RE: Radon Control During Remediation

["McCormick, Luke" <mccormickl@hq.hqusareur.army.mil>]

Bates, 

OSHA has essentially adopted 10 CFR 20  as their own in 29 CFR 1910.1096
and 1926.54 (don't hold me to the exact cites) An OSHA regulator
explained to us that they regulate worker exposure to radiation and not
just regulated source, byproduct and SNM, so that they considered all
radiation within their  domain, and they will usually bow to NRC or
States if they regulate an activity. We did radon monitoring in a tunnel
we were digging in Boston. Another group of sand hogs tunneling at the
airport were cited by OSHA for not monitoring. (we had an average of
0.74 WL and a high of 4.3 WL. I am not sure what they had). FFCA
requires DOE to comply with OSHA, so there is your legal driver.
Hope you are enjoying the move to Colorado. I'm back in Germany for a
while, heading back into the box next week, HOOAH. 

Regards,  Luke McCormick
mccormickl@hq.hqusareur.army.mil


> ----------
> From:
> Bates.Estabrooks@rfets.gov[SMTP:Bates.Estabrooks@rfets.gov]
> Reply To: 	radsafe@romulus.ehs.uiuc.edu
> Sent: 	Thursday, January 08, 1998 4:26 PM
> To: 	Multiple recipients of list
> Subject: 	Radon Control During Remediation
> 
>           Hello Radsafers;
>           
>           Rocky Flats will shortly begin remediation of an area known
> as 
>           Trench 1 (T1) where ~125 drums of depleted uranium (DU)
> chips 
>           and lathe coolant were buried from 1954 until 1962.
>           
>           The work will involve excavating the drums and stabilizing
> the 
>           potentially pyrophoric DU, in place.  All work will be 
>           performed inside a very large tent to be constructed over
> the 
>           site.
>           
>           My question concerns the generation of Radon and decay 
>           products from the DU (primarily U238) during the work. Are 
>           there any regulatory drivers, etc. to require monitoring 
>           worker exposure to the Radon products, as would be the case
> in 
>           a uranium mine, since the Radon is being generated from 
>           man-made materials?
>           
>           We intend to air-sample and monitor (with CAMs) for uranium.
>           
>           Thanks for any input Radsafers might have.
>           
>           Bates Estabrooks
>           bates.estabrooks@rfets.gov  
>