NISP-RP-07 Control of Radioactive Material

Chapter 7 covers the control of radioactive materials which is of paramount importance to ensure the safety of individuals, the environment, and to prevent the unauthorized or unintended use of radioactive substances for harmful purposes. The control of radioactive materials typically involves strict regulations, licensing, monitoring, and safety measures. Here are some key aspects of controlling radioactive materials:

Regulation and Legislation: Most countries have regulatory bodies responsible for overseeing the use, transportation, and disposal of radioactive materials. These agencies often establish rules, regulations, and laws that govern the handling of radioactive materials. In the United States, for example, the Nuclear Regulatory Commission (NRC) regulates civilian use of radioactive materials.

Licensing: Individuals, organizations, and facilities that work with radioactive materials are typically required to obtain licenses or permits. These licenses outline the specific conditions and safety measures that must be adhered to when working with radioactive materials.

Radiation Protection: Controlling exposure to radiation is a fundamental aspect of managing radioactive materials. This includes the use of shielding, containment, and personal protective equipment to minimize radiation exposure to workers and the public.

Security: Due to the potential risks associated with radioactive materials, security measures are essential to prevent theft, diversion, or unauthorized access. This is particularly important to prevent the materials from falling into the hands of terrorists or other malicious actors.

Transportation Regulations: Radioactive materials must be transported safely, often in specially designed containers, and in accordance with international and national regulations. Transport regulations ensure that radioactive materials do not pose a risk to public health or the environment during transit.

Waste Management: The disposal of radioactive waste is a critical consideration. Radioactive waste must be managed and stored in a way that prevents environmental contamination and long-term hazards. Different types of radioactive waste may require different disposal methods, such as deep geological repositories for high-level radioactive waste.

Monitoring and Inspections: Regulatory agencies conduct regular inspections of facilities that handle radioactive materials to ensure compliance with safety and security regulations. This includes assessing radiation levels, security measures, and record-keeping.

Training and Education: Workers who handle radioactive materials must be properly trained in radiation safety procedures. This includes understanding the risks, knowing how to use protective equipment, and responding to emergencies.

Emergency Response: Plans and procedures must be in place to respond to accidents, leaks, or other emergencies involving radioactive materials. This may involve evacuation, containment, and cleanup measures.

International Cooperation: Because radioactive materials can cross borders, international cooperation is essential to prevent illicit trafficking and ensure safe management. Organizations like the International Atomic Energy Agency (IAEA) play a crucial role in promoting nuclear safety and security worldwide. Overall, the control of radioactive materials is a multifaceted process that involves regulatory oversight, safety measures, security measures, and ongoing monitoring to mitigate the risks associated with these materials and ensure their responsible use.

1.1 Purpose

The purpose of this procedure is to provide guidance for the survey, release or control of materials from Radiological Controlled Areas.

This procedure does not provide guidance for the control or release of materials packaged for transportation under DOT regulations.

This procedure does not provide guidance for control of radioactive sources which may be used at the station for calibration or instrument response verification or Special Nuclear Material.

1.2 Scope and Applicability

This procedure describes the normal process for monitoring material exiting from the radiological controlled area assuming contamination monitors are operational. In the event equipment is not available site specific procedures will provide guidance to supplemental personnel.

This procedure is applicable to US member utilities with the Institute of Nuclear Power Operations (INPO). Member utilities are expected to use this standard to enable supplemental workers to transition between nuclear power plants with minimal site-specific training. Compliance with these instructions is expected without additional site requirements or process deviations being imposed that may require additional training or challenge the performance of supplemental workers.

This is an information use procedure that will be used to train and instruct supplemental radiological protection technicians. Member utilities may implement these process requirements in site procedures provided the site procedures are equivalent and updated whenever this Nuclear Industry Standard Process (NISP) is revised. Member utilities may also elect to delete equivalent site-specific procedures and use this procedure for training and instruction. Current revisions are maintained on the INPO website.

Terms, acronyms, and definitions are provided in NISP-RP-13, Glossary

Clarifying notes for requirements and process steps are provided in Section 4.0 using superscript numbers in the preceding sections.

2.0 General Requirements

2.1 Lanyards, hard hats, badges and primary and secondary dosimetry may remain on the individual and worn through the whole body contamination monitors.

2.2 When possible, personal items should not be taken inside the RCA. Personal items inside pockets or worn on the belt such as cell phones, pagers, radios and keys may remain on the individual and worn through the whole body contamination monitors.

2.2.1 Items removed from pockets while in the RCA should be monitored using the Tool and Equipment Monitor (TEM) prior to leaving the RCA.

2.3 Items used during the entry in a contamination area should always be released in a TEM. These items include

2.3.1 Data logging devices including lap top computers

2.3.2 Radio’s

2.3.3 Flashlights

2.3.4 Hand carried items such as notebooks and pens.

2.4 Gloves should always be monitored in a TEM for release.

2.5 Security personnel may wear tactical gear such as weapons, ammunition, emergency respiratory equipment, gloves, or other security equipment through the personnel whole body monitors for release.

2.5.1 In the event an alarm occurs on the whole body contamination monitors indicating potential contamination of security equipment, RP is to provide oversight of the survey and decontamination of the security equipment but should not touch any of the equipment.

2.6 Except for personal items release of material from radiological control can only be performed by a ANSI qualified Radiation Protection technician.

2.7 Items suspected of having the potential for being contaminated with pure beta emitters, such as components from PWR waste gas or BWR off gas systems shall be surveyed with an instrument capable of detecting beta activity.²

2.8 In addition to typical release survey requirements, items which could have been contaminated with alpha contamination must be surveyed with an instrument capable of detecting alpha contamination.

2.9 Smoke detectors, or other plant equipment containing radioactive sources, cannot be free released without RP Supervision approval.³

2.10 Alarm set points for TEM will be established by the site based on background, instrument efficiency, and hard to detect radionuclides and should alarm when 5000 dpm of radioactivity has been detected.

2.11 Non-personal items less than 100 cm² in size cannot be released through TEM only. Additional surveys must be completed by a frisker or similar instrument in a background of <200 cpm.

2.12 Release of non-personal items can be completed by using a TEM. If the size of the object prevents the use of a tool monitor then RP Supervision will determine the survey methods.

2.13 Attachment 4, Unconditional Release of Certain Equipment, provides the survey methodology for items such as computers, breakers, cameras, gauges and power tools.

2.14 If monitoring multiple items concurrently in the TEM, consider the effects of self-shielding. Avoid stacking items when possible. The shielding effects of approximately ¼ inch of steel or 2 inches of paper may reduce monitor sensitivity to unacceptable levels.

2.15 Alarms on a TEM indicate the presence of radioactive material and proper contamination controls will be implemented by the RP Technician in response to alarms. As a minimum wear protective gloves for removing the item and performing additional surveys.

2.16 Items suspected of containing natural radioactive material, such as welding rods or camera lens, can be released after gamma spectroscopy indicates only natural products are present and any unidentified gamma photo peaks have been resolved.

2.17 Items may be consider free released as long as all of the following criteria are met:

2.17.1 No detectable fixed activity above background, other than naturally occurring isotopes.⁷

2.17.2 No detectable loose surface contamination.

2.17.3 No detectable/ suspected internal contamination

2.17.4 No detectable alpha contamination

2.17.5 No radioactive labels or markings

2.18 Items which indicate the presence of radioactive material, other than naturally occurring, must be labeled in accordance with NISP-RP-04, Radiological Posting and Labeling.

2.19 For the release of a large volume of equipment, or for the release of very large items, a survey plan should be developed using Attachment 3, Unconditional Release Survey Plan.

3.0 Process Instructions

1.1 Release of Personal Items

1.1.1 Individuals may release personal items through the use of a TEM by the following method:¹

a. Place items in the center of the TEM and minimize stacking of materials.

b. Initiate the count

c. No alarm, individual may retrieve the item from the unit.

d. If an alarm occurs, initiate count cycle again on the TEM as per posted instructions. If alarm occurs do not open the unit but contact RP for additional surveying. No alarm, individual may remove the item.

e. RP will determine the cause of the alarm and decontaminate the item as appropriate.

f. RP will place item in TEM after decontamination. No alarm the item may be released

g. Any item which cannot clear a TEM will be controlled as radioactive material and labeled in accordance with NISP-RP-04, Radiological Posting and Labeling.⁷

1.2 Release of non-personal items

1.2.1 Non-personal items such as tools, plant components, parts, or other solid items can be released using the following method:

a. If internal contamination is suspected then the unit must be dissembled so internal surfaces can be surveyed. If the internal conditions cannot be verified the item is to be controlled as radioactive material.⁵

b. If alpha contamination is suspected (i.e. from an Alpha Level 3 area) then complete a direct/ loose surface alpha survey.

c. If no detectable activity is noted during internal or alpha contamination surveys then place the item in the center of a TEM and activate the count cycle.

d. If pure beta contamination is suspected, then complete a direct/loose surface beta survey.

e. If the item is too large to place inside a TEM then contact RP Supervision for proper survey methods to release the item.

f. If the item had been disassembled it must be placed back into the same configuration for monitoring as it will be used once free released. It cannot be released piece by piece.

1.2.2 Survey methodology has been defined for computers, video monitors, breakers, cameras, gauges and power tools in Attachment 4, Unconditional Release of Certain Equipment.

1.2.3 For the release of a large volume of equipment, or for the release of very large items, a survey plan should be developed using Attachment 3, Unconditional Release Survey Plan.

1.2.4 If the TEM does not alarm, and direct frisk surveys are equivalent to background, then the item may be released.

1.2.5 If the item is released by survey methods other than a TEM then document the release on Attachment 1, Unconditional Release Survey.

1.2.6 If an alarms occurs on the TEM, then initiate a second count as per posted instructions. If no alarm occurs item can be released. If second alarms occurs take the following actions:

a. Using proper contamination controls remove the item from the monitor and determine the cause of the alarm.⁴

b. Take appropriate actions such as decontaminate the component or removed the item causing the alarm.

c. Re-monitor the item after corrective actions have been taken. If the item had been disassembled it must be placed back into the same configuration for monitoring as it will be used once free released. It cannot be released piece by piece.

d. If alarms or indications of radioactive material are still present then control the item in accordance with procedure NISP-RP-04, Radiological Posting and Labeling.⁷

e. If no indications of activity above background the item may be free released.

1.2.7 Personnel clothing, which had been contaminated and deconned, can be released after direct frisk of the affected area has been completed, or the item successfully passes the TEM with no indications of radioactivity.

1.3 Release of Liquids

3.3.1 Site specific procedures will provide guidance for sample methods for liquids including the sample container and volume requirements.⁹

3.3.2 Liquids can only be released after a review of all analysis has been completed.

3.3.3 Liquids should be analyzed for tritium if there is the potential for tritium activity to be present.

3.3.4 Ensure a representative sample of the liquid is obtained. This may require the liquid to be mixed or recirculated to ensure some contaminates have not separated in the liquid.⁶

3.3.5 Control the liquid as radioactive material until the sample indicates it can be free released.

3.3.6 Liquids can be free released once the analysis indicates the activity is below the environmental LLD values (i.e. no detectable activity) for both gamma emitters and tritium (as applicable) or contains only naturally occurring isotopes.

3.3.7 Once the sample analysis has been reviewed and indicates the liquid is releasable, survey the exterior container to ensure it is free of radioactive material by completing a smear and direct frisk.

3.3.8 Consider other controls which may be required for the liquids such as flammable, safety, or environmental toxic hazards.

1.4 Release of Bulk or Aggregate Materials

1.4.1 Site specific procedures will provide guidance for sample methods for bulk or aggregate materials including the sample container and volume requirements.

1.4.2 Bulk or aggregate material can only be released after a review of all analysis has been completed.

1.4.3 Ensure enough samples are taken of the bulk or aggregate material to determine the radiological characteristic of the overall volume. The sample plan should be approved by RP Supervision.

1.4.4 Examples of bulk or aggregate materials are sand, soil, concrete rubble, gravel, resins or other types of material where the concentration of radioactive material is expected to be uniform if present.

1.4.5 If the bulk or aggregate material is concrete, or from a location where a radioactive liquid spill could have occurred, consider the need for sampling for tritium contamination.

1.4.6 Bulk or aggregate materials should be controlled as radioactive material until sample results indicate it can be free released.

1.4.7 Bulk or aggregate material can be released once sample analysis indicates only the presence of naturally occurring radioisotopes or all isotopes is below environmental LLD values.⁸

1.5 Control of Radioactive Material Temporarily Released

1.5.1 With RP Supervisor approval, items which have been surveyed and found to be radioactive can be temporarily released based on the following criteria:

a. Item is labeled as radioactive material in accordance with NISP-RP-04, Radiological Posting and Labeling.

b. No loose surface contamination

c. No potential for spills or leaks

d. Item is being transported to an area that satisfies NISP-RP-04, Radiological Posting and Labeling, and proper radiological controls have been established.

e. Individual transporting the material is logged in on the appropriate RWP and understands the requirements of transporting the material directly to the radioactive materials area.

f. The dose rate on the item is <2.0 mrem/hr at 30cm.

1.5.2 Conditionally released items are to be documented on Attachment 2, Radioactive Material Log or similar document.

1.6 Storage of Radioactive Material

1.6.1 If the amount of licensed material stored in an area or room exceeds 10 times the quantity specified in 10CFR20, Appendix C, then the area is required to be posted in accordance with NISP-RP-04, Radiological Posting and Labeling.

1.6.2 If the potential exist for the movement of radioactive material to change the dose rates at the boundary of the storage area then radiation protection will perform a survey and document the radiological conditions.

1.6.3 Consider the following potential impacts before radioactive material is stored inside the RCA.

a. Impacts on low dose waiting areas

b. Impacts on ALARA estimates

c. Impacts on plant operating systems such as Area Radiation Monitors

d. Potential for contamination spread

e. Potential for spill of liquids into clean areas or clean systems

f. Impacts on fire loading and fire zones

g. General housekeeping

1.6.4 Contact the appropriate site personnel for instructions for storage of mixed hazardous waste or material. Some common mixed waste hazards are batteries, chemicals, and combustible liquids.

1.6.5 Items placed in storage should be clearly labeled in accordance with NISP-RP-04,Radiological Posting and Labeling, showing all radiological hazards and the contents of the package. Label should be attached in a manner to be easy to read.

1.6.6 Items must be stored in containers suitable to prevent the spread of contamination. The container design should take into consideration the expected duration the item is projected to be in storage. Containers should be subjected to periodic inspections to ensure they do not degrade over time.

1.6.7 Radioactive material stored in outside areas where the material is subject to exposure to weather hazards should meet the following requirements:

a. Be contained in water tight containers with the lids secured in place. If the size of the object is too large to fit inside a manufactured container contact RP Supervision for direction on the proper storage method.

b. Boxes or containers are inspected for leaks prior to being loaded

c. Containers are staged/stored in areas not subject to flooding

1.7 Movement of Radioactive Material

1.7.1 All radioactive material shall be properly labeled in accordance with NISP-RP-04,Radiological Posting and Labeling, prior to be transported from one location to another.

1.7.2 The individual transporting the material has the responsibility to ensure it reaches its final destination and is inside a properly posted area.

1.7.3 The potential impact on plant operating equipment must be considered when transporting radioactive material. Radiation and Process monitor set points should be understood before transporting material in close proximity.

1.7.4 If the potential exist for the movement of radioactive material to change the dose rates at the boundary of the storage area then radiation protection will perform a survey and document the radiological conditions.

1.7.5 The movement of highly radioactive material can impact the sites 10CFR37 security requirements. Prior to movement contact RP Supervision to determine the potential impacts to the stations 10CFR37 implementation plan.

1.7.6 The individual who is transporting the material has the responsibility to be aware of all the hazards associated with it including both radiological and industrial.

1.7.7 Radiation workers may transport radioactive material inside the RCA with dose rates which are <100 mrem/hr contact and < 4 mrem/hr at 30cm as long as the following conditions have been met:

a. The item has been labeled in accordance with NISP-RP-04, Radiological Posting and Labeling

b. The item is properly contained to prevent the spread of contamination

1.7.8 Radiation workers may transport radioactive material inside the RCA with dose rates > 4 mrem/hr at 30cm but <100 mrem/hr at 30cm as long as the following conditions have been met:

a. The item has been labeled in accordance with NISP-RP-04, Radiological Posting and Labeling

b. RP approves the movement of the item to the new storage location and agrees to the transport route and determines the radiological controls.

c. The area is properly posted and the addition of the item will not change the radiological boundaries

d. The item is properly contained to prevent the spread of contamination

1.7.9 Radiation protection must escort all radioactive material with a dose rate > 100 mrem/hr at 30cm.

1.7.10 Radiation workers may transport radioactive material outside the RCA between established posted radioactive material storage areas as long as the following conditions have been met:

a. Notify Radiation Protection for approval prior to transport

b. The item has been labeled in accordance with NISP-RP-04, Radiological Posting and Labeling

c. The item is properly contained to prevent the spread of contamination

d. The dose rate on the item is < 4 mrem/hr at 30cm and <100 mrem/hr contact.

1.7.11 Radiation protection must escort all radioactive material with a dose rate > 4 mrem/hr at 30cm or >100 mrem/hr contact outside the RCA.

2.0 Clarifying Notes

1 Site specific procedure may contain a list of additional personal items that radworkers can monitor through the TEM.

2 When attempting to release components or parts it is essential to understand where the item originated from and the potential radiological hazard so that proper surveys can be performed. Items from waste gas or similar systems can be contaminated with pure beta emitters and must be surveyed with the appropriate instrument capable of measuring beta activity.

3 Extreme care must be taken when surveying items with radioactive sources so that the source is not damaged in the process. In addition use a survey method that would detect if the source was leaking (e.g., An AM-241 sealed source should be smeared and counted using the appropriate survey instrumentation to detect alpha contamination).

4 Wear gloves as a minimum for removing items and performing additional surveys.

5 To determine the potential for internal contamination it is important to understand how the item was used and where it came from and the history of the station. Items removed from systems with contaminated liquid or gas should be suspected to have internal contamination. However non-radioactive system components can become contaminated through leaks or spills over the history of the plant.

6 Over time contaminates can settle to the bottom of the storage container. In addition some contaminants may be suspended or trapped in oil which may rise to the surface. The sample method has to be designed to ensure you are getting a true representative sample of the contents.

7 Items which have been proved to contain only naturally occurring isotopes do not have to be labeled as radioactive material.

8 Cesium-137 may be detected in bulk materials, such as soil, as a result from fallout from atomic bomb testing. Sites may develop technical papers determining the amount of CS-137 found in soil, or other bulk materials, and include those values as part of the sites background determination.

9 Liquids cannot be released by monitoring only in a TEM but must include sample analysis.

3.0 References

3.1 EPRI 1019224, Radioactive Material Monitoring and Control Guideline

3.2 INPO 05-008, Guideline for Radiological Protection at Nuclear Power Stations

Attachment 1: Unconditional Release Survey - Sample