Do you really want to be the RSO?

You must ask yourself that question before you accept the responsibilities of the position. The spotlight will be on you. You cannot cut corners or attempt regulatory “end-arounds”. The regulatory agency is delegating the responsibility of “protecting public and property” to your shoulders. Your actions will be viewed and scrutinized by everyone around you. The “Notice to Employees” poster tells your workers about their rights and how to notify the regulatory agency if they see you or your radiation safety program in violation of the regulations. If you let them see you skimp on a rule or regulation today you may regret it in the future. Today’s happy employee may be tomorrow’s disgruntled employee, one who is looking to get back at you or the company at a later date. Don’t give them a reason to “exercise” their employee rights.

You must also not let senior management compromise your duties and authority. The following article gives a reality check to those considering the RSO position.

So You’re the New RSO! 

Dr. Carl J. Paperillo

What is a Radiation Safety Officer (RSO) and what are his/her duties?

The RSO is the person responsible for radiological safety in conjunction with the use, handling, and storage of radioactive materials in a program licensed by the Nuclear Regulatory Commission (NRC) or Agreement State. It is the duty of the RSO to ensure that all licensed activities are carried out in compliance with the requirements of the license and the applicable rules and regulations.

The following excerpts of an article written by Dr. Carl J. Paperillo, former Deputy Regional Administrator of NRC Region III, offers insight into what the NRC or Agreement State expects of an RSO. (From the March 1993 issue of Nuclear Material Safety and Safeguards (NMSS) Licensee Newsletter)

What does it mean, if you agree to be named as the new Radiation Safety Officer (RSO) on an NRC or Agreement State license?

It means you have the knowledge and skill, the resources and time, the will, and the clout in your organization to ensure that activities involving radiation and radioactive materials are conducted safely, and all license requirements, both in the regulations and those specific to your license, are being met. Although you can delegate tasks, you have the ultimate responsibility.

How much knowledge do you have to have?

It depends. You don’t need an advanced degree in nuclear physics if your responsibility is limited to sealed sources contained in devices like portable nuclear testing gauges. On the other hand, an RSO for a major broad-scope university, medical center, or manufacturer will probably need a fairly good scientific background, including substantial knowledge of radiation characteristics and methods of detection.

There is a skill set frequently overlooked in the selection of an RSO: Can you manage? If there is a large program under your license (i.e., a lot of users, diverse places of use, and/or branch offices) can you establish a management system that ensures you know everything that has to be done is being done?

For example, if your license involves a lot of gauges at diverse locations used by numerous employees, the knowledge of dose calculations, shielding or biological effects is not much help if you don’t know if your users are properly trained, wearing the proper dosimetry, and transporting and storing gauges correctly.

Most of the civil penalty enforcement actions with which I have been involved result from a failure of a licensee to manage the radiation safety program correctly. The major management failure is the failure to know whether activities are being conducted in accordance with NRC and Agreement State requirements. I fail to understand why a business that knows how to audit its financial activities does not conduct an annual audit of its Radiation Safety Program and safety and operating procedures.

Do you have the time and resources to be an RSO?

This can be a problem, particularly if the RSO function is an ancillary assignment. It can generally work well for a small program in which the RSO is a user and has day-to-day contact with the other users. One geotechnical office with a few gauge operators is such an example. Others might include a small paving operations company with one office and several gauge operators, or a small testing services company. Problems usually arise when a small business grows, particularly when it adds branch offices, and the part-time RSO can no longer keep track of activities at other locations.

Do you want to be an RSO?

An RSO can be unpopular. You have to be a cop. Sometimes you have to say no. Don’t let your name get on the license just because you have a Ph.D. and a desire to teach or do research but not to be a snoop! I know the feeling. I originally wanted to teach, too. I suppose, in a way, that is what I am doing now, by writing this article. As an RSO, you are a regulator just like me. A regulator has to have the will to regulate.

Do you have the clout in your organization?

Or, are you so low in your organization that no one listens to you? Does the senior gauge operator or job foreman write your performance appraisal or control your salary bonus? If so, you may have a problem. You must have the authority to stop an unsafe activity or an activity in violation of NRC or Agreement State requirements. Or you must at least have ready access to someone who can stop it. Organizations that prevent an RSO from doing his or her job are in violation of NRC or Agreement State regulations.

RSO Requirements

Recordkeeping File

Designate a file drawer for maintaining all of the documents required for the license. This file drawer should hold all of the original documents and be kept under lock and key. A further discussion of these documents can be found in the “Licensing & Regulations” section of this manual.

RSO Training and Your License

The RSO should have the proper training and experience to carry out the position. A minimum training requirement is the completion of the Gauge Safety Certification Class. This class should qualify the individual to perform the duties of the RSO. Your APNGA membership includes the Gauge Safety Certification Class as well as a RSO class. The RSO class will include more in-depth analyses of RSO responsibilities.

Training

The RSO must have practical experience in operating gauges and must introduce and instruct workers to the safety and operational aspects of the gauge.

All gauge workers must pass the Gauge Safety Certification Class.  APNGA recommends that all gauge workers also complete the RSO class. It is included in every member’s annual dues and completion of this class will aid the RSO and further the understanding of safety, security and compliance requirements for every person in the organization. Remember, your gauge safety program is only as good as your least trained person.

The RSO will oversee the training and monitor the test that is required of company employees and will ensure that he/she has received training. Company employees should be trained in all safety and emergency procedures and possess a copy of the company radiation safety program.

Training for the employees should include:

• • Gauge safety training
  • HAZMAT training
  • Annual refreshers

Topics of training include:

• • Principles and practices of radiation protection
  • Radiation measurement and monitoring
  • Biolocial effects of radiation

It is important for the RSO or a senior gauge operator to spend time with new workers in the basics of gauge safety and operation.

The certificate issued for APNGA Gauge Safety Training will include a confirmation and signature line for the RSO to acknowledge that the employee has received hands on training with the gauge in use by the company. The APNGA training course covers the safe use of gauges. Virtually all gauges use the same mechanics of measurement, specifically, an adjustable source rod that can be lowered for measuring density, and an internal, stationary source for measuring moisture. The only differing aspects of various models are the keypad and software. The RSO must familiarize the worker with the gauge, as well as the specific gauge methodology and applications in use by the company.

The RSO will authorize and ensure that only properly trained individuals will operate the gauges and prepare and transport gauges. All training certificates are to be kept on file.

Personnel Monitoring/Dose Rates

The RSO will ensure that all gauge workers wear a dosimeter for monitoring occupational radiation exposure. Typical annual exposure is less than 100mRem. Train and practice the concepts of ALARA (As Low As Reasonably Achievable) to ensure minimal exposures. When not in use all employee dosimeters should be kept with the control badge, at a distance free from gauge exposure. Store badges in a temperate environment.

The annual dose limit for workers is 5,000mRem. Declared (in writing) pregnant workers are limited to 500mRem for the term of the pregnancy. Workers under the age of 18 are limited to 500mRem/yr (some states limit their exposure to 50mRem).

Storage areas should have limited access to the general public and ensure that public exposure is less than 100mRem/yr or the exposure at 3 feet is less than 0.2mRem/hr. A general rule of 15 feet from a full-time work station should ensure compliance but areas with multiple gauges will need to be evaluated.

Reciprocity

Gauges can only be used within the state under the licensee’s regulatory agency. The gauge will be kept at the licensed storage area or approved work site temporary storage.  Use in another state will require reciprocity (permission from the NRC or Agreement State). Look under “View My State” for contact information.

Storage/Security

When not in use gauges will be stored behind double-locked security that prevents unauthorized access or removal. The RSO must authorize and approve any operators before they can remove gauges from storage. Any gauge and case removed from storage must be inspected and logged out with the operator’s name, date, gauge serial number and place of use.

Gauges can never be left unattended at the work site. Gauges left in vehicles should be double-locked and concealed with appropriate bill of lading and emergency response sheets left on the driver’s seat.

Gauges cannot be left unsupervised with 3rd party gauge service personnel. If you have an individual from a gauge service company visit your facility to calibrate, service or repair your gauges you must have one of your authorized gauge operators accompany the individual at all times. They cannot be left alone with your gauges nor can they be left alone in the secured storage areas of the gauges. The service individual is not employed by your company and you have not transferred the gauge to their ownership.

You cannot let the individual remove a gauge to take to their vehicle without supervision. If a gauge is removed from storage you must adhere to all requirements of the radiation safety program.

If you are in possession of radionuclide quantities of concern (Risk Significant Radioactive Material aka RSRM) you are not allowed to let 3rd party individuals access the gauges unless they have regulatory background clearance. Look in the Appendices/Attachments for the NRC Notice.

Leak Testing

Gauges should be leak tested for contamination every 6 months and documentation placed on file.

Inventory

Hands on gauge inventory will be taken every 6 months and documentation kept on file.

Gauge maintenance

Typically, licenses only allow for general maintenance on gauges, including removal of dirt, clays and debris from the area directly inside the base plate and from the source rod. You must have a special license to remove a source rod. Removal can only be performed by a licensed service facility.

Gauge transport

Gauges transported in a vehicle must be by a trained and authorized company employee. Gauges must be properly double-locked, blocked and braced from movement, and concealed. The driver should have immediate access to a bill of lading and emergency response sheet.

Gauges turned over to a common carrier will include the properly completed bill of lading. Always check the identification of common carrier personnel.

Gauges prepared and turned over to an air cargo company will have the required dangerous goods documentation.

Emergency procedures

Gauge workers will be trained in aspects of emergency precautions and emergency response. In the event of damage at the work site the gauge operator will respond in the following order:

a.  Attend to anyone that may have been injured.

b.  Determine the location of radioactive sources (typically the source rod)

c.  Take control and deny access to the area (15 feet in all directions)

d.  If a vehicle is involved keep it on site until it is determined that it is not contaminated

e.  Gather details about accident and damage – if possible, perform radiation survey

f.   Stay at the site but contact RSO with details

g.  If necessary, the RSO will contact the regulatory agency, manufacturer  and police

h. The RSO will give guidance on whether to move the gauge or;

i.  The RSO should travel to the site with a radiation survey meter

In the event of damage in an auto accident:

a.  Attend to injuries

b.  Deny access

c.  Gather details

d.  Contact the RSO and/or emergency response number

e.   Wait for instructions or arrival of emergency response

In the event of theft:

a.  Contact the RSO

b.  Call the regulatory agency

c.   Immediately contact the police

d.  Consider issuing a reward through the media

Investigations and corrections

Investigate all unusual occurrences involving the gauge (accident, damage, theft, oversights), determine the cause, identify corrective actions and implement such actions.

Enforcement actions and employee misconduct

Enforce all requirements of the license and stop any activities that are considered unsafe or illegal. Misconduct by any employee should be documented and corrective actions taken.

Self-Reporting

An important requirement of your license is for the RSO to self-report any violations of the gauge safety program or conditions of the license. No one is perfect and your regulatory agency understands this. Self corrections are an important learning tool.

Self corrections will show the regulatory agency that you are conscientious and committed towards the gauge safety program. Self corrections rarely subject you to a fine, whereas “hidden” violations are far more likely to result in a fine.

Self corrections should include a report of the violation and corrective steps to ensure that the violation will not be repeated.

The File Drawer and Original Copies

The RSO should designate a file drawer for maintaining all of the documents required for the license. This file drawer should hold all of the original documents and be kept under lock and key. If you have to remove an original, make a photocopy and immediately return the original to the file.

There is nothing more helpful during an inspection than a neat, tidy, complete and accurate file of all of your records and it will go a long way towards a successful inspection.

RSO Recordkeeping Checklist

These documents and procedures are discussed in the Training Manual.

• • Specific Gauge License
  • The Regulations
  • Employee Training Records
    • Gauge Safety Class Certification
    • Gauge Field Training
    • U.S. DOT Hazardous Materials (HAZMAT) Training
    • RSO Training
    • Employee Annual Refresher
  • Notice to Employees Poster
  • Personnel Gauge Radiation Exposure Records – Dosimetry Records
  • Inventory and Gauge Receipt Records
  • Gauge Receipts
  • Inventory
  • Leak Test Reports
  • Daily Use Logs
  • Special Form Certificate required by IAEA – Certificate of Competent Authority
  • Sealed Source and Device (SSD) Sheets
  • Original License Application Package
  • Extra Labels
  • Type “A” Package Test Results
  • Radiation Safety Program
  • Annual Audits
  • Transport Documents
  • Field Gauge Operating Procedures
  • Emergency Procedure Documents/Procedures/Plans
  • Gauge Documents Package for File and Gauge Case

In Summary

A.      The RSO will emphasize the ALARA philosophy to workers, instruct personnel on current procedures and provide guidance on relevant changes to reduce exposures.

B.     The RSO will review dosimetry reports for all monitored personnel to determine if unnecessary exposures are being received.  The RSO will investigate within 30 days the cause of any dose considered to be excessive.  If warranted, the RSO will take corrective actions to prevent recurrence.  A report of each investigation and the actions taken, if any, will be recorded and maintained for inspection purposes.

C.     At least annually, the RSO will conduct a formal review of the radiation protection program’s content and implementation. The review will include an evaluation of equipment, procedures, dosimetry records, inspection findings, and incidents.  The RSO will assess trends in occupational exposures as an index of the program’s success and determine if any modifications to the program are needed.  A summary of the results of each annual review, including a description of actions proposed and taken (if any) will be documented by the RSO, discussed with management, and signed and dated by both.  A report on each audit will be maintained on file for 3 years from the date of the review.

D.     The RSO will provide written notifications of annual radiation exposures to all monitored personnel and will be available to respond to any questions regarding the exposure reports.