RECORD ID D95-09-005

STANDARD NUMBER

INFORMATION DATE 05-31-1996

SUBJECT Radiological Posting Requirements

QUESTION

The following request was faxed in to the Response Line: 1. Paragraph 835.601(a) under general requirements for posting and labeling (subpart G) states: "Working areas that require posting because of the presence of, or potential presence, of radiation and/or radioactive materials are delineated in the subsequent paragraphs of this section." Subsequent paragraphs addressing Controlled and Airborne Areas obviously require posting when potential conditions exist while all other referenced paragraphs for radiological areas (i.e., Radiation Area, Contamination Area, etc.) imply posting only when actual radiological conditions exist. Some individuals have interpreted paragraph 835.601(a) to mean that a location shall be posted as a radiological area anytime a potential exists for radiological conditions to occur independent of the actual measured conditions. For example, it has been suggested that a "clean" laboratory containing a glove box should be posted as a Contamination Area since the potential exists for contamination to escape into the room. Similarly, it is suggested that a maintenance/repair activity involving a potential for contamination shall be posted as a Contamination Area even though contamination might not be present during the job. It is the contractor's interpretation of 835.601(a) that except for controlled and airborne areas, potential radiological conditions do not need to be posted as radiological areas until such conditions actually exist. 2. The second question also involves radiological posting expectations and requirements related to maintenance/repair activities where there is a potential for contamination and concerns the temporal aspects of posting requirements in respect to discovery of radiological conditions and cleanup. If the potential hazards and necessary controls for a job are clearly identified per RWP or other work document, is it necessary to immediately post a job location as a radiological area if well-managed, transient radiological conditions unexpectedly arise? For example, during a glove box change, contamination is sometimes temporarily exposed on glove attachment ring but is either quickly decontaminated or again covered with installation of the new glove. Another example might be the removal of a sanitary trap beneath a sink where contamination is detected inside the pipe but is quickly isolated by sealing the ends of the pipe. Or perhaps during the course of disconnecting a piece of equipment, a few spots of contamination are detected upon the floor covering or worker's surgeons gloves. In all cases, the contamination is cleaned up, surveyed, and ensured to be clean relatively soon and prior to the completion of the job. At our facility, we have historically posted such activities as "hot job exclusion areas" abating a potential for contamination (along with posting of the RWP) to avoid undesirable over posting a Contamination Area since contamination might not arise. Under such circumstances when contamination does arise, is it necessary to immediately repost as a Contamination Area since the contamination will be controlled and cleaned up relatively quickly? The second sentence of 835.601(a) states "radioactive items or containers... shall be individually labeled if adequate warning is not provided by control measures and required posting." Assuming that adequate controls are identified by the work documentation, and that radiological posting is not immediately required if the contamination is contained and/or decontaminated in a reasonably short time frame, is it a reasonable interpretation to assume that radiological posting would not be strictly required? A related question is the case when a spot of contamination is found during a routine survey. Again, if the contamination is cleaned up relatively quickly, is it necessary to post the area as contaminated? Is this a non-compliance with 10 CFR 835 since the area was not correctly posted at the time the spot was found? Finally, if Contamination Area posting is interpreted as being required for any of the above examples, are the concomitant requirements for a Contamination Area also required? That is the need for a surrounding Buffer Area, contamination levels included on the posting, equipment release documentation, etc. also required?

REGULATORY REVIEW

QUESTION 1 RESPONSE: Because 10 CFR 835 is result-oriented instead of prescriptive, with a few notable exceptions, alternative approaches are often possible. The contractor is correct that there is no absolute requirement for posting for potential radiological conditions except for posting of controlled areas and airborne radioactivity areas; however, good practice requires a graded approach to area posting. If good radiological control practices cannot prevent the spread of contamination outside current boundaries and into a limited surrounding area, posting may also reduce the occurrence-reporting requirements. Although similar arguments can be used for posting of potential radiation areas, prediction of radiation conditions is usually more accurate. Interim US Department of Energy Implementation Guide G-10 CFR 835/G1, Rev 0, December 1993, "Posting and Labeling for Radiological Control," provides guidance on posting for likely radiological conditions. Section IV.B, paragraph 12, states in part: "In many operations, the likelihood that a radiological condition will exist, rather than the actual condition, will define the boundaries and posting of a Radiological Area. For example, opening a contaminated ventilation system in an uncontaminated area would require a Contamination Area to be established, or opening a radiological vacuum cleaner in a contamination area may require that an Airborne Radioactivity Area be established." Note that this is nonmandatory guidance unless G-10 CFR 835/G1, or this provision from it, has been incorporated into the contractor's radiation protection program required by 10 CFR 835.101(a). Since it is impossible to address all potential issues and gradations of potential radiological conditions, it is best to specify that the contractor will rely on the radiological control organization to address posting for routine questions of potential, and to refer the few questionable issues (e.g., cases where posting might not conform to the ALARA principle) to a health physicist certified by the American Board of Health Physics (ABHP). The answers to the examples cited in the question are merely illustrative of the logical process that a health physicist would use in deciding specific cases. In the case of a radiochemical glovebox in an uncontaminated room, the radiological control organization could readily conclude that there is no need to post the room, or a portion of it, as a contamination area for routine operations. It would be prudent to post the room during glove changes or other conditions with the likelihood of contact between glovebox air and the room atmosphere. In the case of maintenance or repair that could result in contamination (i.e., a source of contamination is determined to be at risk of release), the radiological control organization would likely conclude that the routine response would be to post the surrounding area as a contamination area. This decision would be based not only on the possible uncovering of contamination on the equipment but also on the probability that, without the posting, workers without the appropriate training and expertise in contamination work would become involved and cause or increase the spread of contamination. It is DOE's position that there is no regulatory requirement for posting for potential radiological conditions except for posting of controlled areas and airborne radioactivity areas. Good radiological control practice necessitates posting beyond the regulatory requirements, and the contractor's radiation protection program should address such posting. DOE may permit the contractor to specify that decisions on posting for specific potential radiological conditions are made by the radiological control organization with advice from an ABHP-certified health physicist. QUESTION 2 RESPONSE: Each of the several parts to this question will be answered separately when possible; however, some of the parts are interrelated, and a full answer may require reading the total response. Question # 2 first asks: "if the potential hazards and necessary controls for a job are clearly identified per RWP or other work document, is it necessary to immediately post a job location as a radiological area if well-managed, transient radiological conditions unexpectedly arise?" The same question appears in a slightly different form as: "under such circumstances when contamination does arise, is it necessary to immediately repost as a Contamination Area since the contamination will be controlled and cleaned-up relatively quickly. First, one should note that the conditions posed in the question are not compatible: an RWP that clearly identifies potential hazards and necessary controls for a job should identify the need for posting if contamination is likely. 10 CFR 835.603 makes it clear that having other controls and plans for dealing with contamination does not eliminate the requirement for appropriate radiological posting. If needed radiological safety controls are implemented, response to remove contamination and eliminate conditions that lessen radiological safety for workers should not be delayed to provide area posting; however, if contamination clean-up does not occur essentially as quickly as the area could be posted, posting is required whenever contamination is discovered. A similar response would be appropriate if a radiation source was accidentally uncovered and increased the radiation-dose rate in an area to a level above that required for posting. The question in reference to the second sentence of 10 CFR 835.601(a), is whether a reasonable interpretation is that radiological posting is not strictly required if adequate controls are identified by the work documentation and if radiological posting is not immediately required if the contamination is contained or cleaned up in a reasonably short time. Except under the conditions addressed in the previous paragraph, 10 CFR 835.602 requires radiological posting. The referred-to labeling of individual items or containers is a supplementary measure when posting and other controls are not adequate. This condition might occur if a small radioactive item or material container presented the major radiological hazard in a posted area of generally lower hazard. Now, with respect to the question concerning required actions relative to posting upon finding a spot of contamination outside a contamination area during a routine survey. A separate question is if finding a spot of contamination outside a contamination area during a routine survey is a noncompliance with 10 CFR 835. Although this circumstance would be an occurrence if the contamination level qualified under DOE Order 5000.3B, a single incident or even a few isolated occurrences do not constitute noncompliance with 10 CFR 835 unless the occurrence is extraordinarily serious. The final question is whether concomitant requirements for a contamination area become necessary if posting is required by any of the events postulated in the previous questions. Specific questions include the necessity for establishing and posting buffer areas, displaying contamination levels on posting, and providing and maintaining documentation for equipment released from a radiological area. 10 CFR 835.1101(d) and the discussion of public comments on this section leave no doubt that the requirements for documentation apply; however, one should use reason in applying the requirements. Normal radiological survey records kept for clearing a contamination area appear to satisfy the criteria specified in 835.1101(d) if the equipment is kept in the immediate controlled area. If the equipment is transferred to another controlled area, the equipment should have a label or tag for identifying it and connecting its history to the survey record. 10 CFR 835 does not have requirements for buffer areas or for listing contamination levels on the posted sign; however, it does permit changing the posted signs to include such relevant information. G-10 CFR 835/G1, Rev 0, provides nonmandatory guidance in section III.C concerning buffer areas and in section IV.B concerning posting of contamination levels or expected contamination levels. It is DOE's position that a valid RWP does not obviate the requirement for radiological posting when it would otherwise be required. One purpose of an RWP is to aid one in recognizing potential radiological conditions and taking required actions which might include posting. It is DOE's position that the circumstance under which a contractor discovers radiological conditions requiring posting do not change the requirements for posting. However, when removal of radiological conditions using controls recommended by the radiological control organization would require no longer time than would posting, posting should be omitted in favor of removal, e.g., decontamination. It is DOE's position, however, that intent to remove radiological conditions in a short time does not eliminate posting requirements. It is DOE's position that a single incident or a few isolated incidents of conditions that do not meet the requirements of 10 CFR 835 do not constitute noncompliance with the regulation. However, a radiological control program that does not address control of such incidents, and corrective actions if they occur, would be a noncompliance. The contractor should follow established DOE programs for reporting and correcting isolated incidents involving loss of radiological control.