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[Fwd: Draft 10 CFR 835]



The following was recently received regarding changes to 10 CFR 835. 
The CAM issues may be interesting to RADSAFE, as well as the address for
comments.
-- 
Bates Estabrooks
Westinghouse Elec. Corp
WIPP
P.O. Box 2078
Carlsbad, NM 88220

besta@tis.eh.doe.gov
505-234-8470
fax:505-885-4562


STANDARD DISCLAIMER


     Ahhh, are you in for it now.  Several years ago I was skeptical of 
     e-mail, but now I have come to truly appreciate.  You'll be sorry that 
     I have your address.
     
     I appreciate the responses that I've gotten back on my previous query 
     about particles and airborne activity.  Everyone has made valid 
     points.  I am in the process of digesting everything.
     
     I wanted to make sure everyone was aware of the proposed changes to 10 
     CFR 835.  We, Savannah River, are in the process of commenting on the 
     changes.  I also plan on submitting comments as a private citizen.  If 
     you haven't seen it, the draft came out in the 12/23/96 Federal 
     Register.  Comments must be received by DOE by 2/21/97.  You can also 
     submit comments electronically to:
                        http://tis-nt.eh.doe.gov/wpphm/835/835.htm
     
     The following are some of my initial comments that I sent to several 
     people here for their feedback.  As I read the new rule, DOE is 
     putting less emphasis on CAMs and more on the quality of the air 
     sample.  I don't know about the other sites but by requiring the air 
     sample to be representative of the air breathed pushes us into 
     personal air samplers - something we are not setup to do on a 
     large-scale basis.
     
     Our comments alone will not make a difference, but if other people are 
     in the same boat, we can each respond separately.  Mark, this also 
     seems to be a perfect opportunity for AMUG to address, and just maybe, 
     together we can!  Sorry that was a bit corny.
     
     As always, feel free to comment back to me.
     
     Thanks
     
     
     For your information, the following are my initial comments (on 
     applicable air monitoring sections) on the draft 10 CFR 835.  As you 
     will see there are some significant changes from the current version.  
     By "significant", I mean in both the good and the bad.  Please note 
     that these are my initial comments that I am passing on for your 
     information and feedback.  Second, this is a proposed revision to 835. 
     From before, we know that there could be big differences between the 
     draft and final rule.  I will be finalizing my comments by the end of 
     the week.  Please get any comments to me as soon as possible.  Third, 
     the Workplace Air Monitoring Implementation Guide will also need to be 
     revised.  Only the shadow knows what direction the IG will take.
     
     Definitions
     
     The term "ambient air" has been removed.  No real indication as to why 
     except it doesn't seem to add much value to the rule.
     
     The term "continuous air monitor" has been removed and essentially 
     replaced with "real-time air monitoring".  While no real difference is 
     outwardly apparent, the CAM definition specifically refers to an 
     instrument with alarming capabilities, while real-time air monitor 
     simply states "measurement of the concentrations or quantities of 
     airborne radioactive materials on a continuous basis."  Given the 
     revised words in the air monitoring section, it seems the door may be 
     open to argue that a person probing a filter paper could serve as a 
     CAM.
     
     Section 835.403
     
     The current title of this section is "Area Monitoring" and the revised 
     title is "Air Monitoring".  The last paragraph which discusses 
     radiation monitoring in the workplace has been removed.  There is no 
     indication as to why.  If I were to speculate (and I will), it is 
     because the requirements in this paragraph are redundant with those in 
     835.401.
     
     The proposed rule states that air sampling is required if an 
     individual is likely to receive 40 or more DAC-hours per year.  This 
     is the same as 2% ALI.  There are two differences though.  First, the 
     phrase "in occupied areas, where under typical conditions" which is in 
     the current rule has been removed.  Second, the new rule requires the 
     sample to be representative of the air inhaled by the workers.  The 
     representative issue could prompt a more quantitative reevaluation of 
     whether the current samplers are representative or increase the use of 
     personal air sampling (PAS).
     
     The new rule also requires air sampling if respiratory protection is 
     worn.  While we have been requiring this for the past few years, our 
     basis was an ANSI standard and if we weren't in compliance, no real 
     skin off our nose.  Now, it's codified.  In conjunction with the 
     representativeness previously mentioned, this could add fuel to the 
     PAS fire.
     
     DOE 5480.11 required CAMs if you had the potential to exceed 0.1 DAC.  
     The RadCon Manual and 835 requires them if you are likely to exceed 1 
     DAC.  The proposed 835 increases this further to requiring real-time 
     monitoring "where unexpected increases" in airborne concentration are 
     likely to result in an individual being exposed to 40 DAC-hours in a 
     week.  The 8 DAC-hr alarm setpoint has been removed.  This could 
     provide added justification for having a 24 DAC-hr alarm setpoint and 
     for having even fewer CAMs especially in the non-plutonium facilities.
     
     Section 835.1002, Facility Design and Modifications, has been removed 
     and reserved.  Some of these paragraphs have been incorporated in 
     other sections.  However, paragraph (c) has been removed which 
     basically requires engineering controls be the first line of defense 
     against airborne radioactivity.  This was done because DOE states that 
     this may not be practical when modifying existing facilities.  The 
     expectation is that this design objective be utilized as much as 
     practical through other guidance documents and good design practices.