TFC-ESHQ-RP_RWP-C-03_ ALARA Work Planning

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					CH2M HILL Hanford Group, Inc.                                        Manual                                              ESHQ
                                                                     Document                    TFC-ESHQ-RP_RWP-C-03, REV F-2
ALARA WORK PLANNING                                                  Page                                                1 of 43
                                                                     Issue Date                                January 27, 2005
                                                                     Effective Date                            January 27, 2005
FUNCTIONAL AREA MANAGER:                                                                                           E. J. Adams

DOCUMENT OWNER:                                                                                                                      O. D. Berglund

                                                         TABLE OF CONTENTS

1.0        PURPOSE AND SCOPE ................................................................................................................ 2
2.0        IMPLEMENTATION ..................................................................................................................... 2
3.0        RESPONSIBILITIES ...................................................................................................................... 2
4.0        PROCEDURE ................................................................................................................................. 2
           4.1  Radiological Review and Approval of Work Documents .................................................. 2
           4.2  Risk Screening .................................................................................................................... 3
           4.3  Radiological Work Planning/Work Document Preparation................................................ 5
           4.4  ALARA Management Worksheet Preparation ................................................................. 20
           4.5  Dose Estimates .................................................................................................................. 21
           4.6  Dose Tracking ................................................................................................................... 22
           4.7  In-Process and Post-Job ALARA Reviews....................................................................... 23
           4.8  Radiological Design Review............................................................................................. 25
5.0        DEFINITIONS .............................................................................................................................. 25
6.0        RECORDS .................................................................................................................................... 26
7.0        SOURCES ..................................................................................................................................... 26
           7.1  Requirements .................................................................................................................... 26
           7.2  References......................................................................................................................... 27

                                                           TABLE OF FIGURES

Figure 1. ALARA Work Planning Process. ............................................................................................... 29
Figure 2. Dose Estimate Worksheet. .......................................................................................................... 30

                                                            TABLE OF TABLES

Table 1. Tank Farms Radiological Risk Screening Criteria. ..................................................................... 31
Table 2. 222-S Laboratory Radiological Risk Screening Criteria. ............................................................ 33
Table 3. Requirements for Working in Contaminated Soils. ..................................................................... 34

                                                     TABLE OF ATTACHMENTS

ATTACHMENT A – HEALTH PHYSICS HOLD POINTS ..................................................................... 35
ATTACHMENT B – APPROVED FIXATIVE SOLUTIONS .................................................................. 38
ATTACHMENT C – DETERMINATION OF POTENTIAL AIRBORNE RADIOACTIVITY
      CONCENTRATION .................................................................................................................. 39
ATTACHMENT D – WORK PRACTICE SURVEYS NOT REQUIRED TO BE SPECIFIED BY
      WORK DOCUMENTS .............................................................................................................. 41
ATTACHMENT E – TYPE C MOCKUP GUIDELINES ......................................................................... 42
ATTACHMENT F – ALARA MANAGEMENT WORKSHEET PREPARATION ................................ 43
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1.0   PURPOSE AND SCOPE
      (7.1.2.a, 7.1.2.i, 7.1.2.j, 7.1.6)


      This procedure establishes the Tank Farm Contractor (TFC) as low as reasonably achievable
      (ALARA) process for TFC operations and maintenance work planning in accordance with
      10 CFR 835 and HNF-5183. This process is utilized to minimize personnel exposures to ionizing
      radiation and to limit the spread of radioactive contamination to the work place and environment.

      This procedure applies to personnel who plan, prepare, review, or perform radiological work in
      TFC facilities and is to be used in conjunction with TFC-OPS-MAINT-C-01 and
      TFC-PRJ-SUT-C-02. (7.1.1)

2.0   IMPLEMENTATION

      This procedure is effective on the date shown in the header.

3.0   RESPONSIBILITIES

      Responsibilities are contained within Section 4.0.

4.0   PROCEDURE

      See Figure 1 for process flowchart.

      Sections 4.3 through 4.8 may be performed in any order and/or independent of other sections, as
      necessary, to adequately address radiological hazards of the job.

      NOTE: The AMW should be team-planned in a group for high risk work activities. The work
      planning team shall include the workers that will be performing the work activities, in as much as
      possible.

4.1   Radiological Review and Approval of Work Documents

 RadCon Program                      1. Review and approve work documents for tasks involving:
 (RadCon)
                                               Work on contaminated or potentially contaminated facilities or
                                                systems

                                               Work in radiological buffer areas (for contamination)

                                               Work in radiation, high radiation, and very high radiation areas

                                               Work in contamination, high contamination and airborne
                                                radioactivity areas

                                               Work in contaminated or potentially contaminated soil
                                                (including digging, excavating, or disturbing the soil)

                                               Packaging or un-packaging of radioactive material
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                                      Work in any area where there is a high probability of
                                       radioactive material being present.

                                      Work requiring health physics (HP) hold points. See
                                       Attachment A for hold point criteria and implementation
                                       guidelines.

4.2     Risk Screening

 RadCon                    1. Categorize work into one of three radiological risk categories in
                              accordance with Table 1 for the tank farms and Table 2 for the 222-S
                              Laboratory.

4.2.1   Low Radiological Risk

        NOTE: Work documents for low risk activities may be used in repeat work without additional
        radiological review and approval as long as:

              The work document has received RadCon review and approval
              Work scope and processes governed by the work document have not changed
              Radiological conditions in the work area and controls specified in the work document
               have not changed since review and approval.

 Planner/FWS/              1. Review with the RadCon subject matter expert the planned work
 Operations Engineer          activity to ensure it falls within the low radiological risk criteria.

                                NOTE: It is recommended that representatives from the crafts that will
                                be performing the work are involved in the work planning process.

 RadCon                    2. Determine if the work can be performed using a general Radiological
                              Work Permit (RWP).

                           3. Assign an existing general RWP to the work

                                OR

                                Work with the planner to develop a new RWP for the work in
                                accordance with TFC-ESHQ-RP_RWP-C-04.

 Planner                   4. Incorporate radiological controls into the work instructions per
                              Section 4.3.

 RadCon                    5. Approve the work.

4.2.2   Medium Radiological Risk/Planning Required

 RadCon                    1. Review the planned work activity to ensure it falls within the medium
                              radiological risk criteria.
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                         2. Based on the scope of work and the survey data available, develop a
                            DRAFT of the ALARA Management Worksheet (AMW)
                            (A-6003-121).

 RadCon/Work             3. As part of the Job Hazard Analysis (JHA) development discussed in
 Planning Team              TFC-OPS-MAINT-C-01, document the hazards identified and the
                            controls required to mitigate the radiological hazards.

                         4. Incorporate input gathered during the planning process into the DRAFT
                            AMW for review and modification, as needed, during the team
                            planning meeting.

                             NOTE: The AMW should be team planned in a group for medium and
                             high risk work activities. The work planning team shall include at least
                             one or more representatives of the bargaining unit that will be
                             performing the work activities.

 RadCon                  5. Develop or assign an RWP for the work scope.

 Planner                 6. Incorporate appropriate work steps and hold points into the work
                            document to mitigate radiological hazards and to implement
                            radiological control requirements identified and developed for the job.

                         7. Work documents for medium risk activities may be used in repeat work
                            orders without additional radiological review and approval as long as:

                                    The work document has received RadCon review and approval

                                    Work scope and processes governed by the work document
                                     have not changed

                                    Radiological conditions in the work area and controls specified
                                     in the work document have not changed since review and
                                     approval.

4.2.3   High Radiological Risk/Work Planning with Joint Review Group Review

 Planner, RadCon,        1. For high radiological risk work, complete Section 4.2.2, steps 2 through
 Field Work                 6 of this procedure and participate in the ALARA Joint Review Group
 Supervisor                 review in accordance with TFC-ESHQ-RP_ADM-C-11.

                         2. Ensure that the Operations director has reviewed and documented the
                            need for, and level of, mock-up needed for high risk radiological work
                            activities. (7.1.9)
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4.3     Radiological Work Planning/Work Document Preparation

        The ALARA work planning process should ensure that anticipated dose to general employees
        does not exceed the administrative control levels specified in HNF-5183, Table H2-1. The
        primary method used to maintain exposures ALARA shall be physical design features (e.g.,
        confinement, ventilation, remote handling and shielding). Administrative controls shall be
        employed only as supplemental methods to control radiation exposure. (7.1.2.c, 7.1.2.d, 7.1.2.e, 7.1.2.g,
        7.1.2.h)


        Steps in this section may be performed in any order and/or independent of one another as
        necessary to adequately address radiological hazards of the job.

        NOTE 1: It is recommended that work planning personnel routinely review the daily report for
        elements relevant to the work planning process. (7.1.8)

        NOTE 2: Caution should be used when planning for and working with contaminated or
        radiological items. Consideration should be given to installation of shielding and the use of
        extension tools to reduce or prevent handling of items that present radiological hazards. (7.1.10)

4.3.1   Radiation Exposure Considerations

 Planner/Document             1. Ensure procedures are developed and implemented to ensure work is
 Owner/RadCon/                   commensurate with existing and potential radiological hazards created
 Field Work                      by the activity and are consistent with the education, training, and skills
 Supervisor/                     of the individuals exposed to the hazard. (7.1.2.a)
 Operations Engineer
                              2. Apply the following hierarchy of controls in the order listed when
                                 planning radiological work: (7.1.2.c)

                                           Design features
                                           Engineered/physical controls
                                           Administrative controls
                                           Protective clothing.

 RadCon                       3. If available, obtain survey data from the most current radiological
                                 survey report or work history records.

                                   a.       If reliable survey reports are unavailable, request a pre-job
                                            survey, as needed.

                                   b.       If survey data is not available, and surveys cannot be performed
                                            for the planning of the work, then plan the work using the high
                                            risk assumptions with the highest level of radiological controls
                                            incorporated into the work instructions.
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 Planner/Document        4. Consider the following techniques (not an all-inclusive list) to reduce
 Owner/RadCon/Work          personnel radiation exposure.
 Planning Team
                             a.      Delete unnecessary work. This may require obtaining changes
                                     in technical specifications to reduce time in radiation areas.

                             b.      Develop special tooling to reduce time in, or increase distance
                                     from, radiation fields.

 Work Planning Team          c.      Specify work to be performed outside of radiation areas to the
                                     maximum extent practicable.

                             NOTE: Using the work steps capabilities of the work order planning
                             software, consider planning activities that can occur outside of radiation
                             areas in a separate step(s) from those activities that must be conducted
                             within radiation areas so that radiological controls are not necessarily
                             applied to all work activities when only a portion of that work requires
                             significant radiological controls.

 RadCon/Engineering/         d.      Specify use of temporary shielding and/or special shielding or
 Work Planning Team                  shipping containers.

                                     1)        Document the basis for shielding design and
                                               application in the work instructions. If these
                                               requirements have been met by another procedure or
                                               document (technical basis document, engineering data
                                               transmittal, etc.), reference it.

                                     2)        Prepare a technical basis document for temporary
                                               shielding designs that are used repetitively for specific
                                               applications.

                                     3)        Other single-use designs may be included in the work
                                               document using simple calculations to determine
                                               design effectiveness, with a simple drawing of the
                                               design attached.

                             e.      Identify the need for mock-up training or special briefings. See
                                     Section 4.3.13 for mock-up training guidelines.

                             f.      Provide a technical sequence or control chart for complex jobs.

                             g.      Observe the work in progress to identify problem areas.

4.3.2   Contamination Control Considerations

 Document Owner/         1. Consider controlling contamination at the source using radiological
 RadCon/Work                containment devices (for specific criteria of radiological containments,
 Planning Team              see TFC-ESHQ-RP_RWP-C-02), fixatives, or high-efficiency
                            particulate air (HEPA) filtered ventilation.
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                  2. Include provisions in the JHA and/or specified radiological controls
                     addressing the need for checks, inspections, or contingencies for the
                     presence of unanticipated liquid or contamination before handling any
                     part of equipment that has been in contact with tank waste as
                     uncontaminated. (7.1.3, 7.1.5)

RadCon            3. Specify the following if radiological containment devices will be used:

                             Type of containment required

                             Special instructions needed for containment fabrication and/or
                              installation

                             Containment certification requirements (drapes are not
                              certified)

                             When the containment is required to be certified/re-certified

                             If appropriate, radiological conditions necessary for opening
                              the containment. For example, if a glove bag is to be opened
                              and used as a drape containment, the work document shall
                              specify the conditions necessary for opening the glove bag and
                              when it shall be re-certified

                             Radiological conditions necessary for containment removal

                             When the containment, including drapes, is to be removed.

Document Owner/   4. Consider the following when working on pressurized systems.
RadCon/Work
Planning Team         a.      Ensure criteria for pre-job pressure testing of pressurized
                              systems and components that impact radiological conditions if
                              failure were to occur during system operation or testing are
                              incorporated into the work document, as appropriate.

                      b.      Ensure pressure sources connected to radiologically
                              contaminated systems during operations, maintenance, or
                              testing includes provisions for monitoring pressure and
                              temperature.

                      c.      Ensure pressure sources include provisions for pressure relief
                              or regulation to preclude over-pressurization of the system,
                              hoses, jumpers, etc.

                      d.      Consider the use of an enclosure around temporary systems,
                              joints, or other likely leak points.

                  5. Specify provisions for debris collection and control where there is a
                     possibility of fixed contamination being present and work evolutions
                     could liberate solid debris, such as paint chips or flakes.
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 RadCon                         6. Determine if locations and capabilities of personnel decontamination
                                   equipment and facilities are adequate should an unplanned spread of
                                   contamination occur. This determination should include, but is not
                                   limited to: (7.1.7)

                                           Potential radiological hazards inherent to the work being
                                            performed

                                           Size of work crew

                                           Location and number of safety showers

                                           Location and capabilities of permanent and portable
                                            decontamination facilities relative to the work site

                                           Operability and location of portable decontamination facilities

                                           Availability and adequacy of spill kits at or near the work site

                                           Availability of additional water and personnel decontamination
                                            supplies at or near the work site

                                           Job site specific items necessary to promptly respond to a
                                            potential personnel contamination event.

4.3.3   Airborne Radioactivity Control Considerations
        (7.1.2.j)


        The following operations have the potential to generate airborne radioactivity when accomplished
        on surfaces with removable or fixed contamination:

                   High-speed abrasive operations (e.g., grinding and sawing)

                   Hot cutting (e.g., carbon arc and plasma arc)

                   Welding

                   Dust producing operations, such as wire brushing and abrasive blasting

                   Non-aggressive work (i.e., hand tools only) on surfaces >1 square meter in surface area
                    where dry contamination levels exceed 175,000 dpm/100cm2 beta-gamma or 42 dpm/
                    100cm2 alpha.

                   Decontamination.

        In addition, the chemical form of the contamination may decrease its stability relative to the
        potential for generating airborne radioactivity. Evidence indicates that systems that have been
        exposed to plutonium oxide or that have received an oxalic acid flush or treatment tend to contain
        contamination that becomes airborne very easily. However, the chemical form of contamination
        is not normally known prior to commencing work. A conservative approach to controlling
        exposure to or potential release of airborne radioactivity should be taken in these instances. (7.1.7)
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 Document Owner/           1. Consider the following practices to reduce airborne radioactivity levels:
 RadCon/Work
 Planning Team                        Fully enclosed radiological containments

                                      HEPA filtered ventilation

                                      Performing activities under water

                                      Application of wetting agents or fixatives. (See Attachment B
                                       for a list of approved fixatives.)

                           2. Determine potential airborne radioactivity concentration per
                              Attachment C.

                           3. Determine appropriate respiratory protection measures if work:

                               a.      Will be performed in a posted airborne radioactivity area
                                       (ARA) or

                               b.      Will result in the concentration of airborne radioactivity, above
                                       natural background, exceeding or likely exceeding 10% of the
                                       derived air concentration (DAC) values listed in Appendix A
                                       or C of 10 CFR 835.

                           4. Specify use of respiratory protection and air sampling for pit work
                              where engineering controls and source term characterization data
                              cannot be verified, or where changing conditions are anticipated.
                              Changing radiological conditions can be expected when disconnecting
                              nozzles and/or jumpers or when removing them from the pit. (7.1.7)

                               NOTE 1: Movement of flexible jumpers has historically been a source
                               of airborne radioactivity release and/or contamination spread.

                               NOTE 2: Once pit conditions are stabilized and known, the respiratory
                               protection requirement may be relaxed based on analysis of collected
                               air sample data.

4.3.4   Voluntary Respirator Use

        NOTE: This section is to be performed in conjunction with the requirements of
        TFC-ESHQ-S_IH-C-05.

 RadCon                    1. If work will be performed in a high radiation area, with dose rates
                              >1 rem, calculate additional dose employee(s) will receive due to
                              voluntary respirator use (TEDE), as follows, and document in the
                              work instructions.
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                                        TEDE  DDEw  DDEw / o

                                       where:

                                                mrem 
                                        DDEw          hr  IF
                                                hr 

                                                    mrem 
                                        DDEw / o          hr
                                                    hr 

                                       w = with respirator
                                       w/o = without respirator
                                       IF = 1.15

                               NOTE: The above calculation assumes that airborne radioactivity is
                               absent.

                           2. Document on the RWP if voluntary respirator protection is not allowed
                              due to radiological consideration.

4.3.5   Beta Radiation Hazards

        NOTE: Direct (contact) handling of items with beta radiation hazards should be avoided unless
        reviewed and approved by a work planning team as part of the work planning process. (7.1.10)

 RadCon/Work               1. Implement controls to minimize exposure to beta radiation whenever
 Planning Team                personnel may receive an extremity exposure of 500 mrem or be
                              exposed to a shallow dose rate of 500 mrem.

                           2. Consider beta shielding whenever personnel are working on items that
                              have contacted (or been contacted by) tank waste.

                           3. Consider the following techniques to reduce personnel beta radiation
                              exposure (not an all-inclusive list):

                                      Place a layer of plastic or rubber (containment, glove bag,
                                       heavy plastic bag, face shield, protective eye-wear, air-fed
                                       hood, respirator) between the worker and beta radiation source.

                                       NOTE: Air-fed hoods and respirators are acceptable protective
                                       clothing for beta radiation but should not be used solely for
                                       beta radiation protection.

                                      Use shielded gloves.

                                      Use extension tools.
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                            4. Ensure work documents governing work where personnel may be
                               exposed to beta radiation specify precautions for minimizing and
                               monitoring beta radiation exposure.

                            5. Ensure work documents governing work where personnel may be
                               exposed to beta radiation specify when beta radiation surveys are
                               required.

4.3.6   High Radiation Area Considerations

        NOTE: If the breach of a high radiation area boundary is such that a portion of a person’s whole
        body cannot be exposed to actual radiation levels of >100 mrem in an hour, the requirements of
        this paragraph do not apply.

 RadCon                     1. Specify high radiation area access controls when work documents
                               direct a breach of a high radiation area boundary or creation of a new
                               high radiation area. Removal of pit cover blocks, removing
                               radiological samples from shielded containers or tank riser shield plugs
                               >6 inches in diameter are examples of activities that could result in
                               breaching a high radiation area boundary.

                            2. Specify instructions for temporary cover and/or locking device
                               installation or guarding at high radiation area access points in the work
                               document when the high radiation area will be established for >8
                               continuous hours.

                            3. Specify instructions for continuous high radiation area boundary and
                               access control in the work document when the high radiation area will
                               be established for less than eight continuous hours and the high
                               radiation area will not be physically posted.

                            4. Specify requirements for closeout inspections of high radiation area
                               prior to access closure if the high radiation area will be secured in a
                               manner that would prevent unassisted exit by personnel (e.g.,
                               padlocking a vault door).

                            5. Specify special monitoring required of work where whole body
                               radiation levels exceed 1 rem/hour. Work documents directing work on
                               equipment and components with accessible radiation levels in excess of
                               1 rem/hr shall require steps for the performance of:

                                       Radiation gradient surveys (survey detail commensurate with
                                        the work) or in-process surveys in transient situations

                                       Establishment of stay times
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                                       Establishment of predetermined supplemental dosimeter
                                        readings that require workers to exit the area

                                       When the radiation source is a point source and work does not
                                        require any part of the whole body to come within 30
                                        centimeters (cm) of the source, the work is to be performed so
                                        that the worker’s body position does not come within 30 cm of
                                        the source to the maximum extent practicable.

4.3.7   Radiation Gradient Surveys

        Radiation gradient surveys are not required to be specified in the work document if workers are
        not likely to maintain a relatively constant position with respect to the radiation field. This
        includes tours, tasks/jobs where general/component/piping radiation levels in the work area are of
        short duration (e.g., changing a light bulb) where general/component/piping radiation levels are
        relatively low.

 RadCon                     1. Specify radiation gradient surveys to quantify radiation levels and to
                               aid in determining dosimetry placement, use of multiple whole body
                               dosimetry, and/or use of extremity dosimetry when:

                                        There is an inadequate exposure history to allow the work
                                         document preparer to specify dosimetry requirements.

                                        Work is in a high radiation area that is not well characterized.

                                        The work evolution may create a radiation gradient.

                            2. Determine the detail and complexity of gradient survey requirements as
                               follows:

                                        Simple gradient survey information includes the radiation
                                         levels for worker position and time spent in various positions
                                         with consideration to the entire volume of the body. Time in
                                         various positions may be estimated. The two types of simple
                                         gradient surveys are:

                                                 5 point (head, chest/back, waist, thighs and upper
                                                  arms)

                                                 3 point (head, chest/back and waist).

                                        Complex gradient survey information includes the radiation
                                         levels at grid locations shown on a survey map (i.e., three
                                         dimensions and all six sides of the worksite envelope to
                                         represent the work area).

                                 NOTE: Specific dosimetry requirements for monitoring extremity
                                 exposure are specified based on criteria of TFC-ESHQ-RP_DOS-C-03.
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4.3.8   Radiological Survey Requirements

        Steps in this section are not intended to cover all conditions or situations warranting radiological
        surveys. Professional judgment should be used when specifying radiological survey requirements
        to ensure monitoring of radiological conditions is sufficient to maintain exposure to radiological
        hazards ALARA.

        Many radiological surveys are performed as skill based work during accomplishment of work.
        General work practice surveys are not required to be specified in the work document. See
        Attachment D for examples of work practice surveys.

4.3.8.1 General Contamination Surveys

 RadCon/Work                1. Specify removable contamination survey requirements when a work
 Planning Team                 operation is expected to spread contamination or when the survey data
                               is necessary to determine the radiological controls required for
                               subsequent work steps.

                                 NOTE: The location of surveys is normally not specified, but if
                                 specific information is required, the location will be specified. Work
                                 documents should specify contamination surveys, as follows.

                            2. Specify a removable contamination survey at initial fluid system entry;
                               for highly contaminated systems, perform a smear of the areas, surveys
                               of wipe-down material may be used as an indicator of contamination
                               levels.

                                 NOTE: Surveys are not required during remote entry into fluid
                                 systems. Examples of remote entry include, but are not limited to,
                                 jumper removal and cutting that is performed using remote tooling.

                            3. If radiological conditions have changed since the last survey was
                               performed, specify removable contamination surveys when entering
                               potentially contaminated areas that contain known and potentially
                               contaminated systems, such as pits or vaults.

                            4. Specify removable contamination surveys when operations known to
                               spread contamination are specified, such as machining, filing, and
                               grinding.

                            5. Specify removable contamination surveys of previously unexposed
                               surfaces when removing equipment/components from areas where
                               radioactivity from previous spills may have not been completely
                               removed, or when uncovering potential sources of contamination, such
                               as removal or disassembly of potentially contaminated components.
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                           6. When removable contamination levels in excess of 100,000 dpm/
                              100cm2 are expected, perform additional surveys for removable
                              contamination commensurate with work operations, when required.

                                NOTE: Additional surveys may include containment exteriors,
                                radioactive material packaging, and radioactive material travel paths.

                           7. Specify removable contamination surveys prior to opening glove bags.

                           8. Specify maximum removable contamination levels allowed before
                              removing a glove bag, de-posting a drape containment, or containment
                              tent as follows:

                                       Downposting to Radiological Buffer Area (RBA) status:

                                        <1,000 dpm/100cm2 beta-gamma
                                        <20 dpm/100cm2 alpha

                                       Downposting to Contamination Area (CA) status:

                                        <50,000 dpm/100cm2 beta-gamma
                                        <20 dpm/100cm2 alpha.

                           9. Specify contamination levels for working in localized contamination
                              areas and high contamination areas as follows: (RPP-10709)

                                       Localized contamination areas:

                                                Distributed removable contamination >10,000
                                                 dpm/100cm2 beta-gamma or >200 dpm/100cm2 alpha

                                                > 100,000 dpm/100cm2 beta-gamma or >2000
                                                 dpm/100cm2 alpha on components.

                                       Localized high contamination areas:

                                                Distributed removable contamination >175,000
                                                 dpm/100cm2 beta-gamma or >2000 dpm/100cm2 alpha

                                                >39 mrad/hr beta-gamma or >420 dpm/100cm2 alpha
                                                 on components.

4.3.8.2 Alpha Contamination Surveys

       If survey data is not available, and surveys cannot be performed for the planning of the work,
       then plan the work using the high risk assumptions with the highest level of radiological controls
       incorporated into the work instructions.

 RadCon                    1. Specify alpha contamination surveys when working in areas where
                              alpha contamination is expected or known to exist.
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4.3.8.3 Airborne Radioactivity Surveys

 RadCon                     1. Specify airborne radioactivity surveys when operations that are likely to
                               generate airborne radioactivity. This includes working with dry,
                               distributed, removable contamination:

                                         >175,000 dpm/100cm2 beta-gamma
                                         >42 dpm/100cm2 alpha

                                or wet, distributed removable contamination:

                                         >39 mrad/hr beta-gamma
                                         >420 dpm/100cm2 alpha.

                            2. Specify airborne radioactivity surveys when opening known dry
                               contaminated systems in a drape or walk-in contamination area.

                            3. Specify airborne radioactivity surveys during contaminated pit access,
                               disconnecting/removing pit jumpers, pit demolition, and pit cleaning.
                                (7.1.7)


                            4. Specify airborne radioactivity surveys when opening or upon initial
                               entry into areas containing radioactive piping if a piping breach in the
                               area is believed to exist.

4.3.8.4 Radiation Surveys

 RadCon                     1. Specify gamma and/or beta radiation surveys when operations likely to
                               significantly change radiation levels are performed, such as:

                                         Movement of highly radioactive material
                                         Opening waste transfer or storage system components
                                         Installation/modification/removal of shielding
                                         Removal of highly contaminated piping from plant component
                                         Radioactively contaminated liquid movement
                                         Draining of waste transfer systems.

                            2. Specify gamma radiation surveys be taken when contact radiation
                               levels on material (including decontamination rags) or equipment
                               removed during work is expected to be >100 mrem/hr, including when
                               removal of components or interferences could expose previously
                               inaccessible areas with radiation levels >100 mrem/hr.

                            3. Specify contact gamma radiation surveys to be taken on radioactive
                               piping following insulation removal.

                            4. Specify neutron radiation surveys to be taken where personnel may be
                               exposed to neutron radiation, such as when handling neutron test
                               sources.
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4.3.9   Excavation in Radiological Areas

 RadCon                   1. Screen the planned excavation activity in accordance with
                             HNF-PRO-090, Section 5.2, step 2.d.

 RadCon/Work              2. Plan and control work in contaminated soil in accordance with the
 Planning Team               requirements of ALARACT 5, any applicable Notices of Construction
                             (NOCs), and Table 3.

 RadCon                   3. Specify health physics technician coverage requirements when working
                             in contaminated/ potentially contaminated soil as follows: (7.1.4)

                                     Continuous health physics technician coverage is required
                                      when:

                                               Excavating in a contamination area

                                               Excavating in a soil contamination area (SCA)

                                               Excavating in an underground radioactive material area
                                                (URMA) posted due to potentially contaminated soil)

                                               Excavating within 3 feet of a waste transfer line or tank
                                                dome

                                               Prior to entry into an exposed waste transfer line.

                                     Health physics technician coverage when excavating outside of
                                      a contamination area, soil contamination area, or underground
                                      radioactive material area is to be handled on a case-by-case
                                      basis using a graded approach. In these situations, include
                                      health physics technician coverage requirements in the job-
                                      specific work instructions/procedure.

4.3.10 Hold Points

 RadCon/Work              1. Incorporate radiological hold point steps into work documents for steps
 Planning Team               that require action by the RadCon organization to prevent any of the
                             following:

                                     Radiation exposures in excess of administrative control levels

                                     Personnel contamination

                                     Airborne radioactivity levels in excess of 10 times the DAC
                                      values provided in Appendices A and C of 10 CFR 835
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                                      Work that can result in the spread of contamination to the
                                       environment requiring notification as specified in
                                       TFC-OPS-OPER-C-24.

                              NOTE: Criteria for radiological hold points are contained in
                              Attachment A.

                              a.       Format hold point steps in work documents as specified in
                                       TFC-OPS-MAINT-C-01.

                              b.       With the exception of pre- and post-job radiological surveys,
                                       ensure RadCon action steps (not hold points) in work
                                       documents do not have sign-off lines.

4.3.11 Contingency Planning

      NOTE: Contingency planning is defined as the determination of plausible events that might
      occur during the course of performing planned work and identifying approaches to deal with
      these events. Since the potential number of contingent events is large for any task and increases
      with task complexity, it is not reasonable to plan for every contingency. A graded approach
      should be taken.

 RadCon/Work              1. Address events with high probability of occurrence or which may result
 Planning Team               in significant adverse impact in the work document. Those with lesser
                             probability and/or lesser impact should be addressed consistent with
                             good engineering judgment and ALARA principles.

                          2. Incorporate contingency planning into work documents for activities
                             which have a high probability of:

                                      Personnel receiving exposures in excess of administrative
                                       control levels

                                      Work that can result in the spread of contamination to the
                                       environment requiring notification as specified in
                                       TFC-OPS-OPER-C-24

                                      Airborne radioactivity levels in excess of 10 times the DAC
                                       values provided in Appendices A and C of 10 CFR 835.

 RadCon/Engineering       3. Verify engineered barriers for minimizing contamination of equipment
                             will perform, or have performed their intended function before relying
                             on the barrier.

                              a.       Request radiological surveys of suspect areas of used
                                       contaminated equipment to determine if unusual or
                                       unanticipated contamination and/or radiation levels exist,
                                       indicating potential engineered barrier failure.
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                               b.     Request a visual inspection be performed of used contaminated
                                      equipment for the presence of unusual or unanticipated
                                      amounts of liquid that may indicate potential engineered barrier
                                      failure.

4.3.12 Work Site Restoration

 Field Work               1. Do not consider work activities complete until support material and
 Supervisor                  equipment have been removed and the area has been returned to at least
                             pre-work status. If this is not feasible:

                               a.     Notify the cognizant project RadCon director and facility
                                      Operations managers.

                               b.     Ensure that the radiological survey report and in the
                                      radiological field office logbook document the as-left
                                      condition, as appropriate.

                               c.     Initiate a Problem Evaluation Request (PER) in accordance
                                      with TFC-ESHQ-Q_C-C-01.

                          2. Do not consider work activities complete until temporary shielding has
                             been removed or converted into permanent shielding. If this is not
                             feasible:

                               a.     Notify the cognizant project RadCon director and facility
                                      Operations managers and the company technical authority for
                                      temporary shielding.

                               b.     Initiate a PER in accordance with TFC-ESHQ-Q_C-C-01.

4.3.13 Mock-Up Training

    Mock-up training provides a method for verifying specialized skills training, work practices,
    adequacy of work documents, and special tools needed to ensure work is completed safely while
    maintaining radiation exposure ALARA.

 Planner/RadCon           1. Consider mock-up training for complex radiological work performed in
                             high radiation areas or involving work on highly contaminated systems
                             or working in high contamination area. Jobs that should be considered
                             for mock-up training include:

                                     Work that could involve an individual receiving >250 mrem or
                                      cumulative dose >1000 mrem

                                     Work that can result in the spread of contamination to the
                                      environment requiring notification as specified in
                                      TFC-OPS-OPER-C-24.

                                     First-time or complex work on radiological systems using new
                                      tooling and/or techniques
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                               Work that will result in rapidly changing radiological
                                conditions

                               Work that, if mock-up training were accomplished, would
                                significantly reduce the time it takes to complete the job or the
                                number of workers required.

                    2. Determine the degree of mock-up training required during work
                       planning. A graded approach should be taken when determining the
                       type of mock-up training required as follows.

                               Type A: Training can be accomplished by an instructor or
                                technically competent individual using a lecture or conference
                                technique.

                               Type B: Hands-on training should be conducted by an
                                instructor or technically competent individual who will
                                demonstrate the use of a tool or equipment and then the
                                workers set up and operate the tool or equipment under his/her
                                direction. This training could be accomplished on a workbench
                                or mockup. When the workers are familiar with the setup and
                                operation of the tool, they would set up the tool individually
                                without assistance from the instructor. Minimal or no
                                protective clothing would be used.

                               Type C: Training should be conducted by an instructor or
                                technically competent individual in a full-scale mockup that
                                closely simulates the actual work area, with the same
                                radiological work requirements as the actual job. Personnel
                                will be dressed in the same protective clothing and follow the
                                same steps in the work procedure and RWP (see
                                Attachment E).

Field Work          3. Obtain or construct mock-ups, as required, for training. Mock-ups may
Supervisor             consist of a small bench-top device or a full scale model of the work
                       area, including all interferences, services, containments and tooling to
                       be encountered during actual work.

Field Work          4. Perform mock-up evaluation and document on A-6002-598.
Supervisor/RadCon
                        a.      Assign personnel to act as mock-up evaluators, as needed.

                        b.      Ensure instructors, trainers, and management personnel
                                evaluate the mock-up to verify work can be performed safely in
                                the field.

                        c.      Ensure for Type B or C mock-ups that an Operations or
                                RadCon director or delegate are part of the evaluation team.
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 Operations Director      5. Review and approve mock-up documentation on A-6002-598.
 and Project RadCon
 Director

4.4    ALARA Management Worksheet Preparation

       See Attachment F for ALARA Management Worksheet preparation.

       The ALARA Management Worksheet is a tool to used to ensure all achievable methods of
       reducing the worker’s exposure have been considered while developing the work instructions for
       the work and is not a substitute for approved work instructions.

       NOTE 1: TFC ALARA Management Worksheets (AMW) (A-6003-121), a CH2M HILL
       template in Word) are prepared following requirements and guidelines and AMW training.

       NOTE 2: The applicable lessons learned documented on the AMW should be incorporated into
       the work instructions and/or work documentation. (7.1.9)

 RadCon                   1. Prepare an ALARA Management Worksheet for activities that:

                                     Meet medium or high radiological risk screening criteria

                                      NOTE: All medium and high risk work activities require team
                                      planning in a group.

                                     Are considered significant radiological work determined to be
                                      infrequent or first time activity (requires enhanced line and
                                      RadCon management oversight during initiation and conduct of
                                      work)

                                     Are management requests

                                     Are RadCon requests.

                          2. Prepare a standing ALARA Management Worksheet, when practicable,
                             for repetitive work that has previously been completed successfully
                             (e.g., pit work, core sampling, grab sampling, excavation) as long as:

                                     The activity has been previously planned using the work
                                      planning process

                                     The activity has received initial RadCon review and approval

                                     The activity has been successfully performed under field
                                      conditions
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                                   Work scope and processes governed by the work document
                                    have not changed

                                   Radiological conditions and controls specified in the work
                                    document have not changed since original review and approval

                                   A post-job ALARA review was not required for previously
                                    performed work.

                            NOTE: Standing ALARA Management Worksheets are effective for
                            one year or until the ALARA Management Worksheet is revised or
                            corrected, whichever occurs first. At the end of the one year period, the
                            standing ALARA Management Worksheet shall be reviewed/revised, if
                            necessary, and be reactivated or discontinued.

 Work Planning Team     3. Review the AMW as a part of the Job Hazard Analysis roundtable
                           meeting, and update, as necessary.

 RadCon                 4. Sign each ALARA Management Worksheet before its initial use and
                           after each revision or correction. Verify the appropriateness of using a
                           standing ALARA Management Worksheet for the work activities being
                           covered.

                        5. Route the ALARA Management Worksheet for approval as follows:

                                   AMW preparer
                                   Cognizant field work supervisor
                                   Project ALARA chairperson or delegate
                                   Project Operations director or delegate
                                   Project RadCon director or delegate
                                   ALARA Joint Review Group chairperson (high risk).

                        6. If a standing ALARA Management Worksheet is used, verify the
                           standing ALARA Management Worksheet has not exceeded the review
                           frequency or expired. If the standing ALARA Management Worksheet
                           is expired, evaluate and reissue it, or create a new one.

4.5    Dose Estimates

 Planner/RadCon/        1. Obtain data, as needed, to perform the dose estimate (see Figure 2 for
 Field Work                suggested worksheet). This data includes, but is not limited to:
 Supervisor
                                   Description of work steps
                                   Approximate stay times
                                   Number of exposed workers
                                   Dose rate(s) in the work area.
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                      2. If available, obtain survey data from the most current radiological
                         survey report or work history records.

                          a.      If reliable survey reports are unavailable, request a pre-job
                                  survey, as needed.

                          b.      If insufficient survey data is available to develop an accurate
                                  dose estimate, then plan the work using the high risk
                                  assumptions with the highest level of radiological controls
                                  incorporated into the work instructions.

 RadCon               3. Estimate a collective dose for the job.

                          a.      For collective dose estimate <200 person-mrem, perform dose
                                  estimate using simple calculations, previous job history, or pre-
                                  job survey data.

                          b.      For collective dose estimate between 200 and 500 person-
                                  mrem, perform dose estimate by:

                                         Obtaining previous collection dose history from the
                                          same or similar jobs

                                         Performing simple calculations based on previous
                                          radiological survey data and estimated stay times.

                                         Performing calculations that take into account varying
                                          dose rates for multiple tasks within the job and
                                          estimated stay times associated with those tasks.

                          c.      For collective dose estimate >500 person-mrem, perform dose
                                  estimate by:

                                          Breaking the job down into its component parts.

                                          Estimating the dose for each task by multiplying the
                                           estimated stay time and the dose rate in the area where
                                           the task is being performed.

                                          Developing a table to display how the estimated
                                           collective dose was determined.

                      4. Document the dose estimate and method in the work document.

4.6   Dose Tracking

 RadCon               1. Monitor collective dose periodically for work with dose estimates
                         above 200 person-mrem.
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                          2. For work categorized as high radiological risk due to dose
                             considerations, specify a dose tracking periodicity and responsible
                             person(s) to track collective and individual dose.

                          3. Conduct an ALARA review if accumulated dose exceeds the triggers
                             established in Section 4.7.

4.7   In-Process and Post-Job ALARA Reviews

      NOTE: An equivalent critique or event investigation report that fulfills the requirements of this
      section may be used rather than an ALARA review.

      In-process ALARA reviews shall be completed when:

             Work is stopped due to a reportable radiological event (defined in
              TFC-OPS-OPER-C-24) and revisions are required to engineered or administrative work
              controls

             Accumulated dose exceeds 150% of estimated job dose for jobs where the dose estimate
              is >200 person-mrem

             Accumulated dose exceeds 125% of estimated job dose for jobs where the dose estimate
              is >1,000 person-mrem

             During the job it is anticipated that a trigger level for a higher radiological risk category
              will be exceeded

             Requested by management

             Feedback is received for significantly improving radiological performance during
              completion of remaining work governed by the work document.

      A post-job ALARA review shall be completed when:

             The job produces an actual collective dose of 5 person-rem or greater

             The actual dose encountered for the job differs from the predicted dose by more than
              25%, if the actual collective dose is 1.0 person-rem or greater

             Stop radiological work authority was exercised by any worker during the performance of
              the work

             A reportable radiological occurrence occurred during the performance of the work

             Significant lessons learned are identified during work or during radiological surveillances
              and assessments associated with the work

             The work document was screened as high radiological risk

             Requested by management.
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Planner              1. Notify cognizant RadCon when field work has been completed for all
                        medium and high radiological risk work documents.

RadCon               2. Determine if an ALARA review is required.

Planner or Field     3. Schedule a post-job ALARA review meeting as soon as possible after
Work Supervisor         the work is complete, but no later than 30 days after completion of the
                        field work portion of the work document.

                         NOTE: Attendance at ALARA reviews should include the ALARA
                         chairperson or coordinator (when possible), cognizant RadCon
                         personnel, CH2M HILL Hanford Atomic Metals Trade Council
                         (HAMTC) safety representative (when possible), and at least one
                         representative from each craft involved in the job. Craft representatives
                         should (when possible) have participated in the job to be involved in the
                         post-job ALARA review. The function of the ALARA chairperson or
                         coordinator may be fulfilled by cognizant RadCon personnel. If craft
                         representatives are unavailable for the post-job ALARA review
                         meeting, and their supervisor has sufficient knowledge of what took
                         place during the work, the supervisor may represent the craft(s) at the
                         meeting.

Field Work           4. Conduct the ALARA review meeting.
Supervisor/RadCon/
Planner                  a.      Gather data to reflect the work practices and ALARA measures
                                 that were effective, and define those needing improvement.

                         b.      Solicit input from workers involved in the job for identification
                                 of good practices and areas for improvement that can be
                                 incorporated into the continuous work improvement process.

                         c.      Keep a roster of the ALARA review meeting attendees and
                                 include as part of the ALARA review document.

RadCon               5. Document the results of the ALARA review using A-6002-919.

                         a.      Obtain an ALARA review number from TFRWP/ALARA
                                 Reviews/PJAR Index.

                         b.      Route the ALARA review documentation for review and
                                 approval.

                                 NOTE: Approvals to in-process ALARA reviews include:

                                         In-process ALARA review preparer
                                         Cognizant field work supervisor
                                         RadCon subject matter expert.
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                                       NOTE: Approvals for post-ALARA reviews include:

                                               Post-ALARA review preparer
                                               Cognizant field work supervisor
                                               Project ALARA chairperson or delegate
                                               Project Operations director or delegate
                                               Project RadCon director or delegate

                               c.      Place the original completed ALARA review documentation in
                                       the work package (as applicable) and forward a copy to the
                                       CH2M HILL ALARA chairperson.

 RadCon/Work Team         6. Revise ALARA Management Worksheets, as needed, for future use.

 RWP Preparer             7. Revise RWPs, as needed, for future use.

 Planner/Document         8. Revise work documents, as needed, for future use.
 Owner

 RadCon                   9. Initiate a Problem Evaluation Request (PER) in accordance with
                             TFC-ESHQ-Q_C-C-01, as necessary

4.8   Radiological Design Review
      (7.1.2.g)


      Controls shall be incorporated in the design and modification of radiological facilities such that
      personnel exposure from external sources of radiation in areas of continuous occupational
      occupancy (2000 hours per year) shall be maintained below an average of 0.5 mrem
      (5 microsieverts) per hour and as far below this average as is reasonably achievable.

      The design objectives for exposure rates for potential exposure to a radiological worker where
      occupancy differs from the above shall be ALARA and not exceed 20 percent of the applicable
      standards in 10 CFR 835.202.

      For specific activities where use of physical design features is demonstrated to be impractical,
      administrative controls shall be used to maintain radiation exposures ALARA. (7.1.2.f)

 RadCon                   1. Perform radiological design review, as needed, in accordance with
                             TFC-ENG-DESIGN-P-17 and TFC-ESHQ-RP_ADM-C-12.

5.0   DEFINITIONS

      Annual limit on intake. The derived limit for the amount of radioactive material taken into the
      body of an adult worker by inhalation or ingestion in a year. ALI is the smaller value of intake of
      a given radionuclide in a year by the reference man that would result in a committed effective
      dose equivalent of 5 rems (0.05 sievert) or a committed dose equivalent of 50 rems (0.5 sievert)
      to any individual organ or tissue.

      Derived air concentration. The concentration of a given radionuclide in air which, if breathed by
      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 ALI.
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      Deep dose equivalent. The dose equivalent derived from external radiation at a depth of 1 cm in
      tissue.

      Excavation. Excavations include any operation in which earth, rock, or other material in the
      ground (below existing grade) is moved, removed or otherwise displaced by means or use of any
      hand tools, mechanical equipment or explosives.

      Inefficiency factor. The estimated percent decrease in worker efficiency due to wearing
      respiratory protection.

      Localized radiological area. A radiologically controlled area that will not be entered into with the
      whole body.

      Protection factor. The ratio of ambient airborne concentration to concentration inhaled of a given
      substance while wearing a respirator.

      Routine radiological work. Repetitious work for which the radiological risk does not vary
      enough between each performance of the activity to justify repetitive reviews.

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

6.0   RECORDS
      (7.1.1.b)


      The following records are generated during the performance of this procedure:

                 TFC ALARA Management Worksheet (AMW) (A-6003-121)
                 CH2M HILL ALARA Review (A-6002-919)
                 Mock-Up Attributes (A-6002-598).

      The RadCon Program organization is responsible for record retention and retirement in
      accordance with TFC-BSM-IRM_DC-C-02.

7.0   SOURCES

7.1   Requirements

      1.          DOE O 433.1, “Maintenance Management Program for DOE Nuclear Facilities,”
                  Section 4a. (S/RID)

      2.          HNF-MP-5184, “CH2MHILL Hanford Group, Inc., Radiation Protection Program.”
                  a.   Requirement #20, 835.101(c).
                  b.   Requirement #180, 835.704 (b).
                  c.   Requirement #207, 835.1001(a).
                  d.   Requirement #208, 835.1001(a).
                  e.   Requirement #209, 835.1001(a).
                  f.   Requirement #210, 835.1001(b).
                  g.   Requirement #212,835.1002(b).
                  h.   Requirement #217, 835.1003(a).
                  i.   Requirement #218, 835.1003(b).
                  j.   Requirement #255, 835 Appendix A.
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       3.    PER-2002-3575. (Management Directed)

       4.    PER-2003-2858. (Management Directed)

       5.    PER-2003-3072. (Management Directed)

       6.    RPP-MP-003, “Integrated Environment, Safety, and Health Management System
             Description for the Tank Farm Contractor.”

       7.    SPER-2003-2427. (Management Directed)

       8.    PER-2004-1746. (Management Directed)

       9.    SPER-2004-4057. (Management Directed)

      10.    PER-2004-5835. (Management Directed)

7.2   References

       1.    ALARACT 5, “Tank Farm ALARACT Demonstration for Soil Excavation (Using Hand
             Tools).”

       2.    10 CFR 835, “Occupational Radiation Protection.”

       3.    HNF-5183, “Tank Farms Radiological Control Manual.”

       4.    HNF-5779, “Radiological Control Instructions.”

       5.    HNF-IP-0842, RPP Administration, Volume 7, Section 13.6, “Supplemental Dosimetry.”

       6.    HNF-PRO-090, “Excavating, Trenching, and Shoring.”

       7.    Letter 7TA00-02-KMH-004, K.M. Hall to J.W. Hobbs, “Corrective Action Plan for
             PER-2002-3575,” dated September 23, 2002.

       8.    NUREG/CR-0041, “Manual of Respiratory Protection Against Airborne Radioactive
             Material.”

       9.    PNL-MA-552, “Hanford Project Internal Dosimetry Project Manual.”

      10.    RPP-10709, “Radiological Control Requirements for Working in Localized
             Contamination and High Contamination Areas in Tank Farms.”

      11.    TFC-BSM-IRM_DC-C-02, “Records Management.”

      12.    TFC-ENG-DESIGN-P-17, “Design Verification.”

      13.    TFC-ESHQ-Q_C-C-01, “Problem Evaluation Request.”

      14.    TFC-ESHQ-RP_ADM-C-11, “ALARA Joint Review Group.”
ESHQ                             Document           TFC-ESHQ-RP_RWP-C-03, REV F-2
                                 Page                                      28 of 43
ALARA WORK PLANNING              Effective Date                   January 27, 2005

   15.   TFC-ESHQ-RP_DOS-C-03, “External Dosimetry.”

   16.   TFC-ESHQ-RP_MON-C-11, “High Radiation Areas Physical Access Controls.”

   17.   TFC-ESHQ-RP_RWP-C-04, “Radiological Work Permits.”

   18.   TFC-ESHQ-S_IH-C-05, “Respiratory Protection.”

   19.   TFC-OPS-MAINT-C-01, “Tank Farm Contractor Work Control.”

   20.   TFC-OPS-OPER-C-24, “Occurrence Reporting and Processing of Operations
         Information.”

   21.   TFC-PRJ-SUT-C-02, “Operational Acceptance Test Preparation.”

   22.   TWR-4675, “RPP Radiological Source Term Report.”
ESHQ                                                    Document                         TFC-ESHQ-RP_RWP-C-03, REV F-2
                                                        Page                                                    29 of 43
ALARA WORK PLANNING                                     Effective Date                                 January 27, 2005

                                        Figure 1. ALARA Work Planning Process.

                                   Define work scope         Perform
               Start                  TFC-OPS-           radiological risk
                                     MAINT-C-01             screening




             Low risk                                      Medium risk                                            High risk




           Incorporate                                   Prepare draft job-
        requirements into                                                                                      Prepare draft job-
                                                       specific RWP/AMW                                      specific RWP/AMW
        work document(s)




            Can work be      No    Prepare new RWP                                    Participate in EWP      Participate in EWP
       performed on existing          TFC-ESHQ-                                           TFC-OPS-                TFC-OPS-
           general RWP?             RP_RWP-C-04                                         MAINT-C-01              MAINT-C-01


                       Yes
                                                                  ,
                                                                                     Participate in graded       Incorporate
         Assign general                                     Changes in         Yes     approach EWP           requirements into
             RWP                                           work scope or             TFC-OPS-MAINT-           work document(s)
                                                             hazards?                        C-01

                                                                      No
          Approve work
            document                                                                    Incorporate
        TFC-OPS-MAINT-                                 Finalize job-specific         requirements into       Finalize job-specific
              C-01                                         RWP/AMW                   work document(s)            RWP/AMW

                                                                                                                                     No


                                                          Approve work                                          Participate in
                                                            document                                            JRG review
                                                        TFC-OPS-MAINT-                                          TFC-ESHQ-
                                                              C-01                                             RP_ADM-C-11



                                                          Perform work                                              Work
                                                        TFC-OPS-MAINT-                                           approved by
                                                              C-01                                                  JRG?

                                                                                                                       Yes

                                                             ALARA                                               Perform work
                                                          trigger levels       Yes   Perform post-job
                                  End                                                                          TFC-OPS-MAINT-
                                                            exceeded?                ALARA review
                                                                                                                     C-01




                                                                                     Key:

                                                                                     ALARA:     As Low As Reasonably Achievable
                                                                                     AMW:       ALARA Management Worksheet
                                                                                     EWP:       Enhanced Work Planning
                                                                                     JRG:       Joint Review Group
                                                                                     RWP:       Radiological Work Permit
 ESHQ                                    Document            TFC-ESHQ-RP_RWP-C-03, REV F-2
                                         Page                                       30 of 43
 ALARA WORK PLANNING                     Effective Date                    January 27, 2005

                                Figure 2. Dose Estimate Worksheet.


The worksheet below may be used in developing dose estimates.

                                      ALARA WORK SCOPE
                                         Job Breakdown
                                                                               RC Use Only
                                                          Estimated
                                                No. In     Hours in    Dose Equiv.     Collective
    Component Task(s)/                                                     Rate       Dose Equiv.
                             Individual/Group   Group      Elevated
       Work Steps                                                       (mrem/hr)    (person-mrem)
                                                 (A)      Dose Field
                                                             (B)         Estimate       Estimate
                                                                           (C)          (AxBxC)
 1.
 2.
 3.
 4.
 5.
 6.
 7.
 8.
 9.
 10.
                         Total Estimated Collective Dose Equivalent (person-mrem)
ESHQ                                       Document               TFC-ESHQ-RP_RWP-C-03, REV F-2
                                           Page                                          31 of 43
ALARA WORK PLANNING                        Effective Date                       January 27, 2005

                   Table 1. Tank Farms Radiological Risk Screening Criteria.


                              Medium Risk/Planning               High Risk/Planning Required with
       Low Risk
                                      Required                           Joint Review Group
  Routine or                Tasks with a potential for        Work in, or that may result in creation
   repetitive                 changing radiological              of, whole body dose rate >1,000
   activities, such as        conditions that could result       mrem/hr
   tours and                  in exceeding any of the           Estimated individual exposure for the
   inspections or             criteria listed below              task is projected to exceed 250 mrem
   minor work                Work in, or that may result        or collective dose for the task is
   activities, in areas       in creation of, a high             projected to exceed 1,000 person-
   with well-                 radiation area                     mrem
   characterized and         Estimated individual              Work in, or that may result in,
   stable                     exposure for the task is           creation of an airborne radioactivity
   radiological               projected to be >100 mrem          concentration >10 times the applicable
   conditions.                to <250 mrem or collective         DAC value or >200 DAC-hours is
  Tasks that do not          dose >500 mrem to <1000            predicted
   meet any medium            person-mrem                       Non-routine or complex activities in
   or high risk              Normal repetitive work in          work areas where removable
   criteria that are          areas where removable              contamination is estimated to be
   performed using            contamination is estimated         >100,000 dpm/100cm2 Beta-Gamma
   an RWR,                    to be >100,000 to                  and/or >2,000 dpm/100cm2 Alpha in
   WRCSOF,                    <1,000,000 dpm/100cm2              the general area, or in the work area
   Generic/Repeat             Beta-Gamma and/or                  such that the workers personnel
   Work Package               >2,000 to <20,000 dpm/             protective equipment will be expected
   (GWP), Repeat              100cm2 Alpha in the                to come in contact with this level of
   PM Package                 general area, or in the            contamination
   (PM) or Graded             work area such that the
   Approach Work              workers personnel
   Package (WP) as            protective equipment will
   determined by              be expected to come in
   other                      contact with this level of
   requirements.              contamination
                             Work in, or that may result
                              in creation of, an airborne
                              radioactivity area
ESHQ                                  Document             TFC-ESHQ-RP_RWP-C-03, REV F-2
                                      Page                                        32 of 43
ALARA WORK PLANNING                   Effective Date                     January 27, 2005

             Table 1. Tank Farms Radiological Risk Screening Criteria. (cont.)


                         Medium Risk/Planning           High Risk/Planning Required with
       Low Risk
                                 Required                        Joint Review Group
                       Non-repetitive or complex  Potential releases of radioactive
                         activities in work areas       material to the environment that
                         where removable                exceed the following reporting
                         contamination levels are       criteria:
                         estimated to be >50,000         Identification of radioactive

                         dpm/100cm2 but <100,000           contamination on-site that is not
                         dpm/100cm2Beta-Gamma              located within a controlled area
                         and/or >1,000 but <2,000          (radiological), fixed contamination
                                      2
                         dpm/100cm Alpha in the            area, or soil contamination area, and
                         general area, or in the           is in excess of two (2) times the total
                         work area such that the           contamination levels in Table 2-2 of
                         workers personnel                 HNF-5183:
                         protective equipment will         >10,000 dpm/100 cm2 Beta/Gamma
                         be expected to come in                            OR
                         contact with this level of        >1,000 dpm/100 cm2 Alpha
                         contamination                                     OR
                       Dose estimates indicate            >2 x limit for known or identified
                         multi-pack dosimetry is              radionuclide constituent
                         required for a specific job
                         assignment.                     Identification of radioactive

                       Estimated individual dose          contamination outside a radiological
                         to the extremities or skin        area (as defined in HNF-5183) or
                         of >2,000 mrem but                radiological buffer area established
                         <5,000 mrem                       for contamination control, but
                       Tasks screened as high risk        within a controlled radiological
                         for the purpose of applying       area, in excess of 10 times the total
                         containment per TFC-              contamination levels in Table 2-2 of
                         ESHQ-RP_RWP-C-02                  HNF-5183:
                      Tasks with a potential for           >50,000 dpm/100 cm2Beta/Gamma
                      changing radiological                                OR
                      conditions that could result in      >5,000 dpm/100 cm2 Alpha
                      exceeding any of the above                           OR
                      criteria                             >10 x limit for known or identified
                                                             radionuclide constituent
                                                       Estimated individual dose to the
                                                         extremities or skin >5,000 mrem
                                                       Radiological activities that are
                                                         infrequently conducted or represent
                                                         first time operations.
 ESHQ                                     Document           TFC-ESHQ-RP_RWP-C-03, REV F-2
                                          Page                                      33 of 43
 ALARA WORK PLANNING                      Effective Date                   January 27, 2005

                   Table 2. 222-S Laboratory Radiological Risk Screening Criteria.
                                        HNF-5183, Table 2.2


           Risk Factor                 Low Risk           Medium Risk            High Risk
General area removable             <20 times Table    ≥20/<100 times Table   ≥100 times Table
contamination                      2-2                2-2                    2-2
Removable contamination levels     <100 times Table   ≥100/<1000 times       ≥1000 times Table
for straight sashed fume hood      2-2                Table 2-2              2-2
work activities
Removable contamination levels     <100 times Table   ≥100/<5000 times       ≥5000 times Table
for arm ported fume hood work      2-2                Table 2-2              2-2
activities
General area radiation (mrem/hr)   <100               ≥100/<1000             ≥1000
Individual whole body dose         ≤100               >100/<250              ≥250
(mrem)
Estimated collective dose          ≤500               >500/<1000             ≥1000
(person-mrem)
Airborne radioactivity             <0.1 DAC and/or    <1 DAC and/or 200      ≥1 DAC or 200
                                   40 DAC-hrs         DAC-hrs                DAC-hrs
Release of radioactivity to the    None               Potential              Likely
environment per DOE 232.1
 ESHQ                                          Document               TFC-ESHQ-RP_RWP-C-03, REV F-2
                                               Page                                          34 of 43
 ALARA WORK PLANNING                           Effective Date                       January 27, 2005

                      Table 3. Requirements for Working in Contaminated Soils.


     Condition                  Action(s)                                 Controls                      Source
>1,000 dpm/         Perform  surveys                      Apply suppressants (water, fixatives, or
                                                                                                       ALARACT 5
probe                                                    windscreens), as necessary
General Area Soil   1. Suspend work until controls are     1. Wet soil if not already damp
Contamination:         implemented and approval is         2. Perform general area workplace air
                       obtained to continue.                  monitoring
>200 dpm/probe     2. Notify Environmental and            3. Cover soil piles with plastic or apply
                       cognizant RadCon personnel             fixative as necessary to prevent dust    ALARACT 5
or                  3. Implement controls                     AND at end of each shift
                                                           4. Containerize or cover soil with clean
>500,000 dpm/                                                 fill if contaminated soil will be left
probe                                                       >48 hours
General Area Soil   1. Suspend work until adequacy of
Contamination:         controls is assessed and
                       approval is obtained to continue.
>20 mrad/hr         2. Notify Environmental and
                       cognizant RadCon personnel                                                      ALARACT 5
                    3. Notify WDOH
                    4. Assess adequacy of controls
                    5. Air sample

General Area Soil   1. Suspend work pending re-            1. Bioassay monitoring for
Contamination:         evaluation of bioassay                 contaminated soil is determined with
                       requirements and approval to           HNF-5183, Table 5-2
>245 dpm/probe        continue is received from
                       cognizant RadCon personnel
or                  2. Obtain soil sample and submit                                                   HNF-5183,
                       to lab for TA, TB, and GEA                                                       Table 5-2
>180 mrad/hr         analysis
(CP or RO-20, on    3. Notify cognizant RadCon
contact, window        personnel
open,               4. Air Sample
uncorrected)
Speck                                                      1. Remove and contain specks or
Contamination:                                             2. Locate specks in bottom of trench
                                                              upon excavation completion and
>490 dpm/probe                                            3. Cover with clean fill
                                                           4. Air Sample                               ALARACT 5
or

>1,000,000 dpm/
probe 
Sustained wind      Suspend work until winds subside
                                                                                                       ALARACT 5
speed >20 mph
 ESHQ                                     Document              TFC-ESHQ-RP_RWP-C-03, REV F-2
                                          Page                                         35 of 43
 ALARA WORK PLANNING                      Effective Date                      January 27, 2005

                   ATTACHMENT A – HEALTH PHYSICS HOLD POINTS


1.0   PURPOSE OF HOLD POINTS

      Health physics hold points are incorporated into work documents for steps that require action by
      the RadCon organization to assess existing radiological conditions or prevent significant adverse
      radiological consequences during subsequent steps.

      The intended results of the action are:

      A.      Prevention of radiation exposures in excess of administrative control levels.

      B.      Prevention of airborne radioactivity levels in excess of 10 times the DAC values provided
              in Appendices A and C of 10 CFR 835.

      C.      Prevention of the release of radioactivity to the environment.

2.0   HOLD POINT CRITERIA

      In support of these functions, the following activities require health physics hold points to be
      included in work packages when appropriate:

      NOTE: Actions to ensure radiation exposures in excess of administrative control levels are
      prevented are being controlled by means other than work document hold points and include the
      following:

             Use of alarming electronic pocket dosimeters (EPD) for all entries made into areas where
              the whole body dose rate exceeds 100 mrem/hr (all HRA entries), with the maximum
              integrated dose alarm set at 80% of the individuals remaining weekly or annual dose
              margin to the ACL or 100 mrem, whichever is more limiting (HNF-IP-0842, Volume 7,
              Section 13.6).

             Use of direct reading pocket dosimeters (DRD) for all entries into areas where the whole
              body dose rate exceeds 25 mrem/hr but is less than or equal to 100 mrem/hr
              (HNF-IP-0842, Volume 7, Section 13.6).

             Formal assignment of a Health Physics Technician(s) to provide direct, continuous
              coverage for activities requiring access to a work area dose rate >250 mrem in any one
              hour (TFC-ESHQ-RP_RWP-C-04).

      A.      Initial certification of containment tents and glove bags.

      B.      Verification of contamination levels prior to removing a glove bag from an installed
              component.

      C.      Actions taken to ensure airborne radioactivity levels do not exceed 10 times the
              applicable DAC values for radionuclides of concern in the work area.
 ESHQ                                      Document            TFC-ESHQ-RP_RWP-C-03, REV F-2
                                           Page                                       36 of 43
 ALARA WORK PLANNING                       Effective Date                    January 27, 2005

           ATTACHMENT A – HEALTH PHYSICS HOLD POINT CRITERIA (cont.)


      D.      Action to assess changing radiological conditions and ensure implementation of required
              controls when it is anticipated a changing condition could result in failure to meet the
              intended results of 1.A, B, and C.

      If there is a need for a health physics hold point other than those above, the health physics hold
      point needs to be cleared through the project RadCon manager.

3.0   RECOMMENDED HOLD POINT ACTION STATEMENTS

      To assist in defining the text associated with health physics hold point actions, the following
      general guidance is provided:

      NOTE: See TFC-OPS-MAINT-C-01 for hold point format.

      A.      Initial certification of containment.

              Place the following step either:

                     Immediately after the step for installation of a containment tent or glove bag, or
                     Immediately prior to beginning work inside of the containment tent or glove bag.

              Health physics technician perform initial certification of containment in accordance with
              attached certification checklist.

              _________________________ _________________________ __________
                     Printed Name               Signature            Date

      B.      Removing a containment from an installed component.

              Place the following step immediately prior to the step for removal of containment:

              Health physics technician verify contamination levels inside the containment are less
              than (insert appropriate value).

              _________________________ _________________________ __________
                    Printed Name                Signature            Date
ESHQ                                       Document             TFC-ESHQ-RP_RWP-C-03, REV F-2
                                           Page                                        37 of 43
ALARA WORK PLANNING                        Effective Date                     January 27, 2005

           ATTACHMENT A – HEALTH PHYSICS HOLD POINT CRITERIA (cont.)


    C.     Actions taken to ensure airborne radioactivity levels do not exceed 10 times the
           applicable DAC values for radionuclides of concern in the work area.

           Place the following statements immediately prior to steps that may result in airborne
           radioactivity levels exceeding 10 times the applicable DAC values in the work area if
           omitted or improperly performed:

                       CAUTION: Omission or improper performance of steps XXX through XXX
                       may (or is expected to, as appropriate) result in airborne radioactivity levels in
                       excess of 10 times the applicable DAC values in the work area.

           Health physics technician ensure that the following control(s) is(are) in place prior to
           performing steps XXX through XXX:

       _____        List control(s) used to ensure airborne radioactivity levels in excess of 10 times the
                    DAC values do not occur. Controls used to control airborne radioactivity include,
                    but are not limited to, items such as applying fixative prior to breaching
                    containment boundaries and performance of smoke testing to ensure direction of
                    ventilation flow.

               _________________________ _________________________ __________
                     Printed Name                Signature            Date

   D.      Verification of radiological controls.

           Incorporate the following statement(s) as needed to ensure anticipated radiological
           conditions are within the controlling values/limits/assumptions used when planning the
           work.

           Health physics technician perform a survey (dose rate, contamination, air sample as
           appropriate) to verify conditions are within (insert appropriate value) prior to continuing.

               _________________________ _________________________ __________
                     Printed Name                Signature            Date

               Health physics technician ensure that the following control(s) is(are) in place prior to
               performing steps XXX through XXX:


       _____        List control(s) used to ensure work is performed within the controlling values/limits/
                    assumptions used when planning the work.

               _________________________ _________________________ __________
                     Printed Name                Signature            Date
 ESHQ                                      Document           TFC-ESHQ-RP_RWP-C-03, REV F-2
                                           Page                                      38 of 43
 ALARA WORK PLANNING                       Effective Date                   January 27, 2005

                    ATTACHMENT B – APPROVED FIXATIVE SOLUTIONS


The following fixatives are approved for use:

NOTE: The use of fixative solutions that are not listed must be approved by Process Engineering.

1.      Safeguard (MSDS #20641)
2.      Encapsulation Technologies Glycerin Solution (MSDS #057158)
3.      ETGS Invisible Blue (MSDS #057802)
4.      Soil-Cement® (MSDS #035321)
5.      InstaCote®, Inc. (MSDS #060070 and #060071)
6.      Polymeric Barrier Systems (MSDS #032197)
7.      WT-HS13, High Strength Spray Adhesive (MSDS #062721)

        NOTE: InstaCote® use must meet requirements of:

               Process Control’s letter to M. D. Hasty, CHG, Compatibility Evaluation of InstaCote®
                ML-2 Soft Resin Part “B” Fixative for Use in Tank Farm Facilities, CL3120-00-011.

               DOE RLID 5480.7, “Limits on Flame Spread and Smoke Development for Building
                Interior Finishes.”

USQ determination 97-0769 was completed for use of InstaCote® at the 244-AR facility as described by
work package 2E-00-01669. The USQ must be revised or a new USQ issued for all future applications of
the above InstaCote® fixative.
 ESHQ                                        Document              TFC-ESHQ-RP_RWP-C-03, REV F-2
                                             Page                                         39 of 43
 ALARA WORK PLANNING                         Effective Date                      January 27, 2005

     ATTACHMENT C – DETERMINATION OF POTENTIAL AIRBORNE RADIOACTIVITY
                             CONCENTRATION


1.      Determine if air sample data is available from similar jobs performed in the past.

        a.      If historical data is available, proceed to step 2.
        b.      If historical data is unavailable, proceed to step 5.

2.      Convert the airborne radioactivity concentration to a derived air concentration (DAC) fraction.

3.      If the resultant airborne radioactivity concentration is >10% of a DAC (>0.1 DAC), respiratory
        protection is required.

4.      Document the method and results of the calculation of potential airborne radioactivity
        concentration on the ALARA Management Worksheet (AMW) (A-6003-121).

5.      When removable contamination values (representative of work surfaces) are available, estimate
        the airborne radioactivity concentration with the following equation:

        C = R Sc (4.5E-07 uCi/dpm)/CF

        Where: C = estimated workplace air concentration (uCi/cm3)
               R = resuspension factor (cm-1); see Table C-1 for values
               Sc = removable activity per unit area (dpm/cm2), except when using a cutting torch, the
               total activity per unit area must be used
               CF = confinement factor (unitless) from Table C-2. This factor takes into consideration
               whether the material is separated and confined while a worker is present or whether it is
               actually handled in the open.

                                    Table C-1. Resuspension Factor.

                     R, cm-1                    Work Description
                     1. E-08 Tours, hands-off inspections
                             Moderate activity, non-heat generating work, slow speed
                     1. E-07
                             mechanical cutting, maintenance
                             Vigorous work activity, such as sweeping, grinding,
                     1. E-06
                             flapper wheels, drilling
                     1. E-05 Cutting torch, welding, high pressure air
 ESHQ                                      Document             TFC-ESHQ-RP_RWP-C-03, REV F-2
                                           Page                                        40 of 43
 ALARA WORK PLANNING                       Effective Date                     January 27, 2005

     ATTACHMENT C – DETERMINATION OF POTENTIAL AIRBORNE RADIOACTIVITY
                           CONCENTRATION (cont.)


                                   Table C-2. Confinement Factor.

                                     Condition                          Factor
                   HEPA ventilated glove bag                             100
                   Glove bag without HEPA ventilation                     10
                   Clean wet rags on source of contamination,             10
                   keeping material wet
                   Ventilated hood, portable HEPA ventilation             10
                   (e.g., point source ventilation)
                   HEPA ventilated bullpen or environmental               10
                   barrier
                   Plastic covering on material                           10
                   Bullpen or environmental barrier, without               1
                   HEPA ventilation
                   Bench top or open work area                             1

6.      Document the method and results of the calculation of the potential airborne radioactivity
        concentration on the ALARA Management Worksheet (AMW) (A-6003-121).
 ESHQ                                      Document             TFC-ESHQ-RP_RWP-C-03, REV F-2
                                           Page                                        41 of 43
 ALARA WORK PLANNING                       Effective Date                     January 27, 2005

 ATTACHMENT D – WORK PRACTICE SURVEYS NOT REQUIRED TO BE SPECIFIED BY
                         WORK DOCUMENTS


This attachment lists examples of work practice surveys that are accomplished during work and are not
required to be specified by a work document. This list is not all-inclusive.

NOTE: ALL radiological surveys are required to be documented on a radiological survey report form, air
sample counter log, smear sample counter log, etc., as appropriate.

1.      CONTAMINATION SURVEYS incidental to:

              Decontamination.

              Maintaining contamination levels below established levels.

              Work on potentially contaminated systems or components (not expected to be
               contaminated) in radiological buffer areas or radiation areas (other than initial system
               entry surveys).

              Packaging and transporting radioactive material.

              Glove bag transfer sleeve operations, removing items from glove bags, and umbilical
               cuts.

              Removing items from radiological buffer areas established for contamination control,
               contamination areas, high contamination areas, or airborne radioactivity areas.

              Pre-work surveys supported by formalized process to validate expected contamination
               levels.

2.      AIRBORNE RADIOACTIVITY SURVEYS incidental to:

               Removal of respiratory protection equipment.

3.      RADIATION SURVEYS incidental to:

               Storing or moving radioactive material.

               Monitoring of installed poly bottles not related to movement of highly radioactive
                liquids.

               Monitoring of vacuum cleaners and associated debris collectors/in line filters not related
                to vacuuming of highly contaminated surfaces.

               Periodic monitoring of installed temporary shielding.

               Marking/tagging radioactive material.

               Pre-work surveys supported by formalized process to validate expected radiation levels.
 ESHQ                                      Document             TFC-ESHQ-RP_RWP-C-03, REV F-2
                                           Page                                        42 of 43
 ALARA WORK PLANNING                       Effective Date                     January 27, 2005

                      ATTACHMENT E – TYPE C MOCKUP GUIDELINES


Simulate actual field work conditions during conduct of mock-up training to the maximum extent
practicable.

a.     Pre-job briefings are held exactly as they would be on the actual job.

b.     Work document requirements are followed, as written, unless it is impractical to perform the
       work steps using the mockup. This includes taking actions required by radiological hold point
       steps.

c.     Stay times and pre-determined dosimeter readings are included in the training if they are
       established for any work steps. Extremity dosimetry are required and should be worn during
       training.

d.     If radioactive waste will be created during work, personnel are expected to minimize and handle
       the waste properly.

e.     Simulated radiation levels will be posted in the mockup to familiarize personnel with the actual
       levels in the work area. This can be accomplished by using radiological warning signs and/or
       “hot spot” labels. Radiological warning signs and labels shall be clearly marked, such as “For
       Training Purposes Only.”

f.     If liquids or wet waste will be encountered during the job, ensure the mock-up will contain water
       to simulate actual field conditions.

g.     Abnormal and/or casualty situations will be simulated to assess the actions taken by involved
       personnel.

h.     If workers do anything during the training that would result in either a gross spread of
       contamination, skin or clothing contamination, or excessive radiation exposure, training is
       stopped and the worker(s) briefed before continuing. If necessary, the worker(s) will be re-
       trained.
 ESHQ                                 Document           TFC-ESHQ-RP_RWP-C-03, REV F-2
                                      Page                                      43 of 43
 ALARA WORK PLANNING                  Effective Date                   January 27, 2005

         ATTACHMENT F – ALARA MANAGEMENT WORKSHEET PREPARATION


1.   A TFC ALARA Management Worksheet (A-6003-121) is initiated.

     NOTE: ALARA Management Worksheets are required as specified in Section 4.4 of this
     procedure.

2.   The next sequential ALARA Management Worksheet number is obtained from the ALARA
     Management Worksheet log located in the Health Physics Job Control Log on the computer
     shared network drive for RWPs and ALARA Management Worksheets (AMW). The ALARA
     Management Worksheet log contains:

            AMW number
            RWP number
            Work document number, when applicable
            RadCon Reviewers initials.

3.   The ALARA Management Worksheet file is created on the appropriate project drive and the
     ALARA Management Worksheet is saved using the number obtained from the AMW log.

				
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