Module 5 RASP Regulations

Objectives List the organizational structure governing the RASP program. Identify the responsibilities that each organization has in the RASP program. Identify each of the regulatory standards. Identify the regulatory standard governing various attributes.

The Nuclear Regulatory Commission (NRC) The NRC regulates the use of radioactive material in the United States Issues radioactive material licenses Conducts program inspections Promulgates Title 10 of the Code of Federal Regulations

NAVY RADIATION SAFETY COMMITTEE (NRSC) The NRC has issued a master materials license to the NRSC for control of all NRC licensed radioactive material. The NRC has granted the NRSC authority to issue Navy Radioactive Material Permits (NRMPs) to Navy activities in lieu of NRC licenses. NRC has done at least 3 audits at PSNS

NAVSEADET RASO NAVSEA Detachment Radiological Affairs Support Office (NAVSEADET RASO) The NRSC has tasked RASO with: Reviewing NRMPs Auditing for NRMP compliance Disposing of RASP radioactive waste Reviewing RASP facility proposals Training of RSOs Providing technical assistance to RASP command

Radiological Affairs Support Program (RASP) The RASP includes all radioactive material except the following: Sources controlled by the Naval Nuclear Power Program DOE exempt sources Nuclear weapons Medical sources

THE NPS RASP President, NPS, responsible for the program The RSO reports directly to the President RASP program governs: Accelerators Analytical x-ray machines Generally licensed sources Broad Scope Type B License Consumer products

Code of Federal Regulations (CFR) CFRs are a set of enforceable regulations issued by an agency. 10 CFR Energy 49 CFR Transportation

NRC REGULATIONS Title 10 of the Code of Federal Regulations Part 19 “Notices, Instructions and Reports to Workers: Inspection and Investigations” Part 20 “Standards for Protection against Radiation” Part 21 “Reporting of Defects and Noncompliance”

NRC REGULATIONS (Cont.) Title 10 of the Code of Federal Regulations Part 30 “Rules of General Applicability to Domestic Licensing of Byproduct Material” Part 71 “Packaging and Transportation of Radioactive Material” Part 30 What is byproduct material? By product material means any radioactive material (except special nuclear material) yielded in or made radioactive by exposure to the radiation incident to the process of producing or utilizing special nuclear material  

10 CFR PART 19 Part 19 requires that we conspicuously post the following notices to personnel who work with licensed material: NRC Form 3 The license or NRMP Parts 19 and 20 of 10 CFR Applicable operating procedures Any notice of violations

Part 19 also requires that: Workers be trained prior to using sources 10 CFR PART 19 Part 19 also requires that: Workers be trained prior to using sources Workers be informed of their exposure Workers be allowed to speak to the NRC without reprisal

10 CFR PART 20 Requires establishment of a radiation safety program Contains: Dose limits Survey and monitoring requirements Requirements for control of sources and restricted areas Waste disposal requirements Requirements for records and reports Quantities of sources requiring labeling Limits for concentrations of effluents in air and water

10 CFR PART 21 Contains requirements for reporting instances of noncompliance or deficiencies to the NRC Notification of the NRSC and NAVSEADET RASO has replaced the 10 CFR 21 notifications for naval activities. The RSO will perform the required notifications but you must inform the RSO of any problem or potential problem.

10 CFR PART 30 Contains information on: Employee protection Completeness and accuracy of information Deliberate misconduct Byproduct material

DOT 49 CFR Specifically, DOT 49CFR, Subtitle B, Chapter 1, Subchapter C Contains: Definitions Requirements for package selection Marking, labeling, shipping paper, and vehicle placarding requirements Training and emergency response requirements

NAVSEA S0420-AA-RAD-010 Rev 1 Generic RASP manual issued by NAVSEADET RASO Adds Navy regulations to applicable NRC regulations in one document Contains x-ray requirements not found in 10 CFR Requires annual drills of emergency response plan Contains Navy reporting procedures Contains requirements for training of RSO Defines scope of RASP

NAVMED P-5055 Radiation Health Protection Manual Issued by U.S. Navy – Bureau of Medicine & Surgery Contains requirements for Occupational exposure to ionizing radiation to Naval personnel Dosimetry Medical examinations and records

Radiation Safety Instruction for Naval Postgraduate School NAVPGSCOL INST 6470.1G Radiation Safety Instruction for Naval Postgraduate School Command endorsed instruction on how NPS controls radiation NPS personnel must be familiar with instruction Available on the intranet http://intranet.nps.edu/Code00/Instructions/IndexNew_page04.html

NAVPGSCOL INST 6470.1G Defines responsibilities 18 enclosures, including: Control of personnel exposure Personnel monitoring Survey Instructions Control of Machine Sources SEOP Requirements Records Training