DRAFT SOW for GSFC_JSC_LaRC_2024.04.12.pdf

Introduction to Radiation Protection Program (GSFC ONLY)

The objective of the NASA Radiation Protection Program is to limit exposure of personnel to ionizing and non-ionizing radiation to As Low As Reasonably Achievable (ALARA). However, under no circumstances shall exposure exceed appropriate Federal standards. National standards shall be used as guidelines to determine ALARA for non-ionizing radiation (e.g. American National Standards Institute (ANSI), American Conference of Governmental Industrial Hygienists (ACGIH), etc.).

The U.S. Nuclear Regulatory Commission (NRC) has issued radioactive material licenses, which authorize handling of radioactive sources ranging in radiation activity. The types of NRC licenses issued include a Broad Scope byproduct material license, a Gamma Source Irradiator license, and materials under other general NRC licenses or Agreement States under a Letter of Reciprocity from the NRC. The major use of these radioactive materials is for radiation effects and calibration tests. Radioactive waste products produced on Centers-are small amounts. Many types of ionizing radiation and non-ionizing radiation sources and devices are present at each Center. These include radioactive sources and X-Ray devices, radars, Ultraviolet (UV) sources, High Intensity Lights (HIL) and Lasers. The Contractor shall maintain complete records and a comprehensive inventory of each source/device (ionizing and non-ionizing) that falls under the Radiation Protection Program.

Radiation Protection (RP)

RP01 - The Contractor shall work with the Radiation Safety Officer (RSO), a Civil Servant, to effectively manage the Radiation Protection Program. They will help the RSO provide administrative controls and provisions relating to organization and management, procedures, record keeping, material control, and provide accounting and management review to ensure safe operations.

Radiation Protection Support (RPS)

RPS01 - The Contractor shall work with the RSO to evaluate the status of the Radiation Protection Program per NRC requirements on an annual basis.

RPS02 - The Contractor shall review all requests for Ionizing or Non-Ionizing Radiation Source or Device Use and User of such for compliance with NRC and/or NASA and Center regulations and coordinate the process of issuing a Use Authorization or Permit for the Use of sources or devices and the issuing of User Approval Documents.

RPS03 - The Contractor shall save the approved documents to an electronic file location designated by the Center within 5 business days of receiving the approved document. Contractor shall work with the RSO to prepare these documents to be sent to the Ionizing Radiation Safety Committee (IRSC) or Non-Ionizing Radiation Safety Committee (NIRSC) for approval.

RPSRPS04 - The Contractor shall maintain records in support of the Radiation Protection Program as maintained by Federal, State and NASA requirements.

RPS05 - The Contractor shall provide services to initiate and maintain safety activities/programs that control the exposure to both ionizing radiation from radioactive elements in equipment (including, but not limited to an x-ray machine or particle accelerator) and non-ionizing radiation (including, but not limited to, a laser, microwave or other equipment found in a wide range of occupational settings). Non-ionizing radiation includes the spectrum of ultraviolet (UV), visible light, infrared (IR), microwave (MW), radio frequency (RF), and extremely low frequency (ELF).

RPS06 - The Contractor shall serve as a liaison between the Center and other agencies when Center sponsored radiation activities extend beyond the Center, e.g., if the Center personnel has scheduled an aerial laser test, the Contractor shall coordinate with the Federal Aviation Administration (FAA) and any other agency (including local, state and federal) to ensure the safety of commercial and civil aircraft during the test.

RPS07 - The Contractor shall serve as the Center point of contact during emergency situations involving radiation sources, including, but not limited to, emergency planning, training, and participation in drills/exercises.

RPS08 - The Contractor shall review and recommend to the Government for approval all NASA forms regarding Radiation Hazard, submitted for the purchase of equipment/supplies that support radiation activities.

RPS10 - The Contractor shall attend Center's Non-Ionizing and Ionizing Radiation Safety Committee meetings (Note: Regularly scheduled meetings are held quarterly, however; meetings may be called whenever required).

RPS10 - The Contractor shall conduct Initial and Annual Audits of each Use Authorization or Permit granted for the use of Ionizing and Non-Ionizing Radiation Sources/Devices. Initial Audits shall be conducted within 5 business days of the Authorization/Permit being issued and all Annual Audits shall be conducted by November 30th of each calendar year.

Radiation Dosimetry (RD)

RD01 - Personnel Monitoring – The Contractor shall distribute and collect radiation dosimeters issued to personnel. The badges shall be turned in on a timely basis, (minimum quarterly) and accurate records of individual exposure levels shall be maintained.

RD02 - Exposure monitoring records will be periodically reviewed and recommendations for necessary actions developed shall be submitted to the RSO.

RD03 - Area monitoring – Radiation dosimeters shall be placed at certain locations for the purpose of monitoring the area. The location of these will be determined by the needs of the program. Accurate records shall be maintained of the radiation environment.

RD04 - Occupational Exposure – The Contractor shall ensure regulatory notifications are made for anyone exceed limits established by the NRC and that personnel badged with a dosimeter receive annual notification as stated in 10 CFR Part 19.

RD05 – The Contractor shall receive dosimeters from the organization used by the Center that supplies them and will process them so that they are ready for this issue period defined by the Center’s NRC license requirements or Center policy. Once the issue period is completed, the Contractor will collect all dosimeters and package them for shipment back to the organization that will process them.

Monitoring of Radioactive Sources (MRS)

MRS01 – The Contractor shall conduct testing of sealed radiation sources for leakage or contamination. Sealed sources are required to be leak tested in accordance with the Center’s NRC licenses.

MRS02 - Frequency of Leak Testing – Each sealed source required to be leak tested as a condition of the Center's NRC licenses shall be leak tested every six (6) months, or more frequently as required by license or regulation. Leak tests shall be performed on sources prior to shipment and again upon receipt. Sources to be thermo-vacuum (TV) tested shall be leak tested prior to and following TV tests. Other sources shall be leak tested in accordance-with the determination of the RSO and as a minimum to comply with regulatory requirements. In addition, sources shall be tested whenever they are suspected of leakage. The Contractor shall provide the RSO a written report of NRC reportable leakages within 1 day of identification of leaking source, or per NRC license requirements, whichever is less.

MRS03 - Sensitivity of Leak Tests – Tests performed by the Contractor shall detect limits set by the RSO, at a minimum in accordance with the Center’s NRC Licenses.

MRS04 - Thermal Vacuum Testing of Radioactive Sources - Any radioactive sources to be used in a space environment shall be certified for environmental extremes. After thermal vacuum testing, the Contractor shall be responsible for certifying that the sealed source is not leaking. The Contractor shall maintain records of this certification.

MRS05 - Radon – When it has been determined that Radon Testing should be conducted the Contractor shall support the RSO in determining the number of samples needed to monitor an area.

Based on that determination the Contractor shall setup and place the samples then collect them after the determined testing period. Results from this testing period that show Radon levels above the limit established by NASA will determine the need for additional sampling and then mitigation to an area based on the NASA limit.

Inventory of Radioactive Sources (IRS)

IRS01 - The Contractor shall physically inventory all radioactive sources to verify their location on a quarterly basis.

IRS02 - The Contractor shall make appropriate changes to the source records in order to maintain an accounting of current sources status.

IRS03 - The Contractor shall maintain/modify the Center existing tracking system(s) (electronically or paper) to maintain an accurate and up-to-date source inventory.

IRS04 - The Contractor shall notify the Center RSO immediately of any sources identified as missing during the inventory and follow up within 2 business days with a written report or per NRC requirements, whichever is less.

Shipping, Receipt, and Transfer of Radioactive Sources (SRTRS)

SRTRS01 - Shipments of all radioactive sources shall be made in accordance with the Department of Transportation (DOT) and other applicable regulations.

SRTRS02 - At a minimum, one Contractor shall be certified per NRC regulations to ship radioactive source material.

SRTRS03 - The Contractor shall support the development of shipping documentation for the transportation of radioactive material to locations off Center, including, but not limited to, review of shipping forms and declarations, radiological surveys and labeling/place carding of shipments.

SRTRS04 - The Contractor shall package radioactive materials shipments for items weighing less than 35 pounds. Packing materials will be available at center. All other shipments shall be coordinated with the material custodian and the Information and Logistics Management Division shipping personnel. Applicable shipment information shall be recorded on the shipping, receiving and transfer forms used by the Center

SRTRS05 - The contractor shall be responsible for the physical transportation of radioactive materials on the Center. This entails the transfer of sources between buildings for test and evaluation, moving to and from storage, etc.

Radioactive Source Storage and Usage (RSSU)

RSSU01 - The Contractor shall periodically inspect (at a minimum semiannually) any area where radiation sources are used or stored to ensure sources are being used in a safe and secure manner.

RSSU02 - The Contractor shall monitor areas where radioactive sources are used or stored. Dose rate measurements shall be performed on these areas. Survey Reports shall be completed as required by NRC license requirements and submitted to the RSO for review within 3 business days after the survey was completed.

RSSU03 - Smear surveys shall be taken of the storage or use areas per regulation or license requirements, or at a minimum bi-annually to verify that these areas are free from contamination. Reports of smear surveys shall be completed as required by NRC license requirements and submitted to the RSO for review within 3 business days after the survey was completed

RSSU04 - The Contractor shall notify the Center RSO immediately of any dose rates or smear survey results above any NRC regulations requirements and follow up within 1 business day with a written report.

RSSU05 - In the event an area or items are found to be contaminated above the NRC’s or Center’s limits, the Contractor shall work with the RSO and Center Emergency personnel to isolate the area or items. The Contractor shall use proper decontamination methods to eliminate the contamination to regulatory acceptable limits. Large scale, catastrophic events shall be managed by the Contractor to the point of regulatory acceptable final release to the public.

RSSU06 - The Contractor shall manage the radioactive source storage facility located at each Center. Sources that are not in active use by employees are kept in this location to ensure material security and the ALARA principle.

Radioactive Waste Disposal (RWD)

RWD01 - Radioactive waste shall be packaged in approved DOT containers and prepared and stored for disposal. Records shall be maintained on the contents of all items placed in such containers. The Contractor shall manage radioactive waste in accordance with applicable Federal and state regulations.

RWD02 - The Contractor shall maintain a list of radioactive materials in waste storage.

RWD03 - Historically most disposal have been associated with smoke detectors and exit signs that contain radioactive sources. When it comes time for disposal of radioactive waste the Contractor shall work with the Center to obtain an authorized company that can proper receive this waste.

Contractor will be required to work with company to properly package the waste for shipment off Center and complete all documentation required by the Center’s NRC License and DOT regulations.

RWD04 – Contractor shall maintain all records produced by the storage of radioactive waste and the shipment of waste offsite as required by the Center’s NRC License and NASA regulations.

RWD05 – Contractor shall ensure that final documentation is obtained from the company that received the waste showing that they have officially disposed of the waste per Federal Regulations or that they have transferred the waste to their organization’s NRC License.

Decommissioning of Radiological Sites, Buildings, or Outdoor Areas (DRSBOA)

DRSBOA01 - The NRC requires the radiological decommissioning of sites, buildings, and outdoor areas where licensed activities have ceased radiological operations, even while licensed activities continue to be conducted at other site locations. The Contractor shall plan for and conduct appropriate radiological surveys that demonstrate compliance with NRC regulations and allow for “free release” of such areas for unrestricted use.

DRSBOA02 - The Contractor shall work with the RSO to make proper notification to the NRC, when required, to explain what was decommission and to see if this would require any amendment to the Center’s NRC License.

DRSBOA03 - The Contractor shall complete and maintain all records produced with these efforts as required by NRC regulations and NRC License application package.

X-Ray Devices and Accelerator Surveillance (XDAS)

XDAS01 - The Contractor shall maintain a comprehensive inventory of all X-Ray devices and accelerators.

XDAS02 - The Contractor shall survey the equipment in accordance with Center, NASA or Federal regulations or manufacturers recommendations.

XDAS03 - The Contractor shall write inspection reports and surveys and maintain adequate records to verify the inspections and surveys have been complete.

Radiation Detection Instruments (RDI)

RDI01 - The Contractor shall ensure that radiation detection instruments are calibrated as required by regulation or manufacturer's guidance and when otherwise necessary to support the requirements of the Center.

RDI02 - Contractor shall provide an individual with training and knowledge to conduct calibration on ionizing radiation detectors that can be done in-house.

RDI03 - Instruments (both ionizing and non-ionizing) that have to be send to a certified company for calibration, the Contractor shall arrange for these calibrations, produce documents required for the shipment of the instruments to the off-site location, and package instruments for the shipmen

RDI04 - The Contractor shall perform routine maintenance such as replacement of batteries and the inspection of cables. Major repairs requiring more extensive electronic equipment will be returned to the manufacturer.

RDI05 – The contractor shall maintain a complete record, including calibration and servicing on all ionizing and non-ionizing radiation instruments.

Laser and Laser Systems (LLS)

LLS01 - The Contractor shall conduct a laser hazard analysis for each laser being used to determine its classification based on Laser Standards.

LLS02 - The Contractor shall maintain a comprehensive inventory of all Laser devices/systems that have been classified.

LLS03 - The Contractor shall develop and maintain requirements specific to the use of lasers that comply with Federal regulations and ANSI standards.

LLS04 - The Contractor shall ensure that all lasers evaluated are following the Food and Drug Administration (FDA) classification and labeling requirements. The Contractor shall work with the RSO to obtain an exemption from the FDA for any laser system/device being used cannot met the FDA requirements due to mission requirements or unique design and then met the requirements listed in the FDA exemption.

LLS05 - The Contractor shall conduct inspections of Class 3B and 4 laser operations and any outdoor laser usage at a minimum annually, which includes visits to off campus locations (i.e.

Operational Areas belonging to Projects/Missions located at other Organization’s/Agencies’ locations).

LLS06 – The Contractor shall provide support to the RSO for documentation and program requirements for any outdoor laser system which will need an evaluation by the NASA Laser Safety Review Board (LSRB) and for Center’s projects anywhere in the world which require laser safety plan evaluation.

LLS07 - The Contractor shall provide oversight and direction to the outdoor laser activities to assure adequate protection of air transportation. The Contractor shall ensure coordination with the NASA Laser Safety Review Board, Federal Aviation Administration, and the US Space Commands Laser Clearinghouse for outdoor laser activities as required by the ANSI standards.

LLS08 - The Contractor shall ensure that any laser system/device being transferred to any non- NASA organization meets the FDA certification regulations. If it is not FDA certified, then the Contractor will work with the NASA owner of the system/device to ensure compliance with the certification. If certification can’t be done, they would notify the RSO to take action to prevent this system/device from being transferred.

Electromagnetic Radiation (ER)

ER01 - The Contractor shall develop, maintain and implement safety programs and activities for radiofrequency (RF), microwave, electromagnetic, extra low frequency and other appropriate radiations in accordance with Federal, State and National Consensus Standards.

ER02 - The Contractor shall maintain a comprehensive inventory of all electromagnetic radiation devices/systems.

ER03 - The contractor shall conduct a hazard evaluation of all potentially hazardous emitters and ensure that a Safety Plan is produced that identifies safety requirements when limits established by IEEE C95.1 for the Members of the General Public or RF workers or both are exceeded.

ER04 - The Contractor shall conduct inspections of IEEE C95.1 Category 3 and Category 4 Radiofrequency Emitters at least annually.

ER05 – The Contractor shall conduct surveys of potentially hazardous radiofrequency radiation emitters that are in accessible areas as listed in Center’s procedures.

ER06 - The Contractor shall investigate Radiofrequency and Electromagnetic Field concerns identified by center employees. The Contractor shall provide written reports of the investigation to the RSO within 3 business days.

Ultraviolet Radiation/High Intensity Light sources (URHILS)

URHILS01 - The Contractor shall develop, maintain, and implement safety programs and activities for ultraviolet (UV) radiation and high intensity light (HIL) sources in accordance with Federal, State and National Consensus Standards.

URHILS02 -The Contractor shall maintain a comprehensive inventory of all UV Radiation and HIL sources identified to the RSO.

URHILS03 -The Contractor shall develop and maintain procedures to manage the UV radiation/HIL source program.

URHILS04 -The Contractor shall conduct a hazard assessment of UV radiation/HIL source use. The contractor shall write and/or review safety procedures for uses of UV radiation/HIL sources.

URHILS05 -The Contractor shall investigate UV radiation/HIL concerns identified by Goddard employees. The Contractor shall provide written reports of the investigation to the RSO within 3 business days.