Re: restricted area == rad prot prog

[jgbarnes@ix.netcom.com (JAMES BARNES)]

I have some thoughts regarding your discussion. 

You wrote:

>So what this train of thought leads to is:

>If an area meets the definition of a restricted area that is where you 
>must have a radiation protection program, and it is the ONLY area where 
>such a program is required.

	Maybe this, in a strict sense, is true for a radioactive 
materials operation, but it is not necessarily true for areas utilizing 
radiation producing equipment.  In our state (California) training is a 
specific requirement for users of such devices.

	Also, "employee awareness" programs are appearing where such 
training could be required, even though the individual may not enter a 
restricted area.  This would be based on the individual's needing to be 
made "aware" of the hazard, even though he/she would not be routinely 
exposed to it.

	Philosophically, I have a problem with "area based" 
training approach as training is designed to produce a desired behavior 
in the user.  I may want that behavior inculcated in people who do not 
enter the restricted area, but who could definitely impact radiological 
safety (e.g., managers, planners, engineers, etc.).  In other cases 
(for users of small quantity check sources, for example), I may not have 
a formal "restricted area" established, but expect the individual to 
know exactly what to do with the material so it is used in a safe 
manner.

>
>Hence (to return to my previous comment about training) the training
>requirement is most appropriately linked to the restricted area 
>concept.

	(See above).  Personally, I think it is most appropriately 
linked to the activity the person is performing.  Generally, these 
activities would be performed in the restricted area, but not always.  
"WHAT is the person doing?" is almost always senior to WHERE is he doing 
it.

>
>Note that 'access is limited' can mean the most minimal sort of limit, 
>e.g., stopping to read a sign imparting mandatory information.  It does 
>not have to mean barriers or physical controls on access, although 
>NucPwr facilities usually think along those lines.  Materials licensees 
>certainly do not.

	Coming from a power reactors background, "access is limited" has 
a much more onerous tone that reading a posted sign.  It means that one 
has a positive method of some type (administrative or physical) that 
prevents unauthorized personnel from entering the area.

	Now working in a "materials licensee" program, I still require 
something more than a sign to limit access.  At a minimum, we would 
impose a "locked or guarded" control on areas containing radioactive 
materials or X-ray equipment; and we quickly scale up from there as the 
hazard increases.

>
>I have seen and heard words from NRC types that interpret restricted 
>area in a much more restrictive fashion, e.g., just where you have 
>Radiation Areas, HRAs, etc.  I have also seen them interpret the phrase 
>'limit access' in a more strict fashion, e.g., forceable barrier 
>(albeit in the context of interpreting 'Controlled Area').
>
	I addressed this in my discussion immediately above.  Where this 
gets really difficult is when you are required to limit access against 
personnel who are intent on gaining unauthorized access (as opposed to 
inadvertent access).  This area has never really been clarified, and has 
led to lots of money being spent trying to prevent people from breaking 
into high radiation areas.

>But the above discussion is attractive (a least to me) because it links
>the basic definition of restricted area to what the rad prot program 
>covers in terms of controlling occupational dose.  Occupational dose 
>that occurs outside a restricted area, and hence outside the coverage 
>of the rad prot program, is another can of worms linked to the 
>deficient definition of occupational dose.  If the dose occurs outside 
>the area covered by the rad prot program, and hence outside the 
>Justification and Optimization processes of the licensee, how can it be 
>classed as dose subject to the occupational dose limits?

	I'm not sure I agree with the premise that "occupational dose" 
is defined deficiently.  You get the dose in a "restricted area," 
it's occupational (that does me some favors, especially regarding 
limits).  You work with radioactive materials or x-ray equipment, its 
occupational dose (that just seems logical).  Granted there is some hazy 
grey in there (yeah, I know, "black and white viewed too far away"), but 
in my experience, these issues have not been very difficult to resolve 
in the workplace.


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Anyway, thanks for bring the issue up.


Jim Barnes, CHP(PR)
Radiation Safety Officer
Rocketdyne Division, Rockwell Aerospace