. • Survey location. Be as specific as possible. Use building and room numbers if

applicable. • Requester’s name. If the survey is in support of HP routines, write ‘N/A’ in

the space. • Date and time that the survey was begun. • Purpose of the survey. If the survey is in support of HP routines, list the

routine survey being performed. • RWP number, if used. • Model, probe type(s), and serial number(s) for the instrument(s) used in the

performance of any survey. • Any applicable remarks in the appropriate section on the Radiological Survey

Form or the Radiological Survey Remarks sheet.

NOTE: Count lab instrument information need not be included on survey forms provided the lab report of the counting data is attached.

6.9.6 For radiation surveys, enter the following information on the Radiological Survey Form, if a Radiological Survey Map is not used:

• A unique number used to identify each item, if multiple items are surveyed. • The measured dose rate. Units are assumed to be mrem/hr for gamma dose

rate surveys, unless otherwise noted. For beta dose rate surveys, the units shall be listed as mrad/hr.

• Any specific distance (not already mentioned in this procedure) at which the measurement was taken.




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6.9.7 For contamination surveys, enter the following information on the Radiological Survey Form(s):

• A unique number used to identify each item, if multiple items are surveyed. • Item(s) description and location. • Radionuclide of concern, if known, and the instrument’s efficiency. • The resultant cpm for each smear, background count rate, corrected dpm/100

cm2 value, and indicate whether the results are for total, removable or fixed contamination.

• Count lab results of removable contamination levels in units of dpm per 100 cm2 (or indicate other appropriate area).

6.9.8 Use the following symbols and descriptors to present information on the Radiological Survey Map, as necessary:

• Written number (e.g., 2.5) indicates a general area dose rate reading in mrem/hr. If the survey is not for gamma/photon radiation, indicate the type of radiation next to the measurement.

• Written number with asterisk beside it (e.g., 1.5 *) indicates contact dose rate reading in mrem/hr. If the survey is not for gamma/photon, indicate the type of radiation next to the measurement.

• Number in circle (e.g., ) indicates smear number and location taken. Removable surface activity shall be recorded on the Radiological Survey Form.

• Written number with pound sign beside it (e.g., 1 #) indicates direct frisk reading in dpm/100 cm2. Total/fixed surface activity shall be recorded on the Radiological Survey Form.

• Number in triangle (e.g., ) indicates volumetric sample and location taken. • Number beside LAW (e.g., LAW-2) indicates large area wipe number and

location taken. LAW activity shall be recorded on the Radiological Survey Form.

NOTE: Additional symbols may be utilized by the surveyor provided they are defined in the comment section of the survey form.

6.9.9 If using a Radiological Survey Map:

• Illustrate the item or area surveyed. Be as detailed as necessary. • Indicate the location of step-off pads used by illustrating a small rectangle

with the letters ‘SOP’ written inside the rectangle.

1




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6.9.10 Use the Radiological Survey Form Continuation sheet as necessary to document survey information. Do NOT use blank paper to record radiological survey results or information.

6.9.11 To complete survey documentation:

• Print name and sign the Radiological Survey Form in the spaces provided. • Number all pages in sequential order and ensure that the survey number is on

each page. • Attach all survey documentation and transmit to the RSO (or designee) for

review and storage.


Documents generated during the performance of this procedure shall be audited in accordance with the Uniform Federal Policy Quality Assurance Project Plan for the Luckey FUSRAP Site Remediation Luckey, Ohio, Sampling and Analysis Plan..

8. RECORDS


Related documents and/or records, showing the results of radiological surveys and instrument calibrations shall be maintained as required by 10 CFR 20. These documents/records include, as a minimum:

• Records of all surveys for radiation dose rates, area and equipment contamination levels, unconditional release of materials, and any other surveys as designated by the RSO.

• Records of the results of measurements and calculations used to determine individual intakes of radioactive material and used in the assessment of internal dose.

• Records showing the results of air sampling surveys and bioassays sampling.

• Records of the results of measurements and calculations used to evaluate the release of radioactive effluents to the environment.




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Forms FRN-0007, Radiological Survey and FRN-0008, Radiochemistry Analytical Results can be associated with this procedure.

9. REFERENCES





RPO-106, “Radiological Training and Qualification.”


RPO-204, “Calibration and Quality Control of Portable Radiological Survey Instruments.”

Regulatory Guide 8.21 “Health Physics Surveys for Byproduct Material at NRC Licensed Processing and Manufacturing Plants.”

USACE, 2016, Uniform Federal Policy Quality Assurance Project Plan for the Luckey Formerly Utilized Sites Remedial Action Program Site Remediation, Luckey, Ohio, Sampling and Analysis Plan, PLN-5503, U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York.

10. APPENDIXES

Appendix A, Personnel Frisking Instructions




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APPENDIX A Personnel Frisking Instructions

Personnel monitoring with portable frisking instruments shall perform the following: 1. Visually inspect frisker to verify that the:

Instrument is on Instrument is on lowest scale Audio output can be heard Verify calibration label and currency of calibration date

2. Prior to picking up probe, frisk one hand by moving hand across active area of probe. The detector (frisking probe) shall be held within ½ inch of the skin or clothing and moved at a rate of no faster than 2 inches per second. If alpha contamination is suspected or present, the detector shall be held as close as possible (without touching) to the surface and moved at a rate of no faster that 1 inch per second.

3. If the instrument's audible output increases, hold the probe over the area for 10-15 seconds to provide adequate time for instrument response.

4. After frisking the first hand, frisk the other hand. 5. If the frisk of the second hand does not indicate the presence of contamination, complete

a whole body frisk as indicated below: Head and face - pause at mouth and nose Neck and shoulders Arms Chest and abdomen Back, hips, and seat of pants Legs Shoe tops and sides Bottoms of shoes Personal equipment

6. Return probe to holder and leave the area. Be sure to position the probe so that the next person can frisk one hand without touching the probe.

7. Notify Health Physics personnel or the RSO of any instrument reading above background or if the instrument alarms, and remain at the frisking station unless directed otherwise.

ATTACHMENT 11 RPO-303, Area Air Sampling

RPO-303 Rev. 0

Area Air Sampling for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project




Signature

AREA AIR SAMPLING FOR THE LUCKEY FORMERLY UTILIZED SITES REMEDIAL ACTION



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Table of Contents

1. PURPOSE ..............................................................................................................................5

2. APPLICABILITY ..................................................................................................................5



3.2 Prerequisites ...............................................................................................................5

4. GENERAL .............................................................................................................................6

4.1 Equipment ..................................................................................................................6



4.4 Revisions ....................................................................................................................6

5. OTHER ...................................................................................................................................6

6. DEFINITIONS .......................................................................................................................7

7. PROCEDURE ........................................................................................................................7

7.1 General Requirements ................................................................................................7

7.2 Continuous Air Monitoring ........................................................................................7

7.3 Low/High Volume Air Sampling ...............................................................................8

7.4 Stack Monitoring ........................................................................................................8

7.5 Lapel Air Sampling ....................................................................................................8

7.6 Preparing, Transporting and Counting Sample(s) ....................................................10


9. RECORDS ...........................................................................................................................12




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10. REFERENCES .....................................................................................................................12

11. APPENDIXES .....................................................................................................................12

APPENDIX A Sample Activity Calculation Examples .................................................................13




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1. PURPOSE

The purpose of this procedure is to provide instruction for the sampling of airborne radioactive materials in the workplace.

2. APPLICABILITY

This procedure applies to Portage management, supervisors, individuals and contractors that perform airborne radioactive material sampling and/or operate airborne radioactive material sampling or monitoring equipment.






• Ensure that all air sampling documentation is reviewed in a timely manner.

• Determine the air sampling instrumentation to be utilized to perform airborne radiological surveys, if necessary.

Health physics staff • Comply with this procedure, exercising appropriate contamination control techniques in the performance of radiological surveys and while handling sample media, and complying with entry requirements for the areas to be surveyed.

• Ensure that individuals have completed, and are current in, Radiation Worker Training qualifications prior to issuance of a lapel air sampler.

• Operate airborne radiological survey instrumentation in accordance with approved operating procedures.

3.2 Prerequisites

Not applicable.




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4. GENERAL

4.1 Equipment

Various air sampling equipment (includes but is not limited to, general area high volume and low volume air samplers, lapel air samplers, continuous air monitors, etc.)

Laboratory counting equipment.

Various sample filter media.


Not applicable.


The presence of radon daughters, which are naturally occurring, can give a false indication of high airborne radioactivity.

If sample lines are used for collecting airborne particulates, the lines shall be as short as possible and shall be made of a material that is not subject to significant static charge effects.

4.4 Revisions


5. OTHER

5.1.1 Perform workplace air sampling for any of the following conditions:

• When work activities or radiological conditions could result in an intake to occupational workers in excess of 10% of the regulatory limit.

• When respiratory protection equipment is used for the purpose of limiting intakes of radioactive material.

• When performing work in an existing Airborne Radioactivity Area, if applicable.

• As required by the RWP and/or RSO.

5.1.2 Use continuous air monitoring (CAM) for fixed perimeter air monitoring.




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5.1.3 Lapel air samplers shall be used when:

• Airborne concentrations exceed, or have the potential to exceed 10% of DAC and the occupational worker is subject to >100 mrem (TEDE) for the year.

• Working in an environment where the potential for an intake of four (4) DAC-hours could be received in one 40 hour work week.

• Individuals are wearing respiratory protection used for the purpose of limiting intakes of radioactive material.

• Required by the RWP.

6. DEFINITIONS

See RPO Glossary.

7. PROCEDURE


7.1.1 Protect airborne sampling equipment from becoming externally contaminated to the extent possible (i.e., placing plastic between a sampling pump and contaminated surface).

7.2 Continuous Air Monitoring

7.2.1 Operate the CAM in accordance with the manufacture’s operating instructions and recommendations, and in accordance with applicable RPOs.

7.2.2 Inspect operating CAMs on a daily basis (excluding non-work days). The “CAM Inspection” form (FRN-010) shall be completed for each inspection performed.

7.2.3 Collect and analyze CAM system sample filters at least weekly, when in operation. If CAMs are operated where there is a potential for intakes to exceed 40 DAC-hours in one week, then collect and analyze CAM system sample filters daily.

NOTE: CAM units with installed detector(s) and moving filter media are exempt from filter media analysis.

7.2.4 Analyze the filter media in accordance with Section 6.6.

7.2.5 Perform weekly source checks on CAMS (if applicable) with automatic alarms systems to verify proper operation.




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7.3 Low/High Volume Air Sampling

7.3.1 Install the recommended sample filter media on the appropriate filter holder of the sampler. Contact RSO for guidance as necessary.

7.3.2 Place the air sampler (if not permanently installed) in the desired location to obtain the best representation of air the worker will be breathing during the job. Contact RSO for guidance as necessary.

7.3.3 Operate the air sampler equipment in accordance with the manufacture’s operating instructions and recommendations, and in accordance with applicable RPOs.

• Check for air in-leakage into sampling lines by momentarily blocking the sampler inlet immediately after starting the unit. Flow indication should drop towards “zero” flow rate. If flow does not drop, investigate for source of air in-leakage and correct. If air in-leakage cannot be corrected, tag the unit out of service and immediately inform the RSO.

7.3.4 Collect required airborne radioactive sample. Contact the RSO for guidance, as necessary.

7.3.5 Remove the filter media from the filter holder and analyze the filter media in accordance with Section 6.6.


7.4 Stack Monitoring

7.4.1 Changed-out stack sampler filter media on a weekly basis.

7.4.2 Calculate sample activity in accordance with Section 6.6

7.4.3 Notify the RSO if any calculated stack activity exceeds 10% of the isotope appropriate value specified in 10 CFR 20 Appendix B, Table 2, Column 1 or the appropriate regulatory guidance.

7.5 Lapel Air Sampling




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7.5.1 Instruct the wearer to operate the sampler only during the time the wearer is in the work area.

NOTE: Multiple entries may be made during a shift without changing the filter media. Perform a contamination survey of the lapel sampler head and filter prior to removing from the airborne or contamination area.

7.5.2 If anti-contamination clothing is worn, locate the pump under the clothing (if possible) to protect it from external contamination, with the filter head protruding outside in the lapel. If work conditions are such that the HPT determines it is not feasible to physically protect the pump from external contamination, then the pump must be surveyed and proven radiologically clean externally before leaving the work area.

7.5.3 Ensure lapel air sampler heads are not covered by any protective equipment or clothing (i.e., respirators, bubble hoods, coveralls, etc.) when in use.

7.5.4 Operate the lapel air sampler in accordance with Reference 3.4.

7.5.5 Complete the general information section of the Airborne Radiological Survey Form (FRN-0009), as well as parts of the lapel sampler section that are applicable to the beginning of the job.

7.5.6 Record sample start and stop times each time they occur during the work for each sample.

7.5.7 When the wearer is finished using the lapel air sampler, remove the filter media from the filter holder and analyze the filter media in accordance with Section 6.6.


7.5.8 Count lapel air sampler media the following workday. If sample activity indicates a potential intake of > 10 DAC-hours, restrict the individual from work involving potential airborne exposure.

NOTE: Notify the RSO of any individual whose lapel sample indicates an intake of > 1 DAC-hour after the initial sample analysis.

7.5.9 When calculating DAC-hours for users of respiratory protection equipment,




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obtain RSO approval to apply respiratory protection factors.

• With approval, DAC-hours calculated shall be reduced by the assigned respiratory protection factor.

7.5.10 A record of the individual’s intake and accumulated DAC hours shall be maintained. DAC hour calculations and resulting exposures shall be included in the individual’s dose history file, if applicable.

7.6 Preparing, Transporting and Counting Sample(s)

7.6.1 Remove filter media from filter holder, if not previously done.

NOTE: Use tweezers or equivalent apparatus to remove the filter media from the air sampler. If removing sample with hands, use gloves for removal. Change gloves as needed to avoid cross contamination of filter media.

7.6.2 Place filter media in an air sample filter media collection container (i.e., coin envelop, counting planchet, etc.)

NOTE: Handle filter media and containers with care to reduce potential loss of activity from the media.

NOTE: If activity levels in excess of 10,000 cpm are suspect or identified, field count the filter media and consult with the counting laboratory personnel or the RSO on methods for analyzing the filter media. Do not bring these samples into the counting laboratory without permission. This does not apply to samples in closed containers prepared for analysis by liquid scintillation counting (LSC).

7.6.3 Record the following information on the air sample filter media collection container: air sample number, sampler start time and date, stop time and date, beginning and ending flow rate, total volume of air sampled, lapel sampler information and HP’s initials.

NOTE: If a copy of the Airborne Radiological Survey form is provided to the count lab with all the information listed above, the filter media container need only have the sample number and HPT’s initials.

7.6.4 Record applicable information in the appropriate sections of the Airborne Radiological Survey Form (FRN-0009) and/or the CAM Inspection Form (FRN-0010), as applicable.




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7.6.5 Deliver sample(s) to count lab as soon as practicable, if used, but at least within one working day.

NOTE: Results of air samples taken which could provide indications of personnel intakes should be available no later than the beginning of the next working day. If positive results are obtained, but radon daughters are suspected, an allowance for radon decay may be assumed (i.e., three day decay time for thoron daughters).

7.6.6 Count samples within three working days of collection.

7.6.7 Perform sample analysis for all suspect isotopes. Work area characterizations, past radiological surveys, known work area profiles, and/or as determined by the RSO may be used to identify suspect isotopes.

7.6.8 Samples shall be analyzed for a sufficient length of time such that the calculated Minimum Detectable Concentration (MDC) value is less than or equal to one-tenth (1/10) the isotope specific concentrations identified in the applicable regulatory guidance.

• MDC values shall be calculated and documented for each counting instrument.

7.6.9 If the analyzed sample activity is less than the counting systems MDA value, then the counting systems MDA value will be utilized to calculate the sample’s activity. Contact the RSO for guidance, as necessary.

7.6.10 Calculate sample activity manually or through the use of computer programs.

7.6.11 Retain all samples submitted for laboratory analysis until disposal is authorized by the RSO.


The RSO or Radiological Engineer shall review lapel air sample results as soon as practical, but at least daily when lapel samples are obtained.

The RSO shall annually review the past year’s air sampling program and components to determine:

• Whether the measurements were accurate and reliable.

• Whether changes should be made to improve the measurements.




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• Whether the air sampling was appropriate for the intended purpose.

• Whether the air sampler/monitor was located properly during sampling.

Computer programs used to calculate general area airborne activity and DAC hours shall be QA checked prior to initial use.

• This check will involve inputting known values and verifying that the computer generated results match the results that are independently calculated.

If computer generated results do not agree with the independently calculated results the RSO shall be notified, and all sample calculations shall be considered invalid until the source of the discrepancy is identified and corrected.

9. RECORDS

Airborne radiological survey documents and/or records are generated during the performance of this procedure and shall be stored, arranged, indexed, retained, retrieved, and disposed of in accordance with all applicable NRC document regulations and requirements.

Forms FRN-0009, Airborne Radiological Survey and FRN-0010, CAM Inspection can be associated with this procedure.

10. REFERENCES




RPO-209, “Operation and Calibration of Lapel Air Samplers.”


11. APPENDIXES

Appendix A, Sample Activity Calculation Examples




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APPENDIX A Sample Activity Calculation Examples

1) Sample volume:

(Sample Rate [LPM]) x (# minutes sampled) x (1000 ml/L) = Sample volume in ml’s.

2) DAC-hour calculation from Lapel Air Sampler:

DAC-hours = Hours Worked x Sample Activity (uCi/ml) DAC value (uCi/ml)

3) Air Activity concentration from gamma spectroscopy results:

Air Activity = Sample Activity (pCi) x 1x 10-6 uCi/pCi = uCi/ml Sample Volume (ml)

4) Air Activity concentration from gross alpha/beta counting:

Air Activity Concentration = Sample Activity (dpm) x 4.5 x 10-7 uCi/dpm = uCi/ml Sample Volume (ml)

5) Air Activity from Victoreen Model 08-430 Personnel Air Monitor:

Sample Volume = Digit Stop* - Digit Start X Conversion Factor (ml/digit)

* Victoreen Model 08-430 has a mechanical digital readout with a maximum reading of 99,999. When the sampler continues to operate past 99,999 the digit counter resets to 0. For sample volume calculations a one must be added as the first digit to the digit stop total when the sampler digit readout resets to zero during operation.

Example Digit start: 95,000 Digit stop: 01000 Sample Volume = (101000 - 95,000) x (Conversion Factor [ml/digit])

Air Activity Concentration = Net dpm x 4.5 x 10-7 uCi/dpm = uCi/ml Sample volume (ml)

DAC-hours = Hours Worked x Sample Activity (uCi/ml) DAC value (uCi/ml)

ATTACHMENT 12 RPO-401, Radiation Work Permits

RPO-401 Rev. 0

Radiation Work Permits for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project




Signature

RADIATION WORK PERMITS FOR THE LUCKEY FORMERLY UTILIZED SITES REMEDIAL ACTION



RPO-401 0 2 of 15






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Table of Contents

1. PURPOSE ..............................................................................................................................4

2. APPLICABILITY ..................................................................................................................4



3.2 Prerequisites ...............................................................................................................5

4. GENERAL .............................................................................................................................5

4.1 Equipment ..................................................................................................................5



4.4 Revisions ....................................................................................................................5

5. DEFINITIONS .......................................................................................................................6

6. PROCEDURE ........................................................................................................................6

6.1 RWP Initiation ............................................................................................................6

6.2 RWP Development .....................................................................................................7

6.3 RWP Issuance ..........................................................................................................11

6.4 RWP Termination ....................................................................................................12


8. RECORDS ...........................................................................................................................14

9. REFERENCES .....................................................................................................................14

10. APPENDIXES .....................................................................................................................15




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1. PURPOSE

The purpose of this procedure is to provide instruction in the preparation, distribution, utilization, administration, revision, and termination of Radiation Work Permits (RWPs).

2. APPLICABILITY

This procedure applies to Portage management, supervisors, individuals and contractors that prepare, review, approve, distribute, utilize, and/or cancel RWPs, where their work assignment is controlled by Portage.

This procedure applies to radiological work activities that have the potential for personnel exposure and/or the spread of radioactive contamination to personnel, the site, or the environment.





• Ensure that individuals are qualified and trained to perform this procedure.

• Review and approve RWPs and revisions to RWPs.

• Review completed RWP package.

• Approve RWP Termination Packages.

• Review, on a monthly basis active RWPs.


• Compose RWPs in accordance with this procedure or as required by the RSO.

• Review terminated RWPs for completeness and accuracy.




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Radiation workers • Read and understand the RWP controlling the work.

• Agree to abide by the requirements of the RWP as written.

• Agree to ask questions about the RWP when the RWP is not understood.

3.2 Prerequisites

Not applicable.

4. GENERAL

4.1 Equipment

Not applicable.


Not applicable.


RWPs developed for radiological work shall be in compliance with the conditions of the applicable NRC Licenses and any other appropriate regulatory requirement that is in effect.

It is critical that the Health Physics Technician has a thorough understanding of the work activities to be performed. Failure to have a complete understanding of the work activities to be performed could result in unnecessary personnel exposure and/or the spread of radiological contamination.

During the job evaluation phase of writing the RWP, emphasis should be placed on determining any administrative or engineering techniques/methods to help keep personnel exposure ALARA.

4.4 Revisions





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5. DEFINITIONS

See RPO Glossary.

6. PROCEDURE

6.1 RWP Initiation

6.1.1 The RWP process shall be initiated upon the receipt of an RWP Request (form FRN-0018) or when deemed necessary by a Health Physics Technician or Health Physics staff.

6.1.2 The Health Physics Technician shall assess the radiological condition(s) of the proposed work area and complete the applicable sections of the RWP, based on:

• Information provided in the RWP Request. • Additional information obtained from the RWP requester. • Current radiological survey data of the proposed work area. • Discussion with the requesting personnel and/or other Health Physics staff

members. • Related SOPs or other regulatory guidance.

6.1.3 If current radiological survey data is not available, perform pre-job radiological survey(s) of the work area in accordance with appropriate SOPs.

6.1.4 If pre-job radiological surveys cannot be performed prior to initiating work, the necessary surveys shall be performed after RWP approval and concurrent with work activities.

• Radiological hold points shall be established (on the RWP) to stop work and allow for the performance of survey activity when the area or item becomes available to survey.

• Increased HP work coverage shall be provided when performing work where a radiological survey is not practical or possible prior to work start.

• The work shall be stopped and the RWP revised if radiological conditions are significantly different then estimated.

6.1.5 Previous survey data may be used in place of a pre-job survey when either:

• Performing a survey would present an unnecessary safety hazard (e.g. confined space) or be contrary to ALARA practices, or




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• The latest radiological survey performed in the area of question is less than three calendar months old AND activities performed in the area have not changed the radiological conditions since this last survey.

6.1.6 The pre-job survey shall include the following, as applicable:

• A map of the work area detailing boundaries, postings, entrance and exit points, step-off pad locations, and any other physical hazards present in the work area.

• An assessment of radiological hazards (known and potential) associated with the work area.

6.1.7 If the potential for other hazards (e.g., physical hazards, confined spaces, etc.) are identified, contact the appropriate safety personnel for guidance to determine whether or not radiological controls will be impacted.

6.2 RWP Development

6.2.1 On the RWP (form FRN-0019), indicate whether this will be a job-specific or general RWP.

• A job-specific RWP is issued for performance of a specific job in a specific area where the work may affect or change the radiological conditions, as well as any work or task that does not meet the requirements for a general RWP. Job-specific RWPs are issued for the duration of the job, not to exceed a period of one month.

• A general RWP is issued for work of a routine nature, such as routine sampling, surveys, calibrations, tours, inspections, or other repetitive tasks that do not change the radiological protection requirements for a system or area and/or do not result in significant radiation exposure. General RWPs can be issued for an extended period of time, not to exceed a period of one year.

6.2.2 Enter the unique RWP number obtained from the RWP Tracking Log (form FRN-0023).

• An RWP Tracking log shall be maintained for the tracking and issuance of RWP numbers and shall be controlled by the RSO.

• The numbering format shall be YY-XXX where YY = the last two digits of the current year and XXX = the sequential numbering starting with 001 (e.g. 02-010 would be the tenth RWP issued during 2002).




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6.2.3 Enter the start and end dates on the RWP and the RWP Tracking Log.

6.2.4 Enter the job location on the RWP and the RWP Tracking Log.

6.2.5 Provide a description of work on the RWP and the RWP Tracking Log.

• The work description should include enough detail to adequately explain the job and associated radiological hazards.

6.2.6 Radiological Source(s): Indicate the radiological hazards of concern for the work area by marking any appropriate box(es).

6.2.7 Airborne Radioactivity:

• Indicate the contaminants of concern and record the airborne activity concentration (µCi/ml) for each.

• If airborne radioactivity is not a concern, mark the ‘N/A’ box.

6.2.8 Surface Contamination:

• If contamination is not a radiological hazard for the work, mark the ‘N/A’ box.

• If contamination is not detected, mark the ‘None Detected’ box. • If the contamination levels are unknown, mark the ‘Unknown Levels’ box and

establish hold points, as necessary, to determine the radiological conditions. • Enter the fixed and removable surface contamination levels for the work area

and the radionuclide(s), as applicable.

NOTE: Typically, the highest removable and fixed contamination levels present in the work area should be recorded.

• If it is expected that contamination levels will change during the duration of work, mark the ‘See Latest Survey’ box.

6.2.9 Radiation Levels

• Enter applicable radiation levels in the space(s) provided. Clearly include the appropriate units.

• If radiation levels do not apply, record ‘N/A’ in the spaces provided.

6.2.10 Pre-Job Survey Information:




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• Record pre-job survey number(s). • If radiological conditions are to be determined concurrent with work

activities, enter ‘TBD.’ A TBD notation shall be related to a radiological hold point.

• If pre-job surveys are not applicable, enter ‘N/A.’

6.2.11 Protective Clothing (PCs)

• Indicate the appropriate type of PCs that are required for the work. • Use the blank spaces as needed to specify the type of PCs or to reference a

radiological hold point or a special instruction. • If PCs are not required, mark the ‘None Required’ box.

6.2.12 Respiratory Protection

• Indicate the type of respiratory protection required. • If respiratory protection is not required, mark the ‘None Required’ box.

6.2.13 Dosimetry

• Indicate the type(s) of dosimetry required. • If ‘Additional TLD(s)’ or ‘Extremity’ dosimetry is needed, indicate the

placement of the dosimetry, and describe the proper use and placement of multiple or self-reading dosimetry in the Special Instructions section of the RWP.

• Consult with RSO or Radiological Engineer regarding bioassay requirements, if needed.

• If bioassay sampling is required, mark the type of bioassay (pre-job, post-job, or frequency). Indicate any frequency requirements in the space provided.

• If dosimetry is not required, mark the ‘None Required’ box.

6.2.14 Training

• Indicate the type(s) of training required. • Consult with the RSO or Radiological Engineer, as needed, to determine if

additional training is required prior to the commencement of the work activity.

6.2.15 Monitoring:

• Indicate appropriate requirements for monitoring radiological conditions.




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6.2.16 Complete the Radiological Hold Points section of the RWP form as follows:

• List and explain any radiological hold points.

NOTE: A radiological hold point should include the criteria that must be met, or action the must be taken, to satisfy the hold point prior to continuing with subsequent steps in the planned activity.

NOTE: The following activities and potential conditions should be considered when determining the need for radiological hold points.

• Action needed to assess changing radiological conditions and ensure implementation of required controls.

• Potential for radiation doses in excess of the applicable limit. • Potential for elevated airborne radioactivity levels. • Potential for elevated or changing removable surface contamination levels on

accessible surfaces. • Potential for unplanned or uncontrolled release of radioactive material to the

environment.

6.2.17 Complete the Special Instructions section of the RWP form as follows:

• Present instructions in short, easy-to-follow steps. • Start each step with an action verb; avoid passive statements. For example,

write, “Secure the area” instead of “The area should be secured.” • Include only one action per step, unless multiple actions are performed

simultaneously within a step. • If actions need to be performed sequentially, label steps with numbers or

letters to indicate the order in which steps are to be performed. • Use “if’ or “when” to introduce a step in which certain conditions must be met

before the step is performed. • Be specific and detailed enough so that the worker can perform the task(s)

without direct supervision. • If practical, use sketches or photographs to clarify topics, such as work area

boundaries, radiological hazards, worker positions, and access controls. • If practical, make checklists for critical tasks.

6.2.18 Use an RWP Continuation Sheet (form FRN-0020) if more space is needed to list radiological hold points or special instructions. Indicate that an RWP Continuation Sheet is used by marking the ‘Continuation Sheet(s) Attached’ box.




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6.2.19 Authorized Personnel

• Only personnel identified on the RWP Request form and/or approved by health physics shall be allowed to perform work activities under the approved RWP.

• The sign-in sheet shall be posted with the job site RWP. • Prior to entry into the work area to perform tasks under the RWP, individuals

shall review the requirements of the RWP, print their name on the RWP Sign In Sheet, and record their initials in the appropriate spot.

6.2.20 RWP Sign In/Out:

• Indicate the RWP sign in/out requirements.

6.2.21 Personnel Contamination Frisk:

• Indicate the type of frisk required upon exiting the work area. • If needed, provide additional instruction in the appropriate space. • If frisking is not required, mark the ‘None’ box.

6.2.22 Sign and date the RWP form.

6.2.23 Generate an RWP Sign-In Sheet.

6.2.24 Retain the RWP Request (if one was generated) for inclusion in the original RWP package.

6.2.25 Route the RWP package for review and approval to the RSO or designee.

6.2.26 After RWP approval, ensure:

• The RWP number has been recorded on each page of the RWP and the RWP Sign-In Sheet.

• Pages of the RWP package are numbered.

6.2.27 Make a copy of the RWP and store the original RWP, along with the RWP Request, in the Active RWP Folder.

6.3 RWP Issuance

6.3.1 Insert a copy of the Radiation Work Permit into the RWP Work Package Folder.




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• This copy is considered the work-area copy and shall be posted at the work area while work is in progress.

6.3.2 Insert a copy of the Radiation Work Permit Sign-in Sheet (form FRN-0021) into the RWP Work Package Folder.

6.3.3 Insert any additional information into the RWP Work Package Folder deemed necessary to convey radiological information to the work force. (e.g., radiological survey maps, radiological survey results, B-Z sign-in forms, diagrams or drawings, etc.)

6.3.4 Issue the RWP Work Package Folder to the individual requesting the RWP.

6.3.5 Review radiological protection requirements, radiological hold points, and special instructions with the individual, as required. If survey maps are supplied with the RWP Package Folder, instruct the individual to post the maps at the entrance to the area.

6.3.6 If a pre-job meeting is required, assemble authorized individuals and conduct the briefing. Individuals who do not receive the briefing will not be allowed to perform work under the RWP until properly briefed.

6.4 RWP Termination

6.4.1 Remove the posted work area copy RWP from the work area.

6.4.2 Remove the original RWP from the Active RWP Folder.

6.4.3 Cancel the original RWP by signing and dating the RWP in the Termination Signature section of the RWP.

6.4.4 Retrieve or obtain the following items for inclusion in the RWP Termination Packet:

• The original terminated RWP. • Any documentation associated with the RWP (e.g., RWP Sign-In Sheets,

RWP ALARA Review attendance records, RWP Request form, etc.) • An RWP Termination Checklist (form FRN-0022).

6.4.5 Enter the RWP number on the RWP Termination Checklist.

6.4.6 Complete the Post-Job Conditions/Analysis section of the RWP Termination




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Checklist as follows:

• Indicate the reason for termination. • Indicate whether Post-Job radiological surveys were performed to support this

RWP. If yes, list the corresponding radiological survey numbers. • Indicate whether other surveys were performed to support this RWP. If yes,

list corresponding survey numbers.

6.4.7 Complete the Termination Packet section of the RWP Termination Checklist as follows:

• Indicate if the RWP Request is in the Termination Packet by marking the appropriate box.

• Indicate if all pages of the original RWP are in the Termination Packet by marking the appropriate box.

• Indicate if all RWP Sign-In Sheets are in the Termination Packet by marking the appropriate box.

• Indicate if any pre-job briefing and associated Attendance Records are in the Termination Packet by marking the appropriate box.

• Indicate if data from supplemental self-reading dosimeters (SRD) or Breathing Zone sampling is provided by marking the appropriate box. If supplemental sign-in sheets were not required, mark the ‘N/A’ box.

• List any additional documentation that is included in the packet. • Indicate that the RWP Tracking Log has been updated.

6.4.8 Destroy the work area copy RWP.

6.4.9 Contact the RSO if any items known to have been completed are marked as not being included (i.e., are missing). The Original RWP and RWP Sign-in Sheets are the minimum records required for each RWP Termination Package.

6.4.10 In the Verification/Approval section of the RWP Termination Checklist, the individual completing the Termination Package shall print his/her name on the line provided, then sign and date the form.

6.4.11 Place items marked as being attached in the Termination Packet folder, including the RWP Termination Checklist.

6.4.12 Route the Termination Package to the RSO for review and approval.

6.4.13 The RSO (or designee) shall:




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• Review the RWP package for completeness. • Obtain corrections to the information, as applicable. • Sign and date the RWP Termination Checklist. • Route the complete RWP Termination Package for storage.


The RSO or Radiological Engineer shall review active RWPs on a monthly basis.

The RWP program shall be evaluated as part of the annual audit of the health physics program.

8. RECORDS

Records that may be generated during the performance of this procedure include the following:

• Radiation Work Permit • RWP Request • RWP Log • Radiation Work Permit Sign-In Sheet • Record of pre job meetings or briefings • Radiation and contamination surveys • RWP Termination Checklist

RWP documents and/or records shall be stored, arranged, indexed, retained, retrieved, and disposed of in accordance with this procedure and applicable NRC document regulations and requirements.

Records that are generated as a result of the requirements of federal regulations must be retained until NRC authorizes their disposition.

9. REFERENCES







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10. APPENDIXES

None

ATTACHMENT 13 RPO-402, Radiological Posting and Labeling

RPO-402 Rev. 0

Radiological Posting and Labeling for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project




Signature

RADIOLOGICAL POSTING AND LABELING FOR THE LUCKEY FORMERLY UTILIZED SITES REMEDIAL



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Table of Contents

1. PURPOSE ..............................................................................................................................5

2. APPLICABILITY ..................................................................................................................5



3.2 Prerequisites ...............................................................................................................5

4. GENERAL .............................................................................................................................5

4.1 Equipment ..................................................................................................................5



4.4 Revisions ....................................................................................................................6

5. DEFINITIONS .......................................................................................................................6

6. PROCEDURE ........................................................................................................................6

6.1 General Requirements ................................................................................................6

6.2 Establishing Physical Controls (Barriers, Posting, etc.) .............................................7

6.3 Radiological Posting Documentation .........................................................................9


8. RECORDS .............................................................................................................................9

9. REFERENCES .....................................................................................................................10

10. APPENDIXES .....................................................................................................................10

APPENDIX A Radiological Posting Requirements ......................................................................11

APPENDIX B General Guidance - Signs and Labels ...................................................................13




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APPENDIX C Establishing Physical Access Controls ..................................................................15

APPENDIX D Radiological Postings ............................................................................................17

APPENDIX E Radioactive Materials Label ..................................................................................19

APPENDIX F Recommended Inserts for Radiological Postings ..................................................20

APPENDIX G Ranking of Radiological Posting Based On Hazard .............................................21




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1. PURPOSE

The purpose of this procedure is to provide instruction for the posting and labeling of radiologically controlled areas, equipment, and material. This procedure also identifies the requirements for documenting and inspecting these posted areas.

2. APPLICABILITY

This procedure applies to Portage management, supervisors, individuals and contractors that post or label radiologically controlled areas, equipment, and materials where their work assignment is controlled by Portage.






• Implement oversight and specific control measures needed for entry into high and very high radiation areas.


• Ensure compliance with posting, labeling, and access control requirements during the conduct of work activities.

3.2 Prerequisites

Not applicable.

4. GENERAL

4.1 Equipment

Radiological warning signs, stickers, labels, and tags

Information inserts for warning signs

Radiological warning rope, ribbon, chain, or tape




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Stanchions


Not applicable.


Ensure that only current, up-to-date radiological survey information is used to post and label radiologically controlled areas, equipment, and material.

4.4 Revisions


5. DEFINITIONS

See RPO Glossary.

Permanent Posting - Any area intended or expected to be posted for a period of greater than 90 days shall be considered a Permanent Posting.

6. PROCEDURE


6.1.1 Results from radiological surveys shall be used as the basis for all radiological posting, labeling, and access control measures.

• RSO may authorize the use of radiological data from existing surveys in lieu of new survey for areas with stable, well-characterized radiological conditions, or if ALARA considerations preclude a new survey.

• Routine survey data shall be used as a means to verify the adequacy of existing controls.

6.1.2 All signs, labels, rope, tape, chain, ribbon, etc., used as visual indicators of the presence of radiological hazards shall comply with the following requirements:

• All postings shall be in accordance with the requirements of Appendix A. • Inserts shall be used with signs, as appropriate, to provide sufficient

information to satisfy access control requirements.




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• All signs, labels, rope, tape, chain, ribbon, etc. shall be constructed of materials that can endure environmental conditions without significant deterioration of color, legibility, strength, or other physical characteristics.

• Signs and other postings communicating the existence of radiological hazards under certain conditions shall specify those conditions (i.e., “Potential Internal Contamination” or “Radiation Area When Light Is On” etc.)

6.1.3 Health Physics personnel observing the use of radiation protection signs, labels, rope, tape, chain, ribbon, etc., which are not authorized or are not being used in accordance with this procedure shall:

• Notify the RSO. • Stop the unauthorized use of the material.

6.2 Establishing Physical Controls (Barriers, Posting, etc.)

6.2.1 Using current radiological survey data, compare measured or estimated radiological conditions to posting criteria in Appendix A and determine the type of postings appropriate for the area and the hazards involved.

6.2.2 Determine if barriers are required to control access to the area.

6.2.3 Identify locations at which barriers will be required and potential access/egress points to establish access control. Guidance can be found in Appendix A through C.

6.2.4 Determine if collection containers for used protective clothing and equipment are needed.

6.2.5 Obtain materials required to establish and post access barriers.

• Area selected shall have sufficient room for location of collection containers, if required.

• Consider the numbers of personnel that will be entering or leaving the area.

6.2.6 Place stanchions, rope, tape, chain, ribbon, etc., to establish the physical boundaries of the area. Keep posted areas as small as reasonable possible when placing boundaries.

• Post with entry requirements (Appendix D). • Place step-off pads outside of barrier at access/egress point.




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• Create a movable barrier such as a rope, chain, ribbon, etc., across access/egress point if no door/barrier exists.

WARNING: Do NOT establish any control that would prevent the rapid exit of personnel from the area under emergency conditions.

6.2.7 It is not necessary to post sections of boundaries that consist of permanent structural barriers (i.e., walls, buildings, structures, etc.)

6.2.8 Place a sufficient number of signs/labels, etc., to clearly indicate to personnel the conditions within the barriers. As a minimum, place a sign at each access point and at least one sign on each side of bounded area. Additional signs should be placed approximately every 20 feet on boundaries of large areas.

6.2.9 If postings or barricades must be moved to facilitate the removal or transfer of equipment or material, move the posting or barricade and:

• Replace the moved posting/barricade with temporary posting/barricade, such as rope or tape with a sign.

• Return permanent posting/barricades when removal or transfer process is complete.

6.2.10 Notify the RSO if areas, for which controls have been established, are new or if area posting and/or access control requirements have changed.

6.2.11 Verify, by radiological survey, that radiological conditions at new or relocated boundaries are adequate for the affected area.

6.2.12 Posting requirements may be waived for periods of less than 12 continuous hours when the area is placed under the continuous observation and control of an individual knowledgeable of and empowered to implement required access and exposure control measures.

6.2.13 Document all changes or additions/deletions to radiological postings in accordance with Section 6.3.




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6.3 Radiological Posting Documentation

6.3.1 Record information regarding radiological posted areas on the Radiological Posting Log and Radiological Posting Log Continuation Sheet (forms FRN-0025 and FRN-0026). The minimum information recorded shall include the:

• Location. • Posting classification (e.g., Contamination Area, Radiation Area, Airborne

Radioactivity Area, etc.) • Posting type - temporary or permanent. • Signature and date of HPT installing posting. • Signature and date of HPT removing posting.

6.3.2 Do not record materials or areas requiring only radioactive material tags or labels on the Radiological Posting Log.


Perform an inspection of all areas posted under this procedure on a monthly basis or as required by the RSO.

The inspection shall consist of reviewing and visually verifying posted areas are properly posted. The inspector shall ensure that the Radiological Posting Log and the Radiological Posting Log Continuation Sheet accurately reflect the posted areas inspected. The inspection results shall be documented on a Radiological Posting Inspection form (FRN-0024).

If the individual performing the inspection finds a posting that is in error, that individual should make the correction (if qualified to post radiological areas) and notify the RSO of the error and corrective action taken. If the correction cannot be made during the inspection, the individual shall identify and note the unsatisfactory condition in the “Comments” section of the Radiological Posting Inspection form and notify the RSO.

The RSO shall review the Posting Inspection form for accuracy and completeness. The RSO shall document the review by signing and dating the Posting Inspection Form.

8. RECORDS





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9. REFERENCES




NRC Regulatory Guide 8.38, June 1993.

10. APPENDIXES

Appendix A - Radiological Posting Requirements

Appendix B - General Guidance - Signs and Labels

Appendix C - Establishing Physical Access Controls

Appendix D - Radiological Postings

Appendix E - Radioactive Materials Label

Appendix F - Recommended Inserts for Radiological Postings

Appendix G - Ranking Of Radiological Posting Based On Hazard




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APPENDIX A Radiological Posting Requirements

Radiological Condition Required Posting At a nuclear facility, an area outside of a restricted area but within the site boundary, to which access can be limited by the licensee for any reason.

Controlled Area

An area, where access is limited by the licensee for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive materials.

Restricted Area

Any area, accessible to individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of 0.005 rem (0.05 mSv) in 1 hour at 30 centimeters from the radiation source or from any surface that the radiation penetrates.

Radiation Area

Any area, accessible to individuals, in which radiation levels from radiation sources external to the body could result in an individual receiving a dose equivalent in excess of 0.1 rem (1 mSv) in 1 hour at 30 centimeters from the radiation source or 30 centimeters from any surface that the radiation penetrates.

High Radiation Area

Any area, accessible to individuals, in which radiation levels from radiation sources external to the body could result in an individual receiving an absorbed dose in excess of 500 rads (5 grays) in 1 hour at 1 meter from a radiation source or 1 meter from any surface that the radiation penetrates.

Very High Radiation Area

Any room, enclosure or operating area where there exists loose surface contamination at levels greater than the established regulatory guideline/limit.

Contamination Area

A room, enclosure, or area in which airborne radioactive materials, composed wholly or partly of licensed material, exist in concentrations: (1) In excess of the DAC, or (2) To such a degree that an individual present in the area

without respiratory protective equipment could exceed, during the hours an individual is present in a week, an intake of 0.6 percent of the annual limit on intake (ALI) or 12 DAC-hours, or

(3) In excess of 10 % of the DAC.

Airborne Radioactivity Area




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Any room, enclosure, operating area, or surface where there exists contamination that is not easily removed from the surface, at levels greater than the established regulatory guideline/limit.

Fixed Contamination Area

Any room, area or enclosure in which licensed material is used or stored. The licensee shall post each room, area or enclosure in which there is used or stored an amount of licensed material exceeding 10 times the quantity of such material specified in Appendix C to Part 20.

Radioactive Material Area




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APPENDIX B General Guidance - Signs and Labels

1. Only approved labels, signs and symbols shall be used for posting and labeling of Radiological Areas and Radioactive Materials.

2. Radiological Areas shall be clearly and conspicuously posted.

3. Signs and labels shall not be altered or defaced in any way to change their meaning.

4. When used for illustrative purposes, warning signs and labels shall be clearly marked to indicate that the radiological condition does not exist (e.g., FOR TRAINING USE ONLY).

5. Postings and labels shall be securely affixed and located such that they can be expected to remain in place under normal environmental conditions in the posted location.

6. Posting shall be completed prior to commencement of work, maintained current and updated periodically when changes in radiological conditions occur, and shall be removed as soon as possible when no longer required.

7. Boundary identifiers shall be posted on all sides of radiological areas if the boundaries can be breached by personnel. (It is not necessary to post solid walls if the other side contains a radiological area.)

8. Each area boundary shall be posted with area conditions if personnel could encounter that barrier in their pathway through the work area. At least one sign should be visible from any normal avenue of approach.

9. Postings shall be mounted on chains, stanchions, walls, doors, fences, or other permanent structures, whenever possible.

10. Signs shall not be placed such that they will be blocked from view during normal operations.

11. Inserts, when used on postings, shall contain pertinent information about the requirements for entry into the area or about the area itself.

12. Posting may be used to reflect potential or intermittent conditions.

13. If more than one radiological condition exists within an area, posting for each condition shall be identified, beginning with the condition with the highest hazard.




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• This statement should not be interpreted to mean that every access point should be posted with all of the conditions that might be encountered within that access point. Posting the entry to a building containing multiples types of radiologically posted areas does not have to include all of the posted area designators.

• If access controls are established at the entry point to an area with different radiological requirements, post the access point with the most restrictive conditions included in that area.




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APPENDIX C Establishing Physical Access Controls

1. The number of access and egress points for an area requiring posting shall be kept to a minimum.

2. Area boundaries shall be clearly identified with rope, tape, chain, ribbon, etc., if existing structural barriers cannot be used. Structural boundaries shall be used as much as possible.

3. It is not necessary to erect physical barriers to identify the boundaries of areas that are not accessible to personnel.

4. Appropriate signs shall be placed intermittently along the boundary of an area (e.g., fences, barricades, ropes, tapes, etc.) approximately every 20 feet. At least one sign shall be placed on each side of an area boundary, and a sign should be visible from any normal avenue of approach. Rope, tape, chain, ribbon, or similar barrier material used to designate radiological areas should be yellow and magenta in color.

5. Rope, chain, or ribbon barriers shall be placed a sufficient distance from the floor to prevent creating a tripping hazard.

6. Radiological postings and barriers SHALL NOT be placed in a manner that interferes with the operation of emergency exits.

7. Rope, chain, or ribbon shall be attached in a manner preventing inadvertent loosening and failure. Combinations of taping and knotting, as appropriate, are the preferred technique.

8. Rope, chain, or ribbon shall not be attached to operating handles, valves or operating components.

9. Access/egress points shall not be in locations offering threats to worker safety and shall be located in lowest dose areas when possible.

10. Containers, for collection and segregation of disposable and reusable materials, shall be placed at egress points from Contamination and Airborne Radioactivity Areas. These containers shall be located inside the area boundary and close to the egress point.

11. Frisking stations, with posted frisking instructions, shall be located as close as possible to egress points from Contamination and Airborne Radioactivity Areas.




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12. Areas of fixed contamination, which are located outside of radiological areas, shall be established by clearly marking those areas to advise personnel of the presence of fixed contamination. Areas shall be clearly identified as described below.

• Painted with different colored paint so that wear of surfaces can clearly be identified prior to exposing the fixed contamination. The colors used shall be different than the color used for surrounding areas.

• Clearly marked to indicate the boundaries of the fixed contamination and identified as Fixed Contamination.




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APPENDIX D Radiological Postings

Examples of radiological postings and signage are provided to achieve uniformity and consistency for posting areas with known or potential radiological conditions. The Trefoil warning symbol and text shall be either black or magenta in color on a yellow background.

Standard Radiological Posting:

Radiation Area - shall be posted with a conspicuous sign or signs bearing the radiation symbol and the words “CAUTION, RADIATION AREA” as a minimum.

High Radiation Area - shall be posted with a conspicuous sign or signs bearing the radiation symbol and the words “CAUTION, HIGH RADIATION AREA” or “DANGER, HIGH RADIATION AREA” as a minimum.

Very High Radiation Area - shall be posted with a conspicuous sign or signs bearing the radiation symbol and the words “GRAVE DANGER, VERY HIGH RADIATION AREA” as a minimum.

Airborne Radioactivity Area - shall be posted with a conspicuous sign or signs bearing the radiation symbol and the words “CAUTION, AIRBORNE RADIOACTIVITY AREA” or “DANGER, AIRBORNE RADIOACTIVITY AREA” as a minimum.

Contamination Area - shall be posted with a conspicuous sign or signs bearing the radiation symbol and the words “CAUTION, CONTAMINATION AREA” as a minimum.

Radioactive material rooms or areas in which there is used or stored an amount of licensed material exceeding 10 times the quantity of such material specified in Appendix C to part 20 - shall be posted with a conspicuous sign or signs bearing the radiation symbol and the words “CAUTION, RADIOACTIVE MATERIAL(S)” or “DANGER, RADIOACTIVE MATERIAL(S)” as a minimum.

HEADING

HAZARD TYPEREQUIRED INFORMATION

OPTIONAL INFORMATION




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Fixed Contamination - Areas or surfaces with fixed contamination shall be conspicuously posted with a sign and/or label bearing the radiation symbol and the words “CAUTION, FIXED CONTAMINATION” as a minimum.




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APPENDIX E Radioactive Materials Label

Radioactive material labels shall be used when there is a need to help identify that an area, material, or object is radioactive, contains radioactive material, or has the potential to become contaminated with radioactive material. Radioactive material labels shall not be used in place of the proper posting of an area, material, or object as required by regulation. The two most commonly used colors for radioactive material labels are the magenta on yellow or black on white schemes. However, these colors are not a requirement. If using colors other than magenta on yellow or black on white, ensure the colors are of high contrast to each other. Examples of radioactive material labels include (but are not limited to):

Equipment that is internally contaminated or potentially contaminated shall be labeled “Caution Internal Contamination” or “Potential Internal Contamination”. The region in a radiation/contamination area in which the level of radiation/contamination is significantly greater than in neighboring regions in the area might be labeled. Containers of radioactive materials shall be clearly labeled “Caution Radioactive Material”. A sufficient number of labels shall be used such that the containers contents can be clearly identified when viewed from any angle. Radioactive sources, or there containers, shall be labeled “Caution Radioactive Material”.




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APPENDIX F Recommended Inserts for Radiological Postings

HEALTH PHYSICS RESTRICTED AREA RADIOACTIVE MATERIAL(S) VERY HIGH RADIATION AREA HIGH RADIATION AREA RADIATION AREA CONTAMINATION AREA AIRBORNE RADIOACTIVITY AREA FIXED CONTAMINATION INTERNAL CONTAMINATION POTENTIAL INTERNAL

CONTAMINATION CONTACT HEALTH PHYSICS PRIOR TO ENTRY

NOTIFY HEALTH PHYSICS BEFORE REMOVING ANY MATERIAL FROM THIS AREA

EATING, DRINKING, CHEWING, SMOKING PROHIBITED

ENTRANCE

EXIT KEEP OUT NOT AN ENTRANCE TLD REQUIRED RWP REQUIRED FOR ENTRY FRISK REQUIRED UPON EXIT

This is not intended to be an all-inclusive list. Special conditions may require specific inserts not listed here. The above inserts are intended to be used for routine postings.




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APPENDIX G Ranking of Radiological Posting Based On Hazard

Posting of multiple radiological conditions can be successfully accomplished using one of two commonly used practices. The first practice is to post each radiological condition on a separate sign with appropriate supplemental wording. The second practice is to post all radiological conditions on one sign (using inserts) using the most stringent heading with the radiological areas listed in decreasing order of importance. For example, a sign delineating both a contamination area and high radiation area would carry the heading “Danger” rather than “Caution.” Any supplemental information would follow the radiological area designations. In the case of very high radiation areas, posting in combination with any other radiological area is strongly discouraged.

1) DANGER, VERY HIGH RADIATION AREA 2) DANGER, HIGH RADIATION AREA 3) CAUTION, AIRBORNE RADIOACTIVITY AREA 4) CAUTION, RADIATION AREA 5) CAUTION, CONTAMINATION AREA 6) CAUTION, FIXED CONTAMINATION 7) CAUTION, RESTRICTED AREA 8) CAUTION, CONTROLLED AREA

Example: If both a Radiation Area and a Contamination Area exists in the same space, post the Radiation Area as the top insert followed by the Contamination Area insert.

ATTACHMENT 14 RPO-403, Access to Radiological Areas

RPO-403 Rev. 0

Access to Radiological Areas for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project




Signatur

ACCESS TO RADIOLOGICAL AREAS FOR THE LUCKEY FORMERLY UTILIZED SITES REMEDIAL ACTION PROGRAM REMEDIATION

PROJECT


RPO-403 0 2 of 9




PROJECT


RPO-403 0 3 of 9

Table of Contents

1. PURPOSE ..............................................................................................................................4

2. APPLICABILITY ..................................................................................................................4



3.2 Prerequisites ...............................................................................................................5

4. GENERAL .............................................................................................................................5

4.1 Equipment ..................................................................................................................5



4.4 Revisions ....................................................................................................................5

5. DEFINITIONS .......................................................................................................................5

6. PROCEDURE ........................................................................................................................5

6.1 Access Control – General Requirements....................................................................5

6.2 Contamination and Airborne Radioactivity Areas .....................................................6

6.3 High Radiation Areas .................................................................................................7

6.4 Very High Radiation Areas ........................................................................................8


8. RECORDS .............................................................................................................................9

9. REFERENCES .......................................................................................................................9

10. APPENDIXES .......................................................................................................................9


PROJECT


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1. PURPOSE

The purpose of this procedure is to provide instruction in the control of access to Restricted Areas and radiologically controlled areas.

2. APPLICABILITY

This procedure applies to Portage management, supervisors, individuals and contractors that control access to Restricted Areas and radiologically controlled areas, where their work assignment is controlled by Portage.







• Implement oversight and specific access control measures needed for Restricted Areas and radiologically controlled areas.

• Ensure appropriate entry controls are installed and maintained where required.

• Ensure minors and members of the public do not have access to radiologically controlled areas.



• Ensure compliance with posting, labeling, and access control requirements during the conduct of work activities.


PROJECT


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3.2 Prerequisites

Not applicable.

4. GENERAL

4.1 Equipment

Various access control equipment described in this procedure (as necessary).


Not applicable.


Access control measures shall NOT be installed at any radiologically controlled area exit that would prevent rapid evacuation of personnel under emergency conditions.

4.4 Revisions


5. DEFINITIONS

See RPO Glossary.

6. PROCEDURE

6.1 Access Control – General Requirements

WARNING: Do NOT establish any access control that would prevent the rapid exit of personnel from the area under emergency conditions.

6.1.1 Access control shall be maintained for each Restricted Area, Radiologically Controlled Area, Radiological Buffer Area, and/or Radiological Area.

• Radiological Buffer Areas are established around Contamination Areas as a secondary boundary to minimize the spread of contamination.


PROJECT


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• Equipment used for radioactive contamination monitoring shall be located within and at the exit point of the Restricted Area, Radiologically Controlled Area, or Radiological Buffer Area.

6.1.2 The degree of control shall be commensurate with existing and potential radiological hazards within the area.

6.1.3 Use one or more of the following methods to implement access control:

• Signs and barricades. • Control devices on entrances. • Conspicuous visual and/or audible alarms. • Locked entranceways. • Administrative controls.

6.1.4 Implement written authorization (i.e., RWP) to:

• Control entry into and work within areas. • Specify radiological protection measures commensurate with existing and

potential hazards.

6.1.5 Provide a method or technique for ensuring that individuals entering areas have:

• Authorization to enter the area. • Proper training and qualifications commensurate with existing and potential

hazards of the area. • Required dosimetry. • Required personnel protective equipment.

6.2 Contamination and Airborne Radioactivity Areas

6.2.1 Step-off pads shall be used at major access points of long-term Contamination Areas and Airborne Radioactivity Areas.

6.2.2 The type of protective clothing required for entry into any area shall be prescribed (on the RWP) based upon considerations of contamination levels, chemical and physical form of the contaminant, activities to be performed, and area accessibility.


PROJECT


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• Other area and activity hazards, such as heat, flame, hazardous chemicals, physical obstructions, electrical shock, and limited visibility, shall be considered when prescribing protective clothing.

• When penetration of protective clothing by a contaminant is likely, such as during activities likely to induce heavy sweating or otherwise wet the individual, an additional layer of impenetrable clothing should be considered.

6.2.3 Necessary tools and equipment needed for work in Contamination Areas, or Airborne Radioactivity Areas shall be available and serviceable prior to work entry.

6.2.4 Hoses, electrical cables, etc. shall be properly secured to prevent movement of such items across boundaries of Contamination and Airborne Radioactivity Areas.

6.2.5 High-efficiency particulate air (HEPA) units may be used to provide ventilation to work areas or containments, or as part of HEPA vacuum units. Contact the RSO for additional guidance.

6.2.6 For individuals exiting areas where the only Contaminated Areas are laboratory bench surfaces or exhaust hoods, or where contamination potential is limited to specific portions of the body, the frisking should concentrate on affected areas as prescribed by the RWP for the job.

6.2.7 Individuals exiting contamination or airborne radioactivity areas shall perform whole body monitoring.

• If background radiation levels or other conditions at the exit point preclude performance of personnel frisking, the exit point should be relocated to an area of lower background levels. If relocation of the exit point is not practicable, individuals should proceed directly from the exit point to an appropriate area to perform a whole body frisk. The travel path should be monitored frequently for the spread of contamination during use and after the detection of any contamination at the frisking station.

6.3 High Radiation Areas

6.3.1 High Radiation Areas shall be monitored (dose rate) as necessary to determine the exposure rates to individuals in the area.

6.3.2 Hand-held radiation detectors shall be used in addition to any installed radiation area monitors.


PROJECT


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6.3.3 A supplemental dosimeter shall be required for access to High Radiation Areas.

• This dosimeter must be capable of providing an immediate estimate of the individual’s integrated deep dose equivalent during the entry.

6.3.4 Where a supplemental dosimeter is impractical or ineffective (e.g., when monitoring doses from neutron radiation), other means (e.g., knowledge of the area exposure rate and tracking of individual access times) may be used to provide an immediate estimate of an individual's dose.

6.3.5 One or more of the following controls shall be used for each access point to a High Radiation Area:

• A control device that prevents entry into the area when high-radiation levels exist or that, upon entry, causes the radiation level to be reduced below levels that define a High Radiation Area.

• A device that functions automatically to prevent use or operation of the radiation source or field while individuals are in the area.

• A control device that energizes a conspicuous visible or audible alarm signal so that the individual entering the High Radiation Area and the supervisor of the activity are made aware of the entry. The audible signal shall be of a frequency (or be capable of producing a sound-pressure level) that can be heard over background noise.

• Entryways that are locked. During periods when access to the area is required, positive control over each entry is maintained.

• Continuous, direct, or electronic surveillance that is capable of preventing unauthorized entry.

• A control device that will automatically generate audible and visual alarm signals to alert personnel in the area of the intended use or operation of the radiation source in sufficient time to either evacuate the area or activate a secondary control device that will prevent use or operation of the source.

6.4 Very High Radiation Areas

6.4.1 In addition to the requirements in Section 6.3, additional control measures, such as double controlled locks, shall be used to ensure individuals are not able to gain unauthorized or inadvertent access to Very High Radiation Areas.


PROJECT


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Any records generated during the performance of this procedure shall be evaluated as part of the annual audit of the Health Physics program.

8. RECORDS

Radiological documents and/or records shall be stored, arranged, indexed, retained, retrieved, and disposed of in accordance with all applicable NRC document regulations and requirements.

9. REFERENCES




RPO-402, “Radiological Posting and Labeling.”

10. APPENDIXES

None

ATTACHMENT 15 RPO-404, Sealed Source Accountability

and Leak Checks

RPO-404 Rev. 1

Sealed Source Accountability and Leak Checks for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project




Signatur

SEALED SOURCE ACCOUNTABILITY AND LEAK CHECKS FOR THE LUCKEY FORMERLY UTILIZED

SITES REMEDIAL ACTION PROGRAM REMEDIATION PROJECT


RPO-404 1 2 of 11



1 09/19/16 Revise document. Edits and comments from the Stakeholder review.




RPO-404 1 3 of 11

Table of Contents

1. PURPOSE ..............................................................................................................................5

2. APPLICABILITY ..................................................................................................................5



3.2 Prerequisites ...............................................................................................................6

4. GENERAL .............................................................................................................................6

4.1 Equipment ..................................................................................................................6



4.4 Revisions ....................................................................................................................6

5. DEFINITIONS .......................................................................................................................6

6. PROCEDURE ........................................................................................................................6

6.1 Source Receipt ............................................................................................................6

6.2 General Requirements for Source Accountability and Leak Checks .........................7

6.3 Source Leak Check .....................................................................................................8

6.4 Conducting Leak Checks of Plated Sources or Sources with Thin/Fragile Coverings ...................................................................................................................8

6.5 Conducting Leak Checks of Encapsulated Sources ...................................................9

6.6 Interpretation of Source Leak Check Results .............................................................9

6.7 Source Accountability ................................................................................................9





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8. RECORDS ...........................................................................................................................10

9. REFERENCES .....................................................................................................................11

10. APPENDIXES .....................................................................................................................11




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1. PURPOSE

The purpose of this procedure is to provide instruction for the performance of leak checks and accountability checks of radioactive sources.

2. APPLICABILITY

This procedure applies to Portage management, supervisors, individuals and contractors that perform leak check and accountability checks or radioactive sources where their work assignment is controlled by Portage.





• Ensure that individuals are qualified to perform this procedure.

• Notify individuals and schedule source leak checks and inventories when due.

• Evaluate the results of leak checks and consult with the source owner when a source fails a leak check.

• Dispose of radioactive sources that are leaking or are no longer desired/required.

• Ensure that all radiological survey documentation, relating to source leak checks, is reviewed.



• Comply with entry requirements.

• Operate radiological survey instrumentation in accordance with approved operating procedures




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3.2 Prerequisites

Not applicable.

4. GENERAL

4.1 Equipment

Radiation and contamination survey instrumentation

Smear material

Various Personnel Protective Clothing


Not applicable.


When perform leak checks on electroplated sources or sources with a thin/fragile covering, DO NOT smear the active electroplated surface or the thin/fragile covering. This may damage the source and give a false indication that the source is leaking.

Source leak check results shall be recorded in units of microcuries.

4.4 Revisions


5. DEFINITIONS

See RPO Glossary.

6. PROCEDURE

6.1 Source Receipt

6.1.1 Upon receipt of a new radioactive source, assign a unique source identification number.

6.1.2 Add the source information to the Source Inventory Log (form FRN-0027)




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6.1.3 Complete an individual Source Leak Check and Inventory Record (form FRN-0028).

6.1.4 Add the leak check and inventory record to the logbook.

6.1.5 Perform a source leak check in accordance with Section 6.3.

6.2 General Requirements for Source Accountability and Leak Checks

NOTE: Sealed sources are exempt from leak check and inventory requirements when the source activity is less than the activity stated in the regulations regarding exempt sources.

6.2.1 Leak check and inventory each sealed source containing licensed material, with a half-life greater than thirty days and in any form other than gas or H-3, for leakage and/or contamination at intervals not to exceed six (6) months. Leak check sources designed for the purpose of emitting alpha particles at intervals not to exceed three (3) months.

6.2.2 Leak check all new sources prior to placing them in service.

6.2.3 The periodic leak check interval for sealed sources that are stored and not being used will not exceed 3 years. Leak check sources held in long term storage for leakage prior to any use or transfer to another person unless they have been leak checked within six months prior to the date of use or transfer.

6.2.4 Source leak checks shall be capable of detecting the presence 0.005 microcuries of radioactive material on the sample media (smear material). A smear shall be taken from the sealed source or from the surfaces of the device in which the sealed source is permanently or semi-permanently mounted or stored on which one might expect contamination to accumulate.

6.2.5 If the leak check reveals the presence of 0.005 microcuries or more of removable contamination:

• Immediately withdraw the sealed source from use. • Decontaminate, repair, or dispose of the source in accordance with

regulations. • Immediately contact the RSO. The RSO will file a report with the U.S.

Nuclear Regulatory Commission, describing the equipment involved, the leak check results, and the corrective actions taken within five (5) days.




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6.3 Source Leak Check

6.3.1 Prior to leak checking new or unfamiliar radioactive sources, determine how the source is used and decide which surfaces need to be surveyed. If there is a question on how to conduct a source leak check for a particular source, contact the RSO for guidance.

6.3.2 Using a dry smear, gently wipe the accessible area of the source and/or source container and place smear in a clean coin envelope or suitable collection container.

NOTE: See precaution in Section 6.4 for performing leak checks on plated sources or sources with thin or fragile coverings.

6.3.3 Using an appropriate portable survey meter, scan all smears to identify any elevated activity that could contaminate laboratory counting equipment.

6.3.4 Record the date and source location on the Source Leak Check and Inventory Record (form FRN-0028).

6.3.5 Count the smear (in accordance with Ref. 3.6, Section 6.9) for the appropriate alpha or beta radiation and record the results in microcuries.

6.3.6 When performing sealed source leak checks:

• Minimize direct contact with the source surface to limit extremity exposure. • Use extension devices, such as tongs or tweezers, to leak check sources when

dose rates are in excess of 10 millirem per hour (mrem/hr) at one foot. • Perform a frisk of your hands after performing the survey. • Wear appropriate PPE and dosimetry.

6.4 Conducting Leak Checks of Plated Sources or Sources with Thin/Fragile Coverings

CAUTION DO NOT WIPE THE SURFACE OF THE SOURCE. THIS MAY DAMAGE THE SOURCE OR GIVE A FALSE INDICATION THAT THE SOURCE IS LEAKING

6.4.1 Perform a survey for removable surface contamination on suspect surfaces, such




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as the inside of the source storage container and/or the area around the source. Use standard smear material if possible, otherwise use a cotton swab.

6.5 Conducting Leak Checks of Encapsulated Sources

6.5.1 Perform a survey for removable surface contamination on the accessible area of the source.

• Pay particular attention to seams or joints in the casing material since these areas are the most likely to develop a leak.

• Sources that are housed in a storage/use assembly need not be directly accessed (to maintain ALARA).

6.6 Interpretation of Source Leak Check Results

6.6.1 If source leak check results are greater than or equal to 0.005 microcuries, perform the following actions:

• Immediately contain the source and restrict access to source storage/use locations until area surveys are performed.

• Notify the RSO. • Conduct contamination surveys in source storage, use, and transit locations to

identify the potential spread of contamination.

6.6.2 If source leak check results indicate removable contamination, but are below regulatory removable contamination limits, perform the following actions:

• Instruct the source owner to contain the source and restrict access to source storage/use locations until area surveys are completed.

• Conduct contamination surveys in source storage, use, and transit locations to identify the potential spread of contamination.

• Notify the RSO.

6.6.3 Assist the source owner with interpretation of positive survey results. Provide, as needed, written instruction (e.g., remarks on survey form or e-mail) that clarifies appropriate actions for sources that are leaking or contaminated.

6.7 Source Accountability

6.7.1 Register new sources, or sources removed from long term storage, by recording the appropriate information on form FRN-0027 and form FRN-0028, within 5




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days of receipt.

6.7.2 When a new source is received, retain copies of the shipping documents and any manufacturer-supplied documents (e.g., leak test results or calibration certificates) for the life of the source.

6.7.3 During the inventory of both active and stored sources, pay particular attention to whether the source:

• is present and accounted for, • appears free of any damage, • is properly posted/labeled, and • is properly stowed and the storage device (locker, drawer, cabinet, etc.) is

properly posted/labeled.

6.7.4 For in-use (not in storage) sources, perform a physical inventory at least every six (6) months.

6.7.5 Document source inventory results on the Source Leak Check and Inventory Record (form FRN-0028).

6.7.6 When a source is removed from service, note the date of removal on the Source Inventory Log and remove the Source Leak check and Inventory Record form from the active section of the source logbook and place it in inactive section.

• If the source is to be disposed of, indicate disposal in the location column of the inventory record and dispose of in accordance with Ref. 3.6.


Documents generated during the performance of this procedure shall be audited in accordance with the Uniform Federal Policy Quality Assurance Project Plan for the Luckey FUSRAP Site Remediation Luckey, Ohio, Sampling and Analysis Plan..

8. RECORDS





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A log will be maintained containing a inventory of all accountable radioactive sources (form FRN-0027) and a record of each individual source with its leak check and inventory result (form FRN-0028).

Source leak check and inventory records shall be maintained for a minimum of five years from the date of the inventory. Leak check and inventory records shall be available for audits and inspection.

9. REFERENCES

CFR 20, “Standards for Protection against Radiation.”





RPO-610, “Procurement, Receipt, and Control of Radioactive Material.”

USACE, 2016, Uniform Federal Policy Quality Assurance Project Plan for the Luckey Formerly Utilized Sites Remedial Action Program Site Remediation, Luckey, Ohio, Sampling and Analysis Plan, PLN-5503, U.S. Army Corps of Engineers, Buffalo District, Buffalo, New York.

10. APPENDIXES

None

ATTACHMENT 16 RPO-405, Respiratory Protection

RPO-405 Rev. 0

Respiratory Protection for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project




Signatur

RESPIRATORY PROTECTION FOR THE LUCKEY FORMERLY UTILIZED SITES REMEDIAL ACTION



RPO-405 0 2 of 17






RPO-405 0 3 of 17

Table of Contents

1. PURPOSE ..............................................................................................................................5

2. APPLICABILITY ..................................................................................................................5



3.2 Prerequisites ...............................................................................................................6

4. GENERAL .............................................................................................................................6

4.1 Equipment ..................................................................................................................6



4.4 Equipment ..................................................................................................................8


4.6 Revisions ....................................................................................................................9

5. DEFINITIONS .......................................................................................................................9

6. PROCEDURE ........................................................................................................................9

6.1 General Information ...................................................................................................9

6.2 Selection of Respiratory Protection Devices ..............................................................9

6.3 Use of Respiratory Protection Devices ....................................................................12

6.4 Removal of Respiratory Protection Devices ............................................................12

6.5 Release of Respiratory Protective Devices ..............................................................12

6.6 Respirator Decontamination .....................................................................................13





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8. RECORDS ...........................................................................................................................14

9. REFERENCES .....................................................................................................................14

10. APPENDIXES .....................................................................................................................14

APPENDIX A Respirator Use Recommendation Charts ..............................................................15




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1. PURPOSE

The purpose of this procedure is to provide instruction to the Health Physics staff in the proper selection, issue, and use of respiratory protection for individuals wearing respiratory protection for the purpose of limiting intakes of radioactive material. This procedure also provides programmatic requirements and cautions for the various aspects of respiratory protection equipment use.

2. APPLICABILITY

This procedure applies to Portage management, supervisors, individuals and contractors using respiratory protection for the purpose of limiting intakes of radioactive materials where their work assignment is controlled by Portage.




RSO or designee • Implement this procedure. • Ensure individuals that issue respiratory protection

equipment are qualified to perform this procedure. • Provide support for determination of feasible engineering

controls when assessing the need for respiratory protection. • Assist in the selection of the appropriate type/class of

respirator that will provide adequate protection for each radiological contaminant.

• Provide adequate equipment or material, to supplement respiratory protective equipment, to reduce the likelihood that respirator use might contribute to workplace accidents or injury. (i.e., spectacle adapters, voice amplification equipment, material or equipment to prevent or reduce fogging of respirator lenses, and body-cooling equipment in environments with high temperature or high humidity).

• Estimate and review, as necessary, the concentration of radiological contaminants in the work area, both prior to respirator selection and periodically during respirator use.

• Recommend the performance of work without respiratory protection if the total effective dose equivalent (TEDE) would be lower by not using respiratory devices.




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Health physics staff • Assess the radiological respiratory hazard(s) in a work area and assigning the appropriate respiratory protection for this work, as needed.

• Perform periodic monitoring of radiological hazards in the work area, in accordance with Reference 4, to ensure that the assigned respiratory protection is effective against the hazard(s) of concern.

• Survey respirators that are to be released from Airborne Radiological Areas and verify that surface contamination levels on respiratory equipment do not exceed the limits for unrestricted release.

• Inform the RSO when contamination is found on the inside of a respirator facepiece and/or on an individual’s face after removal of respiratory equipment.

3.2 Prerequisites

Individuals requiring respiratory protection equipment for the protection against airborne radioactive materials shall complete a suitable respiratory protection training program, including hands-on training, prior to being issued respiratory protection equipment or being fit tested for a tight-fitting respirators.

The worker shall be fit-tested with the same make, model, style, and size of respirator that will be used at the work location. A successful fit test shall be conducted, for each respirator used, prior to issuance of respiratory protection equipment to the individual.

Medical screening, respirator training, and respirator fit testing is a prerequisite for issuance and usage of respiratory protection equipment.

Any individual wearing a respirator shall be clean shaven.

4. GENERAL

4.1 Equipment

Various types of personnel monitoring devices.


Not applicable.




RPO-405 0 7 of 17


Any change or modification to respiratory protection equipment, however minor, may void the respirator approval (NIOSH certification) and significantly affect the performance of the respirator. Changes or modifications to respiratory protection equipment, except by a manufacturer’s certified technician, is NOT allowed.

Work involving industrial hazards as well as radiological hazards may require special respiratory equipment or filtration canisters/cartridges and require additional engineering controls to be implemented. Consult with the Respiratory Protection Program Administrator (RPPA) to determine the appropriate respirator use.

When wearing an airline respirator (also known as a supplied-air respirator), the user is restricted in movement by the hose and must return to a respirable atmosphere by retracing the route of entry. In addition, the hose is subject to being severed, pinched, or disconnected. Additional precautions and limitations associated with supplied-air respirators are provided in the Respiratory Protection Program (as part of the APP/SSHP (PRC-1153).

The time period over which protection is provided by an air purifying respirator (APR) is dependent on the canister, cartridge, or filter type; the concentration of the contaminant; the temperature and humidity levels in the ambient atmosphere; the user’s respiratory rate; etc.

While wearing a respirator, communication can be difficult. Therefore, prior consideration as to how individuals will communicate, especially in the event of an emergency, is essential.

Half-face respirators shall NOT be used for protection from airborne radioactive materials.

When used in environments below 32°F, SCBAs must be equipped with a full facepiece that is certified for use below 32°F and equipped with a nose cup or other suitable accessory or coating to maintain NIOSH certification.

While using an SCBA or a combination of a airline respirator with SCBA under Immediately Dangerous to Life or Health (IDLH) conditions, at least one standby person shall be present.

The standby person shall have the proper equipment available to assist the respirator wearer in case of difficulty.




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Communications (visual, voice, signal line, telephone, radio, or other suitable means) shall be maintained between the standby person and the respirator wearer.

While working in the IDLH atmosphere, the wearer shall be equipped with safety harness and safety lines to permit removal to a safe area, if necessary. Provisions for rescue other than safety harness and lines may be used, if equivalent.

When respirator use is required, the user is expected to leave the area anytime the following conditions occur:

Equipment malfunction. Undue physical or psychological distress. Procedural or communication failure. Significant deterioration of operational conditions. Or any other condition requiring relief by the wearer. Anything in the face-to-facepiece seal area of a tight-fitting respirator that is under the control of the respirator user is prohibited. The list of prohibited materials includes (but is not limited to) facial hair of any kind in the seal area (the worker must be clean-shaven), hair from the head intruding into the seal area, cosmetics, spectacle temple bars, protective clothing, and equipment. Any item worn inside the respirator must be approved for use with the respirator, consult with RPPA for guidance.

The periods of time respirators are worn continuously and the overall duration of use should be kept to a minimum. Under no circumstances shall a worker be allowed to wear a respirator for more than 4 consecutive hours without a break of at least 15 minutes.

Use of air supplied suits requires special training and qualifications. Consult the RPPA for guidance.

Respirator fit testing shall be in accordance with the requirements of 29 CFR 1910.1048 Appendix E. Fit testing may only be performed by individuals trained to perform those activities, consult the RPPA for guidance.

4.4 Equipment

Various Respiratory Protection Equipment

Various Personnel Protective Clothing





RPO-405 0 9 of 17

Not applicable.

4.6 Revisions


5. DEFINITIONS

See RPO Glossary.

6. PROCEDURE

6.1 General Information

Engineering controls, administrative controls, and safe work practices are the primary means to contain radioactivity at the source, thereby reducing the need for respiratory protection. Consider the use of respiratory protection under the following conditions:

When engineering and administrative controls have been applied and the potential for airborne radioactivity still exists.

During breach or disassembly of contaminated systems or components. When work is to be done in areas or on equipment identified as Contamination Areas. During work on contaminated or activated surfaces with the potential to generate

airborne radioactivity in excess of 0.5 times the Derived Air Concentration (DAC). Only respirators approved by the RPPA (NIOSH certified) shall be used at the work site. Any change or modification, however minor, may void the respirator approval and significantly affect the performance of the respirator.

6.2 Selection of Respiratory Protection Devices

6.2.1 To the extent possible, determine the following:

Radionuclides of concern and the physical properties of each. This information should be recorded in the RWP covering the job.

Worker activity, such as continuous or intermittent, and rate, such as light, medium, or heavy.

Work location and area(s) of potential hazard(s). Duration of the job.




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6.2.2 Measure or estimate the area dose rate(s) of the work site, if any.

6.2.3 Obtain a representative air sample to determine the airborne radionuclide concentration(s) at the work site, unless:

The acquisition of an air sample(s) is not practical. The acquisition of air sample(s) is not consistent with ALARA. The work itself may generate airborne activity later in the job. 6.2.4 For these cases, contact the RSO for guidance in estimating the potential airborne

radionuclide concentration(s) and the need for respiratory protection.

6.2.5 Determine the DAC for each radionuclide of concern.

6.2.6 Determine the fraction of the DAC in the work area by dividing the measured or estimated radionuclide concentration by the corresponding DAC value.

Fraction DAC Ci/ml) ( DAC

Ci/ml) (ion ConcentratActivity deRadionucli=

µµ

6.2.7 If two or more radionuclides of concern are present and the concentration of each radionuclide can be determined, calculate the DAC fraction as follows:

Fraction DAC = DACCi/ml + . . . +

DACCi/ml +

DACCi/ml

n

n

B

B

A

A µµµ

6.2.8 If two or more radionuclides of concern are present, and the concentration of one or more of the radionuclides is not known, calculate the DAC fraction based on the most restrictive DAC for the radionuclides of concern.

6.2.9 If the DAC fraction is < 0.5, document that respiratory protection equipment is not required.

6.2.10 If the DAC fraction is > 0.5 and a radiation dose rate exists, determine if the use of respiratory protection is recommended.

Use the appropriate chart in Appendix A and find the point where the area dose rate (measured or estimated) and the DAC fraction intersect.

Respiratory protection is recommended when intersecting points are located outside of the shaded area of the graph.




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NOTE: Respiratory protection may not be warranted for short-term jobs. If needed, contact the RPPA for guidance.

6.2.11 If respiratory protection is recommended, select a respirator that has an Assigned Protection Factor (APF) greater than the value of the DAC fraction, if available.

6.2.12 APFs for commonly used respirators are listed below. Contact the RPPA to obtain the appropriate APF for respirators not listed.

Respirator Type APF

Air Purifying (APR) - Full Face 50

Airline Hood (Supplied-Air) 25/1000*

SCBA 10,000

NOTE: * = The employer must have evidence provided by the respirator manufacturer that testing of these respirators demonstrates performance at a level of protection of a 1000 or greater to receive an APF of 1000.

NOTE: The use of positive pressure respiratory protection devices is recommended wherever practicable to alleviate fatigue and increase comfort.

6.2.13 All APRs used to protect against the inhalation of radioactive material shall employ an approved High Efficiency Particulate (HEPA) or combination HEPA and chemical canister/cartridge.

6.2.14 Contact the RPPA for assistance if:

There is a potential for an oxygen-deficient environment. A confined space hazard exists. Work time limits and/or body cooling devices are needed to reduce heat stress when

work is to take place in hot environments. 6.2.15 Obtain written permission from the RSO prior to allowing personnel to incur

internal exposure.




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Specific justification of the need to accept the exposure, including a description of measures taken to mitigate the airborne radioactivity, shall be documented in the RWP as part of the authorization process.

6.2.16 Document the type of respirator selected and any work time restrictions on the RWP.

6.2.17 Attach or include supporting calculations with the RWP, as applicable.

6.3 Use of Respiratory Protection Devices

WARNING: HPTs should remind personnel that fit checks of respirators shall be performed each time a respirator is donned or adjusted.

6.3.1 While respiratory protection equipment is in use, evaluate the level of airborne radioactivity in the workplace through the use of continuous air monitors or grab air-samplers.

6.3.2 Evaluate air sample media as soon as practicable to ensure that the appropriate respiratory protection is being used.

6.3.3 Stop the job and re-evaluate respiratory requirements if air sample results demonstrate the potential for the DAC fraction to exceed the APF of the respirator.

6.4 Removal of Respiratory Protection Devices

6.4.1 If an operation requires that respiratory protection devices be re-used prior to release, or the RWP requires a survey be performed, perform a surface contamination survey on the inside of the respirator facepiece and on the external surface(s) of respiratory equipment and document.

6.4.2 If the respiratory equipment is not going to be re-used that day, perform a release survey of respiratory equipment (checking inside and outside the mask) as soon as possible upon its removal. Be careful not to contaminate the inside of the facepiece during removal.

6.4.3 If contamination is found on the inside of a respirator facepiece, restrain the individual from leaving the immediate area. Contact the RSO immediately.

6.5 Release of Respiratory Protective Devices

6.5.1 If respirator contamination levels are below the release limits, remove the




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respirator from the radiologically controlled area as soon as practicable.

6.5.2 If respirator contamination levels exceed the release limits, control the equipment as radioactive material. Instruct the user that the respirator will either need to be decontaminated, stored for decay, or disposed of as radioactive waste.

NOTE: Respirator cartridges and canisters, with any detectable contamination levels, shall be treated and disposed of as radioactive material. Combination HEPA and chemical cartridges or canisters shall be disposed of as mixed waste.

6.5.3 Document the respirator release survey.

6.6 Respirator Decontamination

6.6.1 Decontaminate respiratory protection equipment if required. Use only commercially available wipes or water and a mild detergent. Avoid solvents or harsh chemicals as decontamination agents.

6.6.2 Treat respirator cleaning effluents (materials and fluids) as radioactive waste.


Inspect respirator facepieces that are routinely available for issue, at least every month or in accordance with manufacturer's instructions. If such devices are stored in clear plastic bags, they should be handled and examined, but need not be removed from the bags for this inspection as long as the inspector can determine that the device is ready for issue.

Inventory and functionally test equipment, used in conjunction with facepiece respirators (e.g., belt- or facepiece-mounted air regulators, air-supply hoses, portable distribution manifolds), periodically or prior to use.

Visually inspect emergency respiratory protection equipment, monthly and operationally tested at least quarterly. Visually inspect escape-only devices monthly.

Test breathing air cylinders, including SCBA cylinders, as prescribed in the Shipping Container Specification Regulations of the Department of Transportation. Each breathing air cylinder should be permanently and legibly marked “Breathing Air” or “Compressed Breathing Air.”




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The quality of the air delivered to any atmosphere-supplying respirator shall meet the requirements of Grade D air for breathing air systems, as defined in CGA G-7.1-1997, “Commodity Specification for Air.”

8. RECORDS

Respiratory protection related documents and/or records shall be stored, arranged, indexed, retained, retrieved, and disposed of in accordance with this procedure and all applicable document regulations and requirements.

9. REFERENCES

10 CFR 20, “Standards for Protection Against Radiation.”

NRC Regulatory Guide 8.15, “Acceptable Programs for Respiratory Protection,” October 1999.

29 CFR 1910.134, “Respiratory Protection.”

29 CFR 1910.1048, Appendix E “Qualitative and Quantitative Fit Testing Procedure.”

49 CFR 173 and 178, “Shipping Container Specification Regulations of the Department of Transportation.”

Respiratory Protection Program (PRC-1153, Respiratory Protection)

CGA G-7.1-1997, "Commodity Specification for Air."



10. APPENDIXES

Appendix A, Respirator Use Recommendation Charts




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APPENDIX A Respirator Use Recommendation Charts




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Respirator Use Chart 0 - 10 mrem/hr

0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1

1 2 3 4 5 6 7 8 9 10

Area Exposure Rate (mrem/hr)

DACFraction

Respirator use may increase TEDE.

Respirator use may decrease TEDE.


0

0.5

1

1.5

2

2.5

3

3.5

4

4.5

5

1 10 20 30 40 50


DACFraction






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0

1

2

3

4

5

6

7

8

9

10

1 10 20 30 40 50 60 70 80 90 100


DACFraction




0

10

20

30

40

50

60

70

80

90

100

1 100 200 300 400 500 600 700 800 900 1000


DACFraction



ATTACHMENT 17 RPO-406, Internal and External

Personnel Monitoring

RPO-406 Rev. 0

Internal and External Personnel Monitoring for the Luckey Formerly Utilized Sites Remedial Action Program Remediation Project




Signature

INTERNAL AND EXTERNAL PERSONNEL MONITORING FOR THE LUCKEY FORMERLY



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Table of Contents

1. PURPOSE ..............................................................................................................................5

2. APPLICABILITY ..................................................................................................................5



3.2 Prerequisites ...............................................................................................................5

4. GENERAL .............................................................................................................................5

4.1 Equipment ..................................................................................................................5



4.4 Revisions ....................................................................................................................6

5. DEFINITIONS .......................................................................................................................6

6. PROCEDURE ........................................................................................................................6

6.1 External Monitoring ...................................................................................................6

6.2 Planned Special Exposures (PSE) ..............................................................................8

6.3 Monitoring Devices ....................................................................................................8

6.4 Internal Monitoring ....................................................................................................9

6.5 Summation of Internal and External Exposures .......................................................10

6.6 Documentation .........................................................................................................11

6.7 Notification and Reporting .......................................................................................12





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8. RECORDS ...........................................................................................................................13

9. REFERENCES .....................................................................................................................13

10. APPENDIXES .....................................................................................................................13

APPENDIX A Occupational Dose Limits .....................................................................................14




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1. PURPOSE

The purpose of this procedure is to provide guidance and instruction for the monitoring, documentation, and reporting of occupational radiation exposure.

2. APPLICABILITY

This procedure applies to Portage management, supervisors, individuals and contractors that are involved in the monitoring of occupational exposure (internal and external) to radiation from licensed and unlicensed radiation sources, where their work assignment is controlled by Portage.







3.2 Prerequisites

Dosimetry issued to personnel shall be capable of measuring the appropriate and expected external radiation field(s).

Dosimetry shall only be issued to currently qualified and trained individuals and shall be worn only by the individual issued the dosimeter.

Prior to initial issue of dosimetry, the lifetime and current year exposure shall be determined in accordance with this procedure. A dose estimate provided by the worker may be used for the current year while awaiting receipt of exposure records or if such records are not received from other facilities.

4. GENERAL

4.1 Equipment

Various types of personnel monitoring devices.




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Not applicable.


Not applicable.

4.4 Revisions


5. DEFINITIONS

See RPO Glossary.

6. PROCEDURE

6.1 External Monitoring

6.1.1 Portage shall monitor individuals, where their work assignment is controlled by Portage for occupational radiation exposure received from licensed and unlicensed radiation sources, and shall supply and require the use of individual monitoring devices.

6.1.2 For individuals at a work location where the regulatory requirements are NRC based, dosimetry shall be issued for:

• Adults likely to receive, in 1 year from sources external to the body, a dose in excess of 10 % of the regulatory limits.

• Minors likely to receive, in 1 year, from radiation sources external to the body, a deep dose equivalent in excess of 0.1 rem (1 mSv), a lens dose equivalent in excess of 0.15 rem (1.5 mSv), or a shallow dose equivalent to the skin or to the extremities in excess of 0.5 rem (5 mSv).

• Declared pregnant women likely to receive during the entire pregnancy, from radiation sources external to the body, a deep dose equivalent in excess of 0.05 Rem (.5 mSv).

6.1.3 For individuals at a work location where the regulatory requirements are DOE-based, dosimetry shall be issued for:




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• Radiological workers who, under typical conditions, are likely to receive an effective dose equivalent to the whole body of 0.1 rem (0.001 sievert) or more in a year.

• Radiological workers who, under typical conditions, are likely to receive a shallow dose equivalent to the skin or to any extremity of 5 rems (0.05 sievert) or more in a year.

• Radiological workers who, under typical conditions, are likely to receive a lens of the eye dose equivalent of 1.5 rems (0.015 sievert) or more in a year.

• Declared pregnant workers who are likely to receive from external sources a dose equivalent to the embryo/fetus in excess of 10 percent of the applicable limit.

• Occupationally exposed minors likely to receive a dose in excess of 50% of the applicable limits in a year from external sources.

• Members of the public entering a controlled area likely to receive a dose in excess of 50% of the limit in a year from external sources.

• Individuals entering a high or very high radiation area.

6.1.4 Work restrictions shall be implemented for any worker reaching 50% of the limits of Appendix A or as required by the RSO.

6.1.5 When required, external exposure monitoring shall normally be accomplished using thermoluminescent dosimeters (TLD). The RSO shall approve the use of monitoring devices other than TLDs.

6.1.6 Self-reading pocket dosimeters may be used to provide real time exposure readings for external deep dose measurements but should only be used as an estimate of exposure and not legal dose. If pocket dosimeters are utilized, they must meet the performance specifications as identified in NRC Regulatory Guide 8.4.

6.1.7 Monitoring device(s) shall be worn on the front of the upper torso unless otherwise directed by the RSO.

6.1.8 For work areas where the external radiation field is non-uniform, and requires the use of exposure monitoring devices, extremity dosimetry shall also be issued to the worker.

6.1.9 Radiological surveys shall be performed to supplement personnel monitoring when work is being performed where workers are required to be monitored for occupational exposure to radiation.




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6.2 Planned Special Exposures (PSE)

6.2.1 Provisions for planned special exposures, which are in addition to and accounted for separately from routine occupational doses, shall be authorized by the Corporate RSO.

6.2.2 Planned Special Exposures should only be authorized in exceptional situations when alternatives which might avoid the higher exposure are unavailable or impractical.

6.2.3 The following conditions apply to all planned special exposures:

• The individual(s) involved are informed of the purpose of the planned operation. • The individual(s) involved are informed of the estimated exposure and special

radiation or other conditions that might be involved in performing the task. • The individual(s) involved are instructed in the measures to be taken to keep their

exposure ALARA considering other risks that may be present. • A complete and documented lifetime exposure history for each individual shall be

available. • A PSE shall not be authorized that would cause an individual to receive a dose

from all planned special exposures and doses in excess of the limits to exceed the numerical values of any of the federal limits in any year, and five (5) times the annual limits during the individual’s lifetime

6.2.4 Portage shall maintain records of all Planned Special Exposures in accordance with federal regulations and report to the individuals in writing the best estimate of their exposure within 30 days of the exposure.

6.2.5 Portage shall submit a written report to the Administrator of the appropriate NRC Regional Office listed in appendix D to part 20 within 30 days following any planned special exposure conducted, informing the Commission that a planned special exposure was conducted and indicating the date the planned special exposure occurred and the information required.

6.3 Monitoring Devices

6.3.1 All personnel dosimeters issued to individuals shall be of the appropriate type, range, accuracy, and sensitivity for the radiation being measured.

6.3.2 TLD’s used for record dose monitoring must be selected and processed under the following conditions:




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• Processing lab must have accreditation from the National Voluntary Laboratory Accreditation Program (NVLAP) or DOE Laboratory Accreditation Program (DOELAP); and

• Approved in this accreditation process for the type of radiation or radiations included in the accreditation program that most closely approximates the type of radiation or radiations for which the individual wearing the dosimeter is monitored.

6.3.3 A record shall be maintained of TLD’s issued to individuals for monitoring purposes. Form FRN-0029 is an example of an approved TLD issue log.

6.4 Internal Monitoring

6.4.1 Portage shall monitor the occupational intake of radioactive material during any work activity (routine or special operations).

6.4.2 For individuals at a work location where the regulatory requirements are NRC based, monitoring shall take place for, and assess the committed effective dose equivalent to:

• Adults likely to receive, in 1 year, an intake in excess of 10 % of the applicable ALI(s).

• Minors likely to receive, in 1 year, a committed effective dose equivalent in excess of 0.1 rem (1 mSv).

• Declared pregnant women likely to receive, during the entire pregnancy, a committed effective dose equivalent in excess of 0.05 Rem (.5 mSv).

6.4.3 For individuals at a work location where the regulatory requirements are DOE based, monitoring shall take place for, and assess the committed effective dose equivalent to:

• Radiological workers who, under typical conditions, are likely to receive a committed effective dose equivalent of 0.1 rem (0.001 sievert) or more from all occupational radionuclide intakes in a year;

• Declared pregnant workers likely to receive an intake or intakes resulting in a dose equivalent to the embryo/fetus in excess of 10 percent of the limit stated;

• Occupationally exposed minors who are likely to receive a dose in excess of 50 percent of the applicable limit stated from all radionuclide intakes in a year; or

• Members of the public entering a controlled area likely to receive a dose in excess of 50 percent of the limit stated at from all radionuclide intakes in a year.




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6.4.4 Routine internal exposure shall be determined by sampling the air within the breathing zone of the worker.

6.4.5 Internal dose shall be determined by converting airborne concentrations to intakes in accordance with NRC Regulatory Guide 8.34, Position 3.3.

6.4.6 Dose tracking shall be maintained using the DAC Hour Tracking Log (form FRN-0030).

6.4.7 When a potential or actual condition exists where the individual(s) could have received an unmonitored intake of radioactive material, determine intake by measurements of quantities of radionuclides excreted from or retained in the body by:

• Urine or fecal analysis. • Whole body counting.

6.4.8 Calculation of declared pregnant worker intake to committed effective dose equivalent (for the conversion of declared worker intake to embryo/fetus dose), shall be performed in accordance with NRC Regulatory Guide 8.36, Positions 2 and 3.

6.4.9 Work restrictions shall be implemented for any worker with an intake in excess of 50% of the applicable ALI(s), or as required by the RSO.

6.4.10 Work restrictions shall be implemented for any worker with an intake in excess of 50% of the chemical toxicity limits for soluble uranium, or as required by the RSO.

6.5 Summation of Internal and External Exposures

6.5.1 Results of internal and external dose monitoring shall be used to calculate the total organ dose equivalent and total effective dose equivalent as required.

6.5.2 Summation calculations shall be performed in accordance with NRC Regulatory Guide 8.34, Position 7.1.

6.5.3 For a declared pregnant worker, sum the internal exposure of the embryo/fetus with the external dose to the declared pregnant worker to obtain the dose equivalent to the embryo/fetus.




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6.6 Documentation

6.6.1 For those individuals for whom monitoring is required, a determination of current year occupational exposure at other facilities is required.

6.6.2 Personnel Exposure History (form FRN-0032) shall be completed prior to providing any dose monitoring devices to the individual.

6.6.3 For missing exposure reports an Exposure History Request Form (form FRN-0031) may be sent to the licensee from whom the exposure record is required.

6.6.4 Acceptable dose reports are those issued by specific licensees or a completed NRC Form 4, or equivalent, signed by the individual and countersigned by an appropriate official of the most recent employer or current employer.

6.6.5 If an individual’s records are estimates or incomplete Portage shall make reasonable efforts (at least two written attempts) to obtain complete records of each individual’s prior years’ occupational dose.

• If complete records cannot be obtained, a written estimate signed by the individual may be accepted to demonstrate compliance with federal regulations.

6.6.6 A NRC Form 5, or equivalent, shall be maintained for each individual being monitoring.

6.6.7 The Form 5, or equivalent, shall be at a minimum updated quarterly.

NOTE: Organ doses (committed dose equivalent to the organ receiving the highest dose) need not be calculated if the committed effective dose equivalent does not exceed 1 rem and there are no overexposures in any dose category within the monitoring year, including doses previously reported by other licensees.

6.6.8 For a declared pregnant worker, the embryo/fetus’ dose for the entire gestation period shall be recorded, but need not be included on NRC Forms 4 and 5.

• If requested by the monitored woman, a letter report shall be provided to subsequent licensees to document prior embryo/fetus dose.

6.6.9 If dose monitoring is performed in compliance, a dose report to the monitored




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individuals(s) will be issued.

• A copy of the report shall also be issued to the NRC.

6.6.10 Dosimetry records, including detailed information, identified with a specific individual shall be readily available to that individual and to others on a need-to-know basis (e.g., the individual’s supervisor, management, and safety personnel).

• Individuals can request their dosimetry records from the Corporate RSO.

6.6.11 Upon request, Portage shall provide dose records to an individual terminating employment as soon as the data is available, but not later than 90 days after termination.

• If requested, a written estimate of the radiation dose received by that employee (based on available information) shall be provided at the time of termination.

6.7 Notification and Reporting

6.7.1 The appropriate regulatory agency shall be immediate notified for any event involving byproduct, source, or special nuclear material possessed by the licensee that may have caused, or threatens to cause, an individual to receive:

• A total effective dose equivalent of 25 rems (0.25 Sv) or more; or • A lens dose equivalent of 75 rems (0.75 Sv) or more; or • A shallow-dose equivalent to the skin or extremities of 250 rads (2.5 Gy) or more.

6.7.2 The appropriate regulatory agency shall be notified within 24 hours of discovery of an event involving the loss of control of licensed material possessed by the licensee that may have caused, or threatens to cause an individual to receive:

• A total effective dose equivalent exceeding 5 rems (0.05 Sv); or • A lens dose equivalent exceeding 15 rems (0.15 Sv); or • A shallow-dose equivalent to the skin or extremities exceeding 50 rems (0.5 Sv)

6.7.3 In addition to the notification(s) required above, each licensee shall submit a written report within 30 days for any incident for which notification is required by step 6.7.1 or 6.7.2; or after learning of any of the following occurrences:

• Doses in excess of the occupational dose limits for adults; or • Doses in excess of the occupational dose limits for a minor; or




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• Doses in excess of the limits for an embryo/fetus of a declared pregnant woman; or • Doses in excess of the limits for an individual member of the public; or • Doses in excess of any applicable limit in the license


This procedure and related documents shall be made available as part of the annual audit of the Health Physics Program.

8. RECORDS

Any documents and/or records created in the evaluation or reporting of worker exposures shall be stored, arranged, indexed, retained, retrieved, and disposed of in accordance with this procedure and all applicable document regulations and requirements.

9. REFERENCES

CFR 20, “Standards for Protection against Radiation.”



RPO-209, “Operation and Calibration of Lapel Air Samplers.”

NRC Regulatory Guide 8.4, “Direct-reading and Indirect-reading Pocket Dosimeters.”

NRC Regulatory Guide 8.7, “Instructions for Recording and Reporting Occupational Radiation Exposure Data.”


NRC Regulatory Guide 8.34, “Monitoring Criteria and Methods to Calculate Occupational Radiation Doses.”

NRC Regulatory Guide 8.36, “Radiation Dose to the Embryo/Fetus.”

10. APPENDIXES

Appendix A, Occupational Dose Limits




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APPENDIX A Occupational Dose Limits

General Employees Whole body (total effective dose equivalent) 5 rems Individual organ or tissue other than the lens of the eye 50 rems Lens of the eye 15 rems Skin or to any extremity 50 rems

Embryo/fetus of a declared pregnant worker 0.5 rems Occupationally Exposed Minors

Whole body (total effective dose equivalent) 0.1 rems Lens of the eye 1.5 rems Skin or to any extremity 5 rems

Members of the Public 0.1 rems The assigned deep-dose equivalent and shallow-dose equivalent must be for the part of the body receiving the highest exposure. The deep-dose equivalent, lens dose equivalent, and shallow-dose equivalent may be assessed from surveys or other radiation measurements for the purpose of demonstrating compliance with the occupational dose limits, if the individual monitoring device was not in the region of highest potential exposure, or the results of individual monitoring are unavailable.

ATTACHMENT 18 RPP Forms

AUDIT/ASSESSMENT TRACKING LOG Page _____ of _____

Tracking No.

Audit Date Audit No. Audit Type1

Corrective Action

Plan No.

Corrective Action Plan

Written Date

Written Closure

Report No.

Written Closure Report Date

Comments

FRN-0002 Notes:

1 - Internal, Independent, NRC, DEP, OSHA, etc.

PORTABLE INSTRUMENT RESPONSE CHECK SHEET Page ___ of ___

Instrument: Serial No: Probe: Serial No:

Cal. Due Date: Response Check Location:

α Channel

Source Isotope: Source ID: Source Jig ID:

Source Reference Reading: +20% -20%

βγ Channel

Source Isotope: Source ID: Source Jig ID:

Source Reference Reading: +20% -20%

Response Checks

Date/Time α Bkg. βγ Bkg. α Reading

βγ Reading Remarks Initials

Review: Date:

FRN-0005

INSTRUMENT QC CHECK SHEET Page ___ of ___

Date: Time:

Instrument: Serial No:

Probe: Serial No:

Cal. Performed Date: Cal. Due Date:

Source Isotope: Source #:

QC Check Location:

Jig Used: Yes No Jig ID# (circle one)

QC Counting Results

Count No. Count Result

1

2

3

4

5

Add results, list in Total

Total

Divide the total by 5

Source Reference Reading

(Average)

Performed By: Date:

RSO Review: Date:

FRN-0006

Range Calculation

Source Ref. Reading: X 20% =

Avg. + 20% =

Avg. - 20% =

Acceptable Range:

From to (Avg. - 20%) (Avg. + 20%)

Comments:

RADIOLOGICAL SURVEY FORM

Survey Number: Page _____ of _____

Location Requester Date Time

Purpose RWP #

Instrument and Probe Type and Serial Number Surveyor(s) Printed Name Surveyor(s) Signature

BETA-GAMMA ACTIVITY

Counting Data Attached �Yes

% Eff. /Radionuclide

ALPHA ACTIVITY Counting Data Attached �Yes

% Eff. /Radionuclide

RADIATION SURVEY

# ITEM DESCRIPTION/LOCATION

cpm Bkg. cpm

dpm 100 cm2 (1)

T/R/F(2)

cpm

Bkg. cpm

dpm 100 cm2 (1)

T/R/F(2)

mrem/hr (3) Distance

(1) If area other than 100 cm2, record as dpm/probe, or dpm/LAW. (2) Total/Removable/Fixed. (3) Indicate type, if other than gamma (i.e., n or β). Remarks: Reviewed by: Date:

FRN-0007a

RADIOLOGICAL SURVEY MAP (complete)

Page ________of _______

Site Name:________________________________________________ Location:_______________________________________________ Date:_____________ Time:___________ Purpose:____________________________________________________________________Survey #______________________________ RWP #:___ _______________________ Instrument #1 – Model:____________________ Serial #_________________Probe Model:___________________ Serial#________________ Cal Due:__________ Eff.:_____ _____ Instrument #1 – Model:____________________ Serial #_________________Probe Model:___________________ Serial#________________ Cal Due:__________ Eff.:____ ______ Remarks: __________________________________________________________________________________________________________________________________________ Surveyor Name (Print):_____________________________ Surveyor Signature:___________________________ Reviewed By (RSO Signature):______________________________

indicates smear location * indicates contact radiation reading indicates volumetric sample location LAW indicates large area wipe All radiation readings are gamma in mrem/h unless noted. FRN-0007b1

RADIOLOGICAL SURVEY MAP

Page______ of ______ indicates smear location * indicates contact radiation reading indicates volumetric sample location LAW indicates large area wipe All radiation readings are gamma in mrem/h unless noted. FRN-0007b

RADIOLOGICAL SURVEY REMARKS

Survey Number: Page _____ of _____ Remarks:

FRN-0007c

RADIOLOGICAL SURVEY FORM CONTINUATION

Survey Number: Page ____ of ____ BETA-GAMMA ACTIVITY

ALPHA ACTIVITY

RADIATION SURVEY

# Item Description/Location

cpm Bkg. cpm

dpm 100 cm2 (1)

T/R/F(2)

cpm

Bkg. cpm

dpm 100 cm2 (1)

T/R/F(2)

mrem/hr (3) Distance

FRN-0007d

RADIOCHEMISTRY ANALYTICAL RESULTS

Page ____ of ____

Sample Number Sample Matrix 1

Sample Size /Area

Activity 2

Activity 2

Activity 2

Activity 2

Activity 2

Total Activity 3

dpm/100 cm2 α ß

Matrix 1: S - Soil, P - Paint, I – Insulation, L- Liquid, D - Dust, C - Concrete, O - Other Activity 2: All activity to be reported in pico-curies per gram (pCi/g)

Total Activity 3: For surface samples activity is reported in dpm/100 cm2. Circle Alpha or Beta Comments:

Prepared By: Date:

Reviewed By: Date:

FRN-0008

AIRBORNE RADIOLOGICAL SURVEY Page: of

Location: __________________________________ Requester: _________________________________________________________________________________

Purpose of Survey: _________________________________ Radionuclide(s): _____________________________________________________________________________

RWP #: __________________________________________ Date of Survey: __________________________________ Sample Type(s): Lapel General Area Other:

General Information ALPHA ACTIVITY BETA-GAMMA ACTIVITY

Instrument Eff.: % MDC: Instrument Eff.: % MDC:

Sample # Remarks Volume cpm Bkg. cpm Sample dpm Activity (uCi/ml)

cpm Bkg. cpm Sample dpm Activity (uCi/ml)

Remarks: HPT Signature: Date:

RSO Signature: Date:

FRN-0009a

Page: of

LOW VOLUME/HIGH VOLUME AIR SAMPLING Air Sample Number: Sampler Model: Sampler Serial #: Cal Due Date:

Sample Location:

Respirator Type: Air Purifying Air Line SCBA None Other:

Low Volume Sampler (Long Duration Sampler) High Volume Sampler (Short Duration Sampler)

Sample Start Date/Time: Sample End Date/Time: Total Sampling Time (Minutes):

Beginning Air Flow: Ending Flow: Total Volume Sampled: LPM CFM CCM Remarks:

LOW VOLUME/HIGH VOLUME AIR SAMPLING Air Sample Number: Sampler Model: Sampler Serial #: Cal Due Date:

Sample Location:

Respirator Type: Air Purifying Air Line SCBA None Other:

Low Volume Sampler (Long Duration Sampler) High Volume Sampler (Short Duration Sampler)

Sample Start Date/Time: Sample End Date/Time: Total Sampling Time (Minutes):

Beginning Air Flow: Ending Flow: Total Volume Sampled: LPM CFM CCM Remarks:

FRN-0009b

Page: of

Error! Bookmark not defined.LAPEL SAMPLING Air Sample Number: Sampler Model: NOTE: 1 cc = 1 ml, 1000 ml=1 liter

Wearer’s Name: S.S.#: RWP #:

Sampler Serial #: Respirator Type: Air Purifying Air Line SCBA None Other:

RUN 1 RUN 2 RUN 3 RUN 4 RUN 5 RUN 6

Sampler Start Time ______ : ______ ______ : ______ ______ : ______ ______ : ______ ______ : ______ ______ : ______

Sampler End Time ______ : ______ ______ : ______ ______ : ______ ______ : ______ ______ : ______ ______ : ______

Sampler Air Volume Register Start Number

_______

_______

_______

_______

_______

_______

Sampler Air Volume Register End Number

_______

_______

_______

_______

_______

_______

Total Sampler Air Volume Register Number

_______

_______

_______

_______

_______

_______

Cumulative Sample Air Volume Register Number

_______

_______

_______

_______

_______

_______

Total Run Time: (minutes) Beginning Flow Rate: (LPM) Ending Flow Rate: (LPM) Average Flow Rate: (LPM)

Total Run Time X Average Flow Rate = Total Volume: liters

Sampler Air Volume Register Number Conversion Factor: (ml/digit)

Cumulative Sample Air Volume Register Number X Conversion Factor (ml/digit) X 1000 = Total Volume: _______________ liters

Remarks:

FRN-0009c

PORTABLE AIR SAMPLER CERTIFICATION OF CALIBRATION

Air Sampler New Calibration Date:

Air Sampler New Calibration Due Date:

Air Sampler Data Calibrator Data

Manufacturer: Manufacturer:

Model Number: Model Number:

Serial Number: Serial Number:

ID Number: Calibration Date:

Temperature (°F):

Pressure (mm Hg):

Calibration Results

Range Point Calibrator Flow Rate Value

Air Sampler Flow Rate As-Found

Air Sampler Flow Rate As-Left

High

Mid range

Low

Calibration: (check one) ACCEPTED REJECTED

Remarks:

Calibration by: Date:

Reviewed by: Date:

FRN-0016

PORTABLE AIR SAMPLER INSPECTION LOG

Date Time Sampler Serial #

Sampler Location

Calibration Date

Physical Condition (Sat/Unsat)

Filter Condition (Sat/Unsat)

Air In-leakage Check

(Sat/Unsat)

Flow Rate (LPM/CFM)

Filter Changed Y/N/na

Initial

Note: Not all fields of the inspection log need to be completed for every inspection. Some inspections are performed at sampler start-up, while others are performed daily when the sampler is in operation. Consult with the RSO if necessary FRN-0017

RADIATION WORK PERMIT REQUEST Page of

(1) WORK LOCATION

Organization:

This section to be completed by the HPT:

RWP Number:

Bldg.: Room: Area:

Other Info:

(2) WORK DESCRIPTION

(3) Title and Number of Related Work Documents:

INFORMATION

(4) Authorized Users(s): Attached List? Yes No

(5) Job Start Date: (6) Estimated Job End Date:

(7) RADIOLOGICAL HAZARDS ASSOCIATED WITH THE WORK ACTIVITY/LOCATION

a. Will any radioactive material/equipment be moved to another location? Yes No

b. Will any grinding, burning, cutting, or welding be done? Yes No

c. Will any vacuuming or sweeping be done? Yes No

d. Will any compressed gas or air powered tools be used? Yes No

e. Will any volatile solvents or fluids be used? Yes No

f. Will any radiological work be done in a confined space? Yes No

g. Will any intrusive work be done? (panels moved or voids entered) Yes No

(8) Other possible hazards:

(9) Remarks: (Explain any Yes answers above; supply additional information as needed.)

(10) Requestor (Print)

Requestor (Signature) Phone

Date

FRN-0018

INSTRUCTIONS

Complete the Radiation Work Permit (RWP) Request prior to returning it to Health Physics (HP). All blanks, except for those in the shaded section, must be completed. HP will complete this section after they assign a number to the RWP. (1) Complete all requested information about the work location. If any information does not

apply, write ‘N/A’ in that space. (2) Provide a description of the work to be performed. Give sufficient detail to adequately

describe radiological control required. Use another sheet of paper if necessary. The more detailed you are, the easier and quicker it will be for HP to write your RWP, and the more accurate it will be.

(3) If any documents are applicable to this work, write this information in the space. These

documents should be provided to HP for review. If not applicable, write ‘N/A’ in the space. (4) Indicate the individuals who will be authorized to work under this RWP. If you want to

have a users list, check the ‘YES’ box, and attach a list of authorized users, else check the ‘NO’ box.

(5) Enter the Job Start Date. This is when the radiation work is scheduled to begin and the

RWP becomes active. (6) Enter the estimated Job End Date. (7) Answer the following radiological hazard-related questions. If you are unsure whether any

of the hazards are, or will be, present, discuss it with HP. Every question must be answered. NOTE: ‘Yes’ answers may require other permits or documents in addition to the RWP.

(8) Indicate any other hazards that you think HP should know about, list them in this space.

Use extra paper if necessary. (9) Write any remarks or extra information here that you think HP may want to know. Use

extra paper if necessary. Any ‘Yes’ answer in (7) must have an explanation here. (10) Print and sign your name, indicate your phone number and date of request. After all information is completed, print your name and phone number, sign and date the form. Turn the completed form in to HP.

RADIATION WORK PERMIT Page of

General Job Specific RWP No.:

Start Date:

End Date:

Location:

Description of Work:

RADIOLOGICAL CONDITIONS * Indicates an estimated value Radiological Source(s)

Alpha Emitting Beta/Gamma Emitting Other: __________________

__________________________

Airborne Radioactivity Source Concentration (b/g or alpha) µCi/ml µCi/ml

N/A

Surface Contamination N/A None Detectable Unknown Levels

Fixed: dpm/ cm2 Alpha Fixed: dpm/ cm2 Beta/Gamma Removable: dpm/ cm2 Alpha Removable: dpm/ cm2 Beta/Gamma Radionuclide(s): See Latest Survey

Radiation Levels General Area: Contact: Other:

Pre-Job Survey Information Detailed survey information contained in the following:

RADIOLOGICAL PROTECTION REQUIREMENTS

Protective Clothing None Required Lab Coat Surgeon-Style Gloves

Coveralls/Tyvek Shoe Covers Plastic Suit Plastic Shoe Covers Rubber Boots Hood Work Gloves Other:

Respiratory Protection None Required Full Face Air Purifying (APR) SCBA Airline (Supplied Air) Other:

Dosimetry None Required Whole Body TLD Additional TLD(s): Extremity: Self-Reading Dosimeter Lapel Air Sampling Bioassay:

Pre-job Post-job Frequency:

Other:

Training GERT Radiation Worker (RWT) Respiratory Protection Confined Space Safety Other:

Monitoring Notify HPT at Job Start Intermittent Continuous Notify HPT at Job Completion HPT required at Control Point Undress by HPT Portable CAM Portable Air Sampling During Job Other:

RADIOLOGICAL HOLD POINTS and SPECIAL INSTRUCTIONS

Use RWP Continuation Sheet (if necessary) Continuation Sheet(s) Attached

RWP Sign-In/Out

Initial Entry Daily Each Entry

Other: (List other sheet if used for access control)

Personnel Contamination Frisk

None On Exiting Area Hands & Feet Whole Body

Other:

REVIEW/APPROVAL SIGNATURES

Prepared by: Date: Approved by (RSO): Date:

TERMINATION SIGNATURE

RWP Termination By: Date:

FRN-0019

RWP CONTINUATION SHEET Page of

RWP No.:

RADIOLOGICAL HOLD POINTS and SPECIAL INSTRUCTIONS

FRN-0020

RWP Sign-In Sheet

RWP No.:

Work Area Location: Date:

Name and ID Number Initials Resp. Pro. (Y or N) Dose In PAS ID # Digit/Flow

Start # Time In Time Out Dose Out Digit/Flow Stop #

FRN-0021

PAS Air Sample Media Collected By: * By my initials, I verify that I understand and will comply with the requirements of the RWP. Record NA for spaces not used or not applicable.

RWP TERMINATION CHECKLIST

RWP No.

POST-JOB CONDITIONS/ANALYSIS

Job Completed Change in Scope of Work

Reason for Termination: Change in Job Site RWP Expired

Other:

Post-Job Survey(s) Performed? Yes No Survey Number(s):

Other Survey(s) Performed? Yes No Survey Number(s):

TERMINATION PACKET (information attached)

RWP Request Yes No N/A

RWP (including all RWP Continuation Sheets) Yes No* # of sheets ______

RWP Sign-In Sheet(s) Yes No* # of sheets ______

Pre Job Meeting Attendance Record Yes No N/A

RWP Tracking Log Updated Yes No

Additional Documentation:

FRN-0022

VERIFICATION/APPROVAL

Name: (Print) Signature: Date: RSO Signature: Date: * Contact RSO for guidance

RWP Tracking Log

RWP Number

Date Issued

Date Closed

Job Location and Description of Work Initials

FRN-0023

RADIOLOGICAL POSTING INSPECTION

Inspected for the month of: Inspected by: Date: Results of Radiological Posting Inspection: SAT UNSAT* * NOTE: Describe all “unsatisfactory conditions” in the comments section. Any unsatisfactory condition corrected by the inspector shall also be noted in the comments section. Comments:

Inspector Signature: Date:

RSO Signature: Date:

FRN-0024

RADIOLOGICAL POSTING LOG Page ____ of ____

For all radiological postings, indicate on the Radiological Posting Log Sheet the location of the posting (building, room, area, etc.), posting classification (Radiation Area, Contamination Area, Airborne Radioactivity Area, etc.), whether the posting is temporary (T) or permanent (P), the date and initials of the HPT installing posting, and the date and initials of the HPT removing posting. Location

Classification T or P

HPT Installing Posting (Signature)

Date HPT Removing Posting (Signature) Date

Location




Location




Location




Location




FRN-0025

RADIOLOGICAL POSTING LOG Continuation Sheet

Page ____ of ____ Location




Location




Location




Location




Location




Location




FRN-0026

SOURCE INVENTORY LOG Page ___ of ___

Source ID

# Source Serial #

Physical State Isotope(s) Assayed

Activity Date In Service

Date Removed

FRN-0027

SOURCE LEAK CHECK AND INVENTORY RECORD Page ___ of ___

Source ID # ____________ Serial # __________________ Isotope(s): __________________

Source Location:

Date Reason LC = leak check, Inv. = inventory Results (uCi) Location Initials

LC Inv. Both

LC Inv. Both

LC Inv. Both

LC Inv. Both

LC Inv. Both

LC Inv. Both

LC Inv. Both

LC Inv. Both

LC Inv. Both

LC Inv. Both

LC Inv. Both

LC Inv. Both

LC Inv. Both

LC Inv. Both

LC Inv. Both

LC Inv. Both

LC Inv. Both

LC Inv. Both

LC Inv. Both

LC Inv. Both

LC Inv. Both

LC Inv. Both

LC Inv. Both

FRN-0028

TLD ISSUE LOG

For quarter beginning:

Name SS # TLD # Date Issued Date Pulled Form 5 Update

FRN-0029

Reviewed By: Date:

DAC HOUR TRACKING LOG

Name Date / DAC Hr Date / DAC Hr Date / DAC Hr

FRN-0030

Environmental TLD Record

Location TLD # Date Hung

Time Hung

Hung By

Date Pulled

Time Pulled

Pulled By Avg. Dose* Quarterly

Dose ** Total

Dose*** 1 2 3 4 5 6 7 8 9

10 11 12 13 14 15 16

Background

* Average Dose = average of 4 zones from each TLD ** Calculated dose for actual quarter *** Total Dose = Quarterly dose adjusted for background All dose is reported in mrem.

Prepared By: _______________________ Date: _________ Reviewed By: ________________________ Date: __________ RSO

FRN-0034

Radiation Worker Training Applied Training Exercise Evaluation

Student: _

Instructor: _

OJT and Qualifications Date: _

Classroom Training Completion Date: _

After the student has demonstrated their classroom knowledge by successfully completing the RWT written examination, the student shall then demonstrate operational knowledge by demonstrating the below radiological worker skills after being provided OJT as a Radiation Worker. OJT and Practical Exercise Evaluation If the skill item evaluated is performed to an acceptable level as determined by the OTJ instructor, then write the point value associated with the skill item in the “Score” box to the right of the skill item. If the skill item evaluated is deemed unsuccessful, place a zero inside the “Score” box and identify the reason for the unsat performance in the Comments Section below. If the listed skill item is not applicable for the student’s certification/ qualification, place an “NA” inside the “Score” box. 80% is the minimum acceptable passing score for OJT evaluation.

Item Evaluated Pt Value Score Job Understanding

Stated purpose of entry 3

Stated radiation level(s) with correct units 3

Stated contamination level(s) with correct units 3

Stated special instructions listed on the RWP 3

Pre-Job Preparation Selected proper PPE (protective clothing) 3 Selected and properly wear dosimetry 3 Donned PPE correctly 5 Read and follow RWP instructions 5 Recorded appropriate information on RWP 4 Radiological Work Practices Minimized exposure while completing task 4 Minimized radioactive waste generation 3 Didn’t walk thru contamination unnecessarily 4 Didn’t spread contamination to other areas 4 Chose low exposure route to and from work area 5

Student Acknowledgement By my signature I verify that I was instructed on the proper performance of any item(s) completed unsatisfactorily above and that I had the opportunity to ask questions about the practical exercise and I understand my final score. I understand that failure (<80%) of this OJT evaluation restricts me from entering in to Radiologically Controlled Areas. Student name, signature and date: _

(see next page for Instructor signature and comments)

Emergency Response Responded appropriately to emergency alarm 10 Exited area as appropriate for alarm condition 4 Notified RCT/HPT upon exit 4 Exit Practices Doffed PPE correctly 4 Did not contaminate step-off pad during exit 5 Did not contaminate self during exit 5 Performed whole body survey properly 4 Surveyed personal equipment/dosimeter 4 Read personal dosimetry correctly upon exit 4 Signed out of RWP correctly 4 Total Points (available) 100 Percent 80% (passing)

Instructor Certification As the OJT instructor, I certify that the above named student has successfully completed the required formal and OJT training and has demonstrated that they can safely and effectively prepare for radiological work; enter, work inside and exit a Radiological Area; perform a correct whole-body frisk for contamination; sign in to and out of a Radiation Work Permit and respond correctly to emergencies while inside the Radiological Area. NOTE: This qualification is valid for two years from the qualification date listed above. Instructor name, signature and date: _ Comment Section:

FRN-0037

PROCEDURE-SPECIFIC TRAINING COMPLETION RECORD

Procedure/Document Title and ID Number (as applicable)

Type(s) of Training Completed (2)

Training Completion Date(s)

Name of Trainer(3)

(1) Examples: On-the-job training (OJT), training by equipment manufacturer. (2) Examples: Required reading, classroom presentation/instruction. (3) Examples: Dept. Mgr., manufacturer representative, self.

Signed: Date: Signature of Trainee

FRN-0038

LETTER FOR DECLARING PREGNANCY This letter is provided for your convenience. To make your written declaration of pregnancy, you may fill in the blanks in this letter, you may use a letter the licensee has provided to you, or you may write your own letter.

DECLARATION OF PREGNANCY

To:

In accordance with the NRC's regulations at 10 CFR 20.1208, "Dose to an Embryo/Fetus," I am declaring that I am pregnant. I believe I became pregnant in (only the month and year need be provided).

I understand the radiation dose to my embryo/fetus during my entire pregnancy will not be allowed to exceed 0.5 rem (5 millisievert) (unless that dose has already been exceeded between the time of conception and submitting this letter). I also understand that meeting the lower dose limit may require a change in job or job responsibilities during my pregnancy.

(Your Signature)

(Your Name Printed)

(Date)

FRN-0039

RADIOLOGICAL TRAINING ATTENDANCE ROSTER Page of

Course Information

Course Title Course Number

Instructor Name Instructor Signature Course Start Date/Time Course End Date/Time

Attendee Information

Name Signature ID # (SSN)

Dept. / Address

Exam Score

SAT/ UNSAT

FRN-0041

Certificate of Calibration SECTION I

General Information

Instrument Type: Lapel Air Sampler

Calibration Document: Procedure: RPO-209

Manufacturer: Calibration Date: Model: Calibration Due Date:

Manufacturer Serial No:

SECTION II Equipment Used To Perform Calibration

1) Calibrator Type: 2) Stopwatch

Manufacturer: 3) Filter Holder Stand Model No: 4) Large filter holder Manufacturer Serial No:

SECTION III

Calibration Results

Time Average Flow Rate* (LPM)

100 Dig. Elapsed Time (sec.)

Average Conversion Factor (mL/Digit)

Initial Calibration

Final Calibration

Average* * Average of five tests

Remarks:

ACCEPTED REJECTED Performed By: Date: Reviewed By: Date: ________________ RSO

Form FRN-0044

Inspection Checklist - Daily Routines Page 1 of 3

For The Week Beginning:

Facility Daily Checks Sun Mon Tue Wed Thr Fri Sat

General Area Safety and Radiological Inspection

Sample Counter QC Check

General Area and Stack Air Sampler Checks

Frisker Response Checks

Calculate and Review Lapel Air Sampler Results

Waste Storage Areas

For HP instrumentation, the check includes visual for damage, current calibration sticker, battery and source response check performed (as required).

Form FRN-0045, a


Buffer Zone Contamination Survey

Sun Mon Tue Wed Thr Fri Sat

Building X

Form FRN-0045, a


Site Daily Checks Sun Mon Tue Wed Thr Fri Sat

Remove and Analyze Daily General Area/Stack Air Sample Monitors (as required)

Check HP Equipment/Areas When Work Is In Progress

Review the various Inspection Checklists when completed

HPT initials indicate a completed inspection with satisfactory results of the item checked. Comments:

Reviewed by: Date:

Form FRN-0045, a

Inspection Checklist - Weekly Routines Page 1 of 2

For The Week Of:

Weekly Contamination Survey Initials

Health Physics Office

Temporary Work Areas

Weekly Air Sample Filter Change Out Initials

Air Sampler Filter Media Change*

* Weekly when in use, for non-moving filter media. Weekly source checks required on CAMS with automatic alarms systems to verify proper operation.

Weekly Site Checks Initials

Weekly Outdoors Inspection

Instrument Calibration List Update

Fill Gamma Spec. Cryostat

Gamma spectroscopy system background count (when in use)

Form FRN-0045, b

Inspection Checklist - Weekly Routines Page 2 of 2

Weekly Site Checks (cont.) Initials

Air Sampler Filter Change

HPT initials indicate a completed inspection with satisfactory results of the item checked.

Comments:

Reviewed by: Date:

Form FRN-0045, b

Inspection Checklist - Monthly Routines Page 1 of 2

For The Month Of: ,

(year)

Reference Location/Item Inspection Type Initials

RPO-301 Building X General Area

Radiological Survey

RPO-301 R.M.S.A Radiological Survey

RPO-402 Radiological Postings Inspection

Visual - Complete Radiological Posting

Inspection Sheet

RPO-401 Monthly RWP Review List Active RWPs:

RPO-103 Audit/ Assessment Tracking Log

Review and List Open Audit Numbers:

RPO-104 Inspection Tracking Log

Review

RPO-405 Respirator Facepieces That Are Routinely Available

For Issue

Inspect

Form FRN-0045, c

Inspection Checklist - Monthly Routines Page 2 of 2


RPO-405 “Escape-Only” Respiratory Protection

Devices

Visually Inspect

RPO-405 Emergency Respiratory Protection

Equipment

Visually Inspect

RPO-106 Radiological Training List

Review Current


Comments:

Reviewed by: Date:

Form FRN-0045, c

Inspection Checklist - Quarterly Routines

Page 1 of 2

For the 1st 2nd 3rd 4th Quarter of: (circle one) (year)


RPO-301 Building X General Area Radiological Survey

RPO-406 Personnel TLD Exchange Exchange

RPO-103 Open Audit Items List Audit ID Number(s) Open > 3 Months:

RPO-405 Emergency Respiratory Protection Equipment

Operationally Test

RPO-405 (periodically or prior to

use)

Equipment Used In Conjunction With

Facepiece Respirators

Inventory and Functionally Test

RPO-603 Environmental TLD Change-out

Form FRN-0045, d

Inspection Checklist - Quarterly Routines

Page 2 of 2


RPO-404 Alpha Source Leak Checks

Perform Source Leak Checks

RPO-404 Beta-gamma Source Leak Checks Every Six Months

- June and Dec.

Perform Source Leak Check


Comments:

Reviewed by: Date:

Form FRN-0045, d

HEALTH PHYSICS ROUTINE INSPECTION TRACKING LOG Page _____ of _____

Tracking No.

Inspection Date

Description of Finding Description of Corrective Action Planned

Corrective Action Due

Date

Corrective Action

Completion Date

Comments

Reviewed by: Date:

Form FRN-0045, e

Counting System Chi-Squared Test Data Sheet

System Model Serial No.

Detector Model Serial No. Cal Due Date

α Source ID No. β-γ Source ID No.

α Source Isotope β-γ Source Isotope

α Source Activity dpm β-γ Source Activity dpm

α Source Diameter mm β-γ Source Diameter mm

α Source Assay Date β-γ Source Assay Date

Alpha Beta-Gamma n ix ix - x ( ix - x )2 n ix ix - x ( ix - x )2

1 1 2 2 3 3 4 4 5 5 6 6 7 7 8 8 9 9

10 10 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 S ix S( ix - x )2 S ix S( ix - x )2

x = S ix /20 x

xxi∑=2

2 ) - (χ x = S ix /20

xxxi∑=

22 ) - (

χ

= /20 = /20 = cpm 2χ = = cpm 2χ =

Chi-Squared Limits: 8.9 to 32.9

α Chi-Squared Test Result Pass

Fail

Chi-Squared Limits: 8.9 to 32.9

β-γ Chi-Squared Test Result Pass

Fail FRN-0049a

Performed by: Date: Reviewed by: Date:

Counting System Set Up Data Sheet

System Model Serial No.

Detector Model Serial No. Cal Due Date

α Source ID No. β-γ Source ID No.

α Source Isotope β-γ Source Isotope

α Source Activity dpm β-γ Source Activity dpm

α Source Diameter mm β-γ Source Diameter mm

α Source Assay Date β-γ Source Assay Date

Background Data

α Background cpm β-γ Background cpm

Counting System Efficiency Data Alpha Beta-Gamma

20 minute count 20 minute count

Gross count rate cpm Gross count rate cpm

Net count rate cpm Net count rate cpm

Source activity dpm Source activity dpm

Efficiency Efficiency

Acceptable Source Range Alpha Beta-Gamma

20 minute count 20 minute count

Gross count rate cpm Gross count rate cpm

Net count rate cpm Net count rate cpm where: σ = standard deviation of the net count rate

gR = source gross count rate (cpm)

bR = background count rate (cpm)

Alpha σ = cpm Beta-Gamma σ = cpm

1σ = to 1σ = to

2σ = to 2σ = to

FRN-0049b Performed by: Date: Reviewed by: Date:

201bg RR

+=σ

Alpha Counting System Daily Check Data Sheet

Model: Serial No: Cal. Due Date:

Detector Model: Detector Serial No:

Alpha Source ID No: Isotope:

Source Activity: Source Diameter:

Alpha Source Ranges: 1σ = to cpm

2σ = to cpm

Date/Time Alpha

Background Counts

Alpha Background

cpm

Alpha Source Counts

Alpha Source

cpm

Sat/ Unsat MDA Initials

FRN-0049c Reviewed by: Date:

Beta-Gamma Daily Check Data Sheet

Model: Serial No: Cal. Due Date:

Detector Model: Detector Serial No:

Beta-Gamma Source ID No: Isotope:

Source Activity: Source Diameter:

Beta-Gamma Source Ranges: 1σ = to cpm

2σ = to cpm

Date/Time Beta-Gamma Background

Counts

Beta-Gamma Background

cpm

Beta-Gamma Source Counts

Beta-Gamma Source

cpm

Sat/ Unsat MDA Initials

FRN-0049d Reviewed by: Date:

Alpha Background Control Chart

Instrument: Serial No.: Cal Due: Month/Year: W

rite

in A

LPH

A BA

CKG

RO

UN

D C

OU

NTS

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31

Day of Month

Reviewed By: Date:

FRN-0049e

Beta-Gamma Background Control Chart

Instrument: Serial No.: Cal Due: Month/Year: W

rite

in B

ETA-

GAM

MA

BAC

KGR

OU

ND

CO

UN

TS

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31

Day of Month

Reviewed By: Date:

FRN-0049f

Alpha Source Response Check Control Chart

Instrument: Serial No.: Cal Due: Month/Year:

+2σ cpm-

+1σ cpm-

Avg. cpm-

-1σ cpm-

-2σ cpm-

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31

Day of Month

Reviewed By: Date:

FRN-0049g

Beta-Gamma Source Response Check Control Chart

Instrument: Serial No.: Cal Due: Month/Year:

+2σ cpm-

+1σ cpm-

Avg. cpm-

-1σ cpm-

-2σ cpm-

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31

Day of Month

Reviewed By: Date:

FRN-0049h

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