ML19350C566
| ML19350C566 | |
| Person / Time | |
|---|---|
| Site: | 07000984 |
| Issue date: | 11/04/1980 |
| From: | Battelle Memorial Institute, PACIFIC NORTHWEST NATION |
| To: | |
| Shared Package | |
| ML19350C565 | List: |
| References | |
| PNL-MA-527, NUDOCS 8104060028 | |
| Download: ML19350C566 (3) | |
Text
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PNL-MA-527 Revision 6 Supplement 1 APPLICATION FOR RENEWAL OF i
SPECIAL NUCLEAR MATERIALS LICENSE SNM-942 Supplement
' Request for Exemption to Title 10 Code of Federal Regulation Paragraph 20.203 (c) (2).
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November 3,1980 l.
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BATTELLE~
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' PACIFIC NORTHWEST LABORATORIES
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RICHLAND, WASHINGTON 99352 N
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Request for Exemption to 10 CFR 20.203 (c) (2)
Paragraphs 20.202(b)(3) and 20.203(c)(2)(i) define a "High Radiation Area" as an area where personnel could be exposed to a dose rate in excess of 100 millirem / hour.
Battelle-Northwest requests that the level of 1 rem / hour be accepted as the dose rate at which physical safeguards, including locks or interlocks, shall be required rather than the levels specified in paragraph 20.203(c)(2). This exemption is requested for the following reasons:
1.
Hanford standard practices define " Restricted Access Radiation Zones" as those areas where dose rates may exceed 1 rem / hour.
2.
Battelle is currently, and will continue for the foreseeable future, conducting. radia' ion work in facilities that are shared with other Hanford contractors.
3.
The use of dual standards between Battelle and other Hanford contractors, and between DOE and license work within Battelle could lead to can-fusion which could possibly contribute to overexposure of employees.
(e.g., If a Battelle employee is trained that all radiation zones over 100 millirem / hour. are locked up, he could enter a zone in shared facilities with dose rates of between 100 millirem / hour and 1 rem / hour without realizing it.)
4.
It is an established pr.actice of long standing at Hanford that work in any area having dose rates in excess of 100 millirem / hour will be performed under the guidance and direction of a radiation monitoring technician.
5.
All Battelle radiation zones are well identified and in buildings or areas that preclude inadvertent access by the general public.
Ba' telle employees are not allowed'to enter any radiation zone unless 6.
t it is their regular work location or they are escorted by an employee assigned to that location.
7.
No employees have free access to all radiation zones or work areas.
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All " radiation zones"* are estatslished by first providing the Radiation Monitoring Section with a protocol of the work to be performed and the expected radiation levels. Next a " radiation work procedure" (RWP) is prepared which governs what and how the work is to be performed, including dose rates and radiation monitoring (health physics) coverage.
No radiation work may be performed in Battelle or DOE facilities without 1
a current approved RWP.
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- STANDARDS FOR RADIATION PROTECTION RL Apoendix 0524 APPENDIX I 2.
Locations.in which a major portion of the body may receive radia-tion exposures in excess of_2.5 mrem /hr shall be posted as Radiation Zones.
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