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It is Lawrence Berkeley National Laboratory (LBNL or Berkeley Lab) policy that all types of radiological work activities be conducted safely and in accordance with applicable regulations and U.S. Department of Energy (DOE) requirements. This is achieved by adherence to Berkeley Lab policies set forth in this PUB-3000 chapter and the related programs and procedures implemented by the Radiation Protection Group (RPG), under the direction and management of the Radiological Control Manager (RCM). The RPG communicates to line management the radiological work requirements applicable to individual facilities and projects through written work authorizations, training, and support service programs described in this PUB-3000 chapter.
Line managers are accountable for implementation and compliance with these radiation safety requirements as they apply to their facilities and work. RPG personnel provide support by performing appropriate hazard evaluations, developing applicable radiation safety authorization documents, and providing all necessary field support services. These services include worker training, hazard evaluation, surveys and radiation monitoring, dosimetry, bioassay, instrumentation, and oversight of work activities. For further information and guidance, line managers and workers should consult this PUB-3000 chapter or contact the RPG at http://ehswprod.lbl.gov/rpg/who_to_call.shtml.
The DOE Rule on Occupational Radiation Protection (Title 10, Part 835 of the Code of Federal Regulations; also referred to as 10 CFR 835 or herein as “the Rule”) provides the basis for the LBNL Radiation Protection Program (RPP). The Rule requires LBNL to have a formally approved document, the LBNL RPP, which describes LBNL’s implementation methodology. LBNL maintains only one DOE-approved RPP. The requirements of the DOE-approved RPP have been integrated into this PUB-3000 chapter and the associated implementation program and procedural documents as “shall” or “must” statements. “Should” and “may” are used to convey best practices, not requirements. The following policies apply:
Other applicable elements of the following rules and standards are integrated into this chapter:
DOE Order 5400.5, Radiation Protection of the Public and the Environment, applies to the analysis of potentially contaminated materials and equipment for unrestricted release.
DOE Order 460.1B, Packaging and Transportation Safety, applies to the on-site transportation of radioactive materials.
DOE Order 420.2B, Safety of Accelerator Facilities, applies to the operation of accelerator facilities at LBNL.
DOE Notice 234.1, Reporting of Radioactive Sealed Sources, applies to the receipt, creation, reporting, and off-site shipment of high-activity radioactive sealed sources at LBNL.
DOE Manual 470.4-6, Nuclear Material Control and Accountability, applies to the control and accountability of nuclear materials at LBNL.
The U.S. Department of Transportation (DOT) Rule, 49 CFR Subtitle B, Other Regulations Relating to Transportation, Chapter I; and the International Air Transportation Association (IATA) Dangerous Goods Regulations apply to the receipt and shipment of radioactive materials at LBNL.
This chapter and the related programs and procedures implemented by the Radiation Protection Group (RPG) do not apply to:
The Radiation Safety Committee (RSC), which is appointed by and reports to the Laboratory Director, is responsible for advising LBNL management on all matters related to occupational and environmental radiation safety. The RSC reviews and recommends approval of radiation safety policies. More information on the RSC mission, membership, and functioning is available at http://ehswprod.lbl.gov/rpg/charter.shtml.
Radiological work may be stopped by a worker through line management, line supervision, or the RCM if radiological controls are inadequate or are not being implemented. Violations of radiation safety policy may result in restrictions from radiological work and/or disciplinary actions. Serious violations of the policy, which are knowingly and willfully committed, may result in civil penalties or criminal prosecution as determined by applicable federal agencies.
Part 830 of Title 10 in the Code of Federal Regulations (10 CFR 830, Nuclear Safety Management) requires LBNL to accurately and completely characterize each LBNL facility containing radioactive and/or fissionable materials. This Nuclear Safety Program is planned, conducted, and documented by LBNL in accordance with DOE Standard DOE-STD-1027-92 [Change Notice No. 1 (CN1)], Hazard Categorization and Accident Analysis Techniques for Compliance with DOE Order 5480.23, Nuclear Safety Analysis Reports.
LBNL facility inventories will be managed and monitored to ensure only radiological facilities occur [i.e., radiological inventories maintained below those defined in DOE-STD-1027-92 (CN1) for a Hazard Category 3 nonreactor nuclear facility]. These management and inventory controls are implemented by the RPG with management oversight by the RCM and institutional oversight by the Radiation Safety Committee and the Office of Contract Assurance.
The Rule, Section 101(c), requires that there be a formal documented program at LBNL that is designed to ensure that radiation exposures are maintained as low as reasonably achievable (ALARA). LBNL’s primary mechanisms for training personnel, monitoring the workplace, controlling work activities, and maintaining radiation exposures ALARA are implemented through the authorization system, worker awareness, and RPG's monitoring (of individuals and areas) and surveillance activities.
Oversight of the ALARA Program is provided through reviews by the RSC in conjunction with the RCM. The RSC and RCM meet periodically with the Laboratory Director to provide a summary of ALARA activities and reports for senior management.
The elements of the ALARA Program include the following:
Workers who use radioactive materials and radiation-producing devices have the most important role in reducing exposure, waste, and environmental effluents. For each job involving exposure to radiation or radioactive material, each worker is responsible for understanding the job requirements, the radiological hazards and control measures, and ALARA practices. Workers and their managers are responsible for being aware of and understanding the radiation hazards in the workplace. Each Radiological Work Authorization details ALARA criteria, limitations, and monitoring actions specific to the work tasks.
Each new facility or operation using radiation is subject to formal safety reviews prior to commencement of any radiation work. Design and control measures are specified in the authorization basis for each facility or in the work authorization for facility operations.
For new facilities, design features and administrative controls are selected to meet regulatory requirements and to keep radiation exposures to workers, the public, and the environment as low as reasonably achievable. The primary methods used are engineering controls such as containment, ventilation, and shielding.
ALARA work/experiment reviews by the RPG assess radiological impacts, determine optimum radiological controls, track the effectiveness of controls, and document lessons learned. ALARA work planning is commensurate with the relative risks associated with the activity. ALARA reviews are carried out through the work-authorization process prior to starting work. Thereafter, the work is periodically audited and monitored for continuing safe and compliant operations.
The RPG reviews personnel dosimetry reports compiled by the Dosimetry Office for all individuals receiving positive dosimetry readings. This review helps ensure that ALARA measures are effective, and allows any dose that appears not to be ALARA to be brought to the attention of appropriate management personnel.
LBNL is required to conduct all work activities in compliance with an RPP, which is both approved by DOE and formally documented. The RPP document describes the LBNL management approach and implementation methodology for complying with federal regulations, and for protecting individuals during LBNL work activities involving radioactive materials or other radiation sources. The Laboratory Director has direct responsibility for LBNL compliance with 10 CFR 835 and thus ensures complete and comprehensive implementation of the RPP. To maintain the RPP and to ensure its effective LBNL promulgation and implementation, the Laboratory Director has appointed an RCM.
The requirements of the RPP apply to all employees, supervisors, researchers, and individuals who may be exposed to ionizing radiation because of their LBNL work. The RPP includes all the elements of LBNL’s comprehensive radiation safety effort, i.e., management and administrative functions, radiation dose limits, monitoring requirements, entry controls, posting and labeling criteria, record keeping, communication reporting, safety training requirements, design and control standards, radioactive material controls, and emergency response.
RPG professional staff and technical experts provide the knowledge, resources, and services required for safe RPP implementation and compliance. The RPG, overseen and managed by the RCM, controls the on-site use of radioactive material and radiation-producing machines by performing radiological hazards and work-authorization analysis, monitoring and surveying, radiation safety training and testing, radiological work reviews, and other service functions.
DOE regulations contained in 10 CFR 820 implement nuclear safety enforcement requirements of the Price Anderson Amendment Act (PAAA). At LBNL, the PAAA Coordinator (PAAAC) reports directly to the Laboratory Directorate. The RCM is responsible for reporting to the PAAAC instances of actual or potential noncompliance with DOE radiation safety or RPP requirements.
Effective 01/01/2012, new locations being posted as Controlled Areas for Radiation Protection (Radiological Controlled Areas) for work under hazard category Class II or Class III Radiological Work Authorizations (RWAs) or Sealed Source Authorizations (SSAs) must be equipped with an LBNL Prox Key control (or equivalent approved by the Radiological Control Manager) that prevents access to the Radiological Controlled Area by untrained and unauthorized personnel. All personnel who are granted access to the posted area shall possess current General Employee Radiological Training (GERT), or shall be escorted by an individual with GERT.
Locations posted as Radiological Controlled Areas prior to 01/01/12 for work under hazard category Class II or Class III RWAs or SSAs must be equipped with a Prox Key control (or equivalent approved by the Radiological Control Manager) as resources are identified and allocated.
Temporary locations posted as Radiological Controlled Areas for work under hazard category Class II or Class III RWAs or SSAs do not require Prox Key control, but additional administrative controls may be implemented at the discretion of the Radiological Control Manager. Temporary locations are defined as locations that will be posted for less than 90 days (consecutive or total) in any 365-day period.
LBNL complies with Subpart J of 10 CFR 835 by requiring all individuals to receive radiation safety training, commensurate with the hazards in the area and the required controls, before being allowed unescorted access to Controlled Areas and before receiving occupational doses during access to Controlled Areas.
Basic radiation safety training at LBNL consists of information appropriate for nonradiological worker access to Controlled Areas. This training is known as General Employee Radiation Training (GERT). It consists of both general and site-specific information pertinent to maintaining a high level of radiation safety at LBNL. This information is distributed to all individuals when they receive their site-access badges. GERT meets the baseline criteria of Subpart J of 10 CFR 835 and shall be conducted at intervals not exceeding 24 months or when there are significant changes to radiation safety procedures or practices that may affect the individual.
All individuals must complete radiological worker training before being permitted unescorted access to Radiological Areas and before performing unescorted assignments as radiological workers. The training shall include a written examination. The training required depends on the nature of the radiological work and usually includes formal LBNL courses and on-the-job training by the supervisor or designated person. In addition, job-specific training is given for the type of radiation, the work-specific radiation-related operations, and the radiation safety measures pertinent to the work site.
Additional information is available in Environment, Health and Safety (EH&S) Procedure 790, Radiation Safety Training Program, which may be obtained at http://ehswprod.lbl.gov/rpg/.
A radiological worker is an individual at LBNL whose job assignment involves operation of radiation-generating machines or work with radioactive materials, or who is likely to be routinely occupationally exposed to greater than 100 millirem (mrem) of ionizing radiation per year. All radiation workers must:
Supervisors and PIs must:
The Radiological Work Authorization (RWA) program authorizes the use of radioactive material and radiation-producing machines, except X-ray machines. If only sealed sources are to be used, a Sealed Source Authorization (SSA) will be issued. The SSA is handled similarly to the RWA. See Section 21.6.4 (Sealed Source Authorization) of this PUB-3000 chapter for more information regarding sealed sources.
RWAs are issued for activities that are considered long-term projects under routine radiological conditions. RWAs specify quantitative limits on amounts of radioisotopes, and the radiological conditions acceptable at the specified work areas. The RWA will specify the limitations of its use.
Radioactive material possessed or used at or below the limits specified in EH&S Technical Note 9, Technical Basis for the Low Activity Source Work Authorization for Radioactive Material, Attachment F, “10CFR835 Based LAS Limits,” require a Low Activity Source (LAS) authorization. The limits in Attachment F are based on values defined in 10 CFR 835, Appendix D, “Surface Contamination Values,” and Appendix E, “Values for Establishing Sealed Radioactive Source Accountability and Radioactive Material Posting and Labeling Requirements.”
Dispersible radioactive materials can be used at or below removable limits defined in 10 CFR 835, Appendix D. Containers of dispersible radioactive materials are also subject to the limits defined in 10 CFR 835, Appendix D, for nondispersible materials.
An LAS is required to possess or use nondispersible radioactive materials (including sealed sources) at or below the limits specified in EH&S Technical Note 9, Attachment F. Each authorized LAS work location is permitted to have up to 10% of the value per isotope defined in 10 CFR 835, Appendix E, for nondispersible radioactive materials. If there is more than one isotope in the work location, then the sum of the activity-to-Appendix E- limits fractions for all the isotopes must not exceed 0.1. Each work location may have any number of samples.
With these limits and oversight by the Radiation Protection Group, no radiological areas or radioactive materials areas are likely at these levels. Therefore, authorized LAS work locations are not required to be posted as Controlled Areas for Radiation Protection (Controlled Areas). The work locations are exempt from posting controls, but designated work areas where dispersible radioactive materials are handled must be clearly delineated (e.g. with tapes or ropes). Materials stored in these areas must be properly labeled unless the materials meet one of the exceptions identified in EH&S Procedure 709, Radiation Protection Posting, Labeling and Access Control.
General Employee Radiation Training (GERT) and authorization-specific on-the-job training is required for personnel working under an approved LAS authorization. Workers performing tasks with LAS quantities of dispersible or nondispersible radioactive material will receive neither an external nor internal whole body dose greater than 100 millirem in a year (mrem/yr); no dosimetry is required.
For those projects possessing research devices that generate, or have the potential to generate, directly or indirectly ionizing radiation and do not currently exhibit dose rates in excess of 0.5 mrem/h at 30 cm from the device, a Low Dose Machine (LDM) Authorization is required. Once dose rates exceed 0.5 mrem/h at 30 cm from the device, a Radiological Work Authorization is required. GERT is required for individuals operating LDM-authorized devices. LDM-authorized radiation-generating devices are not required to be used or stored within a posted Controlled Area. Unmodified consumer devices utilizing ionizing radiation where shielding cannot be adjusted nor modified do not require an LDM.
Work Process A, Radiological Work Authorization (RWA), Low Activity Source (LAS), and Low Dose Machine (LDM) Authorization Work Process, provides further details on the LAS and LDM processes. Additional information may be obtained at http://ehswprod.lbl.gov/rpg/.
Radiological Work Permits (RWPs) are a type of radiological authorization issued for short-term or nonroutine projects and/or specific scopes of work that have a radiological hazard element and are not captured by other radiological authorizations (e.g., the RWA). The RWP document informs workers of the radiological controls, limitations, training/entry requirements, hold points, engineering controls, radiological sampling, and other measures necessary for a specific scope of work and each work activity within a project. The RWPs may supplement, or be independent of, other Radiological Authorizations and are valid only for the duration and scope of the project. Work Process B provides further details on the RWP process. Additional information may be obtained at http://ehswprod.lbl.gov/rpg/.
A sealed source is radioactive material encapsulated or plated in such a way that it will not be released under normal conditions. The RPG is responsible for approving all procurement and use of radioactive sealed sources. Sealed Source Authorizations (SSAs) specify appropriate procedures including requirements for accountability, procurement, receipt, use, storage, inventory, and leak testing to help ensure worker safety when working with or near sealed radioactive sources.
An SSA is needed to use sealed radioactive sources. If both sealed and unsealed materials are authorized, a Radiological Work Authorization (RWA) is used. Sources exempt from Nuclear Regulatory Commission (NRC) licensing or sources generally licensed by the NRC, known as Generally Licensed Sources, may require authorization by an SSA, RWA, or Generally Licensed Source Authorization (GLA) at the discretion of the Sealed Source Program Manager.
Sources exempt from Nuclear Regulatory Commission (NRC) licensing, or sources generally licensed by the NRC known as Generally Licensed Sources, require authorization by an SSA, RWA, or Generally Licensed Source Authorization (GLA) at the discretion of the Sealed Source Program Manager.
Examples of generally licensed sources include but are not limited to:
These sources are usually an integral part of a machine or apparatus and are not handled directly. Prior to obtaining an exempt or generally licensed source, contact the RPG to determine the level of authorization that must be obtained.
Work Process C provides further details on the SSA and GLA process. Additional information may be obtained at http://ehswprod.lbl.gov/rpg/.
Only radioactive material authorized by an approved RPG-issued work authorization shall be procured. All incoming shipments of radioactive materials shall be delivered to the RPG for survey and inclusion in the Laboratory inventory control system prior to being delivered to their intended final destination.
Radioactive materials must be controlled at all times. Each PI is responsible for maintaining accurate records of the amount and type of radioactive material in storage and use in his or her laboratory. Each quarter, the PI is provided with a Quarterly Inventory Report (QIR) from the RPG, which details the radioactive material delivered to the PI in the past quarter and provides a list of stored radioactive stock. The PI must promptly update the report, noting the location of the material and whether it is still in use or in storage, or has been disposed of as radioactive waste.
Sealed radioactive sources must be controlled in a locked cabinet or room. The source must be signed out, and the use location must be tracked. The Radiation Protection Group (RPG) performs periodic inventory audits for sealed sources.
Nuclear materials are materials that DOE has identified as requiring special controls to prevent their loss or theft. Examples of such materials are depleted uranium, enriched uranium, americium-241, americium-243, curium, berkelium, californium-252, plutonium-238 through plutonium-242, lithium-6, uranium-233, normal uranium, neptunium-237, deuterium, tritium, and thorium.
The NMMSS Program at LBNL is outlined in the institutional program procedure Material Control and Accountability Plan (MCAP), and implemented via EH&S Procedure 740, Nuclear Material Control and Accountability, by the Material Control and Accountability (MC&A) Coordinator and the RPG Nuclear Material Representative (NMR). NMMSS material must be stored in a locked location when not being used. The material must be auditable at any time.
Nuclear-material custodians are responsible for the protection, control, and accountability of nuclear materials under their cognizance. Nuclear-material users are responsible for documenting internal transfers and ensuring their personnel are authorized to handle nuclear materials and comply with MC&A procedures. No nuclear material must be received or shipped without approval by the RPG NMR (ext. 6228). The RPG NMR must be notified prior to the transfer of nuclear materials to a new storage location.
DOE nuclear-material control requirements consist of four function areas: access controls, material surveillance, material containment, and detection/assessment. LBNL maintains a rigorous nuclear-material control program. Nuclear materials are required to be used or stored in secured and alarmed facilities supported by strong administrative controls. Access to Material Control and Accountability (MC&A) data is limited. The access control program for nuclear materials is designed to prevent theft or diversion of nuclear materials. The material surveillance program implemented at LBNL consists of material controls, administrative controls, and physical security measures. All nuclear materials must be attended when in use or maintained in a secured area. LBNL's nuclear-material containment policy is based on the graded safeguards approach and the consequence of loss. Nuclear materials (including special nuclear materials) are stored and used in locked facilities with limited access, and secured when not in use. The material surveillance program implemented at LBNL includes storage/use area proximity alarms, video surveillance, and standardized administrative controls. These program elements supported by the RWA and SSA programs assure the detection/assessment of unauthorized activities.
Radioactive materials not defined as DOE nuclear material must also be accounted for and protected from theft or misuse. Radioactive materials that are not being used (exclusive of "induced radioactive material," which is material that has become radioactive by bombardment with neutrons or charged particles, and is discussed separately below) must be stored securely in an area designated as a Radioactive Material Storage Area (RSA). Storage of radioactive material within a Radioactive Material Area (RMA) is discouraged. Radioactive material should be stored and used in limited-access facilities and secured when not in use. Inventory audits are required quarterly.
Work Process D provides further details on the radioactive materials inventory control process. Additional information may be obtained from http://ehswprod.lbl.gov/rpg/.
This section applies to electronic devices under the administrative control of LBNL that are designed to produce X-rays beyond a contiguous vacuum. It is directed towards the use of X-rays as an analytical tool; it is not meant to apply to the design and construction of prototype X-ray equipment. Once put into routine use, any such equipment will be covered by the LBNL X-Ray Safety Program. Other X-ray radiation-producing machines are also addressed.
The primary objective of the LBNL X-Ray Safety Program is to ensure that exposure to radiation from X-ray machines is as low as reasonably achievable (ALARA). The primary means to achieve this objective is by engineered controls. To the extent possible, a combination of interlocks, sensors, barriers, shielding, warning lights and tones, and area monitors are used. For analytical X-ray machines, this means that only enclosed beams are allowed for routine use. The expected exposure to radiation from analytical X-ray machines for routine users and nonusers at LBNL is below the minimum reportable dose of an optically stimulated luminescence (OSL) dosimeter. The program is based on the X-ray safety guidance provided by American National Standards Institute (ANSI) N43.2 and N43.3 for analytical X-ray machines; National Council on Radiation Protection & Measurements (NCRP) Report Nos. 102 and 49 for medical X-ray machines; and Title 21 of the Code of Federal Regulations (21 CFR), Chapter I, Subchapter J, for cabinet X-ray machines and irradiators. Medical machines not being used for human use at LBNL are considered industrial equipment and must be operated fully enclosed, except when granted a variance by the Radiation Safety Committee (RSC). All X-ray operations at LBNL must be reviewed by the LBNL X-Ray Safety Officer (XSO) or Backup XSO and approved by the RCM.
Devices Beyond the Scope of This Program
X-ray machines are a subset of a much broader set designated as radiation-producing machines. It is recognized that it is easy to generate X-rays either intentionally or adventitiously. Any device that combines high voltage and a metal target in a contiguous vacuum can cause X-rays when a current flows, and users should be alert to this possibility.
Therefore, any electronic device that could produce an X-ray field should be brought to the attention of the XSO. An evaluation of the hazards will be performed by the XSO, and controls will be implemented on a case-by-case basis to achieve the objectives of X-ray safety at LBNL.
For equipment designed and built at LBNL, it is advisable to inform the XSO early in the design process so that safety needs may be predicted to the extent possible and protective measures employed as an integral part of the design. The goal will be to make the device as intrinsically safe as reasonably achievable with no detectable X-ray fields outside of the contiguous vacuum of the X-ray source. If this goal can be achieved, the device will not be considered a radiation-producing machine, and no additional radiation safety controls will be required.
Electron microscopes, ion implanters, electron spectroscopy for chemical analysis (ESCA), photoemission X-ray spectrometers, and X-ray photoelectron spectrometers (XPS) do not emit X-rays beyond the contiguous vacuum as a part of their designed function and are usually designed to prevent such emissions on an incidental basis. Thus, they are not usually considered radiation-producing machines at LBNL. If such a device is suspected of emitting X-rays, it must be brought to the attention of the XSO, who will evaluate it and determine what provisions must be made for safe use.
Any radiation-producing machine, such as a neutron generator, Vann de Graaff accelerator, or an ion source, that can directly or indirectly produce ionizing radiation outside a contiguous vacuum must be reviewed by the RPG Health Physicist (HP) and properly authorized in accordance with Section 21.6.1 (Radiological Work Authorization) or Section 21.6.2 (Low Activity Source and Low Dose Machine Authorizations) of this PUB-3000 chapter.
Work Process E provides further details on the X-ray authorization process. Additional information may be obtained at http://ehswprod.lbl.gov/rpg/.
Radiological safety of accelerators is assured through appropriate formal RPG authorization, either an RWA or an RWP, as specified in Section 21.6 (Radiological Work Authorization and Permit Programs) of this PUB-3000 chapter. Additionally, facilities that meet the definition of accelerators in DOE Order 420.2B, Safety of Accelerator Facilities, shall comply with 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. Before any operation is begun at any LBNL accelerator, the RPG must conduct a review to determine whether a radiological authorization will be required, and whether the accelerator facility must comply with DOE Order 420.2B or seek an exemption.
Assurance of compliance with DOE Order 420.2B is described in EH&S Procedures 703 and 703.1, which are available at http://ehswprod.lbl.gov/rpg/.
EH&S Procedure 703.1 describes the Unreviewed Safety Issues Determination (USID) process that accelerator line management personnel must use to determine whether a proposed change, modification, or experiment will either (1) significantly increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety from that evaluated previously by safety analysis, or (2) introduce an accident or malfunction of a different type than any evaluated previously by safety analysis that could result in significant consequences.
Accelerator beams can produce induced radioactivity in components and equipment that are in close proximity to the beam. Materials removed from these areas must be characterized as to their activity and radiation levels. Items must not be removed from Accelerator Controlled Areas for unrestricted release until a release survey has been performed and the item tagged as “released.” Only an RCT or specially trained and designated radiation worker shall perform such surveys and tag items for release.
LBNL policy requires radiation safety interlock systems at accelerators to protect personnel from accidental exposure to hazardous levels of radiation. Interlocks must be addressed in the RWA or RWP. Contact the RPG for further information about accelerator interlocks.
Occupancy of a beam enclosure while the beam is directed to that area is not normally allowed unless specifically permitted in either the RWA or RWP. Entrances to such enclosures must be interlocked to the beam permissive-logic control system for safety. Overriding these safety mechanisms for purposes of convenience or expedience is strictly prohibited. Experiments must be designed so that electronic or mechanical means are incorporated to monitor and to adjust the apparatus remotely if necessary.
Interlock systems protect personnel from accidental exposure to potentially high levels of radiation by excluding personnel from High Radiation Areas or Very High Radiation Areas. Beam interlock systems and warnings must be tested and serviced by the operating groups at least every 12 months, within the anniversary month. These requirements will be detailed in the applicable authorizing document.
LBNL has established administrative control levels below federal dose limits (see Tables 21.1 and 21.2). These levels are monitored by personal dosimetry. Prior to exceeding any control level, written authorization is required from the appropriate level of management, as indicated in Table 21.2.
Table 21.1. Federal Exposure Limits
|Type of Exposure||
Radiological worker: whole body (internal + external)
Radiological worker: lens of eye
Radiological worker: extremity (hands, feet, arms below the elbow, and legs below the knees)
Radiological worker: any organ or tissue (other than lens of eye) and skin
Declared pregnant worker: embryo or fetus
0.5 rem in
Minors and students (under age 18): whole body (internal + external)
Visitors* and public: whole body (internal + external)
*Applies to visitors who have not completed training.
Table 21.2. LBNL Administrative Control Levels**
Skin and Extremity
Lens of the Eye
1 (Administrative control level)
Line manager, RCM
RCM, Deputy Director for Operations
DOE control level
DOE Program Secretarial Official
In general, dosimetry will be required for all accelerator and X-ray-generating device users and for users of radioactive material who are likely to receive a whole-body dose of more than 100 millirem/year. Specified internal and external dosimetry requirements are listed in the controlling radiation work document [RWA, RWP, SSA, or X-Ray Authorization (XA)].
An investigation will be performed if there is any unplanned exposure exceeding any of the administrative control levels.
No one under 18 years old should be employed in, or be allowed to enter, any Radiological Area (e.g., Radiation Area, Contamination Area) or work with radioactive material where they can receive a total of more than 0.1 rem [1 millisievert (mSv)] per year from both internal and external doses.
No declared pregnant worker may receive more than 0.5 rem (5 mSv) during the nine-month gestation period.
Contact the RPG for details on how to become a declared pregnant radiation worker.
The dose equivalent received by members of the public during direct on-site access shall not exceed 0.1 rem (1 mSv) per year based on the sum of both internal and external doses.
Contract personnel are the responsibility of their employers and are obligated by contract to comply with all pertinent DOE and LBNL safety and health regulations and requirements, including restrictions on personnel under 18 years of age.
Personnel in the dosimetry program receive a report of their dose as required by 10 CFR 835.
All radiation workers exposed to external ionizing radiation will be issued a dosimeter as required by the RWA, RWP, SSA, or XA.
Optically stimulated luminescence (OSL) dosimeters and CR-39 track-etch detectors are considered the primary dosimeters at LBNL. Any other dosimeter is supplemental.
Notify the RPG immediately if nonoccupational radiation exposures occur to a dosimeter.
The RPG provides extremity dosimeters for personnel who have the potential to receive an extremity dose significantly higher than the whole-body dose. Personnel will be issued and must wear extremity dosimeters as required by their RWA or RWP. The dosimeters must be returned to the RPG Dosimetry Office for evaluation.
Electronic personal dosimeters (EPDs) must be worn as specified by the RWA or RWP. EPDs are worn simultaneously with the primary dosimeter.
All radiation workers must wear their dosimeters as required and are encouraged to wear their dosimeters at all times when at the Laboratory. The preferred location for wearing a dosimeter is the upper torso, where it will give the best estimate of the whole-body dose equivalent. The dosimeter must not be worn during nonoccupational activities, such as when undergoing medical or dental X-rays, nuclear medical procedures, or radiation therapy, or during air travel.
Laboratory personnel, both staff and guests, who might be exposed to radiation while working at other facilities will be issued dosimeters by those facilities. The LBNL dosimeter must not be used to monitor occupational radiation exposures at other facilities.
Exposures received at other facilities must be reported to the RPG.
Compliance With External Dosimetry Requirements
Personnel are responsible for following Laboratory procedures and for returning their dosimeters as prescribed. Supervisors are responsible for enforcing this procedure. Personnel who do not return their dosimeters during the prescribed period will receive a written reminder, as will their division safety coordinator.
Continued failure to return the dosimeters will result in notification of the appropriate division director, and the worker will be removed from any radiation work until an evaluation of the employee’s work practices has been completed.
Replacement costs of lost or damaged dosimeters and dosimeter holders will be charged to the worker’s program account.
The hazard analysis in the RWA/RWP process will determine the risk of internal intake of radioisotopes and whether internal dosimetry is required. The dose limits for internal radiation are based on the standards listed in the Internal Dosimetry Technical Basis. Laboratory policy requires that all Controlled Areas be kept as free as possible of airborne radioactivity and contamination.
The RPG administers the program to monitor internal radiation dose equivalents to Laboratory employees. Line management supervisors are responsible for ensuring compliance with the program requirements.
The Internal Dosimetry Program consists of in vitro (body fluid) and in vivo (whole-body counting) analyses. Workers who require internal dose monitoring must submit samples and undergo whole-body counts as scheduled.
Compliance With Internal Dosimetry Program Requirements
An employee who does not submit the requested in vitro samples or complete the in vivo analysis as required will receive a written reminder, as will his or her supervisor. Continued noncompliance will result in notification of the appropriate division director, and the worker will be removed from any radiation work until an evaluation of the employee's work practices has been completed.
In order to demonstrate that the doses outside Controlled Areas for Radiation Protection are negligible, the RPG is responsible for establishing and maintaining a comprehensive area dosimetry program. Two types of area monitors are used: passive (i.e., dosimeters) and active (i.e., telemetered instruments). The measurement results provide information that supports radiological safety decisions, particularly with regard to personnel doses and the requirement to monitor individual personnel doses.
Contact the RPG if questions arise regarding placement or results of area monitoring equipment.
Radiation workers are provided appropriate, calibrated radiation-detection equipment. The RPG provides guidance in the selection of instruments, in addition to instrument distribution, calibration, and maintenance. Individuals who use these instruments must be trained in their use and familiar with their limitations. Users are responsible for obtaining adequate instrument training and maintaining the equipment in working order. In addition, users are responsible for the safekeeping of the instrument assigned to their authorization.
All of the steps below must be followed satisfactorily by radiation workers prior to using radiation-detection equipment or instruments:
Radiation Surveys by Users
Radiation workers must conduct periodic radiation and contamination surveys to ensure that safety controls are adequate. This involves surveying the work area, work surfaces, floors, equipment, and personnel. This should be done with portable equipment before, during, and after work that may change the radiological conditions of the work area. In areas where materials could be dispersed, causing contamination, swipe samples must be taken and analyzed on a suitable instrument. Positive results must be documented and reported to the RPG.
Formal, documented surveys must be performed by radiation workers in accordance with provisions of the controlling RPG authorization. The RPG will provide instruction and resources for this work.
The RPG must be notified of radiation levels that could cause significant personnel exposure (>100 mrem/hr) or any unusual radiation fields. Additionally, RPG notification is required if laboratory spaces cannot be decontaminated immediately. Corrective actions and additional surveys must be documented.
RPG Routine Surveys
Routine radiological contamination and radiation dose rate surveys will be conducted by the RPG on a schedule that is commensurate with the radiological hazards in the area and the potential for a change in conditions.
RPG Decommissioning Surveys
Surveys will be performed to decommission areas to be released for unrestricted use, such as nonradioactive work, construction, or maintenance. The RPG must be notified at least 30 days in advance of a project termination so that arrangements may be made for decontamination, decommissioning, or both.
Equipment or materials to be removed from areas where activation or contamination could occur must be surveyed and tagged by RPG personnel or personnel who have been trained and authorized by the RPG in the applicable RPG-issued work authorization.
Based on an RPG assessment of the operation and in accordance with RPG procedures, air sampling will be performed within areas where there is the potential for airborne radioactive contamination.
All employees must:
For further details, see PUB-3000, Chapter 9 (Emergency Management).
Radioactive spills are divided into two categories: minor spills and major spills.
A minor spill is a spill of radioactive material that (1) is contained within the boundary of an RMA or RSA, (2) has not contaminated the floor, and (3) has not made contact with skin or personal clothing. All three conditions must be met. Authorized radiation workers may initiate cleanup prior to contacting the RPG for assistance.
In the case of a major spill, contact the RPG at ext. 7277 immediately. A major spill is any spill of radioactive material that has made contact with the floor, personal clothing, or skin, or that spreads outside the RMA or RSA.
All radiological emergency incidents will be investigated by the RPG, and a report will be completed.
Work Process F provides further details on accident and emergency situation processes. Additional information may be obtained at http://ehswprod.lbl.gov/rpg/index.shtml.
Activation is the process of producing a radioactive material by bombardment with neutrons, protons, or other nuclear particles.
An administrative control level is a numerical dose constraint established at a level below the regulatory limits in order to administratively control and help reduce individual and collective doses.
An Airborne Radioactivity Area is any area accessible to individuals, where the concentration of airborne radioactivity, above natural background, 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 an individual present in the area without respiratory protection could receive an intake exceeding 12 DAC-hours in a week.
The annual limit on intake (ALI) is the derived limit for the amount of radioactive material taken into the body of an adult worker by inhalation or ingestion in a year. The ALI is the smaller value of intake of a given radionuclide in a year by the reference man (International Commission on Radiological Protection, Publication 23) that would result in a committed effective dose of 5 rem (0.05 sievert), or a committed equivalent dose of 50 rem (0.5 sievert), to any individual organ or tissue.
As low as reasonably achievable (ALARA) describes 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 is reasonable, taking into account social, technical, economic, practical, and public policy considerations. As used in this PUB-3000 chapter, ALARA is not a dose limit but a process that has the objective of attaining doses as far below the applicable controlling limits as reasonably achievable.
Background radiation is radiation from cosmic sources; naturally occurring radioactive materials, including radon (except as a decay product of source or special nuclear materials); and global fallout as it exists in the environment from the testing of nuclear explosive devices. Background radiation does not include radiation from source, by-product, or special nuclear materials.
The becquerel (Bq) is the International System (SI) unit for activity of radioactive material. One becquerel is that quantity of radioactive material in which one atom is transformed per second or undergoes one disintegration per second.
A bioassay is an internal dosimetry test used to determine the kinds, quantities, concentrations, and in some cases the locations of radioactive materials within or excreted from the human body. This process includes whole-body and organ counting, as well as analysis of urine, feces, and other specimens.
Calibration is the process of adjusting or determining one of the following:
A containment device is a barrier, such as a glove box or fume hood, for inhibiting the release of radioactive material from a specific location.
A Contamination Area is an area where ambient contamination levels are more than those specified in 10 CFR 835, Appendix D.
In a contamination survey, swipes or direct instrument surveys are used to identify and quantify radioactive material on personnel, on equipment, or in areas.
A Controlled Area for Radiation Protection is any area to which access is managed in order to protect individuals from exposure to radiation or radioactive materials. Individuals who enter Controlled Areas, without entering Radiological Areas, are expected to not receive a total effective dose equivalent of more than 0.1 rem (0.001 sievert) in a year.
Controlled Items, as designated by the Laboratory’s Property Management Office, are items that shall be kept under inventory control, regardless of value.
A declared pregnant worker is a woman who has voluntarily informed her employer in writing of her pregnancy and the estimated date of conception.
Decontamination is the process of removing radioactive contamination and materials from personnel, equipment, or areas.
The derived air concentration (DAC) is the airborne concentration equal to the ALI divided by the volume of air breathed by an average worker for a working year of 2,000 hours (assuming a breathing volume of 2,400 m3).
A dose is an amount of energy deposited in body tissue because of radiation exposure. Various technical terms, such as absorbed dose, equivalent dose, effective dose, committed equivalent dose, committed effective dose, and total effective dose, are used to evaluate the amount of radiation an exposed worker receives. These terms (see below) are used to describe the differing interactions of radiation with tissue as well as to assist in the management of personnel exposure to radiation:
An absorbed dose (D) is the average energy imparted by ionizing radiation to the matter in a volume element per unit mass of irradiated material. The absorbed dose is expressed in units of rad (or gray) (1 rad = 0.01 gray).
Committed effective dose (E50) means the sum of the committed equivalent doses to various tissues or organs in the body (HT,50), each multiplied by the appropriate tissue weighting factor (wT), that is, E50 = ΣwTHT,50 + wRemainderHRemainder,50; where wRemainder is the tissue weighting factor assigned to the remainder organs and tissues, and HRemainder,50 is the committed equivalent dose to the remainder organs and tissues.
Committed equivalent dose (HT,50) is the equivalent dose calculated to be received by a tissue or organ over a 50-year period after the intake of a radionuclide into the body. It does not include contributions from radiation sources external to the body. A committed equivalent dose is expressed in units of rem (or sievert).
Effective dose (E) is the summation of the products of the equivalent dose received by specified tissues or organs of the body (HT) and the appropriate tissue weighting factor (wT), that is, E = ΣwTHT.
Equivalent dose (HT) means the product of average absorbed dose (DT,R) in rad (or gray) in a tissue or organ (T) and a radiation (R) weighting factor (wR). For external dose, the equivalent dose to the whole body is assessed at a depth of 1 cm in tissue, the equivalent dose to the lens of the eye is assessed at a depth of 0.3 cm in tissue, and the equivalent dose to the extremity and skin is assessed at a depth of 0.007 cm in tissue.
Tissue weighting factor (wT) means the fraction of the overall health risk, resulting from uniform whole-body irradiation, attributable to specific tissue (T). The equivalent dose to tissue, (HT), is multiplied by the appropriate tissue weighting factor to obtain the effective dose (E) contribution from that tissue.
Total effective dose (TED) is the sum of the effective dose (for external exposures) and the committed effective dose.
Dose assessment is the process of determining the radiological dose and the uncertainty included in the dose estimate through the use of exposure scenarios, bioassay results, monitoring data, source term information, and pathway analysis.
Employee: An individual who is paid for his or her work at LBNL, and has an LBNL site-access badge with an employee number.
Engineering controls are components and systems used to reduce airborne radioactivity and the spread of contamination by using piping, containment, ventilation, filtration, or shielding.
An escort is an individual with the prerequisite training necessary for unescorted access to the area where the escort works, and who is authorized to accompany and ensure the safety of individuals who have not completed required training. An escort must always maintain continuous direct line-of-sight and communication proximity to the persons he/she is escorting.
An Exclusion Area is an area defined by a qualified expert as one that all personnel should be restricted from entering during operation of an accelerator.
Extremities include hands, feet, arms below the elbow, and legs below the knee.
Being fail-safe means having the property that any single failure causes a sequence of events that always results in a safe situation.
A fail-safe design is one in which all single-component failures of indicators or safety systems (that can reasonably be anticipated) cause the equipment to fail so as to maintain personnel radiation safety. For example, if a light indicating "X-Ray On" fails, the production of X-rays is prevented; similarly, if a shutter-status indicator fails, the shutter closes.
Fixed contamination is radioactive material above the appropriate limits specified in 10 CFR 835, Appendix D, that cannot be readily removed from surfaces by nondestructive means, such as casual contact, wiping, brushing, or washing.
Frisking is the process of monitoring personnel for contamination. Frisking can be performed with handheld survey instruments or automated monitoring devices.
The gray (Gy) is the SI unit of absorbed dose. One gray is equal to an absorbed dose of 1 joule per kilogram (100 rads).
A guest is an individual who may or may not be paid for his or her work at LBNL, and has an LBNL site-access badge with an ID number. Auditors are classified as guests, but are exempt from the site-access badge and ID number requirement.
A High Contamination Area is an area where ambient contamination levels are higher than 100 times those specified in 10 CFR 835, Appendix D.
A high-efficiency particulate air (HEPA) filter is an extended, pleated, medium dry–type filter with (1) a rigid casing enclosing the full depth of the pleats, (2) a minimum particle-removal efficiency of 99.97% for thermally generated monodisperse DOP smoke particles with a diameter of 0.3 mm, and (3) a maximum pressure drop of 1.0 inch w.g. when clean and operated at its rated airflow capacity.
A High Radiation Area is any area, accessible to individuals, in which radiation levels could result in an individual receiving a deep dose equivalent in excess of 0.1 rem (0.001 sievert) in one hour, 30 cm from the radiation source or from any surface that the radiation penetrates.
An irradiator is a sealed radioactive material that has the potential to create a radiation level exceeding 500 rads (5 gray) in 1 hour at a distance of 1 meter.
Low Activity Source (LAS) Authorizations allow use or transfer of radioactive materials with very low activity, provided that a project does not possess more than 10 such quantities. Compliance with regulations and other provisions of EH&S programs is required.
Mixed waste is waste containing both radioactive and hazardous components as defined by the Atomic Energy Act and the Resources Conservation and Recovery Act, respectively.
Occupational dose is the dose received by a person during employment in which the person’s assigned duties involve exposure to radiation and to radioactive material. An occupational dose does not include doses received from background radiation, from medical procedures, from voluntary participation in medical research programs, or as a member of the public.
Personal protective equipment is equipment, such as respirators, face shields, and safety glasses, that is used to protect workers from excessive exposure to radioactive or hazardous materials.
Personnel dosimeters are devices, such as optically stimulated luminescence (OSL) dosimeters and neutron dosimeters, designed to be worn by a single person for the assessment of his or her dose equivalent.
Personnel monitoring describes systematic and periodic estimates of radiation doses received by personnel during working hours. The term is also used for the monitoring of personnel, their excretions, their skin, or any part of their clothing to determine the amount of radioactivity present.
The exposure of an embryo or fetus to radiation is known as prenatal radiation exposure.
The operation of any accelerator will result in radiation called prompt radiation, as distinguished from induced radioactivity. Prompt radiation stops as soon as the accelerator is turned off.
A qualified expert is a person having the knowledge and training to measure ionizing radiation, to evaluate safety techniques, and to provide advice on radiation-protection needs as determined by LBNL management.
The rad is a unit of absorbed dose. One rad is equal to an absorbed dose of 100 ergs per gram or 0.01 joule per kilogram (0.01 gray).
A Radiation Area is any area, accessible to individuals, in which radiation levels could result in an individual receiving a deep dose equivalent in excess of 0.005 rem (0.05 millisievert) in one hour, 30 cm from the radiation source or from any surface that the radiation penetrates.
The Radiation Safety Committee (RSC) is responsible for advising LBNL management on all matters related to occupational and environmental radiation safety. The RSC provides oversight to the Radiation Protection Program (RPP), including the ALARA Program.
A radioactive material is any material, equipment, or system component determined to be contaminated or suspected of being contaminated. Radioactive material also includes activated material, sealed and unsealed sources, and material that emits radiation.
A Radioactive Material Area (RMA) is an area or structure where radioactive material is used, handled, or stored.
Radiography is the nondestructive examination of the structure of materials by using a radioactive source, X-ray machine, or accelerator.
A Radiological Area is any area within a Controlled Area that must be posted as a Radiation Area, High Radiation Area, Very High Radiation Area, Contamination Area, High Contamination Area, or Airborne Radioactivity Area in accordance with 10 CFR 835.603.
A Radiological Buffer Area (RBA) is an area intended to provide a boundary to minimize the spread of contamination and to limit doses to general employees who have not been trained as radiological workers. An RBA may be established for contamination control adjacent to any entrance to or exit from a contamination, high contamination, or airborne radioactivity area.
A Radiological Control Technician (RCT): is a qualified individual, per RPG procedures, who performs radiological surveys to assure compliance with applicable LBNL and federal rules and regulations. An RCT is responsible for conducting reviews of records generated and maintained by authorized radiation workers and providing direct radiological support to LBNL personnel.
A radiological posting is a sign or label that indicates the presence or potential presence of radiation or radioactive materials.
Radiological work is any work that requires the handling of radioactive material or requires access to Radiation Areas, High Radiation Areas, Contamination Areas, High Contamination Areas, or Airborne Radioactivity Areas.
A Radiological Work Authorization (RWA) is an authorization for use of radiation-producing machines and/or radioactive materials in long-term projects having stable radiological conditions. Precautions, limits of use, and requirements are specified.
A Radiological Work Permit (RWP) is a permit that identifies radiological conditions, establishes worker protection and monitoring requirements, and contains specific approvals for specific radiological work activities. The Radiological Work Permit serves as an administrative process for planning and controlling radiological work and informing workers of the radiological conditions. A permit for construction or demolition work in a Radioactive Material Area is one example.
A radiological worker is a worker whose job assignment requires work on, with, or in the proximity of radiation-producing machines or radioactive materials AND has the potential of being exposed to more than 0.1 rem (1 millisievert) per year, which is the sum of the dose equivalent from external irradiation and the committed effective dose equivalent from internal irradiation. A radiological worker may also be referred to as a “radiation worker” or a “rad worker.”
Release to Uncontrolled Areas is the release of material from administrative control after confirming that the residual radioactive material meets the guidelines in DOE Order 5400.5.
The rem is a unit of equivalent dose. The equivalent dose in rem is numerically equal to the absorbed dose in rad multiplied by a radiation weighting factor, a distribution factor, and any other necessary modifying factor (1 rem = 0.01 sievert).
Removable contamination is radioactive material that can be removed from surfaces by nondestructive means, such as casual contact, wiping, brushing, or washing.
Radioactive material that is contained in a sealed capsule, sealed between layers of nonradioactive material, or firmly fixed to a nonradioactive surface by electroplating or other means is called a sealed source. The confining barrier prevents dispersion of the radioactive material under normal, and most accidental, conditions related to use of the source.
A Sealed Source Authorization (SSA) authorizes possession and use of sealed sources. Precautions, limits of use, and other requirements are specified.
The sievert (Sv) is the SI unit of any of the quantities expressed as equivalent dose. The equivalent dose in sievert is equal to the absorbed dose in gray multiplied by the radiation weighting factor (1 Sv = 100 rem).
A subcontractor is an individual who may or may not be paid for his or her work at LBNL and does not have an LBNL site-access badge.
Techniques are X-ray machine-operating parameters, such as voltage, current, exposure time, anode type, filters used, distance, field size, etc., employed during an X-ray exposure. Not all parameters are applicable to all types of X-ray machines.
An Uncontrolled Area is any area where access is not restricted and the effective dose equivalent received by any member of the public resulting from exposure during direct on-site access does not exceed a limiting value of 0.001 sievert (0.1 rem) in any year.
An unusual occurrence is a nonemergency occurrence that has significant impact or potential for impact on safety, environment, health, security, or operations. Examples of the types of occurrences that are to be categorized as unusual occurrences are listed in DOE Manual 232.1-2.
A Very High Radiation Area is any area, accessible to individuals, in which radiation levels could result in an individual receiving an absorbed dose in excess of 500 rads (5 gray) in 1 hour, 1 meter from a radiation source or from any surface that the radiation penetrates.
A visitor is an individual who does not have an LBNL site-access badge, does not get paid by LBNL, and does not perform work for LBNL.
An X-ray accessory apparatus is any portion of an X-ray installation that is external to the radiation-source housing, and into which an X-ray beam is directed for making X-ray measurements or for other uses.
The X-ray tube and that portion of an X-ray system that provides the accelerating voltage and current is the X-ray generator.
An X-Ray System Supervisor is a person having administrative control over an X-ray machine and is so designated in the X-Ray Machine Safety Document for that machine.
Related PUB-3000 Chapters
When a new RWA or major RWA revision is needed to perform radiological work, the principal investigator (PI) shall prepare an application to request that the Radiation Protection Group (RPG) issue an RWA.
Applications are to be submitted to the Radiation Protection Group Leader/Radiological Control Manager or to the assigned health physicist. The receipt of the application will be acknowledged via telephone or e-mail to the person initiating the memo. A meeting will be scheduled by the RWA Health Physicist to review the draft of the RWA with the PI and evaluate the facilities. A minimum of three weeks is required to establish a new RWA.
The following information is to be provided:
Review and Processing of RWA Applications
After an application is received by the RPG, or when a renewal is required, the RWA Health Physicist conducts a detailed review of the proposed project to determine the appropriate precautions, limitations, and ALARA practices necessary to ensure both good and safe work practices. This review must be followed by a personal interview with the applicant and an inspection of the proposed workplace(s).
All personnel must have training commensurate with radiation hazards prior to performing work authorized by an RWA. EH&S Radiation Worker training is generally required. [See Section 21.4.3 (Training) of this PUB-3000 chapter.] Principal investigators must ensure that on-the-job training (OJT) addressing the unique hazards of the authorized work is performed and documented.
Amending an RWA
An RWA must be amended if it does not specify adequate radiological controls or maximum radiological conditions. Changes to RWAs are classified as either minor or major amendments. Minor amendments may be accomplished by "pen and ink" changes to the original RWA. Major amendments require the generation of a new RWA and require the same review and approval process as a new RWA.
Terminating an RWA
To terminate an RWA, the PI must notify the RPG in writing at least 30 days before the anticipated termination. The PI is responsible for disposal of all radioactive material authorized by the RWA. The RWA terminating process requires that the PI complete the following:
Procurement of Radioisotopes
Only radioactive material authorized by an approved RWA, Sealed Source Authorization (SSA), or Low Activity Source (LAS) Authorization shall be procured. See Section 21.6.6 (Control and Accountability of Radioactive Material) of this PUB-3000 chapter.
Each project group must maintain a Radioisotope Journal (RIJ), or equivalent, in which pertinent records are filed in a readily retrievable manner. This RIJ must be accessible to all persons who work with radioactive material under the project. The RIJ must also be available for inspection at any time during normal working hours, and the project staff should know where such records are kept. The RIJ must contain all relevant documents, or reference the location of documents, and must be kept in one or more volumes at one location. The RPG will furnish RIJ binders.
The RIJ must include, but is not limited to, the following records.
Application for LAS Authorization is made by the responsible researcher via e-mail or direct mail to the Radiation Protection Group. describe the following: materials to be used, proposed use, work/storage areas, delivery-point information, names of users, and waste-disposal and survey needs.
Review and Processing of LAS Application
The LAS Authorization is formalized in a document that is sent to the applicant; the applicant retains a copy and returns a signed copy to the RPG. The authorization is for a term of 12 months. Near the end of the authorization period, the RPG will contact the PI to review the continuation of the LAS Authorization for another term.
LAS Area Posting and Labeling
Work with LAS-level radioactive material shall be conducted within a posted Controlled Area unless otherwise authorized. Waste is to be disposed of in properly labeled radioactive-material waste containers.
General Employee Radiological Training (GERT) is required for all LAS users.
Application for the Low Dose Machine (LDM) Authorization is made by the responsible researcher via e-mail or direct mail to the RPG. The assigned health physicist (HP) will determine, with the responsible individual for the device, whether an LDM Authorization is required. The assigned HP will evaluate the characteristics, operating envelope, and proposed use of the device and perform a dose-rate survey to ensure that accessible dose rates are less than the stated limits for an LDM.
The LDM Authorization is formalized in a document written by the assigned HP, and is forwarded for review to a designated RPG technical reviewer and the Radiological Control Manager (RCM). The document is then forwarded to the responsible individual for the authorized device and the listed authorized workers for their review and signatures; the responsible individual retains a copy and returns the signed original to the RPG. The authorization is valid for 12 months. Renewals of LDM Authorizations will be managed in the same manner as renewals of LAS Authorizations.
LDM Area Posting and Labeling
LDM-authorized radiation generating devices are not required to be used or stored within a posted Controlled Area.
LDM Authorization amendments and terminations will be managed in the same fashion as amendments and terminations of RWAs.
Any proposed changes to the operating conditions or shielding of an LDM-authorized device must be reviewed in advance by the RPG to ensure continued compliance with this program.
EHS0470, General Employee Radiological Training (GERT), is required for all LDM users who have shielding configuration control responsibilities.
To initiate a Radiological Work Permit (RWP), determine the following information and follow the instructions contained within EH&S Procedure 705.
Once the above is completed, contact the RWP Program Manager and send a written request with the above information. Upon receipt of the RWP request, the RWP Program Manager will review the information to determine the hazard class of the RWP and specific controls necessary to complete the project.
Approving an RWP
Once the RWP is developed and the work lead and RWP Program Manager have collaborated on the final draft of the RWP; the RWP Program Manager routes the final RWP for approvals, which are indicated by signatures. The hazard class of the RWP determines who approves the RWP. Regardless of the hazard class, all RWPs must be reviewed and signed by the Lawrence Berkeley National Laboratory facility director (e.g., the Advanced Light Source Director, the 88-Inch Cyclotron Director, the Molecular Foundry Director) if applicable and the work lead to ensure proper notification and compliance.
Issuing an RWP
When an RWP has been approved, copies will be made available to the work lead. A copy of the RWP must be maintained at the work site. The original RWP must be kept in the Radiation Protection Group (RPG) RWP files.
All personnel must have training commensurate with radiation hazards prior to performing work authorized by an RWP. EH&S Radiation Worker training is generally required. (See Section 21.4.3, Training.)
Amending an RWP
An RWP must be amended if it does not specify adequate radiological controls or maximum radiological conditions. Changes to RWPs are classified as either minor or major amendments. Minor amendments may be accomplished by "pen and ink" changes to the original RWP. Major amendments require the generation of a new RWP and require the same review and approval process as a new RWP.
Extending an RWP
The RWP Program Manager and work lead must verify the status of the project two weeks before the expiration date. If the project is not complete, the expiration date may be extended.
An extension is issued in the same manner as a new RWP and may be granted for up to one year.
Throughout the course of the RWP work, RPG staff will monitor the radiological conditions and the conduct of work in accordance with the terms of the RWP. This information will be documented in the master RWP file.
At the conclusion of the work activity, RWP closeout surveys and audits will be completed by RPG personnel. All surveys, air sampling, contamination, incidents, dosimetry results, work-site status, audits, violations, and lessons learned will be documented in the master RWP file.
Requests for an SSA must be initiated through the Radiation Protection Group (RPG).
Source Custodian Requirements
Each sealed source requiring an authorization must be assigned to a source custodian who will be responsible for it.
Procurement of Sources
The RPG must approve in writing the procurement of a radioactive sealed source. Only radioactive material authorized by an approved RPG-issued authorization shall be procured or otherwise acquired at LBNL.
Transfer of Sources
Any radioactive source coming on site must be delivered to the RPG, as with other radioactive material.
If a source is to be moved to a use or storage location not indicated on the Radiological Work Authorization (RWA), SSA, or Generally Licensed Source Authorization (GLA), the RPG must be notified to amend the authorization and assist in the transfer.
All off-site transfers must be directed by the RPG.
Interlocks and Area Monitors
As determined by the RPG, high-activity, sealed-source irradiators must have fail-safe interlocks specified to applicable standards and an area monitoring device (or devices) that continuously surveys the environment inside the irradiation chamber that is connected to the interlock system.
All irradiators must be shielded according to the direction of the RPG, with reference to prescribed standards and within the prescribed practice of ALARA (as low as reasonably achievable). Shielding must be approved before acceptance and qualified by the RPG during the first use.
Custodians of radioactive materials are responsible for the protection, control, accountability, and characterization of radioactive inventory in their custody. All losses or suspected losses of materials must be immediately reported to the Radiation Protection Group (RPG) (ext. 7277 for urgent assistance).
Custodians of nonsealed radioactive materials are required to periodically respond to a data call from the RPG for information pertaining to their inventory of radioactive materials. The following applies to all custodians of nonsealed radioactive materials (i.e., any materials other than sealed sources).
Radionuclide Primary Emission Type
RPG Approval Limit
Custodians of nuclear materials described in previous sections are subject to additional controls per federal requirements. Custodians of such materials shall request in writing permission from the RPG to create, transfer ownership, or change location or disposition of such materials. Internal transfers shall be initiated by contacting the Nuclear Material Representative (ext. 6228), completing the provided Internal Transfer Form, and returning the completed form to the Nuclear Material Representative.
In addition to the specific responsibilities detailed below, additional information is detailed in EH&S Procedure 735, X-Ray Machine Authorization Program.
X-Ray Safety Officer (XSO) and/or Backup XSO
The X-Ray Safety Officer is responsible for managing and executing the X-Ray Safety Program, including, but not limited to, the following:
X-Ray System Supervisor (XSS)
The X-Ray System Supervisor (XSS) must provide detailed written information to the XSO to assist in preparation and implementation of the X-Ray Authorization (XA). The XSS must contact the Engineering Division and request that an electrical engineer perform a system safety analysis prior to initial machine use and issuance of an XA. The XSS must ensure that the XA requirements and limits are adhered to and that good work practices are followed.
The XSS must:
X-Ray Radiation Workers
X-ray radiation workers are:
X-ray radiation workers must ensure that the XA requirements and limits are adhered to and that good work practices are followed. X-ray radiation workers must:
X-ray users are those individuals who may operate an X-ray machine while the X-ray machine is fully interlocked and in an enclosure that prevents any individual from placing any body part into an area with a dose rate in excess of 0.5 mrem/h at 5 cm from the enclosure. It is expected that the majority of X-ray users at LBNL will fit into this category. Any authorization for other than routine use must be specified in the X-Ray Machine Safety Document. X-ray users must:
Division directors, by virtue of the delegation of responsibility for all aspects of environmental health and safety through line management, must:
Manufacturers or Outside Service Representatives
Manufacturers or outside service representatives, used for installation or service of X-ray machines at LBNL, are responsible to their parent organization unless their actions are done in such a way as to cause X-ray exposure to LBNL personnel or the general public.
Manufacturers or outside service representatives who must operate an X-ray machine must:
Electrical Engineer Performing a System Safety Analysis
Electrical engineers assigned by the Engineering Division to perform a system safety analysis of an X-ray machine must:
X-Ray Machine Safety Documents
X-Ray Authorization (XA)
An XA is an authorizing document renewable at 18-month intervals in conjunction with a visit by the XSO. The XA is prepared by the XSO from information presented by the XSS in the XA application. The XA must contain at least the following:
When a new XA or a major revision to an existing XA is required, the XSS should submit an application to the XSO requesting him or her to prepare or change the XA.
Applications are to be submitted to the XSO or Backup XSO by e-mail or mail (Mail Stop 75-122). The receipt of the application will be acknowledged via telephone or e-mail to the person initiating the application. A meeting with the XSS will be scheduled by the XSO to review the draft of the XA and evaluate the facilities. For new installations, the system safety analysis must be completed first, after which a minimum of two weeks is required to establish a new XA. The request for a new XA or modification of an existing XA must contain at least the following:
An XA application guide is available from the XSO to assist in preparing the XA request. Contact the XSO at ext. 2278 to obtain a copy of the guide.
The XA application is used to prepare the XA. There is no requirement to review or revise the XA application after initial submission, unless it is requested by the XSO.
System Safety Analysis
All X-ray machines must undergo a system safety analysis as follows:
A system safety analysis must be performed by an electrical engineer and must consist of at least the following:
The Engineering Division Management, in consultation with the XSO, appoints the electrical engineer assigned to perform system safety analyses for an indefinite period. The funding for a system safety analysis is provided by recharge to the owner of the X-ray machine. Owners must be prepared to provide an LBNL account number for this service.
Interlocks and Indicators
An interlock system can provide safety by ensuring that humans and hazards do not contact each other. Interlock systems on X-ray machines must be fail-safe. The interlocking system is fail-safe if the system is designed such that all realistically anticipated failures of indicators or safety components result in a condition in which personnel are safe from exposure to radiation. For example: If a light indicating “X-Ray On” fails, the production of X-rays shall be prevented; or if a shutter status indicator fails, the shutter shall close. This usually means that the interlocking system consists of two independent interlock chains that employ two different methods to stop X-ray emissions.
All X-ray machines must meet the requirements in this PUB-3000 work process.
Override of X-Ray Safety System Interlocks
Interlocks and indicators must not be bypassed or overridden for any reason unless specifically authorized in the XA. Only specifically authorized and designated personnel may bypass or override an interlock or indicator. Such individuals must be specifically identified in the XA.
Overriding of interlocks is never allowed for routine use.
X-Ray Machine Design
All X-ray machines authorized by an XA must meet the following minimum requirements.
The X-ray machine must be located within an enclosure that is designed so that it prevents any individual from placing any body part into a primary beam within the enclosure when the enclosure is fully interlocked.
An X-ray machine that uses architectural structures other than the floor on which it may be placed as part of the X-ray enclosure (e.g., a CT scanner enclosed within a room) will be considered an enclosed X-ray machine if all access points, such as doors and windows, are fully interlocked in accordance with this procedure or permanently secured in a closed position with tamper-resistant fasteners. Prior to permanently securing doors and windows in a closed position, the appropriate EH&S personnel, such as the Fire Marshal, must be consulted. Personnel occupancy is not allowed within such enclosures during routine operations.
All enclosures must be designed to prevent access to the primary X-ray beam, by means of interlocks or in a manner that requires tools for access.
X-ray enclosures must be shielded such that the dose rate at any accessible region 2 inches (5 cm) from the outside surface of the enclosure does not exceed 0.5 mrem in any 1 hour.
If an enclosure is designed with openings, such as an open top or penetration labyrinth, the enclosure must be shielded such that the dose rate at any area accessible through the opening, without the use of tools (e.g., a ladder), does not exceed 0.5 mrem in any 1 hour.
All X-ray machines designed such that an individual can enter the enclosure without activating an interlock override/bypass mode while the X-ray machine is energized and producing X-rays must be equipped with an automatic safety shutter on each X-ray port.
Safety shutters must be designed such that the shutters’ position can be manipulated remotely from outside the enclosure as well as automatically by the interlock system. X-ray machines with automatic shutters do not require an interlock bypass/override mode of operation to gain access to the enclosure if:
X-ray machines that are equipped with a manual safety shutter or where the dose rate at any accessible region 2 inches (5 cm) from the outside surface of the X-ray tube with the shutters closed exceeds 0.5 mrem in any 1 hour will be treated as if no shutter exists. Such X-ray machines must require the activation of an interlock override/bypass mode to gain access to the enclosure if the X-ray machine is energized and producing X-rays.
All X-ray machines must be equipped with at least two independent methods to verify that X-rays are on. One, but not both, may be a current (mA) meter. Failure of one indicator must not result in the failure of the second indicator. At least one indicator must be an illuminated warning lamp with the words “X-Ray On” or similar wording. The illuminated X-Ray On indicator must be part of the interlock chain and fail-safe. A failure of this warning indictor must prevent the generation of X-rays.
All X-ray machines equipped with an interlock bypass/override system must be equipped with an audible alert that can be heard from within the enclosure and that remains activated until the bypass/override mode is disabled.
All X-ray machines equipped with an interlock bypass/override system should be equipped with a visual alert, such as a strobe or beacon, that can be seen from within the enclosure and remains activated until the bypass/override mode is disabled.
All X-ray machines equipped with safety shutters and an enclosure designed to allow access while the X-ray tube is generating X-rays must be equipped with a mechanical shutter- position indicator or a fail-safe electronic shutter-position indicator for each shutter. Each shutter-position indicator must be clearly visible from all entry points to the enclosure. In addition to the mechanical shutter-position indicator, electronic shutter-position indicators are highly recommended.
All doors and any portion of an enclosure that can be opened without the use of tools must be equipped with two interlocks that disable the X-ray machine if the enclosure is opened while the X-ray machine is producing X-rays and a safety shutter is open unless a bypass/override mode has been activated. Except for diagnostic X-ray machines designed for use in the healing arts (e.g., CT scanners), one of the interlocks but not both must terminate high voltage to the X-ray machine. The X-ray enclosure containing X-ray machines designed for use in the healing arts but authorized by an XA must have two interlock chains; however, these units typically have a single connection for the external interlocks, thus a single point for terminating X-ray production.
Any portion of an enclosure designed for routine entry that requires tools to gain access must be equipped with a single interlock at a minimum.
Enclosure walls that are not designed to be removed for routine access or maintenance and that require tools for removal do not require interlocking.
All interlock systems must be fail-safe.
All X-ray machines must be equipped with a key control that prevents the operation of the X-ray machine by untrained and unauthorized personnel.
X-ray machines equipped with an interlock bypass/override mode must be equipped with a separate key control and/or Prox key designation that controls activation of the bypass/override mode.
Prox Key Control
All X-ray machines must be equipped with a Prox key control that prevents the operation of the X-ray machine by untrained and unauthorized personnel. When a Prox key system cannot be incorporated directly into an X-ray machine’s interlock system, the X-ray machine must be located within a room with Prox key access control. All personnel who are granted access to the room must be trained and authorized X-ray users.
Open Beam Operation
Occasions may arise, such as when performing primary beam alignments, that require an X-ray radiation worker to bypass/override the interlock system to gain entry into an X-ray enclosure while the X-ray tube is energized and the safety shutter is open. Prior to performing open-beam operations, the following conditions must be met:
In addition to the above requirements, the X-ray machine should:
Posting of warning signs and labels must be in accordance with EH&S Procedure 709, Radiation Protection Posting, Labeling and Access Control.
All posting and labeling requirements will be specified in the applicable XA by the XSO.
All X-ray machines are controlled items, requiring complete property management accountability records.
All X-ray machines should have a User's Logbook located near the machine, and a Maintenance Logbook. As applicable, the User's Logbook must be used as directed in the machine-specific XA to record specified information. The following information is recommended:
All notifications of suspected machine abnormalities must be noted and addressed in the logbook.
The XA defines the requirements for when whole-body optically stimulated luminescence (OSL) dosimeters and/or finger ring dosimeters for X-ray radiation workers are to be worn. Specifically, finger ring dosimeters must be worn whenever engaged in interlock bypass/override operations.
Users of X-ray equipment who are required to be monitored for radiation exposure must properly wear appropriate personnel radiation dosimeters supplied by the RPG Dosimetry Office.
Because of the low-penetrating nature of X-rays, whole-body OSL dosimeters, when required, must be worn on the side of the body facing the X-ray equipment, at the level of the X-ray beam, and outside all clothing. The XSO (ext. 2278) or the Dosimetry Office (ext. 7497) should be consulted regarding proper use of personnel dosimeters.
Dosimeters are optional for X-ray users and X-ray radiation workers when they are performing routine work with a fully enclosed and interlocked X-ray machine.
Radiation Safety Surveys
All X-ray machines must have a radiation safety survey performed by the RCT upon installation but before regular use, at least once a year for machines in active use, and upon start-up of machines that have been removed from service. In addition, all X-ray machines must have a radiation safety survey performed:
To supplement these major surveys, the XSS for analytical equipment may spot-check the X-ray machine for radiation leakage.
Routine Interlock Testing
The XSS is responsible for ensuring that X-ray machine safety systems are tested at the intervals specified in the system safety analysis. This interval is usually six months and is specified in the XA. The XSS may allow an authorized X-ray radiation worker listed in the XA to perform the interlock tests. Interlock testing must be in accordance with the routine Interlock Testing Protocol Checklist established as part of the system safety analysis.
The completion of interlock testing must be documented using the routine Interlock Testing Protocol Checklist established in the system safety analysis. The checklist must be signed and dated by the XSS or designated X-ray radiation worker and sent to the XSO. A notation of findings and action taken must also be included. A copy of the completed and signed checklist must be filed in the appropriate section of the X-Ray Radiation Journal (XRJ) and the original sent to the XSO for filing in the RPG X-ray files.
All modifications to X-ray generating systems must have the prior approval of the XSO. Modifications affecting the safety or interlock system will require a new system safety analysis and amendment of the XA.
Only authorized X-ray users who are properly trained and listed in the applicable XA are allowed to use X-ray machines. To prevent unauthorized use, each X-ray machine must be controlled with a key control and the institutional access control system referred to as "Prox key access.” Prox key access may be controlled at the entrances to the room containing the X-ray machine when the Prox key system cannot be connected to the interlock system.
General Employee Radiological Training (GERT)
All personnel performing work within a Controlled Area for Radiation Protection (Controlled Area) must have successfully completed General Employee Radiological Training (GERT) (EHS0470) and the GERT exam. Training is valid for two years following the completion date.
All X-ray users must complete EHS0475, Radiation Protection, X-Ray Awareness Training, an online course that allows for an LBNL Lightweight Directory Access Protocol (LDAP) or non-LDAP log-in. Users who use a non-LDAP log-in are encouraged to provide as much of the requested log-in information as possible, including a valid e-mail address. Training is valid for two years following the completion date.
X-Ray Radiation Workers
Advance planning may be required to ensure training classes are available for all XSSs and X-ray radiation workers. All XSSs and X-ray radiation workers must demonstrate satisfactory completion of Radiation Worker I (RWI) training consisting of EHS0471, Radiation Protection, Radiation Worker I, Part 1 . In addition to completion of RWI training, X-ray radiation workers must complete EHS0475, Radiation Protection, X-Ray Awareness Training. Training is valid for two years after the completion date.
On-the-Job Training (OJT)
All X-ray users and X-ray radiation workers must receive OJT from the appropriate XSS or designee for each X-ray machine they use.
At a minimum, OJT must include proper job-specific procedures for radiological safety including:
OJT must be documented and signed by the individual who provided the training and the individual who received the training. Documentation of OJT must be filed in the appropriate section of the XRJ.
Escort in Lieu of Training
Personnel performing work in accordance with this procedure may be exempted from the training requirements under the following conditions:
A radiation survey meter with appropriate energy response characteristics to serve as an X-ray detector should be used frequently to monitor for scattered radiation when working in an interlock bypass/override mode. In addition, a fixed Geiger-Mueller or ionization-type (active) area monitor is required for analytical X-ray machines equipped with an interlock bypass mode. All other X-ray machine installations will be evaluated for the need to use passive (OSL dosimeter) area monitors.
Except as noted previously in this PUB-3000 work process, newly installed X-ray machines must not be operated without prior XSO approval and performance of a system safety analysis. An approved XA must also be in place. Therefore, it is strongly advised that the XSO be consulted while the installation is still in the planning stage to review requirements such as shielding, interlocks, and safety devices.
X-Ray Machine Classifications and Specific Supplemental Requirements
Analytical X-Ray Equipment
Analytical X-ray machines are classified into two types:
The definitions of these terms are contained in ANSI N43.2, Subsection 6.2.1, Classification.
The classification of enclosed-beam X-ray systems includes X-ray diffraction, X-ray fluorescence, and cabinet X-ray systems that meet the specifications in this PUB-3000 work process when operated in the fully interlocked mode.
The classification of open-beam X-ray systems includes all X-ray systems that do not meet the requirements in this PUB-3000 work process and all enclosed-beam X-ray systems operated in an interlock bypass/override mode.
In all cases, first consideration and effort must be given to making a system meet the requirements of an enclosed system. Approval to use an open-beam X-ray system is handled as a variance.
Portable X-Ray Equipment
Portable X-ray equipment presents particular hazards due to its flexibility of use and therefore must be used more carefully. Extra caution and awareness of beam orientation and the location of personnel in the vicinity of the X-ray machine are essential.
The following specific provisions are required for portable X-ray generators:
Additionally, a reliable audio indication that X-rays are being generated should be provided.
Diagnostic X-Ray Equipment
Medical diagnostic equipment safety is described in NCRP Report Nos. 102 and 49.
All diagnostic X-ray installations must, if possible, have a light outside the room that indicates when the X-ray control unit is energized and when X-rays are being produced. (A Rotor On indicator will suffice for the X-Ray On indicator.) These lights must be fail-safe or redundant. Furthermore, they must be positioned and labeled so that their presence and meaning are obvious.
When an emergency arises, use the SWIMS concept. The SWIMS concept will help you remember the proper actions to take during an emergency. SWIMS stands for:
S Stop and Think. Stop Working. Stop the Spill.
Assess the situation:
W Warn others.
I Isolate the area.
M Monitor yourself carefully and completely.
S Stay in or near the area until help arrives.
Reporting an Emergency
Suspected Radioactive Contamination to Personnel or an Area
Injured Personnel With Suspected Radioactive Contamination
Avoid moving the victim if possible. Weigh the risk of moving the victim against the risk of potential exposure.
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