PROCEDURE-10 TRAINING PROGRAMthat may involve radioactive materials and/or radioactive...

VISTA Technologies, Inc. Radiation Safety Program

PROCEDURE-10

TRAINING PROGRAM

TECHNOLOGIES

1019 Central Parkway North, Suite 115 San Antonio, Texas 78232

210-494-4282

TABLE OF CONTENTS

TRA INING ............................................................................................................................................................ 1

1.1 On-Site Radiation Offi cer .............................................................................................................................. 2

1.2 Field Technical Staff Working in Ionizing Radiation Controlled Areas .................................................. 3

1.2.1 M aterials ................................................................................................................................................ 4

1.2.2 Specific Instructions .............................................................................................................................. 4

1.2.3 Training Outline .................................................................................................................................... 6

1.2.4 Industrial Hygiene and Health Physics ............................................................................................. 6

1.2.5 Pre-Field Review of Field Sampling Plans, Sampling and Analysis Plans, and Instruction Guides ... 7

1.2.6 Docum entation ...................................................................................................................................... 7

1.3 Site Radiation Health and Safety Orientation and Training ...................................................................... 8

1.3.1 Instructor ............................................................................................................................................... 8

1.3.2 Site-Specific Health and Safety Orientation and Training ................................................................ 9

1.3.3 Docum entation .................................................................................................................................... 12

1.4 Supplem ental Radiation W orker Training ................................................................................................ 13

1.4.1 Introduction ......................................................................................................................................... 13

1.4.2 Specific Classroom Instructions ...................................................................................................... 14

1.4.3 Docum entation .................................................................................................................................... 16

1.5 Radiation W orkers ....................................................................................................................................... 16

1.6 On-Site V isitors ........................................................................................................................................... 17

List of Tables

Table 1.1-1 - Training Requirements For Vista Employees For Radiological Work ................................................... 3

Table 1.4-1 - Estim ated Loss of Life Expectancy From Health Risks .................................................................... 14

i

List of Attachments

Attachment Number Name of Attachment

5 Training Notice and Record Form

6 Site Activities Training Form

7 Health and Safety Training Form

8 Health and Safety Training Daily Attendance Sheet

Form

9 NRC-Regulatory Guide 8.13

10 General Radiation Protection Rules

11 General Safety Work Rules and Guidelines

12 Prohibited Practices in Chemically Contaminated

Area

13 Clean Site Workers Weekly Status Report Form

14 Health and Safety Database Site Worker

Information Input Form

15 NRC-4 Equivalent Form "Occupational External

Radiation Exposure History" Instructions 16 Occupational Radiation Exposure History

Employee Acknowledgement Form 17 Hazard Communication Training Record Form 18 Respiratory Protection Attendance Record Form

19 Respiratory Protection Education and Fit Testing

Form

Procedure 10 Attachments

ABBREVIATIONS AND ACRONYMS

c - Alpha B Beta y - Gamma Ii - Micro

241Am - Americium-241 137 Ce - Cesium-137 234Pa - Protactinium-234 2 opb - Lead-210 210po - Polonium-210 214po - Polonium-214 218po Polonium-218 32PU- Plutonium-232

226Ra - Radium-226 228Ra - Radium-228 21P.n Radon-219 (Actinium Series) 22°Rn - Radon-220 (Thorium Series) 222n - Radon-222 (Uranium Series)

89Sr - Strontium-89 9OSr - Strontium-90 230Th - Thorium-230 232Th - Natural Thorium 238U - Uranium-238

1iCi - MicroCurie gCi/hr - MicroCuries per hour itCi/ml - MicroCuries per milliliter jIM - Micrometer jiRlhr - MicroRoentgen per hour gg/mg - Microgram per milligram

ALARA - As low as reasonably achievable ALl - Annual limit on intake ANSI - American National Standards Institute APR - Air-purifying respirator

Bq - Becquerel Bq/m 3 - Becquerels per cubic meter of air BZ - Breathing Zone

C - Coulomb C/kg - Coulombs per kilogram CDE - Committed Dose Equivalent CEDE - Committed Effective Dose Equivalent

CFR - Code of Federal Regulations Ci - Cunre CIH - Certified Industrial Hygienist CFM - Cubic feet per minute CLIA - Clinical Laboratories Improvement Act

CLP - Contract Laboratory Program cm - Centimeter cm/sec - Centimeters per second cpm - Counts per minute CPR - Cardiopulmonary resuscitation CSE - Certified Safety Executive

(D) - Duplicate count DAC - Derived air concentration DAC-h - DAC hours DCA - Double Contingency Analysis DDE - Deep Dose Equivalent DI - De-ionized water DOT - U.S. Department of Transportation

dm 2 - Square Decimeter; one square decimeter equals 100 square centimeters

dpm - Disintegrations per minute dpM/cm 2

- Disintegrations per minute per square centimeter

dpm/dm2 - Disintegrations per minute per square decimeter dps - Disintegrations per second

DRD - Direct reading dosimeter DU - Depleted uranium

EPA - U.S. Environmental Protection Agency eV - Electronvolt

FE - Feces sample FIDLER - Field instrument for detection of low energy radiation

FR - Filter ratio FSP - Field Sampling Plan ft2

- Square foot

y - Gamma ray GA - General area GeLi - Germanium - Lithium G-M - Geiger-Mueller GMC-H - Mine Safety Appliances Company, full-facepiece, dual ..combination filter

cartridges for an APR

GPD - Gaseous Diffusion Plang

h hours lte-3 - helium Three (3)

HEPA - High efficiency particulate air HN0 3 - Nitric acid HP - Health Physics hr - Hour HS - Hot spot (radiation) HSP - Site-specific Health and Safety Plan HWP - Hazardous Work Permit

ICRP - International Commission on Radiological Protection ID - Identification IDLH - Immediately dangerous to life or health IDW - Investigation derived waste IP - Ionization potential IVC - Independent verification contractor

keV - Kiloelectronvolt kg - Kilogram

LANL - Los Alamos National Laboratory 1pm - Liters Per Minute

MCA - Multi-channel analyzer MDA - Minimum detectable activity meV - Millielectronvolt m - Meter m2

- Squared Meters m3

- Cubic meters mCi - MilliCurie MSHP - Manager, Vista Safety and Health Program mil - 1/1000 inch ml - Milliliter mm - Millimeter mR - MilliRoentgen mR/hr - MilliRoentgens per hour mrem - Millirem mrem/hr - Millirems per hour MSA - Mine Safety Appliances Company MSDS - Material Safety Data Sheet MSHA - Mine Safety and Health Administration

NaI - Sodium iodide NCA - Nuclear Criticality Analysis NCS - Nuclear Criticality Safety NCRIP - National Council on Radiation Protection and Measurements NEA - Nuclear Energy Agency NIST - National Institute of Science and Technology

Iyat Natural uranium UR - Urine sample U.S. - United States

VISTA - Vista Technologies, Inc. VSHP - VISTA Safety and Health Program VRSP - VISTA Radiation Safety Program

WL - Working Level WP - Work Plan

Page 1

1 TRAINING

Training is an essential element of implementation of the Vista Radiation Safety Program (VRSP), As Low As Reasonably Achievable (ALARA) program, and the Vista Safety and Health Program (VSHP). When workers have a basic understanding of the rationale behind safe work practices, they are better able to incorporate the safe practices into their work..

The Vista Radiation Safety Officer (RSO) will determine the amount of additional training need by the Vista On-Site Radiation Protection Officer (ORPO) and field technical staff beyond that required by the VSHP. Specific training and record keeping requirements for Vista field personnel are presented in Procedure 10. "Training Prograrn" and ProcedUtre 24,"Records and Reports" respectively.

The required level of training will take into consideration the degree of ionizing radiation hazard associated at the Vista project work site and the individuals work assignment. Four levels of ionizing and non-ionizing radiation training are recognized:

* Vista ORPO training * Vista field technical staff training * Radiation worker training

* Visitor training

Specific requirements for each training level are provided in the sections below. Radiation workers will receive refresher training at least once every other year. Remedial training will be performed on an annual basis.

Vista Technology shall issue generic certificates for the various levels of radiation (e.g., Health Physicist (HP)) and non-radiation (e.g., non-radiation workers) training. These generic certificates enable workers at one site to go to another site with minimal (or zero) additional training. This training requires an examination, and training certificate(s) will be presented to those employees that pass examination(s). The certificates are interchangeable between the sites for similar types of work.

Certificates that represent equivalent training from other Nuclear Regulatory Commission (NRC) or Department of Energy (DOE) sites are acceptable. The Vista site-specific orientation training would still be required for a new worker with an equivalent certificate.

Examinations will be needed for training for new workers. Some new workers will need little or no new training because of their previous experience, training or equivalent training. The HPs, or equivalent (e.g., Radiological Health Engincers), will not require training because of their university/certification training. Visitors will need orientation training without examinations, but records of their orientation will be kept.

The training, which requires examinations, could be done by,

Procedure - I oTraining Program 01/08/99

Note: For the purposes of this document, Ionizing Radiation includes certain types of Non-Ionizing Radiation

Page 2

"* Computer Based Training (CBT)

"* Classroom training "* Equivalent training from other Department of Defense (DoD), DOE sites or other

agencies.

"* Combinations of the above.

The radiation workers could be field trained by on-site HP, ORPO and/or appropriately trained engineers.

Vista and its subcontractors are responsible for ensuring that their personnel are adequately trained for specific work assignments. Additionally, each individual is responsible for understanding the specific ionizing radiation protection requirements of each job before beginning work. The Vista RSO is available to answer questions that radiation workers and health physics technicians may have. Visitors to a Vista project work site where radioactive materials and/or radioactive contamination are present will be briefed by the Vista ORPO prior to entry into the site.

The following sections discuss training for the Vista ORPO, training for Vista field technical staff working in ionizing radiation controlled areas, site radiation health and safety orientation and training, supplemental radiation worker training, training for radiation workers, and training for onsite visitors.

1.1 On-Site Radiation Officer

The Vista ORPO will receive the general basic training covering the use and interpretation of the concept of air concentrations in unrestricted areas, as outlined in Procedure 16, "Air Radiological Sampling". The training will be conducted by the Vista RSO or his/her designee. The Vista ORPO's training will include instruction in the following areas:

* Acute and chronic health effects of acute and chronic exposure to ionizing radiation

* Knowledge of the requirements of the VRSP, including the responsibilities of the Vista HP, including 10 CFR 19, 10 CFR 20, 10 CFR 21, 10 CFR 30, 10 CFR 40, 10 CFR 70, and 10 CFR 71

e Hands-on instruction in the use of air sampling and ionizing radiation detection survey instrumentation

* Theory and practical instruction in instrument calibration and simple maintenance procedures

* Practical health physics and ionizing radiation calculations instruction * Detailed instructions in ALARA concepts * Radioactive decontamination procedures and contamination control instructions e Health physics record keeping instructions necessary to implement the procedures in the

VRSP.

Procedure - 10 Training Program 01/08/99


Page 3

The Vista HP shall have a college degree at the bachelor level, or equivalent training and experience, in the physical or biological sciences or in engineering. The Vista HP shall also have at least 40 hours of training and experience in the safe handling of radioactive materials, and in the characteristics of ionizing radiation, units of radiation dose and quantities, radiation detection instrumentation, and biological hazards of exposure to radiation appropriate to the type and forms of byproduct material to be used.

* Table 1.1-1- Training Requirements For Vista Employees For Radiological Work

eauivalent)

ORPO B.S., CHP, Nuclear v v Engineer (or equivalent) _

OSHO B.S., CHP (or v v equivalent) 2

Visitor 5 N/A V V HP 2 B.S., Health Physics V V v

(or equivalent) Radiation worker ' High school v v v MSH CHP (or equivalent) v v PM B.S., Engineering v v

(or equivalent)

Lep-end: CHP - Certified Health Physicist HP - Health Physicist ORPO - Off-site Radiological Protection Officer OSHO - On-site Health Officer MSH - Manager Safety & Health RSO - Radiation Safety Officer PM - Project Manager

Notes:

I. Appropriate equivalent experience can substitute for education. 2. Equivalent radiological training can be substituted, with proper documentation. 3. Rad worker II more comprehensive than Rad worker I. 4. Worker dependent 5. Visitor is anybody visiting the project site including regulators.

1.2 Field Technical Staff Working in Ionizing Radiation Controlled Areas

The purpose of this procedure is to describe specific classroom training requirements for Vista field personnel who will work in Restricted/Radiation Areas (RAs) at a specific Vista project work site that may involve radioactive materials and/or radioactive contamination. Safe and successful completion of field activities can be cxpcteid through a program of initial training, refresher training, and remedial training on all procedures and site-specific instruction guides.



Page 4

This instruction covers the activities used to accomplish site-specific tasks assigned to field personnel. Supplemental training will be conducted annually for all PMs and Vista HPs.

Applicable references are:

* VRSP;

* VSHP; * Nuclear Regulatory Commission (NRC) Regulatory Guide 8.13, "Instruction

Concerning Prenatal Radiation Exposure," * NRC Regulatory Guide 4.5, "Measurements of Radionuclides in the Environment

Sampling and Analysis of Pu in Soil," "* NRC Regulatory Guide 4.6, "Measurements of Radionuclides in the Environment - 89Sr

and 'Sr Analyses," "* NRC Regulatory Guide 8.34, "Monitoring Criteria and Methods to Calculate

Occupational Radiation Doses"

* NRC Regulatory Guide 8.35, "Planned Special Exposures," * NRC Regulatory Guide 8.36, "Radiation Dose to the Embryo/Fetus," * 29CFR1910.120, "Hazardous Waste Operations and Emergency Response,"

Department of Labor, OSHA; I 1OCFR20, "Standards for Protection Against Radiation"

* Environmental Protection Agency (EPA), "Handbook for Sampling and Sample Preservation of Water and Waste Water," Latest Edition;

* EPA, "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," Latest Edition;

* EPA, "A Compendium of Superfund Field Operational Methods," Volume 1 & 2, Latest Edition; and

* Standard Methods for the Examination of Water and Wastewater, 17th Edition

The following sections delineate materials, specific instructions, training outline, industrial hygiene and health physics, pre-field review of Field Sampling Plan (FSP), Sampling and Analysis Plans (SAP), instruction guides, and documentation.

1.2.1 Materials

"* "Training Notice and Record Form," shown as Attachment 5; and "* "Site Activities Training Form," shown as Attachment 6.

1.2.2 Specific Instructions

* All field personnel assigned to Vista project work sites must receive training in the following areas prior to their field assignment:

Applicable regulations and license conditions;



Page 5

- Areas where radioactive material is used and stored; - Potential hazards associated with radioactive material; - Individual's obligation to report unsafe conditions to the ORPOiRSO or

applicable authorities; - Appropriate response to emergencies or unsafe conditions; - Worker's right to be informed of occupational radiation exposure and bioassay

results; Locations of pertinent regulations, licenses, and other material required by regulations;

- VRSP; - VSHP; - Radiation Protection Procedures (RPP); - Health and safety procedures and requirements; - Industrial hygiene/health physics practices/concepts; - Site-specific instruction guides; - Vista procedures as required; - EPA or Contract Laboratory Program (CLP) sampling techniques; and - Radiological sampling techniques.

All field personnel will also receive training as specified in this Procedure, Sections 1.2, "Field Technical Staff Working in Ionizing Radiation Controlled Areas", Section 1.3, "Site Radiation Health and Safety Orientation and Training", and Section 1.4, "Supplemental Radiation Worker Training." Field personnel will receive refresher training annually;

Field technicians will:

Receive site-specific procedures, instructions, training and briefings in advance of their assignment to a Vista project work site. Supplementary written training instructions will be provided to each of Vista field technical staff when new or revised procedures are issued. Receive training in the standard procedures in the Vista Quality Assurance (QA)\Quality Control (QC) Program in advance of their assignment at a Vista project work site. Supplementary written training instructions will be provided to field laboratory supervisors when analytical procedures are issued or revised. The field laboratory manager will provide specific instructions. Review those procedures that are pertinent to their job assignment and the Vista project work site. This will be done prior to an on-site assignment for scheduled Vista site activities. Upon assignment to a new job or site, remedial training of additional site-specific procedures will be required. Receive annual refresher training on relevant procedures and instruction guides, industrial hygiene, radiation protection concepts, and QA/QC basic principles and requirements.

* The Vista RSO is responsible for scheduling and conducting training, remedial training,

and annual refresher training of health physics procedures. To facilitate administration,



Page 6

the Vista RSO may organize procedure-training sessions in accordance with the degree of responsibility among field labor categories;

"* The Vista ORPO and On-Site Health and Safety Officer (OHSO) will be trained in the procedures set forth in the VRSP, VSHP, FSPs, SAPs, and Vista procedures at their time of site deployment;

" Field laboratory technicians will receive radiation protection, and industrial hygiene training that satisfies the health and safety requirements of samples to be received and that satisfies sample receipt and sample control management. The training will be coordinated by the Vista RSO; and

"* Field laboratory technicians will be trained in on-site laboratory procedures at the time of their deployment to a field laboratory. The field laboratory supervisor is responsible for scheduling a time and place for this review, and for demonstrating that each step of an analytical procedure is correctly being performed prior to assigning specific field laboratory duties to laboratory technicians.

During a specific session, training will include routine procedures and pertinent radiation health and safety procedures and concepts. It will be necessary to conduct training prior to initial site start up when all site personnel are fully mobilized.

1.2.3 Training Outline

The Vista OHSOs will be responsible for, and assure that, all applicable training requirements are conducted and documented prior to the start of Vista project work site activities. Coordination with the Vista RSO, Vista OHSO, and Vista ORPO will also be required to assure that all training requirements are completed as needed.

1.2.4 Industrial Hygiene and Health Physics

The Vista RSO will be assigned the task of coordinating site-specific training as is applicable to site conditions for all of Vista field technical staff assigned to a Vista project work site with suspected or confirmed radioactive materials and/or radioactive contamination. These instructors will develop a training agenda. The following must be covered as a minimum:

* Types of radioactive contamination present; * Exposure pathways, biological effects, and threshold limit values of radioactive

contamination(s) present; * Engineering controls to be used to reduce personnel exposure; * Personal Protective Equipment (PPE) required; * Site historical information as pertains to site radioactive contamination and other useful

information that may add to Vista field technical staff awareness of potential chemical and health and safety hazards;

* Industrial hygiene/health physics surveys required for comprehensive monitoring of radioactive contamination types present at the site;

* Health, safety and ionizing radiation issues and general work practices;



Page 7

"* A generic review of site activities with respect to FSPs, SAPs, instruction guides, and

Health and Safety Plan (HSP) as provided by Vista with consideration for industrial

hygiene and health physics practices during such site activities;

"* A review of site industrial hygiene and health physics instrumentation with "hands-on"

experience for Vista field technical staff prior to use in field assignments;

"* Mock emergency situation(s) and complete descriptions of correct practices for these

hypothetical events including, but not limited to, evacuation routes, assembly points,

emergency contacts, warning signals, etc; and

"* Training should be provided on any additional information with respect to industrial

hygiene, or health and safety as deemed appropriate by the Radiation Health and Safety

Committee (RHSC), instructor(s), and the Vista RSO.

1.2.5 Pre-Field Review of Field Sampling Plans, Sampling and Analysis Plans, and Instruction Guides

All site activities will require a pre-field work review of the applicable site-specific FSP, SAP,

instruction guides, and other directions issued by Vista. Project managers will be responsible for

coordination of the pre-field review under the technical direction of Vista RSO. The following

training or pre-field review will be conducted:

* FSP reviews (if available);

* SAP reviews (if available);

* Instruction Guides or subcontract reviews (if available);

* Site historical information (if available);

* EPA or CLP sampling requirements (if applicable);

* Sampling equipment to be used and radioactive decontamination techniques utilized as specified by Vista;

* Documentation requirements of data, samples and other information as required within

the site activity;

* Radiological survey and sampling requirements;

* Review of the work schedule and approach;

* Potential problems; and

* QA/QC sampling requirements.

1.2.6 Documentation

Documentation of training is required for topics specified within Sections 1.2, "Field Technical

Staff Working in Ionizing Radiation Controlled Areas," 1.3, "Site Radiation Health and Safety

Orientation and Training," and 1.4, "Supplemental Radiation Worker Training." Documentation

must be completed at the end of each training session on the form shown as "Site Activities

Training Form," shown as Attachment 6.



Page 8

Each training topic must be documented individually on the form and should be completed at the end of each training session. A copy of the form will be retained in the site training records file, and the original sent to the Vista RSO.

Formal notice of routine procedure review and remedial training schedules will be documented on the forms shown as "Health and Safety Training Form," shown as Attachment 7, and "Health and Safety Training Daily Attendance Form," shown as Attachment 8, and posted in a conspicuous area. Individual signatures on the form, shown as Attachment 8, will attest to attendance and understanding of information presented.

The Vista OHSOs will document areas of weakness for each member of Vista field technical staff and will provide remedial training, with the assistance of the Vista RSO for these areas. Copies of training agendas and instructor comments will be affixed to forms shown as Attachments 5, 6, 7, and 8 and sent to the PM.

1.3 Site Radiation Health and Safety Orientation and Training

The purpose of the site radiation health and safety orientation and training procedure is to define the minimum requirements of the site-specific orientation and training for Vista workers, subcontractor personnel, and visitors at Vista project work sites where radioactive materials and/or radioactive contamination may be present.

All individuals who enter a radiation restricted work area at a Vista project work site will receive an orientation in site-specific hazards prior to entry into the restricted work area. This procedure includes guidance for site-specific Vista project training/orientation, and documentation requirements.

Applicable references are:

* VRSP; * VSHP;

* DOE Order 5480.11, Procedure 9(o), "Radiation Safety Training"; * 29 CFR 1910.120, "Hazardous Waste Operations and Emergency Response",

* 29 CFR 1910.1200, "OSHA Hazard Communication", * 29 CFR 1926.59, " OSHA Hazard Communication", and * 10 CFR 20, "Standards for Protection Against Radiation."

The following sections discuss the instructor, site-specific health and safety orientation and training, and documentation.

1.3.1 Instructor

The instructor for any Vista site-specific project radiation hazard orientation and training must be approved by the Vista RSO. The instructor directs the site-specific orientation and training to on



Page 9

site workers. The instruction may be contracted to a licensed training institution or may be done internally. If done internally the RSO, ORPO, or HiP will conduct the training.

The instructor should be well informed of the basic principles of radiological safety and industrial hygiene, have a general working knowledge of federal and state regulations applicable to Vista project work sites, and attend bi-annual retraining sessions covering fundamental radiation protection principles and the ALARA process. The instructor must be thoroughly familiar with pertinent procedures described in the VRSP and VSHP.

1.3.2 Site-Specific Health and Safety Orientation and Training

The site-specific health and safety orientation and training must provide adequate information pertaining to radiological hazards as shown in the following Attachments:

* NRC Regulatory Guide 8.13, "Instruction Concerning Prenatal Radiation Exposure," and Appendices A and B, shown as Attachment 9;

"* "General Radiation Protection Rules," shown as Attachment 10;

"* "General Safety Work Rules and Guidelines," shown as Attachment 11; and

"* "Prohibited Practices in Chemically Contaminated Areas," shown as Attachment 12.

Visitors do not need to receive in-depth training as outlined in this procedure. However, they must be informed of health and safety issues for the area(s) at the Vista project work site to which they will be exposed.

The following course outline is to be used by the instructor to format a lesson plan for the particular needs of the participants. The on-site orientation and training must include, but is not limited to, the following topics:

1.3.2.1 Overview of the Work Site

Depending on the site conditions and hazards identified at the project work site, the training may last 2-4 hours. The overview training will be conducted prior to beginning work on site and anytime when workers are replaced. If hazards or site conditions change, overview training will be conducted incorporating the changed/new conditions/concerns.

* Hazardous conditions present at the site; * Purpose of activities being conducted at the site;

* Site-specific HSP;

* Standard operating procedures;

* NRC, EPA, and Vista radiation protection policies and procedures applicable to the site;

* Federal and state regulations applicable to the site;

* Historical review of the site; and

* Organizational authority and responsibilities.


Note: For the purposes of this document. lonizing Radiation includes certain types of Non-Ionizing Radiation

Page 10

1.3.2.2 Basic Radiation Protection Principles

"* Biological effects (acute and chronic exposures and limits for pregnant women); "* Types of radiation present at the site; "* Personal protection (protective clothing, dosimetry, respiratory protection, and

bioassays); "* Exposure pathways (inhalation, ingestion, and absorption); "* Radiation detection methods and measurements; "* ALARA and engineering controls to limit exposures; and "* Radioactive decontamination of personnel, equipment, and monitoring instruments.

1.3.2.3 Industrial Safety

* Emergency response procedures in accordance with the HSP and who to contact; * Safe work practices (including buddy system); * Hazardous Work Permits (HWP); * Electrical equipment lockout/tagout; * Confined space entry procedures and restrictions; * Handling, storage, and transportation of hazardous materials; and * Rights and responsibilities of workers.

1.3.2.4 Industrial Hygiene

"* Chemical and biological hazards present at the site; "* Hazard communication training in accordance with "Right-to Know" laws, 29 CFR

1910.1200, "Hazardous Communication," 29 CFR 1926.59, "Hazard Communication," OSHA, and provision of Material Safety Data Sheets (MSDS);

* Chemical detection methods and measurements; and * Hearing conservation program.

Whenever Vista project work site conditions significantly change or personal protection policies change, site-specific orientation will be re-administered to all personnel on-site at that time.

1.3.2.5 Radiation Worker Training

In addition to the general radiation principles outlined in the site-specific orientation, workers whose job assignment has the potential of exposures to ionizing radiation from either the external dose and the committed dose equivalent from internal exposure are considered radiation workers and will receive additional training.

Workers under these conditions are considered radiation workers and will be given training in accordance with this Procedure, Section 1.4, "Supplemental Radiation Worker Training." Radiation worker training will include both classroom and applied training.



Page 11

1.3.2.6 Hazardous Waste Site Operations Training

OSHA 40-hour "Hazardous Waste Operations and Emergency Response" training, in compliance with 29 CFR 1910.120, is required for anyone working in a restricted work area on a Vista project work site. Proof of this training must be provided by the worker prior to performing work in a

restricted work area. Documentation of the required training for Vista personnel will be forwarded to the Vista RSO.

1.3.2.7 Hazard Communication Training

All workers who have the potential for exposure to hazardous materials in the work place must be

advised of associated hazards working with or in proximity to these materials in accordance with 29

CFR 1910.1200, "Hazardous Communication," and 29 CFR 1926.59, "Hazard Communication." Examples of hazards at Vista project work sites are as follows:

* Radioactive materials;

* Radioactive contamination;

* Radioactive decontamination chemicals;

* Herbicides/pesticides;

* Glues;

* Solvents; and

* Asbestos.

Workers must be trained to recognize and understand the potential hazards to health and safety when working with hazardous materials prior to any work being performed. This can be

accomplished by reviewing Material Safety Data Sheets (MSDS)s for all hazardous materials on a

Vista project work site, and by training workers on how to read warning labels on containers.

For this training, special emphasis should be placed on the following topics:

"* What an MSDS is and how to read it;

"* Location of MSDSs on-site, and the worker's right to review them;

"* Safe handling practices for different hazardous materials;

"* How to read warning labels;

"* Emergency response procedures/first aid administration in the event of a spill or exposure in accordance with the HSP; and

"* Health and safety risks associated with working with hazardous materials on-site.

1.3.2.8 Respiratory Protection Training

In accordance with the policy of Vista, all Vista project site workers who may be required to

perform work in a Restricted Area (RA) must be properly trained in inspection, selection, limitations, care, maintenance, storage, and overall use of respiratory protective equipment. The



Page 12

provision of training in the use of respiratory protective equipment is the responsibility of the Vista RSO. The PM or Vista ORPO will arrange for such training with the Vista RSO, as needed.

The primary method of training the respirator wearer is through a comprehensive training session in conjunction with a respirator fitting (or refitting) procedure. Retraining and refitting is performed and documented annually. Copies of respirator training must be forwarded to the Vista RSO.

1.3.3 Documentation

All occupational and radiation workers who receive in-depth site-specific orientation and training and who will work in a RA will have this training entered into the Health and Safety Database in San Antonio, Texas, office. Such training will be recorded on the following Attachments:

* "Vista Site Workers Weekly Status Report," shown as Attachment 13, must be completed by each contractor at the end of every week and submitted to the Vista RSO. This form's purpose is to show which site personnel are still working at a Vista project work site;

e "Vista Health and Safety Database Site Worker Information Input Form," shown as Attachment 14, is to be completed by each contractor every time a Vista project site worker begins or terminates work at a site or transfers to another Vista project work site. This form must be completed within 5 days of the employee's change in work status and sent to the Vista RSO;

* "Nuclear Regulatory Commission-4 Equivalent Form, Occupational External Radiation Exposure History," shown as Attachment 15, will be completed for all workers who have occupational exposure to ionizing radiation and provided to the Vista RSO. If an employee has not previously been occupationally exposed to ionizing radiation, the form sfiown as "Vista Occupational Radiation Exposure History - Employee Acknowledgment Form," Attachment 16, must be signed by each employee and submitted to the Vista RSO;

* "Vista Occupational Radiation Exposure History - Employee Acknowledgment Form," shown as Attachment 16, will be used to document previous occupational exposure or lack of previous occupational exposure of subcontractor personnel to ionizing radiation. The form must be completed and submitted to the Vista RSO;

* The form shown as "Health and Safety Training Form," Attachment 7, will be completed and signed by the individual receiving orientation and training, checked by the Contractor and transmitted to the Vista RSO;

e The form shown as "Health and Safety Training Daily Attendance Form," Attachment 8, must be completed for each day of training presented at a Vista project work site and submitted by the Contractor to the Vista RSO. Training documents submitted to Vista will be entered into the health and safety database.

* "Hazard Communication Training Record Form," shown as Attachment 17, and copies of training documentation must be transmitted to the Vista RSO;

* "Respiratory Protection Training Attendance Record Form," shown as Attachment 18, is required to be completed to include the names of all respiratory training participants. Copies of this form must be submitted to the Vista RSO; and



Page 13

"Respiratory Protection Education and Fit Testing Form," shown as Attachment 19, is required for each worker who is trained on the proper usage of respirators, and is fittested. Copies of this form must be submitted to the Vista RSO.

1.4 Supplemental Radiation Worker Training

This procedure describes specific topics that should be addressed, practical examples, and classroom and applied training. The applicable reference is DOE Order 5480.11, Procedure 9(o), "Radiation Safety Training." The following sections delineate the necessary supplies, introduction, specific classroom instructions, and documentation.

1.4.1 Introduction

Supplemental radiation worker training should include both classroom and applied training. This training should include site-specific information and generic training (not specific to a site) in all or some of the topics listed below. Some topics listed may be waived provided this training has been presented at another facility or Vista project work site, and an appropriate official has certified the training of the individual.

The knowledge of radiation safety fundamentals possessed by radiation workers must be certified by a written examination prior to unsupervised assignments. The training should emphasize procedures specific to an individual's job assignment. Additionally, the level of training in the following topics is to be commensurate with each worker's assignment. Topics for instruction include the following:

* Radioactivity and radioactive decay;

* Characteristics of ionizing radiation; * Man-made radiation sources; * Acute and chronic effects of exposure to radiation; * Risks associated with occupational radiation exposures; * Special considerations in the exposure of women of reproductive age; * Dose equivalent limits; * Mode of exposure--internal and external; * Dose-equivalent determinations; * Basic protective measures--time, distance, shielding; * Site-specific procedures for maintaining exposure ALARA; * Radiation survey instrumentation, calibration and limitations; * Radiation monitoring programs and procedures; * Radioactive contamination control, including PPE in the work place; * Personal decontamination procedures; * Emergency procedures in accordance with the HSP; * Warning signs, etc.;

* Responsibilities of employees and management;

Procedure - 10 Training Program 0t/08/99


Page 14

"* Interaction with radiation protection personnel; and "* Operational procedures associated with specific job assignments.

1.4.2 Specific Classroom Instructions

Radioactive Decay - Describe the properties of radioactive atom decay, (e.g., emissions of oX particles, B particles, or 'y rays).

Characteristics of Ionizing Radiation - Describe the ionization process where electrons may be removed from or added to a neutral atom or molecule. Explain particulate ionization, secondary ionization, and specific ionization.

Man-Made Radiation Sources - Explain the difference between mah-made and natural occurring radionuclides.

Risks of Exposure - Explain the associated risk of radiation exposure and describe chronic and acute effects of exposure to ionizing radiation. Describe how risk is proportional to dose. Compare radiation exposure risk to other health risks. Typical risks are shown in the table below.

Table 1.4-1 - Estimated Loss of Life Expectancy From Health Risks

Exposure to Women - Provide a copy of NRC Regulatory Guide 8.13 and Appendix A and B and explain.

Dose Equivalent Limits - Explain the dose/exposure limits for radiation hazards present on-site.

Mode of Exposure - Explain external and internal exposure. Provide examples of how an external and internal exposure may occur.

Procedure - 10 Training Program


01/08/99

Estimate offtlays ofife

Page 15

Dose Equivalent Determinations - Explain how external and internal dose is determined, e.g., dosimeters, SRDs, airborne particulate sampling, and bioassays.

Basic Protective Measures - Describe how time, distance, and shielding affect dose. Further describe the types of Personal Protective Equipment (PPE) used in minimizing external and internal exposure.

Site-Specific ALARA - Describe site-specific measures, controls, engineering, etc., used in reducing exposure to ALARA levels.

Instruments - Describe and demonstrate the types of radiation monitoring instruments used for sitespecific radioactive contamination.

Exposure - Detail monitoring programs used to quantify and qualify exposure. Explain specific procedures that apply to site activity.

Control - Provide visual demonstrations of radioactive contamination control with respect to the following:

- The use of PPE/clothing - Equipment in the work place - Preventing the spread of radioactive contamination - Controlled area egress - Radioactive decontamination

Explain personal radioactive decontamination techniques; detail possible personnel contamination potentials.

Emergency Response - Provide information about the site-specific emergency response procedures described in the HSP. Prior to classroom discussion, gather all site/area relevant information and document area hospital information, phone numbers of local police, etc. The HSP will have this information. Provide copies of the information to trainees.

Signs - Explain the types of signs used at the specific Vista project work site. Detail the actual meaning of each sign.

Responsibility - Explain the responsibilities of all site personnel with respect to site activity. Detail all specific Vista project work site personnel and their assigned tasks. Further explain the roles of various contractors and site employees at the specific Vista project work site.

Communication - Describe what types of interactions are expected with Vista's OPRO and OHSO, and other radiation protection personnel. Point out that any questions concerning ionizing radiation safety are warranted. Further explain that radiation protection personnel may directly respond to non-safe work practices.



Page 16

Operational Procedures - Explain all operational procedures related to specific job assignments. Detail all information pertinent to specific tasks. Where tasks may involve substantial exposure potential, schedule rehearsals in non-controlled areas.

1.4.3 Documentation Document supplemental radiation worker training using the forms shown as "Health and Safety Training Form," Attachment 7, and "Health and Safety Training Daily Attendance Sheet Form," Attachment 8. Additionally, all trainees are required to pass a radiological module written examination.

Copies of the certificates of radiation (and non-radiation) examinations shall be kept in the RSO office. Also, copies of persons attending visitor orientation training shall be kept in the RSO office.

1.5 Radiation Workers Radiation worker training will familiarize workers with the fundamentals of ionizing radiation protection and the ALARA process. The training can be concurrent with assignment as a radiation worker only if the worker is accompanied by, and under the direct supervision of, a trained radiation worker; otherwise, the training must precede assignment as a radiation worker. Generic training (not specific to a facility) in all or some of the topics listed below may be waived provided the training has been received at a previous employer or at another Vista project work site.

The training will emphasize procedures specific to an individual's job assignment at a specific Vista project work site. Additionally, the level of training in the following areas is to be commensurate with each worker's assignment:

* Radioactivity and radioactive decay; * Characteristics of ionizing radiation; * Man-made ionizing radiation sources; * Acute and chronic effects of exposure to ionizing radiation; * Risks associated with occupational ionizing radiation exposures; the risk discussion will summarize the information provided in NRC Regulatory Guide 8.29, "Instruction

Concerning Risks from Occupational Radiation Exposure,"; * Special considerations in the exposure of women of reproductive age as summarized in

NRC Regulatory Guide 8.13, "Instruction Concerning Prenatal Radiation Exposure,"; * Regulatory and administrative dose-equivalent limits; * Mode of exposure - internal and external; * Dose-equivalent determinations; * Basic protective measures: time, distance, and shielding; this will include a summary of

NRC Regulatory Guide 8.29, when appropriate; * Specific procedures for maintaining exposure in accordance with ALARA principles; * Ionizing radiation survey instrumentation - calibration and limitations; * Ionizing radiation monitoring programs and procedures;

Procedure - 10 Mraining Program 01/08/99


Page 17

* Radioactive contamination control, including protective clothing and equipment and work place design;

* Personal radioactive decontamination;

* Emergency procedures;

* Warning signs and alarms; * Responsibilities of employees and management; * Interaction with ionizing radiation health and safety staff; and

* Operational procedures associated with specific job assignments.

Proof of prior training in the form of a certification document containing the individual's name, date of training, and specific topics covered will be submitted to the Vista RSO for approval.

1.6 On-Site Visitors

Site visitors that have a one-time need to observe site activities at a Vista project work site may be admitted to a RA after receiving a site visitor briefing. Site visitors will be escorted at all times by the Vista ORPO and OHSO. Other than regulatory personnel, site visitors will not be admitted into areas requiring the use of respiratory protection or areas having a high radioactive contamination potential. The site visitor briefing will include the following:

* An overview of the requirements of the HSP; 0 A description of the site conditions at a Vista project work site including a discussion of

the ionizing radiation health and safety hazards present; * The health and cancer risks associated with low level ionizing radiation exposure;

* The mutagenic and teratogenic characteristics and risks of low-level ionizing radiation exposure; and

* Site ionizing radiation protection requirements.



ATTACHMENTS

Attachment 5

TRAINING NOTICE AND RECORD FORM

TOPIC DATE DATE HOURS SCHEDULED COMPLETED SPENT

+ 4 +

+ F +

+ F F

+ F F

Attachment 6

SITE ACTIVITIES TRAINING FORM

Date:

Site Name and Location:

Site Activity: Contract Task Order: Instructor(s): Description of Training:

Training Document Used:

Time Spent:

Note: Attach Training Agenda if Available

LIST ALL PERSONNEL PRESENT

NAME EMPLOYER TRAINING DOCUMENTS

USED

I

Attachment 7

HEALTH AND SAFETY TRAINING FORM

I have received the following training beginning:

__ Hazardous Waste Management Supervisory Training

__ Asbestos Abatement Training

8__ Hrs. Annual Re-training

__ Site-Specific Training

40 Hrs. Hazardous Waste Training

__ Respirator Fit Testing and Training

Initial

__ Avg. Grade

Semi-Annual

__ Other Training (Specify)

The Instructor(s) for the training was/were:

I understand the material presented and have had my questions answered satisfactorily. In the event of any further questions, including questionable work practices, I know the individual to contact is

The following is a list of specific potential health and safety concerns/hazards discussed in the training.1. 2. ___ 3. 4.

COMPLETE THIS SECTION ONLY IF THE RESPIRATOR FIT TESTING AND TRAINING SECTION IS CHECKED ABOVE Size: __ Small __ Medium -Large

CIRCLE AS APPROPRIATE:

Full Face/Negative Air Half Mask/Negative Air Self Cont'd Breathing App Gas Mask Air line support

FF HF SCBA GM AL

Mine Safety Apparatus MSA Wilson WIL Norton NOR Surviair SVA Other

Quantitative QN Qualitative QL

I understand the usage and benefits of wearing a respirator and other forms of personal protective equipment (PPE) and will utilize what I have learned when a respirator or PPE is necessary for my job. __-(Initials)

I have received a copy of NRC Regulatory Guide 8.13, Instruction Concerning Preriatal Radiation Exposure. Instruction has been provided to explain the content and I understand the recommendations contained in this Regulatory Guide. (Initials)

NRC-4 EQUIVALENT OCCUPATIONAL EXTERNAL RADIATION EXPOSURE HISTORY FORM NRC-4 Form Completed. .(Initials)

Signature: Company Name:

Date:Printed:

(Print Clearly)

Site Name and Location: Social Security Number

Attachment 8

HEALTH AND SAFETY TRAINING DAILY ATTENDANCE SHEET FORM

Contract Task Order No.: Contract No.:

Site Name: Location:

HEALTH AND SAFETY TRAINING DAILY ATTENDANCE SHEET FORM

Meeting Held By: Date ITEMS DISCUSSED

Hazard Evaluation Circle Personal Protective

Toxic Vapors Equipment and Clothing

Explosivity Yes No

Radioactivity

Oxygen Depletion

Physical Hazards/Confined Spaces Decontamination Procedures Yes No EMERGENCY

INFORMATION First Aid

Hospital Route

Poison Control Center SIGNATURES

Team Member Signature Date

Attachment 9

U.S. NUCLEAR REGULATORY COMMISSION

REGULATORY GUIDE 8.13

and

APPENDIX A and B

Revision 2 , ,.oN U.S. NUCLEAR REGULATORY COMMISSION December 1987

0 REGULATORYGUIDE OFFICE OF NUCLEAR REGULATORY RESEARCH

REGULATORY GUIDE 8.13 (Task OP 0314)

INSTRUCTION CONCERNING PRENATAL RADIATION EXPOSURE

A. INTRODUCTION

Section 19.12, "Instructions to Workers," of 10 CFR Part 19, "Notices, Instructions, and Reports to Workers; Inspections." requires that all individuals working in or frequenting any portion of a restricted areal be instructed in the health protection problems associated with exposure to radioactive materials or radiation, in precautions or procedures to minimize exposure, and in the regulations that they are expected to observe. The present 10 CFR Part 20, "Standards for Protection Against Radiation," has no special limit for exposure of the embryo/fetus. 2 This guide describes the instructions an employer should provide to workers and supervisors concerning biological risks to the embryo/fetus exposed to radiation, a dose limit for the embryo/fetus that is under consideration, and suggestions for reducing radiation exposure.

This regulatory guide takes intu consideration a proposed revision to 10 CFR Part 20, which incorporates the radiation protection guidance for the embryo/fetus approved by the President in January 1987 (Ref. 1). This revision to Part 20 was issued in January 1986 for comment as a proposed rule. Comments on the guide as it pertains to the proposed Part 20 are encouraged. If the new Part 20 is codified, this regulatory guide will be revised to conform to the new regulation and will incorporate appropriate public comments.

Any information collection activities mentioned in this regulatory guide are contained as requirements in 10 CFR Parts 19 or 20. which provide the regulatory

IRestricted urea means any area that has controlled access to protect individuals from being exposed to radiation and radioactive materiLas.

2in conformity with the proposed revision to 10 CFR Part 20.

the term "embryo/fetus" is used throughout this document to represent al stz.geS3 of pregnancy.

basis for this guide. The information collection requirements in 10 CFR Parts 19 and 20 have been cleared under OMB Clearance Nos. 3150-0044 and 3150-0014. respectively.

B. DISCUSSION

It has been known since 1906 that cells that are dividing very rapidly and are undifferentiated in their structure and function are generally more sensitive to radiation. In the embryo stage, cells meet both these criteria and thus would be expected tQ be highly sensitive to radiation. Furthermore, there is direct evidence that the embryo/fetus is radiosensitive. There is also evidence that it is especially sensitive to certain radiation effects during certain periods after conception, particularly during the first 2 to 3 months after conception when a woman may not be aware that she is pregnant.

Section 20.104 of 10 CFR Part 20 places different radiation dose limits on workers who are minors than on adult workers. Workers under the age of 18 are limited to one-tenth of the adult radiation dose limits. However, the present NRC regulations do not establish dose limits specifically for the embryo/fetus.

The NRC's present limit on the radiation dose that can be received on the job is 1,250 millirems per quarter (3 months).3 Working minors (those under 18) are Limited to a dose equal to one-tenth that of adults, 125 mi-l.irems per quarter. (See § 20.101 of 10 CFR Part 20.)

Because of the sensitivity of the unborn ch.ild, the National Council on Radiation Protection and Measurements (NCRP) has recommended that the dose equivalent

3The limit is 3.000 millirems per quarter if the worker's occupational dose histcry is known and the average dose does not exceed

S.000 milLirems per year.

USNRC REGULATORY GUIDES

Regulatory Guides ire 1$uteO to describe ano make Available to the PubliC methods ACClPt&Abe to the NRC Staff of imlrnementing specific parts of the Commission's regutations. to delineate techIlCutts Used by the staff In evaluiatint soecifc problems or Postu. .ate- &CCidOenl., 0i to Provide guidance to aoplicants. Regulatory Guldes Are not substitutes for regulations. &no compliance with them Is not required. Methods ano solutions different from those set Out In the guides will be acceptable if they prOvIde a basis to, Ihe linctrgs reouisile to the iSsuance or continuance ut a permit oi ,Icense by the Commission.

This guide was issued afite consoertalion of comments received from thn public. Comments and suggestions for improvements in these giuides are encouraged at all times. ano guides will be revised, as a Pi oorlate, to accommodate comments and to reflect new urformalion or eiserlence.

Written cOmmentS may ct $uolr!er *r the Pules 8cC P_.--C'

'The guides are issued in the following ten broad divisions:

1. 2. 3 4. s

Power Reactors 6. Products Research anc Test Reactors 7. Transportation Fuels and Materials Factities 8. Occupational Health Environmentý.a and Siting 9. Antitrust and Financial Review Materials and Plant Protection 10. General

Copies of issuea guides may oe Purchased fioi the Government Printing Office a: the current GPO broce. Inormalton on current GPO prices may be Obtained by contacting the Superintenoent of Documents. U.S. Government Printing Office. Post Office Bo0 237082. Washington oC 2001:1-7082, telephone (202)275-2060 oi

isued uiemaaLso o urchatec from, the National Technincal

to the unborn child from occupational exposure of the expectant mother be limited to 500 millirems for the entire pregnancy (Ref. 2). The 1987 Presidential guidance (Ref. I) specifies an effective dose equivalent limit of 500 millirems to the unborn child if the pregnancy has been declared by the mother; the guidance also recommends that substantial variations in the rate of exposure be avoided. The NRC (in § 20.208 of its proposed revision to Part 20) has proposed adoption of the above limits on dose and rate of exposure.

In 1971, the NCRP commented on the occupational exposure of fertile women (Ref. 2) and suggested that fertile women should be employed only where the annual dose would be unlikely to exceed 2 or 3 rerns and would be accumulated at a more or less steady rate. In 1977, the ICRP recommended that, when pregnancy has been diagnosed, the woman work only where it is unlikely that the annual dose would exceed 0.30 of the dose-equivalent limit of 5 rerns (Ref. 3). In other words, the ICRP has recommended that pregnant women not work where the annual dose might exceed l.S rem.

C. REGULATORY POSITION

Instructions on radiation risks should be provided to workers, including supervisors, in accordance with § 19.12 of 10 CFR Part 19 before they are allowed to work in a restricted area. In providing instructions on radiation risks, employers should include specific instrc-

tions about the risks of radiation exposure to the embryo/fetus.

The instructions should be presented both orally ane' in printed form, and the instructions should include, a a minimum, the information provided in Appendix A (Instructor's Guide) to this guide. Individuals should be given the opportunity to ask questions and in turn should be questioned to determine whether they understand the instructions. An acceptable method of ensuring that the information is understood is to give a simple written test covering the material included in Appendix B (Pregnant Worker's Guide). This approach should highlight for instructors those parts of the instructions that cause difficulties and thereby lead to appropriate modifications in the instructional curriculum.

D. IMPLEMENTATION

The purpose of this section is to provide information to applicants and licensees regarding the NRC staff's plans for using this regulatory guide.

Except in those cases in which an applicant or licensee proposes an acceptable alternative method for complying with specified portions of the Commission's regulations, the NRC will use the material described in this guide to evaluate the instructional program presented to individuals, including supervisors, working in or frequenting any portion of a restricted area.

8,13-2

APPENDIX A

INSTRUCTOR'S GUIDE

EFFECTS ON THE EMBRYO/FETUS OF EXPOSURE TO RADIATION

AND OTHER ENVIRONMENTAL HAZARDS

In order to decide whether to continue working

while exposed to ionizing radiation during her preg

nancy. a woman should understand the potential effects

on an embryo/fetus, including those that may be pro

duced by various environmental risks such as smoking

and drinking. This will allow her to compare these risks

with those produced by exposure to ionizing radiation.

Table I provides information on the potential effects

resulting from exposure of an embryo/fetus to radiation

and nonradiation risks. The second column gives the

rate at which the effect is produced by natural causes

in terms of the number per thousand cases. The fourth

column gives the number of additional effects per

thousand cases believed to be produced by exposure to

the specified amount of the risk factor.

The following section discusses the studies from

which the information in Table I was derived. The

results of exposure of the embryo/fetus to the risk

factors and the dependence on the amount of the

exposure are explained.

1. RADIATION RISKS

1.1 Childhood Cancer

Numerous studies of radiation-induced childhood cancer

have been performed, but a number of them are con

troversial. The National Academy of Science (NAS) BEIR

report reevaluated the data from these studies and even reanalyzed the results. Some of the strongest support for

a causal relationship is provided by twin data from the

Oxford survey (Ref. 4). For maternal radiation doses of

1,000 millirems, the excess number of deaths (above those

occurring from natural causes) was found to be 0.6

death per thousand children (Ref. 4).

1.2 Mental Retardation and Abnormal Smallness of the Head (Microcephaly)

Studies of Japanese children who were exposed while in

the womb to the atomic bomb radiation at Hiroshima and

Nagasaki have shown evidence of both small head size and

mental retardation. Most of the children were exposed to

radiation doses in the range of 1 to 50 rads. The impor

tance of the most recent study Lies in the fact that

investigators were able to show that the gestational age

(age of the embryo/fetus after conception) at the time the

children were exposed was a critical factor (Ref. 7). The

approximate risk of small head size as a function of

gestational age is snown in Table 1. For a radiation dose

of 1,000 millirems at 4 to 7 weeks after conception, the

excess cases of small head size was 5 per thousand; at 8 to 11 weeks, it was 9 per thousand (Ref. 7).

In another study, the highest risk of mental retarda

tion occurned during the 8 to 15 week period after

conception (Ref. 8). A recent EPA study (Ref. 16) has

calculated that excess cases of mental retardation per

live birth lie between 0.5 and 4 per thousand per rad.

1.3 Genetic Effects

Radiation-induced genetic effects have not been observed

to date in humans. The largest source of material for

genetic studies involves the survivors of Hiroshima and Nagasaki, but the 77,000 births that occurred among

the survivors showed no evidence of genetic effects. For doses received by the pregnant worker in the course of

employment considered in this guide, the dose received

by the embryo/fetus apparently would have a negligible effect on descendants (Refs. 17 and 18).

2. NONRADIATION RISKS

2.1 Occupation

A recen: study (Ref. 9) involving the birth records of 130,000 children in the State of Washington indicates

that the risk of death to the unborn child is related to

the occupation of the mother. Workers in the metal irdustry, the chemical industry, medical technology, the wood ind,.:stry, the textile industry, and farms exhibited

sVillbirths or spontaneous abortions at a rate of 90 per

thousand above that of workers in the control group, which co-sisted of workers in several other industries.

2.2 Alcohol

It has been recognized since ancient times that alco

hol consumption had an effect on the unborn child. Car

thiaginian law forbade the consumption of wine on the

wedding night so that a defective child might not be

conceived. Recent studies have indicated that small

amounts of alcohol consumption have only the minor

effect of reducing the birth weight slightly, but when

consumpton increases to 2 to 4 drinks per day, a pat

tern of abnormalities called the fetal alcohol syndrome

(FAS) berns to appear (Ref. I 1). This syndrome consists

of reduce: growth in the unborn child, faulty brain func

ton, and abnormal facial features. There is a syndrome

Lhat has the same symptoms as full-blown FAS that

cccurs i2 children born to mothers who have not

consumed alcohoL This naturally occurring syndrome

occurs i-. about I to 2 cases per thousand (Ref. 10).

8.13-3

Effect

Cancer death in children

Small head size

Small head size

Mental retardation

Stillbirth or spontaneous abortion

Fetal alcohol syndrome



Perinatal infant death (around the time of birth)

Perinatal infant death

Perinatal infant death

TABLE 1

EFFECTS OF RISK FACTORS ON PREGNANCY OUTCOME

Number Occurringfrom Natural Causes

1.4 per thousand (Ref. 5)

40 per thousand (Ref. 6)




1 to 2 per thousand (Ref. 10)

I to 2 per thousand (Ref. 10)

1 to 2 per thousand (Ref. 10)

23 per thousand (Refs. 13. 14)

23 per thousand (Refs. 13, 14)

23 per thousand (Refs. 13, 14)

Excess Occurrences from Risk FactorRisk Factor

RADIATION RISKS

Childhood Cancer

Radiation dose of 1000 millirems received before birth

Abnormalities

Radiation dose of 1000 millirads received during specific periods after conception:

4-7 weeks after conception

8-1 1 weeks after conception

Radiation dose of 1000 millirads received 8 to 15 weeks after conception

NONRADIATION RISKS

Occupation

Work in high-.risk occupations (see text)

Alcohol Consumption (see text)

2-4 L-inks per day

More than 4 drinks per day

Chronic alcoholic (more than 10 d.•.nks per day)

Chroic alcoholic (more than 10 d:inks per day)

Smoking

Less :han I pa:k per day

One .ack or more per day

8.13-4

0.6 per thousand (Ref. 4)





100 per thousand (Ref. I1)




S per thousand (Ref. 13)


For mothers who consume 2 to 4 drinks per day,

the excess occurrences number about 100 per thousand;

and for those who consume more than 4 drinks per

day, excess occurrences number 200 per thousand.

The most sensitive period for this effect of alcohol

appears to be the first few weeks after conception,

before the mother-to-be realizes she is pregnant (Refs. 10

and 11). Also, 17% or 170 per thousand of the embryo/ fetuses of chronic alcoholics develop FAS and die before birth (Ref. 15). FAS was first identified in 1973 in the United States where less than full-blown effects of the syndrome are now referred to as fetal alcohol effects (FAE) (Ref. 12).

2.3 Smoking

Smoking during pregnancy causes reduced birth weights in babies amounting to 5 to 9 ounces on the average. In addition, there is an increased risk of 5 infant deaths per thousand for mothers who smoke less than one pack per day and 10 infant deaths per

thousand for mothers who smoke one or more packs per day (Ref. 13).

2A Miscellaneous

Numerous other risks affect the embryo/fetus, only a few of which are touched upon here. Most people are familiar with the drug thalidomide (a sedative given to some pregnant women), which causes children to be born with missing limbs, and the more recent use of the drug diethylstilbestrol (DES), a synthetic estrogen given to some women to treat menstrual disorders, which produced vaginal cancers in the daughters born to women who took the drug. Living at high"altitudes also gives rise to an increase in the number of low-birth-weight children born, while an increase in Down's Syndrome (mongolism) occurs in children born to mothers who are over 35 years of age. The rapid growth In the use of ultrasound in recent years has sparked an ongoing investigation into the risks of using ultrasound for diagnostic procedures (Ref. 19).

APPENDIX B

PREGNANT WORKER'S GUIDE

POSSIBLE HEALTH RISKS TO CHILDREN OF WOMEN WHO ARE EXPOSED TO RADIATION DURING PREGNANCY

During pregnancy, you should be aware of things in your surroundings or in your style of life that could affect your unborn child. For those of you who work in or visit areas designated as Restricted Areas (where access is controlled to protect individuals from being exposed to radiation and radioactive materials), it is desirable that you understand the biological risks of radiation to your unborn child.

Everyone is exposed daily to various kinds of radiation: heat, light, ultraviolet, microwave, ionizing, and so on. For the purposes of this guide, only ionizing radiation (such as x-rays, gamma rays, neutrons, and other high-speed atomic particles) is considered. Actually, everything is radioactive and all human activities involve

exposure to raiauon. People are exposed amounts of natural "background" ionizi depending on where they live. Radon gas ir problem of growing concern. Background rad from three sources:

AnTerrestrial - radiation from soil

and rocks Cosmic - radiation from outer

space Radioactivity normally found

within the human body

Dosage range (geographic and other factors)

1

75 to 5,0

The first two of these sources expose th the outside, and the last one exposes it fror The average person is thus exposed to a tabout 125 millirems per year from natural background radiation.

In addition to exposure from normal background radiation, medical procedures may contribute to the dose people receive. The following table lists the average doses received by the bone marrow (the blood-forming cells) from different medical applications.

"*Radiation doses in this document are described in two different units. The rad is a measure of the amount of energy absorbed in a certain amount of material (100 ergs per gram). Equal amounts of energy absorbed from different types of radiation may lead to different biological effects. The rem is a unit that reflects the biological damage done to the body. The milir d and mfllirem refer to 1/1000 of a rad and a rem, respectively.

X-Ray Procedure

Normal chest examination Normal dental examination Rib cage examination Gall bladder examination Barium enema examination Pelvic examination

Average Dose*

10 millirem 10 millirem 140 millirem 170 millirem 500 millirem 600 millirem

*Variations by a factor of 2 (above and below) are not unusual.

NRC POSITION

to different NRC regulations and guidance are based on the ng radiation conservative assumption that any amount of radiation, n homes is a no matter how small, can have a harmful effect on an .iation comes adult, child, or unborn child. This assumption is said to

be conservative because there are no data showing ill Average effects from small doses; the National Academy of nual Dose Sciences recently expressed "uncertainty as to whether a

dose of, say, I rad would have any effect at all." 50 millirem Although it is known that the unborn child is more

sensitive to radiation than adults, particularly during 50 millirem certain stages of development, the NRC has not estab

lished a special dose limit for protection of the unborn 25 millirem child. Such a limit could result in job discrimination for

women of child-bearing age and perhaps in the invasion 25 mihhrem* of privacy (if pregnancy tests were requi:ed) if a sepa

rate regulatory dose limit were specified for the unborn 00 millirem child. Therefore, the NRC has taken the position that

special protection of the unborn child should be -olune body from tary and should be based on decisions made by workers n the inside, and employers who are well informed about the risks otal dose of involved.

For the NRC position to be effective, :t is important that both the employee.and the employer understand the risk to the unborn child from radiation received as a result of the occupational exposure cf the mother. This document tries to explain the risk as clearly as possible and to compare it with other risks to the unborn child during pregnancy. It is hoped this will help pregnant employees balance the risk to the unborn child against the benefits of employmen. to decide if the risk is worth taking. This document also dis-usses methods of keeping the dose, and therefo:e the risk, to the unborn child as low as is reasonably achievable.

8.13-6

RADIATION DOSE LIMITS

The NRC's present limit on the radiation dose that can be received on the job is 1,250 millirems per quarter (3 months).* Working minors (those under 18) are limited to a dose equal to one-tenth that of adults, 125 millirems per quarter. (See § 20.101 of 10 CFR Part 20.)

Because of the sensitivity of the unborn child, the National Council on Radiation Protection and Measurements (NCRP) has recommended that the dose equivalent to the unborn child from occupational exposure of the expectant mother be limited to 500 millirems for the entire pregnancy (Ref. 2). Thp 1987 Presidential guidance (Ref. 1) sp.ecifies an effective dose equivalent limit of 500 millirems to the unborn child if the pregnancy has been declared by the mother; the guidance also recommends that substantial variations in the rate of "exposure be avoided. The NRC (in § 20.208 of its proposed revision to Part 20) has proposed adoption of the above limits on dose and rate of exposure.

ADVICE FOR EMPLOYEE AND EMPLOYER

Although the risks to the unborn child are small under normal working conditions, it is still advisable to limit the radiation dose from occupational exposure to no more than 500 milfirems for the total pregnancy. Employee and employer should work together to decide the best method for accomplishing this goal Some methods that might be used include reducing the time spent in radiation areas, wearing some shielding over the abdominal area, and keeping an extra distance from radiation sources when possible. The employer or health physicist will be able to estimate the probable ,dose to the unborn child during the normal ninemonth pregnancy period and to inform the employee of the amount. If the predicted dose exceeds 500 millirems, the employee and employer should work out schedules or proce

The imit is 3,000 mfllxremz per quarter If the worker's occupational dose history is known and the av-era dose does not exceed 5.000 mflliems per year.

dures to limit the dose to the 500-millirem recommended limit.

It is impor-iznt that the employee inform the employer of her condition as soon as she realizes she is pregnant if the dose to the unborn child is to be minimized.

INTERNAL HAZARDS

This document has been directed primarily, toward a discussion of radiation doses received from sources outside the body. Workers should also be aware that there is a risk of radioactive material entering the. body in workplaces where unsealed radioactive material is used. Nuclear medicine clinics, laboratories, and certain manufacturers use radioactive material in bulk form, often as a liquid or a gas. A list of the commonly used materials and safety precautions for each is beyond the scope of this document, but certain general precautions might include the following:

1. Do not smoke, eat, drink, or 'apply cosmetics around radioactive material.

2. Do not pipette solutions by mouth.

3. Use disposable gloves while handling radioactive material when feasible.

4. Wash hands after working around radioactive materal.

5. Wear lab coats or other protective clothing whenever there is a possibility of spills.

Remember that the employer is required to have demonstrated that it will have safe procedures and practices before the NRC issues it a license to use radioactive material. Workers are urged to follow established procedures and consult the employer's radiation safety officer or health physicist whenever problems or questions aris-.

8.13-7

REFERENCES

1. "Federal Radiation Protection Guidance for Occupational Exposure," Federal Register,.p. 2822, January 27,1987.

2. National Council on Radiation Protection and Measurements, "Basic Radiation Protection Criteria," NCRP Report No. 39, 1971.

3. International Commission on Radiological Protection, "Recommendations of the International Commission on Radiological Protection," ICRP Publication No. 26, Vol. 1, No. 3, 1977.

4. National Academy of Sciences, "The Effects on Populations of Exposure to Low Levels of Ionizing Radiation (BEIR 111)," National Academy Press, Washington, DC, 1980.

5 J. L. Young and R. W. Miller, "Incidence of Malignant Tumors in U.S. Children," Journal of Pediatrics, pp. 254-258, 1975.

"N. J. Blot, "Growth and Development Following erenatal and Childhood Exposure to Atomic Radiation," Journal of Radiation Research (Supplement), pp. 82-85. 1975.

7. R. W. Miller and J. J. Mulvihill, "Small Head Size After Atomic Radiation," Teratology, VoL 14, pp. 355358, 1976.

8. M. Otake and W. J. Schull, "in Utero Exposure to A-bomb Radiation and Mental Retardation; a Reassessment," The British Journal of Radiology, VoL 57, pp. 409-414, 1984.

9. T. L Vaughan et al., "Fetal Death and Maternal Occupation," Journal of Occupational Medicine. Vol. 26, No. 9, pp. 676-678, 1984.

10. J. W. Hanson, A. P. Streissguth, and D. W. Smith, "The Effects of Moderate A4cohol Consumption During Pregnancy on Fetal Growth and Morphogenesis," Journal of Pediatrics, Vol. 92, pp. 457-460, 1978.

I I. D. W. Smith, "Alcohol Effects on the Fetus," Progress .4n Clinical and Biological Research, VoL 36, pp. 73-82, 1980.

12. L B. Robe, "Alcohol and Pregnancy," The American Medical Association, Box 10946, Chicago, 1984.

13. M. B. Meyer and J. A. Tonascia, "Maternal Smoking, Pregnancy Complications, and Perinatal Mortality," American Journal of Obstetrics and Gynecology, VoL 128, No. 5, pp. 494-502, 1977.

14. R. H. Mole, "Radiation Effects on Pre-Natal Development and Their Radiological Significance," The British Journal of Radiology. VoL 52, No. 614, pp. 89-101, February 1979.

15. D. A. Roe, Alcohol and the Diet, AVI Publishing Company Inc., Westport, Connecticut, 1979.

16. Environmental Protection Agency, "Radionuclides." Background Information Document EPA 520/ .1-84-022-1, pp. 8-56 - 8-63.

17. G. W. Beebe, "The Atomic Bomb Survivors and the Problem of Low-Dose Radiation Effects," American Journal of Epidemiology, VoL 114, No. 6, pp. 761-783, 1981.

18. W. J. Blot et al., "Reproductive Potential of Males Exposed in Utero or Prepubertally to Atomic Radiation," in Atomic Bomb Carualty Commission Technical Report TR-39-72, Radiation Effects Research Foundation, Hiroshima, Japan, 1972.

19. National Council on Radiation Protection and Measurements, "Protection in Nuclear Medicine and Ultrasound Diagnostic Proceduies in Children," NCRP Report No. 73, 1983.

8.13-8

VALUE/IMPACT STATEMENT

A draft value/impact statement was published with

the proposed Revision 2 to Regulatory Guide 8.13

(Task OP 031-4) when the draft guide was published for

public comment in August 1981. No changes were

necessary, so a separate value/impact statement for the

final guide has not been prepared. A copy of the draft value/imp!act statement is available for inspection and

copying for a fee at the Commission's Public Document

Room at 1717 H Street NW., Washington, DC, under Task 0? 031-4.

-U.S. G.P.C. 1987-202-292i60318

8.13-9

Attachment 10

GENERAL RADIATION PROTECTION RULES

The following general rules are applicable to individuals entering, working or performing tasks in radiologically controlled restricted work areas:

"* Personnel shall contact the On-Site Radiation Protection Officer (ORPO), or his or her designee, for information needed regarding radiation health and safety and the protective measures required for their jobs.

"* Personnel shall minimize their exposure to radiation by ensuring that adequate job preparations, hazardous work permits (HWP) approvals, necessary equipment, and work familiarity are completed prior to entering the area.

"* Personnel are required to comply with the provisions of the site-specific Health and Safety Plan, site-specific HWP, and the posted area entrance requirements.

"* Personnel shall inspect personal protective equipment (PPE) coveralls or suits before dressing. Damaged or ill-fitting coveralls or suits shall not be worn.

"* If protective coveralls, suits, or equipment is damaged while working, personnel shall stop work when it is safe to do so and proceed to a changing area to replace the PPE coveralls or suits. During replacement of PPE coveralls or suits, the individual shall frisk or be frisked for radioactive contamination. Contaminated areas of the body shall be cleaned prior to returning to work.

"* When removing PPE coveralls or suits, especially when it is contaminated with radioactive material, care shall be taken by the individual to avoid spreading radioactive contamination to other areas or contaminating his or her person or clothing.

No individual shall begin work with radioactive materials until:

"* The individual has a working knowledge of the procedures that will minimize radiation exposure of contamination to himself and to other personnel.

"* The individual is aware of the proper procedures to follow in case of an accident.

"* Personnel shall notify the ORPO of any malfunctioning radiation PPE.

"* Personnel shall keep work areas clean and use work methods that prevent the spread of contamination.

"* Work shall be conducted consistent with maintaining occupation exposure as low as reasonable achievable (ALARA).

"* Appropriate personnel radiation monitoring survey equipment shall be used based on the type and levels of radiation involved and the type of work activities conducted.

"* Maximum practical distance and shielding and minimum working times shall be utilized for protection in working with external sources of radiation.

1

Attachment 11

VISTA GENERAL SAFETY WORK RULES AND GUIDELINES

" Check your work area as you begin your duties to determine what problems or hazards might exist. Review the health and safety requirements of each job with the Vista OnSite Health and Safety Officer (OHSO) and Vista On-Site Radiation Protection Officer (ORPO). Report unsafe equipment, hazardous conditions, and unsafe worker activities to the Vista OHSO.

"* Be sure that you understand emergency procedures. Anticipate what you will do in case of an emergency and review where emergency telephone numbers are posted.

"* Practice good housekeeping in your work area. Pick up your tools. Do not leave material and scrap where they will be hazardous to others.

"* Obey all warning signs such as "Keep Out", "No Smoking", "Eye Protection Required",

and "Authorized Personnel Only".

"* Do not take shortcuts. Use appropriate ladders, ramps, stairways, and paths.

"* Use the sanitary facilities provided and no others. Smoking, eating, and drinking are only permitted in designated areas, check with your supervisor.

"* Do not tamper with, move or use emergency equipment without permission of authorized personnel, except in an emergency.

"* Follow all instructions and directions from the ORPO and OHSO. Failure to do so may result in injury or death to you or your coworkers.

" You are not expected to do a job that might result in injury to yourself or your fellow workers. If you have health and safety concerns that you feel are not being addressed, you may call the Vista RSO in confidence.

Attachment 12

PROHIBITED PRACTICES IN CHEMICALLY CONTAMINATED AREAS

The contamination control or "hot line" is the boundary of an area of known or suspected contamination, a restricted area. A hazardous or potentially hazardous environment may exist at any point inside the contamination control line. All team members who have passed the contamination control line at any time during their visit should be considered to be contaminated. The following items and practices are prohibited at any time within the contamination control line and for all individuals who have crossed the line prior to fully prescribed decontamination practices:

"* No eating, drinking, chewing gum or tobacco, or smoking.

"* No hand-to-mouth contact while contamination of your clothing is possible.

"• No wearing of contact lenses.

"* No using of facial makeup

"* No open wounds unless covered with an airtight bandage.

"* No sores or lesions in the mouth, eyes, or nose unless proper protection is specifically approved by the On-Site Health and Safety Officer (OHSO).

"* No climbing over barrels or obstacles.

"* No starting or maintaining an open flame of any type without approval from the OHSO.

"* No entering area without required safety equipment.

"* No entering area with safety equipment not determined to be in working order immediately prior to entrance.

"• No entering area alone without approval by the OHSO.

"* No leaving an individual alone in the area during a hazardous operation as defined by the OHSO.

Attachment 13

CLEAN SITE WORKERS WEEKLY STATUS REPORT

For week ending:

To:

From:

The following site workers are currently at

__No change from last week

Name: (Please Print)

Last, First, MI Company

Phone:

(Site Name/Location)

___ Except as noted below

Name: (Please Print)

Last, First, MI Company

The following site workers terminated/transferred from this site during the past week:

Name:

Last, First, MI

Terminated I Transferred Name:

Last, First, MI

Note: Do Not Include Visitors On This Report.

Attachment 14

HEALTH AND SAFETY DATABASE SITE WORKER INFORMATION INPUT FORM

Name:Last _First

Social Security No.:

Sex: Male: Female:

Home Address:

Ntreet

Middle

Date Form Completed:

Date of Birth:

Apt. No.

City/State/Zip Code

Occupational Code: Job Title:

Company Name:

Company Address:

Street

City/State/Zip Code

Currently Clean Site: _

IF BEGINNING WORK AT THE SITE:

Actual Start Date:

IF TERMINATING OR TRANSFERRING FROM THE SITE:

Actual Termination Date:

Actual Transfer Date:

Verified By:

ite No:

To Clean Site:

Signature

Printed Name: Date:

The Project Manager should return the completed form to the Health and Safety Program Manager within 5 working days.

Signature

Attachment 15

NUCLEAR REGULATORY COMMISSION FORM 4 OCCUPATIONAL EXTERNAL RADIATION EXPOSURE IfSTORY

INSTRUCTIONS

If you have previously worked in a radiation environment and have been monitored for radiation exposure, print (or type) the following information in ink:

Block No. Complete as follows

I. Enter your last name, first name, and middle initial.

2. Enter your Social Security Number.

3. Enter your date of birth (month, day, year).

4. Enter your age as of your last birthday.

5. Enter the name and full mailing address of each site and previous employer at which you received occupational radiation exposure. If there were no such employments, enter the word "None".

NOTE: It is very important for you to list the facility or institution that maintains your exposure records. For example, if you were employed by XYZ Construction Co. to work at the Salem Nuclear Power Plant, list Salem Power Plant since the plant maintains your records.

6. List the dates of each employment shown in Block 5.

7. Enter the dates of the exposure period, if applicable.

8. - 11. Leave Blank

12. Read certification statement. Sign and date completed forms. Enter the Site name.

13. Leave Blank.

14. Enter the name of your current employer.

Attachment 16

VISTA OCCUPATIONAL RADIATION EXPOSURE HISTORY

EMPLOYEE ACKNOWLEDGEMENT FORM

Attention: Subcontractor Employee

Vista Technologies Inc. (Vista), monitors occupational radiation exposure of persons working on Vista project work sites.

Occupational radiation exposure is detected by monitoring devices worn by the employee when working in an environment that contains radioactive materials and/or contamination.

Federal regulations require that Vista collect your previous occupational radiation exposure history as part of their monitoring of your occupational radiation exposure. This does not relieve individuals of the responsibility for monitoring their own radiation exposure. Each person should keep records of his or her own occupational monitoring their own radiation exposure. Each person should keep records of his or her own occupational exposure.

If you have previously worked in a radiation environment, and have been monitored for occupational radiation exposure, complete the attached forms as follows:

1. Occupational Radiation Exposure History

Provide copies of radiation exposure reports from previous employers.

2. Request for Radiation Exposure Report Records

Print your full name and social security number in the spaces indicated. If you received radiation exposure in the armed forces, indicate the branch of service and service number. Sign the release statement at the bottom of the request letter authorizing Vista to obtain copies of your radiation exposure records prior. to your employment at a site. Vista will complete the rest of the form. (Note: One request form will be needed for each previous employer).

If you have never been monitored for radiation exposure, complete the acknowledgement below.

After you have completed the applicable forms, return all of these forms to the person who provided them to you or to the person they designated.

I understand and acknowledge that as of this date, I have never been monitored for occupational exposures to radiation.

Print full name

Social Security Number Employee Signature

Attachment 17

HAZARD COMMUNICATION TRAINING RECORD FORM

Date:

Employee Name:

Employee I.D. or Social Security Number:

Dates of Training: Initial

Other

Other

Contract Task Order No.:


Information covered in training session:

Employee received hand-outs pertaining to hazardous materials as follows:

I certify that I attended the hazard communication training indicated above.

Signature of employee

I certify that the above named employee received the training indicated.

Signature of Training Supervisor

Attachment 18

RESPIRATORY PROTECTION TRAINING ATTENDANCE RECORD FORM

Type of Training:

Orientation

Reinforcement

Date:

Instructor(s):



The following employees have attended a

Name (Please Print)

Last First Midc

___ Supervisory

___ Respiratory Protection

Time:

hour course in respiratory protection:

Social Security Number

lie Initial

Attachment 19

RESPIRATORY PROTECTION EDUCATION AND FIT TESTING FORM

This is to confirm that

Print Name

Company

Social Security Number

Type of Respirator

I thoroughly understand the usage and benefits of wearing a respirator and will utilize what I have learned when a respirator is necessary for my job.

Type(s) of Respirator(s) Fitted:

Fit-Test By:

Trained and Fitted By:



Date:

Employee Signature:

Date post:	09-Jul-2020
Category:	Documents
Upload:	others
View:	2 times
Download:	0 times