From:	Pomije, Brian D. (LCDR)
Sent:	Wednesday, April 12, 2006 3:37 PM
To:	Burke, Gerald; Clark, Dorothy M. (CIV); Ely, Karen D. (CIV); Fairchild Gregory R LT; Feightner, Michael P. LT; Fong, Raynard K   CAPT; Frampton, Scott W  CIV; Giel, Daniel T. (CIV); Goodwill, Michael E; Gorsuch, Gregory  M. CAPT; Harden, Gary W; Houston, Tony L. HM2; Johnson, Gabrielle M.; LaFontaine, Richard L CT; Loscocco, Michele F (CDR); Minette, Christopher E. (LCDR); Ozeroglu, Muhammed A  LT; Pomije, Brian D. (LCDR); Scott, John H., CIV.; Simays, Andrew E., CDR; Smith, Glenee L. (Civ); Solanki, Haresh P; Tarver, James K. (CDR); Van Way, Rick L  LCDR (Ret); Younes, Georges  E LCDR; Beecham, Harry J. CAPT NAMRU2; Forcier, Michael R. HMC; 'Hanan El Mohammady'; HMC (org account) Redona; Ratiwayanto, Sutanti (NAMRU2 Jakarta); safety_namru2@attglobal.net; Tomon, John LT; Wilfredo Redona (kevinmkeitha@yahoo.com)
Cc:	Farrand, David E CAPT; LCDR J. P. Aldridge (E-mail); Pomije, Brian D. (LCDR); Ely, Karen D. (CIV); Clark, Dorothy M. (CIV); Nazareno, Felix M GS; Antosek, Edward CAPT; Rudolph, W. Garry (CAPT); Fallon, Ann P. (CAPT); Earles, Marvin R LCDR ; Glennon, Brendan K. CDR BUMED; Lino CDR Fragoso (E-mail) (Lino.Fragoso@navy.mil); Hutto, Robert CAPT; Lorenzen, William F GS; Netzer, Patricia H. (CAPT); Styles, Donna L (CAPT)
Subject:	Guidance for Permittees that Possess Radioactive Material Quantities of Concern (Order for Increased Controls)

To all Radiation Safety Officers and NRMP Permittees:

This message is a follow-up to the CNO ltr 5104 Ser 455C/6U838097 dtd 05 Apr 06, "Increased Controls for Radioactive Material Quantities of Concern."

The attached documents have been made available by the Nuclear Regulatory Commission (NRC) as guidance in the implementation of Increased Controls (ICs) for radioactive material quantities of concern (QCs).  One attachment includes common questions and answers, and the other includes highly detailed guidance on implementing the ICs.    

The original NRC Order as well as the Naval Radiation Safety Committee (OPNAV-N455) Order had originally been distributed by e-mail.  These two messages with attachments can be accessed on our intranet website at http://www-nehc.med.navy.mil/occmed/Messages_RSO_CY06.htm.

The additional questions and answers provided by OPNAV-N455 help to clarify certain ICs in the CNO letter.
 
Question:  (IC 1.b.)  For military personnel who have been at a command for less than 3 years and do not have a security clearance, but have been in the military for greater than 3 years, can that time be used to meet the greater than 3 year requirement?  As most military assignments are for 3 or less years, this would apply to most military personnel.  
 
Answer:  Yes, you can use time in service to meet the requirements of the order.  If the member has been in service less than three years, then you must meet the requirements of the order or insure that a third party has checked the reliability of the person.  This also applies to civilian personnel.  HRO can do the reliability check for you, but you have to document and insure that it was done.

Question:  (IC 2.a.)  Our irradiator is located in a room within the main laboratory space.  The door is secured with a cipher lock.  The lab is manned 24/7.  Will an intrusion alarm that sounds in the lab spaces meet the intent of immediate notification/response?  All lab personnel would be trained on what to do and who to call if the alarm sounds.
 
Answer:  It seems the facility already meets the requirement for increase control, as long as the lab personnel can challenge unauthorized persons near the device.  Other ways of meeting the requirement are:
•	Limiting distribution of keys, keycards, or combinations to doors and gates to approved individuals;
•	Remote activation of locked doors and gates using remote surveillance;
•	Using a card reader and electronic locking devices at control points; and
•	Constant surveillance by a person approved for unescorted access.

Question:  (IC 2.b.)  Local law enforcement agency (LLEA) implies “city civilian police.”  My conversation with our on-sight military police force indicates that we would notify them of the actual or attempted theft, sabotage, etc. of RAM QC.  They would in tern contact NIS and the local City Police Department if necessary for assistance.  Does my on-sight police force constitute LLEA or is contacting the local city police the real aim?

Answer:  The local law enforcement can be the federal police.  As long as it has authority to arrest and implement federal law.  You will need to train the police officers on the risks associated with your device.

Very respectfully,

LCDR Pomije

Brian D. Pomije, MS, DABR
Lieutenant Commander, Medical Service Corps, USN
Radiation Health Team Leader
Navy Environmental Health Center
620 John Paul Jones Circle (Suite 1100)
Portsmouth, VA 23708-2103

W: (757) 953-0766; DSN: 377-0766
Cell: (757) 651-2814
Fax: (757) 953-0685

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