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Radiation Generating Device Program David Kestell Radiological Control Manager. Why? The 2009 HSS review noted that LBNL did not possess a program to consistently manage radiation generating devices and ensure all aspects of 10CFR835 were fully implemented.
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Radiation Generating Device Program David Kestell Radiological Control Manager
Why? • The 2009 HSS review noted that LBNL did not possess a program to consistently manage radiation generating devices and ensure all aspects of 10CFR835 were fully implemented. • RPG wanted to develop a single program to capture all requirements to simplify and streamline the existing programs as well as provide the Laboratory community with a transparent set of requirements documents.
Result - Single RGD program document (EHS 730) developed covering: • Devices that produce radiation intentionally: • X-ray diffraction and fluorescence analysis systems. • Flash x-ray machines, cabinet RGDs. • Industrial radiography equipment. • Particle accelerators. • Devices that produce radiation incidentally: • 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. • Neutron-generators, such as deuterium - tritium (D-T) sources. • Lasers that produce ionizing radiation exceeding what is defined for commercially available devices: • Ultra-intense lasers [e.g., Berkeley Lab Laser Accelerator (BELLA)]. • Certain focused high-power lasers.
We need a list of all RGDs within each Division. Specifically, we need to know; • the Principal Investigator (PI) or RGD custodian responsible for the RGD, • the make and model of the RGD, • maximum and typical operating parameters (kV, mA), • any unique number that can be used to identify the RGD (e.g. DOE property number, serial number, etc.), and • the location of the RGD.
The appropriate Health Physicist (HP) will work with the appropriate DSC to develop and review the list of Division RGDs. • Many of these devices will be covered under existing work authorizations. RPG will provide a list of authorizations to each DSC within their Division. • Once the list of Division RGDs has been developed and reviewed, the HP will contact the PI/custodian to schedule an RGD characterization.
The RPG HP will work with the PI/custodian to determine if the RGD is exempt from the requirements of EH&S Procedure 730 and if not, will assist with classification and characterization of the RGD. • As needed, the HP will work with the PI/custodian to develop an implementation plan, approved by Division Line Management to bring any non-conforming RGD into alignment with the new program.
Exclusions • RGDs approved for use by the Food and Drug Administration (FDA) and used for human studies. • Medical x-ray devices used for diagnostic purposes only • RGDs that use sealed radioactive materials as a source of radiation, but when unshielded, are incapable of producing dose rates at or exceeding 100 mrem/h at 30 cm. • Unmodified commercially available components or devices that meet all the following criteria. • Have a potential across the terminals <16 kV. • Produce radiation fields that are no more than 0.5 mrem/h 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.
RGD classificationsMaximum Potential Unmitigated Dose Used to Classify RGDs at LBNL
Timeline • List of Division RGDs – 03/31/12 • Draft implementation plan for non-conforming devices – 06/30/12.
To follow from RPG to each DSC • List of existing work authorizations • List of known RGDs • EHS 730 (RGD Program) • EHS 731 (RGD Interlock Program)