division of nuclear materials safety u.s. nrc region i · this procedure applies to all personnel...

August 26, 2014,

Licensing Assistance Team Division of Nuclear Materials Safety U.S. NRC Region I 2100 Renaissance Blvd., Suite 100 King of Prussia, PA 19406-2713

Subject: Request to Amend License# 20-31340-01(Docket # 03037850}

Dear Licensing Assistance Team:

This letter is to request an amendment to CB&I Federal Services license# 20-31340-01 section 10 of the original application dated 10/12/2008 and clarification submitted 12.17.2008 referenced in Condition 26. A. and B. of the license.

The Enclosure labeled "Item 10 Enclosure B" dated April 29, 2014 is submitted as a complete revision to the original"ltem 10 Enclosure B" submitted with the application dated 10.21.2008.

If you have any question regarding this request please contact me or Claire Doherty at 781-821-3516.

Sincerely,

Mark 0. Somerville MPH, Ph.D. Certified Health Physicist Radiation Safety Center

CB&I Federal Services [email protected] (925) 222-0848 (work) (805) 441-6747 (Cell)

::c:• :::::.::

Item 10 Enclosure B

April 29, 2014

'

PROCEDURE

Procedure Title: Qualifications, Responsibilities and CMS Number: SPL-SOP-8.7 Training

Procedure Mark Somerville Issuing CFS Radiation Safety Owner: Authority:

QUALIFICATIONS, RESPONSIBILITIES AND TRAINING

00 Reformatted into CB&I CMS format MOS 01 May2014

Rev Changes Approved Date

UNCONTROLLED COPY IF PRINTED Page 1 of 8

"©Chicago Bridge & Iron Company, 2009. All Rights Reserved. For Internal Use Only. NOTICE: THIS DOCUMENT, AND ALL TEXT, DRAWINGS, DETAILS AND DATA SHOWN HERETO, IS THE SOLE PROPERTY OF CHICAGO BRIDGE & IRON COMPANY, AND SHALL NOT BE REPRODUCED IN ANY MANNER, USED FOR ANY PURPOSE WHATSOEVER, OR RELEASED TO ANYONE EXCEPT BY EXPRESS WRITIEN PERMISSION OF CHICAGO BRIDGE & IRON COMPANY."

Qualifications, Responsibilities and Training

CMS Number: Revision: A~oval Date:

SPL-SOP-8.7 00 01 May 2014

1.0 PURPOSE

The purpose of this procedure is to establish the qualifications, responsibilities and training of individuals involved in CB&I Federal Services LLC (CB&I) radiological operations.

2.0 SCOPE

This procedure applies to all personnel responsible for the implementation of the specific radiation protection plan (RPP) and also those individuals who work in, or frequent restricted areas. The qualifications, responsibilities, and training of personnel shall be reviewed and evaluated prior to their beginning radiological operations. An example Radiological Training Evaluation Form is provided as Exhibit 7.1 of this procedure. The form, or equivalent, is to be used to document training and qualifications.

The direction provided by this document may be amended to comply with specific client, project, program, or regulatory requirements that are equivalent, or more restrictive, when compared to the requirements of this document. Such variances shall be implemented with proper documentation in project records and approval by the proper project authority. These variances will be applicable only for specific project use.

3.0 RESPONSIBILITIES

3.1 License Radiation Safety Officer (License RSO)

The LRSO shall ensure that appropriate project specific processes or procedures are established to implement the requirements of this procedure. The LRSO shall approve all project radiation safety officers and authorized users.

3.2 Project Radiation Safety Officer (PRSO)

The PRSO is responsible for implementing this procedure and site specific processes or procedures. The PRSO is also responsible for notifying the LRSO of any issues or noncompliance.

4.0 PROCEDURE

4.1 RADIATION STAFF QUALIFICATIONS AND APPROVAL.

The License RSO or PRSO shall perform a review of the training and qualification records for each candidate. Only qualified candidates shall be permitted to work on CB&I projects as RCTs.

If the candidate meets the qualification and project-specific selection criteria, he/she is considered qualified to staff the project without further approval.

If the candidate does not meet the criteria, the project manager may request that the candidate be evaluated by the License RSO for exemption from the requirements. The License RSO may administer written or oral examinations to determine if the candidate may be qualified. Exemptions may not be granted for customer specific requirements such as DOE Radiological Control Technician Qualification, Naval Reactors Article 108, or American National Standards Institute requirements.

A file shall be kept for each successful candidate. This file shall contain the resume, qualification certificates, if appropriate, and any testing or evaluation results.


Project Responsibilities

The PRSO is responsible for radiation safety and compliance with the regulations for the use of radioactive material, which may include by-product, source, and special nuclear material. The PRSO must ensure that radiation safety activities are being performed safely according to



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approved policies and procedures and that all regulatory requirements are met. The PRSO is to have full access to all activities involving the use of licensed material and the authority to terminate any activity in which health and safety appear compromised without consulting executive management.

PRSO responsibilities include but are not limited to ensuring the following:

• Activities involving licensed material considered unsafe are stopped.

• Radiation exposures are As Low As Reasonably Achievable (ALARA).

• Development, distribution, implementation and maintenance of up-to-date operating and emergency procedures.

• Possession, installation, relocation, use, storage, repair and maintenance of sealed sources, devices and radioactive wastes are consistent with the limitations in the license.

• Evaluations of occupationally exposed individuals and members of the public.

• Investigations of unusual occurrences and notifications of proper authorities as required.

• Proper handling, transportation and disposal of licensed material along with appropriate record maintenance.

• Monitoring and surveys of all areas in which radioactive material is used.

• Training personnel.

• Serving as a point of contact for regulatory agencies during routine operations, emergencies, or incidents.

Training and Qualification Records

The Project Radiation Safety Officer (PRSO) shall be qualified by training and experience in radiation protection and be available for advice and assistance on radiological safety matters. The PRSO's training and experience shall include the uses of licensed material identified on the license so that the PRSO is able to oversee the radiation safety program during normal and emergency conditions.

4.3 Authorized Users


Authorized users may be designated any or all of the responsibilities of the PRSO.


Authorized users shall have adequate training and experience to use, possess, or provide services involving licensed materials. Duration of training and experience should be commensurate with the expected hazards personnel may encounter during routine and emergency conditions.

Criteria for acceptable training and experience shall include classroom training in the form of lecture, videotape, or self-study that emphasizes practical subject matter important to the safe handling of licensed materials. The duration and technical level of training should be


I I


CMS Number: I Revision: Approval Date:

SPL-SOP-8.7 I 00 01 May 2014

commensurate with the expected hazards encountered during routine and emergency conditions. Training shall be required prior to the authorized user assuming duties with or in the vicinity of radioactive materials and whenever there is a significant change in duties, regulations, or terms and conditions of the license. Annual refresher training shall also be required.

4.4 Senior Radiological Control Technicians

Responsibilities

A Senior Radiological Control Technician (SRCT) is a technician that may assume all responsibilities for radiological control on a project except for the authority and responsibility of the PRSO. Examples of an SRCT's responsibilities include performing radiation and contamination surveys, performing air sampling and analysis, providing job coverage, responding to radiological emergencies, performing personnel decontamination, performing release surveys, performing incident investigations, performing instrument checks, conducting pre-job briefings, supervising radiological work performed by work crews, and supervising other technicians.

Training and Qualifications Records

An SRCT must have at least 36 months of documented direct, hands-on radiological controls experience or equivalent education in radiological controls from a college, university, or technical school.

In addition to the m1mmum experience and education requirements additional nationally recognized training and qualification requirements, such as DOE Radiological Controls Technician, U.S. Navy Article 108, Radiological Control Monitor, or other client-mandated training requirements, may be imposed on a project-specific basis.

4.5 Radiological Control Technicians

Responsibilities

An RCT may only assume limited responsibilities unless under the direct supervision of a SRCT or PRSO. Examples of RCT responsibilities include manning an access control point, issuing dosimetry, performing clean area routine surveys, surveying laundry and respiratory protection equipment, decontaminating equipment, performing instrument checks, and manning a counting room. RCTs may also assist, under direct supervision, SRCTs in the performance of their assigned tasks. All paperwork and records produced by RCTs must b.e reviewed and countersigned by an SRCT or PRSO.


All RCT candidates shall be qualified if they meet the requirements of one or more of the following categories:

• Verifiable evidence of training, experience, or a combination of training and experience consistent with the requirements of American National Standards Institute/American Nuclear Society, Standard N3.1 - 1993, American National Standard for Selection, Qualification and Training of Personnel for Nuclear Power Plants (reaffirmed 1999}, for Senior Health Physics Technicians.

• National Certification with the National Registry of Radiation Protection Technologists.

• Certification as a DOE Radiological Controls Technician consistent with the requirements of Title 10 CFR, Part 835, Section 835.103.

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CMS Number: Revision: I Approval Date:

SPL-SOP-8.7 00 I 01 May 2014

• Evidence of NAVSHIPS 389-0288, Radiological Controls for Shipyards or NAVSEA 389-0153, Radiological Controls, Article 108, Qualification.

• Two-year technical degree in health physics or related field.

An RCT must have at least 12 months of documented direct, hands-on radiological controls experience. In addition to the minimum experience and education requirements additional nationally recognized training and qualification requirements, such as DOE Radiological Controls Technician, U.S. Navy Article 108, Radiological Control Monitor, or other clientmandated training requirements, may be imposed on a project-specific basis.

The candidate shall supply training and qualification records for review. Copies of these records shall be maintained as part of the project record.

4.6 Radiation Workers


Radiation workers are responsible for working in accordance with the project RPP and follow the direction of the PRSO and RCT's.

Qualifications

All project personnel designated as radiation workers shall be qualified or trained as radiation workers prior to beginning work in Restricted Areas. Those personnel qualified as radiation workers shall re-qualify on a yearly basis. Training and/or qualification shall be conducted in accordance with the one or more of the following training standards:

• Training as required by CFR Title 10, Part 19, Section 19.12

• Training as required by CFR, Title 29, Part 1910.1096

• Any project-specific training that is determined by the License RSO to meet the requirements of the applicable standards noted above.

4.7 Ancillary Personnel

Ancillary personnel may include individuals whose assigned duties involve exposure to radiation and/or radioactive material and individuals who in the course of their employment are not likely to receive in a year an occupational dose of radiation greater than 100 millirem (1 millisievert). Ancillary personnel may include but are not limited to clerical, housekeeping, and security. These individuals should be informed about radiation hazards and the appropriate precautions they should take when working in the vicinity of license material.

4.8 Visitor/Contract Workers

Management, technical, and other personnel who require occasional access to Restricted Areas and areas where radioactive materials are stored and who enter these areas for observation or similar purposes, or to perform work not involving radioactive materials, shall have the radiological control training necessary for the radiological conditions expected to be encountered or shall be escorted by appropriately qualified personnel at all times. A continuous escort is not required if the visitor/contract worker is in continuous view of qualified personnel. The presence of personnel normally assigned to these areas fulfills this function. The PRSO shall determine the training requirements and shall record the decision.


4.9


CMS Number: Revision:

SPL-SOP-8.7 00

Instructors and Radiation Safety Topics

Instructor Responsibilities

Approval Date:

01 May 2014

A qualified individual, such as a person who meets the qualifications of the PRSO or authorized user on the license and is familiar with the program, shall conduct the training. Instructors shall have adequate training and experience and possess a thorough understanding of the licensee operations.

Training course topic shall include but not be limited to:

• Fundamentals of radiation safety, including characteristics of radiation, units of dose and quantity of radioactivity, hazards of exposure to radiation and the concept of A LARA.

• Radiation detection instruments, including their operation, calibration, limitations and proper use and handling.

• Radiation protection equipment, including proper use.

• Review of applicable federal and state regulations.

• Licensee's operating and emergency procedures;

• Course examination, including a review of incorrect answers with the student.

• On-the-job training, including the performance of tasks authorized on the license that are commensurate with the expected hazards during routine and emergency conditions. A practical examination consisting of an assessment of the student by the PRSO shall also be performed.

5.0 REFERENCES

• Code of Federal Regulations, Title 29, Part 1910.1096, Ionizing Radiation.

• Code of Federal Regulations, Title 10, Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations.

• American National Standards Institute/American Nuclear Society, Standard N3.1 - 1993, American National Standard for Selection, Qualification and Training of Personnel for Nuclear Power Plants (reaffirmed 1999).

• California Code of Regulations, Title 17, Public Health

• NUREG-1556, Vol. 18, Consolidated Guidance About Materials License.

6.0 TERMINOLOGY

Ionizing Radiation-Alpha particles, beta particles, gamma rays, neutrons, energetic electrons or protons, and other particles capable of producing ions when interacting with matter.

Radiation Worker-An individual who is properly trained, in accordance with the personnel training requirements of 10 Code of Federal Regulations (CFR) 19.12, 10 CFR 1910.1096, U.S. Department of Energy (DOE) Radiation Worker II, or equivalent training, to perform work activities involving the potential for exposure to ionizing radiation.



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Project Radiation Safety Officer (PRSO)-Individuals who, by virtue of training and/or experience, have been authorized by the License RSO to use or directly supervise the use of radioactive materials under the requirements of the U.S. Nuclear Regulatory Commission (NRC) service license.

Radiological Control Technician (RCT)-An individual who, by virtue of education, experience, or certification, is qualified to perform radiological surveys and implement radiological controls for work activities.

Restricted Area-An area access to which is limited by the licensee for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive materials. Restricted areas do not include areas used as residential quarters, but separate rooms in a residential building may be set apart as a restricted area.

7.0 EXHIBITS

7.1 Radiological Training Evaluation Form

8.0 ATTACHMENTS




SPL-SOP-8.7 00 01 May 2014

Exhibit 7.1 Radiological Training Evaluation Form

Evaluator: _____________________ D License RSO, D Project RSO

Candidate Name: _____________________________ _

Employer: D Employee Number ______________________ _

D Subcontractor: Company Name _________________ _

Position Evaluation: D Radiation Worker or D Radiological Controls Technician

Article I. RADIATION WORKER Training Standard YES

Code of Federal Regulations, Title 10 Part 19.12 0

U.S. Department of Energy, DOE/EH-0256T, Radiological Control Manual, Radiation Worker Training n Code of Federal Regulations, Title 29 part 1910.1096 0

Trainingwhich meets the requirements of the above standards 0 NOTE: Only Training performed within last year is valid.

Article II. RADIOLOGICAL CONTROLS TECHNICIAN Article Ill. Training/Certification Standard YES

American National Standards Institute/American Nuclear Society, Standard N3.1 -1993, American National Standard for Selection, Qualification and Training of Personnel for Nuclear Power Plants (reaffirmed 1999) National Registry of Radiation Protection Technologists

U.S. Department of Energy, DOE/EH-0256T, Radiological Control Manual, RadioloQical Control Technician Qualification

NAVSHIPS 389-0288, Radiological Controls for Shipyards or NAVSEA 389-0153, Radiological Controls, Article 1 08 Certification

Two-Year Technical Degree in Health Physics or related field

Notes:

Radiation Worker Qualified: Radiological Controls Technician Qualified:

NOD NOD

YESDNAD YESDNAD

D

D

D

D

D

Evaluator Signature: __________________ Date: _____ _

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0

0

NO

D

D

D

D

D

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PROCEDURE

Procedure Title: Radiation Protection Program CMS Number: SPL-SOP-8.10

Procedure Mark Somerville Issuing CFS Radiation Safety Group Owner: Authority:

RADIATION PROTECTION PROGRAM

00 Reformatted into CB&I CMS format MOS 01 May 2014



"©Chicago Bridge & Iron Company, 2009. All Rights Reserved. For Internal Use Only. NOTICE: THIS DOCUMENT, AND ALL TEXT, DRAWINGS, DETAILS AND DATA SHOWN HERETO, IS THE SOLE PROPERTY OF CHICAGO BRIDGE & IRON COMPANY, AND SHALL NOT BE REPRODUCED IN ANY MANNER, USED FOR ANY PURPOSE WHATSOEVER, OR RELEASED TO ANYONE EXCEPT BY EXPRESS WRITTEN PERMISSION OF CHICAGO BRIDGE & IRON COMPANY."

Radiation Protection Program


SPL-SOP-8.10 00 01 May 2014

1.0 PURPOSE

The purpose of this procedure is to outline CB&I Federal Services LLC (CB&I) radiation protection program requirements for the radiologically safe performance of operations. The provisions of the program shall be implemented by specific procedures, which may be more restrictive than the requirements herein. This procedure is intended to supplement existing CB&I policies as well as applicable federal and state rules and regulations.

2.0 SCOPE

This procedure applies to all CB&I activities and personnel involved with radiological operations. The direction provided by this document may be amended to comply with specific client, project, program, or regulatory requirements that are equivalent, or more restrictive, when compared to the requirements of this document. Such variances shall be implemented with proper documentation in project records and approval by the proper project authority. These variances will be applicable only for specific project use.


3.1 License Radiation Safety Officer (License RSO).

The License RSO is responsible to maintain and implement the Service Provider License in strict compliance with the requirements of this document, the conditions of the license, and the associated radiation safety program. Specifically, the License RSO shall do the following:

• Act as the official point of contact between the Regulator and CB&I for all licenserelated issues, including making regulatory notification of license implementation and the termination of license use on a project site

• Review, and approve, the qualifications of Authorized License users • Maintain all required license records at the location specified on the license


PRSOs are responsible to understand, implement, and properly document the performance of the activities in accordance with the conditions of the license and all procedures, and program requirements that are incorporated by reference, on CB&I projects where the license is in use. P RSOs must be approved by the License RSO and shall report directly to the License RSO in matters involving the implementation of the Service Provider License.

4.0 PROCEDURE

No operational or related activities shall proceed unless the applicable requirements of this RPP are properly implemented through the use of standard operating procedures or site-specific plans and work instructions. The requirements of 10 CFR Part 20, Standards for Protection Against Radiation; 10 CFR Part 19, Notices, Instructions, and Reports to Workers: Inspection and Investigations; 29 CFR Section 1910.1096, Ionizing Radiation; and California Code of Regulations, Title 17, Public Health, will be met without exception, as they apply to specific projects and situations.

4.1 ALARA Program

CB&I activities shall maintain personnel radiation exposure ALARA. A continuing effort is required to meet this goal by developing and implementing improvements to work procedures and work performance. The following general requirements are designed to assist in meeting this goal:

• In radiological work areas, work shall be performed only under the guidance of an approved procedure or work instruction and Radiation Work Permit (RWP).

• Individual work procedures, radiological work permits (RWPs) and job specific instructions shall specify engineering controls and other applicable actions to be used to minimize radiation exposure during work. These controls/actions may include pre-




SPL-SOP-8.1 0 00 01 May 2014

work decontamination of work areas, use of ventilation to reduce airborne radioactivity, mockup training, or removal of radioactive sources from work areas.

• Pre-work planning is essential to ensuring that all radiological work is conducted in a manner that minimizes personnel exposure to ionizing radiation and complies with 1 0 CFR 20.1001 and this ALARA policy. All such planning should be performed by personnel who are experienced and knowledgeable in health physics principles, practices, and procedures and who are familiar with those design features and operations of nuclear facilities and waste handling equipment that affect the potential for exposures of personnel to radiation.

• Radiation levels in high-radiation areas shall be identified by the use of signs that clearly show the areas with high and low radiation levels, along with the radiation intensity and the date of the last survey.

• Records of the cumulative radiation exposure received in performing a work task should be used, as necessary, to improve methods of work performance in order to minimize personnel radiation exposure in future similar work.

• Dose to the public must be maintained ALARA, and documentation showing compliance shall be kept in the appropriate record system.

4.2 Description of Equipment and Facilities

Facilities and equipment must be adequate to protect health, minimize danger to life or property, minimize the possibility of contamination, and keep exposure to occupationally exposed workers and the public ALARA. Facilities shall provide adequate storage capabilities, appropriate shielding, and the ability to minimize contamination or release of licensed materials as a result of normal and emergency conditions including fire, floods, and wind damage.

Equipment including proper radiological instrumentation must be available for proper implementation of site-specific procedures.

Site-specific documents shall provide details on applicable equipment and facilities.

4.3 Qualifications and Training

All project personnel shall be qualified or trained as applicable prior to beginning work in Restricted Areas. Those personnel shall re-qualify on a yearly basis as necessary.

Radiation safety training shall be provided to all CB&I personnel and contractors before they are permitted unescorted access to controlled areas or occupationally exposed to ionizing radiation during access to controlled areas, whether escorted or not (1 0 CFR 19.12, 10 CFR 20.206,).

Radiation safety training shall include topics appropriate to the individual's prior training, work assignments, and degree of exposure to potential radiological hazards (1 0 CFR 19.12, 10 CFR 20.206, and 10 CFR 835.901 [c]). Radiation safety training requirements should be established in project-specific plans/procedures that address, at a minimum, the issues addressed in this procedure.

A satisfactory training program for radiation safety should also include training evaluations and provisions for maintaining training records.

All site - specific radiation protection programs (RPP) shall include procedures for the training of personnel. The level of training for different groups shall be commensurate with the level of exposure anticipated and compliant with applicable regulations, requirements, and commitments. Outlines of topics to be covered shall be developed and trainers identified. A system of documenting training and, as applicable, examination results shall be established and maintained. Groups for whom training programs should be established include general employees, radiation workers, radiological control technicians and visitors.

4.4 Operating and Emergency Procedures

Each CB&I project shall develop, implement, and maintain operating and emergency procedures and instructions which should include but not be limited to the following:



CMS Number: Revision: ~oval Date:

SPL-SOP-8.10 00 01 May 2014

• • • • •

•

•

•

•

•

Instructions for handling and using licensed materials . Steps to take to keep radiation exposures ALARA. Steps to control access to work sites . Steps to take and whom to contact when an emergency occurs . Methods and occasions for conducting radiation surveys, including surveys for detecting contamination. Procedures to minimize personnel exposure during routine use and in the event of an incident, including exposures from inhalation and ingestion of licensed unsealed materials. Procedures for personnel monitoring, including bioassays, and the use of personnel monitoring equipment. Instructions for maintaining records in accordance with the regulations and the license conditions. Procedures to be followed in the event of uncontrolled release of radioactive unsealed licensed material to the environment, including notification of the RSO, NRC, and other Federal and state agencies. Procedures for the implementation and adherence to good health physics practices while performing service operations.

4.5 Procedures and Work Instructions

Work in a Restricted Area shall be performed under the guidance of a task-specific standard operating procedure (SOP), radiation work permit (RWP) or work instruction (WI). Development, issue and use of SOPs, RWPs or Wls shall be described in the site specific RPP. The License RSO shall approve SOPs.

SOPs, RWPs or Wls should describe the task, radiological conditions, and radiological controls.

A pre-job briefing shall be held prior to beginning work under a SOP, RWP or WI to ensure that all personnel understand the task, radiological conditions, and radiological controls.

4.6 Organizational Structure and individual Responsibilities

The RPP or other site-specific procedures shall contain the organizational structure of the CB&I project and shall also detail individual responsibilities of those involved with implementation of the RPP.

4.7 Audits

CB&I shall review the content and implementation of the RPP annually to:

• Ensure compliance with applicable regulatory requirements • Ensure occupational doses and doses to members of the public are ALARA • Ensure that records of audits and other reviews of program content are maintained for

at least three years from the date of record.

4.8 Records System

Records Policy

All records required or created as a result of CB&I activities will be established and maintained in a manner that is consistent with regulatory requirements and the requirements of projectspecific quality assurance plans.

Records of audits and other reviews of program content are maintained for at least three years from the date of record.

The following records shall be maintained on site during operations:

• Personnel radiation exposure records • Personnel training records


5.0


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• • • • • •

REFERENCES

• • •

•

• •

•

Radiation/contamination survey records RWP records Effluent records Environmental monitoring records Instrumentation records Radioactive source control records

California Code of Regulations, Title 17, Public Health Kansas Administrative Regulations, 28-35, Radiation Protection Code of Federal Regulations, 10 CFR Part 20, Standards for Protection Against Radiation Code of Federal Regulations, 10 CFR Part 19, Notices, Instructions, and Reports to Workers: Inspection and Investigations Code of Federal Regulations, 29 CFR Section 1910.1096, Ionizing Radiation National Council for Radiation Protection and Measurements Report Number 39, Basic Radiation Protection Criteria NUREG-1556, Vol. 18, Consolidated Guidance About Materials License .

6.0 TERMINOLOGY

ALARA-An acronym for "As Low As Reasonably Achievable." Making every reasonable effort to maintain exposure to radiation as far below established dose limits as is practical consistent with the purpose for which the licensed activity is undertaken, taking into account the state of technology, the economics of improvements in relation to state of technology, the economics of improvements in relation to benefits to the public health and safety, and other societal and socioeconomic considerations, and in relation to utilization of nuclear energy and licensed materials in the public interest.

Authorized License User-a person whose training and experience meet applicable criteria, who is named either explicitly or implicitly on the license and who uses or directly supervises the use of licensed materials. Also designated as the Project Radiation Safety Officer (PRSO).

Contamination-The deposition of unwanted radioactive material on surfaces or in media.

Dosimetry-The theory and application of the principles and techniques involved in the measurement and recording of radiation dose.

Monitoring-The measurement of radiation levels, concentrations, surface area concentrations, or quantities of radioactive material and the use of the results of these measurements to evaluate potential exposures and dose equivalents.

Project Radiation Safety Officer (PRSO) -an individual who is responsible for radiation safety and compliance with the regulations for the use of radioactive material for a specific project

Radiation Worker-An individual who is properly trained, in accordance with the personnel training requirements of 10 Code of Federal Regulations (CFR) 19.12, or equivalent training, to perform work activities involving the potential for exposure to ionizing radiation.

Radiological Control Technician-An individual who, by virtue of education, experience, or certification, is qualified to perform radiological surveys and implement radiological controls for work activities.

Radiological Work Permit (RWP)-A work document that contains the necessary controls and protective measures to prevent inadvertent exposures to radiation and radioactive contamination while performing work in radiologically controlled areas.

Restricted Area-An area to which access is limited by the licensee for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive materials. Restricted area does not include areas used as residential quarters, but separate rooms in a residential building may be set apart as a restricted area.




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Survey-An evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiation.

7.0 EXHIBITS

None

8.0 ATTACHMENTS

None


PROCEDURE

Procedure Title: Audit of Radiation Protection Plan CMS Number: SPL-SOP-8.1 0.1


AUDIT OF RADIATION PROTECTION PLAN

00 Reformatted into CB&I CMS format MOS 01 May2014




Audit of Radiation Protection Plan


SPL-SOP-8.1 0.1 00 01 May 2014

1.0 PURPOSE

This procedure provides expectations of Radiation Protection Plan (RPP) audits and program selfassessments and provides the responsibilities and requirements for documenting field checklists and reports. This procedure is provided to assist in the development of an audit and site-specific selfassessment program that meets regulatory requirements, identifies improvement items, and tracks corrective actions.

2.0 SCOPE

This procedure applies to all CB&I Federal Services LLC (CB&I) projects performing work per an RPP and to all personnel assigned RPP audit and/or self-assessment.



The License RSO is responsible for the following:

• Ensuring that RPP compliance audits are conducted of licensed field work at least annually in accordance with this procedure.

• Establishing and reviewing frequency requirement for conducting self-assessments. • Reviewing all findings and ensuring all corrective actions are implemented in a timely

manner


The PRSO is responsible for the following:

• Preparing appropriate corrective action plan{s) (CAP) and responses to RPP audits and self-assessment findings.

• Implementing corrective actions in a timely manner. • Ensuring self-assessments are conducted in accordance with the frequency

established by the License RSO.

4.0 PROCEDURE

Annual audits and defined periodic self-assessments shall be conducted in accordance with applicable regulations and RPP requirements. The Radiation Safety Group audit/self-assessment program is used as a management tool for involving site workers in identifying areas of performance improvement, developing appropriate corrective actions to resolve non-compliances and establishing measures to monitor the effectiveness of the corrective actions as implemented. The program is designed to foster continual improvement in radiological safety performance.

Three types are findings are identified during audits and self-assessment:

• Issue • Improvement Opportunity • Strength

An Issue is an RPP or regulatory non-compliance. Upon identification of an Issue, appropriate corrective action(s) shall be developed and implemented in a timely manner. The PRSO and Project Manager shall develop and implement a CAP (Section 5.2) with specifically assigned tasks and a schedule for completion. The CAP shall be submitted to the License RSO for approval. If safetysignificant deficiencies are noted, immediate notification and action is required.

An Improvement Opportunity is documented when elements of the RPP or activity are found to be inefficient or lack effectiveness. Improvement Opportunities are noted weaknesses or areas of improvement that do not violate a regulatory or RPP requirement. A CAP is not required. Improvement Opportunities are documented in the audit and/or self-assessment report.




SPL-SOP-8.1 0.1 00 01 May 2014

Noteworthy practices are documented as program or site-specific RPP implementation Strengths. Positive Lessons Learned reports should be generated to communicate noted Strengths to other field and Radiation Safety Group staff.

4.1 Compliance Audits and Self-Assessments

4.1.1 Compliance Audits

Compliance audits are performed by the License RSO or designee. The audits shall be designed to satisfy regulatory requirements for periodic program reviews. Compliance audits shall include a review of the content and implementation of the sitespecific RPP at least annually to ensure the following elements are satisfied:

• Compliance with State, NRC and DOT regulations (as applicable), and the terms and conditions of the license;

• Occupational doses and doses to members of the public are maintained as low as reasonably achievable (ALARA); and

• Records of audits and other reviews of program content are maintained for at least three years from the date of record.

Exhibit 7.1 is an example of an audit checklist used as a guide during annual compliance audits. Only areas applicable to the project's scope of work must be addressed. An equivalent checklist may be used to satisfy the annual audit.

Audit records shall include the following information: date of audit, name of person(s) who conducted audit, persons contacted by the auditor(s), areas audited, audit findings (Issue, Improvement Opportunity and Strengths), and recommended corrective actions, if appropriate. The audit report shall include a summary of personnel occupational radiation dose records and incidents involving radiation sources. If the audit report identifies Issues requiring a CAP, the CAP and closeout of each corrective action shall be documented by the PRSO and Project Manager and submitted to the License RSO, or designee, for approval.

4.1.2 Self-Assessment

A self-assessment is the scheduled examination of certain aspects of the site-specific RPP to monitor on-going effectiveness and compliance. Self-assessments are performed by the PRSO or designee within the Radiation Safety Group. The selfassessment is used to routinely identify non-compliances, weaknesses and strengths to support prompt resolution and on-going feedback. All lessons learned shall be developed and disseminated, as appropriate.

The scope and design of a project's self- assessment is site-specific and the frequency is established by the License RSO in collaboration with the PRSO at the initiation of the project and renewed annually. Self-assessments shall include routine unannounced inspections of each use area. Each of the following areas shall be reviewed at least annually as part of the self-assessments, if applicable to the project:

• Review of inventory and radiation survey records • Evaluation of radiation safety training through discussion and observation

of work practices • Performance of independent surveys of work areas • Evaluation of compliance with regulations, the conditions of the license,

site-specific work instructions and work plans • Provision for performance-based instruction to users and technical-level

staff. • Self-assessment reports shall include information including date of

assessment, name of person(s) who conducted assessment, persons




SPL-SOP-8.1 0.1 00 01 May 2014

contacted, areas reviewed, findings, corrective actions (if required), and follow-up.

4.2 Corrective Action Plan (CAP)

Non-compliances with the site-specific RPP or any applicable State or Federal regulation requires development of a CAP that includes a description of each finding, the safety significance, proposed corrective action, required resources, assignment of task and completion date. The CAP must be developed in collaboration with the Project Manager and approved by the License RSO. Findings and identified areas of improvement shall be corrected immediately, as appropriate, and in a manner that ensures prompt, long-term, and effective corrective action. A corrective action effectiveness review shall be performed and documented during the subsequent RPP audit, or as directed by the License RSO.

5.0 REFERENCES

NUREG-1556, Vol. 18, "Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Service Provider Licenses," November 2000

Title 10 Code of Federal Regulations, Part 20, Section 20.1101 ,Standards for Protection Against Radiation

Title 10 Code of Federal Regulations, Part 835, Occupational Radiation Protection

Title 17, California Code of Regulations, Public Health.

Kansas Administrative Regulations, 28-35, Radiation Protection

6.0 TERMINOLOGY

None

7.0 EXHIBITS

7.1 Exhibit A- NUREG 1556 Vol 18 Appendix L Suggested Audit Checklist

8.0 ATTACHMENTS

None




SPL-SOP-8.10.1 00 01 May 2014

7.1 ATTACHMENT NUREG 1556 VOL 18 APPENDIX L SUGGESTED [SPECIFIC PROGRAM} AUDIT CHECKLIST

Sample Audit Checklist

Audit Report No. ___________ License No. ________ _

Licensee's name and mailing address:

Audit of licensed activities at (Address(es)):

Contact at Audit Location------------ Telephone No. _____ _

Date of this Audit. ______________ _

Summary of Findings and Action:

IJ No deficiencies il Deficiencies

Indicate if corrective actions taken to prevent recurrence from the previous audit were comprehensive and effective Recommendations:

Auditor: __________________ Date:---------




SPL-SOP-8.1 0.1 00 I 01 May 2014

1. AUDIT HISTORY o N/A (N/A means "Not applicable" - Initial Audit)

a. Last audit of this location conducted on: ----::--b. Problems/deficiencies identified during last two audits or two years, whichever is

longer ............................................................................................ o Y o N c. Open problems/deficiencies from the previous audits:

Status Requirement Problem/Deficiency Corrective Action Taken (Y/N)

Open/Closed

d. Any previous problem/deficiency not corrected or repeated .................. o Y o N o N/A Explain:

2. ORGANIZATION AND SCOPE OF PROGRAM a. Briefly describe organizational structure

I l

b. Structure is as described in license documents ...................................................... 1 1 Y IJ N c. Multiple authorized locations of use listed .............................................................. Ll Y u N

Provide address(es) of those locations reviewed as part of this audit: d. Briefly describe scope of activities involving licensed material, frequency

of use, staff size e. Radiation Safety Officer:

Authorized on license ........................................................................................ CJ Y o N Fulfills duties as RSO ........................................................................................ n Y n N

f. Use of licensed material only by authorized individuals ......................................... u Y o N Remarks:

3. TRAINING, RETRAINING, AND INSTRUCTIONS TO WORKERS a. Instructions to workers per[10 CFR 19.12] ............................................................ o YoN b. Training program implemented as required [UC] ................................................... ll Y 1-1 N c. Training records maintained [UC] .......................................................................... u Y LJ N d. Evaluation of individuals' understanding of procedures and requirements

based on interviews, observation of selected workers was performed .................. o Y o N If so: Each has an up-to-date copy of the licensee's operating use and emergency procedures ............................................................................................................. n Y ll N Adequate understanding of: Operating procedures ............................................................................................. o Y o N Emergency procedures ........................................................................................... o Y o N

e. 10 CFR Part 20 Workers cognizant of requirements for:

Radiation Protection Program [20.1101] ........................................................... o Y ll N Annual dose limits [20.1301, 20.1302] .............................................................. o Y o N NRC Forms 4 and 5 .......................................................................................... n Y n N 1 0 percent monitoring threshold [20.1502] ....................................................... c Y o N Dose limits to embryo/fetus and declared pregnant women [20.1208] ............ o Y 1 1 N Procedures for opening packages [20.1906] .................................................... ll Y n N




SPL-SOP-8.10.1 00 01 May 2014

f. 10 CFR Parts 19, 20, 21, 30, 37, 40, 70 and 71 reviewed as applicable ....... o Y n N Remarks:

4. INTERNAL AUDITS, REVIEWS OR INSPECTIONS a. Audits are conducted n Y o N

Audits conducted by---------------------Frequency ____ ~--------~------------

b. Content and implementation of the radiation protection program reviewed at least annually [20.11 01 (c)] ............................................................................... o Y o N

c. Records maintained [20.2102] ............................................................................. [] Yo N Remarks:

5. FACILITIES a. Facilities as described in license documents ....................................................... o Y o N b. Access to restricted area/licensed material in accordance with 20.1801,

20.1802 ................................................................................................................ rJ Y u N Remarks:

6. MATERIALS Isotopes, quantities, model numbers, and use as authorized on license ................... n Y n N Using NUREG-1757 Volume 3: Financial Assurance is current ........................ o Yo N DN/A [10 CFR 30.35, 10 CFR 40.36, 10 CFR 70.25] Remarks:

7. LEAK TESTS a. Leak test performed as described in correspondence with NRC

(leak test kit; service provider licensee performed and/or analyzed) ..................... lJ Y o N b. Frequency: every 6 months or other interval, as approved by NRC or

Agreement State .................................................................................................... n Y o N c. Records with appropriate information maintained .................................................. o Y o N

Remarks:

8. INVENTORIES a. Conducted at 6-month intervals [UC] ..................................................................... D Y D N b. Visual verification confirmed or security seal still in place ...................................... o Y o N c. Transactions entered into the National Source Tracking System,

including annual reconciliation [10 CFR 20.2207] ........................................ o YoN o N/A d. Records with appropriate information maintained .................................................. o Y o N Remarks:

9. RADIATION SURVEYS a. Instruments and Equipment:

Appropriate operable survey instrumentation possessed or readily available [UC] .......................................................................................................... o YON Calibrated as required [20.1501] ............................................................................ o YoN Calibration records maintained [20.2103(a)] .......................................................... o Yo N

b. Briefly describe survey requirements [20.1501]: c. Performed as required [20.1501 (a)] ....................................................................... Cl Y u N

Radiation levels within regulatory limits .................................................................. r J Y r1 N Corrective action taken and documented .................................................... n Y n NoN/A




SPL-SOP-8.1 0.1 00 01 May 2014

d. Records maintained [20.2103] ................................................................................ o Y D N e. Protection of members of the public:

Adequate surveys made to demonstrate either (a) that the TEDE to the individual likely to receive the highest dose does not exceed 1 00 mrem in a year, or (b) that if an individual were continuously present in an unrestricted area, the external dose would not exceed 2 mrem in any hour and 50 mrem in a year [20.1301(a)(1), 20.1302(b)] .......................................................................... D Y D N Unrestricted area radiation levels do not exceed 2 mrem in any 1 hour [20.1301 (a)(2)] ........................................................................................................ o Y o N Records maintained [20.2103, 20.2107] ................................................................. o Y n N

Remarks:

10. RECEIPT AND TRANSFER OF RADIOACTIVE MATERIAL a. Describe how packages are received and by whom: b. Written package opening procedures established and followed

[20.1906(e)] ............................................................................................................ D Y D N c. If package shows evidence of degradation, monitor

for contamination and radiation levels .......................................................... n Y n N n N/A d. Monitoring of degraded packages performed within time

specified [20.1906(c)] ................................................................................... D Y D N D N/A e. Transfer(s) between licensees performed in compliance with 30.41 .......... o Y u N D N/A f. Records of receipUtransfer maintained [30.51] ....................................................... o Y o N g. Transfers within licensee's authorized users or locations performed

as required [UC] ........................................................................................... D Y o N n N/A h. Package receipUdistribution activities evaluated for compliance with

27 20.1301 [20.1302] ................................................................................... lJ Y D N D N/A Remarks:

11. TRANSPORTATION (10 CFR 71.5(a) and 49 CFR 170-189) ......................................... n N/A a. Licensee shipments are:

Delivered to common carriers ...................................................................... D Y D No N/A Transported in licensee's own private vehicle ............................................. u Y uNo N/A No shipments since last audit ................................................................................. rl Y rl N

b. Hazmat Training Applicability and responsibility for training and testing [49 CFR (172.702)] ........................................................................... D YoND N/A Training requirements [49 CFR (172.704)] .................................................. o YoN o N/A

c. Packages ..................................................................................................................... r~l N/A Authorized packages used [173.415, 416] ................................................... o Yo N Cl N/A Closed and sealed during transport [173.475(f)] .................................................... u Y u N

d. Properly labeled and marked [172.403, 173.441] .................................................. n Y n N Shipping Papers ......................................................................................................... n N/A Prepared and used [172.200(a)] ............................................................................. o Y o N Proper {Shipping Name, Hazard Class, UN Number, Quantity, Package Type, Nuclide, RQ, Radioactive Material, Physical and Chemical Form, Activity, Category of Label, Tl, Shipper's Name, Certification and Signature, Emergency Response Phone Number, "Cargo Aircraft Only" (if applicable)}

[172.200-204] ·········································································································· D y D N Readily accessible during transport [177.817(e)] ................................................... lJ Y u N

e. Vehicles ...................................................................................................................... o N/A Cargo blocked and braced [177.842(d)] ................................................................. o Yo N Placarded, if needed [172.504] ............................................................................... o Y 'J N



CMS Number: I Revision: I Approval Date:

SPL-SOP-8.10.1 I 00 I 01 May 2014

Proper overpacks, if used (shipping name, UN Number, labeled, statement indicating that inner package complies with specification package) [173.25] ........................................................................................ D Y D N D N/A

f. Any incidents reported to DOT [171.15, 171.16] .................................................... D Y D N Remarks:

12. PERSONNEL RADIATION PROTECTION a. ALARA considerations are incorporated into the Radiation Protection

Program [20.11 01 (b)] .............................................................................................. D Y D N b. Adequate documentation of determination that unmonitored

individuals are not likely to receive >10 percent of allowable limit [20.1502(a)] .......................................................................... D Y D N n N/A

OR c. External dosimetry required and used ......................................................... D Y n N Ll N/A

Supplier: Frequency: ---------=-Supplier is NVLAP-approved [20.1501(d)(1))] ........................................................ D Y D N Dosimeters exchanged at required frequency [UC] ............................................... rl Y D N

d. Occupational intake monitored and assessed [20.1502(b)] ......................... n Y 11 N LJ N/A e. Reports: ..................................................................................................................... D N/A

Reviewed by: Frequency: _______ _ Auditor reviewed personnel monitoring records for period to ----=-Prior dose determined for individuals likely to receive doses [20.2104] ................ D Y D N Maximum exposures TEDE: Other: _________ _

f. NRC Forms or equivalent [20.2104(d), 20.2106(c)]: NRC-4 "Cumulative Occupational Exposure History" Complete: ........................... D Y u N NRC-5 "Occupational Exposure Record for a Monitoring Period" Complete: ........ rl Y [] N

g. Worker declared her pregnancy in writing during audit period (review records) ............................................................................................ 0 Y D N D N/A If yes, determine compliance with [20.1208 ............................................................. DY D N and check for records per 20.2106(e) ..................................................................... u Y lJ N

h. Records of exposures, surveys, monitoring, and evaluations maintained [20.2102, 20.2103, 20.2106, UC] ........................................................................... D Y D N

i. Pocket dosimeters and/or alarming rate meters [UC]: ............................................... D N/A Possessed and used as required ........................................................................... D Y D N Operable and calibrated/checked at required frequency ........................................ D Y D N Records maintained ..................................................................................... lJ Y D N D N/A

Remarks:

13. SECURITY PROGRAM FOR CATEGORY 1 AND CATEGORY 2 MATERIALS [10 CFR Part 37] a. Commensurate security program implemented .................................... u Y u N lJ N/A b. Trustworthiness and Reliability Determinations Made ........................................... U Y U N c. Access Control to information and RSRM .............................................................. D Y n N d. Monitoring/Detection/Assessment/Response Operationai24/7 ................. D Y D N D N/A e. Valid test of security system to ensure operability ................................. D Y D N D N/A f. Local Law Enforcement Agency Coordination and Written Plan ............... D Y D N 0 N/A g. Package tracking for transport of risk significant radioactive material ...... 0 Y n N n N/A h. Mobile devices secured .............................................................................. n Y 0 N [J N/A i. Sensitive information secured and only available to personnel who have been deemed

trustworthy and reliable .......................................................................................... U Y U N j. Reports made (loss, theft, or sabotage of RSRM, or if results of fingerprints are




SPL-SOP-8.10.1 00 01 May 2014

positive for the FBI Terrorist Screening Data, etc.) ................................................ Jl Y D N k. Records maintained ................................................................................................ D Y u N Remarks:

14. AUDITOR'S INDEPENDENT MEASUREMENTS (IF MADE) Survey instrument Serial No. Last calibration

Auditor's measurements compared to licensee's ......................................................... D Y D N Describe the type, location, and results of measurements; attach a diagram/survey sheet and refer to this section:

15. RADIOACTIVE EFFLUENTS, WASTE MANAGEMENT, AND DISPOSAL a. Waste disposed of by decay-in-storage (DIS): ........................................................... D N/A

Procedure for DIS disposal approved by license condition .................................... lJ Y lJ N Disposal by DIS in accordance with UC ................................................................. rJ Y u N Licensee in compliance with 20.1501 and 20.1904(b) ............................................ D Y D N Records maintained [20.2103(a), UC] .................................................................... n Y ll N

Remarks:

b. Licensed material released into sanitary sewerage: ................................................... 11 N/A Material is readily soluble (or is readily dispersible biological material) in water [20.2003(a)(1)] .............................................................................................. D Y D N Monthly average release concentrations do not exceed Appendix 8 values [20.2003(a)(2,3)] .................................................................................................... n Y f] N No more than 5 curies of hydrogen-3,1 curie of carbon-14 and 1 curie of all other radionuclides combined were released in a year [20.2003(a)(4)] .......................... u Y u N Procedures for ensuring adequate sample representativeness and analysis properly implemented [20.1501, UC] ..................................................................... D Y D N Records maintained [20.2108] ............................................................................... D Y D N

Remarks:

c. Waste disposed of by incineration: ........................................................................... D N/A License authorizes incineration [20.2004(a)(3)] .................................................... D Y D N If licensee directly monitors incinerator exhaust, the monitor sample is representative and the monitoring instrumentation is operational and properly calibrated [20.1501] ...................................................................... o Y o N o N/A If licensee calculates exhaust concentrations, incinerator airflow and activities incinerated are accurately known, and the calculations are correct [20.1501] ........................................................................................ D Y D N D N/A Management of effluents and ashes in accordance with 20.1301, 20.1201, 20.1501, 20.2001 and UC ...................................................................... 11 Y ; 1 N Records maintained [20.2108] ............................................................................... u Y u N

Remarks:

d. Disposal of liquid scintillation (LS) media and/or animal carcasses: ......................... D N/A Licensee disposes of LS media and carcasses contaminated with only H-3 or C-14, and at a concentration not exceeding 0.05 IJCi/g per 20.2005 .................... o Y o N Records maintained [20.2108] ............................................................................... o Y u N

Remarks:

e. Transfers for disposal at land disposal facilities: ........................................................ o N/A Waste transferred to person specifically licensed to receive waste [30.41,




SPL-SOP-8.10.1 00 01 May 2014

20.2001 (b)] ..................................................................................................... n Y n N Each shipment accompanied by a shipment manifest prepared as specified in Section I of Appendix G to 10 CFR Part 20 [10 CFR 20.2006(b) and Section III.A.4 of Appendix G to 10 CFR Part 20] ................................... D Y n N Shipment manifests certified as specified in Section II of Appendix G to 10 CFR Part 20 [10 CFR 20.2006(c)] ............................................................. D Y D N Compliance with Section Ill of Appendix G to 10 CFR Part 20 [10 CFR 20.2006(d)]: Note: The licensee's waste is likely to be Class A waste not packaged for disposal in cardboard or fiberboard boxes [61.56(a)] Liquid wastes solidified [61.56(a)] .................................................................. D Y D N Volume of solid wastes contain less than 1 percent freestanding liquid [61.56(a)(3)] .................................................................................................... n Y n N Waste does not generate harmful vapors [61.56(a)] ...................................... D Y D N Waste structurally stable, i.e., will maintain its physical dimensions and form under expected disposal conditions [61.56(b)] ....................................... n Y ll N Void spaces within the waste and between the waste and its package minimized [61.56(b)] ....................................................................................... D Y D N Waste packages labeled to identify their proper class [Section III.A.2 of Appendix G to 1 0 CFR Part 20] ...................................................................... D Y D N Licensee conducts a QA program to ensure compliance with 61.55 and 61.56, and which includes management evaluation of audits [Section III.A.3 of Appendix G to 10 CFR Part 20] ......................................... i I Y 1-1 N For shipments not acknowledged by recipient within 20 days after transfer, incident investigated and reported [Section III.A.9 of Appendix G to 10 CFR Part 20] ........................................................... D Y D N D N/A Records maintained [20.2108] ........................................................................ 11 Y 1 1 N

Remarks:

f. Special disposal procedures and other effluents (e.g., hood exhausts, special dilutions): ............................................................................................................ :J N/A Performed in accordance with UC ................................................................. D Y n N Appropriate surveys conducted [20.1501, UC] .............................................. o Y n N Operations comply with 20.1201 and 20.1301 ............................................... u Y lJ N Special disposals per 20.2001 and 20.2002, i.e., no improper/unauthorized disposals were noted . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 Y 1 1 N Use of dose constrainUALARA [20.1101(d)] ................................................... D Y n N Records maintained [20.2108] ........................................................................ D Y n N

Remarks:

g. Waste compaction operations: ........................................................................... il N/A Airborne releases evaluated and controlled [20.1501, 20.1701, UC] ............. D Y o N Internal exposures evaluated and controlled [20.1501, 20.1204, 20.1702, 20.1703, 20.1201] ........................................................................................... U Y D N Compliance with 20.1301 evaluated [20.1302] ............................................... o Y o N

Remarks:

h. Waste storage areas: ......................................................................................... D N/A Adequate protection from the elements (floods, tornadoes, hurricanes, etc.) and fire [UC] . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . o Y u N Adequate control of waste in storage [20.1801] ............................................. n Y o N Containers properly labeled and area properly posted [20.1902, 20.1904] .... D Y o N Package integrity adequately maintained [UC] .................................................... o Y o N




SPL-SOP-8.10.1 00 01 May 2014

Adequate records of surveys and material accountability are maintained [20.2103, 20.2108] ............................................................................................... lJ Y D N

16. NOTIFICATION AND REPORTS ................................................................................... D N/A a. Licensee in compliance with 19.13, 30.50 (reports to individuals,

public and occupational, monitored to show compliance with Part 20) ........ Y lJ N u N/A b. Licensee in compliance with 20.2201, 30.50 (theft or loss) ...................... D Y lJ N n None c. Licensee in compliance with 20.2202, 30.50 (incidents) .......................... LJ Y Cl N u None d. Licensee in compliance with 20.2203, 30.50 (overexposures and

high radiation levels) ................................................................................ D Y D N D None e. Licensee in compliance with 21.21 (device defect) .............................. D Y n N u None f. Licensee aware of telephone number for NRC Emergency Operations

Center [301-816-5100] .......................................................................................... n Y Cl N

17. POSTING AND LABELING a. NRC Form 3 "Notice to Workers" is posted [19.11] ............................................... D Y D N b. Parts 19, 20, 21, Section 206 of Energy Reorganization Act, procedures

adopted pursuant to Part 21, and license documents are posted, or a notice indicating where documents can be examined is posted [19.11, 21.6] ................. D Y D N

c. Other posting and labeling per [20.1902, 1904] and the licensee is not exempted by 20.1903, 1905 .................................................................................. D Y c N

Remarks:

18. RECORDKEEPING FOR DECOMMISSIONING ............................................................ D N/A a. Records of information important to the safe and effective decommissioning

of the facility maintained in an independent and identifiable location until license termination ................................................................................................. n Y :l N

b. Records include all information outlined in 30.35(g}, 40.36(f}, 70.25(g) ................. u Y Ll N Remarks:

19. NRC CORRESPONDENCE a. Review of such documents as NRC Regulatory Issue Summaries, Bulletins, Information

Notices, FSME Newsletters ................................................................................... D Y D N b. Appropriate action taken in response to NRC correspondence ............................ D Y D N Remarks:

20. LICENSE CONDITIONS OR ISSUES ............................................................................. u N/A a. Review license conditions; NRC/Agreement State violations, Orders, Confirmatory Action Letters; site-specific procedures and other safety or security issues, and describe findings:

b. Problems/deficiencies identified at licensee facilities other than at audit location:

c. Evaluation of compliance:

21. PERFORMANCE-BASED REVIEW ................................................................................ D N/A a. Conduct performance-based reviews of radiation workers performing licensed activities:

( 1) to assess the capability of the radiation workers to maintain exposures ALARA; (2) to assess that radiation workers follow the operating procedures; (3) to assess the effectiveness of the operating procedures and compliance with the

regulations, license conditions and the licensee commitments submitted in




SPL-SOP-8.1 0.1 00 01 May 2014

support of a license (and incorporated by "tie-down" conditions); (4) to ensure the safe and secure use of radioactive material; (5) to verify that radiation workers are cognizant of the emergency procedures and, if

necessary, would be able to implement them and maintain exposures ALARA; and

(6) to ensure that emergency procedures have been developed for all likely scenarios.

b. Take the necessary actions to address programmatic and performance deficiencies with radiation workers and facilitate immediate corrective measures.

Note: Performance-based reviews may include observation of licensed activities, review of records, and interviews with key personnel.

22. PROBLEMS OR DEFICIENCIES NOTED AND RECOMMENDATIONS ................ D N/A Note: Briefly state (1) the requirement and (2) how and when violated. Provide recommendations for improvement.

23. EVALUATION OF OTHER FACTORS a. Senior licensee management is appropriately involved with the radiation

safety program and/or radiation safety officer (RSO) oversight ..................... o Y n N b. RSO has sufficient time to perform his/her radiation safety duties and is not

too busy with other assignments .................................................................... D Y o N c. Licensee has sufficient staff . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D Y D N d. Performance-based review (observation of licensed activities conducted) .... n Y D N

Remarks:

Note: All areas indicated in audit notes may not be applicable to every license and may not need to be addressed during each audit. For example, licensees do not need to address areas that do not apply to the licensee's activities, and activities that have not occurred since the last audit need not be reviewed at the next audit.

Date of This Audit------------ Date of Last Audit _______ _ Next Audit Date-----------Auditor-----:-=-:---:----:---------Date---------

(Signature)

Management Review------------ Date ________ _


PROCEDURE

Procedure Title: Radiation Monitoring Instrumentation CMS Number: SPL-SOP-8.1 0.2


RADIATION MONITORING INSTRUMENTATION





Radiation Monitoring Instrumentation


SPL-SOP-8.1 0.2 00

1.0 PURPOSE

This procedure provides the requirements for the proper control, calibration, and quality control checks of portable and fixed radiation monitoring instrumentation selected for use by CB&I Federal Services LLC (CB&I) projects. The requirements for documentation of instrument performance are also provided.

2.0 SCOPE

This procedure applies to all CB&I radiological projects and personnel who utilize radiation monitoring instrumentation. This procedure specifies standard practices for the performance of portable and fixed instrumentation operations.

The direction provided by this document may be amended to comply with specific client, project, program, or regulatory requirements that are equivalent, or more restrictive, when compared to the requirements of this document. Such variances shall be implemented by the License Radiation Safety Officer (License RSO) and/or the Project Radiation Safety Officer (PRSO), with proper documentation in project records and approval by the proper project authority. These variances will be applicable only for specific project use and may be documented in a site-specific work instruction.

Only personnel with appropriate documented training shall issue or use radiation monitoring instruments. Training and documentation shall comply with 10 Code of Federal Regulations 20.19 and/or other applicable regulations such as Title 17, California Code of Regulations, Public Health.

Site-specific instrument procedures shall address the performance testing requirements before initial use, after maintenance that could affect performance, and periodically over the life of the project to verify that they continue to meet the project objectives. The site-specific instrument procedures shall define the requirements for the testing and calibration of instruments.


Responsibilities for ensuring that radiation monitoring instrumentation is properly utilized shall be determined in the site-specific radiation protection plan or in associated work instructions.


The License RSO is responsible to ensure that appropriate project specific procedures are established to implement the requirements of this procedure.


The PRSO is responsible for implementing this procedure and notifying the License RSO of any issues or noncompliance.

3.3 Radiological Control Technician (RCT)

The assigned RCT is qualified per SOP 8.7, Qualification, Responsibilities and Training, and site-specific requirements and responsible for performing required radiological surveys and implementing radiological controls for work activities.

4.0 PROCEDURE

4.1 Types and Quantities of Instruments.

Prior to initiating radiological work the PRSO, with License RSO concurrence, shall determine the appropriate types and quantity of radiation monitoring instrumentation for a project based on what is known regarding the isotopes of concern for the project. The following will be considered:

• Isotope to be measured




SPL-SOP-8.1 0.2 00

• Types of measurements to be taken (count rate, dose rate etc.)

• Purpose of the measurements, sensitivity required (Data Quality Objective)

Instruments and detectors shall be inspected for mechanical damage (including light leaks, battery response and source response tested) prior to use. Instruments with mechanical damage or that do not pass the response test shall be immediately tagged with a "Do Not Use" tag.

4.2 Calibration

Portable and fixed radiological instrumentation, self-reading dosimetry, counter-scalers, and air sampling equipment shall be properly calibrated prior to use using NIST traceable sources. The PRSO is responsible for ensuring that all radiological instrumentation, dosimeters, and air sampling equipment to be used at the project have a current calibration.

Copies of calibration records shall be maintained throughout the duration of the project in the permanent project file.

• Calibration of survey instruments used in assessing dose or exposure rates must be conducted at required intervals, in accordance with vendor recommendations, recognized standards or documented evaluation.

• Calibration must produce readings within ± 10 per cent of the actual values over the range of the instrument; or +/-20 per cent when accompanied by a calibration chart; or an alternate value authorized by the License RSO.

4.2.1 Calibration Records

Calibration records, for all survey instruments, shall indicate the procedure used and the data obtained. The description of the calibration shall include:

• The owner or user of the instrument;

• A description of the instrument, including the manufacturer's name, model number, serial number, and type of detector;

• A description of the calibration source, including the exposure rate at a specified distance or activity on a specified date;

• For each calibration point, the calculated exposure rate or count rate, the indicated exposure rate or count rate, the deduced correction factor (the calculated exposure rate or count rate divided by the indicated exposure rate or count rate), and the scale selected on the instrument;

• For exposure rate meters, the source isotope used to calibrate the instrument (with correction factors) for each scale;

• Instrument efficiency shall be determined, by an approved calibration service provider or by project staff, in accordance with an approved procedure;

• For each scale or decade not calibrated, an indication that the scale or decade was checked only for function but not calibrated;

• The exposure rate or count rate from a check source, if used;

• The name of the person who performed the calibration and the date it was performed.




SPL-SOP-8.1 0.2 00 01 May 2014

4.2.2 Calibration Sticker and Tag

Calibration stickers and tags shall include the following information as appropriate:

• The date of calibration and the next calibration due date;

• The apparent exposure rate or count rate from the check source, if used;

• Initials of the person performing the calibration.

4.3 Typical Instruments

Typical Survey Instruments

Portable Instruments Used for,Contamination and Ambient Radiation Surveys

Energy Range y~

Detectors Efficiency

Exposure Rate Gamma, x-ray RF-R N/A Meters

Count Rate Meters

GM Alpha All energies (dependent on window thickness) Moderate Moderate

Beta All energies (dependent on window thickness) Moderate Moderate

Gamma All energies 1-13%

Gas Proportional Alpha All energies High

Beta All energies Moderate

Nal Scintillator All energies (dependent on crystal thickness) Moderate

Stationary Instruments Used to Measure Wipe, Bioassay, and Effluent Samples

Detectors Radiation Energy Range Efficiency

Liquid Alpha All energies High Scintillator Counter (LSC)

Beta All energies High

Gamma All energies Moderate

Gamma Counter All energies High (Nal)

Gas Alpha All energies High Proportional

Beta All energies Moderate




SPL-SOP-8.1 0.2 00

4.4 Pre-Operational Requirements

4.4.1 Ratemeter

4.4.2

Project-specific requirements for instrument/detector operation verification shall be identified during the project planning. A copy of each manufacturer's operating instructions shall be available, and instruments shall be operated in accordance with these instructions.

Prior to the use of ratemeter-type instruments and detectors, the following inspections/operational verifications shall be performed.

• Calibration Verification

• Physical Check

• Battery Check

• High-Voltage Check

• Response Check to a known source

Scaler

Per specific project procedures, prior to the use of scaler-type instruments and detectors, the following inspections/operational verifications shall be performed in addition to those required in Section 6.4 for ratemeter-type instruments (i.e., calibration verification, physical check, battery check, HV check):

• Background Measurement Perform the background measurement of the instrument.

• Instrument Efficiency, if applicable Determine the detector efficiency with a source of known activity of the nuclide to be monitored (or with a source of known activity of a nuclide with energy decay products similar to those of the nuclide to be monitored).

• Calculation of Minimum Detectable Concentrations Minimum detectable concentrations (MDC) of each instrument shall be determined upon initial setup of the counting system and as needed following modification, calibration, repair, or replacement (i.e., new detector, cables, calibration, etc.).

• High Voltage Plateau The high-voltage plateau (HVP) is performed during instrument calibration and should not be required under normal operating conditions. However, following any equipment modification or replacement (i.e., new detector, cables, etc.) or whenever there is a noticeable degradation of instrument/detector performance (e.g., decreasing efficiency, erratic results, etc.), the HVP shall be investigated. If necessary, a new HVP shall be performed in accordance with the specific instrument's manufacturer's technical manual.

4.4.3 Fixed Counting System General Requirements

The site-specific instrument procedure shall provide the methodology and guidelines for the operation of site fixed counting systems to include:

• Physical inspections

• Counting gas requirements if appropriate




SPL-SOP-8.1 0.2 00

• System setup, acceptable

• Range for background

• Operational parameters

• Calibration, precautions, and limitations

• Performance testing and acceptable testing criteria

• Appropriate response when instrument response is out of range

• Sample counting operations, establishing required minimum detectable activity or MDCs

• Safety precautions

• Record-keeping requirements, including data package and data verification and validation.

4.5 Records

The PRSO shall be responsible for maintaining instrumenUdetector physical checks and performance verification records. In addition, all instrumentation problems and corrective actions shall be recorded on the appropriate data sheets.

All records, forms, and memos shall be maintained in the on-site project file throughout the duration of the project.

5.0 REFERENCES

• Title 10 Code of Federal Regulations, Part 20, Standards for Protection Against Radiation • Title 10 Code of Federal Regulations, Part 30, Rules of General Applicability to Domestic

Licensing of Byproduct Material • Title 17, California Code of Regulations, Public Health • Kansas Administrative Regulations, 28-35 Radiation Protection • SOP 8.7, Qualification, Responsibilities and Training • National Council on Radiation Protection, Report No. 58, A Handbook of Radioactivity

Measurements • Manufacturer's Technical Manual(s) • U.S. Nuclear Regulatory Commission, NUREG-1556, Vol. 182, Consolidated Guidance About

Materials Licenses • American National Standards Institute N323A-1997, Radiation Protection Instrumentation Test

and Calibration, Portable Survey Instruments. • "The Health Physics & Radiological Health Handbook, Revised Edition," edited by Bernard

Shleien, 1992.

6.0 TERMINOLOGY





SPL-SOP-8.1 0.2 00

Background Radiation-Radiation that occurs naturally in the environment. Background radiation consists of cosmic radiation, terrestrial radiation, consumer products, and other natural sources, including radon and its decay products in air and global fallout as it exists in the environment from the testing of nuclear explosive devices or from past nuclear accidents (such as Chernobyl). Background radiation and are not under the control of the licensee. "Background radiation" does not include radiation from source, byproduct, or special nuclear materials regulated by the Nuclear Regulatory Commission (NRC).

Calibration-The check or correction of the accuracy of a measuring instrument to ensure proper operational characteristics.

Radiation-Alpha particles, beta particles, gamma rays, neutrons, energetic electrons or protons, and other particles capable of producing ions when interacting with matter.

Monitoring-The measurement of radiation levels, concentrations, surface area concentrations, or quantities of radioactive material and the use of the results of these Scanning-A type of directmeasurement monitoring performed by moving a detector slowly over the surface or area being evaluated.

Source Check or Response check--An assessment of the operability of a monitoring instrument that is performed daily or prior to each intermittent use. Typically, a source check is performed daily when an instrument is to be used during that day.


7.0 EXHIBITS

None

8.0 ATTACHMENTS

None


PROCEDURE

Procedure Title: Procurement, Receipt, Transfer, and CMS Number: SPL-SOP-8.1 0.3 Accountability of Radioactive Material

Procedure Mark Somerville Issuing CFS Radiation Safety Group Owner: Authoritv:

PROCUREMENT, RECEIPT, TRANSFER, AND ACCOUNTABILITY OF RADIOACTIVE MATERIAL





Procurement, Receipt, Transfer, and Accountability of Radioactive Material


SPL-SOP-8.1 0.3 00

1.0 PURPOSE

The purpose of this procedure is to establish requirements for developing site-specific procedures for the procurement, receipt, transfer, and accountability of radioactive material as part of a site-specific radiation protection program.

2.0 SCOPE

This procedure applies to all CB&I Federal Services LLC (CB&I) radiological activities and personnel involved with the procurement, receipt, transfer, and accountability of radioactive material.



The license RSO shall determine the project requirements for procurement, receipt, transfer, and accountability of radioactive material. The License RSO shall ensure that appropriate project specific procedures are established to implement the requirements of this procedure. The License RSO reviews and approves project specific procedures. The License RSO shall sign any purchase requisition for non- exempt quantities of radioactive material.


The PRSO is responsible for notifying the License RSO of the need for procurement of radioactive materials in excess of exempt quantity and is responsible for implementing this procedure and notifying the license RSO of any issues or noncompliance. The PRSO shall develop, implement, and maintain written procedures for:

• Purchasing and receipt of radioactive material

• Safely receiving and opening packages

• Ensuring control and accountability of licensed material.

4.0 PROCEDURE

Each radiation protection plan shall include a project specific procedure for maintaining an inventory of radioactive material under its control. As appropriate, the procedure shall include provisions to assure that only authorized individuals receive radioactive materials and that those individuals receive only the types and quantities of radioactive material that they are authorized to receive. Licensed material shall not be transferred or shipped from one licensee to another without the written approval of the License RSO or the PRSO.

4.1 Receiving Radioactive Material

Site specific procedures for ordering licensed material and package receipt and opening will follow the model procedures in NUREG-1556, Vol. 18, Appendix K.

Individuals that will receive packages containing licensed material shall be trained and approved by the PRSO to do the following:

• Identify the package as radioactive by labeling and shipping papers;

• Segregate the package from other incoming items in a secured area;

• Notify the license RSO of receipt.

4.2 Inventory Sealed Sources

Sealed sources containing greater than 100 microcuries (3.7 megabecquerels [MBq]) of beta/gamma or 10 microcuries (0.37 MBq) of alpha radioactive material shall be subject to




SPL-SOP-8.1 0.3 00 01 May 2014

inventory and leak test every 6 months or at frequency specified by the license. Leaking sources must be immediately withdrawn from use and decontaminated, repaired, or disposed of according to regulatory requirements. Leak testing shall follow the procedure outlined in NUREG-1556, Vol. 18, Consolidated Guidance About Materials Licenses, Appendix 0.

4.3 Records

Site specific records shall include records of receipt, use, transfer, and disposal of all licensed material. In general, records must be maintained as follows:

• Receipt records must be maintained for as long as the material is possessed until three years after transfer or disposal.

• Transfer records must be maintained for three years after transfer.

• Disposal records must be maintained until the termination of the license.

• Records important to decommissioning must be maintained until the site is released for unrestricted use.

Records important to decommissioning include information about locations where licensed material is used or stored.

4.4 Transfers

Licensed radioactive materials may be transferred from one internal department, laboratory, or authorized user to another. The transferee must be an authorized user and must be authorized to possess the type and quantity of radioactive material being transferred. Internal transfers require prior written approval from the License RSO.

Licensed radioactive materials may be transferred to another licensee only after a copy of the transferee's license has been obtained and it has been verified that the transferee is authorized to receive and possess the radioactive material. A copy of the license should be kept on file for subsequent verification and review.

Internal or on-site transfers over nonpublic thoroughfares or between facilities on the same site must be performed in accordance with written procedures utilizing pre-approved routes. The procedures must include requirements to ensure appropriate monitoring and control of the radioactive material, including packaging, monitoring, labeling, and inventory assessment.

4.5 Generally Licensed Material

Generally licensed material may be received when a generally licensed item is transferred to a specific license that is authorized to possess the material. When received by the specific licensee, the item must now be considered as specifically licensed and shall be tracked with other specifically licensed material.

5.0 REFERENCES

• Code of Federal Regulations, 10 CFR Part 20, Standards for Protection Against Radiation • Code of Federal Regulations, 10 CFR Part 30, Rules of General Applicability to Domestic

Licensing of Byproduct Material • Code of Federal Regulations 10 CFR 33, Specific Domestic Licenses of Broad Scope for

Byproduct Material • NUREG 1556, Vol. 18, Consolidated Guidance About Materials Licenses • NUREG-1660/RAMREG-002, "Specific Schedules of Requirements for Transport of Specified

Types of Radioactive Material Consignments." • Larson, William A., A Health Physics Management Program for the Receipt and Shipment of

Radioactive Materials, Proceedings of the Ninth Midyear Topical Symposium of the Health Physics Society on "Operational Health Physics," Denver, CO, USA (1976).




SPL-SOP-8.1 0.3 00 01 May 2014

• National Council on Radiation Protection (NCRP) Report No. 114, "Maintaining Radiation Protection Records," (1992).

• NCRP Report No. 59, "Operational Radiation Safety Program," (1978). • Title 17, California Code of Regulations, Public Health. • Kansas Administrative Regulations, 28-35, Radiation Protection

6.0 TERMINOLOGY

Sealed Source-Radioactive material that is permanently bonded or fixed in a capsule or matrix designed to prevent release and dispersal of the radioactive material under the most severe conditions which are likely to be encountered in normal use and handling.

Leak Test- The test performed to determine if a sealed source has 0.005 mCi (185 kBq) or more of transferable radioactivity.

7.0 EXHIBITS

None

8.0 A TI ACHMENTS

None


PROCEDURE

Procedure Title: Occupational Dose CMS Number: SPL-SOP-8.1 0.4


OCCUPATIONAL DOSE




"©Chicago Bridge & Iron Company, 2009. All Rights Reserved. For Internal Use Only. NOTICE: THIS DOCUMENT, AND ALL TEXT, DRAWINGS, DETAILS AND DATA SHOWN HERETO, IS THE SOLE PROPERTY OF CHICAGO BRIDGE & IRON COMPANY, AND SHALL NOT BE REPRODUCED IN ANY MANNER, USED FOR ANY PURPOSE WHATSOEVER. OR RELEASED TO ANYONE EXCEPT BY EXPRESS WRITTEN PERMISSION OF CHICAGO BRIDGE & IRON COMPANY."

Occupational Dose


SPL-SOP-8.1 0.4 00 01 May 2014

1.0 PURPOSE

The purpose of this procedure is to establish the requirement for evaluation of potential internal and external occupational radiation doses. Dose projections generated are to be used in assessing the scope of radiation protection requirements, assessing requirements for external and internal dosimetry programs, and developing As-Low-As-Reasonably-Achievable (ALARA) programs.

2.0 SCOPE

This procedure applies to all CB&I LLC (CB&I) radiological activities that require occupational dose monitoring of individuals.



The License RSO shall approve an evaluation of the dose the individual is likely to receive prior to allowing the individual to receive any dose (prospective evaluation) to determine if radiation monitoring is required. The License RSO may not require monitoring if the prospective evaluation determines that an individual's dose is not likely to receive 10% of the annual dose limit.


The PRSO shall document an evaluation of the dose an individual is likely to receive prior to allowing the individual to receive any dose {prospective evaluation). The PRSO is responsible for implementing this procedure and site specific procedures. The PRSO is also responsible for notifying the License RSO of any issues or noncompliance.

4.0 PROCEDURE

4.1 Prospective Evaluation.

The PRSO shall perform a prospective evaluation of the dose individuals (or employees with similar job functions or work areas) are likely to receive prior to allowing an individual to receive the dose {prospective evaluation). Dose estimates will be based on any combination of work location radiation monitoring, survey results, monitoring results of individuals in similar work situations, or other estimates to produce a "best estimate" of the actual dose received.

If the prospective evaluation shows that an individual's dose is not likely to exceed 10% of any applicable regulatory limit, provided below, the individual is not required to be monitored for radiation exposure and there are no recordkeeping or reporting requirements for doses received by that individual. If the prospective dose evaluation shows that the individual is likely to exceed 10% of an applicable limit, monitoring is required.

Occupationally Exposed Individual -Regulatory Limits

Total effective dose equivalent (TEDE), internal and external sources Sum of the annual dose equivalent (external exposures) and committed dose equivalent, other than the lens of the eye Lens of the eye dose equivalent Shallow dose equivalent to skin or any extremity Declared Pregnant Worker TEDE

UNCONTROLLED COPY IF PRINTED

5 rem (0.05 Sv)/year

50 rem (0.5 Sv)/year

15 rem (0.15 Sv)/year 50 rem (0.5 Sv)/year

0.5 rem (0.005 Sv) /gestation period

Page 2 of 11

Occupational Dose


SPL-SOP-8.1 0.4 00 01 May 2014

The License RSO shall approve prospective dose evaluations and the PRSO shall maintain prospective dose evaluation reports with the project records.

The prospective dose evaluation shall be updated as is appropriate to field conditions and at least annually.

The License RSO shall approve prospective dose evaluations and the PRSO shall maintain prospective dose evaluation reports with the project records.

The prospective dose evaluation shall be updated as is appropriate to field conditions and at least annually.

4.1.1 External Radiation Dose

If the prospective evaluation determined that individuals are likely to receive dose in excess of 10% of the allowable limits in 10 CFR Part 20, NVLAP-accredited (or equivalent) dosimetry (film badge, TLD, OSL, etc.) processed by a NVLAP-accredited entity will be issued.

The site-specific external monitoring requirements shall be determined by the License RSO prior to the commencement of any work activities that could result in external radiation exposure.

The PRSO and/or the technical lead shall consider and implement the following external radiation dosimetry program elements when developing the site-specific RPP and Work Instructions:

a) Criteria for identifying individuals required to be monitored for exposure to external sources of radiation

b) Written procedures covering each step in the activities that determine worker external dose

c) Appropriate personnel dosimeter measurement method and frequencies

d) Adequate detection capability and quality of personnel dosimeter measurements

e) Appropriate dosmetric models and default parameters for evaluating external doses

f) Methods for control, accountability, and safe handling of dosimeters

g) Appropriate action level and investigation level guidelines

h) Timely analysis of personnel dosimeter measurements, transmission of results, dose evaluation, and recommendations to management

i) Records of the external dosimetry program and procedures, as well as changes in the program and procedures

j) Quality assurance program covering all steps in the activities that determine worker external dose

k) Appropriate workplace monitoring program

I) A program to report external doses to workers, management, and applicable regulatory agencies

m) Appropriate training


Occupational Dose


SPL-SOP-8.1 0.4 00 01 May 2014

4.1.2 Internal Radiation Monitoring Requirements - Bioassay Internal contamination monitoring shall be performed when personnel are or may be exposed to airborne contamination exceeding 0.3 DAC, or have the potential for intakes greater than 0.1 All, as defined in 10 CFR Part 20 Appendix B, Table I, Standards for Protection Against Radiation.

Suspected intakes of radioactive materials, such as may occur when there is significant skin contamination, shall be investigated by internal monitoring.

The site-specific internal monitoring requirements shall be determined by the PRSO and assigned technical lead, per the applicable technical basis document (TBD) with approval from the License RSO prior to the commencement of any work activities that could result in internal radiation exposure.

Where the possibility exists for a worker to receive a radioactive material intake, the PRSO shall manage the preparation of a site specific TBD that contains the sampling, internal dosimetry, and decision-making processes. The internal dosimetry TBD will be implemented through written procedures and the RPP. The TBD presents the scientific basis and other rationale supporting each element of the sampling, data evaluation, decision making (i.e., Action Level), and internal dosimetry program with respect to applicable regulations, requirements, and commitments.

4.2 Radiation Dose Limits and Exposure Monitoring

Exposure limits are established to control personnel exposure to ionizing radiation. Federal and State regulations provide the maximum annual doses that a radiation worker and member of the public may receive.

4.2.1 Occupationally Exposed Individuals Administrative (CB&I) Dose Limits In order to ensure that no regulatory limits are exceeded, an administrative exposure limit will be established at 80% of regulatory limits with a goal of 10% or less of the regulatory limits. No CB&I or subcontractor employee may ever be authorized to receive annual occupation radiation dose in excess of the limits in Attachment 3 of this document.

These limits at guideline levels (1-111) are established to ensure dose is consistently minimized on all projects. The set of monthly and quarterly administrative guideline levels, which are significantly below regulatory limits, are established to ensure proper exposure planning and to prevent any single individual from receiving their annual dose limit in a fraction of the year. Personnel are authorized to receive doses up to Level I without additional approval. Personnel shall not receive doses in excess of the Levels I and II monthly administrative level or the Level Ill quarterly administrative level without the appropriate approval. Approval by both the Project RSO, or equivalent, and the Project Manager responsible for the project on which the employee would exceed the limit are necessary to authorize exposures above the Level I administrative limits at their particular projects. Review by the License RSO is necessary to authorize exposures above the Level II administrative limits. The written approval of the Director, Radiation Safety is necessary to authorize exposures above the Level Ill administrative limits.

Extensions beyond the Level II or Level Ill limits shall be granted in increments of no more than 0.250 rem (2.4 mSv). Requests for all exposure limit extensions shall be made by the appropriate Project Manager or designee prior to any operation that might cause any person to exceed a guideline level.

Visitors/contract workers shall not be allowed to receive exposures in excess of 1 00 millirems (1 mSv) per calendar year unless they are fully trained as radiation workers.


Occupational Dose


SPL-SOP-8.1 0.4 00

4.2.2 Radiation Dose Limits for the Unborn Child

During the entire gestation period, the maximum permissible dose equivalent to a fetus from occupational exposure for a declared pregnant worker shall not exceed 0.5 rem (0.5 mSv) for the entire gestation period.

Prior to being issued dosimetry equipment, all personnel authorized to receive radiation exposure, all supervisors, and all females authorized to receive radiation exposure as visitors shall be given specific instruction about prenatal exposure risks to the developing embryo and fetus. This instruction shall include both verbal and applicable written information found in the appendix to NRC Regulatory Guide 8.13, Instruction Concerning Prenatal Radiation Exposure. Instruction concerning prenatal exposure to the unborn child shall be given during initial and re-verification training. All personnel receiving instruction in accordance with this section shall sign the Instruction on Radiation Exposure to the Unborn Child Acknowledgement Form prior to being issued dosimetry.

4.2.3 External Radiation Dose Monitoring

Personnel dosimetry requirements for each project shall be determined and approved by the PRSO prior to work activities involving the potential for radiation exposure.

Individuals shall not enter any radiologically controlled area without required personnel dosimetry.

With the exception of visitors, a record of the individual's current annual dose shall be obtained prior to issuing dosimeters that are required per prospective dose evaluation. Dosimeters that are not required per the prospective dose evaluation may be issued without obtaining current annual dose records.

4.2.4 Internal Radiation Dose Monitoring

The internal dosimetry program shall adequately demonstrate compliance with dose limits and action levels established in regulations, requirements, and commitments. Facility monitoring data and composite monitoring of workers may be used to support the action levels that indicate that an individual internal dosimetry program is not required. The TBD must be approved by the License RSO, PRSO and the Project Manager.

The site-specific internal dosimetry program shall include a written evaluation of the following:

• Controlling regulations, requirements, and commitments impacting the internal dosimetry program along with resolution of any conflicts.

• Expected radionuclides, chemical form, respiratory class, activities, concentrations, and exposure pathways.

• Logic, assumptions, and algorithms used for calculations.

• Estimates of possible dose (TEDE, committed dose equivalent, lens dose equivalent, and shallow-dose equivalent) and/or DAC-hour to workers performing various tasks.

• Limits, reference levels, investigation levels, and dose investigation levels based on regulations, requirements, and commitments that can be used to establish compliance with limits and action levels.

• Determination of the need for bioassay or other monitoring programs in accordance with 10 CFR 20 and guidance in NRC Regulatory Guide 8.9.


Occupational Dose


SPL-SOP-8.1 0.4 00 01 May 2014

• Monitoring and assay methods, sensitivities, and frequencies necessary to demonstrate compliance with limits and action levels. Recommended references for bioassay laboratory performance include HPS N13.30-1996, Performance Criteria for Radiobioassay and American National Standards Institute N42.23-1996, Measurement and Associated Instrumentation Quality Assurance for Radiobioassay Laboratories.

• Method for determining adequacy of monitoring and assay methods used by the project, site, or license to demonstrate compliance with limits and action levels.

4.2.5 Dose Records

The PRSO shall keep records of personnel dose and shall forward those records and data as required by CB&I procedures. Copies of all dose records will be maintained on the project site, while original exposure reports are forwarded to the appropriate CB&I office for retention.

5.0 REFERENCES

• 10 CFR Part 20, Code of Federal Regulations, Standards for Protection Against Radiation • NUREG-1556, Vol. 18, Program-Specific Guidance About Service Provider Licenses, dated

November 2000 • U.S. Nuclear Regulatory Commission, Regulatory Guide 8.7, Instructions for Recording and

Reporting Occupational Radiation Exposure Data • U.S. Nuclear Regulatory Commission, Regulatory Guide 8.9, Acceptable Concepts, Models,

Equations, and Assumptions for a Bioassay Program • U.S. Nuclear Regulatory Commission, Regulatory Guide 8.13, Instruction Concerning Prenatal

Radiation Exposure • U.S. Nuclear Regulatory Commission, Regulatory Guide 8.20, Rev. 1, Applications of Bioassay

for 1-125 and 1-131 • U.S. Nuclear Regulatory Commission, Regulatory Guide 8.34, Monitoring Criteria and

Methods to Calculate Occupational Radiation Doses • Title 17, California Code of Regulations, Public Health • Kansas Administrative Regulations, 28-35, Radiation Protection

6.0 TERMINOLOGY



Bioassay-The measurement, or assay, of kinds, quantities, or concentrations and, in some cases, the locations of radioactive materials within an individual worker. Bioassay is generally determined by in vitro methods, such as urine analysis, sampling of other body fluids (such as blood), tissue analysis,


Occupational Dose


SPL-SOP-8.1 0.4 00


Bioassay-The measurement, or assay, of kinds, quantities, or concentrations and, in some cases, the locations of radioactive materials within an individual worker. Bioassay is generally determined by in vitro methods, such as urine analysis, sampling of other body fluids (such as blood), tissue analysis, or fecal sample. Bioassay may also be performed by direct (in vivo) measurement using specialized radiation detection equipment.

Controlled Area-An area, outside of a posted Restricted Area but inside the site boundary, access to which can be limited by the licensee for any reason.

Declared Pregnant Worker-A woman who has voluntarily informed the licensee, in writing, of her pregnancy and the estimated date of conception. The declaration remains in effect until the declared pregnant woman withdraws the declaration in writing or is no longer pregnant.

Derived Air Concentration (DAC)-The concentration of a given radionuclide in air which, if breathed by the reference man for a working year of 2,000 hours under conditions of light work (inhalation rate 1.2 cubic meters of air per hour), results in an intake of one annual limit on intake (All).

Derived Air Concentration Hours (DAC-hours)-The product of the concentration of radioactive material in air (expressed as a fraction or multiple of the derived air concentration for each radionuclide) and the time of exposure to that radionuclide, in hours. A licensee may take 2,000 DAChours to represent one All, equivalent in most cases, to a committed effective dose equivalent of 5 rems (0.05 Sievert [Sv]).


External Dose-That portion of the dose equivalent received from radiation sources outside the body.

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 0.1 rem (1 mSv) in 1 hour at 30 centimeters from the radiation source or 30 centimeters from any surface that the radiation penetrates.

lntake--Radionuclides entering the body by any exposure pathway, primarily inhalation, absorption, or ingestion means.

Investigation Level-The level of exposure above which the result is regarded to be of sufficient concern to warrant additional investigation. Investigation levels should be established for routine and non routine monitoring.

In Vitro-"ln the glass." For the purposes of an internal dosimetry program, in vitro bioassay measurements are performed by analysis of bodily fluids or tissues removed from the body and analyzed in a laboratory environment.

In Vivo-"ln the living body." For the purposes of an internal dosimetry program, in vivo bioassay measurements are performed by measuring radionuclide body burden within the body using specialized detection instrumentation and monitoring techniques.


Monitoring-The measurement of radiation levels, concentrations, surface area concentrations, or quantities of radioactive material and the use of the results of these measurements to evaluate potential exposures and doses.


Occupational Dose


SPL-SOP-8.1 0.4 00

Radiation Area-An area accessible to individuals in which radiation levels could result in an individual receiving a dose equivalent in excess of 0.005 rem (0.05 mSv) in 1 hour at 30 centimeters from the radiation source or from the surface that the radiation penetrates.

Radiation Worker-An individual who is properly trained, in accordance with the personnel training requirements of 10 Code of Federal Regulations (CFR) 19.12, U.S. Department of Energy Radiation Worker, or equivalent training, to perform work activities involving the potential for exposure to ionizing radiation.

Restricted Area-An area to which access is limited by the licensee for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive materials. Restricted area does not include areas used as residential quarters, but separate rooms in a residential building may be set apart as a restricted area.

Stay Time-Allowable dose per task divided by radiation dose rate.

Thermoluminescent Dosimeter (TLD}-Radiation monitoring device used to record the radiological exposure of personnel or areas to certain types of radiation.

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 (5 grays) in 1 hour at 1 meter from a radiation source or 1 meter from any surface that the radiation penetrates.

Whole Body-For purposes of external exposure, head, trunk (including male gonads), arms above the elbow, or legs above the knee ..

7.0 EXHIBITS

8.0 ATTACHMENTS

8.1 Instruction on Radiation Exposure To The Unborn Child Acknowledgement Form

8.2 Visitor/Contract Worker Exposure Record Form

8.3 CB&I Quarterly/Annual Administrative Dose Limits


Occupational Dose

I CMS Number: Revision: A_mll'oval Date:

I SPL-SOP-8.1 0.4 00 01 May 2014

8.1 ATTACHMENT

INSTRUCTION ON RADIATION EXPOSURE TO THE UNBORN CHILD

ACKNOWLEDGEMENT FORM

All personnel receiving instruction in accordance with Section 4.2.2 shall sign the following statement prior to being issued dosimetry equipment:

"The recommendation of the National Council on Radiation Protection and Measurements to limit radiation exposure to the unborn child to the very lowest practicable level, not to exceed 0.5 rem (5 mSv) during the entire period of pregnancy, has been explained to me."

Signature-----------------------------------------------------------------------

Typed or Printed Name-------------------------------------------------------------

Date------------------------------------------------------------------------


Occupational Dose


SPL-SOP-8.1 0.4 00

8.2 ATTACHMENT

Visitor/Contract Worker Exposure Record Form

Date Name (Print) Organization TLD or SS# Dose


Occupational Dose


SPL-SOP-8.1 0.4 00 01 May 2014

8.3 Attachment

CB&I ADMINISTRATIVE DOSE LIMITS

ACCUMULATED CALENDAR APPROVALS

LEVEL DOSE (rem/mSv)

CATEGORY PERIOD

REQUIRED FOR EXTENSION

I 0.125 I 1.25 TEDE Quarter Project RSO, or equivalent, and Project Manager

0.375 I 3.75 LDE Quarter "

1.250 I 12.5 SDE, TODE Quarter "

II 0.25 I 2.5 TEDE Quarter License RSO Review, Project

Manager Approval

0.750 I 7.5 LDE Quarter "

2.5 I 25 SDE, TODE Quarter u

Ill 1.0 I 10 TEDE Quarter License RSO Review, Director, Radiation Safety

Approval

3.0 I 30 LDE Quarter u

10.0 I 100 SDE, TODE Quarter "

MAXIMUM 4.0 I 40 TEDE Annual No Extension LIMIT Allowed

12.0 I 120 LDE Annual "

40.0 I 400 SDE, TODE Annual "

TEDE = Total Effective Dose Equivalent

LDE = Lens Dose Equivalent

SDE = Shallow Dose Equivalent

TODE = Total Organ Equivalent


PROCEDURE

Procedure Title: Public Dose CMS Number: SPL-SOP-8.1 0.5

Procedure Mark Somerville Issuing CFS Radiation Safety Group Owner: Authoritv:

PUBLIC DOSE





Public Dose


SPL-SOP-8.1 0.5 00

1.0 PURPOSE

The purpose of this procedure is to establish the requirement for radiological methodology that will be instituted on CB&I Federal Services LLC (CB&I) projects to ensure that licensed material will be used, transported, stored, and disposed of in such a way that members of the public will not receive more than 100 millirem (mrem) (1 milliSievert [mSv]) Total Effective Dose Equivalent (TEDE) in one year, and that the dose in any unrestricted area will not exceed 2 mrem (0.02 mSv) in any one hour, from licensed operations. Procedures will also ensure that CB&I will control and maintain constant surveillance of licensed material when in use and not in storage and secure stored licensed material from access, removal, or use by unauthorized personnel.

2.0 SCOPE

This procedure applies to all CB&I radiological activities and personnel associated with the implementation of a radiation protection program (RPP) that may involve the possibility of exposure to the public. Public dose is defined in 10 Code of Federal Regulations (CFR) 20 as "the dose received by a member of the public from exposure to radiation and/or radioactive material released by a license, or to any other source of radiation under the control of a licensee." Public dose excludes doses received from background radiation and from medical procedures. Whether the dose to an individual is an occupational dose or a public dose depends on the individual's assigned duties and not on the area (restricted, controlled, or unrestricted) the individual is in when the dose is received.



The License RSO shall approve the methodology that document estimates of public dose that are ALARA and do not exceed regulatory limits. Periodically evaluate public dose assumptions and confirm that estimates are appropriate revise as required. Approve the environmental monitoring requirements for the project.


The PRSO shall Implement the ALARA radiation safety program designed to ensure that no member of the public receives a total effective dose equivalent in one year exceeding 100 mrem (1 mSv) due to the performance of project tasks. Ensure radiation levels in unrestricted areas do not cause an individual continuously present in the area to receive more than 2 mrem (0.02 mSv) in one hour. Develop and implement the environmental monitoring requirements necessary to confirm all doses to the environment and the public are consistent with CB&I ALARA policy and control all radioactive material and ensure that material is not released outside a posted Restricted Area in excess of limits established in any applicable regulatory guidance.

4.0 PROCEDURE

Each project will have a site-specific radiation protection plan (RPP) and necessary site-specific procedures which address the specific controls appropriate for ensuring public dose will not equal or exceed 100 mrem (1mSv) in one year and that the dose in any unrestricted area will not exceed 2 mrem (0.02 mSv) in any one hour, from licensed operations. ALL site-specific RPP's shall be reviewed annually to ensure compliance with the terms of the License and applicable regulations. The review shall ensure that doses to members of the public are ALARA. Records of audits and other reviews of program content are maintained for at least three years from the date of the record.

4.1 Demonstrating that Individual Members of the Public Will Not Receive Dose Exceeding the Allowable Limits

The method License RSO used to estimate public dose shall be addressed in the site-specific RPP and detailed in the annual public dose report for approval by the License RSO. Factors included in the estimate are the amount and location of the use and storage of radioactive


Public Dose


SPL-SOP-8.1 0.5 00

material and/or radiation producing devices, the dose rates associated with this material during project operations, the occupancy and use factors associated with each location, and the physical processes involved with the transport of radioactive material from its source to a location where it becomes available to exposure a member of the public.

Project compliance with the annual dose limit for individual members of the public may be demonstrated by:

• Demonstrating that the TEDE to an individual likely to receive the highest dose at the boundary of the unrestricted area does not exceed 100 mrem (1 mSv).

• Demonstrating that the annual average concentration of radioactive material released in gaseous and liquid effluents at the boundary of the unrestricted area does not exceed the values specified in Table 2, Appendix B, 10 CFR Part 20 (or similar limits imposed by other regulators); and if an individual were continuously present in an unrestricted area the dose from external sources would not exceed 2 mrem (0.02 mSv) in any hour and 50 mrem (0.5 mSv) in a year.

• Demonstrating that air emissions of radioactive material do not result in doses greater than 10 mrem (0.1 mSv) TEDE.

Measurements may be used to demonstrate that the TEDE to the individual likely to receive the highest dose at the boundary on the unrestricted area does not exceed 100 mrem (1 mSv), and that the average annual releases are below regulatory limits. These measurements may include both dose rate surveys for radiation exposures from external sources and measurements of radionuclides in air and water effluents.

Calculations that are used to demonstrate compliance with limits must determine the highest dose an individual is likely to receive at the boundary of the unrestricted area. These calculations must take all exposure pathways into account (external, waterborne, airborne).

NUREG 1556, Vol. 18, Appendix M, can be used for further guidance to developing sitespecific methods for determining public dose from operations.

Public dose calculations do not need to be estimated based upon a worst-case scenario. Scenarios should be realistic and the member of the public likely to receive the highest dose should be considered when determining annual public doses.

Major Dose Pathway Groups:

• Airborne radioactive material

• Waterborne radioactive material

• External radioactive exposure.

Note: The PRSO shall provide the continuous or periodic sampling and/or monitoring required to detect the levels of airborne and waterborne radioactivity and external radioactive exposure in accordance with applicable CB&I procedures. The monitoring program will ensure compliance to Code of Federal Regulations, 10 CFR 20, California Code of Regulations, Title 17, Public Health, and any other applicable regulations

4.2 Environmental Monitoring and Reporting

4.2.1 The PRSO shall develop the environmental monitoring requirements for the project, as applicable, and the License RSO shall review and approve those requirements. The types of samples and analyses are dependent on the radionuclides at the site and the possible release mechanisms.

The site specific environmental monitoring program may require monitoring of direct radiation, air, water, soil, and vegetation.


Public Dose


SPL-SOP-8.1 0.5 00 01 May 2014

• Direct radiation may be monitored by TLDs placed at the site boundary and at off-site locations.

• Air monitoring may consist of taking samples for airborne particulate at the site boundary and at off-site locations. The techniques may be similar to those used to monitor occupational airborne activity.

• Water monitoring may be performed by taking water samples from surface water bodies (i.e., lakes, ponds, and streams), surface runoff, and wells located both on and off site and analyzing those samples for radionuclide content.

• Surface soil samples may be collected and analyzed for radioactivity.

4.2.2 Documenting Annual Public Dose

Within 60 days of receipt of final environmental sample and monitoring results, the PRSO shall prepare and submit an annual public dose report to the License RSO for approval. The report shall detail the methodology used to determine the public dose, including but not limited to the radionuclide(s) of concern, pathways of exposure, occupancy and use factor assumptions.

The License RSO's approval of the annual public dose report meets the requirement stipulated in Section 5.1

4.2.3 Public Dose Records

5.0 REFERENCES

All records relevant to the calculation or measurement of public dose shall be in the project records in accordance with 10 CFR 20.2107. This includes ALARA determinations, pathway analyses, effluent release measurements, off-normal occurrences, recovery actions, administrative and engineering controls instituted to reduce collective dose, surveys in support of public dose determination, and copies of the approved annual dose reports.

• Code of Federal Regulations, 10 CFR Part 20, Standards for Protection Against Radiation

• NUREG-1556, Vol. 18, "Program-Specific Guidance About Service Provider Licenses,' dated November 2000

• US Nuclear Regulatory Commission, Regulatory Guide 8.13, Instruction Concerning Prenatal Radiation Exposure

• California Code of Regulations, Title 17, Public Health.

• Kansas Administrative Regulations, 28-35 Radiation Protection

6.0 TERMINOLOGY



Public Dose


SPL-SOP-8.10.5 00


Controlled Materials-Any licensable radioactive material controlled by CB&I at a project location under NRC license or Agreement State license.


External Dose--That portion of the dose equivalent received from radiation sources outside the body

Internal Dose - That portion of the dose equivalent received from the uptake of radioactive material in the body.

Inventory-Licensable radioactive materials that are in the possession of CB&I prior to the beginning of a project and materials controlled by CB&I during the course of a project.


Licensed Material-Source material, special nuclear material, or byproduct material received, possessed, used, transferred, or disposed of.

Monitoring-The measurement of radiation exposure and dose levels, concentrations, surface area contamination, or quantities of radioactive material.

TEDE-Total effective dose equivalent. The sum of the deep-dose equivalent (for external exposures) and the committed effective dose equivalent (for internal exposures).

Thermoluminescent Dosimeter (TLD)-Radiation measuring device that uses lithium fluoride crystals to record radiation exposure.

Whole Body-For purposes of external dose, the whole body is defined as including the head, trunk (including male gonads), arms above the elbow and legs above the knee.

X-Ray Radiation-High-energy, short-wavelength photons produced outside an atomic nucleus by the interaction or attenuation of other types of radiation. Identical to gamma radiation in ability to penetrate human tissue and pose a substantial external radiation hazard.

7.0 EXHIBITS

None

8.0 ATTACHMENTS

None


PROCEDURE

Procedure Title: Safe Handling of Radioactive CMS Number: SPL-SOP-8.1 0.6 Materials and Emergency Procedures


SAFE HANDLING OF RADIOACTIVE MATERIALS AND EMERGENCY PROCEDURES





Safe Handling of Radioactive Materials and Emergency Procedures


SPL-SOP-8.1 0.6 00

1.0 PURPOSE

The purpose of this procedure is to establish the requirements applicable to radiological safety considerations for handling radioactive material associated with CB&I Federal Services LLC (CB&I) operations. Strict radiological control procedures are mandatory for such material to minimize the external and internal radiation exposure received by personnel and to prevent the uncontrolled spread of radioactive materials.

2.0 SCOPE

This procedure applies to all CB&I projects involving the use of radioactive materials. The direction provided by this document may be amended to comply with specific client, project, program, or regulatory requirements that are equivalent, or more restrictive, when compared to the requirements of this document. Such variances shall be implemented with proper documentation in project records and approval by the proper project authority. These variances will be applicable only for specific project use.



The License RSO shall ensure that appropriate site specific procedures are established to implement the requirements of this procedure. Work plans or other documents that discuss responses to unexpected conditions may substitute for additional, specific procedures. The License RSO or designated authorized user is responsible for all regulatory and emergency notifications.


The PRSO is responsible for implementing this procedure and site specific procedures. The PRSO is also responsible for notifying the License RSO of any issues or noncompliance.

4.0 PROCEDURE

4.1 Receipt of Radioactive Material.

If a radioactive material receipt procedure is required by a project the License RSO shall approve prior to ordering materials. CB&I requires specific control procedures be in place to ensure that adequate radiological safety precautions are observed, both in unpacking and in subsequent use of the material. The procedure shall address potential radiological problems including external exposure, surface contamination, and airborne radioactivity. The procedure shall also address special precautions if damage is suspected during shipment. The minimum requirements for receipt of radioactive materials procedure shall include the following;

• Receipt Inspection - When received, the radioactive material shall be inspected. This inspection shall be performed as soon as practical after receipt of the package, but not later than three hours after the package is received at the licensee's facility if it is received during the licensee's normal working hours, or not later than three hours from the beginning of the next working day if it is received after working hours.

This inspection shall consist of verifying radiation and contamination levels on the outside of the package and verifying that the package was properly transferred. The package shall be opened solely for the survey purposes unless directed by the PRSO. For packages that are shipped, this inspection shall verify that the package was shipped in accordance with U.S. Department of Transportation, state, and federal regulations, and other federal and state requirements for notification and permitting.

• Damaged/Contaminated Package - If damage to the radioactive material package has occurred, or removable surface contamination exceed the regulatory limits for




SPL-SOP-8.1 0.6 00

transportation (10 Code of Federal Regulations [CFR] 71.87), or the external radiation level exceeds the regulatory transport limits (10 CFR 71.47), the PRSO shall immediately notify the final delivery carrier and the U.S. Nuclear Regulatory Commission (NRC) Operations Center and the appropriate Agreement State contact (i.e. CDPH, KDHE) by telephone.

• Investigate in accordance with CB&I Health and Safety Procedure CMS-710-05-PR-02300, Incident Investigation.

• Inventory - Received packages shall be inventoried as soon as possible.

• Records - Records of the transfer of radioactive material and all associated survey documentation shall be maintained in the on-site project file throughout the duration of the project.

4.2 Packaging and Shipping Radioactive Materials

Site specific procedures for shipping radioactive materials shall require that radioactive materials be packaged and treated as required by U.S. Department of Transportation regulations, applicable federal and state regulations, and applicable disposal site criteria. Packaging for transport and other transportation related activities require function specific training as specified in 49 CFR 172 Subpart H.

4.3 Radioactive Material Storage

At a minimum, all radioactive material storage areas shall be posted in accordance with 1 0 CFR Part 20, Standards for Protection Against Radiation. This means that a room or area containing 10 times 10 CFR 20 Appendix C quantities will be posted as "Caution- Radioactive Material". Individual containers will be labeled in a manner appropriate to the contents of the container. Typically, a container holding an "Appendix C" quantity of radionuclides singly or as a sum of the fractions will be labeled "Radioactive Materials", include the trefoil, and contain information appropriate to adequately inform individuals about internal and external radiological conditions.

4.3.1 Fire Protection

Proper selection of a fire-resistant storage area for radioactive material shall minimize the release of radioactivity to the environment in the event of a fire. The project health and safety plan shall include discussion of fire protection.

4.3.2 Contamination Control

Storage locations should routinely be assessed for radiological contamination. Personnel in these areas, particularly if they handle contaminated material, shall wear necessary anti-contamination clothing when such a precaution is appropriate based on the results of surveys. Reasonable care shall be taken in packaging and storing contaminated items to prevent the spread of contamination and to ensure that entry to areas where such storage is permitted does not result in the contamination of personnel or other areas.

4.3.3 Radiation Exposure Control

Storage of radioactive materials can result in possible personnel radiation exposure in the storage area and surrounding areas. Facilities should store radioactive materials so as to minimize the radiation exposure of personnel entering or working in the area and of personnel in surrounding spaces. Radiation surveys of the storage area and of spaces immediately around the storage area shall be performed to ensure proper posting of radiation areas and to prevent inadvertent exposure of personnel in the storage space or surrounding spaces. 1/Vhen necessary, temporary shielding should be used to reduce radiation levels.




SPL-SOP-8.1 0.6 00

4.3.4 Loss of Radioactive Material

If radioactive material associated with CB&I operations is suspected of being lost, the following actions shall be taken:

5.0 REFERENCES

• Immediately notify the PRSO and License RSO and conduct a search for the lost material. A primary purpose of this search is to ascertain that no persons shall receive inadvertent internal or external radiation exposure from this material.

• Follow up with the proper reports and investigation in accordance with CB&I Health and Safety Procedure CMS-710-05-PR-02300, Incident Investigation.

• Code of Federal Regulations, 10 CFR Part 20, Standards for Protection Against Radiation

• Code of Federal Regulations, 10 CFR Part 19, Notices, Instructions, and Reports to Workers: Inspection and Investigations

• California Code of Regulations, Title 17, Public Health


• NUREG-1556, Vol. 18, Program-Specific Guidance About Service Provider Licenses, dated November 2000.

• CMS-71 0-05-PR-02300, Incident Investigation

6.0 TERMINOLOGY


Contamination-The deposition of unwanted radioactive material on surfaces or in media.


Monitoring-The measurement of radiation levels, concentrations, surface area concentrations or quantities of radioactive material, and the use of the results of these measurements to evaluate potential exposures and doses


Transferable, Removable, or Loose Contamination-Radioactive material that can be easily removed from a surface or item.




SPL-SOP-8.1 0.6 00 01 May 2014

7.0 EXHIBITS

7.1 Emergency/Regulatory Notifications- NRC

8.0 ATTACHMENTS

None




SPL-SOP-8.1 0.6 00

Exhibit 7.1 EMERGENCY/REGULATORY NOTIFICATIONS- NRC

Incident Notifications

Event Telephone Written Requirement

Notification Report

Theft or loss of material Immediate 30 days 10 CFR20.2201 (a)(1 )(i)

Whole body dose > 25 rem (0.25 Immediate 30 days 10 CFR20.2202(a)(1 )(i) Sievert [Sv))

Extremity dose > 250 rem (2.5 Sv) Immediate 30 days 10 CFR20.2202(a)(1 )(iii)

Whole body dose > 5 rem (0.05 Sv) 24 hours 30 days 10 CFR20.2202(b)(1 )(i) in 24 hours

Extremity dose > 50 rem (0.5 Sv) in 24 hours 30 days 10 CFR20.2202(b)(1 )(iii) 24 hours

Whole body dose > 5 rem (0.05 Sv) None 30 days 10 CFR20.2203(a)(2)(i)

Dose to individual member of the None 30 days 10 CFR20.2203(a)(2)(iv) public> 100 rem (1 mSv)

Defect in equipment that could create a substantial safety hazard 2 days 30 days 10 CFR21.21 (d)(3)(i)

Filing petition for bankruptcy under None Immediately after 10 CFR30.34(b) 11 U.S.Code filing petition

Expiration of license None 60 days 10 CFR30.36(d)

Decision to permanently cease None 60 days 10 CFR30.36(d) licensed activities at entire site

Decision to permanently cease None 60 days 10 CFR30.36(d) licensed activities in any separate building or outdoor area that is unsuitable for release for unrestricted use

No principal activities conducted for None 60 days 10 CFR30.36(d) 24 months at entire site

No principal activities conducted for None 60 days 10 CFR30.36(d) 24 months in any separate building or outdoor area that is unsuitable for release for unrestricted use

Event that prevents immediate Immediate 30 days 10 CFR30.50(a) protective actions necessary to avoid exposure to radioactive material that could exceed regulatory limits

Equipment disabled or fails to 24 hours 30 days 10 CFR30.50(b)(2) function as designed when required to prevent radiation exposure in excess of regulatory limits

Unplanned fire or explosion that 24 hours 30 days 10 CFR30.50(b)(4) affects the integrity of any licensed material or device, container, or equipment with licensed material




SPL-SOP-8.1 0.6 00

Incident Notifications

Event I

Telephone I Written

I Requirement Notification Report

Note: Telephone notifications shall be made to the NRC Operations Center at (301) 816-5100 or at (301) 951-0550.


PROCEDURE

Procedure Title: Surveys and Monitoring CMS Number: SPL-SOP-8.1 0. 7


SURVEYS AND MONITORING





Surveys and Monitoring


SPL-SOP-8.1 0. 7 00

1.0 PURPOSE

The purpose of this procedure is to establish the requirements for developing site specific survey and monitoring procedures necessary to evaluate exposure to personnel and concentrations of radioactive material.

2.0 SCOPE

This procedure applies to all CB&I Federal Services LLC (CB&I) radiological projects and personnel performing radiological surveys and monitoring. These evaluations may be measurements (e.g., radiation levels measured with survey instruments or results of wipe tests for contamination}, calculation, or a combination of measurements and calculations. The License RSO will ensure that each project determines the proper selection and use of appropriate instruments.

Each radiation protection plan (RPP) shall include requirements to evaluate and document radiological hazards which may be present. Methods used to perform these surveys include air sampling, smear testing, collection and analysis of samples, measurement of the intensity of radiation fields, calculations, and observations. A schedule for performing surveys of various types shall be established for each project.



The License RSO shall ensure that appropriate site specific procedures are established to implement the requirements of this procedure. The License RSO approves the selection and use of appropriate instruments and the schedule for performing surveys of various types for each site.

3.2 Project Radiation Safety Officer (PRSO


4.0 PROCEDURE

4.1 Monitoring of External Radiation Exposure Levels.

Radiation safety personnel shall monitor locations where individuals may be exposed to radiation intensities that may result in radiation doses in excess of 10 percent of the limits specified in 10 Code of Federal Regulations (CFR) Part 20 or appropriate Agreement State regulation . Performance of radiation surveys should include, for example, dose rate measurements of the general area, dose rates at a distance of 30 centimeters from a source or surface of interest to evaluate potential whole body exposures, and dose rates on contact with potential sources of radiation where there is potential for hands-on work.

Site specific monitoring requirements shall be established prior to the start of site activities and should include pre-operational, routine, and special surveys. These requirements may be included in work plans or other documents as steps used to characterize a work location.

• Pre-operational surveys are performed before work commences in order to establish baseline exposure levels. The results are used to plan work and appropriate radiological controls, estimate future worker dose, and verify assumptions concerning exposure levels.

• Routine surveys are performed in order to evaluate the impact of operations on radiological conditions, assess the radiological controls currently in place and modify them if necessary, and identify in a timely manner unexpected radiological conditions that may adversely impact worker exposure.

• Special surveys are performed to evaluate specific non-routine conditions. These may include surveys in support of accident and emergency situations.




SPL-SOP-8.1 0. 7 00

• Area radiation monitors may be required by the License RSO in frequently occupied locations with the potential for unexpected increases in dose rates and in remote locations where there is a need for local indication of dose rates prior to personnel entry.

4.2 Measurements of Airborne Radioactivity

The radiation safety staff shall perform measurements of airborne radioactivity for areas where radioactive materials are handled or processed in un-encapsulated form if by surveillance or calculation it is determined that operations could expose a worker to the inhalation of quantities of radioactive materials exceeding those specified in 10 CFR 20.1502(b) (1 0 percent or more of the specified Annual Limit on Intake [All] values (200 Derived Air Concentration hours). An annual intake of 10 percent of a specified All generally represents a committed effective dose equivalent to a person of approximately 500 millirem (5 millisieverts [mSv]). Project-specific air monitoring requirements shall be established by the PRSO.

Air samples used to monitor individual exposure to airborne radioactivity should be representative of the air in the worker's breathing zone. However, when obtaining representative samples from the breathing zone is not practicable, every effort should be made to locate the sample collection media in a location known or suspected of containing a higher concentration of radioactive material than the breathing zone (e.g., position the sample collection device between the worker and the source of airborne radioactive material). When measuring the quantity of radioactive material deposited on an air sample filter, consideration should be given to activity calculation corrections for self-absorption by the filter media. Sitespecific policies and procedures shall be supported by a written and approved technical basis.

Air samples shall be obtained for all work activities requiring respiratory protection unless respiratory protection is prescribed for non-radiological purposes or respiratory protection is chosen by individual workers as a preference but is not otherwise justified as appropriate considering the Total Effective Dose Equivalent (TEDE) to the worker. The calculated airborne radioactive material concentration is used to support the decision to use specific respiratory protection and may provide a basis for the calculation of worker committed effective dose equivalent in lieu of bioassay results.

Continuous air monitors can be used to verify that the concentration of airborne radioactive material is not likely to exceed 25 percent of the values given in 10 CFR 20, Appendix B, Table I. It may also serve to provide a warning signal that the buildup of airborne radioactivity has become unexpectedly high. Where there is a need to alert potentially exposed workers to unexpected increases in the airborne radioactivity levels, the air monitor should be located as close to the potential source of airborne radioactivity as possible. When used to monitor intakes, the air monitor should be positioned within the work area to measure air concentrations to which workers are exposed. Continuous air monitoring equipment shall have alarm capability and sufficient sensitivity to alert personnel that immediate action is necessary in order to minimize or terminate inhalation exposures.

4.3 Surface Contamination Surveys

The RPP shall address routine monitoring for radioactive contamination, which is a necessary part of the survey program. Failure to control surface contamination may result in unnecessary exposure to personnel. Limiting contamination to areas where it can be adequately controlled will assist in detecting any loss of control as early as possible.

Removable contamination (smearable contamination) is that fraction of the total contamination present that can be easily transferred to the skin and clothing of workers and to tools and instruments and that is readily available to become airborne.

The instruments used to detect removable contamination shall be determined based site specific conditions and shall be sensitive enough to detect the nuclides present at a fraction of the control levels. The area sampled should be uniform (typically 100 square centimeters [cm2

])

so that the data are easily comparable to other smear data. Smear survey results on items smaller than 100 cm2 should be clearly indicated as such to avoid erroneous interpretation.




SPL-SOP-8.1 0. 7 00 01 May 2014

Similarly, large area wipes can be obtained to evaluate general conditions and trends. Survey results of these large area wipes should also clearly indicate that they are not 100 cm2 in area.

Total surface contamination limits in restricted areas above which decontamination is required shall be developed on a site-specific basis. These limits shall consider the type of work to be performed, the need to avoid transfer of contamination to unrestricted areas, the potential to create airborne radioactivity and the personnel dose associated with the decontamination effort.

4.4 Equipment Contamination Surveys

Potentially contaminated equipment shall be surveyed, decontaminated if necessary, or controlled as radioactive material. Site-specific guidelines shall be developed which address the actions to be taken to control, store, decontaminate, and dispose of contaminated tools and equipment. This guide should include consideration of factors such as the use, the potential for personnel exposure, the value of the equipment, and the required storage and decontamination effort.

4.5 Personnel Surveys

Workers who enter restricted areas where removable radioactive contamination is present shall be required to don protective clothing prior to entry and to remove it prior to exiting. After removal of this protective clothing, the worker should be required to perform a whole body frisk. This survey includes exposed body surfaces as well as any clothing (such as modesty garments, personal clothing, and hard hats) that will be worn outside of this restricted area. The site specific RPP shall specify contamination survey criteria. Workers shall be required to report all incidences of contamination above these criteria to the PRSO or designee. Radiation protection personnel will perform follow-up actions which may include decontamination or control of contaminated items. Site-specific decontamination procedures should be developed that address all aspects of this process. Components of this process include control of personal items that cannot be successfully decontaminated, skin decontamination, postdecontamination surveys, repeated decontamination efforts, protocols for control and monitoring of personnel with skin contamination that cannot be successfully removed, personnel dose assessments and bioassays as a result of contamination, records, and reports associated with the contamination incident and follow-up actions to address the root cause of the loss of control.

4.6 Unrestricted Release Surveys

Surveys of all material and equipment removed from restricted area shall be documented. The release criteria and survey instrument(s) for conducting unrestricted release surveys including minimum detectable concentration (MDC) shall be documented in site specific procedures.

4.7 Surveys in Unrestricted Areas

Unrestricted areas shall be surveyed to ensure that radiation and radioactive material are adequately controlled. Contamination surveys shall be performed and documented at frequencies established by the PRSO. Frequency should be consistent with the potential for spreading contamination and the consequences of the loss of radiological control. Radiation surveys should be performed and documented at frequencies consistent with the potential for uncontrolled personnel exposure and the potential to exceed 10 CFR 20.1301 (dose limits for individual members of the public) requirements.

Contamination found in unrestricted areas shall be assessed for health and safety issues and communicated by the PRSO to appropriate individuals if outside the scope of the project. The need for decontamination should be based on the project scope and the health and safety assessment.




SPL-SOP-8.10.7 00 01 May 2014

4.8 Survey Instrumentation

The radiation detection instruments used to monitor the site and the workers shall be approved by the License RSO and shall be appropriate for the physical environment, the amount and type of radiation to be detected, and the skill level of the radiation protection technician. Each instrument shall have procedural guidance on its operating characteristics, use, detection levels, maintenance and calibration, preparation and use of control charts, daily use checks, and training requirements for its operators.

4.9 Frequency of Surveys

The frequency of surveys depends on the nature, quantity and use of radioactive materials, as well as the specific facilities, equipment and procedures that are designed to protect the workers. Surveys shall be performed before, during, and at the completion of work that has the potential for causing changes in levels of radiation and radioactivity. Survey frequencies shall be established in the RPP or site specific procedures.

Baseline surveys should be performed before any work is initiated or any radioactive material is introduced into the facility. Initial surveys should be performed as soon as normal operations commence so that general levels can be evaluated. Surveys should be conducted after any circumstance that has the potential to cause a significant change in conditions. Routine surveys are necessary to monitor the work control measures and worker protection systems and procedures.

4.10 Records of Surveys

Survey records shall be documented legible, understandable, and authenticated by authorized personnel. The signature of the person making the record should be on the same page as the record.

Record-keeping requirements should be formalized in the site-specific radiation protection program procedures and should conform to the legal requirements of 10 CFR 20.

Each survey record shall include the following:

• A diagram of the area surveyed; • A list of items and equipment surveyed; • Specific locations on the survey diagram where wipe test was taken; • Ambient radiation levels with appropriate units; • Contamination levels with appropriate units; • Make and model number of instruments used; • Background levels; • Name of the person making the evaluation and recording the results and date.

Personnel contamination records shall include the following:

• Contamination levels observed • Decontamination procedures followed • Names of individuals involved, • Description of work activities, • Calculated dose, • Probable causes (including root causes), • Steps taken to reduce future incidents of contamination, • Times and dates of incident, • Surveyor's signature.




SPL-SOP-8.1 0. 7 00

5.0 REFERENCES

• Title 10 Code of Federal Regulations, Part 20, Standards for Protection Against Radiation • Title 17, California Code of Regulations, Public Health • Kansas Administrative Regulations, 28-35 Radiation ProtectionNureg-1556, Vo. 18,

Consolidated Guidance About Materials License.

6.0 TERMINOLOGY

Removable Contamination-Contamination that is easily transferred to the skin and clothing of workers and to tools and instruments, and that is readily available to become airborne.

Total Surface Contamination-Combination of fixed and removable contamination.

TEDE-The sum of the deep-dose equivalent (for external exposures) and the committed effective dose equivalent (for internal exposures).

Restricted Area-An area access to which is limited by the licensee for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive materials. A restricted area does not include areas used as residential quarters, but separate rooms in a residential building may be designated as a restricted area.

Unrestricted Areas-An area with unlimited access.

7.0 EXHIBITS

None

8.0 ATTACHMENTS

None


PROCEDURE

Procedure Title: Minimization of Contamination CMS Number: SPL-SOP-8.10.10


MINIMIZATION OF CONTAMINATION





Minimization of Contamination

CMS Number: Revision: Approval Date: I SPL-SOP-8.10.10 00 01 May 2014 I

1.0 PURPOSE

This purpose of this document is to establish the requirements for developing and implementing a contamination control program that will comply with applicable regulations. The overall purpose of these regulations is to limit, to the extent practicable, the exposure of people and the environment to radiation and radioactive materials associated with operations.

2.0 SCOPE

This procedure applies to all CB&I Federal Services LLC (CB&I) radiological activities and personnel responsible for implementing a contamination control program.



The License RSO shall ensure that appropriate site-specific procedures are established to implement the requirements of this procedure. The License RSO is responsible for all regulatory and emergency notifications.


The PRSO is responsible for implementing this procedure and site-specific procedures. The PRSO is also responsible for notifying the License RSO of any issues or noncompliance.

3.3 Radiological Control Technician (RCT)

The RCT is an individual who, by virtue of education, experience, or certification, is qualified to perform radiological surveys and implement radiological controls for work activities procedure

4.0 PROCEDURE

Each specific Radiation Protection Plan (RPP) shall include prov1s1ons for limiting the spread of radioactive contamination. The key component of contamination control is the identification and demarcation of areas where contamination is likely. Contamination control shall emphasize controlling the flow of personnel, equipment, and supplies into and out of these areas. A work site may utilize other techniques appropriate for the environment, such as dust management plans, to effectively control the spread of contaminants including radioactive materials.

Activities that have the potential to generate contamination shall be identified and evaluated to ensure that appropriate controls are established.

A contamination monitoring program as described in SOP 8.10.7, Surveys and Monitoring, shall be implemented to evaluate the control program and to provide accurate and timely information which may be necessary for recovery actions.

4.1 Physical Design Features

When possible, physical design features of a facility shall be considered for purposes of contamination control. The controls shall be appropriate to the extent of the radiological hazards and the potential adverse effects of uncontrolled releases.

For new construction and facility modifications, a review and evaluation of physical design and engineering controls designed to support workplace contamination control shall be conducted. The evaluation should identify additional and/or modified engineering controls needed to ensure adequate contamination control. Contamination control design features that shall be considered include:

• Containment of radioactive materials • Components and materials that minimize leakage across seals • Catch basins and controlled drains



CMS Number: Revision: I Approval Date: I SPL-SOP-8.10.10 00 I 01 May 2014 I

• Multiple barriers to control the spread of contamination • Adequate working space around serviceable components to facilitate maintenance and

repair • Filtered ventilation from areas of lower to areas of higher contamination levels • Adequate space for donning and doffing of protective clothing • Low-background contamination monitoring stations • Offices and break areas located away from radiological areas.

Areas posted as Contamination Areas (SPL-SOP-8.1 0, Radiation Protection Program) should be limited in physical area and magnitude of contamination levels. Construction material used in Contamination Area should be capable of being decontaminated without relying upon hazardous compounds, including smooth and corrosion-resistant material.

4.2 Engineering Controls

In additional to facility design features, required engineering controls shall be identified during the activity planning stage by the License RSO and/or PRSO. An evaluation shall be performed that addresses the specific radionuclide hazards, the potential for the spread of contamination and the extent to which proposed engineering controls will minimize the spread of contamination. If engineering controls alone cannot adequately control contamination potential, administrative controls will be required.

Temporary containment devices should be considered to limit the spread of contamination from system leaks, material handling operations and during maintenance of contaminated systems. Containment devices range from simple catch containments or plastic garbage bags for small leaks to temporary containment buildings with high-efficiency particulate air (HEPA) ventilation which may be used for large component decontamination or high hazard material handling. Other containment devices to consider include glove boxes and temporary drain lines connected to installed, controlled drain lines or collection devices.

Portable air filtering devices shall be considered when there is a potential for the generation of airborne contamination. Site specific conditions shall considered when selecting the appropriate engineering control (e.g., HEPA filtered units will not be effective for radioactive noble gases). The buildup of radioactive material on the filter media and ductwork shall be considered, as it may become a significant source of exposure.

The benefit and cost of the proposed engineering controls shall be considered. Cost of installation, use, and decontamination may result in additional worker dose to set up, maintain, and remove.

4.3 Administrative Controls

The following administrative controls shall be considered when developing a site-specific contamination control program.

4.3.1 Radiological Work Permits (RWPs)

RWPs shall be used during work site evaluation and when working on posted Contamination Areas. Project specific radiation work permit procedure shall be approved by the PRSO or designee. Access control to potentially contaminated areas is required to ensure that personnel entering the area are informed of the radiological conditions and potential hazards and are provided with the appropriate protective clothing and equipment. Control of egress from potentially contaminated areas ensures that radioactive material is not inadvertently removed from the area. Known contaminated areas should be limited in both number and size in order to minimize the need for protective clothing, restricted access, additional training, and the generation of radioactive waste.




SPL-SOP-8.1 0.10 00 01 May 2014

4.3.2 Personal Protective Equipment

Entry into the potentially contaminated areas requires appropriate Personal Protective Equipment (PPE). The type of protective clothing required shall be prescribed based upon considerations of contamination levels, chemical and physical form of the contaminant, activities to be performed, and area accessibility. Required PPE is noted on the work area RWP and shall be communicated to each worker during pre-job briefing. A comprehensive PPE program that includes the following shall be developed for each site:

• hazard identification; • medical monitoring; • environmental surveillance; • selection, use, maintenance, and decontamination of PPE; • and associated training, as needed.

4.3.3 Exiting Contaminated Areas

Site-specific work instructions shall address personnel and equipment survey requirements exiting contaminated areas and the use of appropriate survey instruments. RCTs may perform surveys of personal items carried into the area. Personal items include papers, pens, jewelry, security badges, dosimeters, and other items commonly used within the area. The monitoring of tools or other material and equipment shall be performed by trained radiological control personnel.

The instruments and techniques used for contamination monitoring shall be appropriate for the types, levels, and energies of the radiations encountered and for the existing environmental conditions. The instruments used for frisking shall be capable of detecting contamination at or below the total surface contamination control values. Individuals shall be trained in proper frisking techniques, including detector speed and distance, and proper techniques shall be enforced through frequent line management observation.

The RPP or site-specific work instructions shall contain written instructions to be followed when a worker becomes contaminated. The written instructions will address the following:

• Immediate notification of radiation protection personnel for assistance, • Actions to prevent the further spread of material, • Protocol for seeking medical attention, • Personnel decontamination and or securing the contaminated victim for

transport for medical attention, • Area and equipment decontamination, • Notifications to regulators • Generation of a Radiological Incident Report (RIR), and • Personnel dose assessments (trigger levels should be developed and

documented).

Note: Medical treatment of injuries takes precedence over radiological considerations. Emergency medical care must be administered immediately.

The details of this emergency response program shall be provided to radiation workers during initial radiation worker training and reviewed periodically during the routine safety meetings.




SPL-SOP-8.10.10 00 01 May 2014

4.4 Contamination Monitoring

Contamination monitoring shall be performed in accordance with policies established in SOP-

8.10.7, Surveys and Monitoring.

Federal and applicable state regulations specify the levels at which contaminated areas/radioactive material areas must be posted and equipment must be labeled. An established contamination monitoring program shall be sufficient to identify the location of surfaces having contamination at or above the posting threshold. Contamination levels on surfaces outside of contaminated areas shall be maintained below the applicable regulatory limits.

5.0 REFERENCES

• Title 10 Code of Federal Regulations, Part 20, Standards for Protection Against Radiation\

• SPL-SOP-8.1 0, Radiation Protection Program

• SPL-SOP 8.1 0.7, Surveys and Monitoring

• Title 17, California Code of Regulations, Public Health


6.0 TERMINOLOGY

ALARA - An acronym for "As Low As Reasonably Achievable." Making every reasonable effort to maintain exposure to radiation as far below established dose limits as is practical consistent with the purpose for which the licensed activity is undertaken, taking into account the state of technology, the economics of improvements in relation to state of technology, the economics of improvements in relation to benefits to the public health and safety, and other societal and socioeconomic considerations, and in relation to utilization of nuclear energy and licensed materials in the public interest.

Anti-Contamination Clothing - Personal protective equipment (PPE) worn by radiation workers to prevent the contamination of the worker's skin or clothing when working in contaminated areas.

Authorized License Users - Individuals who, by virtue of training and/or experience, have been authorized by the License Radiation Safety Officer to use or directly supervise the use of radioactive materials under the requirements of the service provider license.

Contamination -The deposition of unwanted radioactive material on surfaces or in media.

Contamination Areas - Areas where surface contamination exceeds the established limits, areas where equipment or materials with exposed parts exceeding these levels are handled, or areas where activities may cause contamination in excess of the limits.

Decontamination -The reduction or removal of radioactive contamination from a structure, area, object, or person, or the extraction of radionuclides from contaminated media.

Frisking -The process of monitoring an individual's clothing and/or body with a portable radiation detection instrument prior to exit of the person from a radiologically-controlled area.

Intake- Radionuclides entering the body by any exposure pathway, primarily inhalation, absorption, or ingestion.

Monitoring - The measurement of radiation levels, concentrations, surface area concentrations, or quantities of radioactive material and the use of the results of these measurements to evaluate potential exposures and doses.

Smear Sampling - A method of determining the removable contamination on a surface. A specified area is wiped with a media, e.g., filter paper and the radioactivity collected on the media is measured by portable or laboratory instrumentation. The area smeared is normally 100 square centimeters.




SPL-SOP-8.10.10 00 01 May 2014

Survey - An evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiation.

7.0 EXHIBITS

None

8.0 ATTACHMENTS

None


PROCEDURE

Procedure Title: Transportation of Radioactive CMS Number: SPL-SOP-8.1 0.11 Materials


TRANSPORTATION OF RADIOACTIVE MATERIALS





Transportation of Radioactive Materials


SPL-SOP-8.10.11 00 01 May 2014

1.0 PURPOSE

The purpose of this procedure is to establish the requirements for the safe shipment of radioactive materials, including mixed waste, by CB&I Federal Services LLC (CB&I) radioactive materials brokers. This procedure incorporates the transportation requirements of 49 CFR, 10 CFR 71, 10 CFR 61, 10 CFR 20 and other applicable parts of the Code of Federal Regulations and the applicable regulations of the various agreement states as applicable by reference. Therefore, the list of procedural steps is not exhaustive but is used to describe typical activities incident to cooperative efforts with licensed transportation brokers or shippers.

2.0 SCOPE

This procedure applies to all personnel who ship or assist in the shipment of radioactive materials as defined by the Department of Transportation (DOT). This document outlines the minimum required steps and quality checks that all employees and subcontractors are to follow when performing these operations.



The License RSO shall ensure that appropriate project specific procedures are established to implement the requirements of this procedure. The License RSO or designated authorized user is responsible for all regulatory and emergency notifications.



3.3 Radioactive Materials Broker

The broker is responsible for the safe and proper shipment of radioactive materials, including the following activities:

• Identifying appropriate proper shipping names • Identifying estimated activity, weight and volume • Selecting packaging • Packaging materials • Preparing DOT shipping papers and required waste manifests • Supervising loading of materials, if shipment is exclusive use • Performing radiological surveys of waste packages and conveyance, as required to

meet DOT regulations.

4.0 PROCEDURE

4.1 Prerequisites.

Individuals performing any function related to the transport of hazardous materials shall be trained in accordance with the requirements of Title 49 CFR Part 172, Subpart H.

Individuals shipping radioactive materials shall ensure that the following administrative requirements have been met prior to shipment of materials:

• The material must be identified by the most appropriate proper shipping name in accordance with the Hazardous Materials Tables of 49 CFR Part 172. Radioactive waste being shipped for disposal or shipped to a collector or processor for eventual disposal by shallow land burial shall be classified in accordance with 10 CFR Part 61 or a valid disposal site license.




SPL-SOP-8.10.11 00 01 May 2014

• Material shipped under an Exclusive Use Agreement shall be shipped as defined in 49 CFR 173. The agreement should be in place and signed by the appropriate parties.

• If the material is a hazardous or mixed waste, the material must be identified by the most appropriate EPA waste code in accordance with 40 CFR Part 261.

• The generator, transporter, and disposer of hazardous or mixed wastes shall have valid EPA identification numbers and all appropriate EPA permits (generator permits, transporter permits, TSD permits, etc.). The generator shall also provide evidence that the waste stream(s) being shipped are acceptable at the receiving facility in accordance with all permit requirements.

• The generator of hazardous and mixed waste shall have completed all notifications and certifications for the waste material subject to the land disposal restrictions in accordance with 40 CFR Part 268.

The generator of radioactive waste or mixed wastes shall have all applicable permits or other requirements of the disposal facility, such as the following:

• Evidence of the acceptability of the waste stream by the facility (including all waste profile information and analytical data)

• Any other required federal, state, or local permits, or other requirements mandated by law including compact import/export requirements

• Evidence, by provision of a receiving/disposal site license, of the acceptability of the waste being shipped

• Radioactive materials not shipped as waste shall be shipped in such a manner as to conform to all federal, state, and local ordinances. Non-waste radioactive materials shall only be shipped to a facility upon provision of evidence, such as a valid NRC license, by the customer, that the material is acceptable at the receiving facility.

• All radioactive materials shipped internationally shall be shipped in accordance with all applicable international regulations and requirements, i.e., IMO and lATA.

4.2 Tools, Materials, and Equipment

Unless provided by the customer, the broker will be required to provide all tools, administrative forms, survey instruments, labels, markings, and placards for each shipment of materials. Special care must be taken by the broker to ensure that an adequate supply of such materials is maintained. A broker's field kit materials list is provided with this procedure.

4.3 Detailed Instructions

Project specific shipping and handling procedures, approved by the LRSO may be developed in accordance with the requirements of this procedure to address specific transportation needs.

4.3.1 Procedure for Material Preparation

All materials shipped by CB&I shall be in strict adherence to the requirements of 49 CFR and all other applicable federal, state, and local regulations:

• Materials shall be packaged and the packaging inspected in accordance with the requirements of 49 CFR Part 173 for the proper shipping name and DOT subtype of the material being offered for transport. Type 8 and NRC-approved Type A packages shall be prepared in accordance with the applicable certificate of compliance.

• All packages offered for transport shall be properly marked and labeled in accordance with the requirements of 49 CFR Part 172 prior to shipment.

• Shipping papers will be prepared for shipments as follows:

• All radioactive materials (unless otherwise excepted) shall have DOT hazardous materials shipping papers prepared in accordance with 49 CFR Parts 172.200 - 172.205.

• If the material is to be shipped under an exclusive use agreement, the written instructions for the maintenance of the exclusive use shipment controls will be included with the shipping papers. In addition to DOT




SPL-SOP-8.1 0.11 00 01 May 2014

hazardous materials shipping papers, all mixed waste shall have a uniform hazardous waste manifest selected and prepared in accordance with 40 CFR Part 262.20.

• All low-level radioactive waste (unless otherwise exempted per 10 CFR 71) shall have a manifest prepared in accordance with the requirements of 1 0 CFR Part 20.311.

• Additional forms shall be prepared as may be required by federal, state, and local ordinances and by receiving site license or acceptance criteria.

4.4 Procedure for Material Loading

With the exception of common carrier shipments of radioactive materials, the following procedure shall be followed when loading material for transportation:

1. Conduct and document a visual inspection of the conveyance and ensure that any discrepancies are repaired prior to loading. This inspection shall include all vehicle safety devices, tires, brakes, and trailer, as applicable.

2. If the vehicle floor shows evidence of moisture, wipe the floor as dry as possible and note the condition of the floor and action taken on the shipping papers. The consignee shall also be notified prior to shipment.

3. Perform and document a radiation and contamination survey of the conveyance prior to loading. Compare the survey results to the requirements of 49 CFR Part 173.

4. The broker shall inspect all packages as they are loaded to ensure that the packages are in full compliance with all the requirements set forth in this procedure. Incompatible materials shall be segregated as required by 49 CFR. NOTE: SPECIAL CARE SHALL BE TAKEN TO ENSURE THAT ALL STRONG TIGHT CONTAINERS USED FOR RADIOACTIVE MATERIAL TRANSPORT ARE COMPLETELY SEALED TO THE MAXIMUM EXTENT PRACTICAL THIS INCLUDES THE USE OF SEALANT ON SEAMS OF METAL BOXES. SPECIAL CARE SHALL ALSO BE TAKEN TO ENSURE THAT ALL SPECIFICATION PACKAGES ARE PROPERLY PREPARED FOR TRANSPORT AND IN PRISTINE CONDITION PRIOR TO TRANSPORT.

5. Upon completion of loading, visually verify that all packages are loaded. 6. Verify the proper use of blocking, bracing, dunnage, and tie-down, as appropriate. 7. Verify the conveyance is properly placarded, as applicable. 8. Perform and document a final contamination and radiation survey of the conveyance

and ensure that the results are in compliance with the requirements of 49 CFR Part 173.

9. Seal the vehicle/conveyance if required.

4.5 Post Loading Requirements

1. Confirm that the driver (or transporter's representative) and shipper (or shipper's agent) have signed all required forms.

2. Review all paperwork to ensure legibility. 3. Copy and distribute paperwork as needed. Uniform hazardous waste manifests shall

be distributed in accordance with 40 CFR Part 262 and as required by the laws of the generating state.

4. Verify that the driver (transporter's representative) understands all special instructions such as the maintenance of exclusive use and prior notification requirements. The shipment may now be released for transport.

5. Make any required prior notification of correction telephone calls. Mail copies of the radioactive shipment manifest cover sheets to the disposal site for radioactive waste shipments.

6. Notify the emergency response services in accordance with CB&I Health and Safety Procedure HS811, DOT 24-Hour Emergency Number




SPL-SOP-8.1 0.11 00 01 May 2014

4.6 Shipping Errors

If the responsibilities of the broker are improperly executed and/or negligence is shown on the part of the broker, the broker shall be suspended from all shipping activities until the error is investigated and appropriate corrective action determined. Reinstatement shall be made only after any required retraining or recertification is completed.

4.7 Records

4.7.1 Broker

The broker shall retain copies of records, forms, and shipping papers generated as a result of this procedure until written acknowledgment is received from the consignee for all waste shipments or telephone acknowledgment is received for all non-waste shipments.

4.7.2 Project Records

All shipping papers shall be retained as part of a permanent project file for each project.

4. 7.3 Generator

The generator of waste shall be provided with a copy of all shipping papers. The generator will also be provided documentation as to the disposition of shipments received at the disposal facility. The documentation shall include all disposal receipts and if applicable the decontamination and release documents meeting the empty packaging requirements of 49 CFR 173.428.

5.0 REFERENCES

• Code of Federal Regulations, 49 CFR, Transportation • Code of Federal Regulations, 40 CFR, Protection of Environment • Code of Federal Regulations, 10 CFR 20, Standards for Protection Against Radiation • Code of Federal Regulations, 10 CFR 71, Packaging and Transportation of Radioactive

Materials • Code of Federal Regulations, 10 CFR 61, Licensing requirements of Land Disposal of

Radioactive Material • International Air Transportation Association (lATA) regulations • U.S. Department of Transportation, USDOT Emergency Response Guidebook • California Code of Regulations, Title 17, Public Health • Kansas Administrative Regulations, 28-35 Radiation Protection

6.0 TERMINOLOGY

Broker-Any individual who performs one or more of the following functions for a waste generator:

• Arranges for transportation of the waste • Collects and/or consolidates shipments of waste • Processes waste in some manner.

This definition shall not apply to a carrier whose sole function is to transport waste.

Curie-The basic unit of radioactivity. The quantity of any radioactive element that decays at a rate equal to 2.22E+12 disintegrations per minute.

Disposal Site-For the purposes of this procedure, any facility licensed for the purpose of disposing of low-level radioactive waste.

Disposer-The site that receives radioactive or mixed waste for disposal.




SPL-SOP-8.10.11 00 01 May 2014

Curie-The basic unit of radioactivity. The quantity of any radioactive element that decays at a rate equal to 2.22E+12 disintegrations per minute.

Disposal Site-For the purposes of this procedure, any facility licensed for the purpose of disposing of low-level radioactive waste.

Disposer-The site that receives radioactive or mixed waste for disposal.

Hazardous Material-Any material that is determined by the U.S. Secretary of Transportation to present a hazard when transported in commerce.


Function-Specific Training-Training, specific to job function, provided in accordance with Title 49, Code of Federal Regulations (CFR), Part 172, Subpart H to all HAZMAT employees.

HAZMAT Employee-An employee who loads, unloads, or handles hazardous materials; is responsible for the condition of containers used to transport hazardous materials; prepares hazardous materials for transportation; is responsible for the safety of hazardous materials; or operates a vehicle used to transport hazardous materials.

Hazardous Waste-Any material that is subject to the Hazardous Waste Manifest Requirements of the U.S. Environmental Protection Agency (EPA) specified in 40 CFR Part 262.

International Air Transport Association (IATA)-IATA is the trade association of the world's international airline industry and serves as the body that develops the international air transport working standards.

International Maritime Organization (IMO)-IMO is a technical organization and specialized agency of the United Nations. Its main concern is to improve the safety of maritime operations, and it serves as the body that develops international maritime standards.

Low-Level Radioactive Waste-Wastes containing source, special nuclear, or byproduct material that is acceptable for disposal at a low-level radioactive waste disposal facility.

Low-Level Radioactive Waste Compact-A group of states that have formed a compact, as defined by the Federal Low Level Radioactive Waste Policy Amendments Act, for the purpose of managing the disposal of low-level radioactive waste within the compact states.

Mixed Waste-Wastes containing materials that are, by definition, radioactive waste as defined by the U.S. Nuclear Regulatory Commission (NRC) and hazardous waste as defined by EPA.

Monitoring-The measurement of radiation levels, concentrations, surface area concentrations, or quantities of radioactive material and the use of the results of these measurements to evaluate potential exposures and doses

NORM Waste-Wastes that contain only naturally occurring or accelerator-produced radioactive materials. These materials are regulated by state law and are not low-level radioactive waste.

Transportation, Storage, and Disposal (TSD) Facility-A Treatment, Storage, or Disposal Facility as defined by EPA in accordance with 40 CFR.

Radiological Controls Technician-An individual who, by virtue of education, experience, or certification, is qualified to perform radiological surveys and implement radiological controls for work activities.





SPL-SOP-8.10.11 00 01 May 2014

Exclusive Use-Means sole use by a single cosignor of a conveyance for which all initial, intermediate, and final loading and unloading are carried out in accordance with the direction of the cosignor or cosignee ..

7.0 EXHIBITS

None

8.0 ATTACHMENTS

8.1 Broker Field Kit Recommended Material List




SPL-SOP-8.10.11 00 I 01 May 2014

8.1 ATTACHMENT BROKER FIELD KIT RECOMMENDED MATERIAL LIST

I. PROCEDURES AND REFERENCES

1.) 49 CFR, PARTS 100-177;

2.) 10 CFR, PARTS 0-50 AND 51-199;

3.) 40 CFR, PARTS 260-299;

4.) CB&I PROCEDURE, T-RA-003, SHIPMENT OF RADIOACTIVE MATERIALS;

5.) ALL APPLICABLE PROJECT SPECIFIC RULES, REGULATIONS, AND LICENSES (RADIOACTIVE MATERIAL LICENSES, STATE HAZARDOUS MATERIAL REGULATIONS, ETC.);

II. PAPERWORK

Ill.

IV.

1.) BLANK LOW LEVEL RADIOACTIVE WASTE MANIFESTS;

2.) BLANK BILLS OF LADING;

3.) BLANK US EPA UNIFORM HAZARDOUS WASTE MANIFESTS;

4.) ALL PROJECT SPECIFIC PAPERWORK (STATE HAZARDOUS WASTE MANIFESTS, WASTE CERTIFICATION FORMS, PRIOR NOTIFICATION FORMS, ETC.).

LABELS AND MARKINGS

1.) "RADIOACTIVE" STICKERS;

2.) "RADIOACTIVE-LSA" STICKERS;

3.) WASTE CLASS AND STABILITY STICKERS;

4.) ITEM NO. AND WEIGHT STICKERS;

5.) HAZARDOUS MATERIALS LABELS;

6.) "7 A TYPE A" STICKERS;

7.) HAZARDOUS WASTE CONTAINER LABELS;

8.) PERMANENT MARKERS (2) AND PENS (2);

9.) HAZARDOUS MATERIALS PLACARDS;

1 0.) PROJECT SPECIFIC MARKINGS AND LABELS AS REQUIRED.

TOOLS AND MATERIALS

1.) 12" CRESCENT WRENCH (1);

2.) 15/16" COMBINATION WRENCH (2);

3.) HALF ROUND NEOPRENE GASKETS AND SILICONE GREASE (IF SHIPPING DRUMS);

4.) E-520 WITH HP-260 AND HP-270 PROBES, OR EQUIVALENT;

5.) OTHER TOOLS, MATERIALS, AND INSTRUMENTATION AS REQUIRED BY PROJECT.


PROCEDURE

Procedure Title: Waste Management CMS Number: SPL-SOP-8.11


WASTE MANAGEMENT





I I

Waste Management

CMS Number: I Revision: Approval Date:

SPL-SOP-8.11 I 00 01 May 2014

1.0 PURPOSE

The purpose of this procedure is to establish the requirements for generation, handling, storage, identification and transportation of radioactive waste. Guidance is presented to assist in the development of a site-specific radioactive waste control procedures.

2.0 SCOPE

This procedure applies to all CB&I Federal Services LLC (CB&I) radiological activities and personnel associated with the implementation of a radioactive waste management program.



The License RSO shall approve the waste management program and requirements for the site.


The PRSO shall ensure the waste management program is implemented properly in accordance with approved procedures.

4.0 PROCEDURE

Each project will have a site-specific radiation protection plan (RPP) which addresses the specific elements of a waste management program. The type of radioactive waste generated is dependent on the specific purpose of the facility. An examination of the activities taking place at the facility shall be made in order to completely identify the waste streams. Operations should be designed and developed to promote minimization of radioactive waste and permit segregation, monitoring, treatment, storage, and disposal. Waste minimization goals and practices shall be considered and should be established.

Ultimate decision making regarding the disposition of materials will necessarily include the input of regulatory authorities and any client regarding the costs associated with detailed waste analysis, time to determination, and the ability to safely and conclusively characterize any material with respect to specific waste acceptance criteria.

All radioactive waste shall be stored in appropriately labeled containers until it is disposed. During the period between storage and disposal container integrity must be assured. All radioactive waste must be secured against access or removal by unauthorized personnel.

Licensees must dispose of radioactive waste as follows:

• Decay-in-storage (DIS); • Release into sanitary sewerage; • Transfer to an authorized recipient; Extended interim storage; • Obtaining prior approval from appropriate regulator of an alternate method; • Disposal of waste as if it were not radioactive (specific wastes); • Release in effluents to unrestricted areas, other than into sanitary sewerage • Incineration • Disposal in a licensed low-level radioactive waste (LLRW) disposal facility

Waste that is shipped for disposal or treatment must be well characterized in order to demonstrate its conformance to the transportation requirements and the waste acceptance criteria. Instruments used to characterize waste samples must be appropriate for the nuclides and radioactive material inventory present.

Requirements for shipments of radioactive waste including shipping papers and package markings, labeling, and placarding are governed by 49 CFR 172. A project may employ a specialist to prepare


Waste Management


SPL-SOP-8.11 00 01 May 2014

and certify radioactive material shipments. A signature by a representative of the client is required since the radioactive waste belongs to them.

Records

All records relevant to waste management shall be maintained in a manner that is consistent with regulatory requirements and the requirements of project specific quality assurance plans.

5.0 REFERENCES

• Code of Federal Regulations, 10 CFR Part 20, Standards for Protection Against Radiation • Code of Federal Regulations, 10 CFR Part 30, Rules of General Applicability to Domestic

Licensing of Byproduct Material • Code of Federal Regulations, 10 CFR Part 61, Licensing Requirements for Land Disposal of

Radioactive Waste • Code of Federal Regulations, 10 CFR Part 71, Packaging and Transportation of Radioactive

Material • Code of Federal Regulations, 49 CFR Part 171-178, 403, Transportation • NUREG-1556, Vol. 18, "Program-Specific Guidance About Service Provider Licenses,' dated

November 2000 • California Code of Regulations, Title 17, Public Health. • Kansas Administrative Regulations, 28-35 Radiation Protection

6.0 TERMINOLOGY

Controlled Materials-Any licensable radioactive material controlled by CB&I at a project location.

Exposure-Being exposed to ionizing radiation or to radioactive material.

Inventory-Licensable radioactive materials that are in the position of CB&I prior to the beginning of a project and materials controlled by CB&I during the course of a project.


Licensed Material - Source material, special nuclear material, or byproduct material received, possessed, used, transferred, or disposed of under an applicable license.

Radioactive Waste - waste generated during radiological activities that may include contaminated soil/samples, sealed sources, unusable items contaminated with radioactive material, e.g. absorbent paper, gloves, filters, tools, etc.

Waste Management - services that may include but are not limited to, commercial incineration, compaction, solidification/vitrification and packaging and transportation of radioactive waste.

7.0 EXHIBITS

None

8.0 ATTACHMENTS

None


This is to ~cknowledge the receipt of you@application dated

0 ? , and to infonn you that the initial processing which

incudes ~: a~ministr~tiv~ review has been performed. . . / \

f1o ·-3t3 1/0--01 (u)nu/rUI/Jnb!l/U I4J There were no administrative omissions. Your application was assigned to a technical reviewer. Please note that the technical review may identify additional omissions or require additional information.

O Plea§e provide to this office within 30 days of your receipt of this card

A copy of your action has been forwarded to our License Fee. & Accounts Receivable Branch, who will contact you separately if there is a fee issue involved.

Your actio~ has been assigned Mail Control Number \. ?&'L( 7 q 9. When calling to inquire about this action, please refer to this control number. You may call us on (61 0) 337-5398, or 337-5260.

NRC FORM 532 (RI)

{6-96)

Sincerely, Licensing Assistance Team Leader.

division of nuclear materials safety u.s. nrc region i · this procedure applies to all personnel...

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