University of Missouri - NRC: Home Page · University of Missouri, Pickard Hall Site...

(iJ University of Missouri

March 23, 2018

Mike LaFranzo Senior Health Physicist Region III- Division of Nuclear Materials and Safety U.S. Nuclear Regulatory Commission 2443 Warrenville Road Lisle, IL 60532

Environmental Health & Safety

180 General Services Building Columbia, MO 65211

PHONE 573-882-7018 FAX 573-882-7940

EMAIL [email protected] WEB ehs.missouri.edu

Re: Additional Information to Control Number 586692: Pickard Hall Characterization Plan -License No. 24-00513-32, Docket No 030-02278

Dear Mr. LaFranzo:

Attached are the University of Missouri's responses to the requests for additional information (RFAI) regarding Pickard Hall Site Characterization Plan (SCP) from the October 5, 2017 trip report (MLl 7283Al 95). The responses to the specific RFAis can be found in Appendix A. The University and its decommissioning contractor, Chase Environmental Group (Chase), developed a Pickard Hall Decommissioning Project (PHDP) Radiation Safety Manual (RSM). The RSM describes the radiological engineering and administrative controls that MU and Chase will implement for the PHDP and is attached as Appendix B. MU and Chase are committed to the highest standards of radiological and industrial safety during the PHDP.

If you have any questions, please do not hesitate to contact me at (573) 882-7018.

Sincerely, n.~i · , , . I ' .

' .'

Felicity Beckfield, MS, CHP Radiation Safety Officer

cc: Todd Houts, Director, MU Environmental Health & Safety

Enclosure: Appendix A: Pickard Hall Site Characterization Plan Requests for Additional Information Appendix B: Pickard Hall Decommissioning Project Radiation Safety manual Appendix C: Pickard Hall Decommissioning Schedule

RECEIVED MAR 2 'i' 2010

Appendix A: Pickard Hall Site Characterization Plan

Requests for Additional Information

University of Missouri, Pickard Hall Site Characterization Plan Requests for Additional Information from October 5, 2017 meeting

During discussions, the licensee committed to provided additional information including, but not limited

to, detailed and specific procedures associated with the future radiological characterization and/or remediation of Pickard Hall:

1.

2.

Request from the US NRC: The use of a Structural Engineer at all stages of characterization

and remediation to ensure the structural integrity of the building is not compromised;

Response from the University of Missouri:

MU will ensure that Chase has a structural engineer available for evaluations during the

detailed characterization planning phase, during site prep and characterization, and

throughout the decommissioning project.

Request from the US NRC: Submittal of procedures to include engineering and

administrative controls concerning:

a. Analysis of fire hazards and mitigation measures to be used during characterization

and/or remediation;

i. Response from the University of Missouri:

The MU Fire Marshall will make periodic inspections of the Pickard Half

Decommissioning Plan (PHDP} commensurate with the decommissioning

operations. Please refer to Section 11.2 of the PHDP Radiation Safety Manual (RSM} (Appendix B).

b. Radiological effluent releases to the environment including dose analysis;


Characterization and remediation activities will be performed inside of

containment where air monitoring will be performed inside of the building to

prove no effluent releases greater than limits specified in 10 CFR 20 Appendix B

Table 2. Monitoring will be performed in accordance with section 9.3 of the

RSM.

c. Air monitoring of workers to include general area and lapel monitoring systems, to

include radon; ,


Sections 4.7 and 9.3 of the RSM discuss personal air monitoring and general

area air sampling in addition to the Characterization Plan. Additionally, MU is in

the process of collecting passive radon and thoron air monitoring of Pickard

Hall. The collection period is November 1, 2017 through April 30, 2018 with a 3

month exchange. Active monitoring will be performed during decommissioning

as described in section 13.4.5 of the Characterization Plan.

d. Air monitoring of members of the general public;


Page 1 of 3


Air sampling is administratively controlled by section 9.3 of the PHDP RSM. Per

section 13.4.4 of the Characterization Plan, general area air samples will be

collected at effluent release locations and in the vicinity of outdoor activities as

necessary to verify that any radioactive materials released to the environment

meet the effluent concentration limits of 10 CFR 20, Appendix B, Table 2,

Column 1; for W Class Th-232, this is 4E-15 µCi/ml.

e. Any conditions which could impact any ground water. This would include an analysis of

ground water conditions in the area (location, depth, etc ... );


In June 2004, subsurface soil borings were performed just north of Pickard Hall

in support of the construction of the Reynolds Journalism building. Two borings

were within approximately 30 feet of Pickard Hall. The logs from the two

borings demonstrated that bedrock is approximately 40-feet below ground

surface (BGS) and ground water was 15-18 feet BGS. Initial characterization of

the outside soils does not indicate any residual material has affected

groundwater as there has not been any activity detected in the subsurface.

Potential areas where activity is present in the subsurface will be in the soils

beneath the basement and beneath the sewer line exiting Pickard Hall. Any

groundwater impacts will be noted in the characterization report.

f. Analysis of dose, internal and external, to workers and members of the public;


Sections 4.7 and 4.10 of the PHDP RSM describe the administrative control and

process of dose analysis for the PHDP.

g. Radiological controls associated with potential air borne releases during

characterization and/or remediation;


Section 4.11 of the RSM describes the use of Radiological Work Permits (RWP)

to administratively control personnel exposures. Engineering controls and PPE

will also be described in the RWP. The RWP procedure is also included in this

submittal.

h. Any work subsurface or in walls, floors, etc. to include analysis of water-lines, electrical

lines, chemical, gaseous-lines or other hazards that might be impact by any

characterization and/or remediation;


Prior to any activities disturbing subsurface soils, utilities will be located per

local, state, and federal regulations. Utilities in walls and floors will be verified

to be de-energized before removal.

Page 2 of 3


i. Characterization and/or remediation of soil and subsurface;


Engineering and administrative controls will be delineated in the task specific

RWP.

3. A detailed estimated time plan of the characterization and/or remediation efforts;


A level two Gantt chart has been included with this submittal (Appendix C). A more detailed

schedule can be made available 60 days prior to on site work.

4. Estimated volume and type of waste generation, radiological or otherwise;


The initial estimated volume of waste is 500 cubic yards with the composition being 80%

interior finishes such as plaster and floor tile. Concrete surfacing and soil removal to expose

drain lines is estimated to produce the other 20% of the volume. All waste in this estimate is

considered to be radiological waste.

5. How the licensee plans to transfer and dispose of licensed material;


Waste materials will be sent to a licensed facility per section 15.0 of the Characterization

Plan in accordance with section 10.0 of the RSM, Packaging, Storage and Transportation.

6. How the licensee plans to store licensed material prior to transfer and disposal;


Due to limited space for the PHDP, material will be shipped soon after produced. Material

will be stored in shipping containers while waiting for trucks per RSM Section 10.0.

Containers that can not be locked, i.e., soft sided bags, will be stored in another container

that can be locked such as a connex box or intermodal. Construction fencing will also be

utilized to help prevent unauthorized access to the PHDP area.

7. Radiological criteria to be used to release material for unrestricted use;


NU REG 1556 Volume 18 Appendix I will be used for release of material for unrestricted use.

The values are also shown in Table 9.1 of the RSM.

Page 3 of 3

Appendix B: Pickard Hall Decommissioning Project

Radiation Safety manual

PICKARD HALL DECOMMISSIONING

RADIATION SAFETY MANUAL

Revision 0

March 2018

Prepared By:

Reviewed By:

Reviewed By:

Approved By:

RADIATION SAFETY MANUAL

Revision 0

Certified Health Physicist

Dustin Miller

Chase Radiation Safety Officer

Chris Echterling

Field Services Manager

Dave Culp

MU Radiation Safety Officer

Felicity Beckfield

Date:

Date:

Date:

Date:

Revision Tracking

Revision Effective Description of Revision

Number Date

1.0

2.0

3.0

3.1 3.1.1 3.1.2 3.1.3 3.1.4 3.1.5 3.1.6 3.1.7 3.2 3.2.1 3.2.2 3.2.3 3.2.4

4.0

4.1 4.2 4.3 4.3.1 4.3.2 4.4 4.5 4.6 4.7 4.7.1 4.7.2 4.7.3 4.7.4 4.7.5 4.8 4.9 4.10 4.10.1 4.10.2 4.10.3 4.10.4 4.11 4.11.1 4.11.2 4.11.3 4.11.4 4.12 4.12.1 4.12.2 4.12.3 4.12.4 4.12.5 4.12.6 4.12.7

TABLE OF CONTENTS

INTRODUCTION AND PURPOSE ......................................................................... l

POLICY ..................................................................................................................... 1

ORGANIZATIONAL STRUCTURE AND RESPONSIBILITIES ......................... .2

Typical Project Structure ..................................................................................................................... 2 MU Director of Facilities Planning, Design, and Construction ........................................................... 3 MU Radiation Safety Officer .............................................................................................................. 3 Chase Project Manager ........................................................................................................................ 3 Chase Radiation Control Supervisor (RCS) ........................................................................................ 4 Radiation Control Technicians (RCT) ................................................................................................. 5 Radiation Workers ............................................................................................................................... 5 Radwaste Manager .............................................................................................................................. 6 Personnel Selection and Qualification ................................................................................................. 7 Project Manager .................................................................................................................................. 7 Radiation Control Supervisor .............................................................................................................. 7 Radiation Control Technician(s) ......................................................................................................... 7 Radwaste Manager .............................................................................................................................. 7

RADIATION PROTECTION ................................................................................... 7

ALARA Policy .................................................................................................................................... 7 Task Work Plans ................................................................................................................................. 8

, Occupational Dose Limits ................................................................................................................... 9 , Regulatory Limits ................................................................................................................................ 9 Administrative Limits .......................................................................................................................... 9 Dose to an Embryo or Fetus .............................................................................................................. 10 Public Dose Limits ............................................................................................................................ 10 Escorted Access ........................................................................................ , ........................................ l 0 Internal Monitoring ........................................................................................................................... 11 Air Sampling ..................................................................................................................................... 11 Whole Body Count (in-vivo Bioassay) ............................................................................................. 12 Urine/Fecal Analysis (in-vitro Bioassay) .......................................................................................... 12 Routine Monitoring ........................................................................................................................... 12 Non-routine Monitoring .................................................................................................................... 12 Pre-project Baseline Bioassay ........................................................................................................... 12 Post-project Bioassay ........................................................................................................................ 13 External Radiation Monitoring Dosimetry ........................................................................................ 13 Whole Body Monitoring Dosimetry .................................................................................................. 13 Extremity Monitoring Dosimetry ...................................................................................................... 13 Quality Assurance of Dosimetry ....................................................................................................... 13 Records .............................................................................................................................................. 14 Radiological Work Permits (RWP) ................................................................................................... 14 General RWP ..................................................................................................................................... 14 Job-Specific RWP ............................................................................................................................. 15 Revising RWPs .................................................................................................................................. 15 RWP Records .................................................................................................................................... 15 Respiratory Protection ....................................................................................................................... 15 Evaluation ofHazard ......................................................................................................................... 16 Respiratory Protection Equipment Training ...................................................................................... 16 Medical Surveillance ......................................................................................................................... 17 Respiratory Protection Equipment Fit Testing .................................................................................. 17 Issuance of Respiratory Protection Equipment.. ................................................................................ 17 Respiratory Equipment Inspection and Maintenance ........................................................................ 18 Respiratory Protection Program Records .......................................................................................... 19

Pickard Hall Decommissioning Project Radiation Safety Manual i ofv

4.13 4.13.1 4.13.2 4.13.3 4.13.4 4.13.5 4.14 4.15 4.15.1 4.15.2 4.15.3 4.15.4 4.15.5 4.16 4.16.1 4.16.2 4.16.3 4.16.4 4.17 4.17.1 4.18 4.19 4.19.l 4.19.2 4.19.3

5.0

5.1 5.2 5.3 5.4 5.5

6.0

6.1 6.2 6.3 6.3.1 6.3.2 6.3.3 6.3.4 6.4 6.5

7.0

7.1 7.2 7.3 7.4

8.0

8.1 8.2 8.3

TABLE OF CONTENTS

Posting and Labeling ......................................................................................................................... 19 General Posting and Labeling Requirements .................................................................................... 19 Radiological Area Posting Requirements .......................................................................................... 19 Exceptions to Posting Requirements ................................................................................................. 20 Radioactive Material Labeling/Tagging Requirements ..................................................................... 20 Exceptions to Labeling ...................................................................................................................... 21 Instructions and Notices to PHDP personnel... .................................................................................. 21 Notifications and Reports to Individuals ........................................................................................... 22 Format ............................................................................................................................................... 22 Annual Report to Individuals ............................................................................................................ 22 Report to Former PHDP personnel .................................................................................................... 23 Report to Individuals - Incidents ..................................................................................................... 23 Report to Individuals -Termination ............................................................................................... 23 Instrument Check Sources ................................................................................................................. 23 Security and Posting .......................................................................................................................... 23 Radiation Levels ................................................................................................................................ 23 Transfer or Disposal .......................................................................................................................... 24 Inventory ........................................................................................................................................... 24 Maintenance and Retention ofRecords ............................................................................................. 24 General Provisions ............................................................................................................................ 24 Planned Special Exposures ................................................................................................................ 25 Notification ofincidents .................................................................................................................... 26 Immediate Notifications .................................................................................................................... 26 Twenty-four Hour Notifications ........................................................................................................ 26 Thirty Day Notifications .................................................................................................................... 27

RADIATION PROTECTION PROGRAM REVIEW ........................................... .28

Review Scope .................................................................................................................................... 28 Reviewer Qualifications .................................... : ............................................................................... 28 Review Frequencies .......................................................................................................................... 28 Program Review Reports and Responses .......................................................................................... 29 Program Review Records .................................................................................................................. 29

PERSONNEL TRAINING .................. ' .................................................................... 29

Radiation Protection Training Instructors ......................................................................................... 29 Training/Retraining Frequency ......................................................................................................... 30 Training Requirements ...................................................................................................................... 31 General Orientation ........................................................................................................................... 31 Radiation Worker Training ................................................................................................................ 31 DOT Training .................................................................................................................................... 32 Female Radiation Worker Training ................................................................................................... 32 Performance Examinations .............................. : ................................................................................. 32 Training Records Retention ............................................................................................................... 32

PROJECT SECURITY ............................................................................................ 32

Job Site .............................................................................................................................................. 33 Materials Removed from the Job Site ............................................................................................... 33 Key Control ....................................................................................................................................... 33 Breach of Security ............................................................................................................................. 33

INSTRUMENTS ...................................................................................................... 33

Instrument Calibration ....................................................................................................................... 34 Field Response Checks ...................................................................................................................... 34 Instrument Selection .......................................................................................................................... 34

Pickard Hall Decommissioning Project Radiation Safety Manual ii ofv

TABLE OF CONTENTS

9.0 RADIOLOGICAL SURVEY PROGRAM .............................................................. 35

9.1 General Requirements ....................................................................................................................... 35 9.1. l Radiological Surveys ......................................................................................................................... 35 9.1.2 Action Limits ..................................................................................................................................... 35 9.1.3 Documentation of Surveys ................................................................................................................ 38 9.2 Personnel Contamination ................................................................................................................... 38 9.3 Airborne Radioactivity Sampling ...................................................................................................... 38 9.3.1 Calibration ......................................................................................................................................... 39 9.3.2 Sampling Locations and Type ........................................................................................................... 39 9.3.3 Airborne Radioactivity Action Limits ............................................................................................... 39 9.3.4 Documentation of Air Monitoring ..................................................................................................... 39 9.4 Environmental Sampling ................................................................................................................... 40 9.5 Receiving and Opening Packages ...................................................................................................... 40

10.0 PACKAGING, STORAGE, AND TRANSPORTATION ..................................... .40

10.1 Packaging .......................................................................................................................................... 40 10.2 Storage ............................................................................................................................................... 41 10.3 Transportation ................................................................................................................................... 41

11.0 EMERGENCY ACTIONS ...................................................................................... 42

11.1 Unplanned Release ............................................................................................................................ 42 11.1.l Supplementary Actions for Unplanned Releases .............................................................................. 42 11.2 Fires and Explosion .............................................................................................................. : ........... .43 11.2.1 Supplementary Actions for Fires ...................................................................................................... .43 11.3 Personnel Injuries and Illnesses ......................................................................................................... 44 11.3.1 First Responders' Actions ................................................................................................................. 44 11.3.2 Support Actions ................................................................................................................................ .44 11.3.3 Post Incident Recovery ...................................................................................................................... 44 11.4 Emergency Response Documentation .............................................................................................. .45

12.0 REFERENCES ........................................................................................................ 45

Pickard Hall Decommissioning Project Radiation Safety Manual 1 iii of V

TABLE OF CONTENTS

TABLES

Table 4-1 Regulatory Annual Adult Dose Limits ..................................................................... 9 Table 4-2 Administrative Annual Dose Limits ......................................................................... 9 Table 6-1 RPP Training and Frequency for Assigned Personnel ............................................ 30 Table 9-1 Radiation Surveys and Action Limits ..................................................................... 36 Table 9-2 Airborne Activity Action Limits ............................................................................. 39

Attachments Attachment 1: Task Planning Form Attachment 2: Dosimetry Issuance Form Attachment 3: RWP Log Attachment 4: RWP Form Attachment 5: R WP Sign In Sheet Attachment 6: Survey Forms Attachment 7: Instrument Forms Attachment 8: Source Accountability Log Attachment 9: Air Sample Log Attachment 10: Air Sample DAC-Hour Tracking Form Attachment 11: Visitor Orientation Form Attachment 12: Training and Safety Brief Attendance Attachment 13: Respirator Selection and Qualitative Fit Test

'Attachment 14: Pregnancy Declaration & Instructions

Pickard Hall Decommissioning Project Radiation Safety Manual iv ofv

ALARA ALI CFR Chase coc DAC DCGL DFPDC DOT EMS IDLH MARSSIM MEV MSHA NLVAP NIOSH NIST NRC PHDP PM PPE RCS RCT RPP RSM RSO RWP SCBA TEDE TI TLD

ACRONYMS

As Low As Reasonably Achievable Annual Limit on Intake Code of Federal Regulations Chase Environmental Group, Inc. Chain of Custody Derived Air Concentration Derived Concentration Guideline Level Director of Facilities Planning, Design, and Construction Department of Transportation Emergency Medical Services Immediately Dangerous to Life or Health Multi-Agency Radiation Survey and Site Investigation Manual Mega-Electron Volts Mine Safety and Health Administration National Laboratory Voluntary Accreditation Program National Institute for Occupational Safety and Health National Institute of Standards and Technology Nuclear Regulatory Commission Pickard Hall Decommissioning Project Project Manager Personnel Protective Equipment Radiation Control Supervisor Radiation Control Technician Radiation Protection Program Radiation Safety Manual Radiation Safety Officer Radiation Work Permits Self Contained Breathing Apparatus Total Effective Dose Equivalent Transport Index Thermo-Luminescent Dosimeter

Pickard Hall Decommissioning Project Radiation Safety Manual v ofv

1.0 INTRODUCTION AND PURPOSE

The University of Missouri (MU) identified residual radioactivity from historical operations in the basement of Pickard Hall located at 405 S. Ninth Street, Columbia, MO 65211-1420. Built in 1892 as the Chemistry Building, Pickard was subsequently used as the Museum of Art and Archaeology, and housed the Department of Art History and Archaeology. The building has a footprint of 8,400 square feet with approximately 24,600 gross square feet of floor area over three elevations (not including the attic). The building is located within the Francis Quadrangle, which is listed on the National Register of Historic Places. As a result of historical operations involving radium and thorium in the early 1900's, Pickard Hall is impacted by legacy radioactive materials on building structures and in soils around (and potentially under) the building and requires radiological decommissioning. The goal of decommissioning is to accomplish unrestricted release of the building and grounds.

MU has procured a Decommissioning Contractor, Chase Environmental Group, Inc. (Chase), to assist MU with the Pickard Hall Decommissioning Project (PHDP). Chase is a full-service decontamination, decommissioning, remediation and radwaste management firm that provides services nationwide. Chase is an independent corporation headquartered in Louisville, Kentucky and maintains a mobile decommissioning license issued by the Kentucky Cabinet for Health and Family Services, Radiation Health Branch.

MU maintains the ultimate regulatory responsibility for the decommissioning of Pickard Hall. Chase will be responsible for the daily implementation of the RSM during decommissioning tasks at Pickard Hall with oversight by MU Radiation Safety Department. Therefore, this RSM is based on the RSM Chase uses for its mobile decommissioning license.

This Radiation Safety Manual (RSM) supports the use and handling of radioactive materials in a radiological decommissioning environment. This RSM provides the standards and policy for safeguarding the health of PHDP personnel, the public and for protecting the environment for the Pickard Hall Decommissioning Project (PHDP). Operations shaH be conducted in a manner that complies with the regulations and laws established by the MU Broadscope License and NRC regulations.

2.0 POLICY

MU's policy is to implement a decommissioning radiation protection program that achieves a consistently high level of protection for personnel and the environment. MU and Chase institutes controls and practices to provide assurance that radiation exposures are controlled to levels below regulatory limits and as low as reasonably achievable (ALARA).

Pickard Hall Decommissioning. Radiation Safety Manual 1 of 52

3.0 · ORGANIZATIONAL STRUCTURE AND RESPONSIBILITIES

The staffing and structure of the decommissioning tasks will be commensurate with the scope and complexity of the activities being performed. The structure for each task will be included in a task-specific work plan.

MU and Chase are committed to maintaining a safe work environment while protecting the worker, the environment and the public. All PHDP personnel, regardless of their title, position or assignment, have a responsibility to work safely. Every employee is empowered to halt or suspend operations if they perceive conditions or activities that are adverse to safety for themselves, their coworkers, the environment or the public.

3.1 Typical Project Structure

Radiological activities are implemented by the Chase Project Manager (PM) as contracted by the MU Director of Facilities Planning, Design, and Construction. The Chase Project Manager is responsible for regulatory compliance and radiation safety during the performance of each task. The MU Radiation Safety Officer (RSO) oversees Chase's implementation of the Radiation Protection Program (RPP) on each decommissioning task. The organizational chart in Figure 1 depicts a typical structure for decommissioning.

Figure 1: Pickard Hall Decommissioning Organization

Pickard Hall Decommissioning. Radiation Safety Manual

Director Planning, Design,

Construction

MU Project

Manager

D'irector of EHS

MU Radiation Safety Officer

h 2 of 52

Additional personnel may be assigned to tasks as necessary. These personnel may include a project Radiation Control Supervisor (RCS), Radiation Control Technicians (RCTs ), and radiation workers.

The following is a brief description of the roles and responsibilities of key personnel incorporated into the organizational structure depicted in Figure 1.

3.1.1 MU Director of Facilities Planning, Design, and Construction

The MU Director of Facilities Planning, Design, and Construction (DFPDC) reports to the MU Vice-Chancellor of Operations. The MU Director of FPDC maintains fiduciary and contractual responsibilities for the PHDP. Contractually, Chase reports to the MU Director of FPDC.

3.1.2 MU Radiation Safety Officer

The MU RSO is responsible for monitoring and overseeing radiological safety at the PHDP. The RSO has the responsibility and authority to stop any plan or activity that has the potential to result in an unacceptable radiological hazard. The following duties and responsibilities will be assigned to the MU RSO, or designee:

• Supervise the implementation of the PHDP radiation protection program by Chase radiation safety staff.

• Review radiation safety procedures.

• Ensuring compliance with all terms and conditions of the MU Broadscope license;

• Developing, maintaining and implementing procedure, recordkeeping and program audits;

• Oversee the training and qualification program;

• Ensuring personnel assigned to licensed activities are qualified and competent;

• Serving as a point of contact with the NRC for events such as the loss, theft or damage of radioactive material; and

3.1.3 Chase Project Manager

The PM is responsible for task operations from initiation through completion. The PM reports to the MU Project Manager for contractual obligations and to the MU RSO for regulatory obligations. The Chase PM is responsible for daily implementation of the RPP. The PM's duties include the following:

• Ensuring personnel are aware of radiation safety procedures and verifying adequacy of instruction and training for the tasks which they perform;

• Overseeing the personnel monitoring program and maintaining records;

Pickard Hall Decommissioning. Radiation Safety Manual 3 of52

• Ensuring that required surveys and leak tests are performed and documented;

• Maintaining medical surveillance program;

• Ensuring radiological safety of PHDP personnel, public and environment;

• Providing selection criteria for equipment, supplies and services for radiation protection;

• Maintaining instrumentation program and records;

• Establishing standards and procedures for personnel protection to assure that exposures to ionizing radiation and contamination are ALARA.

• Maintaining working conditions which assure health, safety, and protection for all project personnel, visitors and the environment;

• Ensuring that PHDP personnel are provided physical examinations as required by company policy, local, state and federal regulations;

• Ensuring that PHDP personnel are instructed regularly, or as required by law, on precautions, procedures and practices to be followed to minimize exposure to radioactive materials and to conduct operations safely;

• Notifying the RSO promptly, of any operation or condition which appears to present a radiological hazard to PHDP personnel, the public, the environment or exceed limitations set forth in this RSM or applicable procedures and work plans;

• Furnishing proper personnel protective equipment (PPE);

• Ensuring'that PHDP personnel are instructed in the proper use of PPE and enforcing rules for the equipment's utilization;

• Ensuring their project has sufficient staffing to conduct daily operations in compliance with regulatory requirements; and

• Maintaining project radiation exposures ALARA.

3.1.4 Chase Radiation Control Supervisor (RCS)

The RCS reports directly to the PM for day-to-day supervision and is responsible for field implementation of the RPP at the PHDP. If a RCS is not designated for a task, the PM will assume duties of the RCS. The responsibilities of the RCS include but are not limited to the follow:

• Monitoring on-site operations to ensure compliance with the RSM;

• Implementing radiological monitoring programs;

• Tracking worker doses;

• Determining appropriate PPE for project personnel;

• Issuing respiratory protection where applicable;


• Ensuring that the RSO is notified of conditions or situations that present a radiological hazard, concern or exceed limitations set forth in this RSM or applicable procedures and work plans;

• Issuing Radiation Work Permits (RWP) to govern work involving radioactive material; and

• Maintaining records related to the RPP in an auditable condition for the duration of the project.

3.1.5 Radiation Control Technicians (RCT)

RCTs report to the RCS and act as the RCS's representative in specifically implementing the RPP. Responsibilities may include but are not limited to the following:

• Performing and documenting radiological surveys;

• Maintaining, inspecting and performing operational checks of field instrumentation;

• Identifying and controlling radiation protection hazards;

• Tracking worker doses;

• Ensuring that the RSO is notified of conditions or situations that present a radiological hazard, concern or exceed limitations set forth in this RSM or applicable procedures and work plans; and

• Performing job coverage duties, (i.e., surveys, contamination control, air sampling, sample analysis, environmental sampling, custody control, etc.).

, 3.1.6 Radiation Workers

Radiation workers are individuals who have received training for unescorted access into Restricted Areas to perform work where they may receive exposure to ionizing radiation. A Radiation Worker's responsibilities may include but are not limited to the following:

• Obeying all posted, verbal, and Radiation Work Permit (R WP) instructions;

• Wearing dosimetry as required;

• Tracking and controlling one's own radiation exposure;

• Minimizing exposure;

• Not eating, drinking or smoking in areas where dispersible radioactive material may be present;

• Utilizing contamination control techniques to prevent the spread of contamination;


• Properly utilizing anti-contamination clothing and respiratory protection equipment;

• Adhering to personnel monitoring requirements when leaving a contaminated area;

• Notifying radiological control personnel in the event of a spill;

• Reporting the presence of open wounds to radiation protection personnel prior to working in areas where radioactive materials exists; and

• Reporting all injuries occurring in restricted areas to radiation protection personnel and supervisors.

3.1.7 Radwaste Manager

The Radwaste Manager (RM) is specifically trained and qualified to package, survey, and ship radioactive materials. The RM reports to the PM and is responsible for implementing the requirements set forth in lOCFRPart 71, "Packaging and Transportation of Radioactive Material" for the transportation of hazardous materials. This person is responsible through direct performance, observation, or receipt of written notification for the following:

• Verifying that the consignee is licensed to receive the shipment of radioactive material and that the material meets the consignee's specific acceptance criteria;

• Preparing and submitting of an advance notification if required by the receiving facility;

• Obtaining the necessary variances in the event that a shipment does not comply with the consignee's general acceptance criteria;

• Performing various physical tasks necessary to complete the shipment; These tasks include, but are not limited to, the following:

Inspecting packages;

Marking packages;

• Labeling packages;

Loading and shoring packages;

Surveying packages and conveyance;

Placarding transport vehicles; and

• Inspecting transport vehicles.

• Preparing shipping documentation including radiological survey data: the Broker shall ensure that the materials are properly classified, described and are otherwise appropriate for shipment in accordance with the requirements of 1 OCFR 71; and

• Verifying that radiation protection equipment used to perform surveys is calibrated, response checked and functioning properly.


3.2 Personnel Selection and Qualification

No individual shall be assigned a responsibility for radiation protection until that individual has met the RPP personnel qualification. The following outlines qualification criteria for responsible positions.

3.2.1 Project Manager The PHDP PM shall possess at least a B.S. Degree and 10 years combined experience in decommissioning, project management, and radiation safety with at least ten (10) of the years specific to radioactive materials decommissioning. The PM will also have familiarity with applicable federal and state regulations, MARSSIM and NRC decommissioning guidance.

3.2.2 Radiation Control Supervisor

The RCS shall possess at least an associate's degree in science or engineering and have at least two years of experience in the use or handling of radioactive material or demonstrate equivalency of this requirement to the satisfaction of the RSO.

3.2.3 Radiation Control Technician(s)

RCTs shall have one year of working experience in radiation protection or demonstrate equivalency to this requirement to the satisfaction of the RSO.

3.2.4 Radwaste Manager

The Broker shall have two years of applicable experience in radioactive material shipping and possess verifiable training in accordance with 49 CFR 172 Subpart H ~'TrainiIJ.g" and be approved by the PM.

4.0 RADIATION PROTECTION

MU and Chase have established a program of occupational radiation safety to minimize personnel exposure to ionizing radiation. All PHDP personnel shall be committed to maintaining personnel exposures within regulatory limits and ALARA.

4.1 ALARA Policy

It is MU and Chase's policy to maintain control of occupational radiation exposure to levels, which are ALARA. PHDP personnel will be aware of MU and Chase's commitment to keep occupational exposures ALARA through an integrated program consisting of:

• Utilizing engineering controls whenever possible;

• Employee training and instruction;

• Procedural reviews;


• Making available proper tools and equipment;

• Accounting for exposure from licensed and unlicensed material and radiation sources other than background;

• Administrative exposure control limits; and

• Annual exposure reviews.

The MU RSO will review the effectiveness of the ALARA program through the audit program.

4.2 Task Work Plans

PHDP tasks conducted under this RSM shall be reviewed prior to initiation to ensure adherence to this RSM and ALARA policy. Task-specific work plans may serve as the documentation for these reviews, which will address the following:

• Description of the project;

• Estimate of the types, quantities and physical/chemical forms ofradioactive material;

• Specifications of building location including facilities and equipment;

• Radiation detection instruments to be used;

• Description of activities including waste management and disposition; j ;

• Estimated task start date and duration;

• Identification of and contact information fbr key personnel;

• Description of personnel dosimetry and bioassay procedures;

• Evaluation of hazards including risk of internal and external exposure to the workers and the environment;

• Methods to minimize personnel radiation exposure;

• Potential use of engineering controls; and

• Establishment ofRWP criteria such as, PPE, radiological monitoring requirements and specific work instructions.

The content of work plans shall be commensurate with the scope, complexity, and risk of the task. To assist in project planning and work plan development, "Task Review" form, Attachment 1, is provided as an aid, but is not required for each task. Simple tasks that typically require only one person will not need this level of review or generation of project-specific work plans.


4.3

4.3.1

4.3.2

Occupatio nal Dose Limits

Appropriat 10% of the

e dosimetry shall be issued to individuals that have a potential to exceed regulatory limits listed in Table 4-1. Additionally, extremity monitors ( e.g., ) and/or Self Reading Dosimeters (SRD) will be utilized when conditions ., entry into High Radiation Area).

finger rings warrant (i.e

Regulato ry Limits

All PHDP exposures

personnel will make every reasonable effort to maintain radiation worker ALARA. Occupational dose to individual adults and minors shall be to the limits presented in Table 4-1 and as described in 1 OCFR20 Subpart constrained

C.

Annual Adult Dose Limits Quantity

Total Effe ctive Dose E uivalent TEDE Sum ofth e Deep Dose Equivalent and the Committe d Dose Equivalent to an Individual

Tissue Other Than the Lens of the Eye Organ or

Eye Dose E uivalent Shallow Dose Equivalent to the Skin or to Any Extremity Embryo o r Fetus of a Declared Pre ant Woman

Administr ative Limits

Annual Limit rems Adults Minors

5 0.5 50 5

15 1.5 50 5

0.5

Administra for occupati

tive limits have been established as part of the ALARA program. The limits onal doses are set at 50% of the regulatory limits and are presented in Table

4-2.

Table 4-2 Administrative Annual Dose Limits Quantity Annual Limit rems

TEDE Sum ofth e Deep Dose Equivalent and the Committe d Dose Equivalent to any Individual

Other Tissue Other Than the E e Organ or Eve Dose E uivalent Shallow Dose Equivalent to the Skin or to Any Extremity

Adults Minors 2.5 0.25 25 2.5

7.5 0.75 25 2.5

Pickard Hall Deco mmissioning. anual Radiation Safety M 9 of52

Administrative limits may knowingly be exceeded with written approval from the MU RSO after a thorough review of the individual's exposure history, engineering controls and project ALARA practices.

4.4 Dose to an Embryo or Fetus

MU and Chase shall ensure that the dose to an embryo or fetus during the entire pregnancy, due to occupational exposure of a declared pregnant woman, does not exceed 500 mrem. Efforts will be made to avoid substantial variation above a uniform monthly exposure rate to a declared pregnant woman during the gestation period or remainder thereof.

The dose to an embryo or fetus from occupational exposure shall be the sum of the deep-dose equivalent to the declared pregnant woman and the dose to the embryo or fetus from radionuclides in the embryo or fetus and the declared pregnant woman.

If the dose to the embryo or fetus at the time of declaration exceeds 500 mrem, or is within 50 mrem of this dose, the declared pregnant woman shall be limited to no more than 50 mrem from occupational exposure for the remainder of the pregnancy. Any individual wishing to declare their pregnancy should do so utilizing Attachment 14 or equivalent.

Records for dose to an embryo or fetus of a declared pregnant woman shall be maintained in the declared pregnant woman's file.

4.5 Public Dose Limits

Exposure of any individual outside of a restricted area shall be limited such that the total.dose from project operations shall not exceed 100 mrem per year. The dose in an unrestricted area from external sources associated with project operations shall not exceed 2 mrem in any one hour.

If members of the public (i.e., individuals not designated as occupationally exposed personnel) are permitted access to restricted areas, the limits for members of the public apply.

Air emissions of radioactive material to the environment, excluding radon-222 and its daughters, shall be limited to ensure that the highest dose that could be received by a person shall not exceed a dose 10 mrem per year.

4.6 Escorted Access

At times, it is necessary to allow visitors or subcontractors into restricted areas for short duration activities. The PM/RCS will evaluate the activities, duration, dose rates, and contamination levels in the areas. If it is anticipated that personnel could receive greater than 10% of the public limit (10 mrem per year), then the individual shall be


issued dosimetry and dose recorded. At a minimum, these individuals will be briefed in accordance with Section 6.3.1 and escorted by a qualified radiation worker.

4.7 Internal Monitoring

Tasks shall be evaluated to determine if individuals will be exposed to airborne radioactive material in the quantities, chemical and physical forms, and activities which make it likely that radioactive material will be ingested, inhaled or absorbed resulting in an intake in excess of 10% of the applicable annual limit on intake (ALI) in 1 OCFR20 Appendix C

MU and Chase will institute exposure monitoring if the evaluation determines that personnel will likely intake greater than 10% of an ALI. The monitoring will consist of one or a combination of the following:

• Air sampling to determine airborne concentrations of radioactive materials in work areas;

• In-vivo monitoring for quantities of radionuclides in the body; or

• In-vitro monitoring for quantities of radionuclides excreted from the body. !

4.7.1 Air Sampling

Air sampling will be conducted in accordance with Section 9.3 to determine the quantity of radioactive material stispended in the air during project activities when required in accordance with Section 4.7. The following will apply when assessing and assigning dose to individuals using air samples.

• Assume an individual inhales radioactive material at the airborne concentration in which the individual is present, unless respiratory protective equipment is used;

• If the identity and concentration of radionuclides in a mixture are known, the fraction of the derived air concentration (DAC) applicable to the mixture for use in calculating DAC-hours will be the sum of the ratios of the concentration to the appropriate DAC value (e.g., D, W, Y) from Appendix B of 10 CFR 20 for radionuclides in the mixture; or the most restrictive DAC value may be applied to the mixture.

• If the identity of radionuclides in a mixture is known, but the concentration of one or more of the radionuclides in the mixture is not known, the DAC for the mixture shall be the most restrictive DAC of any radionuclide in the mixture.

• If a mixture of radionuclides exists, certain radionuclides in the mixture may be disregarded if the concentration of a disregarded radionuclide is less than 10% of its DAC and the sum of the percentages for the disregarded radionuclides in the mixture does not exceed 30%.


4.7.2 Whole Body Count (in-vivo Bioassay)

A whole body count may be required for PHDP personnel reqmrmg internal monitoring. If this method is impractical due to logistics or availability of commercial providers for this service, then other methods may be utilized.

4.7.3 Urine/Fecal Analysis (in-vitro Bioassay)

In-vitro bioassay is a measurement or analysis of materials excreted from the body. Depending on the radionuclide involved, internal monitoring may consist of urine and/or fecal samples sent to a laboratory for analysis.

4.7.4 Routine Monitoring

Periodic routine internal monitoring may be established for projects with long duration. A routine monitoring program is designed to provide continuity of information from initial pre-project bioassay to project termination.

4.7.5 Non-routine Monitoring

In the event radiation workers are involved in a spill or other unanticipated radiological condition that could expose them to greater than I 0% of an ALI as specified in 1 OCFR20 Appendix B Table 1 (including allowance for respiratory protection), the PM/RCS shall notify the MU RSO and perform an evaluation of the nature of the hazard to project per~onnel and the public. Consideration will be given to type of radioactivity, length of exposure, inhalation class, concentrations of radioactivity and type of uptake.

Additional monitoring may be necessary to evaluate internal exposures. This additional monitoring may include but is not limited to the following:

• Nasal smears;

• Whole body counts;

• Urine/fecal samples;

This monitoring will be performed as necessary to evaluate individual doses from internally deposited radionuclides.

4.8 Pre-project Baseline Bioassay

An initial project baseline bioassay may be established for radiation workers expected to be occupationally exposed to conditions that could result in an intake greater than 10% of an ALI. These baselines are normally established prior to permitting an employee to work in a restricted area.


4.9 Post-project Bioassay

The PM and/or RCS should make an effort to ensure that project personnel exposed to conditions that exceeded 10% of an ALI have a post project bioassay performed. Alternately, dose may be assigned from air sample results in accordance with Section 4.7.1.

4.10 External Radiation Monitoring Dosimetry

4.10.1 Whole Body Monitoring Dosimetry

A personnel dosimeter shall be assigned to individuals that are likely to receive external occupational exposure greater than 10% of the allowable limits listed in Table 4-1. The dosimeter shall consist of a Thermo-Luminescent Dosimeter (TLD) or equivalent issued by Chase or MU. Each person assigned a dosimeter will wear it on the front upper portion of the torso (i.e. chest) unless otherwise directed by radiation protection personnel. When conditions warrant, a SRD may also be issued for real time dose tracking. Personnel assigned dosimeters shall be instructed on the proper use and care of the dosimeter. Such instructions shall include the following:

• Avoid extreme temperatures, (e.g., do not leave in vehicles)

1 • A void extreme moisture, ( e.g., do not launder with clothes)

• Avoid exposures when traveling where practical, (e.g., X-Ray devices in airports)

,,.; • 1 Report lost or missing dosimetry immediately upon discovery

4.10.2 Extremity Monitoring Dosimetry

Each project shall be reviewed to determine if extremity-monitoring dosimetry will be required. Extremity dosimetry will be assigned to and worn by individuals who will handle radioactive material that could result in an exposure greater than 10% of the extremity exposure limit listed in Table 4-1.

4.10.3 Quality Assurance of Dosimetry

All personnel whole body and extremity dosimetry ,will be processed by an !organization holding a current accreditation for personne! dosimetry by the National Voluntary Laboratory Accreditation Program (NVLAP) of the National Institute of Standards and Technology (NIST).

Currently, TLDs are issued; however, other types of dosimetry may be utilized provided they are accredited with NVLAP and approved by the RSO.

Personnel whole body and extremity dosimeters shall be processed at least quarterly.

SRDs will be calibrated annually by properly licensed facility unless specified otherwise by the vendor or manufacturer.


4.10.4 Records

The RSO shall be responsible for maintaining personnel dosimetry and internal monitoring records in accordance with Section 4.17 and make these records available for inspection by the NRC.

The RCS shall be responsible for acquiring historical data from temporary PHDP personnel or subcontractors that may be exposed to greater than 10% of the applicable limits listed in Section 4.3 .1. Attachment 2 "Dosimetry Issuance Form" or equivalent shall be used to obtain required information and assign dosimetry.

4.11 Radiological Work Permits (RWP)

A RWP is an administrative tool used to:

• Establish radiological controls for intended work activities; and

• Inform workers of area radiological conditions and entry requirements.

RWPs are used to control radiological work by specifying:

• PPE requirements for a job;

• Respiratory protection requirements;

• ALARA Limits;

• Dosimetry requirements; add/or

• Work restrictions.

Special work instructions may be incorporated for additional protection of radiation workers. RWPs are records of the controls established during the course of a project. All personnel will be briefed on the contents and requirements established in the applicable RWP. RWPs are to be maintained at or near work locations for access by radiation workers. Each person making entry into an area where an R WP is required will sign the entry form indicating that the individual has read, understands, and will comply with the requirements of the R WP.

The RCS is responsible for initiating RWPs and periodically evaluating the applicable radiological conditions for adequacy. The RCS shall terminate RWPs upon completion of the work covered by the RWP. Attachment 3 through Attachment 5 or equivalent may be utilized. Attachment 2 may serve as the R WP for routine packaging operations.

4.11.1 General RWP

General R WPs are used in radiological areas that have stable conditions with uniform fields of radiation/contamination. These RWPs can cover a wide range of activities from tours and inspections to daily operations of a repetitive nature. General R WPs may last the duration of the project or duration of the activities in a specified location.


4.11.2 Job-Specific RWP

Job-Specific R WPs are used in radiological areas that have changing conditions, require entry into a "High Radiation Area", "Airborne Radioactivity Area", and for activities that are new in nature or rarely performed.

4.11.3 Revising RWPs

During the course of project activities, changes in field conditions may cause the requirements of an RWP to be inadequate or too restrictive. If such a situation is encountered, the RCS will initiate field changes with the concurrence of the PM. Changes shall be made in indelible ink, initialed and dated by the RCS and the PM.

4.11.4 RWP Records

RWPs will be maintained at temporary job sites until completion of the project, at which time, the R WPs will become part of the project files and maintained in accordance with Section 4.17.

4.12 Respiratory Protection

The radiation protection respiratory protection program will be administered by the RSO in accordance with 29 CFR 1910.134 and IO CFR 20 Subpart H. MU and Chase's policy is to use, to the extent practical, process or other engineering controls ( e.g., containment or ventilation) to control the concentrations ofradioactive material in air.

If it is not practical to apply process or engineering controls to limit the concentration of radioactive material in air to values below those defining an Airborne Radioactivity Area, MU and Chase will increase monitoring and limit intakes by one or more of the following actions:

• Controlling access;

• Limiting exposure times;

• Using respiratory protection equipment; or

• Utilizing other controls approved by the NRC.

MU and Chase shall only use National Institute for Occupational Safety and Health (NIOSH) approved respiratory protection equipment to limit intake of radioactive material.

Voluntary use of respirators at the request of PHDP personnel will be allowed if the use will not in itself create a hazard. The employee requesting to use respirators voluntarily should be made aware of information in Appendix D "Information for PHDP personnel Using Respirators When Not Required Under The Standard" of 29 CFR 1910.134.


PHDP personnel who voluntarily use filtering face-pieces (dust mask) are not subject to the provisions of the respiratory protection program. As such, no protection factor is assigned.

4.12.1 Evaluation of Hazard

An evaluation of the hazards will be conducted by the PM to determine the practicality of respiratory protection. The evaluation will take into consideration the following criteria:

• The operation involves the handling of radioactive material that is known or suspected to be unconfined or dispersible;

• The operation involves activities where an individual could likely inhale greater than 10% of the most restrictive ALI as listed in 10 CFR 20, Appendix B for the radionuclide of concern or combination of radionuclides;

• Air samples taken of an operation indicates greater than 10% of the most restrictive DAC listed in 10 CFR 20, Appendix B for the radionuclide of concern or combination of radionuclides;

• Respiratory protection is a specific requirement of operational procedures; and

• The TEDE with respiratory protection vs. the TEDE without respiratory protection should be determined.

All other means of control must have been evaluated for feasibility prior to the assignment or use of respiratory protection.

4.12.2 Respiratory Protection Equipment Training

All personnel required to use respiratory protection shall have received training within 12 months prior to its use. Training shall include the following procedures:

• Selection;

• Fit testing;

• Issuance;

• Maintenance;

• Inspection prior to use;

• Testing requirements;

• Medical evaluation requirements;

• Proper use and limitations; and

• Respiratory protection program .

Pickard Hall Decommissioning. Radiation Safety Manual . j 16 of 52

All personnel required to use respiratory protection will be informed that the user may leave the area for relief from respirator use in the event of the following:

• Equipment malfunction;

• Physical or psychological distress;

• Procedural or communication failure;

• Significant deterioration of operating conditions; or

• Other conditions that may require relief.

4.12.3 Medical Surveillance

The Chase PM or RCS shall ensure that each individual has been evaluated by a physician within the past 12 months and determined to be medically able to use the equipment prior to:

• Initial fitting; and

• Issuance for use.

4.12.4 Respiratory Protection Equipment Fit Testing

All personnel who are required to use tight fitting face-piece respirators and who have been medically qualified to do so shall have received a fit test within twelve months prior to its use. The fit test will be administered under the guidance and direction of an individual or entity as delegated by the RSO and documented on Attachment 13 or equivalent.

The respirator fit test will be conducted in accordance with 29 CFR 1910.134 Section (f), "Fit Testing" and utilize one or more of the methods specified in 29 CFR 1910.134 Appendix A, "Fit Testing Procedure." '

No tight-fitting face-piece respirators shall be worn by personnel who have facial hair such as beards or long sideburns that interfere with the sealing surfaces of the respirator face-piece or with respirator valve function.

If the user of a respirator requires vision corrective lenses, respiratory glasses will be provided. Under no circumstances will glasses with temple pieces be used were the temple pieces may interfere with the sealing surface of a tight-fitting face-piece respirator.

4.12.5 Issuance of Respiratory Protection Equipment

Only the RCS or properly trained designee shall be permitted to issue respiratory protection.


4.12.6 Respiratory Equipment Inspection and Maintenance

The wearer, prior to each use, shall inspect all tight-fitting face-piece respiratory protection equipment. This inspection shall include the following:

• Presence of face-piece distortion;

• Strap elasticity;

• Face-piece rubber deterioration;

• Proper valve seals; and

• Cleanliness.

If, at any time, a respirator is found to be deficient, the employee shall return it to the RCS or designee for a suitable replacement.

All respirators shall be cleaned and disinfected after each day's use by the RCS or designee. Each respirator will be inspected as previously described prior to placing it back in storage for reuse.

After cleaning, disinfecting or maintenance, respiratory equipment will be properly stored in a manner that mitigates contamination and face-piece distortion. Tight fitting air-purifying devices may be placed in a clean plastic bag and sealed.

Only NIOSH-approved components and repair parts will be' used. · Repair and replacement parts shall be provided by the same manufacturer as the equipment being serviced. No interchanging of parts with different makes or models of respirators is permitted.

No attempt shall be made by personnel to repair or adjust reducing valves or regulators unless they have attended and satisfactorily completed training provided by the manufacturer or vendor and approved by the RCS. Otherwise, equipment of this type will be sent to the manufacturer or to an approved vendor for repairs.

Emergency use devices (i.e., self-contained breathing apparatus (SCBA)), are devices dedicated for.use in emergencies only. Such equipment will be stored in the supplied wall mount cir carrying case. Emergency use respiratory equipment shall be inspected by a properly trained individual, at least once a month when in service, to ensure its readiness. A record of inspection shall be maintained, listing the respirator, date of inspection and any defects found.

Emergency use devices that are not in service, (not available for use) shall be tagged or marked to indicate that they are not for use and segregated/stored separately from equipment that is available for use.

Pickard Hall Decommissioning. Radiation Safety Manual , 18 of 52

4.12.7 Respiratory Protection Program Records

All records relating to the respiratory protection program (i.e., medical evaluation, fit testing, inspections, etc) shall be maintained in accordance with Section 4.17.

4.13 Posting and Labeling

The PM/RCS shall be responsible for complying with posting areas and labeling materials per the requirements of 10 CPR 20 Subpart J.

4.13.1 General Posting and Labeling Requirements

Postings and labels shall include the standard radiation warning three bladed trefoil in

black, purple or magenta on a y~~

\ I ,:

~·t') I J:-" I t-t......... t -SA--'

Figure 2: Trefoil

Exception to color requirements for standard radiation symbol are source labels, source holders or device components containing sources of radiation subjected to high temperatures provided they are conspicuously etched or stamped with radiation caution symbols.

Postings and labels may provide, on or near the required signs and labels, additional information, as appropriate, to make individuals aware of potential radiation hazards and to minimize exposures.

4.13.2 Radiological Area Posting Requirements

1. The words "Caution, Radioactive Material" or "Danger, Radioactive Material" shall be posted at any area or room in which there is used or stored an amount of licensed or registered material exceeding 10 times the applicable values in Appendix C to 10 CPR 20.


2. The words "Caution Radiation Area" shall be posted at any area accessible to individuals where radiation levels could result in an individual receiving a dose equivalent in excess of 5 mrem in one hour at 30 cm from the radiation source or from any surface that radiation penetrates.

3. The words "Caution, High Radiation Area," or "Danger, High Radiation Area" shall be posted at any area accessible to individuals in which radiation levels from sources external to the body could result in an individual receiving a dose equivalent in excess of 100 mrem in one hour at 30 cm from the radiation source or from any surface that the radiation penetrates.

4. The words "Grave Danger, Very High Radiation Area" shall be posted at any area accessible to individuals in which radiation levels from sources external to the body could result in an individual receiving an absorbed dose in excess of 500 rads in one hour at one meter from the radiation source or from any surface that the radiation penetrates.

5. The words "Caution, Airborne Radioactivity Area" or "Danger, Airborne Radioactivity Area" shall be posted for:

• Any area accessible to individuals in which airborne radioactive material, composed wholly or partly of licensed material, exists in concentrations in excess of the DAC specified in 10 CFR 20, Appendix B; or

• Any area where an individual present without respiratory protection equipment could receive an intake in excess of 12 DAC-hours in a week. For a 40-hour week, this is equivalent to 0.30 DAC.

4.13.3 Exceptions to Posting Requirements

Areas may be exempted from posting when:

• The area will exist for less than 8 hours and is under the control of a RCT or designated qualified representative who is knowledgeable of and empowered to implement required access and exposure control measures and the area or room is subject to the licensee's control;

• The source of the radiation is a sealed source, and the radiation level at 30 cm from the surface of the source container or housing does not exceed 5 mrem/hr;

4.13.4 Radioactive Material Labeling/Tagging Requirements

Except as provided in Section 4.13.5, each item or container of radioactive material shall bear a durable, clearly visible label containing the radiation symbol and the words "Caution, Radioactive Material", or "Danger, Radioactive Material". The label shall provide sufficient information to permit individuals handling, using, or working near the items or containers to take precautions to avoid or control exposures.


The label or tag will have, at a minimum, the following information as applicable:

• Radionuclide present;

• An estimate of the quantity of radioactivity;

• Date the activity is estimated;

• Radiation levels;

• Kinds of materials; and

• Mass enrichment.

4.13.5 Exceptions to Labeling

Items and containers may be exempt from the radioactive material labeling requirements when:

• Used, handled or stored in areas posted and controlled in accordance with Section 4.13.2 and sufficient information is provided to permit individuals to take precautions to avoid or control exposures; or

• The quantity of radioactive material is less than the quantities specified in 10 CFR 20, Appendix C;

• The quantity of the radioactive material is less than the quantities specified in 10 CFR 20, Appendix B;

• Packaged, labeled or marked in accordance with 49 CFR 100-180;

• The containers are attended by an individual who takes precautions necessary to prevent the exposure of individuals in excess of the limits; or

• , Installed in manufacturing, process, or other equipment such as reactor components, piping and tanks.

Prior to removal or disposal of empty uncontaminated containers to unrestricted areas:

• Remove or deface all radioactive material labels; or

• Cleariy indicate the container no longer contains radioactive materials.

4.14 Instructions and Notices to PHDP personnel

The following items will be posted at the PHDP or a notice posted to where they may be found.

• A copy ofNRC Form 3 "Notice to personnel";

• Current copies of 10 CFR parts 19 and 20;

• A copy of the current MU radioactive material license;


• Notice of violation involving radiological working conditions, proposed imposition of civil penalty, or order issued as authorized by 10 CFR 20 and responses;

• A copy of the Radiation Safety Manual; and

• Operating procedures (i.e. decommissioning plan, health and safety plan, etc.) applicable to the work being performed.

Where it is impractical to post documents, a notice shall be posted which describes the documents and states where they may be examined. Post these notices in a sufficient number of places to permit an individual engaged in work under the license to observe them on the way to or from a particular work location to which the documents apply. Other documents/notices to workers may be made available via electronic media such as a compact disc, memory card, or via the internet.

4.15 Notifications and Reports to Individuals

Individual employee radiation exposure data shall be reported to the individual as specified in this section. This data may consist of the following:

• Results of any measurements;

• Analyses and calculations of radioactive material deposited or retained in the body of an individual; or

• Data and results required by regulations, orders or license conditions.

4.15.1 Format

Notification reports shall be in writing, issued by the MU RSO, and include:

• Name of the licensee;

• Name of the individual;

• Individual's identification or social security number;

• Individual's exposure information; and

• Contain the following statement:

"This report is furnished to you under theJ provisions of the Nuclear Regulatory Commission regulation 10 CFR part 19. You should preserve this report for further reference."

4.15.2 Annual Report to Individuals

The RSO shall advise in writing each monitored individual annually of exposure to radiation or radioactive material as shown in the records maintained by the RSO for the previous 12 month period for which monitoring occurred if the TEDE is greater than 100 mrem/yr.


4.15.3 Report to Former PHDP personnel

At the request of an individual formerly engaged in PHDP activities, a report of the individual's radiation exposures shall be issued within 30 days from the time the request is made, or, within 30 days after exposure has been determined, whichever is later. The report will contain the following:

• Period of time the worker's activities involved exposure to radiation from radioactive materials; and

• Dates and locations of work under the license in which the worker participated during this period.

4.15.4 Report to Individuals - Incidents

Where MU is required, pursuant to 10 CFR 20.2203, 2204, and 2206, to report to the NRC an exposure of an individual to radiation or radioactive material, MU shall also provide the individual a report on the exposure data included in the report to the NRC. The reports shall be transmitted to the individual at a time not later than the transmittal to the NRC.

4.15.5 Report to Individuals - Termination

At the request of a worker who is terminating employment in work involving exposure to radiation or radioactive material, during the current year, MU shall provide to the worker or designee, a written report regarding the radiation dose received by that worker from operations during the current year or fraction thereof at termination.

If the most recent individual personnel monitoring results are not available at the time of termination, a written estimate of the dose shall be provided. Estimated doses will be clearly indicated as estimated doses.

4.16 Instrument Check Sources

4.16.1 Security and Posting

All non-exempt instrument check sources, when not in use, shall be located in a source storage locker, posted in accordance with Section 4.13, and locked when not attended. The PM will ensure sources are secured against unauthorized removal and access when the sources are not assigned to projects.

4.16.2 Radiation Levels

The on-contact radiation level to all accessible exterior surfaces of the storage locker shall be maintained at less than 2 mrem/hr. A radiation survey of the storage locker will be performed immediately after the receipt of any additional non-exempt check sources. Surveys shall be performed of the storage locker and of project-specific storage container when sources are transferred.


4.16.3 Transfer or Disposal

In the event a non-exempt source is no longer required, it shall be disposed of as radioactive waste or transferred to an individual licensed to possess the source. Written verification of the assignee's legal authorization to possess the source will be obtained prior to transferring possession. All documents associated with such transfers shall be maintained in accordance with Section 4.17.

4.16.4 Inventory

A physical inventory and leak test of all non-exempt sources shall be conducted semiannually. This inventory will be updated as sources are transferred, received, or disposed. A physical inventory shall be conducted at temporary locations by the RCS at the establishment, termination, and quarterly during the project. This inventory shall be updated as sources are transferred, received, or disposed. Attachment 8 "Source Accountability Log" or equivalent shall be used when sources are transferred between storage and projects.

Records of inventories and leak test shall be maintained for a period of not less than five years in accordance with 10 CFR 20 in a manner that complies with Section 4.17.

4.17 Maintenance and Retention of Records

Records will be maintained pursuant to 1 OCFR parts 19 and 20 and discussed in the following sections.

4.17.1 General Provisions

Records shall be legible throughout the specified retention period and stored in the following formats:

• The original;

• A reproduced copy;

• Authenticated microform copy that can produce a clear legible copy; or

• Electronic media that can produce a clear, legible, accurate, and complete record.

Records such as letters, drawings and specifications, will include pertinent information such as stamps, initials and signatures. Records will be stored and controlled in order to mitigate tampering and/or loss.

Records will use the units curie, rad, dpm and rem, including multiples and subdivisions. Units and quantities will be clearly indicated on required records, such as the following:

• Total effective dose equivalent;


• Shallow-dose equivalent;

• Eye dose equivalent;

• Deep-dose equivalent; and

• Committed effective dose equivalent.

The following records shall be maintained for a period of no less than three years after the record was made:

• Audits;

• Surveys and instrument calibration records;

• Records used for preparing NRC Form 4 or equivalent;

• Records of Radiation Safety Committee meetings; and

• Testing of Very High Radiation Area control devices.

The following records shall be maintained until the NRC terminates the PHDP amendment in the MU broadscope license:

• Records detailing the provisions of the Radiation Protection Program;

• Surveys used to determine dose for assigning individual dose equivalents;

• Results used to assign internal dose (i.e., air sample data, surveys, bioassay, etc.);

• Results used for effluent release ofradioactive material;

• NRC Form 4 or equivalent;

• Records of planned special exp~sures;

• Records for dose received by monitored individuals on NRC Form 5;

• Records for dose received by embryo or fetus of declared pregnant woman;

• Dose to individual members of the public; and

• Records of physicals and fit testing for respiratory protection purposes;

[

Records described above shall be maintained and available for inspection by the NRC, at the MU Radiation Safety Office.

4.18 Planned Special Exposures

MU does not anticipate the need to authorize any adult worker to receive doses in addition to, and accounted for separately, from the doses received under the limits specified in Section 4.3. If in the course of decommissioning it is determined such an exposure authorization is warranted, then MU will comply with the regulations as specified in 10 CFR 20.1206.


4.19 Notification oflncidents

MU will make notifications to the NRC in accordance with 10 CFR 20 sections 2201, 2202, and 2203.

4.19.1 Immediate Notifications

Immediate notification to the NRC shall be made upon discovery of any event involving radioactive materials that may have caused, or threatens to cause any of the following conditions:

• Lost, stolen or missing licensed/registered material in an aggregate quantity equal to or greater than 1,000 times the quantity specified in Appendix C to part 20 under such circumstances where it appears that an exposure may result to persons in unrestricted areas;

• An individual receiving:

A TEDE of25 rems or more;

An eye dose equivalent of 75 rems or more; or

A shallow-dose equivalent to the skin or extremities of250 rads or more.

• Release of radioactive material, except in areas not normally occupied by personnel (i.e., hot-cells or process enclosure), such that an individual present for 24 hours, could receive an intake 5 times the occupational ALL

4.19.2 Twenty-four Hour Notifications

Notification shall be made within 24 hours of discovery of any event involving the loss of control of licensed/registered source of radiation possessed that may have caused, or threatens to cause any of the following conditions:

• An individual could receive, in a period of 24 hours:

A TEDE exceeding five 5 rems;

An eye 'dose equivalent exceeding 15 rems; or

A shallow-dose equivalent to the skin or extremities exceeding 50 rems.

• Release of radioactive material, except in areas not normally occupied by personnel (i.e., hot-cells or process enclosure), such that an individual present for 24 hours, could receive an intake in excess of 1 ALI;

A report will be prepared and filed with the NRC such that names of individuals who have received exposure are stated in a separate and detachable part of the report.


The provisions of this section shall not include doses that result from planned special exposures that are within the limits for planned special exposures and are reported in accordance with Section 4.18.

4.19.3 Thirty Day Notifications

A written report shall be submitted to the NRC within 30 days after discovery of any of the following incidents:

• An incident for which notification shall be required by Section 4.19 .1 or 4.19 .2;

• Doses in excess of any of the following:

Occupational dose limits for adults and minors in Section 4.3.1;

Limits for an embryo or fetus of a declared pregnant woman in Section 4.3.1;

• Limits for an individual member of the public in Section 4.4; or

• Air emissions that could result in a member of the public receiving greater than 10 mrem per year from any nuclide excluding radon 222 and its progeny.

• Levels of radiation or concentrations of radioactive material in:

• A restricted area in excess of an applicable limit in the license; or

An unrestricted area in excess of 10 times the limits in Section 4.4 regardless of exposure to an individual.

The report required by this section shall describe the extent of exposure of individuals to radiation and radioactive material, including, as appropriate: :

• Estimates of each individual's dose;

• The levels of radiation and concentrations of radioactive material involved;

• The cause of the elevated exposures, dose rates or concentrations;

• Corrective actions, (taken or planned) to prevent a recurrence of the incident; and

• Schedule for achieving conformance with applicable limits, ALARA constraints, environmental standards and associated license conditions.

A report filed under this section shall include for each individ~al exposed:

• Name of the individual;

• Unique identifier or Social Security Number; and

• Date of birth.

The report shall be prepared so that information is stated in a separate and detachable part. The identifiers for the embryo or fetus shall be of the declared pregnant woman.


5.0 RADIATION PROTECTION PROGRAM REVIEW

The MU RSO shall establish and administer a radiation protection review program to ensure compliance with the license and to ensure that radiation safety practices are followed. This program shall result in the RPP content and implementation being reviewed annually.

5.1 Review Scope

The program review will consist of a comprehensive system of planned and documented inspections to verify compliance with all aspects of the RPP and regulatory requirements.

Reviews shall include, at a minimum, verification of compliance and effectiveness of implementation of the following:

• Internal rules;

• Procedures;

• Regulations;

• License provisions;

• Programs for training and retraining;

• Programs for qualification and performance of operating staff;

• Corrective actions taken following abnormal occurrences; and

• Record keeping requirement.

5.2 Reviewer Qualifications

Radiation protection program reviewers shall have the following minimum qualifications:

• Bachelor's Degree in science, engineering or equivalent experience and training as approved by the RSO; and

• A minimum of one year of experience with radiation safety and program management or equivalent.

5.3 Review Frequencies

RPP reviews shall be performed at least annually. Program elements shall be inspected such that the entire radiological controls program is reviewed.

All reviewers will utilize checklists developed from NUREG-1556 Vol. 18 Appendix I or operating documents (i.e., license, RSM, procedures, etc.).


5.4 Program Review Reports and Responses

The reviewer shall immediately identify and bring to the attention of project supervision any items that may present a radiological or safety concern, or other hazard to PHDP personnel, the environment, or the public. Corrective actions shall be initiated immediately.

Upon completion of an inspection at a specific project, the reviewer shall meet with the PM to review the findings.

The reviewer shall prepare an inspection report and submit it to the RSO. The RSO shall forward the report to the PM. The PM shall respond to the report by indicating actions scheduled, or already taken, to comply with the findings. All action items shall include a schedule for completion or implementation. The RSO will verify completion of corrective actions.

5.5 Program Review Records

Copies of inspections, reports, and corrective actions shall be maintained in accordance with Section 4.17.

6.0 PERSONNEL TRAINING

The RSO has overal.l responsibility for the radiation protection-training program. The PM shall be responsible for ensuring/verifying that project PHDP pe~sonnel, contractors and visitors have been furnished training commensurate with their duties.

Each active/assigned radiation worker and supervisor will undergo training commensurate with potential radiation protection problems likely to be encountered during routine and emergency conditions in work areas. Prior training and experience will be taken into consideration for determination of the appropriate training approach and subject matter.

Training may be delivered in a variety of formats such as classroom instruction, onthe-job-training, vipeos, self-study and/or computer based training that emphasizes practical subject niatter important to the safe handling of licensed materials. · Written, oral and/or performance based examinations may be given to determine understanding and proficiency of the employee.

6.1 Radiation Protection Training Instructors

Persons conducting training will be qualified individuals, approved by the RSO, who are familiar with the RPP. Instructors who provide classroom training to individuals in the principles of radiation safety will have knowledge and understanding of these principles beyond those obtainable in a course similar to the one given to students. Individuals who provide instruction for the hands-on use oflicensed materials will have


training and experience that would qualify them to be authorized users or possess a thorough understanding of the licensed operations.

6.2 Training/Retraining Frequency

Training shall be conducted on a frequency commensurate with the activities to be performed by the individuals assigned to projects in accordance with the following:

• Before assuming duties with, or in the vicinity of, licensed radioactive materials;

• Whenever there is a significant change in duties, regulations, or the terms and conditions of the license;

• Annually for refresher training unless otherwise noted in Table 6-1.

Personnel shall receive initial training and, thereafter, retraining as necessary to ensure a high degree of proficiency is maintained. The required training frequencies for general PHDP personnel, radiation worker and radiation protection personnel training are presented in Table 6-1.

Table 6-1 RPP Training and Frequency for Assigned Personnel

Typ~ of Training PHDP personnel

Receivin2 Trainin2

, General Escorted visitors

Orientation All project personnel

Radiation Worker Training

Radiation Workers

Personnel required to

Respiratory wear respiratory

. Protection protection or to

I supervise work · Training involving respiratory

protection

DOT 1 72 subpart All Hazmat PHDP H personnel

Pickard Hall Decommissioning. Radiation Safety Manual

Completion of Minimum Initiat'1'rainin2: Freauency Prior to entering

Once per project restricted areas Prior to start of

Once per project oroiect

Prior to handling radioactive Annually materials

Prior to first use Annually ~

'

Prior to performance of every 3 years

activities

30 of 52

6.3 Training Requirements

MU and Chase are committed to maintaining a qualified and informed workforce. Individuals will receive the training necessary to complete their assigned task. The following sections detail the minimum training requirements for individuals who may receive exposure during the course of their duties.

6.3.1 General Orientation

General orientation shall be administered to all personnel, contractors and visitors requiring access to restricted areas. The scope of orientation shall be commensurate with the activities being performed and the risks involved. The orientation shall consist of the following:

• Project-specific health and safety orientation;

• The location of restricted areas;

• Posting and labeling identification of radiological areas and packages;

• Requirement for PPE and dosimetry;

• Escort requirements;

• Review of Regulatory Guide 8.13 "Instructions Concerning Prenatal Radiation Exposure," Appendix B (required for female contractors or visitors); and

• For visitors, completion of "Visitor Orientation" form, Attachment 11 or equivalent.

General orientation training shall be. valid only for the particular project at which it is administered. Escorts shall have a minimum of Radiation Worker training.

6.3.2 Radiation Worker Training

Radiation workers are personnel who work in restricted areas, handle or transport radioactive material, or otherwise receive occupational exposure to radiation because of their job function. Radiation worker training shall address, at a minimum, the items listed in the general orientation plus the fundamentals ofradiation safety, which include the following:

• Characteristics of radiation;

• Units of radiation dose and quantity of radioactivity;

• Hazards of exposure to radiation;

• Methods of controlling radiation dose (time, distance and shielding);

• Proper use of protective equipment (i.e., respiratory protection, donning and doffing of PPE);

• Proper use and care of dosimetry;


• Operating and emergency procedures;

• Handling and proper use of personnel monitoring equipment; and

• ALARA concept.

Personnel shall have successfully completed the radiation worker training requirements within one year of performing duties. This training may be administered in conjunction with site-specific training for temporary job sites.

6.3.3 DOT Training

All hazmat PHDP personnel as defined by 49 CPR 171.8, shall be trained in accordance with DOT regulations as specified in 49 CPR 172 subpart H.

6.3.4 Female Radiation Worker Training

Training of female radiological workers shall include a review of the concepts contained in U.S. NRC Regulatory Guide 8.13.

6.4 Performance Examinations

A comprehensive written examination shall be administered to each active radiation worker. The examination shall demonstrate an understanding of the material discussed during training.

Examinations shall be developed under the direction of the RSO for initial qualification and subsequenfrequalification of PHDP personnel. A certificate will be issued upon successfully passing with a grade of 70 percent or better and maintained in the PHDP personnel file.

After ,the examination has been graded, the instructor will interview the trainee to discuss missed questions.

6.5 Training Records Retention

Records of training shall be maintained in accordance with Section 4.17. Copies of training records applicable to personnel at temporary job sites shall be maintained by the RCS at the job site for the duration of the project.

7.0 PROJECT SECURITY

This section describes the minimum requirements for project security, which shall be implemented by the PM.


7.1 Job Site

A positive physical control against unauthorized access to the job site is the most desirable method of ensuring project security. The use of fences, gates and doors, which can be locked to prevent access by unauthorized personnel, will be acceptable. For tasks conducted inside a building, securely locking all access doors is sufficient project security.

Tasks may be performed in areas that are not easily secured by means of a physical barrier. In these cases, the PM in coordination with MU RSO shall ensure there is constant surveillance at the job site. This may be accomplished with electronic surveillance, alarms, contracted security personnel or a combination of these methods.

7.2 Materials Removed from the Job Site

If the project requires removal of radioactive material from the job site for transfer to another licensee for storage, processing or disposal, those materials may be stored in closed transport vehicles provided the vehicle can be securely locked to prevent unauthorized access and are properly labeled and placarded per DOT regulations as presented in 49 CPR 100 to 180.

7.3 Key Control

Distribution of keys to personnel is the responsibility of MU. Personnel may have keys consistent with the need for access.

7.4 Breach of Security

If it is determined that job site security has been breached, the PM shall immediately conduct a thorough search of the job site and determine if any radioactive material was removed. If there is evidence that unal:lthorized personnel removed radioactive material from the secured area, the PM shall perform the following actions:

• immediately notify the MU RSO who will contact the NRC, in accordance with Section 4.19;

• Attempt to locate and retrieve the missing materfal; and I

• Perform an investigation to determine how access was gained and what corrective actions must be taken to prevent any further unauthorized entry.

8.0 INSTRUMENTS

Instruments for the detection and measurement of radiation, appropriate for the types and levels of radiation on a project, will be made available.

Pickard Hall Decommissioning. Radiation Safety Manual l· 33 of 52

8.1 Instrument Calibration

A vendor specifically licensed by the NRC or an agreement state to provide instrument calibration services shall perform calibration of radiation detection instruments. Each instrument will be calibrated with an appropriate NIST traceable source at least annually, after significant repairs or more frequently if requirements that are more stringent apply.

Instruments that are not calibrated at the specified interval may be utilized for qualitative purposes. However, such instruments shall not be utilized for the quantitative assessment of activity present or the establishment ofradiological controls.

Records of calibration will be maintained in accordance with Section 4.17.

8.2 Field Response Checks

Radiological survey instrumentation shall have the following checks performed on them daily or prior to use. Daily checks are not required for instruments in storage or on stand-by.

• Physical Condition: Consider the general physical condition of the instrument. Look for missing knobs, inoperative switches, punctured windows and/or damaged meter faces;

• Calibration Check:· Verify the instrument has been satisfactorily calibrated within its required calibration cycle;

• Battery Check: Observe the indication for the current battery condition.

• High Voltage Check: If applicable, verify that the high voltage is within the preestablished range or± IO volts of the pre-established setting;

• Source Check: Verify that the instrument will respond accurately to a known source of radiation.

When required by Task Specific Work Plans or Quality Assurance Project Plans, documentation of these checks shall be maintained on Attachment 7 or equivalent.

Any instrument found to respond improperly or exhibit erratic behavior, shall be taken out of service.

8.3 Instrument Selection

Specific instruments that must be available at each task will be determined during the task planning and evaluation phase as specified in Section 4.2. This shall include provisions for ensuring sufficient numbers of instruments are available in the event of instrument failure or for instrument calibration.


9.0 RADIOLOGICAL SURVEY PROGRAM

In order to properly protect workers that handle radioactive material, an assessment of the materials by means of a radiological survey must be performed. Personnel performing surveys for licensed activities are to be trained and knowledgeable in the proper use and operation of instrumentation. Data obtained from surveys will be evaluated to establish controls in conjunction with the RPP.

9.1 General Requirements

This section describes the requirements for radiological surveys that shall be implemented by the RCS.

9.1.1 Radiological Surveys

Surveys shall be conducted that are:

• Necessary to comply with the provisions in 10 CPR 20.1501; and

• As necessary to evaluate:

• The extent of radiation levels;

Concentrations or quantities of radioactive material; and

The potential radiological hazards that may be present.

Table 9-1 provides guidance for meeting the requirements of this section for typical tasks with duration of more than a few days. Surveys shall be documented on appropriate forms found in Attachment 6 or equivalent.

9.1.2 Action Limits

If a survey result indicates an action level has been exceeded, the actions specified in Table 9-1 will be implemented.


Survey Type Location

Personnel Exit Area

Contamination

Exit of restricted area

Equipment/ tools Removable exiting restricted

Contamination area

Shipping packages

containing radioactive

material Equipment / tools exiting restricted

Fixed area

Contamination Facility or

restricted area release for

unrestricted use

Chase Environmental Group, Inc. Radiation Safety Manual Rev. 02

Table 9-1 Radiation Surveys and Action Limits

Frequency Limit Action

Any response above background Notify RCS; Initiate personnel

decontamination

Each occurrence I 0,000 dpm/100 cm2 Notify RCS/PM/RSO; Initiate

I 00 dpm/100 cm2 personnel decontamination; Evaluate need for internal dose assessment

Daily when work is in Isotopic specific limits as listed in

NUREG 1556 Vol 12 Table P.5 or as Notify RCS; Decontaminate the area progress

directed by task-specific work plans

Isotopic specific limits as listed in Notify RCS; Decontaminate, or Each occurrence ANSI/HPS Nl3.12 or as directed by contain and label in accordance with

task-specific work plans Section 4.13 .4

2,400 dpm/100 cm2 Decontaminate and Notify RCS; re-Prior to shipment

240 dpm/100 cm2 survey prior to shipment.

Isotopic specific limits as listed in Notify RCS; Decontaminate, or Each occurrence ANSI/HPS N13.12 or as directed by contain and label in accordance with

task-specific work plans Section 4.13.4

As needed or as Isotopic specific limits as listed in Notify RCS;

Control area in accordance with directed by project- NUREG 1556 Vol 12 Table P.5 or as

Section 4.13, Decontaminate, and specific work plans directed by task-specific work plans

resurvey.

36 of 52

Survev Type Location

Packages containing radioactive

material

Conveyance of

External radioactive

radiation dose material

rates

Within restricted work areas

Boundaries of restricted areas

Chase Environmental Group, Inc. Radiation Safety Manual Rev. 02

Frequencv

Prior to shipment

Prior to departure

Weekly when being accessed

Daily when work is in progress

Limit Action Non-Exclusive use conveyance

200 mrem/hr on contact; or 10 mrem/hr@), I meter (TI=lO)

Exclusive use conveyance Notify RCS; Evaluate Packaging and

1,000 mrem/hr on contact use of shielding.

Exclusive use conveyance 1,000 mrem/hr on contact

2 mrem/hr in cab; or 200 mrem/hr sides, top, or bottom of Notify RCS; Evaluate the need for

conveyance; or shielding, rearrange load, split 10 mrem/hr at 2 meters from side of shipment, etc.

conveyance

5 mrem/hr; or Notify RCS; control area in

100 mrem/hr for radiation area; or 500 rads/hr for high radiation area

accordance with Section 4.13;

Notify RCS; Evaluate cause and 2 mrem/hr initiate corrective actions

immediately.

37 of 52

9.1.3 Documentation of Surveys

All surveys will be documented to include, at a minimum, the following information:

• Project identification;

• Date and time of the survey;

• Person performing the survey;

• Location or item surveyed;

• Instrumentation used, (Model and Serial number);

• Calibration due date;

• Efficiency of instrumentation where applicable; and

• Results of survey (i.e., dose rates, activity in cpm or dpm, etc)

All surveys will be maintained at the job site by the RCS until the project is completed. After completion, records will be maintained by the MU Radiation Safety Office in accordance with Section 4.17.

9.2 Personnel Contamination

When required by R WP or RCT instruction, all personnel shall survey themselves upon exiting a restricted area. If contamination is detected, personnel must remain stationary and notify an RCT. An RCT shall quantify contamination and implement decontamination measures as directed by the RCS. If the contamination on an individual exceeds 10,000 dpm/100 cm2 beta-gamma or 100 dpm/100 cm2 alpha on the face near the nose or mouth, then internal monitoring may be warranted in accordance With section 4.7. The RCS shall investigate the contamination event through a review of survey data, and interviews with the affected individual to determine:

• The cause for the contamination;

• Potential effect on other personnel;

• Potential for spread of contamination outside/inside area;

• Corrective actions if any;

• Appropriateness of PPE; and

• If additional internal monitoring is required.

9.3 Airborne Radioactivity Sampling

Air sampling requirements will be established during the project review as established in Section 4.2.

Chase Environmental Group, Inc. Radiation Safety Manual Rev. 02 38 of 53

9.3.1 Calibration

All airflow or volume metering devices used with air samplers will be calibrated at least annually when in use.

Records of calibration will be maintained in accordance with Section 4.17.

9.3.2 Sampling Locations and Type

At a minimum, air sampling shall be required if potential airborne concentrations may exceed 10% of the most limiting DAC as listed in 10 CFR 20, Appendix B for the radionuclides of concern or combination of radionuclides. Location and type of samples will be commensurate with physical and chemical form of the radionuclide(s) present. For the PHDP, Class W Th-232 is the limiting nuclide for air sampling.

9.3.3 Airborne Radioactivity Action Limits

If the Airborne Radioactivity Action Limits are exceeded, the project RCS shall evaluate the work in progress to determine if actions can be taken which would reduce airborne contamination. Otherwise, personnel may be required to wear respiratory protection. Actions to be taken when levels are exceeded are listed in Table 9-2.

Table 9-2 Airborne Activity Action Limits Limit Action

If air sample results are 2:: 10% of the Evaluate engineering controls for applicable DAC value listed in 10 CFR 20, effectiveness. Initiate dose assessment and

Appendix B or combination thereof. assign dose to exposed individuals. If air sample results are 2:: 30% of the Post and control area as an "Airborne

applicable DAC value listed in 10 CFR 20, Radioactivity Area" in accordance with Appendix B or combination thereof. Section 4.13.2. Evaluate engineering

controls for effectiveness. Initiate dose assessment and assign dose to exposed

individuals. If air sample results are 2:: 100% of the Perform ALARA analysis and upgrade PPE

applicable DAC value listed in 10 CFR 20, if warranted. Evaluate operational activities Appendix B or combination thereof. for changes in methodology or equipment.

Evaluate engineering controls for effectiveness. Initiate dose assessment and

assign dose to exposed individuals.

9.3.4 Documentation of Air Monitoring

All air monitoring will be documented to include of the following:

• A description of the sample location;

• Sample type;


• Sample volume or flow rate;

• Date and time the sample was started and stopped;

• Sampler used-model and serial number;

• Calibration due date;

• Persons monitored for breathing zone samples;

• Analysis results; and

• Person collecting the sample.

All air sample logs will be maintained at the job site by the RCS until the project is complete. After completion, records will be maintained in the MU Radiation Safety Office in accordance with Section 4.17.

9.4 Environmental Sampling

Tasks consisting of environmental sampling and remediation may require soil and/or water samples. Task-specific plans will specify the procedures for collection, packaging and controBing samples from point of collection to analysis. Sample locations will be specified in survey packages.

Records for environmental samples consisting of field logs, chain of custody and/or analysis reports will become part of the PHDP files and maintained in accordance with Section 4.17.

9.5 Receiving and Opening Packages

Radioactive materials shall not be received at the PHDP.

10.0 PACKAGING, STORAGE, AND TRANSPORTATION

As previously discussed in Section 1.0, the PHDP will entail remediation and waste disposal. As such, this will entail the packaging, storage and transportation of radioactive materials at the site. All personnel associated with the packaging and transportation of radioactive material will be trained in accordance with Section 6.3.3 commensurate with their assigned duties. The following sections discuss the precautions to be implemented when providing these services.

10.1 Packaging

Before making a shipment of licensed material, ensure that the package with its contents satisfies the applicable requirements and regulations. Determine the following:


• Verify that the consignee is licensed to receive the shipment of radioactive material and that the material meets the consignee's specific acceptance criteria;

• The package is proper for the contents to be shipped and is in unimpaired physical condition except for superficial defects, such as marks or dents;

• Material is packaged in a manner that the contents will not cause damage to the package and/or container during the handling or transport of the material. During loading, consideration should be taken whether to brace or secure the material to minimize the chance of material movement or breaching the package or container integrity;

• Each closure device of the packaging, including any required gasket, is properly installed and secured and free of defects;

• The package has been loaded and closed m accordance with manufacturer's recommendations or written procedures;

• The level of non-fixed, or removable, radioactive contamination on the external surfaces of each package offered for shipment is ALARA, and within the limits specified by DOT regulations in 49 CFR 173.443 and Section 9.1.2; and

• External radiation levels around the package and around the vehicle, if applicable, shall not exceed the limits specified in 49 CFR 173 .441 and Section 9 .1.2 during transportation.

10.2 Storage

Materials and items packaged, placarded, and labeled incidental to transportation will be stored in a manner to prevent damage to the package and mitigate access from unauthorized personnel.

10.3 Transportation

When required by the regulations, Chase will comply with the conditions set forth in 10 CFR 71 by ensuring that transportation or delivery for transport oflicensed materials on public highways shall:

• Comply with the applicable requirements, appropriate to the mode of transport, of DOT regulations in 49 CFR 170-180; and

• Assure that special instructions needed to open the package safely are made available to the consignee for the consignee's use in accordance with IOCFR71.89.


11.0 EMERGENCY ACTIONS

Emergency actions are actions performed in response to conditions such as spills, fires, and injuries. Actions will be taken to mitigate the release of radioactive material where appropriate. However, at no time will radiological controls take precedence over or impede the response of emergency personnel responding to such conditions. Lifesaving actions will always take precedence. The following sections will provide guidance in responding to such incidents.

11.1 Unplanned Release

Immediate response actions to unplanned releases can be summarized in the acronym "S•W•I•M•S". Each of the letters is discussed below.

Stop the release: Take immediate action to secure the source of leaking radioactive materials; however, do not put your own safety at risk to do so.

Warn others: Communicate the spill to the activity supervisor and client contact. Also, warn others that may enter into an area that a release has occurred so that they may avoid unnecessary exposure.

Isolate the area: As soon as practical, rope the area off and identify boundaries of the release.

Minimize exposure: Apply the concepts of time, distance, and shielding to minimize personnel exposures during initial and supplementary response to the release.

Secure ventilation: Secure ventilation that may cause the spread ofreleased material.

11.1.1 Supplementary Actions for Unplanned Releases

When initial response actions have been completed, supplementary actions are taken to commence restoring the facility to normal conditions. These may include the following actions:

• Perform contamination and radiation surveys to confirm initial boundaries are properly located and posted;

• Survey personnel and equipment near the area during the material release for contamination;

• Collect air samples downwind from the release of material;

• Brief recovery crews on the radiological conditions and hazards anticipated as a result of the release of material; and/or

• Evaluate the incident and make regulatory notifications as required by Section 4.19 and 10 CFR 20.


11.2 Fires and Explosion

The risk of a serious fire event will be kept low by enforcing a rigorous housekeeping ·. campaign during decommissioning. The MU Fire Marshall shall inspect the site on a

periodic basis depending on the site activities. Additionally, hotwork will only be performed when a non-thermal option is not viable. DAW generated during decommissioning will be collected and packaged to limit the volume of DAW available for consumption by fire and to lower the potential for a fire to consume additional waste collections. The MU RSO will include routine fire loading inspections in radiological oversight of decommissioning activities. Chase and their subcontractors will also perform daily housekeeping tasks.

In the event of a fire, MU and Chase policy is to extinguish only the most minor of fires. No PHDP personnel should attempt to extinguish a major fire. If a fire or explosion is imminent or occurs, the nearest fire alarm should be sounded and the area evacuated.

For all fires, immediately notify emergency personnel first, the Chase PM, MU RSO, and MU emergency contact. After proper notifications have been initiated, the following may be instituted if applicable:

• Initiate evacuation by activating building alarm systems if so equipped. Notify other occupants and have them exit the building;

• Fight fire, if properly trained. If trained and the fire is small, fight the fire if this can be done so without putting yourself in danger; and

• Prepare to support fire-fighting personnel when they arrive. Where warranted, issue SRDs or TLDs if time permits and inform responders of radiological conditions.

11.2.1 Supplementary Actions for Fires

When initial response actions have been completed, supplementary actions are taken to support fire-fighting activities and to return to normal conditions after the fire has been brought under control. The following may be instituted:

• Where possible, collect air samples downwind from the fire;

• Perform contamination and radiation surveys to confirm that initial boundaries are properly located. Establish egress areas for personnel exiting the area;

• Survey personnel evacuated from the building and near the area during the fire for contamination;

• Make preparations to survey and decontaminate, as necessary, firefighting personnel and equipment as they exit the area;

• Brief recovery crews on the radiological conditions and hazards anticipated as a result of the release of material; and


• Evaluate the incident and make regulatory notifications as required by Section 4.19 and 10 CPR 20.

11.3 Personnel Injuries and Illnesses

Injuries and illnesses can occur in a wide range of severity from a simple sprain to cardiac arrest. The actions to be taken for each type of injury or illness can vary greatly. MU and Chase's policy directs all personnel to report injuries to their immediate supervisor regardless of the severity.

First aid will be provided by qualified persons as needed. For other than minor physical injuries, the injured person should not be moved prior to stabilization unless the location is immediately life threatening.

In most cases, for injuries that occur in a restricted area, the greater concern is for the physical injury rather than for the radiological hazard. This does not mean that radiological controls should be ignored, but, rather, that the emphasis be placed on treatment of the greater hazard to the injured person. , Exposure control takes precedence only for minor injuries.

11.3.1 First Responders' Actions

Upon discovery of a severe injury or illness, immediately notify Emergency Medical Services (EMS) personnel, (e.g., call 911), the MU emergency contact, and the Chase PM to report the person's location. Utilize PPE such as lab 1coats and gloves to protect against blood borne pathogens.

'no not move any individual, who is unconscious, have a back, neck or head injury, unless there is imminent danger.

11.3.2 Support Actions

After proper notifications have been made and first aid has been rendered, take steps to prepare the individual for transport. Care of the patient takes precedent over radiological controls. Assist EMS personnel but do not delay or interfere with care of ,the injured individual. Prepare to support EMS personnel when they arrive by doing the following:

• Dispatch an RCT with the ambulance to provide guidance on controlling contamination in the ambulance and at the hospital for potentially contaminated patient; and

• The RCT should perform surveys of materials and maintain control of items that may have become contaminated in the process of treating the injured individual.

11.3.3 Post Incident Recovery


When initial response actions have been completed, supplementary actions are taken to return to normal conditions when the emergency is over. These actions may include the following:

• Post incident surveys of adjacent areas and travel paths taken by EMS personnel when;

• Restock first aid supplies if utilized during the incident; and

• Evaluate the incident and make regulatory notifications as required by 10 CPR 20.

11.4 Emergency Response Documentation

Maintain complete records of the incident, actions taken, survey data, exposure monitoring and notifications made. All records will be maintained as follows:

• Incident reports shall be maintained in accordance with Section 4.17;

• Incident reports shall be submitted to the NRC as required by Section 4.19;

• Results of personnel monitoring, radiation surveys, contamination surveys, airborne activity surveys, and R WPs generated in response to a release of radioactive material shall be maintained in accordance with Section 4.l 7; and

• Results of personnel monitoring shall be maintained in accordance with Section 4.17.

12.0 REFERENCES

• 10 CPR 20, "Standards for Protect.ion Against Radiation"

• 10 CPR 19, "Notices, Reports and Instructions to personnel"

• 10 CPR 20 Appendix B U.S. Nuclear Regulatory Commission "Annual Limits on Intake and Derived Air Concentrations of Radionuclides for Occupational Exposure; Effluent Concentrations; Concentrations for Release to Sewerage"

• 10 CPR 71 U.S. Nuclear Regulatory Commission "Packaging and Transportation of Radioactive Material"

• 29 CPR 1910.134, Occupational Safety and Health Administration "Occupational Safety and Health Standards, Respiratory Protection"

• 49 CPR 100-189, U.S. Department of Transportation, "Transportation"

• American National Standards Institute ANSI/HPS N13.12-2013, "Surface and Volume Radioactivity Standards for Clearance"

• NUREG 1556 Volume 12, "Consolidated Guidance about Materials Licenses, Program-Specific Guidance About Possession Licenses for Manufacturing and Distribution"

• NUREG 1556 Volume 18, "Consolidated Guidance about Materials Licenses, Program-Specific Guidance About Service Provider Licenses"


• NUREG-1736, "Consolidated Guidance: 10 CFR 20 - Standards For Protection Against Radiation"

• Regulatory Guide, 1.86, "Termination of Operating Licenses for Nuclear Reactors"

• Regulatory Guide, 8.13, "Instructions Concerning Prenatal Radiation Exposure"

• Regulatory Guide, 8.21, "Heath Physics Surveys For Byproduct Material At NRCLicensed Processing and Manufacturing Plants"


Attachment 1: Task Planning Form

Task Name: ------------------------------Chase PM Name/Phone: --------------- L) ___ _

MU Contact Name/Phone: ------------After Hours/Emergency Contact:------------

Brief Description, (Scope of work, equipment):------------------

Start Date: _________ Duration: ------------------

Is the area/site capable of being secured? YES NO

IfNO, what method will be used to maintain after-hours security? Refer to Section 0

Personnel Assigned:

POSITION NAME CURRENT YEAR DOSE

Project Manager

Project RCS

Radiation Workers

Use additional sheets as necessary.

A-1 Page 1 of 6

TASK PLANNING FORM (continued)

Are subcontractors to be used?

If yes;

YES NO

Subcontractor Name: ___________________________ _

Phone number: _____________ _ Number of People: ______ _

Type of Work: ___________________________ _

Are contractor personnel to be escorted?

Training: Are assigned personnel trained in accordance with Section 6.0 commensurate with their duties? Does the PM have copies of training certificates for assigned personnel?

YES

YES YES

Date, time, and location training will be conducted for contractor personnel:

NO

NO NO

Person assigned to conduct training: ______________________ _

Task Radiological Conditions:

Expected loose surface contamination levels: __________________ _

Expected total activity concentration: ----------------------

Expected radiation levels: _________________________ _

Expected airborne activity: -------------------------

What DAC Value and ALI apply?---------------------

Will operations cause a condition where it is likely that personnel may inhale > I 0% of an ALI?

Explain:---------------------------------

Is air sampling required? YES NO_Explain: ---------------

IfYES, what parameters will be monitored? Particulate-_

BZ General Area Perimeter

A-1

Tritium

Other

Radon

---------

Page 2 of 6


Respiratory Protection:

Is respiratory protection required?

If YES, list type of respirator and cartridges needed:

Is respiratory protection tight fitting face-piece?

If yes, answer the following:

Have assigned personnel and subcontractors been medically cleared?

Have assigned personnel been trained on wearing respirators?

Have assigned personnel been fit-tested for the type of

respirator to be used?

YES NO

YES NO

YES NO

YES NO

YES NO

Does the PM have copies of records for medical clearance, fit test, and training? YES NO

Instrumentation:

Required radiation detection equipment:

MINIMUM# INSTRUMENT

Are instrument check sources available? YES NO

A-1 Page 3 of 6


Dosimetry required:

Whole body__ Extremity __

Internal Monitoring:

Required?

SRD __ _ None ---

YES NO

If yes, list requirements:--------------------------

Dose Estimate:

TASK DOSE

TOTAL --------

Waste Disposal:

Processing or disposal facility to be used:

Transporter to be used:

Name: --------------------------------Contact: Phone #: ------------------ -------------

Containers needed (number and type):---------------------

Labels required: ____________________________ _

A-1 Page 4 of 6


Boundary controls:

What signs and postings are needed?

Stanchions and barriers available:

PPE needed:

Coveralls ---

Tyveks __ _

Hard Hats ---

Shoe Covers

Gloves ----

EarPlugs __

YES

Wet Suits Lab Coats ---

Gloves Hoods ----

Safety Glasses__ Other __ _

NO

Specify: ----------------------------

Comments:

Prepared by: Reviewed by:

Project Manager ____________ _ MURSO ----------Date: ________ _ Date: ________ _

A-1 Page 5 of 6

Attachment 2: Dosimetry Issuance Form Personal Data

Last Name First Name Middle Initial Sex:M F

Date of Birth Company Position/Title SSNorDLN

Phone Email

Mailing Address:

C urren tY ear E xposure ff t IS Ory

Check here if you have not been issued a dosimeter this year.

Name/Address where a dosimeter was issued Date From: Date To: Dose: Estimate if no records are available

By my signature below, I certify that the information provided above is true and accurate to the best of knowledge. Furthermore,, I hereby grant Chase Environmental Group, Inc. the authority to request my occupational exposure history and any information associated with such request from the companies listed above. (Use additional sheets as necessarv and attach to this form.)

Date:

To be filled out b Chase Re Original Badge Data as printed

on Label

Pin# Issue Date

PIN#----

Signature:

resentative Whole Body/

Extremity WB/RF/LF

Project#

A-3

Worker/ Visitor W/V

PIN#

Training Verified

Issued By:

Page 1 of 1

Attachment 3: RWP Log

Project#: Project Name:

RWP Date Date Number Task Comments Initiated Terminated

--

A-4 Page 1 of 1

0 General O Job Specific Job Location Job Descriotion

Radiation QN!A

Max Contact

Max30cm

General Area

RCT Coverage 0 Continuous

0 Intermittent

0 Start ofJob

Air Sampling

0 GA Air Sample

0 BZ Air Sample

0 Not Applicable

Radiation ()NIA

Max Contact

Max30cm

General Area

) Additional Pages Attached

Prepared

Authorized

Terminated

Attachment 4: RWP Form

Radiological Work Permit RWP#

Start Date End Date

Radiological Conditions Removable Contamination Airborne Radioactivity

QN!A ON/A

dpm a I I 00cm2 %aDAC

dpm f3y I I 00cm2 %pyDAC

Controls Protective Equipment Dosimetry Exit Monitoring

QGloves 0 Not Applicable 0 Frisk Hands and Feet Type:

QTLD

0 Shoe Covers QExtremity 0 Frisk Whole Body

0Labcoat QSRPD 0 RCT Assistance

0 Coveralls QEAD QOther Type: Dose Alarm

0 Respirator Dose Rate Alarm -- 0 Not Applicable

'!ype:

0 Other 0 Ion Chamber

Limiting Conditions Removable Contamination Airborne Radioactivity

()NIA ON/A

dpm a I I 00cm2 %aDAC

dpm py / I00cm2 %PyDAC

Special Instructions

,. I

Namefl'itle Signature Date

Page 1 of __

Radiological Work Permit RWP#

A-5 Page 1 of 2

Special Instructions - Continued

Page __ of __

A-5 Page 2 of 2

Attachment 5: RWP Sign In Sheet

RWP#: Job Location: Bv mv sirmature below I state that I have read, understand, and will comvlv with all reauirements svecified in the RWP.

NAME Time In Time Out Time In Time Out Time In Time Out Time In Time Out Time In Time Out SRD Serial#

DATE Dose In Dose Out Dose In Dose Out Dose In Dose Out Dose In Dose Out Dose In Dose Out BZAS Serial#

SIGNATURE Flow In Flow Out Flow In Flow Out Flow In Flow Out Flow In Flow Out Flow In Flow Out Air Sample#

Respirator Type Respirator Type Respirator Type Respirator Type Resoirator Tyne AS Run Time


DATE Dose In Dose Out Dose In Dose Out Dose In Dose Out Dose In Dose Out Dose In Dose Out BZAS Serial #


Respirator Type Respirator Type Respirator Type Respirator Type Respirator Type AS Run Time


DATE Dose In Dose Out Dose In Dose Out Dose In Dose Out Dose In Dose Out Dose In Dose Out BZAS Serial#


Respirator Type Respirator Type Resoirator Type Respirator Type Respirator Type AS Run Time


DATE Dose In Dose Out Dose In Dose Out Dose In Dose Out Dose In Dose Out Dose In Dose Out BZAS Serial #


Respirator Type Respirator Type Respirator Type Respirator Type Respirator Type AS Run Time

A-6 Page 1 of 1

Attach t 6: S F Project: Area: Survey No: Date:

Time:

Instrument/ Serial Number Cal Due.

Alpha/ Bkgd Source Efficiency

MDC Surveyor:

Detector/ Serial Number Beta cpm Check (dpm) Surveyor:

Signature:

Reviewed:

Signature: ..

Item Total or Gross -..Net Net Item Total or Gross Net Net Number Removable Counts CPM DPM Remarks Number Removable Counts CPM DPM Remarks

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

A-8 Page 1 of 5

I Project I A~, I S=eyNoc ID~~ Time: I I

Item Total or Gross Net Net Item Total or Gross Net Net Number Removable Counts CPM DPM Remarks Number Removable Counts CPM DPM Remarks

19 19

20 20

21 21

22 22

23 23

24 24

25 25

26 26

27 27

28 28

29 29

30 30

31 31

32 32

33 33

34 34

35 35

36 36

37 - -·- 37

38 38

39 39

40 40

A-8 Page 2 of 5

s s· t F

Scan Survey Signature Form Location: Area: Survey No: I Date: I

J Time: I Surveyor Name Surveyor Signature

1 I

2 2

3 3

4 4

5 5

6 6

7 7

8 8

9 9

10 10

d' Detector

Instrument/ Serial No. Detector I Serial No. background from Observation

MDCR Efficiency Correction Scan MDC

(cpm) Table Interval (dpm/100 cm2)

6.5 Factor

1

2

3

4

5

6

7

8

9

10

Comments:

A-8 Page 3 of 5

Chase Environmental Group, Inc. Survey Map

Project Name/No: Survey Number:

Survey Unit:

Instrument: I Serial Number: Probe: I Serial Number: I Cal. Due: Instrument: I Serial Number: I Probe: I Serial Number: I Cal. Due:

I I I I I I I I Technician: I Technician: II Date/Time:

I : Reviewed B~: Date:

Symbols Boundary Designation

® = Smea:r Location # = General Area Dose Rate RM = Radioactive M aterial(s) Area RA = Radiation Area

~ = La:rge Area Wipe (SOP! = Step Off Pad RCA = Radiological Controlled Area HRA = High Radiation Area --~ """-- --

JL = Contact Dose Rate • Air Sample Location CA ~- Contamination Area VHRA • Grave Danger Very High Radiation Are,.

# = 30 cm Dose Rate HS* Hot Spot HCA = High Contamination Are a ARA = Airborne Radioactivity Area

All Dose rates a:re inmR.lhrGamma unless otherwise noted on the survey map above"

A-8 Page 4 of 5

Survey Map (Portrait)

Chase Environmental Group, Inc. Survey Map

Project Name/No: IDate/Time: !survey Number:

Survey Unit: Instrument: Serial Number: Probe: Serial Number: Cal. Due: Technician:

Instrument: Serial Number: Probe: Serial Number: Cal. Due: Technician:

Reviewed By: Date:

I

' \

I

Symbols Bound1uy Design,tion

® ""Smev Location # • General Are• Do,e R•tr RM • Radio•ctive M,temil(s) Are• RA • R,di.tion Area

@-,'vi) • Large Are• Wipe jsoPj •SupOtfPad RCA • R•dio!ogical Cont.rolled Area HRA • HighR•di,tionA,ea

! • ContactD,,se Rat• /:) = AirSampi, Location CA

1

. Conto,ninationA,ea VHRA • Gr,w D ong,r Very High Radi<llion Area ~

# • 30 tmDo,e Rat, HS* Hot Spot HCA Contamination Area ARA • Airborne Radioacti,~ty Art•

AU Dose rates are in mR/hr Gamm~ unless othetWise noted on the swvey map above,

A-8 Page 5 of 6

Survey Log

Project Name: Project#:

Survey Log

Survey#: Date: Comment:

A-8 Page 6 of 6

Project Name/#:

Instrument/#:

Probe Type/#:

D Efficiency:

D Efficiency:

High Voltage:

Cal. Due:

Attachment 7: Instrument Forms Contamination Instrument Set-up Form

Date/Time:

Technician:

Source Type:

____________ Activity:

Source ID:

Probe Area: ------------

Record ten I-minute bkgd counts for both D and D:

Record ten I-minute gross source counts for both D and D:

2

3

4

5

6

7

8

9

10

D

D

D

D D

1

2

3

4

5

6

7

8

9

10

Calculate the average bkgd count:

D

Calculate bkgd range(+/- 20%):

to

to

Calculate the MDC:

D dpm/100cm2

D dpm/100cm2

D D

1

2 2

3 3

4 4

5 5

6 6

7 7

8 8

9 9

10 10

Calculate average source count:

D D

Calculate source count range(+/- 20%):

D to

D to

Note: Mark NI A in blanks as appropriate for instrument configuration.

Reviewed By: Date:

A-9 Page 1 of 4

Contamination Instrument Daily Response Form Source

Project Name/#:

Instrument/#:

Probe Type/#:

High Voltage: D D D D D D D DD D Background range (+/- 20%):

to DD DD DD DD D Background range ( +/-20%):

to

HV +/-10 DBKG DBKG

Date Time volts Count Count

D Gross Source Count

;

Type:

Activity:

Source ID:

Cal. Due: DD DD DD DD DD DSource count range (+/-20%):

to

DD DD DD D Source count range(+/- 20%):

to

D Gross Batt. Inst. Source Count SIU SIU Technician

Note: Mark NIA in blanks as appropriate for instrument configuration.

Reviewed By: _______________ Date: ________ _

A-9 Page 2 of 4

Rate Instrument Set-Up and Daily Response Form

Project Name/#: Source Type: Date/Time:

Instrument/#: Activity: Technician:

Probe Type/#: Source ID: Units:

High Voltage: Background: BKG+/-20% TO

Cal. Due: Scale 1 Scale 2 Scale 3 Scale 4 Scale 5

Source Gross: Source Range

+/- 20% TO TO TO TO TO Geometry: (OW,CW,

DISTANCE)

RESPONSE TEST

Cal. HV BATT Inst. Date Time Due SIU SIU BKG Scale 1 Scale 2 Scale 3 Scale 4 Scale 5 SIU Technician

Note: Mark NIA in blanks as appropriate for instrument configuration.

Reviewed By: ________________ Date: ________ _

A-9 Page 3 of 4

Instrument Accountabilitv Loe: Instrument/ Reason (Task Name, OOS, Responsible Date Date

Detector Serial Number Cal. Due OOC) Person Out Returned -

-

A-9 Page 4 of 4

Date Date Serial# Nuclide Activity Task/Reason out Siena tu re Returned

A-10 Page 1 of 1

[ Task#: Attachment 9: Air Sample Log I TaskName:

Sample# Date Area Type

RCT a Result f3/y Result a Recount f3/y Recount <BZor GA)

Page~~of~~

A-11 Page 1 of 1

Attachment 10: Air Sample DAC-Hour Tracking Form

Task#: J Task Name:

Employee Name:

TOTAL TIME IN AIR SAMPLE DAC DAC-HOURS RWP# DATE - ---

AREA CONCENTRATION

TOTAL DAC HOURS THIS PAGE

Page __ of __

A-12 Page 1 of 1

Attachment 11: Visitor Orientation Form Visitor Orientation Form

Signing this form indicates that I have been briefed on entry requirements, hazards present, posting and labeling identification, areas that I may enter, escort requirements, and will comply with all written and verbal instructions from site personnel (required for female contractors or visitors) Review of Regulatory Guide 8.13 "Instructions Concerning Prenatal Radiation Exposure." I have had an opportunity to ask questions and any questions have been answered to my satisfaction.

Date Print Name Signature

A-14 Page 1 of 1

Attachment 12: Training and Safety Brief Attendance

Trainin2 and Safet v Brief Attendance

Task: Date:

Sub_ject: Instructor:

Personnel Attending

Print Name Signature

A-15 Page 1 of 1

Attachment 13: Respirator Selection and Qualitative Fit Test Employee Date

Respirator Model Size

Responds to Irritant Smoke QPass QFail Normal Breathing QPass QFail Deep Breathing QPass QFail Turning Head Side to Side QPass QFail Nodding Head Up and Down QPass QFail Talking QPass QFail Bending QPass QFail Normal Breathing QPass QFail

Employee Signature Date

Technician Signature Date

Rainbow Passage:

"When the sunlight strikes raindrops in the air, they act like a prism and form a rainbow. The rainbow is a division of white light into many beautiful colors. These take the shape of a long round arch, with its path high above, and its two ends apparently beyond the horizon. There is, according to legend, a boiling pot of gold at one end. People look, but no one ever finds it. When a man looks for something beyond reach, his friends say he is looking for the pot of gold at the end of the rainbow."

A-16 Page 1 of 1

Attachment 14: Pregnancy Declaration & Instructions

Section 1- Voluntary Pregnancy Statement

With this notice I, inform you that I am pregnant or trying to become pregnant with an estimated conception date of ____ and an expected delivery date of ___ _

Section 2 - Instruction to Employee Oral and written information about prenatal occupational radiation exposure has been provided to the individual declaring pregnancy at this time. This information includes:

1) The risk associated with prenatal radiation exposure and methods available for minimizing risk.

2) A review of previous personnel monitoring results for the individual, if available.

3) The fetal dose limit of 0.5 rem during the gestation period for occupationally exposed declared pregnant workers.

4) The fetal dose limit of 0.05 rem for the remainder of the gestation period if the limit of 0.5 rem has already been reached or exceeded at time of declaration.

5) The U.S. NRC Regulatory Guide 8.13 "Instructions Concerning Prenatal Radiation Exposure."

Section 3 - Dose Evaluation The estimated dose to the fetus/embryo is as of this date: . The estimation is based on available dose records, interviews with the individual, and available survey data.

Section 4 - Acknowledgments I acknowledge that the above information relating to occupational exposure to radiation has been discussed and an opportunity to ask questions and receive answers concerning the information was available.

Declarer: Date: ------------------ ---------Signature oflndividual Declaring Pregnancy

Radiation Safety Representative: _________ Date:

A-18 Page 1of 1

Appendix C: Pickard Hall Decommissioning Schedule

ID nrask Name fouration Start I 1st Half ! 2nd Half I

rl tr 2 tr 3 Qtr...1 Pickard Hall Characterization 205 days Fri 3/1/19

Characterization Planning 40 days Fri 3/1/19

I~ Develop Survey Packages 40 days Fri 311/19 , ___ ,

4 Characterize Building 135 days Fri 4/26/19 5 . ACM Abatement 40 days Fri 4'26119

---· 6 Demo Wall and Floor Coverings 70 days Fri6121/19

Vacuum/Clean 5days Fri9f27/19

8 Surface Survey 5days Fri 10/4/19

--. 9 Surface Basement Floor 5days Fri 10/11/19 --· 10 . Locate/ Excavate Drain Lines 5days Fri 10/18/19

11 Coring/Soil Sampling Under Building Sdays Fri 10/25119

12 Characterize Grounds 15 days Fri 5/17/19 ---:

13 Gamma Scans Sdays Fri 5117119

- 1-4 ~. Geoprobe Soll Sampling 10 days Fri 5124/19 --· Characterization Report 30 days Fri 11/1/19 Characterization Report 30 days Fri 11/1/19

Task Project Summary 1---i Manual Task Start-on ly [ Deadline + Project: PHDP Schedule Split " " '' ' ' '""""""' ' ' ' ' Inactive Task Duration-only Finish-only ] Progress

Date: Thu 3/22/18 Milestone • Inactive Milestone Manual Summary Rollup External Tasks - - Manual Progress

Summary Inactive Summary Manual Summary External Milestone 0

~

] Q)

ij ~ .s

I .s .e: 1 ()

~ ~

! "' !

ORIGIN ID:COUA (573) 882-7018 CRYSTAL THOMA ENVIRONMENTAL HEALTH SAFETY 900 E STADIUM BLVD UNIV OF MO • EHS UNIVERSITY OF MISSOU, MO 65211 UNITED STATES US

ro MIKE LAFRANZO

SHIP DATE: 22MAR18 ACTWGT: CAD: 112157492/INET3980

BILL SENDER

US NUCLEAR REGULA TORY COMMISSION 2443 WARRENVILLE ROAD, SUITE 210

LISLE IL 60532 \~~O) 829-9865 REF LETIER TO NRG

PO: DEPT:

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~

Ill llllllllllllllllllll Ill I I Ill Ill II II IIII I I II Ill Ill II IIII Ill llll I II I IIIIIIIII IIII I Ill II II 1111111111111111

~::~~- ra,·. TRK# 102011 7718 1119 1384

SH ENLA

-.4c

TUE · 27 MAR 4:30P EXPRESS SAVER

ASR

60532 IL-US ORD

RECEIVED MAR 2 7 2018

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