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 and written authorization
• 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 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 to control the use of radioactive materials and radiation-generating devices.

D.2 Work Preparation and written authorization

Work preparation is documented in a written authorization that 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 Provisions

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

• Physical access controls (e.g. locks, interlocks, barriers, card-key access)l
• 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.

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 issues noted during routine oversight activities.

D.6 Special Applications

Work with accelerators requires special considerations. Special considerations associated with accelerator facilities may 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 420.2D, Safety of Accelerators, must meet all the requirements of this Order. See the Accelerator Safety Policy for more information.

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 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

F. Definitions/Acronyms

G. Recordkeeping Requirements

The care, maintenance, and disposition of RPG records will be done in accordance with Berkeley Lab records management policies and procedures.

H. Implementing Documents

I. Contact Information

David Kestell
Radiological Control Manager
Environment, Health and Safety Division
Environment, Waste, and Radiation Protection Department
[email protected]

J. Revision History

DOCUMENT INFORMATION

Source Requirements Documents

• DOE Order 420.2D, Safety of Accelerators
• 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
07.08.007.000 Accelerator Safety 
01.02.004.000 Continuity of Operations