Plexus-NSD 

 

Special Services

 

Plexus-NSD offers a wide variety of products and services in the areas of radiation protection and radiological engineering. However, we understand that companies might be reluctant to use a consultant with whom they have no experience. Thus when a company initially approaches Plexus-NSD for assistance, we offer a number of special services. Although these services involve small budgets, they provide an insight into the quality and value of working with Plexus-NSD. After evaluating the return received on their investment, companies then become comfortable with establishing a client-consultant relationship with Plexus-NSD.  The following is a list of just a few of the special services we offer.

 

Special Services Menu

 

Annual Compliance Programs

You have already made the commitment .  A radioactive materials license is a necessary part of your operation, whether you are:

  • A nuclear medicine practice

  • A small-scale university research or teaching program

  • A focused industrial operation

 

However, even though your firm is small and has limited operating resources, you have no choice but to comply with the same Federal or State regulations and license requirements that bind your larger-scale competitors and counterparts (e.g., hospitals, broad-scope research operations, radiation source manufacturers, etc.).  It is still up to you to ensure compliance with applicable regulations and license requirements, or suffer the consequences of regulatory enforcement action,  loss of your good reputation, monetary fines/penalties and even the termination of the license that you worked so hard to secure.

Unfortunately, compliance doesn't come cheap.  If your operation is not part of a major organization with a dedicated radiation safety staff or in-house qualifications in the areas of radiation protection and license compliance, the chances are the head of your business or practice is serving as the Radiation Safety Officer.  

In that role, that valuable corporate contributor is also responsible for all of the following and more:

  • Ensuring an effective, implementable and streamlined license is in place that meets the letter of the law without obliging you to unnecessary commitments.

  • Ensuring your radiation protection program will guarantee the radiation safety of you, your employees, your visitors and your contractors.

  • Performing and documenting routine ambient and contamination surveys in your radiologically-restricted areas.

  • Ensuring the instruments used to do your routine surveys are calibrated and used appropriately and on schedule.

  • Providing internal , external and area radiation monitoring, as required, to ensure you are able to demonstrate compliance with your regulatory dose limits for occupational workers and members of the public.

  • Receiving radioactive materials or radiopharmaceuticals from suppliers safely and compliance with your license requirements and those promulgated by the U. S. Department of Transportation.

  • Performing a physical inspection and leak testing your sealed radiation sources on the schedule specified in your license.

  • Providing initial and refresher radiation safety training for your employees, contractors and visitors.

  • Providing initial and refresher authorized user training for those individuals responsible for supervising the use of radioactive materials at your facility.

  • Managing all radioactive waste generated by your operation or practice.

  • Ensuring the quality of all instruments used to assess radionuclides administered to patients.

  • Verifying that all of your restricted areas and radionuclide storage locations are posted/labeled appropriately.

  • Preparing all of the necessary reports and documents that accompany a radioactive materials license.

  • And most importantly, demonstrating to the satisfaction of your regulator that all of the above were done on time and exactly as you committed to do them when your license was issued.

 

There are alternatives, however.  You can hire a full-time health physicist to take care of these requirements for you, although this would be an expensive proposition for a radioactive materials program with such a limited scope. Alternatively, you might want to train one of your own office or technician staff members to schedule, perform, document and defend what needs to be done, although that would take them away from their primary responsibilities and it forces you to rely on an individual with little - if any! - fundamental knowledge of radiation- and compliance-related matters to keep on top of your program for you.  And then there is the worst case scenario where you need to take your valuable time away from facility management, patient care or business development to do the work necessary for ensuring your firm meets the letter of your license. In all cases, your costs and potential liabilities can be excessive.

There is a fourth alternative that can not only ensure a spotless compliance record, it will free up the valuable time of you and your staff and reduce your compliance costs and liabilities to a practical minimum.  That alternative is the Plexus-NSD 'Annual Compliance Program'.  This program, developed and implemented by individuals who are Certified by the American Board of Health Physics and Registered by the National Registry of Radiation Protection Technologists, is tailor-made for firms like yours with tight operating budgets, limited support staff, and the desire to maintain a program that is as technically- and legally-sound as those of your larger competitors.

If Plexus-NSD's 'Annual Compliance Program' sounds like it might provide you with relief from your escalating regulatory costs and demands, simply Contact Us. An Plexus-NSD Certified Health Physicist will work with you to provide you with a firm, fixed price for scheduling and delivery of all of your license compliance needs. Alternatively, you may wish to print, complete and return for proposal our Compliance Services Request Sheet. There is, of course, no cost or obligation associated with our firm, fixed-price quotation that we will send you shortly after we receive you request.  However, when you compare it to your current quality of service and the cost for its implementation, we are confident you will be pleasantly surprised.  We hope you will take us up on our offer to let you get back to doing what you do best while saving money in the long run.

 

Our Cost-Conscious D&D Program

The problem

Most radioactive material licensees routinely use available in-house resources in responding to spills and relatively small decontamination operations. And if the uses of radioactive materials at the site have never resulted in wide-spread contamination (i.e., to air handling systems, sewer discharge lines, etc), the licensee typically has no problem in mounting an in-house-based decommissioning operation . . . assuming, of course, that their license permits them to do so and that they can avoid negative impact on ongoing operations throughout the process.

But what if the clean-up or decommissioning action falls somewhere between a small spill and a major decommissioning action? What if the site is one of the following:

  • A small-scale state or federal licensee that wants to terminate their radioactive materials license but is unfamiliar with their regulator's site-wide decommissioning process.

  • A licensee that wishes to remove a single restricted area or building from the listing of permanent restricted areas on an existing license.

  • A facility facing a small but challenging clean-up issue, such as one that involves mixed wastes, interferences with ongoing operations, or a sensitive workforce and/or neighboring community.

  • A licensee that, for cost-saving purposes, wishes to complete as much site clean-up as possible before entering into the formal decommissioning and license termination process.

  • A facility with a limited scope license that does not authorize the performance of remedial actions without a license amendment.

  • A facility with a tight clean-up deadline and/or a restrictive clean-up budget.

  • A licensee whose in-house staff is unable to complete a decontamination effort while still supporting routine and on-going operations.

  • A site where the pending decontamination job is too small to attract the interest of a large, full-service decommissioning contractor.

The solution

What these licensees need is a company with a special mix of skills. What these licensees need is a support service that offers:

  • The ability to act as an extension of the licensee's operation, to minimize the impact of decontamination efforts on their business

  • Expertise in licensing and regulator interactions to ensure that decontamination activities meet all regulatory requirements

  • Experience in characterizing radiological contamination, removing it safely and cost-effectively, and disposing of it properly

  • Ready access to the other types of expertise (analytical, construction/demolition, geotechnical, waste treatment, etc.) that might be needed to complete a project successfully

  • The ability to accurately project costs, willingness to perform decontamination work on a fixed-price basis, and demonstrable skill at managing decommissioning funding effectively

  • Pollution liability insurance in amounts sufficient to cover the ramifications of any unforseen/unplanned events

  • Heightened/continuous consciousness of and the ability to address both licensee resource limitations and existing operating philosophy

The company that has these skills is Plexus-NSD.  We specialize in assisting primarily commercial clients in the cost-effective management and licensing of ionizing radiation sources and radioactive materials. Plexus-NSD has worked with a wide variety of firms in applying for and updating licenses, improving radiation protection programs, training, conducting surveys/characterizing sites, including the implementation of MARSSIM guidance, and assisting in decontamination and decommissioning (D&D) programs.

 

The Plexus-NSD approach

Plexus-NSD is pleased to offer its 'Cost Conscious D & D Program', a cost- and time-sensitive means of addressing full or partial license termination efforts. We take charge of the effort in its entirety and on your behalf, thus minimizing the drain on your in-house resources. We manage the work effectively so that you won't 'break the bank', and we stay involved in regulator interactions to ensure that they are satisfied with the process and with the final product. Here are some more facts to consider:

  • Plexus-NSD has successfully completed many small- to mid-sized projects, all to the satisfaction of both the customer (cost/schedule) and regulators (compliance/release).

  • Plexus-NSD's personnel have experience in all aspects of this unique topical area, a fact that is recognized and utilized by training organizations and by international standards agencies.

  • Plexus-NSD's excellent cost estimating and scope preparation skills allow us to take on decontamination efforts on a fixed-price basis, thus ensuring our clients will know what their financial obligations are before the project begins.

  • Plexus-NSD's project managers are Registered Radiation Protection Technologists (National Registry of Radiation Protection Technologists), and technical oversight is always provided by Certified Health Physicists (American Board of Health Physics).

  • Plexus-NSD is able to provide turn-key service that includes both planning (e.g., decommissioning plans, decommissioning funding plans, work plans, quality assurance plans, sampling plans, etc., as required) and execution (e.g., facility/site characterization, decontamination, demolition, performance/documentation of final status surveys, preparation of regulatory submittals, etc.).

  • Plexus-NSDhas experience in managing teams of companies that provide all of the expertise necessary to complete decommissioning and decontamination projects successfully.

  • Plexus-NSD has a long list of references available for review and we are widely-recognized by both state and federal regulatory agencies for our technical and management skills.

  • Plexus-NSD's deliverables and work products always withstand the toughest regulatory and legal scrutiny.

  • Plexus-NSD's commitment to effective communications and status reporting ensures the customer is always aware of the progress on the project.

  • Plexus-NSD possesses a radioactive materials license that permits the possession of any radioactive material, in any quantity, for any purpose (subject to agency work plan approval), anywhere throughout the United States via interstate reciprocity.

  • Plexus-NSD maintains a base level of $1 million of pollution liability insurance, with the ability to include project-specific riders for any additional amounts that are necessary.

Plexus-NSD's 'Cost-Conscious D & D Program' permits us to mobilize rapidly to your site and to always hit the ground running . . . which means your start-up time is kept to a practical minimum. And there is no need for you or your staff to take the time to update or generate in-house procedures or amend existing licenses if the work is being performed under the terms of Plexus-NSD's license. Furthermore, Plexus-NSD remains responsible for the work of all subcontractors used on the project, which frees you and your staff from a dedicated (real-time) oversight effort.

Plexus-NSD's 'Cost-Conscious D & D Program' will give you a single point of contact - the project manager - for the entire work effort, meaning you do not have to coordinate multiple services and/or firms. And Plexus-NSD will agree to perform decommissioning or decontamination projects for a single fixed price, allowing you to budget for the work before it even starts. Finally, Plexus-NSD will provide and document all training, monitoring, safety (including industrial hygiene), and quality assurance services necessary to protect you from regulatory and/or legal challenges.

If you are facing a small decommissioning or decontamination effort, if you are on a tight budget or an even tighter schedule, if you want to know what the project is going to cost before it starts, and if you want to be sure the spirit as well as the letter of all applicable regulations and documentation demands are met, you will definitely want to consider Plexus-NSD's 'Cost-Conscious D & D Program'.

For more information about the program, to discuss a site-specific approach, or to receive a listing of satisfied customers, simply Contact Us. An Plexus-NSD Certified Health Physicist will work with your to provide you with whatever additional information you need, and/or to schedule an Initial Consultation.

Our skilled project management and cost-estimating capabilities, our ability to tap a host of pre-qualified ancillary services, our in-depth understanding of regulatory requirements, our willingness to perform the work on a fixed-price basis, and our successful experience to date are all a part of Plexus-NSD's 'Cost-Conscious D & D Program'. Call us to find out if this is the answer for your organization!

 

Initial Consultation

Before investing money in the services of a consultant, Plexus-NSD invites prospective clients to take advantage of our Initial Consultation on radiological, industrial hygiene, environmental or general compliance issues as a way of getting to know us and the quality of work we do. During a consultation with one of our Certified Health Physicists or Certified Industrial Hygienists, which takes place at your site and lasts for up to four hours, we will discuss the current status of the facility's involvement in the issue at hand, the facility's relationship with federal and state regulatory agencies, review relevant data and information, and, if appropriate, do a brief walk-over of the plant/facility. At the completion of the on-site visit, you will receive a letter report of findings, a summary of alternative actions, a recommended "action plan", and a cost estimate for implementing the plan.

There is a good chance that the Initial Consultation alone will provide you with a sufficiently comprehensive solution to whatever the matter might be . . . meaning that no further work by Plexus-NSD on this issue is necessary. In any event, there is never an obligation to contract Plexus-NSD for additional work after the Initial Consultation is complete.

Plexus-NSD urges management, environmental, and health/safety personnel at facilities facing radiological, environmental, regulatory or enforcement issues to consider the benefits of the our Initial Consultation and the valuable strategic information that it provides. The cost of this service is only $500.  In return, you will receive useful information, you will have an opportunity to evaluate the professionalism of Plexus-NSD's staff and deliverables, you will have guidance on where to go next in order to address the problem or issue at hand, and you will walk away with a full understanding of what it will cost to get there.

If you are considering the services of a firm like Plexus-NSD, and if you believe our Initial Consultation would be helpful in your decision-making process, Contact Us. An Plexus-NSD Certified Health Physicist will work with you to provide you with whatever additional information you need, and/or to schedule your on-site.

 

Land Area Survey Program (Final Status & Verification Surveys)

The last time you surveyed five acres of land, it took three people a week to prepare maps, lay out grids, develop procedures, train personnel and make the measurements. Then after the data were acquired, you spent another week re-writing field records and entering data into spreadsheets. After that came the campaign to chase down all of those transcription errors.  Only then were you able to scan through the spreadsheet, look to see where measurement results were elevated, try to figure out the dimensions of the impacted area and then try to re-locate that spot for remediation a few weeks later.

There is a better way for those same five acres to be surveyed with greater precision, with no transcription errors and by only one person in less than a half of a day.  Its called the Plexus-NSD Land Area Survey Program (LASP). This comprehensive and cost-effective system for assessing residual radioactivity in open land areas covers more ground and collects more data than conventional survey procedures by far. It also presents the data in readily-repeatable and easy-to-understand and interpret formats, with quality assurance provisions that withstand even the toughest of regulatory or legal scrutiny.

The Plexus-NSD LASP is a multi-component program that starts with specially-equipped radiation detectors linked to a global positioning system (GPS) for precise data acquisition. No maps or grids are required, yet the readings can be located and re-located to within six (6) inches anywhere on the earth's surface. Position, time and radiation instrument read-outs are acquired once each second and then safely stored away for later processing. At all times an experienced operator remains aware of the survey objectives and can quickly determine if a specific criterion has been exceeded or if site conditions demand a closer look.

When the on-site work is done, the masses of data that were captured are transferred directly into a computer-based Geographical Information System (GIS) that displays them in tabular form for easy statistical analysis.  It also provides the results in map form over photographic images of the property that is easier to understand than a hand-drawn survey map with few recorded data points that are connected by only marginally-representative isodose lines. There are no data losses and no transcription errors throughout the process.

The final and the most important component of the LASP is that survey design, objective-setting, data acquisition and final reporting are performed by individuals that are heavily credentialed (CHP and RRPT) and with many years of experience in not only radiation surveys but regulatory and legal requirements, and quality assurance. The final product you receive will not only meet your original objectives, but will be compatible with applicable regulatory drivers.

The Plexus-NSD LASP offers maximum survey coverage at a fraction of the cost of conventional survey techniques, yet it comes with the strict quality standards and the technically-defensible interpretation that facility owners and their regulators demand. It is an invaluable tool that can pay for itself quickly when applied to the following:

  • Characterizing large land areas

  • Performing final status surveys after land area remediation

  • Providing independent verification/validation data of areas that have already been surveyed and staged for release or

  • When a comprehensive assessment of site conditions is needed immediately

Its time to say goodbye to traditional radiation survey methods with their excessive cost and their data presentations that leave interpretation open to the eye of the beholder. Before you decide how you are going to address your next land area survey, we invite you to Contact Us to see how the LASP can exceed your outdoor area survey expectations at a fraction of the cost of the alternatives. Our Nuclear Services Division is standing by to tell you more about fast, accurate and easily-interpreted radiation surveys from the LASP.  And if you know how much land you need to have surveyed, they would be glad to give you a firm, fixed price for the entire package!

 

Now that the “former Plexus-NSD” has joined forces with Plexus Scientific Corporation (Plexus), our joint capabilities have expanded significantly, and we’re proud to have a much larger and more diverse pool of professional talent.  Where previously Plexus-NSD provided radiation-related consulting and services, and subcontracted the non-radiological services we so often needed, we no longer need to do that, and the result is a more efficient and cost-effective delivery system!

We are pleased to offer quite a number of non-radiological services to our valued clients and visitors to this web site.  Plexus has a long history of providing environmental support services, remediation services, and more to government agencies and commercial facilities.  We have successfully completed hundreds of multi-phase, multi-discipline projects that involved investigation, design, remedial action, long-term monitoring, and various combinations of these.  Our seasoned and credentialed staff have cutting-edge experience with hazardous, toxic, radioactive, and munitions contaminants in groundwater, soil and sediment.  The following are just a few examples of the services Plexus provides:

  • CERCLA and RCRA Investigations and Feasibility Studies

  • Groundwater evaluations, management and remediation

  • Remediation methods for multimedia contaminated sites

  • Land area (soil) investigation and remediation

  • Environmental assessments

  • Soil gas and vapor intrusion surveys and studies

  • Contaminated soil removal and disposal

  • Evaluation and optimization of legacy remediation systems

  • Operation and Maintenance of remediation systems

  • Regulatory analysis and consulting

When it comes to remediation, Plexus doesn’t follow the crowd.  Instead, innovative solutions that are technically sound, legally defensible, and cost effective are standard practice.  Here are just a few examples of what differentiates us from the competition:

  • Skilled at practical application of new and emerging remediation technologies

  • Successful reduction of client risk and improved budget certainty using performance-based contracts

  • Able to improve corporate images through our history of achieving green and sustainable goals for our remedial systems

  • Able to reduce current life-cycle costs by optimizing legacy remediation systems

  • Driven towards and successfully meeting objectives for regulatory site closure

 

Plexus employs strategies that integrate innovative technology, regulatory feasibility and economic practicality into sustainable solutions that are consistent with client objectives, community needs and environmental protection.  We are confident that any non-radiological issues one might be facing can be addressed and resolved with the same attention to quality and customer service as the “former Plexus-NSD” has provided over the years.

If you or your organization are interested in learning more about the broad-based and experienced perspective that Plexus can bring to your team, please take a look at our “Why Plexus” brochure.  We would also be pleased to provide you with a list of satisfied customers who will attest to our capabilities.  Simply Contact Us to find out if Plexus has answers for you!

Non-Radiological Services

Nuclear (Level, Density, Fill, Thicnknes) Gauge Support Services

Nuclear gauges are handy devices used to monitor a production process or ensure quality control. Many types are in use today, including those designed to measure thickness, density, level, moisture and volumetric flow. Some of them are portable, and others are mounted at a fixed location.  Some are used in areas that are inhospitable to people - such as in tanks or other dangerous locations - and others are critical to high-tech measurement and analytical operations.  However, all of these types have one thing in common . . . each contains a sealed source of radioactivity that requires some level of regulatory control (i.e., either a specific or a general license from a federal or state agency to purchase, possess and use the device).

If you or your firm own a nuclear gauge or two, you are probably aware of the flury of attention they have been receiving from regulators (see the January, February and March 2009 editions of the Plexus-NSD e-Newsletter). And if you do not have a specific license to possess and operate your gauge (i.e., you purchased your gauge under the provisions of a 'general license'), you may soon be invited (i.e., ordered) to apply for a radioactive materials license (see the August 2009 edition of the e-Newsletter).  The bottom line is that nuclear gauges, as effective and advantageous as they are, are coming under increasing regulatory scrutiny, which means greater compliance pressure on their owners.

You and your firm may be well-suited to address these new challenges.  Or like others, you may have limited in-house resources to turn to. Perhaps you are counting on your plant engineers, environmental managers, or technician staff with other responsibilities to schedule, perform, document and defend functions such as radiation surveys, source accountability, training, annual program audits, sealed source leak testing, sealed source physical inventory, posting confirmation, instrument quality control, and report preparation/distribution.  You may also expect these personnel to stay up-to-speed on compliance-related issues, perform all of the necessary compliance services consistently and effectively at all of your plants and work sites, identify and report non-standard radiological issues or those that could trigger regulatory intervention, and ensure scheduled compliance activities are completed on time and effectively . . . all while doing the rest of the work  they were originally hired to do.  In any event, compliance with gauge use requirements may present a challenge to your limited organization

On the other hand, failure to understand and comply with the rules and regulations for nuclear gauge use is not an option.  One ramification might be a Notice of Violation from your regulator.  (Yes, even general licensees can be the beneficiary of a NOV!)  Another might be a fine or civil penalty.  A third might be action to keep you from purchasing or using nuclear gauges in the future.  In all cases, there is a good chance you will be subject to some bad press and increased potential for legal action by employees or neighbors.

To avoid these troubles and more, you might be interested in Plexus-NSD's 'Nuclear Gauge Compliance Program', developed and implemented over 10 years ago by individuals who are Certified by the American Board of Health Physics and Registered by the National Registry of Radiation Protection Technologists.  The Plexus-NSD program is tailor-made for nuclear gauge users with tight health/safety/compliance budgets, limited in-house support staff, and the desire to maintain a program that is as technically- and legally-sound as as it needs to be. With Plexus-NSD on your team, you will have:

  • An effective, implementable and streamlined license is in place that meets the letter of the law without obliging you to unnecessary commitments (or we'll help you get such a license)

  • A radiation protection program that guarantees the safety of employees, visitors and contractors

  • Routine ambient radiation and contamination survey data that covers all of your radiologically-restricted areas (i.e., locations where fixed nuclear gauges are in use)

  • Access to instruments that are calibrated and used appropriately

  • Physical inspection and leak testing of all of your sealed radiation sources on the schedule specified in your license

  • Initial and refresher Authorized User training for those individuals responsible for supervising the use of nuclear gauges at your facility

  • Verification that all gauge use areas and storage locations are posted and labeled appropriately

  • All of the necessary reports and documents required by your radioactive materials license and applicable regulations

  • A password-protected web page, set up and maintained for you, where all of the documents and records associated with your program, including Device Registrations, operations manuals, leak test certificates, survey results, program audit reports and more, are never more than a click away

Plexus-NSD's 'Nuclear Gauge Compliance Program' lets our clients demonstrate to the satisfaction of regulators and to any legal challenge that all of the obligations of their license, whether specific or general, are being done on time and exactly as required.  The following are just a few of the benefits:

  • Automatic scheduling of all compliance-related tasks, so they never miss a deadline

  • Documented evidence that every one of their gauges is confirmed to be present and accounted for at least twice per year

  • Leak testing of all eligible sealed sources

  • A solid understanding of the radiation exposure environment where their gauges are located, whether in active use or in storage, so they can assure employees and visitors they are safe

  • The individual with responsibility for safe operation of  their gauges is fully trained and has immediate access to a team of senior-level radiation protection professionals in the event an issue or question arises

  • Every record needed to demonstrate compliance with applicable regulations is at their fingertips, with no hunting through file cabinets, calling on former employees, etc

  • A staff of Certified Health Physicists and Registered Radiation Protection Technologists to answer their every question and assist them with every gauge-related challenge

If Plexus-NSD's 'Nuclear Gauge Compliance Program' sounds like it might provide you with relief from escalating regulatory demands, just give us a call at (240) 631-8990 or Contact Us.  We would be glad to answer any questions you might have, talk with you about your own gauge program and what requirements you might be facing, and provide you with a firm, fixed price for doing everything right by participating in our 'Nuclear Gauge Compliance Program'. We will also provide you with references who will attest to the quality and effectiveness of our services.  There is, of course, no cost or obligation associated  with either the initial consultation or our firm, fixed-price quotation. However, we're pretty sure you will be pleasantly surprised at how inexpensive and easy it is to achieve confidence in your own nuclear gauge program once it meets the letter as well as the spirit of the law.

 
 

Oversight Service

On occasion, companies embark on large radiation-related projects, such as environmental monitoring programs, remediation activities, major waste disposal operations, area or facility decommissioning, including release for restricted or unrestricted use, or regulatory/legal challenges. They then find, after the project gets underway, that it is difficult to determine whether cost/schedule commitments are being met, that decision-making has become complicated, or that the path to successful completion is not clear. These are not uncommon circumstances, particularly when the problem/solution is unique to the company's operations, when the company has limited technical and project management expertise 'in house', and when full-service environmental firms (or a large collection of subcontractors) have been tasked with achieving the solution.

No company likes to 'fly blind' into big dollar projects, since small errors in judgement or a weakly-formulated decision can quickly translate into significant cost over-runs, regulatory liability, bad press, and possible legal consequences. On the other hand, what company can afford to dedicate a valued staff member to monitoring and understanding the project, especially if there are limited radiological resources available within the company?

It is for this reason that Plexus-NSD is pleased to provide its oversight service. Plexus-NSD has the qualifications, experience and communications skills to quickly understand the fundamentals of the problem and its proposed solution. On the company's behalf, we monitor the status of large and complicated projects in light of objectives and client-generated specifications, provide insights and interpretations as issues of controversy arise, monitor complicated subcontractor interactions to ensure all are working towards a common goal, coordinate and expedite the work of individuals with specialty expertise, recommend supplemental expertise when project resources are found to be deficient, track the quality of data generated and work performed, assist in decision-making, and facilitate technical discussions between the company and the project team. If brought on-board well-before the start of the project, Plexus-NSD is also available to assist with specification development, bid reviews, and reference checks. Because Plexus-NSD has no financial stake in the project's scope and execution, we serve as an independent extension of your own organization. Our goal is nothing more than using our own expertise to be sure your company's objectives are being met.

As well as providing stand-alone oversight services, Plexus-NSD can also be used to augment in-house project management capabilities. In this case, companies can call on us on an 'as needed' basis to address one or more technical or regulatory disputes, prepare 'white papers', audit the status of a deliverable, provide data validation and verification, serve as an independent "final status survey" contractor, or simply explain or lay out the pro's and con's of a tricky implementation issue. This role can be particularly important when unanticipated conditions arise and the project's scope and schedule are being impacted. When the issue has been resolved, Plexus-NSD's job is done. There is never any further obligation.

If you are interested in instituting independent oversight of an existing or pending project, simply Contact Us. An Plexus-NSD Certified Health Physicist will work with you to provide you with whatever additional information you need, we well as an estimate of the cost of the desired services.

 

Most regulatory agencies require licensees to provide individual monitoring programs to personnel that have the potential to incur a radiation dose above a set annual limit - typically 500 millirem.  Some licensees wish to monitor their radiation workers anyway, regardless of the dose potential.  In any case, there is more to setting up an external dosimetry program than just hanging "badges" on applicable employees.  The following are just a few programmatic issues that need to be taken into account:

  • Determining what you are monitoring your employees for (i.e., beta/gamma radiation, low/high-energy x-rays, neutrons or some combination)

  • Selection of the correct badge type (e.g., , film, TLD, optical dosimeter, track etch detector, etc.)

  • Determining the correct badge placement (e.g., extremities, eyes, torso, under/over shield, etc.)

  • Setting the monitoring frequency to minimize "missed dose" (i.e., weekly, monthly, quarterly, annually)

  • Ensuring the dosimeters themselves and the processing protocols are accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) in the applicable exposure categories

  • Setting procedures for deployment/retrieval, use and storage of dosimeters

  • Setting action levels for 'early notification' from the dosimeter processor

  • Verifying/validating processing results before they are entered as a 'dose of record'

  • Developing a dose reporting program that is in compliance with regulations, informative to employees and protective of personal information

  • Training all monitored personnel in the requirements of the program and their right to measurement results

  • Developing and implementing procedures to investigate anomalous results, lost/damaged dosimeters or over-exposures

  • Making sure everything associated with the monitoring program is performed on time and exactly as specified

 

There are a number of commercial firms that provide dosimeter processing services.  However, these are typically designed to satisfy the needs of large-scale consumers (i.e., those with hundreds or thousands of monitored employees as opposed to just a handful) and thus lack in the flexibility needed for small-scale programs.  Fortunately, there is an alternative that takes into account all of the aforementioned programmatic considerations but on a budget that even the smallest company can afford.

Plexus-NSD is pleased to offer 'Personnel Monitoring Services' that are designed for licensees that need to monitor only a few individuals, that have non-routine deployment durations, that even have one-time use requirements, or that just want to save money.  Our programs can be customized to specific needs yet remain even more cost-competitive than having to force-fit your requirements into the service protocols offered by  the large processors.  Of course the Plexus-NSD program is based upon the use of NVLAP-accredited dosimeters and processing methods in the exposure categories applicable to your operations, and our results are made immediately available to you via a password-protected web site.  The web site also serves as a repository of information that is always at your fingertips in the event of management or regulatory query.

If you think Plexus-NSD's 'Personnel Monitoring Services' just might relieve you of the time and energy required to design and implement a technically-defensible external dosimetry program that meets all regulatory and license requirements, simply Contact Us and an Plexus-NSD Certified Health Physicist will work with you on your monitoring requirements, which portions of the program you would like for Plexus-NSD to perform - we can schedule/deliver dosimeters and processing only or implement an entire program, soup to nuts! - and provide you with a firm, fixed price for the entire package. There is, of course, no cost or obligation associated with our quotations, and we believe you will find our costs to be amazingly competitive - with plenty of 'value added' and a guarantee of tight quality control.  So if you have only one person  you need to place onto a quarterly monitoring program, four people that require monitoring on an 'every two month' exchange period, or a one-time deployment of 50 dosimeters to support a special project, consider Contacting Us for your personnel monitoring needs.  Our many satisfied customers who have been relying on our services for many, many years can attest to the quality and reliability of our services.

Personnel Monitoring Services (External Dosimetry programs)

 

Procedure Development

Any facility that uses radioactive materials or radiation-producing machines must be able to describe to regulators, management, and employees the way in which radiation safety will be assured. This is typically accomplished by creating and documenting a Radiation Protection Program Plan.

For small licensees whose work with radioactive materials doesn't change significantly over time or is limited to just a few tasks in a few locations (i.e., the use of level gauges, radio-luminescent exit signs, or x-ray diffraction units), the Radiation Protection Program Plan can be a stand-alone document that contains all regulatory and license commitments, and the procedures that will be followed to ensure those commitments are met. The Radiation Protection Program Plan is then attached to the radioactive materials license or permit, by reference, so that both the licensee and its regulatory authority have a clear picture of commitments and obligations.

For programs of broader scope or for operations that are dynamic in nature, the Radiation Protection Program Plan serves primarily as a policy document that is used to guide the function of the radiation safety organization and the generation of a comprehensive package of implementing procedures. A solid technical basis, compliance with regulatory requirements, good inter-procedure integration, and implement-ability are the keys to success for this type of documentation.

If you are in the process of applying for a license or permit to use radioactivity or rad-producing machines, or if your existing radiation protection program needs a bit of a "face lift" to bring it up to speed with new requirements and/or improve its cost-effectiveness, the Plexus-NSD fixed price radiation protection program development service may be of interest to you. The first step in the process is an exchange of information, where Plexus-NSD learns what you want to do, where you want to do it, and what constraints your program will have. From there, we will generate a draft Radiation Protection Program Plan that will be forwarded to you for review and comment. Once all comments have been resolved, you will receive the final Radiation Protection Program Plan in a form that is ready for signatures and duplication. You will also receive an electronic version of the Radiation Protection Program Plan to facilitate future revisions.

Plexus-NSD prepared Radiation Protection Program Plans are in widespread use by USNRC and Agreement State licensees. They contain exactly the amount of information required to meet the necessary objectives - no more, no less. Typically, the following programmatic elements are addressed, to a greater or lesser degree, depending upon the scope of the program:

  • Radiation Protection Organization and Administration

  • Facilities and Equipment

  • Training in Radiation Protection

  • Radiation Exposure Control

  • Control of Radiological Work

  • ALARA Program

  • Contamination Control

  • Instrumentation

  • Surveillance

  • Posting

  • Receipt and Control of Radioactive Material

  • Packaging and Transportation of Radioactive Materials

  • Control of Radioactive Waste

  • Radiation Protection Records

  • Documentation

  • Emergency Response and Notifications

  • Periodic Program Review

 

If one or more implementing procedures are necessary, Plexus-NSD draws from our existing stock that have already been tested for regulatory acceptance, ease of use, and technical defensibility. Once again, after an initial exchange of information, procedures will be tailored to your specific operation(s) and forwarded to you for review and comment. Once all comments have been resolved, you will receive the final version of each procedure in paper as well as electronic form. Just a few of the procedure topics that can be quickly customized for your program are:

  • Air Sampling

  • ALARA Program

  • Building/Structure Surveys

  • Contamination Control

  • Control of Radiological Work (including the Radiation Work Permits)

  • Control of Radioactive Waste

  • Control of Radiation Safety Procedures

  • Definitions

  • Emergency Response and Notifications

  • Exposure Control

  • External Exposure Monitoring

  • Final Status Surveys

  • Health and Safety Planning

  • Instrument Rental

  • Instrumentation

  • Internal Exposure Monitoring

  • Land Area Surveys

  • Packaging and Transportation of Radioactive Material

  • Quality Assurance Audits and Periodic Program Reviews

  • Radiation Protection Records

  • Radiological Areas and Posting

  • Receipt, Handling and Identification of Radioactive Material

  • Sample Collection

  • Sealed/Bulk Radiation Source Handling

  • Smear, Swab and Filter Counting

  • Stop Work Authority

  • Subcontracting and Purchases

  • Surveillance

  • Tailgate Safety Training

  • Training and Qualifications of Radiation Protection Personnel

  • Training in Radiation Protection

 

When asked to prepare a Radiation Protection Program Plan or implementing procedure, Plexus-NSD does not re-invent the wheel with every request. Instead we use existing, field-tested methods that have withstood the scrutiny of regulatory authorities, and tough legal challenges. Because each Radiation Protection Program Plan or implementing procedure is built upon "off the shelf" products whose development costs have long ago been recovered, we are able to offer this service at a fraction of the cost of in-house procedure development.

If you are interested in a Radiation Protection Program Plan for implementing procedures, simply Contact Us. An Plexus-NSD Certified Health Physicist will work with you to provide you with whatever additional information you need or a fixed-price cost for performing the work you require.

 

Program Reviews (Audits)

There are a number of reasons why a company might wish to have an independent (outside) review or audit of its in-house radiation safety program. One reason might be the old "can't see the forest for the trees" problem, where program developers are too close to the day-to-day operations to fairly evaluate the big picture. Another reason might be a desire for fresh insights into programmatic efficiency. It might be a recent staffing change where a fresh look at your program can facilitate the transition to new personnel. Or it might be to simply use the findings of an independent review to demonstrate compliance with federal and state periodic review requirements for licensees.

Plexus-NSD is pleased to offer an independent program review service. On a fixed-price basis, Plexus-NSD will perform and document a technical evaluation and/or a compliance evaluation of your entire radiation protection program, or some specific aspect of the program (i.e., dosimetry, waste management, environmental monitoring, training). The evaluation may, or may not include, at your discretion, an on-site visit and first-hand observations.

The first step in the process is an exchange of preliminary information about your operations, upon which programmatic objectives (e.g., technical, regulatory, legal) will be determined. (For compliance reviews, Plexus-NSD has pre-prepared checklists to facilitate the completion of this step.) From there, Plexus-NSD then reviews applicable programmatic documentation and other information that you wish to have taken into account, to determine whether the objectives have been met. A draft report of findings, to include an introduction (Purpose, qualifications of reviewer(s), personnel interviewed, documents reviewed, and areas visited), a review summary (Approach, Observations, Recommendations), and a list of findings, will then be prepared and forwarded to you or your legal counsel for review and comment. Once all outstanding comments have been resolved, bound copies of the final report will be forwarded to you for your records.

If you are interested in having an independent technical or compliance review of your program, Contact Us. An Plexus-NSD Certified Health Physicist will work with you to provide you with whatever additional information you need or a fixed-price cost for completing the review

 

Radiation Monitoring & Action Plan

In December of 2000, the Pennsylvania Department of Environmental Protection (PaDEP) promulgated regulations requiring monitoring for radiation and radioactive materials (25 Pa. Code 273, 277, 279, 281, 283, 284, 288, 289, 293, 295 and 297). The State has also prepared a companion guidance document,"Final Guidance Document on Radioactivity Monitoring at Solid Waste Processing and Disposal Facilities" (PaDEP Document Number: 250-3100-001).  While your facility may not intentionally receive or treat radioactivity as part of your in-house operations, if you are classified as one of the following, you may nonetheless be required to comply with the new State rules:

  • Municipal/construction/demolition waste landfills (25 Pa. Code Ch. 273 and 277)

  • Resource recovery and municipal waste transfer or reprocessing facilities (25 Pa. Code Ch. 279 and 283)

  • Commercial municipal waste composting facilities that receive sewage sludge or unseparated municipal waste, or both (25 Pa. Code Ch. 281)

  • Commercial infectious or chemotherapeutic waste processing facilities (25 Pa. Code Ch. 284)

  • Noncaptive residual waste landfills, disposal impoundments, transfer facilities, composting facilities, incinerators, or other noncaptive processing facilities (25 Pa. Code Ch. 288, 289, 293, 295 and 297)

 

A number of Plexus-NSD's clients (i.e., recycling firms, solid waste facilities, materials processors, etc.) have already been advised by the PaDEP that they must (1) screen incoming loads for the presence of radioactivity, and (2) have a PaDEP-approved 'Radiation Monitoring and Action Plan' for their waste or recycling streams . . . and we are hearing from more of them every day!

For your information, a 'Radiation Monitoring and Action Plan' required by the State must contain several sections. These include but are not limited to the following:

  • Management Responsibilities

  • Radiation Detection Equipment and Initial Procedure

  • Designated Storage Area

  • Action Levels

  • Follow-Up Actions

  • Determination of Origin

  • Disposition and/or Storage of radioactive material

  • Training for facility staff

  • Procedures for surveying

  • Posting suspect containers

  • Program Oversight

  • Periodic Plan Review and Update

  • Records of surveys

 

However, as with most regulator-mandated activities, there is usually more than one way of achieving the necessary level of compliance without expending any more resources than are absolutely necessary. For example, many facilities have purchased, installed and are maintaining some fairly expensive radiation detection equipment at their entrance gates as part of their own 'Radiation Monitoring and Action Plan'. In some cases, this level of oversight is warranted due to the volumes and types of materials that  are being received and handled.  However, most facilities within the State have no need for such a comprehensive approach.  They would be much better served by the use of small-scale equipment an easy-to-implement procedures.

If your facility is located in Pennsylvania and you are required to prepare such a 'Radiation Monitoring and Action Plan' - but you are looking to keep the cost of the entire process to a practical minimum! - we hope you will consider contacting Plexus-NSD. Because we have already prepared 'Radiation Monitoring and Action Plans' for a number of Pennsylvania facilities, including equipping them with the necessary instrumentation and training their employees in what needs to be done to stay within the letter of the law, we are able to do the same for others in a highly cost-effective manner. All we would need from you is a description of your operation and the types of materials you typically receive. (If you have written acceptance criteria for these materials in place that you give to your suppliers, all the better!) From there we will prepare a 'Radiation Monitoring and Action Plan' that is appropriate for the scale of your operations, and make sure you understand why and how each step is performed. We will also assist you in resolving any issues raised by the PaDEP during the approval process.

However, if your facility is not located in Pennsylvania but you nonetheless have concerns about inadvertently receiving unwanted radioactive materials from others, a 'Radiation Monitoring and Action Plan' might be just the ticket for you as well.  In your case, Plexus-NSD would focus on guidance promulgated by your own State agency as input to your plan, along with standard industry monitoring and recording practices, and proven cost control methods as we address your needs.

If you are considering Plexus-NSD's 'Radiation Monitoring and Action Plan' special service, simply Contact Us. An Plexus-NSD Certified Health Physicist will work with you to provide you with a firm, fixed price for taking care of this problem for you  - in its entirety.  There is, of course, no cost or obligation once we deliver our proposal to you . . . but when you compare what Plexus-NSD offers to the cost and effort of completing the work using in-house resources, we think you will be pleasantly surprised.

 

Radiological Support for the Oil and Gas Industry 

The oil and gas (O&G) industry performs conventional and unconventional drilling procedures through various subsurface layers of rock to produce oil and natural gas. Produced water, flowback water, drill cuttings and off-gas sources that come from the process contain naturally occurring radioactive material, or NORM, to a greater or lesser degree. The isotope Ra-226, which is naturally-occurring and exhibits greater mobility in the environment than other NORM isotopes, has been identified in samples of these production streams.

In 2013, the Commonwealth of Pennsylvania, Department of Environmental Protection (DEP), initiated a field study to identify the types and quantities of naturally occurring radioactive materials (NORM) being encountered in the oil and gas industry in support of possible future regulatory action. Specifically, the DEP is interested in understanding radioactivity levels in drill cuttings (vertical and horizontal), natural gas and oil processing pipes and equipment, waste water generated at drilling sites, and in the sludge produced during waste water processing in order to determine the type and magnitude of regulatory control and oversight that is required. They are equally interested in the potential for transfer of NORM-bearing materials from production sites to publicly owned treatment works (POTWs), centralized waste treatment (CWT) facilities and zero liquid discharge (ZLD) facilities for processing.

Some of Plexus-NSD’s clients have already been contacted by the DEP for the purpose of investigation NORM levels, and we are hearing from more of them every day. Others have not yet been contacted, but they are nonetheless wanting to get ahead of the game by understanding whether NORM is present at their sites and to what degree. Still others that do not have production sites in Pennsylvania, are concerned that their State may soon mount similar initiatives. In all cases, the O&G industry in general wishes to understand and pre-plan for potential future liabilities and increased regulatory influence.

If you are an oil or gas producer in the State of Pennsylvania that has been contacted by the DEP, if you are interested in whether you have radiological issues of significance at your production sites, and if you are interested in keeping the cost of these issues to a practical minimum, we hope you will consider contacting Plexus-NSD. The following are just a few of the support services we can provide:

  • Plexus-NSD can provide technically defensible “shadow” measurements while the State is at your property that can be used to confirm or counter, as applicable, the State’s findings.

  • Plexus-NSD can cost-effectively characterize the radiological constituents at your site and determine whether they have the potential to radiologically impact your employees or the surrounding population.

  • Plexus-NSD can assist you in collecting and analyzing samples for radiological constituents, including the preparation of specifications for laboratories, selecting State-approved laboratories for the analyses, monitoring the status of the samples as they make their way through the laboratory, and providing you with an interpretation of the analytical results that is written in a way that is easy to understand.

  • Plexus-NSD can provide hazard communication training in radiation and radioactivity to your on-site staff, answer any questions they might have about radioactivity in the workplace, and ease their concerns about radiation-related issues.

  • Plexus-NSD can prepare written procedures for working safely at NORM sites that include standard industry monitoring and recording practices, and proven cost control methods.

  • Plexus-NSD can provide waste characterization, profiling and disposal services for NORM that is eligible for disposal within the State of Pennsylvania. If not eligible, we can prevent suitable and cost-effective alternatives.

  • Plexus-NSD can facilitate technical discussions with regulators and work closely with your safety and management personnel to ensure they fully understand all of the relevant issues.

  • Plexus-NSD's operations have been certified to the ISO 9001:2008 international quality standard, which speaks to the quality of our work and our attention to customer service.

 

The presence of NORM at oil and gas production facilities is not new, although increasing aggressive state regulation and control over the NORM aspects of these operations is fairly recent. Chances are more likely than not that your facility will be asked to participate in a State-sponsored investigation, that one or more of your employees will become concerned as they hear more about NORM at production facilities in the local news media, or that your waste processing site will contact you because a gate monitor their site “alarmed” when a vehicle carrying your waste passed through. These are all easily handled situations, as long as the handling is well-managed.

If you are considering Plexus-NSD’s services, simply Contact Us and an Plexus-NSD Certified Health Physicist would be glad to talk with you more about the issues, our experience at dealing with the issues, or work with you to provide you with a firm, fixed price for taking care of the problem for you - in its entirety. There is, of course, no cost or obligation once we deliver our proposal to you . . . but when you compare what Plexus-NSD offers to the cost and effort of doing nothing or completing the work using in-house resources, we believe you will be pleasantly surprised.

 

An important Special Service that Plexus-NSD provides is radioactive waste brokerage, wherein we assist our clients in transporting radioactive waste and contaminated items from their site to a processing facility for subsequent disposal.  And while there are a number of competing brokers throughout the country, Plexus-NSD's service differs from theirs because we are not tied to specific waste packaging (containers), processes, modes of transport or disposal sites.  As a result, each contract is "tailor-made" for the generator and at the lowest cost available at the time of the project.  Most important is the fact that our clients can count on demonstrable quality in Plexus-NSD's service because our operations and procedures have been certified to the ISO 9001:2008 international quality standard, and they are audited by an independent third-party once per year.

Plexus-NSD's Nuclear Services Division personnel are experienced with shipping and arranging for transport and disposal of by-product material, NORM waste, sealed sources, demolition waste, mixed wastes and a host of others.  We hold a Tennessee Department of Environment and Conservation (TDEC) License for Delivery (No. T-TN055-L06), we maintain significant liability and transportation insurance coverage, and all of our shippers/brokers hold the necessary certifications for preparing and offering waste shipments for transport.

When contacted by clients about disposing of radioactive waste or other unwanted materials, we are not driven towards 'disposal for a fee at all costs'.  If available, other alternatives such as re-cycle/reuse, risk-based release and others are presented for client consideration.  And if there is no commercial disposal alternative, as in the case of unwanted sealed radiation sources, our services consist of registering the sources for acceptance by the Off-Site Source Recovery Project where there is no disposal fee.

Every now and then, our competition - with their 'one size fits all' services - is able to offer a lower cost than Plexus-NSD. Most of the time, however, Plexus-NSD is able to secure significant cost reductions by simply thinking outside the box, looking for opportunities that are sometimes fleeting, and evaluating all of the options. So before you sign your next purchase order for waste brokering services, we invite you to Contact Us to see if we can give you more for your money.  If not, you will know it right away; if so, you will come out ahead! Our Nuclear Services Division is standing by to tell you more about our waste brokering services, and to give you a firm, fixed price quote for a solid technical solution to disposing of your staged waste or materials.

Waste Transport and Disposal