1. Introduction to Reg Guide 8.8, 8.10 the Significant Determination Process and EN-RP-110 ALARA Program ALARA indoctrination for Station ALARA Committee / ALARA Sub Committee Members and Alternates

2. 2 Indoctrination EN- RP-110 ALARA Program requires the following:  ALARA Managers Committee members and ALARA Sub-Committee members are required to be indoctrinated to the requirements found in Reg. Guide 8.8, Reg. Guide 8.10, EN-RP-110, and Significant Determination Process (SDP) on the ALARA program.

3. 3 Indoctrination This PowerPoint will take you through the main points found in Reg Guide 8.8, 8.10, and the Significant Determination Process as it applies to ALARA and EN- RP -110, The ALARA Program. As member of either committee, it is important to understand some of the regulatory driving forces that are behind As low As Reasonably Achievable. Copies of the Regulatory Guide 8.8 and 8.10 and Significant Determination Process for ALARA have been included for a review for additional details and insights that the regulator will gather information from. In addition, obtain a copy of EN-RP-110 ALARA Program and review it.

4. 4 NRC’s Discussion What mitigates dose?  Effective design of facilities  Selection of equipment for systems that contain, collect, store, process, or transports radioactive materials  Station and equipment layout Shielding Adequate space for ease of maintenance and other operations that can permit the task to be completed more quickly

5. 5 NRC’s Discussion Continued  Remote handling tools  Moving components to a remote location to work on Sources of dose that lead to exposure  Maintenance  Radwaste Handling  In-service inspections  Refueling and non routine operations  Products of erosion (i.e. 1 CRUD) 1 Chalk River Unidentified Deposits

6. 6 NRC’s Discussion Continued CRUD becomes mobile and is activated, constitutes an important source of radiation with respect to station personnel CRUD is accumulated in and transported by coolant  Examples of CRUD, Co-58, Co-60, Mn-54, Zn-65, and Zr-95 CRUD can generally be reduced substantially by minimizing the formation of CRUD and by designing or modifying equipment to minimize locations where it can deposit and accumulate What is not ALARA  Limiting dose to an individual at a fraction of what is allowed, but would require more personnel to receive dose is not considered ALARA

7. 7 Regulatory Requirements In this next section you will read about regulatory requirements. As you read through this section, you will find that there are a number of building and system requirements that are associated with the initial design of the plant. In many cases the requirements do not appear to be applicable to a plant that has already been built. But keep in mind, as the plant undergoes modification or reconfigurations there are some requirements (principles) that are applicable none the less.

8. 8 Regulatory Position continued Maintain the annual dose to individual station personnel ALARA and Keep the annual integrated (collective) dose to personnel ALARA  How is this done?  Programs maintain station personnel radiation dose ALARA Maintain dose exposure ALARA in all phases of the station life Should be in written form (procedures,) Cover specific guidance found in Reg Guide 8.8

9. 9 Regulatory Position continued  Establishment of a program to maintain occupational Radiation Dose ALARA Management policy and commitment Reflect in written processes and procedures  Organization, Personnel, and Responsibilities. Upper level management support to implement the ALARA programs utilizing committee as one example with  Responsibility and Authority to  Ensure corporate programs are in place  Ensure effective measurements are in place  Ensure measurements are reviewed periodically

10. 10 Regulatory Position continued Responsibility and Authority Continued  Authority is in place to provide procedures and practices.  Resources are in place to support ALARA Plant Manager is responsible for all aspects of station operations, including onsite radiation programs. Responsibilities of the Plant Manager, with respect to a program to maintain occupational radiation exposure ALARA should include:  Ensuring support from all station personnel;  Participation in the selection of specific goals and objectives for the station

11. 11 Regulatory Position Continued Plant Manager Responsibilities Continued  Supporting the onsite Radiation Protection Manager (RPM) in formulating and implementing the station program in maintaining occupational radiation exposure ALARA  Expediting the collection and dissemination of data and information concerning the program to the corporate management The Radiation Protection Manager (RPM) onsite has a safety function and responsibility to both employees and management that can best be fulfilled if the individual is independent of station division such as operations, maintenance, or technical support whose prime responsibility is continuity or improvement of station operability of station responsibility Responsibilities include:  Participating in design revisions for facilities and equipment that can affect potential radiation exposures;

12. 12 Regulatory Position Continued Radiation Protection Manager Continued  Identify locations, operations and conditions that have the potential for causing significant exposure to radiation,  Initiating and implementing exposure control programs,  Develop plans, procedures, and methods for keeping radiation exposure of station personnel ALARA,  Reviewing and commenting on job procedures to maintain exposure ALARA,  Participating in the development and approval of training programs related to work in radiation area or involving radioactive materials,  Supervising the radiation surveillance program to maintain data on exposures of and doses to station personnel, by specific job functions and type of work,

13. 13 Regulatory Position Continued Radiation Protection Manager Continued  Supervising the collection, analysis, and evaluation of data and information attained from radiological surveys and monitoring activities,  Supervising, training, and qualifying the radiation protection staff  Ensuring that adequate radiation protection coverage is provided for station personnel during all working hours. Training and Instruction  Working with radioactive materials  Entering radiation areas  Rules for the station  Inform on the applicable Federal Regulations  Provide copies of the rules and regulations for those receiving the instructions

14. 14 Regulatory Position Continued Training and Instruction Continued  Training on the activities of those who work with radioactive materials or enter radiation areas  For those not entering the radiation area  They should receive sufficient instruction on why they cannot enter the radiation area or on handling radioactive materials Review of new or modified designs and equipment selections  Design concepts and station features should reflect consideration of the activities of station personnel such as maintenance, refueling, in-service inspections, process of radioactive waste, decontamination, and decommissioning that might lead to personnel exposure  Specifications for equipment should reflect the objectives of the ALARA program

15. 15 Regulatory Position Continued Facility and Equipment Design Features  Radiation resources within a nuclear power station differ appreciably with respect to location, intensity, and characteristics.  The magnitude of the dose rates that result from these sources is dependent on many factors including the facility and equipment design, layout, mode and length of operation, and radiation source strength and characteristic.  Access Control of Radiation Areas Dose rates at all locations should be estimated during station design,

16. 16 Regulatory Position Continued  Access Control of Radiation Areas Continued Consider personnel access, Provide controls to consider ingress and egress in the station, Extraordinary designs in place to prevent acute biological effects that could be received in a short time, Administrative controls to prevent inadvertent exposure or contamination to personnel, Provide features such as platforms, walkways, stairs or ladders that permit easy access to the areas in higher radiation areas

17. 17 Regulatory Position Continued  Radiation Shielding and Geometry Shielding should be designed using design basis assumptions  Shield design features should reflect the following consideration to maintain occupational radiation exposure ALARA:  Provide shielding between individual components that constitute substantial radiation sources and the receptors,  Utilize distance and temporary shielding where permanent shielding can not be added

18. 18 Regulatory Position Continued Process Instrumentation and Controls  Appropriate station layout and design features should be provided to reduce the potential doses of personnel who must operate, service, or inspect station instrumentation and controls.  Manually operated valves: Should have reach rods, Utilize remote operation of valves, Instrumentation, monitors, and controls  Locate readouts or control points in low radiation zones

19. 19 Regulatory Position Continued Process Instrumentation and Controls Continued  Instrumentation meets functional requirements Instrument design should consider:  Long service life,  Ease and low frequency of maintenance and calibration,  Low CRUD accumulation,  Operating experience used to consider replacements Minimize instrumentation that has minimal quantities of contaminated working fluid

20. 20 Regulatory Position Continued  Control of Airborne Contaminants and Gaseous Radiation Sources The spread of airborne contamination within the station can be limited by maintaining air pressure gradients and airflow from the clean areas to areas where higher potential for contamination exists. Periodic checks would ensure that the design pressure differentials are being maintained. Effectively design ventilation systems and gaseous Radwaste treatment systems that will contain radioactive material that has been deposited, collected, stored or transported within or by the system.

21. 21 Regulatory Position Continued  Control of Airborne Contaminants and Gaseous Radiation Sources Continued Auxiliary ventilation systems that augment the permanent system can provide local control of airborne contaminants when equipment containing potential airborne sources is opened to the atmosphere. Utilize existing duct work, by extending duct work to the location and connect to permanent system. Utilize portable HEPA equipment. Sources of Airborne contamination:  Machining of contaminated materials  Sampling stations for primary coolant or other fluids containing high levels of radioactive material can constitute substantial sources of airborne contamination.

22. 22 Regulatory Position Continued  Control of Airborne Contaminants and Gaseous Radiation Sources Continued Wet transfer or storage of potentially contaminated components will minimize air contamination.  Keep items wet.  CRUD control  Production of Co-58 and Co-60, which constitute substantial radiation source in CRUD, can be reduced by specifying, to the extent practicable:  Low nickel and low cobalt bearing materials for primary coolant pipe, tubing, vessel internal surfaces, heat exchangers,  Wear materials, and other components that are in contact with primary coolant.

23. 23 Regulatory Position  CRUD control Continued Utilize alternate materials for hard facings of wear materials of high-cobalt content should be considered. (e.g., do not use stellite seats) Considerations to improve CRUD  Use favorable geometrics and lubricant where practicable.  Continuously monitoring and adjusting oxygen concentration and pH in primary coolant above 250 0 F by using bright hydrogen annealed tubing and piping in the primary coolant and feed water systems  Cleanup of systems for removal of CRUD from the primary coolant during operations  Provide laminar flow and smooth surfaces for coolant and by minimizing CRUD traps in the system to the extent practicable.

24. 24 Regulatory Position Continued  Isolation and Decontamination Removes source from the equipment Design with ability to isolate and decontaminate to reduce the source of radiation. Design lines with slopes instead of straight horizontal runs. Take measures to contain contamination –utilize  HEPAs  Drainage control Utilize Radwaste component that treat fluids Utilize redundant systems so one system can be isolated and deconned while the other is operating Ensure clean and contaminated systems are not mixed and clean systems do not become contaminated

25. 25 Regulatory Position Continued  Isolation and Decontamination Continued Utilize smooth non-porous and free of crack material when designing equipment and components for easier decontamination. Utilize discharge points that provide enhanced mixing and avoid stagnation areas in the fuel pool. Utilize fluid jet or vacuum cleaner type agitators to help reduce the settling of CRUD on surfaces of the fuel pool system.

26. 26 Regulatory Position Continued Radiation Monitoring Systems  Central built in monitoring Systems  Areas and locations to consider Readout capability at the main RP access control point Placement of detector for optimum coverage of areas Circuitry that indicates component failure Local alarm and readout Clear and unambiguous readout Ranges adequate to ensure readout of the highest anticipated radiation level and to ensure positive readout at the lowers anticipated levels and Capability to record the readout of all systems

27. 27 Regulatory Position Continued  Resin and Sludge Treatment Systems Systems that store, transport, or process resins, and sludge handling slurries  Use larger diameter piping (to minimizing plugging)  Reduce number of pipe fittings  Avoid low points and dead legs in piping  Use gravitational flow to extent practicable  Minimize flow restrictions of processed materials  Pipe bends of at least five pipe diameters  Smooth interior pipefitting  Pressurized gas to blow down lines

28. 28 Radiation Programs Preparation and Planning  ALARA Planning  RWP Development Operations  RP Supervisor oversight  RP Job Coverage  Use of remote technology Post Operations  Debrief of work complete  Post job reviews

29. 29 Radiation Protection Facilities, Instrumentation and Equipment Counting room Portable instrument Personnel Monitoring Protective Equipment Support Facilities Implementations

30. 30 Reg Guide 8.10 NRC Staff believes all specific licensees should follow to keep occupational exposure to radiation as low as is reasonably achievable.

31. 31 Introduction Reg. Guide 8.10 under regulatory position states that “there are two basic conditions necessary in any program for keeping occupational exposure as far below the specified limits as is reasonably achievable. The management of the licensed facility should be committed to maintaining exposure as low as reasonably achievable and the personnel responsible for radiation protection should be continually vigilant for means to reduce exposure. “

32. 32 Regulatory Position Management should be committed to maintain exposure ALARA  Plant personnel should be made aware of managements commitment to keep occupational exposure ALARA Policy statements Management should periodically perform formal audits to determine how exposure might be lowered. Management should ensure that there is a well- supervised RP capability with well defined responsibilities.

33. 33 Regulatory Position Management Commitment … Continued  RP Staff Surveillance Programs are in place and audited to ensure programs are driving lower exposure. Understand the origins of the radiation sources in the plant. Looks for ways to reduce exposure Periodically review operational procedures that may affect radiation safety. Adequate equipment and supplies for RP.  Plant worker receive sufficient training  Modifications to operating and maintain procedure and to plan equipment and facilities should be made where they will be substantially reduce exposure at a reasonable cost.

34. 34 Significant Determination Process as it Applies to ALARA The significance determination process is a process by which the Nuclear Regulatory Commission utilize to assess a radiological safety event, which affects the site’s finding in radiation safety. This assessment is tied to how the site can receive a finding. Green White Yellow Red Reference – IMC-0609 Applicability The significance determination process (SDP) is designed to provide a means by which NRC inspectors and management can assess the significance of inspection findings related to worker health and safety from exposure to radiation from licensed or unlicensed radioactive material during routine operations of civilian nuclear reactors.

35. 35 Significant Determination Process as it Applies to ALARA Continued Read the attached IMC 0609 for more detailed explanation. Additional explanation  Under item 3 Definitions section B, 1. 0.02 of ALI is equal to 100 mrem internal dose  Step 6 discusses Shallow Dose Exposure (SDE) SDE limit is 50 Rem  Step 11 discusses Very High Radiation Area (VHRA) VHRA represents an area that has radiation dose levels of 500 RAD/hr at 1 meter

36. 36 Significant Determination Process as it Applies to ALARA Continued For the remainder of this section read the attached document  IMC 0609 Occupational Radiation Safety Significance Determination Process Read EN-RP-110 ALARA Program

37. 37 ALARA Indoctrination Upon completion of reading this PowerPoint, a review of the two regulatory guides 8.8 and 8.10, a read of IMC 0609 SDP and a read of the EN- RP-110, you will have met the following requirement.  ALARA Managers Committee members and ALARA Sub-Committee members are required to be indoctrinated to the requirements found in Reg. Guide 8.8, Reg. Guide 8.10, EN-RP-110, and Significant Determination Process (SDP) on the ALARA program.