Radiation program help

[jezibel]

I have a general question related to this topic. I am a Sr. RCT with over 8 years of DOE facility experience.

I am currently auditing a program that used to be DOE but is now privatized. The "RCT's" they have working have minimal rad worker knowledge and aren't core qualified. This isn't a nuclear facility, so the NPP exams wouldn't apply. It's entirely radiomedical nuclides.

My question is, Can they even be called RCT's without having had to take or pass a core exam?  We are governed mainly under NRC 10 CFR 19, 20 Broadscope Type A License.  They have almost no knowledge of how instrumentation works, how to do basic things such as Direct Surveys or Large Area Wipe surveys, or even basic techniques for leak testing, and removing unsealed sources from inactive status.

It's so hard to assess a program when so much of it is, in my opinion, complete trash. They just hired a new RSO/PhD who has next to zero health physics or radiation protection background.  The other day he was rambling on about dose swipes.... this is the kind of thing I am having to deal with.

Thanks for reading. Opinions? Ideas?

[GLW]

.....It's so hard to assess a program when so much of it is, in my opinion, complete trash. They just hired a new RSO/PhD who has next to zero health physics or radiation protection background.  The other day he was rambling on about dose swipes.... this is the kind of thing I am having to deal with.........

Start with the basics,...

Fiducial documents first,...

License(s), then plans, then the NRC Generic Communications Library, and so forth and so on,...

From your description this one will not be as simple as Tech A violated Procedure X, Step 2.4.1, followed by root cause and corrective action recommendations,...

Nope, this will be "You're (the licensee) is committed or required to do XYZ, here's why you're committed or required, here's where you do not meet commitment or requirement", and then recommend the corrective actions,....

At least that's where you're at as you describe it,...

[Marlin]

Your post justified it's own thread so I split it from the original thread. As to what an RCT is depends on the facility, if it is no longer a DOE facility I suspect DOE core no longer applies. With minimal hazard minimal quals are needed, the simple answer is to comply with your license. Stay tuned for more info from someone with more specific experience in this area.

[jezibel]

Start with the basics,...

Fiducial documents first,...

License(s), then plans, then the NRC Generic Communications Library, and so forth and so on,...

From your description this one will not be as simple as Tech A violated Procedure X, Step 2.4.1, followed by root cause and corrective action recommendations,...

Nope, this will be "You're (the licensee) is committed or required to do XYZ, here's why you're committed or required, here's where you do not meet commitment or requirement", and then recommend the corrective actions,....

At least that's where you're at as you describe it,...

Yes, Exactly. Thank you. I have been basing most of my assessments from experience (practical techniques, procedures, etc) Now, I have read numerous 800 page NUREG pdf's for NRC guidance, since they don't specify how to run an RP program under 10 CFR 20 as clearly as they do in 10CFR835. 20 seems mainly concerned with exposure.

Cheers!

[jezibel]

Your post justified it's own thread so I split it from the original thread. As to what an RCT is depends on the facility, if it is no longer a DOE facility I suspect DOE core no longer applies. With minimal hazard minimal quals are needed, the simple answer is to comply with your license. Stay tuned for more info from someone with more specific experience in this area.

Thank you! I wondered where it went.

They are all about minimal quals. It's all about money, bring it in, but don't spend it on excessive training.
The problem is that at any time there may need to be a study done aerosolizing transuranics, and that scares the shit out of me (not for my safety, I know what I'm doing. But for the safety of the workers.) Most use N-95 respiratory protection, and if they use full face, they don't dress out appropriately and are terrible at doffing/frisking. 

[GLW]

Yes, Exactly. Thank you. I have been basing most of my assessments from experience (practical techniques, procedures, etc) Now, I have read numerous 800 page NUREG pdf's for NRC guidance, since they don't specify how to run an RP program under 10 CFR 20 as clearly as they do in 10CFR835. 20 seems mainly concerned with exposure.

Cheers!

It's very clear, these things are owned by the RSO:

http://www.nrc.gov/reading-rm/doc-collections/cfr/part020/part020-1101.html

http://www.nrc.gov/reading-rm/doc-collections/cfr/part020/part020-2102.html

http://www.nrc.gov/reading-rm/doc-collections/cfr/part035/part035-0024.html

The RSO is qualified to provide a quality program because of this:

http://www.nrc.gov/reading-rm/doc-collections/cfr/part035/part035-0050.html

With some guidance in the situation as you describe it from this:

http://www.aapm.org/pubs/reports/RPT_160.PDF

[jezibel]

With some guidance in the situation as you describe it from this:

http://www.aapm.org/pubs/reports/RPT_160.PDF

Thank you. I was referencing the NUREGs for the Rad Techs who were regularly releasing materials with > 20 dpm removable for transuranics, but freaking out about 300 dpm removable for tritium. This was because of bad oversight from the last RSO who completely neglected the whole program for years. I just think if their job title is RCT, then they should be able to pass the tests to qualify their proficiency.

10 CFR 51.22(c)(14)(v) is how the NRC sees a license amendment for a change in RSO,( who is by leaps and bounds better just because of involvement and willing to learn,) but doesn't mean they know anything about radiation protection.

[HPEDVA]

 Usually, any "licensed" nuclear facility will have to go through the agency's process to legally terminate it's license or tranfer it properly to the control of another agency. I was a part of the latter, but this was quite involved with site wide radiological characterization surveys and supporting documents before control was given over to the NRC (10CFR20) from DOE (10CFR835). Your answer may be found in finding out which agency has Issued the nuclear license to allow it to operate. (10CFR 35?)

[Touche]

So late to the party am I...

Jezibel, you state that you are auditting a Type A Broadscope and imply a transfer from DOE to NRC has occurred. Is this true? Does the NRC or an Agreement State have jurisdiction? I will assume the NRC has jurisdiction and the licensee is not exempt under 10 CFR 30.12.

Type A Broadscopes are typically byproduct material licenses issued under the authority of 10 CFR 33. (You mention transuranics; it is possible to have other licensed activities on a Type A per 10 CFR 30.32 as long as the program complies with the applicable regulations) However, parts 19,20,21, 30, 32 - 37, & 39 may apply. I am unclear about your reference to 10 CFR 51; it is a list of categorical exclusions of certain activities for environmental impact...a change of RSO for a Type A Broadscope is explained in the NUREGs.

NOTE: Some balk at using the NUREGs but there are instructions to see detailed instructions at the top of an application, NRC Form 313, "SEE THE APPROPRIATE LICENSE APPLICATION GUIDE FOR DETAILED INSTRUCTIONS FOR COMPLETING APPLICATION."

NUREG 1556 Vol. 11 "provides guidance to an applicant in preparing a broad scope license application and describes the criteria used by NRC staff when evaluating the application." Additionally, this NUREG references other NUREGs depending upon the scope of the license (e.g., Vol 6 for Irradiators, Vol 7 for R&D, Vol. 17 for Special Nuclear Material, etc.)

While you mention the RSO, you failed to mention anything about the Radiation Safety Committee which is required for all Type A Broadscopes. Do they have one?

They, along with the executive officer and RSO, should have ensured "that the RSO has adequate resources to effectively manage the program." (See Section 8.7.4 of Vol. 11 for Radiation Safety Office Staff)

I empathize with you; auditting a seemingly mediocre or substandard program is stressful and eye-opening to the world outside Reactors and DOE 

Do you mind sharing the NRC Adams document numbers for the license and application?

[SloGlo]

I have a general question related to this topic... 
I am currently auditing a program that used to be DOE but is now privatized. The "RCT's" they have working have minimal rad worker knowledge and aren't core qualified.
My question is, Can they even be called RCT's without having had to take or pass a core exam?  We are governed mainly under NRC 10 CFR 19, 20 Broadscope Type A License.

welcome to the whirled of private concerns.  in this venue, many of the corporate players look at rct personnel as wrench monkeys, i.e. a tek is a tec is a tech.  if they due knot have to train to a level, they will not.  most of the private sites i have bin two have "decent" rct tex, in that they can do the job at hand.  if, however, things are off the page it is almost a certainty they will.... .. be challenged in they're handling of the situation.  your comment re: respiratory choice and competence with doffing/frisking brought many wallet fattening memories to mind, but the >20dpm transuranic releasing vs 300 dpm four h3 made me positively glow with fondness.  i, two, have had to deal with rso level people of the ilk you describe.  most of the time, they due not care that they are their simply in order to supply a fall guy for the inevitable... the money is good, the resume is bean padded, life is good . 

my advices?  have fun, go with what is offered here by glw,hpedva, touche, et al and make sure your plane ticket home is current.

[HAIRDUDE]

This sounds frighteningly familiar .... Are you by chance quite near St. Louis, Missouri? ... at a place that rhyms with Povidian?