Appendix A ESOHMSs and ORPP Ge recycling 2020.pdf

Appendix A

Environmental Safety Occupational Health Management Systems and

Occupational Radiation Protection Program

HAMMOND DEPOT ESOHMS ORIENTATION GUIDE

FOR CONTRACTORS AND VISITORS

“I Am The Key”

Statement of Acceptance: I have received, read and accepted the information contained in this depot orientation guide and will brief other employees on the information contained herein.

Accepted by:

NAME COMPANY DATE

Hammond Depot Orientation Guide

INTRODUCTION

DLA Strategic Materials has developed an Environmental, Safety and Occupational Health Management System (ESOHMS) that is based on ISO 14001:2015 - "Environmental Management Systems - Specification with Guidance for Use" and Occupational Health and Safety Assessment Series (OHSAS) 18001 - "Occupational Health and Safety Management Systems - Specification.”

The ESOHMS encompasses all of our Environmental, Safety and Occupational Health (ESOH) policies and programs, and applies to all our employees and all those working on our behalf. We wish to inform visitors and others working at our depots about the key components of the ESOHMS. The purpose of this briefing is to ensure everyone is aware of our ESOHMS and the key environmental, safety and occupational health information that is critical to protecting human health and the environment.

ESOH POLICY STATEMENT

The Environmental, Safety and Occupational Health Policy Statement establishes the framework for the ESOHMS. As such, the ESOH Policy Statement provides the foundation for controlling the environmental impacts, safety and occupational health risks of its activities, commodities, and services and establishing environmental goals and objectives. The key elements of the ESOH Policy Statement include:

• Compliance with applicable laws and policies

• Continuous improvement

• Management review on a regular basis

• Communication with employees as well as the public

• Use of best management practices in protecting our natural resources and preventing pollution

• Providing the resources for all mandatory training

• A social responsibility toward their customers

FIVE COMMANDMENTS

The Five Commandments of the ESOHMS are:

1. Be Safe

2. Recycle

3. Conserve Our Natural Resources

4. Understand Your Job Responsibilities

5. Know What Regulations Apply To Your Job

Critical ESOHMS Information for Hammond Depot

EMERGENCY RESPONSE

The Hammond Depot has an Emergency Response Plan. The pages attached provide key contacts for the Hammond Depot. The Depot Manager, is the primary contact for emergencies (219) 937-5383 x 304 (office) or (571) 474-7628 (cell). Also, 911 emergency service is available in the area. In the event of an emergency, all contractors and visitors are directed to calmly make a spot check of their immediate work area, and then proceed to the depot security office, or if without transportation, exit work area to a safe distance, if necessary. Contractors and visitors are required to communicate all emergency information to the Depot Manager’s office immediately. The nearest emergency room is St. Margaret’s Mercy Hospital; directions and a map to the hospital are attached.

HAZARDOUS MATERIALS STORAGE

Hazardous materials stored at Hammond Depot are identified by National Fire Protection Association (NFPA) color-coded signs as follows:

BLUE – HEALTH HAZARD

RED – FIRE HAZARD

YELLOW – REACTIVITY

WHITE – SPECIFIC HAZARD

1 (one) is the Least Hazardous and 4 (four) is the Most Hazardous

POLLUTION PREVENTION

We have a pollution prevention policy and a spill prevention control and countermeasures policy.

Hammond Depot maintains a Storm Water Pollution Prevention (SWPP) Plan and a Spill Prevention, Control and Countermeasures (SPCC) Plan. These plans describe the aboveground petroleum storage tanks, commodity storage areas and other potential sources of contamination and the procedures to follow in the event of a spill or release. Aboveground storage tanks containing gasoline or diesel fuel are located in the vehicle fueling area, and in the pump house (see attached depot map).

Spills of petroleum or hazardous materials contaminate not only the stormwater runoff pathways, but also the soil and air. Spill response should be focused on protecting human health and preventing impacts to the environment. In the event of a spill, remember SWIM:

S – Stop the spill W – Warn others (and contact the depot manager) I – Isolate the area M – Minimize your exposure

The commodities stored at the depot could also pose a risk to the environment if released from the site.

Follow these best management practices when handling commodities:

• Identify and locate all storm drains and surface water flow pathways in the vicinity of the work area.

• Appropriate materials, such as hay bales, silt fence, or railroad ties, should be readily available and placed as a barrier between the commodity area and the storm drainage system, to help reduce the amount of any loose commodity material that could get washed into the drainage system by runoff from the outloading area.

• Surface runoff that flows towards nearby drainage ditches, swales, streams, etc., should also be similarly blocked.

• These activities should be performed not only while storm water runoff is actively occurring, but also to plan ahead for any rainfall, snowfall, snowmelt, etc. that may occur during the handling of commodities.

OTHER CONTRACTOR REQUIREMENTS

• Contractors working on site must advise the Depot Manager, in writing, of the presence of hazardous material, hazardous waste and their method of fuel supply.

• .Contractors must maintain (on-site) an SDS for all hazardous materials on site.

• Contractors must store and dispose of hazardous waste in accord with state, local & federal regulations.

• Contractors must conduct operations in accordance with applicable OSHA hazardous waste regulations (29 CFR 1910).

• Hazardous materials must be stored, used and transported in accordance with state, local and federal regulations.

• Contractors must comply with the depot recycling program.

• Contractors should refer all media enquiries regarding operations, environmental management, safety, occupational health, etc. to the Depot Manager.

(Visit the Depot main office for questions on our Hazard Communication Program and Procedures)

YOU ARE THE KEY!

The Environmental, Safety and Occupational Health Policy Statement provides the foundation for controlling the environmental impacts of our activities, commodities, and services and establishes environmental goals and objectives. Compliance with the SWPP and SPCC Plans and protecting water quality are a part of these goals.

It is your duty to keep an eye open to identify conditions that may contribute to contamination of storm water runoff. During your daily routine should you notice a potential problem, take the steps to fix it! Keep the lines of communication open.

Remember that whatever goes into the storm water system will end up in our groundwater or local waterways. Often times, that waterway is used for recreation, as a source for food (i.e., fish), and as a source for drinking water.

Depot Office (219) 937-5383 Security Guards-Main Gate

Office: (219) 937-5383, x 119 Cell: (219) 712-5996

Bomb Disposal and Federal Protective Service (312) 353-0735 FPS I Homeland Security - Battle Creek

(877) 719-4894 Poison Control Center:

(Emergency) (800) 222-1222 National Response Center and Terrorist Hotline (Oil & Toxic Chemical Spills from Terrorist Activity)

(Emergency) (800) 424-8802 FBI (Gary, IN) (219) 886-3795 Alarm Monitor- Emergency 24

(800) 877-3624 Gas and Electric- NIPSCO

(Emergency) (800) 634-3524

(Non-emergency) (800) 464-7726 or (219) 853-5050

Hammond Police (Non-emergency) (219) 853-6544

Indiana State Police (Non-emergency) (219) 769-8459

Hammond Fire Department (Non-emergency) (219) 853-6524

Telephone - SBC (24-hour repair) (800) 556-3000

Water - Hammond Water

(219) 853-6428

NIPSCO (219) 853-5050

St. Margaret Hospital (219) 93 2-2300

ORPP- Dewey Blair -· -

Office: (518) 370-3347 Cell: (518) 859-4938

Chain of Command for Emergency Events

1. Call 911 if appropriate.

2. Notify the Distribution Facilities Manager, Nate Walsko at:

(219) 937-5383, x 304 (Office), or (571) 474-7628 (Cell).

Alternate: Vanessa Brown: (703) 223-2311 (Cell)

EMERGENCY PHONE LISTING

The Hammond Depot phone system requires dialing 9 before calling outside numbers.

Use a wired (non-cellular) telephone if possible when calling 911. If using a cell phone, you may need to give your location to the 911 operator.

Local Emergency Phone Numbers

Fire Department (9) - 911

Police Department (9) - 911

Ambulance (9) - 911

NEAREST EMERGENCY ROOM

St. Margaret Mercy Hospital 5454 Hohman Ave.

Hammond, IN 46320

(219) 932-2300 or (708) 891-9305

Directions to St. Margaret Mercy Hospital:

1. Exit depot main gate, turn Right onto S. SHEFFIELD AVE., going towards E. 136TH ST. -

(0.6 mile)

2. Continue on S. HOHMAN AVE. – (2.2 miles)

3. Arrive at St. Margaret Mercy Hospital, on the right at 5454 S. HOHMAN AVE.

Note: Sources list hospital address as both Hohman Avenue and South Hohman Avenue.

Approximate travel time: 8 minutes. Approximate distance: 2.8 miles

Figure 1. Map to St. Margaret Mercy Hospital:

A indicates 3200 Sheffield Ave. (Hammond Depot)

B indicates 5454 S. Hohman Ave. (St. Margaret Mercy Hospital)

WOLF LAKE

SCALE HOUSE

OUTFALL

OUTFALL

-·--.._ 1

- D

AREA "c" CINDER

AREA "E" BLOCKS

AREA "D"

POND CONTRACTOR

MAINT. BLDG.

AREA "8" WAREHOUSE AREA "F" (55 GAL DRUM

No. 1 00-W USED OIL STORAGE)

LEGEND WAREHOUSE WAREHOUSE

---- PROPERTY LINE / No. 1 00-E No. 200-E WOLF LAKE

/ INDUSTRIAL CENTER

AST's

11111111111111111111 R.R. TRACKS SEE FIGURE 3

FOR MORE DETAIL AREA "G" AREA "J" AREA ''H''

AREA BOUNDARY

- - - DRAINAGE DITCH

GAR AGE & OFC.

ACCESS ROAD

c::::> SURFACE FLOW DIRECTION PUMP HOUSE

GUARD HOUSE

® SLAG PILES

• LIMESTONE PILES WETLANDS IDI WITH PILE NUMBER COMMODITY STOCKPILES

D BUILDINGS

·-· STREAM OR LAKE NOT TO SCALE

J2) SPILL KIT LOCATION

..----·) PROPOSED STORAGE PONDS

'--. (APPROXIMARE LOCATIONS)

FIGURE 2

HAMMOND DEPOT

HAMMOND. INDIANA

HAMMOND DEPOT SITE MAP

XREF1

P:\742714\HAMMOND\CAD\714C2FIG 2).DWG, 10:20, 3/4/04, CLW

MAI NTENANCE BLDG

(SEE NOTE 1)

AST-1 WAREHOUSE

No. 1 00-E

AST-2

AREA "G"

GARAGE AND OFFICE

c---------------------

PUMP HOUSE ACCESS ROAD

OFFICE

GATE

GUARD HOUSE

1. THREE PORTABLE GENERATORS ARE STORED

LEGEND IN VEHICLE MAINTENANCE BLDG.

[QJ INDICATES SOLID WASTE

BIN (DUMPSTER)

---- PROPERTY LlNE

11111111111111111111 R.R. TRACKS

AREA BOUNDARY

I I BUILDINGS

ABOVEGROUND STORAGE TANK (AST) IDENTIFICATION

NOT TO SCALE

AST ID NO. CAPACITY CONTENTS LOCATION

AST-1 1000 GALLONS GASOLINE FUELING STATION

J?) SPILL KIT LOCATION

1,_- I) PROPOSED STORAGE PONDS

AST-2 1000 GALLONS DIESEL FUEL FUELING STATION FIGURE 3

AST-3 140 GALLONS DIESEL FUEL PUMP HOUSE HAMMOND DEPOT

HAMMOND. INDIANA

AREA •A• DETAIL MAP

"-I (APPROXIMATE LOCATIONS)

XREF1

P:\742714\HAMMOND\CAD\714C3FIG 3).DWG, 10:20, 3/4/04, CLW

SCOTIA DEPOT ESOHMS ORIENTATION GUIDE

FOR CONTRACTORS AND VISITORS

January 2020

“I Am The Key”

Statement of Acceptance: I have received, read and accepted the information contained in this depot orientation guide and will brief other employees on the information contained herein.

Accepted by:

NAME COMPANY DATE

Hard copies of this document may not be the current version. Refer to the “I Am The Key” to verify the current version

Scotia Depot Orientation Guide

INTRODUCTION

DLA Strategic Materials has developed an Environmental, Safety and Occupational Health Management System (ESOHMS) that is based on ISO 14001:2015 - "Environmental Management Systems - Specification with Guidance for Use" and ISO 45001: 2018 - "Occupational Health and Safety Management Systems - Specification.". The ESOHMS encompasses all of our environmental, safety and occupational health (ESOH) policies and programs, and applies to all our employees and all those working on our behalf. We wish to inform visitors and others working at our depots about the key components of the ESOHMS. The purpose of this briefing is to ensure everyone is aware of our ESOHMS and the key environmental, safety and occupational health information that is critical to protecting human health and the environment.

ESOH POLICY STATEMENT

The Environmental, Safety and Occupational Health Policy Statement establishes the framework for the ESOHMS. As such, the ESOH Policy Statement provides the foundation for controlling the environmental impacts, safety and occupational health risks of its activities, commodities, and services and establishing environmental goals and objectives. The key elements of the ESOH Policy Statement include:

• Compliance with applicable laws and policies

• Continuous improvement

• Management review on a regular basis

• Communication with employees as well as the public

• Use of best management practices in protecting our natural resources and preventing pollution

• Providing the resources for all mandatory training

• A social responsibility toward their customers

FIVE COMMANDMENTS

The Five Commandments of the ESOHMS are:

1. Be Safe

2. Recycle

3. Conserve Our Natural Resources

4. Understand Your Job Responsibilities

5. Know What Regulations Apply To Your Job

Critical ESOHMS Information for Scotia Depot

EMERGENCY RESPONSE

The Scotia Depot has an Emergency Response Plan. The pages attached provide key contacts for the Scotia Depot. The Emergency Coordinator, is the primary contact for emergencies (518) 370-3347 (office). Also, 911 emergency service is available in the area. In the event of an emergency, all contractors and visitors are directed to calmly make a spot check of their immediate work area, and then proceed to the depot security office, or if without transportation, exit work area to a safe distance, if necessary. Contractors and visitors are required to communicate all emergency information to the Depot Manager’s office immediately. The nearest emergency room is St. Clare’s Hospital;

directions and a map to the hospital are attached.

HAZARDOUS MATERIALS STORAGE

Hazardous materials stored at Scotia Depot are identified by National Fire Protection Association (NFPA) color-coded signs as follows:

BLUE – HEALTH HAZARD

RED – FIRE HAZARD

YELLOW – REACTIVITY

WHITE – SPECIFIC HAZARD

1 (one) is the Least Hazardous and 4 (four) is the Most Hazardous

POLLUTION PREVENTION

We have a pollution prevention policy and a spill prevention control and countermeasures policy.

Scotia Depot maintains a Storm Water Pollution Prevention (SWPP) Plan and a Spill Prevention, Control and Countermeasures (SPCC) Plan. These plans describe the aboveground petroleum storage tanks, commodity storage areas and other potential sources of contamination and the procedures to follow in the event of a spill or release. Aboveground storage tanks containing gasoline or diesel fuel are located in the vehicle fueling area, and in the pump house (see attached depot map).

Spills of petroleum or hazardous materials contaminate not only the stormwater runoff pathways, but also the soil and air. Spill response should be focused on protecting human health and preventing impacts to the environment. In the event of a spill, remember SWIM:

S – Stop the spill W – Warn others (and contact the depot manager) I – Isolate the area M – Minimize your exposure

The commodities stored at the depot could also pose a risk to the environment if released from the site.

Follow these best management practices when handling commodities:

• Identify and locate all storm drains and surface water flow pathways in the vicinity of the work area.

• Appropriate materials, such as hay bales, silt fence, or railroad ties, should be readily available and placed as a barrier between the commodity area and the storm drainage system, to help reduce the amount of any loose commodity material that could get washed into the drainage system by runoff from the outloading area.

• Surface runoff that flows towards nearby drainage ditches, swales, streams, etc., should also be similarly blocked.

• These activities should be performed not only while storm water runoff is actively occurring, but also to plan ahead for any rainfall, snowfall, snowmelt, etc. that may occur during the handling of commodities.

OTHER CONTRACTOR REQUIREMENTS

• Contractors working on site must advise the Depot Manager, in writing, of the presence of hazardous material, hazardous waste and their method of fuel supply.

• Contractors must maintain (on-site) an SDS for all hazardous materials on site.

• Contractors must store and dispose of hazardous waste in accord with state, local & federal

• Contractors must conduct operations in accordance with applicable OSHA hazardous waste regulations (29 CFR 1910).

• Hazardous materials must be stored, used and transported in accordance with state, local and federal regulations.

• Contractors must comply with the depot recycling program.

• Contractors should refer all media enquiries regarding operations, environmental management, safety, occupational health, etc. to the Depot Manager.

(Visit the Depot main office for questions on our Hazard Communication Program and Procedures)

YOU ARE THE KEY!

The Environmental, Safety and Occupational Health Policy Statement provides the foundation for controlling the environmental impacts of our activities, commodities, and services and establishes environmental goals and objectives. Compliance with the SWPP and SPCC Plans and protecting water quality are a part of these goals.

It is your duty to keep an eye open to identify conditions that may contribute to contamination of storm water runoff. During your daily routine should you notice a potential problem, take the steps to fix it! Keep the lines of communication open.

Remember that whatever goes into the storm water system will end up in our groundwater or local waterways. Often times, that waterway is used for recreation, as a source for food (i.e., fish), and as a source for drinking water.

Depot Office (518) 370-3347 Security Guards-Main Gate

(518) 370-3346 Cell: (518) 858-4110

Bomb Disposal and Federal Protective Service

(518) 431-4310 Poison Control Center

(Emergency) (800) 222-1222 National Response Center and Terrorist Hotline (Oil & Toxic Chemical Spills from Terrorist Activity)

(Emergency) (800) 424-8802

Gas and Electric: Niagara Mohawk (Emergency) (800) 892-2345

(Power outages) (800) 867-5222

Sewer: Scotia Public Works

(518) 393-2159

Verizon Telephone (800) 722-2300 Fire Alarm Services: Alarm & Suppression, Inc.

Voice: (518) 399-5110 Fax: (518) 399-8702

St. Clare’s Hospital (518) 382-2000 Ellis Hospital (518) 243-4000 Radiological, Dewey Blair:

Office: (518) 370-3347 Cell: (518) 859-4938

Chain of Command for Emergency Events

1. Call 911 if appropriate.

2. Notify the Emergency Coordinator at: (518) 370-3347

(office), or (518) 859-4938 (cell).

EMERGENCY PHONE LISTING

Use a wired (non-cellular) telephone if possible when calling 911. If using a cell phone, you may need to give your location to the 911 operator.

The Scotia telephone system does not require a “9” before calling outside numbers.

Local Emergency Phone Numbers

Fire Department 911

Police Department 911

Ambulance 911

Water: Glenville Public Works

(518) 382-1406

END

NEAREST EMERGENCY ROOM

The closest Emergency Room to Scotia Depot is at:

St. Clare’s Hospital 700 McClellan Street Schenectady, NY 12304

(518) 382-2000

Directions to hospital:

1. Exit depot and travel 1 block east in Corporations Park.

2. Turn RIGHT (south) on Capital Boulevard

3. Follow Capital Blvd (approx 2/10 mile) to NY Route 5.

4. Turn LEFT onto NY Route 5. Continue to follow NY-5, through Scotia and over the bridge into Schenectady. (3.8 miles)

5. Turn LEFT onto MCCLELLAN ST. (0.6 mile)

6. End at St. Clare’s Hospital.

Total Est. Time: 15 minutes Total Est. Distance: 4.6 miles

Figure 1. Map to Hospital indicates Scotia Depot; indicates St. Clare’s Hospital at 700 McClellan Street. START

II

1-----------,_) \: _r---- --0 1-

NOTES:

1. "S" INDICATES NEW SECURITY CENTER.

2. SYMBOLS FOR ASTS AND TRANSFORMERS

ARE NOT TO SCALE.

403 503 1-\ rI •r

LEGEND

h'----------' L l ' ------------------------------------------------ ' - t_ -----' - I l. . ----- 1 DNSC PROPERTY LINE

-- -- ------J-=---=-r===== ----- 1/

23 /

TRANSFORMER LOCATIONS

INSIDE BUILDINGS (APPROXIMATE)

ABOVEGROUND STORAGE TANKS (AST)

STORM SEWER

MANHOLES

CATCH BASINS

INDICATES FLOW OF

STORMWATER DRAINAGE

SPILL KIT LOCATION

-- ---- ==;:::.--w... c_ _J L J '---------' ...:====::::;----' =

I I -

506 I

X X-

- .... _w --------- '

- T

G l

I

I/

XREF: P:\742714\CAD\BASE-1.DWG

P:\742714\SCOTIA\CAD\714C001FIGURE2.dwg, 5/13/09

200 100 0 200 400

APPROX. SCALE: 1 "=200'

FIGURE 2

DLA/DNSC SCOTIA DEPOT

SCOTIA. NEW YORK SPCC

PLAN

OIL PRODUCT STORAGE LOCATIONS

PARSONS

290 ELWOOD DAVIS ROAD, SUITE 312. LIVERPOOL. N.Y. 13088, PHONE: 315-451-9560

I

ABOVEGROUND STORAGE TANK (AST) IDENTIFICATION

AST ID NO. CAPACITY CONTENTS LOCATION

10 560 GALLONS DIESEL FUEL CENTER TANK ON FUEL ISLAND

11 250 GALLONS KEROSENE NORTH TANK ON FUEL ISLAND

20 1 ,000 GALLONS GASOLINE SOUTH TANK ON FUEL ISLAND

OCCUPATIONAL

RADIATION PROTECTION

PROGRAM

Defense Logistics Agency – Strategic Materials

(DLA-SM)

January 2020

Hard copies of this document may not be the most current version. Refer to https://www.dla.mil/HQ/Acquisition/StrategicMaterials/iamthekey/ to verify the most current version.

http://www.dla.mil/HQ/Acquisition/StrategicMaterials/iamthekey/

Occupational Radiation Protection Program DLA SM January 2020

PREFACE

This January 2020 revision of the Defense Logistics Agency Strategic Materials (DLA-SM) Radiation Protection Guidelines supersedes all previous publications relating to radiological protection for DLA Strategic Materials personnel and property.

It is the goal and stated policy of DLA Strategic Materials to establish appropriate and adequate procedures and controls to minimize exposure to ionizing radiation to DLA Strategic Materials employees and the general public to “As Low As Reasonably Achievable” (ALARA). Adherence to the guidance set forth in this document will maintain the protection necessary to achieve this goal and greatly minimize the biological effects of low-level radiation exposure.

TABLE OF CONTENTS

TITLE PAGE

1. PURPOSE 1

2. SCOPE 1

3. RESPONSIBILITY 1

4. PROGRAM REQUIREMENTS 1

5. CONTROL MEASURES 3

6. PRECAUTIONARY MEASURES 5

7. WASTE DISPOSAL 6

8. WARNING SIGNS, LABELS, MARKINGS AND PLACARDS 6

9. EXPOSURE CRITERIA 6

10. STANDARDS AND REGULATIONS 8

11. SURVEYS 8

12. DECONTAMINATION & DECOMMISSIONING 8

13. INSTRUMENTATION 8

14. EMERGENCY PROCEDURES 9

15. MEDICAL SURVEILLANCE 9

16. RECORDS 9

17. TRAINING 9

APPENDIX A DEFINITIONS 10

APPENDIX B APPLICABLE REGULATIONS 16

APPENDIX C UNITS OF RADIOLOGICAL MEASUREMENT DNSC 18

APPENDIX D RADIOLOGICAL SAFETY OFFICER 21

APPENDIX E DEMONSTRATING COMPLIANCE WITH PUBLIC DOSE 23

APPENDIX F ANNUAL SURVEY REPORT TEMPLATE 27

1. Purpose

The policy stated herein establishes guidelines for protection against ionizing radiation and an "Occupational Radiation Protection Program" (ORPP) for the handling and storage of licensed radioactive source materials at DLA Strategic Materials facilities.

2. Scope

These guidelines apply to all DLA Strategic Materials personnel, visitors, and contractor personnel who, by the nature of their duties, may be exposed to ionizing radiation at locations where licensed DLA-SM radioactive materials are stored.

3. Responsibility

3.1 The Chief, Environmental Management is responsible for the development and overall administration of the ORPP. It is the responsibility of the Radiological Safety Officer (RSO) listed on the NRC license to carry out the functional responsibilities included in these guidelines.

3.2 The Chief of Environmental Management is responsible for nominating an RSO and assuring that they attend the required training course(s).

3.3 The RSO is responsible for monitoring the effectiveness of the radiological programand extending the training program among personnel as required.

3.4 The Facility Manager and Depot RSO are responsible for the day to day supervision of the

ORPP at their facility. They are also responsible for and will ascertain that prescribed monitoring and safety precautions are taken with respect to radioactive materials.

3.5 It is the responsibility of the RSO or Designated alternate to immediately notify the appropriate responsible officials (i.e., fire department, DLA-SM officials, etc) and take appropriate action in the event of an incident involving the release or potential release of radioactive materials in accordance with the Depot’s Emergency Protection Plans.

4. Program Requirements

An active, closely supervised ORPP will be implemented at a high level of organization, training, and proficiency. In implementing and maintaining the ORPP, the following specific requirements will be observed:

4.1 The RSO will maintain current copies of this ORPP. The RSO will periodically review all plans and procedures, care for and maintain instruments, inspect records and materials in storage.

4.2 All personnel entering a restricted area shall first complete a DD Form 1952,“Dosimeter

Application and Record Of Occupational Radiation Exposure”. Mailing addresses shall be obtained for all Non-DLA-SM personnel and dosimetry results shall be forwarded to them, annually. A permanent record on DD Form 1141, Record of Occupational Exposure to Ionizing Radiation, will be maintained for each potentially exposed person (whenmonitoring has been provided), by the Depot RSO. A computer-generated form containing the same information as the printed DD Form 1141 is authorized; this will be referred to as the Automated Dosimetry Record (ADR).

4.3 Section 206 of Public Law 93-438 “Energy Reorganization Act of 1974”, NRC Form3

"Notice To Employees", “Notice of Violation” involving radiological working conditions (within two working days after receipt of the documents from the Commission and for a minimum of 5 working days or until action correcting the violation has been completed, whichever is later), and the location of the NRC license will be posted so as to be clearly visible.

4.4 The depot will have on hand, at a minimum, two instruments capable of detecting alpha and gamma radiation, one alpha and one gamma check source, and TLD’s for each employee. A supply of TLD’s shall also be maintained for use by occasional visitors at any facility that has a restricted area.

4.5 The RSO shall make, at a minimum, one survey per year at the depot to review; 1) records, 2) inventories of instruments, check sources and licensed materials, 3) instrument calibration, 4) dosimetry services, and 5) Emergency Protection Plans. During the survey they shall also monitor all licensed material and evaluate radiation safety procedures through observation and discussion with depot employees. Further, they shall prepare a comprehensive report detailing their annual survey and forward the same to the ORPM. The survey reports shall also: 1) Utilize a format and include a checklist; 2) contain a written evaluation of public dose compliance as noted in 10 CFR 20.1302 and 3) note the specific range of employee accumulated doses for the past year.

4.6 The RSO shall review and document the review of all exposure records (DD Form 1141 or

ADR) annually. The RSO shall notify each person monitored of his/her accumulated dose and obtain written acknowledgements from the employees that shall be placed in the depot records annually. The notification shall be in accordance with the requirements of Title 10 CFR 19.13 and include the statement: “This report is furnished to you under the provisions of the NRC regulation 10 CFR Part 19. You should preserve this report for further reference”.

Additionally, the depot RSO shall monitor operational activities relating to licensed radioactive materials, and maintain appropriate records of such operations.

4.7 The RSO shall be responsible for the coordination of shipments and paperwork, including Nuclear

Regulatory Commission reporting requirements. Strict compliance with 49 CFR § 173 shipping and labeling requirements shall be observed.

4.8 Once each fiscal year, the RSO shall coordinate with the Depot Facility Manager to set aside a monthly safety meeting for radiation protection training. The RSO(s) shall provide the training to all personnel except the guard force and clerical staff. Upon completion of the training, the RSO shall notify the Chief, Environmental Management, in writing, of the names of all attendees at the meeting. Training of the guard force will be accomplished in the form of written instructions.

4.9 The Chief of Environmental Management or their designee shall audit the program by reviewing the annual reports submitted to determine compliance with the requirements of the NRC license and the ORPP, and shall also annually review the overall licensed radiation protection program, NRC regulations, provisions of the NRC License and compliance status of the National Defense Stockpile program. The ORPM shall report any adverse findings to senior management and shall forward each annual survey to the Depot Manager to advise the status of the program at the depot.

4.10 The RSO shall conduct a physical inventory of all NRC licensed material (if material is present) once each fiscal year. This inventory shall be documented in writing and kept on file at the depot. A copy shall be forwarded to the Chief of Environmental Management.

Shipments or receipts of licensed material shall be reported by the RSO directly to the Chief of Environmental Management.

4.11 The RSO shall establish a Decommissioning File at each open location listed on the license. The file shall contain the following records:

a. Documentation indicating where radioactive materials have been stored, handled, or used;

b. Documentation of any spills or areas found to be contaminated;

c. Copies of all annual surveys and surveys performed after sampling repackaging or shipping activities; and

d. Inventories and documentation regarding disposal, sale or shipment of radioactive commodities.

5. Control Measures

The greatest emphasis should be placed on engineering control measures to reduce exposures to levels "As Low As Reasonably Achievable" (ALARA).

5.1 Ventilation, Dust Collection, Isolation, and Facility Layout. Ventilation systems are not normally utilized during regular handling and storage of licensed material within DNSC as material is normally kept in unopened, sealed containers. However, local exhaust ventilation systems may be necessary in the rare event of a special project.

Prior to the beginning of a repackaging or decontamination project, an assessment shall be made by the RSO in conjunction with other stockpile personnel, to determine if there is a need for additional controls. Engineering controls such as, but not limited to, isolation, enclosure, exhaust ventilation and dust collection shall be used to meet the NRC exposure limit criteria.

5.2 Access. The layout of storage facilities shall be such that it minimizes exposure to ionizing radiation. For example, radioactive commodities shall be consolidated and isolated to limit access. Warehouses shall generally be kept locked and sealed and a log maintained to control the issuance of numbered seals. Depot access is to be controlled by perimeter fences along the site boundary and a full time securityforce.

5.3 Shielding. For materials stored inside buildings or structures, if necessary, highly dense material in drums can serve as an effective perimeter shield. Normally, lead, concrete, or a combination of the two is used to attenuate the highly penetrative gamma rays. If shielding material is installed, special attention should be paid to such details as overlapping joints, eliminating voids or non-homogeneities in the shielding material, the need for structural support for non-load bearing material such as lead, the need to ensure proper attenuation through leaky areas in the shield, (e g., glass windows, joints, seams, pipes, conduits, service boxes and doors). There is also a need for continuous maintenance of the shielding structure, to prevent deterioration.

5.4 Time. The longer a person is exposed to radiation, the greater the biological risk. It should be understood that work operations involving radioactive stockpile commodities, particularly thorium, should take into account the length of time a person is exposed to a given dose of radiation. Personal monitoring, in conjunction with radiation surveys, is necessary to ensure that workers; a) are not exposed to radiation in excess of NRC regulations and b) exposure for a particular work task is maintained ALARA

5.5 Distance. Distance is a practical method of reducing the amount of radiation exposure to persons conducting stockpile work operations in and around radioactive materials. The levels of radiation decline rapidly as the distance is increased between the source and the person.

5.6 Protective Equipment. Every effort shall be made to reduce potential radiation exposures by the methods noted above. There may be times, however, when personal protective clothing and equipment will be the primary means of personnel protection, especially for airborne radionuclide particulates. Respirators shall be chosen for use according to the DLA Strategic Materials Occupational Health Guidelines for Respiratory Protection. Such respirators shall be approved for use in atmospheres containing radionuclides by the National Institute for Occupational Safety and Health (NIOSH). The specific type of respiratory protective equipment to be used shall be based on the judgment of the RSO.

Special training is necessary for the proper usage of personal protective clothing and equipment; such training (except for the care and use of respirators) is the responsibility of the RSO. Respiratory protection training is the responsibility of Respiratory Protection Designees as noted in the DLA Strategic Materials Respiratory Protection Program

6. Precautionary Measures.

There are a number of measures that the Radiation Safety Officer and other depot personnel should be aware of at all times:

• the amount of exposure should be controlled in accordance with section 5.0 of this document;

• employee rotation (dose sharing);

• eating, drinking, smoking or chewing gum is strictly prohibited in areas containing radioactive materials;

• personal belongings such as: watches, rings, combs, etc shall not be worn while working in restricted areas;

• persons with open wounds shall not be allowed work in areas containing radioactive materials;

• if a person receives a cut or wound during a work operation involving radioactive materials, they shall immediately be removed from that area and the wound shall immediately be attended to;

• containers of licensable radioactive materials that are to be received into the Defense National Stockpile shall be thoroughly inspected for contamination and leaks prior to storage; in accordance with 10 CFR 20.1906;

• engineering controls, such as shielding, local exhaust ventilation, dust collection and isolation shall be used when and where necessary;

• handling of radioactive materials shall be carried out in a manner, which will prevent damage to the containers and reduce radiation exposure to ALARA;

• personnel shall exercise good personal hygiene habits (e.g., washing and showering thoroughly) when conducting work operations involving contact with radioactive materials;

• personnel shall wear personal protective equipment when conducting work operations where they may come into contact with airborne radioactive materials, or their gases;

• personnel shall be monitored by dose rate and contamination surveys during and after contact with licensed radioactive materials;

• radiation doses measured by personal dosimetry shall be recorded immediately after determination of the dose; and

• shipment of licensed materials shall be in accordance with all federal, state, and local

7. Waste Disposal.

Shipment of radioactive waste is performed by a Department of Defense (DoD) Broker under contract to the DoD Executive Agent for Low-Level Radioactive Waste (US Army Joint Munitions Command). The broker is responsible for packaging the items and shipping them in accordance with applicable DOT regulations. The RSO is responsible for ensuring that all work performed by the broker is performed in accordance with the ALARA principle, standard radiological health practices, and this manual.

8. Warning Signs. Labels. Markings and Placards.

8.1 General. Documents, notices, signs, or forms shall be conspicuous, and shall be replaced if defaced or otherwise rendered illegible.

8.2 Notices. Items a., b, & d. below shall be posted such that workers have access to them as they travel to/from work. The other items can be posted with a notice as to where personsentering a Radioactive Materials Area (RAM) can review them:

a) NRC Form 3, Notice to Employees.

b) 10 CFR Parts 19, 20, 21

c) NRC license for DLA Strategic Materials and amendments

d) Notice of Violation, or any other applicable infraction, involving radiologicalworking conditions.

e) Section 206, Energy Reorganization Act

8.3 Radioactive Material (RAM) Areas. Radioactive Material Areas shall be posted at each entrance of a building, room, or area. An area within a building may be designated a RAM area by the use of stanchions positioned such that the posting is clearly visible from each avenue of approach.

• Restricted areas where dose rates exceed 5.0 mR/hr at any point shall be postedwith conspicuous signs in accordance with 10 CFR 20.1902(a).

• Any area which contains more than 1,000 microcuries of licensed material shallbe posted with conspicuous signs in accordance with 10 CFR 20.1902(e).

9. Exposure Criteria and Evaluation.

There are some basic assumptions that have been derived in formulating radiation protection guidelines. They are: 1) the biological effects of low level radiation are not precisely known, 2) there is no known level of radiation below which there will be no biological effects, and 3) there is a linear relationship between biological effects and dose.

Permissible levels of radiation exposure in an occupational environment are set higher than in a non-occupational environment.

9.1 DLA Strategic Materials Exposure Criteria.

9.1.1 The maximum permissible occupational dose is 5.0 rems per year. The maximum permissible dose to members of the public is 100 millirem per year.

9.1.2 The DLA Strategic Materials maximum permissible dose rate within a controlled area shall not exceed 0.50 mR/hr. A Restricted Area shall be established where dose rates exceed 0.50 mR/hr at a distance of one foot from the material.

9.1.3 TLD’s shall be used by ALL personnel entering a restricted area where they are likely to receive, in one year, a dose in excess of 500 mRem. The RSO will annually evaluate the need for personnel dosimetry at the depot and document the evaluation in the annual survey.

9.1.4 The DLA Strategic Materials maximum permissible dose rate at the perimeter fence of the storage facility shall not exceed background.

9.1.5 Minors shall not be permitted to enter restricted areas.

9.1.6 Because of the DLA Strategic Materials mission and operational structure, exposure to radiation is limited. It is, however, recognized that radiation exposure can produce damaging effects to embryos and fetuses, especially when received during certain periods of gestation.

Because of this sensitivity, it is DLA Strategic Materials policy to minimize fetal exposure to radiation. DLA Strategic Materials employees who are at risk for occupational exposure and who are pregnant, or believe that they could be pregnant, are encouraged to notify their supervisor and/or Radiation Safety Officer, in writing, and to discuss the situation, risks, and possible consequences of continued exposure. All such discussions will remain confidential.

All female employees likely to receive an occupational dose, and all supervisors at NRC licensed sites, shall be given a copy of NRC Regulatory Guide 8.13, “Instructions Concerning Prenatal Radiation Exposure” and instructed in the potential risks of exposure to ionizing radiation during pregnancy.

Upon receipt of a written notification containing the estimated date of conception, pregnant employees shall be provided with an alternate work assignment comparable to their current position that will eliminate occupational exposure to radiation during the remainder of their pregnancy.

Declared pregnant workers (DPW) will not be exposed to more than 100 millirem during the gestation period after they have declared their pregnancy in writing to their supervisor.

Supervisors are responsible for informing the RSO of all such declarations as soon as possible, providing a copy of the declaration to the RSO and taking appropriate action to limit the worker’s potential exposure for the remainder of the pregnancy. If the worker has already received 100 millirem from the time of conception to the time of declaration, contact the ORPM for additional guidance. DLA Strategic Materials employees unable to continue their regular duties because of this limitation will be provided with an alternative work assignment, free from occupational radiation exposure, that will have no adverse effect on their rate of pay, benefits or promotion.

10. Standards and Regulations.

Applicable standards, regulations and guidelines shall be fully understood and complied with when handling, storing, or, shipping licensed radioactive materials in the Defense National Stockpile. A list of these standards can be found in Appendix B.

11. Surveys

Annual radiological surveys shall be conducted by an RSO at each open facility listed on the license. They shall include, but not be limited to, a physical survey of the material and equipment, review of records, review of training, and interviews of the Distribution Facility Manager.

As a minimum the survey shall include the requirements outlined in 10 CFR Part 20. 1501.

Surveys shall also include measurements of dose rates at contact with the container (where practical), at one foot distance, at the perimeter of any restricted area, and at the depot perimeter if the depot contains a restricted area. (NOTE: In lieu of radiological measurements at the Depot perimeter, measurements may be taken within the controlled area at a point where levels of radiation do not exceed background.) The RSO shall also document the location of licensed materials in the depot and assure that an inventory was conducted within the past 365 days.

12. Decontamination & Decommissioning

When closing out a facility or "decommissioning" a specific storage building, area, material or equipment, residual radioactive contamination must be addressed. The procedures, level or limits established by the Nuclear Regulatory Commission (NRC) in their document NUREG 1757 “Consolidated Decommissioning Guidance: Decommissioning Process for Materials Licensees” shall be used. Specific procedures shall be developed by the Chief of Environmental Management. Decontamination actions shall be documented in writing.

13. Instrumentation

13.1 Monitoring instruments shall have sufficient sensitivity, precision, and dynamic range to accommodate the type of radiation being measured.

13.2 The monitoring level on the instruments should be set at the level of radiation expected to be encountered. Review of previous survey results in the area will provide the expected levels.

13.3 Annual calibration of all monitoring instruments is mandatory. Calibration must be performed by a laboratory possessing a valid NRC or Agreement State license. When the instruments are received from the calibration facility, establish a baseline for future operational checks by taking a reading with the appropriate check source. Place a written record of the date, reading, instrument and source serial numbers in the depot calibration file.

13.4 TLD’s must be obtained from, processed and evaluated by, the Department of the Army

Ionizing Radiation Dosimetry Center.

14. Emergency Procedures

14.1 The Depot Manager will establish an Emergency Protection Plan. This plan shall be reviewed and/or updated annually. The revisions must be reviewed by the RSO.

14.2 Prior arrangements should be established with local police and fire departments, hospitals, in-house and outside emergency squads and other medical facilities. Evacuation routes and assembly points should be designated. Documentation of meetings/contacts with outside agencies shall be maintained.

15. Medical Surveillance

A pre-employment and annual medical examination program for stockpile employees potentially exposed to hazardous and radioactive materials shall be conducted. Complete medical records for each employee shall be maintained by the servicing health unit.

16. Records

16.1 The Nuclear Regulatory Commission requires each licensee to keep exposure, monitoring, survey, disposal, and decontamination records. These records shall be kept indefinitely at the depots where the licensed material is stored. Copies of radiation surveys will be forwarded to the DLA Strategic Materials Headquarters.

16.2 The RSO for each site where licensed source material is stored will establish a Radiological

Data Book containing license data, exposure data, calibration data, the DLA Strategic Materials ORPP and all other documents related to the source material at the site. Included shall be written records of quarterly exposure reviews, annual radiation exposure notifications, and initial and annual radiation safety training.

17. Training

17.1 Radiological officers shall be given at least 40 hours formal classroom training commensurate with their assigned duties and specific to their responsibilities within the DLA Strategic Materials ORPP. At minimum, the training shall include: the fundamentals of ionizing radiation, its characteristics, and appropriate units of measure, evaluation techniques, instrumentation, biological effects, NRC Regulations, and control measures. Refresher training shall be provided triennially. Additionally, radiological officers shall receive training in DOT Regulations.

17.2 All depot personnel (except clerical staff and security personnel) shall receive annual training regarding potential hazards, precautions to minimize exposure, work practices and operating procedures, personal hygiene, information contained in NRC Regulatory Guide 8.13, and use of personal protective clothing and equipment. The RSO shall develop a detailed, site specific, outline which will be kept on file at the depot. Attendance at all training sessions shall be documented and lists kept on file (See paragraph 4.8).

17.3 Security personnel should not encounter radiological hazards during the performance of their duties. They will be instructed to not enter the restricted area. They will be instructed to only guide emergency personnel to the restricted area and not to enter in the event of an emergency.

APPENDIX A

DEFINITIONS

DEFINITIONS

Absorbed dose means the energy imparted by ionizing radiation per unit mass of irradiated material. The units of absorbed dose are the rad and the gray (Gy).

Activity is the rate of disintegration (transformation) or decay of radioactive material. The units of activity are the curie (Ci) and the becquerel (Bq).

Adult means an individual 18 or more years of age.

Airborne radioactive material means radioactive material dispersed in the air in the form of dusts, fumes, particulate, mists, vapors, or gases.

Airborne radioactivity area means a room, enclosure, or area in which airborne radioactive materials, composed wholly or partly of licensed material, exist in concentrations:

(1) In excess of the derived air concentrations (See Appendix B, 10 CFR Part 20) or,

(2) To such a degree that an individual present in the area without respiratory protective equipment could exceed, during the hours an individual is present in a week, an intake of 0.6 percent of the annual limit on intake (ALI) or 12 DAC hours.

ALARA (acronym for "as low as is reasonably achievable") means making every reasonable effort to maintain exposures to radiation as far below the dose limits in this part as is practical, consistent with the purpose for which the licensed activity is undertaken, taking into account the state of technology, the economics of improvements in the relation to state of technology, the economics of improvements in relation to benefits to the public health and safety, and other societal and socioeconomic considerations, and in relation to utilization of nuclear energy and licensed materials in the public interest.

Background Radiation means radiation from cosmic sources, naturally occurring radioactive materials, including radon (except as a decay product of source or special nuclear material) and global fallout as it exists in the environment from the testing of nuclear explosive devices.

"Background radiation" does not include radiation from source, byproduct, or special nuclear materials regulated by the Commission.

Bioassay (radiobioassay) means the determination of kinds, quantities or concentrations and in some cases, the locations of radioactive material in the human body, whether, by direct measurement (in vivo counting) or by analysis and evaluation of materials excreted or removed from the human body.

Byproduct material means

(1) Any radioactive material (except special nuclear- material) yielded in, or made radioactive by, exposure to the radiation incident to the process of producing or utilizing special nuclear material; and,

(2) The tailings or wastes produced by the extraction or concentration of uranium or thorium from ore processed primarily for its source material content, including discrete surface wastes resulting from uranium solution extraction processes. Underground ore bodies depleted by these solution extraction operations do not constitute "byproduct material" within this definition.

Collective dose is the sum of the individual doses received in a given period of time by a specified population from exposure to a specified source of radiation.

Committed dose equivalent means the dose equivalent to organs or tissues of reference that will be received from an intake of radioactive material by an individual during the 50-year period following the intake.

Committed effective dose equivalent is the sum of the products of the…