Attachment A - The Army Radiation Permit ARP.pdf

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Attached to
New Fort Bliss Paving IDIQ Contract
Solicitation number
W911SG27BA002
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This document outlines the requirements for an Army Radiation Permit (ARP) application in accordance with DA PAM 385-24, The Army Radiation Safety Program. The ARP application must include ten primary components that establish operational authority, safety protocols, and personnel qualifications for contractors using radioactive sources, equipment, and devices at Army installations.

Applicants must provide a formal letter of application with supporting documentation, copies of relevant licensing authorization (NRC license, DOE radiological permit, or Agreement State License), and proof of NRC Form 241 compliance if applicable, which limits work to 180 days annually unless full NRC licensing is obtained. The application requires specification of ARP start and stop dates with a Proposed Work Statement justifying the need, relevant contract portions identifying use locations and duration, and a current company Radiation Safety Program (RSP) document. Personnel qualifications must be demonstrated through a current list of trained and qualified employees with training records, the contractor Radiation Safety Officer (RSO) name and emergency contact information. Storage and security protocols must be detailed, including overnight storage locations and methods, security during breaks and lunch hours, and proposed marking if radiation levels exceed two mR/hr at the storage container surface. The application must also include operating instructions for equipment containing radioactive sources, an exposure control plan utilizing NVLAP-accredited dosimetry for dose of record, an Emergency Response Plan addressing lost, damaged, or contaminated sources and overexposure incidents, and current leak test documentation on all radiation sources, equipment, and devices.

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Text version

In accordance with DA PAM 385-24, The Army Radiation Safety Program, 30, Nov 15:

An Army Radiation Permit (ARP) application should consist of the following:

(1) A letter applying for an ARP with supporting documentation.

(2) A copy of the NRC license that permits use or storage of radioactive sources, equipment, and devices at Army bases, garrisons, and installations. A copy of a DOE radiological permit with documentation showing that it is valid for the location and operation. A copy of an Agreement State License and if provided, then documentation to show the license is valid on Federal Property. This is usually NRC Form 241, Report of Proposed Activities in Non-Agreement States, Areas of Exclusive Federal Jurisdiction with the NRC in accordance with 10 CFR 150. If work is covered by NRC Form 241, then the work is limited to 180 days in a calendar year, otherwise an NRC license is required. If exempt from NRC licensing or under general licensing, proof of exemption or general licensing must be provided. For NARM, the contractor must provide appropriate NRC or State authorization that allows the contractor to use the radiation emitting sources, equipment, and devices. The licensing must show operational use conditions and restrictions with expiration date.

(3) The documentation must specify the start and stop dates for the ARP and describe why the applicant needs the ARP (Proposed Work Statement).

(4) Provide the portion of their contract that identifies the location(s) that the source will be used, the length of time required for the source, and the type of use for the source.

(5) A copy of the company RSP.

(6) A current list of trained and qualified employees using the radiation emitting sources or radiation generating equipment and their training records.

(7) The name of the contractor RSO and emergency contact telephone number.

(a) Operating instruction(s) and technical order(s) for the equipment that contains the radioactive source, provide an indication of whether the sources, equipment, and devices are to be stored on-site overnight and how it is to be stored and secured.

(b) Designated storage location and how it will be secured if the radioactive source remains overnight.

(c) Proposed marking of the storage location if it exceeds two mR/hr as measured at the surface of the storage container.

d) How the sources, equipment, and devices will be stored and secured during lunch hour and breaks.

(8) How exposure to contractors and Government personnel will be controlled and that NVLAP accredited dosimetry is used for dose of record.

(9) Emergency Response Plan in case of an emergency for a lost or damaged source, equipment, and device and over exposure incident and injury.

(10) Current leak tests on radiation sources, equipment, and devices.

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