TP-1 HPT Rev. 4 Page 1 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program ALARA As Low As is Reasonably Achievable

TP-2 HPT Rev. 4 Page 2 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Enabling Objectives - 1 Define ALARA & Describe Concepts Explain Stochastic & Nonstochastic Effects & Describe Differences State Aim of ALARA & How Achieved Identify Regulatory Basis for ALARA Define “Acceptable” and “Total” Risk Responsibilities for Implementing ALARA

TP-3 HPT Rev. 4 Page 3 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Enabling Objectives - 2 Identify the ALARA Committee and Functions State the ALARA Goal Setting Process State Criteria for ALARA Planning Report & Post-Job Report Identify Responsibilities for the Annual ALARA Report Identify Six Items in the Pre-Job Brief

TP-4 HPT Rev. 4 Page 4 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Enabling Objectives - 3 State Means to Reduce Cobalt Identify the Desired Type of Control List Four Exposure Reduction Techniques Identify Regulatory Basis for Change Evaluations State two Consequences of Removing Shielding Without Approvals

TP-5 HPT Rev. 4 Page 5 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Radiation Protection Radiation Protection is concerned with the protection of Individuals, their Progeny and Mankind as a whole, while still allowing necessary activities from which radiation exposure might result.

TP-6 HPT Rev. 4 Page 6 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Purpose of ALARA Minimize Risk as a Result of Exposure to Radiation or Radioactive Material to Employees and the Public to a Level that is As Low As is Reasonably Achievable (ALARA)

TP-7 HPT Rev. 4 Page 7 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program ALARA Make Every Reasonable Effort Maintain Radiation Exposures as far Below the Dose Limits as is Practical Consistent with Purpose of Licensed Activity Consider State of Technology and Economics vs. Benefits Provided

TP-8 HPT Rev. 4 Page 8 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program ALARA Goal Maintain ALL Exposures ALARA - Individual Exposures – Rem - Collective Exposures – Sum of Doses received by all exposed Individuals – Man-rem Don’t reduce individual exposure at the expense of population exposure.

TP-9 HPT Rev. 4 Page 9 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Acute & Chronic Doses Acute Radiation Dose – A relatively large dose of Radiation received in a short period of time. Chronic Radiation Dose – The sum of small radiation doses received repeatedly over long periods of time.

TP-10 HPT Rev. 4 Page 10 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Nonstochastic Health Effects Health Effects, the severity of which varies with the dose and for which a threshold is believed to exist. Example - Radiation-Induced cataract formation

TP-11 HPT Rev. 4 Page 11 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Stochastic Health Effects Health Effects that occur randomly and for which the probability of the effect occurring, rather than its severity, is assumed to be a linear function of dose without threshold. Examples – Hereditary effects and cancer incidence.

TP-12 HPT Rev. 4 Page 12 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Aim of Radiation Protection Prevent detrimental nonstochastic effects and limit the probability of stochastic effects to levels deemed acceptable.

TP-13 HPT Rev. 4 Page 13 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program To Achieve Aim: (1) Nonstochastic Effects – Set dose limits at sufficiently low values so that no threshold dose would be reached.

TP-14 HPT Rev. 4 Page 14 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program To Achieve Aim: (2) Stochastic Effects – Keep all justifiable exposures as low as is reasonably achievable, taking into account economic and social factors and ensuring that appropriate dose equivalent limits are not exceeded.

TP-15 HPT Rev. 4 Page 15 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Basis for ALARA Regulation: 10CFR “The licensee shall use, to the extent practical, procedures and engineering controls based upon sound radiation protection principles to achieve occupational doses and doses to members of the general public that are as low as is reasonably achievable (ALARA).”

TP-16 HPT Rev. 4 Page 16 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Guidelines for ALARA Regulatory Guides: -RG 8.8, Maintaining exposures at nuclear power stations ALARA. -RG 8.10, Guidance for maintaining occupational exposures ALARA. -RG 8.29, Risks from occupational radiation exposures.

TP-17 HPT Rev. 4 Page 17 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Acceptable or Comparable Risk The occupational dose limit for adult workers (5 rem/y), combined with the application of ALARA principles, provides a level of risk of delayed effects considered acceptable by the NRC (stochastic effects), or comparable to risks associated with other “safe” industries. (RG 8.29)

TP-18 HPT Rev. 4 Page 18 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Total Risk Concept In evaluating specific activities, the concept of “total” risk reduction should be considered. (RG 8.29) -Consider the sum of external and internal exposures.

TP-19 HPT Rev. 4 Page 19 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Total Risk Concept: Example The use of respirators can lead to increased work time in radiation areas, which increases external doses. The advantage of using respirators to reduce internal exposure must be evaluated against the increased external exposure.

TP-20 HPT Rev. 4 Page 20 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Components of ALARA Training Planning Cost-Benefit Analysis Implementation ALARA Suggestion Program

TP-21 HPT Rev. 4 Page 21 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Cost-Benefit Analysis Costs: -Equipment Dollars -Labor Dollars -Risk in Dollars of exposure received Benefits: -Dollars saved by use of ALARA -Exposure saved, Dollars Assign a value of $25,000 for each rem.

TP-22 HPT Rev. 4 Page 22 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Cost-Benefit Example Proposal to add shielding to piping Cost: -(equipment & labor) = $359, man-rem X $25,000 = $200,000 -Total cost = $559,000 Benefit: -Reduced dose: 0.95 man-rem/month for 2 year fuel cycle = 22.8 man-rem. -Total benefit = $570,000

TP-23 HPT Rev. 4 Page 23 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program ALARA Responsibilities - 1 Corporate Manager, Radiological and Chemistry Services -Recommend and Document ALARA Policy Radchem Manager -Administer site ALARA Program Each Individual -Seek methods to save or reduce man-rem exposure.

TP-24 HPT Rev. 4 Page 24 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program ALARA Responsibilities - 2 RADCON staffs: -Maintain ALARA dose tracking. -Review radiation exposures. -Prepare Annual ALARA Report. -Pursue reduction of occupational radiation exposures. -Promote ALARA attitude -Implement RADCON requirements

TP-25 HPT Rev. 4 Page 25 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program ALARA Responsibilities - 3 Each Individual should: -Seek methods to save or reduce man-rem exposure. -Comply with procedures & practices. -Report hazardous/changing condition -Minimize personal radiation exposure -Track individual dose status. -Avoid exceeding dose limits.

TP-26 HPT Rev. 4 Page 26 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program ALARA Committee Responsibilities Review effectiveness of ALARA program. Track ALARA goals. Review ALARA suggestions. Review ALARA planning documents for jobs exceeding 5 man-rem TEDE. Review exposure trends.

TP-27 HPT Rev. 4 Page 27 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program ALARA Committee Chaired by Site VP, Plant Manager or designee Members from: -RADCON- Modifications -Operations- Engineering -Outage- Maintenance -Nuclear Assurance -Training

TP-28 HPT Rev. 4 Page 28 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program ALARA Goals Objectives Objective – Minimize TEDE. Ensures continued awareness in radiological control. Established by functional areas and approved by Site VPs.

TP-29 HPT Rev. 4 Page 29 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program ALARA Goals Purposes Set organizational exposure goals. Set annual station man-rem goals. Goals for major outages or work events Goals for routinely performed operations. Emphasize administrative dose levels. Incentives for improving performance. Focus attention at all levels of ALARA.

TP-30 HPT Rev. 4 Page 30 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Setting ALARA Goals Identify the task, components, sources. Identify number of workers & time. Review radiation survey results. Review past history. Develop exposure estimate. Identify exposure reduction potential. Establish dose/dose rate action levels.

TP-31 HPT Rev. 4 Page 31 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program ALARA Planning Report Form SPP-5.2.1, “Preliminary Radiological Impact/Evaluation Checklist.” Issued when plant specific criteria met, for example when TEDE for a specific task expected to exceed 1 man-rem.

TP-32 HPT Rev. 4 Page 32 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Post-Job Report Required if: -Pre-Job Report was required, -Dose exceeds estimated dose by 25 percent or greater, -TEDE exceeded 1 man-rem.

TP-33 HPT Rev. 4 Page 33 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Annual ALARA Report Submitted by RADCON to Site VP Includes: -Comparison of ALARA Results with ALARA Goals. -Comparison of ALARA Results with Results in previous years. -ALARA Goals for coming year.

TP-34 HPT Rev. 4 Page 34 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Pre-Job Briefing Conducted when TEDE expected to exceed 1 man-rem. Incorporates appropriate ALARA considerations. Attended by all personnel directly involved in the work. Scheduled as near as possible to start of job.

TP-35 HPT Rev. 4 Page 35 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Pre-Job Brief Contents - Radiological (1) Review of applicable procedures. Dose rates, Contamination levels, etc. Access routes to & from work site. Areas to be avoided. High radiation areas & hot spots. Location of low dose rate areas. Special radiological limitations/controls

TP-36 HPT Rev. 4 Page 36 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Pre-Job Brief Contents – Radiological (2) Hold Points. Stay Times. Maximum dose limits. Maximum dose rate limits. Operating Experience/Lessons learned. ALARA goals for the job or task. Potential problems & contingency plan

TP-37 HPT Rev. 4 Page 37 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Pre-Job Brief Contents – General What are we going to do? What is the Worst Thing that could happen? What are the Critical Steps? What if Mistakes happen, especially at Critical Steps? What are the Error Likely Situations? What are the Safety Concerns? Operating Experiences

TP-38 HPT Rev. 4 Page 38 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Post-Job Briefing – Radiological Review factors affecting job performance or exposure. Identify problems encountered. Review radiological exposures & identify factors leading to increases or decreased from expected. Identify corrective actions.

TP-39 HPT Rev. 4 Page 39 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Post Job Briefing – General (1) Any Recommended Changes? Any Unexpected Aspects or Occurrences? Task Accomplished with Expected Results? Any Enhancement to Plant Documentation Warranted? Planning & Scheduling Optimized to Reduce Human Errors?

TP-40 HPT Rev. 4 Page 40 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Post Job Briefing – General (2) Was Preparation Adequate? Lessons Learned Identified? Needed Supervision Support Provided? Any Human Factor Issues, Hindrances to Work Observed? Training for Job Adequate & Effective?

TP-41 HPT Rev. 4 Page 41 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Radiation Exposures Major portion of radiation exposures from: Maintenance Radwaste handling In-Service inspections Refueling Nonroutine operations

TP-42 HPT Rev. 4 Page 42 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program ALARA Program Procedures TVAN RCDP-1 Sets policy to ensure risks from ionizing radiation are ALARA. TVAN SPP-5.2 Establishes ALARA Program and outlines responsibilities.

TP-43 HPT Rev. 4 Page 43 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program ALARA Responsibilities Senior VP, Nuclear Operations and VP, Engineering & Technical Services Establish controls to incorporate:

TP-44 HPT Rev. 4 Page 44 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program VPs Establish Controls For: Evaluate Design & Design Mods to: -Determine Radiological Impacts -Achieve Cobalt Reduction Temporary Shielding Analysis ALARA Walkdowns Consider Occupational Radiation Doses

TP-45 HPT Rev. 4 Page 45 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Design Functions Mechanical Design Standard DS-M Addresses the Concept of ALARA in Plant Design Activities

TP-46 HPT Rev. 4 Page 46 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Design Standards Include: (1) References to Radiological Requirements of Plant Specific Restrictions or Radiological Technical Specifications. Methods to Minimize Source Terms Control of Fuel Integrity ALARA Conditions of Reg Guide 8.8 ALARA from Effluent Releases

TP-47 HPT Rev. 4 Page 47 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Design Standards Include: (2) Radiological Control Impacts of Design Changes Radiological Impacts Regarding: -Changes in Zoning, Shielding, etc. -Source Term or Chemistry Changes -Other Systems or Adjacent Areas Steps to Reduce Impacts of Cobalt

TP-48 HPT Rev. 4 Page 48 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Cobalt Reduction Use of Low Cobalt Materials for Piping and Equipment in Contact with Primary Coolant. Eliminate Use of Cobalt-Containing Materials for Parts or Components of Valves (e.g. Valve Trim, Seats, Pins) in Flow Path to Reactor Core.

TP-49 HPT Rev. 4 Page 49 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Impacts on ALARA - 1 Access Control to Radiological Areas Shielding -Labyrinth Entrances for Access -Permanent Shielding -Temporary Shielding Instruments & Controls -Location -Remote Operation

TP-50 HPT Rev. 4 Page 50 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Labyrinth Shielding

TP-51 HPT Rev. 4 Page 51 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Penetration Shielding

TP-52 HPT Rev. 4 Page 52 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Impacts on ALARA - 2 Control Airborne Contamination -Maintain Pressure Gradients -Use Filtration Control “Crud” Buildup Potential Activation Produces Contributing to Crud Buildup Include: C0-58, Co-60, Mn-54, Zn-65, & Zr-95

TP-53 HPT Rev. 4 Page 53 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Controlling Crud Use “Y” Pipe Joints, Not “T” Joints (Laminar Flow) Rounding Pipe Bends Use of Crud Traps or Filters Smooth Welds Use of Low Cobalt Materials Flush Lines to Remove Crud

TP-54 HPT Rev. 4 Page 54 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Desired Radiological Control Engineering Controls are Given Precedence over Administrative Controls in Both Facility Design and Operations

TP-55 HPT Rev. 4 Page 55 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Exposure Reduction Source Removal or Reduction Reduce Exposure Time Increase Distance from Sources Provide Additional Shielding

TP-56 HPT Rev. 4 Page 56 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Source Removal or Reduction Replace Filters or “Crud” Traps Flush Crud from Piping Decontaminate Surfaces Isolate Contamination -Glove Boxes -Tents -Confine to a Room or Building -Reduce Resuspension

TP-57 HPT Rev. 4 Page 57 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Glove Box? ENSURE: Effective Communications Self- Checking

TP-58 HPT Rev. 4 Page 58 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Contamination Control WBN 5-Path Drive

TP-59 HPT Rev. 4 Page 59 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Contamination With High Radiological Risk Work Activities Include: Use of Explosives Grit Blasting, Grinding, Burning, Welding Spalling (e.g. Concrete) Use of Volatile Solvents Cleaning with Compressed Air Refueling Work

TP-60 HPT Rev. 4 Page 60 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Contamination With Moderate Radiological Risk Work Activities Include: Mechanical Cutting (e.g. Saw) Handwork with File or Stone Emery Hydrostatic Testing Chemical Cleaning Decontamination, Damp or Wet Purging of Contained Systems Machining (Cutting Tools)

TP-61 HPT Rev. 4 Page 61 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Contamination With Low Radiological Risk Work Activities Include: Mechanical Work (Unbolting, Torquing) Cleaning, Vacuuming, Housecleaning Lubricating (Greasing or Oiling) Painting Surveillance (Includes Job Scoping and Measurement)

TP-62 HPT Rev. 4 Page 62 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Reduce Exposure Time - 1 Ensure Adequate Planning Ensure Proper Training Job Rehearsal Use Mockups Pre-Fabricate Materials Pre-Job Briefing

TP-63 HPT Rev. 4 Page 63 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Reduce Exposure Time - 2 Sequence Work to Remove High Dose Rate Items First. Provide Areas of Low Radiation Exposure in RCA. Increase Worker Comfort.

TP-64 HPT Rev. 4 Page 64 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Increase Distance Use Remote Handling Tools. Provide Areas of Low Radiation Exposure in RCA. Locate Instrumentation & Controls in Low Radiation Exposure Areas. Remove Equipment to Low Dose Rate Areas for Maintenance.

TP-65 HPT Rev. 4 Page 65 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Temporary Shielding Used Only When Other Methods not Practical Addressed in SPP 9.4 and SPP 9.5 Anyone May Request Shielding Approved by ALARA Supervisor Review by Site Engineering

TP-66 HPT Rev. 4 Page 66 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Temporary Shielding Factors to Consider Cost & Effectiveness Dose During Installation Personnel & Equipment Safety Static Loading on Floor & Components Length of Installation Interference with Other Jobs Prevent Bare Lead Contact w/Nickel

TP-67 HPT Rev. 4 Page 67 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Temporary Shielding Removal Temporary Shielding Should Never Be Removed Without Proper Approvals! -May Create Variance from Technical Specifications. -May Cause Personnel Exposure to High Levels of Radiation.

TP-68 HPT Rev. 4 Page 68 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Shielding Applications Shielded Pipe Chases Mobile Shields near Wall Penetrations Lead Brick in Chemistry Laboratory Lead Blankets over Piping

TP-69 HPT Rev. 4 Page 69 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program RVDL Shielding

TP-70 HPT Rev. 4 Page 70 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program CRD Pump Shielding

TP-71 HPT Rev. 4 Page 71 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Summary - 1 Required by 10CFR Purpose Aims Cost-Benefit Analysis Societal & Socioeconomic Factors

TP-72 HPT Rev. 4 Page 72 of 66 TVAN Technical Training Health Physics (RADCON) Initial Training Program Summary - 2 Acceptable & Total Risks ALARA Committee Each Individual Responsible Principles to Reduce Exposures Engineering Controls take Precedence