ML20234D396
| ML20234D396 | |
| Person / Time | |
|---|---|
| Issue date: | 11/06/1984 |
| From: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20234D394 | List: |
| References | |
| FOIA-87-809, TASK-OP-722-4, TASK-RE NUDOCS 8801070009 | |
| Download: ML20234D396 (11) | |
Text
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O nov 81984 1
i MEMORANDUM FOR: Regional Administrators Branch Chiefs Division of Fuel Cycle and Material Safety, NMSS FROM: Richard E. Cunningham, Director Division of Fuel Cycle and Material Safety, NMSS -
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SUBJECT:
POLICY AND GUIDANCE DIRECTIVE FC 84-18: TRANSPORTATION '
0F IRRADIATOR UNITS NOT MEETING CURRENT REQUIREMENTS OF 10 CFR PART 71 i Prior to the adoption of the require 1ents of 10 CFR Part 71 in 1966, -
irradiators could be transported without being evaluated under the accident damage test requirements that are now incorporated in Part 71.
Many of these irradiators are in use and from time to time need to be transported to a new location. .1 In those cases where the irradiator cannot be practically transported in j packagings which meet the requirements of Part 71, the licensee may 1 request a one-time shipment in accordance with 10 CFR 6671.7 and 71.41(c).
The shipment can only be authorized by Headquarters. In applying for a one-time shipment, the licensee must provide adequate controls such that ] i the shipment will not endanger life or property. '
The following information is typical of what the licensee has been requested to submit to Division of Fuel Cycle and Material Safety, NMSS, to support one-time shipment requests J
- 1. The circumstances as to why an existing package cannct be used. 1
- 2. Engineering drawings of irradiator.
- 3. Information to confirm: i 1
- a. Transport during time of low road usage. l 1
- b. Use of good roads and avoidance of residential areas to maximum i extent possible. l
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Multiple Addressees NOV 6 1984
- c. Accompaniment of shipment by escort knowledgeable in the use of radiation survey instrument.
- d. Provision of escort with appropriate survey instrument and supplies to permit the establishment of a radiation exclusion
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- e. Written pr acedures to be followed by the escort in an emergency situation.
- f. Use of exclusive use vehicle and shoring to limit movement of package during transport.
- g. Notification of state health officials and local fire department of time and route of shipment.
Prior to applying to the NRC for its approval .the licensee should contact the State Health Officer of each state through which the shipment will be made to confirm the points of contact and to discuss the proposed controls for the shipment. In several recent cases, short distance shipment of irradiators have been successfully made with the cooperation of state officials.
All requests for shipments of irradiators containing the above infomation should be referred to the Material Licensing Branch who will coordinate the approval authorizing the shipment with the Transportation Certification .
Branch. j i
All new irradiators are expected to meet the requirements of Part 71.
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Richard E. Cunningham, Director Division of Fuel Cycle and ,
Material Safety, NMSS I CONTACT:
R. H. Odegaarden i 301/427-4122 9
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["*%n l U.S. NUCLEAR REGULATORY COMMISSION 0FFICE OF NUCLEAR REGULATORY RESEARCH April 1982 Division 8 DRAFT REGULATORY GUIDE AND VALUE/ IMPACT STATEMENT Task OP 722-4
Contact:
J. M. Bell (301) 443-5970 QUALIFICATIONS FOR THE RADIATION SAFETY OFFICER IN A LARGE-SCALE NON-FUEL-CYCLE RADIONUCLIDES PROGRAM A. INTRODUCTION , ,
Paragraph 30.33(a)(3) of 10 CFR Fart 30, " Rules of General pile 111ty to Domestic Licensing of Byproduct Materi'a1." requires thatkhe a)[pIfcant for a byproduct materials license be qualified by training bd.exphience to use .
radioactive material safely. Paragraphs 33.13(c)(2 *d3 n b)(1) of 10 CFR Part 33, " Specific Domestic Licenses of Broad Sca'pe.fohtyproduct Material,"
%ww require that the applicant for a Type A or T pe 8E ond license for the posses-sion and use of byproduct material appoint a 'adiol ical safety officers who ,
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is qualified by training and experience To(rg,atTon protection. Para- j graph 35.11(b) of 10 CFR Part 35, " Human,AUses of Byproduct Material," requires l that an institution applying for a icense for human use of byproduct material f
appoint a medical isotopes combee ofI least three. members, one of whom
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ahould be a p son experience in assay of radioisotopes and protection against Nea.ak l ionizing radiations. Paragraph 40.32(b) of 10 CFR Part 40, " Domestic Licensing 1 1
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ofSourceMaterial,"ggiresthatanapplicantforalicensetopossessand use source material .be fuglified by training and experience to use the source A:h w ,
3" Byproduct material", is defined in paragraph 30.4(d) of 10 CFR Part 30; I genera 11ygpeng,pthe tem refers to reactor produced radionuclides.
- Professi'oryals responsible for radiation safety are referred to by various titles such,as " radiological safety officer " " radiation protection officer,"
s and " radiatio'n safety officer." This guide uses the title " radiation safety officer (R50)."
a" Source material" is defined in paragraph 40.4(h) of 10 CFR Part 40; gener-ally speaking, the term refers to naturally occurring uranium and thorium.
i This regoletery guise ens the essociated eelse/teset stateneat see 6mia0 issued in tref t fees te levolve the pelic in the early stages of the development of a regulatory sesitten in this cree. They have not ecceleod toutete staf f review and de not represent en of ficial meC stef f positten.
Public comments are betag solicited en both tref ts. the eutee (f acteding any 8eeleneatetten schedule) and the value/lesset statement. Cauments en the eelue/lesect statement ehevis te acteepeales by segeerting date.
Cauments en both Wref ts shavid be seat to the secretary of the Camelssten. U.s. hvclast.pegu1 story Commission. Washineten. B.C. 20555. Attention: anchettat ens service treach. Dy.)UN 3 o nec Reevests for stacle cooles of tref t evices (which may be coerseuced) er for sistement en en evtomatic elettibutton itst for stagne contes of future eref t gulses la esecific divistens snevla me mese te w',itias to the U.S. oveleer sesvletery Commissten, weshingtes. D.C. F0655. Attention: Director.
99 4sica of Techattei late *metion aas Docuneat Coatrol.
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,and responsibilities. This guide describes the qualifications (training and
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experience) acceptable to the NRC staff for a radiation safety officer (R50) for a large program involving the use of radioactive materials under a Commission license. -
B. DISCUSSION
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The individual worker using radionuclides as a tool may find that acquir-ing the knowledge and developing the practices necessary to ensure that his or her radiation doses are as low as is reasonably achievable demands too much of his or her valuable time. When a number of individuals are working with radio-active materials, it becomes very inefficient for each worker to make the many assessments and decisions related to his or her and the group's radiation safety.5 In addition, coordination of various activities (e.g., effluent discharges, receipt and distribution of radioactive materials, disposal of radioactive wastes) will be necessary to avoid violation of Commission reg-j ulations and to be consistent with good radiatf- Aafety practices. In such cases, a person specifically trained in the radiation health sciences and appropriately experienced in applying this training,to the management of a radiation protection program becomes invaluable. This person can maintain an awareness of devel.opments in the radiation health sciences and inform
. workers (e.g., by means of training programs) of the benefits to be deriveci from recent advances in radiation safety knowledge. His or her knowledge of -
regulatory requirements and improvements in equipment and radiation safety '
practi'ces can also be made available to management for its ust in asking deci-sions af fecting the radiation safety of workers. Also, such E person with -
experience managing a radiation safety program and with knowledge of the licensee's specific program will be in a position to comunicate appropriate I
sin accordance with i 19.12 of 10 CFR Part 19. all workers must receive train-ing commensurate with the radiation safety problems associated with their individual jobs. However, such training will usually not qualify each wer'ker c
as a radiation safety professional capable of interpreting and applying i basic radiation safety standards to such things as the design of procedures, processes, and equiptunt.
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,materil a s. Within the limits of flexibility of the Ifeense, the licensee has
(., the prerogative and responsibility to make decisions that have a major effect on the health and safety of its workers and that are necessary to maintain compliance with Commission regulations. Competency in the radiation safety field is basic to making and implementing such decisions. Such flexibility is not limited to " broad" licenses issued under the provisions of 10 CFR Part 33.
A large program may have any or all of the following characteristics:
- 1. In-house calibration of radiation survey, monitoring, and measurement instruments.
- 2. The use of multiple chemical and physical forms of multiple radio-nuclides for various purposes.
3.
Program flexibility with regard to the use of radionuclides, their chemical and physical form, and the uses to be made of such radionuclides.
- 4. The need for accurate detection, identification, and measurement of radioactivity in various types of effluents (gas, liquid, solid) containing varying amounts of different radionuclides and for evaluation of these effluents against Commission regulatory requirements and limitations.
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The need for radioactive ef fluent treatment by filtration, absorption,-
adsorption, holdup, etc.
- 6. The need for the selection, evaluation, design, fabrication, mainte-nance, and use of radioactive effluent treatment systems.
- 7. The need for the selection, evaluation, and maintenance of radiation measurement and analysis equipment.
- 8. A potential for the contamination of facilities, equipment, and personnel accompanied by the need to control such contamination (including airborne contamination), decontaminate personnel and equipment, and evaluate l
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. 18. The need for maintaining records necessary for compliance with
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g, Commission regulations and license conditions.
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The nerd for selecting, evaluating, distributing, and maintaining personnel monitoring devices and interpreting monitoring results from them. l I
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The need for continual overall surveillance of the radiological health aspects of the use of radioactive materials, including the analysis and reporting
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of surveillance results to appropriate management.
- 21. The need for written, formalized rules, instru,:ifons, and procedures 2 for procurement, disposal, and safe handling of radioactive materials.
22.
The need for evaluating, from a radiation safety standpoint, proposed work with radioactive materials in accordance with an established review process. I 23.
The need for determining the adequacy, from a radiation safety stand-j
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point, of the training and experience of individuals pro' posing to work with s radioactive materials. .'
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The need for effective communication to public and private groups of the implications of the proposed use of radioactive materials and the licensee's radiation safety program. '
2'5.
The need for proper packaging and transport of radioactive materials.
The R50 in a large program will need a basic technical knowledge suffi-cient to understand, in general, the majority of the work being done with radio-active materials under his or her responsibility. However, every R50 cannot 1
be an expert in every field that may be associat'ed wf th the creation or solution of radiation safety problems. It will be necessary, in many instances, for the R50 to consult experts in such specific fields as criticality control, bio-assay, and biochemistry to supplement his or her own knowledge and ability.
It it important trat the R50 have a background of training and experience and 4
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s Table 1 COMBINATIONS OF TRAINING'AND EXPERIENCE FOR A RADIATION SAFETY OFFICER
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Formal Education and Certification Experience {
i A. Bachelor's degree in health A. Four years of applied physics or radiological health. health physics experience
. in a program with radia- l tion safety problems similar to those in the program to be managed.
B. Bachelor's degree in a physical B. Same as above science or a biological science with a physical science minor, and one year of graduate work in health physics.
C. Master's degree in health physics C. Three years of applied health or radiological health, physics experience in a program !
with radiation safety problems similar to those in the program
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to be managed.
1 D. Doctor's degree in health D. Two years of applied health l physics er radiological health, physics experience in a program with radiation safety problems similar to '
t, hose in the program to be .
managed.
E. Comprehensive certification by E. Same as above the American Board of Health Physics.
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, APPENDIX A j
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CHARACTERISTICS FOR QUALIFYING'A RADIATION SAFETY OFFICER CANDIDATE
- 1. Ability to communicate clearly, both verbally and in writing.
- 2. Knowledge of mathematics, physics, chemistry, and biology sufficient to understand health protection standards, theories, and practices.
- 3. Knowledge of current standards, guides, and reports published by various )
organizations (e.g., the International Commission on Radiological Protec-tion; the National Council on Radiation Protection and Measurements; the United Nations Scientific Comittee on the Effects of Atomic Radiation; ;
the National Academy of Sciences, National Research Council Advisory Committee on the Biological Effects of Ionizing Radiations; and the American National Standards Institute) and the ability to understand, interpret, and effectively apply them. -
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- 4. Knowledge of applicable NRC regulations, regulatory guides, and NUREG-series reports and ability to understand and effectively apply them.
- 5. Knowledge and ability sufficient to operate instruments used in the -
program for measuring radiation and radioactive materials and to inter-pret the resulting measurements.
- 5. Knowledge and ability sufficient to perform calibrations of instruments used in the program for measuring radiation and radioactive materials.
- 7. Knowledge and -hility sufficient to select radiation and radioactive materials measuring instruments appropriate to their proposed use in the program.
- 8. Knowledge and ability sufficient to evaluate the need for shielding and to determine the types and amounts of shielding required.
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- 20. Knowledge and abilit,r sufficient to evaluate, design, test, maintain, and
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supervise the maintenance (from the radiation safety standpoint) of pro-cess control and confinement systems such as gloveboxes and hoods.
- 21. Knowledge and ability s'ufficient to evaluate, select, design, maintain, and test sealed sources of radiation and devices in which the sources are to be used.
- 22. Knowledge and ability sufficient to evaluate, select, and design and effectively use, s.aintain, and supervise the use and maintenance of radioactive waste collection, treatment, packaging, and disposal equipment and facilities and to prepare related radiation safety procedures.
- 23. Working knowledge of transport regulations and requirements as they apply to the transport of radioactive materials.
- 24. Knowledge and ability sufficient to conduct a bicassay program.
- 25. Knowledge and ability (including a maturity of' judgment developed frem appropriate radiation safety program experience in work situations similar to that of the program for which he or she is a candidate radiation safety officer) sufficient to manage effectively the applicant's radiation safety program. .
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.' providing guidance for determining the acceptability of individuals as R50s ,
( .' for large-scale non-fuel-cycle programs.
Use of this guidance should significantly reduce the time and effort
- expended by NMSS in reviewing applications and corresponding with applicants.
1.3.2 Other Government Acencies i A significant value/ impact will not accrue to any other Federal agency. )
unless that agency happens to be an applicant. A definite benefit will accrue to Agreement States that adapt the guide to their own use.
1.3.3 Industry The availability of guidance with respect to RSO qualifications shoL1d result in greater uniformity in the review of license applications and the ,
1 expenditure of less time and effort by applicants in meeting licensing require-ments and in selecting individuals to serve as R50s. Any changes in health physics programs resulting from the publication of the guidance would most j probably be in the direction of upgrading their quality. Such upgrading may result in increased costs to the applicant. However, it is expected that
- i. such costs would be of fset by improvements in healt.h physics programs result-ing in reductions in exposure to radiation and radioactive materials. I Educational institutions and professional groups.that participate in the training of individuals who are to serve as R50s or that establish RSO qualifi-cation standards may also benefit from use of the guidance. .
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1.3.4 Public l j
No significant direct impact on the public is foreseen. A likely benefit is the reduction in occupational exposures and effluent releases brought about j through the knowledge of better qualified R50s.
- 1. 4 Decision -
It is concluded that guidance should be furnished on acceptable training and experience for R50s within large-scale non-fuel
- cycle programs.
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, , with respect to qualifications for an RSO responsible for large-scale programs
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will present all pertinent information in one document, thereby avoiding con-fusion. In addition, preparation of a single, separate guide will be more*
efficient from the standpoint of accommodating comments in the internal NRC review and concurrence proces's than would several guide revisions. A guide will also provide a mechanism for public review and comment.
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3.3 Decision on Procedural Approach l
A regulatory guide should be prepared.
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- 4. STATUTORY CONSIDERATIONS I i
4.1 NRC Authority i The Commission's authority to issue this guide is derived from the Atomic Energy Act of 1954, as amended, through the Commission's regulations. 1 4.2 Need for NEPA Assessment ,
The proposed action is not a majer action as defined by paragraph 51.5(a)(10)
I of 10 CFR part 51 and does not require an environmental impact statement.
- 5. RELATIONSHIP TO OTHER EXISTING OR PROPOSED REGULATIONS OR POLICIES This action will result in a guide that will supplement other guides related to radiation safety. When this guide is completed, appropriate revision of existing and in process guides affected by the guidance will be made.
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SUMMARY
AND CONCLUSIONS A regulatory guide on R50 qualifications for large-scale non-fuel-cycle programs should be prepared and issued.
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