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.