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Re: 10CFR19 training requirement



I have always felt that the area definitions should have a hierarchy going
from higher hazard to lower hazard to allow the radiation protection program
to be consistent with the level of hazard.  For example,

Restricted areas: Areas within controlled areas with significant potential
for exposure.
    *  Very high rad, high rad and rad areas.
     * Airborne radioactivity areas.
     * Any areas where doses are likely to exceed 10% of limits (individual
monitoring is required).

Controlled areas: Areas established for radiation protection purposes with
low potential for exposure.
     * Areas where doses are likely to exceed 100 mrem/yr or which contain
quantities of material which would require posting--90% or more of academic
research labs would fit into this category.

Uncontrolled areas--onsite: Areas with 100 mrem/yr TEDE dose limit and no
material which requires posting.

Uncontrolled areas--offsite: Areas where EPA limit of less than 100 mrem/y
TEDE may be in effect if established.

The training requirements could vary with the type of area and hazard
within.  Assignment to a restricted area would require more training than
assignment to a controlled area.  Visitors in restricted areas should have
some training, which could be very short for tours (a few minutes at the
start).  Short term visitors in controlled areas would not need any training.

Frank E. Gallagher, III, CHP
RSO, Univ. of California, Irvine   92717-2725
Voice: (714) 824-6904, Fax: (714) 824-8539
E-mail: fegallag@uci.edu