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2.6.1 Health physics and safety plan

Contents
2.6.1.1 National and international legislation relevant to site investigation on radioactively contaminated sites
2.6.1.2 Health and safety management arrangements
2.6.1.3 Establishment of a proper organisation
2.6.1.4 Training
2.6.1.5 Hazard characterisation and exposure assessment
2.6.1.6 Site access and hazards controls
2.6.1.7 Protected environments
2.6.1.8 Protective clothing
2.6.1.9 Respiratory protective equipment
2.6.1.10 Site and worker monitoring
2.6.1.11 Worker and equipment decontamination
2.6.1.12 Emergency preparedness and response

Consistent with the approach for any operation, activities associated with the radiological surveys should be planned and monitored to assure the health and safety of the worker and other personnel, both on-site and off-site, are adequately protected. At the stage of determining the final status of the site, residual radioactivity is expected to be below the derived concentration guideline level (DCGL) values; therefore, the final status survey should in principle not include radiation protection controls. However, radiation protection controls may be necessary when performing scoping or characterization surveys where the potential for significant levels of residual radioactivity is unknown.

2.6.1.1 National and international legislation relevant to site investigation on radioactively contaminated sites

It is advised to check key safety legislation for health and safety management. In Table 2.5 key terms are given as guidance, as in most countries these topics may be treated under different legalisations.

Management:
• Management of health and safety at work;
• Working time regulations;
• Health and safety (first-aid);
• Reporting of injuries, diseases and dangerous occurrences.

Working environment:
• Workplace (health, safety and welfare);
• Provision and use of work equipment;
• Fire;
• Lifting operations and lifting equipment;
• Provision and use of personal protective equipment;
• Health and safety (e.g., safety signs and signals).

Construction:
• Construction (design and management);
• Construction (head protection).

Hazards:
• Control of substances hazardous to health;
• Ionising radiation;
• Electricity at work;
• Manual handling operations;
• Control of noise at work;
• Control of asbestos;
• Control of heavy metals, e.g. lead, at work.
tential for significant levels of residual radioactivity is unknown.

Table 2.5 Key terms relevant to site investigations on contaminated land

2.6.1.2 Health and safety management arrangements

The overall safety principle should be to provide competent and trained employees working under a safe system carried out in a safe place of work with safe plant and materials. These principles are featured in the common law “duty of care” and in occupational health and safety laws. The safety management arrangements provide the basis for the working procedures and for the work activities.

Workers involved with site remediation may be exposed to conventional construction and operations hazards as well as to hazards coming from radioactive materials, toxic metals, organic compounds or bio-hazardous agents, respirable fibres, flammable and combustible materials, corrosive and reactive chemicals, and explosives.

Remediating a contaminated site requires a thorough and disciplined approach to evaluating the potential hazards to site workers, and taking the necessary steps to perform the work in a safe manner. A hazard and operability study (HAZOP) may be required to identify and evaluate the hazards. The results of the safety analyses should be incorporated into a site health and safety plan, along with remediation work plans and procedures and controls. Safety measures resulting from these safety analysis and findings should be made in compliance with the ALARA principle and optimal measures should be put into practice. As new hazards are identified at the site, they should be incorporated into an update of the assessment.

The possible elements of a health and safety plan may involve:

  • Establishment of a proper organisation;
  • Training;
  • Hazard characterisation and exposure assessment;
  • Site access and hazard controls;
  • Site and worker monitoring and medical surveillance schedules;
  • Decontamination (personnel and equipment);
  • Arrangements for monitoring of compliance;
  • Communications;
  • Welfare requirements;
  • Emergency action plan, including first-aid facilities;
  • Emergency response.

It is advised to update the health, security and safety plan regularly and that a health, security and safety file should be produced and maintained for the duration of the project. This document should include:

  • Workplace authorisations (e.g., acknowledgement that workers have read and understood relevant safety procedures and instructions and method statements);
  • Training records (to demonstrate that all staff are suitably qualified and experienced personnel and have attended all required site-specific training/induction courses);
  • All permits (e.g., permits-to-operate, permits-to-work, excavation permits);
  • All personal protective equipment (PPE)/respiratory protective equipment (RPE) service records;
  • All radiation and contamination survey records and clearance certificates;
  • Site diaries;
  • All documentation relating to disposal of wastes (e.g., duty of care notices);
  • Records of any permanent changes to land or buildings as a result of the work;
  • Adequate monitoring of the system by the management.

2.6.1.3 Establishment of a proper organisation

Establishment of a multidisciplinary team is a first step required to plan, organise, evaluate and conduct a remediation plan. The team should include health and safety specialists with expertise in more than just radiation protection; for example, specialists who can also assess chemical and biological hazards and develop safety procedures accordingly. The organisation typically would also include a health and safety officer who has the responsibility for maintaining the health and safety of the site [IAEA-2006b].

The organisation responsible for implementing the remediation activities should have, or should have access to, competent staff to cover the following areas adequately [IAEA-1999], [IAEA-2006b]:

  • Project management;
  • Safety requirements of any permits or authorisations issued;
  • Regulatory standards and issues;
  • Radiation protection;
  • Conventional industrial hazards;
  • Data collection and evaluation;
  • Environmental monitoring;
  • Quality assurance and quality control;
  • Radiochemical analysis;
  • Geological and hydro-geological expertise;
  • Waste management;
  • Site security;
  • Equipment operators;
  • Labour force.

Information should be provided to all interested parties concerning the future implementation of the remediation programme, including: identification of the organisations responsible for implementing the programme; the provision of adequate human resources, equipment and supporting infrastructure; the organisation and allocation of the required funding; the programme for waste management; the safety and health protection protocols for the remediation workers and the public; and the arrangements for pre- and post-remediation monitoring procedures for assessing the efficiency and effectiveness of the remediation programme.

2.6.1.4 Training

Because of its complexity, workers on a remedial action need a wide range of skills and experience. Labourers should be able to critically analyse the situation for both individual safety and the general success of the operation. Equipment operators should be empowered to make decisions about the depth of excavation, etc. Supervising staff should be able to modify the plan according to changing conditions (e.g., weather). Project designers and managers should be able to prepare a holistic approach to the problem, including technical, legal, economic and natural science issues. They also need to determine the education level required from their staff [IAEA-1999].

All persons involved in the remediation should be made familiar with the contaminated area, the hazards and the safety procedures for the safe and effective performance of their duties. Training of personal protective equipment (PPE) proper use must be conducted prior starting of remediation actions of workers. Specialised training may be needed in certain areas of work with the workers certified in both radiological and non-radiological hazardous worker safety. For some activities, the use of mock-ups and models in training can enhance efficiency and safety [IAEA-2006b].

The requirements for a basic training programme and for refresher training should be stated in the remediation plan.

The remediation organisation should anticipate possibilities in their plans to revise their health and safety planning in the light of new discoveries. Such ‘contingency’ planning allows a more efficient adaptation to necessary changes in the health and safety approach.

2.6.1.5 Hazard characterisation and exposure assessment

The remediation team typically should conduct a thorough safety analysis to assess potential impacts on site workers (and the public) such as a nuclear safety assessment and a criticality assessment, as well as evaluating the hazards associated with radioactive constituents. In addition, the team should assess exposure scenarios and pathways associated with non-radiological contaminants, such as biological contaminants, chemical contaminants and explosives. The results of the safety analysis should then be incorporated into the site health and safety plan, along with remediation work plans and procedures. As new hazards are identified at the site, they become incorporated into an update of the assessment [IAEA-2006b].

2.6.1.6 Site access and hazards controls

An additional component of protecting worker health and safety during the conduct of remediation should be accomplished through the application of a hierarchy of access and hazard control methods. The first option to consider in implementing control of worker access to hazards should be the use of engineering controls to remove or isolate the hazard (e.g., defining a support zone, contamination reduction zone, exclusion zone and control room). The next option should be the use of administrative controls, and finally, protected environments, personal protective equipment and respiratory protective equipment, personal protective equipment may be used as a supplement to the two preferred methods. Different levels of personal protective equipment may be required, beyond dealing with only the radiological component. For example, respiratory protection with specialised filters (e.g., designed to filter out certain toxic organic compounds) may be required [IAEA-2006b].

2.6.1.7 Protected environments

When it is decided after a careful consideration to implement an enclosing of the contaminated area to control the exposure of humans and the wider environment, depending on the length of time of the investigation, this may be a semi-permanent building or a tented enclosure.

Consideration of what to do in extreme weather events and at decommissioning of the facility should be taken into account at the planning stage. Further control of the internal environment may be required, by the use of negative pressures. This may extend to creating a negative pressure within the tent to contain contamination, and protecting workers with air-line suits.

2.6.1.8 Protective clothing

Before the start of the project, suitable protective clothing should be selected. Influencing factors on the selection will include the following:

  • Full range of hazards and level of protection required;
  • Compatibility with other personal protective equipment;
  • Availability, storage and maintenance arrangements;
  • Cost (e.g., use of disposable items);
  • Working environment (dry, wet, muddy, etc);
  • Number of workers;
  • Project duration.

Typical protective clothing for site characterisation projects (non-radioactively contaminated sites) is shown in Table 2.6. Most of the protective clothing is also suitable for radioactively contaminated sites. It is best practice (and commonly a requirement on nuclear-licensed sites) that separate protective clothing is used for designated and non-designated areas.

Typically, the two sets of protective clothing are distinguished by colour-coding or other marking. Durable personal protective equipment should be carefully looked after and its working life maximised without prejudicing personal safety. Damaged, redundant or discarded personal protective equipment will be treated as waste and this should be factored into the waste management plan.

For areas with known or suspected radioactive contamination, a risk assessment by a suitably qualified and experienced person, such as a radiation protection officer, or a group should be undertaken. This assessment should indicate the actions that are required to ensure protection of the workers through the provision of operational procedures (local instructions) and, potentially, personal protective equipment and respiratory protective equipment (RPE) if appropriate. In general terms it is likely that the requirements necessary for ensuring protection against chemical contamination will also provide protection against radiological contamination. However, it may be that disposable oversuits and boots may be of benefit for contamination control. Personal dosimetry may be required and this could therefore include the requirement to record exposures with an Approved Dosimetry Service. In particular cases health physics support may be appropriate to ensure the radiological protection of workers during specific operations. It is important, where mixed radiological and non-radiological contamination exists, that a holistic approach is taken to ensure the protection of workers.

Contamination type Protective clothing and equipment Monitoring equipment Safety procedures

Non-radioactive contamination Overalls
Safety boots
Appropriate gloves
Tested hard hats
Eye protection
Face masks and filters
Breathing apparatus
Safety harness and lanyards
Life jackets
Safety torches
Fire extinguishers
First aid equipment
Mobile phone (where allowed)
Hand-held gas monitors
Automatic gas detectors
Personal monitors
Environmental monitoring equipment
Cable avoidance tool
Training
Permit to work systems
Notification of emergency services
Access to telephone contact
Decontamination facilities for plant
Decontamination facilities for personnel
Safe sampling procedures
Safe sample handling procedures
Access for emergency vehicles

Table 2.6 Examples of protective clothing and equipment, monitoring equipment and safety procedures that could be applied in characterization projects on contaminated sites

2.6.1.9 Respiratory protective equipment

Before any respiratory protective equipment is used, an exposure assessment should be carried out. A number of assessments may be needed in projects that are of long duration, or where the nature and/or execution of work changes. All individuals wearing respiratory protective equipment should receive suitable training in its use and they should be aware of its limitations. When not in use, the respiratory protective equipment should be kept in clean, secure and dry storage conditions and it should always be kept fully serviceable (clean, no broken straps, etc). Respiratory protective equipment must be regularly inspected and tested by qualified personnel, and records kept. The selection and use of respiratory protective equipment can be regulated by national legalisation.

2.6.1.10 Site and worker monitoring

The extent of monitoring programmes should be determined on the basis of the activities that will be performed during the remediation and the degree of uncertainty concerning the performance of these activities, and should be consistent with longer term monitoring programmes set up to verify the long term stability of exposure conditions (e.g., by monitoring the covering of mining residues, protection against the infiltration of water and protection against erosion or atmospheric dispersion) 12. There should also be a medical surveillance programme for site workers in order to minimise adverse health effects on the workforce. The medical surveillance programme would need to be broad enough to anticipate potential exposure to contaminants other than just radiological hazards [IAEA-2006b].

2.6.1.11 Worker and equipment decontamination

Worker and equipment decontamination programmes are critical to expedite entry of workers, minimise the generation of costly hazardous wastes and minimise equipment replacement. Before work can begin, contamination control and decontamination programmes for workers and equipment should be documented in the health and safety plan, communicated to site workers and implemented in areas where there is a possibility for exposure to chemical, biological or radiological hazards [IAEA-2006b].

2.6.1.12 Emergency preparedness and response

A programme for emergency planning that is applicable for remediation activities should be established and described in the remediation plan. Operating organisations should ensure that procedures for dealing with unforeseen events that may occur during remediation are prepared and put into place. Personnel should be trained in emergency procedures. Provision should be made for the periodic testing and updating of these procedures by conducting periodic exercises. In the event of an unforeseen incident happening during remediation, the responsible parties should without delay notify the regulatory body [IAEA-2007a].

The emergency preparedness and response plan should address potential uncontrolled hazardous substance releases causing a potential health, safety or environmental hazard, i.e., one that cannot be mitigated by personnel in the immediate work areas where the release occurs. For example, a fire at the site may come into contact with, and volatilise, certain chemical contaminants that could be released into the air.
Such a plan can include the following items [IAEA-2006b]:

  • Hazard evaluation;
  • Emergency action plan (including evacuation plan);
  • Emergency response plan;
  • Emergency response organisation;
  • Emergency equipment and personal protective equipment;
  • Emergency training;
  • Medical surveillance;
  • Emergency medical treatment, transport and first aid arrangements.