Restricted Areas

[10525kfb@ibm.cl.msu.edu (Kristin Erickson)]

Hello, Radsafers:

I have recently gained some information "from the mouths of the NRC" on
this topic, and perhaps sharing the comments will help shed some light on
this very slippery subject.  The definitions are clear.  And according to
the definitions in the Revised 10 CFR 20, we happily chose originally
(beginning in 94) to call our research laboratories in this large public
teaching and research institution Controlled Areas.  We do have all of the
requirements in place for the restricted areas; that is, badging, training,
surveys, records, waste management, security, and all of that long list.
For contamination and release limits, as part of our ALARA program, we
teach and enforce unrestricted area contamination limits.

During a recent discussion with the NRC Region III inspections chief, we
were told that we should not call those areas controlled areas.  The
controlled area was defined in the law only for certain areas at reactors,
and were not intended by the NRC for other areas.  In fact, he said, there
are virtually no laws whatsoever for controlled areas, and "NRC could sit
and write violations all day for licensees who call radioactive use areas
controlled areas".  He said the NRC may remove the controlled area
definition from the law.

Basically, our discussion centered around who should be trained, and how,
in the radioactive use areas.  Radiation workers (whom we consider to be
those who actually use RAM) of course are trained by our office and by the
principal investigator (PI).  Those who work in the lab but do not handle
RAM now must be trained by the PI.  This training incorporates the things
in 10 CFR 19 as they pertain to people working in an area where RAM is
present and used.  We developed a checklist for principal investigators to
use and keep on file in the lab. safety record books.  It is a one pager,
in checklist form, has instructions for the PI, and is signed by both the
PI and the worker.  It serves as an informed consent also.  This has been
very useful; it is simply a uniform, easy and effective way that we chose
internally to document PI training of workers in radiation safety.

A more serious problem related to restricted areas it the requirement for
security.  Most all of the public teaching and research institutions are in
a difficult position with that requirement.  But that's a different topic
for discussion.

The upshot of this post is:

Radiation use, storage and disposal areas should be managed as restricted
areas, according to the NRC.

Controlled areas are not for use in areas where radioactive materials are
present, and may lead to violations.

People who "frequent" (meaning they are in the area frequently) the
restricted areas must be trained in 10 CFR 19 inasfar as their functions
necessitate.  All individuals who frequent the restricted area share
responsibility for security and the other aspects of radiation safety that
"come with the turf", and resultantly, should be aware of these
responsibilities and trained accordingly.

People who visit (seldom there) the restricted areas are members of the
public, and must be escorted while in these areas.


If anyone is interested in a copy of the training checklist we use, let me
know.  I will be happy to share it; if enough of you want it, I'll post it
on RADSAFE.

There!  I'm done expostulating for today!  Hope this is helpful.  Have a
good weekend, everyone.

Kristin


All comments herein contained are my own opinions and/or experiences and
are not necessarily those of my employer or institution.

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Kristin Erickson, Radiation Safety Officer
Office of Radiation, Chemical and Biological Safety
C124 Research Complex-Eng.
Michigan State University
East Lansing, Michigan 48824
Telephone: (517) 355-5008   Fax: (517)353-4871   Email: 10525kfb@msu.edu
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