Current Radiation Safety Issues

1. Current Radiation Safety Issues Pictures: Clockwise from upper right: SM-1 Army Nuclear Power Plant at Ft Belvoir during operation; Remediation work at the St Louis Downtown FUSRAP Site, Manhattan Project Button. Pictures: Clockwise from upper right: SM-1 Army Nuclear Power Plant at Ft Belvoir during operation; Remediation work at the St Louis Downtown FUSRAP Site, Manhattan Project Button.

2. 2 USACE Radiation Protection Program Documentation and organization Radiation Safety Support Team What it is What it does Army Radon Reduction Program Tritium Exit Signs RSO Resources

3. 3 ER 385-1-80, Ionizing Radiation Protection Slight changes to dosimetry reporting Removed PSE�s Clarified tiered dose limits, information flow Overall � cleaned it up EM 385-1-80, Radiation Protection Manual Draft for peer review by end of FY AR 385-10, The Army Safety Program Mandatory DA PAM 385-24, The Army Radiation Safety Program Dosimetry change � at termination IF REQUESTED Cleaned it up � name changes, reg citations unnecessary, definitions, compatible with AR 385-10 and DA PAM 385-24 Tiered dose limits � what is suggested v what is required, when RSSO approval is required, etc.Dosimetry change � at termination IF REQUESTED Cleaned it up � name changes, reg citations unnecessary, definitions, compatible with AR 385-10 and DA PAM 385-24 Tiered dose limits � what is suggested v what is required, when RSSO approval is required, etc.

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5. 5 Established by the USACE Chief of Staff in December 1997 The RSST consists of health physicists in NAB, LRB, MVS and NWK and the EMCX The RSST is coordinated at the EMCX and the POC is Julie Clements, CHP The HQUSACE Radiation Program Manager, Andrea Pouliot, is responsible for RSST oversight

6. 6 Radiation Surveys and Site Investigation Design, oversee, and/or perform surveys during all phases of site investigation and restoration Radioactive Waste Transportation and Disposal Profiling, packaging, and transporting

7. 7 Radiation Risk/Dose Modeling RESRAD/RESRAD BUILD Nuclear Reactor Decommissioning Radiation Protection Training Audits of USACE licensees/ARA holders Required by DA PAM 385-24 and ER 385-1-80 Performed triennially Conducted by an RSST member

8. 8 Subchapter III of TSCA, Indoor Radon Abatement Act (1988) Required the head of each federal agency to design a study to assess the extent of radon contamination in buildings A centralized testing program was initiated AR 200-1, Environmental Protection and Enhancement (1990) Chapter 11, Army Radon Reduction Program In buildings that it managesIn buildings that it manages

9. 9 AR 200-1 revised (2007), ARRP removed AR 420-1, Army Facilities Management (2007) Defines radon Requires that each installation establish a radon assessment and mitigation program Refers to AR 200-1 For additional info on measurements, relative risk, action levels, and mitigation techniques In buildings that it managesIn buildings that it manages

10. 10 PWTB 420-1-XX, Installation Toxics Planning Covers lead, asbestos, PCB�s, and radon (Appendix D) Purpose � provide guidance on how to detect, evaluate, control or remove subject toxic materials Applicability � Army owned or leased or otherwise controlled structures

11. 11 Prioritizes structures Priority 1 = day care centers, hospitals, schools and living areas (4 pCi/L) Priority 2 = areas having 24 hr operations (30 pCi/L) Priority 3 = all other routinely occupied structures (30 pCi/L) Details for testing in installation plans Program is decentralized Establishes timelines for remediation On the 17th (this month) we will be conducting an HQDA QA/QC Team meeting at HQUSACE. From that point, there may be a last review fielding to a selected community. I would see that review process taking 30-45 days; then a rework of the document as required (5-10 days). Once this is complete it will be sent to Mr. McCloud at USACE for approval and inclusion on the site. On the 17th (this month) we will be conducting an HQDA QA/QC Team meeting at HQUSACE. From that point, there may be a last review fielding to a selected community. I would see that review process taking 30-45 days; then a rework of the document as required (5-10 days). Once this is complete it will be sent to Mr. McCloud at USACE for approval and inclusion on the site.

12. 12 US EPA - action level 4 pCi/L for lived-in areas of residences Serves as the basis for Priority 1 standard OSHA � 29 CFR 1910.1096 100 pCi/L averaged over a 40 hr work wk US NRC � 10 CFR 20 Derived air concentration < 30 pCi/L Serves as the basis for Priority 2/3 standard plus ALARA

13. 13 Glass tubes internally coated with phosphor and containing tritium (H-3) gas Typically contain 10 to 20 Ci of H-3 Several different manufacturers Cheap and reliable if not mishandled Breakage is common in certain settings (e.g., school gym, around a forklift operation, or where a sign near the floor is required)

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15. 15 US NRC Regulations 10 CFR 31 10 CFR 32 US NRC Guidance NUREG-1556 DOD Unified Facilities Criteria UFC 3-600-01

16. 16 Relevant language found in �31.5 General licensees who possess TES must: Appoint an individual responsible for ensuring compliance with the requirements Ensure that labels are intact Suspend operation of broken signs

17. 17 General licensees who possess TES must: Return unwanted or broken signs to a specific licensee authorized to receive them (typically a manufacturer) Report lost, stolen or transferred signs to the appropriate regulatory agency within 30 days

18. 18 Relevant language found in �32.51a Manufacturers of TES must provide information to the general licensee receiving the signs, to include: A copy of the requirements pertaining to a general licensee

19. 19 Manufacturers must provide: A list of services that can only be performed by a specific licensee Information on acceptable disposal options A reminder that NRC can issue penalties for improper disposal

20. 20 Volume 16, Appendix L: Guidance on Self Luminous Exit Signs Question and answer format, reiterates the requirements of 10 CFR 31.5 Expands on key issues such as how to make the required reports, how to determine if a sign is functional, and what to do if a sign is broken to minimize the spread of contamination Most signs that are broken do not cause a release of tritium. If a sign is excessively damaged, the tritium gas could be released and would dilute rapidly in the air. Keep in mind that for this to occur, the outer frame and inner protective housing would also have to be damaged. The area should be evacuated and ventilated to avoid unnecessary exposure to the radioactive material. The material does not pose any immediate health hazard to workers at the location or members of the public. However, the sign would be expected to have relatively high levels of tritium on it and should be properly handled. Do not move the sign into other areas to avoid spreading contamination prior to disposal. Contact the manufacturer for directions on proper handling of the damaged sign, as well as proper shipping and disposal. If you do not know who the manufacturer is, carefully look on the sign itself for the name and phone number of the manufacturer. If you still cannot identify a manufacturer, call NRC to request assistance in dealing with the broken sign.Typically, manufacturers will advise a procedure such as the following: Wear rubber gloves and eye protection since you may come in contact with broken glass and/or radioactive material. Wipe the entire surface of the sign with a paper towel. Wrap the sign, paper towel, and gloves in a plastic bag (i.e., garbage bag) and tape it closed. Wash your hands with soap and water. Wrap the sign a second time in a plastic bag (i.e., garbage bag) and tape it closed. Wash your hands with soap and water. Place each sign in a sturdy carton. Use filler materials to assure a tight, rattle-free fit. Tape the seal flaps and seams. Label the carton: "RADIOACTIVE". Place this package into a second sturdy cardboard carton and include a piece of paper with the following words: "This package conforms to the conditions and limitations specified in 49 CFR 173.424 for radioactive material, excepted package-instruments or articles, UN2910." Use filler materials to assure a tight fit. Tape the seal flaps and seams. DO NOT label this outer carton "RADIOACTIVE." Before shipping, contact the manufacturer whose name appeared on the sign label. Make a report to NRC (see the table of reporting requirements in Question�4). Most signs that are broken do not cause a release of tritium. If a sign is excessively damaged, the tritium gas could be released and would dilute rapidly in the air. Keep in mind that for this to occur, the outer frame and inner protective housing would also have to be damaged. The area should be evacuated and ventilated to avoid unnecessary exposure to the radioactive material. The material does not pose any immediate health hazard to workers at the location or members of the public. However, the sign would be expected to have relatively high levels of tritium on it and should be properly handled. Do not move the sign into other areas to avoid spreading contamination prior to disposal. Contact the manufacturer for directions on proper handling of the damaged sign, as well as proper shipping and disposal. If you do not know who the manufacturer is, carefully look on the sign itself for the name and phone number of the manufacturer. If you still cannot identify a manufacturer, call NRC to request assistance in dealing with the broken sign.Typically, manufacturers will advise a procedure such as the following: Wear rubber gloves and eye protection since you may come in contact with broken glass and/or radioactive material. Wipe the entire surface of the sign with a paper towel. Wrap the sign, paper towel, and gloves in a plastic bag (i.e., garbage bag) and tape it closed. Wash your hands with soap and water. Wrap the sign a second time in a plastic bag (i.e., garbage bag) and tape it closed. Wash your hands with soap and water. Place each sign in a sturdy carton. Use filler materials to assure a tight, rattle-free fit. Tape the seal flaps and seams. Label the carton: "RADIOACTIVE". Place this package into a second sturdy cardboard carton and include a piece of paper with the following words: "This package conforms to the conditions and limitations specified in 49 CFR 173.424 for radioactive material, excepted package-instruments or articles, UN2910." Use filler materials to assure a tight fit. Tape the seal flaps and seams. DO NOT label this outer carton "RADIOACTIVE." Before shipping, contact the manufacturer whose name appeared on the sign label. Make a report to NRC (see the table of reporting requirements in Question�4).

21. 21 UFC 3-600-01 1-3.1 Existing Facilities. Existing facilities must meet the requirements of NFPA 101, Life Safety Code, for existing occupancies. 1-3.1.1 Facilities that do not meet the requirements of NPFA 101 for existing facilities must be brought up to, at least the minimum requirements for UFC 3-600-01 26 September 2006 Change 1, 14 July 2009 3 existing facilities. If the facility cannot be brought up to the minimum requirements for existing facilities without initiating a renovation, modernization, or rehabilitation project, that project must meet the requirements for new construction as specified in this UFC. 1-3.1.2 Any changes in occupancy require the facility to meet the requirements for new construction for the new occupancy as specified in this UFC. 1-3.1 Existing Facilities. Existing facilities must meet the requirements of NFPA 101, Life Safety Code, for existing occupancies. 1-3.1.1 Facilities that do not meet the requirements of NPFA 101 for existing facilities must be brought up to, at least the minimum requirements for UFC 3-600-01 26 September 2006 Change 1, 14 July 2009 3 existing facilities. If the facility cannot be brought up to the minimum requirements for existing facilities without initiating a renovation, modernization, or rehabilitation project, that project must meet the requirements for new construction as specified in this UFC. 1-3.1.2 Any changes in occupancy require the facility to meet the requirements for new construction for the new occupancy as specified in this UFC.

22. 22 UFC 3-600-01 �This does not effect existing facilities.� Robert M. DiAngelo, P.E. Fire Protection Engineer Headquarters, USACE CECW-CE 1-3.1 Existing Facilities. Existing facilities must meet the requirements of NFPA 101, Life Safety Code, for existing occupancies. 1-3.1.1 Facilities that do not meet the requirements of NPFA 101 for existing facilities must be brought up to, at least the minimum requirements for UFC 3-600-01 26 September 2006 Change 1, 14 July 2009 3 existing facilities. If the facility cannot be brought up to the minimum requirements for existing facilities without initiating a renovation, modernization, or rehabilitation project, that project must meet the requirements for new construction as specified in this UFC. 1-3.1.2 Any changes in occupancy require the facility to meet the requirements for new construction for the new occupancy as specified in this UFC. 1-3.1 Existing Facilities. Existing facilities must meet the requirements of NFPA 101, Life Safety Code, for existing occupancies. 1-3.1.1 Facilities that do not meet the requirements of NPFA 101 for existing facilities must be brought up to, at least the minimum requirements for UFC 3-600-01 26 September 2006 Change 1, 14 July 2009 3 existing facilities. If the facility cannot be brought up to the minimum requirements for existing facilities without initiating a renovation, modernization, or rehabilitation project, that project must meet the requirements for new construction as specified in this UFC. 1-3.1.2 Any changes in occupancy require the facility to meet the requirements for new construction for the new occupancy as specified in this UFC.

23. 23 UFC 3-600-01 AR 420-1, Section VIII, Fire Protection Engineering �New construction, renovations and modernization projects will comply with UFC 3�600�01, Fire Protection Engineering for Facilities. For repair projects, only the new work is required to comply with the requirements for new construction. As a minimum, existing buildings will comply with the requirements of NFPA 101, Life Safety Code.� 1-3.1 Existing Facilities. Existing facilities must meet the requirements of NFPA 101, Life Safety Code, for existing occupancies. 1-3.1.1 Facilities that do not meet the requirements of NPFA 101 for existing facilities must be brought up to, at least the minimum requirements for UFC 3-600-01 26 September 2006 Change 1, 14 July 2009 3 existing facilities. If the facility cannot be brought up to the minimum requirements for existing facilities without initiating a renovation, modernization, or rehabilitation project, that project must meet the requirements for new construction as specified in this UFC. 1-3.1.2 Any changes in occupancy require the facility to meet the requirements for new construction for the new occupancy as specified in this UFC. 1-3.1 Existing Facilities. Existing facilities must meet the requirements of NFPA 101, Life Safety Code, for existing occupancies. 1-3.1.1 Facilities that do not meet the requirements of NPFA 101 for existing facilities must be brought up to, at least the minimum requirements for UFC 3-600-01 26 September 2006 Change 1, 14 July 2009 3 existing facilities. If the facility cannot be brought up to the minimum requirements for existing facilities without initiating a renovation, modernization, or rehabilitation project, that project must meet the requirements for new construction as specified in this UFC. 1-3.1.2 Any changes in occupancy require the facility to meet the requirements for new construction for the new occupancy as specified in this UFC.

24. 24 Possessors of TES are often unaware of the requirements Responsible person may not be identified especially when new ownership occurs TES are often mishandled when broken EPA concerns regarding tritium leachate in landfills pointed to TES disposal as the problem

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28. 28 EPA on-line training course Responsible Management of H-3 EXIT Signs www.trainex.org EM CX web site www.environmental.usace.army.mil Integrated Environmental Management www.iem-inc.com NUREG-1556 undergoing a 3 yr review and update process (complete June 2013) We hope you will find our content-rich web site to be a good example of our depth of understanding of radiological issues, and evidence of our commitment to keeping our clients and colleagues informed. 1556 �three core objectives incorporation of security requirements, removal of expolitable information, and general update for regulatory and policy changes enacted since the initial publicationsWe hope you will find our content-rich web site to be a good example of our depth of understanding of radiological issues, and evidence of our commitment to keeping our clients and colleagues informed. 1556 �three core objectives incorporation of security requirements, removal of expolitable information, and general update for regulatory and policy changes enacted since the initial publications

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