æ Requires Prior CNSC Approval

BP--00002 1 of 80 Prepared/Revised by Verified by Approved by B. Cleaver Manager Employee Safety K. Fox Vice President Environment and Safety Date 05APR2001 Date Date æ Requires Prior CNSC Approval Filed with Regulator/Governing Agency Current Revision Summary Supersedes N--03415.1-10001 New document. TABLE OF CONTENTS Page 1.0 INTRODUCTION...2 2.0 CORPORATE MANDATES...4 3.0 PERSONAL MANAGEMENT...6 4.0 LIMITS...9 4.1 Dose Limits in Canadian Nuclear Safety Commission regulations...9 4.2 Exceptions to Dose Limits - Nuclear Energy Workers...11 4.3 Dose Limits - Workers Other Than Nuclear Energy Workers...11 4.4 Dose Limits - Members of the Public...11 4.5 Dose Limits - Pregnant Nuclear Energy Workers...11 4.6 Facility Emission Limits...11 4.7 Dose Rate Limits in Facilities...12 4.8 Surface Contamination...12 4.9 Annual Limits on Intake and Derived Air Concentrations...13 5.0 FACILITY DESIGN AND OPERATION...14 6.0 HAZARD AND EXPOSURE MANAGEMENT...22 7.0 RADIOACTIVE MATERIAL MANAGEMENT...28 8.0 INCIDENTS AND EMERGENCIES...35 9.0 INFORMATION MANAGEMENT...44 APPENDIX A: RECORDS RETENTION...49 APPENDIX B: APPENDIX C: QUALIFICATION STANDARDS...51 ANNUAL LIMITS ON INTAKE AND DERIVED AIR CONCENTRATIONS...52 APPENDIX D: MEDICAL INFORMATION...55

2 of 80 BP--00002 APPENDIX E: FEDERAL AND PROVINCIAL TRANSPORT REGULATIONS...59 APPENDIX F: REFERENCES...62 APPENDIX G: GLOSSARY...63 APPENDIX H: INDEX...77 1.0 INTRODUCTION 1.1 Framework Bruce Power s system for managing health and safety includes a set of documents intended to guide management action. The documents describe how the corporation manages health and safety and can be used to provide information to employees, regulatory agencies, members of the public, and other interested parties. This set of documents is headed by the Policy on Health and Safety. Further corporate direction is provided by Policies on Leadership, Assessment, Exposure Management, Hazard Management and Information Management. The Bruce Power Radiation Protection Policies and Principles document is a concise set of objectives, principles, responsibility statements and policies which govern radiation protection in Bruce Power. It is senior to all other radiation protection related documents in the corporation. It is intended for use by Bruce Power staff who are responsible for preparing or issuing policies, practices and information related to radiation protection. It also applies to those who are responsible for making decisions that may impact on radiation protection and for which more detailed instructions do not exist. Two documents direct much of the application of the Policies and Principles. These are the Radiation Protection Requirements for general use and the Radiation Protection Regulations Part 2 for radiography. Both documents are referred to by the acronym RPRs As a minimum standard, the RPRs comply with the federal Nuclear Safety and Control Act and Regulations, as well as other applicable federal and provincial regulations. Licences issued pursuant to the Nuclear Safety and Control Act may contain additional requirements pertaining to radiation protection. Bruce Power s RPRs apply the intent of the principles and recommendations established by the International Commission on Radiological Protection and the International Atomic Energy Agency. At all stages of the life cycle, management produces documents subsidiary to the Radiation Protection Policies and Principles and the RPRs, which specify local application and practice. [2.1.1, 2.1.2, Appendix A, Records Retention - 1.3 (13)]. The Radiation Protection Policies and Principles and the RPRs, and their subsidiaries, stand in addition to and are not substitutes for, documents of similar purpose governing conventional health and safety.

BP--00002 3 of 80 1.2 Applications Application of the RPRs in the design and performance of radiation protection programs, is intended to protect all persons, including members of the public, who may be exposed to ionizing radiation as a result of activities at Bruce Power s facilities. The Radiation Protection Requirements apply to the design, construction, operation, maintenance and decommissioning of Bruce Power facilities and equipment and to the use of radioactive materials for any purpose within the corporation. The Radiation Protection Requirements do not apply to the prevention and mitigation of reactor accidents. The Radiation Protection Regulations Part 2 apply to all radiography work, and focuses primarily on hazards which arise from radiography work itself. Responsibility for implementation of the RPRs is with management unless otherwise specified. Responsibility is held by different units depending on the stage in the life cycle of the business area or project. The RPRs are applicable to all persons entering a facility where ionizing radiation is present. All personnel, regardless of function, shall comply with the RPRs whenever their work involves the potential for radiation exposure to themselves or others. When employees of contractors or government employees could be exposed to radiation at a Bruce Power facility, the RPRs shall apply to these persons as though they were employees of Bruce Power. In particular, the requirements for designation as Nuclear Energy Workers (NEWs) [3.1.1] shall apply. 1.3 Organization of the RPRs 1.3.1 Nomenclature Unless otherwise stated, the adjective approved means approved by the Responsible Health Physicist, and the adjective authorized means authorized by the Canadian Nuclear Safety Commission (CNSC). Management refers to managers of those units that design, construct, operate, maintain or decommission facilities, programs or equipment where ionizing radiation hazards may exist. The terms nuclear facility and facility include nuclear-electric generating stations, laboratories, testing facilities, material storage sites and locations where radioisotopes are used or handled, such as a tritium removal facility. The term material refers to any radioactive material which is used in the conduct of Bruce Power s business. Use of the word shall indicates that compliance with the given regulation is mandatory. Use of the word should indicates that the given course of action is recommended as meeting the intent of the Bruce Power Radiation Protection Policies and Principles or RPRs, but is not mandatory.

4 of 80 BP--00002 1.3.2 Cross-References 1.3.3 Index Cross-references to other sections of the RPRs are given in square brackets in the text, e.g., [4.1.1]. There is a comprehensive keyword index at the end of the text, to assist users in finding specific information. 1.3.4 References The RPRs follow the British form for references. In the text, references are cited in round brackets by the first two letters of the first author s surname or the organization s name, and the year of publication, e.g., (AB83). A complete, alphabetized list entitled References. 1.3.5 Glossary The Glossary gives the official meanings of most special terms used. 1.4 Maintenance The RPRs shall be revised based on experience and to comply with current radiation protection philosophy and technology, and applicable federal and provincial regulations. All revisions shall be submitted to the CNSC for authorization. The RPRs are administered by the Radiation Protection Department. Revisions can be proposed by any unit or individual and shall be addressed in a timely manner by the Employee Safety Manager. Employees, through officially recognized employee groups, and management shall have the opportunity to review proposed changes and to make recommendations for the improvement of the RPRs. This does not apply to employees of contractors or government employees. 2.0 CORPORATE MANDATES 2.1 Approval 2.1.1 Site or division level documents whose primary purpose is radiation protection shall be approved in their entirety by the Responsible Health Physicist. [1.1 paragraph 7, Appendix A - 1.3 (13)]. 2.1.2 The Responsible Health Physicist or delegate shall review the radiation protection aspects of facility policies, procedures and manuals. 2.1.3 Bruce Power documents whose primary purpose is radiation protection, including Policies, and Procedures, shall be prepared by the Employee Safety Department/Manager and approved by the Vice President Safety and Environment.

BP--00002 5 of 80 2.1.4 [Revoked] 2.1.5 Other approvals are specified in the appropriate sections of the RPRs. 2.2 Interpretation and Deviations [Appendix A - 1.3 (1)] 2.2.1 The Employee Safety Department shall provide interpretations of the RPRs. 2.2.2 Each facility where radiation hazards may exist shall have a Responsible Health Physicist. This person provides approvals, as required by the RPRs, as they apply to that facility. For nuclear stations, this person shall be stationed at the facility and shall be authorized by the CNSC. For other facilities (e.g., those containing radioactive sources under a radioisotope licence), the Responsible Health Physicist need not be stationed at the facility, unless this is required as a condition of a licence issued pursuant to the Nuclear Safety and Control Act. The Responsible Health Physicist shall be held accountable for the performance of all activities assigned to the position by the RPRs. An authorized health physicist may delegate functions if the function is identified in the regulations by the phrase or delegate or if the function is being delegated to a person authorized by the CNSC to perform this function. 2.2.3 Deviations from the RPRs shall be documented and approved. Such exceptions shall be granted on the basis of a suitable written rationale prepared by facility management. Deviations that apply to more than one facility must be approved by the Employee Safety Manager. In all cases approval by the CNSC prior to the change being implemented must be obtained. 2.3 Assessment 2.3.1.1 [Revoked] 2.3.1.2 The Performance Assurance Department shall provide assessments on behalf of the Chief Executive Officer according to Independent Assessment Program. 2.3.1.3 [Revoked] 2.3.2 Management shall make available all the information required to conduct assessments. 2.4 Modifications Management shall inform the Responsible Health Physicist of proposed modifications to equipment or installations which might reasonably be expected to affect the radiation protection of employees or members of the public.

6 of 80 BP--00002 3.0 PERSONAL MANAGEMENT 3.1 Administration Concerning Nuclear Energy Workers (NEW) Programs shall be in place to ensure that NEWs receive appropriate health surveillance and radiation protection. Health surveillance records shall be kept [Appendix A - 1.3 (6)]. 3.1.1 For the purpose of the RPRs, any employee who in the course of his or her work for Bruce Power is likely to receive a dose of ionizing radiation in excess of any dose specified in the Nuclear Safety and Control Regulations (i.e., the dose limits for the public) shall be designated a NEW. 3.1.2 Management shall maintain a readily accessible list of all NEWs employed at each facility and shall inform the Radiation Protection Department of any NEW status changes. 3.1.3 Each NEW shall be informed in writing of: 1. His or her designation as a NEW; 2. The risk involved in working with radiation, including the risks to the embryo and fetus [4.5]; 3. If the NEW is a woman, her responsibility to notify Management in writing upon having reason to believe that she is pregnant [4.5]; 4. The withdrawal of his or her NEW status. 3.1.4 Management shall obtain from every NEW, usually when the person has first been designated as such, written acknowledgement that the person has been informed of: 1. His or her designation as an NEW; 2. The risk involved in working with radiation, including the risks to the embryo and fetus [4.5]; 3. If the NEW is a woman, her responsibility to notify Management upon having reason to believe that she is pregnant [4.5]. 3.1.5 Upon a Management representative being notified in writing by a worker that she is pregnant, the Management representative shall inform the Responsible Health Physicist. 3.1.6 Each NEW shall undergo a medical examination as prescribed in any licence applicable to that person. A record shall be kept of all examinations [Appendix A - 1.3 (6)]. 3.1.7 [Revoked] 3.1.8 No person shall be employed as a NEW if: The person s qualifications, training and experience do not comply with the conditions contained in any licence that is applicable to him or her.

BP--00002 7 of 80 3.1.9 When a person is attached to a facility as temporary staff, the decision as to whether or not to designate the person as a NEW and at what level of qualification, is subject to the facility s policies. Such policies shall be consistent with the RPRs. 3.2 Administration Concerning Workers Other Than Nuclear Energy Workers 3.2.1 Persons working at a nuclear facility shall be informed of the risks associated with exposure to ionizing radiation, including the risks to the embryo and fetus. 3.2.2 Every woman working at a nuclear facility shall be informed that upon having reason to believe that she is pregnant, she should notify Management in writing. 3.2.3 Upon a Management representative being notified in writing by a worker that she is pregnant, the Management representative shall inform the Responsible Health Physicist. 3.3 Training and Qualification 3.3.1 The Training Department shall be responsible and accountable for development and delivery of the radiation protection training program, in accordance with standards for qualification approved by the Employee Safety Manager. [Appendix A - 1.3 (14), (15)] 3.3.2 As part of their normal job duties, individuals shall maintain familiarity with the RPRs. 3.3.3 Individuals shall be trained to meet the qualification [Appendix B, Qualification Standards] requirements and all training shall be approved. 3.3.4 Both Line management and the Responsible Health Physicist or delegate shall be satisfied that an individual is qualified in radiation protection. 3.3.5 Individuals shall be informed when their qualification status changes. 3.4 Access and Working Restrictions 3.4.1 Individuals shall be informed of any restrictions on their access to radiological zones and on their performing radioactive work. 3.4.2 Individuals shall not enter a radiological zone, perform or supervise radioactive work or be made responsible for the radiation protection of themselves or other persons, unless they are qualified [Appendix B] to do so. 3.4.3 Individuals qualifications shall govern decisions made regarding their ability to be responsible for their own radiation protection or to be responsible for the radiation protection of others. 3.4.4 The Responsible Health Physicist shall make the final decision on the appropriate restrictions on radioactive work for a person who has exceeded any of the limits set out in the RPRs. Such persons shall be removed from radioactive work and shall not return to it without approval and authorization [6.3.4].

8 of 80 BP--00002 3.4.5 Approved removal and return to work levels shall be established and shall be applied to persons who have received internal uptakes of radionuclides [8.1.1 (e), 8.1.2 (d)]. 3.5 Joint Health and Safety Committees 3.5.1 Joint health and safety committees to deal with both conventional and radiological hazards shall be established in facilities. 3.5.2 Composition, roles and responsibilities for the joint health and safety committees shall be as described in the applicable legislation. 3.6 Refusals to Work 3.6.1 A person has the right to refuse to work for conventional and radiological health and safety reasons as described in the applicable legislation. 3.6.2 Procedures for handling refusals to work related to conventional health and safety issues shall be as described in the applicable legislation and administered by the appropriate regulatory body. 3.6.3 Procedures for handling refusals to work related to radiological health and safety issues shall be as described in the procedures of the CNSC and administered by the CNSC. 3.6.4 For any specific work refusal, the right to refuse to work shall terminate when the appropriate regulatory body, determines that working conditions are acceptable. The worker or Bruce Power may appeal such a decision as stipulated by the applicable legislation. 3.7 Freedom from Reprisal 3.7.1 A person, who has exercised his or her right to refuse to work [3.6.1], shall not be dismissed, disciplined, suspended, intimidated, coerced or threatened to be dismissed, disciplined or suspended. 3.8 Emergency Training It is important that all staff be trained to respond competently in an emergency [8.1, 8.2, 8.3]. Periodic practice is required to maintain the necessary skills. Each facility shall conduct an emergency practice at least once per year. Definition: For the purposes of this section, the term individual represents everyone who could reasonably be expected to have a role to play in an emergency. Included are employees, contractors and government employees attached to the facility. 3.8.1 Individuals shall be made aware of the hazards of their work and emergencies which may arise. 3.8.2 Individuals shall maintain familiarity with procedures relevant to personnel and facility emergencies and with the equipment that they could be expected to operate in an emergency.

BP--00002 9 of 80 3.8.3 Individuals shall take part in emergency practices and drills at a frequency sufficient to maintain competence in the activities for which they could be responsible in an emergency. 3.9 Disciplinary Measures 3.9.1 In order to maintain a safe workplace for all, an employee may be warned, suspended or discharged if it is shown that he or she has acted or repeatedly acts in an irresponsible manner with respect to the RPRs and/or radiation protection. 4.0 LIMITS The dose limits do not include dose equivalent received by a worker from background sources or from medical diagnostic or therapeutic procedures. The dose limits do include any dose equivalent received by a worker, as a consequence of his or her occupation, from all sources of ionizing radiation. The dose limits specified in Section 4.1, 4.3, 4.4 and 4.5 of the RPRs do not apply to ionizing radiation received by a person carrying out emergency procedures undertaken to avert danger to human life. However, all doses shall be kept as low as is feasible and unnecessary exposure shall be avoided. In determining the dose received, the contribution from sources of ionizing radiation both inside and outside the body shall be included. 4.1 Dose Limits in Canadian Nuclear Safety Commission regulations Regulatory doses and limits prescribed in the Canadian Nuclear Safety Commission (CNSC) Regulations are summarized in this Section. 1. Worker s doses shall be monitored to regulatory dose limits. 2. If a person has exceeded a dose limit prescribed by the CNSC, the CNSC must be notified. 3. A person may not receive a planned dose in excess of a dose limit prescribed by CNSC Regulations. Dose Limits Prescribed in the Canadian Nuclear Safety Commission Regulations According to the CNSC Regulations all NEWs shall be notified of the regulatory Effective Dose Limits and Equivalent Dose Limits. These limits are presented in Tables 1 and 2 below.

10 of 80 BP--00002 4.1.1 Table 1 Effective Dose Limits Person Period Whole Body (Effective Dose) Limit NEW One-year dosimetry period Five-year dosimetry period 5 rem (50 msv) 10 rem (100 msv) Pregnant NEW Balance of the pregnancy 400 rem (4 msv) A person who is not a NEW Table 2 Equivalent Dose Limits One calendar year 100 rem (1 msv) Organ or Tissue Person Period Equivalent Dose Limits Lens of an eye NEW Any other person One-year dosimetry period One calendar year 15 rem (150 msv) 1.5 rem (15 msv) Skin NEW Any other person One-year dosimetry period One calendar year 50 rem (500 msv) 5 rem (50 msv) Hands and feet NEW Any other person One-year dosimetry period One calendar year 50 rem (500 msv) 5 rem (50 msv) 4.1.2 CNSC Radiation Protection Section on Emergency Dose Limits states the following. During the control of an emergency and the consequent immediate and urgent remedial work, the effective dose and equivalent dose may exceed the applicable dose limits prescribed in the above tables, but the effective dose shall not exceed 50 rem (500 msv) and the equivalent dose received by the skin shall not exceed 500 rem (5 msv). Emergency dose limits does not apply in respect of pregnant nuclear energy workers who informed the licensee in accordance with the regulations. The dose limits does not apply in respect of pregnant nuclear energy workers who informed the licensee in accordance with the regulations. The dose limits prescribed in the above tables may be exceeded by a person who acts voluntarily to save or protect human life. For more information on emergencies, see BP-PROG-00047, The Consolidated Bruce Power Emergency Plan.

BP--00002 11 of 80 4.2 Exceptions to Dose Limits - Nuclear Energy Workers 4.2.1 Special planned exposures: The CNSC, in response to an application made in advance, may permit a NEW a single or accumulated dose up to twice any of the annual dose limits for NEWs [4.1]. However, the CNSC shall not be requested to issue such a waiver unless: 1. There are extraordinary circumstances where no appropriate alternative is available; and 2. The NEW has been informed of the implications of the exposure for his or her own health and has consented in writing to the waiver being applied. 4.2.2 Waivers shall not be arranged for NEWs who are known to be pregnant. 4.3 Dose Limits - Workers Other Than Nuclear Energy Workers Administrative and procedural controls shall be established to ensure that these limits are not exceeded. 4.3.1 Whole body: The total of all effective doses shall not exceed 500 mrem during any calendar year. 4.3.2 Organs or tissues: The total of all doses shall not exceed 5 rem during any calendar year. 4.4 Dose Limits - Members of the Public 4.4.1 Whole body: The total of all effective doses shall not exceed 500 mrem during any calendar year. 4.4.2 Organs or tissues: The total of all doses shall not exceed 5 rem during any calendar year. 4.5 Dose Limits - Pregnant Nuclear Energy Workers Administrative and procedural controls shall be established to ensure that these limits are not exceeded. 4.5.1 Abdomen of a pregnant NEW: The total of all doses of radiation received after Management is informed of the pregnancy of that worker, shall not exceed a total of 400 mrem. 4.6 Facility Emission Limits 4.6.1 Authorized emission limits shall be established for radionuclides likely to be released from a nuclear facility (GO86). These limits shall be based on a methodology approved by the Environment Department, Technical Support. 4.6.2 Operating targets for emissions shall be established.

12 of 80 BP--00002 4.7 Dose Rate Limits in Facilities 4.7.1 General Radiation Background 4.7.1.1 Zone 1 [5.1, 5.1.3] shall have a general radiation background as low as possible and in any case shall have an average monthly radiation field level less than 0.25 mrem/h. 4.7.1.2 Under normal operating conditions, areas which are usually occupied or are occupied for long periods of time, should have a low ambient radiation field. The long term exposure of personnel who are normally in or frequently passing through the areas shall be considered. The following guidelines on general dose rates apply for design purposes. Area mrem/h 1. Average dose rate, accessible area 1 2. Average dose rate, shutdown area 4 3. Maximum dose rate, shutdown area 20 4.7.2 Dose Rate Limits in Material Storage Facilities Definition: For the purposes of this section: The term external boundary means the outside surface of the wall of an above ground structure, or the surface of the ground or the clearly delineated perimeter of the area in the case of a below ground structure. The term temporary boundary means a boundary of unfixed form the purpose of which is to warn personnel of temporary hazards caused by unfinished storage operations. For example, a system of portable barriers and signs is commonly used to form a temporary boundary. 4.7.2.1 Gamma dose rates outside a long-term storage structure, measured at the external boundary, shall not exceed 2.5 mrem/h. 4.7.2.2 Within a long-term storage structure currently receiving radioactive material, the gamma dose rate, measured at the temporary boundary shall not exceed 300 mrem/h. Access to such facilities shall be controlled. 4.7.2.3 Where it is necessary to store radioactive material on a temporary or interim basis, the radiation hazards resulting from the storage should not exceed those arising from long-term storage. [4.7.2.1, 4.7.2.2] 4.8 Surface Contamination 4.8.1 The Employee Safety Department, shall approve contamination limits and decontamination levels for both fixed and loose surface contamination. In the absence of limits or levels established for specific circumstances, the default values in Sections 4.8.2 and 4.8.3 shall apply.

BP--00002 13 of 80 4.8.1.1 Under normal circumstances, the reference area for calculation of β/γ surface contamination is 1 x 10-2 m 2. However, in practice, most survey and monitoring instruments use 3 x 10-2 m 2 as a reference area. 4.8.1.2 For the purposes of this section (and Section 5.1.5.1) the term non-detectable means nondetectable with an instrument and monitoring technique capable of detecting contamination OHYHOVRI &LP 2 or less. 4.8.2 Contamination limits: The following surfaces shall not exceed the β/γ surface contamination limits indicated. Surface Materials given an unconditional transfer Fixed Contamination Limit [µci/m 2 ] Loose Contamination Limit [µci/m 2 ] 1 Non-detectable Zone 1 and Unzoned Area surfaces 1 Non-detectable 4.8.3 Decontamination levels If β/γ surface contamination is detected on the following surfaces in excess of the levels identified, appropriate actions shall be taken to reduce the contamination to these levels or lower. Surface Fixed Contamination Level [µci/m 2 ] Loose Contamination Level [µci/m 2 ] Body surfaces 1 Non-detectable Personal clothing 1 Non-detectable Protective clothing 5 Non-detectable Respirators 1 Non-detectable Contamination control areas No limit 5 4.8.3.1 If loose contamination is detected in any area outside a contamination control area, that area shall be decontaminated as soon as practicable or it shall be set up as a contamination control area. All such events shall be recorded and reported to the Responsible Health Physicist. 4.9 Annual Limits on Intake and Derived Air Concentrations The Employee Safety Department will approve values for Annual Limits on Intake (ALIs) and Derived Air Concentrations (DACs) as required [Appendix C, Annual Limits on Intake and Derived Air Concentrations]. ALIs are guidelines for limiting the intake of radioactive materials to prevent internal uptakes that could result in doses in excess of the annual dose limits. DACs are derived from ALIs to provide guidelines for contamination and exposure control and the use of protective equipment. It is the intension of Bruce Power to use the ICRP recommendations given in ICRP 68. These recommendations will be used in Section 6.5.5.2 and Appendix C.

14 of 80 BP--00002 5.0 FACILITY DESIGN AND OPERATION In selecting a site for a facility, the implications for public and occupational health and safety shall be thoroughly considered. In the design of facilities, good design practices shall be followed with the specific intention of managing the impact of facility operation and decommissioning on the health and safety of members of the public and the workforce. Plans shall exist for managing radioactive materials which arise from large non-routine operations such as the decontamination of a major reactor system. 5.1 Zones-Establishment, Monitoring, and Movement An important means of radiation protection of personnel and contamination control is the division of a facility into zones. These are Zone 1, a clean area which may be considered as the equivalent of a normal public access area and radiological zones (of higher number e.g., Zones 2, 3, etc.) in which the potential for radioactive contamination and/or radiation exposure exists. 5.1.1 Zoning Plans and Procedures 5.1.1.1 Approved zoning plans and operating procedures shall be established for facilities and for outside areas which adjoin them. 5.1.2 Boundaries and Traffic 5.1.2.1 Interzonal contamination monitors shall be set to alarm at levels as far below the established contamination limits for body surfaces [4.8] as feasible. 5.1.2.2 The number of interzonal boundaries shall be kept to a minimum. 5.1.2.3 The movement of personnel shall be controlled by establishing traffic routes and exit-entry points between zones and from the facility. 5.1.2.4 Interzonal boundaries shall be clearly marked. 5.1.2.5 All persons moving from a zone of higher contamination probability to a zone of lower contamination probability should monitor themselves for radioactive contamination at the entry point [4.8]. 5.1.2.6 Contaminated material which is moved within the facility should either be suitably contained to prevent the spread of contamination, or should be decontaminated to remove loose activity. 5.1.2.7 Persons who alarm the contamination monitors shall conduct themselves so that the spread of contamination is minimized and shall comply with approved procedures for subsequent movement and decontamination [5.1.2.11, 5.5, 6.8].

BP--00002 15 of 80 5.1.2.8 Persons wearing protective clothing or equipment shall not enter Zone 1, except for demonstration purposes, provided all other constraints are met [7.4.4], or in emergencies. 5.1.2.9 All persons entering Zone 1 from other zones shall be monitored for contamination on exposed body surfaces and personal clothing, and shall not proceed if they alarm the monitor. 5.1.2.10 Material entering Zone 1 from other zones shall be monitored for contamination and shall not be taken into Zone 1 if it exceeds the established contamination limits [4.8]. 5.1.2.11 If, after carrying out approved decontamination procedures [6.6.1], a person s skin still alarms the contamination monitor, he or she shall be permitted to enter Zone 1 under the appropriate one of the following conditions. 5.1.3 Zone 1 1. If the beta-gamma contamination remaining is less than five times the established contamination limit for body surfaces [4.8.3] and there is no loose contamination, then permission to proceed can be given by persons designated for this purpose by the Responsible Health Physicist. The Responsible Health Physicist should be notified of the event within a reasonable period of time. 2. If after decontamination, the remaining skin contamination level is greater than five times the established contamination limit for body surfaces [4.8.3.], then permission to proceed shall be sought from the Responsible Health Physicist promptly and directly [9.2.2 (6)]. The Responsible Health Physicist or his or her delegate should ensure that the contaminated person s concerns are addressed. Zone 1 is a clean area which is not a radiological zone and may be considered the equivalent of a normal public access area. 5.1.3.1 Zone 1 shall not contain radioactive sources other than those found in normal industrial establishments, or those specifically approved for use in applications such as training and demonstrations. 5.1.3.2 Fixed contamination levels in Zone 1 shall not exceed the established contamination limit for Zone 1 surfaces [4.8.2]. No detectable loose contamination shall be permitted in Zone 1 [4.8.2]. 5.1.3.3 Zone 1 shall have a very low probability of cross-contamination from adjacent areas and shall have a low general radiation background, not exceeding the established limit [4.7.1.1]. 5.1.4 Zone 2 Zone 2 is a radiological zone that is normally free of contamination but is subject to infrequent cross-contamination due to the movement of personnel and equipment from contaminated areas.

16 of 80 BP--00002 5.1.4.1 Zone 2 is normally free of radioactive sources other than those found in normal industrial establishments, or those specifically approved. 5.1.4.2 Zone 2 shall have a low general radiation background. 5.1.4.3 All materials being moved from Zone 3 to Zone 2 should be monitored. 5.1.4.4 Where appropriate, local containment systems shall be used when radioactive systems in Zone 2 are opened or leaking. 5.1.4.5 If local containment systems are not used, a rubber area shall be established when radioactive systems in Zone 2 are opened or leaking, and it shall be removed promptly when work on the system is complete. 5.1.5 Zone 3 Zone 3 is a radiological zone which contains systems and equipment which may be sources of contamination. 5.1.5.1 Areas of Zone 3 which are normally frequented should have no detectable loose contamination [4.8.3]. When loose contamination is detected, decontamination should be considered in light of factors such as occupancy levels, degree of hazard and probability of spread. Decontamination should be carried out at the discretion of either line management or the Responsible Health Physicist or delegate. 5.1.6 Unzoned Area An unzoned area is an outdoor location, building or structure within the protected area that has not been otherwise explicitly zoned. 5.1.6.1 An unzoned area shall be free of radioactive materials except for: 1. Naturally occurring radioactive material; 2. Consumer products containing radioactive isotopes; 3. Licenced radioisotopes; 4. Radioactive materials packaged and labeled in accordance with radioactive shipment requirements; and 5. Radioactive materials in containers approved by the Responsible Health Physicist and in storage areas approved by the Responsible Health Physicist, or in transit to or from the approved storage areas. 5.1.6.2 Fixed contamination levels in an unzoned area shall not exceed the established contamination limit for Zone 1 surfaces [4.8.2]. No detectable loose contamination shall be permitted in an unzoned area [4.8.3].

BP--00002 17 of 80 5.2 Hazard Monitoring Systems 5.2.1 Comprehensive public and occupational hazard identification and assessment shall be conducted throughout the life cycle of a facility. This shall include but should not be limited to: Analysis of the potential for creation of hazards; monitoring of the production and movement of radioactive materials for control purposes; and assessment of the nature, extent and impact of hazards. 5.2.2 Monitoring of hazards shall be scaled to the probability and consequences of exposures. 5.2.3 Within a facility, provision shall be made for continuous monitoring of hazard levels where there is a probability of sudden unexpected increases in radiological hazards that may result in a significant acute dose (25 to 50 rem) to an individual. These provisions may include permanently installed monitoring systems or the equivalent. 5.2.4 For air monitoring, if the instruments used do not accurately measure the concentration of radioactive material but merely give an indication of a change, then instruments which accurately determine the air contamination concentration shall be used in conjunction with the continuous monitor. 5.2.5 Area Alarming Gamma Monitoring Systems 5.2.5.1 Area alarming gamma monitoring systems which comply with specifications approved by the Employee Safety Department shall be provided in areas where variable high gamma radiation fields may occur. To ensure that these systems continue to meet specifications, they shall be routinely tested and maintained except when inaccessible. 5.2.5.2 The system shall be operative immediately upon someone entering the area. 5.2.5.3 The alarm shall be effective (clearly audible and/or visible) throughout the monitored area. 5.2.5.4 The system shall warn against sudden unexpected increases in radiation fields and radionuclide concentration, to prevent a significant acute dose (25 to 50 rem) to an individual. 5.2.5.5 When entry to a monitored area is necessary and the system is out of service, other approved protective measures shall be taken [5.4.5]. 5.2.6 Surveys 5.2.6.1 Radiological measurements and surveys shall be carried out to ensure the safety of personnel engaged in work, other workers, and members of the public. 5.2.6.2 Surveys which can be justified in terms of exposure control shall be carried out whenever abnormal or suspected abnormal radiological conditions exist, and when it is known or suspected that conditions have changed. 5.2.6.3 Unusual conditions found on surveys shall be communicated to affected personnel and shall be documented in facility records [9.6.1, Appendix A-2.3 (7)].

18 of 80 BP--00002 5.2.6.4 Routine surveys shall be carried out in all zones of a facility at an approved frequency sufficient to prevent the prolonged presence of an unknown condition in accessible, normally frequented areas [6.8.4, 9.6.2, Appendix A-1.3 (7), 2.3 (1)]. 5.2.7 Emission Monitoring [4.6, 9.3, Appendix A-1.3 (8), (9)] 5.2.7.1 Emission monitoring programs which meet standards approved by the Environment Department, Technical Support, or demonstrate compliance with Radioisotope licences shall be established. 5.2.7.2 The monitoring program for measuring radioactive emissions in facility effluent shall be sufficient to demonstrate the extent to which limits and targets are being achieved. 5.2.7.3 Sampling and analysis of liquid and gaseous effluents for radioactivity shall be conducted at an approved frequency sufficient to establish the presence of radionuclides and their abundance. 5.2.8 Environmental Monitoring [9.4, Appendix A-1.3 (10)] Facilities shall have an environmental monitoring program which meets radiation protection standards approved by the Environment Department, Technical Support, focussed on and scaled to, probable emissions and environmental pathways leading to human exposure. 5.3 Posting of Hazard Warnings [7.1.8] At each facility, a consistent system for the posting of warnings is required so that personnel will be aware of the nature of the radiation hazards throughout the working environment. The minimum standard for such a system is given in this section of the RPRs. 5.3.1 Areas that routinely have radiation fields shall be clearly identified with permanent warning signs. 5.3.2 Posted warnings shall be kept current with the most recent survey data. 5.3.3 Prescribed Symbol Radiation Warning 5.3.3.1 The prescribed radiation warning symbol is that shown in Figure 1. It is specified in CSA Standard Z69-1960.

BP--00002 19 of 80 5.3.3.2 The trefoil shall be black or magenta and the background lemon yellow as shown in Figure 1. Figure 1. Prescribed Symbol - Radiation Warning 5.3.3.3 The size of the trefoil shall be as large as permitted by the size of the container, device, label or sign on which it appears, providing that the proportions shown in Figure 1 are maintained. In any case, the symbol shall be identifiable from a safe distance. 5.3.3.4 Where possible, the symbol shall be oriented with one blade pointed downward and centred on the vertical axis. 5.3.3.5 No wording shall be superimposed on the symbol. 5.3.3.6 Appropriate wording should be used in association with the radiation symbol to indicate the nature of the source of radiation, measured hazard levels, type of radiation, limits of occupancy and similar precautionary information. 5.3.4 Hazard Warnings External Radiation Fields 5.3.4.1 Each room or clearly defined area where there are radiation fields greater than 2.5 mrem/h shall be posted with a conspicuous sign bearing: 1. The prescribed radiation warning symbol; 2. Words such as RADIATION - DANGER; 3. An indication of the highest field levels in accessible locations within the room or area. The posting may be done locally where only a few locations exceed 2.5 mrem/h. It may be done either centrally or at the boundary or entrances if there are several places within where the field level exceeds 2.5 mrem/h.

20 of 80 BP--00002 5.3.4.2 In some areas of the facility pieces of equipment may give rise to local gamma fields which are much higher than the general gamma background. These local fields shall be delineated and posted with a conspicuous sign bearing: 1. The prescribed radiation warning symbol; 2. Words such as RADIATION - DANGER; 3. The local field level. 5.3.5 Hazard Warnings Surface Contamination 5.3.5.1 The entrance to areas in which protective footwear is necessary because of the risk of contamination being spread shall be posted with a conspicuous sign bearing words such as RUBBER AREA. 5.3.5.2 Equipment, fume hoods or other similar working areas which have loose surface contamination present shall be posted with signs bearing: 1. The prescribed radiation warning symbol; 2. Words such as CAUTION - RADIOACTIVE CONTAMINATION. 5.3.6 Hazard Warnings Airborne Contamination The entrance to rooms or areas where the airborne activity is such that respiratory protection is required [6.5.5] shall be posted with a conspicuous sign bearing: 1. The prescribed radiation warning symbol; 2. Words such as RESPIRATOR AREA or CAUTION - AIRBORNE ACTIVITY; 3. The minimum respiratory protection required; 4. The hazard level e.g., 10 DAC H-3 [Appendix C]. 5.4 Access Control Hazardous radiation fields may exist as a result of normal reactor operation, irradiated fuel transfer, equipment operation, or exposure of calibration sources. In such situations, access control is required. 5.4.1 Access control systems, which meet standards approved by the Radiation Protection Department, and which are operated by procedures approved by the Responsible Health Physicist, shall be established [6.4.1]. 5.4.2 When people are in or are about to enter an access-controlled area, significant increases in radiation hazard levels shall be prevented. 5.4.3 Accidental access to access-controlled areas shall be prevented as long as hazardous radiation fields exist. 5.4.4 It shall be possible to exit an access-controlled area under any circumstances.

BP--00002 21 of 80 5.4.5 In situations where entry to an access-controlled area is necessary and the normal barriers to the introduction of hazardous radiation fields are out of service, other approved protective measures shall be taken [5.2.5.5]. 5.5 Contamination Control Plant Aspects [6.8] 5.5.1 The movement and accumulation within facilities of all forms of contamination shall be controlled. 5.5.2 Suitable facilities shall be provided to enable adequate personal hygiene. 5.5.3 Approved areas shall be designated for the consumption of food and drinks and for smoking. 5.5.4 Control of Surface Contamination Precautions shall be taken to control the spread of surface contamination and may include the establishment of rubber areas [5.3.5.1], and the use of monitoring devices [6.4] and protective equipment [6.5]. 5.5.5 Control of Airborne Contamination 5.5.5.1 High efficiency filtration systems capable of retaining radioiodines and radioactive particulates shall be provided where there is reasonable probability that quantities of radioactivity escaping to the facility gaseous effluent may approach design and operating targets. 5.5.5.2 Ventilation systems shall be designed and operated to minimize: 1. The accumulation of airborne radioactive contamination in areas routinely occupied by personnel; 2. The spread of airborne radioactive contamination from any zone to another of lower number [5.1]. 5.6 Radioactive Material Storage Facilities 5.6.1 The Responsible Health Physicist shall be notified of any planned extensions or additions to temporary and permanent radioactive material storage facilities at any existing nuclear facility or other site. 5.6.2 The management of occupational dose during material handling shall be a major factor in facility design. At material storage facilities, this handling occurs during initial placement, as well as during transfers between temporary, interim and long term storage, and disposal. 5.6.3 The type of storage facilities and storage volume available at any time shall be capable of storing wastes arising from one year s normal operation of any of the major facilities which utilize that waste management site.

22 of 80 BP--00002 6.0 HAZARD AND EXPOSURE MANAGEMENT The exposure of employees and members of the public to the hazards of ionizing radiation shall be managed through the planning of work, the consistent application of safe work practices, and the active participation of all involved personnel. In limiting dose received, the preferred method is to remove the source. When this is not possible, control of exposure shall be accomplished through controlling the circumstances of the work. This shall include but not be limited to the control of duration of exposure, distance from the source, and the use of shielding and other protective equipment. No one shall enter a radiological zone, do or supervise radioactive work, or be made responsible for the radiation protection of other persons unless they are qualified [Appendix B] to do so. 6.1 Planning Radioactive Work 6.1.1 Planning Process 6.1.1.1 Planning, including scheduling, of work shall take into account personnel, hardware, procedures, supervision and the physical environment aspects of the job. The planning process shall include the anticipation and evaluation of radiation hazards and the selection of appropriate protective measures and dosimetry. 6.1.1.2 The degree of formalization of the planning process shall be proportional to the potential for exposure. 6.1.2 Work Approvals The level of authority from whom approval of plans must be sought shall depend on level of radiological hazard. 6.1.2.1 Plans for work where the whole-body dose rate from all sources exceeds 300 mrem/h shall be approved in writing by the authorized duty shift manager at nuclear generating stations. Alternate supervisory staff may have the responsibility at facilities other than nuclear generating stations. 6.1.2.2 Plans for work where the whole-body dose rate from all sources exceeds 3 rem/h shall be approved by the Responsible Health Physicist. 6.1.3 Radiation Exposure Permits Under certain defined circumstances (see Sections 6.1.3.1 and 6.1.3.2), indirect protection of work involving radiological hazards can be exercised by a qualified person through the use of written radiation exposure permits. 6.1.3.1 Indirect protection can only be used in situations where radiological conditions are considered to be static and likely to remain so.

BP--00002 23 of 80 6.1.3.2 In the event that radiological conditions change in the direction of increased hazard levels from those specified in the applicable radiation exposure permit, work shall cease and the involved workers shall leave the area. 6.1.3.3 The form and usage of all types of permits associated with radiation protection, shall be detailed in facility radiation protection procedures. 6.1.3.4 Radiation exposure permits, used with indirection protection, are issued by qualified personnel to define the radiation protection requirements for a specific job. The issuer of a permit must be fully satisfied that the permit holder understands his or her own roles and responsibilities. In turn, the holder of the radiation exposure permit must be fully satisfied that the workers under his or her protection understand the restrictions placed on their movement at the work area(s), and the correct use of their protective equipment. 6.1.3.5 Permits shall only be issued to and held by Green [Appendix B] qualified persons. 6.1.3.6 Persons holding Orange [Appendix B] qualification in radiation protection, who are required to do radioactive work, shall work under a radiation exposure permit unless a Green qualified person is made responsible for their radiation protection. 6.1.3.7 Red [Appendix B] qualified persons may not work under permits and a Green qualified person shall be responsible for their radiation protection while they are doing radioactive work. 6.1.3.8 The permit issuer, at his or her discretion, may authorize one change of permit holder. Notwithstanding this, permits shall be in effect for no more than one change of holder. 6.1.3.9 Work shall not begin until the permit has been validated by the signatures of the permit issuer and the permit holder. 6.1.3.10 Specific provision shall be made on the permit for the following items. 1. Location of work; 2. Radiation hazards; 3. Time limits; 4. Protective clothing; 5. Special instructions; 6. Requirements for special surveys, etc.; 7. Special dose limits; 8. Name and signature of permit issuer(s); 9. Name and signature of permit holder(s); 10. Name of person(s) working under the permit. 6.2 Work Execution 6.2.1 All individuals shall carry out their assigned radiation protection tasks conscientiously and make every effort to minimize their own radiation doses and the doses of others. 6.2.2 All individuals shall use radiation protection equipment and devices properly and shall ensure that such equipment is in good working order or is removed from service.

24 of 80 BP--00002 6.2.3 Direct reading personal monitoring devices should be used to estimate the actual dose received. When circumstances warrant the use of these devices, they shall be checked frequently enough to ensure that the person s dose is within the expected range [6.3.5.2]. 6.3 Dosimetry Program The objective of a dosimetry program is to assess all doses of ionizing radiation received by workers and visitors at Bruce Power facilities as a result of the presence of radioactive sources or the operation of radiation devices. The functions of a dosimetry program are: 1. To assign and record all significant radiation doses received by an individual over a known period of time, whether these result from exposures of the whole body or to only a limited region; 2. To retain these records in useable form for comparison with the appropriate limits and targets; 3. To facilitate improvements in dose reduction practices. 6.3.1 All facilities shall have a dosimetry program approved by the Radiation Protection Manager. This shall include procedures approved by the Responsible Health Physicist that shall ensure appropriate dosimetry is provided for all NEWs and other persons who are likely to receive radiation exposures. [9.2.4, Appendix A - 1.3 (3)] 6.3.2 The Responsible Health Physicist or delegate shall interpret and assign dose. 6.3.3 The Responsible Health Physicist and the employee shall be promptly notified when the dose received by the employee has exceeded any of the dose limits of the RPRs. [8.1.1.1, 8.1.2.1, 8.1.3.1, 8.1.4.1, 8.1.5.1] 6.3.4 Provision shall be made by the Radiation Protection Department for the prompt evaluation of the dose received by a person from a known or suspected high exposure to ionizing radiation. The persons concerned shall not do further radioactive work until the dose evaluation is complete [3.4.4]. When a direct-reading dosimeter is "off scale" the wearer shall be considered to have received a high exposure until his or her dose is evaluated. 6.3.5 External Dosimetry 6.3.5.1 In order to meet the objective and goals of the dosimetry program [6.3], all persons entering radiological zones [5.1] shall be provided with and shall use dosimetry devices approved by the Radiation Protection Department. All events in which individuals fail to wear the dosimeter with which they have been provided, shall be reported to the Responsible Health Physicist. Such events shall be considered to be a contravention of the RPRs if: 1. The individuals are performing radioactive work; 2. They have entered Zone 3; or