General Employee Training Radiation Worker Training/Retraining

Welcome to Progress Energy; Brunswick, Harris, Robinson and Crystal River-3. This study guide contains the Radiation Worker Student Study Guide. Students will be held accountable for this information and successful completion of an examination (initial/requalification) will be required before an individual can be granted unescorted access to the Radiation Control Area of our nuclear facilities.

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Atomic Structure and Radiation Sources Section I Terminal Objective Fitness-For-Duty and Plant Access Training are prerequisites for this Radiation Worker Training. At the completion of this lesson individuals should be able to use sound radiological practices to minimize dose, and understand the risks associated with working in a radiation field. Students will be able to work within an RCA with minimal risk of becoming contaminated or spreading contamination. This lesson is presented in modules; the enabling objectives are listed at the beginning of each module. Enabling Objectives AS-01 Describe the structure of an atom including the three primary components. AS-02 Describe how radiation results from the nuclear process. AS-03 List potential sources of radiation in the plant. Atomic Structure (AS-01) As we learned in Plant Access Training, all matter in the universe is composed of atoms. Atoms are composed of three smaller subatomic particles; protons, neutrons, and electrons. Neutrons and protons form the nucleus (center) of an atom. These two components are approximately the same size. They differ in that protons have a positive electrical charge and neutrons have no electrical charge. The number of protons determines what the element is, for

example, oxygen or iron.

Surrounding the nucleus is a cloud of electrons. The number of electrons generally depends upon the element. Normally, the number of electrons will be equal to the number of protons in the atom. The electron has a negative electrical charge. Radiation Process (AS-02) Radioactive material may be defined as any material that emits radiation as it decays. When an atom has too much energy, it becomes unstable. Since atoms "like" to be stable, they will emit packets of energy or particles from the nucleus to retain their stability. This excess energy emitted from the unstable atom is called IONIZING RADIATION. The reactor of a nuclear power plant creates unstable atoms by forcing a stable atom to accept a neutron, thereby increasing the energy level of that atom. Energy in the form of ionizing radiation may also be created when a larger atom is fissioned into two or more smaller atoms. Ionizing radiation produces electrically charged particles in material it passes through. These charged particles are called ions. In people and animals, ions can cause chemical changes that can be biologically harmful. Sources of Radiation (AS-03) There are many potential sources of radiation inside a nuclear plant. Just a few examples include: water that has been in the reactor (reactor coolant/moderator). corrosion products that have passed through the reactor and been deposited in plant equipment (cobalt, iron). reactor fuel (enriched uranium). reactor operations (the fission process that causes neutron radiation).

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contaminated plant equipment (filters, pipes, valves).

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Types and Measurement of Radiation Enabling Objectives TMR-01 State the four types of radiation found in a commercial nuclear power plant. TMR-02 Characterize the four types of radiation by the following: penetrating ability methods of shielding exposure hazard potential sources TMR-03 Define total effective dose equivalent (TEDE). TMR-04 Define dose rate. TMR-05 Perform conversions between rem and millirem.

Section II

Types of Radiation (TMR-01, 02) In a commercial nuclear power plant, there are four types of ionizing radiation Alpha: contains two protons and two neutrons. has a plus two electrical charge. has the least penetrating power--travels a short distance in the air (1-2 inches). originates primarily from reactor fuel. can be shielded by a piece of paper, the outer layer of skin, or by clothing. is primarily an internal hazard. can result in a high dose to a sensitive organ. attracts two electrons and becomes a helium atom when its energy is expended. Beta: originates from the nucleus of an atom. has more penetrating power than alpha, but is usually limited to a few feet. is primarily found in steam and water leaks from contaminated piping systems. can be shielded by a few layers of plastic or lightweight metal (aluminum foil). is primarily a hazard to the eyes and skin. must be in close proximity to the worker for much exposure to be received. Neutron: is a part of the atomic nucleus which has been freed by decay or fission. has no electrical charge. is very penetrating and can travel a great distance. is found during nuclear fission (in the reactor core at power) is best shielded by water and concrete. is mainly a problem when personnel enter the containment/drywell when the reactor is operating. Because it has high-penetrating capabilities, it gives a whole-body dose. Gamma: has no mass or electrical charge; it is pure energy. is a very penetrating form of radiation; it gives a whole body dose. is found in fission products and steam and water leaks from primary piping systems. is responsible for the majority of occupational dose received at a nuclear plant. is best shielded by very dense material; usually lead, steel, concrete, and water.

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TEDE (TMR-03) The total amount of radiation dose you receive is called the Total Effective Dose Equivalent (TEDE). It is determined by adding the external dose (Deep Dose Equivalent) to the internal dose (Committed Effective Dose Equivalent). Your TEDE is expressed in units of rem or mrem, which is a measurement used to relate radiation dose to biological effects. Dose Rate (TMR-04) DOSE is defined as the amount of radiation absorbed by the body or a particular organ relative to its biological effect. DOSE RATE is the amount of dose received in a specific period of time. Dose rate is usually given in units of mrem per hour (mrem/hr). Dose is determined by multiplying the dose rate and the time of exposure.
EXAMPLE If you spend 4 hours in an area with 5 mrem/hr, your total dose would be 20 mrem. 4 hours x 5 mrem/hr = 20 mrem

Converting rem and millirem (TMR-05) Since the amount of dose received is frequently in very small fractions of rem, the prefix milli, meaning 1/1000, is used for the purpose of measurement.
NOTE To convert from rem to millirem (mrem), multiply the number of rem by 1000 or MOVE THE DECIMAL POINT THREE PLACES TO THE RIGHT. 1.5 rem X 1000 = 1500 mrem To convert from mrem to rem, divide by 1000 or MOVE THE DECIMAL POINT THREE PLACES TO THE LEFT. 1500 mrem 1000 = 1.5 rem

At very high doses received at high dose rates, units of absorbed dose (rads) are appropriate, rather than units of dose equivalent (rem).

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Biological Effects Section III Enabling Objectives BE-01 State the effects of radiation on human cells. BE-02 Define chronic and acute radiation exposure. BE-03 Define genetic, teratogenic, and somatic and compare the effects of radiation exposure. BE-04 Compare radiosensitivity and age. BE-05 State the purpose of NRC Form-4. Radiation Effects on Human Cells (BE-01) The human body is composed of millions of cells that, through natural processes, are continually dying and being replaced by new cells. Excessive exposure to radiation may cause permanent damage or destruction of these cells. Radiation causes cell damage by ionizing atoms and molecules in the cell, thus disrupting normal cellular chemistry, and by damaging chromosomes in the cell nucleus, thus impairing the cell reproductive process. Four things MAY happen when cells are exposed to excessive amounts of ionizing radiation: No change occurs Cell damage Cell mutation Cell death Generally speaking, RADIOSENSITIVITY (how sensitive a cell is to radiation) increases as the cells division rate and metabolism rate increases, therefore: infants are more sensitive to radiation than adults. blood-forming cells are more sensitive than bone cells. Radiation exposure, both internal and external, can cause adverse effects on the body. The effect on the body varies depending on the: area or organ of the body exposed to radiation. type of radiation exposure. the length and amount of exposure. Types of Exposure (BE-02) A small dose received over a long period of time is called CHRONIC exposure. Scientific studies show that there may be an increased risk of cancer from chronic exposure to low levels of radiation. A member of the general public receives about 360 mrem/year of chronic background radiation, depending on geographical location and other contributing factors. A large dose received in a short period of time, usually less than 24 hours, is called an ACUTE exposure. Receiving 25 mrem in a one hour period would not be considered an acute dose, however receiving 25 rem in a one hour period would be an acute dose.

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The following chart shows the PROBABLE effects of acute radiation exposures.
Acute Dose (Rem) >1-25 25-100 100-200 200-600 Probable Clinical Effect Based on exposure to the entire body, exposure to the entire population, and no medical treatment (Adapted from S. Gladstone, Sourcebook on Atomic Energy) No observable effects. Slight blood changes, no observable effects. Vomiting may occur in 5%-50% within 3 hours, with fatigue and loss of appetite. Moderate blood changes are likely. Except for the blood-forming system, recovery will occur in essentially all cases within a few weeks. Vomiting, fatigue, loss of appetite occur in 50%-100% within 3 hours. For doses over 300 rem, these effects will appear in all cases within 2 hours. Loss of hair after 2 weeks. Other effects include severe blood changes, hemorrhaging and infection. Death occurs in 50-80% within 2 months. For survivors, recovery period is one month to a year. Vomiting within 1 hour. Severe blood changes, hemorrhaging, infection, and loss of hair. Death occurs in >80% within 2 months. Survivors convalesce over a long period of time.

> 600

Source: S. Glasstone, Sourcebook on Atomic Energy

Biological Effects (BE-03) GENETIC effects cause damage to cells and may appear as birth defects in the offspring of an exposed individual. Studies indicate that the risk of radiation induced genetic effects is very small. TERATOGENIC effects may be observed in children who were exposed to radiation during the embryonic stages of development. These effects may slightly increase the chances of death, structural abnormalities, abnormal growth, and mental retardation. SOMATIC effects are the direct biological effects that will occur in the exposed individual. There are two classifications of somatic effects; prompt and delayed. Prompt effects may occur immediately following the exposure or up to several months following the exposure. Prompt effects are generally the result of a large acute exposure. Examples of prompt effects are radiation illness and blood changes. Delayed effects do not occur until months or years following an exposure. This delay in time creates a problem in linking the exposure with the effects which may have been caused by many influences other than the radiation exposure. Thus, there can be no positive assignment of the cause in most cases. Delayed effects may result from acute or chronic exposure. Some of the known delayed effects of radiation are cancer and cataracts. Effects of Age (BE-04) As previously discussed, the faster the cell-reproduction rate, the more sensitive the body or organ is to ionizing radiation. As a person ages, most cell reproduction rates decrease. Therefore, as an individual ages, he/she becomes less sensitive to radiation.

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NRC Form-4 (BE-05) Dose received at another nuclear facility must be recorded and included in the accumulated dose for the individual and applied toward the exposure limit. A special form documents all previous occupational exposures. This form is NRC Form-4. BEFORE A WORKER IS ALLOWED TO RECEIVE A DOSE >500 mrem, AN NRC FORM-4 (OR PLANT EQUIVALENT) FORM MUST BE COMPLETED. It is your responsibility to ensure all exposure is reported to the company prior to starting work in the plant. This is also true if a company employee visits another nuclear facility. This form is also used to document your dose history.

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Limits and Guidelines Section IV Enabling Objectives LG-01 State the federal radiation dose limits for total effective dose equivalent (TEDE), skin, extremities, and lens of the eye. LG-02 State the possible consequences if any federal radiation dose limit is exceeded. LG-03 State the Progress Energy limit for TEDE. LG-04 State the action to be taken if the Company TEDE limit is being approached. LG-05 State the federal limit for a declared pregnant worker. LG-06 State the rights of a declared pregnant worker. LG-07 Recognize the definition of a planned special exposure. Federal Dose Limits (LG-01) Radiation dose limits are set by the United States Nuclear Regulatory Commission (USNRC). These legal limits are based on the present understanding of the biological effects of radiation and are set low enough to prevent prompt effects, to minimize delayed effects, and to ensure that risk due to radiation exposures are comparable with other industrial risks. Since the effects of radiation vary depending upon the area of the body that is exposed, the NRC has divided the body into different categories. Title 10, Code of Federal Regulations, Part 20, (10CFR20) states that no licensee shall allow any individual to receive a total occupational dose in excess of the standards specified in the following table:
Area of Concern TEDE (whole body-head/trunk; active blood forming organs; gonads) Lens of the eye Skin of whole body regions Extremities (hands and forearms; feet and ankles) Internal organs Declared Pregnant Woman Rem per Year 5 15 50 50 50 0.5 (500 mrem for duration of pregnancy)

Federal regulations also state that the TEDE to individual members of the public from licensed operation shall not exceed 100 mrem/year, exclusive of background, medical, administered radioactive material from voluntary participation in medical research programs, or from the licensees disposal of radioactive material into sanitary sewerage. Exceeding the Limits (LG-02) If any of the federal limits are exceeded, there could be an increase in the risk of health effects. Additionally, plant management will evaluate the incident and report it to the NRC. This could lead to disciplinary action by Progress Energy and the NRC may choose to fine or take other actions against the Company. Remember that it is each workers responsibility to keep his/her radiation exposure as low as reasonably achievable. Administrative Limits (LG-03) Progress Energy has established an administrative limit to provide an added measure of radiation protection. This will minimize the potential for a worker to exceed the federal limits.

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Total dose allowed at a Progress Energy nuclear facility Total dose if the worker has received occupational exposure from other sources

2 rem/year TEDE 4 rem/year TEDE (2 rem Progress Energy + 2 rem other occupational sources)

Approaching the Administrative Limits (LG-04) If a Progress Energy administrative limit is being approached, NOTIFY YOUR SUPERVISOR. It is possible to increase your allowed administrative dose, but only if authorization is obtained prior to exceeding the limit. DPW Exposure Limit (LG-05, 06) As discussed in Plant Access Training, a pregnant employee should understand the potential effects of radiation on an embryo/fetus, including those produced by ionizing radiation. Both NRC Reg Guide 8.13 and 10CFR20.1208 contain an exposure limit of 500 mrem DURING THE TERM OF THE PREGNANCY. Pregnant occupationally exposed employees who choose to limit their exposure must submit written declaration of pregnancy (no medical proof is required), including the estimated date of conception/conclusion, to RADIATION CONTROL SUPERVISION. This request is voluntary and remains in effect until the declared pregnant woman withdraws the declaration in writing or is no longer pregnant. Once this request is received, the company will make every effort to provide work that will minimize the amount of dose received and spread the dose that is received evenly throughout the pregnancy. In order to meet this limitation, alternate work assignments may be given. A declared pregnant worker will not be allowed to exceed the 500 mrem limit. Planned Special Exposure (LG-07) A planned special exposure is an infrequent exposure to a high dose of radiation. Use of a planned special exposure is a serious undertaking that can result in exceeding the federal limits. It is not anticipated that this type of exposure will be used, but in the unlikely event that it is there are several requirements that must be met, including senior management approval.

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ALARA Enabling Objectives AL-01 State the purpose of ALARA (As Low As Reasonably Achievable). AL-02 Describe the ALARA program. AL-03 Explain the concept of time, distance, and shielding. AL-04 State individual responsibilities regarding temporary shielding. AL-05 Calculate stay time given a dose rate, current exposure, and an exposure limit.

Section V

Purpose (AL-01) ALARA is an acronym meaning As Low As Reasonably Achievable. The purpose of ALARA is to keep individual and collective dose as low as reasonably achievable and still maintain plant operation. This includes internal as well as external dose. Some projects, particularly during outages may include an ALARA Evaluation, also known as an ALARA work plan. This will include detailed information concerning expected exposures, contamination levels, and job planning. ALARA Program (SOER 01-01) (AL-02) A formalized ALARA program represents managements commitment to minimize dose. This program will help ensure that ALARA concerns are addressed in a systematic manner and will help make all employees aware of ALARA in their daily activities. To make the ALARA program effective, several policies and procedures have been established such as: pre-job briefings training using mock-ups installation of shielding job planning, including worker experience engineering controls use of radiological practices for dose reduction

The INDIVIDUAL WORKER is the most important element of the ALARA program. The workers actions on the job determine the dose received and, consequently, the success of the ALARA program. ALARA Techniques (AL-03) TIME is one of the most important tools that you can use to maintain your dose ALARA. Making the most efficient use of time in a radiation field will certainly be effective in reducing your exposure and, consequently, your dose. Effective planning can also help reduce time. Take a few extra minutes to reduce dose by talking to other workers about the job scope and work area, knowing what tools to take into the radiation area, prefabricating whenever possible, and locating the work area on a survey map and pre-planning the job.

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Assume it takes a worker 20 minutes to adjust a valve in a radiation area using a wrench or 12 minutes using a ratchet. Who received the least amount of dose?

Make sure you understand the job by reviewing the radiological survey data, knowing what areas to avoid and leaving the area as soon as the work is complete. DISTANCE is also a very effective way of reducing dose. In general, the greater the distance from a source of radiation, the less the dose received.
Assume that during a work break one worker moves to the low dose area, another worker stays near the source of radiation. Who received the least amount of dose?

The dose received may be greatly reduced by moving even a small distance from the source. Standing four feet from a radiation source instead of two feet can reduce your dose rate by as much as 75%. (This reduction assumes that you are not moving closer to another source). SHIELDING can significantly reduce the dose you receive by reducing the intensity of a radiation field. Standing behind a large building support while examining a defective component will help reduce dose. Temporary Shielding (AL-04) For temporary shielding to be used, a total dose savings must be realized for the entire plant population. That is, the overall dose for the job, including the dose received during the installation and removal of the shielding, must be less to make it a sound ALARA decision. Temporary shielding, usually in the form of blankets containing lead, MUST NOT BE INSTALLED, REMOVED, OR MOVED WITHOUT FIRST RECEIVING PERMISSION FROM RADIATION CONTROL. Unauthorized removal or movement of any type of shielding can lead to RADIATION OVEREXPOSURE. Calculating Stay Time (AL-05) A time limit, called STAY TIME, may be imposed on a worker due to the amount of exposure the individual has already received and the dose rate in the area. Stay time is used to ensure an individual does not exceed a limit by restricting the amount of time allowed in a radiation field. Stay Time = (Dose Limit Current Dose) Dose Rate

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Assume an employee has received 1500 mrem of dose this year. Remember the administrative dose is 2000 mrem/yr. If the employee works in an area with a dose rate of 100 mrem/hr, how long could he remain in the area without exceeding the administrative limit? First determine the allowed dose 2000 mrem 1500 mrem = 500 mrem Next, divide the allowed dose by the dose rate 500 mrem 100 mrem/hr = 5 hrs

Additional ALARA Information The phrase source term reduction means the removal or reduction of area dose rates by actions such as flushing, purging, or removing the component that is the source of radiation. Source term reduction is being used in the plant and is a very efficient means of helping to maintain dose ALARA. Even with the precautions mentioned, workers must be alert to changing radiological conditions due to certain plant operations such as radiography (testing of pipes or welds with radioactive sources), changes in reactor power levels, and changes in system lineups. If abnormally high radiation levels are noticed, workers should leave the area immediately and notify radiation control. As a result of lessons learned from industry events, certain tasks require a more comprehensive prejob review as part of the overall ALARA effort. Pre-job briefings can include active participation by radiation control personnel who may even physically provide RC coverage for the job. The pre-job briefing should also address any anticipated problem areas in performance of the task, available alternatives, and expected radiological protection impact.

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Dosimetry Section VI Enabling Objectives ED-01 State the purpose of dosimetry. ED-02 List the types of radiation detected by thermoluminescent dosimeters (TLDs) and electronic dosimeters (EDs). ED-03 Identify how to wear dosimetry devices properly including placement and orientation. ED-04 Identify the modes, methods, and frequency for operating and reading EDs. ED-05 Identify how dosimetry is issued and returned. ED-06 State the action(s) to be taken if a dosimeter is lost, damaged, or alarming. Purpose and Characteristics (ED-01, 02) Dosimeters are used as a tool to monitor and control personnel radiation exposures during work inside Radiation Control Areas. There are two basic types of dosimeters issued, the thermoluminescent dosimeter (TLD) and the Electronic Dosimeter (ED). EDs provide you with an approximation of dose received, while TLDs are used to record your permanent occupational external dose record.
TLD Passive Monitoring Requires Processing Measure Dose Only Detects Beta, Gamma, Neutron No Alarms Characteristics of the TLD and ED ED Active Monitoring Direct Reading of Dose Estimate Measures Dose and Dose Rate Detects Gamma Only Dose and Dose Rate Alarms

ED dose and dose rate alarm set-points will be established by RC personnel for each Radiation Work Permit/ALARA Task. Alarm set-points are determined during RWP development, and will be based on anticipated radiological conditions, average time of RCA entry, maximum expected dose per RCA entry, and ALARA considerations. The goal in establishing the ED dose alarm is to alert personnel and prevent them from exceeding an Administrative Dose Limit. You should pre-plan your work activities; allowing yourself enough time to exit the area before the ED alarms. If your ED alarms for DOSE, you should immediately place the work area in a safe condition, promptly exit the work area, and contact RC. RC supervision is notified of all accumulated dose alarms. RC supervisor concurrence is required prior to continuing work. The ED dose rate alarm set-point is typically set at, or near, the maximum anticipated work area dose rates. High dose rates that may be encountered during transit to the work area, or for short periods of time during the work activity, may be excluded if these alarm conditions are discussed with workers during the RC briefing. If the ED alarms for DOSE RATE, the response should be based on the type of dose rate alarm: Unanticipated Dose Rate Alarm Place the work in a safe condition, promptly exit the work area, and contact RC.

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Anticipated Dose Rate Alarm If the alarm is outside RC briefing conditions, immediately place the work in a safe condition, promptly exit the work area, and contact RC. If the cause of the dose rate alarm is known and has been addressed; RC may authorize the work to continue. If the cause of the dose rate alarm is unknown, or has not been addressed, RC supervisor concurrence is required prior to continuing work. Wearing Dosimetry (ED-03) THE TLD AND ED SHOULD BE WORN IN CLOSE PROXIMITY TO EACH OTHER, ON THE UPPER FRONT PORTION OF THE BODY (BETWEEN THE NECK AND WAIST). The ED should be worn with the clip toward the body (this ensures the ED detector faces away from the body) and the TLD Beta window should be facing away from the body. Additional or special dosimetry may be required for certain jobs where dose rates to areas of the body are higher than those to the chest region. Typical placements for additional whole-body dose include the head, back, and thigh. For extremity dose considerations, the wrists or ankles may have special dosimetry attached. If you are required to wear any special dosimetry, RC will provide you with instructions. USE OF DOSIMETRY (ED-04) Electronic Dosimeters operate in two modes; dose and dose rate The DOSE mode provides a read-out of estimated dose in units of mrem. The DOSE RATE mode provides a read-out of the current dose rate in units of mrem/hr. The ED should never be removed from the body and should never be used as a survey meter. It should be kept near the body at all times. EDs will alarm if a preset dose or dose rate is exceeded. The LED on the dosimeter will remain illuminated when the dosimeter is alarming. It is still important, however, to track on-the-job dose by periodically checking your dosimeter readings (once or twice per hour in a radiation area and every 15 minutes in a posted high radiation area). The ED has a continuous display for Dose; however, you can toggle between dose and dose rate readings by depressing the button located on the front of the dosimeter. Use the alarms as a backup only. There is also an alarm that will sound on your ED if the battery requires recharging/ replacement. This alarm is not associated with your dose or dose rate requirements for your RWP; however, it is still important that you exit the area when this alarm sounds.
OE12441 07/03/01 During a refueling outage, a worker was performing in-service inspections when his ED alarmed for dose rate (conditions in the area changed based on work being performed). The worker, not suspecting that the work conditions had changed, misinterpreted the alarm as a low battery alarm. The worker made a cognitive decision that the alarm was battery related based upon past experiences at other facilities. The dose rate alarm and battery alarm sound similar, as do many of the other audio signals associated with the ED. This event is not significant because the radiation dose received by the worker was very small. This event is noteworthy because the exposed worker misinterpreted the dose rate alarm and apparently did not check the dose rate reading when the alarm sounded.

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It is your responsibility to monitor your own radiation exposure while performing a task in a radiation area. The ED provides the best method to perform this responsibility. Workers should never tamper with their dosimeters. Failure to comply with the dosimetry requirements may result in disciplinary action up to and including termination.
Pocket External Alarm/Lighted External Device A Pocket External Alarm (PEA) is a device that connects to the ED. It translates the ED alarm signals into three alarm functions (wide-view LED, audio buzzer, and mechanical vibration) for easy recognition in high noise environments. The Lighted External Device (LED) is a device that connects to the ED and hooks to the safety glasses. A light at the end of the connection indicates alarm functions in high noise areas. Both of these devices are designed to give visual indication of an ED alarm in a high noise area where it may be difficult to hear the ED alarms.

Issue and Return of Dosimetry (ED-05) To gain access to a Radiation Control Area (RCA), workers must log onto a Radiation Work Permit (RWP)/ALARA Task at an ED workstation. An ED workstation consists of a PC, dosimeter reader, and a bar code laser scanner or a numeric key pad. The log-in steps are as follows: Retrieve the ED from the rack/bin located in the ED workstation area. Read the ED and verify that it is in the Pause (off) mode. Insert the ED into the dosimeter reader. Enter your worker ID (social security number) at the prompt by scanning the bar code on the security badge or by using the numeric key pad. Enter the ALARA task number by scanning the bar code off the supplied sheet or by using the numeric key pad. Verify the information. o Choose Yes if the information is correct o Choose No if the information is incorrect. o Choose Abort to exit the Log-In attempt. o Choose View RWP to review the RWP information. Remove your dosimeter from the reader at the prompt Entry Granted and place it on the chest area. Make sure the ED is firmly secured to the body to minimize the possibility of dropping or losing the dosimeter! Your dosimeter should now be in the dose mode (reading d: 0.0). Upon exiting the RCA, use the following log-out steps: Insert the ED into the dosimeter reader. Enter your worker ID (social security number). Verify the information. o Choose Yes if the information is correct. o Remove the ED at the Exit Granted prompt. Verify the ED is in the "Pause" (off) mode.

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Place the ED back in the storage rack after completion of log-out. Report to RC if directed to do so by a message on the screen. A log-in/log-out attempt can be canceled at any time by choosing Abort.
Log-Off Exemptions The only workers exempted from logging off an RWP/ALARA Task upon exiting the RCA are Emergency Response Organization (ERO) personnel during an emergency. Exceptions may be made to this policy for personnel who routinely log in on a general RWP/ALARA Task for the entire shift, i.e., Operations, Security and RC Technicians.

TLDs Personnel with unescorted access to the RCA are required to have a TLD. The TLD should normally be attached to the individuals security badge and taken home at the end of the work day. You are not allowed to store your TLD inside the Protected Area (e.g., inside desks, lockers, etc.). Safety & RC Considerations DO NOT point the laser scanner at the eyes. Make sure you sign off the RWP/ALARA Task upon exiting the RCA. DO NOT wear electronic dosimeters outside the Protected Area (through the turnstile) unless authorized by RC personnel to do so. REMEMBER to bring your TLD to work each day. If the dosimeter is dropped, proper operation should be verified. In high noise areas workers should visually check the alarming dosimeter frequently and follow RWP/ALARA Task instructions. Radio frequencies can cause a malfunction of the ED. If you use portable radios, place the radio and ED on opposite sides of the body.
OE 13236 01/08/02 A worker dropped his TLD from a height of approximately 10-15 feet. The TLD hanger opened and the TLD insert came out. The worker reassembled the TLD, not realizing that the TLD element card had also fallen out of the TLD holder and was lost. This was not discovered until the TLD was returned to the Dosimetry office for processing. Dosimetry treated this as a lost TLD and assigned dose to the individual based on the cumulative EPD reading recorded during the quarter. This was not a safety significant event, however, individuals should be aware that if their TLD hanger is subjected to sufficient shock to cause the hanger to open, the parts should be taken to qualified personnel (Dosimetry) for reassembly.

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OE 15845 03/12/03 Permanent magnets which remain in close proximity to a DMC-2000S ED may cause the dosimeter to stop integrating dose. This was seen when large magnets were held within @2 of the dosimeter and when small magnets were held in contact with certain areas on the dosimeter case. Dose accumulated prior to exposure to the magnetic field was apparently not affected. Once the magnet is moved away from the dosimeter, operation returns to normal. This problem will be apparent to the observant user because when a magnet is first placed near the dosimeter, the dosimeter emits a short duration audible tone and the LED alarm light briefly flashes. As long as the magnet is affecting dose integration, the display is in test mode with all pixels dark.

Lost, Damaged, Alarming Dosimeter (ED-06) If the TLD or ED is damaged or lost while working in the RCA, exit and contact RC. If the ED does not appear to be working properly, exit the area and contact RC. Response to the ED alarms will be the first priority unless you are performing lifesaving activities or preventing a release of radioactivity to the public and/or the environment.

SER 4-98 (HNP) 04/12/97 An insulation contract worker and a station RC Technician exceeded their RWP allowed dose while removing and installing insulation on a heat exchanger. When they started to work, they realized that more insulation than anticipated had to be removed. As work progressed, the insulation contractors EPD alarmed; five minutes later, the EPD worn by the RC Technician also alarmed. Rather than leave the area, the technician allowed the work to continue and helped remove insulation in order to complete the task with only one entry. The contractor received 495 mrem and the RC Tech received 530 mrem. The RC Tech did not follow station procedures when he allowed work to continue after the dosimetry alarmed. Also, the technician lost focus on his radiation protection responsibilities by helping finish the insulation work.

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RNP 03/14/98 A worker from another nuclear plant within the utility was repairing a valve actuator when he received 110 mrem of radiation exposure (the allowed dose was 100 mrem) because he did not respond to an alarm on his alarming dosimeter. After receiving the continuous dose alarm, the worker stayed in the area, completed torquing four remaining actuator bolts, and picked up his tools to take them to the tool room. An investigation faulted the workers judgement because he did not exit the area immediately upon receiving the alarm. The worker thought it was more important to complete the job than exit the area as expected.

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Contamination Section VII Enabling Objectives CC-01 Identify and compare fixed, loose, and discrete (hot) particle contamination. CC-02 State the units used to measure contamination. CC-03 Describe methods to prevent the spread of contamination. CC-04 Describe sources and/or indications of contamination. CC-05 Discuss methods used to prevent personal contamination events. CC-06 State individual actions for removing contaminated and non-contaminated materials from an RCA. CC-07 Explain contamination monitoring techniques including the use of friskers and personal contamination monitors. CC-08 State the actions to be taken upon indication of personal contamination. CC-09 State the methods used to control contaminated tools, equipment, and materials including radwaste minimization, hot tool issue, and bagging/surveillance requirements. CC-10 State the methods used to designate contaminated areas including postings and step-off pads. CC-11 Regarding discrete (hot) particles be able to state: the methods used to warn of hazards the methods to identify discrete particles sources work activities that may result in discrete particle contamination special precautions to be used in an area that may contain discrete particles CC-12 Identify situations that would require workers to immediately exit a contaminated area. Radioactive Contamination Contamination is defined as radioactive material where it is not wanted. A surface may be contaminated by a spill of radioactive liquid, settling of airborne particulate matter, or maintenance activities performed on a contaminated system. Contamination emits radiation. The two major sources of contamination at a nuclear plant are fission products as a result of the reactor fissioning process and activated corrosion and wear products (rust, metal, etc.). In either case, the products are transported throughout the systems that carry reactor water and steam. Routine maintenance operations or leaks in these systems may allow radioactive material to be released and to accumulate on surfaces of the plant. This creates a contamination problem for workers and may also contribute to a hot particle problem. Types of Contamination (CC-01) FIXED CONTAMINATION is surface contamination that has become embedded in an object and cannot be removed by normal cleaning techniques. Since no results would be obtained by rubbing a smear across a surface where the contamination is fixed, a direct check for radiation is required to detect fixed contamination. Workers should be aware that certain maintenance activities, such as welding and grinding could cause fixed contamination to become loose contamination.

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LOOSE contamination is radioactive material that is loosely adhered to an object. Loose contamination may be easily transferred to clean areas, or your coworkers, by improper work practices such as leaning against equipment in contaminated areas and not using proper procedures when exiting the contaminated area. Another potential problem associated with loose surface contamination is that it may become airborne during sanding or grinding operations. DISCRETE (HOT) PARTICLES are very small, often microscopic bits of radioactive material. If a hot particle gets on the skin, the NRC limit can be exceeded in a very short period of time. If hot particles are ingested they can give a large dose to the internal organs. Hot particles originate in the reactor fuel or as activated corrosion products.

Contamination Units; Sources and Indications of Contamination (CC-02, 04) Since contamination is radioactive, it can be detected through the use of radiation detectors. Loose contamination is frequently detected by wiping a piece of filter paper (smear) over a surface area and measuring the radiation that is being emitted. The level of contamination is measured in DISINTEGRATIONS PER MINUTE (DPM), and the surface area is usually 100 square centimeters 2 2 (cm ). Normally, this is written as DPM/100 CM . Higher levels of contamination may be denoted in units of mrad/hr on survey maps. The levels of contamination denoted by units of mrad/hr indicate that additional care should be taken when working in that area. The worker may require additional protective clothing, respiratory protection, or continuous RC coverage. The RC group should be contacted prior to working in these areas. Fixed (total) contamination is detected by a frisker and is measured in COUNTS PER MINUTE (CPM). In the plant, you will be working with many potential sources of contamination. Spills and leaks from a system carrying reactor water Contaminated systems that have been opened for maintenance activities Grinding on a contaminated pipe Disassembling plant equipment that has internal contamination
AR 97609 CR-3 On July 1, 2003, maintenance personnel were performing a pressure gauge calibration which required them to breach a potentially contaminated system, however, no catch devices were used to contain fluids from the system. A small amount of liquid spilled onto the floor, but was later verified by RC as non-contaminated. Inappropriate acts associated with this event include inattention to detail and poor radiation work practices.

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When working in a potentially contaminated area, be sensitive toward indications of possible contamination such as: water leaking from a pump or valve. a pipe that has been removed from a contaminated system. maintenance on a potentially contaminated system. water standing near a contaminated system.

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an increase in counts per minute on the frisker or a frisker alarm.

It is easy to see that if proper contamination control methods are not used, you could become contaminated and even spread contamination around the plant. Preventing the Spread of Contamination (CC-03, 05,06) Contamination is radioactive, and if it were allowed to spread uncontrolled, it would be all over the office areas, your car, and at home. This would result in unmonitored radiation dose (internal and external), an increase in radioactive waste, decreased productivity (since someone will have to clean it up), and possible exposure to the public.
Think of contamination as invisible wet paint that never dries. Now imagine people walking through the invisible paint day after day. It is not difficult to see that before long the paint would be everywhere, emitting radiation.

Preventing the spread of contamination is not difficult, but it does require good work practices. Pre-plan the job and conduct a pre-job briefing to discuss the work plan, hazards that might exist, and contingencies. Use protective clothing (PCs) when working in contaminated areas. PCs protect you from contamination, not radiation! The type and use of PCs will be specified by RC and/or the RWP/ALARA Task. Avoid water that is near a contaminated system. Avoid skin contact with contaminated items. Use step-off pads and follow instructions specified on radiological warning signs or postings. Restrict access to contaminated areas. Use engineering controls such as containment devices. Additionally, how you CONTROL contaminated items and REMOVE them from certain areas is important in preventing the spread of contamination. Take only those TOOLS and MATERIALS absolutely necessary to perform work into contaminated areas. Contact RC prior to removing ANY item from a contaminated area. RC may direct workers to bag the item and have it escorted to a different location for radiological surveying and tagging. Placing these items in a bag or container will lessen the spread of contamination. The survey and tagging of the item may be performed by an RC technician. Bags used for potentially contaminated items must be labeled CAUTION, RADIOACTIVE MATERIAL. IT IS THE WORKERS RESPONSIBILITY TO ENSURE THAT THESE ACTIONS ARE COMPLETED. Removing Material From the RCA (CC-06) EVERYTHING that is removed from the RCA must be checked for contamination. Small Article Monitor (SAM) Use caution when opening/closing the door of the SAM; the SAM door is heavy due to shielding. NonRC personnel may release only the following items from the RCA using the SAM: Paperwork (for example procedures, work packages) Clipboards

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 Pens and Pencils PPE, (including work gloves) Hand-carried radios and cell phones If SAM alarm sounds: Do not remove the item(s) from the SAM Contact RC
AR 133831 BNP An operator arrived at the RCA exit carrying an umbrella that was too large to fit into the SAM. RC directed him to use a larger monitor in the Hot Machine Shop. The Operator went to the Hot Machine Shop, but could not find the monitor. He became frustrated and placed his umbrella outside the RCA without monitoring it.

Personal Contamination Monitoring Devices (CC-07, 08) Frisking is performed either manually using a hand-held frisker or automatically using a whole body contamination monitor (WBCM). The WBCM is the preferred instrument to use for frisking if it is available. Hand-Held Frisker Check the calibration date to ensure it is current. Check that the meter is on the x1 scale. Check that the response switch is on slow response. Check the background radiation. o The frisker background count rate at the monitoring location should not exceed 300 cpm. Frisk your hands first. Pass your hands over the probe at a distance of about inch while observing the meter. Pick up the probe, and move it over the surface of the body at about 2 inches/ second. It should take about 2-3 minutes to frisk your entire body. If you see an increase in indicated counts, hold the probe stationary and if there is an increase of > 100 CPM ABOVE BACKGROUND, AN INCREASE IN THE AUDIBLE "CLICK" RATE, OR AN AUDIBLE ALARM, there may be contamination present. If this occurs, contain the contamination in a bag, glove, or shoe cover and contact RC. Personnel Gamma Monitor When Traffic light is green: Stand in portal at yellow line; overhead Busy will display. If Busy changes to Recheck, reposition body in monitor to reset. Wait for chime or alarm tone (alarm will also display overhead) When chime sounds, leave monitor and exit. When alarm tone sounds (alarm light will also display in overhead), exit backwards and re-enter the same unit after traffic light returns to green. If alarm tone sounds a second time, notify RC. If any other alarm lights are displayed, notify RC.

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Whole-Body Contamination Monitor Ensure your ED is attached to the upper front portion of your body (if applicable). When Monitor light is green: Enter automatic monitor. o If no alarm sounds, exit RCA o If alarm sounds, Re-monitor nd Enter automatic monitor for the 2 survey o If no alarm sounds, exit RCA o If alarm sounds: Exit Monitor on RCA side Contact RC Alarm setpoints for Whole Body Contamination Monitors are established based on industry standards and instrument sensitivity. Not all alarm setpoints are identical and some may be more sensitive than others. [RNP - Personnel exiting a building located within the RCA are required to monitor for contamination prior to exiting the building.]
OE15655 03/03/03 A newly hired worker alarmed a nuclear stations security exit monitor. An HP responded to the alarm and it was subsequently determined that a lanyard used for safety glasses contained radioactive material. The worker was in the In-processing/training phase, so at this point had not physically entered the sites radiologically controlled area. The worker had recently completed working an outage at a European facility and had traveled to this site on 02/26/03. Whole Body Counts also revealed the presence of Co-60 on the clothing. Two possible explanations (1) the items in question may have bypassed the free release process at the previous plant; (2) the previous plant may have had different free release programs or limits. The personal items were confiscated and it was determined that individual exposure was low.

Contamination Control (CC-09) You can easily contaminate tools, equipment, or other materials you use during a job if you are working on a contaminated system. Some methods that will assist you in controlling the spread of contamination include: Minimize the amount of material taken into a contaminated area and do not store clean material in a contaminated area. Use only those tools that are necessary, do not take packaging material into a contaminated area, and minimize the amount of trash generated. Contaminated materials should be bagged using yellow plastic bags, properly marked washable bags, or as directed by Radiation Control. Contamination Area Postings (CC-10) Yellow and magenta signs and ropes warn you of plant areas that are contaminated. Contamination areas are defined as any area accessible to personnel where removable surface contamination is >1000 2 2 dpm/100 cm beta-gamma and/or 20 dpm/100 cm alpha. An RWP/ALARA Task is required for entry

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and you can only enter/exit the area at the step-off pad (SOP) unless approved by RC supervision. DO NOT ENTER THE AREA OR REACH OVER/UNDER THE ROPES UNLESS APPROVED BY RC. Failure to adhere to these requirements can result in disciplinary action up to and including termination.

Discrete (Hot) Particles (CC-11) Several methods are used by radiation control to warn workers of discrete particle hazards and to help workers maintain total dose ALARA. Ropes, signs, barrier tape, or a combination of these items may be used. Stay alert to hot particles, changing radiological conditions, and postings which may be helpful in warning you of radiological hazards. There are several ways to identify a hot particle. When frisking, a hot particle can cause the meter to rapidly rise to a much higher count rate. Remember that the frisker will respond only if you have it close enough (1/2 inch) to the discrete particle and if you are moving it slow enough (2-3 inches/second) for the detector to respond. The whole-body contamination monitor (WBCM) is not the preferred method of detecting a hot particle (due to blind spots); however, industry experience has shown that the WBCM is capable of detecting hot particles. As discussed earlier, hot particles originate in the nuclear fuel or from corrosion products. Therefore, when working on equipment connected to the reactor or systems with activated corrosion products, always be aware of the risk that they may contain hot particles. Remember exposure to hot particles may result in exceeding the NRC limits for skin dose or internal organ dose. When working in areas that may contain hot particles: Review the RWP/ALARA Task and Survey Map carefully. Use PCs as required by the RWP/ALARA Task (no rips or tears). Carefully frisk upon exiting the area.
LER 96-003-00 04/08/96 An employee at Braidwood was working on the bottom elevation of containment where other employees who had been working on the steam generators had traveled through. During his work activities, the employee used the control point telephone using work practices that were consistent with plant policy. After use of the phone, the worker performed various other tasks. When the employee frisked, he detected a discrete particle which resulted in a reading of 4.4 million dpm. Dose calculations were performed manually and by computer using the isotopic data and time estimates. The final calculations resulted in a Shallow Dose Equivalent of 70.6 rad.

Emergency Conditions (CC-12) You should immediately exit the contaminated area and frisk if any of the following situations occur: You tear or cut the PCs. You suffer cuts, abrasions, or have other types of open wounds. The PCs become wet (sprayed with water from equipment or sweating). Your ED is lost, damaged, or alarming.

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You observe any abnormal conditions in the work area. You are directed to leave by RC personnel. You suspect you are contaminated.

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Internal Exposure Section VIII Enabling Objectives IE-01 State four methods which allow contamination to enter the body. IE-02 State the methods used to limit internal deposition of radioactive materials. IE-03 State the processes used to eliminate radioactive material from the body. IE-04 Recognize the methods used to determine the amount of radioactive material deposited in the body. IE-05 Define CEDE, ALI, and DAC. IE-06 State the relationship among DAC, ALI, CEDE, and TEDE. IE-07 Discuss plant conditions that may increase the potential for airborne radioactivity. Internal Deposition (IE-01) As we have learned, most of the radiation dose received comes from external sources. However, workers should also be aware that there is a risk of internal exposure. There are four primary methods which will allow radioactive material to enter the body: Inhalation; breathing it in Ingestion; eating, drinking, smoking, or chewing Absorption; absorbing it through the skin Open wounds; includes sores (should be properly bandaged) Limiting Internal Exposure (IE-02) Internal contamination should be limited as much as possible because it can become lodged inside an organ and give a high dose to that organ. Listed below are some methods that you can use to help reduce internal exposure. DO NOT eat, drink, smoke, or chew while in a radiation control area. DO NOT pipette solutions by mouth. Properly use engineering controls such as installing ventilation systems with temporary filters, isolating potentially radioactive steam leaks, or shifting ventilation flow paths. Properly use respirators and other protective equipment. REMEMBER, IT WILL NORMALLY TAKE LONGER TO ACCOMPLISH A TASK WHILE WEARING A RESPIRATOR; THEREFORE, THE TEDE MUST BE CONSIDERED. Limit the time spent in airborne radioactivity areas if a respirator is not worn. Use personal protective equipment such as lab coats, protective clothing, and gloves when handling radioactive material. Decontaminate work areas and equipment used in contaminated areas. Notify RC personnel immediately of any wound or injury occurring in a contaminated area so the injury can be monitored for contamination. THIS DOES NOT ELIMINATE THE REQUIREMENT TO ALSO NOTIFY SUPERVISION.
REMEMBER!!! Progress Energy must have safe procedures and practices in order to maintain its license to use radioactive material. Follow approved procedures and consult RC if problems or questions arise.

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Elimination of Internal Depositions (IE-03) There are two primary processes to rid the body of radioactive material. Biological processes occur naturally and purge most types of radioactive material from the body. Radioactive decay will occur with those radioisotopes that remain in the body. The decay process will make these isotopes less radioactive as time passes. The amount of time required for an isotope to decay is entirely dependent on the isotope. This can vary from a few seconds to a few years. Measuring Internal Activity (IE-04) There are two primary methods used to measure internal radioactivity. Whole-Body Counts measure the level of internal radioactivity. Periodically, whole-body counts will be performed and compared to previous results to determine if any changes have occurred. In-Vitro Bioassays may also be used to determine internal levels of radioactivity. The bioassay is an evaluation of a waste sample (urine, fecal) taken from the body and can be more effective in determining the amount and location of the radioactive material CEDE, ALI, and DAC (IE-05) The most common pathway for internal contamination is by inhalation. The amount of internal dose is directly related to the radioactivity level in the air and the duration of time spent in that environment. Federal law limits the amount of internal dose you are allowed to receive. The committed effective dose equivalent (CEDE) is the amount of assigned internal dose that relates organ dose to the whole-body dose. The annual limit on intake (ALI) is the amount of airborne radioactive material you would have to inhale or ingest to receive 5 rem CEDE or 50 rem to any organ or tissue. The federal limit is 1 ALI per year. The derived air concentration (DAC) is the concentration of airborne contaminants that you would have to breathe for 2000 hours to reach 1 ALI. Relating DAC, CEDE, ALI, and TEDE (IE-06) Since 1 ALI is based on 5 rem/year (2000 working hours), then a DAC hour is equivalent to 2.5 mrem of internal dose, (5000 mrem 2000 = 2.5 mrem/DAC hr). Therefore: 5 rem CEDE = 1 ALI = 2000 DAC hours
Example A worker is assigned a task in an area with a dose rate of 100 mrem/hr, which also has airborne concentration = 1 DAC hour. From previous experience, the worker knows it will take 2.5 hours to complete the task if he is wearing a respirator; 2 hours without a respirator. Should the worker complete the task WITH or WITHOUT a respirator? If the worker wears a respirator, what will the total external dose be? (100 mrem/hr)(2.5 hrs) = 250 mrem external If the worker does not wear a respirator, what will the total dose be? (100 mrem/hr)(2 hrs) + (2 DAC hrs)(2.5 mrem/DAC hr) = 205 mrem TEDE (external + internal)

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Since we have determined that the risk associated with internal and external dose is the same, we report all dose received at our nuclear facilities in terms of TEDE.
Example A worker receives 100 mrem externally, it is reported as 100 mrem TEDE (0 CEDE + 100 external DDE). A worker receives 100 mrem internally, it is reported as 100 mrem TEDE (100 CEDE + 0 external DDE).

Airborne Radioactivity (IE-07) In a contaminated area, there are many activities that can create or increase airborne radioactivity levels such as: brushing or sweeping a contaminated surface. fans blowing across a contaminated surface. steam leaks from a contaminated system. sanding, grinding, or welding on contaminated equipment. wet contamination that is evaporating. poor housekeeping in a contaminated area. improper work techniques. breaching contaminated systems CHECK WITH AN RC TECHNICIAN BEFORE ATTEMPTING ANY OF THESE ACTIVITIES. BE ALERT TO ANY CONDITIONS WHICH COULD INCREASE YOUR TEDE.

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Radiological Postings Section IX Enabling Objectives RP-01 Define and recognize the following radiological areas and postings: restricted area radiation control area (RCA) radiation area high radiation area locked high radiation area very high radiation area airborne radioactivity area radioactive material area hot spot hot particle area low-dose area RP-02 State the potential consequences of violating, moving, or altering a radiological posting. Postings (RP-01) Different types of radiological conditions exist in the plant. Before entering any type of radiological area, you must meet the requirements of the RWP/ALARA Task. The following are common types of postings that may be encountered in the plant. Restricted Area - an area, access to which is limited by a physical barrier such as a wall, fence, or continuous surveillance and control of access by a representative of the company, for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive materials. Radiation Control Area (RCA) - any area within a restricted area that is posted for radiological protection purposes. Radiation area - any area accessible to individuals, in which 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 the radiation penetrates

High radiation area - any area accessible to individuals, in which radiation levels from radiation sources external to the body could result in an individual receiving a dose equivalent in excess of 100 mrem in one hour at 30 cm from the radiation source or 30 cm from any surface the radiation penetrates. High radiation areas shall be posted with a physical barrier (such as a wall, door, radiation rope or ribbon, chain or gate) that checks the advance of personnel. Physical barriers should remain closed/secured except during normal entry/exit.

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Radiation Safety Violation LaSalle Nuclear Plant A contractor foreman and three workers were assigned work on a valve in the reactor building, but were unable to locate it. The foreman led the three workers into a posted high radiation area without necessary authorization and training. NRC investigators determined that the violation was willful in that the foreman and two of the workers were aware they were not authorized to enter the high radiation area and had not received the briefing by radiation protection personnel necessary to enter the area. None of the workers received a significant radiation exposure.

Locked high radiation area - any area accessible to individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of 1000 mrem in one hour at 30 cm from the radiation source or from any surface the radiation penetrates. [CR3 the dose equivalent is greater than or equal to 1000 mrem in one hour at 30 cm]. This area must remain locked. To enter this area requires an RC Technician with a key. [BNP, HNP, CR3 In situations where no reasonable enclosure can be constructed and/or lockable boundary exists, the locked high radiation area boundaries can be designated by barricading the area and installing a flashing red light as a warning device. Very high radiation area - any area accessible to individuals in which radiation levels from radiation sources external to the body could result in an individual receiving an absorbed dose in excess of 500 rads in one hour at one meter from a radiation source or one meter from any surface that the radiation penetrates. At very high doses received at high dose rates, units of absorbed dose (rad) are appropriate, rather than units of dose equivalent (rem). Airborne radioactivity area - an area containing airborne radioactive materials that exceeds the DAC specified in 10CFR20, Appendix B or to such a degree that the individual present in the area without respiratory protective equipment could exceed 0.6 percent ALI or 12 DAC hours/week (40 hours). Normally this area will be posted at airborne concentrations greater than 30 percent DAC

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Radioactive materials (storage) area - Any area or room where radioactive material is used or stored in amounts exceeding ten times the amount of such material specified in 10CFR20, Appendix C.

Containers of radioactive material with dose rates < 2 mrem/hr at contact and contamination 2 2 levels < 1000 dpm/100 cm beta-gamma and <20 dpm/100 cm alpha will be clearly labeled CAUTION, RADIOACTIVE MATERIAL. No additional information is required. Containers of radioactive material with dose rates > 2 mrem/hr at contact or contamination levels > 1000 2 2 dpm/100 cm beta-gamma or > 20 dpm/100 cm alpha must contain additional tagging information including: dose rate on contact with the container contamination levels on the material inside the bag description or type of material surveyors name or initials date of survey Hot spot - A local intense source of radiation with a contact dose rate greater than 100 mrem/hr and greater than five times the dose rate at 30 cm.

Hot Particle Area - An area where hot particles are known to be present or suspected to be present based on historical information. Low Dose Area - the area inside the radiation work area with the lowest dose. Use these areas for taking a short rest, waiting for QC inspectors, or reviewing procedures. This will help maintain your TEDE ALARA Posting Violations (RP-02) The postings discussed above serve an important purpose. They inform workers of potential radiation/contamination hazards in the work area. If these postings are violated, it can affect the safety of you and your co-workers. Therefore, any violation, movement, or removal of radiological postings will not be tolerated. This can result in a radiological hazard, unanticipated or increased radiation dosage to personnel, regulatory fines, and disciplinary action up to and including termination.

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Radiological Alarms Enabling Objectives RA-01 Identify the radiological alarms used at Progress Energy nuclear facilities. RA-02 State the proper response to radiological alarms. RA-03 State the potential consequences of ignoring radiological alarms.

Section X

Radiological Alarms and Responses (RA-01, 02) Many areas of the plant are monitored for radiological conditions. These monitors will alarm if the condition being monitored is not within the normal range. The following are typical radiological alarms used in the plant: Continuous Air Monitor (CAM) This alarm monitors airborne radioactivity in the plant and indicates if the air being sampled by the CAM has exceeded a preset level of radioactivity. If a CAM alarms NOTIFY your co-workers, SECURE the work area, EXIT the area, and CONTACT RC. Area Radiation Monitor (ARM) This alarm monitors radiation levels in various areas of the plant. If an ARM alarms, it indicates that the radiation level in the monitored area has exceeded a preset limit. Your response to an ARM is the same as the response to a CAM. However, when you exit the area, DO NOT EXIT IN THE DIRECTION OF THE ALARM. This area could contain a higher radiation field. Ignoring Alarms (RA-03) Radiation alarms can be an indication of a serious radiological problem. Improperly responding to or ignoring a radiation alarm can increase your dose and negatively impact your health and safety. ANYONE WHO WILLFULLY IGNORES A RADIATION ALARM WILL BE SUBJECT TO DISCIPLINARY ACTION UP TO AND INCLUDING TERMINATION.

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Radioactive Waste (Radwaste) Section XI Enabling Objectives RW-01 Define radioactive waste (radwaste). RW-02 Contrast the disposal costs of radwaste versus clean trash. RW-03 State the methods used to minimize radwaste. RW-04 Explain why it is important to keep contaminated and non-contaminated waste separate. RW-05 Explain why it is important to keep wet and dry contaminated material separate. RW-06 Explain why it is important to keep contaminated and non-contaminated hazardous waste separate. Definition (RW-01) Radioactive waste (radwaste) is radioactive material that must be disposed of properly. Potential sources of radwaste are: washable Fire Retardant PCs that have been used in contaminated areas that are no longer repairable or serviceable. used tape, gloves, paper material, and plastic bags from a contaminated area. packing material that was taken into a contaminated area. Waste Cost and Reduction (RW-02, 03) Waste generation is a major expense that Progress Energy must budget and plan for each year. The cost of processing Low Level Radwaste (LLRW) is considerably higher than the cost of processing clean trash. For each item removed from stock there are up to five additional charges associated with it prior to burial; to issue, to handle the material after it is used and trashed, to process, to store, and to bury. Reducing both clean trash and radwaste improves our economic position considerably. Effective methods to reduce radwaste are: Ensure that tools with fixed contamination are returned to the proper RCA storage area and not deposited in clean or contaminated waste containers. Return unused protective clothing to the PC bins for other workers to use. Do not put trash from the RCA in clean waste containers. Use washable bags and protective clothing. Preplan the job. Take only those items and quantities that you really need into the contaminated area. DO NOT take packing material into contaminated areas. Tape protective clothing only when required by the RWP/ALARA Task. Choose reusable items over disposable items. When disposable items are necessary, choose incinerable material. Properly separate waste. Ensure material placed in clean waste containers is clean. Contact the Radwaste Shipping Group with any questions regarding proper disposal techniques. Contact the site Environmental Coordinator for questions concerning oil waste. Separating Waste Products (RW-04, 05, 06) Dispose of waste material properly; separate clean and contaminated waste. If mixed, there will be cross-contamination that, at best, will require someone to sort through the trash. This requires additional processing which increases disposal costs. Waste facilities are designed at each site.

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Containers at these facilities have been designated for reusable hose, rubber matting, netting, washable tarps, oil waste (liquid and material), clean solid waste, and radioactive material. Keep wet and dry radwaste separate; if the two are mixed and shipped, the container may leak or corrode which could cause a radioactive spill. Most LLRW disposal sites will refuse to accept LLRW that is mixed. Therefore, if wet and dry LLRW is mixed, it must be separated prior to disposal which increases the processing cost. If any chemicals are mixed with LLRW, it becomes even more difficult to dispose of due to the additional restrictions that apply to chemical and hazardous waste disposal. When radwaste generation cannot be avoided, use incinerable or reusable material. If waste must be generated, incinerable waste is the most desirable.

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Rights and Responsibilities Section XII Enabling Objectives RR-01 State individual rights and responsibilities regarding: ALARA concepts. Instructions provided by RC personnel, written policies and procedures, RWPs/ALARA Tasks, and posted warning signs. Personal dose accountability and the process to follow to obtain dose records. NRC and Progress Energy dose limits. Abnormal radiological conditions and/or violations of radiological requirements. Reporting of unusual events such as primary system leakages RR-02 State individual responsibilities for reporting of unusual events such as primary system leakages. Rights and Responsibilities (RR-01) A nuclear power plant employee has many responsibilities. Most of these have already been discussed, however, due to their importance; we will review them once again. Maintain your dose ALARA at all times. Utilize time, distance, and shielding to accomplish this goal. Work in compliance with the governing RWP/ALARA Task. Read and understand the instructions on the RWP/ALARA Task before beginning a job. Follow directions from RC technicians, including a directive to stop work. Be aware of your personal radiation dose. You have the right to review your radiation dose record. To obtain your records, contact Dosimetry. Comply with NRC and Progress Energy dose limits. Keep plant management informed of radiological and/or procedural violations that occur in the plant. Ask questions and communicate with the RC technicians if you do not understand work conditions.
10CFR19.12 Instructions to Workers All individuals working in or frequenting any portion of a restricted area shall be kept informed of the storage, transfer, or use of radioactive materials or of radiation in such portions of the restricted area; shall be instructed in the health protection problems associated with exposure to such radioactive materials or radiation, in precautions or procedures to minimize exposure, and in the purposes and functions of protective devices employed; shall be instructed in, and instructed to observe, to the extent within the workers control, the applicable provisions of Commission regulations and licenses for the protection of personnel from exposures to radiation or radioactive materials occurring in such areas; shall be instructed of their responsibility to report promptly to the licensee any condition which may lead to or cause a violation of Commission regulations and licenses or unnecessary exposure to radiation or to radioactive material; shall be instructed in the appropriate response to warnings made in the event of any unusual occurrence or malfunction that may involve exposure to radiation or radioactive material; and shall be advised as to the radiation exposure reports which workers may request pursuant to 19.13. The extent of these instructions shall be commensurate with potential radiological health protection problems in the restricted area.

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Primary System Leakage (Boric Acid Awareness and Control) (RR-02) Employees should be aware of deteriorating conditions which might impact the ability of the plant to operate safely, efficiently, and economically. Accurate and timely reporting of a primary system leak can help to mitigate damage. If you detect leakage in one of the primary systems of the plant, you should report it to your supervisor immediately. Do not disturb or remove any deposits that you may find on the system.
SOER 02-04 On March 7, 2002, Davis-Besse Nuclear Power Station conducted an ultrasonic inspection of a control rod drive mechanism (CRDM) penetration on the reactor pressure vessel (RPV) head. The inspection led to the identification of a cavity in the RPV head adjacent to CRDM nozzle 3. The cavity extended @ 7 inches from the nozzle and, at the widest point, was @ 6 inches wide. The wastage extended through the base metal of the head, eventually reaching the 3/8-inch steel cladding on the inside of the head. This wastage was attributed to corrosion resulting from boric acid deposition left on the RPV Head. The stainless cladding appeared to be deflected upward @ 1/16 inch for a distance of approximately 4 inches, indicating that the material had yielded under the nominal 2,200 psig pressure maintained in the RCS during operation. Calculations performed on the as-found condition of the cladding predicted that failure would occur at a pressure of 5,600 pounds per square inch. Two of the lessons learned as a result of this event at Davis-Besse are 1) the importance of removing all boron deposits from the RPV head and 2) that 100 percent bare-metal inspection is the most accurate method of determining if leakage is occurring through the RPV head penetrations.

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Radiation Work Permit (RWP)/ALARA Task Section XIII Enabling Objectives RWP-01 State the function of an RWP/ALARA Task. RWP-02 State the type of RWP used at Progress Energy. RWP-03 Extract information from an RWP/ALARA Task. RWP-04 State the responsibility for complying with RWP/ALARA Task requirements. RWP-05 Extract information from a survey map. RWP-06 State the required action(s) to be taken if the work scope or radiological conditions of an RWP/ALARA Task change. RWP Function (RWP-01) A radiation work permit (RWP)/ALARA Task provides controls and expectations to workers so they can perform their assigned tasks safely in radiation areas. By following the requirements of the RWP/ALARA Tasks, workers can minimize dose and reduce the likelihood of contamination. The RWP/ALARA Task is one of the most important tools available to maintain dose ALARA. The RWP/ALARA Task has three major functions: Authorizes individuals to enter radiation control areas Provides radiological work requirements including protective clothing, equipment, special instructions, and precautions to be followed Provides information regarding radiological conditions in the work area RWP Types (RWP-02) Most RWP/ALARA Tasks originate from Work Order Tasks. You should know the Work Order Task Number or the RWP/ALARA Task Number prior to logging in. You can review current RWP/ALARA Tasks by utilizing Passport Net Tools. Some RWP/ALARA Tasks are considered general RWPs; they cover large areas of the plant and are not designed to cover a specific tasks. An example of this type of RWP/ALARA Task would be an RWP written to encompass management or Nuclear Oversight observations. RWP/ALARA Task Information (RWP-03) An RWP/ALARA Task also contains information such as clothing and dosimetry requirements, and any other special requirements that will help you perform your job safely in a radiological area. Discuss any questions you have with RC technicians before signing in on the RWP/ALARA Task and actively participate in the pre-job briefing. Specifically, an RWP/ALARA Task contains the following information: RWP/ALARA Task number Job location and work description Radiological conditions o Dose rates o Smearable contamination levels o Airborne activity (DAC found in special instructions) o Other applicable radiological conditions (hot spots found in special instructions) Protective requirements o Dosimeters o Protective clothing o Respiratory protection Special Instructions and precautions

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 Electronic Dosimeter Dose and Dose Rate Set-points Access authorization Termination information RWP/ALARA Task Compliance (RWP-04) The requirements of an RWP/ALARA Task protect you and your coworkers from receiving unnecessary dose. THEREFORE, IT IS IMPORTANT THAT YOU COMPLY WITH THE REQUIREMENTS/RESTRICTIONS OF YOUR RWP/ALARA TASK AT ALL TIMES. Noncompliance with an RWP/ALARA Task may result in a radiological event, increased dose, contamination violations, or other radiological problems. This could also result in being fined by the NRC, or other regulatory action, as well as possible disciplinary action up to and including termination for the worker. Survey Maps (RWP-05) Survey maps are prepared by Radiation Control and provide detailed dose rate and contamination information on plant locations and equipment. The survey map generally shows a drawing of the area(s) covered by the RWP/ALARA Task and includes information on dose rates, contamination areas, contamination levels, and other radiological information. Typically, survey maps present much more area radiation hazard information than can be presented on an RWP/ALARA Task. Radiation Control maintains these survey maps at Access Control Checkpoints. Workers are encouraged to review these maps prior to beginning work. The types of information found on a survey map (i.e., posting locations, smears, dose rates) are differentiated through the use of symbols and/or designators. A matrix located on the survey map indicates the symbol definitions. Radiological postings are designated by the abbreviations that corresponds with the appropriate dose rate conditions for that postings, example: RA, HRA, LHRA. A dose rate is designated by a number in a square box. A smear location is designated by a number in a circle; the number will correspond with the same number in a matrix located at the bottom of the survey map. An airborne sample is designated by a number in a triangle; the number will correspond with the same number in the matrix located at the bottom of the survey map. Low Dose Waiting Areas will be designated by the abbreviations LDWA. A Change in Conditions (RWP-06) When working in the plant, remember that radiological conditions can change rapidly. If radiation levels increase, the dose rate will increase. These changes may not be obvious since the cause of the change may not even be in the same building. Radiological conditions can change with reactor power level, equipment status changes, movement of shielding, and/or other reasons. THEREFORE, IT IS IMPORTANT TO MONITOR DOSE AND CHECK YOUR ED FREQUENTLY. At a minimum, check your ED once or twice an hour while working in a Radiation Area and every 15 minutes in a High Radiation Area. If radiological conditions are different than the RWP/ALARA Task or survey map indicates, or if the conditions change unexpectedly, inform your coworkers, exit the area, and contact RC.

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If, while working in a radiation control area, the scope of the job changes, contact RC before proceeding. This could include opening a potentially contaminated system, or moving lead shielding. By contacting RC prior to the beginning of the job you will prevent unanticipated dose or unnecessary contamination violations.

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Radiation Worker Practical Exercise (Dressout) Section XIV Enabling Objectives In order to receive credit for Initial Radiation Worker, a student must participate in a practical exercise followed by a graded exercise based on the following objectives. PE-01 Given an RWP/ALARA Task, properly respond to questions concerning the following: RWP/ALARA Task/revision number Job location/work description Radiological conditions Dosimetry requirements Protective clothing requirements including use of respiratory protection Special instructions (RC coverage/hold points) Radiation work practices Frisking techniques PE-02 Given a security badge, TLD, and ED, log-on to an assigned RWP/ALARA Task. PE-03 Given an RWP/ALARA Task, select and properly don the protective clothing required to perform the assigned task. PE-04 Demonstrate the proper placement of the security badge, TLD, and ED for work in a contaminated area. PE-05 Meet the requirements of signs and postings within a contaminated area. PE-06 Apply radiation work practices to minimize exposure and the spread of contamination. PE-07 Demonstrate a proper method to read an ED while inside a contaminated area. PE-08 Remove protective clothing without spreading contamination. PE-09 Demonstrate proper frisking techniques using a hand-held frisker and/or a wholebody contamination monitor. PE-10 Log-off of the assigned RWP/ALARA Task. Introduction You will be working as a team with other students from your class to satisfactorily complete a work assignment as described by an assigned RWP/ALARA Task. You will practice safe working habits including the proper use of safety glasses and hard hats. The instructor will role play as an RC technician and will provide remedial feedback as applicable. The instructor can simulate material and/or equipment that is unavailable or non-operational. The instructor can freeze-frame a scenario to discuss/clarify safety or radiological concerns. Site specific radiation work/contamination control practices may be included in this exercise. Return the badge, TLD, ED, safety glasses, hard hat, and/or protective clothing to the appropriate storage locations as directed by the instructor. Pre-Job Brief (PE-01) The instructor will conduct a pre-job brief including a review of the assigned RWP/ALARA Task and associated survey map (as applicable). ED Log In (PE-02) A badge, TLD, and ED will be provided for your use during the exercise. It will be your responsibility to log onto an assigned RWP/ALARA Task. Basic log-in instructions will appear on the computer monitor once you insert the ED.

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Protective Clothing Requirements (PE-03) The RWP/ALARA Task will state the minimum requirement of dress for the job, however if you feel that you need additional protective clothing, you may contact Radiation Control. Generally, no personal street clothing except undergarments; i.e.,shorts and T-shirt or assigned modesty garments, socks, and shoes are to be worn in a contaminated area. FOR THE PURPOSE OF THIS EXERCISE, YOU WILL DON THE PROTECTIVE CLOTHING OVER YOUR STREET CLOTHES. The selection of protective clothing is important to ensure adequate protection against contamination. Ensure that you choose protective clothing that fits comfortably; the coveralls should be loose to allow adequate air flow while you are working and to make it easier to remove the coveralls when the job is complete. With prior approval from the Radiation Control group, labcoats, shoe covers, and gloves may be worn into contaminated areas. Typically, labcoats are used in the place of standard anti-cs when the work activity does not involve hands-on work where climbing or crawling may occur, for example; when entering a contaminated area to perform an inspection. If lab coat use is approved, the buttons on the lab coat must be buttoned. The badge, TLD, and ED should remain outside the lab coat. These items may be placed in the coat pocket if the type of work being performed could reasonably cause them to become contaminated. Always check the condition of the protective clothing. There should be no rips, tears, or broken zippers which might allow contamination on the body. Inspect outer gloves (surgeon, rubber, or latex) for air leaks. Even a pinhole leak in a glove could create a personal contamination event. Capture air in the glove and then squeeze it tight to ensure that no air escapes. Donning Protective Clothing The order listed here is a guideline for donning protective clothing. Other sequences may be used, but it is important that protective clothing be donned properly prior to entering a contaminated area. Orex PCs are considered standard dress at all PGN facilities. Don the inner shoe covers. Pull the shoe cover as far as possible up on the leg. Don the cotton/orex liners. The liners make it easier to don the outer gloves and soak up sweat as you work; the liners provide limited protection from contamination. Don the coveralls. The coveralls must remain fully zipped at all times. In certain situations, cloth or fire retardant coveralls may be used. If you are wearing cloth or fire retardant coveralls you should also ensure that the velcro overflap is closed. Coveralls should not be unzipped temporarily to get pens, etc., from inside pockets or for comfort. The coveralls may be unzipped to avoid heat stress, but this should be done with RC assistance. Don the outer shoe covers. Don the outer gloves (surgeon, rubber, or latex). Remember to check for air leaks. The Orex coveralls have an inner and outer sleeve. The inner sleeve has a thumbhole; insert your thumb into the hole, this ensures that the coverall sleeve will not ride up on the arm. Gloves or loose clothing can become entangled when working with lathes or similar rotating equipment. Contact RC for proper protective clothing prior to working around rotating equipment.

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A full hood is required for standard dress; other hood types can be approved by RC. Long hair should be tucked completely inside the hood to prevent a personal contamination event. The hood should be completely closed underneath the chin. A standard issue hard hat will be worn over the hood whenever a worker is entering a contaminated area. At some of the PGN facilities, the hard hat will be magenta colored and will be deposited in a designated receptacle during the undress sequence. At others, an Orex cover will be worn over the hard hat. The cover will be deposited in the Orex container during the undress sequence and the hard hat will be placed on the Step-Off Pad.
OE 8207 04/12/96 A mechanic was polishing a pitted valve stem with sandpaper (emory cloth). He was using his right hand to hold the paper and perform the polishing. The sandpaper trapped his rubber glove which was pulled into the rotating stem. He attempted to pull back, but his glove and coverall sleeve became entangled on the stem, along with his arm. The root cause of the event was determined to be the combination of hand sanding while wearing standard rubber gloves.

Badge/TLD/ED (PE-04) The placement and arrangement of the security badge, TLD, and ED may vary from site to site and due to various circumstances. Consult the Radiation Control Group at each site for specific requirements. Regardless of the placement or arrangement, the TLD and ED should always be configured so that the fronts of each instrument are facing away from the body. If the ED and TLD are turned backwards, they may under-respond to radiation dose rate fields. Radiological Postings (PE-05) Remember, there are many different signs and postings in the plant. These are designed to make you aware of the hazards in your immediate work area. Examples include: Contamination boundaries such as yellow/magenta rope and/or tape are used to designate the boundaries of the area. There will also be a Step-Off Pad (SOP) at the entry/exit point of the area. Radiological Postings indicate the radiation dose rates and/or contamination levels for the work area. If the area is designated as a High Radiation Area there will be a swinging gate at the Step-Off Pad. IT IS THE WORKERS RESPONSIBILITY TO ENSURE THAT THE GATE IS CLOSED AFTER ENTERING/EXITING THE AREA. Plan your work so that any time not spent directly associated with your task is spent in the Low Dose Area. Caution and Danger Tags inform workers of potential equipment hazards. Warning signs indicate potential safety hazards (Example: Danger - Electrical). Practice the ALARA concepts of time, distance, and shielding to minimize radiation dose when working in posted radiation areas. You may see different types of receptacle bags in the contaminated areas; typically you will see two a contaminated trash and an Orex receptacle. If the receptacles at the SOP are full, contact RC. DO NOT COMPACT MATERIAL IN THE RECEPTACLES. THIS COULD CAUSE A PERSONAL

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CONTAMINATION OR AIRBORNE EVENT. Tools and Equipment Tools and equipment used in the RCA or contaminated areas may have fixed contamination and normally are stored in the Hot Tool Room inside the RCA. Clean tools should not be brought into the RCA unless the tools that are needed to perform the task are unavailable from the Hot Tool Room. If tools or equipment have been used in the non-contaminated areas of the RCA and they have no loose contamination, they should be returned to the Hot Tool Room or designated drop off area upon completion of the job. All tools and equipment should be monitored according to posted instructions before they are returned to the Hot Tool Room. Workers should follow RC instructions for removal of tools and equipment from a contaminated area, but generally the following rules apply: Items are staged for RC survey prior to removal. If the survey indicated that the item is not contaminated, the item can be removed from the area by the worker. If the item is contaminated, RC will leave the item in the contaminated area and notify the worker or will place the item in a suitable container, attach a completed RADIOACTIVE MATERIAL TAG to the bag and notify the worker with the proper instructions for removal of the item. Radiation Work Practices (PE-06) Occasionally, you may need to use a phone or Public Address system while in a contaminated area. Normally, in areas that have low levels of contamination you can use the phone/Public Address system without removing the outer glove. DO NOT TOUCH THE PHONE/PUBLIC ADDRESS WITH THE OUTER GLOVE IN AREAS WITH HIGH CONTAMINATION LEVELS. DO NOT TOUCH THE RECEIVER TO THE FACE. In areas with high contamination levels, you may be required to wear two gloves. If two gloves are worn, remove the outer glove before touching the phone/Public Address. Whenever possible, hose lines such as airline hoses and extension cords should be brought into a contaminated area from overhead. Otherwise, secure the line to the nearest stanchion with a tie wrap. Bag both ends of the line when it is not being used. This limits movement in and out of the contaminated area and prevents the spread of contamination. Face shields are worn to protect the face from loose contaminated particles. Do not allow the face shield to touch your face. Do not touch your face if face shield adjustment is required. Do not redon a face shield that has been set on a contaminated surface unless it has been wiped down first by an HP technician or designated deconner. Place the face shield in the appropriate container when the work is complete (disposable -vs- reusable). Remember to check your ED frequently and respond immediately if the ED alarms. DO NOT come in contact with spills that occur in the work area. If a spill occurs you should notify co-workers, secure the area, exit, and contact Radiation Control and the Control Room. Maintain good housekeeping in the work area. Be aware of loose contamination levels in your work area. If your job requires you to continuously touch a component with loose contamination on it, consider decontamination or placing a barrier between your protective clothing and the component. A decon towel or piece of herculite are acceptable contamination barriers (contact RC to obtain these items). If you must kneel, sit, or lie down to perform your work; plan ahead and contact Radiation Control to

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decon the area or provide decon towels or herculite to place as a protective barrier between you and the contaminated surface. If you tear your PCs while working, exit the work area and notify Radiation Control. If you are perspiring heavily, you have a greater chance of becoming contaminated. Exit the area before your PCs become saturated and monitor yourself for contamination. DO NOT ADJUST YOUR SAFETY GLASSES. A strap can be used to prevent your safety glasses from slipping down your nose. DO NOT TOUCH EXPOSED SKIN WITH PROTECTIVE CLOTHING. The clothing may be contaminated and could result in skin contamination. Utilize good ALARA work practices. This includes dose and radwaste minimization planning. Tools from the Hot Tool Room should be returned to the Hot Tool Room and should not be removed from the RCA. Eating, drinking, and smoking are not allowed inside the RCA. RC Supervision may designate areas inside the RCA for drinking water. Contact Radiation Control prior to working > 8 feet above floor level. Areas greater than 8 feet above ground level are not routinely surveyed for contamination.

ED Usage (PE-07) You should read your ED frequently to help ensure that the specified limits are not exceeded. Generally, you should read the ED once or twice an hour in Radiation Areas and every 15 minutes in High Radiation Areas and Locked High Radiation Areas. The ED will be bagged and should be visible through the bag, however, if you cannot read the ED through the bag, remove your outer glove, squeeze the ED to the top of the bag and read it. After you read the ED, return it to its original location. Protective Clothing Removal (PE-08) It is recommended that you maintain a distance of at least 2 feet from the SOP to prevent contamination from spreading to the SOP. When removing the protective clothing, remove in the order of the most contaminated to the least contaminated item. Remove the outer shoe covers pulling away from the SOP, and deposit them in the trash receptacle. Remove the outer gloves. Do not cross contaminate to the inner liner. The outer gloves should be deposited in the trash receptacle. Pull the hard hat towards the back to avoid facial contamination. Remove the hard hat cover (if applicable) and using it as a shield around your hand, place the hard hat on the inside corner of the SOP. Place the hard hat cover in the Orex receptacle. If a hard hat cover was not used, deposit the hard hat in the designated receptacle. Remove the hood. Grasp the hood by the crown and pull towards the back to avoid facial contamination. The hood should be deposited in the Orex receptacle. The badge, TLD, and ED should be removed from the plastic whirlpack or pocket and placed on the SOP or other area designated by RC. Do not drop the ED onto the SOP. The ED is expensive equipment to maintain and dropping it from a high distance may cause damage. If your TLD and badge are on a lanyard, they should remain on the lanyard and only the ED should be placed on the SOP. Remove the coveralls, unzipping all the way down the front. Loosen the coveralls at the shoulder and then grasp the coveralls at your waist to pull down. Step out of the coveralls. As you remove the coveralls, do not touch your body. The coveralls should be deposited in the Orex receptacle.

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With your back to the SOP, use a receptacle for support and remove the first inner shoe cover. When you remove the shoe cover, step back onto the SOP. The shoe cover should be deposited in the designated receptacle. REMEMBER THAT STREET SHOES SHOULD NEVER TOUCH THE FLOOR OF A CONTAMINATED AREA. Remove the second shoe cover and step back onto the SOP. You should now be in a position where you are standing on the SOP, but your hands are still inside the contaminated area. Remove the liners at the SOP and deposit them in the trash/orex receptacle; dependent upon which type was used. Retrieve dosimetry and proceed to the nearest frisking station and frisk for contamination. Frisking Techniques (PE-09) You may be asked to perform a frisk using a Hand-held Frisker, and/or a Whole Body Contamination Monitor. You should follow the guidelines previously learned in Radiation Worker Training and any additional guidance provided by the instructor.
RCA Release Contact RC if a WBCM alarms twice. Radiation Control will remonitor the worker. The worker will not be released from the RCA without RC supervision/designee approval unless the worker successfully clears a WBCM or RC determines that release is acceptable.

Hand-Held Frisker Only ANSI qualified RC Technicians can release personnel or material from the RCA using a frisker.

ED Log Out (PE-10) It will be your responsibility to log-off of the assigned RWP/ALARA Task. Insert your ED into the reader and follow the computer prompts. Do not remove the ED until you receive a prompt indicating that you have logged out successfully.

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INDUSTRY EVENTS SOER 01-01 A number of unplanned radiation exposure events have occurred at nuclear power plants across the world in recent years. The objective of SOER 01-01 is to review these events, draw out the common learning lessons, and provide recommendations for nuclear power plants to adopt in order to reduce the likelihood of any similar events. Several issues have been identified as contributing factors for these events; Administrative Controls, Human Performance, Training, Operating Experience and the Importance of Radiation Protection. The following events have been chosen from many industry events to illustrate the types of situations leading to overexposure. As you read them, consider: Could this be me? Event 1 March 1999 Tricastin (U1), PWR - France U1 was shut down for a 10-year inspection. At the beginning of the shutdown period, two flood lamps were temporarily installed in the reactor pit room (area under the reactor vessel) which is classified as a high radiation area or Red Zone. Near the end of the shutdown period, a containment tightness test was to be performed. All fuel was off-loaded and in-core instruments (thimbles) were retracted, resulting in radiation dose rates in the reactor pit room of approximately 500 to 800 rem per hour. A radiation protection department technician was assigned to make sure that the flood lamps were removed prior to the test. He was not authorized to enter into the room but was supposed to just look into the room. He noted that the flood lamps had not been removed and took the initiative to enter the room and remove them. This took approximately three minutes. Upon exiting, the technician noted that his EPD indicated about 8 rem and immediately informed supervisors and managers. Development of the technicians film badge revealed he had received an exposure of approximately 34 rem.

Event 2 November 1998 Zaporozhye (U1/3), Ukraine During radiographic testing of turbine hall piping welds, which were in scheduled maintenance outage, control was lost over a gamma-ray source in the Gamma Read radiographic device when the source failed to fully retract into its shielded container. Due to a failure of the gamma-radiographic device, 14 plant staff were exposed to doses exceeding 24 hourly limits. At the same time, 3 gamma radiographers from the plant metal testing laboratory received radiation doses exceeding a years maximum reference level.

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Event 3 March 1997 Koeberg (U2), PWR South Africa A quality control inspector unintentionally entered the in-core detector penetration room to perform an inspection on the detectors. He used two maintenance personnel to assist him in opening the door leading to the room, as he assumed that this was the in-core detector storage room. Once inside the room, he realized that he was in fact in the wrong room. He then left the room, closed the room door, and noted that his dosimeter was off-scale high. The inspector and maintenance personnel received an unplanned exposure of 3.2 rem, 1.76 rem, and 260 mrem, respectively, due to this mistake.

Event 4 May, 1997 Koeberg (U1), PWR South Africa U1 was operating at 100% power when a high differential pressure was observed on the spent fuel pool demineralizer filter. The flow to the filter was reduced in anticipation of a filter change. As a result of weaknesses in the use of prior operating experience and in the pre-job radiation survey, the dose rate on the filter was identified as 200 mrem per hour instead of 200 rem per hour. During the removal of the filter, three plant personnel unknowingly received unplanned dose which exceeded the legal annual dose limits.

Event 5 April 1997 Calvert Cliffs (U2), PWR Maryland Calvert Cliffs, U2 was in a refueling outage when spent fuel pool diving operations were performed to replace a magnetic proximity switch on the fuel transfer carriage. The diver left the approved diving area, traveled about 20 feet to within approximately 5 feet of an area reading 12,000 rem per hour as a result of a large group of recently discharged spent fuel assemblies, and received an unplanned whole body exposure of 270 mrem. Breakdown of multiple barriers resulted in the diver attempting to perform a canceled item in the work scope that was outside the surveyed, approved work area. Taking prompt action in response to an alarm on one of the multiple remote reading dosimeters attached to the diver, a radiation protection technician directed the diver to leave the pool immediately. This final barrier prevented a significant radiation exposure to the diver.

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Event 6 Narora (U2), India Unit 2 was in an annual shutdown. A radiological work permit was issued to carry out preventive maintenance of leak detectors (beetles) in the pump room, delayed neutron monitoring rooms, and fuel transfer rooms (north and south). Health Physics Unit cleared the radiation work permit in all areas except the fuel transfer rooms, where radiation fields and contamination level were high. Two contractor workers with elementary radiation protection qualification needing to be supervised for radiation work went ahead with the above work without the knowledge of the supervisor who issued the radiation work permit. After completing the job in the north fuel transfer room and confirming the dose received as expected, they proceeded to the south fuel transfer room unaware of the high radiation field in the area. They started work in the room. After working in the room about 15 minutes, they checked their pocket dosimeters and found they were off-scale high. Subsequent reading of their TLDs indicated they had received doses of 12.48 rem and 7.6 rem, respectively.

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GUIDANCE TO PERSONNEL CONCERNING NRC INSPECTIONS AND INVESTIGATIONS This guidance is being distributed to ensure that all personnel are aware of their responsibilities and rights during NRC inspections and investigations. Please review this information carefully and contact your supervisor if you have any questions. In order to fulfill its responsibility to protect the public health and safety, the NRC staff continuously inspects licensed nuclear power facilities. It is Progress Energys policy to cooperate fully with the NRC at all times. During the course of these inspections and related investigations, an NRC representative may seek to speak with you or other personnel privately. When you do speak to the NRC, your statements must be completely truthful and accurate. Making a deliberately false statement to an NRC representative (even orally) is a basis for disciplinary action, for enforcement action by the NRC, and may be a federal crime. Even an inadvertent false statement can subject you and the Company to an NRC enforcement action. There are two basic situations in which the NRC staff may ask to speak with you. First, during routine or special "inspections" of the plant or other licensed activities, an NRC inspector may want to discuss with you plant activities in which you are or have been involved. This is the most common situation. Second, if the NRC has a concern about possible wrongdoing at a plant, it may initiate an "investigation." In this situation, the NRC's Office of Investigations (or "OI") sends trained investigators (rather than technical inspectors) to interview particular employees, typically in a fairly formal setting. It is not unusual for two investigators to conduct such an interview together, and they may ask you to sign a written statement during the interview. You should ask the OI investigator for sufficient time to review the statement (such as asking to take it home overnight) so that you may ensure completeness and accuracy. You should also ask the OI investigator for a copy of any written statement before you agree to sign it. If you are to be questioned by an OI investigator, you have a right to ask that an attorney or other advisor knowledgeable in NRC investigative practices be present on your behalf. An experienced advisor will be able to clarify confusing questions, advise you as to any matters that may be especially sensitive to you, and assist you in reviewing any written statement and discuss it with you prior to signing it. The key point is that the statement be complete and accurate. If you are a Progress Energy employee and want to have an attorney present with you when you are questioned by OI, Progress Energy will provide you with an attorney at no cost to you. If you are a Progress Energy employee, you should contact your supervisor for further information on obtaining an attorney to represent you. You are, of course, free to select a lawyer at your own expense without consulting Progress Energy. If you are not a Progress Energy employee, you should consult with the company that employs you to determine under what circumstances an attorney might be provided for you.

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CORPORATE HEALTH PHYSICS POLICY NGGM-PM-0002 It is the policy of the Progress Energy to develop, implement, and maintain sound health physics programs at each Company facility where radiation producing equipment and/or radioactive materials are used or stored. The radiation control programs shall ensure that radiation doses to Company personnel, contractor personnel, and the general public are maintained at levels which are as low as reasonably achievable (ALARA) and consistent with the Nuclear Regulatory Commission Regulations and with applicable state regulations. The line management at each of these Company facilities is responsible and accountable for the facility's health physics program. Radiation control personnel shall be assigned to assist line management in carrying out their responsibility to protect workers and the general public. Radiation control personnel shall have sufficient independence to ensure that proper health physics practices are not compromised by operational pressures. Furthermore, radiation control personnel shall have access to higher levels of management for the resolution of health physics concerns which cannot be resolved at a lower management level. All Company and contractor employees are personally responsible for maintaining radiation doses and releases of radioactive materials to unrestricted areas as far below specific limits as reasonably achievable, to minimize the creation of radioactive wastes, and to support the requirements of the Company's radiation control programs. Personnel who habitually or willfully disregard or violate radiation control procedures and practices will be subject to disciplinary action up to and including termination. The Radiation Control & Protection Manual shall be maintained as the controlling document for the Company's radiation control programs and shall set forth high level policies and standards for these programs. The radiation control programs at the Company's nuclear plants shall comply with this manual and in addition, meet the intent of the Institute of Nuclear Power Operations' "Guidelines for Radiological Protection at Nuclear Power Stations."

The goal of the Company is to maintain the annual integrated dose to its occupational workers and dose to members of the public resulting from the Company's activities ALARA. The design, maintenance, and operation of the Company's nuclear facilities shall be consistent with this goal. Modifications to existing nuclear facilities shall be designed and implemented in compliance with the radiation control programs to meet the ALARA objective. To support this goal and to allow management to conduct effective radiation control programs, the Company will commit sufficient resources in the form of facilities, equipment, and personnel to the programs. Personnel involved in the conduct of the radiation control programs, including general employees and contractors, shall be given adequate training and instruction to allow them to contribute to the programs.

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SELF-STUDY GUIDE REVISION LOG PLANT ACCESS AND RADIATION WORKER TRAINING Rev. No. 0-11 12 0 1 2 3 Date -Description/Reason for Change Previously controlled by HEEC, BNP will be responsible for the following revisions Incorporated supervisory FFD into worker GET; added high heels, STAR program, Orsers memo, updated NRC-Form 3, chemical control, and confined space entry certificate. Generic program based on INPO ACAD 93-009. This is an entirely new program and not a revision to the previous General Employee Training program. More detailed review of INPO ACAD 93-009 by BNP/RNP/HNP, proper placement of EAD, delete reference to medically trained personnel (page 31), cotton liner removal procedure change. Updated dosimetry terminology, hand geometry and swipe card reader, conservative decision making, environmental awareness for workers, OSHA standardized industrial safety information, cotton liner removal procedure change. Supervisor/Worker FFD Responsibilities, CBO, more specific Environmental Awareness Statement, Chemical Control Program, Foreign Material Exclusion Policy, NRC commitment to include statement on notification of NRC inspectors to plant, prohibited items, hand geometry and swipe card reader, escort responsibilities, contamination control, removal of items from an RCA. Supervisor/worker FFD responsibilities, upgrade FME policy, radio communications, reporting of injuries requiring medical treatment, NRC Form-3 (1/96), EPD log-off exemption, update instruction concerning risks from radiation exposure based on Reg. Guide 8.29, Rev. 1, (2/96). Revisions to FFD to include reference to Schedule I Drugs (NRC Letter 97-01), revisions to NGGC-2130 and 2140, enhance signs of impairment and effect of drugs, enhance guidelines for CBO intervention and follow-up, revise Clearance Tag procedure to include Operations and Personal clearance tags, move Radiation Effects on an Unborn Child and Table 1 from Reg. Guide 8.13 from RWT to PAT, define dpm levels for hot particles, include instruction for frisking hands before removing articles from SAM, enhance radwaste minimization information, delete Mr. Smiths Safety Message and replace with Mr. Cavenaughs Safety Message. Program Assessment to ensure continuing compliance with ACAD Add statement that CAT is part of RWT, delete supervisory responsibility to refer individuals to EAP, add Information Notice 99-08, clarify Preaccess testing requirements, add statement on responsible person for installing ground tags, clarify statement for chemicals brought on site, clarify radiography requirements, define mrad, delete statement concerning EPDs automatically calculating stay time, clarify exceptions for personnel who are exempted from logging off RWPs, revise definitions for High Rad Areas and Very High Rad Areas per RCPM revision, clarify DPW requirements per RCPM revision, include tagging instructions for Rad Material per HPS-NGGC-003 Review of ACAD 00-007 and NEI 95-04, add requirement for all supervisors to be badged to maintain supervisory FFD responsibilities, add OE 36803 Ref: FFD, enhance Human Performance Fundamentals, Revise Environmental Awareness Training current with EVC-CPL-001, include plant drawings and emergency phone numbers for BNP/HNP/RNP, enhance Heat Stress and Chemical Control per CHENGGC-0045, include use of fire retardant clothing, add definition for Teratogenic, clarify difference between EPDs and PICs, delete Glossary, update Nuclear Safety and Quality Concerns message from Scotty Hinnant, include safety message Ref: SAF-CPL-065, revise quality program section in accordance with NGGM-PM-0007,

09/01/93 04/01/94 10/01/94 05/31/95 12/15/95

08/31/96

08/31/97

6 7

08/21/98 11/15/99

11/01/00

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(Rev 19)

Rev. No. 9

Date

12/07/01

10

08/30/02

11

08/30/03

12

8/30/04

revise Employee Concerns program content, include practical exercise into GNB02N (delete GNB03N CAT), revise FME section per MNT-NGGC-0007. Description/Reason for Change Name change from CP&L to Progress Energy, change style/font to reduce volume, FFD testing definitions, notification of licensee for EAP candidate, enhance industrial safety section based on corporate safety policy revision, add information on radiopharmaceuticals, revise dosimetry to include accurate description of DMC 2000, implementation of Total Exposure, revised Employee Concerns Program policy, deletion of SOER 85-03 and implementation of SOER 01-01 Include CR-3 site map, emergency control room number, and TLD/Badge placement, reword FFD requirement for current Plant Access Trng, EAP service information and guidelines for intervention per procedural revision, revise cell phone usage definition, added OE 13236, added Security Briefing Information for Hostage Situations, corrected spelling, grammatical errors, added additional information for nonparticipating members during a fire drill, revised Clearance Holder responsibilities, added PEA/LED information, removed reference to HNP/RNP removing cotton gloves at RCA. Revise FFD to include revised NEI 03-04 BOP standards, change 60 day requirement to 30 day requirement for preaccess testing per SEC-NGGC-2140, title change; Occupational Health/Industrial Hygienist to Health and Safety, Included SAFER acronym to HPF section, enhanced communications section to include PA line use and new emergency phone numbers, revised site maps to include emergency assembly locations per NEI 03-04, Chemical Control Program per CHENGGC-0045, eliminated unnecessary wording in Purpose and Response section of QA Program, added objective to EP program to identify emergency assembly locations and recognize emergency alarms, removed Table 1 from Rad. Orientation section per revised Reg Guide 8.13 (Rev. 3, 1999), removed reference to PICs, revised Dosimetry section; changed from EPD to ED, removed reference to PICs, removed time alarm ref., revised alarm setpoint alarm response, included LED information for alarming dosimeters, deleted reference to hard copy RWPs, added OE 15845, revised SAM use instructions, added OE 15655, deleted ref. to general/specific RWPs, added instructions for computerized RWP access, deleted NRC Report 98-300, revised Corporate Health Physics Policy per NGGM-PM-0002, corrected typographical errors, reformatted to reduce size Revise FFD to include revised NEI 03-04 CBOP standards, changed CBOP to BOP (SEC-NGGC-2101), add Plant Status Control to Plant Admin. Section, enhance FME; proper use of FME covers, revise emergency phone # for BNP, revise PA use statement for all sites, remove Environmental Policy as objective and relocate to back of SSG, revise reference document for hart hat use to ANSI Z89.1-1997, revise ECP program policies, enhance definition of Owner Controlled & Protected Area, change pat-down to hands-on search, include information on camera use inside PA, revise escort responsibilities during site evacuation [HNP], delete reference to Loss of Life pertaining to personal habits, i.e., smoking vs working in nuclear industry, revised response to dose and dose rate alarms per RC Mgt peer group, added AR 97609, remove reference to HT for Hot Tools [CR-3], revised wording for SAM usage per RC Mgt Peer Group, revised individual responsibilities prior to entering WBCM [CR3], revised CA practical exercise to generically cover usage of cloth or paper anti-cs

RWTSSG

53

(Rev 19)

Rev. No. 13

Date

08/31/05

14

06/22/06

15

11/17/06

16

08/17/07

17

08/28/08

18

05/12/10

19

11/18/10

Description/Reason for Change Remove percentage numbers from Negative Impact of Substance Abuse section make generic to avoid conflict with constantly changing statistics, update FFD Company policy to reflect procedural changes, Make statement on pg 24 deteriorating conditions generic to apply to PWR and BWR, separate RC/Chemistry organizations, clarify housekeeping responsibilities and conservative decision making, revise no transmit zones per CSP-NGGC-2600, additional asbestos info per AR 127132, visitor badge definition, Protected Area access, Prohibited items per SEC-NGGC-2166, visitors allowed per escort, included Contamination examples in Rad. Orientation section, Use of Dosimetry removed CR-3 specifics, added instruction on retrieval of ED from rack/bin, AR 133831, enhanced WBCM use and added CR-3 specific information, removed references to magenta tools, LaSalle Rad Safety Violation, simplified RWP types Include specific information for reporting traffic violations, clarify that workers should notify site supervisor in the event of an accident (AR 186634), add conversion from dpm to mrad (AR163844), revise expectation for removing items from the RCA, add statement ..not process TLDs/EDs through Security x-ray, revise HNP site layout Spelling, editorial changes, change blue or green description of fire retardant wood to blue/green, describe alternate method of badge display, update prohibited items per procedure, enhance visitor violation rule, change administrative dose rule, delete reference to TLD requirement in Protected Area, include information on sensitivity of WBCM, simplified definition of DAC, clarified RWP definition Enhance safety posting section to include rigging and/or lifting activities as one of the potential safety hazards, add reference to SOER 06-01, add OPS-NGGC-1301 reference to Equipment Clearance section, update camera policy per SEC-NGGC2166, enhance log in/log off to indicate that the computer screen will be green if login/log-out is successful, enhance PC section to include the use of Orex clothing and remove reference to hard hat covers. Add information on FFD request for additional information on sleep medication, upgraded RNP map, deleted OE on back sprain, enhanced information on door closures, enhanced statement on removal of outer garments when entering Security checkpoint, add OE 26731 (Digital Camera Use in the Control Room), vehicle use by unescorted personnel, update prohibited items list per SEC-NGGC-2166, add response check to hand-held frisker, revised radiological postings per HPS-NGGC0003, enhance use of labcoats in CAs, add requirement to frisk TLD, ED, and hardhat Change frisker minimum background cpm to 300 cpm per HPS-NGGC-0013, move Boric Acid event (Davis Besse SOER 02-04) from PAT to RWT and enhance accompanying information. Separate PAT and RWT study guides. Remove reference to ARW (Advanced Radiation Worker), add work gloves to items that personnel can SAM. Update ED Log In/Log Out to support implementation of the Windows Access Control (WACs) System; add optional use of orex liners

RWTSSG

54

(Rev 19)