[ RadSafe ] Incidental Radiation Generating Device Leakage Radiation Limits

Wed Sep 5 16:33:59 CDT 2012

John:

I am pleased to have wowed you!

I referenced the OLD DOE manual because I was not able to readily find the 
most recent manual online yesterday.  After a bit more digging, I was able 
to locate the following:

DOE STANDARD: RADIOLOGICAL CONTROL (DOE-STD-1098-99), July 1999
http://www.orau.org/ptp/PTP%20Library/library/DOE/Misc/Radiological_Control_Standard.pdf

DOE O 420.2C, Safety of Accelerator Facilities (2011)
https://www.directives.doe.gov/directives/0420.2-BOrder-c/view

Article 365.3 in the 1999 DOE Radcon manual is the same as in the 1994 DOE 
Radcon manual, that article leaves the establishment of radiological 
controls for such devices to line management AND the Radiological Controls 
Organization (RCO) (DOE, p. 3-24, pdf p. 75/189).  The policy also remains 
substantially the same.

The DOE order O 420.2C (2011) defines what constitutes and accelerator. An 
electron beam welder would fall under the definition of an accelerator. 
This order appears to still leave determination of the device exposure 
limits to management and the RCO.

FDA purview:

Compliance Guide for Cabinet X-Ray Systems
http://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/ucm094358.htm

The FDA does not appear in the above guide or 21CFR Subcahapter J to 
provide any specific or general guidance regarding leakage radiation 
limits for devices such as electron microscopes or electron beam welders.

Applicability of State regulations to the B&W Y-12 or other DOE site - 
State radiological health regulations, though possibly useful as a guide, 
might not be applicable at DOE sites or operations.  Such sites are often 
considered federal enclaves or exclusive federal jurisdictions.  Assuming 
the device is actually located in Tennessee at a DOE site or operation, 
and that the device is an electron beam welder, the following Tennessee 
rule could be applicable or used as guidance, since an electron beam 
welder appears to meet the definition of an accelerator in the rule

CHAPTER 0400-20-09, REQUIREMENTS FOR ACCELERATORS
http://www.tn.gov/sos/rules/0400/0400-20/0400-20.htm

The above rule does not provide any specific or general guidance regarding 
leakage radiation limits for an accelerator device.  The guidance or 
requirements provided as to permissible radiation levels in the 
accelerator facility appear to be less stringent (2 mrem or 10 mrem, 0.02 
mSv or 0.10 mSv) in any one hour) than those in ANSI N43.3 for an Exempt 
Shielded Installation (0.5 mrem or 0.005 mSv in any one hour).  The ANSI 
N43.3 radiation level criteria for an Exempt Shielded Installation appears 
to be a reasonable and feasible leakage radiation control limit for 
devices such as electron microscopes and electron beam welders, especially 
if the available data for these devices (i.e. manufacturer's data, site 
survey data, etc.) indicate reasonable entitlement for this control limit.

Henry

Boyd H. Rose, CM, CIH, CHMM, EI
Sr. Safety and Environmental Engineering Specialist
Corporate Radiation Safety Officer
General Dynamics Land Systems
38500 Mound Road
Mail Zone 436-10-75
Sterling Heights , MI 48310-3269
Tel: 586 825 4503
Fax: 586 825 4015
E-mail: roseb at gdls.com

"Dixon, John E. (CDC/ONDIEH/NCEH)" <gyf7 at cdc.gov> 
Sent by: radsafe-bounces at agni.phys.iit.edu
09/05/2012 01:17 PM
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Subject
Re: [ RadSafe ] Incidental Radiation Generating Device  Leakage Radiation 
Limits

Wow! That's the first time in a long time I have seen a reference to the 
OLD DOE (Admiral Watkins) Radcon Manual! I am not certain if this topic is 
addressed in newer DOE regulations. The leakage levels in question may be 
addressed by certain TN State regulations (series 1200***), but these 
would be noted as radiation boundary levels, not allowable leakage. The 
ANSI standard N43.3 might be best used here (it is one of many developed 
for homeland security applications). 

For these kinds of radiation generation devices, some NCRP's might be of 
use. In particular, NCRP 20 (for cargo scanning systems) might be 
applicable. I would also try NCRP-147 or 144. Look for the same key words: 
exempt, shielded, or as installed facility. 

I would also research the purview of the Food and Drug Administration. If 
you go their home page and search for ionizing radiation devices 
manufactures standards, you might find this leakage limit as applicable 
prior to the device being purchased for such uses. Non-ionizing radiation 
generating devices, such as commercial microwave ovens, are included under 
the FDA's responsibilities. 

Hope this helps.

Regards,
John E. Dixon, CHP

-----Original Message-----
From: radsafe-bounces at health.phys.iit.edu [
mailto:radsafe-bounces at health.phys.iit.edu] On Behalf Of roseb at gdls.com
Sent: Tuesday, September 04, 2012 10:03 AM
To: The International Radiation Protection (Health Physics) Mailing List
Subject: Re: [ RadSafe ] Incidental Radiation Generating Device Leakage 
Radiation Limits

Randy:

Reference U.S. Department of Energy Radiological Control Manual, 
DOE/EH-0256T, Revision 1 (1994), 
https://www.orau.org/PTP/PTP%20Library/library/DOE/Misc/doe_rcm.pdf .

The DOE appears to have recognized the absence of specific federal 
radiological health standards for certain devices in their Radcon Manual 
(1994), and referred management and the RCO to applicable ANSI standards. 
As you are aware, in the case of devices such as electron microscopes and 
electron beam welders, Article 365.3 leaves the establishment of 
radiological controls for such devices to line management AND the 
Radiological Controls Organization (RCO) (DOE, p. 3-29, pdf p. 93/220).

Given the absence of a specific federal standard for the devices under 
consideration, and, given that the location where the devices are operated 
is likely a federal enclave or exclusive federal jurisdiction with respect 
to state radiological health regulations (state regs might not apply), 
your reference to the ANSI N43.3 Exempt Shielded Installation criteria 
dose equivalent limit of 0.005 mSv (0.5 mrem) in any one hour at any 
accessible area 5 cm (2 inches) from the outside surface of the enclosure 
(N43.3-2008, para. 5.1.10, p.9, pdf p. 18/79) appears to be a reasonable 
and feasible radiological control measure that is consistent with the DOE 
Radiological Health and Safety Policy (DOE, p. i, pdf p. 3/220).

Henry

Boyd H. Rose, CM, CIH, CHMM, EI
Sr. Safety and Environmental Engineering Specialist Corporate Radiation 
Safety Officer General Dynamics Land Systems
38500 Mound Road
Mail Zone 436-10-75
Sterling Heights , MI 48310-3269
Tel: 586 825 4503
Fax: 586 825 4015
E-mail: roseb at gdls.com

"Redmond, Randy (RXQ)" <redmondrr at y12.doe.gov> Sent by: 
radsafe-bounces at agni.phys.iit.edu
09/04/2012 07:25 AM
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Subject
[ RadSafe ] Incidental Radiation Generating Device Leakage      Radiation 
Limits

Does anyone know a citation for federal leakage radiation limits for 
incidental radiation generating devices such as electron beam welders and 
electron microscopes? I have searched and cannot find any.  As a default, 
I'm using ANSI N43.3 Exempt Shielded Installation criteria of 0.5 mrem at 
5 cm.

Thanks,

Randy Redmond
B&W Y-12
Radiological Engineering
865.574.5640

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