Introduction
The Nuclear Regulatory Commission (NRC) has granted a Master Material License to the Air Force for use of radioactive material. Under the license agreement, the Air Force is given authority to manage radioactive materials generally regulated by the NRC and allows the Air Force to issue individual permits for use of licensed permitted radioactive material at individual Air Force installations. As a condition of the Master Materials License, the Air Force agreed to form a committee chartered to manage and oversee the implementation of Air Force radioactive material management procedures. The committee is known as the USAF Radioisotope Committee (RIC).
The RIC is maintained by the Surgeon General (HQ USAF/SG) and is under the direction of the Air Force Medical Operations Agency (AFMOA). The RIC is responsible for coordinating all use of radioactive materials in the Air Force except for:
- Radioactive materials transferred from the DOE to the Department of Defense (DOD) as part of nuclear weapons systems;
- Certain radioactive parts of weapon systems; and
- Nuclear reactor systems, parts and fuel controlled under Section 91b of the AEA.
The RIC is composed of members from the Inspector General (SAF/IG), Deputy Chief of Staff for Air and Space Operations (HQ USAF/XO), Deputy Chief of Staff for Installations and Logistics (HQ USAF/IL), Office of the Civil Engineer (HQ USAF/ILE), Director of Civil Law and Litigation, Air Force Legal Services Agency (AFLSA/JAC), and is chaired by the Air Force Medical Operations Agency (AFMOA/CC).
The main roles and functions of the RIC are the following:
- Oversight of USAF use of radioactive materials;
- Single point of contact for the USAF Master Materials License issued by the NRC;
- Establishment of administrative controls to acquire, receive, store, distribute, use, transfer, and dispose of radioactive material per NRC, Department of Transportation, and USAF Master Materials License requirements;
- Single point of contact with the NRC or Agreement States on byproduct, source, or special nuclear material licensing, and the NRC Sealed Source and Device Registry;
- Contact with the Council of Radiation Control Program Directors (CRCPD) and the CRCPD licensing states for naturally occurring and accelerator produced radioactive material;
- The USAF Radioisotope Committee Secretariat (AFMOA/SGOR) is delegated daily operating responsibility for Air Force radioactive materials including initiating actions to carry out RIC decisions and policy.
Other Regulatory Agencies
Nuclear Regulatory Commission (NRC): The NRC regulates the byproduct, source, and special nuclear material constituents acquired, received, stored, distributed, used, transferred, or disposed of by facilities permitted to manage radioactive materials. NRC guidance is found throughout Title 10 Code of Federal Regulations (CFR), "Energy" and forms the basis for Air Force implementing instructions and RIC policy.
Department of Transportation (DoT): The DoT regulations establish criteria for the safe transport of radioactive materials in the United States. The NRC regulations complement DoT regulations regarding the shipment of radioactive materials and primarily pertain to materials with higher activities than those covered by the DoT regulations. DoT regulations are found in Title 49 CFR Part 171 through 178.
Environmental Protection Agency (EPA): Title 40 CFR, Subchapter F, "Radiation Protection Programs" imposes limits on radiation exposures, levels, concentrations, or quantities of radioactive material received by members of the public in the general environment or radioactive materials introduced into the general environment as a result of operations associated with nuclear power generation, disposal of nuclear fuel, and certain other activities such as control of residual radioactive materials from inactive uranium processing sites. The EPA also has joint authority with the NRC over the disposal of low level radioactive material mixed with hazardous waste as defined in the implementing regulations for the Resource Conservation and Recovery Act (RCRA) in 40 CFR Part 261.
Managing Radioactive Materials in the Air Force
Day to day management of radioactive material in the Air Force is governed by Air Force Instruction (AFI) 40-201, "Managing Radioactive Materials in the Air Force." AFI 40-201 governs the acquisition, receipt, storage, distribution, use, transfer, and disposal of radioactive material. The AFI also describes procedures for non-Air Force activities to gain approval to use radioactive materials on Air Force installations. The AFI does not govern radioactive materials transferred from the Department of Energy to the Department of Defense as parts of nuclear weapons systems, certain radioactive parts of weapons systems, nuclear reactor parts and fuel controlled under
Section 91b of the Atomic Energy Act (AEA), and Department of Energy activities related to SAFE HAVEN requirements. These exceptions are not addressed in this fact sheet.
Items typically found on an Air Force installation which contain radioactive material include:
- Sealed Radiation Sources used by Precision Measurement and Equipment Laboratories and Bioenvironmental Engineering for radiation detection instrument calibration;
- Medical Products;
- Gas Chromatographs;
- X-Ray Fluorescence Lead Based Paint Analyzers;
- Soil Moisture Density Gages;
- Chemical Agent Alarms;
- Exit Signs (self luminating);
- Lensatic Compasses;
- Smoke Detectors; and
- Depleted Uranium Counterweights.
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USAF Radioactive Material Acquisition and Use
It is Air Force policy that all human exposures to ionizing radiation be As-Low-As-Reasonably-Achievable (ALARA). There should be no exposure to ionizing radiation without an expected benefit and any dose received should be the lowest possible, consistent with technology, cost, and operational requirements.
USAF personnel responsible for acquisition of radioactive materials are required to limit the use of radioactive material. USAF radioactive material acquisition policies include the following:
- Acquisition of radium or devices containing radium is prohibited;
- Radioactive material can not be accepted into the USAF inventory unless an USAF permit issued by the RIC exists or the material is exempted from permit requirements by the RIC or AFI 40-201;
- Systems using radioactive materials must have radiation safety features built-in by design;
- Acquisition of radioluminescent signs and markers solely for energy conservation in general administrative, industrial, and housing applications is prohibited; and
- Radiation safety requirements must be specified in all contracts awarded for operating, changing, and repairing systems containing radioactive material.
Air Force organizations must secure a permit from the RIC before receiving, storing, distributing, using, transferring, or disposing of:
- Licensed Byproduct, Source, and Special Nuclear material;
- Naturally Occurring and Accelerator Produced radioactive materials in activities greater than the exempt concentrations or quantities listed in AFI 40-201 unless waived by the RIC.
The permit request must be submitted by the using organization, through the host base RSO for coordination and endorsement, and through the MAJCOM Bioenvironmental Engineer (unless otherwise authorized for direct submittal by the MAJCOM), for submittal to the RIC. The permit application requirements are outlined in AFI 40-201. Once approved by the RIC, all permit submittals outlining receipt, use, transfer, shipment, disposal, and radiation safety procedures are incorporated into the permit and become mandatory permit compliance requirements. Formal permit procedures as outlined in AFI 40-201 must be completed for permit renewals, amendments, and termination.
Installation radioactive material programs are managed by the base and permit radiation safety officer (RSO). At each permitted USAF base, there are two RSO functions: the Base RSO and the Permit RSO. The two functions may be served by the same person, however, the two roles do not overlap. Each person is designated by name and must meet management and radiation safety prerequisites established by the RIC prior to appointment. The main responsibilities of each of the two functions are:
Base RSO:
- Establishes the overall installation radiation protection program;
- With base contracting officers, writes base instructions on how to coordinate and obtain approval for non-USAF organizations to use radioactive materials on base;
- Keeps a record of approved uses of radioactive materials;
- Checks user operations to protect base personnel and property; and
- Works with the permit RSO, environmental coordinator, bioenvironmental engineer, and fire chief to research storage and disposal needs and develop methods, locations, and rules for handling and storing radioactive materials
Permit RSO:
- Checks the receipt, storage, distribution, use, transfer, and disposal of radioactive materials for compliance with: approved rules, specific conditions of the permit, and directives listed in AFI 40-201;
- Sets up, in one binder or file, the permittee's written policy and rules for: authorizing the purchase of radioactive material; receiving and opening packages of radioactive materials; storing radioactive materials; keeping an inventory record of radioactive materials; emergency response to a loss of control of radioactive material; using radioactive material safely; doing periodic radiation surveys; calibrations and checks of survey instruments and other safety equipment; disposing of radioactive material; and training personnel who work in, or frequent, radioactive material use and storage areas.
- Works with the base RSO on actions which may affect the base such as changes in source-use locations and method of disposal, etc.
Non-Air Force organizations and contractors using radioactive materials on an Air Force installation must have approval of the installation commander or their appointee. Approval is obtained by submitting a written request through the base RSO. Requests must include:
- Description of proposed radioactive material use;
- A copy of the appropriate NRC or Agreement State License with NRC Form 241, Radioactive Material Permit, exemption, or RIC approval;
- Name and local address of responsible local representative and contact information for the permit RSO;
- A copy of any Air Force contract describing the work to be done and inclusive dates; and
- An acknowledgment stating the base RSO can make periodic checks to ensure that the user is following radiation safety practices to prevent exposures to Air Force personnel and avoid contamination of governmental property.
USAF Radioactive Material Inventory Control
The following USAF policies apply to the control of radioactive materials: (1) All radioactive material stored in unrestricted areas must be secured from unauthorized removal or access. Permitted materials used in unrestricted areas must be under the constant surveillance of an authorized individual when not in storage; (2) All permitted radioactive sources and devices and nonexempt quantities of radioactive material in non-permitted sources and devices must be inventoried as specified in AFI 40-201. Inventory documentation must be retained for 5 years
Radioactive Material Transportation
Air Force activities shipping or transporting radioactive materials must follow US Department of Transportation (DoT), NRC, and US Postal Service (USPS) Regulations. When shipping or transporting licensed radioactive materials, Air Force activities must follow the requirements of 10 CFR 71, "Packaging and Transportation of Radioactive Material" and 49 CFR 172, "Hazardous Materials Tables, Hazardous Materials Communications Requirements and Emergency Response Information Requirements," through 178 "Specifications for Packagings." Proper packaging and shipping requirements can be provided by the base Traffic Management Office (TMO). The generator must provide the following information in order for TMO to determine shipping procedures:
- Radionuclide;
- Activity in units of curies;
- Chemical and physical form;
- Item nomenclature; and
- Stock Number (if applicable).
Management and Disposal of Radioactive Waste
Procedures must be developed by the base Radiation Safety Officer in conjunction with the permit RSO, if applicable, to secure waste radioactive material from unauthorized persons. The degree of waste management rules required is dependent upon local conditions including quantity and type of waste produced, where the waste is generated, and location and configuration of available storage. A permit must be obtained for radioactive waste storage areas used for licensed quantities of Byproduct, Source, or Special Nuclear material and non-exempt quantities of Naturally Occurring and Accelerator Produced Radioactive Material wastes.
Radioactive waste generating activities must:
- Secure laboratories or rooms where radioactive wastes are generated or stored;
- Use a bound log book with consecutively numbered pages to document information on waste generation and radiation levels including items listed in AFI 40-201.
- Survey waste containers at least weekly; and
- The permit RSO must check log books, visually inspect containers, survey the container with radiation instrumentation, and seal the container prior to packaging waste for shipment to a disposal site.
Disposal of licensed and non-exempt radioactive material
Disposal of licensed and non-exempt radioactive materials is governed by 10 CFR 20, Subpart K, "Waste Disposal" and AFI 40-201. Disposal of waste radioactive material can be accomplished in several ways:
Disposal by Transfer: Radioactive material can be transferred to an authorized recipient following the procedures in AFI 40-201.
Disposal by Decay in Storage: Dispose of radio active materials having a physical half-life in storage of less than 120 days by decay in storage, if authorized by permit conditions.
Disposal by Release to Sanitary Sewer: Dispose of radioactive material by release to a publicly owned treatment works (POTW) sanitary sewer system only when authorized by the permit and allowed by local, state, and Federal regulations. Federal regulations limit disposal via this route to readily soluble material or readily dispersible biological material in water and the quantity does not exceed limits referenced in 10 CFR 20.2003, "Disposal by release into sanitary sewerage." Release to a federally owned treatment works (FOTW) must be authorized by the RIC.
Disposal of Specific Wastes: A licensee may dispose of the following licensed material as if it were not radioactive according the requirements of 10 CFR 20.2005, "Disposal of specific wastes:"
- 0.05 microcuries, or less, of hydrogen-3 or carbon-14 per gram of medium used for liquid scintillation counting; and
- 0.05 microcuries, or less, of hydrogen-3 or carbon-14 per gram of animal tissue, averaged over the weight of the entire animal.
Disposal by Transfer for Land Burial: Radioactive material may be transferred to a licensed low level radioactive waste disposal facility for land burial. The requirements for transfer of material are currently outlined in Technical Order (T.O.) 00-110N-2, "Radioactive Waste Disposal," and 10 CFR 20.2006, "Transfer for disposal and manifests."
| Editors Note: AFI 40-201 is currently being revised to incorporate the requirements specified in T.O. 00-110N-2. |
The requirements for transfer for burial are complex and strictly controlled by the Air Force. All disposal actions must be coordinated in advance with the Base RSO and:
Air Force Institute of Environmental, Safety, and Occupational Health Risk Analysis (AFIERA)
Air Force Radioactive and Mixed Waste Office (AFRMWO)
AFIERA/SDRH/ (AFRMWO)
2402 E Drive
Brooks AFB, TX 78235-5114
DSN 240-1904 or commercial (210) 536-1904
The above address reflects the current location of the Air Force radioactive waste manager as referenced in AFI 40-201 and T.O. 00-110N-2. The AFRMWO office will provide written instructions on disposal procedures and may in some cases perform a site visit prior to authorizing shipment.
Radioactive Material Recovery and Recycling Program
The Wright-Patterson Radiation Safety Branch (88 ABW/EMB) established a contract for the recycling of radioactive material. Since initial recycling in September 1993, the 88 ABW/EMB has recycled over 18,000 pounds of depleted uranium, 8000 curies of Tritium, and 41 curies of krypton 85.
Recyclable Radioactive Material
| Isotope | Form | Recyclable Types | Recyclable NSN | Excluded Types/NSN |
| Krypton 85 | Gas | Any source type | Any | Wave Guides, Ignition Exciters |
| Tritium | Gas Only | Compasses | 6605-00-151-5337
6605-01-196-6971 | Compass, Oxide
(6605-00-846-7618) |
| Tritium | Gas Only | Watches | Any | Oxides |
| Tritium | Gas Only | Luminescent Safety Devices (i.e. Exit Signs) | Any | None Known |
| Depleted Uranium | Solid | Counterweights; Non-explosive Munitions; Armament | Any | Extraneous Metal (i.e. nuts, bolts, airframe parts, casings, aluminum) |
| Cesium 137 | Solid | Exempt Quantity Check Sources | Any | Check sources issued as general or specifically licensed devices |
| Polonium 210 | Solid | Any device distributed under 10 CFR 31.3 | Any | 3M distributed devices |
| Americium 241 | Solid | Smoke Detectors (CASE BY CASE) | Any | |
Department of Defense operations having any of the above items they would like to recycle, must complete a request. This request may be a letter, facsimile, or electronic mail message. The request should be sent to: Wright-Patterson Radiation Safety Office, Radiation Safety Branch, 88 ABW/EMB, Building 30089, 5490 Pearson Road, Wright-Patterson AFB, OH 45433-5332, attention: Chris Anthony. Do not ship any radioactive materials unless specifically authorized by 88 ABW/EMB. If additional assistance is required to facilitate your recycling request, call DSN 787-2010 extension 205, (937) 257-2010, or facsimile DSN 986-1534, (937) 656-1534, or electronic mail anthonc@wrigem.wpafb.af.mil.
After authorization is granted, the 88 ABW/EMB will provide the necessary instruction to satisfy all regulatory requirements, provide notification to the Nuclear Regulatory Commission (if required), and provide a verification of material receipt.
Mixed Waste Disposal
Generators of mixed radioactive waste (waste containing both low level radioactive waste and EPA regulated hazardous waste as defined in RCRA) must meet NRC and EPA disposal requirements. NRC rules are implemented in the Air Force under the direction of the RIC as described above. The Base Environmental Flight is responsible for implementing hazardous waste management programs at the installation level as outlined in Air Force Pamphlet (AFPAM) 32-7043, Hazard Waste Management Guide. Close cooperation between the Base Environmental Flight, Permit and Base RSO, and Bioenvironmental Engineering is necessary to properly manage mixed waste disposal.
Managing Low Level Radioactive Waste Burial Sites
Specific policies and procedures for managing low level radioactive waste sites are outlined AFI 40-201. The requirements specify the Base RSO is responsible for annually surveying radioactive waste burial sites and reporting on the site condition. Any further site characterization must be coordinated with local and MAJCOM authorities and appropriate AF authorities. Additional guidance has been published in the HQ AFMOA/SGPR (Radioisotope Committee Secretariat) letter, "Clarification of AFI 40-201 Paragraph 3.1, Managing Low Level Radioactive Waste Burial Sites, 31 August 1995. The guidance outlines site characterization policies for the three types of radioactive waste burial sites typically located on Air Force facilities. The guidance is summarized below:
- Sites containing or suspected to contain materials regulated under Part 91b of the Atomic Energy Act (such as source material resulting from nuclear weapons maintenance activities or accidents) are not regulated by the RIC. Questions regarding the characterization of these sites should be referred to the Air Force Safety Center, Weapons, Space and Nuclear Safety Division (AFSC/SEW), Kirtland AFB, NM.
- Characterization plans for sites containing or suspected to contain Byproduct, Source, or Special Nuclear material must be submitted to the RIC for review. The RIC will submit the plans to the NRC for approval.
- Characterization of sites containing or suspected to contain Naturally Occurring or Accelerator-Produced Radioactive materials are regulated by the EPA. Site remediation is managed in accordance with the policies for remediation of hazardous waste burial sites as specified by USAF/ILE.
Radioactive Material Incident Management and Reporting
AFI 40-201 provides specific guidance for radioactive material incident reporting. The reporting procedures are designed to ensure prompt response to incidents and maintain compliance with the requirements of the Air Force Master Material License issued by the NRC. AFI 40-201 provides reporting instructions, response instructions, and provides incident investigation instructions. It also defines various types of incidents along with reporting timelines.
Some incidents and accidents requiring reporting include:
- Loss of control of radioactive material posing hazard to life or health;
- Spills or unplanned releases of radioactive material;
- Medical misadministration;
- Lost, stolen, or missing sources;
- Releases which may cause an individual to receive a dose equivalent of radiation in excess of specified regulatory limits; and
- Any unexpected event involving radioactive material or radiation exposure which attracts the interest of non-Air Force officials or agencies such as inquiries by the public or press.
A checklist of requirements to complete during the reporting process can be found in AFI 40-201.
Where to go for help?
The following organizations can provide consultant services on the management of radioactive material.
USAF Radioisotope Committee Secretariat
AFMOA/SGOR
110 Luke Avenue, Room 400
Bolling AFB, DC 20332-7050
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AFIERA/SDR
2402 E Drive
Brooks AFB, TX 78232-5114
DSN 240-3486 or commercial (210) 536-3486
Important Terms
Atomic Energy Act (AEA) - 1954 Act which created the Atomic Energy Commission (AEC). The AEC later split into the Nuclear Regulatory Commission (NRC) and the Energy and Research and Development Administration (ERDA). ERDA then became part of the Department of Energy (DOE) in 1977. The AEA encouraged the development and use of nuclear energy and research for the general welfare and of the common defense and security for the United States. The AEA is the basis of authority for NRC, DOE, and Environmental Protection Agency (EPA) in regulating radioactive materials.
Activity - Measure of the intensity of a radioactive material. Activity is usually designated in terms of the number of transformations or disintegrations that occur over a period of time. It is typically measured in units of curies. One curie is equivalent to 3.7 x 1010 disintegrations per second (one microcurie is 3.7 x 104 disintegrations per second).
Agreement States - States that have signed agreements with the NRC enabling them to regulate source, byproduct, and small quantities of special nuclear material within their boundaries. The following states are currently NRC Agreement States: Alabama, Arizona, Arkansas, California, Colorado, Florida, Georgia, Illinois, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Mississippi, Nebraska, Nevada, New Hampshire, New Mexico, New York, North Carolina, North Dakota, Oregon, Rhode Island, South Carolina, Tennessee, Texas, Utah, and Washington.
Background Radiation - Radiation from cosmic sources, naturally occurring radioactive materials, including radon (except as a decay product of source or special nuclear material) and global fallout as it exists in the environment from the testing of nuclear explosive devices. "Background radiation" does not include radiation from source, byproduct, or special nuclear materials regulated by the NRC.
Byproduct Material - (1) Any radioactive material (except special nuclear material) yielded in, or made radioactive by, exposure to the radiation incident to the process of producing or utilizing special nuclear material; and (2) The tailings or wastes produced by the extraction or concentration of uranium or thorium from ore processed primarily for its source material content, including discrete surface wastes resulting from uranium solution extraction processes. Underground ore bodies depleted by these solution extraction operations do not constitute "byproduct material" within this definition.
HalfLife - The time it takes for half of the activity of a radionuclide to decay by radiation of energetic particles and rays. For example, the halflife of cesium (Cs137) is 30 years, after which time half of its activity decays to a nonradioactive stable nuclide, barium (Ba137). If the original activity of Cs-137 was 10 curies, the activity after 30 years would be 5 curies, after 60 years (two half lives) it would be 2.5 curies, and soon.
High Level Radioactive Waste (HLRW) - Radioactive waste material resulting from the reprocessing of spent nuclear fuel, including liquid waste produced directly from reprocessing and any solid waste derived from the liquid that contains a combination of transuranic and fission product nuclides in quantities requiring permanent isolation.
LowLevel Radioactive Waste (LLRW) - Radioactive material which: (a) is not highlevel radioactive waste, spent nuclear fuel, or byproduct material; and (b) is classified by the NRC as lowlevel radioactive waste. In a sense, LLW is defined by what it is not and consequently is the most broad category of waste. It encompasses materials slightly above natural radiation background levels to highly radioactive materials which require extreme caution when handling.
Mixed Waste (MW) - Waste containing both hazardous waste and source, special nuclear, or byproduct material subject to the Atomic Energy Act of 1954.
Naturally Occurring or Accelerator Produced Radioactive Materials (NARM) - Radioactive materials not covered under the AEA that are naturally occurring or produced by an accelerator. Accelerators are used in subatomic particle physics research NARM waste is not covered under the AEA, is not a form of LLW, and is not regulated by NRC.
Radiation (Ionizing Radiation) - Alpha particles, beta particles, gamma rays, xrays, neutrons, highspeed electrons, highspeed protons, and other particles capable of producing ions. Human exposure to various types of ionizing radiation presents the following potential hazards:
Alpha radiation consists of heavy, positivelycharged particles emitted by atoms of heavy elements such as uranium and radium (naturally occurring) and some humanmade sources. Alpha radiation imparts energy to a relatively small area causing a high number of ionizations per unit of tissue impacted. Alpha radiation has low penetration characteristics and is completely absorbed by the outer dead layer of skin and is therefore not a hazard outside the body. If it is taken into the body by inhalation or with food or water, it can directly expose internal tissues and can be a hazard. Alpha radiation is considered an internal exposure hazard.
Beta radiation consists of positively or negatively charged electrons that are emitted from the nucleus during decay. Although beta particles have moderate penetration characteristics and can penetrate the skin, beta radiation is generally more hazardous when inhaled or ingested. Gamma radiation consists of photons emitted from atoms when radioactive materials decay. Gamma radiation imparts energy over a relatively large area and has high penetration characteristics. Damage is less focused but can extend deep into tissue layers. Gamma radiation is primarily considered an external exposure hazard.
X-Rays are similar to gamma radiation in that they cause similar exposure hazards. X-Rays are derived from excitation of electrons in a molecule in contrast with gamma rays which originate from the nucleus of a radionuclide.
Source Material - (1) Uranium or thorium or any combination of uranium and thorium in any physical or chemical form; or (2) Ores containing, by weight, onetwentieth of 1 percent (0.05 percent), or more, of uranium, thorium, or any combination of uranium and thorium. Source material does not include special nuclear material.
Special Nuclear Material - (1) Plutonium, uranium233, uranium enriched in the isotope 233 or in the isotope 235, and any other material the NRC, pursuant to the provisions of section 51 of the Atomic Energy Act of 1954, determines to be special nuclear material, but does not include source material; or (2) Any material artificially enriched by any of the foregoing but does not include source material.
References
Title 10 Code of Federal Regulations Part 20, "Standards for Protection Against Radiation."
"Air Force Policy on Management of Radioactive Material and Waste at Closure Installations," SAF/MIQ, 8 June 1995.
Air Force Instruction 40-201, "Managing Radioactive Materials in the USAF," 25 July 1994.
Air Force Pamphlet (AFPAM) 32-7043, "Hazard Waste Management Guide."
"Transporting Radioactive Materials," US Department of Energy, DOE/EM-0097, April 1993.
Regulatory Guide 8.29, Revision 1, "Instruction Concerning Risks from Occupational Radiation Exposure," February 1996.
Nuclear Regulatory Commission Regulatory Digest, 1995 Edition.
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