[ RadSafe ] RSO questions

ROY HERREN royherren2005 at yahoo.com
Fri Nov 13 18:12:08 CST 2009

See http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1556/v11/#_1_30

8.7.3 Radiation Safety Officer
Regulations: 10 CFR 30.33(a)(3); 10 CFR 33.13(c)(2); 10 CFR 33.14(b)(1); 10 CFR 34.42; 10 CFR 35.21; and 10 CFR 36.13(d).
Criteria: Type A and Type B broad scope licensees must have a Radiation Safety Officer (RSO) who is qualified by training and experience in radiation protection, and who is available for advice and assistance on radiological safety matters. The RSO's training and experience must include the types and quantities of licensed material to be authorized on the license. While regulation does not require Type C broad scope licensees to have an RSO, 10 CFR 33.15 requires that the licensee establish administrative controls and provisions relating to procurement of byproduct material, procedures, recordkeeping, material control and accounting, and management review to assure safe operations. Type C broad scope licensee management should appoint someone responsible for the day-to-day operation of the radiation safety program, such as an RSO.
Discussion: Each Type A and Type B program in which byproduct materials are used must appoint an RSO who is responsible for radiation safety and compliance with the regulations for the use of byproduct material. Each Type C broad scope program should appoint an individual who is responsible for the day-to-day operation of the radiation safety program. In a Type A broad scope license the RSO is a member of the RSC and works closely with the RSC and executive management in implementing the radiation safety program. The RSO must ensure that radiation safety activities are being performed safely according to approved policies and procedures, and that all regulatory requirements are met. The RSO should have full access to all activities involving the use of byproduct material and the authority to terminate any activity in which health and safety appear to be compromised without consulting with executive management or the RSC, if required. The applicant should
 submit a "Radiation Safety Officer Delegation of Authority" signed by executive management. Appendix J contains a model "Delegation of Authority" that is acceptable to NRC.
In a Type A broad scope licensed program, the RSO typically performs a preliminary review of proposed new uses and users, prior to formally discussing the proposal with the RSC. The RSC grants the formal approval of new users and uses in a Type A broad scope license. The task of reviewing and approving proposed uses and users in a Type B broad scope licensed program is the responsibility of the RSO. In a Type C broad scope program, individuals are qualified as users if they meet the training and experience criteria described in 10 CFR 33.15(b). While no licensee Committee or individual is required by regulation to make the determination that an individual is qualified to use the material possessed under the Type C broad scope license, or that a particular use of byproduct material is safe, licensee management is ultimately responsible for assuring safe operations.
The RSO performs audits of all areas of use and individuals who are authorized to use byproduct material to ensure work is done in accordance with the license, regulations, and user permit conditions. Specific duties and responsibilities of the RSO include:
	* Monitoring and surveys of all areas in which radioactive material is used 
	* Oversight of ordering, receipt, surveys, and delivery of byproduct material 
	* Packaging, labeling, surveys, etc., of all shipments of byproduct material leaving the institution 
	* Personnel monitoring program, including determining the need for and evaluating bioassays, monitoring personnel exposure records, and developing corrective actions for those exposures approaching maximum permissible limits 
	* Training of all personnel 
	* Waste disposal program 
	* Inventory and leak tests of sealed sources 
	* Decontamination 
	* Investigating any incidents and responding to any emergencies 
	* Maintaining all required records. 
The responsibilities of the RSO may not be transferred to other individuals. Many tasks and duties associated with managing the program may be assigned or delegated to other qualified individuals; however, the responsibility for these tasks and duties is with the RSO. NRC does recognize that a qualified individual will have to fill in for the RSO when the RSO will be away for short periods of time for professional conferences, vacation, or illness. However, this should not occur for extended or indefinite periods of time. Consideration should also be given to how this individual would be contacted in the event of an emergency.
When selecting an RSO, the applicant should keep in mind the duties and responsibilities of the position, select an individual who is qualified to serve as the RSO. The RSO will need a basic technical knowledge sufficient to understand, in general, the majority of the work being done with byproduct materials under his or her responsibility. NRC recognizes that an RSO cannot be an expert in all areas that might be involved in a broad scope program. The RSO should be qualified by training and experience to perform the duties required for the position. Executive management should ensure that enough time is allocated to the individual selected as the RSO to carry out the responsibilities of the position.
The applicant should review the Radiation Safety Officer guidance provided in the base NUREG corresponding to the particular type of licensed program. For example, NUREG-1556, Volume 7, "Program Specific Guidance About Academic, Research and Development, and Other Licenses of Limited Scope," contains guidance that is appropriate for broad scope licensees who are involved in research and development.
The applicant should also be aware of specific regulatory requirements for the RSO which may apply to their licensed program. For example, 10 CFR Part 35 contains specific requirements for an RSO in a medical program. However, an individual who qualifies as a medical RSO is not necessarily qualified to be RSO in a broad scope program.
Chapters 3 and 4 of NUREG-1516, "Management of Radioactive Material Safety Programs at Medical Facilities," describes the role of the RSO and selection of the RSO at medical facilities but it also contains information pertinent to all broad scope programs.
Response from Applicant:
For Type A and Type B Applicants:
	* Submit the name of the proposed RSO 
	* Describe the training and experience for the proposed RSO that demonstrates the individual is qualified to perform the duties required under the license 
	* Submit a statement delineating the RSO's duties and responsibilities 
	* Submit a Radiation Safety Officer Delegation of Authority signed by the licensee's executive management. 
For Type B Applicants, submit the criteria used by the RSO to approve of new users and uses of byproduct material.
For Type C Applicants, submit the name of the person who will serve as the individual responsible for the day-to-day operation of the radiation safety program, e.g., the RSO, who will be contacted if there are further questions about this application, and who is duly authorized to act for the applicant or licensee, as required by 10 CFR 30.32(c).
Applicants should provide specific information about the proposed RSO's training and experience which is relative to the licensed material requested in the application. Applicants should not submit extraneous information such as unrelated lists of publications, research grants, committee and society memberships, etc. This only serves to slow down the review process. 
Note: It is important to notify NRC, as soon as possible, typically within 30 days, of changes in the designation of the RSO. The name and qualifications of the replacement RSO must be submitted to NRC as part of an amendment request. Applicants should review the regulations for specific program areas, such as medical uses, that have specific requirements regarding changes in the RSO.

From: Khalid A. <kaleissa at gmail.com>
To: radsafe at radlab.nl
Sent: Thu, November 12, 2009 10:42:24 PM
Subject: [ RadSafe ] RSO questions

I am looking for a database of RSO examination questions. Anybody has any
information please respond to me directly.


Khalid A.
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