ML20217A271
| ML20217A271 | |
| Person / Time | |
|---|---|
| Issue date: | 04/15/1998 |
| From: | Cool D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Callan L, Cyr K, Stoiber C NRC OFFICE OF INTERNATIONAL PROGRAMS (OIP), NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO), NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| References | |
| NUDOCS 9804220219 | |
| Download: ML20217A271 (12) | |
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April 15,1998 MEMORANDUM TO: Those on the Attached List a
FROM:
Donald A. Cool, Director Division of Industnal and N f
Medical Nuclear Safety, NMSS
SUBJECT:
ANNUAL REPORT ON THE NRC RADIATION SAFETY PROGRAM On October 21 and 22,1997, NMSS hosted the second annual NRC Radiation Safety Officer (RSO) Counterpart Meeting. RSOs and other staff from the Regions and Headquarters participated. The attached minutes of this meeting are being provided as an annual report on the NRC radiation safety program in accordance with Management Directive MD 10.131, Protection of NRC Employees Against lonizing Radiation.
As these minutes demonstrate, the Agency is complying with the employes protection j
requirements in MD 10.131. A key challenge to the radiation safety program continues to be the transition from the old employee exposure database system to the new Windows-based system. We encourage offices with RSOs to e,ontinue their support of this effort and the ongoing interaction necessary to address rPJiation safety program issues.
Attachment:
As stated cc: H.L. Thompson, Jr., DEDR C. Paperiello, NMSS CONTACT: Kevin M. Ramsey, NMSS/IMNS (301)415-7887 DISTRIBUTION: IMNS-5964 NRC Central File JGreeves TDecker JRicci IMNS r/f CHaughney JHouse MThomas NMSS r/f ETen Eyck GMVasquez POR: YES X NO ADimitriadis RPedersen DOCUMENT NAME: a:imns5964.kmr To receive a copy of this document, indicate in the box:
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f "C"= Copy w/o att/enct "E" = Copy w/att/enct"N" = No copy
- See previous concurrence.
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April 15, 1998 MEMORANDUM TO: Those on the Attached List FROM:
Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
ANNUAL REPORT ON THE NRC RADIATION SAFETY PROGRAM On October 21 and 22,1997, NMSS hosted the second annual NRC Radiation Safety Officer (RSO) Counterpart Meeting. RSOs and other staff from the Regions and Headquarters participated. The attached minutes of this meeting are being provided as an annual report on the NRC radiation safety program in accordance with Management Directive MD 10.131, Protection of NRC Employees Against lonizing Radiation.
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As these minutes demonstrate, the Agency is complying with the employee protection requirements in MD 10.131. A key challenge to the radiation safety program continues to be the transition from the old employee exposure database system to the new Windows-based system. We encourage offices with RSOs to continue their supp~ rt of this effort and the o
ongoing interaction necessary to address radiation safety program issues.
,/
Attachment:
As stated cc: H.L. Thompson, Jr., DEDR C. Paperiello, NMSS
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CONTACT: Kevin M. Ramsey, NMSS/IMNS-(301) 415-7887
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DISTRIBUTION: IMNS-5964 NRC Central File
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< CHaughney JHouse MThomas NMSS r/f ETen Eyck GMVasquez PDR: YES X NO
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ADimitriadis RPedersen DOCUMENT NAME: a:imis5964.kmr To receive a copy of this document, indicate in the box:
"C"= Copy w/o att/ encl. "E" = Copy w/att/ encl."N" = No copy
- See previous concurrence.
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DATE 3/12/98 4/2/98 4/ 15 /9 8 OFFICIAL RECORD COPY IMNS/SEC
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l MEMORANDUM TO: Those on the Attached List
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Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
ANNUAL REPORT ON THE NRC RADIATION SAFETY PROGRAM On October 21 and 22,1997, NMSS hosted the second annual NR Radiation Safety Officer (RSO) Counterpart Meeting. RSOs and other staff from the Regi s and Headquarters participated. The attached minutes of this meeting are being p vided as an annual report on the NRC radiation safety program in accordance with Manag ent Directive MD 10.131,
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Protection of NRC Employees Against lonizing Radiation.
As these minutes demonstrate, the Agency is complyi with the employee protection requirements in MD 10.131. The minutes also show at during past year, NRC awarded the j
dosimetry contract to a new contractor and began u ng a new dosimetry service. In addition,
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NRC switched from the existing employee exposu database to a new Windows-based j
employee exposure database. These efforts, c bined with routine radiation safety matters, have the potential for strengthening the Agen s radiation safety program, but have also placed significant demands on radiation saf staff.
Attachment:
As stated cc: H.L. Thompson, Jr., DEDR CONTACT: Kevin M. Ramsey, SS/IMNS (301) 415-7887 DISTRIBUTION: IMNS-59 NRC Central File JGreeves TDecker JRicci IMNS r/f CHaughney JHouse MThomas NMSS r/f ETen Eyck GMVasquez PDR: YES X N
ADimitriadis RPedersen
-h DOCUMENT N E: a:imns5964.kmr To receive a co of this document, indicate in the box:
"C"= Copy w/ tt/ encl. "E" = Co ay w/att/ encl,"f4" = No copy
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April 15, 1998 Date:
l MEMORANDUM TO: Those on the Attached List l
l
SUBJECT:
ANNUAL REPORT ON THE NRC RADIATION SAFETY PROGRAM l
L. Joseph Callan, EDO Karen Cyr, OGC Carlton Stoiber, OIP l
William Beecher, OPA l-Hubert T. Bell, OlG j
Jesse Funches, CFO Arnold Levin, CIO Edward Halman, ADM Paul Bird, HR l
Thomas T. Martin, AEOD l
James Lieberman, OE Guy Caputo, Ol Malcolm Knapp, RES Samuel Collins, NRR Richard Bangart, OSP l
Hubert Miller, RI Luis Reyes, Ril Arthur Beach, Rlli Ellis Mershoff, RIV 1
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Minutes of the Second Annual NRC Radiation Safety Officer Counterpart Meeting held at NRC Headquarters on October 21 - 22,197/
Background
On October 21 and 22,1997, NMSS hosted the Second Annual Radiation Safety Officer (RSO)
Counterpart Meeting. RSOs and other staff from Regions I, il, Ill, IV, TTC, NMSS, NRR, and RES participated. The purpose of the meeting was to exchange information and ideas about the radiation safety program for NRC employees. Topics included a peer review of the programs in Region I and NMSS, the NRC dosimetry program, mail room x-ray machines, the employee exposure database system, radiation safety training, surveys and disposal records, and Management Directive (MD) 10.131.
Hugh L. Thompson, Deputy Executive Director for Regulatory Programs, welcomed the participants and emphasized the importance of effective and consistent radiation safety programs for NRC employees. He discussed the need to address resources and noted that the program reviews conducted during these meetings are an essential part of satisfying that need.
Summarv of items Discussad
- 1. Review of Followuo items from Last Meetina - The participants reviewed and closed several itemc identified for followup action during the last meeting. Areas requiring further action include procedures for handling training records, record retention schedules in MD 10.131, and evaluating the feasibility of a contingency contract to provide bioassay services to employees.
- 2. Peer Review of Realon i Radiation Safety Proaram - The participants reviewed Regional Instruction 0860.1, Rev.5, " Region l Radiation Safety Program." It was noted that Rl has a Radiation Safety Committee (RSC) that meets quarterly. The RSC is comprised of the Deputy Regional Administrator and a representative from each division. (Region IV is the only other region or office that has a radiation safety committee.) An RSO and an Alternate RSO are appointed for 2-year terms. The RSC Chairman nominates individuals to fill RSO vacancies. RI has a radiation permit program to authorize the possession and use of radioactive materials and radiation producing devices by RI personnel. The current permits cover the regional laboratory (including an irradiator for the environmental dosimeter system), the portable laboratory van, and the mail room x-ray machine.
The peer review concluded that RI has a comprehensive radiation safety program that complies with the requirements of MD 10.131. Comments were provided on areas that could be clarified or improved. These included employee responsibilities to return dosimeters, report problems to management, and (for female employees) submit written declarations if they choose to declare themselves pregnant. It was also noted that employees should be piovided with an annual exposure report, rather than just being notified ofits availability.
Attachment
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- 3. ' Peer Review of NMSS Radiation Safety Proaram - The participants reviewed NMSS Policy and Procedures Letter 1-42, Rev.1, " Radiation Protection Procedures for NMSS Employees." The NMSS program consists of an RSO reporting directly to NMSS management. There is no Radiation Safety Committee and no Alternate RSO. Although MD 10.131 does not require a Radiation Safety Committee nor an Alternate RSO, the participants believed it would be good practice for NMSS to establish an Alternate RSO.
The peer review concluded that the NMSS radiation safety program complies with MD 10.131. It was noted that NMSS requires declared pregnant employees to provide a copy of their written declaration to appropriate licensee management before site visits that may involve exposure to radiation or radioactive materials. Some participants raised concerns that this may violate Privacy Act provisions. NMSS noted that all NRC offices rely on licensee radiation safety programs to protect NRC employees during site visits. NMSS believes it is necessary for the protection of the employee to inform licensee management when the declared pregnant employee is subject to special dose limits for the embryo / fetus.
It was agreed that NMSS would consult with OGC on this matter. Each RSO will be 4
provided a copy of OGC's response.
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- 4. Exoerience with New Dosimetry Service - On April 1.1997, NRC began using a new dosimetry service (Landauer, Inc.). The establishment of new accounts and the first shipment of dosimeters to each office was performed well with only a few shipping errors.
Two NRC offices experienced delays in July retuming their second quarter dosimeters for processing. Landauer failed to inform the NRC Technical Monitor that they had not received these shipments (as required by the contract). In addition, Landauer failed to promptly notify the appropriate RSO of a dosimeter result exceeding ALARA reporting threshold (125 millirems) specified in the contract.' On August 15,1997, a cure letter was issued directing Landauer to address these problems. On August 21,1997, Landauer informed NRC of corrective actions taken to ensure that they comply with reporting requirements for late dosimeter shipments and dosimeter results exceeding ALARA thresholds in the future.
An additional problem was experienced with the electronic report required by the contract.
Landauer is required to provide a written report of dosimetry results to the appropriate RSO for each office, and an electronic report (i.e., computer disk) of the same information to the l
NRC Technical Monitor for loading into the employee exposure database system. During September, a disk with records for Headquarters dosimeters (only) was received. Landauer subsequently informed the NRC Technical Monitor in October that they had failed to code the regional accounts for electronic reports, so no electronic reports were generated.
Second quarter disks for the regional accounts were still pending at the time of the f
counterpart meeting. (Subsequently, computer disks for the regional accounts were received on October 29,1997.)
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5 The RSO talked to the employee about recent activities and the need to maintain exposures as low as reasonably achievable. No limits were exceeded.
3 The RSOs expressed disappointment with Landauer's performance to date, but Landauer's corrective actions appear to be prompt and effective. It was noted that a second high dosimeter reading from a third quarter dosimeter was promptly reported to the appropriate RSO in accordance with the contract.:
- 5. Exoerience with Mail Room X-rav Machines - During 1996, x-ray machines were installed in j
the mail rooms of all NRC offices. X-ray machines are typically regulated by State agencies (NRC has no jurisdiction). Each RSO (except as noted below) has contacted the appropriate State agency and confirmed that x-ray machine operations are consistent with State requirements. Except for Pennsylvania (which requested registration), the States do not intend to inspect or othenuise regulate these x-ray machines because they are in Federal facilities. The following reports were provided by each office:
- a. Headauarters - There are two x-ray machines at Headquarters. The NRR RSO provides radiation safety support to ADM contractor staff in the Headquarters mail room.
There are four operators. Radiation safety training was provided to the operators in 1996. Refresher training was provided in 1997 to the Headquarters operators and some regional operators. Surveys are done by the vendor every 6 months after service. A dosimeter is posted on each wall and a dosimeter is provided to each operator (at their request). The NRR RSO noted that he has little authority over the x-ray machines and was not notified the last time the vendor serviced the machines.
- b. Reaion I - There is one x-ray machine in the Region I mail room. There are three operators. The RSO provides the operators annual radiation safety training as part of the Non-Radiation Worker Training provided to all ancillary staff. Surveys are performed by the RSO quarterly. Dosimeters are posted on the key and under the operations console.
- c. Reaion ll - The Federal Building in Atlanta houses several Federal agencies, and another agency provides oversight of the x-ray machine operations.
- d. Reaion ill - There is one x-ray machine in the Region lli mail room. There are ten operators and each has received radiation safety training, however only two had received operator training at the time'of the counterp art meeting. Operator training is provided at Headquarters and future training is controlled by ADM. Region ill contracted with the company that calibrates their survey meters to survey their x-ray machine quarterly, because that company has experience performing x-ray machine inspections for the State of Illinois and it was an easy modification to the existing i
contract. Initially the operators refused to operate the x-ray machine, however, after l
extensive discussions, the RSO agreed to post nume rous dosimeters to alleviate operator concerns. Dosimeters are posted on three walls, the ceiling (for staff in the storeroom above), the operations console, the entrance and exit of the machine, and the top of the machine.
2 The RSO talked to the employee about recent activities and the need to maintain exposures as low as reasonably achievable. No limits were exceeded.
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- e. Reaion IV - There is one x-ray machine in the Arlington mail room and one x-ray machine in the Walnut Creek mail room. There are two operators in Arlington and one operator in Walnut Creek. The operators were trained at Headquarters. Dosimeters are posted on the unit keys, the front of each machine (abdomen level), and are provided to each operator. Surveys are performed semi annually by the vendor during routine maintenance. The region performed independent surveys after installation and before the first use. The RSO noted that the disposition of the Walnut Creek unit after the field office closes is unresolved.
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Technical Trainino Center - There is one x-ray machine in the TTC mail room. AEOD has appointed a special, on-site RSO responsible for x-ray machine operations only.
The AEOD RSO in Headquarters is responsible for personnel monitoring and radiation safety issues involving other TTC staff, There are two operators and they were trained by the TTC RSO. Dosimeters are posted on the operations console, and the entrance and exit of the machine. Surveys are performed annually by the TTC RSO.
- 6. Develooment of the New Emolovee Exoosure Comouter System - The RES contractor (SAIC) developing the new employee exposure computer system briefed the RSOs on the status of the new system. This system will replace the existing mainframe system currently located at the National Institutes of Health computer facility. The new system will be Windows-based and compatible with the Radiation Exposure information and Reporting I
System (REIRS) used to store occupational exposure data submitted by licensees. The SAIC Project Manager reported that the new server has' been installed at their Oak Ridge, TN facility and it is operational. The data will be transmitted over the Internet and a number of security measures (firewalls, encryption, etc.) have been established to protect the information. Three separate software packages are required for each user. The procurement and delivery of the software is scheduled to be complete by the end of
' December. (Software delivery has been completed.) RSOs were provided with instructions and passwords to install the software. A request is being processed to download data from the existing database to diskettes and provide it to SAIC to populate tables in the new system. The old system will be decommissioned after the data is transferred and validated.
(The data has been provided to SAIC and they are in the process of placing it into production.)
- 7. Review of 1996 Monitorina Results - The RSOs reviewed a summary of the employee monitoring results for calendar year 1996. A copy of this summary is attached.
- 8. Review of Radiation Safety,Trainina - The RSOs discussed the radiation safety training.
provided to employees. " 9 AEOD Technical Training Division (TTD) provides several site access training courses de..igned for employees requesting unescorted access at nuclear power plants, and fuel cycle facilities with similar site access requirements. These site access courses include a 2-dey class with restricted area mock-ups, a 1-day refresher class, and a self study computer-based course. The site access courses include a 50-question exam with r. passing grade of 80 percent. TTD also provides an NMSS Radiation Worker Tralrang course designed for employees visiting nonreactor sites without formal site access recairements. This is a half-day class including a 20-question exam with a passing grade of 8C percent.
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In addition to the training developed by TTD, Region I has developed a nonradiation worker training class for housekeeping and other ancillary personnel, and refresher training for inspectors in the Division of Nuclear Materials Safety. Regions ll, lil, and IV each use the computer-based site access training developed by TTD for all inspectors.
- g. Review of Reaional Facility Survevs and Waste Shioments - The regional RSOs discussed the periodic surveys they perform around their laboratories, x-ray machines, and radioactive material storage areas. In addition to calibration and check sources, the regions analyze swipes and samples taken by inspectors. The disposal of old sources and laboratory waste was discussed also. The following information was provided by each region:
Region 1:
Monthly radiation surveys during 1990 showed background radiation levels.
Environmental dosimeters posted on the wall of the irradiator room read approximately 0.20 millirem / day. A waste shipment of two 55-gallon drums and one 30-gallon drum was shipped on August 29,1996.
Region 11:
Quarterly radiation surveys during 1996 showed background radiation levels (regionallaboratory inactive). There wers no waste shipments.
Region lil: Monthly radiation surveys during 1996 showed background radiation levels.
There were no waste shipments.
- Region IV: No radiation surveys were conducted during 1996 because no work was performed in the regional laboratory. There were no waste shipments.
- 10. Onen Discussion of Radiation Safety Proaram issues - The following additional issues were discussed:
- a. Chanaes to Manaaement Directive 10.131 - A number of changes were suggested including: (1) revising the responsibility for providing the list of employees that have completed radiation safety training to recognize the training records already maintained by HR, (2) specifying record retention schedules in sections that do not yet have schedules, (3) clarifying recordkeeping requirements for abnormal dose investigations, (4) requiring personnel monitoring if employees enter high radiation areas, (5) clarifying that HR is responsible for providing quarterly updates of employee data to RES for validating dose reports, and (6) clarifying that regions and offices are responsible for controlling all sources of radiation (including x-ray machines). NMSS agreed to prepare a draft revision for comment.
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- b. Resoiratorv Protection Reauirements - Randy Brown, the Agency Safety and Health Manager, participated in a discussion of the requirement for each region to establish a written respiratory protection program specified in Management Directive (MD) 10.130, Safety and Health Program Under the Occupational Safety and Health Act. This directive states that a minimally acceptable program must have written procedures i
governing the selection, use, and maintenance of respirators. It was noted that regional inspectors are authorized to use respirators at licensee sites if the inspectors comply with the approved respiratory protection program at the site. It is impractical for regional
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6 offices to establish written procedures for the use of respirators by employees in these situations. Mr. Brown was asked to consider changes to MD 10.130 recognizing that NRC employees may use respirators under a licensee's written respiratory protection program. Mr. Brown agreed to review the matter,
- c. Resoondina to Reauests for Emolovee Dose Histories - The RSOs discussed the fact that MD 10.131 requires dose reports to be provided when they are requested by current and former employees, but there is no requirement to respond to requests submitted by licensees under 10 CFR 20.2104. Licensees are required under 20.2104(a)(2) to attempt to obtain dose records before the current year. The large number of site visits by NRC employees generates a large number of requests for dose histories. Responding to these requests would impose a significant burden on the Agency's radiation safety staff, without improving employee safety. A health physics position issued on June 6,1994, states that employee dose histories will not be provided when requested by licensees under 20.2104(a)(2). Employees will provide licensees with a signed estimate of their dose for the current year only.
Conclusion The participants agreed that the meeting provided a useful exchange of information and ideas.
The Region IV RSO tentatively volunteered to host the next counterpart meeting, pending approval of regional management. The office programs tentatively scheduled for peer review at the next meeting are NRR and Region 11.
Attachments:
1.1996 Exposures
- 2. Attendance List j
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NRC Radiation Safety Officer Counterpart Meeting NRC Headquarters October 21 - 22,1997 Attendance List Name OMce Anthony Dimitriadis RI Tom Decker Ril John House Rlli G. Michael Vasquez RIV Kevin Ramsey NMSS Roger Pedersen NRR John Ricci TTC May Thomas RES Derek Hagemeyer SAIC (RES contractor) 1 i