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Re: Open-Bay Labs

I think I understand the difficulties of working in a political climate of
"more bang for the buck."  While there is, of course, no regulation against
the open lab design, it seems clear that the only way that 10CFR20 and
10CFR19
can be implemented in such a facility is to consider everyone who works in
that space a "radiation worker", with all of the concomitant training and
monitoring requirements.  It's that or a "costly retrofit" to the facility.
To
do otherwise is to invite disaster, either from a real spill, or from
litigation, eg., the pregnant employee who doesn't use RAM, but works in
that
space and then has a birth defect, miscarriage, etc.  It's a classic case of
"pay me now or pay me later."

I think that RP's tend to underestimate their power.  My experience at a DOE
facility is that researchers may threaten or cajole, but will not directly
refute or ignore you.  One particularly intense confrontation involved plans
for an accelerator beam line which I refused to approve until an emergency
exit was included.  (Since the beam line was underground, this involved
tunneling up to the surface.)  If looks (or words) could kill, you wouldn't
have to put up with me, now, but, when it was all over, there seemed to be a
consensus that I did the right thing.

I'm also curious as to why the "Radiation Safety Committee" has not been
mentioned, so far.  My apologies if I missed it.  I thought that this is
required for broad scope licenses.  Are they any help?

The opinions expressed are strictly mine.
It's not about dose, it's about trust.

Bill Lipton
liptonw@dteenergy.com


You wrote:

>Dear RADSAFERs:
>     I have received several replies to my original RADSAFE posting
>regarding open-bay research labs without interior walls.  Several
>have suggested that the radiation safety office review plans before
>construction.  We do that as a matter of course.  Our input is
>usually regarded with care and acted upon, so long as we are asking
>for things like moving a door or two, or changing the floor tiles
>from a textured design to a smooth one that can be decontaminated
>if necessary.  But when we are finding fault with the entire design
>and that design is politically correct because it is new and
>innovative (read "more floor space for less money"), that is asking
>for too much.  We can be that dramatic only if there is a law or
>regulation specifically forbidding the design.  We could not find
>such a regulation, therefore the lab was built.  More are on the
>way.  The only good news is that interior walls can be constructed
>later.
>     My question to you all is this:  Has anyone been refused
>permission to use radioactive material in a lab of this design,
>either because a regulator found a regulation and interpreted it
>that way, or else because of an incident that proved the design
>unsafe?


Dear RADSAFERs:
     I have received several replies to my original RADSAFE posting
regarding open-bay research labs without interior walls.  Several
have suggested that the radiation safety office review plans before
construction.  We do that as a matter of course.  Our input is
usually regarded with care and acted upon, so long as we are asking
for things like moving a door or two, or changing the floor tiles
from a textured design to a smooth one that can be decontaminated
if necessary.  But when we are finding fault with the entire design
and that design is politically correct because it is new and
innovative (read "more floor space for less money"), that is asking
for too much.  We can be that dramatic only if there is a law or
regulation specifically forbidding the design.  We could not find
such a regulation, therefore the lab was built.  More are on the
way.  The only good news is that interior walls can be constructed
later.
     My question to you all is this:  Has anyone been refused
permission to use radioactive material in a lab of this design,
either because a regulator found a regulation and interpreted it
that way, or else because of an incident that proved the design
unsafe?
**********************************************************************
William G. Nabor
University of California, Irvine
EH&S Office
Irvine, CA,  92697-2725
WGNABOR@UCI.EDU
mailto:wgnabor@uci.edu
**********************************************************************
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