1.0 INTRODUCTION
1.1 Purpose
This document describes the Radiation Protection Plan for site work at the Boeing Michigan Aeronautical Research Center (BOMARC) Project in New Jersey. Project activities will be performed in compliance with the requirements of this document. The radiation protection plan provides for the radiological protection of personnel working on the site and ensures compliance with the applicable State, Federal and local regulations. This plan is designed to supplement the Health and Safety Plan (HASP). Where differences occur between this document and other applicable safety procedures, the more restrictive requirement shall apply.
In addition to compliance with the rules and regulations, CNS is committed to further reducing personnel exposures to radiation to levels that are as low as reasonably achievable (ALARA). CNS is committed to the radiation protection program and the ALARA concept embodied in the management directives on radiation protection. An effective radiation protection program and ALARA program is a cooperative effort among all individuals involved in the operation. Each individual working in radiologically controlled areas (RCAs) is required to adhere to established radiation protection and ALARA rules, regulations, and concepts.
1.2 Applicability
This procedure applies to all CNS personnel and subcontractors involved in the BOMARC project who work with radiation. This plan will be in effect until operations are complete at the site.
2.0 REFERENCES
2.1 CN-AD-019, "Chem-Nuclear ALARA Policy",
2.2 CN-AD-020, "Chem-Nuclear Health Physics Policy Manual,
2.4 CN-AD-026, "External Radiation Dosimetry and Dosimetry Records Policy",
2.5 CN-AD-032, "Radiological Training Policy",
2.6 CN-AD-033, "Field Project Administration and Control Procedure",
2.7 FS-RP-001,"Radiological Control Procedure for Field Projects",
2.8 FS-RP-002, "Portable Instrument Procedure for Field Projects",
2.9 CN-AD-005, "First Notification Reporting Procedure",
2.10 FS-AD-011, "Field Project Quality Assurance Records" and
2.11 CN-AD-036, "Chem Nuclear Systems Internal Dose Evaluation Program".
3.0 ALARA
ALARA stands for "As Low As Reasonably Achievable." It is CNS's policy to maintain radiation exposures to its employees, subcontractors, and the general public as far below the limits specified in 10 CFR 20 as is reasonably achievable. The ALARA program will be implemented through the training of employees and subcontractors, work procedures and radiation work permit use, good housekeeping practices, and, as necessary, use of personal protective equipment. Reference 2.1 provides guidance necessary for the implementation of the ALARA program.
4.0 RADIATION SAFETY ORGANIZATION AND RESPONSIBILITIES
CNS is committed to maintaining a radiation protection program for the protection of CNS staff, subcontractor personnel, visitors to the site, and the general public. Every individual involved in work within the restricted area has a responsibility for radiation safety and proper performance of assigned operational duties. This section describes these basic responsibilities.
4.1 Radiation Protection Organization
The organizational lines and responsibilities for radiation protection originate with the individual worker and go through the Site Certified Health Physicist (CHP) to corporate management.
4.1.1 Site Certified Health Physicist
The Site Certified Health Physicist (CHP) has overall responsibility for assuring that the work is conducted in accordance with the requirements of Federal and State regulations. The CHP has overall responsibility for safety and health. The CHP's radiological responsibilities are as follows:
4.1.1.1 Implementing and maintaining the radiation protection program, including applicable procedures.
4.1.1.2 Monitoring and evaluating the radiological status of the project and site. Routinely reporting the radiological status of the project to the CNS Corporate Health Physicist (CNS-HP).
4.1.1.3 Making recommendations for the control and elimination of existing and potential radiological hazards.
4.1.1.4 Issuing dosimetry devices and maintaining personnel dosimetry records in accordance with Reference 2.4.
4.1.1.5 Functioning in an advisory capacity to assist personnel in carrying out their radiation protection responsibilities.
4.1.1.6 Approving Radiation Work Permits (RWPs) and selecting protective clothing for radiological work.
4.1.1.7 Stopping work if conditions indicate that a potential exists for an unanticipated and or excessive radiation exposure to personnel or the general public or if an individual violates the radiation protection rules, regulations, or procedures in a manner that may adversely affect personnel working at the site or the general public.
4.1.1.8 Ensuring that radiation exposures are ALARA.
4.1.1.9 Assisting in providing required reports of personnel exposures to individuals and to the applicable regulatory agencies in cooperation with the CNS Corporate Office.
4.1.1.10 Implementing and maintaining records of radiological surveys and evaluations.
4.1.1.11 Ensuring adequate radiation safety training is provided to all project personnel and maintaining documentation.
4.1.1.12 Preparing, implementing, and maintaining a radiological respiratory protection program, as necessary.
4.1.1.13 Arranging, as required, all necessary services for bioassay analysis.
4.1.1.14 Arranging maintenance and calibration service and maintaining associated records for radiation survey instruments used at the site.
4.1.1.15 Ensuring that all required monitoring is performed at the work site.
4.1.1.16 Ensuring that occupational monitoring is provided for workers who may come in contact with radiologically contaminated material.
4.1.1.17 Performing periodic safety and quality reviews and monitoring activities of project operations to ensure compliance with the HASP.
4.1.1.18 Reviewing planned site activities and implementing safety procedures to ensure safe performance and completion of the work.
4.1.2 Health Physics Personnel
CNS shall provide qualified health physics personnel to implement the health physics monitoring and surveys required by Federal regulations, CNS programs, and this document.
Health physics personnel are also identified as Radiological Control Personnel in some of the procedures used on this project. The following lists the responsibilities of the individual health physics personnel.
4.1.2.1 Senior Radiological Control Technician(s): Implements the radiation protection program under the direction of the CHP.
4.1.2.2 Radiological Control Technician(s): Acts under the direction of the Senior Radiological Technician(s) and the CHP to conduct all required monitoring and surveys.
4.1.2.3 All Radiological Personnel: Implement and enforce RWP requirements in areas under their control.
4.1.2.4 All Radiological Personnel: Stops work when necessary to maintain a safe radiological and industrial work area.
4.1.3 Individuals
Each individual assigned to the project is responsible for demonstrating familiarity with the radiation protection program, for strict adherence to the radiation protection rules and regulations, and for minimizing radiation exposure to the maximum extent practical. Flagrant or willful disregard of radiological protection rules, regulations, or practices shall result in disciplinary action. Each individual shall be provided training and will successfully complete a test on the requirements of the radiation safety program. Each individual's basic responsibilities are listed below.
4.1.3.1 All individuals working in the restricted area shall have a working knowledge of the radiological protection rules, regulations, and procedures. This knowledge shall be obtained through training and instruction commensurate with the individual's work assignment.
4.1.3.2 Individuals shall know the specifics of the task or job that they are to perform. This knowledge should be obtained through the use of blueprints, technical manuals, standard operating procedures, or instructions from supervisory personnel. Unfamiliarity with the job can result in an increased or unsuspected radiological safety hazard. The RWP is the one document that the individual must be most familiar with for radiological conditions and precautions in the individual's work area. Each individual working in areas covered by an RWP must comply with all requirements of the RWP.
4.1.3.3 Individuals shall understand and follow the radiological protection requirements. Individuals should acquaint themselves with the radiological status of the areas in which they are assigned to work.
4.1.3.4 Individuals shall "stop work" on a job or task whenever radiation safety is not assured or they are uncertain about the radiological status of the job. The CHP (or designee) shall be notified to reassess the situation.
4.1.3.5 Individual workers are not expected to be experts in radiological controls. Consequently, Radiological Control Technicians and supervisory personnel should always be available while radiological work is in progress. Individuals should follow the directions of radiological controls personnel to the maximum extent practicable.
4.1.3.6 Individuals are required by federal regulations to report promptly to management any condition that may lead to or cause a violation of the radiation protection rules/ regulations or unnecessary exposure to radioactive materials. These reports should be made to immediate supervisors, health physics personnel, the CHP, or corporate management.
4.1.4 CNS Corporate Health Physicist (CNS-HP)
The CNS-HP interfaces with the health physics staff, management, and the workers as necessary to make sure the radiological and technical aspects of the project meet all Federal standards. The CNS-HP's responsibilities include the following:
3.1.4.1 Making recommendations to the Project Manager and CHP for the control and elimination of existing and potential radiological hazards.
3.1.4.2 Visiting the site as necessary to ensure compliance with radiation protection rules, regulations, and procedures.
3.1.4.3 Functioning in an advisory capacity to assist personnel in carrying out their radiation protection responsibilities.
3.1.4.4 Stopping work if conditions indicate that a potential exists for an unanticipated and or excessive radiation exposure to site personnel or the general public or if an individual violates the radiation protection rules, regulations, or procedures in a manner that may adversely affect personnel working at the site or the general public.
4.2 Quality Assurance Program
In order to maintain the high standards required for handling radioactive materials, the CNS Quality Assurance program will be enforced on the BOMARC project. The planning of the BOMARC project was performed and documented in compliance with the CNS Quality Assurance Program. Incorporated in the specific procedures are the individual responsibilities for these activities and the control measures necessary to assure and document compliance. Radiation protection procedures implemented on this project may be standard CNS procedures.
5.0 EXTERNAL EXPOSURE TO RADIATION
5.1 Requirements
CNS radiation protection procedures have been developed in accordance with 10 CFR 20.
5.1.1 Administrative Control Limits
Consistent with the commitment to ALARA, administrative control limits are established at levels below regulatory limits specified in 10 CFR 20 to prevent inadvertent overexposure and to serve as an action level and control point for investigating radiation exposures. If an individual receives an exposure that exceeds an administrative limit, an investigation shall be conducted to determine the cause of such exposure and to determine if future exposures can be avoided. The applicable administrative control limit for this project is the whole body Total Effective Dose Equivalent (TEDE) which has an action level of 0.25 rem (250 millirem) per month. Any exposure above this limit requires additional approvals. The total dose received for this project by all individuals, the collective dose, is not expected to exceed 250 millirem.
5.2 Exposure Control
The basic methods used to control radiation exposure include training, personnel monitoring, evaluation of radiological conditions, use of work instructions and radiation work permits, posting of areas, implementing engineering controls, and specifying with using, personal protective equipment.
5.2.1 Personnel Monitoring and Dosimetry
The CHP (or designee) is responsible for ensuring that personnel (employees, vendors, contractors, and visitors) are appropriately monitored for exposure to ionizing radiation. Each individual working at the site shall wear the dosimetry devices specified in the RWP. The CHP (or designee) shall specify the requirement for work assignments. Visitors to the site may not be required to wear dosimetry devices unless they enter a Restricted Area. Personnel shall be issued appropriate personnel monitoring devices consisting of one or more of the following types: thermoluminescent dosimeter (TLD), self-reading dosimeter (SRD), and extremity TLD devices.
5.2.1.1 Proper Location for Wearing Dosimetry Devices - Unless otherwise directed by the CHP, personnel monitoring dosimetry shall be worn on the front of the body between the neck and the waist. When circumstances are such that other parts of the body may receive significantly greater doses, the CHP may instruct the individual to wear the dosimetry in a more representative place or may specify additional dosimetry devices.
5.2.1.2 Official Exposure Determination - Dosimetry is provided by TLDs from a National Voluntary Laboratory Accreditation Program (NVLAP) certified lab. CNS shall have the responsibility for distributing and collecting the devices. The official and permanent record of accumulated external dose received by individuals is obtained from the interpretation of the personnel monitoring devices (TLDs). Upon written request, personnel will be informed of their exposure. In the event of lost or damaged TLD devices, the CHP shall investigate the exposure conditions and assign an external dose for the individual with concurrence of the CNS-HP.
5.2.1.3 Lost or Damaged Dosimetry Devices - Individuals shall immediately notify the CHP (or designee) if they lose or damage their dosimeters. A thorough search shall be made for any dosimeter reported lost. Personnel whose exposures are being investigated shall be excluded from work in radiologically controlled areas until the investigation is completed and documented and dosimetry devices are reissued.
5.2.1.4 Personnel contamination incidents shall be reported immediately to the CNS-HP per Reference 2.9.
5.2.2 Personnel Exposure Investigations
If a situation occurs involving the suspected or known exposure of personnel in excess of the CNS's administrative limits, the situation shall be promptly reported to the CNS-HP. These situations will be investigated, and personnel exposures will be evaluated. This procedure may require special bioassays, radiation surveys, air samples, and TLD device analyses. Conditions at the BOMARC should not produce any exceptional situations related to personnel exposures.
5.2.3 Radiation Work Permits
A Radiation Work Permit (RWP) system shall be implemented at the site to ensure that Restricted Areas are accessed only by personnel who have the appropriate training, personnel monitoring, instrumentation, and personal protective equipment.
The RWP may also be used as an information document for biological or chemical safety. Hazards other than radiological hazards may be included in the RWP so that proper requirements for all possible hazards will be listed on one controlling document.
Implicit in any RWP is the need for a briefing on the radiological conditions present in the work environment.
The RWP shall list tasks and specific levels of protection for each worker covered by the RWP. The RWP shall also detail the dosimetry requirements, the protective clothing requirements, and the expected radiation and contamination levels expected to be encountered during the job.
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