RADIATION WORK PERMITS HPT

TERMINAL OBJECTIVE n Upon completion of this course, the participants will demonstrate their knowledge and understanding of the information presented during RADCON Technician training by obtaining a score equal to or greater than 80% on a written examination. The information presented in this lesson plan may be part of an overall exam or be the only information for which the student is examined. (OH-2)

ENABLING OBJECTIVES n Define the terms listed in the definitions section of this lesson plan. n Identify the procedures used to control work in radiologically controlled areas and prepare and administer Radiation Work Permits (RWP). n State the measures used to control work in radiologically controlled areas.

ENABLING OBJECTIVES n Determine the criteria requiring the use of a RWP. n Determine when the requirements for a RWP may be waived. n State the requirements for compliance with a RWP

ENABLING OBJECTIVES n Determine the responsibility requirements for individuals entering the RCA to work on a RWP. n State the types of RWPs. n State the different levels of status of a RWP.

ENABLING OBJECTIVES n Discuss the preparation, issuance and approval requirements of a RWP. n Discuss the steps to be taken when a RWP is revised. n Determine the administrative requirements for the use of a RWP, the training requirements for RWP use, RADCON verbal authority during job coverage while using a RWP, and the steps taken during when RWP approval requirements are waived.

ENABLING OBJECTIVES n State the actions necessary when a RWP is terminated. n Discuss the necessary steps to take when the RADCON Computer Systems is not available for RWP entry and exit documentation.

Introduction n In this lesson you will learn the requirements for Radiation Work Permits (RWPs) and the administrative processes for requesting, obtaining and using them. These permits establish the radiological controls and precautions to be followed while performing authorized work in radiologically controlled areas (RCA).

Introduction n RWPs are administered via the RADCON Computer System. The specific methods for implementing the various elements of the permit are contained in the system user’s guide and site implementing procedures.

DEFINITIONS n Airborne Radioactivity Area – A room, enclosure or area in which airborne radioactive materials, composed wholly or partly of licensed material, exist in concentrations – (1) in excess of the derived air concentrations specified in Appendix B of 10CFR20, or (2) to such a degree that an individual present in the area without respiratory protective equipment could exceed, during the hours an individual is present in a week, an intake of 0.6 percent of the annual limit of intake or 12 DAC hours.

DEFINITIONS n ALARA Preplanning Report (APR) - Documents evaluations of the radiological conditions and potential radiological hazards associated with a job, establishes man-hour and exposure estimates, and provides precautions, recommendations and requirements to assure exposures will be ALARA. n Annual Limit of Intake (ALI) – The derived limit for the amount of radioactive materials taken into the body of an adult worker by inhalation or ingestion in a year.

DEFINITIONS n Bioassay Area – Any airborne radioactivity area and any other area where unencapsulated radioactive material is present in a form and quantity such that the area has significant potential for becoming an airborne radioactivity area. Entry into bioassay areas is governed by RWPs. n Contaminated Area – A radiologically controlled area in which uncontained, removable radioactive material (contamination) is present in excess of the levels specified in SPP-5.1.

DEFINITIONS n Derived Air Concentration (DAC) – The concentration of a given radionuclide in air which, if breathed by the reference man for a working year of 2000 hours under conditions of light work (inhalation rate of 1.2 cubic meters of air per hour), results in an intake of one ALI. For modes of intake other than inhalation, an equivalent DAC-hr shall be determined and included as DAC-hrs in the individual’s dose tracking record. The equivalent DAC-hr is equal to the number of hours of exposure at the DAC (i.e., DAC-hrs exposure which would result in an equivalent intake of radioactive material as has been observed in a particular exposure incident). This permits the comparison of intake by inhalation with other modes of intake (ingestion, injection, absorption, etc.) DAC-hr is equal to one ALI.

DEFINITIONS n High Radiation Area – An 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 millirem in 1 hour at 30 centimeters from the radiation source or 30 centimeters from any surface that the radiation penetrates. n Individual Monitoring Devices (individual monitoring equipment) – Means devices designed to be worn by a single individual for the assessment of dose equivalent such as film badges, thermoluminescence dosimeters (TLDs), pocket ionization chambers and personal (lapel) air sampling devices.

DEFINITIONS n Protective Clothing – Clothing such as coveralls, gloves, shoe covers, etc., used to prevent personnel contamination. n RADCON Computer System – A computerized radiological data management and control system which includes radiation work permits, surveys and control of access to the radiologically controlled area.

DEFINITIONS n RADCON Coverage – Normally defined as the actual presence of RADCON at the job location. Coverage can be continuous, intermittent or none depending upon the radiological requirements of the job. In some special cases, RADCON coverage may be provided with remote surveillance and monitoring equipment. n Radiation Work Permit (RWP) – A document for controlling the radiological aspects of work.

DEFINITIONS n Radiologically Controlled Area (RCA) – An area within (or that may coincide with) the Restricted Area (defined in 10CFR ) boundaries that may have increasing radiological hazards. n Removable Contamination – Contamination which may be easily transferred to personnel or surfaces through casual contact.

DEFINITIONS n Total Effective Dose Equivalent (TEDE) – The sum of the deep dose equivalent (for external exposures) and the committed effective dose equivalent (for internal exposures). n Very High Radiation Area – An 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 1 hour at 1 meter from any source that the radiation penetrates.

Procedures n TVAN RCDP-3 Administration of Radiation Work Permits n TVAN SPP-5.1 Radiological Controls n BFN RCI-9.1 Radiation Work Permit Preparation and Administration n SQN RCI-14 Radiological Work Permit Program n WBN RCI-100 Control of Radiological Work

n RWP system documents conditions and prescribe appropriate protective requirements for work in radiologically controlled areas. n Site RADCON establishes entry requirements. n Work area is surveyed before the start of work and/or as appropriate during work. n Protective clothing and equipment, individual monitoring devices and work limitation requirements are specified for all workers entering the area. Control of Work in the RCA

n RWPs may be required for work in radiologically controlled areas. n RWPs shall be required for areas that meet or exceed the following: RWP Criteria Work assignments where it is anticipated employees may receive a deep dose equivalent > 50 mrem in any regular workday or when extremity monitoring is required. Entering a High Radiation Area or Very High Radiation Area. Entering a Contaminated Area.

n RWPs shall be required for areas that meet or exceed the following: RWP Criteria Entering an Airborne Radioactivity Area. Breaching a contaminated system or component. RADCON discretion to provide adequate radiological control. For radiographic examination conducted at licensed nuclear facilities.

n RWP requirements may be waived during a declared emergency. Control shall be in accordance with TVAN RCDP-3. Waived Requirements for RWPs

n Each worker shall be responsible for awareness and compliance with the requirements of a RWP and for meeting the prerequisites for RWP entry. RWP Compliance

n Entries into plant RCAs including RCAs outside the plant (e.g., radwaste yard, stack, etc.) may require the use of a RWP at RADCONs discretion. n All workers shall check with RADCON prior to starting any work in any RCA. It is the responsibility of the individual controlling the work (i.e., foreman, supervisor, etc.) to assure this requirement is met. Requirements for a RWP

n 1.General RWPs – RWPs written for routine work evolutions that contain no special requirements. n Specific RWPs- RWPs written for job specific work evolutions in which special requirements or precautions are specified. n NOTE: Site specific restrictions apply to the definitions of the types of RWPs. Types of RWPs

Requesting a RWP  A task leader (e.g., engineer, job supervisor, planner, etc.) should request a RWP by completing a RWP request.  Sufficient detail must be included to provide RADCON with the information necessary to evaluate the hazards associated with the job. NOTE: RWP requests are not normally required for General RWPs.

n Pre-Active – The RWP is in the process of being written or approved. n Active – The RWP has been approved and access to a RCA may be attained through the RWP. n Suspended – Access to a RCA is prevented under this RWP although the RWP may be re- activated. n Terminated – The RWP may never be used again for entry into the RCA. Status of RWPs

n All RWPs will be prepared by ANSI qualified RADCON personnel. n RADCON provides dose rates and man-rem estimates based on survey information and the anticipated duration of the job. n Protective requirements will be determined using survey information. If current survey information is not available, historical data may be used. n A TEDE evaluation, in accordance with SPP-5.10, is required when an activity may require the use of respiratory protection. Preparation, Issuance and Approval of RWPs

n May be required when radiological conditions or job scope changes, which increases or decreases protective requirements. n If radiological conditions have increased, the RWP may require more levels of approval, an APR or a revised APR. Approval of revised RWPs requires the original or previous revision to be terminated. n Personnel must be rebriefed on requirements and radiological conditions of the area. As a minimum, they must be informed of changes and provided with a brief explanation of the change. Revising RWPs

n RADCON will control the use of RWPs by maintaining a RWP briefing list via the RADCON computer system. n Anyone who signs in on an RWP must review and understand the requirements of the RWP before using it. Use of RWPs

n Individuals who use RWPs must receive a briefing. During the briefing, they must be given the opportunity to ask questions concerning anything they don’t understand. The frequency of briefings shall be determined by the job scope and radiological hazards. In addition, the briefing should contain a thorough explanation of the scope of the job, radiological conditions, contingency plans, hold points, stop work authority of RADCON and, if applicable, ALARA preplanning requirements. Use of RWPs

n By signing or electronically entering the RWP via the RADCON computer system, they are demonstrating: Use of RWPs they have been briefed. they have had an opportunity to ask any questions, as needed. they understand the RWP requirements. they will comply with the RWP requirements, as well as any verbal instructions given by RADCON.

n Workers must ensure they are using the correct RWP for the work to be performed. n Individuals must have Radiation Worker Training and a current whole body count (for entries into bioassay areas), to use a RWP. n RADCON may require additional protective requirements for certain aspects of a work activity without revising the RWP. RADCON supervision may also authorize short-term deviations without revising the RWP which will be documented in the RADCON Computer System RWP logbook. n RADCON may terminate the use of a RWP due to safety concerns, housekeeping, or changes in radiological conditions or job scope. Use of RWPs

n The use of HIS-20 to log RWP entries and exits may be suspended during emergency conditions. In this case, the Shift Manager authorizes immediate entry to an area. If the RWP approval requirement is waived, RADCON and the personnel escorted by RADCON must comply with radiation protection procedure for entry into high radiation areas. n The RWP must be completed when the emergency is over. At the completion of the exempt work, actions will be taken to document, in the RADCON Computer System, the work, entries, exits, dose accrued, etc. Per Watts Bar Tech Specs and FSAR, this does not apply. Use of RWPs

n scope of work n radiation, contamination and airborne radioactivity n internal and external dose action levels n location of hot spots n personnel authorized to use the RWP n dosimetry requirements Information Required on a RWP

n respiratory protection requirements n protective clothing requirements n period during which the RWP is valid. n radiological protection coverage, surveys, hold points and notification requirements n special precautions, restrictions or limitations Information Required on a RWP

n RADCON will perform the closure of a RWP after the work has been completed or if a RWP is being revised. The task leader will inform RADCON that the work is complete. n Perform a post job critique. The RWP, problems, work performance, total exposure versus the estimate, protective requirements, radwaste volume generated, good or bad practices and lessons learned should all be considered in the critique and documented in the RADCON Computer System RWP logbook. Terminating RWPs

n During periods when the RADCON Computer System is unavailable for implementing the RWP program, a manual backup method shall be provided until the main system is returned to service. The local mode for the system should normally be used when the main system is experiencing a problem or outage. Routinely, the local mode provides adequate interim backup. Manual Backup for the RADCON Computer System

n If the system local mode also becomes unavailable or unsuitable, then a hard copy backup method should be used and as a minimum will have a RWP and a RWP timesheet or Dose Card. Information documented by the manual hard copy method will be entered into the system as soon as possible upon system return to service. The first priority will be RWP entry data. Manual Backup for the RADCON Computer System