DOE-STD-1098-99 Reaffirmed 2004, Radiological Control

NOT MEASUREMENT SENSITIVE DOE-STD-1098-99 July 1999 Reaffirmation December 2004 DOE STANDARD RADIOLOGICAL CONTROL U.S. Department of Energy AREA SAFT Washington, D.C. 20585 DISTRIBUTION STATEMENT A. Approved for public release; distribution is unlimited. ii This document has been reproduced directly from the best available copy. Available to DOE and DOE contractors from ES&H Technical Information Services, U.S. Department of Energy, (800) 473-4375, fax (301) 903-9823. Available to the public from the U.S. Department of Commerce, Technology Administration, National Technical Information Service, Springfield, VA 22161; (703) 605-6000. iii Changes to DOE-STD-1098-99, “Radiological Control” Page/Section/Paragraph Change Page iii, Header and throughout Change July 1999 to June 2004 Page 13, Section 127, paragraph 2 Change DOE O 232.1 to DOE O 231.1A Page 14, Section 131 First paragraph Remove introductory paragraph. DOE O210.1 archived 9/27/95 Page 22, Section 151, paragraph 2 Add ”s” to” Operations Office” and change “Field Office Managers” to “Field Organization Managers” Page 23, Section 155, paragraph 1 paragraph 4 Change “Office of Defense Programs” to “National Nuclear Security Administration” Add “Field Organizations” after “Operations Offices” Page 3-3, Section 312, paragraph 2 Change DOE O 440.1 to DOE O 440.1A Page 3-23, Section 361 paragraph 2 Section 362, paragraph 2 Update reference DOE-STD-1128-98, Guide to Good Practices for Occupational Radiological Protection in Plutonium Facilities (Reaffirmation with Errata, May 2003) Change reference EG&G-2530, Health Physics Manual of Good Practices for Uranium Facilities, to DOE-STD-1136- 2000, Guide of Good Practices for Occupational Radiological Protection in Uranium Facilities Page 4-13, Section 441, paragraph 1 Change DOE O 5820.2A to DOE O 435.1 Page 6-16, Section 661 Section 662 Change DOE/EH-0425, Plutonium Facility Training to DOE-STD-1128-98, Guide to Good Practices for Occupational Radiological Protection in Plutonium Facilities Change DOE-HDBK-1113-98, Radiological Safety Training for Uranium Facilities to DOE-STD-1136-2000, Guide of Good Practices for Occupational Radiological Protection in Uranium Facilities iv THIS PAGE INTENTIONALLY LEFT BLANK DOE-STD-1098-99 Radiological Control Foreword June 2004 v Foreword The Department of Energy (DOE) has developed this Standard to assist line managers in meeting their responsibilities for implementing occupational radiological control programs. DOE has established regulatory requirements for occupational radiation protection in Title 10 of the Code of Federal Regulations, Part 835 (10 CFR 835), Occupational Radiation Protection, amended 1998. Failure to comply with these requirements may lead to appropriate enforcement actions as authorized under the Price Anderson Act Amendments (PAAA). While this Standard does not establish requirements, it does restate, paraphrase, or cite many (but not all) of the requirements of 10 CFR 835 and related documents (e.g., occupational safety and health, hazardous materials transportation, and environmental protection standards). Because of the wide range of activities undertaken by DOE and the varying requirements affecting these activities, DOE does not believe that it would be practical or useful to identify and reproduce the entire range of health and safety requirements in this Standard and therefore has not done so. In all cases, DOE cautions the user to review any underlying regulatory and contractual requirements and the primary guidance documents in their original context to ensure that the site program is adequate to ensure continuing compliance with the applicable requirements.

To assist its operating entities in achieving and maintaining compliance with the requirements of 10 CFR 835, DOE has established its primary regulatory guidance in the DOE G 441.1 series of Guides. The Guides are structured to assist radiation protection professionals in developing the documented radiation protection program required by 10 CFR 835.101 and the supporting site- and facility-specific policies, programs, and procedures that are necessary to ensure compliance with the related regulatory requirements. The Guides establish a macroscopic view of the various elements of a comprehensive radiation protection program and discuss concepts that the cognizant professionals should consider in developing and implementing the site- and facility-specific programs. This Standard supplements the DOE G 441.1 series of Guides and serves as a secondary source of guidance for achieving compliance with 10 CFR 835. While there is significant overlap between the DOE G 441.1 series of Guides and this Standard, this Standard differs from the Guides in both intent and detail. In contrast to the macroscopic view adopted by the Guides, this Standard discusses specific measures that should be implemented by affected line managers, workers, and support staff to ensure proper fulfillment of their radiological control responsibilities. DOE expects that each site will identify the provisions of this Standard that support its efforts to implement an effective radiological control program and incorporate these provisions, as appropriate, into the site-specific radiological control manual, site procedures, training, or other administrative instruments that are used to guide employee activities. The specific administrative instruments used at DOE sites vary widely, as would be expected given the varying nature of DOE facilities and activities and their associated hazards. Both the science of health physics and the practice of radiological control are relatively new and continue to evolve at a rapid rate. DOE encourages the users of this Guide to submit comments regarding its content, accuracy, and utility. DOE-STD-1098-99 Radiological Control DOE Policy June 2004 vi THIS PAGE INTENTIONALLY LEFT BLANK DOE-STD-1098-99 Radiological Control DOE Policy June 2004 vii Following is a reprint of the Department of Energy Radiological Health and Safety Policy, which was originally published as DOE P 441.1 on April 26, 1996. DEPARTMENT OF ENERGY Radiological Health and Safety Policy It is the policy of DOE to conduct its radiological operations in a manner that ensures the health and safety of all its employees, contractors, and the general public. In achieving this objective, the Department shall ensure that radiation exposures to its workers and the public and releases of radioactivity to the environment are maintained below regulatory limits and deliberate efforts are taken to further reduce exposures and releases as low as reasonably achievable. The Department is fully committed to implementing a radiological control program of the highest quality that consistently reflects this policy. In meeting this policy, the Department shall: A. Establish and maintain a system of regulatory policy and guidance reflective of national and international

radiation protection standards and recommendations. The Assistant Secretary for Environment, Safety and Health has responsibility for promulgating and maintaining policies, standards, and guidance related to radiological protection. Departmental radiological protection requirements are, at a minimum, consistent with the presidentially approved "Radiation Protection Guidance to the Federal Agencies for Occupational Exposure" which was developed by the Environmental Protection Agency in accordance with its mandated Federal guidance responsibilities. Departmental requirements often are more stringent and reflect, as appropriate, recommendations and guidance from various national and international standards-setting and scientific organizations, including the International Commission on Radiological Protection, the National Council on Radiation Protection and Measurements, the American National Standards Institute, and others. Departmental requirements related to radiological protection will be set forth, as appropriate, in rules and Department of Energy Orders, and guidance documents will be issued on acceptable means to implement these requirements. B. Ensure personnel responsible for performing radiological work activities are appropriately trained. Standards shall be established to ensure the technical competency of the Department's work force, as appropriate, through implementation of radiological training and professional development programs. C. Ensure the technical competence of personnel responsible for implementing and overseeing the radiological control program. An appropriate level of technical competence gained through education, experience, and job-related technical and professional training is a critical component for achieving the goals of the Department's radiological control policy. Qualification requirements commensurate with this objective shall be established for technical and professional radiological control program positions and shall, at a minimum, be consistent with applicable industry standards and promote professional development and excellence in radiological performance as a goal. DOE-STD-1098-99 Radiological Control DOE Policy June 2004 viii D. Establish and maintain, at all levels, line management involvement and accountability for departmental radiological performance. The responsibility for compliance with Departmental radiological protection requirements, and for minimizing personnel radiation exposure, starts at the worker level and broadens as it progresses upward through the line organization. The Department's line managers are fully responsible for radiological performance within their programs and the field activities and sites assigned to them, and shall take necessary actions to ensure requirements are implemented and performance is monitored and corrected as necessary. E. Ensure radiological measurements, analyses, worker monitoring results and estimates of public exposures are accurate and appropriately made. The capability to accurately measure and analyze radioactive materials and workplace conditions, and determine personnel radiation exposure, is fundamental to the safe conduct of radiological operations. Policy, guidance, and quality control programs shall be directed towards ensuring such measurements are appropriate, accurate, and based upon sound technical practices. F. Conduct radiological operations in a manner that controls the spread of radioactive materials and

reduces exposure to the workforce and the general public and that utilizes a process that seeks exposure levels as low as reasonably achievable. Radiological operations and activities shall be preplanned to allow for the effective implementation of dose and contamination reduction and control measures. Operations and activities shall be performed in accordance with departmental conduct of operations requirements and shall include reasonable controls directed toward reducing exposure, preventing the spread of radiological contamination, and minimizing the generation of contaminated wastes and the release of effluents. G. Incorporate dose reduction, contamination reduction, and waste minimization features into the design of new facilities and significant modifications to existing facilities in the earliest planning stages. Wherever possible, facility design features shall be directed toward controlling contamination at the source, eliminating airborne radioactivity, maintaining personnel exposure and effluent releases below regulatory limits and utilizing a process that seeks exposure levels and releases as low as reasonably achievable. Radiological design criteria shall reflect appropriate consensus recommendations of national and international standards setting groups. H. Conduct oversight to ensure departmental requirements are being complied with and appropriate radiological work practices are being implemented. All departmental elements shall conduct their radiological operations in a manner consistent with the above policies and objectives. IMPORTANT NOTE DOE Policy 450.4 establishes DOE policy with regard to integrated safety management (ISM) . The principles of ISM and relationship between DOE’s ISM Policy and the provisions of this Standard are discussed in Article 118 of this Standard. DOE-STD-1098-99 Radiological Control Table of Contents June 2004 ix FOREWORD DOE POLICY CHAPTER 1 EXCELLENCE IN RADIOLOGICAL CONTROL PART 1 Department of Energy (DOE) Radiological Control Standard PART 2 Leadership in Radiological Control PART 3 Improving Radiological Control Performance PART 4 Contractor Radiological Control Organization PART 5 DOE Management CHAPTER 2 RADIOLOGICAL STANDARDS PART 1 Administrative Control Levels and Dose Limits PART 2 Contamination Control and Control Levels PART 3 Posting CHAPTER 3 CONDUCT OF RADIOLOGICAL WORK PART 1 Planning Radiological Work PART 2 Work Preparation PART 3 Entry and Exit Requirements PART 4 Radiological Work Controls PART 5 Evaluation of Performance PART 6 Special Applications PART 7 [Reserved] PART 8 Design and Control CHAPTER 4 RADIOACTIVE MATERIALS PART 1 Radioactive Material Identification, Storage and Control PART 2 Release and Transportation of Radioactive Material PART 3 Sealed Radioactive Source Controls PART 4 Solid Radioactive Waste Management PART 5 Control of Radioactive Liquids and Airborne Radioactivity PART 6 Support Activities CHAPTER 5 RADIOLOGICAL HEALTH SUPPORT OPERATIONS PART 1 External Dosimetry PART 2 Internal Dosimetry PART 3 Respiratory Protection Program PART 4 Handling Radiologically Contaminated Personnel PART 5 Radiological Monitoring PART 6 Instrumentation and Calibration DOE-STD-1098-99 Radiological Control Table of Contents June 2004 x CHAPTER 6 TRAINING AND QUALIFICATION

PART 1 Radiological Control Training and Qualification PART 2 General Employee Radiological Training PART 3 Radiological Worker Training PART 4 Radiological Control Technician and RCT Supervisor Qualification PART 5 Other Radiological Training PART 6 Training For Special Applications CHAPTER 7 RADIOLOGICAL CONTROL RECORDS PART 1 General Provisions PART 2 Employee Records PART 3 [Reserved] PART 4 Radiological Control Procedures PART 5 Radiological Monitoring PART 6 Instrumentation and Calibration Records PART 7 Records Management PART 8 Radiological Reporting REFERENCES GLOSSARY INDEX TABLES 1-1 Suggested Radiological Performance Indicators 2-1 Summary of Occupational Dose Limits 2-2 Summary of Surface Contamination Values 2-3 Criteria for Posting Radiation Areas 2-4 Criteria for Posting Contamination, High Contamination, and Airborne Radioactivity Areas 3-1 Radiological Control Training Guidelines 3-2 Guidelines for Selecting Protective Clothing (PC) 4-1 Radioactive Material Labeling 4-2 Exceptions from Radioactive Material Labeling Requirements FIGURE 2-1 Establishing Posted Areas DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −1 CHAPTER 1 EXCELLENCE IN RADIOLOGICAL CONTROL TABLE OF CONTENTS Article Page PART 1 Department of Energy (DOE) Radiological Control Standard 111 Radiological Health and Safety Policy...............................................................................................................1-3 112 Standard Applicability and Control....................................................................................................................1-3 113 Implementation ..................................................................................................................................................1-4 114 Site-Specific Manual..........................................................................................................................................1-4 115 Application of Provisions...................................................................................................................................1-5 116 User Groups .......................................................................................................................................................1-5 117 The “As Low As Is Reasonably Achievable” Process .......................................................................................1-6 118 Integrated Safety Management...........................................................................................................................1-6 PART 2 Leadership in Radiological Control 121 Senior Management Commitment......................................................................................................................1-8 122 Worker Attitude .................................................................................................................................................1-9 123 Worker Responsibilities .....................................................................................................................................1-9 124 Radiation and Risk Communications ...............................................................................................................1-11 125 Conduct of Radiological Operations ................................................................................................................1-11 126 Improving Worker Awareness of Radiological Conditions .............................................................................1-12 127 Critiques...........................................................................................................................................................1-13 128 Facility Modifications and Radiological Design Considerations .....................................................................1-13

PART 3 Improving Radiological Control Performance 131 Radiological Performance Goals......................................................................................................................1-14 132 Management of Radiological Control Goals and Performance Indicators .......................................................1-14 133 Radiological Control Performance Reports......................................................................................................1-15 134 Assessments .....................................................................................................................................................1-17 135 Workplace Awareness......................................................................................................................................1-18 136 Internal Exposures............................................................................................................................................1-18 137 Neutron Exposures ...........................................................................................................................................1-19 138 ALARA Committee .........................................................................................................................................1-19 DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −2 Article Page PART 4 Contractor Radiological Control Organization 141 Radiological Control Organization ..................................................................................................................1-20 142 Radiological Control Manager Qualifications..................................................................................................1-20 143 Radiological Control Organization Functions and Staffing .............................................................................1-21 144 Relationship Between Radiological Control Technicians and Workers...........................................................1-21 145 Marginal Radiological Control Performance ...................................................................................................1-21 PART 5 DOE Management 151 Program Office.................................................................................................................................................1-23 152 Operations Offices and Applicable Field Offices.............................................................................................1-23 153 Department Policy............................................................................................................................................1-23 154 Departmental Independent Radiological Control Performance Oversight .......................................................1-23 155 Radiological Control Coordinating Committee................................................................................................1-24 156 DOE Employees in the Workplace ..................................................................................................................1-24 Table 1-1 Suggested Radiological Performance Indicators ..............................................................................................1-16 Last Page........................................................................................................................1-24 DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004

−3 PART 1 Department of Energy (DOE) Radiological Control Standard 111 Radiological Health and Safety Policy A key element of the Radiation Protection Guidance to the Federal Agencies for Occupational Exposure approved by President Reagan on January 20, 1987, and a fundamental principle underlying this Standard is: "There should not be any occupational exposure of workers to ionizing radiation without the expectation of an overall benefit from the activity causing the exposure." The Department of Energy is firmly committed to having a radiological control program of the highest quality. This commitment is reflected in the DOE Radiological Health and Safety Policy reproduced at the beginning of this Standard. 112 Standard Applicability and Control DOE has established basic standards for occupational radiation protection in Federal regulation 10 CFR part 835, "Occupational Radiation Protection" (10 CFR 835). Section 835.101 of 10 CFR 835 requires affected DOE activities to be conducted in compliance with a documented radiation protection program (RPP) that addresses each requirement of that regulation. DOE’s 441.1 series of Guides provide guidance for developing and implementing an RPP sufficient to ensure compliance with 10 CFR 835. The DOE 441.1 series of Guides are primarily directed toward radiological control organization professionals who are responsible for developing programs that will ensure regulatory compliance. The Guides therefore tend to provide flexibility for the use of professional judgment and are more technical and general in nature than this Standard. This Standard is primarily directed toward line management; it therefore discusses specific, detailed measures that should be implemented by line managers as they discharge their radiological control responsibilities. However, because both the DOE 441.1 series of Guides and this Standard discuss development and implementation of appropriate radiological controls, there are necessarily many overlaps. As a result, in the documented RPPs developed to ensure compliance with 10 CFR 835, most DOE facilities have committed to implementation of certain provisions of this Standard or its predecessor, the DOE Radiological Control Manual. The radiological control program discussed in this Standard goes beyond the scope of, and includes more details than, the documented RPP required by 10 CFR 835. To ensure implementation of a comprehensive and coherent radiological control program that exceeds basic requirements and provides a substantial safety margin, DOE encourages its contractors to implement the provisions of this Standard to the extent appropriate to facility hazards and operations, consistent with DOE’s Integrated Safety Management Program. Should any conflicts arise between the site-specific radiological control manual (based on this Standard, see Article 114), and the documented RPP, the requirements of the documented RPP should take precedence. Such conflicts should be expeditiously resolved. The Standard is not a substitute for regulations; it is intended to be consistent with all relevant statutory and regulatory requirements and will be revised whenever necessary to ensure such consistency. Some of the Standard provisions, however, challenge the user to go well beyond minimum requirements. 1. This Standard is a living document. DOE intends to review and update provisions on a periodic basis to incorporate

lessons learned and suggestions for improvement. The Assistant Secretary for Environment, Safety and Health is responsible for this task. Recommendations to correct or improve this Standard are encouraged and should be processed in accordance with DOE’s published guidance for providing comments on documents in the DOE technical standards system. 2. This Standard will be kept current and should be entered into the contractor document control system. The Office of Environment, Safety and Health will ensure that a current version of this Standard is maintained on the DOE Technical Information System (TIS). DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −4 113 Implementation 1. This Standard sets forth DOE's views on the proper course of action in the area of radiological control within the scope of DOE-sponsored activities. The words "shall" and "should" have the meaning below when used in this Standard. 2. The word "shall" identifies those elements and requirements that DOE has considered and found to be mandatory due to their derivation from related regulatory requirements found in 10 CFR 835 or other regulations or DOE orders. These requirements are indicated by a bracketed reference following the related Standard provision (e.g., [see 835.XXX]). For purposes of regulatory and contractual compliance, DOE encourages users of the Standard to refer to the source document to view the requirement in context and to determine the applicability of the requirement to the specific facility operations and hazards. Federal regulation 10 CFR part 820, Procedural Rules for DOE Nuclear Activities, establishes requirements for obtaining exemptions from DOE regulatory requirements. Due to its primary focus on line management implementation strategies, the Standard does not address all of the requirements of 10 CFR 835. 3. The word "should" means DOE has evaluated the provision and found that it is a proven practice or remedy that supports compliance with the basic requirements found in applicable regulations or DOE Orders or their underlying basis documents for occupational radiation protection.. The use of "should" recognizes that: 1) there may be site- or facility-specific attributes that warrant special treatment; 2) the safety benefit derived from implementation of the provision may not in all cases be commensurate with the associated detriments (e.g., financial cost, worker discomfort, schedule impacts); and 3) literal compliance with the provision may not achieve the desired level of radiological control performance. Although a contractor may decide to follow an alternative technique, approach, or method in lieu of the "should" provision, DOE encourages implementation of these provisions to ensure compliance with the underlying basic requirements. 4. The term "Article" is used to reference portions or sections of this document. For ease of communications, portions of this document should be referred to as Articles. For example, the appropriate reference to this Article is Article 113.4. 114 Site-Specific Manual 1. The contractor senior site executive should issue and endorse a site-specific radiological control manual that

invokes the applicable provisions of this Standard. The site-specific radiological control manual does not require review or approval by DOE-EH. One approach in the development of site-specific radiological control manuals is to invoke the applicable provisions of this Standard as written with site specific additions, supplements, and clarifications clearly indicated, included in the appropriate chapters, and directly referenced to the corresponding article. The provisions of specific articles may be changed from “should” to “shall” on a site-specific basis as necessary to emphasize those measures that are deemed necessary for compliance or to ensure the desired level of safety. Additions and supplements to address unique situations or to provide more detailed or prescriptive direction may be included. 2. Management policies, requirements, expectations, and objectives for the site radiological control program should be clearly and unambiguously stated. 3. The site-specific manual should be kept current and entered into the contractor document control system. 4. If a site has multiple facilities, there should be one manual for the site and one radiological control organization. If a prime contractor manages several DOE sites, efforts should be made to have one corporate radiological control manual that applies to all of that prime contractor's DOE sites. For a site that has multiple prime contractors, a common manual, with facility-, contractor-, or building-specific guidance to accommodate unique considerations, should be issued and endorsed by each contractor's senior site executive. For prime contractors who manage DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −5 several sites but who also operate sites with more than one prime contractor, the site manual should take precedence over the corporate radiological control manual. 5. Subcontractors should comply with the site-specific radiological control manual. 6. Where DOE employees are conducting the transport of nuclear devices or components, a program-specific radiological control manual, based upon the provisions of this Standard, should be issued and approved by the DOE Operations Office Manager. Controlled copies of such manuals should be provided to the Secretarial Officer having primary responsibility for operations at the site. 115 Application of Provisions 1. This Standard assumes that most facilities or sites have organizations in place that generally meet the provisions presented in the text. It is not the intent of this Standard to unnecessarily create new or separate organizations if those functions can be incorporated into existing ones. Existing organizational and committee charters should be revised to reflect the provisions and emphasis of this Standard. Similarly, titles such as “radiological control manager” and “radiological control technician” that are used in the Standard may locally be designated differently. A phased approach to transition to the use of the titles of positions in this Standard should be adopted. Corresponding position descriptions and organizational charts should be revised to accurately reflect required radiological control responsibilities. 2. The degree of program formality and extent of the associated administrative process should be commensurate with

the extent of existing and potential radiological hazards. For example, a site with an annual collective total effective dose equivalent of one person-rem or less, that works with small quantities of unsealed radioactive material, would not be expected to have a radiological control program as complex as one required at higher hazard sites. At lower hazard sites, some program elements may be satisfied by brief policy statements. 116 User Groups 1. DOE encourages its contractors to establish informal working associations that promote dialogue among the radiological control organizations from similar or comparable facilities. User Groups should include representation from various contractors. Assignment of members to the user groups should be on a rotating basis. 2. To assist contractors in identifying and adopting proven practices and implementing procedures in a timely manner within the DOE complex, DOE encourages its contractors to develop, through the User Groups, Radiological Work Practices Handbooks that can be used by a given category or class of facilities associated with the User Group. DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −6 117 The “As Low As Is Reasonably Achievable” Process 10 CFR 835 requires DOE activities to develop and implement plans and measures to maintain occupational radiation exposures as low as is reasonably achievable (ALARA) [see 10 CFR 835.101 and 835.1001]. As applied to occupational radiation exposure, the ALARA process does not require that exposures to radiological hazards be minimized without further consideration, but that such exposures be optimized, taking into account both the benefits arising out of the activity and the detriments arising from the resultant radiation exposures and the controls to be implemented. An effective ALARA process includes effective consideration, planning, and implementation of both physical design features (including engineering controls) and administrative controls to balance the risks of occupational radiation exposure against the benefits arising out of the authorized activity. Lessons learned are documented, institutionalized, and considered in planning and executing subsequent activities to further the goals of the ALARA process and to provide optimal employee protection. While most or all of the provisions of this Standard support the ALARA process, the provisions of Chapter 3 are specifically directed toward the planning and execution of work, physical design features and administrative controls, and efforts to implement work controls commensurate with the radiological hazards. 118 Integrated Safety Management DOE requires its contractors to develop and implement an Integrated Safety Management system (ISM) that integrates safety (including radiological safety) into management and work practices at all levels (See DOE Policy P 450.4 and its associated guidance documents). DOE intends for the provisions of this Standard to be consistent with, and to complement implementation of, ISM. This Standard supports ISM by providing a system of radiological controls that can be implemented on a site-wide basis and tailored to meet facility-and hazard-specific needs. This Standard also provides guidance for increasing worker involvement in identification and implementation of appropriate controls. Like the ALARA process, an effective integrated safety management system emphasizes the development and implementation of controls that are commensurate with the hazards associated with any specified activity.

1. Under ISM, both DOE and DOE-contractor line managers are charged with responsibility for integrating safety measures into all facets of work planning and execution. Line managers should use this Standard as a guide to integrating radiological control measures into work planning and execution. 2. This Standard supports the ISM guiding principles as follows: · Line Management Responsibility - This Standard clearly indicates that line management is responsible for ensuring adequate implementation of the radiological control program. · Clear Roles and Responsibilities - This Standard establishes clear roles and responsibilities for DOE and contractor line management and for the radiological control organization. · Competence Commensurate with Responsibilities - This Standard provides guidance for providing classroom and on-the-job training so that individuals may gain and maintain the appropriate competence. · Identification of Safety Standards and Requirements - This Standard provides cross-references to other DOE, Federal Agency, scientific, and consensus standards that are important to developing and implementing an effective and comprehensive radiological control program. DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −7 · Hazard Controls Tailored to Work Being Performed - This Standard provides guidance for implementing a program that establishes radiological controls that are commensurate with the hazards and that provide flexibility for consideration of other hazards (e.g., industrial safety, industrial hygiene, environmental hazards). The concepts of Balanced Priorities and Operations Authorization are outside the scope of this Standard. 3. Both the ISM and ALARA processes require hazard controls to be tailored to the work being performed. In addition to establishing basic radiological safety standards that must be observed, 10 CFR 835 establishes requirements that provide significant flexibility so that individual activities may implement compliance measures in a manner that is commensurate with specific hazards and work activities. This Standard provides guidance for implementing radiological controls that DOE has evaluated and found to meet the requirements of 10 CFR 835 and to be consistent with the specified conditions and activities. For example: · Chapter 3 of this Standard provides guidance for implementing access and egress controls for areas having specific radiological conditions and hazards. · Chapter 4 of this Standard provides guidance for implementing specific controls over radioactive materials. · Chapter 5 of this Standard provides guidance for performing radiological monitoring at specified frequencies consistent with known and likely radiological hazards. · Chapter 6 of this Standard provides guidance for providing training to ensure that individuals are able to discharge their responsibilities related to the radiological control program. DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −8 PART 2 Leadership in Radiological Control

Superior, consistent performance is achieved when qualified individuals use approved procedures and management actively monitors the workplace and assesses ongoing activities. Such ongoing activities include, but are not limited to, operations, remediation, laboratory work, research and development, and cleanup. Constant review and informed interest by senior management are required to achieve a superior radiological control program. Management at all levels should emphasize the need for high standards for radiological control through direct communication, instruction, and inspection of the work space. The DOE Operations Office Manager and the contractor senior site executive responsible for the site should have a basic knowledge of radiation, its effects, and radiological control requirements. The DOE Operations Office Manager and the contractor senior site executive should also be familiar with the current radiological control performance record. Key principles common in a successful, well-managed radiological control program are provided in this Chapter. 121 Senior Management Commitment 1. Senior managers should establish high standards for radiological control performance and frequently communicate these standards and management expectations to the work force. 2. Senior managers should state in writing their firm commitment to a radiological control program of the highest quality. Management commitment and support should be demonstrated, in part, by allocating sufficient resources, including personnel, and providing for training to ensure workers are qualified for their assigned duties. 3. Managers should ensure that orientation, training, and indoctrination reinforce rules and guidelines for each worker to control radiation exposure and radiological conditions. 4. Managers should hold workers and their supervisors accountable for radiological control performance. Relevant knowledge and performance should be assessed as a specific part of each individual's performance evaluation. This assessment should not be limited to those who perform radiological work, since many other workers have an impact on the radiological control program. 5. Senior managers should solicit feedback from their radiological control professionals, line management, and workers on radiological control performance. 6. Senior managers should adopt and promote a positive attitude toward radiological control that encourages initiatives to identify concerns at an early stage, to prevent conditions from deteriorating, and to promote doing the right job correctly the first time. 7. Prevention of the spread of radioactive material is usually less costly than remediation. Management should be willing to accept change that will improve radiological control performance and should foster this mindset throughout the organization. 8. The authority and responsibility to establish a comprehensive and effective radiological control training program should be assigned to line managers and their subordinates. Training, in most cases, should be provided by a dedicated training organization, but the responsibility for quality and effectiveness rests with line management. 9. Senior managers should be alert to opportunities for minimizing the generation of radioactive waste and discharges to the environment, controlling contamination at its source, and reducing radiation exposure to workers and the public.

10. Reporting a problem to a superior (contractor or DOE) does not absolve the manager from promptly fixing or mitigating a situation. DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −9 122 Worker Attitude Control of worker radiation exposure can be achieved only if all individuals involved in radiological activities have an understanding of and the proper respect for radiological hazards. 1. Each worker should understand that proper radiological control is an integral part of his daily duties. 2. The training program should support efforts to improve the attitude of the work force. Training instructors should be knowledgeable about the work environment and those aspects of radiological control that are important to developing a better worker attitude and perspective. 3. The attitude that constant improvement is required in radiological work should be developed at all levels of management and in the work force. Cooperation between the work force and the radiological control organization should be developed and fostered. The workers should not look upon radiological controls as hurdles or restrictions to be bypassed. 4. Radiological control organization personnel should be helpful in showing workers how to follow the rules. This spirit of cooperation should be developed without subverting the control functions of the radiological control technicians. A situation in which radiological controls are left solely to the radiological control organization is unacceptable. 123 Worker Responsibilities Trained individuals should recognize that their actions directly affect contamination control, personnel radiation exposure, and the overall radiological environment associated with their work. The following radiological control rules are applicable to each individual in the workplace. A poster that displays basic worker responsibilities, such as those listed below, should be produced and displayed at appropriate access points and work areas. TO CONTROL YOUR RADIATION EXPOSURE AND RADIOACTIVE MATERIAL, OBSERVE THE FOLLOWING RULES: OBEY • Posted, written, and oral radiological control instructions and procedures, including instructions on radiological work permits. • "Evacuate" and "stop work" orders from radiological control personnel promptly. DO NOT • Loiter in radiation areas. • Smoke, eat, drink, or chew in contamination areas, high contamination areas, and airborne radioactivity areas. BE SURE TO • Wear personnel monitoring devices where required by radiological work permits, signs, procedures, or by radiological control personnel. Report immediately the loss, damage, or unexpected exposure DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −10 of personnel monitoring devices or off-scale readings of self-reading dosimeters to the radiological control organization. • Keep track of your radiation exposure status and avoid exceeding radiological administrative control levels. • Wear personal protective equipment and clothing properly whenever required by radiological 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. • Place contaminated tools, equipment, and solid waste items on disposable surfaces, such as plastic sheets, when not in use.

• Notify radiological control personnel of alarming or faulty radiological control equipment. • Notify radiological control personnel of off-site occupational radiation exposures so that worker dosimetry records can be updated. PRIOR TO ENTERING AREA • 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. • Have necessary materials and equipment on hand to complete your task, thereby minimizing time and exposure. • Notify radiological control personnel of the presence of open wounds, sores or rashes before entering an area where contamination exists and exit immediately if a wound occurs while in such an area. UPON LEAVING AREA • Properly remove personal protective equipment and clothing to minimize the spread of contamination. • Frisk or be frisked for contamination when entering an uncontaminated area after exiting contamination, high contamination, or airborne radioactivity areas and associated radiological buffer areas and notify radiological control personnel when contamination is found. 124 Radiation and Risk Communications DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −11 Due to the continuing concerns of many individuals related to low radiation exposure and health impacts, managers should be trained to deal with personnel perceptions concerning radiation risks. Managers and first-line supervisors should be sensitive to the fact that workers have to understand the fundamentals of radiation, its risks, and their role in controlling exposure. It is not sufficient to rely solely on regulatory limits for establishing or defining acceptable work practices and work environments. 1. Appropriate training in accordance with Article 651 is helpful in dealing with workers who have anxiety about radiation. 2. Some individuals, such as those who have had internal depositions of radionuclides, may be concerned about future doses. Such instances warrant special attention on the part of the manager. Counseling with such individuals is the preferred way to consider relevant factors. In some cases, special control levels as described in Article 216 should be applied. 125 Conduct of Radiological Operations 1. This Standard is consistent with the provisions of DOE 5480.19, Conduct of Operations Requirements for DOE Facilities. The concepts of all chapters of DOE 5480.19 apply to the conduct of radiological control activities. 2. Managers at all levels should be involved in the planning, scheduling, and conduct of radiological work. Assurance of adequate radiological safety should not be compromised to achieve production, remediation, or research objectives. 3. Supervisors should be technically knowledgeable and inquisitive and should ask questions of the work force concerning radiological work details to verify worker comprehension. 4. Line managers should periodically monitor work areas to observe personnel at work and to identify good radiological work practices and radiological deficiencies and concerns. Frequent inspections and walk-throughs, including off-hours and weekends (where appropriate), are essential to reinforce management expectations to the work force. 5. Managers, supervisors, and workers should be involved in the development of accurate, clear, written procedures

for performing radiological work. If during the use of procedures a written requirement cannot be responsibly followed, the work should be stopped and guidance obtained. 6. Supervisors and managers should encourage the work force to identify radiological control deficiencies and concerns. Prompt action should be taken to address and eliminate identified issues and prevent recurrence. Training, indoctrination, and procedure review are useful in addressing these issues. 7. Managers and supervisors should establish working conditions that encourage improved radiological control. This includes temperature, humidity, and lighting as well as the more difficult considerations of accessibility. Work conditions should be considered in planning work. 8. Cleanliness and good housekeeping are essential. A good radiological control program cannot exist in a sloppy, dirty workplace. Cleaning up after operations should be automatic for each person. It is not reasonable to expect radiological control to be separated from the work environment; they go together. 9. Subcontractors and subcontracted employees should be treated the same as facility staff in the area of radiological control matters, shall have comparable radiation safety training [see 835.901], and should meet the same requirements and expectations. DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −12 10. Conditions that could cause or promote the spread of contamination, such as a leaking roof or piping, should be identified and corrected on a priority basis. 126 Improving Worker Awareness of Radiological Conditions In performing assigned duties within radiological areas, workers should be familiar with the area radiological conditions and be aware of the possibility that unforeseen changes may occur. Although the conduct of radiological surveys is viewed as a traditional role of radiological control technicians, experience has shown that properly trained and qualified workers are capable of performing supplemental radiological surveys in the course of work. This process results in exposure savings and improved contamination control. Specific examples of surveys that may be effectively performed by workers and result in exposure reductions include self-monitoring of dose rates during high radiation area entries and monitoring of tools and equipment for contamination as a qualitative check during work in contamination areas. The performance of legal record surveys, such as release surveys, should remain the responsibility of the radiological control organization. DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −13 127 Critiques It is DOE’s desire and expectation, based on concern for the safety and well-being of workers and the general public, that radiological work practices be continually scrutinized and questioned so that opportunities for improvement can be identified, assessed, and applied. A formal critique process should be established to obtain pertinent facts following an unusual radiological situation or at the satisfactory conclusion of a new or unusual operation involving radiological controls. This process complements the Occurrence Reporting and Processing System (ORPS) of DOE O 231.1A, Occurrence Reporting and Processing of Operations Information. The process, as described in Article 351, is used to quickly establish facts in chronological order so that the underlying reasons or causes for the success or failure are well understood.

128 Facility Modifications and Radiological Design Considerations Radiological control performance is affected by human performance and engineered design features. This Standard primarily addresses the way individuals operate and use existing facilities and sites. General design criteria for new facilities and major modifications to existing facilities are provided in 10 CFR 835 and DOE O 420.1, Facility Safety. Additional design criteria are provided in Chapter 3. DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −14 PART 3 Improving Radiological Control Performance 131 Radiological Performance Goals 1. Collective Dose (person-rem): This goal should be based upon planned activities and historical performance. For those sites that have neutron radiation, a goal for collective neutron dose should also be established. 2. Skin and Personal Clothing Contamination Occurrences (number): Personnel contaminations may indicate a breakdown of controls intended to prevent the spread of contamination. 3. Intakes of Radioactive Material (number): Management should focus attention on any failure of the controls that results in unplanned intakes. 4. Contaminated Area Within Buildings (square feet): Operating with a smaller contaminated area may result in less radioactive waste, fewer personnel contaminations, and improved productivity. The reduction of existing contaminated areas should be balanced by the recognition that this generates radioactive waste. Goals for both should be correlated. 5. Radioactive Waste (cubic feet): Minimizing the generation of radioactive waste reduces the environmental impact of DOE operations, helps reduce personnel exposure, and reduces costs associated with handling, packaging, and disposal. 6. Liquid and Airborne Radioactivity Released (curies): Minimizing effluents reduces the environmental impact of DOE operations and reduces the costs associated with remediation. 132 Management of Radiological Control Goals and Performance Indicators 1. The contractor senior site executive should establish, approve, and maintain a radiological control goals and performance indicator program. 2. The radiological control goals should be measurable, achievable, auditable, challenging, and meaningful in promoting improvement. 3. Goals should be developed primarily by those responsible for performing the work. Consideration should be given to the formation of a committee that includes the active participation of the work force. 4. Radiological control goals should be reviewed at least annually and revised as appropriate. Normally, more stringent goals should be set annually to reflect the improved radiological control performance at the facility. Occasionally, a goal may be made less stringent to accommodate changes in work load or mission. DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −15 133 Radiological Control Performance Reports 1. The radiological control manager or designee should provide a monthly summary report to the contractor senior site executive for sites which exceed an annual collective dose of one person-rem. This report should include indicators of progress toward achieving the radiological control goals established in accordance with Article 131. Examples of performance indicators that provide a more detailed analysis of performance are identified in Table 1-1. The monthly report should provide performance indicators for the month, as well as tracking and trending for the prior twelve-month period.

2. The radiological control manager should provide appropriate performance indicator information to supervisors and managers on a frequent enough basis to permit management of radiological control performance. The frequency should be consistent with the nature of the workload and the potential for exceeding the established goals. 3. To promote worker awareness of radiological control performance, selected indicators related to their work group should be posted in the workplace. DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −16 Table 1-1 Suggested Radiological Control Performance Indicators Exposure control a. Collective dose in person-rem b. Average worker dose in rem c. Maximum dose to a worker in rem d. Number of unplanned exposures resulting in doses greater than the facility administrative control level e. Number of dose assessments for lost or damaged dosimeters f. Maximum neutron dose to a worker in rem Personnel contamination a. Number of skin and personal clothing contaminations b. Number of contaminated wounds c. Number of facial contaminations Control of internal exposure a. Number of unplanned intakes b. Number of airborne events c. Number of alarms on airborne monitors (actual and false) d. Number of airborne radioactivity areas e. Area of airborne radioactivity areas in square feet Control of contaminated areas in operational areas a. Number of contamination and high contamination areas b. Area of contamination areas in square feet c. Area of high contamination areas in square feet d. Number of spills Minimization of radioactive waste a. Volume and activity of radioactive waste in cubic feet and curies, respectively b. Number of cubic feet not subject to volume reduction by incineration, compaction, or other means Control of radioactive discharges a. Activity of liquid radioactivity discharges in curies b. Activity of airborne radioactivity discharges in curies DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −17 134 Assessments Assessment, as used in this Standard, refers to the process of providing independent feedback to senior line managers to indicate the adequacy of the radiological control program. 1. Inspections, audits, reviews, investigations, and self-assessments are part of the numerous checks and balances needed in a good radiological control program. Internal audits of the radiation protection program shall be conducted such that over a 36-month period, all functional elements are assessed [see 835.102]. The audits should address program performance, applicability, content, and implementation. These audits should be performed by the radiological control organization, the quality assurance organization, or other organizations having the requisite knowledge to adequately assess radiological control activities. 2. Identification of the functional elements of the program depends upon many site- or facility specific factors. Based upon the contents of 10 CFR 835, the following functional elements should be considered for inclusion in the assessment program: • Personnel dosimetry and dose assessment • Portable and fixed instrumentation • Contamination control • Radiological monitoring (area and item monitoring) • ALARA program • Accident and emergency dose controls • Radioactive material control, including sealed radioactive source control and material release • Entry controls • Training • Posting and labeling • Records and reports • Radiological design and administrative controls

3. Managers, supervisors, and workers should look upon assessments as helpful. It is desirable to approach assessments with nothing to hide and with the radiological control program as an open book. Results of assessments should be incorporated into the ongoing process of improving radiological control performance. 4. Managers should encourage the positive view that identifying even minor deficiencies represents an opportunity for further improvement. The number of deficiencies does not in itself measure the overall quality of the radiological control program. A prioritization system to implement actions for resolving the deficiencies should be implemented. 5. In developing corrective action plans for assessment activities, managers should address root causes for the identified deficiencies or concerns, not just the specific symptoms identified by the reviewer. 6. Feedback on findings from assessments, root-cause analyses, status of corrective actions, and adherence to action plan schedules should be frequently provided to management. DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −18 135 Workplace Awareness 1. DOE encourages management initiatives to facilitate the expression of concerns on the part of the work force, to address such concerns, and to solve them to ensure the proper respect for and understanding of radiation. 2. Management should establish and support a radiological awareness reporting system. To enhance work force awareness, the program should encourage continuous evaluation and improvements, track resolution of concerns, provide feedback to employees, and post results and trends. This system may be integrated with similar reporting systems for non-radiological concerns. 136 Internal Exposures Control and prevention of internal exposure, particularly from long-lived radionuclides in the workplace, present special challenges to a radiological control program and warrant particular attention. Factors requiring management attention include the following: • Workers may be exposed to unanticipated levels of elevated airborne radioactivity. The time required to collect representative airborne radioactivity samples and to determine the airborne concentration of radionuclides may contribute to worker intakes of radioactivity. • If controls fail, internal depositions of radionuclides can occur in a short period of time. • The continued exposure of workers to airborne radioactivity over extended periods of time can create worker concerns. • Doses from some radionuclides taken into the body are difficult to measure. Although some radionuclides, such as cesium and tritium, can be readily measured at levels that produce only a few millirem, some long-lived radionuclides, such as plutonium, may require years for accurate measurements of hundreds of millirem. • Medical intervention, such as the administration of blocking and chelating agents, to mitigate internal deposition may add risks by introducing additional chemicals into the body. • Sampling of body excretions and whole body or organ counting techniques may encourage worker perceptions of internal exposure significance. • Administration of internal dose assessment is costly in dollars and worker time. Control and analysis of samples are also more complicated and time consuming than the elements of external dosimetry. • Use of respiratory protection devices imposes additional physical stresses upon participating workers.

The hierarchy of controls required to control internal exposures is provided in Article 316. DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −19 137 Neutron Exposures Neutron exposures have the following characteristics that require attention: • The specific biological effects of neutrons are not as well understood as the effects of gamma exposure. • Neutron dose equivalent is more difficult to assess than gamma dose equivalent. Article 131 provides guidance for setting goals to focus attention on controlling neutron exposure. 138 ALARA Committee The ALARA process of managing radiation exposures is a fundamental requirement of every radiological control program. An ALARA Committee provides a useful forum for reviewing radiological control plans and performance and focusing management resources on radiological control issues. 1. An ALARA Committee should be established. The membership should include managers and workers from the line, the technical support organization, and the radiological control organization. It is more effective if a line manager, such as Director of Operations, Research, or Maintenance serves as the Chair. This Committee may be part of a general safety or radiation safety committee whose functions include ALARA activities and possibly be combined with other committees for smaller facilities. 2. The ALARA Committee should make recommendations to management to improve progress toward controlling radiation exposure and radioactive releases. The Committee should evaluate items such as construction and design of facilities and systems, planned major modifications or work activities, and experimental test plans for exposure, waste, and release controls. The Committee should also receive, as a minimum, the results of all radiological control program assessments, both internal and external, and should review the overall conduct of the radiological control program. DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −20 PART 4 Contractor Radiological Control Organization 141 Radiological Control Organization 1. A radiological control organization should be established to provide relevant support to line managers and workers. To function effectively, the radiological control organization should be independent of the line organizational element responsible for production, operation, or research activities and should have an equivalent reporting level. A single, dedicated radiological control organization for the site is sufficient. At larger DOE sites where facilities, buildings, or work areas are dispersed, an approach that provides site-wide consistency and individual facility radiological control support is recommended. The senior line manager responsible for operations at a facility should have assigned radiological control personnel dedicated to the facility. Consistency of radiological control is critical. It is not the intent of this Standard to duplicate organizations but to use personnel in a more effective manner in workplace situations. 2. Radiological control personnel should monitor adherence to the site-specific radiological control manual and be available to the facility line manager for radiological support to the work force. To function effectively in this capacity, they should receive their day-to-day priorities from facility managers. To ensure independence in making correct radiological control decisions, the radiological control organization should be accountable to the radiological control manager.

3. The radiological control manager heads the radiological control organization and is responsible for and should establish a high quality radiological control program. 4. The radiological control manager should have access to the senior site executive for radiological control matters. 142 Radiological Control Manager Qualifications 1. The radiological control manager should be an experienced radiological control professional and be familiar with the design features and operations of the facility that affect radiological hazards. 2. The radiological control manager should have the technical competence and experience to establish radiological control programs and the supervisory capability to direct the implementation and maintenance of radiological control programs. 3. The radiological control manager should have a minimum of a bachelor's degree or the equivalent in science or engineering, including some formal training in radiological control. Certification by the American Board of Health Physics provides equivalency to the above. The radiological control manager should have at least three years of professional experience in applied radiological control work. Advanced academic degrees can count as one year of experience where course work related to radiological control is involved. Radiological control manager qualifications should be consistent with the guidelines provided in DOE-STD-1107-97, Knowledge, Skills, and Abilities for Key Radiation Protection Positions at DOE Facilities. 4. If the most effective manager for this position does not satisfy the above qualifications, special arrangements should be made. In these situations, the assignment of a deputy with the requisite expertise and qualifications can satisfy the requirement. The education, training, and skills requirements of 10 CFR 835.103 would apply to both individuals to the extent that their responsibilities address programs to ensure compliance with 10 CFR 835. 5. Management should provide persons assigned to or being considered for the radiological control manager position a structured program leading to certification by the American Board of Health Physics. 143 Radiological Control Organization Functions and Staffing DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −21 1. The senior staff of the radiological control organization should include health physicists and other professionals with four-year degrees in science or engineering. A continuing training program should be established. DOE encourages pursuit of certification by the American Board of Health Physics for senior and professional staff members. Training and education provisions for these individuals are established in Article 654. 2. Radiological support personnel provide health physics and radiological engineering, dosimetry, bioassay, independent oversight, instrumentation, and calibration functions. Training and education provisions for these individuals are established in Article 654. 3. Appropriate standards for the education and training of radiological control organization senior staff and support personnel are provided in DOE-STD-1107-97, Knowledge, Skills, and Abilities for Key Radiation Protection Positions at DOE Facilities. 144 Relationship Between Radiological Control Technicians and Workers Radiological control technicians (RCTs) and their supervisors perform the functions of assisting and guiding workers in the radiological aspects of the job.

1. Radiological workers should be sufficiently trained to recognize questionable or deteriorating radiological conditions and seek advice from radiological control technicians and their supervisors. 2. RCTs and their supervisors have the responsibility and authority to stop work or mitigate the effect of an activity in accordance with Article 345. 3. The actions or presence of radiological control personnel does not absolve the workers of their responsibility for properly conducting radiological control aspects of the job. 145 Marginal Radiological Control Performance 1. When radiological control performance is less than adequate, consideration should be given to strengthening line management and the radiological control organization to provide adequate radiological control. 2. If the work force does not have the required level of sensitivity for radiological work practices, additional management attention is needed to assure the proper outcome. Line management should be held accountable for implementation of the radiological control program. Corrective actions that should be considered include: a. More direct line supervision in the work space b. Curtailment of work schedules c. Deferral of work d. Addition of extra radiological control personnel e. Conduct of additional training. 3. When the workers and supervisors achieve the proper level of radiological control performance, the ongoing need for the corrective actions instituted in accordance with Article 145.2 should be reevaluated. DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −22 PART 5 DOE Management 151 Program Office 1. Secretarial Officers are responsible for the establishment and maintenance of radiological control programs for activities under their cognizance, and are accountable for the quality and performance of radiological work conducted at their assigned sites. 2. Each Secretarial Officer should designate an individual to be the Program Office focal point on radiological control matters with the DOE Operations Offices and applicable Field Organization Managers, counterparts within DOE, and the contractor organizations. This individual is referred to in this Standard as the Radiological Control Program Advisor. 152 Operations Offices and Applicable Field Offices 1. Managers of Operations Offices and the Rocky Flats and Ohio Field Offices are responsible for the line management function of conducting day-to-day management of contractor activities, including monitoring the quality and performance of radiological work. 2. Managers of Operations Offices and the Rocky Flats and Ohio Field Offices should designate an individual to be responsible for providing radiological control program assessments, interacting routinely with the Radiological Control Program Advisors of the affected DOE Program Offices, assisting the DOE field line organization in the use of this Standard, and interacting on a periodic basis with counterparts at other sites. 153 Department Policy The Assistant Secretary for Environment, Safety and Health (EH) is responsible for promulgating and maintaining the overall DOE policy and standards with respect to radiological health and safety. EH is also responsible for periodically revising the Standard to make corrections or improvements to the document. Other DOE elements should rely upon subject matter experts within EH for assistance on issues involving topics such as radiological health effects, health physics, dosimetry, instrumentation, training, and radiological controls.

154 Department Independent Radiological Control Performance Oversight EH carries out its responsibility to provide independent radiological control performance oversight, on behalf of the Secretary of Energy, through various means, including the following: 1. Uses 10 CFR 835 as its basis document. To the extent that a DOE activity’s documented radiation protection program establishes commitments to the use of specific guidance documents, such as the 10 CFR 835 Guides (DOE G 441 Series), this Standard, or consensus standards, to achieve compliance, these documents should also be used as basis documents. 2. Assesses DOE Program, Operations, and applicable Field Office performance of their line management responsibilities for implementing and maintaining radiological controls as detailed in the basis document(s). DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −23 155 Radiological Control Coordinating Committee (RCCC) 1. The RCCC, as a minimum, consists of the Radiological Control Program Advisors from the Offices of the National Nuclear Security Administration, Science, Environmental Restoration and Waste Management, and Nuclear Energy, Science, and Technology, and representatives from EH, and selected Operations Offices and Field Organizations. 2. The RCCC is expected to receive and review suggestions, concerns, and comments from its individual members, Operations Offices, and contractors. The RCCC functions in a collective manner to promote a consistent and uniform emphasis in the direction and implementation of this Standard. Communications with the RCCC should follow standard administrative and reporting channels. 3. The RCCC should meet at least quarterly and more frequently during periods of transition (i.e., when developing or implementing significant new or revised complex-wide programs). 4. RCCC meetings should include representatives from Operations Offices and Field Organizations and recognized industry experts from outside DOE. The interaction with non-DOE professionals enhances the awareness of state- of-the-art technology and practices. 156 DOE Employees in the Workplace DOE employees at a DOE site or facility are subject to and should adhere to the provisions of the contractor's site- specific radiological control manual. DOE-STD-1098-99 Radiological Control Excellence in Radiological Control June 2004 −24 THIS PAGE INTENTIONALLY LEFT BLANK DOE-STD-1098-99 Radiological Control Radiological Standards June 2004 2−1 CHAPTER 2 RADIOLOGICAL STANDARDS TABLE OF CONTENTS Article Page PART 1 Administrative Control Levels and Dose Limits 211 Administrative Control Level.............................................................................................................................2-3 212 Lifetime Control Level.......................................................................................................................................2-3 213 Occupational Dose Limits..................................................................................................................................2-4 214 Member of the Public Dose Limit ......................................................................................................................2-4 215 Embryo/Fetus Dose Controls .............................................................................................................................2-4 216 Special Control Levels .......................................................................................................................................2-6

PART 2 Contamination Control and Control Levels 221 Personnel Contamination Control ......................................................................................................................2-7 222 Contamination Control Levels ...........................................................................................................................2-7 223 Airborne Radioactivity Control Levels ..............................................................................................................2-7 224 Areas of Fixed Contamination ...........................................................................................................................2-8 PART 3 Posting 231 General Posting Provisions ..............................................................................................................................2-10 232 Posting Controlled Areas .................................................................................................................................2-11 233 Posting Radiological Buffer Areas...................................................................................................................2-11 234 Posting Radiation Areas...................................................................................................................................2-14 235 Posting Contamination, High Contamination, and Airborne Radioactivity Areas ...........................................2-15 236 Posting Radioactive Material Areas .................................................................................................................2-16 237 Posting Underground Radioactive Material Areas...........................................................................................2-17 238 Posting Soil Contamination Areas ...................................................................................................................2-17 Appendices 2A [Reserved] ........................................................................................................................................................2-18 2B Weighting Factors for Organs and Tissues ......................................................................................................2-19 2C Non-Uniform Exposure of the Skin .................................................................................................................2-20 Figure 2-1 Establishing Posted Areas ................................................................................................................................2-13 DOE-STD-1098-99 Radiological Control Radiological Standards June 2004 2−2 Tables Page 2-1 Summary of Occupational Exposure Limits.......................................................................................................2-5 2-2 Summary of Surface Radioactivity Values ........................................................................................................2-9 2-3 Criteria for Posting Radiation Areas ................................................................................................................2-15 2-4 Criteria for Posting Contamination, High Contamination, and Airborne Radioactivity Areas...........................................................................................................................2-16 Last Page........................................................................................................................2-20

DOE-STD-1098-99 Radiological Control Radiological Standards June 2004 2−3 PART 1 Administrative Control Levels and Dose Limits To accomplish DOE's objective of maintaining individual doses well below regulatory limits, challenging numerical administrative control levels should be established below the regulatory limits to administratively control and help reduce individual and collective radiation dose. These control levels should be multi-tiered with increasing levels of authority required to approve higher administrative control levels. Unless otherwise indicated, administrative, lifetime, and special control levels and dose limits are stated in terms of the total effective dose equivalent, which is the sum of the doses received from internal and external sources. 211 Administrative Control Level 1. Approval by the appropriate Secretarial Officer or designee should be required prior to allowing an individual to exceed 2,000 millirem in a year. 2. Facility management should establish an annual facility administrative control level based upon an evaluation of historical and projected radiation exposures, work load, and mission. The specific value selected should be more restrictive than the administrative control level established by the Program Office. This control level should be reevaluated annually. The choice of a low level for one year does not preclude choosing either a higher or lower level in a subsequent year. The facility administrative control level should be approved by the contractor senior site executive 3. For most facilities, an annual facility administrative control level of 500 millirem or less will be challenging and achievable. An annual administrative control level above 1,500 millirem is in most cases not sufficiently challenging to meet the goals of this Standard. 4. No individual should be allowed to exceed the facility administrative control level without the prior written approval of the radiological control organization and cognizant facility management. Authorization by the contractor senior site executive is recommended. 5. When there is wide variation in the expected doses to the various work groups at a single facility, facility management should develop work group-specific administrative control levels to control worker doses below the regulatory limits. 212 Lifetime Control Level 1. Efforts should be made to control each individual's lifetime occupational dose below a lifetime control level of N rem where N is the age of the individual in years. Article 216 discusses special control levels for radiological workers who have doses exceeding N rem. 2. To ensure compliance with the lifetime control level, efforts should be made to determine the lifetime occupational dose of individuals expected to receive more than 1 rem in a year. The lifetime occupational dose is determined by summing all occupational internal and external doses received during the individual's lifetime. 3. The internal contribution to lifetime occupational dose from intakes prior to January 1, 1989, may be calculated in terms of either cumulative annual effective dose equivalent or committed effective dose equivalent. The committed effective dose equivalent should be used to the extent that adequate data are available to calculate doses in these terms. 213 Occupational Dose Limits DOE-STD-1098-99 Radiological Control Radiological Standards June 2004 2−4

1. Occupational dose limits are provided in Table 2-1 and shall not be exceeded [see 835.202(a)(1)-(4)]. All occupational dose received during the current year, except the dose resulting from planned special exposures and emergency exposures, shall be included when demonstrating compliance with Table 2-1 limits [see 835.202(b) & 702(d)]. If formal records of an individual’s prior occupational dose during the year cannot be obtained, a written estimate signed by the individual may be accepted [see 835.702(d)]. Written estimates should not be used as a basis for authorizing planned special exposures or emergency exposures. 2. In an exceptional situation, a radiological worker may be authorized to receive a dose in excess of the values of the limits specified in Table 2-1. a. Planned special exposures may be authorized for an individual to receive doses in addition to and accounted for separately from doses received under the Table 2-1 limits [see 835.204]. b. Under emergency conditions, individuals may be authorized to receive doses that exceed the limits established in Table 2-1 [see 835.1301 & 1302]. The provisions of this Standard are not intended to limit actions necessary to protect health and safety under these conditions [see 835.3(d)]. DOE believes that there are few situations in which conduct of a planned special exposure or emergency exposure will constitute a best management practice and that proper implementation of the provisions of this Standard will obviate the need for conducting these operations. Therefore, specific guidance for conduct of these operations is not provided in this Standard. Requirements for authorizing, conducting, recording, and reporting these operations are provided in 10 CFR 835 and, for emergency exposures, in DOE Emergency Management Guides. 3. The occupational dose limits provided in Table 2-1 apply to all general employees. However, general employees who have not completed appropriate training and examinations are not permitted unescorted access to any radiological area [see 835.901(b)]. 214 Member of the Public Dose Limit Members of the public permitted access to the controlled area at DOE sites shall be limited to an annual radiation dose of 100 millirem from the sum of doses received from internal and external radiation sources [see 835.208]. 215 Embryo/Fetus Dose Controls After a female worker voluntarily notifies her employer in writing that she is pregnant, for the purposes of fetal/embryo protection, she is considered a declared pregnant worker. This declaration may be revoked, in writing, at any time by the declared pregnant worker [see 835.2(a), Declared pregnant worker]. 1. The employer should provide the option of a mutually agreeable assignment of work tasks, without loss of pay or promotional opportunity, such that further occupational radiation exposure during the remainder of the gestation period is unlikely. DOE-STD-1098-99 Radiological Control Radiological Standards June 2004 2−5 2. For a declared pregnant worker who chooses to continue work involving occupational exposure: a. The dose limit for the embryo/fetus from conception to birth (entire gestation period) as a result of the occupational exposure of the declared pregnant worker is 500 millirem [see 835.206(a)]. The dose to the embryo/fetus is equal to the sum of doses received from external doses, sources inside the mother, and sources inside the embryo/fetus.

b. Measures shall be taken to avoid substantial variation above the uniform exposure rate necessary to meet the 500 millirem limit for the gestation period [see 835.206(b)]. Efforts should be made to avoid exceeding 50 millirem per month to the declared pregnant worker. 3. If the dose to the embryo/fetus is determined to have already exceeded 500 millirem when a worker notifies her employer of her pregnancy, the worker shall not be assigned to tasks where additional occupational radiation exposure is likely during the remainder of the gestation period [see 835.206(c)]. Table 2-1 Summary of Occupational Dose Limits TYPE OF EXPOSURE LIMIT General Employee: Whole Body (internal + external) (TEDE) [see 835.202(a)(1)] 5 rem/year General Employee: Lens of the Eye (external) [see 835.202(a)(3)] 15 rem/year General Employee: Skin and extremities (external shallow dose) [see 835.202(a)(4)] 50 rem/year General Employee: Any organ or tissue (other than lens of eye) (internal + external) [see 835.202(a)(2)] 50 rem/year Declared Pregnant Worker: Embryo/Fetus (internal + external) [see 835.206(a)] 0.5 rem/ gestation period Minors: Whole Body (internal + external) (TEDE) [see 835.207] 0.1 rem/year Minors: Lens of the eye, skin, and extremities [see 835.207] 10% of General Employee limits Notes: 1. The weighting factors in Appendix 2B shall be used in converting organ dose equivalent to effective dose equivalent for the whole body dose [see 835.203(b)]. 2. The annual limit of dose to "any organ or tissue" is based on the committed dose equivalent to that organ or tissue resulting from internally deposited radionuclides over a 50-year period after intake plus any deep dose equivalent to that organ from external exposures during the year[see 835.202(a)(2). 3. Exposures due to background radiation, as a patient undergoing therapeutic and diagnostic medical procedures, and participation as a subject in medical research programs shall not be included in either personnel radiation dose records or assessment of dose against the limits in this Table [see 835.202(c)]. 4. See Appendix 2C for guidance on non-uniform exposure of the skin. 5. Whole body dose (TEDE) = effective dose equivalent from external exposures + committed effective dose equivalent from internal exposures [see 835.2(a)]. 6. Lens of the eye dose equivalent = dose equivalent from external exposure determined at a tissue depth of 0.3 cm [see 835.2(a)]. 7. Shallow dose equivalent = dose equivalent from external exposure determined at a tissue depth of 0.007 cm [see 835.2(a)]. DOE-STD-1098-99 Radiological Control Radiological Standards June 2004 2−6 216 Special Control Levels Certain situations may require lower individual exposure control levels. In addition to considering recommendations from senior radiological control and medical officials, the contractor senior site executive should obtain advice from professionals in other disciplines such as human resources and legal in establishing special control levels. The contractor senior site executive may wish to establish these special control levels using a radiological health advisory group. 1. A special control level for annual occupational exposure should be established for each radiological worker with a lifetime occupational dose exceeding N rem, where N is the age of the individual in years. The special control level should allow the individual's lifetime occupational dose to approach and, if practicable, fall below N rem during ensuing years as additional occupational dose is received.

2. An employer should be attentive to special circumstances of employees, such as those undergoing radiation therapy, and establish special control levels as appropriate. 3. Special controls on an individual dose should not be implemented in a manner that interferes with that individual's right to work. If reasonable efforts to implement the special control level below 1 rem per year threaten to restrict the individual's right to work or are otherwise unsuccessful, the contractor senior site executive should authorize any doses in excess of the special control level, but not to exceed the regulatory dose limits. DOE-STD-1098-99 Radiological Control Radiological Standards June 2004 2−7 PART 2 Contamination Control and Control Levels Control of radioactive contamination is achieved by using engineering controls and worker performance to contain contamination at the source, reducing existing areas of contamination, and promptly decontaminating areas that become contaminated. 221 Personnel Contamination Control 1. Article 338 provides personnel contamination monitoring requirements and guidance. This guidance is not relevant to individuals exiting areas containing only radionuclides, such as tritium, that cannot be detected using hand-held or automatic frisking equipment. 2. Monitoring for contamination should be performed using frisking equipment that can detect total contamination at or below the values specified in Table 2-2. DOE encourages the use of automatic monitoring units that meet the above requirements. 3. Individuals found with detectable contamination on their skin or personal clothing, other than noble gases or natural background radioactivity, should be promptly decontaminated as described in Article 541. 222 Contamination Control Levels 1. A surface is considered contaminated if either the removable or total surface contamination is detected above the levels in Table 2-2. Controls shall be implemented for these surfaces commensurate with the nature of the contaminant and level of contamination [see 835.1102(b)]. Appropriate postings and controls are established in Chapters 2, 3, and 4 of this Standard. 2. Surfaces exceeding the values of Table 2-2 for total contamination may be covered with a fixative coating to prevent the spread of contamination. However, reasonable efforts should be made to decontaminate an area before a coating is applied. A fixative coating should not be applied without the approval of the radiological control manager or designee. 3. Appropriate controls for areas of fixed contamination are provided in Article 224. 4. For areas with contaminated soil that is not releasable in accordance with DOE’s environmental protection standards, a soil contamination area should be established that: a. Is posted as specified in Article 238. b. Meets the requirements of Article 231.1 through 231.8. 5. Soil contamination areas may be located outside a radiological buffer area. 223 Airborne Radioactivity Control Levels 1. Use of engineering and administrative controls to reduce the potential for internal exposure should be evaluated before allowing individuals, with or without respiratory protection, to enter areas with airborne radioactivity. 2. Posting requirements for areas with airborne radioactivity are specified in Article 235. Values of Derived Air Concentrations are provided in 10 CFR 835. 224 Areas of Fixed Contamination DOE-STD-1098-99 Radiological Control Radiological Standards June 2004

2−8 Due to reduced concerns regarding contamination spread, areas having only fixed contamination may not warrant the full range of entry controls established for areas having removable contamination levels exceeding the Table 2-2 values. Areas located outside of radiological areas having measured total contamination exceeding the total surface contamination values specified in Table 2-2 (removable contamination levels below Table 2-2 values) are subject to the following controls: 1. Periodic surveys shall be conducted to ensure the surface contamination remains fixed to the surface and removable surface contamination levels remain below Table 2-2 values [see 835.1102(c)(1)]. 2. Markings indicating the status of the area shall be applied [see 835.1102(c)(2)]. These markings should be applied directly to the surface (or at the access points) to provide appropriate warning. These markings may also provide appropriate instructions to individuals entering the area or contacting the surface (i.e., "Fixed Contamination" or "Fixed Contamination, Notify Radiological Control Personnel Prior to Removing Paint"). Signs, stencils, or other appropriate markings may be used. 3. Markings and postings should be maintained in a legible condition. 4. Appropriate written procedures should be implemented to prevent unplanned or uncontrolled removal of the contamination. These procedures should address issues such as access controls and fixative coatings, if needed, survey techniques and frequency, area tracking and maintenance, and required markings. 5. If surveys indicate that contamination is likely to be transferred from the area, fixative coatings should be applied. When paint is used as a fixative coating, it should consist of two layers having contrasting colors, to provide indication of erosion of the top layer. Other fixative coatings, such as strippable coatings and applied plastics and foams, should be periodically evaluated for evidence of degradation. Removable contamination should be reduced to the minimum practicable level before application of fixative coatings. 6. Areas meeting these requirements are exempt from the posting requirements of Articles 232 - 238 and the entry and exit requirements of Chapter 3. DOE-STD-1098-99 Radiological Control Radiological Standards June 2004 2−9 Table 2-2 Summary of Surface Contamination Values [see 835 Appendix D] RADIONUCLIDE (See Note 1) REMOVABLE (dpm/100 cm2) (See Note 2) TOTAL (FIXED + REMOVABLE) (dpm/100 cm2) (See Note 3) U-natural, U-235, U-238, and associated decay products 1,000 alpha 5,000 alpha Transuranics, Ra-226, Ra-228, Th-230, Th-228, Pa-231, Ac-227, I-125, I-129 20 500 Th-nat, Th-232, Sr-906, Ra-223, Ra-224, U-232, I-126, I-131, I-133 200 1,000 Beta-gamma emitters (nuclides with decay modes other than alpha emission or spontaneous fission) except Sr-90 and others noted above. Includes mixed fission products containing Sr-907. 1,000 beta- gamma 5,000 beta-gamma Tritium and tritiated compounds 10,000 NA Notes: 1. Except as noted in Footnote 5 below, the values in this Table apply to radioactive contamination deposited on, but not incorporated into the interior of, the contaminated item. Where contamination by both alpha- and beta-gamma-emitting nuclides exists, the limits established for the alpha- and beta-gamma-emitting nuclides apply independently [see 835 App. D, note 1].

2. The amount of removable radioactive material per 100 cm2 of surface area should be determined by swiping the area with dry filter or soft absorbent paper while applying moderate pressure and then assessing the amount of radioactive material on the swipe with an appropriate instrument of known efficiency (Note: The use of dry material may not be appropriate for tritium.). For objects with a surface area less than 100 cm2, the entire surface should be swiped, and the activity per unit area should be based on the actual surface area. It is not necessary to use swiping techniques to measure removable contamination levels if direct scan surveys indicate that the total residual contamination levels are below the values for removable contamination [see 835 App. D, note 4]. 3. The levels may be averaged over 1 square meter provided the maximum activity in any area of 100 cm2 is less than three times the values in Table 2-2 [see 835 App. D, note 3]. 4. This category of radionuclides includes mixed fission products, including the Sr-90 which is present in them It does not apply to Sr-90 that has been separated from the other fission products or mixtures where the Sr-90 has been enriched [see 835 App. D, note 5]. 5. Tritium contamination may diffuse into the volume or matrix of materials. Evaluation of surface contamination shall consider the extent to which such contamination may migrate to the surface in order to ensure the surface radioactivity value provided in this Table is not exceeded. Once this contamination migrates to the surface, it may be removable, not fixed; therefore, a "Total" value does not apply [see 835 App. D, note 6]. 6. These values should be applied to total Sr-90/Y-90 activity resulting from processes involving the separation or purification of Sr-90. 7. These values should be applied to total Sr-90/Y-90 activity resulting from the presence of Sr-90 in mixed fission products. DOE-STD-1098-99 Radiological Control Radiological Standards June 2004 2−10 PART 3 Posting 231 General Posting Provisions 1. Radiological postings are intended to alert individuals to the presence of radiation and radioactive materials and to aid them in controlling exposures and preventing the spread of contamination. Boundaries used for radiological control purposes are depicted in Figure 2-1. 2. Signs shall contain the standard radiation symbol (radiation warning trefoil) colored magenta or black on a yellow background [see 835.601(a)]. Lettering should be either magenta or black. Magenta is the preferred color. Standardized signs, as described in DOE’s core training and 10 CFR 835 Guides, should be used where practicable. 3. Signs shall be conspicuously posted at each access point [see 835.601, 603], clearly worded, and, where appropriate, may include radiological control instructions [see 835.601(b)]. Radiological postings should be displayed only to signify actual or potential radiological conditions. Signs used for training should be clearly marked, such as "For Training Purposes Only." 4. Posted areas should be as small as practicable for efficiency. 5. Postings should be maintained in a legible condition and updated based upon the results of the most recent surveys. 6. If more than one radiological condition (such as contamination and high radiation) exists in the same area, each condition shall be identified [see 835.603]. 7. In areas of ongoing work activities, the dose rate and contamination level or range of each should be included on or

in conjunction with each posting as applicable. 8. Postings at entrance points to areas of ongoing work activities controlled for radiological purposes should state basic entry requirements, such as dosimetry, radiological work permit (RWP) or other written authorization, and respiratory protection requirements. 9. Rope, tape, chain, and similar barriers used to designate the boundaries of posted areas should be yellow and magenta in color. 10. Physical barriers should be placed so that they are clearly visible from all directions and at various elevations. They should not be easily walked over or under, except at identified access points. These barriers shall be set up such that they do not impede the intended use of emergency exits or evacuation routes [see 835.501(e), 502(d)]. 11. Areas shall be clearly and conspicuously posted [see 835.601(b)]. Posting of doors should be such that the postings remain visible when doors are open or closed. 12. A radiological posting that signifies the presence of an intermittent radiological condition should include a statement specifying when the radiation is present, such as "CAUTION: RADIATION AREA WHEN RED LIGHT IS ON." DOE-STD-1098-99 Radiological Control Radiological Standards June 2004 2−11 13. Accessible areas may be excepted from the radiological area posting requirements: a. During transient radiological conditions of less than 8 continuous hours duration when posting is not practical, such as radioactive material transfers. Under these conditions, the area shall be placed under the continuous observation and control of individuals who are knowledgeable of and empowered to implement required access and exposure control measures [see 835.604(a)]. These individuals should be stationed to provide line of sight surveillance and verbal warnings. b. When the area contains only packages of radioactive material received from transportation while awaiting survey in accordance with Articles 552 and 554 [see 835.604(c)]. The exceptions discussed above apply only to radiological area and radioactive material area posting requirements and do not apply to the entry control requirements established in 10 CFR 835.501 and 835.502. 232 Posting Controlled Areas Controlled areas are established and posted to warn individuals that they are entering areas controlled for radiation protection purposes. All radiological areas and radioactive material areas lie within the boundaries of controlled areas. Individuals who enter only the controlled area without entering radiological areas or radioactive material areas are not expected to receive a total effective dose equivalent exceeding 100 millirem in a year. 1. Each access point to a controlled area shall be posted whenever radiological areas or radioactive material areas may be present in the area [see 835.602(a)]. 2. The contractor may select the type of sign used to avoid conflict with local security requirements [see 835.602(b)]. This selection should be approved by the contractor senior site executive. 233 Posting Radiological Buffer Areas Radiological buffer areas are intended to provide secondary boundaries within the controlled area to minimize the spread of contamination and to limit doses to general employees who have not been trained as radiological workers. 1. A radiological buffer area should be established for contamination control adjacent to any entrance to or exit from a

contamination, high contamination, or airborne radioactivity area. The size of the radiological buffer area should be commensurate with the potential for the spread of contamination. 2. A radiological buffer area should be established for exposure control adjacent to radiation, high radiation, and very high radiation areas. The boundary for the radiological buffer area should be established to limit radiation doses to general employees to less than 100 millirem per year. 3. A radiological buffer area is not required for: a. High contamination or airborne radioactivity areas that are completely within contamination areas b. Inactive contamination, high contamination, or airborne radioactivity areas (i.e., areas to which entry has been prohibited by posting or barricades) c. Exposure control, if other posted boundaries or controls provide equivalent employee protection d. Exposure control, if general employees who are not trained as radiological workers are restricted from unescorted entry to controlled areas. 4. The need for radiological buffer areas around radioactive material areas, soil contamination areas, and underground radioactive material areas should be evaluated based upon the potential for exposure of unmonitored individuals and the spread of contamination. DOE-STD-1098-99 Radiological Control Radiological Standards June 2004 2−12 5. Posting of radiological buffer areas should be in accordance with Article 231 and contain the wording "CAUTION, RADIOLOGICAL BUFFER AREA." DOE-STD-1098-99 Radiological Control Radiological Standards June 2004 2−13 DOE-STD-1098-99 Radiological Control Radiological Standards June 2004 2−14 234 Posting Radiation Areas 1. Areas shall be posted to alert individuals to the presence of external radiation in accordance with Table 2-3 [see 835.601, 603]. In addition, hot spots should be labeled as described below to provide warning of discrete radiation sources. 2. Radiation areas and high radiation areas shall be identified based on the dose rates at a distance of 30 centimeters either from the source or from any surface penetrated by the radiation [see 835.2(a), radiation area and high radiation area]. Very high radiation areas shall be identified based on the dose rate at a distance of 100 centimeters either from the source or from any surface penetrated by the radiation [see 835.2(a), very high radiation area]. 3. Hot spots are localized sources of radiation, normally located within piping or components, with contact radiation levels greater than 100 millirem per hour (penetrating radiation dose) and more than 5 times greater than the general area dose rate. Contact readings should be used to determine the need for labeling hot spots. Measures taken to identify sources of elevated general area radiation levels while conducting routine radiation surveys should be sufficient to identify hot spot locations. Special surveys for the sole purpose of identifying hot spots are not required. 4. A label reading "Caution, Hot Spot" and marking the location of the hot spot should be placed on or as near the spot as practicable. The provisions of Article 231.7 through 231.11 do not apply to the hot spot labeling. Labeling of hot spots is not required in areas with general area dose rates greater than 1 rem/hr. However, the locations of such hot spots should be noted on area surveys and discussed in pre-job briefings. 5. Dose received in an hour may be used as the criterion for posting (Column 2 of Table 2-3). At very high doses

received at high dose rates (such as doses received in a very high radiation area), dose rates should be measured and recorded in units of “rads” rather than “rem” in an hour. DOE-STD-1098-99 Radiological Control Radiological Standards June 2004 2−15 Table 2-3 Criteria for Posting Radiation Areas AREA CRITERIA REQUIRED POSTING SUPPLEMENTAL POSTING Radiation Area Radiation levels could result in an individual receiving > 0.005 rem in 1 hour at 30 cm "CAUTION, RADIATION AREA" [see 835.603(a)] "RWP AND PERSONNEL DOSIMETER REQUIRED FOR ENTRY" High Radiation Area Radiation levels could result in an individual receiving > 0.1 rem in 1 hour at 30 cm "CAUTION" or "DANGER," "HIGH RADIATION AREA" [see 835.603(b)] "PERSONNEL DOSIMETER, SUPPLEMENTAL DOSIMETER, AND RWP REQUIRED FOR ENTRY"* Very High Radiation Area Radiation levels could result in an individual receiving > 500 rad in 1 hour at 100 cm "GRAVE DANGER, VERY HIGH RADIATION AREA" [see 835.603(c)] "SPECIAL CONTROLS REQUIRED FOR ENTRY"* * Access requirements may be deleted or modified if personnel access is specifically prohibited. 235 Posting Contamination, High Contamination, and Airborne Radioactivity Areas 1. Areas shall be posted to alert individuals to the presence (or likely presence) of surface contamination and airborne radioactivity in accordance with Table 2-4 [see 835.603]. 2. Derived Air Concentration (DAC) values found in 10 CFR 835 shall be used in posting airborne radioactivity areas in accordance with Table 2-4 [see 835.209(a)]. DOE-STD-1098-99 Radiological Control Radiological Standards June 2004 2−16 Table 2-4 Criteria for Posting Contamination, High Contamination, and Airborne Radioactivity Areas AREA CRITERIA REQUIRED POSTING SUPPLEMENTAL POSTING Contamination Area Removable contamination levels (dpm/100 cm2) > Table 2-2 values1 but ≤ 100 x Table 2-2 values "CAUTION, CONTAMINATION AREA" [see 835.603(e)] "RWP AND PROTECTIVE CLOTHING REQUIRED FOR ENTRY" High Contamination Area Removable contamination levels (dpm/100 cm2) > 100 x Table 2-2 values1 "CAUTION" or "DANGER," "HIGH CONTAMINATION AREA" [see 835.603(f)] "RWP AND PROTECTIVE CLOTHING REQUIRED FOR ENTRY" Airborne Radioactivity Area Airborne concentrations (µCi/ml) above background: 1) are > the applicable DAC values1; or 2) could result in an individual (w/o respirator) receiving an intake > 12 DAC-hrs in a week "CAUTION” or “DANGER,” AIRBORNE RADIOACTIVITY AREA" [see 835.603(d)] "RWP AND PROTECTIVE CLOTHING REQUIRED FOR ENTRY" 1 Levels exceed or are likely to exceed the listed values 236 Posting Radioactive Material Areas 1. Accessible areas where items or containers of radioactive material in quantities exceeding the values provided in Appendix 4A are used, handled, or stored shall be posted "CAUTION, RADIOACTIVE MATERIAL" [see 835.603(g)]. 2. Radioactive material areas shall be located within controlled areas [see 835.(2)(a), radioactive material area]. 3. Radioactive material areas may be excepted from the posting requirements when: a. The area is posted as a radiological area in accordance with Article 234 or 235 [see 835.604(b)(1)]; or b. Each item or container of radioactive material in the area is clearly labeled to warn individuals of the hazards [see 835.604(b)(2)]; or c. The radioactive material of concern consists solely of structures or installed components which have been

activated (such as by exposure to neutron radiation or particles produced in an accelerator); or d. The area contains only packages of radioactive material received from radioactive material transportation while awaiting monitoring in accordance with Articles 552 and 554 [see 835.604(c)]; or DOE-STD-1098-99 Radiological Control Radiological Standards June 2004 2−17 e. For periods of eight continuous hours or less, the area is under the continuous observation and control of an individual knowledgeable of, and empowered to implement, required access and exposure control measures [see 835.604(a)]. 4. Provisions for labeling radioactive material are specified in Chapter 4. 237 Posting Underground Radioactive Material Areas 1. Underground radioactive material areas should be established to indicate the presence of underground items that contain radioactive materials, such as pipelines, radioactive cribs, covered ponds, covered ditches, catch tanks, inactive burial grounds, and sites of known, covered, unplanned releases (spills). Underground radioactive material areas need not be posted if physical or administrative controls are implemented to ensure appropriate radiological controls are established prior to excavating, penetrating, or otherwise disturbing underground radioactive materials. 2. Underground radioactive material areas should be posted "UNDERGROUND RADIOACTIVE MATERIAL." Posting should include instructions or special warnings to workers such as "Consult With Radiological Control Organization Before Digging" or "Subsurface Contamination Exists." The posting should meet the applicable requirements of Article 231. 3. Underground radioactive material areas may be located outside controlled areas unless access is likely to result in individual doses (total effective dose equivalent) greater than 100 millirem in a year from underground radioactive material. 4. Underground radioactive material areas are exempt from the entry and exit requirements of Chapter 3 when access is not likely to result in individual doses greater than 100 millirem in a year. Article 333.1 provides entry provisions for instances in which access is likely to result in individual doses greater than 100 millirem in a year. 238 Posting Soil Contamination Areas 1. For areas with contaminated soil that is not releasable in accordance with DOE’s environmental protection standards, a soil contamination area should be established that is posted in accordance with the requirements in Article 231.1 through 231.8. Posting should include the words "Caution, Soil Contamination Area" and instructions or special warnings to workers, such as "Consult With Radiological Control Organization Before Digging" or "Subsurface Contamination Exists." 2. Soil contamination areas may be located outside controlled areas if exposure to the material in the area is not likely to cause any individual to receive a total effective dose equivalent in excess of 100 millirem in a year. 3. If the contamination levels in the area exceed the values provided in Table 2-2 (as evidenced by the likelihood of tracking contamination out of the area at levels exceeding these values), then the area is a contamination area or high contamination area and shall be posted in accordance with Article 235 [see 835.2(a), contamination area and high contamination area and 835.603(d) and (e)]. DOE-STD-1098-99 Radiological Control Radiological Standards June 2004 2−18 Appendix 2A [Reserved]

DOE-STD-1098-99 Radiological Control Radiological Standards June 2004 2−19 Appendix 2B Weighting Factors for Organs and Tissues [see 835.2(b), Weighting factor] ORGANS OR TISSUES WEIGHTING FACTOR Gonads ................................................. Breasts ................................................. Red bone marrow................................. Lungs ................................................... Thyroid ................................................ Bone surfaces....................................... Remainder............................................ Whole Body ........................................ 0.25 0.15 0.12 0.12 0.03 0.03 0.30 1.00 Notes: 1. Weighting factors as defined in ICRP Publication 26 and NCRP Report 91 are used to convert organ or tissue dose equivalent to effective dose equivalent for the whole body. The effective dose equivalent is obtained by multiplying the organ dose by the weighting factor. For example, a 5 rem dose to the thyroid would be multiplied by the weighting factor 0.03 to yield a contribution of 0.15 rem to the total effective dose equivalent. 2. "Remainder" means the five other organs or tissues with the highest dose (e.g. liver, kidney, spleen, thymus, adrenal, pancreas, stomach, small intestine, and upper large intestine). The weighting factor of 0.30 results from 0.06 for each of the five remainder organs [see 835.2(b), Weighting factor, Note 1]. 3. For the case of uniform external irradiation of the whole body, a weighting factor equal to 1 may be used in the determination of the effective dose equivalent [see 835.2(b), Weighting factor, Note 2]. DOE-STD-1098-99 Radiological Control Radiological Standards June 2004 2−20 Appendix 2C Non-Uniform Exposure of the Skin Non-uniform exposures of the skin from X-rays, beta radiation, and radioactive materials on the skin, including hot particles, shall be assessed and recorded as specified in the table below [see 835.205(a)]. AREA OF SKIN IRRADIATED METHOD OF AVERAGING, ADDING TO OTHER DOSES RECEIVED, AND RECORDING NON-UNIFORM SKIN DOSE > 100 cm2 [see 835.205(b)(1)] Averaged over the 100 cm2 of skin receiving the maximum dose Added to any uniform dose equivalent also received by the skin Recorded as the annual extremity or skin (shallow) dose equivalent (H)1 ≥ 10 cm2 and < 100 cm2 [see 835.205(b)(2)] Averaged over the 1 cm2 of skin receiving the maximum dose (D), reduced by the fraction (f) which is the irradiated area in cm2 divided by 100 cm2 (i.e. H=fD) Added to any uniform dose equivalent also received by the skin Recorded as the annual extremity or skin (shallow) dose equivalent1 < 10 cm2 [see 835.205(b)(3)] Averaged over the 1 cm2 of skin receiving the maximum dose Not added to any other dose equivalent, extremity or skin (shallow) dose equivalent recorded for the annual dose equivalent Recorded in a individual's radiation dose record as a special entry1 1 Recording of shallow dose equivalents resulting from non-uniform exposure of the skin is not required if the resulting dose is less than 1 rem [see 835.702(b)]. DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−1 CHAPTER 3 CONDUCT OF RADIOLOGICAL WORK TABLE OF CONTENTS Article Page PART 1 Planning Radiological Work

311 General...............................................................................................................................................................3-3 312 Planning for Maintenance, Operations, and Modifications ................................................................................3-3 313 Infrequent or First-Time Activities ....................................................................................................................3-5 314 Temporary Shielding..........................................................................................................................................3-5 315 Technical Work Documents...............................................................................................................................3-6 316 Control of Internal Exposure..............................................................................................................................3-6 PART 2 Work Preparation 321 Radiological Work Permits ................................................................................................................................3-8 322 Use of Radiological Work Permits.....................................................................................................................3-8 323 Radiological Work Permit Preparation ..............................................................................................................3-9 324 Pre-Job Briefings................................................................................................................................................3-9 325 Use of Personal Protective Equipment and Clothing .......................................................................................3-10 PART 3 Entry and Exit Provisions 331 Controlled Areas ..............................................................................................................................................3-11 332 Radiological Buffer Areas................................................................................................................................3-11 333 Radioactive Material, Soil Contamination, and Underground Radioactive Material Areas ............................3-11 334 Radiation, High Radiation, and Very High Radiation Areas............................................................................3-11 335 Contamination, High Contamination, and Airborne Radioactivity Areas ........................................................3-12 336 Member of the Public Entry Provisions ...........................................................................................................3-13 337 Controlling the Spread of Contamination.........................................................................................................3-14 338 Monitoring for Personnel Contamination.........................................................................................................3-14 PART 4 Radiological Work Controls

341 General.............................................................................................................................................................3-16 342 Work Conduct and Practices ............................................................................................................................3-16 343 Logs and Communications...............................................................................................................................3-17 344 Review of Work in Progress ............................................................................................................................3-17 345 Stop Radiological Work Authority...................................................................................................................3-17 346 Response to Abnormal Situations ....................................................................................................................3-18 347 Controls for Benchtop Work, Laboratory Fume Hoods, Sample Stations, Glovebags, and Gloveboxes ....................................................................................................................3-19 348 Controls for Hot Particles.................................................................................................................................3-19 DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−2 Article Page PART 5 Evaluation of Performance 351 Conduct of Critiques ........................................................................................................................................3-21 352 Post-Job Reviews .............................................................................................................................................3-21 353 Lessons Learned...............................................................................................................................................3-22 PART 6 Special Applications 361 Plutonium Operations.......................................................................................................................................3-23 362 Uranium Operations .........................................................................................................................................3-23 363 Tritium Operations ...........................................................................................................................................3-23 364 Accelerator Operations.....................................................................................................................................3-24 365 Radiation Generating Devices..........................................................................................................................3-24 PART 7 [Reserved] PART 8 Design and Control 381 Radiological Design Criteria............................................................................................................................3-27 382 Control Procedures...........................................................................................................................................3-28 Appendices 3A Checklist for Reducing Occupational Radiation Exposure ..............................................................................3-29 3B Physical Access Controls for High and Very High Radiation Areas ...............................................................3-31 3C Contamination Control Practices......................................................................................................................3-32 3D Guidelines for Personnel Contamination Monitoring with Hand-Held Survey Instruments ............................3-36

Tables 3-1 Radiological Control Training Guidelines .......................................................................................................3-15 3-2 Guidelines for Selecting Protective Clothing (PC)...........................................................................................3-35 Last Page ................................................................................................................................3-36 DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−3 PART 1 Planning Radiological Work 311 General 1. DOE regulations for occupational radiation protection require written authorizations to control access to and work in radiological areas [see 835.501(d)]. The level of detail included in such authorizations is dependent upon facility hazards and the nature of the work force. Technical requirements for the conduct of work, including construction, modifications, operations, maintenance, and decommissioning, should incorporate radiological criteria to ensure safety and maintain radiation exposures ALARA. In general, efforts to reduce individual dose should not be allowed to cause a concurrent increase in collective dose. 2. The primary methods used to maintain exposures ALARA shall be facility and equipment physical design features [see 835.1001(a)]. Performance of certain activities, such as maintenance and modifications, may render permanently installed physical design features inadequate. In such instances, a special subset of design features, often referred to as engineering controls (e.g., temporary shielding, containment devices, and filtered ventilation systems) should be used, as appropriate, to control individual exposures. Design criteria are discussed in Part 8 of this Chapter. 3. When physical design features, including engineering controls, are impractical or inadequate, they shall be augmented by administrative controls [see 835.1001(a) & (b)]. To accomplish this, the design and planning processes should incorporate radiological control considerations in the early planning stages. The checklist in Appendix 3A is helpful in reducing occupational radiation exposure. 4. To ensure adequate protection of the work force, planning for radiological work should also include consideration of all other workplace hazards (e.g., industrial hygiene and safety, fire safety, electrical safety), consistent with the principles of Integrated Safety Management as discussed in Article 118. 312 Planning for Maintenance, Operations, and Modifications 1. Maintenance and modification plans and procedures should be reviewed to identify and incorporate radiological control requirements, such as engineering controls and dose and contamination reduction considerations. Performance of this review should be the responsibility of line management, with support and concurrence from the radiological control organization. Where hazards are significant this review should be performed by a multi- disciplinary team preparing the work control procedure 2. The radiological hazard assessment and control process should be integrated with the processes used to assess and control other workplace hazards. DOE Order 440.1A, Worker Protection Management for DOE Federal and Contractor Employees, and its associated guidance documents provide requirements and guidance for performing hazards assessments and implementing associated controls.

3. For routine tasks, such as surveillance, tours, and minor non-radiological maintenance, performance of the above review and documentation of identified radiological protection requirements may be conducted as part of the radiological work permit process (see Article 321) or other work authorization development process that may be required by 835.501(d). DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−4 4. The site-specific radiological control manual should establish trigger levels requiring formal radiological review of non-routine or complex work activities. The trigger levels should be based on radiological conditions in existence or expected prior to implementation of the job-specific engineering and administrative controls. These appropriate trigger levels should include: a. Estimated individual or collective dose greater than preestablished values (e.g., any individual likely to receive a dose exceeding 50% of the local administrative control level or collective dose likely to exceed 1 man-rem) b. Predicted airborne radioactivity concentrations in excess of preestablished values (e.g., greater than 10 times the applicable DAC value(s) provided in 10 CFR 835) c. Removable contamination on accessible surfaces greater than pre-established values (e.g., greater than 100 times the values in Table 2-2) d. Entry into areas where dose rates exceed 1 rem/hour e. Potential releases of radioactive material to the environment. 5. For non-routine or complex tasks a formal hazards analysis should be conducted using a nationally recognized process as discussed in DOE G 440.1. This review is in addition to the formal radiological review discussed above. An integrated set of controls for all hazards (e.g., radiological, chemical, and physical) should be developed from this hazard analysis. 6. At a minimum, the formal radiological review should consider the following: a. Inclusion of radiological control hold points in the technical work documents b. Elimination or reduction of radioactivity through line flushing and decontamination c. Use of work processes and special tooling to reduce time in the work area d. Use of engineered controls to minimize the spread of contamination and generation of airborne radioactivity e. Specification of special radiological training or monitoring requirements f. Use of mock-ups for high exposure or complex tasks g. Engineering, design, and use of temporary shielding to reduce radiation levels h. Walkdown or dry-run of the activity using applicable procedures i. Staging and preparation of necessary materials and special tools j. Maximization of prefabrication and shop work k. Review of abnormal and emergency procedures and plans l. Identification of points where signatures and second party or independent verifications are required m. Establishment of success or completion criteria, with contingency plans to anticipate difficulties n. Development of a pre-job estimate of collective dose to be incurred for the job o. Provisions for waste minimization and disposal. 7. Radiological control requirements identified as part of the above formal radiological review should be documented in the job plans, procedures, or work packages. 8. The ALARA Committee should review and approve plans for radiological work anticipated to exceed site-specific individual or collective dose criteria. DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−5

9. Optimization techniques, such as cost-benefit analyses, represent a fundamental part of radiological design analysis and work review. For review of minor activities with low associated doses, a cost-benefit evaluation is an intrinsic part of the engineering review process and a detailed evaluation is not necessary. For review and planning of major tasks involving higher collective dose expenditures, a detailed and documented evaluation should be performed. 313 Infrequent or First-Time Activities In addition to the planning provisions of Article 312, special management attention should be directed to radiological activities that are infrequently conducted (i.e., activities for which there is insufficient facility or worker planning and execution experience to provide assurance of adequate radiological controls) or represent first-time operations. Planning for such activities should include: 1. Formal radiological review in accordance with Article 312.4 2. Senior management review directed toward anticipation of concerns and emphasis and specification of protective measures 3. Review and approval by the ALARA Committee 4. Enhanced line and radiological control organization management oversight during the initiation and conduct of the work. 5. The extent of the formal radiological review should be commensurate with the expected and potential hazards and required controls. 314 Temporary Shielding 1. The installation, use, and removal of temporary shielding should be controlled by procedure. 2. The effects of the additional weight of temporary shielding on systems and components should be evaluated and established to be within the design basis prior to installation. 3. Installed temporary shielding should be periodically inspected and surveyed to verify effectiveness and integrity. Installed temporary shielding should be periodically evaluated to assess the need for its removal or replacement with permanent shielding. 4. Radiation surveys should be performed during the alteration or removal of installed temporary shielding. 5. Installed temporary shielding should be visibly marked or labeled with the following or equivalent wording: "Temporary Shielding - Do Not Remove Without Permission from Radiological Control." 6. Site procedures may identify specific shielding applications, such as the shielding of low activity sources or samples, that fall outside the recommendations of this Article. DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−6 315 Technical Work Documents 1. Technical work documents, such as procedures, work packages, or job or research plans, should be used to control hands-on work with radioactive materials. Requirements for incidental or routine work activities that involve a low potential of worker exposure or workplace contamination, such as the collection of trash or used protective clothing, should be established in generally applicable procedures. 2. Technical work documents used to control radiological work activities should be reviewed and approved by the radiological control organization. 3. Radiological control hold points should be incorporated into technical work documents for steps that require action by the radiological control organization to assess existing radiological conditions or prevent significant adverse radiological consequences during subsequent steps. Sites should define “significant adverse radiological conditions” that require the use of radiological control hold points in the site-specific radiological control manual. The following activities and potential conditions should be considered for inclusion in the requirements for radiological control hold points:

a. Radiological control organization action needed to assess changing radiological conditions and ensure implementation of required controls b. Potential for radiation doses in excess of the applicable site-specific administrative control level c. Potential for elevated airborne radioactivity levels (e.g., levels exceeding 10 times the DAC values provided in Appendices A and C of 10 CFR 835) d. Potential for elevated removable surface contamination levels on accessible surfaces (e.g., levels exceeding 100 times the Table 2-2 values) e. Potential for unplanned or uncontrolled release of radioactive material to the environment. 4. The radiological control hold point should include the criteria that must be met or action that must be taken to satisfy the hold point prior to continuing with subsequent steps in the planned activity. 316 Control of Internal Exposure 1. The primary methods used to maintain individual internal doses ALARA shall be physical design features, such as confinement, ventilation, and remote handling [see 835.1001(a)]. The design objective shall be, under normal conditions, to avoid releases of radioactive material to the workplace atmosphere. The objective, under all conditions, shall be to control inhalation of radioactive material to levels that are ALARA [see 835.1002(c)]. 2. Administrative controls, including access restrictions and the use of specific work practices designed to control airborne radioactivity, shall be used as the secondary method to maintain internal doses ALARA [see 835.1001(b)]. DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−7 3. When engineering and administrative controls have been applied and the potential for airborne radioactivity still exists, respiratory protection should be used to limit internal exposures. Use of respiratory protection should be considered under the following conditions: a. Entry into airborne radioactivity areas b. During breach of contaminated systems or components c. During work in areas or on equipment with removable contamination levels greater than 100 times the values in Table 2-2 d. During work on contaminated or activated surfaces with the potential to generate airborne radioactivity. 4. The selection of respiratory protection equipment should include consideration of worker safety, comfort, and efficiency. The use of positive pressure respiratory protection devices is recommended wherever practicable to alleviate fatigue and increase comfort. See Chapter 5, Part 3, for additional guidance on respiratory protection. 5. In specific situations, the use of respiratory protection may be inadvisable due to physical limitations or the potential for significantly increased external exposure. In such situations, a formal radiological review should be conducted in accordance with Article 312 to ensure measures are implemented to assess available options, monitor and reduce worker exposure, and provide for follow-up monitoring, as required. Specific justification of the need to accept the exposure, including a description of measures taken to mitigate the airborne radioactivity, should be documented as part of the review process. 6. The following controls are applicable to activities authorized in accordance with the above: a. Stay time controls to limit intake should be established for the entry b. Evaluation of workplace airborne radioactivity levels should be provided through the use of continuous air

monitors or air samplers with expedited assessment and analysis of results. 7. When notified that an individual with an open wound wishes to enter an area where contact with radioactive contamination is possible, a representative of the radiological control organization should examine the wound and require appropriate measures to prevent the entry of radioactive contamination. These measures may be range from requiring an appropriate bandage or other covering up to prohibiting access to affected areas until the wound has healed. If other (non-radiological) hazards are present in the area to be entered, the individual should be directed to contact the applicable safety personnel. DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−8 PART 2 Work Preparation 321 Radiological Work Permits The RWP is an administrative mechanism used to establish radiological 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. 1. The RWP should include the following information: a. Description of work b. Work area radiological conditions c. Dosimetry requirements d. Pre-job briefing requirements, as applicable e. Training requirements for entry f. Protective clothing and respiratory protection requirements g. Radiological Control coverage requirements and stay time controls, as applicable h. Limiting radiological conditions that may void the RWP i. Special dose or contamination reduction considerations j. Special personnel frisking considerations k. Technical work document number, as applicable l. Unique identifying number m. Date of issue and expiration n. Authorizing signatures. 2. The RWP should be integrated with other work authorizations that address safety and health issues, such as those for industrial safety and hygiene, welding, or confined space entry. 3. If necessary to ensure appropriate accounting, the RWP number should be used in conjunction with the radiation dose accounting system to relate individual and/or collective dose to specific activities. 322 Use of Radiological Work Permits Many facilities find it effective to use two different types of RWPs. General RWPS are used for entry and repetitive work in areas with known and stable low-hazard radiological conditions. Job-specific RWPs are used for more complex work and for entry into higher-hazard areas. 1. RWPs should be used to control the following activities: a. Entry into radiological areas b. Handling of materials with removable contamination that exceed the values of Table 2-2 c. Work in localized benchtop areas, laboratory fume hoods, sample sinks, and containment devices that has the potential to generate contamination in areas that are otherwise free of contamination d. Work that disturbs the soil in soil contamination areas e. Work that involves digging in underground radioactive material areas 2. Job-specific RWPs should be used to control non-routine operations or work in areas with changing radiological conditions. The job-specific RWP should remain in effect only for the duration of the job. 3. General RWPs may be used to control routine or repetitive activities, such as tours and inspections or minor work activities, in areas with well-characterized and stable radiological conditions. General RWPs should not be approved for periods longer than 1 year. DOE-STD-1098-99

Radiological Control Conduct of Radiological Work June 2004 3−9 4. Radiological surveys should be routinely reviewed to evaluate the adequacy of RWP requirements. RWPs should be updated if radiological conditions change to the extent that protective requirements need modification. 5. RWPs should be posted at the access point to the applicable radiological work area or otherwise made available at the work location. 6. Workers should acknowledge by signature, or through electronic means where automated access systems are in place, that they have read, understand, and will comply with the RWP prior to initial entry to the area and after any revisions to the RWP. 7. Worker pocket or electronic dosimeter readings should be recorded in a format that identifies and provides linkage to the applicable RWP. 8. An alternative formal mechanism, such as written procedures or experiment authorizations, may be used in lieu of an RWP as the administrative control over radiological work activities. If an alternative mechanism is used, it should meet the standards established in this Article and Articles 321 and 323. 323 Radiological Work Permit Preparation 1. The responsibility for ensuring adequate planning and control of work activities resides with line management. The lead work group responsible for the planned activity or for the area should initiate the preparation of the RWP. 2. The RWP should be based on current radiological surveys and anticipated radiological conditions. 3. The RWP, including any revisions or extensions, should be approved by the supervisor responsible for the work or area and the appropriate radiological control supervisor. At least one of the approving individuals should have been trained in formal methodologies for performing hazards analysis and implementing integrated controls. 324 Pre-Job Briefings 1. At a minimum, pre-job briefings should be held prior to the conduct of work anticipated to exceed the trigger levels identified in Article 312.3. 2. At a minimum, the pre-job briefing should include: a. Scope of work to be performed b. Radiological conditions of the workplace c. Procedural and RWP requirements d. Special radiological control requirements e. Radiologically limiting conditions, such as contamination or radiation levels that may void the RWP f. Radiological control hold points g. Communications and coordination with other groups h. Provisions for housekeeping and final cleanup i. Emergency response provisions. 3. Pre-job briefings should be conducted by the cognizant work supervisor or other individuals most familiar with the work to be performed and the required controls. 4. Workers and supervisors directly participating in the job, cognizant radiological control personnel, and representatives from involved support organizations should attend the briefing. DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−10 5. 10 CFR 835 requires maintenance of records of actions taken to maintain doses ALARA; therefore, if pre-job briefings are used for ALARA purposes, records of the briefings shall be maintained [see 835.704(b)]. A summary of topics discussed and attendance at the pre-job briefing should be documented. This documentation should be maintained with the technical work document. 325 Use of Personal Protective Equipment and Clothing 1. Individuals shall wear protective clothing during work in contamination and high contamination areas [see

835.1102(e)] and should wear protective clothing during the following activities: a. Handling of contaminated materials with removable contamination in excess of Table 2-2 levels a. Work in airborne radioactivity areas b. As directed by the radiological control organization or as required by the RWP or other work authorization. 2. Protective clothing and shoes designated for radiological control should be: a. Marked in accordance with Article 461 b. Used only for radiological control purposes. 3. Protective clothing dress-out areas should be established directly adjacent to the work area. Workers should proceed directly to the radiological work area after donning personal protective equipment and clothing. 4. General guidelines for protective clothing selection and use are provided in Appendix 3C and in Table 3-1. 5. The use of labcoats as radiological protective clothing is appropriate for limited applications, such as those discussed in Appendix 3C where the potential for personal contamination is limited to the hands, arms, and upper front portion of the body. Labcoats should not be used as protective clothing for performing physical work activities in contamination, high contamination, or airborne radioactivity areas. 6. Appropriate instructions for donning and removing protective clothing should be posted at the dress-out areas and step-off pad(s) for the affected work areas. 7. The use of personal protective equipment or clothing (including respiratory protection) beyond that authorized by the radiological control organization or other cognizant safety authorities detracts from work performance and is contrary to ALARA principles and waste minimization practices. Such use should not be authorized. 8. For radiological control purposes, company-issued clothing that is not specifically intended to protect individuals from contamination hazards, such as coveralls and shoes, should be considered the same as personal clothing. DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−11 PART 3 Entry and Exit Provisions 331 Controlled Areas 1. DOE regulations for occupational radiation protection require that individuals complete radiation safety training commensurate with the hazards and required controls: a. Prior to unescorted access to controlled areas [see 835.901(a)]; and b. Prior to receiving occupational dose during access to controlled areas (whether escorted or not) [see 835.901(a)]. 2. Training provisions for unescorted entry into controlled areas and radiological areas are specified in Table 3-1. Article 622 establishes training provisions that should be met prior to permitting members of the public in controlled areas. 332 Radiological Buffer Areas 1. Minimum requirements for unescorted entry into radiological buffer areas should include the following: a. Training in accordance with Table 3-1 b. Primary dosimeter, as appropriate. 2. Contamination monitoring provisions for individuals who exit a radiological buffer area containing contamination areas, high contamination areas, or airborne radioactivity areas are specified in Article 338. 333 Radioactive Material, Soil Contamination, and Underground Radioactive Material Areas Minimum requirements for unescorted entry into radioactive material areas, soil contamination areas, and underground radioactive material areas should include training in accordance with Table 3-1. If individual doses are likely to exceed the applicable monitoring thresholds, individual monitoring shall be conducted in accordance with Article 511 and Article 521 [see 835.402(a) and (c)].

334 Radiation, High Radiation, and Very High Radiation Areas 1. Minimum requirements for unescorted entry into radiation areas shall include radiation safety training [see 835.901(b)] and should include the following: a. Training in accordance with Table 3-1 b. Worker's signature on the RWP, as applicable c. Primary dosimeter. 2. Physical controls to prevent inadvertent or unauthorized access to high and very high radiation areas are established in Appendix 3B. DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−12 3. Minimum requirements for unescorted entry into high radiation areas shall include radiation safety training [see 835.901(b)], a primary dosimeter [see 835.402(a)(5)], a radiation survey, and supplemental dosimeter [see 835.502(a)] and should include the following: a. Training in accordance with Table 3-1 b. Worker's signature on the RWP. 4. Minimum requirements for unescorted entry into high radiation areas where dose rates exist such that an individual could exceed a whole body dose of 1 rem in one hour shall include radiation safety training [see 835.901(b)], a primary dosimeter [see 835.402(a)(5)], a radiation survey, and supplemental dosimeter [see 835.502(a)] and should include the following: a. Training in accordance with Table 3-1 b. Worker's signature on the RWP c. A determination of the individual’s current dose, based on primary and supplemental dosimeter readings d. Pre-job briefing, as applicable e. Review and determination by the radiological control organization regarding the required level of radiological control technician coverage. 5. Individuals shall be prevented from unauthorized or inadvertent entry to very high radiation areas [see 835.502(c)]. In addition to the controls required in Articles 334.2 and 334.3, a survey should be performed prior to the first entry to the area after the source has been secured or shielded to verify the termination of the very high radiation field. 6. Operations personnel should immediately notify the radiological control organization of operational or system changes that could result in significant changes in radiological hazards. Such notifications facilitate radiological control organization actions to erect postings and implement required entry controls. 7. The number, issue, and use of keys should be strictly controlled where locked entryways are used to control access to high and very high radiation areas. 8. The radiological control organization should maintain a list of high and very high radiation areas. 9. Written procedures should be implemented to ensure the effectiveness and operability of barricades, devices, alarms, and locks. Determination of the effectiveness of these control devices should also consider individual training and response. Weekly inspections of the physical access controls to high and very high radiation areas should be performed to verify controls are adequate to prevent unauthorized entry. 335 Contamination, High Contamination, and Airborne Radioactivity Areas 1. Minimum requirements for unescorted entry into contamination areas shall include radiation safety training [see 835.901(b)] and protective clothing [see 835.1102(e)] and should include the following: a. Training in accordance with Table 3-1 b. Worker's signature on the RWP, as applicable c. Personnel dosimetry, as appropriate. 2. Minimum requirements for unescorted entry into high contamination or airborne radioactivity areas shall include

radiation safety training [see 835.901(b)] and protective clothing [see 835.1102(e)] and should include the following: DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−13 a. Training in accordance with Table 3-1 b. Worker's signature on the RWP c. Respiratory protection when specified by the RWP or other written authorization d. Pre-job briefing for high contamination or airborne radioactivity areas, as applicable e. Personnel dosimetry, as appropriate. 3. Individuals exiting contamination, high contamination, or airborne radioactivity areas should remove protective clothing (See Appendix 3C for recommended procedure). When entering an uncontaminated area, these individuals shall be monitored, as appropriate, for the presence of contamination on their skin and clothing [see 835.1102(d)]. These individuals should perform whole body frisking to detect personnel contamination in accordance with Article 338. 4. Exit points from contamination, high contamination, or airborne radioactivity areas should include the following: a. Step-off pad located outside the exit point, contiguous with the area boundary b. Step-off pads maintained free of radioactive contamination c. Designated containers inside the area boundary for the collection of protective clothing and equipment d. Contamination monitoring equipment located as close to the step-off pad as background radiation levels permit. 5. Multiple step-off pads should be used at the exits from high contamination areas. Use of multiple step-off pads is described in Appendix 3C. 6. Protective clothing and monitoring provisions specific to benchtop work, laboratory fume hoods, sample stations, and gloveboxes are identified in Article 347. 7. Article 421 provides requirements and guidance for removing materials and equipment from these areas. 336 Member of the Public Entry Provisions 1. Site procedures should identify area entry requirements and access restrictions for members of the public. 2. Members of the public with a demonstrated need to enter the following areas may be allowed access if such access is controlled with a combination of orientation and the use of escorts trained for the specific area: a. Radiological buffer areas b. Radiation areas c. Contamination areas d. Radioactive material areas e. Soil contamination areas f. Underground radioactive material areas 3. Members of the public should be prohibited from entering very high radiation, high radiation, high contamination, and airborne radioactivity areas. 4. Orientation provisions for members of the public are identified in Article 622. 337 Controlling the Spread of Contamination Controls shall be implemented as necessary to prevent the spread of removable contamination outside of radiological areas under normal operating conditions [see 835.1102(a)]. The extent of these controls is dependent upon the type and level of contamination present and the activities in and around the area. The following measures should be used to DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−14 prevent the spread of contamination across the boundaries of contamination, high contamination, and airborne radioactivity areas: 1. Use solid barriers to enclose areas wherever practicable 2. Mark and secure items such as hoses and cords that cross the boundary to prevent safety hazards and the spread of contamination. Markings may include radiological hazard warning labels, ribbon, or tape.

3. Control and direct airflow from areas of lesser to greater removable contamination or airborne radioactivity 4. Use engineering controls and containment devices such as glovebags, gloveboxes, and tents. 338 Monitoring for Personnel Contamination 1. Individuals shall be monitored as appropriate for the presence of surface contamination when exiting contamination, high contamination, and airborne radioactivity areas [see 835.1102(d)]. Individuals should perform a whole body frisk immediately upon entry into an uncontaminated area after exiting contamination, high contamination, or airborne radioactivity areas. Individuals should also perform a whole body frisk as directed by the RWP or the radiological control organization. 2. In addition to the above, individuals exiting a radiological buffer area containing contamination, high contamination, or airborne radioactivity areas should, at a minimum, perform a hand and foot frisk. This frisk is optional if the radiological buffer area exit is immediately adjacent to the location where the exiting individual has already performed a whole body frisk. 3. Where frisking cannot be performed at the exit from contamination, high contamination, or airborne radioactivity areas due to high background radiation levels, individuals should: a. Remove all protective equipment and clothing at the exit b. Proceed directly to the nearest designated monitoring station c. Conduct a whole body frisk. 4. Personnel frisking should be performed after removal of protective clothing and prior to washing or showering. 5. Guidelines for personnel frisking are provided in Appendix 3D. 6. Personal items, such as notebooks, papers, and flashlights, may be frisked by the individual carrying them, provided the individual has been trained to perform this function. 7. Instructions for personnel frisking should be posted adjacent to personnel frisking instruments or monitors. 8. The personnel frisking provisions in this Article are not applicable at those facilities that contain only radionuclides, such as tritium, that cannot be detected by currently available hand-held or automated frisking instrumentation. At such facilities, additional emphasis should be placed on bioassay programs and routine area contamination survey and air sampling programs. Table 3-1 Radiological Control Training Guidelines DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−15 ACTIVITIES MINIMUM TRAINING ARTICLE #(s) Member of the public entry1 Orientation 622 Unescorted entry into controlled areas and radioactive material areas/underground radioactive material areas where an individual is not likely to receive 0.1 rem in a year GERT 612, 613, 621 Unescorted entry into radiological buffer areas Unescorted entry into radioactive material areas/underground radioactive material areas (>0.1 rem in a year) Unescorted entry into soil contamination areas for work that does not disturb the soil Unescorted entry into radiation areas RWI 612, 613, 631, 632 Unescorted entry into contaminated areas2 Unescorted entry into high radiation areas3 Unescorted entry into soil contamination areas to perform work that disturbs the soil Use of containment devices with high contamination levels4 RWII 612, 613, 631, 633 Notes:

1. The radiological control manager may authorize exceptions to the escort requirements in accordance with Article 622. 2. Includes Contamination, High Contamination, and Airborne Radioactivity Areas. 3. This requirement may be satisfied by completing both RWI training and High Radiation Area Training in lieu of RWII training. 4. Includes glove boxes and other containment devices with surface contamination levels exceeding 100 times Table 2-2 values. DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−16 PART 4 Radiological Work Controls 341 General 1. Radiological work activities shall be conducted as specified by the controlling written authorization [see 835.501(d)]. 2. Prerequisite conditions, such as tag-outs and system isolation, should be verified in accordance with the technical work documents before work is initiated. 342 Work Conduct and Practices 1. Contamination levels caused by ongoing work should be monitored and maintained ALARA. Work should be curtailed and decontamination performed at preestablished levels, taking into account worker exposure. 2. Tools and equipment should be inspected to verify operability before being brought into contamination, high contamination, or airborne radioactivity areas. 3. The use of radiologically clean tools or equipment in contamination, high contamination, or airborne radioactivity areas should be minimized by the implementation of a contaminated tool crib in accordance with Article 442.5. When such use is necessary, tools or equipment with complex or inaccessible areas should be wrapped or sleeved to minimize contamination. 4. Engineering controls, such as containment devices, portable or auxiliary ventilation, and temporary shielding, should be installed in accordance with the technical work documents and inspected prior to use. 5. The identity of components and systems should be verified prior to work. 6. Work activities and shift changes should be scheduled to prevent idle time in radiological areas. 7. Where practicable, parts and components should be removed to areas with lower radiological hazards to perform work. 8. Upon identification of radiological concerns, such as inappropriate work controls or procedural deficiencies, workers should immediately report the concern to line supervision or the radiological control organization. If appropriate to control individual exposure to radiological hazards, the affected individuals should exit the radiological area until these issues are resolved and appropriate controls have been instituted. 9. Requirements for area cleanup should be included in technical work documents. Work activities should not be considered complete until support material and equipment have been removed and the area has been returned to at least pre-work status. DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−17 10. To minimize intakes of radioactive material, smoking, eating, or chewing should not be permitted in contamination, high contamination, or airborne radioactivity areas. When the potential for personnel heat stress exists, drinking may be permitted within a contamination area under the following conditions and controls: a. The potential for heat stress cannot be reduced by the use of administrative or engineering controls b. All drinking is from approved containers or sources c. At a minimum, workers’ hands and faces are monitored for contamination prior to drinking d. Participating workers are monitored as part of the bioassay program e. The applicable requirements and controls are described in approved procedures.

343 Logs and Communications 1. Radiological control personnel should maintain logs to document radiological occurrences, status of work activities, and other relevant information. 2. During continuous or extended daily operations, oncoming radiological control personnel should review logs and receive a turnover briefing from the personnel they are relieving. 3. Communication systems required by the radiological work permit or technical work document should be checked for operability before being brought into the work area and periodically during work. 4. Workers should keep radiological control personnel informed of the status of work activities that affect radiological conditions. 344 Review of Work in Progress 1. As part of their normal work review, both radiological control and work supervisors should periodically review ongoing jobs to ensure prescribed radiological controls are being implemented. 2. Radiological control personnel should conduct frequent tours of the workplace to review the adequacy of radiological work practices, posting, and area controls. 3. During the performance of jobs for which a pre-job dose estimate was made, the radiological control organization, in cooperation with line management, should periodically monitor collective dose accumulation and compare it with the pre-job dose estimate. Differences should be reviewed to identify causes and assess the need for corrective actions. 345 Stop Radiological Work Authority 1. Radiological control technicians and their supervisors, line supervision, and any worker through their supervisor shall have the authority and responsibility to stop radiological work activities for any of the following reasons [see DOE 440.1A.g]: a. Inadequate radiological controls b. Radiological controls not being implemented c. Radiological control hold point not being satisfied. 2. Stop radiological work authority should be exercised in a justifiable and responsible manner. 3. Once radiological work has been stopped, it should not be resumed until proper radiological control has been reestablished. DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−18 4. Resumption of work involving radiological hazards should require the approval of the line manager responsible for the work and the radiological control manager or designee. 346 Response to Abnormal Situations 1. The site-specific radiological control manual or procedures for responding to abnormal situations should establish requirements for alarm response. Site alarm response procedures should address the general actions in items 2 through 6 below, modified as necessary to reflect specific facility conditions. 2. Response to a continuous air monitor alarm should include the following actions: a. Stop work activities and place the area in a safe condition (i.e., secure welding equipment, terminate activities that may result in more severe conditions) b. Exit the area c. Notify radiological control personnel. 3. Response to increasing or unanticipated radiation levels, as identified by a supplemental dosimeter or area radiation monitor alarm, should include the following actions: a. Stop work activities and place the area in a safe condition (i.e., secure welding equipment, terminate activities that may result in more severe conditions) b. Alert others c. Affected individuals exit the area d. Notify radiological control personnel. 4. Response to a criticality alarm should include the following actions:

a. Immediately evacuate the area, without stopping to remove protective clothing or perform exit monitoring b. Report to designated assembly area. 5. Response to a personnel contamination monitor alarm should include the following actions: a. Remain in the immediate area b. Notify radiological control personnel c. Take actions to minimize cross-contamination, such as putting a glove on a contaminated hand d. Take follow-up actions in accordance with Article 541. 6. Response to a spill of radioactive material should include the following actions: a. Stop or secure the operation causing the spill b. Warn others in the area c. Isolate the spill area if possible d. Minimize individual exposure and contamination e. Secure unfiltered ventilation f. Notify radiological control personnel. For radioactive spills involving highly toxic chemicals, workers should immediately exit the area without attempting to stop or secure the spill. They should then promptly notify the Industrial Hygiene or Hazardous Material Team and radiological control personnel. 347 Controls for Benchtop Work, Laboratory Fume Hoods, Sample Stations, Glovebags, and Gloveboxes DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−19 The following provisions are applicable to radiological work that has the potential to generate radioactive contamination in localized benchtop areas, laboratory fume hoods, sample stations, glovebags, and glovebox operations located in areas that are otherwise contamination free. 1. Provisions for radiological work permits are provided in Article 322. 2. Protective clothing should, at a minimum, include labcoats and gloves. Gloves should be secured at the wrist as necessary. 3. Shoecovers should be considered based on the potential for floor contamination. 4. Workers should periodically monitor their hands during work. 5. Upon completion of work or prior to leaving the area, workers shall monitor those areas of their body that are potentially contaminated [see 835.1102(d)]. At a minimum, this includes hands, arms, and front portions of the body. A whole body frisk is recommended. 6. If there is a potential for splashing or airborne radioactivity, such as when taking pressurized samples, additional controls such as rubber aprons, face shields, full PCs, or respiratory protection should be instituted. 7. Gloveboxes should be inspected for integrity and operability prior to use. 8. Gloveboxes should be marked with, or survey measurements should be posted to identify, whole body and extremity dose rates. 348 Controls for Hot Particles Hot particles are small, discrete, highly radioactive particles capable of causing extremely high doses to a localized area in a short period of time. Hot particle contamination may be present or be generated when contaminated systems are opened or when operations such as machining, cutting, or grinding are performed on highly radioactive materials. 1. The site-specific radiological control manual should define hot particles, such as those capable of producing a shallow dose equivalent greater than 100 millirem in one hour, specific to facility operations and source terms. 2. Measures for controlling hot particles, as identified in items 3 through 7 of this Article, should be implemented under the following conditions: a. Upon identification of hot particles b. During new or non-routine operations with a high potential for hot particles, based on previous history c. Upon direction of the radiological control organization.

3. Survey provisions for areas or operations with the potential for hot particle contamination are established in Article 554.9. 4. Contamination area postings should be annotated to specifically identify the presence of hot particles. 5. Access to hot particle areas should be controlled by a job-specific RWP. The following controls should be considered for inclusion on the RWP: a. Periodic personnel monitoring during the work activity, at a frequency based on the potential magnitude of personnel exposure DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−20 b. Additional personal protective equipment and clothing c. Direct radiological control coverage during work and assistance during protective clothing removal d. Use of sticky pads or multiple step-off pads. 6. Personal protective equipment and clothing used in hot particle areas should be segregated from other radiological protective equipment and clothing during laundering and surveyed prior to reuse. 7. Response to hot particle skin or clothing contamination should include the following: a. Immediate removal and retention of the hot particle for subsequent analysis b. Analysis of the particle c. Assessment of worker dose d. Evaluation of work control adequacy. DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−21 PART 5 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 programmatic breakdown of radiological 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. In addition, successful performance or completion of unique activities should be evaluated to identify and incorporate appropriate lessons learned. Analysis of the facts should reveal areas where improvements can be made or where methods can be identified to prevent the recurrence of undesired results. 351 Conduct of Critiques Critiques are meetings of the individuals knowledgeable about an event (either a success or an abnormal event) to document a chronological listing of the facts. The purpose of the critique is not to assign blame, but to establish and record the facts. 1. Critiques should be conducted for successes and abnormal events. 2. Critique leaders should be trained in the required elements of the critique process and the appropriate methods of conducting and controlling the critique. 3. Critique meetings should be conducted as soon as practicable after the event or situation is stabilized, or after a successful evolution is completed. Critiques of abnormal events should preferably be conducted before involved personnel leave for the day. 4. At a minimum, the general critique process should include the following elements: a. Formal meetings, chaired by a critique leader b. Attendance by all members of the work force who can contribute c. Personal statement forms completed by selected personnel before the meeting d. Attendance records e. Minutes, recorded and signed by the critique leader and all contributors f. Pertinent personal statements from individuals involved in the event, signed and attached to the meeting minutes g. A listing of the facts in chronological order h. Supporting materials, including documents, records, photographs, parts, and logs, maintained by the critique

leader. 5. Evaluation of complex evolutions or events may require multiple critiques. 352 Post-Job Reviews 1. Performance should be reviewed after completion of non-routine radiological work. Requirements for post-job reviews should be delineated in the site-specific radiological control manual. DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−22 2. As appropriate to the work in question, post-job reviews should include reviews of: a. The total and individual doses compared to the pre-job estimates b. The efficacy of the radiological controls implemented for the work c. Any adverse events occurring during the work, such as skin contaminations, unexpectedly high individual exposures, or problems resulting from unnecessarily burdensome control requirements d. Conflicts between radiological safety requirements and other safety requirements e. Opportunities to improve performance or efficiency during repeated or similar work f. Significant differences between expected and actual radiological conditions or other issues affecting the work g. Worker input regarding possible improvements in radiological safety practices for repeated or similar work. 353 Lessons Learned Lessons learned are available from post-job reviews and reports of past radiological events on site and at other facilities. The radiological control organization, in conjunction with line management, should evaluate lessons learned, provide prompt distribution, and incorporate the lessons into the site radiological control program, the radiological control training program, and related operations. DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−23 PART 6 Special Applications This Part provides supplemental information to augment the basic requirements of the Standard. Articles 361 through 365 provide information to be used in developing the site-specific radiological control manual. Written guidance and requirements contained within DOE documents, consensus standards, or Federal regulations that delineate specifics for each application are referenced. Articles 361 through 363 of this Part are applicable to those facilities where the majority of the work or operations involve the subject radionuclide as the significant source term. This Part is not intended to apply to facilities that use the subject radionuclides in limited or tracer amounts, such as analytical laboratories. 361 Plutonium Operations There is the perception that exposure to small quantities of plutonium presents greater risk than exposure to other radionuclides. Low levels of plutonium in the body are difficult to measure and biological removal processes for plutonium are slow. For these reasons: 1. Primary emphasis shall be placed on engineered features to contain plutonium and to prevent airborne and surface contamination [see 835.1001(a)]. 2. In addition to the provisions of this Standard, guidance contained in the document, DOE-STD-1128-98, Guide to Good Practices For Occupational Radiation Protection in Plutonium Facilities, Reaffirmation with Errata (May 2003) should be considered in preparing the site-specific radiological control manual for plutonium operations. This standard provides specific guidance related to dosimetry, radiological monitoring, instrumentation, contamination control, and applicable radiological control procedures. 362 Uranium Operations

Natural, depleted, and low-enriched uranium are unusual in that their chemical toxicity is more limiting in the human body than their radioactivity. Also, processed uranium sometimes contains transuranic and other radionuclides from recycled materials. For these reasons, in addition to the provisions of this Standard, the guidance contained in DOE-STD-1136-2000, Guide of Good Practice for Occupational Radiological Protection in Uranium Facilities, Change Notice No. 3, (December, 2001) should be considered in preparing the site-specific radiological control manual for uranium operations. This manual provides specific guidance related to management controls, radiological monitoring, contamination control, and internal and external exposure controls. 363 Tritium Operations The following characteristics of tritium require consideration in the implementation of the radiological control program at tritium facilities: 1. Tritium emits low energy beta particles which cannot be monitored using external dosimeters, consequently requiring the use of bioassay measurements to evaluate worker dose. 2. Worker exposure to tritium as water vapor causes a much greater dose than exposure to elemental tritium gas. 3. Normal personnel frisking techniques are ineffective for tritium. Consequently, a high reliance is placed on worker bioassay and routine contamination and air monitoring programs. DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−24 4. Due to its ability to permeate substances which it contacts, including human skin, tritium is difficult to contain. Special attention should be directed to the selection of personal protective equipment and clothing. For the above reasons, guidance contained in DOE-HDBK-1079-94, Primer on Tritium Safe Handling Practices, should be considered in preparing the site-specific radiological control manual for tritium operations. This handbook provides specific guidance related to internal dosimetry, contamination and air monitoring, tritium containment practices and techniques, and personal protective equipment and clothing selection. 364 Accelerator Operations Special considerations associated with accelerator facilities include the presence of extremely high dose rates, high energy and heavy particles, the generation of activation products, and detection and monitoring difficulties associated with pulsed or high energy radiation. For these reasons: 1. In addition to the provisions of this Standard, guidance contained in the document, DOE-HDBK-1108-2002, Radiological Safety Training for Accelerator Facilities, should be considered in preparing the site-specific radiological control manual for accelerator operations. This manual provides specific guidance related to radiological monitoring, dosimetry, shielding design, use of interlocks, and procedures and administrative controls. 2. Consideration should be given to the information provided in DOE O 420.2A ( Safety of Accelerator Facilities, in preparing the site-specific radiological control manual . 3. Safety devices and interlocks that are necessary to meet the high radiation area control requirements of 10 CFR 835.501 shall be operational prior to and during operation of a beam [see 835.501(b)]. Operational status should be verified by testing. Safety divides and interlocks should be fail-safe. 365 Radiation Generating Devices

Special considerations associated with the use of radiation generating devices include the presence of extremely high dose rates and the potential for uncontrolled exposures. Operation of these devices requires stringent physical and administrative controls to prevent overexposure to operating and support personnel and those in adjacent work areas. Site-specific procedures should contain the following provisions for applicable types of radiation generating devices: 1. ANSI N43.3, American National Standard for General Radiation Safety-Installations Using Non-Medical X-Ray and Sealed Gamma-Ray Sources, Energies up to 10 MeV, establishes acceptable guidelines for operations involving the irradiation of materials. 2. The provisions of ANSI N43.2 entitled, Radiation Safety for X-Ray Diffraction and Fluorescence Analysis Equipment, shall be adhered to for operations involving the following devices [see DOE 5480.4.2.d]: a. Analytical diffraction and fluorescence b. Flash X-ray c. Sealed source irradiators used for diffraction studies. 3. Line management, in conjunction with the radiological control organization, should establish the radiological control requirements for incidental X-ray devices such as electron microscopes and electron beam welders. 4. Devices for medical use should be registered with the appropriate regulatory agency. 5. Control requirements for radiographic devices include the following: DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−25 a. On-site operations with devices containing sealed sources for radiographic use should be conducted in accordance with the requirements contained in Title 10 CFR part 34, Licenses for Radiography and Radiation Safety Requirements for Radiographic Operations. b. ANSI N43.3, American National Standard for General Radiation Safety-Installations Using Non-Medical X- Ray and Sealed Gamma-Ray Sources, Energies up to 10 MeV, establishes acceptable guidelines for on-site operations with devices other than sealed sources for radiographic use. c. On-site operations conducted by off-site contractors should be approved by line management in coordination with the site radiological control organization. This process should ensure the contractor has a valid Nuclear Regulatory Commission or Agreement State license and that the operational and emergency procedures are current and available. 6. Safety devices and interlocks at fixed installations that are required to ensure compliance with 10 CFR 835.501 shall be operational prior to and during generation of a radiation field. Operational status should be verified by testing. Safety devices and interlocks should be fail-safe. DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−26 PART 7 [Reserved] DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−27 Part 8 Design and Control 381 Radiological Design Criteria The following design objectives are applicable during the design of new facilities and modification of existing facilities. Additional design criteria are provided in DOE Order 420.1. 1. For areas of continuous occupancy (2000 hours per year), the design objective shall be to maintain the average exposure level ALARA and below 0.5 millirem per hour. If occupancy is not continuous, the design objective shall be to maintain doses ALARA and below 20% of the occupational dose limits provided in Table 2-1 [see 835.1002(b)]. DOE recommends that design criteria be established to limit individual worker doses below 0.25 millirem per hour (500 millirem TEDE per year).

2. For control of airborne radioactivity, the design objective shall be to avoid releases to the work place atmosphere under normal conditions and, under any conditions, to control inhalation by workers to levels that are ALARA. Confinement and ventilation shall normally be used [see 835.1002(c)]. 4. For materials used in facility construction and modification, the design objective shall be to select materials that facilitate operations, maintenance, decontamination, and decommissioning [see 835.1002(d)]. Components should be selected to minimize the buildup of radioactivity. Control of surface contamination should be achieved by containment of radioactive material. 5. In justifying facility design and physical controls, optimization methods shall be used [see 835.1002(a)]. 6. Support facilities should be provided for donning and removal of protective clothing and for personnel monitoring, when required. 7. A neutron quality factor of 20 for conditions of unknown spectra (or doubling of the neutron quality factor associated with known neutron energies) should be used for design purposes only. Design analyses based on these neutron quality factors are intended to estimate the additional construction cost resulting from neutron quality factor increases. The results of these analyses should be used to ascertain the economic feasibility of incorporating such modifications in the final design. This quality factor is not to be used for determination of individual dose equivalents. 8. Existing facility designs that have office space and lunchrooms or eating areas within radiological areas, radioactive material areas, and radiological buffer areas require priority attention. Generally: a. Locating lunch rooms or eating areas, restrooms, drinking fountains, showers and similar facilities and devices is strongly discouraged within these areas b. Locating office spaces within these areas is strongly discouraged; to the extent that such space is essential to support radiological work, steps should be taken to preclude unnecessary occupancy. 9. Facilities currently under construction should be evaluated and the above criteria applied where practicable. DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−28 382 Control Procedures 1. Administrative control and procedural requirements shall be developed and implemented as necessary to supplement facility design features, particularly when the design of existing facilities is not in accordance with current standards [see 835.1001(b)]. Administrative control procedures include access control measures, RWPs, and technical work documents as discussed in this Standard. 2. Written procedures shall be developed as necessary to ensure compliance with the provisions of this Standard that are derived from 10 CFR 835 [see 835.104]. These procedures shall be commensurate with the radiological hazards created by the activity and the education, training, and skills of the individuals who are exposed to these hazards [see 835.104]. 3. Written authorizations, including specific radiation protection measures, shall be required to control entry into and work within radiological areas [see 835.501(d)]. These authorizations may include RWPs, technical work documents, administrative procedures, and other administrative controls. 4. The combination of design features and administrative control procedures shall be sufficient to ensure that, during

routine operation, the Table 2-1 dose limits for general employees are met and to ensure doses are ALARA [see 835.1003(a)]. DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−29 Appendix 3A Checklist for Reducing Occupational Radiation Exposure Preliminary Planning and Scheduling • Plan in advance • Delete unnecessary work • Determine expected radiation levels • Estimate collective dose • Sequence jobs • Schedule work • Select a trained and experienced work force • Identify and coordinate resource requirements Preparation of Technical Work Documents • Include special radiological control requirements in technical work documents • Perform ALARA pre-job review • Select and optimize engineering and administrative controls to control doses • Plan access to and exit from the work area • Provide for service lines (air, welding, ventilation) • Provide communication (sometimes includes closed-circuit television) • Remove or shield sources of radiation • Plan for installation of temporary shielding • Decontaminate • Work in lowest radiation levels • Perform as much work as practicable outside radiation areas • State requirements for standard tools • Consider special tools, including robots • State staging requirements for materials, parts and tools • Incorporate radiological control hold points • Analyze PPE requirements to ensure optimization of hazard control, risks, and costs • Minimize discomfort of workers • Revise estimates of collective dose • Prepare radiological work permits (RWPs) DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−30 Temporary Shielding • Design shielding to include stress considerations • Control installation and removal by written procedure • Inspect after installation • Conduct periodic radiation surveys • Prevent damage caused by weight of heavy temporary shielding • Balance radiation exposure received in installation against exposure saved by installation • Shield travel routes • Shield components with abnormally high radiation levels early in the maintenance period • Shield position(s) occupied by worker • Perform directional surveys to improve design of shielding by locating source of radiation • Use mock-ups to plan temporary shielding design and installation • Consider use of water-filled shielding Rehearsing and Briefing • Rehearse • Use mock-ups duplicating working conditions • Use photographs and videotapes • Conduct briefings of workers in accordance with Article 324 Performing Work • Comply with technical work documents and RWPs • Post radiation levels • Keep excess personnel out of radiation areas • Control radiation exposure while controlling exposure to other hazards • Supervisors and workers keep track of radiation exposure • Compare actual dose against pre-job estimates • Workers assist in radiation and radioactivity measurements • Delegate radiological control monitoring responsibilities • Evaluate the size of the work crew as work progresses • Reevaluate methods used to control radiation doses • Compare actual collective dose against pre-job estimate • Coordinate personnel at the job site to reduce non-productive time DOE-STD-1098-99 Radiological Control Conduct of Radiological Work June 2004 3−31 Appendix 3B Physical Access Controls for High and Very High Radiation Areas 1. One or more of the following features should be used for each entrance or access point to a high radiation area and

shall be used for each entrance or access point to a high radiation area where radiation levels exist such that an individual could exceed a whole body dose of 1 rem in any one hour [see 835.502(b)]: a. A control device that prevents entry to the area when high radiation levels exist or upon entry causes the radiation level to be reduced below that level defining a high radiation area b. A device that functions automatically to prevent use or operation of the radiation source or field while personnel are in the area c. 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 d. Entryways that are locked, except during periods when access to the area is required, with positive control over each entry e. Continuous direct or electronic surveillance that is capable of preventing unauthorized entry f. A control device that automatically generates audible and visual alarm signals to alert personnel in the area before use or operation of the radiation source and in sufficient time to permit evacuation of the area or activation of a secondary control device that will prevent use or operation of the source. 2. In addition to the above requirements, additional measures shall be implemented to ensure individuals are not able to gain access to very high radiation areas when dose rates are in excess of the posting requirements of Table 2-3 [see 835.502(c)]. 3. Physical access controls over high and very high radiation areas shall be established in a manner that does not prevent an individual from leaving the area [see 835.502(d)]. DOE-STD-109