UCRL-AM-133867-VOL-2-PT-20.3-2017 Revision 7 Volume II Part 20: Ionizing Radiation/Nonionizing Radiation Document 20.3 LLNL Radiological Safety Program for Radiation Generating Devices Revision Type: Major Subject Matter Expert (SME)/Author: Kathleen L. Shingleton FAM Approval by: Quang Le Radiation Protection Functional Area FAM Approval date: January 13, 2017 ES&H Directorate Approval by: (Majors/Peer Reviews*) Frances Alston Director, ES&H ES&H Directorate Approval date: February 8, 2017 Last IM Review date: May 2017 Web Posting date: June 8, 2017 Implementation date: August 7, 2017 *Required when Owner/Author are the same person
Transcript
UCRL-AM-133867-VOL-2-PT-20.3-2017
Revision 7
Volume II
Part 20: Ionizing Radiation/Nonionizing Radiation
Document 20.3 LLNL Radiological Safety Program for Radiation Generating Devices
Revision Type: Major
Subject Matter Expert (SME)/Author: Kathleen L. Shingleton
FAM Approval by: Quang Le Radiation Protection Functional Area
3.1 Description of RGD Classifications ................................................................................. 4 3.1.1 Class I RGDs ............................................................................................................ 5 3.1.2 Class II RGDs ........................................................................................................... 5 3.1.3 Class III RGDs .......................................................................................................... 5 3.1.4 Class IV RGDs ......................................................................................................... 5
3.2 Applicability of Design Requirements.............................................................................. 6 3.3 Enclosed-Beam RGD Systems ....................................................................................... 6
3.5 RGD Rooms Containing Open-Beam Class II RGDs .....................................................12 3.5.1 Applicability..............................................................................................................12 3.5.2 Physical Controls .....................................................................................................12 3.5.3 Shielding ..................................................................................................................13
3.6 RGD Rooms Containing Open Beam Class III and IV RGDs .........................................13 3.6.1 Applicability..............................................................................................................13 3.6.2 General Controls .....................................................................................................14 3.6.3 Shielding ..................................................................................................................14 3.6.4 Radiation Safety Interlocks ......................................................................................14 3.6.5 Visible Warning Signals ...........................................................................................14 3.6.6 Additional Control Measures for Very High Radiation Areas ....................................15
* Major Revision
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3.7 Effluent Monitoring.........................................................................................................18 3.8 Verification and Validation of Design .............................................................................18
4.0 Work Planning .....................................................................................................................19 4.1 Acquisition of RGDs ......................................................................................................19
4.1.1 Approval for Acquisition of an RGD .........................................................................19 4.1.2 RGD Acceptance Testing ........................................................................................20
4.2 Characterization of the RGD ..........................................................................................20 4.2.1 General Information .................................................................................................20 4.2.2 Initial Characterization of the RGD ...........................................................................22 4.2.3 Complete Characterization of the RGD ....................................................................23
4.3 Posting, Labeling, and Physical Barriers ........................................................................26 4.3.1 Area Postings ..........................................................................................................26 4.3.2 Barriers ....................................................................................................................27 4.3.3 RGD Labels .............................................................................................................27
4.4 External Dose Monitoring ..............................................................................................28 4.4.1 Class I RGD Operations ..........................................................................................29 4.4.2 Class II, III, and IV RGD Operations ........................................................................29
4.5 Written Authorizations, Safety Plans, and Technical Work Documents ..........................29 4.5.1 Written Authorizations ..............................................................................................29 4.5.2 Hold Points ..............................................................................................................32 4.5.3 Technical Work Documents .....................................................................................33
4.6 Training .........................................................................................................................35 4.7 DOE Approval for Accelerator Operations .....................................................................36
5.0 Conducting Routine Radiological Work ...............................................................................37 5.1 Administrative Requirements .........................................................................................37
5.1.1 Approved Operating Parameters .............................................................................37 5.1.2 Requirements for Non-Operational RGDs ................................................................38 5.1.3 Frequency of RGD Inventory, Safety Assessments, and Radiation Surveys ............38 5.1.4 Inventory Requirements ...........................................................................................39 5.1.5 Radiological Safety Assessment ..............................................................................40 5.1.6 Radiation Survey in Potentially Occupied Areas ......................................................41
5.2 Personnel Safety Controls .............................................................................................42 5.2.1 Access Controls .......................................................................................................42 5.2.2 Use of Interlocks and Hazard-Safe Switches ...........................................................43 5.2.3 Radiation Monitoring Requirements .........................................................................44
5.3 Maintenance, Modification, and Repair ..........................................................................45 5.3.1 RGDs.......................................................................................................................45 5.3.2 Safety Systems ........................................................................................................46 5.3.3 Vendor-Provided Safety Systems ............................................................................46
5.4 Field Radiography .........................................................................................................47 5.5 Documentation and Logbook Requirements ..................................................................47 5.6 Control of RGDs ............................................................................................................48
5.6.1 Use and Location of RGDs ......................................................................................48
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5.6.2 Use of RGDs Owned by Non-LLNL Organizations ...................................................49 5.6.3 Managing Out-of-Use RGDs ....................................................................................51
6.0 Responsibilities ...................................................................................................................52 6.1 Institutional Program Responsibilities ............................................................................53
6.1.1 Radiological Control Manager ..................................................................................53 6.1.2 Radiation Generating Device Safety Officer .............................................................53 6.1.3 Donation, Utilization, and Sales Group ....................................................................53
6.3 ES&H Team Responsibilities .........................................................................................55 6.3.1 ES&H Team Health and Safety Technologist ...........................................................55 6.3.2 ES&H Team Health Physicist ..................................................................................55 6.3.3 ES&H Team Environmental Analyst ........................................................................55
7.0 Requirement Source Documents ........................................................................................55 8.0 Resources for More Information ..........................................................................................56
9.0 Revision History ..................................................................................................................58
Appendices
Appendix A Acronyms, Terms, and Definitions..........................................................................59 Appendix B Summary of RGD Safety Requirements .................................................................64
Tables
Table 1. Maximum Potential Accidental Dose Used to Classify RGDs at LLNL ...................... 5 Table B-1: Summary of RGD Safety Requirements ..................................................................64
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20.3
LLNL Radiological Safety Program for Radiation Generating Devices
1.0 Introduction
The Department of Energy’s (DOE’s) rule on occupational radiation protection (10 CFR 835, hereafter referred to as the “Rule”) requires specific controls for radiological work. The DOE Radiological Control Standard (DOE-STD-1098-99, hereafter referred to as “RCS”) and the Accelerator Safety Order (DOE-O-420.2C) are LLNL contractual obligations that contain additional controls.
This document contains the contractual and institutional requirements and best management practices that pertain specifically to radiation generating devices (RGDs). When implemented in conjunction with Document 20.1, “Occupational Radiation Protection,” in the ES&H Manual, this document provides a basic level of radiation safety for operations involving RGDs. Both the Authorizing Organization and the Environment, Safety, and Health (ES&H) Team health physicist should specify additional operation-specific controls, as necessary.
Failure to comply with radiation protection program requirements could necessitate reporting to DOE under the provisions of DOE Order 231.1A, “Environment, Safety and Health Reporting;” 10 CFR 830 Subpart A, “Quality Assurance Requirements;” or the Price Anderson Amendments Act (PAAA).
Appendices to this document contain supporting information:
— Appendix A contains the definition of “shall,” “must,” “should,” and other terms used in this document.
— Appendix B contains a tabular summary of the RGD radiological safety program requirements.
1.1 Applicability
1. Except as noted below, this document applies to RGD operations conducted at LLNL and to off-site RGD operations where LLNL has primary management authority:
a. Rule requirements are presented as “shall” statements.
b. Contractual and institutional requirements are presented as “must” statements.
— The Radiological Control Manager (RCM) must approve alternate methods of implementing “must” statements, as specified in Document 20.1, Section 1.2.
— Any ‘alternate methods of implementation’ shall be consistent with the as low as reasonably achievable (ALARA) process described in Document 20.1.
c. Best management practices are presented as “should” statements.
a. Devices that produce radiation intentionally, such as
— X-ray diffraction and fluorescence analysis systems.
— Flash x-ray machines, cabinet RGDs.
— Industrial radiography equipment.
— Particle accelerators.
b. Devices that produce radiation incidentally, such as
— Electron microscopes.
— High-voltage electron guns, electron arc-welding machines.
— Evacuated high-voltage electronic devices.
— Electron beam devices with energies >5 kV, unless otherwise excluded below.
c. Lasers that produce ionizing radiation exceeding what is defined for commercially available devices, such as
— Ultra-intense lasers [e.g., the National Ignition Facility (NIF)].
— Certain focused high-power lasers [i.e., those where the intensity (W/cm2) times the wavelength2 exceeds 1018 (1E+18)].
3. Ultra-intense laser interaction with solid materials must be evaluated on a case-by-case basis since it can lead to the production of energetic electrons (up to 100 MeV), high-intensity bremsstrahlung, charged particles, particularly energetic protons, and photo- and proton-induced neutrons.
1.1.1 Exclusions
1. In addition to the exclusions in Document 20.1, this document does not apply to:
a. RGDs approved for use by the Food and Drug Administration (FDA).
— Medical x-ray devices used for diagnostic purposes (e.g., the x-ray devices used by LLNL’s Health Services Department) shall comply with safety requirements specified by the FDA.
b. RGDs that use sealed radioactive materials as a source of radiation, including radiography devices, except as noted below
— Radioactive materials must be controlled in accordance with Document 20.2, “LLNL Radiological Safety Program for Radioactive Materials,” in the ES&H Manual.
— Neutron-generators that utilize deuterium - tritium (D-T) sources are subject to the controls in this document as they generate radiation only when powered on, and their hazard as an RGD far outweighs the hazard from tritium. However,
these RGDs must retain labels indicating they contain radioactive material and are subject to radioactive material transport controls.
c. Unmodified commercially available components or devices that meet all the following criteria
— Produce radiation incidentally.
— Have a potential across the terminals <15 kV.
— Produce radiation fields that are no more than twice background when measured at 5 cm (2 in.) from the device surface (or at the closest accessible surface) when operated at the maximum operating parameters.
— Retain the labels provided by the manufacturer.
— Are used in accordance with the manufacturer’s instructions.
Examples include high-voltage switches, planar triodes, and power supplies containing various types of thermionic valves installed in shielded cabinets or racks, mass spectrometers, vacuum switches, spark-gap devices, and electronic components such as cathode-ray tubes (i.e., computer monitors and televisions).
For convenience, these devices are referred to as ‘exempt’ RGDs.
2. If there is ambiguity or uncertainty about whether or not an RGD is excluded, the RGD Safety Officer must make the determination.
1.1.2 Implementation
1. The design criteria specified in Section 3.0 apply to existing RGD systems.
2. Authorizing Organizations must evaluate their compliance stature and, where existing conditions are inconsistent with the new requirements, develop an implementation plan for achieving compliance.
a. The draft implementation plan must be submitted to the RCM for approval within 60 days of publication of this document on the web.
b. The Authorizing Organization and the RCM will jointly determine the implementation dates based on the issues needing resolution.
3. Review and revision (as needed) of technical work documents may be completed during the RGD’s next regularly scheduled safety assessment.
1.2 Scope
1. RGDs that are not excluded as specified in Section 1.1.1 are within the scope of this document.
2. Some RGDs (e.g., high-energy electron accelerators, neutron generators, and ion accelerators) are capable of activating air and materials in the accelerator enclosure.
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Controls for the radioactive materials produced by these RGDs are outside the scope of this document and are contained in Document 20.2.
2.0 Hazards
1. Many RGDs are capable of producing extremely high radiation doses in very short periods of time. Improper use of RGDs could result in:
a. An accidental external radiation dose to the extremities or the whole body, ranging from insignificant to lethal.
b. Exceeding radiation dose limits for the whole-body and extremities in a very short time period (e.g., sometimes less than a second for many Class III and IV RGDs).
2. High-energy RGDs are capable of activating materials (i.e., making them radioactive), especially if the materials are placed in a particle beam path. Dispersible materials (such as dust or other finely-divided particles) that become activated can create a Contamination Area or a High Contamination Area; bulk materials (such as metal accelerator components) that become activated will continue to emit ionizing radiation after the RGD is turned off; dose rates can range from insignificant to tens of R/h, or more. In addition, some materials undergo fission or spallation, resulting in the production of radioactive materials and additional ionizing radiation. See Document 20.2 for controls associated with radioactive materials.
3. To minimize these hazards and risks, and to ensure that radiation doses are kept ALARA, individuals who work with RGDs must adhere to the requirements and controls specified in this document, as well as its associated documents.
3.0 Radiological Design Criteria
The design criteria in this section supplement the general design criteria in Document 20.1, Section 4.0 and the design considerations for facilities and equipment specified in Document 20.1, Appendix G.
3.1 Description of RGD Classifications
LLNL classifies RGDs according to their accidental dose potential (e.g., if a shutter fails on an RGD), and the dose potential if the RGD was operated without facility-provided engineered controls (e.g., without a shielded, interlocked room). Within each Class, the primary beam (and secondary beam, if it exists) might be inaccessible without disassembling the unit, enclosed during normal operations, or might be an open-beam configuration. Table 1 shows the maximum potential dose to the extremity, eye, or whole body associated with each Class of RGD. If an RGD meets the criteria of more than one Class, the higher Class applies.
Table 1. Maximum Potential Accidental Dose Used to Classify RGDs at LLNL
Maximum Dose (rem)
Organ Class I Class II Class III Class IV
Extremity <0.1 150 >150 — Eye <0.1 45 >45 —
Whole body <0.1 15 — >15
3.1.1 Class I RGDs
Class I RGDs are incapable of reasonably producing an accidental dose >0.1 rem per incident to either a localized area of the body (e.g., an eye or a finger) or to the whole body. Examples of devices that might fit into this class are vacuum-plating units, electron microscopes, high-voltage rectifiers, electron-beam coaters, and cabinet RGD systems meeting the design criteria in Section 3.3.
Class I devices must be inherently safe. These devices include shielding and design features that permit operation without requiring significant occupancy controls or personnel in attendance.
3.1.2 Class II RGDs
Class II devices could reasonably produce accidental doses up to three times the occupational annual dose limit (see Table 1). Examples of devices that might fit into this class are low-intensity flash x-ray devices, e-beam devices, and low-power diffraction, fluorescence, or radiographic devices.
3.1.3 Class III RGDs
Class III devices could reasonably produce an accidental dose in excess of three times the occupational dose limit to the extremity or eye, and could be capable of producing severe biological effects to localized areas of the body. RGDs with collimated beams that could expose <10 cm2 of the whole body are also included. Class III devices are unlikely to produce lethal doses of radiation due to the limited area of exposure. Examples of devices that might fit into this class include diffraction and fluorescence RGDs.
3.1.4 Class IV RGDs
Class IV devices could reasonably produce an accidental dose in excess of three times the occupational annual dose limit to the whole body (see Table 1) and could be capable of producing lethal doses of radiation. Examples of devices that might fit into this class include high dose rate radiography devices and particle accelerators.
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3.2 Applicability of Design Requirements
1. The requirements in this section apply to Class I, II, III, and IV RGDs operated in fixed facilities.
2. If there is more than one port in the radiation source housing or more than one radiation source, the requirements apply to each port in every source housing associated with the system.
3. The facility-related criteria in this section (e.g., interlocks on room doors; installed area radiation monitors) do NOT apply to use of:
a. Portable RGDs intended to be used in many different areas or facilities (e.g., lead based paint analyzers).
b. ‘Field radiography’ operations, even if conducted in a fixed facility.
4. Design criteria are generally presented according to the type of RGD.
a. Class I RGDs that are not otherwise specified in this section (e.g., RGD systems designed exclusively for microscopic examination of material, such as x-ray diffraction, spectroscopic, and electron microscope equipment) must
— Be shielded such that an individual would be unlikely to receive either a localized or a whole-body dose exceeding 0.1 rem in a year under normal or accidental conditions.
— Retain labels and safety systems provided by the manufacturer.
b. In cases where the RGD might fit into more than one category, or doesn’t clearly fit into any category, the RGD Safety Officer must concur as to which controls the RGD is subject to. The RGD Safety Officer’s signature on the RGD Characterization form documents their concurrence.
5. Document 12.1 “Access Control, Barricade Tape, Barricades, Safety Signs, Safety Interlocks, and Alarm Systems,” in the ES&H Manual, provides the basic requirements for interlocks systems. In addition, the requirements in this section apply to interlocks installed to prevent exposure to radiation.
3.3 Enclosed-Beam RGD Systems
3.3.1 Applicability
1. For enclosed-beam systems, the radiation source, beam paths, sample, detector and/or other devices (e.g., analyzing crystal, filters) must be enclosed in a chamber, coupled chambers, beam pipes, whole system enclosure, etc. that cannot be entered by any part of the body during normal operation.
— ‘Cabinet RGDs,’ including RGD systems designed primarily for the inspection of carry-on baggage.
— Scanning electron microscopes (<15 kV).
— Most e-beam welders.
b. The use of interlocked beam pipes or tubes or an interlocked enclosure around the whole RGD system might qualify the system as an enclosed-beam system. However, enclosed-beam systems become open-beam systems during the period when interlocks are defeated and must be controlled in accordance with Section 3.4.
c. An RGD tube used within a shielded part of a building, or RGD equipment that might temporarily or occasionally incorporate portable shielding, is not considered an enclosed-beam or cabinet RGD system.
2. The requirements for enclosed-beam systems are not applicable to enclosures designed to admit humans. See Sections 3.5 and 3.6.
3.3.2 Shielding
1. The dose rate must not exceed 0.5 mrem in an hour when measured at 5 cm (2 in) from the external surface of the enclosure. Compliance with the dose criteria must be determined as follows:
a. By measurements averaged over a cross-sectional area of 10 cm2 with no linear dimension >5 cm.
b. With the RGD system operated at those combinations of RGD tube potential, current, beam orientation, and conditions of scatter radiation which produce the maximum radiation exposure at the external surface, and with the door(s) and access panel(s) fully closed, as well as fixed at any other position(s) which will allow the generation of radiation.
2. Viewing ports must be controlled as follows:
a. Leaded glass used to shield viewing ports must be visually distinct (e.g., mounted with colored brackets) to minimize the likelihood of it being replaced with ordinary glass.
b. Viewing ports that are directly in line with the radiation source must be made an integral part of the vacuum tank so that high voltage and vacuum cannot be achieved without the proper shielding in place.
3.3.3 Radiation Safety Interlocks
1. The enclosure for enclosed-beam RGD systems must be interlocked to the tube high voltage supply and/or the primary beam shutter such that no x-ray beam can enter the sample chamber while it is open. As used herein:
a. A ‘door’ is used during routine operations to access the inside of a cabinet (e.g., to change samples).
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b. An ‘access panel’ allows access into the interior of an enclosed beam or cabinet RGD system without use of tools, but is not intended to be opened for routine operations.
c. Enclosed-beam systems that are not ‘cabinet RGDs’ are subject to the controls for ‘access panels.’
2. Each door of a cabinet RGD system must have a minimum of two safety interlocks.
a. At least one of the required interlocks must be such that opening the door results in physical disconnection of the energy supply circuit to the high-voltage generator.
b. Whenever possible, a single component of the cabinet RGD system must not cause failure of more than one required safety interlock, unless it also causes failure of the RGD.
c. If failure of any single component of the cabinet RGD system could cause failure of more than one required safety interlock (without also causing failure of the RGD), this condition, along with compensatory measures (e.g., quality assurance controls), must be identified on the Characterization form.
3. Each access panel must have at least one safety interlock.
4. Interlocks are not required on access doors/panels to systems required to be under vacuum for RGD operation (e.g., e-beam welders, scanning electron microscopes).
3.3.4 Audible and Visible Warning Signals
1. Cabinet x-ray systems must have two independent means that indicate when radiation is being generated, or when the RGD system is enabled to produce radiation.
a. If the radiation generation period is less than one-half second, the indicators must be activated for at least one-half second, and must be discernible from any point at which initiation of radiation generation is possible.
b. Failure of a single component of the system must not cause failure of both indicators to perform their intended function. It is acceptable for one, but not both, of the indicators to be a milliammeter labeled to indicate RGD tube current.
c. All other indicators must be legibly labeled “X-RAY ON” (or with similar words) and at least one indicator must be visible from each cabinet door, access panel, and port.
2. Cabinet RGD systems must have clearly legible and visible warning signs or labels.
a. A label indicating, ‘Caution: Radiation Produced When Energized,’ or other similar words, must be affixed or inscribed on the cabinet RGD system at the location of any controls which can be used to initiate x-ray generation.
b. A label indicating, ‘Caution: Do Not Insert Any Part of the Body When System is Energized – X-ray Hazard,’ or other similar words, must be affixed or inscribed on the
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cabinet RGD system adjacent to each port, or on the door(s) to the cabinet RGD system. A single label is sufficient if all doors can be seen from the same location.
c. The following are acceptable
— A single sign or label with similar words (e.g., ‘Caution: Radiation Generating Device; High levels of radiation are produced by the equipment in this enclosure’) is acceptable if the control system and the RGD cabinet are a single unit.
— Warning labels with similar words provided on the RGD by the manufacturer.
3.3.5 Physical Controls
1. Cabinet RGD systems must have:
a. A key-actuated control to insure that x-ray generation is not possible with the key removed. In cases where the RGD is software-controlled, key-actuated control may be achieved by use of keyed watchman stations coupled to the software-control, such that the RGD cannot be turned on without the keyed watchman stations being set.
b. A control or controls to initiate and terminate the generation of radiation other than by the functioning of a safety interlock or the main power control.
c. A permanent floor. It is acceptable to deem any support surface to which a cabinet RGD system is permanently affixed as the floor of the system.
2. Insertion of any part of the body through any port or aperture into the primary beam must not be possible.
3. An x-ray tube ground fault must not result in the generation of x-rays.
3.4 RGDs Occasionally Operated with ‘Open Beams’
3.4.1 Applicability
1. This section applies to RGDs that normally are operated in a housing or enclosure that separates the worker from the radiation beam, but where operational requirements make the use of a fully enclosed system during normal operation impractical. Examples include:
a. RGDs where there is a need for frequent changes of attachments and configuration, making adjustments with the x-ray beam on, motion of specimen and detector over wide angular limits.
b. Typical x-ray diffraction and fluorescence analysis equipment.
c. Flash or continuous wave RGDs installed on tanks.
2. This section does not apply to ‘RGD rooms’ where the worker might walk in the room containing the RGD, without an intervening enclosure (e.g., low-voltage neutron generators, radiography RGDs, calibration facilities). See Sections 3.5 and 3.6.
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3.4.2 Shielding
1. Unless otherwise specified, the inherent shielding of the enclosure and RGD housing must be sufficient to limit the dose rate to 0.5 mrem in an hour when measured 5 cm (2 in) from its outer surface during normal operation.
a. The ‘RGD housing’ refers to the RGD tube in combination with its housing, typically containing beam ports and shutters.
b. The ‘enclosure’ refers to the structure (e.g., a Plexiglas box with sliding doors) in which the RGD housing resides.
c. This shielding criteria includes
— The dose due to unwanted, stray, or anticipated accidental scatter.
— Leakage radiation from components such as high-voltage rectifiers.
2. When operated in an open-beam mode:
a. Radiation levels external to the RGD tube housing with all shutters closed must not exceed 2.5 mrem in an hour as measured at 5 cm (2 in) from the surface of the housing within which an RGD tube is operating at full rated power at maximum rated accelerating potential.
b. Radiation dose levels in the vicinity of controls and adjustments of the x-ray accessory apparatus used during normal operation must not exceed 25 mrem in an hour to the extremities or 2.5 mrem in an hour to the whole body.
3. Diagnostic and utility penetrations (e.g., electrical, cooling water, or optical systems) must be adequately shielded to meet the specified dose criteria.
3.4.3 Radiation Safety Interlocks
1. Fail-safe interlocks must be provided on:
a. The RGD control console, such that turning the key to the off/safe position, or activating a ‘crash’ or ‘emergency off’ button, interrupts the high-voltage supply.
b. The RGD housing (if applicable), such that
— The high voltage to the RGD tube is removed if the tube is removed from the tube housing or the housing is disassembled.
— The beam shutter is interlocked with the x-ray accessory apparatus coupling, or collimator, in such a way that the port will be open only when the collimator or coupling is in place.
c. Enclosures to flash RGDs, such that entry is prevented when the high-voltage system is charged (or while it is being charged). When the interlock is opened, the high-voltage must be automatically grounded.
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d. Enclosures needed to prevent access to High Radiation Areas during normal operation.
— Interlocks are not required on doors or panels that can be opened or removed only with tools.
2. ‘Routine’ interlock bypasses (e.g., for beam alignment on an x-ray diffraction device) must be designed to assure:
a. They are only temporary.
b. The bypass condition is immediately recognizable at both the control console and at the interlock location.
3.4.4 Audible and Visible Warning Signals
1. Fail-safe warning lights or devices labeled with the words “X-RAYS ON” (or other words having similar meaning) must activate when the RGD tube is energized.
a. These lights must be located
— Near any switch that activates the high voltage to energize an RGD tube.
— In a conspicuous location visible from all instrument access areas and near the radiation source housing and radiation beam(s).
b. The light must be illuminated
— To indicate when the RGD tube is energized.
— To indicate when an E-beam device is ‘on.’
— When a flash RGD system is charged (or is being charged).
c. Lights must be tested during the routine radiological safety assessment to ensure they are fail-safe, except as follows. If an LED array is used as the warning indicator, fail-safe testing is not required (as it is implausible that an array of lights would simultaneously burn out), as long as:
— The light function is tested during the routine radiological safety assessment.
— At least 75% of the individual LEDs are required to be operational.
2. RGDs with shutters must have a fail-safe ‘Shutter Open’ indication (e.g., warning light or device) mounted near the shutter to indicate the RGD’s status.
a. The ‘closed’ and ‘open’ shutter positions must be easily identified.
b. The indicator must activate when the ‘shutter open’ signal is initiated. [Consideration should be given to the use of materials other than lead for shutters (e.g., tantalum, tungsten) to avoid corrosion that high radiation levels can produce, possibly causing shutter operation to fail].
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3. An installed (fixed) area radiation monitor, or equivalent portable radiation detector with an alarm:
a. Must be in operation if any of the following conditions exists.
— The primary beam is accessible.
— Shielding can be easily removed.
— Interlocks can be easily bypassed.
— The radiation safety evaluation determines that installation of a safety monitor or safety box could prevent an inadvertent exposure.
b. Is not required if, due to technical limitations, a commercially available monitor is not capable of detecting the radiation hazard (e.g., for a pulsed radiation field).
3.4.5 Physical Controls
1. Beams with dose rates exceeding 0.1 rem in an hour must be provided with a guard (e.g., beam tubes) or interlock that prevents entry of any part of the body into the primary beam path when practical.
2. Each port of the radiation source housing must be covered with a radiation shield when not in use.
3. Shutters at unused ports must be secured to prevent casual opening.
3.5 RGD Rooms Containing Open-Beam Class II RGDs
An ‘RGD room’ is a permanent enclosure in which the RGD operates in an open-beam configuration, and in which the individual is intended to enter to conduct work. During Class II RGD operations, the worker might or might not be allowed access.
3.5.1 Applicability
1. This section applies to Class II RGDs operated in an RGD room, in an open-beam configuration, in a fixed facility in which people enter by walking.
2. This section does not apply to Class II RGDs operated in an enclosure that precludes the worker from walking into it, or is a tank or other similar structure. Such RGDs must be controlled in accordance with Section 3.3 or 3.4, as applicable.
3.5.2 Physical Controls
1. The controls for access to Radiological Areas specified in Document 20.1, Section 3.5.1, apply.
2. In addition, 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 an equivalent dose to the whole body of 1 rem in any one hour at 30 centimeters from the source or from any surface that the radiation penetrates:
a. 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.
b. A device that functions automatically to prevent use or operation of the radiation source or field while individuals are in the area.
c. 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.
d. Entryways that are locked. During periods when access to the area is required, positive control over each entry is maintained.
e. Continuous direct or electronic surveillance that is capable of preventing unauthorized entry.
f. 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.
3. The above controls are not required to be fail-safe or to be interlocked to the RGD control console.
4. No control(s) shall be established in a High Radiation Area that would prevent rapid evacuation of personnel.
5. Workers may be in the RGD room during Class II RGD operations, but they must not enter the ‘High Radiation Area.’
3.5.3 Shielding
Document 20.1, Section 4.0 provides the design objectives for new facilities and major modifications to existing facilities.
3.6 RGD Rooms Containing Open Beam Class III and IV RGDs
3.6.1 Applicability
1. This section applies to Class III and IV RGDs operated in a permanent enclosure (e.g., an RGD room or enclosure), in an open-beam configuration, in which people enter by walking.
2. This section does not apply to Class III and IV RGDs operated in an enclosure that precludes the worker from walking in (e.g., a Class III or IV RGD operated in a cabinet that cannot be entered by walking). These RGDs must be controlled in accordance with Section 3.3 or 3.4, as applicable.
1. Workers must be excluded from RGD rooms and enclosures during open beam Class III and IV RGD operations; herein, this area is generally referred to as the ‘exclusion area.’
2. There must be no means by which RGD operations can be initiated from within the exclusion area.
3. No control(s) shall be established in a High or Very High Radiation Area that would prevent rapid evacuation of personnel.
3.6.3 Shielding
Document 20.1, Section 4.0 provides the design objectives for new facilities and major modifications to existing facilities.
3.6.4 Radiation Safety Interlocks
1. Interlocks must be provided to prevent personnel access to the exclusion area during RGD operation.
2. Personnel safety interlocks (e.g., keyed watchman stations, run-safe boxes, door closure devices) must not be capable of being reset from the operator’s console (i.e., the RGD operator or designee must be required to go to the tripped personnel safety interlock to reset it).
3. Where a key is needed for resetting an exclusion-area interlock, the master key, or a key kept only on the master key ring, must be necessary.
4. All doors and panels opening into a High Radiation Area (except those that can be opened or removed only with tools) must be equipped with a fail-safe interlock or a device that prevents irradiation unless the door or panel is closed. The interlock or device must either cause:
a. The level of radiation to be reduced below 0.1 rem in any one hour at 30 cm from the source, or
b. A visual and audible alarm signal to energize upon entry into the area.
3.6.5 Visible Warning Signals
1. A visible warning signal must automatically activate:
a. When the RGD is armed (or being armed) to fire (e.g., for flash or pulsed RGDs).
b. During RGD operation (for continuous wave RGDs).
a. Conspicuous. A flashing or rotating beacon or a light that produces a similar effect (e.g., a variable intensity light-emitting beacon) is preferred. The light should be magenta in color.
b. Provided on the RGD console, and at the entrance to and within the RGD room.
— A single light at the entrance is sufficient if it is also visible from within the room.
— Signs indicating the meaning of the visible signals must be legible and conspicuously posted when the RGD is operational.
3. With the concurrence of the RGD Safety Officer and if documented in the Characterization form, it is acceptable to use either of the following in lieu of a visible warning signal:
a. Each personnel access to an exclusion area must have a minimum of two redundant interlocks. At least one of the required interlocks must be such that opening of any RGD enclosure room door results in automatic physical disconnection of the energy supply circuit to the high-voltage generator.
b. An audible signal that actuates when the RGD is armed (or being armed) to fire (e.g., for flash or pulsed RGDs) and during RGD operation (for continuous wave RGDs).
— Chimes should be used to indicate radiation is being generated.
— During normal operations, constant use of audible signals that can be heard outside the RGD room is discouraged due to the potential desensitization of workers toward responding to alarms.
— The specifications for audible signals are provided in Section 3.6.6.
3.6.6 Additional Control Measures for Very High Radiation Areas
1. A room that contains a Very High Radiation Area due to operation of the RGD shall implement two or more of the physical control measures specified in Section 3.5.2 to ensure individuals are not able to gain unauthorized or inadvertent access to Very High Radiation Areas.
2. An RGD room that contains a Very High Radiation Area must have the following features within the exclusion area:
a. Both audible and visible warning signals that actuate a minimum of 20 seconds immediately before irradiation can be started after closing the last door designed to admit people.
— The audible signal should be silenced approximately 20 seconds after activation if it can be heard by workers outside the exclusion area.
— Failure of any single component must not cause failure of both the audible and visible warning signals while allowing the RGD to operate.
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— For facilities in existence prior to 2010, dimming the lights and making an announcement (as required in areas with timed key-lock watchman stations) meets this requirement.
b. An emergency shutdown switch (i.e., a ‘run-safe’ box) if a person could become trapped in the room when the RGD is on.
c. Key-lock watchman stations if the exclusion area is large or complex such that the area cannot be visually inspected from a single location.
d. Area radiation monitors. The purpose of the area radiation monitor is to provide an independent means of alerting a worker who is inadvertently in the exclusion area that the RGD is producing radiation.
— Area radiation monitors must be installed in RGD rooms with the potential for unplanned increases in dose rates (e.g., from inadvertent operation of the RGD) and in remote locations where there is a need for local indication of dose rates prior to personnel entry.
— When the RGD room is small and simple and can be visually inspected from a single location, the area radiation monitor may be placed either in the RGD room or at the door (on the occupied side of the door) such that the monitor will alarm if the RGD is ‘on’ and the door is open, but will not alarm when the door is closed.
— The need for and placement of area radiation monitors must be documented and reassessed to ensure they accomplish their intended function when changes to facilities, systems, or equipment occur. The need for area radiation monitors must be documented on the Characterization form; the placement of the area radiation monitors may be documented on the Characterization form or other facility-specific document (e.g., the area radiation monitor design review, the facility safety plan (FSP), the Safety Analysis Document).
— Area radiation monitors are not required if the area monitor would not be effective in identifying the presence of radiation (e.g., where the radiation beam is highly collimated; flash RGDs), or to monitor for radiation resulting from radioactivation.
3. The audible signal must be:
a. Of a frequency or sound pressure level that can be heard over background noise.
b. Generally consistent for all Class IV RGDs operated within the same facility so that personnel can immediately recognize the signal’s meaning.
— Intermittent (i.e., pulsating) Klaxon horns are typically used to signal evacuation.
— Specifications for audible evacuation signals found in ISO 11429:1996 should be used whenever practicable.
4. Emergency shutdown switches (which might be integral to a watchman station) must:
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a. Be able to prevent and terminate radiation generation by interrupting the high-voltage supply.
b. Be placed within the interlocked area such that they are
— Readily accessible and located near entrances to and in exclusion areas where work could be performed.
— Clearly and conspicuously labeled as to use and function when the RGD is operational.
c. Not be able to be reset, overridden, or bypassed from outside the room.
5. Key-lock watchman stations must have the following features:
a. RGD operation must be impossible unless all watchman stations are reset with either the master key or a key that is always on the master ring.
b. Key-lock watchman stations must be
— Capable of interrupting the high-voltage supply.
— Located near entrances to and in exclusion areas where work could be performed.
— Placed in strategic positions within the exclusion area to guarantee that all locations within the area have been inspected prior to RGD operation.
c. Opening any entry to an area must necessitate manually resetting all watchman stations in that area.
d. If an individual could enter the exclusion area without being seen while the operator is arming the watchman stations, a key-lock watchman station with a timer must be installed such that the watchman station arming and concomitant inspection must be completed within a specified time period. For areas with timed key-locked watchman stations
— A conspicuous visible signal must be activated (e.g., dimming the lights, activating a beacon) and an audible voice or taped announcement must be made after completing a sweep and approximately 60 seconds prior to operating the RGD.
— The announcement must state that the RGD is about to be operated and personnel are to immediately turn the hazard-safe (run-safe) switch to SAFE and leave the area.
6. Area radiation monitors must have the following features:
a. A readout at the monitoring location and at the control console (or a single monitor visible from both locations).
b. A conspicuous visible or audible alarm that automatically actuates at a pre-established set-point.
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— For area radiation monitors located in the RGD room, the set-point must be exceeded when the RGD is operating.
— For area radiation monitors located on the occupied side of the shielding door, the set-point must be exceeded when the RGD is ‘on,’ presuming the door is open.
— The set-point must be documented in the RGD Characterization.
— The alarm must remain actuated whenever the dose rate from the RGD exceeds the alarm set point.
c. Where an area radiation monitor is incorporated into a safety interlock system,
— The circuitry must be such that a failure of the monitor either prevents entry into the area or prevents operation of the RGD.
— The circuitry must be fail-safe if the circuitry is required to ensure compliance with the access control requirements for exclusion areas.
3.7 Effluent Monitoring
1. Radiation effluent monitoring might be required if significant air, gas, or dust activation is expected as a by-product of operating a high-energy (>15 MeV) RGD.
2. The Responsible Individual (RI) must contact the ES&H Team environmental analyst to determine the need for effluent monitoring.
3.8 Verification and Validation of Design
3.8.1 Design Reviews
1. A formal design review must be conducted prior to routine operation in a new Class III or IV RGD room, or modifications to such that affect radiation shielding effectiveness or interlock systems.
a. The design review must
— Document that the design elements specified in Section 3.6 (e.g., facility shielding, interlocks, run-safe boxes) have been appropriately identified and incorporated.
— Be conducted by someone skilled in the elements being evaluated (e.g., an electrical engineer for evaluating interlock designs; a health physicist for evaluating overall facility layout, shielding, safety controls).
— Be concurred with by the ES&H Team health physicist or the RGD Safety Officer. Signature on the design review package provides sufficient documentation of the review and concurrence.
b. Formal design review requirements for RGD rooms do not apply to ‘field radiography’ work activities.
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3.8.2 Acceptance Testing of Shielded Enclosures
1. Once a shielded enclosure is designed and installed, it must be ‘acceptance tested’ to ensure it meets the design criteria.
a. It is permissible to conduct the acceptance test in concert with the RGD Characterization. During the acceptance test, specific attention must be paid to
— Joints in shielding.
— Penetrations in shielding.
— Shutters, ensuring they adequately cover the port when closed.
— Doors, windows, and other access points that might be of different composition than the main shield.
b. If leakage or insufficient shielding is present, either
— Operating parameters must be curtailed.
— Additional shielding must be provided.
— Administrative controls must be imposed and documented in the work control document.
c. The ES&H Team health physicist must concur with the acceptance test results. It is acceptable to document concurrence via memo, concurrence signature on the acceptance test results, or other similar means.
3.8.3 Safety Software
Software used for safety purposes (e.g., software used to control access systems to exclusion areas) must be compliant with DES-0115, LLNL Quality Assurance Program. This document includes the LLNL requirements for Software Quality Assurance (SQA) and is compliant with the requirements contained in DOE Order 414.1C, Quality Assurance.
4.0 Work Planning
This section contains requirements and controls that workers and the Authorizing Organization must be aware of and implement during the work planning process. Section 5.0 contains controls that pertain to the conduct of ongoing work.
4.1 Acquisition of RGDs
4.1.1 Approval for Acquisition of an RGD
1. The RCM or designee must approve the acquisition of an RGD whether purchased, borrowed, provided by others (e.g., other DOE contractors, universities, or companies), or constructed by LLNL.
— RGDs that are within the scope of this document.
— RGD tube heads.
b. Approval is not required for the acquisition of
— RGD power supplies.
— RGD replacement parts (other than the tube head).
2. Acquisition approval must be documented. RCM (or designee) approval of the procurement requisition or an e-mail from the approving individual provides sufficient documentation.
3. The individual approving acquisition of an RGD must notify the RGD Safety Officer of the pending acquisition and pre-assign an RGD number.
4.1.2 RGD Acceptance Testing
1. Acceptance testing of an RGD is usually conducted by the Vendor to ensure the RGD functions as specified in the purchase order. It does not include developmental work at LLNL prior to the RGD being used for ‘normal programmatic operations.’
2. Acceptance testing of an RGD:
a. Must be authorized with an Integration Work Sheet (IWS), a Procured-Services Work Sheet (PWS), or other approved work control document.
b. Is permitted to be conducted
— Prior to registration (see Section 4.2.1) and the initial characterization of the RGD.
— Utilizing ‘field radiography’ controls (i.e., without the normally required engineered controls).
4.2 Characterization of the RGD
4.2.1 General Information
The controls in this section pertain to LLNL-owned RGDs, and not to RGDs used on-site by vendors, visitors, and subcontractors.
1. Each RGD must be assigned to an RGD Custodian. Unless otherwise specified in the IWS or other work control document, the RI is the RGD Custodian.
2. An RGD consists of the component that actually generates radiation (e.g., the RGD tube) and its control console.
a. If these components are integral to each other (e.g., a Phillips 3100 x-ray diffraction device), 1 RGD number will be issued.
b. If an RGD has more than one tube head (e.g., as with a flash x-ray system), each tube head must have an individual identification number.
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c. Tube heads that are maintained as ‘spare parts’ must have an individual identification number but do not have to be associated with a specific RGD.
3. It is acceptable to include multiple tube heads and multiple RGDs on a single Characterization form if the administrative and technical information is the same for each RGD and tube head.
a. The health physicist will:
— Obtain an RGD number (from the RGD Safety Officer) for each RGD and associated tube head.
— Apply the RGD labels, as specified in Section 4.3.3.
4. The RGD Safety Officer should issue RGD and tube head numbers as follows:
a. RGD numbers should be issued sequentially and should not be reused. For example, if RGD 888 is disposed of, ‘888’ should be ‘retired’ and not be reissued to another RGD.
b. An RGD that is configured from the parts of other RGDs must
— Be characterized by the ES&H Team health physicist.
— Either retain the RGD number on the control console, or the ‘old’ parts must be ‘retired’ in the RGD Safety Officer’s inventory record and a new RGD number must be assigned.
c. Tube heads associated with a specific RGD (e.g., RGD # xxx) should be numbered as RGD-xxx-HD-y, where
— xxx is the RGD number.
— y is a numerical value (1-n) indicating the Head number.
For example, if the RGD has one control console (numbered ‘RGD 999’) and the RI has 3 replacement heads, the tubes should be numbered as follows:
— RGD-999-HD-1, RGD-999-HD-2, RGD-999-HD-3.
d. Tube heads that are maintained as ‘spare parts’ and are not identified with a specific RGD should be numbered as RGD-NA-HD-y, where
— y is a numerical value (1-n) indicating the Head Type number.
e. It is acceptable to use tube heads that are identified with a specific RGD or maintained as ‘spare parts’ on another RGD, if the following conditions are met.
— The tube head is within the parameters established on the Characterization form (e.g., a ‘like-in-kind’ replacement).
5. The RGD Custodian must:
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a. Ensure the tube head remains associated with the assigned RGD tube number in cases where the tube head container (as opposed to the tube head itself) is labeled.
b. Notify the ES&H Team health physicist or RGD Safety Officer in writing (e.g., via e-mail) when a tube head is destroyed, broken beyond repair, or otherwise disposed of.
c. Ensure the inventory record maintained by the RGD Safety Officer is corrected during the routinely-scheduled inventory/safety assessment.
d. Notify the Authorizing Individual (AI) and the Assurance Manager if an RGD or a tube head cannot be located during the routinely-scheduled inventory/safety assessment.
4.2.2 Initial Characterization of the RGD
1. LLNL-owned RGDs must be initially characterized prior to their operation (other than acceptance testing) and within one month of delivery on-site to determine the appropriate RGD Class and assure accountability of the RGD.
a. The information specified on the Initial RGD Characterization form is needed to generate the Complete Characterization Form.
b. The initial characterization documents administrative and technical information associated with the RGD, but does not require identification of the associated safety systems. The RGD Safety Officer may modify the Initial Characterization form as needed.
c. RGDs do not have to be operational to be initially characterized. The output of the RGD (needed for determination of the RGD Class) may be determined by:
— Manufacturer-provided information regarding the RGD’s output. — Calculated output based on RGD parameters (current, voltage, on-time, etc.). — Direct measurement of the RGD output. — Other methods as deemed acceptable by the RGD Safety Officer.
d. The Initial Characterization information may be provided to the RGD Safety Officer informally if the Complete Characterization Form is to be completed within 1 month.
e. A Complete Characterization may be submitted in lieu of the initial characterization.
2. The RGD Custodian must contact the ES&H Team health physicist and arrange for the RGD to be initially characterized.
3. The ES&H Team health physicist must provide the Initial Characterization Form and:
a. Review the information on the Initial Characterization form and ensure it is complete and accurate.
b. Determine the RGD Class. (Table 1 provides RGD Class parameters.)
c. Determine if the RGD is excluded from DOE Order 420.2C.
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d. Input the information into the RGD database, or provide it to the RGD Safety Officer.
4. The RGD Safety Officer must
a. Ensure the requisite information is entered into the RGD database.
4.2.3 Complete Characterization of the RGD
1. The RGD Characterization must be:
a. Finalized prior to programmatic operation of non-exempt RGDs. Programmatic operations include both developmental and routine operations.
— The RGD Custodian and the ES&H Team health physicist should review the Characterization form in conjunction with developing controls for the associated work control document.
— The RGD Custodian must ensure the controls in the work control document and the Characterization form are consistent.
b. Approved by the RGD Safety Officer, who will provide the RI with a copy of the approved Characterization form.
2. In cases where operating parameters are routinely changing (increasing), the requirement to recharacterize the RGD can be eliminated by:
a. Requiring safety systems appropriate for the higher operating parameters. For example,
— Requiring a shield thickness that provides the requisite amount of shielding at the higher operating level.
— Classifying the RGD at a higher Class level to invoke more rigorous safety controls.
b. Clearly stating (and limiting) the extent of allowed increases on the Characterization form (e.g., ‘Shielding is sufficient for current and voltage settings up to xxx kV and xxx mA. A recharacterization and resurvey is required prior to exceeding these values’).
3. The RGD Characterization documents administrative and technical information associated with the RGD and the associated safety systems. The Characterization form contains the following type of information; the RGD Safety Officer is permitted to revise the form as deemed appropriate.
a. Administrative information associated with the RGD.
— Location.
— RGD Custodian.
— RGD components and serial numbers.
b. The basis for the Class of RGD.
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— The design of the RGD (e.g., enclosed or open beam, flash or continuous wave, portable or fixed facility).
— The “Max RGD settings” (i.e., the maximum dial settings on the RGD).
— The radiation dose rate produced by the RGD if operated at the maximum RGD settings (thus producing the maximum beam output). Radiation intensity might be determined by calculation, vendor provided information, direct measurement, or other method acceptable to the RGD Safety Officer.
— Potential accidental doses.
c. The Approved Operating Parameters.
— The Approved Operating Parameters (historically, the “Max Approved settings”) must be established at a level that ensures the shielding is sufficient to maintain radiation doses ALARA, and the tube is not damaged.
— The ES&H Team health physicist must determine the amount of shielding needed given the desired “Approved Operating Parameters,” or conversely, the maximum operating parameters allowed, based on the amount of shielding present.
— The RGD Custodian might further limit the ‘Approved Operating Parameters’ based on tube longevity or other programmatic issues.
d. Controls necessary for RGD operations, including, but not limited to
4. If a radiation survey is conducted to characterize the beam output:
a. The survey should be conducted inside the enclosure, including in the primary beam, if accessible.
b. For pulsed radiation fields, small beam sizes, and primary beam measurements, the survey should be completed using thermoluminescent dosimeters.
c. The survey must be conducted with the RGD operating at the ‘‘Max RGD settings” or at lower levels which are then scaled to reflect the ‘‘Max RGD settings.” For example, if the measurement is made with the RGD operating at half the ‘‘Max RGD current,” the measured dose would be doubled to determine the beam output.
d. The survey should be documented on the standard survey form (e.g., the ‘Radiation/Contamination Survey Log Sheet’).
5. The ES&H Team health physicist must determine the RGD Class based on:
a. The portion of the body most likely to be exposed (e.g., whole body, extremity).
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— Cabinet RGDs and RGDs operated with ‘occasionally open beams’ typically present ‘extremity’ hazards.
— RGDs operated in an open-beam configuration within a room typically present a ‘whole-body’ hazard.
— RGDs that can readily be removed from their housing are usually considered to be a ‘whole-body’ hazard.
b. The dose rate at a location closest to the source where the whole body, or a portion of the body (e.g., a finger) could intersect the radiation beam, presuming the RGD is operated at its “Max RGD settings” (i.e., the maximum dial settings on the RGD) and control devices such as shutters and interlocks are NOT in place. For example,
— For RGDs installed in a beam-pipe that is 10 feet long (with no other access points), the exposure distance would be 10 feet. If the 10-foot long pipe had access ports every 2 feet, the exposure distance would typically be 2 feet.
— For RGDs where the interlocked sample chamber is 4 inches from the anode, a distance of 4 inches is appropriate.
— For RGDs that can readily be removed from their housing, and for open-beam RGDs operated in an RGD room, a distance of 1 m is generally appropriate.
c. The time the individual could reasonably spend in the exposure area before recognizing the situation (typical values are 0.1 minute, 1 minute, 10 minutes, or 100 minutes).
— Selection of an exposure time is somewhat subjective; if a consensus cannot be reached regarding the most appropriate exposure time, the RGD Safety Officer is responsible for making the determination.
— Factors that could serve to diminish how long the exposure might go undetected include (but are not limited to) the presence of area radiation monitors; RGDs that make distinctive noise when they operate; the presence of other physical warning devices, and the typical operational work cycle.
— Administrative controls (such as using a radiation detector prior to entering the area) should not be relied upon to limit the exposure time.
6. RGDs that are excluded from RGD-specific controls (as specified in Section 1.1.1) are referred to as ‘EXEMPT’ and do not require a Characterization form.
a. If a Characterization form (or an Initial Characterization form) is completed and results in the conclusion that the RGD is ‘exempt,’ then
— The ES&H Team health physicist should submit the Characterization form to the RGD Safety Officer.
— The ES&H Team should label the RGDs as ‘Exempt’ to minimize future questions as to whether or not the RGD requires characterization.
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— The RGD Safety Officer must enter the ‘exempt’ RGD in the database and retain the Characterization form in the RGD files.
b. ‘Exempt’ RGDs do not require specific RGD-authorization, periodic inventory, or periodic radiological safety assessment/radiation surveys.
c. Prior to modifying an ‘exempt’ RGD, the RGD Custodian must notify the ES&H Team and obtain a reassessment of the RGD status.
7. Controls for unique RGDs are allowed to be uniquely established with the concurrence of the RGD Safety Officer.
a. The RGD Characterization form must include the unique controls and an explanation of why the ‘normal’ controls are not appropriate or applicable (e.g., ‘radiation monitors are not capable of detecting the nanosecond pulse width’).
b. The RGD Safety Officer’s signature on the RGD Characterization provides sufficient documentation of concurrence.
4.3 Posting, Labeling, and Physical Barriers
General requirements for radiological area postings, barriers, and exceptions to posting/barrier requirements are contained in Document 20.1. General posting and barrier requirements that pertain primarily to RGDs are presented below.
4.3.1 Area Postings
1. Each access point to a radiologically-controlled area that is not a Radiological Area must be posted as follows:
a. A CAUTION Radiation Generating Device Area sign
— Must be posted if the area contains Class II, III, or IV RGDs.
— Must be posted in addition to a CAUTION Radioactive Material Area sign, if both conditions apply.
— Should be posted to contain the RGD control console if it is contiguous with the exposure area.
— Is not required for portable RGD operations.
b. A CAUTION Radiological Buffer Area sign
— Must be established when necessary to limit the total effective dose (TED) to general employees to <0.1 rem per year, taking into account expected stay times, or as needed to keep radiation doses to general employees ALARA.
— Should be posted as needed to limit doses to general employees who have not been trained as radiological workers.
c. A radiological buffer area is not warranted for exposure control, if
— Other posted boundaries or controls provide equivalent employee protection.
— General employees who are not trained as radiological workers are restricted from unescorted entry to controlled areas.
— General employees who are not trained as radiological workers are unlikely to be present in the area long enough to receive 0.1 rem in a year.
d. The following ‘historical’ signs are permitted to remain posted (in lieu of the ‘Radiation Generating Device Area’ sign) if they accurately reflect the area conditions
— CAUTION X-ray Area.
— CAUTION Accelerator Area.
2. Each access point to a Radiological Area shall be conspicuously posted if an individual could receive the following equivalent doses to the whole body:
a. Radiation Area: 0.005 rem (5 millirem) in one hour at 30 cm from the source or from any surface that the radiation penetrates.
b. High Radiation Area: 0.1 rem (100 mrem) in one hour at 30 cm from the source or from any surface that the radiation penetrates.
c Very High Radiation Area: 500 rad in one hour, at one meter from the source or from any surface that the radiation penetrates.
3. High-energy accelerators can activate dust and other materials in the area and potentially create a Contamination Area. See Document 20.2 for postings and labeling requirements for radioactive material and Radioactive Material Areas.
4.3.2 Barriers
1. Radiation Areas shall be physically delineated by a barrier such as a rope, wall, room, or other physical impediment such that workers are made aware of the radiological condition (via the barrier and radiological posting) prior to entry into the area.
4.3.3 RGD Labels
1. Each RGD must be labeled with:
a. A ‘Caution Radiation-Generating Device—Approved Operating Parameters’ label. The label
— Must be located on the RGD console or other appropriate location.
— Must contain a unique RGD number provided by the RGD Safety Officer.
— Must contain the approved operating parameters as reflected in the Characterization.
— Does not need to contain the approved operating parameters if the RGD is not operational.
b. A ‘Caution Radiation-Generating Device—Head’ label on each head or head container, if more than one head is used with a controller. The label must
— Contain a unique head number provided by the RGD Safety Officer.
— Indicate the associated RGD number.
c. A ‘Caution Radiation-Generating Device’ label placed close to each port on the tube housing, if feasible.
— Manufacturer provided labels are acceptable.
— Class I devices do not require this label.
d. A ‘Date Surveyed/Next Survey Due’ sticker attached to the control console or other appropriate location. This sticker is not necessary if the RGD is
— Waived from periodic RGD radiological safety assessments/radiation surveys.
— Not operational.
2. RGDs that have been specifically evaluated and determined to be exempt should be labeled with an ‘Exempt RGD’ sticker, which is available from the RGD Safety Officer. This non-mandatory label indicates that the RGD was initially characterized.
3. RGDs that are in the work area but are ‘non operational’ for administrative or physical reasons:
a. Must be labeled as ‘Not Operational.’
b. Should be labeled with additional information indicating why the RGD is ‘not operational’ (e.g., awaiting repair, IWS suspended, safety assessment/radiation survey/interlock test needed).
c. Must have a current ‘Date Surveyed/Next Survey Due’ sticker at the time it is put into service.
4. RGD heads that are separate from the RGD must have a unique RGD-head number. The RGD-head label must be applied on either:
a. The tube head.
b. The tube head container [e.g., as a sealed radioactive source (SRS) label might be applied to the SRS container, not the SRS itself].
4.4 External Dose Monitoring
External dose monitoring requirements are specified in Document 20.1, Section 3.3. The following information is specific to RGD operators and others working in close proximity to RGDs. The ES&H Team health physicist is permitted to increase the basic monitoring requirements. If multiple monitoring requirements apply (e.g., due to operations in multiple facilities), the most conservative must be implemented.
Whole-body dosimeters should be issued and exchanged at least quarterly unless the ES&H Team health physicist specifies otherwise in the work control document.
4.4.2 Class II, III, and IV RGD Operations
1. Whole-body dosimeters should be issued and exchanged monthly, unless otherwise specified by the ES&H Team health physicist in the work control document.
2. A supplemental whole-body dosimeter (or other means capable of providing an immediate estimate of the individual’s integrated equivalent dose to the whole body during the entry) shall be worn during access to High and Very High Radiation Areas.
a. Document 20.1, Section 3.3.3 contains requirements for using supplemental dosimeters and responding to unexpected readings.
3. Extremity dosimeters (e.g., finger rings or wrist dosimeters) must be worn if specified by the ES&H Team health physicist in the work control document. Specific operations that might warrant the use of extremity dosimeters include:
a. Sample changing.
b. Target changing.
c. Interlock bypass operations.
d. Beam alignment.
e. Open-beam operations.
4.5 Written Authorizations, Safety Plans, and Technical Work Documents
4.5.1 Written Authorizations
1. A written authorization (e.g., an IWS or a PWS for Vendor-provided support) must be in place:
a. To operate a Class I, II, III, or IV RGD, including for
— RGDs owned by others (e.g., Vendors, other DOE contractors, other federal agencies).
b. To purposely break an RGD tube (e.g., to render it nonfunctional for the purposes of disposal).
c. To control entry into and to perform work within Radiological Areas (e.g., Contamination/High Contamination Areas, Airborne Radioactivity Areas, Radiation/High Radiation Areas).
2. In addition to the written authorization, a safety plan (SP) (e.g., an FSP or IWS/SP) must be in place prior to routine programmatic operations with an LLNL-owned Class III and IV RGD.
3. The following operations, along with the associated hazards and controls, must be specifically called out in the written authorization.
a. Safety-interlock bypass operations (e.g., use of jumpers or key switches), including those installed by the manufacturer.
— For non-routine interlock bypass (e.g., for maintenance and repair), a second person, knowledgeable about the interlock bypass, must be in attendance and provide safety oversight.
b. Open beam operations.
c. Field radiography (as defined in Appendix A).
4. The IWS or SP (or other work control document) must include:
a. The controls necessary to ensure that radiation doses are kept ALARA.
b. Supplemental dosimeter requirements, as needed.
c. The requirement for a trained worker to be the first person to enter the exposure area following RGD operations.
5. For field radiography, the IWS or SP must ensure the following:
a. ALARA
— Operations shall be conducted such that personnel radiation exposures are maintained ALARA.
b. Access Controls
— Access to Very High Radiation Areas must not be allowed.
— Access to High Radiation Areas must be restricted, unless specifically authorized in the SP.
— Controls must be specified to manage and control access to all Radiation Areas. Section 3.5.2 contains the Rule requirements for physical controls to High Radiation Areas.
c. Area Sweeps
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— An RGD operator must perform a rigorous sweep of all potential High Radiation Areas and Very High Radiation Areas before each RGD operation of a Class II or IV device.
— It is acceptable to omit this sweep if access to these areas has been continuously guarded (at access points) and monitored (direct observation of area or enclosure) since the last sweep was performed.
d. Posting and Labeling
— Radiological area postings and barriers shall be used as specified in Section 4.3.
— LLNL labels are not required on non-LLNL RGDs.
e. Personnel Monitoring
— RGD operators must wear real-time dosimeters that alarm at pre-established set points.
— A radiation survey instrument or area radiation monitor with appropriate energy response characteristics must be available for use during Class II, III, and IV RGD operations. (Note that pulsed radiation fields might cause severe dead-time problems in certain instruments.)
f. Radiation Surveys
— A documented radiation survey must be conducted upon initial operation of the RGD to confirm dose rates in occupied areas and that Radiation Area boundaries are properly identified and controlled.
— Documented surveys must be repeated after operational changes (e.g., changing the beam direction of the RGD) that could result in increased dose rates at these locations.
— A trained worker must be the first person to enter the exposure area following RGD operations and shall carry an operating radiation detector capable of identifying that the RGD is ‘on.’
g. RGD Characteristics
— The RGD class, associated hazards, and safety features must be identified. (This information might take the place of a formal RGD characterization for non-LLNL RGDs.)
h. RGD Operators
— For Class III and IV RGD operations, two qualified RGD operators must be present during radiography operations and must ensure the RGD is operated safely and safety controls are effectively implemented. (It is acceptable for one of these operators to have “in training” status.)
— Unattended RGD operations must not be allowed.
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— One operator must be designated to be responsible for control of the RGD key (or enabling device) at all times when RGD operations are possible.
i. Safety Observer
— A Safety Observer must be present during radiography operations using Class IV RGDs to verify that administrative controls are effectively implemented.
— The Safety Observer must be knowledgeable of radiological hazards associated with field radiography and the SP controls and be independent from the work task.
6. The following ES&H Manual documents contain relevant information for completing the written authorization and SP.
a. Document 3.3, “Facility Safety Plans and Integration Work Sheets with Safety Plans.”
b. Document 2.2, “LLNL Institution-Wide Work Planning and Control Process.”
4.5.2 Hold Points
Hold points are specific steps or conditions that require work to pause and a decision to be made in order for work to continue. Note: Any employee must pause work any time an unanticipated condition occurs that the employee considers potentially unsafe. By doing so, the employee effectively injects a “hold point” into the work activity without that hold point having been identified in advance.
The threshold for including hold points is somewhat subjective and varies depending on how much is known of the actual conditions, the skill and experience of the workers, the newness of the operation, and the potential consequences of the operation not going as planned. Hold points are not needed in all procedures; ultimately, it is the responsibility of the RGD Custodian (RI), with support from the ES&H Team, to identify appropriate hold points.
1. Hold points are intended to prevent “significant adverse radiological conditions” by ensuring implementation of required controls. Therefore, hold points must be used:
a. To identify conditions that require additional ES&H input, such as changing radiological conditions.
b. To identify conditions which require a programmatic decision to be made.
c. To promote prompt communication of off-normal conditions and solicitation of ES&H support, as appropriate.
2. The radiological control hold point must state the criteria that must be met or action that must be taken to satisfy the hold point prior to continuing with subsequent steps in the planned activity.
a. Hold points must be identified during the work planning process and should be specified as a response to anticipated, potentially unsafe conditions that might arise during performance of the work. Hold points might also be specified for programmatic reasons.
b. It is acceptable to specify hold points for general operations/conditions (e.g., response to detection of a failed interlock) in higher-tier documents (e.g., the FSP).
c. Hold points for specific operations or activities must be specified in the applicable work control document (e.g., the IWS, work permit) and discussed in the pre-job briefing.
3. If it is determined that a hold point has been missed, workers must place work in a safe configuration, pause work, and contact the RI for additional guidance.
4.5.3 Technical Work Documents
1. The Authorizing Organization shall develop and implement RGD operating procedures.
a. The formality and level of detail for these procedures is expected to vary significantly depending upon the complexity and frequency of operations, skill and training of the workers, and the number of administrative controls needed to conduct work activities safely.
b. Use of manufacturer-provided operating procedures is acceptable, so long as they adequately cover the work activity.
2. Written procedures must be established and used for:
a. Interlock tests. Test procedures must clearly identify
— The equipment being tested, person performing the test, and date of test.
— The testing action to be taken, required satisfactory result, and actual test results for each component or set of components tested (i.e., each switch or set of switches). Each of these steps should indicate that the result was satisfactory, or unsatisfactory.
— Actions to be taken for any unsatisfactory result. The ES&H Team health physicist and the RGD Safety Officer must be notified, in writing, if the unsatisfactory result would have prevented the system from performing its intended safety function, if challenged.
— Compensatory steps if redundant components are not independently tested. For example, if eight radiation detectors input to an interlock system, independent testing might result in unacceptable wear (damage) to RGD components. It might be acceptable to response test and inspect each instrument, then select one or two instruments (on a rotating schedule) to functionally test the interlock system.
— The overall test results, corrective actions taken (if any), and the signature (or printed name and initials) of the person performing the test.
Document 12.1 contains additional requirements and guidance for testing interlock systems.
b. Calibration of Area Radiation Monitors, if not calibrated by the Radiation Calibration Laboratory (RCL) (in the Radiation Protection Functional Area). Calibration procedures and associated records must clearly identify
— The equipment being calibrated, person performing the test, and date of test.
— The ‘as found’ readings for each detector (identified by serial number).
— The calibration action to be taken, required satisfactory result, and actual results for each detector.
— Actions to be taken for any unsatisfactory result.
— The overall calibration results, corrective actions taken (if any), and the signature (or printed name and initials) of the person performing the test.
Note: PRO-0124, Control and Handling of Critical Measuring and Test Equipment, provides additional calibration requirements.
c. Area Radiation Monitor function tests. Function test procedures must clearly identify
— The equipment being function-tested.
— Actions to be taken to conduct the function test along with the required satisfactory result.
— Actions to be taken for any unsatisfactory result.
— Documentation requirements.
d. Operating an RGD.
— Procedures documented by the manufacturer of the x-ray system are generally sufficient.
— A site-specific (LLNL-generated) procedure must be developed if the radiation source housing and/or x-ray accessory apparatus are not compatible components supplied by the same manufacturer (i.e., are nonstandard), or the RGD has been modified in a manner that precludes following the manufacturer’s procedure.
— Normal operating procedures must be such that a qualified operator following instructions will not receive in any one hour an equivalent dose in excess of 0.025 rem (25 mrem) to the extremities or 0.0025 rem (2.5 mrem) to the whole body.
e. Radiation beam alignment procedures.
— Alignment procedures recommended by the manufacturer of the x-ray system must be used when available.
— Special alignment procedures must not be used unless approved by the ES&H Team health physicist and the RGD RI.
— Alignment procedures should be such that a qualified worker aware of the radiation hazards will not receive in any one hour a dose equivalent in excess of 0.025 rem (25 mrem) to the extremities or 0.0025 rem (2.5 mrem) to the whole body while following these instructions. If either of these dose rates is likely to be exceeded, a warning must be included in the alignment instructions.
f. Ensuring RGD program requirements have been completed prior to RGD operation.
— Critical M&TE is in calibration and has been function-tested in accordance with facility procedures.
— The RGD Characterization is complete and up-to-date.
— The safety assessment/radiation survey (including interlock testing) has been completed within the required time interval.
— RGD safety features (e.g., warning indicators, interlocks) are operational.
3. These written procedures:
a. Must be approved by the RGD Custodian, who is responsible for ensuring the procedure is adequate for the equipment and operation.
b. Must be reviewed by and have the documented concurrence of the E&SH Team health physicist, except as noted below. Sufficient documentation is provided by
— The health physicist’s signature on the procedure (preferred method).
— Concurrence with IWS or work control document, if the procedure is referenced in and attached to the IWS or work control document.
c. Might be composed of the procedure(s) provided by the manufacturer, if the procedure is identified, referenced in the work control document, and available to the operators.
d. Manufacturer-provided operating procedures for unmodified Class I RGDs do not require the ES&H Team health physicist’s review.
4.6 Training
1. Document 20.1 contains provisions for the following:
a. Institutional training requirements for access to radiologically-controlled areas (i.e., areas posted with the radiation trefoil symbol) and for radiological work.
b. Local training requirements that might be required for work in specific facilities or organizations.
c. Retraining requirements and provisions for use of escorts in lieu of training.
2. For Class I RGDs, classroom training is not required.
a. A Hazard Information Sheet must be conspicuously posted next to the RGD or included in the SP. The Hazard Information Sheet is available from the RGD Safety Officer via the ES&H Team.
b. All individuals using or working on the RGD must read the Hazard Information Sheet.
c. If the IWS references the requirement to read the Hazard Information Sheet, sign-off of the IWS is sufficient documentation of training.
3. For Class II-IV RGDs, classroom training is required, as specified in Document 20.1.
1. Unless excluded or exempted by DOE under the provisions of DOE Order 420.2C, Safety of Accelerator Facilities, RGD operations must have a Safety Assessment Document (SAD) and a DOE-approved Accelerator Safety Envelope (ASE).
a. The Order directly excludes large classes of RGDs (including those incapable of delivering a significant whole-body dose). The ES&H Team health physicist must determine if the RGD is excluded from DOE Order 420.2C during the characterization process.
b. If not excluded, the Authorizing Organization must write and submit for DOE-Livermore Field Office (LFO) approval either an exemption request (if appropriate) or a SAD.
— The Radiological Control Organization can provide assistance in writing an exemption request.
— The Authorization Basis Group can provide assistance in writing a SAD.
2. The SAD must be current and consistent with the administrative controls and physical configuration of the facility and major safety equipment.
a. The SAD might be
— Incorporated into other equivalent documents (e.g., Safety Analysis Reports, Safety Analysis Documents).
— Prepared as a single document addressing the hazards of the entire accelerator facility or as separate SADs for discrete modules of the facility (e.g., injectors, targets, experiments, experimental halls, and other types of modules).
b. The SAD must contain the following, unless otherwise directed by DOE
— Hazards from both normal operations and credible accidents in the facility and associated on-site and off-site impacts to workers, the public, and the environment.
— Sufficient descriptive information and analytical results pertaining to specific hazards and risks identified during the safety analysis process to provide an understanding of the risks presented by the proposed operations.
— A detailed description of engineered controls (e.g., interlocks and physical barriers) and administrative controls (e.g., training) implemented to eliminate, control, or mitigate risks associated with the operation.
— A description of (or a reference to) the facility’s function, location, and management organization, as well as details of major facility components and their operation.
c. For additional information on writing a SAD, see
— Document 3.1, “Nonnuclear Safety Basis Program,” in the ES&H Manual.
— Safety of Accelerator Facilities Implementation Guide, DOE-G-420.2-1.
a. A documented ASE must define the physical and administrative bounding conditions for safe operations based on the safety analysis documented in the SAD.
b. Any activity violating the ASE must be terminated immediately, and the activity must not recommence before DOE/National Nuclear Security Administration (NNSA) has been notified.
c. The controls in the ASE constitute the SAD requirements and must be flowed down to the appropriate technical work documents (e.g., the IWS).
4. Unreviewed Safety Issues:
a. Activities that involve an Unreviewed Safety Issue (USI) (i.e., an activity that is not covered by the existing safety basis document) must not be performed until a USI review is completed to determine if significant safety consequences could result from either an accident or malfunction of equipment.
b. Activities involving an identified USI must not commence without written approval from DOE.
c. Document 3.1 provides requirements for preparing the paperwork associated with a USI.
5. Accelerator Readiness Reviews:
a. If a SAD is required, an Accelerator Readiness Review must be performed prior to approval of commissioning and routine operation, and as directed by the cognizant DOE secretarial officer or a field element manager.
b. See the prestart requirements in Document 2.2.
5.0 Conducting Routine Radiological Work
This section contains requirements and controls that workers and the Authorizing Organization must be aware of and implement during the conduct of ongoing radiological work.
5.1 Administrative Requirements
5.1.1 Approved Operating Parameters
1. RGD users must not exceed the “Approved Operating Parameters” indicated on the RGD label.
2. If an increase in the “Approved Operating Parameters” is needed:
— Conduct a radiation survey at the higher operating parameters.
— Post a revised ‘Approved Operating Parameter’ label on the RGD.
5.1.2 Requirements for Non-Operational RGDs
1. An RGD that is otherwise ‘authorized for use’ must be posted as ‘non-operational’ if either the safety assessment or radiation survey has not been completed within the specified interval:
a. The ES&H Team must
— Post and de-post the ‘non-operational’ sign indicating that a radiological safety assessment/radiation survey must be performed prior to operating the RGD.
— Notify the RGD Safety Officer of the deferral and the date(s) the safety assessment/radiation survey is completed.
b. The RGD Custodian must
— Ensure the RGD has a current safety assessment before operating the RGD.
— Ensure the RGD is inventoried on the routine schedule.
2. It is acceptable for the Authorizing Organization to post and de-post an RGD as ‘Non-operational’ for programmatic purposes (e.g., work pauses), subject to the following:
a. The ES&H Team must additionally post and de-post the official ‘non-operational’ sign if the RGD is otherwise authorized for use and the safety assessment or radiation survey has not been completed within the specified interval.
3. Controls for RGDs that are no longer programmatically needed (i.e., ‘out-of-use RGDs’) are contained in Section 5.6.3.
4. Non-operational and out-of-use RGDs:
a. Are subject to an annual inventory.
b. Are not subject to the periodic safety assessment and radiation survey.
c. Must retain the RGD labels specified in Section 4.3.3, except the ‘Date Surveyed/Next Survey Due’ sticker, which must be applied when the RGD is put into service.
d. Must be controlled to prevent unauthorized and unintended use.
5.1.3 Frequency of RGD Inventory, Safety Assessments, and Radiation Surveys
1. The RGD Custodian must ensure an inventory, radiological safety assessment, and a radiation survey is conducted and documented for each RGD that is authorized for use. Except as noted below, these elements must be conducted:
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a. Annually for Class I RGDs. The ES&H Team health physicist is permitted to waive the radiation survey and the radiological safety assessment (but not the inventory) for Class I devices if the
— Associated radiation exposure risks are minimal.
— Waiver is authorized on the Characterization form and noted on the Radiological Safety Assessment Form.
b. Annually for Class II RGDs.
c. Semi-annually for Class III and IV RGDs.
d. Each time the RGD
— Is modified in a manner that involves the RGD tube, tube housing, shutters, or shielding.
— Is moved from the characterization location (except for portable RGDs, as noted on the Characterization form).
— Is returned to operational status from ‘non-operational’ (i.e., when a ‘non-operational’ sign is removed), unless the previous assessment was conducted within the specified time period.
— ‘Approved operating parameters’ are increased. Note: The RGD will also need to be recharacterized, as specified in Section 4.2.
2. The radiological safety assessment and radiation survey:
a. Must be completed with the involvement of the ES&H Team.
— Other appropriately trained personnel (e.g., electronics technicians) are permitted to perform elements of the radiological safety assessment (e.g., interlock testing).
— Distributed responsibilities should be noted on the Characterization form.
b. Is considered ‘on time’ if it is conducted any time within the month it is due.
3. A radiological safety assessment and a radiation survey are not required for RGDs that are posted as ‘non operational’ if the requirements for ‘non-operational RGDs’ specified in Section 5.1.2 are met.
5.1.4 Inventory Requirements
1. All LLNL RGDs (including those that are ‘non-operational’ and ‘out-of-use’) are subject to inventory on at least an annual basis:
a. Class I RGDs may be inventoried by verbally contacting the RGD Custodian if deemed appropriate by the ES&H Team health physicist and documented on the Characterization form. The individual conducting the inventory (i.e., the Health and Safety Technologist or the health physicist) must
— Verify the location of the RGD and that it has not been modified.
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— Notify the RGD Safety Officer of the inventory result using the protocol established by the RGD Safety Officer. The RGD Custodian’s signature is not required.
b. For RGDs that are off-site (e.g., for repair or use at another facility), a written statement (e-mail) from the RGD Custodian (or other appropriate individual), as to the location of the RGD is sufficient.
c. RGDs that have been excessed [e.g., sent to Donation, Utilization, and Sales (DUS) and placed on the DOE Excess List] but are still on-site must be inventoried and remain the responsibility of the owning organization (not DUS).
2. The ES&H Team must conduct the RGD inventory, typically in conjunction with the radiological safety assessment.
a. The ES&H Team must provide the completed safety assessment paperwork to the RGD Safety Officer upon completion of the inventory.
b. As a best management practice, the RGD Safety Officer typically prompts the ES&H Team when the inventory is due.
3. The following components are subject to inventory:
a. Each LLNL RGD that is on-site, regardless of status (operational, non-operational, storage).
b. Each separately identified RGD tube head.
4. The individual conducting the inventory must note changes in the operational status of the RGD (e.g., ‘Operational,’ ‘Non operational’).
5.1.5 Radiological Safety Assessment
1. The RGD Custodian (or RI) and the ES&H Team must jointly conduct a radiological safety assessment for operational RGDs, unless the RGD has been identified as ‘inventory only’. The safety assessment must include a review of:
a. The RGD Characterization form, including administrative information (e.g., manufacturer and model number, device location, RGD Custodian, approved operators), and approved operating parameters.
b. Area postings and RGD signs and labels.
c. RGD warning indicators.
d. Interlock and radiation area monitoring testing, ensuring testing has been conducted within the safety assessment interval.
2. The ES&H Team must document the radiological safety assessment results, preferably via the RGD Program web application. The safety assessment results must be:
a. Approved by the ES&H Team health physicist or the RGD Safety Officer.
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b. Provided to the RGD operator.
3. The safety assessment must be updated, if
a. The RGD is modified following the characterization, or moved (unless the RGD was identified on the Characterization form as ‘portable’).
— Modification includes, but is not limited to, adding or removing beam ports, changing tube types (anodes), and modifying shielding or interlocks. ‘Like-in-kind’ component replacement is not considered a ‘modification.’
— Each RGD safety system that could have been affected (e.g., shielding, radiation alarms, interlocks) must be retested before being returned to normal operations.
b. Administrative or technical elements change (e.g., the RGD Custodian, authorized operating parameters), unless the RGD Characterization already allows for the change.
— The ES&H Team or RGD Safety Officer may enter administrative and technical changes directly into the RGD Program web application.
— Alternatively, the previously approved Safety Assessment form may be used to record and transmit changes to the RGD Safety Officer.
— RGD Safety Officer will provide the RGD Custodian with an updated Safety Assessment form.
c. If the modification results in changes to the controls identified on the RGD Characterization, then the Characterization must also be updated.
4. If the Inventory/Safety Assessment is not completed within the month due, it is considered ‘overdue.’ An RGD that is overdue by more than 30 days must be tagged as ‘non-operational’ until the safety assessment is complete.
5.1.6 Radiation Survey in Potentially Occupied Areas
1. A radiation survey to detect changes in radiological conditions shall be periodically conducted and documented, except as noted below. The survey is usually conducted in conjunction with the periodic safety assessment.
a. The radiation survey must be conducted with the RGD at high enough energy and current that, if unplanned changes have occurred (e.g., a leaded-glass port replaced with non-leaded glass; failure of a shutter to fully close; slippage of lead shielding), the change could be detected.
b. For portable RGDs intended to be used in a variety of locations, the method of implementing radiation surveys must be noted on the RGD Characterization form and is permitted to be either of the following
— The radiation survey must be conducted in each new use location. Subsequent surveys in the same location must be conducted consistent with the prescribed
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radiation survey frequency. This method is appropriate if a single survey location is not sufficient to assure safety in all use locations (e.g., when conducting radiography).
— The radiation survey must be conducted on the prescribed frequency (but not in each new use location). This method is appropriate if a single survey location is sufficient to assure safety in all use locations (e.g., a portable RGD that produces a dose rate of a few mrem at 1 meter).
c. A radiation survey is not required if the RGD is used in a ‘highly safe’ environment, provided the exception is noted on the RGD Characterization form. For example, a radiation survey would not be required following installation of a flash x-ray tube on an enclosure designed to contain explosive charges, where personnel are excluded from the area during operations and there is ample shielding or distance to ensure a radiologically safe environment.
d. If an RGD cannot be surveyed on the prescribed schedule (e.g., it is broken; the operator is not available; work has been temporarily suspended), it must be posted as ‘non-operational’ as specified in Section 5.1.2.
2. The periodic ‘radiation survey in potentially occupied areas’ is separate and distinct from a survey conducted in association with the RGD Characterization (typically conducted to determine RGD output). To the extent the RGD Characterization survey contains the information required by the radiation safety assessment, it is acceptable to reference the characterization survey on the radiation survey form.
5.2 Personnel Safety Controls
5.2.1 Access Controls
1. Personnel entry control shall be maintained for each radiological area. The degree of control shall be commensurate with existing and potential radiological hazards in the area.
a. Radiological Areas shall be delineated and properly posted (see Section 4.3).
b. Individuals must be excluded from High Radiation Areas during RGD operation. If physical barriers do not preclude access to High Radiation Areas (e.g., during field radiography), a trained operator must provide surveillance and prevent access.
c. The master key(s) for the control console of Class IV RGDs must be the only key(s) that allows access to exclusion areas.
d. Controls shall not prevent the rapid evacuation of personnel from a potentially High Radiation Area or Very High Radiation Area.
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2. A supplemental whole-body dosimeter (or other means capable of providing an immediate estimate of the individual’s integrated deep-dose equivalent during the entry) shall be worn during access to High Radiation Areas.
a. Readings must be recorded in a logbook at least daily.
b. This requirement applies to entry into an actual High Radiation Area (not one posted as a High Radiation Area where the radiation is not present (i.e., the RGD is ‘off’); however, use of a supplemental alarming dosimeter is strongly recommended upon first entry into an RGD room following continuous-wave RGD operations.
3. Before starting up a Class IV RGD, the operator must ensure no personnel are in the potential High Radiation Area by:
a. Performing a sweep of all potential High Radiation Areas and Very High Radiation Areas. It is permissible to omit this sweep if access to these areas has been continuously guarded (access points) and monitored (direct observation of area or enclosure) since the last sweep was performed.
b. Making a verbal announcement (if one is not provided automatically) indicating RGD operations are about to commence. This announcement must be audible throughout the High and Very High Radiation Area.
4. Following RGD operations:
a. An individual identified by the RGD Custodian must be the first person to enter an exclusion area after device operation.
b. The first person to enter a potentially High Radiation Area or exclusion area must use an appropriate survey meter
— To verify that radiation is no longer being produced before any part of the body enters a potential High Radiation Area or Very High Radiation Area.
— When the levels of radiation are unknown.
c. A meter is not required for initial entry in the case of pulsed radiation fields where a meter is incapable of detecting the presence of radiation.
— A meter is required if it could detect the presence of unanticipated radiation, even though it cannot accurately measure the radiation dose or dose rate.
5.2.2 Use of Interlocks and Hazard-Safe Switches
1. Interlocks must be used and maintained as follows:
a. Interlocks must not be used to turn off an RGD, except in an emergency.
b. Interlocks must be tested on the same frequency as the safety assessment, and after any maintenance or repairs that might affect system operability.
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c. The interlock bypass key(s) must be removed and secured unless an authorized bypass operation is in process.
d. If a required interlock malfunctions, it must be repaired before the RGD is operated. (For example, if two interlocks are required and four are present, the RGD is allowed to be operated if at least two of the four interlocks are operational.)
2. Upon entering an area equipped with hazard-safe (run-safe) switches, personnel must set at least one switch to the safe position, unless this occurs automatically.
5.2.3 Radiation Monitoring Requirements
1. Except as noted below, an appropriate portable radiation survey instrument must be available for operational use during Class II, III, and IV RGD operations.
a. The RGD Custodian must ensure that individuals conducting operational RGD surveys are familiar with the RGD and understand its potential hazards.
b. The RGD operator or designee must use a survey meter to verify the radiation is no longer present
— Following RGD operations, as specified in Section 5.2.1.
— Prior to placing any portion of the body (e.g., fingers) into the potential beam path (e.g., during sample changing or beam alignment operations).
c. Caution must be exercised when monitoring RGDs because
— Intense radiation fields from RGDs can quickly over-range most instruments.
— Beam size might be small, resulting in non-uniform irradiation of the measurement device and underestimate of the radiation dose.
— Pulsed radiation (>5 mrem/pulse) might saturate ion chambers, even when used in the integrate mode.
— Radiation energies that are high (>2 MeV), or low (<50 keV), might result in inaccurate readings because the calibration and/or design of the detector is not appropriate.
d. The preferred instruments for monitoring RGDs are as follows
— Pulse rate meters such as GM meters (e.g., ‘pancake’ probes, ‘hot dog’ probes) are preferred for DETECTING leakage radiation because they respond quickly and audibly; however, they are generally NOT appropriate for determining the dose rate from the leakage radiation.
— For photon radiation (i.e., gamma rays, x-rays), thermoluminescent dosimeters (TLDs) and ionization detectors are the preferred methods for measuring dose rates. TLDs are particularly useful for measuring small beam sizes, as the entire TLD can usually fit in the beam.
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— For neutron radiation, a BF3 or He-3 meter is the preferred instrument for detecting leakage radiation and measuring the resultant dose rates.
e. This requirement does not apply when using RGDs that cannot be measured with portable radiation survey instruments (e.g., flash or pulsed RGDs).
2. Area radiation monitors must:
a. Not be substituted for radiation exposure surveys in characterizing a workplace.
b. Be function-tested at least quarterly (or before routine use) for response to radiation. It is acceptable to
— Conduct function testing by observing and documenting the monitor response during RGD operations.
— Document function testing with a notation in a logbook that ‘area radiation monitors are functioning’ (or words to that effect).
3. If installed instrumentation is removed from service for maintenance or calibration, a radiation monitoring program providing similar detection capability must be provided, consistent with the potential for unexpected increases in radiation dose rates.
4. High-energy (>15 MeV) Class IV RGDs might cause exposed objects, tools, or shielding to become activated. See Document 20.2 for survey requirements associated with releasing materials from exclusion areas where activation is likely.
5.3 Maintenance, Modification, and Repair
5.3.1 RGDs
1. The Authorizing Organization, with the concurrence of the ES&H Team health physicist, must approve maintenance and repair operations that could impact the safety system on an RGD, even if an authorized factory representative is performing the work.
a. Any work limitations associated with maintenance and repair must be documented in the work control document (e.g., IWS, PWS).
b. If individuals performing the work are not Lawrence Livermore National Security, LLC (LLNS) employees, they must provide documentation that they are adequately trained to do the work. A letter on company letterhead indicating the person is a factory-authorized representative that is adequately trained to do the work is sufficient.
c. When a safety device or interlock has been approved to be by-passed or is awaiting repair, the entrance to the RGD area or enclosure should be posted with a prominent sign bearing the words “SAFETY DEVICE NOT FUNCTIONING” or a similar message.
2. The individual performing work must verify the power is OFF before performing work that involves the removal of protective shielding or modification of shutters, collimators, or
beam stops. The main switch, and not the safety interlocks, must be used to shut down the RGD.DES-2401, LLNL Lockout/Tagout (LOTO) Program must be followed.
3. The RGD operator must document all maintenance and repair of the RGD. Documentation must include what was done, by whom, the date of the work, and the follow-up radiological safety assessment/radiation survey, if required.
4. Following maintenance and repair that involves disassembly of the RGD tube, tube housing, shutters, or shielding, or modification of any safety system (e.g., interlocks), and before resuming programmatic operations, the RGD Custodian must ensure
a. The ES&H Team conducts a radiation survey following the maintenance or repair.
b. The ES&H Team health physicist recharacterizes the RGD if it has been modified significantly.
5.3.2 Safety Systems
1. Each installed area radiation monitor shall be calibrated annually.
a. The Alarms Division (in the Emergency Management Department) or the RCL calibrates installed radiation monitoring systems. Delegation of this task to others must be documented in an SP or Memorandum of Understanding signed by the affected parties and the RCM.
b. The Authorizing Organization is responsible for arranging for and assuring the completion of routine calibration of these systems.
2. The Authorizing Organization must ensure area radiation monitors are tested periodically (e.g., quarterly) to verify audible alarm system operability and audibility under ambient working conditions and operability of visual alarms when so equipped.
3. Area radiation monitors are ‘critical M&TE’ and must be maintained in accordance with PRO-0124.
5.3.3 Vendor-Provided Safety Systems
1. Safety systems installed by the manufacturer must not be disabled or modified without the approval of the AI, with the concurrence of the ES&H Team health physicist. Safety systems include, but are not limited to:
a. Interlocks.
b. Shielding.
c. Warning lights, such as an “X-Ray On” light.
2. The approval and concurrence must be documented, preferably in the work control document.
3. Modification of radiation safety interlocks must be documented in a formal design review.
The term “field radiography” refers to radiography conducted in an area or facility that does not have the engineered controls required by this document. It is typically associated with non-destructive testing.
Field radiography is appropriate when it is impractical or unsafe to transport an item to a radiographic facility (e.g., when conducting non-destructive testing at construction sites or diagnostics on devices, items, or structures that cannot reasonably or safely be moved). It is acceptable to conduct field radiography in order to train personnel to perform this activity.
1. For an activity in which use of engineered design features is demonstrated to be impractical, administrative controls shall be used to maintain radiation exposures ALARA.
a. Administrative controls must be documented in an SP or other work control document. Section 4.5 contains detailed information on this topic.
b. If a generic field radiography SP (i.e., a safety plan that allows for future field radiography in general) is written, an IWS or other work control document (signed by the management in the facility or area where the operation is to occur) must be used to provide the site-specific information and controls.
c. It is acceptable to use a subcontractor’s company SP in place of an LLNL SP if it is deemed acceptable by the RGD Custodian and the ES&H Team health physicist. In such cases, the form “LLNL Radiation Work Permit for Subcontractors/Visitors” must be completed.
2. The Authorizing organization must obtain the RCM approval to conduct ‘field radiography’ for operations that are expected to exceed either:
a. A span of 2 weeks.
b. A frequency of six times a year.
3. Because field radiography is, by definition, conducted in areas that are not designed for radiographic operations, individuals not associated with the operation are often exposed to low levels of radiation. Operation must be planned so that the dose to such unassociated individuals is kept ALARA (and, ideally, to <1 mrem per person). The AI, with the concurrence of the RCM, must approve anticipated dose in excess of 10 mrem to any unassociated individual.
5.5 Documentation and Logbook Requirements
1. For Class I, II, III, and IV RGDs, the RI must:
a. Have access to the following records in the RGD work area.
— The current Radiological Safety Assessment form.
— The manufacturer-provided instruction manual, if used to operate the RGD.
b. Maintain a use log if the RGD is portable and used in locations other than specifically listed on the Characterization form. The use log must identify:
— The operator.
— The use location.
— The date and time of use.
— Monitoring results, if required by the work control document.
— A brief description of the work conducted (Class IV RGDs only).
2. For Class II, III, and IV RGDs, the RI must ensure the following records are retained and retrievable until the RGD has been transferred or disposed of.
— The most recent interlock test results.
— The work control document (i.e., IWS, IWS/SP).
— Associated operations and technical work documents (e.g., interlock test procedures).
— Maintenance records.
— Records of interlock bypass (other than routine bypasses authorized in the Complete Characterization or work control document), including the time the bypass is turned on and off as well as the reason for the bypass.
3. The following RGD records shall be retained by the RGD Safety Officer (in the Radiation Protection Functional Area) until DOE authorizes their disposition.
— RGD Characterization.
— Radiological Safety Assessment Forms.
— Radiation Survey Forms.
— Equipment/Property Release Forms.
5.6 Control of RGDs
5.6.1 Use and Location of RGDs
1. The Authorizing Organization must maintain control of their RGDs.
a. Unauthorized RGD operations must be prevented by the use of keys or equivalent mechanism.
— Systems must not be left unattended in the ‘enabled’ state unless unattended operations are authorized.
— Systems must not be ‘enabled’ except as needed for planned operations.
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b. The RGD must be labeled as a radiation-generating device.
c. RGDs are permitted to be transferred only to appropriately authorized individuals or institutions, as determined by the RGD Safety Officer.
2. The RGD Custodian must:
a. Notify the ES&H Team health physicist or the health and safety technician prior to
— Physically moving an RGD (other than on-site movement of RGDs that are identified as ‘portable’ in the RGD Characterization).
— Administratively transferring an RGD to an on-site or off-site location.
— Administratively transferring an RGD to the DOE Excess List.
b. Complete the Equipment/Property Release Form for planned transfers of intact RGDs and RGD tubes to non-LLNL individuals or institutions.
— The ES&H Team health physicist must sign the completed form.
— The ES&H Team health physicist must provide a copy of the completed form to the RGD Safety Officer.
c. Maintain control of the keys to RGD installations, RGDs, and/or RGD storage facilities.
d. Ensure RGD operators follow applicable operating procedures and work control documents.
3. Portable RGDs:
a. Must be identified as ‘portable’ in the RGD Characterization.
b. Are permitted to be moved on-site and off-site by the RGD operator, as authorized in the applicable work control document.
— The RGD Custodian must notify the ES&H Team when any LLNL RGD is taken off-site, and when it returns.
— Off-site RGD operations might require compliance with Nuclear Regulatory Commission (NRC) or state regulatory requirements, depending upon the use location.
c. Are subject to inventory on the prescribed schedule.
4. The ES&H Team health physicist or the health and safety technician must provide written notification to the RGD Safety Officer of RGDs that have been removed from LLNL. Notification must be provided within 30 days of the RGD’s removal or of the ES&H Team’s awareness of the removal; an e-mail is sufficient.
5.6.2 Use of RGDs Owned by Non-LLNL Organizations
1. RGDs that would otherwise require classification at LLNL but are owned by others:
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a. Must have the approval of the Authorizing Organization and the concurrence of Radiological Control Organization prior to their being brought on-site. A PWS or IWS is sufficient documentation of the approval/concurrence.
b. Must be operated only by trained, authorized individuals.
— Non-LLNL workers must show proof of training/qualification indicating that they are fully qualified to operate the specific RGDs to be used. A letter from the worker’s organization stating this qualification is adequate.
— RGD operators must meet the same safety training requirements as they would if the RGD was owned by LLNL. Non-LLNL operators who have not completed LLNL radiological safety training are permitted to operate their RGDs under the direct supervision of a worker who has completed the required safety training.
— Non-LLNL workers must receive General Employee Radiological Training (GERT course or pamphlet) prior to conducting radiological work or accessing areas posted with the trefoil symbol.
c. Must be covered by a work control document and SP.
— The Vendor’s SP is permitted to be used if it is reviewed by and acceptable to the ES&H Team, as documented in a ‘LLNL Radiation Work Permit for Subcontractors/Visitors.’
— The Vendor’s SP, if used, must be supplemented with the LLNL-specific information needed to ensure a comprehensive safety envelope. LLNL-specific safety requirements must be documented in the ‘LLNL Radiation Work Permit for Subcontractors/Visitors,’ the IWS/PWS, or other work control document.
d. If the RGD has radiation safety interlocks, the interlocks and test procedures must meet LLNL’s design criteria as specified in Section 3.0, Design Criteria, and Section 4.5, Written Authorizations, Safety Plans, and Technical Work Documents.
e. Do not require LLNL labels to be applied.
— Information such as the approved operating parameters must be included in the IWS/PWS or the SP.
2. RGDs that are owned, managed, or controlled by non-LLNL staff (e.g., subcontractors, other state, or federal agencies) are subject to the following controls if the RGD remains on-site for 6 months or more, or if it remains under LLNL-control for more than one month after the departure of the owner.
a. An LLNL-RGD Custodian must be identified.
b. The RGD Custodian must notify the RGD Safety Officer, who will direct a temporary notation be made in the LLNL database. The notification
— Must include the information required for an initial characterization, as specified in Section 4.2.1.
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— Must include the anticipated departure date of the RGD.
— Must be followed with a second notification noting the actual departure date of the RGD.
— Must be documented; an e-mail from the RI is sufficient.
c. The RGD must be labeled
— As a ‘radiation generating device’ if it does not already bear such a label.
— With the name of the LLNL RGD Custodian unless it is controlled (e.g., in a locked room) in such a manner that only the RGD Custodian and other knowledgeable individuals have access to it.
— In such a manner that the labels can be removed without damaging or marking the RGD.
d. RGDs that remain on-site for 1 year or more, or for more than 6 months beyond the departure of the owner, must be controlled as an LLNL RGD.
3. For RGDs that are repetitively brought on-site, it is acceptable to:
a. Assign an RGD number.
b. Operate RGDs under a ‘generic’ characterization, if the Authorizing Organization provides the ES&H Team health physicist and RGD Safety Officer with RGD-specific information (e.g., applicable serial numbers, dates that the RGD is on-site). Classification-sensitive information will not be recorded in the RGD master files.
c. Reference previously provided information (e.g., for characterizations, safety controls).
5.6.3 Managing Out-of-Use RGDs
1. When no longer needed for programmatic operations, Class II, III, and IV RGDs must be stored in a manner that prevents unintended and unauthorized operation or tampering (e.g., in a locked enclosure or room).
a. RGDs that are no longer needed but are still capable of producing radiation
— Must be posted by the ES&H Team as “Non Operational.”
— Are permitted to be left in place or to be sent to equipment storage.
— Must retain the label indicating the device generates radiation.
— Are permitted to be included on the DOE Excess List, which is managed by the DUS Group.
b. RGDs that are on the DOE Excess List
— Are permitted to be stored either in the programmatic area or at DUS.
— Will be made available to other DOE contractors that are authorized to have them.
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— Are permitted to remain at DUS for a limited period of time (usually several months).
c. If an RGD has exceeded its allowed time at DUS, the RGD Custodian might, with proper authorization and the concurrence of the Radiological Control Organization:
— Return the RGD to the programmatic area.
— Remove the RGD tube and RGD labels from the RGD.
— Render the RGD nonfunctional (i.e., broken beyond repair) and remove the RGD labels.
d. Only RGDs that have been rendered nonfunctional are permitted to be
— Sent for metal recycling, or
— Disposed of in a municipal landfill or hazardous waste (as determined by the Environmental Analyst).
2. RGD tubes removed from an RGD must be controlled in one of the following ways:
a. Returned to the manufacturer. (This is the preferred disposal method.)
b. Stored by the RGD Custodian for future use. (The tube must remain labeled as an RGD tube head and must continue to be inventoried.)
c. Rendered nonfunctional and disposed of.
— An IWS is required to purposefully render a tube nonfunctional (i.e., to break an RGD tube) as tubes typically contain hazardous materials (e.g., beryllium) and are under vacuum.
— Contact the ES&H Team Environmental Analyst to determine the appropriate disposal method.
3. The RGD Custodian must notify the ES&H Team health physicist (who must subsequently notify the RGD Safety Officer) if an RGD is rendered inoperable or disposed of. The RGD Safety Officer must update the RGD files.
4. Decommissioning or dismantling of accelerators or other large devices must be handled on a case-by-case basis. Contact the ES&H Team for guidance.
6.0 Responsibilities
The responsibilities for each individual and organization are listed below each title. These responsibilities are specific to RGD operations and are in addition to the responsibilities identified in Document 20.1.
a. Approve the purchase or acquisition of radiation-generating devices.
b. Appoint the RGD Safety Officer.
c. Ensure LLNL has a comprehensive RGD safety program and the institutional RGD program is effectively managed.
6.1.2 Radiation Generating Device Safety Officer
1. The RGD Safety Officer must:
a. Assist in the determination of whether an RGD requires a SAD, in accordance with DOE O 420.2C.
b. Approve the RGD Characterization.
c. Oversee the periodic inventory and safety assessment/radiation survey process.
d. Maintain the master RGD list.
— Assign RGD numbers to new RGDs.
— Remove RGDs from the inventory when they are no longer under LLNL control.
e. Determine the applicability and sufficiency of RGD controls if questions arise.
f. Provide technical oversight and insight, as needed.
g. Maintain RGD records and associated databases as specified in Section 5.5.
6.1.3 Donation, Utilization, and Sales Group
1. DUS must ensure RGDs on the DOE Excess list are transferred only to institutions/organizations authorized to have an RGD.
6.2 Authorizing Organization Responsibilities
6.2.1 Authorizing Individuals
The AI (which might include either line program or facility staff) must:
1. Control use of RGDs within a facility.
2. Maintain facility engineered systems needed for radiological control (e.g., shielding, interlocks).
3. Respond to off-normal events such as suspected overexposures or failed interlocks.
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6.2.2 Responsible Individuals or RGD Custodian
The RI or RGD Custodian must:
1. Contact the ES&H Team before:
a. Moving or transferring an RGD.
b. Increasing the RGD operating parameters above the ‘approved operating parameters.’
2. Ensure technical work documents are adequate for the equipment and operation.
a. Ensure interlock test procedures/plans are written, concurred with by the ES&H Team health physicist or RGD Safety Officer, and used.
3. Maintain control of RGDs. Take reasonable steps to prevent the unauthorized and unintended use of RGDs, which might include locking doors to unattended laboratories and locking the RGD control keys.
4. Ensure the following activities are conducted on the requisite frequency:
a. Radiological safety assessments (including interlock tests).
b. Radiation surveys.
c. RGD inventories.
6.2.3 RGD Operators
RGD operators must:
1. Safely conduct work with RGDs. This includes:
a. Using the RGD as it was intended and authorized, including staying within the posted operating parameters.
b. Not altering safety systems without the authorization of the AI and concurrence of the ES&H Team.
c. Ensuring shielding and shutters are in place and working as intended.
d. Conducting operational monitoring, as indicated in the work control document.
2. Notify the Authorizing Organization and the ES&H Team immediately if an RGD is damaged; cannot be located; or has been used in a manner other than intended by the manufacturer or authorized by the IWS.
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6.3 ES&H Team Responsibilities
6.3.1 ES&H Team Health and Safety Technologist
The ES&H Team health and safety technologist must:
1. Conduct and document the periodic RGD Inventory, safety assessment, and radiation survey.
2. Send completed forms to the ES&H Team health physicist for review.
6.3.2 ES&H Team Health Physicist
The ES&H Team health physicist must:
1. Provide technical support to programs utilizing RGDs, consistent with the ALARA process. This includes:
a. Characterizing RGDs as Class I, II, III, or IV and determining the appropriate controls for an operation.
b. Identifying the appropriate dosimetry requirements for RGD users.
2. Review safety assessments/radiation surveys completed by the ES&H Team health and safety technologist.
3. Send the reviewed safety assessments/radiation surveys to the RGD Safety Officer for inclusion in the official file.
6.3.3 ES&H Team Environmental Analyst
The ES&H Team environment analyst must:
1. Determine the need for startup approval by the Environmental Protection Agency (EPA) or other regulatory agencies if activation of air is a consideration (e.g., for high-energy accelerators).
2. Review decommissioning activities to determine proper disposal methods for potentially activated components.
7.0 Requirement Source Documents
Part 10 CFR 835, Occupational Radiation Protection/Radiation Protection Program (RPP).
DOE Standard 1098-2008, Radiological Control Standard.
DOE Order 231.1Admin, Chg 1, Environment, Safety and Health Reporting.
DOE O 232.2, “Occurrence Reporting and Processing of Operations Information.”
DOE Order 420.2C, Safety of Accelerator Facilities.
g. Document 20.2, “LLNL Radiological Safety Program for Radioactive Materials.”
h. DES-0115 LLNL Quality Assurance Program.
i. PRO-0124, LLNL Program for the Control and Handling of Critical Measuring and Test Equipment.
j. Part 10 CFR 830, Nuclear Safety, Subpart A, “Quality Assurance Requirements.”
k. DOE Order 414.1C, Quality Assurance.
2. Guidance from the following documents has been incorporated into this document wherever feasible:
a. DOE G 441.1-1C, Radiation Protection Programs Guide for Use with Title 10, Code of Federal Regulations, Part 835, “Occupational Radiation Protection.”
b. ANSI/HPS N43.2, “Radiation Safety for X-Ray Diffraction and Fluorescence Analysis Equipment” (2001).
c. ANSI/HPS N43.3, “For General Radiation Safety--Installations Using Non-Medical X-Ray and Sealed Gamma-Ray Sources, Energies Up To 10 MeV” (2008).
d. Part 21 CFR 1020.40, “Cabinet X-Ray Systems” (April 1, 2008).
3. Shielding design is performance driven by physical design criteria (e.g., seismic qualification) and administrative requirements such as the ALARA design criteria. Applicable national standards that provide shielding guidance and information include:
a. NCRP Report No. 49, “Structural Shielding Design and Evaluation of Medical use of X Rays and Gamma Rays of Energies up to 10 MeV.”
b. NCRP Report No. 51, “Radiation Protection Design Guidelines for 0.1 – 100 MeV Particle Accelerator Facilities.”
c. NCRP Report No. 144, “Radiation Protection for Particle Accelerator Facilities.”
d. NCRP Report No. 147, “Structural Shielding Design for Medical X-Ray Imaging Facilities.”
e. NCRP Report No. 151, “Structural Shielding Design and Evaluation for Megavoltage X- and Gamma-Ray Radiotherapy Facilities.”
01/17/17 Major Rev. 7 08/08/12 Minor Rev. 6 06//24/11 Minor Rev. 5 03/26/10 Minor Rev. 4 11/20/09 Major Rev. 3 12/27/07 Global Rev. 2 06/18/02 Minor Rev. 1 04/01/01 Editorial Rev. 0 12/20/99 Major 05/19/99 Major 05/19/97 Major 09/17/93 Major
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Appendix A Acronyms, Terms, and Definitions
The terms and definitions in this appendix are specific to their use in this document.
Accelerator Devices used to accelerate particles to high energies (typically more than 1 MeV).
ALARA As low as reasonably achievable.
Area radiation monitor A radiation monitor that provides immediate radiological feedback (i.e., local and/or remote readout with alarm capability) as radiation levels change and is installed in such a manner that it operates independently of the worker (i.e., it is installed in a given location and is ‘on’ when the RGD is ‘on’).
ASE Accelerator Safety Envelope.
Beam ports Openings in a radiation-source housing through which radiation is allowed to pass. Collimators, shutters, and filters might be attached to ports to restrict and control the emerging radiation beam.
Cabinet RGD system An RGD system with the RGD tube installed in an enclosure (hereinafter termed ‘cabinet’) which, independently of existing architectural structures except the floor on which it might be placed, is intended to contain at least that portion of a material being irradiated, provide radiation attenuation, and exclude personnel from its interior during generation of radiation. Included are all RGD systems designed primarily for the inspection of carry-on baggage. An RGD tube used within a shielded part of a building, or RGD equipment that might temporarily or occasionally incorporate portable shielding is not considered a cabinet RGD system.
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Close proximity People working ‘in close proximity’ to an RGD includes workers who are significantly involved in RGD operations, even though they do not actually operate the RGD. Typically included are those who routinely work on the RGD or its associated components (e.g., the facility mechanical technicians that might repair or reconfigure beam line components or RGD safety or control systems); people that routinely access exposure rooms in between RGD operations. Occasional workers conducting the above tasks are typically not included. In cases of ambiguity or disagreement, the RCM is responsible for determining if a worker falls into this category.
Controlled area Any area where access is managed to protect individuals from exposure to radiation or radioactive material.
DUS Donation, Utilization, and Sales Group.
Enclosed beam All possible x-ray beam paths are fully contained in a chamber, coupled chambers, or other beam-path-confinement devices to prevent any part of the body from intercepting the beam during normal operations. Normal access to the beam path, such as a sample chamber door, must be interlocked with the high voltage of the x-ray tube or the shutter for the beam to be considered “enclosed.” An open-beam device placed in an interlocked enclosure is considered an “enclosed beam” unless there are provisions for routine bypassing of the interlocks (e.g., for beam alignment).
Entrance or access point Any location through which an individual could gain access to an area controlled for the purpose of radiation protection. This includes entry or exit portals of sufficient size to permit human entry, irrespective of their intended use.
Exclusion area The area around an RGD from which people must be kept out due to high levels of radiation (e.g., an RGD room with an operating Class IV RGD).
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Exempt RGD Unmodified commercially available components or devices that
— Produce radiation incidentally.
— Have a potential across the terminals <15 kV.
— Produce radiation fields that are no more than twice background when measured at 5 cm (2 in) from the device surface (or at the closest accessible surface) when operated at the maximum operating parameters.
— Retain the labels provided by the manufacturer.
— Are used in accordance with the manufacturer’s instructions.
Fail-safe A design feature built into the system or its components that causes the system to return to a safe condition if a key component malfunctions in its most likely failure mode(s).
Field radiography Nonroutine radiographic operations typically conducted for the purpose of non-destructive testing with a high-hazard (typically, Class IV) RGD in an area or facility that does not have the otherwise requisite engineered controls. ‘Field radiography’ does not include low-hazard operations with portable RGDs that do not require facility-provided engineered controls.
High Radiation Area Any area, accessible to individuals, where radiation levels could result in an individual receiving an equivalent dose to the whole body in excess of 0.1 rems in one hour at 30 cm from the radiation source or from any surface that the radiation penetrates. (Note: Dose rates in excess of 500 rads/h are Very High Radiation Areas.)
Incidental radiation-generating device
A device that emits or produces radiation during normal operation, and the radiation is an unwanted by-product of the device’s intended purpose. Examples of such devices include scanning electron microscopes, electron pulse generators, and electron beam welders.
Intentional radiation-generating device
A device in which particles undergo acceleration in a vacuum to produce radiation for a particular application. Examples are medical devices, flash x-ray systems, x-ray diffraction and fluorescence analysis equipment, klystrons, laser irradiators, and accelerators.
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Interlock A device that precludes access to an area of radiation hazard by either preventing entry or by automatically shutting down the RGD.
Must A requirement that shall be implemented, unless the RCM authorizes otherwise, in writing.
Nonroutine operations Operations that last less than 2 weeks and are conducted less than six times each year.
Open beam An x-ray beam that is not fully contained within a chamber, coupled chambers, or other beam-path-confinement devices (e.g., shutters), or where there are no physical barriers between an individual and the radiation beam.
Portable RGD A generic term for RGDs which are intended to be routinely moved and used in a variety of locations. ‘Portable RGDs’ include high-hazard RGDs (such as those used for ‘field radiography’) and low-hazard RGDs (such as lead-based paint analyzers) that normally do not require engineered controls.
Primary beam RGD-generated radiation that has not been shielded, reflected, or diffracted.
Radiation Area Any area, accessible to individuals, where radiation levels could result in an individual receiving an equivalent dose to the whole body in excess of 0.005 rem (5 mrem) in one hour at 30 centimeters from the source or from any surface that the radiation penetrates. (Note: Dose rates in excess of 0.1 rem/h are High Radiation Areas.)
Radiation-generating device (RGD)
A device (including accelerators) that generates ionizing radiation either incidentally or intentionally.
RCM Radiological Control Manager
RGD Area An area within a facility where non-portable Class II, III, or IV RGDs are used.
RGD Room A permanent enclosure in which the RGD operates, and in which people enter by walking.
RGD operator A person who has met the training requirements and is authorized to operate the RGD.
Document 20.3 UCRL-AM-133867-VOL-2-PT-20.3-2017
Revision 7 63 January 17, 2017
RGD Safety Officer A health physicist within the Radiation Protection Functional Area who is responsible for providing technical guidance on safety issues related to RGDs and coordinating the overall RGD safety program for LLNL.
RGD tube The tube in an RGD that produces the radiation. RGD tubes might generate x-rays or neutrons (e.g., with deuterium-tritium tubes).
RPP Radiation Protection Program.
Safety plan (SP) A management-approved safety document that describes the hazards and the applicable controls for a particular work activity.
Secondary beam Radiation that has been diffracted from a primary beam or is generated by fluorescence.
Shall A mandatory requirement.
Should A recommended practice. Can also indicate a desirable or best management practice. Written justification for declining to implement a ‘should’ statement is not required.
Very High Radiation Area Any area accessible to individuals where radiation levels could result in an individual receiving an absorbed dose in excess of 500 rads in one hour at 1 m from a radiation source or from any surface that the radiation penetrates.
Whole body For the purposes of external exposure, any exposure to the head, trunk (including male gonads), arms (above and including the elbow), or legs (above and including the knee).
Document 20.3 UCRL-AM-133867-VOL-2-PT-20.3-2017
Revision 7 64 January 17, 2017
Appendix B Summary of RGD Safety Requirements
Table B-1 contains a summary of the controls presented in Document 20.3. If any conflicts exist between the summary and the information provided in the body of Document 20.3, the information in the body prevails.
Table B-1: Summary of RGD Safety Requirements
RGD Compliance Item Further Explanation Class
I II III IV I. Design Requirements for fixed installations
Shielding Dose rate <0.5 mR/h at 5 cm from housing Or a dose rate <0.1 rem/y X Dose rate <0.5 mR/h at 5 cm from housing, except when operated in open beam mode
See text for open beam mode requirements.
X X
Dose rate to non-radiological workers is <0.1 rem/y — X X X Dose rate in rad-worker occupied areas is <1 rem/y — X X Beams >0.1 R/h fully enclosed, if feasible — X X X Beam ports covered when not in use — X X Interlocks Interlock bypass keys are controlled when not in use Interlock bypass authorized in IWS or SP X X X Required interlocks are operational X X X X Interlocks of fail-safe design (X) X X Access interlocked during charging of flash RGD (X) X X Emergency shutdown switch For RGD rooms containing a VHRA X Master key or key on master key ring required to access exclusion areas
If key required for exclusion area access X
Redundant interlocks on access doors to exclusion areas
— (X) X
Hazard-safe switches at walk-in entrances to exclusion areas
For RGD rooms containing a VHRA (X) X
Key-lock watchman stations or run-safe boxes within the exclusion area
RGD room containing a VHRA not under visual control from a single vantage point.
(X) X
Manual reset requirements for interlocks For RGD rooms containing a VHRA (X) X Audible and Visual Warning Indicators If warning lights are installed, do not modify — X Warning lights near source On, when radiation is generated or RGD is
being charged. (X) (X)
“X-Ray On” or charging status light Located near console X X “Shutter Open” lights near shutter “Shutter Open” lights should be present X X Audible and visible signal 20-sec before operation For RGD rooms containing a VHRA (X) X Audible and/or visible signal if RGD is armed (for flash/pulsed RGDs) or operating
RGD rooms containing a VHRA require both audible and visual signals.
(X) (X) X
20-second warning before radiation generation For RGD rooms containing a VHRA (X) X Radiation Alarms Area radiation monitoring system For RGD rooms containing a VHRA (X) (X)
X denotes “applicable,” (X) denotes “as specified in Doc 20.3,” O denotes “Optional”
Document 20.3 UCRL-AM-133867-VOL-2-PT-20.3-2017
Revision 7 65 January 17, 2017
Table B-1: Summary of RGD Safety Requirements (continued)
RGD Compliance Item Further Explanation Class
I II III IV II. Work Planning
Registration / Characterization Registration / Characterization Initial -- within 1 month of arrival on-site
Full -- prior to routine operations X X X X
Inventory-Non-operational; Class I, II: annually; Class III, IV: semiannually
Class I RGD inventory might be reduced to a verbal/e-mail inventory
X X X X
Safety Assessment -- Class I, II: annually; Class III, IV: semiannually
Not required for ‘non-operational’ and ‘out-of-use’ RGDs
(X) X X X
Radiation Survey -- Class I, II: annually; Class III, IV: semiannually
Not required for ‘highly safe,’ ‘non-operational,’ or ‘out-of-use’ RGDs
(X) X X X
Posting and labeling CAUTION Radiation Generating Device Area On doors entering rooms with RGDs X X X CAUTION or DANGER Radiation, High, or Very High Radiation Area
CAUTION RGD Head label Issued if head is not integral to the RGD. (X) X X X Class I RGD Guidance Posting Post near RGD X CAUTION RGD label Placed close to each port on the tube
housing, if feasible (X) (X) (X)
Last Survey Date/Next Due sticker On control console O X X X External Dose Monitoring Whole-body dosimeters — X X X X Extremity dosimeters As specified by the health physicist (X) (X) Supplemental dosimeters Access to High Radiation Areas (X) (X) (X) Portable survey meter Available at work location and entrances to
exclusion areas (X) X X
Work Control Document and Logbooks Integration Work Sheet (IWS) (or Procured Work Services Sheet)
For RGD use; maintenance and repair not covered under a safety plan; access to Radiation Areas or High Radiation Areas
X X X X
Written interlock test procedure — X X X RGD logbook for portable RGDs and field radiography
