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Re: Definition of a Field Site



Note:  I tried to reply to this directly, however the mailer returned it to me.
So I'm posting to the RadSafe to get the message back.

Jim Barnes, CHP
RSO
Rocketdyne Division, Rockwell Aerospace
----------------------------------------------
Dear Barry,
> 
> California defines by exclusion:
> 
> For X-radiography, "cabinets" and "shielded rooms" are defined (Title 
> 17.30336(a) & (b).  "Field radiography" is defined as "all radiography other 
> than cabinet radiography and shielded room radiography."  Cabinets and 
> Shielded Rooms are (by definition) required to be shielded, interlocked, etc. 
> Thus, if they aren't, then one is in a "field" situation (requiring more 
> training, surveys, logkeeping, etc.).
> 
> For source radiography, a "permanent radiographic facility" is defined 
> (17.30331).  If one is using a permanent radiographic facility, then he is 
> granted relief from several administrative controls (30.30334).  Otherwise, 
> one is in a "field" situation.
> 
> Regarding the "field" vs. facility issue, California has no explicit time 
> requirements to my knowledge.  It is typically addressed as a licensing 
> stipulation that expands or limits the scope of the regulatory language.  
> Controls on field locations are generally much more onerous than at a "fixed 
> site."  One is induced by the level of regulatory stipulations (not by fixed 
> time definitions) to maintain field sites only as long as needed.  They're 
> too much hassle.
> 
> Well logging defines "temporary jobsite" as "a place where licensed 
> radioactive materials are prsent for the purpose of performing well logging 
> or subsurface tracer studies."
> 
> Generally, I would suggest that the approach of "if it's not (one of a list 
> of possibilities), then it's field" is probably the most inclusive and 
> workable way to define it.
> 
> Jim Barnes, CHP
> RSO
> Rocketdyne Division; Rockwell Aerospace
> ------------------------------------------
> > Definition of a Field Site
> > 
> > For such purposes as industrial radiography, borehole logging etc., 
> > radioactive sources and x ray equipment may be used at many varied 
> locations.
> > Under Western Australia's Radiation Safety Act,both the radiation
> > producing equipment AND the premises where it is used must be registered
> > (sometimes known as owner licensed).
> > 
> > `Field sites' need to be defined. After all, how long can radioactive
> > substances be kept at any one location before a `field site' is considered 
> > `permanent'?
> > 
> > Does anyone know of any legal definitions that tackle this problem,
> > either for radiation use as in this case, or in any other relevant areas?
> > 
> > Barry Cobb
> > 
>