Department of Energy (DOE) Radiological Control Manual

Chapter 3 - Conduct of Radiological Work

Part 1 - Planning Radiological Work

Table of Contents (Articles 31x)

• 311 Requirements
• 312 Planning for Maintenance, Operations and Modifications
• 313 Infrequent or First-Time Activities
• 314 Temporary Shielding
• 315 Technical Work Documents
• 316 Minimization of Internal Exposure

Article 311 - Requirements

Technical requirements for the conduct of work, including construction, modifications, operations, maintenance and decommissioning, shall incorporate radiological criteria to ensure safety and maintain radiation exposures ALARA. The primary methods used to maintain exposures ALARA shall be facility and equipment design features. These features may be augmented by administrative and procedural requirements. To accomplish this, the design and planning processes should incorporate radiological considerations in the early planning stages. The checklist in Appendix 3A is helpful in reducing occupational radiation exposure.

Return to Chapter 3, Part 1 Table of Contents

Article 312 - Planning for Maintenance, Operations and Modifications

1. Maintenance and modification plans and procedures shall be reviewed to identify and incorporate radiological requirements, such as engineering controls and dose and contamination reduction considerations. Performance of this review is the responsibility of line management, with support and concurrence from the Radiological Control Organization.

2. For routine tasks, such as surveillance, tours and minor nonradiological maintenance, performance of the above review and documentation of identified radiological requirements may be conducted as part of the Radiological Work Permit process (see Article 321).

3. The Site-Specific Radiological Control Manual shall establish trigger levels requiring formal radiological review of nonroutine or complex work activities. These appropriate trigger levels should include:

4. Estimated individual or collective dose greater than preestablished values
5. Predicted airborne radioactivity concentrations in excess of preestablished values
6. Work area removable contamination greater than 100 times the values in Table 2-2
7. Entry into areas where dose rates exceed 1 rem/hour
8. Potential radioactive releases to the environment.

• Tasks with the potential to exceed the above trigger levels shall undergo a formal, documented radiological or ALARA review. At a minimum, this review should consider the following:

• Inclusion of Radiological Control Hold Points in the technical work documents
• Elimination or reduction of radioactivity through line flushing and decontamination
• Use of work processes and special tooling to reduce time in the work area
• Use of engineered controls to minimize the spread of contamination and generation of airborne radioactivity
• Specification of special radiological training or monitoring requirements
• Use of mock-ups for high exposure or complex tasks
• Engineering, design and use of temporary shielding to reduce radiation levels
• Walkdown or dry-run of the activity using applicable procedures
• Staging and preparation of necessary materials and special tools
• Maximization of prefabrication and shop work
• Review of abnormal and emergency procedures and plans
• Identification of points where signatures and second party or independent verifications are required
• Establishment of success or completion criteria, with contingency plans to anticipate difficulties
• Development of a pre-job estimate of collective dose to be incurred for the job
• Provisions for waste minimization and disposal.

• Radiological requirements identified as part of the above radiological review should be documented in the job plans, procedures or work packages.

• Radiological work anticipated to exceed individual or collective dose criteria established in the Site-Specific Radiological Control Manual should be reviewed and approved by the ALARA Committee.

• Optimization techniques, including cost-benefit analysis, represent a fundamental part of radiological design analysis and work review. For review of minor activities with low associated doses, a cost-benefit evaluation is an intrinsic part of the engineering review process and a detailed evaluation is not necessary. For review and planning of major tasks involving higher collective dose expenditures, a detailed and documented evaluation shall be performed. Return to Chapter 3, Part 1 Table of Contents

Article 313 - Infrequent or First-Time Activities

At those facilities with routine, recurring process operations, special management attention should be directed to radiological activities that are infrequently conducted or represent first- time operations. Planning for such activities should include:

1. Formal radiological review in accordance with Article 312.4

2. Senior management review directed toward anticipation of concerns and emphasis and specification of protective measures

3. Review and approval by the ALARA Committee

4. Enhanced line and Radiological Control management oversight during the initiation and conduct of the work.

Article 314 - Temporary Shielding

1. The installation, use and removal of temporary shielding should be controlled by procedure.

2. The effects of the additional weight of temporary shielding on systems and components should be evaluated and established to be within the design basis prior to installation.

3. Installed temporary shielding should be periodically inspected and surveyed to verify effectiveness and integrity.

4. Radiation surveys should be performed during the alteration or removal of installed temporary shielding.

5. Installed temporary shielding should be visibly marked or labeled with the following or equivalent wording: "Temporary Shielding - Do Not Remove Without Permission from Radiological Control."

6. Installed temporary shielding should be periodically evaluated to assess the need for its removal or replacement with permanent shielding.

7. Site procedures may identify specific shielding applications, such as the shielding of low activity sources or samples, that fall outside the recommendations of this Article.

Article 315 - Technical Work Documents

1. Technical work documents, such as procedures, work packages, or job or research plans, should be used to control hands-on work with radioactive materials. Technical work documents are not required for incidental or routine work activities that involve a low potential of worker exposure or workplace contamination, such as the collection of trash or used protective clothing.

2. Technical work documents used to control radiological work activities should be reviewed and approved by the Radiological Control Organization.

3. Radiological Control Hold Points should be incorporated into technical work documents for steps that require action by the Radiological Control Organization to prevent radiation exposures in excess of Administrative Control Levels, high airborne radioactivity concentrations, or the release of radioactivity to the environment.

Article 316 - Minimization of Internal Exposure

The minimization and control of internal exposure as discussed in Article 136 should be conducted in accordance with the following hierarchy of controls:

1. Engineering controls, including containment of radioactive material at the source wherever practicable, should be the primary method of minimizing airborne radioactivity and internal exposure to workers.

2. Administrative controls, including access restrictions and the use of specific work practices designed to minimize airborne contamination, should be used as the secondary method to minimize worker internal exposure.

3. When engineering and administrative controls have been applied and the potential for airborne radioactivity still exists, respiratory protection should be used to limit internal exposures. Use of respiratory protection should be considered under the following conditions:

4. Entry into posted Airborne Radioactivity Areas
5. During breach of contaminated systems or components
6. Work in areas or on equipment with removable contamination levels greater than 100 times the values in Table 2-2
7. During work on contaminated or activated surfaces with the potential to generate airborne radioactivity.

• The selection of respiratory protection equipment should include consideration of worker safety, comfort and efficiency. The use of positive pressure respiratory protection devices is recommended wherever practicable to alleviate fatigue and increase comfort.

• In specific situations the use of respiratory protection may be contraindicated due to physical limitations or the potential for significantly increased external exposure. In such situations, written authorization should be obtained from the line organization manager and the Radiological Control Manager prior to incurring internal exposure. Specific justification of the need to accept the exposure, including a description of measures taken to mitigate the airborne radioactivity, should be documented as part of the authorization process.

• The following controls are applicable for activities authorized in accordance with the above:

• Stay time controls to limit intake should be established for the entry
• Evaluation of workplace airborne radioactivity levels should be provided through the use of continuous air monitors or air-samplers with expedited assessment and analysis of results. Return to Chapter 3, Part 1 Table of Contents