ML20056B556
| ML20056B556 | |
| Person / Time | |
|---|---|
| Issue date: | 10/18/1990 |
| From: | Glenn J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20056B557 | List: |
| References | |
| HPPOS-307, NUDOCS 9010300388 | |
| Download: ML20056B556 (3) | |
Text
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NUCLEAR REGULATORY COMMISSION 3i j
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OCI 181990 MEMORANDUM FOR:
Mohamed M. Shanbaky, Chief, Nuclear Materials Safety Section, Region I
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FROM:
John E. Glenn, Chief Medical, Academic, and Commercial Use Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
NRC LICENSED FACILITIES REQUESTING TO NAME A CONSULTANT PHYSICIST AS THEIR FULL-TIME RADIATION SAFETY OFFICER TECHNICAL ASSISTANCE REQUEST DATED JULY 10, 1989 This memorandum responds to the technical assistance request dated July.10, 1989, from Region I, regarding an amendment application from an NRC licensee who wishes to name a consultant as its full-time Radiation Safety Officer (RS0).
Qualified individuals, as outlined in 10 CFR 35.900, may be appointed RSO to an NRC license issued under 10 CFR 35 provided the individual commits to being physically present at the facility for a specified amount of time in order to satisfactorily perform the duties of the RSO. The specific time necessary is commensurate with the requirements of the facility and must be determined on a l
case-by-case basis. The time commitment must be during normal working hours which provides the opportunity for interaction between the consultant and-licensee management.
Clarification is needed as to the_ individuals availability to respond to questions, incidents, and/or emergencies as needed, both by telephone, and.on-site. However, it should be noted, there will be some programs where-in it would be inappropriate to designate a consultant as RSO, e.g.,
programs involving radiopharmaceutical therapy, teletherapy, and large scale users l
of byproduct material etc.
The licensee must agree to the above as a license commitment with the caveat that if at a later date the number of hours and days spent by the RSO at the facility or the consultant's availability are insufficient to fulfill the responsibilities required, the program will be re-evaluated, and adjustments will be made.
A similar request for technical assistance was received from Region III.
Included with that package was a list of questions which appeared to address the most pertinent issues concerned with appointing consultants'as RSO (copy enclosed).
This questionnaire has been reviewed and expanded by our staff.
Review of any request by a licensee to use a consultant as an RSO should address minimally these issues.
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Any licensee requesting to designate a consultant as RSO should be reminded that 10 CFR 35.21(a) states "the licensee, through the RSO, shall ensure that radiation safety activities are being performed in accordance with approved procedures and regulatory requirements in the daily operation of the licensee's byproduct material program".
The use of a consultant as RSO does not negate the responsibility of the licensee to ensure the safe use of byproduct material.
If there are any questions, please direct them to Sally Merchant of my staff at (301) 492-0637 S
John Glenn, Chief Medical, Academic, and Connercial Use Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS
Enclosure:
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l ISSUES Prior to approving a consultant as Radiation Safety Officer (RS0), the following 1ssues should be addressed by the licensee:
1.
Describe the control over the radiation safety program that will be delegated to the RSO so that he will be able to exercise his authority over authorized users when confronted with radiation safety problems which require implementation of corrective actions.
2.
Describe the relationship which will exist between the censultant RSO and-the licensees' institutional management regarding expenditure of funds to facilitate the objectives of the licensees' radiation safety program and-related regulatory requirements.
3.
Identify previous commitments as RSO for any NRC-licensed facility, along with a description of how he will divide his time so that he will be able to adequately perform the duties of the RSO as described in 10 CFR 35.21.
4.
Appoint an in-house professional who will serve as a contatt during the R50's absence.
This person may be allowed to assist the RSO with limited authori ty.
5.
Describe the minimum amount of on-site time that the individual will spend performing his/her duties as RSO. This should be defined in terms of hours per week.
6.
Describe the overall availability of the consultant RSO to respond to questions or operational issues which arise during the conduct of the licensee' radiation safety program and related regulatory requirements.
What is the maximum amount of time it will take the RSO to arrive at the facility in the event of an emergency which requires his presence.
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