Title: | Conduct of Radiological Work | Publication date: | 10/30/2020 | Effective date: | 10/30/2020 |
POLICYA. PurposeThis policy describes the control standards for the conduct of radiological work at the Lawrence Berkeley National Laboratory (Berkeley Lab). B. Persons AffectedAll 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. ExceptionsNot applicable D. Policy StatementBerkeley 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, offsite radiological work)
- 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 WorkFor 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 to control the use of radioactive materials and radiation-generating devices. D.2 Work PreparationThe written authorization is an administrative mechanism used to establish radiological controls, and includes a work scope, specific precautions, limitations, and ALARA practices. General authorizations are used for repetitive work in areas with known and stable radiological conditions. Job-specific authorizations remain in effect only for the duration of the jobs. Activity Leads and their line management are ultimately responsible for ensuring adequate work planning and control. D.3 Entry and Exit ProvisionsPosted 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- 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.
- Berkeley Lab personnel have the authority and responsibility to stop radiological work activities if radiological controls are inadequate or are not being implemented.
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 issues noted during routine oversight activities. D.6 Special ApplicationsWork 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 written 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. All off-site radiological work must be reviewed by RPG. 10 CFR 835 establishes that all radiological work performed by Berkeley Lab must be performed in accordance with the DOE approved LBNL Radiation Protection Program (RPP) unless the work meets specific exclusions (see 835.1(b)). Furthermore, all occupational radiation dose, including dose received during off-site radiological work, must be considered when determining compliance with the occupational dose limits specified in 835.202, 835.206, and 835.207 (see 835.1(c)). To ensure off-site radiological work complies with the RPP or meets one of the 835.1 exclusions, RPG utilizes an off-site radiological work screening process. The process consists of an Off-Site Screening Form that can be obtained by contacting the assigned HP for your RPG Zone, as determined in the Who to Call section of the RPG website. In addition, all off-site radiological work must be authorized through a work authorization (e.g., WPC activity with the off-site radiological work hazard) approved by RPG. D.7 Accidents and Emergencies Involving Radioactive MaterialDuring an emergency, the following order of priorities shall be followed: - Life safety/employee health
- Protection of the environment
- 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 ResponsibilitiesRole | Responsibility | Radiation Protection Group (RPG) | - Evaluates radiological work scope hazards and develops controls for work authorizations
- Conducts critiques and post-job reviews, as appropriate
- Responds to accidents and emergencies involving radioactive materials
| Radiological Control Manager (RCM) | - Approves radiological work
- 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
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F. Definitions/AcronymsTerm | 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 achievable, 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 | Work Authorization | A written authorization for use of radiation-producing machines and/or radioactive materials. Precautions, limits of use, and requirements are specified. |
G. Recordkeeping RequirementsThe 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 DocumentsDocument number | Title | Type | 07.08.001.001 | Radiation Protection Program | Program |
| Radiological Control Manual | Manual | 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 | Unrestricted Release and Clearance of Materials, Equipment and Areas | 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 731 | RGD Interlock Program | Program |
David Kestell Radiological Control Manager Environment, Health and Safety Division Environment, Waste, and Radiation Protection Department [email protected] J. Revision HistoryDate | Revision | By whom | Revision Description | Section(s) affected | Change Type | 11/4/2013 | 0 | Q. Le | Re-write for wiki | all | Major | 10/30/2020 | 1 | K. Heinzelman | Added "off-site radiological work" to the Special Applications section; replaced references to RWAs with the generic terms "work authorization" and "written authorization"; updated Implementing Documents section; additional minor changes for consistency with RPG requirements. | D, E, F, H | Minor |
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