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Conduct of Radiological Work

    Title:

    Conduct of Radiological Work

    Publication date:

    11/4/2013

    Effective date:

    11/4/2013

    BRIEF

    Policy Summary

    Berkeley Lab applies controls to ensure properly qualified and authorized individuals are permitted to enter Radiological Areas and perform work safely. These controls include:

    • Planning radiological work
    • Work preparation
    • Entry and exit provisions
    • Radiological work controls
    • Evaluation and performance measurement
    • Special operations (accelerators)
    • Accidents and emergencies

    Berkeley Lab's Radiation Protection Group (RPG) has responsibility for establishing programs and procedures that address these requirements. All personnel at the Laboratory have responsibility for complying with RPG's programs.

    Who Should Read This Policy

    All persons who plan to work in or near an area controlled for radiological protection or who plan to work with or support work with radiation-generating devices or radiological materials.

    To Read the Full Policy, Go To:

    The POLICY tab on this wiki page

    To Read the ES&H Program Details, Go To:

    http://www.lbl.gov/ehs/pub3000/CH21.html

    Contact Information

    David Kestell
    Radiological Control Manager
    Environment/Health/Safety Division
    Environment, Waste, and Radiation Protection Department
    djkestell@lbl.gov

    Title:

    Conduct of Radiological Work

    Publication date:

    11/4/2013

    Effective date:

    11/4/2013

    POLICY

    A. Purpose

    This policy describes the control standards for the conduct of radiological work at the Lawrence Berkeley National Laboratory (Berkeley Lab).

    B. Persons Affected

    All persons who plan to work in or near an area controlled for radiological protection or who plan to work with or support work with radiation-generating devices or radiological materials

    C. Exceptions

    Not applicable

    D. Policy Statement

    Berkeley Lab applies work controls to ensure properly qualified and authorized individuals are permitted to enter Radiological Areas and perform work safely. These controls include:

    • Planning radiological work
    • Work preparation
    • Entry and exit provisions
    • Radiological work controls
    • Evaluation and performance measurement
    • Special operations (accelerators)
    • Accidents and emergencies

    Berkeley Lab's Radiation Protection Group (RPG) has responsibility for establishing programs and procedures that address these requirements. All personnel at the Laboratory have responsibility for complying with RPG's programs.

    D.1 Planning Radiological Work

    For areas of continuous occupancy (potentially 2,000 hours per year), the design objective is to maintain the average exposure level as low as reasonably achievable (ALARA) and below 0.5 millirem per hour. If occupancy is not continuous, the design objective is to maintain doses ALARA and below 20% of the annual occupational dose limits, currently 5 rem for the whole body, 15 rem for the eyes, and 50 rem for the skin and extremities. Facility and equipment design features are utilized wherever practical. When permanently installed design features are inadequate, engineering controls (temporary shielding, containment devices, and filtered ventilation systems) must be used, as appropriate, to control individual exposures. When physical design features, including engineering controls, are impractical or inadequate, they are augmented by administrative controls, such as access restriction and the use of specific work practices. Berkeley Lab requires an approved written authorization — a Radiological Work Authorization (RWA) or an X-Ray Authorization (XA) — to control the use of radioactive materials and radiation-generating devices.

    D.2 Work Preparation

    The RWA is an administrative mechanism used to establish radiological controls, and includes a work scope, specific precautions, limitations, and ALARA practices. General RWAs are used for repetitive work in areas with known and stable radiological conditions. Job-specific RWAs remain in effect only for the duration of the jobs. Principal investigators (PIs) are ultimately responsible for ensuring adequate work planning and control.

    D.3 Entry and Exit Provisions

    Posted Radiologically Controlled Areas are required to have approved entry and exit control provisions. These provisions may include:

    • Prox Key control
    • Training commensurate with the hazards and required control
    • Controls implemented as necessary to prevent the spread of removable contamination outside of Radiological Areas under normal operating conditions
    • Individual monitoring, as appropriate, for the presence of surface contamination when exiting Contamination Areas, High Contamination Areas, and Airborne Radioactivity Areas and
    • Other controls deemed appropriate, such as dosimetry, pre-job briefing, survey and proper doffing procedures, and Radiological Control Technician (RCT) coverage

    D.4 Radiological Work Controls

    1. Radiological work controls are conducted as specified in the written authorization. RPG and work supervisors periodically review prescribed radiological controls for adequacy and implementation as part of their normal work reviews.
    2. Berkeley Lab personnel have the authority and responsibility to stop radiological work activities if radiological controls are inadequate or are not being implemented.

    D.5 Evaluation and Performance

    During the conduct of radiological work and handling radioactive materials, abnormal events may occur that could indicate weaknesses or areas of programmatic breakdown of radiological controls. When this occurs, RPG conducts a critique or post-job review with those involved to establish a record of facts. Corrective actions and Lessons Learned are then developed and approved by the Radiological Control Manager (RCM) or designee. Applicable Berkeley Lab management must be informed by the RCM of all performance evaluations during routine oversight activities.

    D.6 Special Applications

    Work with accelerators requires special considerations.

    Special considerations associated with accelerator facilities include the presence of extremely high dose rates, the generation of activation products, and the detection and monitoring difficulties associated with pulsed or high-energy radiation. The radiological safety of accelerators is ensured through appropriate, formal RPG work authorization. Additionally, facilities that meet the definition of accelerators in DOE Order 420.2C, Safety of Accelerator Facilities, must meet all the requirements of this Order.

    Experimenters and operations personnel must consult with the RPG when planning new facilities or accelerator operations. Failure to consult with the RPG in the planning stage may result in delays.

    D.7 Accidents and Emergencies Involving Radioactive Material

    During an emergency, the following order of priorities shall be followed:

    1. Life safety/employee health
    2. Protection of the environment
    3. Property

    All employees must be familiar with their workplace emergency plan, know their evacuation route, and note the locations of emergency showers, eyewashes, and equipment.

    Supervisors must ensure that emergency shutdown procedures for hazardous operations are posted in a safe and conspicuous location; post and maintain a current emergency call list; conduct pre-work reviews, including emergency responses; and address emergency issues in planning and design processes.

    E. Roles and Responsibilities

    Role

    Responsibility

    Radiation Protection Group (RPG)

    • Develops and provides work authorizations (RWAs and XAs) as needed
    • Conducts critiques and post-job reviews, as appropriate
    • Responds to accidents and emergencies involving radioactive materials

    Radiological Control Manager (RCM)

    • Approves corrective actions and Lessons Learned

    Supervisors, leads, managers, principal investigators

    • Ensure that emergency shutdown procedures for hazardous operations are posted in a safe and conspicuous location
    • Post and maintain a current emergency call list
    • Conduct pre-work reviews, including emergency responses
    • Address emergency issues in planning and design processes
    • Are ultimately responsible for ensuring adequate work planning and control

    Workers

    • Exercise Stop Work authority if radiological controls are inadequate or are not being implemented
    • Must be familiar with their workplace emergency plan
    • Know their evacuation route
    • Note the locations of emergency showers, eyewashes, and equipment
    • Comply with RPG programs and work authorizations

    F. Definitions/Acronyms

    Term

    Definition

    Airborne Radioactivity Area

    Any area that is accessible to individuals and where (1) the concentration of airborne radioactivity is above natural background levels and exceeds or is likely to exceed the derived air concentration (DAC) values listed in Appendix A or Appendix C of 10 CFR 835, or where (2) an individual present in the area without respiratory protection could receive an intake exceeding 12 DAC hours in a week.

    As low as reasonably achievable (ALARA)

    An approach to radiological management and control that aims to keep exposures (individual and collective) of the workforce and of the general public at levels as low as reasonably achievabl, taking into account social, technical, economic, practical, and public policy considerations.

    DOE

    Department of Energy

    Radiologically Controlled Area (RCA)

    Any area to which access is managed to protect individuals from exposure to radiation or radioactive materials. Individuals who enter Controlled Areas without entering Radiological Areas are not expected to receive a total effective dose equivalent of more than 0.1 rem (0.001 sievert) in a year.

    Radiological Control Technician (RCT)

    A qualified individual, per RPG procedures, who performs radiological surveys to ensure compliance with applicable Berkeley Lab policies and procedures.

    RCM

    Radiological Control Manager

    RPG

    Radiation Protection Group

    Radiological Work Authorization (RWA)

    An authorization for use of radiation-producing machines and/or radioactive materials. Precautions, limits of use, and requirements are specified.

    XA

    X-Ray Authorization

    G. Recordkeeping Requirements

    The care, maintenance, and disposition of RPG records will be done in accordance with Berkeley Lab records management policies and procedures, as listed in the Requirements and Policies Manual (PUB-201).

    H. Implementing Documents

    Document number

    Title

    Type

    07.08.001.001

    Radiation Protection Program

    Program

    EHS 700

    Emergency Response to Radiological Incidents

    Procedure

    EHS 704

    Establishing the Need for Personnel and Area Radiation Monitoring

    Procedure

    EHS 706

    Radiological Protective Clothing Requirements for the Radiation Protection Group

    Procedure

    EHS 707

    Radiological Work Authorization Program

    Procedure

    EHS 708

    Survey of Potentially Contaminated Materials and Equipment for Unrestricted Release

    Procedure

    EHS 709

    Radiation Protection Posting, Labeling, and Access Control

    Procedure

    EHS 710

    Radiological Survey Program

    Procedure

    EHS 718.1

    Radiological Hazards Review, Materials

    Procedure

    EHS 718.2

    Radiological Hazards Reviews for Radiation Generating Devices

    Procedure

    EHS 718.3

    Radiation Shielding Design Optimization

    Procedure

    EHS 730

    Radiation Generating Device Program

    Program

    EHS 731

    RGD Interlock Program

    Program

    EHS 735

    X-ray Machine Authorization Program

    Procedure

    EHS 790

    Radiation Safety Training Program

    Program

    I. Contact Information

    David Kestell
    Radiological Control Manager
    Environment/Health/Safety Division
    Environment, Waste, and Radiation Protection Department
    djkestell@lbl.gov

    J. Revision History

    Date

    Revision

    By whom

    Revision Description

    Section(s) affected

    Change Type

    11/4/2013

    0

    Q. Le

    Re-write for wiki

    all

    Major

    DOCUMENT INFORMATION

    Title:

    Conduct of Radiological Work

    Document number

    07.08.003.000

    Revision number

    0

    Publication date:

    11/4/2013

    Effective date:

    11/4/2013

    Next review date:

    11/4/2016

    Policy Area:

    Radiation Protection

    RPM Section (home)

    ESH

    RPM Section (cross-reference)

    none

    Functional Division

    EHS

    Prior reference information (optional)

     

    Source Requirements Documents

    • DOE Order 420.2C, Safety of Accelerator Facilities
    • 10 CFR 830, Nuclear Safety
    • 10 CFR 835, Occupational Radiation Protection

    Related Berkeley Lab Policies

    07.08.001.000 Radiological Control – Overview
    07.08.002.000 Radiological Control Standards
    07.08.004.000 Radioactive Materials
    07.08.005.000 Radiological Health Support Operations
    07.08.006.000 Radiological Training
    01.02.004.000 Continuity of Operations

    Implementing Documents

    Document number

    Title

    Type

    07.08.001.001

    Radiation Protection Program

    Program

    EHS 700

    Emergency Response to Radiological Incidents

    Procedure

    EHS 704

    Establishing the Need for Personnel and Area Radiation Monitoring

    Procedure

    EHS 706

    Radiological Protective Clothing Requirements for the Radiation Protection Group

    Procedure

    EHS 707

    Radiological Work Authorization Program

    Procedure

    EHS 708

    Survey of Potentially Contaminated Materials and Equipment for Unrestricted Release

    Procedure

    EHS 709

    Radiation Protection Posting, Labeling, and Access Control

    Procedure

    EHS 710

    Radiological Survey Program

    Procedure

    EHS 718.1

    Radiological Hazards Review, Materials

    Procedure

    EHS 718.2

    Radiological Hazards Reviews for Radiation Generating Devices

    Procedure

    EHS 718.3

    Radiation Shielding Design Optimization

    Procedure

    EHS 730

    Radiation Generating Device Program

    Program

    EHS 731

    RGD Interlock Program

    Program

    EHS 735

    X-ray Machine Authorization Program

    Procedure

    EHS 790

    Radiation Safety Training Program

    Program

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