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DOE-HDBK-1122-99 Module 2.10, Fundamental Academic Training Instructor's Guide Phase I; Module 2.10, Access Control and Work Area Setup

Functional areas: Radiological Control, Technician Training, Instructor's Guide, Work Area Setup

This lesson presents instruction in Radiological Work Permits, various types of postings used in radiological areas, setting up radiological areas, access controls, and releasing of material from radiological areas. All of these are fundamental duties of RCTs.
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Section 1

DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-1 Course Title: Radiological Control Technician Module Title: Access Control and Work Area Setup Module Number: 2.10 Objectives: � 2.10.01 State the purpose of and information found on a Radiological Work Permit (RWP) including the different classifications at your site. � 2.10.02 State responsibilities in using or initiating a RWP. � 2.10.03 State the document that governs the ALARA program at your site. � 2.10.04 Describe how exposure/performance goals are established at your site. � 2.10.05 State the conditions under which a pre-job ALARA review is required at your site. � 2.10.06 State the conditions under which a post-job ALARA review is required at your site. 2.10.07 State purpose of radiological postings, signs, labels, and barricades; and the RCTs responsibilities for them. � 2.10.08 Identify the following radiological postings at your site, requirements for posting/barriers, and requirements for entry: a. Radiological Buffer Area b. Radiation Area c. High Radiation Area d. Very High Radiation Area e. Hot Spot f. Contamination Area g. High Contamination Area h. Airborne Radioactivity Area i. Fixed Surface Contamination j. Soil Contamination k. Radioactive Material Area l. Underground Radioactive Material Area 2.10.09 Describe good practices, support equipment to use, and common discrepancies in setting up radiological areas. 2.10.10 List discrepancies frequently observed in containment devices. DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-2 2.10.11 Describe good practices in setting up portable ventilation systems and count rate meters. � 2.10.12 List the requirements individuals should follow while working in RBAs. � 2.10.13 State the requirements for removing or releasing materials from any radiological area. References: 1. 10 CFR 835, “Occupational Radiation Protection” (1998) 2. DOE-STD-1098-99, "DOE Radiological Control Standard" Instructional Aids: 1. Overheads 2. Overhead projector/screen 3. Chalkboard/whiteboard 4. Lessons learned DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-3 I. MODULE INTRODUCTION A. Self Introduction 1. Name 2. Phone number 3. Background 4. Emergency procedure review B. Motivation This lesson presents instruction in Radiological Work Permits, various types of postings used in radiological areas, setting up radiological areas, access controls, and releasing of material from radiological areas. All of these are fundamental duties of RCTs. C. Lesson Overview 1. General Overview - Area setup and access control 2. Points of importance a. RWPs b. Radiological postings c. Setting up radiological areas d. Good practices and discrepancies commonly observed in setup of various portions of radiological areas. e. Access control f. Removing materials from radiological areas D. Introduce Objectives O.H.: Objectives DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-4 II. MODULE OUTLINE A. RADIOLOGICAL WORK PERMITS (RWPs) See DOE RCS Art. 321-323 (Insert site specific information here) Objective 2.10.01 1. Structure of an RWP a. Description of work b. Work area/process radiological controls c. Dosimetry requirements d. Pre-job briefing requirements, as applicable e. Training requirements for entry f. Protective clothing and respiratory protection requirements

Section 2

g. Radiological control coverage requirements and stay time controls, as applicable h. Limiting radiological conditions that may void the RWP i. Special dose or contamination reduction considerations j. Special personnel frisking considerations k. Technical work document number, as applicable l. Unique identifying number m. Date of issue and expiration n. Authorizing signature 2. RWPs should be used to control the following activities: a. Entry into High and Very High Radiation Areas DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-5 b. Entry into High Contamination Areas c. Entry into Airborne Radioactivity Areas 3. RWPs should be used to control the following activities: a. Entry into Radiation Areas b. Entry into Contamination Areas c. Handling of materials with removable contamination that exceeds the values in Table 2-2 of the Radiological Control Standard 4. Responsibilities when using an RWP a. It is important for individuals to comply with the requirements of the RWP to prevent personnel contamination or unnecessary radiation exposure. (Insert site specific information here) Objective 2.10.02 B. ALARA CONSIDERATIONS FOR ACCESS CONTROL AND WORK AREA SETUP 1. ALARA documentation (Insert site specific information here) Objective 2.10.03 2. Exposure/performance goals See DOE RCS Art. 131-133 (or appropriate site document) (Insert site specific information here) Objective 2.10.04 3. Pre-job ALARA Reviews a. At a minimum, the pre-job briefing should include: DOE RCS Art. 324.2 1. Scope of work to be performed 2. Radiological conditions of the workplace 3. Procedural and RWP requirements DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-6 4. Special radiological control requirements 5. Radiologically limiting conditions, such as contamination or radiation levels that may void the RWP 6. Radiological Control Hold Points 7. Communications and coordination with other groups 8. Provisions for housekeeping and final cleanup 9. Emergency response provisions b. Pre-job ALARA review requirements Objective 2.10.05 (Insert site specific information here) 4. Post-job ALARA Reviews a. Post-job meetings allow the opportunity to critique the work performance. Although, they will not affect the dose already received for a particular job, they can be effective in reducing the doses received the next time that job is performed. b. Information discussed at post-job meetings includes discussions of what went wrong and what could have been done differently to reduce the exposures received. c. Post-job meetings rely heavily on the input of each radiation worker for information on how best to reduce exposure the next time that job is performed. d. Typical questions asked could include: 1) Were there any problems performing the job in accordance with the procedure? 2) Did you have the tools and equipment needed to perform the work? Could special tools ease the job? DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-7 3) Were there any unexpected conditions noted during the work? Could these conditions have been anticipated? 4) Were there any unexpected delays in the performance of the job? What was the cause of the delay? 5) Was temporary shielding used? Could the use of temporary shielding reduce exposures received for this job? 6) What tools or work practices worked well that need to be reused?

Section 3

e. Post-job ALARA Review Requirements Objective 2.10.06 (Insert site specific information here) C. RADIOLOGICAL POSTINGS Objective 2.10.07 1. Purpose of radiological postings, signs and labels is to: a. Identify items or areas that have the potential for, or actually contain, radiological hazards. b. Identify the radiological hazard(s) present in an area (e.g. Radiation Area, Airborne Radioactivity area, Radiography Area). c. And to prevent: 1) Workers from inadvertently entering radiologically controlled area(s), and/or 2) Mishandling radioactive materials. 2. Each individual is responsible to read and comply with all the information identified on radiological postings, signs and labels. 3. Since there may be more than one radiological hazard identified on a posting, sign or label, it is important to read all of the information and not just the first line. DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-8 4. All access points into an area must be posted to ensure workers are adequately warned of the hazards in the area. 5. Postings and status boards (if applicable) should be promptly updated after completion of a survey to reflect the corrected conditions in the area. 6. If necessary the RWP should be amended to reflect any changes in the area. 7. The information on status boards, RWPs, posting and survey maps should be consistent. If there is a discrepancy it should be immediately corrected. Workers could review erroneous data that has not been updated and subsequently become contaminated or receive some unnecessary radiation exposure. a. Radiological Control Technicians should immediately update postings after performing a survey. The RWP and any status boards must also be updated. b. If the posting was updated and the RWP was not, a worker may consider the RWP correct and the posting wrong. c. If a worker entered the area based on the incorrect RWP information he could become contaminated or receive some unnecessary radiation exposure. 8. Areas should be posted if there is a strong potential for the situation to exist, even if it is not now present. a. Areas can be posted as Airborne Radioactivity Areas or Surface Contamination Areas, if equipment in the area has been known to leak and create airborne or contamination hazards. Posting areas in such a situation will ensure that the proper protective equipment is used and could prevent a personnel contamination incident or a case of internal exposure. b. If areas are posted only when the appropriate limits have been reached, personnel can be subjected to hazards when the hazard could have otherwise been minimized. DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-9 9. Disregarding any radiological posting, sign or label can lead to unnecessary or excessive radiation exposure and/or personnel contamination. 10. Unauthorized removal or relocation of radiological postings, signs and labels may lead to disciplinary actions up to and including job termination. 11. If any type of material used to identify radiological hazards is found outside an RBA, it should be reported to radiological control personnel immediately. RCT shall perform a survey of the sign, posting or label and conduct a survey of the area in which it was found. a. Any contamination or higher than expected radiation levels must be promptly reported to the RCT supervisor. D. TYPE OF RADIOLOGICAL POSTINGS, SIGNS AND LABELS

Section 4

Objective 2.10.08 10 CFR 835 requires the following for posting and labeling: 1. §835.601 General Requirements NOTE: See also §835.605 (a) Except as otherwise provided in this subpart, postings and labels required by this subpart shall include the standard radiation warning trefoil in black or magenta imposed upon a yellow background. (b) Signs required by this subpart shall be clearly and conspicuously posted and may include radiological protection instructions. (c) The posting and labeling requirements in this subpart may be modified to reflect the special considerations of DOE activities conducted at private residences or businesses. Such modifications shall provide the same level of protection to individuals as the existing provisions in this subpart. DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-10 2. §835.602 Controlled areas (a) Each access point to a controlled area (as defined in §835.2) shall be posted whenever radiological areas exist in the area. Individuals who enter only the controlled area without entering radiological areas are not expected to receive a total effective dose equivalent of more than 100 mrem (0.001 sievert) in a year. (b) Signs used for this purpose may be selected by the contractor to avoid conflict with local security requirements. 3. §835.603 Radiological areas Each access point to a radiological area (as defined in §835.2) shall be posted with conspicuous signs bearing the wording provided in this section. (a) Radiation Area - any area, accessible to individuals, in which radiation levels could result in an individual receiving a deep dose equivalent in excess of 0.005 rem (0.05 millisievert) in 1 hour at 30 centimeters from the source or from any surface that the radiation penetrates. The words “Caution, Radiation Area” shall be posted at each radiation area. (b) High Radiation Area - any area, accessible to individuals, in which radiation levels could result in an individual receiving a deep dose equivalent in excess of 0.1 rem (0.001 sievert) in 1 hour at 30 centimeters from the radiation source or from any surface that the radiation penetrates. The words, “Caution, High Radiation Area” or “Danger, High Radiation Area shall be posted at each high radiation area. (c) Very High Radiation Area - any area, accessible to individuals, in which radiation levels could result in an individual receiving an absorbed dose in excess of DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-11 500 rads (5 grays) in one hour at 1 meter from a radiation source or from any surface that the radiation penetrates. The words “Grave Danger, Very High Radiation Area” shall be posted at each very high radiation area. (d) Airborne Radioactivity Area - any area, accessible to individuals, where (1) the concentration of airborne radioactivity, above natural background, exceeds or is likely to exceed the DAC values listed in Appendix A or Appendix C of 10 CFR 835; or (2) an individual present in an area without respiratory protection could receive an intake exceeding 12 DAC-hours in a week. The words “Caution, Airborne Radioactivity Area” or “Danger, Airborne Radioactivity Area” shall be posted at each airborne radioactivity area. (e) Contamination Area means any area, accessible to individuals, where removable surface contamination levels exceed or are likely to exceed the removable surface contamination values specified in Appendix D of this Part 835, but do not exceed 100 times those values. The words “Caution, Contamination Area” shall be posted at each contamination area.

Section 5

(f) High Contamination Area means any area, accessible to individuals, where removable surface contamination levels exceed or are likely to exceed 100 times the removable surface contamination values specified in appendix D of Part 835. The words “Caution, High Contamination Area” or “Danger, High Contamination Area” shall be posted at each high contamination area. (g) Radioactive Material Area means any area within a controlled area, accessible to individuals, in which items or containers of radioactive material exist and the total activity of radioactive material exceeds the applicable values provided in appendix E of Part 835. The words “Caution, Radioactive Material(s)” shall be posted at each radioactive material area. DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-12 4. §835.604 Exceptions to posting requirements (a) Areas may be excepted from the posting requirements of §835.603 for periods of less than 8 continuous hours when placed under continuous observation and control of an individual knowledgeable of, and empowered to implement, required access and exposure control measures. (b) The following areas may be excepted from the radioactive material area posting requirements of §835.603(g): (1) Areas posted in accordance with 835.603(a) through (f); and (2) Areas in which each item or container of radioactive material is clearly and adequately labeled in accordance with §§835.605 and 835.606 such that individuals entering the area are made aware of the hazard. (c) Areas containing only packages received from radioactive material transportation need not be posted in accordance with §835.603 until the packages are surveyed in accordance with §835.405. 5. Area designations (Insert site specific information here) Review 10 CFR 835 definitions of areas. 6. Requirements for posting/barriers (Insert site specific information here) 3. Requirements for entry See 10 CFR 835 (Insert site specific information here) NOTE: RMA posting and labeling of radioactive material was covered in Module 2.08. DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-13 E. SETTING UP RADIOLOGICAL AREAS Objective 2.10.09 1. Good practices to be considered whenever possible in setting up Radiological Areas. a. Establish walkways in low dose areas. b. Do not store radioactive materials near walkways or where personnel frequently work. c. Place rope boundaries as close to the source of contamination as possible to minimize the size of the contaminated area. Care must be taken to ensure the area is not so limited that contamination is easily spread across the boundaries. d. Use appropriate containment devices to prevent the spread of contamination. e. Establish laydown areas for equipment to limit personnel safety hazards and/or radiation exposure. f. Set up SOPs upwind of contamination hazards. g. Post all accessible sides and entrance(s) to areas containing radiological hazards. h. Use Personnel Contamination monitors along with portable contamination survey instrumentation whenever possible. PCMs are more likely to detect contamination on individuals because personnel tend to survey too quickly. If this happened with an actual contamination incident the employee surveying quickly could subsequently pass over the contamination areas with the portable contamination survey instrumentation. 2. The following are commonly observed discrepancies that should be avoided in the setup of Radiological Areas.

Section 6

a. Posting information not updated or information otherwise incorrect. b. Boundaries not verified for contamination, radiation, and airborne radioactivity hazards. DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-14 c. Survey instruments out of calibration or defective. d. Step-off-pads not set up for efficient removal of protective clothing. (Not enough room to prevent contaminating the SOPs.) e. Laundry and waste receptacles not placed for efficient use or not placed at all. Receptacles not properly labeled as to their contents. f. Boundaries of areas setup too far from the hazards interfering with access to areas otherwise unaffected. g. Portable contamination survey instruments not located close to the step-off-pads. h. Status boards do not reflect where SOPs and boundaries lie. i. Status board not kept up-to-date. The information on status boards, postings and RWPs should agree. j. Tripping hazards exist from wires, hoses, or cables. k. Background radiation in monitoring area too high for efficient detection of low level contamination. l. Instrumentation not set up for proper operation. m. Protective clothing (gloves and booties) not readily available in a personnel contamination event. n. Phone or other communication devices not available near the SOP or portable contamination survey instruments. o. Not posting all accesses to the area. p. Failure to post dress and undress procedures. 3. Since contamination or airborne radioactivity and radiation levels are subject to change, it is essential to be able to quickly establish a Radiological Area. To properly set up a Radiological Area, the following support equipment should be readily available. DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-15 a. Step-off-pads. b. Portable contamination survey instrumentation/personnel contamination monitors to establish at exits to Contamination Areas, Airborne Radioactivity Areas, and RBAs. c. Yellow and magenta rope, ribbon or tape. d. Laundry receptacles. e. Waste receptacles (clean and radioactive waste receptacles). f. Receptacles for defective protection clothing (optional). g. Receptacles for non-compactable waste (optional). h. Receptacles for mixed waste (optional). i. Electrical power supply and extension cords (optional). j. Postings, signs, labels, and posting inserts. k. Communication equipment readily available. l. Additional protective clothing. m. Dose rate meters and smears. n. Survey maps. 4. Containment devices include glove boxes, glove ports, hot cells, huts, and windbreaks. Common discrepancies observed in containment devices include. Objective 2.10.10 a. Holes/leaks in the containments, facilitating the spread of contamination. b. Liquids accumulating in hoses or main portions of the containment. DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-16 c. Airlocks too small to remove protective clothing without spreading contamination. d. Ventilation exhaust not directed to the plant ventilation system. e. Material allowed to accumulate inside containments, limiting safe and/or efficient use. f. Sharp objects used inside containments (not covered or taped). g. Devices not tethered to prevent introduction into systems. h. Transfer sleeves/ports are not used or are unavailable. i. Containment not provided with a HEPA filter or ventilation exhaust.

Section 7

j. Containments not periodically surveyed inside and out. k. No means of quickly verifying loss of ventilation. l. Containment not decontaminated prior to dismantling. m. Adequate access not provided for lines or hoses. n. Containment not maintained at a negative pressure. o. Containment not supported properly to minimize stress from minor ventilation changes or not structurally supported to maintain its configuration during use. p. Containments not inspected prior to use and periodically during use. q. Not using appropriate containment devices for leaks. r. Not using a funnel to collect leakage, if appropriate. s. Plastic components showing fatigue or wear. DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-17 t. Funnel not positioned to collect all leaking fluid, if appropriate. u. Drain lines kinked allowing the buildup of liquids. v. Drain lines not secured properly to the collection device. w. Containment device not labeled to indicate hazards that are present. 5. Portable ventilation systems are frequently used to remove contaminated air or filter contamination in the air. Radiological control personnel should adhere to the following good practices in setting up portable ventilation systems. Objective 2.10.11 a. Use only HEPA (High Efficiency Particulate Air) filters with pre-filters (roughing filters). b. Perform radiation survey on filters periodically while in use. c. Have radiological limits established for filter replacement. d. Exhaust filter discharge to the plant ventilation system whenever possible. e. Ensure that there are no openings in the trunk or between the blower and the filter. f. Monitor the filter differential pressure (d/p) periodically. g. Establish filter D/P at which the filter must be replaced. h. Remove filters into plastic bags to prevent the release of activity. i. Position streamers to signify the flow of ventilation through doorways or through containment devices. DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-18 6. The proper setup and use of portable contamination survey instruments and Personnel Contamination Monitors (PCMs) can ensure that contamination is more likely to be detected on workers. The following is a list of good practices for setting up portable contamination survey instrumentation and PCMs. a. They must be placed in low background area. b. They need reliable power supply. c. They should be positioned to facilitate easy access by workers. d. Alarms should be set according to site administrative control levels or DOE limits. e. Must ensure instrument is source checked and calibrated. f. Extension cords must be checked for electrical safety. g. Portable contamination survey instruments and PCMs should be placed upwind of contaminated areas. h. They should not be placed near radioactive material storage areas or other areas where the background radiation can change. i. Portable contamination survey instruments should have sources provided to source check the instrument. F. ACCESS CONTROL Review 10 CFR 835 definitions 10 CFR 835 requires the following: 1. §835.501 Radiological Areas (a) Personnel entry control shall be maintained for each radiological area. (b) The degree of control shall be commensurate with existing and potential radiological hazards within the area. DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-19

Section 8

(c) One or more of the following methods shall be used to ensure control: (1) Signs and barricades; (2) Control devices on entrances; (3) Conspicuous visual and/or audible alarms; (4) Locked entrance ways; or (5) Administrative controls. (d) Written authorizations shall be required to control entry into and perform work within radiological areas. These authorizations shall specify radiation protection measures commensurate with the existing and potential hazards. (e) No control(s) shall be installed at any radiological area exit that would prevent rapid evacuation of personnel under emergency conditions. 2. §835.502 High and Very High Radiation Areas (a) The following measures shall be implemented for each entry into a high radiation area: (1) The area shall be monitored as necessary during access to determine the exposure rates to which the individuals are exposed; and (2) Each individual shall be monitored by a supplemental dosimetry device or other means capable of providing an immediate estimate of the individual's integrated deep dose equivalent during the entry. (b) Physical controls. One or more of the following controls shall be used for each entrance or access point to a high radiation area where radiation levels exist such that an individual could exceed a deep dose equivalent to the whole body of 1 rem (0.01 sievert) in any one hour at 30 centimeters from the source or from any surface that the radiation penetrates: DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-20 (1) A control device that prevents entry to the area when high radiation levels exist or that, upon entry, causes the radiation level to be reduced below the level that defines a high radiation area; (2) A device that functions automatically to prevent use or operation of the radiation source or field while individuals are in the area; (3) A control device that energizes a conspicuous visible or audible alarm signal so that the individual entering the high radiation area and the supervisor of the activity are made aware of the entry; (4) Entryways that are locked. During periods when access to the area is required, positive control over each entry is maintained; (5) Continuous direct or electronic surveillance that is capable of preventing unauthorized entry; (6) A control device that will automatically generate audible and visual alarm signals to alert personnel in the area before use or operation of the radiation source and in sufficient time to permit evacuation of the area or activation of a secondary control device that will prevent use or operation of the source. (c) Very high radiation areas. In addition to the above requirements, additional measures shall be implemented to ensure individuals are not able to gain unauthorized or inadvertent access to very high radiation areas. (d) No control(s) shall be established in a high or very high radiation area that would prevent rapid evacuation of personnel. 3. Besides meeting the requirements for entry into Radiological Areas and RBAs, personnel must also ensure that they take appropriate measures to maintain their exposures ALARA. Objective 2.10.12 DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-21 a. Workers who receive radiation exposures from other nuclear facilities must report the exposure to radiological control and their supervisor upon returning to the site. b. Avoid contact with potentially contaminated surfaces.

Section 9

c. Any management/supervision or RCT personnel should give stop work or evacuation orders if unanticipated radiation or contamination is encountered or if the appropriate RWP is not being followed. d. Wear dosimetry in accordance with the RWP. e. Maintain exposure ALARA. f. Report all injuries. g. Monitor clothing and exposed skin as required and report the presence of radioactive contamination. See DOE RCS Art. 338 and Appendix 3D (or appropriate site document) h. Place contaminated items and waste in approved radioactive waste containers. i. Personnel should wash their hands when leaving the RBA and prior to eating or using tobacco products. j. Personnel who are not respirator qualified shall not enter areas posted as "Respiratory Protection Required". 4. Hot Particles a. Hot particles are small, discrete, highly radioactive particles capable of causing extremely high doses to a localized area in a short period of time. Hot particle contamination may be present or be generated when contaminated systems are opened or when operations such as machining, cutting, or grinding are performed on highly radioactive materials. DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-22 b. The site-specific Radiological Controls Manuals usually define hot particles. Typically they are described as very small discrete particles capable of producing a shallow dose equivalent greater than 100 mrem in one hour. c. Special surveys in areas with the potential for hot particle contamination. d. Posting areas to specifically identify the presence of hot particles. e. Controlling access to hot particle areas should be through a job-specific RWP. The following controls should be considered for inclusion on the RWP: 1) Periodic personnel monitoring during the work activity, at a frequency based on the potential magnitude of skin exposure 2) Additional personal protective equipment and clothing 3) Direct radiological control coverage during work or assistance during protective clothing removal 4) Use of sticky pads or multiple step-off pads f. Personal protective equipment and clothing used in hot particle areas should be segregated from other radiological protective equipment and clothing during laundering and surveyed prior to reuse g. Response to hot particle skin contamination of personnel should include the following: 1) Immediate removal and retention of the hot particle for subsequent analysis 2) Analysis of the particle 3) Assessment of worker dose 4) Evaluation of work control adequacy DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-23 G. REMOVING MATERIALS FROM RADIOLOGICAL AREAS Objective 2.10.13 Facility operations require that radioactive material and non- radioactive material be removed from Radiological Areas, RBAs, and from the site. Prior to allowing this material to leave, important steps outlined in the procedures must be followed. 10 CFR 835 requires the following: 1. §835.1101 Control of material and equipment (a) Except as provided below, material and equipment in contamination areas, high contamination areas, and airborne radioactivity areas shall not be released to a controlled area if: (1) Removable contamination levels on accessible surfaces exceed the removable surface contamination values specified in Appendix D of 10 CFR 835; or

Section 10

(2) Prior use suggests that the removable contamination levels on inaccessible surfaces are likely to exceed the removable surface contamination values specified in Appendix D of 10 CFR 835. (b) Material and equipment exceeding the removable surface contamination levels specified in Appendix D of 10 CFR 835 may be conditionally released for movement on-site from one radiological area for immediate placement in another radiological area only if appropriate monitoring is performed and appropriate controls for the movement are established and exercised. (c) Material and equipment with fixed contamination levels that exceed the limits specified in Appendix D of 10 CFR 835 may be released for use in controlled areas outside of the radiological areas only under the following conditions: (1) Removable surface contamination levels are below the removable surface contamination values specified in Appendix D of 10 CFR 835; and DOE-HDBK-1122-99 Module 2.10 Access Control and Work Area Setup Instructor’s Guide 2.10-24 (2) The material or equipment is routinely monitored and clearly marked or labeled to alert personnel of the contaminated status. 2. Release to Radiological Buffer Areas (Insert site specific information here) 3. Release to Uncontrolled Areas (Insert site specific information here) III. SUMMARY A. Review major topics 1. RWPs 2. Radiological postings 3. Setting up radiological areas 4. Good practices and discrepancies commonly observed in setup of various portions of radiological areas. 5. Access control 6. Removing materials from radiological areas B. Review learning objectives IV. EVALUATION Evaluation should consist of a written examination comprised of multiple choice, fill-in the blank, matching and/or short answer questions. 80% should be the minimum passing criteria for examinations. Module Number: 2.10

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