Re: Controlled Areas

[fegallag@uci.edu (Frank E. Gallagher, III)]

Kent Lambert wrote, in part:
>
>Once again I'm confused.  I don't understand the concept of a controlled 
>area, specifically as it applies to university/hospitals.
>
I have always considered this particular part of the revised 10 CFR Part 20
as one of its most illogical sections.  I guess the answer is that it was
written for power plants, and for research users of 25 years ago, not the
vast majority of small-scale radioisotope users today.  However,
universities/hospitals and other licensees can utilize the concept of
controlled areas to our advantage.

It seems to me that we need to adopt procedures that describe a wide range
of possible radiological controls that can be placed on an operation
involving radioactive materials or x-ray machines (since many of our
agreement states also regulate radiation-producing machines), based on the
relative hazard.  A controlled area would be used at the lower end of the
hazard (e.g., most university labs these days).  Warning signs and locked
doors when labs are not occupied, with routine monitoring and radiation
safety surveillance, may be all that is necessary.

For restricted areas--radiation areas, high radiation areas, etc. (e.g.,
places where someone could receive actual significant doses) additional
radiological controls would be implemented to keep doses both below the
limits and ALARA.

Too bad the NRC did not define controlled areas as areas with access limited
for radiation protection purposes, but where occupational doses are not
likely to exceed 10% of the dose limits.  Then radiation areas, airborne
radioactivity areas, etc. could be restricted areas within controlled areas,
similar to what the DOE has done.
    

*******************************************************************
Frank E. Gallagher, III, CHP            
Manager, Radiation Protection           
  and Radiation Safety Officer
Environmental Health & Safety Office    Phone:  (714) 824-6904
University of California                Fax:    (714) 824-8539
Irvine, CA   92717-2725                 E-mail: fegallag@uci.edu
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