DRC-2018-004077 - 0901a06880801d5b

Div of Waste Management
and Radlation Control
CLIVE SITE APR 2 7 2018
LETTER OF TRANSMITTAL
DRC-2D fa - 0 0+077
DATE: 04/26/2018
ATTN: Don Verbica — DWMRC
CC; Treesa Parker
Karen Kirkwood
RE: Transmittal 18015
Description of Documents Transmitted QtY
See attached for an update to Radiation Safety;
CL-RS-PG-002 Rev 17, Radiation Protection Program
Please replace your current procedure revisions with the documents with in this
Transmittal.
You are not required to sign any documents to verify receipt of this distribution.
However, you should make every effort to ensure that your copy of the License is
current.
FROM: EnergySolutions
Document Control
Clive Facility
C°Si8n
Dave Squires, G.M on behalf of the Radiation Safety
Committee
Concurrence:
Dave Squires
Apr 26 2018 8:22 AM
ENERGYSOLUTIONS CL-RS-PG-002
EnergySolutions'
Clive Facility
Radiation Protection Program
Dale Thorne Apr 24 2018 4:06 PM Author: cos18n
Dale Thorne, Lead, Health Physics / ARSO
Thomas Brown
,i2Aeuf,‘..„ Apr 26 2018 8:15 AM Approved By: C°Sen
Thomas A. Brown, Radiation Safety Officer (RSO)

Date: 4/23/18

Revision: 17
Electronic documents, once printed, are uncontrolled and may become outdated.
Refer to the Intranet or the Document Control authority for the correct revision.
EnergySolutions' Clive Facility CL-RS-PG-002
Radiation Protection Program Revision 17
Table of Contents
1 Radiation Safety Policy and Company Description 6
1.1 Clive Facility Radiation Protection Program 6
1.1.1 Purpose 6
1.1.2 Program Applicability and Control 6
1.1.3 Compliance 6
1.2 Clive Facility Summary 7
1.2.1 Site Description 7
1.2.2 Waste Licensing 7
1.3 Definitions 7
1.4 Responsibilities 9
1.4.1 General Manager of Clive 9
1.4.2 Radiation Safety Officer (RSO) 9
1.4.3 Lead, Health Physics / ARSO 9
1.4.4 Radiation Safety Technician(s) 9
1.4.5 Radiation Workers and Restricted Area Visitors 10
1.5 ALARA 11
2 Radiological Standards 11
2.1 Administrative Control and Dose Limits 11
2.1.1 Legal Dose Limits 11
2.1.2 Embryo/Fetus Dose Limits 11
2.1.3 Radiation Dose Limits for Individual Members of the Public 12
2.1.4 Planned Special Exposure 13
2.1.5 Administrative Control Limits 13
2.1.6 Minors 14
2.2 Contaminafion Control and Control Levels 14
2.2.1 Personnel Contamination Control 14
2.2.2 Contamination Control Levels 15
2.2.3 Unrestricted Release 16
2.2.4 Airborne Radioactivity Control 16
2.3 Posting 17
2.3.1 Posting Requirements 17
2.3.2 Exceptions to Posting Requirements 18
2.3.3 High Radiation Area Requirements 19
2.3.4 Very High Radiation Area Requirements 19
3 Conduct of Radiological Work 20
3.1 Planning Radiological Work 20
3.1.1 Requirements 20
3.1.2 Planning for Maintenance, Operations and Modifications 20
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3.2 Work Preparation 20
3.2.1. Radiation Work Permit 20
3.2.2 Use of Radiation Work Permits 21
3.2.3 Pre-Job Briefings 21
3.2.4 Personal Protective Clothing 21

3.3 Conduct of Radiological Work 23
3.3.1 Restricted Area Entry Requirements 23
3.3.2 Restricted Area Exit Requirements 23
3.3.3 Radiological Work Conduct and Practices 24
3.3.4 Stop Radiological Work Authority 25
3.3.5 Control of Bench Top Work, Laboratory Fume Hoods, and Sample Stations 25

3.4 Evaluation of Performance 25
4 Radioactive Materials 26

4.1 Radioactive Material Identification, Storage and Control 26
4.1.1 Radioactive Material Labeling 26
4.1.2 Radioactive Material Packaging 27
4.1.3 Radioactive Material Storage 27
4.1.4 Radioactive Material Disposal 28

4.2 Release, Receipt and Transportation of Radioactive Material 28
4.2.1 Release of Radioactive Material from Restricted Areas for Transport 28
4.2.2 Receiving and Opening Packages Containing Radioactive Material 30
4.2.3 U. S. Department of Transportation (DOT) Standards 31

4.3 Radioactive Source Control 31
4.3.1 Radioactive Source Controls 31

4.4 Support Activities 32
4.4.1 Personal Protective Equipment (PPE) 32
4.4.2 Equipment and Area Decontamination 32
4.4.3 Vacuum Cleaners and Portable Air-Handling Equipment 33
5 Radiation Safety Support Operations 33

5.1 External Dosimetry 33
5.1.1 Requirements 33
5.1.2 Dosimeter Loss 34
5.1.3 Electronic Dosimeters 35
5.1.4 Area Monitoring 35
5.1.5 Determination of Prior Occupational Dose 36
5.1.6 Visitors and Temporary Employees 37

5.2 Internal Dosimetry 37
5.2.1 Determination of Internal Dose 37
5.2.2 Committed Effective Dose Equivalent (CEDE) Calculation 39
5.2.3 Committed Dose Equivalent (CDE) Calculation 40
5.2.4 Calculation of Internal Dose from Intake through Wounds or Skin Absorption 41

5.3 Radiation Monitoring and Surveys 41
5.3.1 Requirements 41
5.3.2 Radiation Exposure Surveys 42
5.3.3 Contamination Surveys 43
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5.3.4 Airborne Radioactivity Monitoring 44
5.3.5 Bioassay Sampling 45
5.4 Respiratory Protection Program 46
5.4.1 Requirements 47
5.5 Handling Radiologically-Contaminated Personnel 48
5.5.1 Skin Contamination 48
5.5.2 Contaminated Wounds 49
5.5.3 Exposures to Airborne Radioactivity 49
5.6 Instrumentation and Calibration 50
5.6.1 Inspection, Calibration and Performance Tests 50
5.6.2 Maintenance 51
5.6.3 Calibration Facilities 51
6 Training and Qualifications 51
6.1 Visitor Orientation 51
6.1.1 Requirements 51
6.2 Radiation Worker Safety Training 52
6.2.1 Requirements 52
6.3 Radiation Safety Technician Training 53
6.3.1 Requirements 53
7 Radiological Records 53
7.1 Requirements 53
7.1.1 Purpose 54
7.1.2 Records Management Program 54
7.1.3 Record Keeping Standards 55
7.2 Employee Records 55
7.2.1 Personnel Radiation Safety Records 55
7.2.2 Planned Special Exposure Records 57
7.2.3 Medical Records 57
7.2.4 Radiation Safety Training and Qualification Records 58
7.2.5 Dosimetry Reports 59
7.3 Public Dose Records 59
7.3.1 Visitor Record Requirements 59
7.3.2 Member of the Public Dose Records 59
7.4 Radiation Safety Procedures 60
7.4.1 Policies, Procedures and Radiation Work Permits 60
7.4.2 ALARA Records 60
7.4.3 Quality Assurance Records 60
7.5 Radiation Surveys 60
7.5.1 Requirements 60
7.5.2 Radiation Surveys 60
7.5.3 Airborne Radioactivity 61
7.5.4 Contamination Surveys 61
7.6 Instrumentation and Calibration Records 61
7.6.1. Calibration and Operational Checks 61
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7.6.2 Special Calibration Records 62

7.7 Records Management 62

7.7.1 Form of Records 62

7.8 Reports 63

7.8.1 Reportable Events 63
8 References 65
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1 Radiation Safety Policy and Company Description
1.1 Clive Facility Radiation Protection Program
1.1.1 Purpose
The Radiation Protection Program (hereinafter referred to as "RPP" or
program) has been developed to establish Clive Facility requirements' to
receive, possess, process, use, transfer or dispose of licensed radioactive
material. The Clive Facility is committed to managing its operations
involving exposure to ionizing radiation and radioactive materials by
incorporating the philosophy that such doses should be "As Low As
Reasonably Achievable" (ALARA).
The RPP establishes the measures that Clive Facility management will use
to ensure that appropriate regulatory requirements and Clive Facility
policies, programs and procedures are met.
1.1.2 Program Applicability and Control
1.1.2.1 Clive Facility employees, escorted individuals, and
contractors shall meet the requirements of this program.
1.1.2.2 This program shall be reviewed each calendar year to
identify necessary changes as a result of changes in
regulations, lessons learned, and suggestions for
improvement. Changes shall be approved by the Clive
Radiation Safety Officer (RSO) who will verify that this
program remains consistent with the EnergySolutions '
Radiation Safety Program (ES-RS-PG-001), existing
permits, statutory and regulatory requirements, and U.S.
Nuclear Regulatory Commission (NRC) or State of Utah,
Division of Waste Management and Radiation Control
(DWMRC) directives. Deviation from this program
requires the written approval of the RSO.
1.1.2.3 The RSO may delegate in writing any or all of the work to
others. Responsibility, however, cannot be delegated. The
RSO, as applicable, retains responsibility for conformance
to radiation safety requirements for the delegated activity.
1.1.2.4 The RPP includes the Radiation Safety implementing
procedures and the ALARA Program.
1.1.3 Compliance
1.1.3.1 The word "shall" identifies those elements and
requirements that have been considered and found by Clive
management to be mandatory unless prior approval of an
alternative approach is obtained by the appropriate
regulatory agency and/or management.
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1.1.3.2 The use of "should" recognizes that there may be
situational attributes that warrant special treatment and
permits alterations to achieve the desired level of radiation
control performance.

1.1.3.3 The word "may" means Clive management has identified
an acceptable action but management is allowed to select
alternative methods.
1.2 Clive Facility Summary
1.2.1 Site Description
EnergySolutions is a nuclear services company with its corporate office
located at 299 South Main Street, 17th Floor, in Salt Lake City, Utah. The
Clive Facility is a radioactive/mixed waste treatment and disposal site at
Clive, Utah that is approximately three miles south of interstate 1-80 at
exit 49 in the western Utah desert.
1.2.2 Waste Licensing
The Clive Facility has two radioactive materials licenses for the disposal
of radioactive material. A license issued by the Utah Division of Waste
Management and Radiation Control (DWMRC) for disposal of Class A
Low Level Radioactive Waste (LLRW), Naturally Occurring Radioactive
Material or Accelerator-Produced Radioactive Material (NARM), source
material, special nuclear material, mixed waste (radioactive hazardous)
and 11e.(1) byproduct material. The second license is issued by the
DWMRC to permit the disposal of 1le.(2) byproduct material resulting
from the extraction of uranium or thorium from ore.
Permits from DWMRC as well as other regulatory agencies involved in
site operations include:
• DWMRC for hazardous waste treatment, storage, and disposal.
• The Utah Division of Water Quality for protection of ground
waters.
• The Utah Division of Air Quality to ensure precautions are taken
to minimize dust hazards.
1.3 Definitions
1.3.1 Access Control Points are designated areas established for normal
personnel and personal item entrance and egress from the restricted area.
1.3.2 Airborne radioactivity area means a room, enclosure, or area in which
airborne radioactive materials, composed wholly or partly of licensed
material, exist in concentrations-
• In excess of the derived air concentrations (DACs) specified in
appendix B, to 10 CFR 20 .1001-20.2401 or derived from values in
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ICRP 68. To such a degree that an individual present in the area
without respiratory protective equipment could exceed, during the
hours an individual is present in a week, an intake of 0.6 percent of
the annual limit on intake (ALI) or 12 DAC-hours.
1.3.3 Controlled area means an area, outside of a restricted area but inside the
site boundary. This is an area that Clive management can limit access for
any reason.
1.3.4 Individual Monitoring Devices means devices designed to be worn by a
single individual for the assessment of dose equivalent such as film
badges, thennoluminescent dosimeters (TLD'S) or equivalent, electronic
dosimeters and personal ("lapel") air sampling devices.
1.3.5 Personnel Contamination Event (PCE) means radioactive contamination,
above specified limits, on skin, hair or personnel clothing.
1.3.6 Restricted area (RA) is an area within the controlled area, access to which
is limited for the purpose of protecting individuals from undue risks from
exposure to radiation and radioactive materials. The restricted area
boundary is posted "Caution Radioactive Material" and is bordered by a 6-
foot high fence (minimum height 5'9").
1.3.7 Tissue weighting factor (WT), for an organ or tissue (T) is the proportion of
the risk of stochastic effects resulting from irradiation of that organ or
tissue to the total risk of stochastic effects when the whole body is
irradiated uniformly. For calculating the effective dose equivalent, the
values of wT. are from ICRP 68.
Weinhtinn factors for Various Tissues
Organs or tissues, T Weighting factor,
WT.
Gonads 0.20
Red bone marrow 0.12
Colon 0.12
Lungs 0.12
Stomach 0.12
Bladder 0.05
Breasts 0.05
Liver 0.05
Esophagus 0.05
Thyroid 0.05
Skin 0.01
Bones Surface 0.01
Remainder (a) 0.05
Whole body (b) 1.00
a. Remainder means the ten other organs or tissues with the highest
dose (e.g., muscle, brain, small intestine, uterus, kidney, spleen,
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thymus, adrenal, pancreas, extra thoracic airways). The weighting
factor for each remaining organ or tissue is 0.05.
b. For the case of uniform external irradiation of the whole body, a
weighting factor (WT) equal to 1 may be used in determination of
the effective dose equivalent.
Note: In addition to the definitions above, the Clive
Facility recognizes the regulatory definitions
contained in reference 8.14
1.4 Responsibilities
1.4.1 General Manager of Clive
The General Manager of Clive is responsible for ensuring that programs
and activities are consistent with safe operating practices and regulatory
requirements. This person has corporate authority to commit funds and
resources for the resolution of real and potential radiation safety problems.
1.4.2 Radiation Safety Officer (RSO)
The RSO or designee is responsible for:
• ensuring site compliance with RPP, radioactive license(s) and
other applicable regulatory requirements
• supervising the Site Radiation Safety personnel
• coordinating radiation protection related activities at the Site as
directed by the General Manager of Clive with oversight by the
Corporate Radiation Safety Officer
• directing Radiation Safety training.
• conducting site inspections at least weekly.
• monitoring occupational radiation exposure
9 ensuring Clive operations are conducted in a manner as to keep
radiation doses as low as reasonably achievable (ALARA).
1.4.3 Lead, Health Physics / ARSO
The ARSO or designee is responsible for:
• the implementation of the Radiation Protection Program.
1.4.4 Radiation Safety Technician(s)
Radiation Safety Technician(s) (RSTs) or equivalent is responsible for:
• ensuring personnel involved in activities in the restricted area
understand the applicable radiological hazards and appropriate
precautions needed to do their assigned task safely.
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• controlling the release of material/personnel from the Restricted
Area.
• Implementing and documenting compliance with requirements of
this program as they apply directly to Site operations.
• ensuring the routine application of ALARA practices.
• conducting air monitoring, radiation, and contamination surveys as
required by the radioactive material licenses and as needed to
determine occupational exposure.
1.4.5 Radiation Workers and Restricted Area Visitors
Radiation workers and restricted area visitors shall observe the following
rules:
FOLLOW
• Posted, written, and oral radiological control instructions, permits,
and procedures.
• "Evacuate" and "stop work" orders from Radiation Safety
personnel promptly.
• Follow ALARA practices as identified in training or directed by
Radiation Safety personnel.
DO NOT
• Loiter in radiation areas (Visitors are not allowed in radiation
areas).
• Smoke, eat, drink or chew in restricted areas, with the exception of
drinking from an "approved" screw-top container.
BE SURE TO
• Wear personnel monitoring devices where required by signs,
procedures or by Radiation Safety personnel. Report immediately
the loss, damage or unexpected exposure of personnel monitoring
devices to Radiation Safety.
• Keep track of your radiation dose status and avoid exceeding
Radiation Safety Administrative Control Levels.
• Wear Personal Protective Equipment (PPE) and clothing properly
when required by Radiation Work Permits or postings.
• Minimize the spread of potential radioactive spills and promptly
notify the appropriate personnel of all spills.
• Avoid contact of skin, clothing and equipment with contaminated
surfaces.
• Minimize the spread of contamination in contaminated areas.
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• Notify Radiation Safety personnel of alarming or faulty
radiological control equipment.
PRIOR TO ENTERING A RESTRICTED AREA
• Properly document your restricted area entry
• Assure that you are mentally alert and in physically sound
condition.
• Limit the amount of material taken into contaminated areas to
minimize radioactive waste and future decontamination.
UPON LEAVING THE RESTRICTED AREA
• Properly remove PPE to minimize the spread of contamination.
• Perform personal contamination survey.
• Properly document your restricted area exit
Site personnel having access to the restricted area are responsible for
understanding the applicable radiation safety hazards associated with their
work activities and to follow verbal, written, and posted radiation safety
requirements while in the Restricted Area.
1.5 ALARA
See CL-RS-PG-001, ALARA Program document
2 Radiological Standards
2.1 Administrative Control and Dose Limits
2.1.1 Legal Dose Limits
The occupational dose limits shall be controlled so the annual limits listed
in reference 8.14 are not exceeded.
2.1.2 Embryo/Fetus Dose Limits

2.1.2.1 The dose equivalent limit for the embryo/fetus from the
period of conception to birth, as a result of occupational
exposure of a declared pregnant worker, is 0.5 rem.

2.1.2.2 Substantial variation above a uniform dose rate that would
satisfy the limits provided in section 2.1.2.1 shall be
avoided.

2.1.2.3 The dose equivalent to the embryo/fetus shall be taken as
the sum of the deep- dose equivalent to the declared
pregnant woman and the dose to the embryo/fetus from
radionuclides in the declared pregnant woman.
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2.1.2.4 Females shall be informed of the regulations regarding
protection of the embryo/fetus prior to entering the
restricted area.

2.1.2.5 The woman who is pregnant or suspects she is pregnant is
responsible for declaring the pregnancy to initiate the dose
restrictions detailed in this section. The declaration with
the estimated date of conception shall be made in writing to
the RSO. Such a declaration shall not result in a change in
job status.

2.1.2.6 The dose restrictions for a person who has declared
pregnancy remains in effect until it is withdrawn in writing
or until the woman is no longer pregnant.

2.1.2.7 If the dose equivalent to the embryo/fetus exceeds 0.5 rem,
or is within 0.05 rem of this dose, by the time the woman
declares a pregnancy, Clive management shall be in
compliance with section 2.1.2.1 if the additional dose to the
embryo/fetus does not exceed 0.05 rem during the
remainder of the pregnancy.

2.1.2.8 Upon notification of pregnancy, the worker shall be
informed of the risks of anticipated radiation dose to the
embryo/fetus and efforts shall be made to avoid substantial
variation above a uniform monthly dose rate for the
remainder of the gestation period.
2.1.3 Radiation Dose Limits for Individual Members of the Public

2.1.3.1 The total effective dose equivalent (TEDE) to individual
members of the public from Clive facility operations shall
not exceed 0.1 rem in a year.

2.1.3.2 The dose in any unrestricted area from external sources
shall not exceed 0.002 rem in one hour.

2.1.3.3 Utah Radiation Control Board Executive Secretary
permission shall be obtained prior to exposing any member
of the general public to greater than the limits of section
2.1.3.1. The Utah Radiation Control Board Executive
Secretary may only grant permission to raise dose limits to
the general public to 0.5 rem in a year. The application for
permission shall include the following information:
• Demonstration of the need for and the expected
duration of operations in excess of the limit in
section 2.1.3.1;
• Clive Facilities' program to assess a control dose
within the 0.5 rem annual limit.
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• The procedures to be followed to maintain dose
ALARA.
2.1.3.4 Concentrations of radioactive material, which may be
released to the general environment in ground water,
surface water, air, soil, plants, or animals, must not result in
an annual dose exceeding an equivalent of 25 millirems to
the whole body, 75 millirems to the thyroid and 25
millirems to any other organ of any members of the public.
Reasonable effort should be made to maintain releases of
radioactivity to the environment as low as reasonably
achievable.
2.1.3.5 A constraint on air emissions of radioactive material to the
environment, excluding radon-222 and its daughters, shall
be established by the Clive Facility; such that, the
individual member of the public likely to receive the
highest dose will not be expected to receive a TEDE of 10
mrem (0.1 mSv).
2.1.3.6 The Clive Facility is authorized to use ALI, DAC and
Environmental Control Limit (ECL) values based on dose
coefficients adopted by ICRP Publication 68 and 72.
2.1.4 Planned Special Exposure
EnergySolutions does not anticipate authorizing planned special exposures
at the Clive facility. However, in exceptional situations, EnergySolutions
employees may receive doses (planned special exposures) separate from
and in addition to the annual occupational dose limits. All Planned Special
Exposures (PSE's) shall (1) receive prior written authorization from the
Business Group President and the Corporate Radiation Safety Officer and
(2) comply with all Federal or State regulations.
Note: Prior to participating in a planned special exposure an
individual's lifetime cumulative occupational dose
record shall be obtained.
2.1.5 Administrative Control Limits
• TEDE of 100 mrem per year if dose for the current year has not
been determined
• TEDE of 1,500 mrem per year
• Total Organ Dose Equivalent (TODE) of 15,000 mrem per year
• Eye (lens) dose equivalent (LDE) of 4,500 mrem per year
• Shallow dose equivalent (SDE) (skin or extremity) of 15,000 mrem
per year
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• Declared Pregnant Worker (DPW) 150 mrem for entire gestational
period
2.1.6 Minors
Minors shall not be granted access to EnergySolutions Restricted Areas.
2.2 Contamination Control and Control Levels
2.2.1 Personnel Contamination Control

2.2.1.1 Personnel exiting Restricted or Contamination Areas shall
monitor for personal radioactive contamination.

2.2.1.2 Monitoring for contamination should be performed using
frisking equipment that, under laboratory conditions, can
detect total contamination of at least the values specified in
Table 2-1, Acceptable Surface Contamination Levels. Use
of automatic monitoring units that meet the above
requirements is encouraged.
Table 2-1 Acce table Surface Contamination Levels
Nuclide' Averagew MaximumbAf Removable 13,e'f
U-nat, U-235, U-238, and
associated decay products
5,000 dpm
a1pha/100cm2
15,000 dpm
a1pha/100cm2
1,000 dpm alpha
/100cm2
Transuranics, Ra-226,
Ra-228, Th-230, Th-228, Pa-
231, Ac-227, 1-125,
I-129
100 dpm
/100cm2
300 dpm /100cm2 20 dpm /100cm2
Th-nat, Th-232, Sr-90,
Ra-223, Ra-224, U-232,
1-226, 1-131, 1-133
1,000 dpm
/100cm2
3,000 dpm
/100cm2
200 dpm /100cm2
Beta-gamma emitters
(nuclides with decay modes
other than alpha emission or
spontaneous fission) except
Sr-90 and others noted above.
5,000 dpm beta-
gamma
/100cm2
15,000 dpm beta-
gamma
/100cm2
1,000 dpm beta-gamma
/100cm2
Notes:
a. Where surface contamination by both alpha- and beta-gamma
emitting nuclides exist, the limits established for alpha- and beta-
gamma emitting nuclides should apply independently.
b. As used in this table, dpm (disintegrations per minute) means the rate
of emission by radioactive material as determined by correcting the
counts per minute observed by an appropriate detector for
background, efficiency and geometric factors associated with the
instrumentation.
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c. Measurements of average contaminant should not be averaged over
more than one square meter. For objects of less surface area, the
average should be derived for each such object.
d. The maximum contamination level applies to an area of not more
than 100 cm2.
e. The amount of removable radioactive material per 100 cm2 of surface
area should be determined by wiping the area with dry filter or soft
absorbent paper, applying moderate pressure, and assessing the
amount of radioactive material on the wipe with an appropriate
instrument of know efficiency. When removable contamination on
objects of less surface area is determined, the pertinent levels should
be reduced proportionally and the entire surface should be wiped.
f. The average and maximum radiation levels associated with surface
contamination resulting from beta-gamma emitters shall not exceed
0.2 mrem/hr at 1 cm and 1.0 mrem/hr at 1 cm, respectively.

2.2.1.3 Personal items, materials and personnel exiting the
Restricted Area are surveyed for both alpha and beta
emitting nuclides.
Alpha limits are less than 100 dpm/100 cm2 for skin,
clothing, materials, and surfaces; and less than 300
dpm/100 cm2 for the soles of shoes.
Beta limit is less than 1,000 dpm/100 cm2 skin, clothing,
materials, surfaces and the soles of shoes.
Other localized areas on personnel or items may be
released to the maximum limits specified in Table 2-1 as
approved by the RSO on a case by case basis and
documented in accordance with CL-RS-PR-115,
Radiological Surveys.

2.2.1.4 Skin or personal clothing shall promptly be decontaminated
and/or removed if radioactive contamination, from other
than noble gases or natural background radioactivity, is
found to exceed these limits.

2.2.1.5 Personnel shall be advised that any measurable
contamination on their person is excessive and the goal is
to keep such contamination below detectable levels.

2.2.1.6 Personnel Contamination Events (PCEs) shall be
documented and the CRSO shall be notified.
2.2.2 Contamination Control Levels

2.2.2.1 Areas having accessible surface contamination above the
limits listed in Table 2-2, Acceptable Surface
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Contamination Levels shall be posted as detailed in section
2.3.1.

2.2.2.2 Contamination in Restricted Areas shall be controlled to
minimize the potential for personal contamination and
elevated airborne radioactivity levels.
2.2.3 Unrestricted Release

2.2.3.1 Unrestricted release shall be used for all vehicles, materials
and equipment leaving the Restricted Area except where
release to Department of Transportation standards is
permitted as described in section 4.2.1.

2.2.3.2 Items surveyed for radioactive contamination shall be
sufficiently clean to allow an appropriate radiological
survey of the item. There shall be no material that will
mask or shield contamination.

2.2.3.3 The following requirements apply to equipment and
material released from Restricted or Airborne Radioactivity
Areas. Equipment or material from Restricted or Airborne
Radioactivity Areas shall be treated as radioactive material
and shall not be released for unrestricted use if either of the
following conditions exist:
• Measurements of accessible surfaces show that
either the total or removable contamination levels
exceed the values specified in Table 2-1,
Acceptable Surface Contamination Levels or
• Prior use indicates that the contamination levels on
inaccessible surfaces are likely to exceed the values
specified in Table 2-1, Acceptable Surface
Contamination Levels.

2.2.3.4 The records for release of equipment and material shall
include a description of the property, survey date, identity
of the individual who performed the survey, type and
identification number of the survey instrument used, date
the instrument calibration is due, and survey results.

2.2.3.5 The appropriate regulatory authority shall approve methods
used for the unrestricted release of contaminated soil, bulk
material, permeable material, or material with surfaces
which cannot be monitored.
2.2.4 Airborne Radioactivity Control

2.2.4.1 Engineering and administrative controls should be used to
reduce the potential for internal dose prior to allowing
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personnel with or without respiratory protection to enter
Airborne Radioactivity Areas.

2.2.4.2 Airborne radioactivity areas shall be used to identify those
areas requiring additional air monitoring and controls to
verify dose to personnel from airborne radioactivity.
2.3 Posting
2.3.1 Posting Requirements

2.3.1.1 Radiation Safety postings shall be used along with
procedures, Radiation Work Permits, training and job
briefings to alert personnel to the presence of radiation and
radioactive materials and to aid them in minimizing dose
and preventing the spread of contamination.

2.3.1.2 The criteria and posting requirements Table 2-2, Area
Posting Criteria shall be used to identify the specific
radiological hazards.
Table 2-2 Area Postin Criteria
AREA CRITERIA POSTING
Radiation Area An area where an individual may receive > 0.004
rem but <0.08 rem dose in 1 hour at 30 cm
"CAUTION,
RADIATION AREA"
High Radiation
Area
An area where an individual may receive > 0.08
rem but < 500 rad in 1 hour at 30 cm
"DANGER, HIGH
RADIATION AREA"
Very High
Radiation Area
An area where an individual may receive > 500 rad
in 1 hour at 1 m
"GRAVE DANGER,
VERY HIGH
RADIATION AREA"
Airborne
Radioactivity
Area
An area having airborne concenfrations > DAC
value(s) or where a person could receive >0.006 x
ALI (12 DAC-hours)(listed in appendix B to 10
CFR 20.1001-20.2401) during the hours a person
could be present in a week.
"CAUTION,
AIRBORNE
RADIOACTIVITY
AREA"
Areas or rooms
storing or using
license material
An area with > 10 times quantities listed in
appendix C to 10 CFR 20.1001-20.2401
"CAUTION,
RADIOACTIVE
MATERIAL(S) or
"DANGER,
RADIOACTIVE
MATERIAL(S)"
Contaminated
Area
An area where accessible loose surface
contamination levels are greater than 100 dpm/100
cm2 alpha or 1,000 dpm/100 cm2 beta-gamma
"CAUTION,
CONTAMINATED
AREA"
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Notes: Radiation Safety postings should be used to mark area perimeter and access
points, status current Radiation Safety requirements inside buildings or
permanent work areas, and identify special situational requirements.
Posting shall include a "Standard Radiation Symbol" colored magenta or
black on a yellow background. Lettering shall be either magenta or black.
Magenta is the preferred color.

2.3.1.3 Additional information may be included on or near signs
and labels beyond what is specifically identified in this
chapter to make individuals aware of potential radiation
dose and to minimize the exposure.

2.3.1.4 Postings shall:
• Be maintained in a legible condition and kept up to
date.
• Include all applicable wording if more than one
radiological condition (such as a restricted and
radiation area) exists.
• Include entry requirements at access control points
when access is not controlled by an Access Control
or Radiation Safety Technicians. (Entry
requirements may generally be referenced to using a
Radiation Work Permit (RWP).) i.e., "RWP
required for entry."
• Identify intermittent radiological conditions and
include a statement specifying when the conditions
are applicable.
• Remain visible when doors are open or closed.
• Be displayed only to signify actual or potential
radiological conditions. Signs used for training
shall be clearly marked, such as "For Training
Only."
Note: Specific hazards inside the Restricted
Area shall be controlled commensurate to
the magnitude of the hazard with relation
to the general area safety requirements.
2.3.2 Exceptions to Posting Requirements
2.3.2.1 The Clive Facility is not required to post caution signs in
areas or rooms controlled by Clive management which
contain radioactive materials for periods of less than 8
hours provided it is constantly attended by someone who
takes the precautions to prevent exposure of individuals to
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radiation or radioactive materials above the limits listed in
this manual; and

2.3.2.2 A room or area is not required to be posted with a caution
sign because of the presence of a sealed source provided
the radiation level at 30 cm from the surface of the source
container or housing does not exceed 0.005 rem per hour.
2.3.3 High Radiation Area Requirements

2.3.3.1 Each entrance and access point to a high radiation area
shall have one or more of the following features:
• A control device that, upon entry into the area,
causes the level of radiation to be reduced below
that level at which an individual might receive a
deep- dose equivalent of 0.08 rem in 1 hour at 30
centimeter from the radiation source or from any
surface that the radiation penetrates;
• A control device that energizes a conspicuous
visible or audible alarm signal so that the individual
entering the high radiation area and the supervisor
of the activity are made aware of the entry; or
• Entryways that are locked, except during periods
when access to the areas is required, with positive
control over each individual entry;
• Continuous direct or electronic surveillance that is
capable of preventing unauthorized entry; and
• Alternative methods to those listed above shall
require approval from the NRC or the DWMRC.

2.3.3.2 High Radiation Area controls shall be established in such a
way that it does not prevent individuals from leaving the
area.

2.3.3.3 Control is not required for each entrance or access point for
a room or other area that is a high radiation area solely
because of the presence of radioactive materials prepared
for transport and packaged and labeled in accordance with
the regulations of the Department of Transportation (DOT)
provided that the packages do not remain in the area longer
than 3 days and the dose rate at 1 meter from the surface of
any package does not exceed 0.01 rem per hour.
2.3.4 Very High Radiation Area Requirements

2.3.4.1 In addition to the requirements of Step 2.3.3, measures
shall be instituted to ensure that an individual is not able to
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gain unauthorized or inadvertent access to areas in which
radiation levels could be encountered at 5 Gy (500 rad) or
more in one hour at one meter from a source of radiation or
any surface through which the radiation penetrates.
3 Conduct of Radiological Work
3.1 Planning Radiological Work
3.1.1 Requirements
Technical requirements for the conduct of work, including construction
modifications, operations, and maintenance shall incorporate radiation
safety criteria to ensure safety and maintain radiation doses ALARA.
3.1.2 Planning for Maintenance, Operations and Modifications

3.1.2.1 Maintenance and modification plans and procedures shall
be reviewed to identify and incorporate radiation safety
requirements, such as engineering controls and dose and
contamination reduction considerations. Performance of
this review is the responsibility of the RSO.

3.1.2.2 Routine tasks where radiation safety restrictions have the
potential to change significantly or where ALARA requires
increased controls as determined by the RSO shall be
documented and controlled using Radiation Work Permits.
3.2 Work Preparation
3.2.1 Radiation Work Permit
The Radiation Work Permit (RWP) is an administrative mechanism used
to establish radiation safety controls for intended work activities. The
RWP informs workers of area radiological conditions and entry
requirements and provides a mechanism to relate worker exposure to
specific work activities. The RWP shall include the following information
where applicable:
• Description of work
• Work area radiation safety conditions
• Dosimetry requirements
• Pre-job briefing requirements
• Protective clothing and respiratory protection requirements
• Radiation Safety coverage requirements and stay time controls as
applicable
• Limiting radiological conditions that may void the RWP
• Special dose or contamination reduction considerations
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• Special personnel frisking considerations
• Date of issue and expiration
• Authorizing signatures
3.2.2 Use of Radiation Work Permits

3.2.2.1 A RWP shall be required for all work performed at the site
in a Radiological Control Area (RCA).
3.2.3 Pre-Job Briefings

3.2.3.1 Pre-job briefings shall be held as required by the Radiation
Work Permit.

3.2.3.2 At a minimum, pre-job briefings shall include current
condition, radiation safety hazards and the required
radiation safety controls.
3.2.4 Personal Protective Clothing

3.2.4.1 Protective clothing is not a substitute for engineering and
administrative controls. Care shall be used to minimize the
potential for personal contamination. Some of these
practices include:
• Avoid touching face or other areas of the body not
protected by protective clothing with gloves or
other objects which may be radioactively
contaminated.
• Replace protective clothing immediately if it tears
or breaks down and no longer provides adequate
protection.
• Minimize contact with radioactive material. Avoid
kneeling, sitting, or lying on contaminated surfaces
or spreading contamination from gloves or shoes to
other areas.

3.2.4.2 Personnel shall wear protective clothing while inside
airborne radioactivity areas and areas with a reasonable
potential of being exposed to contamination levels greater
than the values listed in Table 2-1, Acceptable Surface
Contamination Levels. Radiation Safety shall establish the
type and amount of protective clothing required for a
specific job or area.
3.2.4.3 Protective clothing dress-out areas shall be established in
close proximity to the Restricted Area Access Control
Points.
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3.2.4.4 Protective clothing shall be compatible and constructed so
that it maintains its integrity during its selected use.

3.2.4.5 Coverall openings shall be taped or have elastic embedded
in the openings when there is a reasonable potential for
radioactive contamination of the skin through these
openings. Potential for radioactive contamination of the
skin will be based on an evaluation by Radiation Safety
management that will include a review of radionuclide
concentration levels (isotopic distribution) as well as the
physical form of the waste. Waste shipments that have the
potential to generate high alpha or beta contamination will
be flagged for special waste handling due to the potential
for contamination of the skin during waste handling
operations. When shipments are flagged, notifications will
be made to the field Radiation Safety personal for special
handling requirements when shipments create a reasonable
potential for contamination of the skin.

3.2.4.6 Industrial Hygiene and Safety concerns shall be considered
in addition to those of Radiation Safety when deciding on
PPE requirements.

3.2.4.7 The following is only to be used as general guidance
because of varying PPE requirements. Whatever method is
used, PPE must be worn properly to provide the proper
protection and removed in such a way as to minimize
personal and area contamination.

3.2.4.8 PPE Donning Sequence (Don applicable items in the
listed sequence.)
• Boot liners
• Glove liners
• Anti-C coveralls
• Exterior Gloves
• Tape Openings (as required by situation)
• Exterior boots
• Respirator
3.2.4.9 PPE Doffing sequence (Remove applicable items in
the listed sequence)
• Exterior boots
• Respirator
• Tape
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• Exterior Gloves
• Anti-C Coveralls
• Boot liners
• Glove liners
3.3 Conduct of Radiological Work
3.3.1 Restricted Area Entry Requirements
3.3.1.1 Personnel entry control shall be maintained for the
Restricted Area. A security guard or other qualified person
shall be stationed whenever personnel are inside the
Restricted Area.
3.3.1.2 The degree of control shall be commensurate with existing
or potential radiation safety hazards within the area.
3.3.1.3 One or more of the following methods shall be used to
ensure access control:
• Signs and barricades;
• Control devices on entrance;
• Conspicuous visual or audible alarms;
• Locked entrance ways; or
• Administrative controls.
3.3.1.4 Access is limited to qualified persons on official business.
3.3.1.5 The access control gate must be locked or controlled by a
designated person meeting required certification
requirements.
3.3.1.6 Prior to entry, visitors shall receive Visitor Orientation
(section 6.2.1) and be escorted by a certified Radiation
Worker when in the Restricted Area. (Visitor training is
restricted to Radiation Safety requirements and does not
replace other training that may be required.)
3.3.2 Restricted Area Exit Requirements
3.3.2.1 Personnel shall remove PPE and protective equipment
according to the requirements of Section 3.2.4 and the
Safety & Health Manual.
3.3.2.2 Personnel shall be monitored and meet the release
standards of Column 2 in Table 2-1, Acceptable Surface
Contamination Levels.
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3.3.2.3 Personal items, such as notebooks, papers and flashlights,
shall be subject to the same Restricted Area and Airborne
Radioactivity Area exit requirements.

3.3.2.4 RSTs shall determine if alarms of Personnel Contamination
Monitors legitimately represent personnel contamination
through evaluation of alarm level, frisking, and visual
inspection.

3.3.2.5 Persons found to be radioactively contaminated above
release limits shall be surveyed by qualified Radiation
Safety personnel. The washing or otherwise
decontamination of affected areas shall be done under the
supervision of qualified Radiation Safety personnel. The
RSO permission is required for the exit of personnel
contaminated above the release limits.

3.3.2.6 Process out via HIS-20 or access control software and
ensure dosimeter information is recorded into the computer
system and the dosimeter is available for reuse.
3.3.3 Radiological Work Conduct and Practices

3.3.3.1 Radiological work practices shall be conducted as specified
by the specific work procedure and Radiation Work Permit.

3.3.3.2 Radiation safety requirements shall be determined with
concern for the use of sound engineering and safety
practices.

3.3.3.3 Contamination levels caused by ongoing work shall be
monitored and maintained ALARA. Work should be
curtailed and decontamination performed at pre-established
levels, taking into account worker dose.

3.3.3.4 Tools and equipment should be inspected to verify
operability before being brought into the restricted area.

3.3.3.5 Where practical, parts and components should be removed
to areas with low dose rates to perform work.

3.3.3.6 Upon identification of radiation safety concerns, such as
inappropriate work controls or procedural deficiencies,
workers should immediately report the concern to their
supervisor or someone in the Radiation Safety organization.

3.3.3.7 To minimize intakes of radioactive material by personnel;
smoking, eating, or chewing shall not be permitted in
Restricted Areas. (Drinking fluids for purposes of
hydrating is permitted when approved by the RSO and it is
done from an approved (screw-topped container).
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3.3.3.8 Time spent in the restricted area should be limited to
necessary activities.
3.3.3.9 Required protective equipment will be worn correctly for
the entire time it is required.
3.3.3.10 Access requirements during an emergency may be waived,
as common sense directs, to perform emergency response
actions.
3.3.3.11 Escorts shall accompany and ensure the safety of persons
they are assigned to escort until they have exited the
Restricted Area.
3.3.3.12 Radioactive contamination shall be controlled inside the
Restricted Area to prevent the contamination of personnel.
3.3.4 Stop Radiological Work Authority
Any Clive Facility employee or employee of a Clive Facility contractor
has the authority and responsibility to stop radiological work activities if
radiation safety controls are not being adequately applied to ensure safe
operations (provided stopping work does not create an additional hazard).
The RSO shall determine the correct course of action prior to resuming the
activity. If the corrective actions are not satisfactory, the individuals
involved may submit in writing to the General Manager of Clive, a
detailed description of the situation with suggested corrective actions.
3.3.5 Control of Bench Top Work, Laboratory Fume Hoods, and Sample
Stations
3.3.5.1 Work shall be controlled through the use of a procedure or
RWP.

3.3.5.2 Protective clothing shall, at a minimum, include lab coats
and gloves. Gloves shall be secured at the wrist, as
necessary.

3.3.5.3 If there is a potential for splashing or airborne radioactivity,
additional controls such as a rubber apron, face shield, full
PPE, and/or respirator should be instituted, as appropriate.

3.3.5.4 Shoe covers should be considered based on the potential for
floor contamination.

3.3.5.5 Upon completion of work or prior to leaving the area,
workers shall monitor those areas of their body that are
potentially contaminated. At a minimum, this includes
hands and feet.
3.4 Evaluation of Performance
During the conduct of radiological work and the handling of radioactive materials,
abnormal events may occur which could indicate a weakness or area of
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programmatic breakdown of radiation safety controls. Prompt, consistent
gathering of facts related to such events is required to satisfy reporting and
investigation requirements and to formulate corrective actions to prevent
recurrence. This process shall be documented in a Condition Report (CR). In
addition, successful performance or completion of unique activities should be
evaluated to identify and incorporate appropriate lessons learned.
Refer to the "EnergySolutions Quality Assurance Manual" for the requirements
used to evaluate performance.
4 Radioactive Materials
4.1 Radioactive Material Identification, Storage and Control
Radioactive material is any material, equipment, or system component determined
to contain or be contaminated with radionuclides. Items located in a restricted or
airborne radioactivity area or otherwise having reasonable potential to become
contaminated are considered radioactive materials. Radioactive material also
includes activated material, sealed and unsealed radioactive sources and materials
that emit radiation.
4.1.1 Radioactive Material Labeling
4.1.1.1 Containers of licensed material (excluding waste
shipments) shall have a durable clearly visible label bearing
a radiation symbol and the appropriate wording as detailed
in Table 4-1, Labeling Requirements for Radioactive
Material (unless comply with special exemptions). The
label shall also provide sufficient information (such as the
radionuclide(s) present, the date for which the activity is
estimated, radiation levels, kinds of materials, and mass
enrichment) to permit individuals handling or using the
containers or working in the vicinity of the containers to
take precautions to avoid or minimize exposure.
Table 4-1 Labeling Re uirements for Radioactive Material
ITEM/MATERIAL REQUIRED LABELING
Equipment, components and other items
that are radioactive, potentially radioactive
or have been exposed to radioactive
contamination or activation sources
"CAUTION, RADIOACTIVE MATERIAL"
Sealed and unsealed radioactive sources or
associated storage containers
"CAUTION,RADIOACTIVE MATERIAL"
or standard radiation symbol
Equipment, components and other items
with actual or potential internal
contamination
"CAUTION, INTERNAL
CONTAMINATION" or "CAUTION,
POTENTIAL INTERNAL
CONTAMINATION"
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Components, equipment or other items with
fixed contamination "CAUTION, FIXED CONTAMINATION"
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4.1.1.2 Prior to removal or disposal of empty uncontaminated
containers from a restricted area the label shall be removed,
defaced, or clearly indicated that the container no longer
contains radioactive materials.
4.1.2 Radioactive Material Packaging
4.1.2.1 Radioactive material outside restricted or airborne
radioactivity areas which is confirmed or suspected of
having removable radioactive contamination levels greater
than Table 2-1, Acceptable Surface Contamination Levels
shall be securely wrapped in plastic (preferably yellow) or
placed in a container. Note: Yellow plastic should not be
used for non-radiological purposes.
4.1.2.2 Radioactive material with sharp edges or projections should
be taped or additionally protected to ensure package
integrity.
4.1.3 Radioactive Material Storage
4.1.3.1 Radioactive material that is outside restricted or airborne
radioactivity areas shall be stored in a designated
radioactive material storage area.
4.1.3.2 Licensed material stored in controlled areas shall be
secured from unauthorized removal or access.
4.1.3.3 Licensed material inside a controlled area but not in a
radioactive material storage area shall be maintained under
constant surveillance and control.
4.1.3.4 Decontamination or disposal of radioactive material is the
preferred alternative to long-term storage.
4.1.3.5 Each Radioactive Material Storage Area shall be approved
by the RSO.
4.1.3.6 A custodian should be assigned responsibility for each
Radioactive Material Storage Area. A custodian may have
responsibility for more than one storage area.
4.1.3.7 The custodian shall conduct annual or more frequent
reviews of each radioactive material storage area, with
emphasis on contamination levels, area conditions, long-
term storage, and disposal.
4.1.3.8 Storage of non-radioactive material in radioactive material
storage areas is discouraged.
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4.1.3.9 Radioactive material storage methods should be in a
manner that reduces combustible loading, controls potential
chemical incompatibilities and conforms with conventional
safety requirements for storage.
4.1.4 Radioactive Material Disposal
Refer to Energysolutions' operating permits/licenses for the requirements
and methods used to dispose of radioactive material.

4.1.4.1 Each person involved in the transfer of waste for disposal
or in the disposal of waste, including the generator, waste
collector, waste processor and waste disposal facility
operator, shall comply with the requirements specified in
Appendix G, 10 CFR 20, as appropriate.
4.2 Release, Receipt and Transportation of Radioactive Material
4.2.1 Release of Radioactive Material from Restricted Areas for Transport
Prior to each shipment of licensed material it shall be determined that:

4.2.1.1 The package is proper for the contents to be shipped;

4.2.1.2 The package is in unimpaired physical condition except for
superficial defects such as marks or dents;

4.2.1.3 Each closure device of the packaging, including any
required gasket, is properly installed and secured and free
of defects;

4.2.1.4 Any system for containing liquid is adequately sealed and
has adequate space or other specified provision for
expansion of the liquid;

4.2.1.5 Any pressure relief device is portable and set in accordance
with written procedures;

4.2.1.6 Any structural part of the package which could be used to
lift or tie down the package during transport is rendered
inoperable for that purpose unless it satisfies design
requirements specified by the manufacturer;

4.2.1.7 Removable surface contamination does not exceed Table 4-
2, Removable External Contamination Wipe Limits;
Table 4-2 Removable External Radioactive Contamination Wi e Limits
Contaminant
Maximum permissible
µCi/cm2
limits
dpm/cm2 Bq/cm2
1. Beta and gamma emitters and low toxicity alpha emitters 4 10-4 240
2. All other alpha emitting radionuclides 0.4 10-5 24
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4.2.1.8 External radiation levels do not exceed 200 millirem on any
point on the exterior surface of the package and 10 millirem
at 1 meter from the exterior of the package; or

4.2.1.9 For a package transported in exclusive use by rail, highway
or water, radiation levels may not exceed any of the
following:
• 200 millirem on any point on the exterior surface of
the package unless the following conditions are met,
in which case the limit is 1,000 millirem per hour.
o the shipment is made in a closed transport
vehicle,
o provisions are made to secure the packages
so that its position within the vehicle
remains fixed during transportation, and
o there are no loading or unloading operations
between the beginning and end of the
transportation:
• 200 millirem per hour at any point on the outer
surface of the vehicle including the upper and lower
surfaces, or in the case of a flat-bed style vehicle,
with a personnel barrier at any point on the vertical
planes projected from the outer edges of the vehicle
on the upper surface of the load, or enclosure if
used and on the lower external surface of the
vehicle. A flatbed style vehicle with a personnel
barrier shall have radiation levels determined at
vertical planes. If there is no personnel barrier, the
package cannot exceed 200 millirem per hour at the
surface;
• 10 millirem per hour at any point 2 meters from the
vertical planes represented by the outer lateral
surfaces of the vehicle, or in the case of a flat-bed
style vehicle, at any point two meters from the
vertical planes projected from the outer edges of the
vehicle; and
• 2 millirem per hour in any normally occupied space,
except that this provision does not apply to carriers
if they operate under the provisions of a State or
federally-regulated radiation protection program
and if personnel under their control who are in such
an occupied space wear radiation dosimetry
devices.
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4.2.1.10 Records for the release of radioactive materials from the
Restricted Area shall include, survey date, identity of the
person who performed the survey, identification number
and model number of the survey instrument, date the
instrument calibration is due, and survey results.
4.2.2 Receiving and Opening Packages Containing Radioactive Material

4.2.2.1 Upon arrival, the external surface of each package shall be
monitored for radioactive contamination and radiation
levels if the package:
• Is labeled as containing radioactive material; or
• Has evidence of potential contamination, such as
packages that are crushed, wet, or damaged.

4.2.2.2 Monitoring required in section 4.2.2.1 shall be required as
soon as practical after arrival, but no more than 3 hours
later if it arrives during normal working hours, or not later
than 3 hours from the beginning of the next working day if
it arrives after working hours.

4.2.2.3 As applicable, the fmal delivery carrier, the DWMRC and
the NRC, shall be notified when removable contamination
or external radiation levels exceed limits contained in
sections 4.2.1.7, 4.2.1.8, and 4.2.1.9.
Note: In the case of packages transported as
exclusive use shipments by rail or
highway only the removable radioactive
contamination at any time during
transport shall not exceed ten times the
level prescribed in Table 4-2, Removable
External Contamination Wipe Limits.
The levels at the beginning of transport
shall not exceed the levels in Table 4-2,
Removable External Contamination Wipe
Limits.
Note: Special form sources being transferred in
EnergySolutions-owned or operated
vehicles to and from the work site are
exempt from radioactive contamination
requirements but not radiation
measurement requirements to ensure the
source is properly lodged in its shield.
4.2.2.4 Written procedures to safely open packages in which
radioactive material is received shall be established,
maintained, and retained. Clive management shall ensure
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these procedures are followed and provide special
instructions for the type of package being opened.

4.2.2.5 When Clive management expects to receive a package
containing quantities of radioactive material in excess of a
Type A quantity, as defined in Section R313-19-100, Clive
management shall make arrangements to receive:
• The package when the carrier offers it for delivery;
or
• The notification of the arrival of the package at the
carrier's terminal and to take possession of the
package expeditiously.
4.2.3 U. S. Department of Transportation (DOT) Standards
Radioactive material shipments shall meet DOT standards for marking,
labeling, and placarding. Radioactive material shipments shall also meet
the following radiological requirements:

4.2.3.1 Conveyances used for the transporting of radioactive
materials shall meet the radiological requirements of 49
CFR 173.443(c) prior to being returned to Class 7
(radioactive) materials exclusive use transport service.

4.2.3.2 Vehicles used solely to transport radioactive material shall
meet the requirements contained in 49 CFR 177.843(b) (49
CFR 174.715(b) for rail shipments) prior to shipping.
4.3 Radioactive Source Control
4.3.1 Radioactive Source Controls

4.3.1.1 The source, source container, or device components
containing sources shall be labeled. The labels shall consist
of a magenta or black "Standard Radiation Symbol" on a
yellow background, the source serial number, the name of
the radionuclide, radioactivity, and the date of assay. The
source at a minimum shall be labeled with its serial number
and the name of its radionuclide.

4.3.1.2 Radiation Safety shall maintain accountability records of
all radioactive sources.

4.3.1.3 A source custodian shall be appointed to maintain
radioactive source controls.

4.3.1.4 Radioactive sources shall only be stored in licensed
radioactive material storage areas and transported in their
containers or shall have an encumbering device attached to
prevent inadvertent loss.
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4.3.1.5 The RSO shall approve changes in use, storage, transfer,
and disposal of radioactive sources.

4.3.1.6 The RSO shall ensure that the required actions are done in
the case of the loss of a sealed source.

4.3.1.7 Leak test shall be done on sealed sources as required by
EnergySolutions' radioactive material licenses.

4.3.1.8 The RSO shall be responsible for the procurement of all
new radiological sources.
4.4 Support Activities
4.4.1 Personal Protective Equipment (PPE)

4.4.1.1 Personal Protective Equipment and laundered protective
clothing shall be inspected prior to use. Clothing shall be
free of tears, separated seams, deterioration and damage, or
repaired in manner that provides the original level of
protection.

4.4.1.2 PPE shall:
• provide adequate protection against the particular
radiological hazard for which they are designed.
• shall fit properly and shall not unduly interfere with
the movements of the wearer.
• be durable enough to withstand anticipated use.
• shall meet the requirements of the Safety & Health
Manual
4.4.2 Equipment and Area Decontamination

4.4.2.1 Procedures shall include consideration of the handling,
temporary storage and decontamination of material, tools
and equipment.

4.4.2.2 Decontamination activities shall be controlled to prevent
the spread of contamination.

4.4.2.3 If wet cleaning is necessary, water and steam are the
preferred decontamination agents. Other cleaning agents
should be selected based upon their effectiveness,
hazardous properties, amount of waste generated and ease
of disposal.

4.4.2.4 Decontamination methods should be used to reduce the
number of contaminated areas.
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4.4.2.5 Efforts should be made to reduce the level of contamination
and the number and size of contaminated areas that cannot
be eliminated.

4.4.2.6 The RSO shall be responsible for directing
decontamination efforts.
4.4.3 Vacuum Cleaners and Portable Air-Handling Equipment

4.4.3.1 The RSO permission is required to use vacuum cleaners or
portable air-handling equipment inside the Restricted Area
or for the cleanup of radioactive debris.

4,4.3.2 High-Efficiency Particulate Air (HEPA) filter equipment
shall be used when it is determined a reasonable potential
exists for the use of non-HEPA equipment to result in
airborne personnel dose to concentrations greater than 0.3
DAC.

4.4.3.3 If it is determined that HEPA air handling devices are
required, these devices shall:
• Be uniquely marked and labeled.
• Designed to prevent accidental access to the inner
surfaces of the vacuum.
• Shall be used within the operating criteria
established by the manufacturer.
• Shall not be used to clean up water or wet debris.
5 Radiation Safety Support Operations
5.1 External Dosimetry
5.1.1 Requirements
5.1.1.1 Exposures to radiation and radioactive material shall be
monitored at levels sufficient to demonstrate compliance
with the dose limits listed in Section 2.1. As a minimum,
personal monitoring devices shall be supplied and required
for use by:
• Adults likely to receive in one year from sources
external to the body radiation dose exceeding 10%
of the legal limit (section 2.1.1),
• Declared pregnant women and minors likely to
receive, in one year a dose in excess of 10 percent
of the applicable limits listed in section 2.1.2 and
2.1.6.
• Individuals entering high radiation areas.
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5.1.1.2 Clive employees and contractor employees requiring
routine access to the Restricted Area shall be issued a
personal record dosimeter which must be worn while in the
Restricted Area or while working around radioactive
material outside the Restricted Area.

5.1.1.3 Record dosimeter used shall be capable of measuring the
shallow dose equivalent (SDE), the lens dose equivalent
(LDE), and the deep dose equivalent (DDE).

5.1.1.4 When determining the dose from airborne radioactive
material, include the contribution to the deep dose
equivalent, eye dose equivalent and shallow dose
equivalent from external dose to the radioactive cloud.

5.1.1.5 Record dosimeter processing shall be done by a dosimetry
processor holding accreditation from the National
Voluntary Laboratory Accreditation Program (NVLAP)
and approved in this accreditation process for the type of
radiation or radiations for which the individual wearing the
dosimeter is monitored.

5.1.1.6 Radiation Safety training is required prior to the issuance of
record dosimeters. Record dosimeters shall only be worn
by the person to whom they were issued.

5.1.1.7 The record dosimeter used to monitor whole body dose
shall be worn in an area around the chest, or between the
waist and the neck, in the manner prescribed by dosimetry
personnel or Radiation Safety Technicians to correlate with
the maximum area of dose.

5.1.1.8 Dosimeters shall not be worn or taken off-site unless
specifically authorized by the RSO.

5.1.1.9 Personnel shall not be issued more than one record
dosimeter at a time to measure whole body dose from Clive
operations.

5.1.1.10 Personnel shall not expose their record dosimeter to
security x-ray devices, excessive heat, medical sources of
radiation, or other specific non-occupational sources of
radiation.

5.1.1.11 The dosimeter exchange should be on the first of each
quarter but may vary by 10 days as needed to coordinate
with Site activities.
5.1.2 Dosimeter Loss
Upon the loss of a record dosimeter:
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• If in a restricted area, immediately leave the area.
• Notify the supervisor and the RSO
• Record the loss.
• Attempt to locate the lost record dosimeter.
• A dose estimate shall be made for the period covered by the lost
record dosimeter using appropriate information e.g. past dose
history, work history, survey information, and associated worker
dose information.
5.1.3 Electronic Dosimeters
Electronic Dosimeters may be used to provide a real-time indication of
radiation dose and assist in maintaining personnel doses less than the
Administrative Control Levels. Dosimeters may also be used to monitor
visitors who do not require a record dosimeter (see section 5.1.1.1).

5.1.3.1 Electronic Dosimeters shall be issued to personnel prior to
entry into the Restricted Area, according to ALARA
Program requirements.

5.1.3.2 Electronic Dosimeters should be set at the dose limit of the
RWP under which the Restricted Area entry is being made.

5.1.3.3 Electronic Dosimeters shall be read periodically and shall
not be permitted to receive more than 75 percent of the
allowable dose.

5.1.3.4 Routine work on a Radiation Work Permit shall be stopped
when electronic dosimeter readings indicate total dose or
rate of dose exceeding the RWP's limits. The RSO shall be
consulted prior to continuation of work.

5.1.3.5 Electronic Dosimeters shall be processed into the dosimetry
database prior to entry and upon exiting the Restricted
Area.
5.1.4 Area Monitoring
Area monitoring shall be adequate to show compliance with the dose
limits detailed in section 2.1.3. Compliance with this requirement shall be
shown by:

5.1.4.1 Demonstrating the total effective dose equivalent to the
individual likely to receive the highest dose from Clive
operations does not exceed the annual dose limit; and

5.1.4.2 Concentrations of radioactive which may be released to the
general environment in ground water, surface water, air,
soil, plants or animals shall not result in an annual dose
exceeding an equivalent of 25 millirem (0.25 mSv) to the
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whole body, 75 millirem (0.75 mSv) to the thyroid, and 25
millirem (0.25 mSV) to any organ of any member of the
public. Reasonable efforts should be made to maintain
releases of radioactivity in effluents to the general
environment as low as reasonably achievable; and

5.1.4.3 The dose from external sources to an individual who if
continually present in an unrestricted area, would not
exceed 0.002 rem in one hour.
5.1.5 Determination of Prior Occupational Dose

5.1.5.1 Where it is determined that a person has the likely potential
or where a person may have received occupational dose
greater than those values listed in section 5.1.1, Clive
management shall determine the occupational radiation
dose received during the current year. To comply with
these requirements Clive management may:
• Accept, as a record of the occupational dose that the
individual received during the current year, a
written signed statement from the individual, or
from the individual's most recent employer for work
involving radiation dose, that discloses the nature
and the amount of any occupational dose that the
individual may have received during the current
year;
• Obtain reports of the individual's dose equivalent(s)
from the most recent employer for work involving
radiation dose or the individual's current employer
(if the individual is not employed by
EnergySolutions) by telephone, telegram, electronic
media, or letter. A written verification of the dose
data shall be required if the authenticity of the
transmitted report cannot be established.

5.1.5.2 The record of dose history for the current year required by
section 5.1.5.1 shall be recorded on NRC Form 4, or other
clear and legible records containing all the information
required by Form 4. The form or record must show each
period during the year in which the individual received
occupational dose to radiation or radioactive material and
must be signed by the individual who received the dose.

5.1.5.3 If Clive management is unable to obtain an individual's
current occupational dose, Clive management shall control
occupational dose to a:
• TEDE of 100 mrem (1.0 mSv) per year
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5.1.6 Visitors
5.1.6.1 Visitors who have the potential to receive greater than 10
mrem TEDE during a quarter shall use an electronic
dosimeter to verify dose.
5.1.6.2 All doses, including zero, shall be documented for entry in
the person's dose record.
5.2 Internal Dosimetry
5.2.1 Determination of Internal Dose
Note: The Clive Facility is authorized to use ALI, DAC and
ECL values based on dose coefficients adopted by ICRP
Publication 68 and 72.
5.2.1.1 Exposures to radiation and radioactive material shall be
monitored at levels sufficient to demonstrate compliance
with the dose limits listed in Section 2.1. As a minimum,
the occupational intake of radioactive material shall be
monitored and the CEDE assessed to:
• Adults likely to receive in one year an intake in
excess of 10 percent of the applicable ALI(s) found
in table 1, Columns 1 and 2 of appendix B to 10
CFR 20.1001-20.2401; and
• Minors or declared pregnant women when the
CEDE is likely to exceed 0.1 rem.
5.2.1.2 If the only intake of radionuclides is by inhalation, the total
effective dose equivalent limit is not exceeded if:
EDE + D, =1 TE'DEL
where:
EDE = Effective dose equivalent.
TEDEL = Total effective dose equivalent limit as listed in
Section 2.1.
DL = One of the following:
• The sum of the fractions of the inhalation ALI for
each radionuclide, or
• The total number of derived air concentration-hours
(DAC-hours) for all radionuclides divided by 2,000,
or
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• The sum of the calculated committed effective dose
equivalents to all significantly irradiated organs or
tissues calculated from bioassay data using
appropriate biological models and expressed as a
fraction of the annual limit of 50 rem.
5.2.1.3 For the purpose of determining dose suitable and timely
measurements shall be taken of:
• Airborne radioactivity concentrations in work areas;
Or
• Quantities of radionuclides in the body; or
• Quantities for radionuclides excreted from the body;
or a
• Combinations of these measurements, as needed to
account for and determine compliance with
occupational dose limits.
5.2.1.4 Unless respirators are properly used, it shall be assumed
that an individual inhales airborne radioactive material at
the airborne radioactivity concentration in which the
individual is present. When a respirator is used inhalation
dose shall be calculated pursuant to section 5.2.2.1.
5.2.1.5 The physical and chemical form of the radionuclides will
be used to determine the appropriate lung clearance class
(e.g. S, M, F). If this is not known, the most restrictive
clearance class shall be used. When calculating internal
dose due to Rn-222 and Rn-220, the "with daughters
removed" DAC value should be used when determining
outside dose (Rn-220 requires this assumption to be
confirmed using environmental working level
measurements). The "without daughters removed" DAC
values shall be used when determining inside Rti-222 and
Rn-220 values.
5.2.1.6 For a mixture of airborne radionuclides, the dose
determination may disregard certain radionuclides in the
mixture if:
• the total activity of the mixture is compared with
the most restrictive DAC concentration to
demonstrate compliance with section 2.1.1 dose
limits,
• the concentration of any radionuclide disregarded is
less than 10% of its DAC, and
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• the sum of these percentages for all of the
radionuclides disregarded in the mixture does not
exceed 30 percent.

5.2.1.7 The dose from oral ingestion shall be calculated and
recorded for demonstrating compliance with regulatory
limits where it is suspected and found that oral ingestion
exceeded 10 percent of the applicable oral ALI in a
calendar year.

5.2.1.8 Intake through wounds or absorption through skin shall be
evaluated and accounted for to the extent that it is practical.

5.2.1.9 When specific information on the physical and biochemical
properties of the radionuclides taken into the body or the
behavior of the material in an individual is known, it is
permissible:
• To use that information to calculate the CEDE, this
information shall be documented in the individuals
record; and
• Upon DWMRC approval, adjust the DAC or ALI
values to reflect the actual physical and chemical
characteristics of airborne radioactive material; and
• To separately assess the contribution of fractional
intakes of Class S, M, or F compounds of a given
radionuclide to the CEDE.
5.2.1.10 If the identity of each radionuclide in a mixture is known,
but the concentration of one or more of the radionuclide in
the mixture is not known, the DAC for the mixture shall be
the most restrictive DAC of any radionuclide in the
mixture.
5.2.2 Committed Effective Dose Equivalent (CEDE) Calculation
5.2.2.1 DAC-hours calculation
C 1 DAC —hours(mrem)= *t * DAC APF
where:
DAC-hours = ALI/2000
C = Airborne concentration of radionuclides in which the
individual is present in uCi/m1
DAC = Derived Air Concentration (Stochastic) in uCilml
from 10 CFR [20.1001-20.2401] Appendix B or equivalent.
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CDE calculation will be required when the non-stochastic
DAC is found more limiting.
t = time of dose in hours
APF = Assigned Protection Factors found in 10CFR20
Appendix A (APF is 1 when respirators were not used.)
• C/DAC shall be determined using either of the
following equations when airborne radioactivity
comprises more than one radionuclide:
C C
DAC — ,:+4 DAC,
where:
Ci =Airborne concentration for each radionuclide in
uCi/ml.
DACi = Derived Air Concentration in uCi/m1 for the
applicable radionuclide in uCi/ml.
n = the total number of radionuclides making up the
airborne radioactivity.
or,
C C
DAC DAC R
where:
C = airborne concentration of radionuclides in uCi/m1
DACR = DAC of most restrictive clearance class for each
radionuclide in the mixture.
5.2.2.2 The Committed Effective Dose Equivalent (CEDE) will be
calculated using the following equation.
5000 mrem CEDE(mrem) = DAC — hours
where:
CEDE = Committed Effective Dose Equivalent (mrem)
DAC-hours = Derived Air Concentration - hours
5.2.3 Committed Dose Equivalent (CDE) Calculation
The CDE for the applicable organs shall be calculated as detailed in 10
CFR [20.1001-20.2401], Appendix B.
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5.2.4 Calculation of Internal Dose from Intake through Wounds or Skin
Absorption
Protective clothing normally protects against radioactivity intake through
wounds and skin absorption. Should an accident result in an open wound,
the RSO will inform the attending physician of the fact and will supply
guidance effecting the removal or reduction of the amount of radioactive
material remaining in the wound. The RSO will perform an investigation
and estimate the intake using data from wound monitoring or other
available information.
The CDE to any organ will be estimated using methods similar to those
used in NCRP Report 111, Developing Radiation Emergency Plans for
Academic, Medical or Industrial Facilities, August, 1991. Table 4.2 of
that publication provides values of maximum committed dose equivalent
to any organ for adults per unit intake.
5.3 Radiation Monitoring and Surveys
5.3.1 Requirements

5.3.1.1 Surveys shall be taken, as is reasonable, to evaluate
radiation levels, the concentration or quantities of
radioactive material, and the potential radiological hazards
that may be present.

5.3.1.2 Instruments used to perform radiation surveys shall be
constancy checked daily. When constancy checks are not
within ±20 percent of the expected value, the instrument
shall be taken out of service. When constancy checks are
not feasible, such as with instruments used to measure
neutrons or tritium, compensatory actions shall be
established to ensure proper instrument performance.

5.3.1.3 Monitoring shall be performed only by trained and
qualified personnel using properly calibrated instruments.

5.3.1.4 Assessment of radiological conditions shall include a
sufficient number of survey points to characterize the
radiation present and to verify boundaries.

5.3.1.5 Surveys shall be performed before, during, and at the
completion of work that has the potential for causing
changes in levels of radiation and radioactivity.

5.3.1.6 Survey frequencies shall be established based on potential
radiological conditions, probability of change in conditions
and area occupancy factors.

5.3.1.7 Monitoring results shall be reviewed by the RSO. The
review shall ensure that all required surveys have been
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performed and that the documentation is accurate and
complete.
5.3.2 Radiation Exposure Surveys
5.3.2.1 In addition to the requirements of section 5.3.1, the
minimum frequency for routine radiation surveys are listed
in Table 5-2, Routine Monitoring and Surveys.
EnergySolutions Radioactive Material License UT 2300249
Condition 22 stipulates that certain Weekly Routine
Surveys shall be performed on a monthly basis when not in
operation / use. These surveys shall continue to be
performed on a weekly basis unless approval is given by
the Radiation Safety Officer. The operational status of the
specified areas shall be documented weekly.
Table 5-2 Routine Monitorin and Surve s
Type Location Frequency
Gamma Radiation
Levels
Perimeter of Restricted Area(s) Weekly
Office Area Weekly
Eating / Change Area(s) Weekly
Waste Transport Vehicles DOT required survey upon
arrival and before departure from
the Site.
Mixed Waste Facilities Weekly
Decontamination Facilities Weekly
Continued on Next Page
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Type Location Frequency
Contamination
Levels
Eating Area Weekly
Restricted Area Access/ Change
Area
Weekly
Office Areas Weekly
Equipment/Vehicles Once before release
Decontamination Facilities Weekly
Mixed Waste Facility Weekly
Shredder Facility and Control
Room
Weekly
Rotary Dump and Control Room Weekly
Radioactive Material Shipments Upon acceptance or prior to
shipment
Radioactive Material Spill As needed
Employee/ Personnel Skin & Personal Clothing Prior to exiting the Restricted
area
Gamma Dose Administrative Bldg Quarterly
Radon Administrative Bldg Quarterly

5.3.2.2 Performance of radiation surveys should include dose rate
measurements of the general area, dose rates at a distance
of 30 centimeters from a source or surface of interest to
evaluate potential whole body doses, and dose rates on
contact with potential sources of radiation where there is a
potential for hands-on work.
5.3.3 Contamination Surveys

5.3.3.1 In addition to the requirements of section 5.3.1, minimum
contamination surveys are listed in Table 5-2, Routine
Monitoring and Surveys.

5.3.3.2 Survey requirements for the release of radioactive materials
shall be conducted in accordance with section 4.2.1 or
section 2.2.3.

5.3.3.3 Contamination surveys should incorporate techniques to
detect removable and fixed plus removable contamination
levels. It is permissible to use direct frisk measurements to
verify the maximum removable contamination on a surface.

5.3.3.4 Items with inaccessible surfaces, which were located in
known or suspected contamination areas and had the
potential to become contaminated at levels likely to exceed
Table 2-1, Acceptable Surface Contamination Levels
values, shall be treated as potentially contaminated and
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subject to administrative controls unless the items are
dismantled and monitored or special survey techniques are
used to survey all surfaces.

5.3.3.5 Swipe surveys for removable contamination shall be
reported in units of disintegrations per minute (dpm) per
100 cm2 (dpm/100 cm2). Swipes of areas less than 100 cm'
shall be reported in dpm per area swiped.

5.3.3.6 Large area wipes are encouraged and should be used to
supplement standard swipe techniques in areas generally
assumed not to be contaminated.
5.3.4 Airborne Radioactivity Monitoring

5.3.4.1 Radon and thoron measurements shall be taken as specified
in the radioactive material license(s) and the Environmental
Monitoring Plan. Rad Trak radon and thoron results may
be supplemented by grab samples.

5.3.4.2 Grab samples shall use the modified Kusnetz method or
other approved method to measure Rn-222 WL
concentrations with sample collection volumes and
counting times sufficient to provide a lower limit of
detection (sensitivity) of better than 0.03 WL (See NRC
Regulatory Guide 8.30, "Health Physics Surveys in
Uranium Mills" and the references cited therein).
Corrections for the presence of Radon-220 daughters may
be required using the procedure given in Radiation
Monitoring, by R. L. Rock and Robert T. Beckman, Mine
Safety and Health Administration, U. S. Department of
Labor. Instant WL meters or continuous WL monitors may
be used only if the equivalent sensitivity can be achieved.

5.3.4.3 Air sample program requirements used to measure
occupational exposure should be capable of measuring
airborne contamination concentrations for the most
restrictive radionuclide at 10 percent of the DAC. The use
of respirators may be necessary to meet this requirement.

5.3.4.4 After allowing for the decay of Rn-220 and Rn-222
daughters particulate air samples shall be analyzed for
gross alpha and beta activities.

5.3.4.5 If after allowing for decay of Rn/Tn progeny, a particulate
air sample used to measure occupational exposure that
exceed a gross alpha concentration of 3.5 E-12 uCi/mL or a
gross beta concentration of 2 E-10 uCi/mL in a sample of
an unknown isotopic content; or greater than 1.0 DAC in a
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sample of a known isotopic content, the following actions
shall be taken:-
• The RSO will evaluate site conditions to determine
whether additional dust suppression methods or
respiratory protection is needed, and whether
posting for airborne radioactivity (UAC R313-15-
902) is required.
• The sample will be analyzed by gamma
spectrometry and, if necessary, by radiochemical
separation and laboratory analysis to determine the
activities of the radionuclides present.
• If it is confirmed or suspected that any employee
received or may have received 8 DAC-hours during
a single day, attempts shall be made to determine
the internal dose received using in vivo or in vitro
monitoring methods for the most significantly
exposed employee. The incident shall be
investigated and corrective actions taken to prevent
the event from reoccurring.

5.3.4.6 Care should be used to minimize errors in air sampling due
to:
• Excessive sample buildup resulting in loss of
material/ or activity self-absorption during counting.
• Excessive sample time which will effectively result
in a sample dilution due to sampling during low
exposure.
• Incorrect air volume determinations.
• Non-representative sampling area.

5.3.4.7 Air monitoring equipment shall be routinely calibrated and
maintained at intervals not to exceed six months.
5.3.5 Bioassay Sampling

5.3.5.1 All radiation workers at the site shall participate in a
bioassay program to assist in evaluating internal deposition
of radionuclides unless an exemption is authorized by the
RSO:
• A baseline bioassay shall be collected upon
employment and a termination bioassay shall be
collected when access to the restricted area will no
longer occur.
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• Routine urine samples shall, at a minimum, be
analyzed for gross beta minus K-40, Ra-226, and
total uranium.
• Action levels developed using NRC Regulatory
Guide 8.9, Acceptable Concepts, Models,
Equations, and Assumptions for a Bioassay
program.
• Routine bioassay action levels shall be calculated
using the midpoint time of the sample frequency
unless actual time of intake can be determined.
• Bioassay results which exceed calculated action
levels shall be investigated in a timely manner. The
investigation should include an evaluation of work
activities and a more detailed analysis to estimate
the intake and resultant dose equivalent.

5.3.5.2 Bioassay samples shall also be used to determine dose to
personnel involved in an incident having a potential for a
significant intake of radionuclides as determined by the
Radiation Safety Officer.

5.3.5.3 Investigations should be coordinated and results reviewed
with responsible management prior to assigning dose to
person assessed with internal dose.

5.3.5.4 Management shall exercise due diligence to collect a
termination bioassay monitoring sample when a person
who participated in the bioassay program terminates
employment or concludes work involving the potential for
internal dose.

5.3.5.5 Special bioassay monitoring shall also be performed when
any of the following occurs:
• Nasal contamination is detected;
• Airborne monitoring indicates the potential for
intakes exceeding 500 mrem CEDE; or
• An intake is suspected for any reason.

5.3.5.6 A preliminary assessment of any intakes detected should be
conducted prior to the employee receiving any additional
occupational radiation dose.
5.4 Respiratory Protection Program
Respiratory protection equipment includes respirators with particulate or gas
filtering cartridges, supplied air respirators, self-contained breathing apparatus
and airline supplied-air suits and hoods.
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5.4.1 Requirements

5.4.1.1 Use of respiratory protection shall be reduced to the
minimum practicable by implementing engineering
controls and work practices to contain radioactivity at the
source.

5.4.1.2 When it is not practical to apply administrative or
engineering controls to limit the concentrations of
radioactive material in air to values below those that define
an airborne radioactivity area, consistent with maintaining
the TEDE ALARA, monitoring shall be increased and
intakes controlled by one or more of the following means:
• Control of Access;
• Limitation of exposure time;
• Use of respiratory protection equipment; or
• Other controls

5.4.1.3 Only respirators tested and certified or certification
extended by the National Institute of Occupational Safety
and Health (NIOSH)/ Mine Safety and Health
Administration (MSHA) shall be used.

5.4.1.4 The Respiratory Protection program shall include:
• Air sampling sufficient to identify the potential
hazard, permit proper equipment selection, and
estimate doses;
• Surveys and bioassays, as appropriate, to evaluate
actual intakes;
• Testing of respirators for operability immediately
prior to each use;
• Written procedures regarding selection, fitting,
issuance, maintenance, and testing of respirators,
including testing for operability immediately prior
to each use; supervision and training of personnel;
monitoring including air sampling and bioassays
and record keeping; and
• Determination by a physician prior to initial fitting
and at least every 12 months thereafter, that the
individual user is physically able to use the
respiratory protection equipment.
5.4.1.5 A written policy statement on respirator usage shall be
issued covering:
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• The use of process or other engineering controls,
instead of respirators;
• The routine, non-routine, and emergency use of
respirators; and
• The periods of respirator use and relief from
respirator use.

5.4.1.6 Respirators shall be used within the limitations for type and
mode of use and shall provide proper visual,
communication, and other special capabilities (such as
adequate skin protection) when needed.

5.4.1.7 In estimating exposure of individuals to airborne
radioactive materials, allowances may be made for
respiratory protection equipment used to limit intakes
pursuant to section 5.4.1.2, provided that the following
conditions, in addition to those in section 5.4.1.3 to 5.4.1.6
are satisfied:
NOTE: An initial estimate of airborne
concentrations breathed while using a
respirator shall be made by dividing the
average air concentration during each
period of uninterrupted use by the
assigned protection factor.
• DWMRC authorization is required to alter the
respiratory assigned protection factors listed in
10CFR20 Appendix A, Assigned Protection Factors
for Respirators.

5.4.1.8 The Clive Facility is authorized to use ALI, DAC and ECL
values based on dose coefficients adopted by ICRP
Publication 68 and 72.
5.5 Handling Radiologically-Contaminated Personnel
5.5.1 Skin Contamination

5.5.1.1 The RSO shall be notified of all PCEs above levels listed in
2.2.1.3.

5.5.1.2 The extent of skin contamination should be determined
prior to initiating decontamination procedures.

5.5.1.3 NCRP No. 65, Management of Persons Accidentally
Contaminated with Radionuclides shall be used for
personal decontamination. RSO permission shall be
required to permit the exit of a person from the restricted
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area with skin contamination above Table 2-1, Acceptable
Surface Contamination Levels.

5.5.1.4 Dose shall be calculated for skin contamination if action
levels in CL-RS-PR-120, Access Control Points are met or
exceeded.

5.5.1.5 Personnel with skin contamination for which dose
assessment was not performed should be informed of the
nature of the contamination and an upper estimate on the
potential dose (such as less than 10 mrem) as soon as
practicable, preferably prior to the end of their work day.
5.5.2 Contaminated Wounds

5.5.2.1 Emergency medical care shall be administered immediately
for injuries involving radioactive materials in accordance
with National Council on Radiation Protection and
Measurements Report Number 65. Medical treatment of
injuries takes precedence over radiological considerations.

5.5.2.2 The treatment of contaminated injuries should include the
following:
• Treatment of contaminated wounds by medically
qualified personnel.
• Monitoring of wounds and associated bandages for
contamination, including alpha emitters if
applicable.
• Identification of the radionuclides involved.
• Medical determination of the need for therapeutic
intervention such as blocking or chelating agents.
• Initiation of appropriate bioassay monitoring.
• Determination of need for work restrictions.

5.5.2.3 An injured person having contaminated wounds that could
result in internal doses greater than 2 percent of the Section
2.1 limits shall be counseled promptly on the medical and
radiological implications. The counseling should be
performed by senior Radiation Safety and/or medical
professionals.
5.5.3 Exposures to Airborne Radioactivity
Potential intakes of radioactive material are indicated when personnel
without respiratory protection are exposed to airborne radioactivity or
when respiratory protection has been compromised. If intakes of
radioactive material are indicated which could result in a committed
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effective dose equivalent greater than 100 mrem, the following actions
should be taken:

5.5.3.1 Identify personnel potentially exposed to airborne
radioactivity;

5.5.3.2 Obtain nasal smears for qualitative indication of intakes
where appropriate;

5.5.3.3 Analyze air samples to determine airborne concentrations
where appropriate;

5.5.3.4 Determine duration of potential exposure to airborne
radioactivity;

5.5.3.5 Perform bioassay appropriate for radionuclides involved;
and

5.5.3.6 Evaluate dose prior to permitting the worker to receive any
ad ditional occupational radiation dose.
5.6 Instrumentation and Calibration
5.6.1 Inspection, Calibration and Performance Tests

5.6.1.1 Record dosimeters shall be processed and evaluated by a
dosimetry processor holding current personnel dosimetry
accreditation from the National Voluntary Laboratory
Accreditation Program (NVLAP). The lab shall be
approved in this accreditation process for the type of
radiation or radiations included in the NVLAP program that
most closely approximates the type of radiation or
radiations for which the individual wearing the dosimeter is
monitored.

5.6.1.2 Electronic dosimeters and area radiation monitors shall be
calibrated at least annually and in accordance with section
5.6.2. All other survey meters shall be calibrated semi-
annually.

5.6.1.3 In unusual and limited situations it may be necessary to use
an instrument in an application other than that envisioned
by the manufacturer. Special calibrations should be
performed for use of instrumentation outside
manufacturer's specifications. The instrument should be
adjusted, calibrated and labeled to identify the special
conditions and used only under the special conditions for
which it was calibrated.

5.6.1.4 Instruments should bear a label or tag with the date of
calibration and due date of the next calibration.
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5.6.1.5 Instruments whose "as found" readings indicate that the
instrument may have been used while out of calibration
shall be reported to the RSO. Surveys performed with the
instrument while it was out of calibration shall be identified
and reviewed with respect to its impact on safety.
5.6.2 Maintenance

5.6.2.1 A program for preventive and corrective maintenance of
radiological instrumentation shall be established and
documented.

5.6.2.2 Preventive and corrective maintenance shall be performed
using components and procedural recommendations at least
as stringent as those specified by the manufacturer of the
instrument.

5.6.2.3 Radiological instruments shall undergo calibration prior to
use following any preventive or corrective maintenance or
any adjustment that voids the previous calibration. A
battery change is not normally considered maintenance.
5.6.3 Calibration Facilities
Calibration facilities shall be audited and approved by EnergySolutions for
its use of acceptable calibration practices and NIST traceable standards.
6 Training and Qualifications
The Radiation Safety Training program is required to ensure each person receiving
occupational radiation dose resulting from Clive operations understands the potential
health risks and can follow the applicable radiation safety requirements. Refer to
operating procedure CL-TN-PR-100, Clive Facility Training for additional safety training
requirements.
6.1 Visitor Orientation
6.1.1 Requirements

6.1.1.1 Information may be communicated by video or handout
materials to personnel entering a site. An examination is
not required.

6.1.1.2 Visitor orientation shall include the following information:
• Basic radiation protection concepts
• Risks of low-level occupational radiation dose,
including cancer and genetic effects
• Radiological protection policies and procedures
• Visitor and management responsibilities for
radiation safety
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• Adherence to radiological posting and labeling
• Applicable emergency procedures
• Training for issuance of dosimetry, if applicable
• Pregnant worker policy and statement. (For women
only)
• Site Radiological Security Plan

6.1.1.3 Orientation shall be commensurate with the areas being
visited.

6.1.1.4 Visitors shall be escorted by a qualified certified radiation
worker while in the Restricted Area.

6.1.1.5 Visitors may not enter Airborne Radioactivity Areas and
Radiation Areas or directly handle radioactive material.
6.2 Radiation Worker Safety Training
6.2.1 Requirements

6.2.1.1 All unescorted persons shall be trained in radiation safety
prior entering the restricted area.

6.2.1.2 Documentation of the radiation safety training shall clearly
identify the individuaPs name, date of training, topics
covered, and name of the certifying individual.

6.2.1.3 Radiation worker safety training programs and retraining
shall be established and conducted at intervals not to
exceed 1 year to familiarize the worker with the
fundamentals of radiation protection and the ALARA
process. The RSO may grant an additional 30 days to
complete the training.

6.2.1.4 Training shall include both classroom and applied training.

6.2.1.5 Training shall either precede assignment or be concurrent
with assignment as a radiation worker if the worker is
accompanied by and under the direct supervision of a
trained radiation worker.

6.2.1.6 Radiation worker training not specific to a given site or
facility may be waived provided that the training was given
in the last year and is adequately documented in the form of
a certification document containing the individual's name,
date of training, and specific topics covered, and an
appropriate official has certified the training of the
individual.
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6.2.1.7 The knowledge of radiation safety possessed by radiation
workers shall be verified by examination prior to an
unsupervised assignment.

6.2.1.8 The training shall include procedures specific to an
individual's job assignment.

6.2.1.9 The level of training shall be commensurate with each
worker's assignment.

6.3 Radiation Safety Technician Training
6.3.1 Requirements

6.3.1.1 Training and retraining programs for Radiation Safety
Technicians shall be established and conducted at intervals
not to exceed 36 months to familiarize them with the
fundamentals of radiation protection and the proper
procedures for maintaining doses ALARA.

6.3.1.2 This program should include both classroom and applied
training. Applied training may be waived at the RSOs
discretion.

6.3.1.3 The training shall either precede performance of tasks
assigned to Radiation Safety Technicians or be concurrent
with such task assignments if the individual is accompanied
by and under the direct supervision of a qualified
individual.

6.3.1.4 The required level of knowledge of radiation safety
possessed by Radiation Safety Technicians shall be verified
by examination to include demonstration prior to any
unsupervised work assignment.

6.3.1.5 The training program shall include procedures specific to
the site or facility where the technician is assigned.

6.3.1.6 The level of training shall be commensurate with the
technician's assignment.

6.3.1.7 Allowances may be made for previous radiation safety or
Radiation Safety Technician training provided that the
training was given within the last 2 years and is adequately
documented.
6.3.1.8 Documentation of the previous training shall clearly
identify the individual's name, date of training, topics
covered, and name of the certifying individual.
7 Radiological Records

7.1 Requirements
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7.1.1 Purpose
This chapter contains the prescribed practices for preparing and retaining
radiation safety related records. Radiation Safety records are needed to
demonstrate the effectiveness of the overall program. The work force and
management are required to use records to document radiation safety
afforded to personnel on-site. Records of Radiation Safety programs may
be required to support worker health studies and future disputes or claims.
Therefore, these records should be high quality, readily retrievable and
managed for the prescribed retention period. Consideration should be
given to cross-referencing related records to aid retrievability. Records
shall be handled such that personal privacy is protected.
7.1.2 Records Management Program
7.1.2.1 The following information shall be maintained and records
retained until the DWMRC terminates each pertinent
license requiring this record:
• Results of surveys, measurements, and calculations
used to determine individual occupational dose
from external and internal sources pursuant to
section 7.2.1.
• Results of air sampling, surveys, and bioassays
pursuant to section 5.4.1.4.
• Records or the results of measurements and
calculations used to release material and equipment
from restricted areas (see section 2.2.1, 2.2.2, 2.2.3,
4.2.1 and 5.3.2) or evaluate the release of effluents
to the environment.
• NRC Form 4 or equivalent
• Personal dose records listed in section 7.2.1
• Dose records to members of the public required to
demonstrate compliance with section 2.1.3
• Provisions of the Radiation Safety Program.
• Records of the disposal of licensed or registered
materials made pursuant to Sections R313-15-1002,
R313-1003, R313-15-1004, R313-15-1005, R313-
25 and disposal by burial by soil.
7.1.2.2 The following information shall be maintained and records
retained for a minimum period of 3 years after they are
created:
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• Results of surveys (section 5.3.1.1), equipment
calibrations (section 5.6.1.2 & 5.6.1.3) and receipt
of radioactive material (section 4.2.2.1);
• Results of audits and other reviews of program
content and implementation.
• Records used in preparing NRC Form 4.
7.1.3 Record Keeping Standards

7.1.3.1 Radiation Safety records shall be accurate and legible. The
records should include the following:
• Company name, specific location, function and
process
• Signature or other identifying code of the preparer
and date
• Legible entries in black/blue ink
• Corrections identified by a single lineout, initialed
and dated

7.1.3.2 Radiation Safety shall maintain a file of names, signatures
and initials for future identification of the person who
signed or initialed a record.

7.1.3.3 Radiation Safety records should not include:
• Opaque substances for corrections
• Non-standardized terms or shorthand.

7.1.3.4 Units shall clearly be indicated for all quantities entered in
records. Units used to denote radiological dose, exposure
or contamination are limited to curie, rad, becquerels, and
rem (including multiples of subdivisions of these units) and
also includes dpm. Working Level concentration units
shall be presented in units of some multiple of curie per
(multiple of) grams or liters.

7.1.3.5 A clear distinction shall be made among the quantities
entered on the records required by this manual (e.g. TEDE,
SDE, DDE).
7.2 Employee Records
7.2.1 Personnel Radiation Safety Records

7.2.1.1 For each employee who may enter the Clive Facility
Restricted Area and is likely to receive in a year an
occupational dose requiring monitoring pursuant to section
5.1.1.1, Clive management shall;
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• Determine the occupational radiation dose received
during the current year.

7.2.1.2 In complying with the requirement section 7.2.1.1, Clive
management may:
• Accept as a record of the occupational dose that the
individual received during the current year, a
written signed statement from the individual, or
from the individual's most recent employer for
work involving radiation exposure that discloses the
nature and the amount of any occupational dose that
the individual may have received during the current
year;
• Obtain reports of the individual's dose equivalent(s)
from the most recent employer for work involving
radiation exposure, or the individual's current
employer (if the individual is not employed by
EnergySolutions by telephone, telegram, electronic
media, or letter. The licensee shall request a written
verification of the dose data if the authenticity of
the transmitted report cannot be established.

7.2.1.3 Clive management shall record the dose history, as required
by section 7.2.1.1 on NRC Form 4 or other clear and
legible record, of all the information required on the form.
The form or record must show each period in which the
individual received occupational dose to radiation or
radioactive material and must be signed by the individual
who received the dose. For each period for which Clive
management obtains reports, Clive management shall use
the dose shown in the report in preparing NRC Form 4.
For any period in which Clive management does not obtain
a report, Clive management shall place a notation on NRC
Form 4 indicating the periods of time for which data are not
available.

7.2.1.4 If the current year's occupational dose record is
incomplete, Clive management shall limit the individual to:
• TEDE of 100 mrem (1.0 mSv) per year.

7.2.1.5 Records of all employees whom monitoring was required
and records of doses received during planned special
exposures, accidents, and emergency conditions. These
records shall include when applicable:
• DDE, EDEX, EDE, SDE to the skin, and SDE to
the extremities; and
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• The estimated intake or body burden of
radionuclides (see section 5.2.1); and
• The CEDE assigned to the intake or body burden of
radionuclides; and
• Specific information used to calculate the CEDE
(see section 5.2.1.13); and
• The TEDE when required by section 5.2.1; and
• The total of the DDE and the ODE to the organ
receiving the highest total dose.
7.2.1.6 Personal dose records shall be updated at least annually.
7.2.1.7 Personal dose records shall be maintained on NRC Form 5
or in clear and legible records containing all the
information required by NRC Form 5.
7.2.1.8 Personal dose records required in this section shall be
protected from public disclosure.
7.2.1.9 Records of dose to an embryo/fetus shall be maintained
with the dose to the declared pregnant woman.
7.2.1.10 Declarations of pregnancy, including the estimated date of
conception, shall also be kept on file.
7.2.1.11 Radiation dose records shall contain information sufficient
to identify each person, or employee number.
7.2.2 Planned Special Exposure Records
EnergySolutions does not anticipate authorizing planned special exposures
at the Clive facility. However, in exceptional situations, EnergySolutions
employees may receive doses (planned special exposures) separate from
and in addition to the annual occupational dose limits. All PSE's shall (1)
receive prior written authorization from the Business Group President and
the Corporate Radiation Safety Officer and (2) comply with all Federal or
State regulations.
Note: Prior to participating in a planned special exposure an
individual's lifetime cumulative occupational dose
record shall be obtained.
7.2.3 Medical Records
7.2.3.1 Medical evaluations and treatment performed in support of
the Radiation Safety program shall be documented.
7.2.3.2 Maintenance of employee non-occupational radiation dose
records for therapeutic or large amounts of diagnostic
radiation doses for medical purposes is encouraged.
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7.2.4 Radiation Safety Training and Qualification Records

7.2.4.1 Radiation safety records of training and qualification shall
be maintained to demonstrate that a person received
appropriate information to perform the work assignment in
a safe manner. Qualification standard records shall be
retained for classroom, on-the-job, and practical factor
training.

7.2.4.2 Formal records of training and qualification shall be readily
available to first-line supervision and management of
involved personnel to aid in making work assignments.

7.2.4.3 Personnel training records shall be controlled and retained.
At a minimum, these records shall include the following:
• Course title
• Attendance sheets with instructor's name
• Employee's name, identification number (if it
provides a positive employee identification) and
signature
• Date of training
• Documentation related to exceptions for training
requirements and extensions of qualification
• Quizzes, tests, responses and acknowledgments of
training, with the date and signature of the person
trained
• Special instructions to female workers concerning
prenatal radiation dose acknowledged by the
worker's signature.

7.2.4.4 Records shall be retained for the following types of
training:
• Visitor Orientation
• Radiation Worker Safety Training
• Radiation Safety Technician Training
• Periodic retraining
• Respiratory Protection Training
• Hazardous Waste and OSHA training
• Instructor training
• Qualifications for special tests or operations
Training of emergency response personnel
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• ALARA Training
• General Employee Training

7.2.4.5 The following instructional materials shall be maintained:
• Course name, with revision and approval date
• Instructor's manuals, course content, handouts, or
lesson plans containing topical outlines
• Video and audio instructional materials, include the
dates and lessons for which they were used
• Job-specific training documents

7.2.4.6 Documentation of training and qualification waived by the
RSO because of previous training, certification, or
demonstrated knowledge or experience.
7.2.5 Dosimetry Reports

7.2.5.1 Terminating employees shall be provided a report that
summarizes radiation dose for the total monitoring period
at the reporting facility either upon a signed request at the
time of termination, or a signed request from the current
monitoring facility, or annually (on or before April 30)
proceeding the affected year.
If at the time of tennination, the most recent monitoring
results estimate of the dose must be provided together with
a clear indication that it is an estimate with a record
following within 30 days after final dose determination.
If a written request has been received and all doses are
final, a record shall be provided to the affected individual
or requesting facility within 30 days of receipt.
7.3 Public Dose Records
7.3.1 Visitor Record Requirements

7.3.1.1 For visitors entering an area where radiation monitoring is
required, the following records shall be maintained:
• Documented completion of Visitor Orientation.
• Any additional training given by Clive management
or its contractors to gain access into the Restricted
Area.
• Radiation dose records, including zero dose.
7.3.2 Member of the Public Dose Records
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Records shall be maintained sufficient enough to demonstrate compliance
with the dose limit for individual members of the public (see section
2.1.3).

7.4 Radiation Safety Procedures
7.4.1 Policies, Procedures and Radiation Work Permits
Records of the Radiation Safety Program should be maintained in a
chronological sequence that will allow correlation with the corresponding
support information. For example, procedures for performing radiation
surveys shall be identifiable with the survey results. Completed Radiation
Work Permits shall be maintained according to the EnergySolutions'
Quality Assurance Manual.
7.4.2 ALARA Records
Records of As-Low-As-Reasonably-Achievable (ALARA) plans and goals
shall be maintained to demonstrate the adequacy of the ALARA Program.
7.4.3 Quality Assurance Records
Records of quality assurance reviews and audits developed for Radiation
Safety functions shall be retained to ensure that sufficient records, are
specified, prepared, reviewed, approved and maintained to accurately
reflect completed work.

7.5 Radiation Surveys
7.5.1 Requirements
The Radiation Safety program requires the performance of radiation,
airborne radioactivity, and contamination surveys to determine existing
conditions in a given location. Maps with sufficient detail to permit
identification of original survey and sampling locations shall be
maintained. Records should contain sufficient detail to be meaningful
even after the originator is no longer available. Radiological surveys shall
be recorded on appropriate standard forms and include the following
common elements:

7.5.1.1 Date and purpose of the survey.

7.5.1.2 General and specific location of the survey.

7.5.1.3 Name and signature of the surveyor and analyst.

7.5.1.4 Pertinent information needed to interpret the survey results.

7.5.1.5 Reference to a specific Radiation Work Permit if the survey
is performed to support the permit.
7.5.2 Radiation Surveys
In addition to the elements provided in section 7.5.1, radiation surveys
shall, at a minimum, include the following information:
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7.5.2.1 Instrument model, calibration date, and serial number.

7.5.2.2 Results of the measurements of area dose rates.
7.5.3 Airborne Radioactivity
In addition to the elements provided in section 7.5.1, records of airborne
radioactivity measurements shall, at a minimum, include the following
information:

7.5.3.1 Sampler location identifier and laboratory counting
instrument model, serial number, calibration date, and
efficiency;

7.5.3.2 Airborne radioactivity concentrations in general airborne
areas and breathing zones; and

7.5.3.3 Supporting parameters, flow rate, duration of sampling,
correction factors and filter medium.
7.5.4 Contamination Surveys
In addition to the elements required by section 7.5.1, records of
contamination surveys shall include, at a minimum, the following
information:

7.5.4.1 Model and serial number of counting equipment.

7.5.4.2 Contamination levels (using appropriate units) and
supporting parameters including counting efficiency,
counting time, correction factors, type of radiation, and
whether the contamination was fixed plus removable or
removable.

7.5.4.3 Location of areas found to contain hot particles or high
concentrations of localized contamination.

7.5.4.4 Follow up survey results for decontamination processes
cross-referenced to the original survey.
7.6 Instrumentation and Calibration Records
7.6.1 Calibration and Operational Checks
Records of calibration and periodic operational checks of fixed, portable,
and laboratory radiation measuring equipment shall be maintained and
include frequencies, method, dates, person performing calibration and
calibration sources numbers. Only National Institute of Science and
Technology or other acceptable standards should be used for calibration.

7.6.1.1 Calibration records shall be maintained for the following
equipment:
• Portable survey instruments
• Bioassay measurement equipment
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• Laboratory, counting room and fixed radiation
measuring equipment
• Process and effluent monitors and sampling
equipment
• Radiation area monitors
• Portal monitors and other personnel contamination
monitors
• Electronic Dosimeters
• Air sampling equipment
• Tool and waste monitoring equipment
• Protective clothing and equipment monitors.

7.6.1.2 Maintenance histories, including the nature of any defects
and corrective actions taken, and calibration results for
each instrument should be created and retained.
7.6.2 Special Calibration Records
Records of additional tests and checks of instrumentation used in
conjunction with a suspected overexposure, questionable indication or
unusual occurrence shall be retained. In addition, records of special
instrument calibrations and modifications made in accordance with section
5.6.1 should be retained.
7.7 Records Management
7.7.1 Form of Records
Records required to be retained by UAC R313-15 and ANI Information
Bulletin 15-01, Nuclear Liability Insurance Records Retention shall be
legible throughout the specified retention period and meet either of the
following conditions.

7.7.1.1 Records may be the original or a reproduced copy or a
microfilm provided that the copy or microfilm is
authenticated by authorized personnel and that the
microfilm is capable of producing a clear copy throughout
the required retention period.

7.7.1.2 Records may be stored in electronic media with the
capability for producing legible, accurate, and complete
records during the required retention period. Records such
as letters, drawings, and specifications must include all
pertinent information, such as, stamps, initials, and
signatures. Adequate safeguards shall be taken to prevent
tampering with and loss of records.
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7.8 Reports
7.8.1 Reportable Events
Reports to the DWMRC are required for the following events (refer to
UAC R313-15-1202 for report requirements):

7.8.1.1 Immediate reporting is required for:
• Loss, stolen or missing licensed material in an
aggregate quantity equal to or greater than 1000
times the quantity specified in appendix C to 10
CFR 20, section 520.1001-20.2401.
• Any event involving byproduct, source or special
nuclear material possessed by the Clive Facility that
may have caused or threatens to cause an individual
to receive:
1) A TEDE of 25 rems or more.
2) An EDE of 75 rems or more.
3) A SDE to the skin or extremities of 250 rads
or more.
4) A release of radioactive material so that had
an individual been present for 24 hours, the
individual could have received an intake five
times the occupational annual limit on
intake.
Make reports to the Executive Secretary by telephone,
telegram, mailgram or facsimile.

7.8.1.2 A written notification is required within 24 hours after the
following events:
• The loss of control of licensed material possessed
by Clive Facility that may have caused or threatens
to cause an individual to receive in a period of 24
hours any of the following conditions:
1) A TEDE of 5 rems; or
2) An EDE of 15 rems; or
3) A SDE to the skin or extremities exceeding
50 rems; or the release of radioactive
material inside or outside of the Restricted
Area, so that had an individual been present
for 24 hours, the individual could have
received an intake in excess of one
occupational annual limit on intake.
4) Make reports to the Executive Secretary by
telephone, telegram, mailgram or facsimile.
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7.8.1.3 A written report is required within 30 days after the
following events.
• Loss, stolen or missing licensed material in an
aggregate quantity equal to or greater than 10 times
the quantity specified in appendix C to 10 CFR
20.1001-20.2401
• Any incident for which notification is required by
section 7.8.1.2
• Doses in excess of any of the following:
1) The occupational dose limits for adults in
Section R313-15-201; or
2) The occupational dose limits for a minor in
section 2.1.6; or
3) The limits for an embryo/fetus of a declared
pregnant women in section 2.1.2; or
4) The limits for an individual member of the
public in section 2.1.3; or
5) Any applicable limit of the license; or
6) The ALARA constraints for air emissions
established under Subsection R313-1 5-101
(4); or
• Levels of radiation or concentrations of radioactive
material in:
1) A restricted area in excess of any applicable
limit in the license.
2) An unrestricted area in excess of 10 times
any applicable limit set forth in this manual
or in the license (whether or not it involved
exposure to any individual in excess of the
limits in section 2.1.3).

7.8.1.4 Contents of Reports
• Each report shall describe the extent of exposure of
individuals to radiation and radioactive material,
including, as appropriate:
1) Estimates of each individual's dose; and
2) The levels of radiation and concentrations of
radioactive material involved; and
3) The cause of the elevated doses, dose rates
or concentrations; and
4) Corrective steps taken or planned to ensure
against a recurrence, including the schedule
for achieving conformance with applicable
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limits, ALARA constraints, generally
applicable environmental standards and
associated license conditions.
• Each report shall include for each occupationally
overexposed individual:
1) The name, Social Security account number
and date of birth. With respect to the limit
for the embryo/fetus, the identifiers should
be those of the declared pregnant female.

7.8.1.5 A copy of the report will also be submitted to the
overexposed individual. This report shall be transmitted at
a time no later than the transmittal to the Executive
Secretary.

7.8.1.6 Any report pursuant to section 7.8.1(1),(2) or (3) shall be
prepared and filed with the Executive Secretary so that
names of individuals who have received exposure to
sources of radiation are stated in a separate and detachable
portion of the report.

7.8.1.7 Vacating Premises
No less than 30 days before vacating or relinquishing
possession or control of premises which may have been
contaminated with radioactive material as a results of
activities, notify the Executive Secretary in writing of
intent to vacate.
8 References
8.1 10 CFR 20, Standards for Protection Against Radiation
8.2 49 CFR, Transportation
8.3 CL-RS-PG-001, Clive ALARA Program
8.4 ES-QA-PG-001, Energysolutions Quality Assurance Program
8.5 ES-RS-PG-001, EnergySolutions Radiation Safety Program
8.6 ICRP Publication 26, Recommendation of the International Commission on
Radiological Protection, 1977
8.7 ICRP Publication 68, Dose Coefficients for Intakes of Radionuclides by Workers
8.8 ICRP Publication 72, Age-Dependent Doses to the Members of the Public from
Intake of Radionuclides
8.9 NCRP Report No. 65, Management of Persons Accidentally Contaminated With
Radionuclides, 1980
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Radiation Protection Program Revision 17
8.10 NCRP Report No. 91, Recommendations on Limits for Exposure to Ionizing
Radiation, 1987
8.11 NCRP Report 111, Developing Radiation Emergency Plans for Academic,
Medical or Industrial Facilities, August, 1991
8.12 NRC Regulatory Guide 8.9, Acceptable Concepts, Models, Equations and
Assumptions for a Bioassay Program, July 1993
8.13 NRC Regulatory Guide 8.30, Health Physics Surveys in Uranium Mills, June
1983
8.14 Utah Administrative Code R313-15, Standards for Protection Against Radiation
8.15 Utah Administrative Code R313-18, Notices, Instructions and reports to Workers
by Licensees or Registrants- Inspection
8.16 Utah Administrative Code R313-19, Requirements of General Applicability to
Licensing of Radioactive Material
8.17 Utah Radioactive Material License UT 2300249
8.18 Utah Radioactive Material License UT 2300478
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EnergySolutions' Clive Facility CL-RS-PG-002
Radiation Protection Program Revision 17
DOCUMENT SUMMARY FORM
Please provide the following information for new/revised documents.
Forward the completed form, review comment forms, approved document,
and electronic file, to Document Control.
Document No.: CL-RS-PG-002 Revision No.: 17
Title: Radiation Protection Program
Special Status (i.e. Restricted; SSI; etc.): NA
If special status is applicable, please note any special distribution/handling requirements:
NA
Summary of changes (if this is a revision):
Added wording to 2.2.3.2 to state that items shall be sufficiently clean to allow for a radiological
survey.
Corrected Radiation Area upper level rate as well as wording in Table 2-2
Changed 5.1.1.3 from "..., eye dose equivalent (EDE)" to "..., lens dose equivalent (LDE),..."
Changed 7.7.1 from "...Bulletin 80-1A,..." to "...Bulletin 15-01,..."
Add program number to step 83, "CL-RS-PG-001
D yes T No
II yes 5C No
This document requires evaluation per the requirements of a license. If yes, attach evaluation
results.
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Document Control.
Type of revision: n Contains technical changes X Contains only administrative changes
Distribution (or changes to distribution) for controlled copies of this document.
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