Re: Hot Spot Exemption

["Rima, Steven D" <SDRIMA@saix367.sandia.gov>]

     Linda,
     
     See Article 412 2.h. in the DOE RCM. It specifically exempts nuclear 
     weapon components from radioactive material labeling requirements. I 
     believe this covers your specific situation. Also keep in mind that 
     10CFR835 defines no such posting; the Posting and Labeling 
     Implementation Guide in IV.A. states "Nuclear weapon components are 
     not required to be individually labeled as radioactive material..."
     
     
     
     **********************************************************************
     
     Steven D. Rima, CHP
     sdrima@sandia.gov
     standard disclaimer...
     
     **********************************************************************


______________________________ Reply Separator _________________________________
Subject: Hot Spot Exemption 
Author:  radsafe@romulus.ehs.uiuc.edu at CCSMTP
Date:    8/14/95 4:46 PM


Radsafers:
   At the DOE Pantex Plant, our mission is to disassemble/assemble
nuclear warheads.
   According to the DOE Radiological Control Manual Article 234, hot
spots shall be posted for localized sources that are 5 times general 
area dose rate and greater than 0.1 rem/hr.  The localized source in 
a nominal warhead is a "hot spot" per the DOE definition.  However, 
isn't the intent and spirit of the Order of "hot spots" applicable to 
crud/buildup in piping, process equipment, etc.. places where it is 
not "designed or engineered" to be.  Our warhead sources are designed 
and engineered to meet or exceed "hot spot" dose rates.  Therefore, 
the question is:  Would not our warhead sources be candidates for an 
exemption to the "hot spot" regulation?
     
Linda Vickers
Health Physicist
Pantex Plant