Re: PCM-1B Sole Release Procedure

[Judd Sills <sillsj@GAT.COM>]

At 10:00 AM 11/8/96 -0600, you wrote:
>     To whom it may concern:
>     
>     I am a senior health physics technician at a D.O.E. facility in 
>     Washington State.  We are currently implementing a program using a 
>     Eberline Personnel contamination monitor (PCM-1b) as a sole and final 
>     release survey when exiting a contamination area.  I would like to ask 
>     you for some comments, but first let me give you some background on 
>     what we have here.
>     
>     We store highly radioactive waste in 177 underground storage tanks in 
>     areas known as farms.  These farms are fenced areas and have loose 
>     contamination on the ground and equipment up to 100,000 dpm/100cm2.  
>     Areas exceeding the 100K level are posted High contamination areas. 
>     We routinely perform entries into pits and install video cameras into 
>     these underground storage tanks.  Other work performed weekly are such 
>     things as pumping the radioactive liquids from the old leaking single 
>     shell tanks to the newer double shell tanks as well as other intrusive 
>     work.
>     
>     We have a "change"  trailer at the entrance to each farm.  This is the 
>     location that the worker dresses into Anti-contamination clothing (pc's) 
>     and enters and exits the farm.  The change trailer contains a PCM-1b.  
>     About half the trailer is posted and controlled as a Radiological Buffer 
>     Area (RBA).  The area posted as a RBA is considered to be a clean area.  
>     The PCM-1b is located inside the RBA about 10 to 15 feet from the step 
>     off pad coming out of the Contamination Area.  Workers exiting the 
>     contamination area and those entering will be using the same change 
>     area.  There are no personnel assigned as a control point at any exit.
>     
>     Now my question:
>     
>     How would your facility handle personnel exiting the contamination 
>     area?  Would you require a hand and foot survey before stepping into 
>     the RBA?  Would you simply undress out of your Anti-C's and then 
>     continue through the RBA to the PCM-1b without any type of survey?  Do 
>     you do a full self survey before moving on to the PCM-1b?  Or how would 
>     you handle this?
>     
>     I would appreciate any help or comments you may have.  Please feel 
>     free to E-Mail me or call me at (509)373-2731.
>     
>     Thank You,
>     
>     Glenn Williams
>     Senior Health Physics Technician
>
I haven't seen anybody offer you any help on this, so I will give you my
opinions.

First, answer a few questions:
(1)What has been your experience with surveys for contamination in the
RBA???  If
   the surveys show that you aren't having contamination migrating out of
the undress
   area, then frisker survey (hands/feet, or full-body) may not be
warranted.  If it 
   is discovered frequently, then you need to be more aggressive and
institute routine
   frisking prior to leaving the step-off pad.
(2)How frequent and how serious are your personnel contamination events?  If
they 
   don't occur very often and are generally low activity, then the  extra
   checks prior to crossing the RBA probably aren't warranted.  If the
events are
   frequent and/or serious, then extra precautions such as frisking are
warranted.
(3)You mentioned that the dress-out areas for entry and exit are common for each
   tank farm.  By this, I presume that you mean that dress-out occurs in
these areas,
   and that workers store their street clothes there as well for re-dress
after    
   exiting the contaminated area.  Assuming this to be the case, I honestly
think
   that you need to have a MANDATORY policy that all workers MUST
successfully clear
   the PCM-1s prior to going ANYWHERE after exiting the Contaminated Area.  You 
   should consider making the dress-out area outside of the Restricted Area, so 
   that workers have to clear the PCMs to get to it anyway.  The workers
should NOT be
   in this area until they have been checked for contamination under any 
   circumstances.
(4)You should review how good your workers are at both dress and undress for use
   of protective clothing.  The dress-out and undress practices will be directly
   related to the probability of contamination events.  If you can get
workers to
   wear the PCs properly, and be careful not to contaminate themselves or others
   during undress, then you can probably have low frequency/minor
contaminations and
   a lighter degree of control in the RBA would be OK.  If workers are not
good at
   contamination control, then you are probably going to have problems
controlling
   contamination no matter how much frisking that you do.  Go to the start
of the
   problem and begin with work practices.  Drill the workers and make sure
that they
   take it seriously.
(5)Make sure that your workers have a phone or intercom to get hold of the
   Radiation Protection staff in the event of a contamination detected at the
   PCMs.  Make certain that the work atmosphere is such that workers know
that it
   is to their better interests to report contaminations to Rad Protection.
If the
   workers are punished for transgressions, an un-manned control point is asking
   for trouble.  If they don't feel threatened, and want to protect
themselves, this
   won't be risky.  If you leave the exits unmanned, you have to accept that you
   are going to have some workers that won't call Rad Protection when they
are con-
   taminated, and workers that will "blow by" the PCMs to prevent delay.
Motives
   for this type of behavior are astounding, but it does occur.  Having Rad
Protection
   Technicians show up at the areas frequently to observe PCM practices may
help.
   The PCM-1Bs are excellent monitors, but workers sometimes find the
sensitivity to
   be annoying, and quickly learn that they can lean away from the detectors
and that
   the PCM won't "know the difference."  Some utilities have installed video
cameras
   at the PCM stations to both monitor workers and to serve as an "ounce of 
   prevention" in that workers will be less likely to skip monitoring if
they think
   that it is likely that they would be caught.

In summary, you need to have good training of workers, and a good atmosphere for
the siutation that you describe to work well.  That is very possible, but
you need
to head off problems by instilling the right attitude in workers, and make
sure that
they know how to prevent problems, and share your desire to prevent personnel
contaminations.

These are my opinions, not my employers....
J. M. Sills, CHP             |   Office: (619)455-2049
General Atomics, Room 01-166C|      Fax: (619)455-3181
3550 General Atomics Court   |   E-Mail:  sillsj@gat.com
San Diego, CA  92121         |