The National Superconducting Cyclotron Laboratory (NSCL), located at Michigan State University in East Lansing, Michigan, operates under the NRC broad scope license and is currently in the process of being permitted by the State of Michigan. Regulatory oversight has been confusing and sometimes deficient over the years, creating a very vague and sometimes uncomfortable situation for radiation safety managers. In fact, as a NRC inspector stated "the NSCL had fallen through the cracks of regulatory oversight", leaving us to do our best with no clear set of guidelines, regulations or programmatic approach.
I began working heavily with the NSCL in 1989, and in 1990, as the new MSU Radiation Safety Officer, radiation safety at the NSCL escalated significantly as a priority. It was clear that radiation safety needed significant improvement and clarification, based on previous experience and encounters with the NSCL safety issues. Practical procedures, guidelines and programs were often lacking or insufficient for the current regulatory and safety needs, and those in existence were frequently inconsistent.
Similar to many radiation safety programs, whether in biological research laboratories or in accelerators, effective, efficient and user friendly radiation safety guidance was desperately needed. Programs, guidance, protocols, forms and tracking needed to be developed and implemented, and training on these items needed development and follow up.
An even more difficult twist on all of this was the sweeping changes in the Federal Title 10 CFR 20 regulations which were in final comment stages in 1990, and which were promulgated to be effective January 1, 1994. We chose to "bite the bullet" and develop everything to be in accordance with these new regulations, a tough challenge.
It is my opinion that one of the problems in trying to manage safety and compliance at accelerators is that institutional radiation safety officers and their staffs are unfamiliar with accelerators and the risks present, and often the physics is elusive. Another reason is the atypical and continually changing nature of the work done and people present at accelerators. Lastly, if an accelerator has its own in-house staff, there is usually a large gap in interactions between the accelerator safety staff and the institutional management staff, creating differences and lags from institutional management programs and changes.
Thanks to the conscientiousness, concern and expertise of Reg Ronningen, NSCL Senior Staff Physicist and Radiation Safety Officer, a superior cooperative approach to radiation safety management was developed, and has been used throughout this eight year odyssey. We continue to work as "brothers in arms" in managing radiation safety programs and issues, running the gamut from incident response and resolution to developing new programs in accelerator safety.
Our NSCL currently operates fully under U.S. NRC regulations and is now in an excellent position as we prepare to write a site specific permit with the State of Michigan under their recently revised regulations.
We are in the midst of major construction as part of the K500/K1200 Coupling Project, targeted for operation in the early 2000s. Many unusual problems have already been resolved, involving complex coordination of many priorities and people. We expect to continue the fast and challenging pace for the next 10-15 years and to see many interesting and unusual radiation safety issues.
We will to continue sharing our "war stories" with you as many accelerators begin preparations for changeover from Department of Energy oversight to Nuclear Regulatory Commission oversight. We also welcome inquiries and discussions with others who are experiencing or anticipating changes in accelerator radiation safety management.
Coming Next:* This will be a regular bimonthly feature. It will focus on some of the difficult issues we encounter and how we tackled or solved them. Articles will be brief and should be of a type that they will benefit others who have or may encounter similar situations. Please submit your articles or suggestions to: Kristin Erickson <10525kfb@msu.edu>. "Lessons Learned" is a good concept to think of when coming up with ideas.
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