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{{Adams
{{Adams
| number = ML13064A091
| number = ML003739603
| issue date = 02/28/1979
| issue date = 01/31/1981
| title = Radiation Safety Surveys at Medical Institutions
| title = Radiation Safety Surveys at Medical Institutions
| author name =  
| author name =  
| author affiliation = NRC/OSD
| author affiliation = NRC/RES
| addressee name =  
| addressee name =  
| addressee affiliation =  
| addressee affiliation =  
Line 10: Line 10:
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = RG-8.023
| document report number = RG-8.23 Rev 1
| document type = Regulatory Guide
| document type = Regulatory Guide
| page count = 14
| page count = 14
}}
}}
{{#Wiki_filter:U.S. NUCLEAR REGULATORY  
{{#Wiki_filter:Revision 1 Jaonia1y 11 U.S. NUCLEAR REGULATORY COMMISSION
COMMISSION
                                REGULATORY GUIDE
February 1979 REG ULATO RY G U [ D 0j"E OFFICE OF STANDARDS  
                              OFFICE OF STANDARDS DEVELOPMENT
DEVELOPMENT
                                                            REGULATORY GUIDE 8.23 RADIATION SAFETY SURVEYS AT MEDICAL INSTITUTION
REGULATORY  
GUIDE 8.23 RADIATION  
SAFETY SURVEYS AT MEDICAL INSTITUTIONS


==A. INTRODUCTION==
==A. INTRODUCTION==
Paragraph  
Surveyst are a necessary supplement to personnel monitoring, which measures individual radiation exposures Paragraph 20.201(b) of 10 CFR Part 20, "Standards for                 by the use of devices worn by the workers (Refs. 4, 6, 12, Protection Against Radiation," requires that each licensee                14. and 16.
20.201(b)  
of 10 CFR Part 20, "Stand-ards for Protection Against Radiation," requires that each licensee make or cause to be made such surveys as may be necessary for him to comply with the regu-lations in Part 20. As used in Part 20, the term "sur-Surveys t are a necessary supplement to personnel monitoring, which measures individual radiation ex-posures by the use of devices worn b, the workers (Refs. 3, 5, 6, 8, and 9).C. REGULATORYAPOSITI
N, vey" means an evaluation of the radiation hazards Methods and procedureI
uuide are accept-incident to the production, use, release, disposal, or able to the NRC staff4r estab,1jshJmg acceptable sur-presence of radioactive materials or other sources of vey programs in aceordane wrlT the as low as is rea-radiation under a specific set of conditions.


This sonably achievnbep ( RApq'hilosophy.
make or cause to be made such surveys as may be necessary for that licensee to comply with the regulations in Part 20.


Generally, guide identifies the types and frequencies of surveys medical instituti n's icenseod by the NRC should have that are acceptable to the NRC staff for use in medi- a health,(s cs a Aivailable for consultation to de-cal institutions licensed by the NRC to use radioac- sign -surv'IT\-
==C. REGULATORY POSITION==
p am appropriate to the institution's tive materials for purposes of diagnosis, therapy, or usei dioa&1 tie material.research.Tgý pesaf Surveys
As used in Part 20. the term "'survey" means an evaluation of the radiation hazards incident to the production, use.                    Methods and procedures in this guide are acceptable to release, disposal, or presence of. radioactive mate'rials or            the NR( staff for establishing survey programs in accord other sources of radiation under a specific set of conditions.            ance with the as low as is reasonably achievable (ALARA)
    This guide identifies the types and frequencies of surveys               philosophy. Generally, medical institutions licensed by thc that are acceptable to the NRC staff for use in medical.                  NRC should have a health physics staff available for consul institutions licensed by the NRC to use radioactive materials            ration to design a survey program appropriate to the for purposes of diagnosis, therapy, or human research institution's use of radioactive material. Nothing in this involving the administration of radioactive materials or                guide should be construed to preclude or discourage the
*  radiation to patients or the use of radioactive materials for patient services.
 
design of survey programs containing provisions other than those in this guide, when such programs are accepted by the NRC licensing staff as providing ALARA exposure conditions for a particular institution.


==B. DISCUSSION==
==B. DISCUSSION==
1tý Gineral Description Surveys are considered to be part of a comrr reen- Surveys performed in compliance with §20.201 of sive protection program established by iceln l 10 CFR Part 20 should include those necessary to consistent with the philosophy and princil),les of eg- evaluate external exposure to personnel, surface con-ulatory Guide 8.10, "Operating Philosoph
1. Types of Surveys Surveys are considered to be part of a comprehensive                1.1      General Description protection program established by the licensee consistent with the philosophy and principles of Regulatory Guide 8.10,
4or 1 in- tamination levels, and concentrations of airborne taining Occupational Radiation Exposures A ,w As radioactive materials in the facility and in effluents Is Reasonably Achievable. " rinciples, methods, and from the facility.instrumentation for carryiie.g iut radiation and con- Environmental monitoring is beyond the scope of tamination surveys we!d(e: ped early in the this guide. However, the radiation safety program atomic energy progriar.
                                                                                Surveys performed in compliance with §20.201 of
  "Operating Philosophy for Maintaining Occupational
                                                                          10 CFR Part 20 should include those necessary to evaluate Radiation Exposures As Low As Is Reasonably Achievable."
                                                                          external exposure to personnel, surface contamination (Ref. 1). Principles, methods, and instrumentation for levels, and concentrations of airborne radioactive materials carrying out radiation and contamination surveys were in the facility and in effluents from the facility.
 
developed early in the atomic energy program and have been discussed in reports of the National Council on Environmental monitoring is beyond the scope of this Radiation Protection and Measurement (Refs. 2-9), the guide. However, the radiation safety program should International Atomic Energy Agency (Refs. 10-14), and the include surveys or records that indicate control of the International Commission on Radiological Protection quantities of radioactive material released in air and water (Refs. 15-17). Other publications (Refs. 17- 34) contain addi to unrestricted areas as required by Part 20. In miny tional information for use in establishing radiation survey medical institutions, surveys of effluents or calculations to programs and selecting methods and equipment for their ensure that permissible concentration limitsare not exceeded implementation.                                                       are included as a regular part of the health physics survey t
                                                                              The word "survey," often used synonymously with "survefl lance," "monitoring," or "area monitoring," is used in this guide to connote the jpes*oa          inspection of vsulouS locations in a facility
    0
      "Lines indicate substantive changes from the February 1979 ver    using radioactive materials, with or without accompanying ments, to determine the effectiveness of measures to protectmeasure sion that was issued for public comment.                                                                                                      against exposure to radiation.
 
USNRC REGULATORY GUIDES
                                                                        Comments should be sent to the Secretary U.S. Nuclear Regulatory Commission,                  of the Commission, Regulatory Guides are Issued to describe and make available public methods acceptable to the NRC staff of implementing      to the Attention: Docketing and Service Branch. Washington, D.C. 20555, specific parts of the Commission's regulations, to delineate niques used by the staff in evaluating specific problems        tech  The guides are Issued in the following tan broad divisions:
                                                            or postu lated accidents or to provide guidance to applicants. Regulatory Guides are noi substitutes for regulations, and compliance            1. Power Reactors                        6. Products them Is not required. Methods and solutions different from        with 2. Research and Test Reactors            7. Transportation out in the guides will be acceptable if they provide a basisthose set  3. Fuels and Materials Facilities 8. Occupational Health findings requisite to the issuance or continuance of a        for the 4. Environmental and Siting              9. Antitrust license by the Commission.
 
Permit or  5. Materials and Plant Protection 10. General and Financial Review Comments and suggestions for improvements in these guides              Copies of issued guides may be purchased at the current Government are encouraged at all times, and guides will be revised, as appropriate,  Printing Office price. A subscription service for future guides in spe to accommodate comments and to reflect new information                cific    divisions is available through the Government Printing Office.
 
experience. This guide was revised as a result of substantive      or Information      on the subscription service and current GPO prices may ments received from the pu 'ic and additional staff review.      com  be obtained by writing the U.S. Nuclear Regulatory Washington, D.C- 20555. Attention: Publications Sales        Commission, Manager.
 
program. Often these calculations may he made by estimat                Surveys are not acceptable for routine compliance with ing the amotints of radioactive material washed down                the personnel monitoring requirements of §20.202. How designated sinks and dividing them by the quantities                ever, in the event of accidental loss of personnel dosimetry of sewage released from the hospital, as indicated on the            data. e.g., as a result of losing the dosimeter or chemical or hospital's water or sewage bills. This procedure normally            physical damage to the dosimeter, the best alternative suffices to show compliance with the effluent limits of              means of estimating the exposure may be to use survey dllat Part 20. Amounts of radioactive material released in air            in conjunction with appropriate occupancy factors. In such within hospitals or exhausted to the outside from hospitals          case, the estimate, including the survey data used. should bh are generally small, but these amounts may sometimes be              documented      and      retained  indefinitely  (see  para estimated by calculational techniques if not by air-monitoring      graph 2 0. 4 01(c)(2)tii)). Survey results should be reviewed procedures.' Appendix A to this guide describes surveys to          carefully by the Radiation Safety Officer to identify be made of radioactive xenon-I 33 releases.                          potentially hazardous situations and unfavorable trends.
 
Radiation protection programs should include the types          1.3    Measurements of Radioactive Material Concentrations of surveys discussed belo
 
====w. In Air====
1.2    Surveys of External Radiation Exposure Levels                    It may ofterr be sufficient in medical institutions to show by calculation, together with monitoring of ventilation Areas to he surveyed should include any locations where          rates, that air concentrations are well below levels that individuals may be exposed to -radiation intensities that            would require routine air sampling. However. concentrations might cause the occupational radiation dose to exceed                of radioactive material in air should be measured at tre-,
10 percent of the limits of paragraph 20.101(a) in any              qucncics described in Section ('.2 and specified in Table 1 calendar quarter or where an individual is working with any          for areas where operations could at any time expose workers radiation source that could produce radiation levels greater        to 10 percent or more of the concentration values given in than 1.0 mR/h at 1 meter. These areas typically include              Table 1. Column I. of Appendix B to 10 CFR Part 20.
 
shipping and receiving areas: radionuclide laboratories              Special requirements for such monitoring may also be made in nuclear medicine; diagnostic areas in nuclear medicine;          a condition of the license.
 
intracavilary .source preparation areas in radiation therapy;
patients' rooms where treatments are given with intracavi                Air samples obtained in accordance with §20.103 tary. interstitial, or radiopharmaceutical therapy sources;          should be representative of the air in the workers' breathing operating rooms, control (console) areas for teletherapy            zones. In cases where breathing zone sampling is not accom equipment rooms; waste packaging and disposal areas;                plished, air samples taken outside the breathing zone
.radiation instrument calibration areas; and any other areas        closer to the source, where the concentration of radioactive where persons might be exposed (e.g., areas occupied by            material can be or is expected to be equal to or greater than technologists, nursing staff, visitors. patients. or any other      the concentration in the breathing zone. are acceptable.
 
persons who may be exposed to radioactive materials                When measuring the quantity of radioactive 'material handled by others).                                                deposited on an air sample filter. corrections should he made for absorption of alpha or beta particles by the filter Preoperational, routine, and special surveys of these            media and by material collected on the filter. [he quantity areas should be performed by the radiation protection staff        of air that has passed through the filter should be accurately as described in Section C.2 of this guide. Results of these        measured and corrections made for any loss of flow rate surveys should be recorded as described in Section (.3. In          caLised by the accumulation of material on the filter.
 
addition to thisý survey program, the Radiation Safety Officer should institute and maintain a program of surveys              Continuous breathing zone or general air sampling performed by workers other than health physics personnel            should be conducted while the work is in progress unless who may be exposed to external radiation levels that could          experience with sample* results or calculations has demon exceed any of the limits of paragraph 20.101(a). Surveys by        strated that the concentration of radioactive material in such workers may consist of no more than occasional                the breathing zone is not likely to exceed 25 percent of the instrument. observations during work with radioactive'              values given in Table I, Column 1, of Appendix B to materials. These personal surveys are particularly appropriate      10 CFR Part 20. The use of personal (lapel) samplers is in nuclear medicine activities. Personnel should he properly        acceptable for breathing zone sampling. If the air sanipl instructed in conducting such surveys and should perform            ing is not continuous, the frequency and the times selected the surveys each day during and after work with radioactive        for the sampling should be based on the nature of the nmaterials, as necessary to determine the need to limit            process involved and the probability that the airborne worktime and to use protective procedures to reduce expos          radioactive material will be present. When assessing this ures as far below the paragraph 20.101(a) limits as is              probability is difficult, frequencies based on information reasonably achievable. The survey results obtained by these        given in Section ('.2 and Table I of this guide are accept workers need not be recorded. However, the Radiation                able.
 
Safety Officer should maintain records to show that the appropriate training for, and implementation of, the worker        1.4    Surface Contamination Surveys survey program has been provided and is a continuing part of the survey program. Workers should be instructed to report              Regular surveys for radioactive contamination that could unusual survey findings to the Radiation Safety Officer.            be  present on surfaces of floors, Walls, furnishings. and
                                                              8.23-2
 
equipment are a necessary part of the survey program. Any                d. Sample,    background,  and test counts and times, surveys carried out in accordance with NRC license condi                      and tions will be considered consistent with the level of safety provided by recommendations in this guide.                                e. Signatures and dates at the bottom of each page.
 
Control of surface contamination is necessary to limit            Provision should also be made on the diagram for recording external dose rates and the resuspension in air of loose              an instrument check with an appropriate check or calibra radioactive materials that may enter the body through                tion source for each batch of smear samples counted.
 
inhalation, ingestion, or skin absorption.


andtlhave been discussed in should include surveys or records that indicate con-reports of the Nafjonai loounc on Radiation Protec- trol of the quantities of radioactive material released tion and Meabure 'ent,_,1(1-RP) (Refs. 1-3), the In- in air and water to unrestricted areas, as required by ternational
The surveys discussed above are regularly scheduled and
' y Agency (IAEA) (Refs.4-8), and thf Iýiternational Commission on Radiolog- The word "survey,'
      1.4.1 Removable Contamination                                    recorded on the survey diagrams. In addition, it may be necessary to conduct more frequent, informal, and unre For the purposes of this guide. removable contamination          corded surveys in nuclear medicine areas or other areas means radioactivity that can be transferred from a surface            where loose radioactive contamination may occur. Such to a snmear test paper by rubbing with moderate pressure.            surveys can be made with a thin-end-window (less than Information is available on the selection and use of instru          2 mg/cm 2 ) detector held close to a dry smear sample ments for performing removable surface contamination                  immediately after it is taken in the work area. When ambient surveys appropriate to the radionuclides used in medlical            external radiation levels in the laboratory are low enough to institutions (Refs. 2, 4-7, 10, and 13). Methods and instru          maintain external radiation exposures below the limits of ments used in surface contamination surveys should be                paragraph 20.101(a), any appreciable surface contamination sufficiently sensitive to detect the nuclides being monitored        can be detected by simply holding the detector in a fixed (Refs. 22 and 25). For optimum detection of low-energy                position and moving the smear sample close to and away beta emitters (e.g., 11-3 and C-14)as well as of alpha emitters      from the detector several times. This method may be used and low-energy x- or gamma-ray emitters (e.g., 1-125),                 for the vast majority of radionuclides used in diagnostic and liquid scintillation counting or internal proportional count          therapeutic medical practice.
often used synonymously with "'surveil- ical Protection
&!CRP) (Ref. 9). More recent reports lance," "monitoring,''
or "area monitoring," is used in this (uide to connote the personal inspection of various locations in (Refs. 10-14) contain additional information for use a facility using radioactive materials, with or without accom-in establishing radiation survey programs and select- panying measurements, to determine the effectiveness of meas-ing methods and equipment for their implementation.


ures to protect against exposure to radiation.
ing is normally necessary with the use of appropriate constancy checks on counter efficiency.                                    Part 20 does not specify limits for surface contamination.


USNRC REGULATORY
Each applicant may propose and justify the levels of remov The collection of smear samples may be preceded by a            able surface contamination that will be allowable before rapid survey with a portable thin-end-window detector in              decontamination. must be performed. These limits should order (a) to ensure that gross contamination levels are not            be based on the need to avoid transfer of significant already too high for counting with sensitive equipment,              amounts of contamination to unrestricted areas and to (b) to minimize (in some cases) the chance for inadvertent            maintain exposures as low as is reasonably achievable. The spread of con tainination by the contamination survey' or            contamination limits for restricted areas presented on line 2 other activities to be performed in the meantime, and (c) to          of Table 2 of this guide are acceptable to the NRC staff and determine which areas require greater attention in smear              need not be justified by the licensee or applicant.
GUIDES Regulatory Guides are issued to describe and make available to the public methods acceptable to the NRC staff of implementing specific parts of the Commission's regulations, to delineate techniques used by the staff in evalu-ating specific problems or postulated accidents, or to provide guidance to applicants.


Regulatory Guides are not substitutes for regulations, and com-pliance with them is not required.
testing. The instrument used for this purpose should (a) have a short enough time constant to facilitate detection or (b) be provided with a speaker for aural indication of                  1.4.2 Fixed Contamination count-rate.


Methods and solutions different from those set out in the guides will be acceptable if they provide a basis for the findings requisite to the issuance or *continuance of a permit or license by the Commission.
For the purposes of this guide, fixed contamination A standardized method for smear testing of a relatively          means radioactivity remaining on a surface after repeated uniform area should be used in order to allow comparison              decontamination attempts fail to significantly reduce the of relative levels of contamination at different times and             contamination level. A total contamination survey using places. A dry smear taken from an area of about 100 cm 2 is          instruments suitable for the radionuclides involved should acceptable to indicate levels of removable contamination.              be conducted simultaneously with each removable conthm ination survey. The applicant may propose and justify the A layout diagram for each laboratory routinely surveyed          levels of total contamination that will be allowable for -both is helpful for recording survey results in a uniform manner restricted and unrestricted areas before decontamination to aid review and observation of trends and for satisfying            must be performed. The limits appearing on lines I and 2 of regulatory requirements for availability of survey records.            Table 2. multiplied by a factor of 5, are acceptable to the On these diagrams, it is helpful to specify key locations that NRC staff and need not be justified by the licensee or are smear tested at each survey and also to provide space applicant.


Comments and suggestions for improvements in these guides are encouraged at all times, and guides will be revised, as appropriate, to accommodate com-ments and to reflect new information or experience.
reminding the recorder to include:
                                                                      1.5    Protective and Personal Clothing Contamination a. Contamination levels converted        to  radioactivity              Surveys units specified in 10 ('FR Part 20,
                                                                          Individuals working in areas where a potential for skin or b. Make and model number of the instruments used in clothing contamination exists should be provided with the survey and in counting the smear samples, suitable protective clothing. Laboratory coats and protective gloves, as described in References 5 and 6, are usually c. Disintegration rate of each instrument test or calibra adequate for any procedures in medical institutions. Protec tion source.                                                tive clothing should be surveyed by the wearer after use if
                                                              8.23-3


However, comments on this guide, if received within about two months after its issuance, will be particularly useful in evaluating the need for an early revision.Comments should be sent to the Secretary of the Commission, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Attention:
significant contamination is possible. Contaminated protec          direction of Radiation Safety Office personnel or a medical live clothing should be removed and placed in special                consultant should be repeated until (a) such attempts cease laundry containers before leaving a restricted work area.            to effect significant reductions or(b) such attempts threaten Disposable gloves should be discarded in radioactive waste          to irritate or harm the skin. 2            When decontamination containers. After gloves are removed, hands should- he              attempts are terminated, there should le no further concern washed and surveyed.                                                if the residual contamination does not exceed preselected levels. Such levels may be proposed and justified by the When protective clothing contamination levels may be            applicant or licensee. The limits given on line 5 of Table 2 expected to exceed preselecled limits, workers should be             will be accepted without justification. If residual contani instructed to take care to avoid dispersal of contamination        ination exceeds the selected limits, the affected individual and to report the situation to the Radiation Safety Office.         may be released (since his contamination is now rela A member of the radiation safety staff should then make            tively fixed and not likely to enier the body), but periodic surveys and supervise any necessary decontamination or              surveys should be made until the limits are no longer clothing disposal. The applicant may propose and justify            exceeded. The resulting dose should be determined and protective clothing contamination limits considered adequate        entered in the individual's personnel dosimetry record.
Docketing and Service Branch.The guides are issued in the following ten broad divisions:
1. Power Reactors 6. Products 2, Research and Test Reactors


===7. Transportation===
for use in each restricted area. The limits on line 4 of           Complete records should be maintained of each incident of Table 2 are acceptable to the NRC staff and need not be            this nature.
3. Fuels and Materials Facilities
8. Occupational Health 4. Environmental and Siting 9. Antitrust and Financial Review 5. Materials and Plant Protection
10. General Requests for single copies of issued guides (which may be reproduced)
or for placement on an automatic distribution list for single copies of future guides in specific divisions should be made in writing to the U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Attention:
Director, Division of Technical Information and Document Control.


Part 20. In many medical institutions, surveys of effluents or calculations to ensure that permissible concentration limits are not exceeded are included as a regular part of the health physics survey program.Often these calculations may be made by estimating the amounts of radioactive material washed down des-ignated sinks and dividing them by the quantities of sewage released from the hospital, as indicated on the hospital's water or sewage bills. This procedure nor-mally suffices to show compliance with the effluent limits of Part 20. Amounts of radioactive material re-leased in air within hospitals, or exhausted to the out-side from hospitals, are generally small but may sometimes be estimated by calculational techniques if not by air-monitoring procedures.
justified by the licensee or applicant.


Appendix A to this guide describes surveys to be made of radioactive xenon-133 releases.Radiation protection programs should include the types of surveys discussed below.1.2 Surveys of External Radiation Exposure Levels Areas to be surveyed should include any locations where individuals may.be exposed to radiation inten-sities that might cause the occupational radiation dose to exceed 10 percent of the limits of paragraph 20.101(a)
Since medical personnel may often handle open vials or Contamination levels observed and procedures followed          containers with millicurie or higher levels of volatile forms during the survey and decontamination of personal clothing          of certain nuclides such as 1-125 or 1-131, which in certain should he recorded. The written record should include the           forms may concentrate in the thyroid or other body organs, names of persons surveyed, a description of prior work              bioassay monitoring is sometimes made a condition of the activities, the probable causes, steps taken to reduce further      license. Acceptable criteria for such programs are published incidence of contamination, times and dates, and the                in Regulatory Guides 8.20, "Applications of Bioassay for surveyor's signature. This information may be entered in a          1-125 and 1-131," and 8.26, "Applications of Bioassay for logbook. Workers' surveys of themselves need not be                Fission and Activation Products." Additionally, guidance routinely recorded unless the limits on line 4 of T'able 2          on bioassay monitoring is available from the Material are exceeded. The radiation safety staff should conduct              Licensing Branch, Office of Nuclear Material Safety and spot checks monthly to ensure that the workers continue            Safeguards. In addition to these programs, placing the their own personal contamination surveys.                           detector against the neck close to the thyroid is often useful for monitoring for internal deposition of these In restricted areas with little potential for surface          nuclides during surveys for skin contamination; however, contamination, personal clothing is often worn beneath              for I-I 25, a thin-crystal scintillation probe would be needed protective clothing. Such personal clothing should be              to obtain adequate sensitivity. In this way, appropriate surveyed by the wearer before he or she leaves the restrict        personnel may be more frequently monitored for internal ed area. (Ilowever, this is neither practicable nor necessary      exposure while they are also being monitored for external for employees working with only microcuric quantities of           contamination. Any positive indications of exposure or tritium or carbon-14.)      Workers should be instnrcted to        contamination from these types of surveys should be report the situation to the Radiation Safety Office when            recorded in the radiation safety logs. Indications of internal personal clothing contamination levels exceed preselected          depositions should be reported to the Radiation Safety limits. A member of the radiation safety staff should then          Office.
in any calendar quarter or where an indi-vidual is working with any radiation source that could produce radiation levels greater than 1.0 mR/h at 1 meter. These areas typically include shipping and re-ceiving areas; isotope laboratories in nuclear medicine;
diagnostic areas in nuclear medicine;
in-tracavitary source preparation areas in radiation ther-apy; patients'
rooms where treatments are given with intracavitary, interstitial, or radiopharmaceutical therapy sources; operating rooms: control (console)areas for teletherapy equipment rooms; waste pack-aging and disposal areas; radiation instrument cali-bration areas; and any other areas where persons might be exposed (e.g., areas occupied by technologists, nursing staff, visitors, patients, or any other persons who may be exposed to radioactive materials handled by others).Preoperational, routine, and special surveys of these areas should be performed by the radiation pro-tection staff as described in Section C.2 of this guide.Results of these surveys should be recorded as de-scribed in Section C.3. In addition to this survey pro-gram, the Radiation Safety Officer should institute and maintain a program of surveys performed by workers other than health physics personnel who may be exposed to external radiation levels that could ex-ceed any of the limits of paragraph
2 0.101(a).
Sur-veys by such workers may consist of no more than occasional instrument observations during work with radioactive materials.


These personal surveys are par-ticularly appropriate in nuclear medicine activities.
make surveys and gupervise any necessary decontamination or clothing disposal. The applicant or licensee may propose        1.7    Surveys of Equipment Prior to Release to Unrestricted and justify personal clothing contamination limits; the                    Areas limits given on line 3 of Table 2 are acceptable to the NR("
staff and need not be justified by the applicant or licensee.            Before the uncontrolled release of potentially contam Records should be maintained in the same manner as those            inated medical instruments or equipment from restricted to for protective clothing contamination.                              unrestricted areas, surface contamination surveys should be conducted on such instruments and equipment for both
1.6 Personal Surveys                                              removable and fixed contamination. If contamination is detected, decontamination procedures should be instituted Alt.hough personal contamination in excess of the value        and repeated until additional efforts do not significantly given on line 5 of Table 2 is unusual in medical institutions,      reduce contamination levels. The applicant or licensee may individuals who work in restricted areas under conditions in        propose and justify total and removable contamination which they may become contaminated should survey all                limits below which uncontrolled release of equipment is exposed areas of the body before donning personal clothing          permitted. The limits given in Table 3 of this guide, as
                                                                      2 or leaving (he restricted area. Particular attention should be          Decontamination attempts without supervision or instruction paid to the hody, hair, bottoms of the shoes or feet, anti          from the licensee's medical consultant should be restricted to washing with mild soap and water unless other safe procedures have the hands. Workers should be instructed to report the              already been approved and personnel have been properly instructed dcleclion of contamination on the body to the Radiation            in using them. If such attempts do not reduce the contamination to acceptable levels, the aid of the licensee's medical consultant should Safety Officer. l)econtamination attempts under the                be obtained.


Personnel should be properly instructed in conducting such surveys and should perform the surveys each day during and after work with radioactive materials, as necessary to determine the need to limit worktime and to use protective procedures to reduce exposures as far below the paragraph
8.23-4
20. 101(a) limits as is rea-sonably achievable.


The survey results obtained by these workers need not be recorded.
I adapted  from Table I of Regulatory Guide 1.86, "Termina            on which these instruments depend for operation should tion of Operating Licenses for Nuclear Reactors," are                also be tested to ensure that they will function reliably in acceptable to the NRC staff and need not he justified by              normal operations or as expected under emergency condi the licensee or applicant. Decontamination guidelines are            tions. Care should be taken to minimize exposure to available from the Material Licensing Branch. Office of              personnel from the tests themselves. Any signs, labels, or Nuclear Material Safety and Safeguards.                              notices found to be missing should be promptly provided.


However, the Radiation Safety Office should maintain records to show that the appropriate training for, and implemen-tation of, the worker survey program has been pro-vided and is a continuing part of the survey program.Workers should be instructed to report unusual sur-vey findings to the Radiation Safety Officer.Surveys are not acceptable for routine compliance with the personnel monitoring requirements of§20.202. However, in the event of accidental loss of personnel dosimetry data, e.g., as a result of losing the dosimeter or chemical or physical damage to the dosimeter, the best alternative means of estimating the exposure may be to use survey data in conjunc-tion with appropriate occupancy factors. In such case, the estimate, including the survey data used, should be documented and retained indefinitely (see paragraph
Temporary signs, signals, or barriers, together with appro
20.401(c)(2)(ii)).
  1.8 Ingestion                                                        priate worker notification and instruction, may be used in the interim when items specified in Parts 19 and 20 are not Surveillance should be included in the radiation safety          available, but acceptable corrections should be provided as program to ensure that workers properly observe rules to            soon as practicable.
Survey results should be reviewed carefully by the Radiation Safety Officer to identify potentially hazardous situations and un-favorable trends.1.3 Measurements of Radioactive Material Con-centrations in Air It may often be sufficient in medical institutions to show by calculation, together with monitoring of ven-tilation rates, that air concentrations are well below levels that would require routine air sampling.


How-ever, concentrations of radioactive material in air should be measured, at frequencies specified in Sec-tion C.2. for areas where operations could expose workers to 10 percent or more of the concentration values given in Table 1, Column 1, of Appendix B to 10 CFR Part 20. Special requirements for such monitoring may also be made a condition of the license.Air samples obtained in accordance with §20.103 should be representative of the air in the workers'breathing zone. In cases where breathing zone sam-pling is not accomplished, air samples taken outside the breathing zone closer to the source, where the concentration of radioactive material can or is ex-pected to be equal to or greater than the concentration in the breathing zone, are acceptable.
prevent ingestion of radionuclides, e.g., rules against eating, drinking, or smoking in work areas or while wearing poten              1.11 Leak Tests of Sources tially contaminated clothing. storing foods in work areas;
  pipetting by mouth; and wearing contaminated laboratory                  Sealed sources containing (a) more than 100 inicrocuries coats to the cafeteria or other unrestricted areas. Water            of a byproduct material with a half-life of more than fountains close to work areas where radioactive materials            30 days (except iridium-192 seeds encased in nylon ribbon)
are used should be smear tested regularly.                            (see paragraph 35.14(bX5)) or (b) more than 10 micro curies of an alpha emitter (see paragraph 31.5(cX2Xii))
  1.9    Surveys of Packages Received and Packages Prepared            must be leak tested for contamination or leakage at inter for Shipment                                                  vals not to exceed 6 months unless a different interval is specified for a particular manufactured source under the External radiation measurements and tests of external            provisions of paragraph 32.74(b) of I OCFR Part 32, "Speci surfaces of packages received or packaged for shipment                fic Domestic Licenses to Manufacture or Transfer Certain
"should be carried out near the receiving or packaging point          Items Containing Byproduct Material." Further provisions to avoid unwarranted radiation exposures and inadvertent            and exceptions to leak-testing requirements are established contamination of personnel or the hospital. Surveys and              in paragraphs 35.14(b) and 35.14(eXl) of 10 (FR Part 35.


When measur-ing the quantity of radioactive material deposited on an air sample filter, corrections should-be made for 8. 2 3- 2 absorption of alpha or beta particles by the filter media and by material collected on the filter. The quantity of air that has passed through the filter should be accurately measured and corrections made for any loss of flow rate due to the accumulation of material on the filter.Continuous breathing zone or general air sampling should be conducted while the work is in progress unless experience with sample results or calculations has demonstrated that the concentration of radioac-tive material in the breathing zone is not likely to exceed 25 percent of the values given in Table 1, Column 1, of Appendix B to 10 CFR Part 20. The use of personal (lapel) samplers is acceptable for breathing zone sampling.
labeling must comply with the NRC's regulations (see                  Any specific license conditions must also be followed.


If the air sampling is not continuous, the frequency and the times selected for the sampling should be based on the nature of the process involved and the probability that airborne radioactive material will be present. When assessing this probability is difficult, frequencies based on in-formation given in Section C.2 and Table I of this guide are acceptable.
§§20.203. 20.205. 32.19. and 32.70 through 32.74 of
  10CFR Parts 20 and 32) and with any specific license                1.12 Calibration and 3    Source Checks of Radiation Survey conditions. Delivery of packages within the hospital should                   Instruments also be monitored. Any delivered containers of radioactive material must be labeled as required by paragraph 20.203(f).               An adequate calibration of survey instruments cannot be All packages bearing yellow II or yellow III Department of          performed with built-in check sources. Electronic calibra Transportation (DOT) labels should be transported by cart.           tions that do not involve a source of radiation are also not Only adequately shielded sources should be transported.              adequate to determine the proper functioning and response Internal containers of packages containing significant              of all components of an instrument.


1.4 Surface Contamination Surveys Regular surveys for radioactive contamination that could be present on surfaces of floors, walls, furnish-ings, and equipment are a necessary part of the sur-vey program. Any surveys carried out in accordance with NRC license conditions will be considered con-sistent with the level of safety provided by recom-mendations in this guide.Control of surface contamination is necessary to limit external dose rates and the resuspension of loose radioactive materials that may enter the body through inhalation, ingestion, or skin absorption.
amounts of radioactive materials should not be ope-ned until the containers have been placed in the appropriate                  Daily constancy checks of survey instruments should be protective facility (e.g., hood).                                    made before and after each use and should be supplemented at least every 12 months with a battery check and two-point All personnel, including security guards, should be             i-alibration (at about 1/3 and 2/3 of full scale) on each scale adequately- instructed in performing at least an initial            of the instrument to be used for radiation protection inspection survey for leakage or damage before transporting          surveys. Survey instruments should also be calibrated after any packages of radioactive materials through hospital              repair or maintenance that may affect the calibration of the areas. The written instructions should clearly indicate              instrument.


1.4.1 Removable Contamination For the purposes of this guide, removable con-tamination means radioactivity that can be transferred from a surface to a smear test paper by rubbing with moderate pressure.
which packages should be transported by cart rather than hand-carried.                                                            A survey instrument may be considered properly cali brated at one point when the exposure rate measured by
  1.10 Checks on Posting of Caution Signs, Labels, Signals,          the instrument differs from the true exposure rate by less Controls, and Notices to Employees                          than 10 percent.


Information is available on the selection and use of instruments for performing re-movable surface contamination surveys appropriate to the radionuclides used in medical institutions (Refs.1-14). Methods and instruments used in surface contamination surveys should be sufficiently sensi-tive to detect the nuclides being monitored (Refs.11-14). For optimum detection of low-energy beta emitters (e.g., H-3 and C-14) as well as of alpha emitters and low-energy x- or gamma-ray emitters (e~g., 1-125), liquid scintillation counting or internal proportional counting is normally necessary with the use of appropriate constancy checks on counter effi-ciency.The collection of smear samples may be pre-ceded by a rapid survey with a portable, thin-end-window detector in order (a) to ensure that gross contamination levels are not already too high for counting with sensitive equipment, (b) to minimize (in some cases) the chance for inadvertent, spread of contamination by the contamination survey or other activities to be performed in the meantime, and (c) to determine which areas require greater attention in smear testing. The instrument used for this purpose should have a short time constant on the order of 1 second or less to facilitate detection.
T1he radiation safety staff should perform surveillance              Each source used for calibration shouId be certified during the surveys described in Table 1 to ensure that              (Ref. 25) in radioactivity content to within 5 percent by signs, labels, radiation alarm signals, other access controls.      the supplier. Alternatively, each source may be calibrated and required Notices to Employees, copies of licenses, and
                                                                        3 other items are properly posted, legible, and operative, as             in order to keep personnel exposures ALARA, high-range scales (e.g., above I R/h) should not be calibrated when they will not be required by 10 (FR Part 11), -Notices, Instructions and            needed in a particular installation. Also, a sufficient variety of Reports to Workers- Inspections." and Part 20 or by license        instruments should be available and calibrated on all scales as needed for the types of radiation and the ranges of intensity or conditions. Radiation alarm signals should be routinely            exposure to be measured. Item 9 of Regulatory Guide 10.8 (Ref. 29)
  tested for operation by use of appropriate check sources            specifies certain types of instruments generally required in a typical nuclear medicine laboratory and information on instrumenltation to to ensure proper functioning of the alarms. Microswitches            be submitted with a license application.


A standardized method for smear testing of a relatively uniform area should be used in order to allow comparison of relative levels of contamination at different times and places. A dry smear taken from an area of about 100 cm 2 is acceptable to indicate levels of removable contamination.
8.23-5


A layout diagram for each laboratory routinely surveyed is helpful for recording survey results in a uniform manner to aid review and observation of trends and for satisfying regulatory requirements for availability of survey records. On these diagrams, it is helpful to specify key locations that are smear tested at each survey and also to provide space re-minding the recorder to include: a. Contamination levels converted to radioactiv- ity units specified in 10 CFR Part 20, b. Make and model number of the instruments used in the survey and in counting the smear samples, c. Disintegration rate of each instrument test or calibration source, d. Sample, backgrbund, and test counts and times, and e. Signatures at the bottom of each page.Provision should also be made on the diagram for recording an instrument check with an appropriate check or calibration source for each batch of smear samples counted.The surveys discussed above are regularly scheduled and recorded on the survey diagrams.
for dose rates at given distances. Each source should also be Icorrected for decay as of the day on which the source is used for survey instrument calibration. All decay corrections
                                                                          1. 15 Surveys in In-Hospital Unrestricted Areas Unrestricted areas should be surveyed periodically to should he included in the radiation safety records system. A            ensure that radiation and radioactive material are adequately posted graph for each source is convenient" helpful in                  confined in restricted areas, except in cases where these avoiding calculational errors, easily available forinspection.          inaterials must he transported between areas. Recommenda and acceptable for obtaining source intensity within the                 tions in References 4, 5, I1. and 14 should be followed required accuracy. For automatic range-changing instru                  when transporting radioactive materials or patients emitting ments or instruments with more than one decade on a                      radiation from licensed radioactive materials through logarithmic scale, a calibration near the mid range of                  hallways or other unrestricted areas of the hospital. Such each decade should be adequate. except that a two-point                  transportation should be surveyed and planned with a check should be used on at least one of the decade ranges.               member of the radiation safety staff.


In addition, it may be necessary to conduct more fre-quent, informal, and unrecorded surveys in nuclear medicine areas or other areas where loose radioactive contamination may occur. Such surveys can be made with a thin-end-window (less than 2 mg/cm 2) detector held close to a smear sample immediately after it is taken in the working area. When ambient external radiation levels in the laboratory are low enough to maintain external radiation exposures below the lim-8.23-3 its of paragraph
Readings obtained from the calibration verifications                    1.15.1  Surface Contamination Surveys should be recorded, preferably by plotting the reading on the instrument calibration curve where applicable. Other                    Removable surface contamination surveys in unrestricted instruments should be calibrated at frequencies suggested                areas in which linencapsulated radioactive materials are by Ihe manufacturer. Check sources should he used to                    used or where contamination may be likely to occur should check the continued accuracy of all instruments each time                be performed and recorded at frequencies consistent they are used in the field, preferably before and after each            with the potential for spreading contamination but no less series of measurements. (See also Regulatory Guide 10.8,                frequently than quarterly. Random smear testing of floors
20.101(a), any appreciable surface contamination can be detected by simply holding the detector in a fixed position and moving the smear sample close to and away from the detector several times. This method may be used for the vast majority of radionuclides used in diagnostic and therapeutic medical practice.Part 20 does not specify limits for surface con-tamination.
  "Guide for the Preparation of Applications for Medical                  alone is acceptable for most unrestricted areas. In cafeterias Programs" (Ref. 29).)                                                   and snack bars, furniture and equipment, as well as floors.


Each applicant may propose and justify what removable surface contamination limits will be allowable before decontamination will be performed.
should also be surveyed. If such surveys reveal that radio
  1.13 Surveys of Protective Clothing Before            and After        active contamination is being transferred out of restricted Laundry                                                          areas, immediate corrective action should be taken to eliminate such transfers. Decontamination efforts should be Surveys of protective garments and linens should be                repeated until it is evident that subequent efforts would not performed prior to release to a conventional laundry.                  significantly reduce contamination levels. If contamination Garments and linens should be released to such a laundry                is found, unrestricted areas should be surveyed more only if contamination levels do not exceed those given on                frequently (e.g., daily or weekly) until a trend of negative line 3 of Table 2.. Items contaminated with short-half-life            results is again established. The applicant or licensee may material that exceeds the levels given on line 3 of Table 2            propose and justify permissible contamination levels should be contained in leakproof bags and transported in                following decontamination efforts described above for carts to controlled storage areas for decay. Items contami              unrestricted areas. The limits given on line I of Table 2 arc nated with long-half-life material may be disposed of as                acceptable to the NRC staff and need not le justified by radioactive waste or sent for decontamination to a laundry              the licensee or applicant.


These limits should be based on the need to avoid transfer of si2nificant amounts of contamination to unrestricted areas and to maintain exposures as low as is reasonably achievable.
licensed by the N RC or by an Agreement Start.


The contamination limits for restricted areas presented on line 2 of Table 2 of this guide are acceptable to the NRC staff and need not be justified by the licensee or applicant.
1.15.2  Radiation Surveys
  1.14 Ventilation Surveys Radiation surveys in unrestricted areas adjacent to Where enclosures such as fume hoods are necessary to                restricted areas should be performed and recorded at protect workers'from unencapsulated radioactive material.              frequencies consistent with the types and quantities of measurements of the face velocity at the enclosure entrance            material in use but no less frequently than quarterly. These should be made quarterly to ensure that the airflow is                  surveys should be made in areas adjacent to restricted areas adequate.4 Such measurements should be made by using a                  and, when exposures may occur, in all areas through which properly calibrated thermoanemometer or velometer to                    radioactive materials are transferred and temporarily stored determine whether the airflow has been reduced to unaccept              before shipment. Radiation levels in these areas should be able levels by filter loading or by the malfunction of                  "evaluated to determine whether they comply with the blowers, fans, etc. The mninimum average face velocity for a            requirements of § 20.105 of 10 CFR Part 20.


1.4.2 Fixed Contamination For the purposes of this guide, fixed contamina- tion means radioactivity remaining on a surface after repeated decontamination attempts fail to signifi-cantly reduce the contamination level. A total con-tamination survey, using instruments suitable for the radionuclides involved, should be conducted simul-taneously with each removable contamination survey.The applicant may propose and justify what total con-tamination limits will be allowable for both restricted and unrestricted areas before decontamination will be performed.
fume hood with the sash in the operating position or for an opening in a special enclosure should be 100 ft/min as                  1.16 Surveillance determined from at least five different measurement points. Airflow monitoring devices such as inclined manom                  1.16.1  Surveillance by Individual Performing Surveys eters should also be available for the user to check for proper airflow during each use. Corrective action should be                The term "surveillance." as used in this section. refers to taken as soon as possible when the face velocity is found to            observations of radiological working conditions in restricted be deficient. Records should be kept of airflow measure                areas made by the person who performs the routine radia ments and any corrective actions.                                      tion and contamination surveys. Such surveillance is one of
    4 Where filtered exhausts are employed, devices such as U-tube        the more important aspects of a radiation protection pro manometers should be provided to indi~ate the pressure drop across      gram. Through surveillance, radiation safety personnel the filters, thus affording an early indication of airflow loss at enclosures.                                                            acquire detailed knowledge of e:ich operation as necessary
                                                                  8.23-6


The limits appearing on line 2 of Table 2, multiplied by a factor of 5, are acceptable to the NRC staff and need not be justified by the licensee or applicant.
(a) to identify ways of preventing or minimizing occupa                    Although the frequencies of routine surveys depend on tional exposures, (b) to select appropriate times for making            many factors, as stated above, and should be designed for radiation safety measurements, and (c) to adequately prepare            the specific medical practices and facilities involved to for emergency conditions. Radiation safety personnel should            maintain exposures as low as is reasonably achievable, be sufficiently familiar with each activity to explain it in            minimum frequencies acceptable to the NRC staff for detail, to describe potential hazards and the precautions              meeting the requirements of § 20.201 of 10 CFR Part 20
  taken to minimize exposures, and to discuss how this                    are given in Table I of this guide.


1.5 Protective and Personal Clothing Contamina- tion Surveys Individuals working in areas where a potential for skin or clothing contamination exists should be pro-vided with suitable protective clothing.
knowledge of procedures within each activity has influenced the selection of appropriate times for performing radiation safety measurement


Laboratory coats and protective gloves, as described in Refer-ences 11 and 12, are usually adequate for any proce-dures in medical institutions.
====s.     ====


Protective clothing should be surveyed by the wearer after use if signifi-cant contamination is possible.
===3. Records of Surveys===
      1.16.2    Regular Inventory of Radioactive Material, Audit of Procedures, and Instruction of Personnel.                  Reference should be made to § § 20.401 and 30.51 and to 10 CFR Parts 31-35 for recordkeeping requirements The surveillance program includes the following:                regarding surveys related to the receipt, use, packaging, transfer, and disposal of byproduct material. Section 20.401 a. Regular inventory      of radioactive materials and          requires that licensees maintain records in the same units their locations,                                                      used in Part 20 (see Table 4). Thus, external exposure rates should be recorded in estimated maximum dose equivalent b. Frequent audits of radiation safety procedures and          units to relevant parts of the body as specified in Part 20.


Contaminated protec-tive clothing should be removed and placed in special laundry containers before leaving a restricted work area. Disposable gloves should be discarded in radioactive waste containers.
the uses and amounts of material in process compared to                Air concentration measurement results should be recorded licensed possession limits, and                                        in units of pCi/ml, and surface contamination measurement results should be recorded in units of dpm/100cm 2 or c. Discussions with personnel to ensure their continued        uJCi/100cm 2 (or as in §20.5).
awareness of safety procedures and the appropriateness of their instruction and training for the tasks they are performing.          Record retention requirements are specified in the regulations cited above. Paragraph 2 0.401(cX2) requires These surveillance activities may be performed during          that survey records be preserved for 2 years, except that the performance of other survey measurements or tests.                 records of air monitoring and (in theabsence of personnel The surveillance should be performed at least annually by              monitoring data) records of surveys to determine external the Radiation Safety Officer in the presence of a manage              radiation dose (see paragraph 20.401(cX2Xii)) are to be ment representative as a management audit. The manage                  maintained until the NRC authorizes their disposition.


After gloves are re-moved, hands should be washed and surveyed.When protective clothing contamination levels may be expected to exceed preselected limits, workers should be instructed to take care to avoid dispersal of contamination and to report the situation to the Radia-tion Safety Office. A member of the radiation safety staff should then survey and supervise any necessary decontamination or clothing disposal.
ment audit should be comprehensive enough to provide management with an awareness of the nature and impor                        Records may be maintained in logbooks or on special tance of activities conducted for personnel protection and            forms as long as they are clear, legible, understandable, and hospital safety. A sample checklist that can be useful in              authenticated . by authorized personnel. Survey records auditing as well as in carrying out radiation surveys is                should include the model and serial numbers of instruments presented in Appendix B.                                              used and efficiencies of counting where appropriate. The signature of the person making the record and the date
2. Frequency of Surveys                                                should be on the same page as the record and should immediately follow each record entry. Either the original or The frequency of routine surveys depends on the nature,          a reproduced copy or microform (duly authenticated) may quantity, and use of radioactive materials, as well as the              be maintained to meet the storage requirements of § 20.401.


The applicant may propose and justify protective clothing contami-nation limits considered adequate for use in each re-stricted area. The limits on line 4 of Table 2 are ac-ceptable to the NRC staff and need not be justified by the licensee or applicant.
specific protective facilities, equipment, and procedures that are designed to protect the worker from external and                                 D.i IMPLEMENTATION
internal exposure.


Contamination levels observed and procedures fol-lowed during survey and decontamination of personal clothing should be recorded.
The purpose of this section is to provide informnation to Generally, surveys should be performed before radioac            applicants and licensees regarding the NRC staff's plan for tive materials are used in a new procedure and area in order          using this regulatory guide.


The written record should include the names of persons surveyed, a de-scription of prior work activities, the probable causes, steps taken to reduce future incidence of con-tamination, times and dates, and the surveyor's signa-ture. This information may be entered in a logbook.Individual worker surveys of themselves need not be routinely recorded unless the limits on line 4 of Table 2 are exceeded.
to establish a baseline of background radiation levels and radioactivity from natural sources, including structural com                Except in those cases in which the applicant or licensee ponents of the facility, and any already existing operations          proposes an acceptable alternative method for complying with radiation sources in nearby rooms or facilities. These            with specified portions of the Commission's regulations, the baseline surveys should be performed under the various                staff will use the methods described herein after April 1, conditions to be expected in routine hospital procedures.               1981, in evaluating applications for specific materials licenses for medical institutions or (in conjunction with Surveys should be repeated after routine procedures              inspections of performance) for evaluating survey programs begin with normal levels of radioactive material and with              established by licensees.


The radiation safety staff should conduct spot-checks monthly to ensure that the work-ers continue their own personal contamination sur-veys.In restricted areas with little potential for surface contamination, personal clothing is often worn be-neath protective clothing.
potentially exposed persons present and carrying out their functions. Surveys should also be conducted after significant              If an applicant or livensee wishes to use the method changes in the quantities of radioactive material handled, in          described in this regulatory guide on or before June 1, 1981,1 the quantities present at any one time, or in protective              the pertinent portions of the application or th. licensee's equipment or procedures.                                               performance will be evaluated on the basis of this guide.


Such personal clothing should be surveyed by the wearer before he or she leaves the restricted area. (However, this is neither practicable nor necessary for employees working with only microcurie quantities of tritium or carbon-14.)
8.23-7
Workers should be instructed to report the situation to the Radiation Safety Office when personal clothing contamination levels exceed preselected limits. A member of the radiation safety staff should then sur-vey and supervise any necessary decontamination or clothing disposal.


The applicant or licensee may pro-pose and justify personal clothing contamination lim-its; the limits given on line 3 of Table 2 are accept-able to the NRC staff and need not be justified by the applicant or licensee.
Table 1 SURVEY FREQUENCIES
  I.    All elution, preparation, and injection areas should be surveyed daily with a survey meter and decontaminated if necessary.


Records should be maintained in the same manner as those for protective clothing contamination.
2.    Laboratory areas where only small quantities of radioactive material (less than 200
                                                                                                          l.Ci at any one time) are used should be surveyed monthly.


1.6 Personal Surveys Although personal contamination in excess of the value given on line 5 of Table 2 is unusual in medical institutions, individuals who work in restricted areas under conditions in which they may become contami-nated should survey all exposed areas of the body be-fore donning personal clothing or leaving the re-stricted area. Particular attention should be paid to the body, hair, bottoms of the shoes or feet, and the hands. Workers should be instructed to report the de-tection of contamination on the body to the Radiation Safety Office. Decontamination attempts, under the direction of Radiation Safety Office personnel or a 8.23-4 medical consultant, should be repeated until (a) such attempts cease to effect significant reductions or (b)such attempts threaten to irritate or harm the skin .2 When decontamination attempts are terminated, there should .be no further concern if the residual contami-nation does not exceed preselected levels. Such levels may be proposed and justified by the applicant or licensee.
3.     All other laboratory areas should be surveyed weekly.


The limits given on line 5 of Table 2 will be accepted without justification.
4.      The weekly and monthly surveys should consist of the following- a.    A measurement of radiation levels with a survey meter sufficiently sensitive to detect
                                                                                                                    0.1 mR/h.


If residual contamina- tion exceeds the selected limits, the affected indi-vidual may be released (since his contamination is now relatively fixed and not likely to enter the body), but periodic surveys should be made until the limits are no longer exceeded.
b.    A series of smear tests to measure contamination levels. The method for performing smear tests should be suffi ciently sensitive to detect the limits in Table 2 to one significant digit.


The resulting dose should be determined and entered in the individual's personnel dosimetry record. Complete records should be main-tained of each incident of this nature.Since medical personnel may often handle open vials or containers with millicurie or higher levels of volatile forms of certain nuclides such as 1-125, 1-131, and Tc-99m, which in certain forms may con-centrate in the thyroid or other body organs, bioassay monitoring is sometimes made a condition of the license. Acceptable criteria for such programs are published in other guides and are available from the License Management Branch. In addition to these programs, placing the detector against the neck close to the thyroid is often useful for monitoring for inter-nal deposition of these nuclides during surveys for skin contamination;
c.     Any air sample measurements necessary to determine compliance with                § 20.103 of 10 CFR Part 20 in cases where calculations alone are not sufficient.
however, for 1-125 a thin crystal scintillation probe would be needed to obtain adequate sensitivity.


In this way, appropriate person-nel may be more frequently monitored for internal exposure while they are also being monitored for ex-ternal contamination.
Table 2 RECOMMENDED ACTION LEVELS FOR REMOVABLE SURFACE CONTAMINATION
                                                        IN MEDICAL INSTITUTIONS*
                                                                              Type of Radioactive Material**
                                                                                                                          Low-Risk Beta or Alph Emitters                  Beta or X-Ray Emitters                  X-Ray Emitters Type of Surface              (tICi/em2) (dpm/10Ocm 2 )          (tJCil/m 2 ) (dpm/100cm 2 )          (PjCi/cm 2 )1 (dpm/1iOcm2 I.    Unrestricted areas                      10"-            22                    10-6            220              10-s          2,200
2.    Restricted areas                        10-6          220                    10-1        2,200                10.4        22,000
3.    Personal clothing worn                  10"1            22                    10-6            220              10"s          2,200
              outside restricted areas
4.      Protective clothing worn                10-6          220                      10"5        2,200                10"4        22.000
              only in restricted areas
5.    Skin                                    106            220                    10-6          220                10s          2,200
  *OAsacapted from Table I of Reference 10. Averaging is acceptable over nonliving areas of up to 300
                                                                                                            cm2 or, for floors, wall, and ceiling, O0cm'. Averaging is also acceptable over 0 cm forskin or, for the hands, over the whole area of the hand, nominally 300cm .
**Beta- or x-ray emitter values are applicable for all beta- or x-ray emitters other than those considered low C-14, H-3, S-35, Tc-99m, and others whose beta energies are less than 0.2                                          risk. Low-risk nuctides include at I meter per curie, and whose permissible concentration in air (see to CFRMeV maximum, whose gamma-or x-ray emission iý le,.s than 0.1 R/h Part 20. Appendix B, Table I ) is greater than 10    IA.i/ml.


Any positive indications from these types of surveys should be recorded in the radi-ation safety logs. Indications of internal depositions should be reported to the Radiation Safety Office.1.7 Surveys of Equipment Prior to Release to Un-restricted Areas Before the uncontrolled release of potentially con-taminated medical instruments or equipment from re-stricted to unrestricted areas, surface contamination surveys should be conducted on such instruments and equijment for both removable and fixed contamina- tion. If contamination is detected, decontamination
8.23-8
2 Decontamination attempts without supervision or instruction from the licensee's medical consultant should be restricted to washing with mild soap and water unless other safe procedures have already been approved and personnel have been properly instructed in applying them. If such attempts do not reduce the contamination to acceptable levels, the aid of the licensee's medical consultant should be obtained.procedures should be instituted and repeated until ad-ditional efforts do not significantly reduce contami-nation levels. The applicant or licensee may propose and justify total and removable contamination limits below which uncontrolled release of equipment is permitted.


The limits given in Table I of Regulatory Guide 1.86. "Termination of Operating Licenses for Nuclear Reactors,'" are acceptable to the NRC staff and need not be justified by the licensee or applicant.
Table 3*
        ACCEPTABLE SURFACE CONTAMINATION LEVELS FOR UNCONTROLLED RELEASE OF EQUIPMENT
          Nuclidea                                    Averageb,e                      Maimumb,d                          Removablebc U-nat, U-235, U-238, and                        5,000 dpm ct/l00 cm 2            15,000 dfpm cV'100 cm 2              1,000 dpm c1 0 0 cm 2 associated decay products Transuranics, Ra-226, Ra-228,                      100 dpm/100 cm 2                  300 dpm/100 cm      2
                                                                                                                          20 dpm/100        cm 2 Th-230, Th-228, Pa-23 1, Ac-227,
1-125, 1-129 Th-nat, Th-232, Sr-90, Ra-223,                  1,000 dpm/100 cm 2                3,000 dpm/100 cm 2                    200 dpm/100 cm 2 Ra-224, U-232, 1-1.26, 1-131,
1-133 Beta-gamma emitters (nuclides                    5,000 dpm *100 cm 2            15,000 dpm BV1100 cm 2              1,000 dpm $V100 cm 2 with decay modes other than alpha emission or spontaneous fission) except Sr-90 and others noted above.


1.8 Ingestion Surveillance should be included in the radiation safety program to ensure that workers properly ob-serve rules to prevent ingestion of radionuclides, e.g., rules against eating, drinking, or smoking in work areas or while wearing potentially contaminated clothing;
Adapted from Regulatory Guide 1.86 (Ref. 30).
storing foods in work areas; pipetting by mouth; and wearing contaminated laboratory coats to the cafeteria or other unrestricted areas. Water foun-tains close to radioactivity work areas should be smear tested regularly.
  aWhere surface contamination by both alpha- and beta-gamma-emitting nuclides exists, the limits established for alpha- and beta-gamma-emitting nuclides should apply independently.


1.9 Surveys of Packages Received and Packages Prepared for Shipment External radiation measurements and tests of ex-ternal surfaces of packages received or packaged for shipment should be carried out near the receiving or packaging point to avoid unwarranted radiation expo-sures and inadvertent contamination of personnel or the hospital.
bAs used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as determined by correcting the counts per minute observed by an appropriate detector for background, efficiency, and geometric factors associated with the instrumentation.


Surveys and labeling must comply with the NRC's regulations (see §§20.203, 20.205, 32.19, and 32.70 through 32.74 of 10 CFR) and with any specific license conditions.
cMeasurements of average contaminant should not be averaged over more than I square meter.


Delivery of packages within the hospital should also be monitored.
For objects of less surface area, the average should be derived for each such object.


Any de-livered containers of radioactive material must be labeled, as required by paragraph
dThe maximum contamination level applies to an area of not more than 100 cm 2 .
20.203(f).
  eaThe amount of removable radioactive material per 100 cm 2 of surface area should be determined by wiping that area with dry filter or soft absorbent paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency. When removable contamination on objects of less surface area is determined, the pertinent levels should be reduced pro portionately and the entire surface should be wiped.
All packages bearing yellow I or yellow III labels should be transported by cart. Only adequately shielded sources should be transported.


Internal containers of packages containing significant amounts of radioac-tive materials should not be opened until the contain-ers have been placed in the appropriate protective facility (e.g., hood).All personnel, including security guards, should be adequately instructed in performing at least an initial inspection survey for leakage, or damage, before transporting any packages of radioactive materials through hospital areas. The instructions should clearly indicate which packages should be transported by cart rather than hand-carried.
Table 4"
                                CONVERSION FACTORS FROM OLD TO NEW RADIATION UNITS
Quantity                Old Unit        Symbol                New Unit            Symbol                    Conversion Factor Activity                curie              Ci                  becquerel              Bq              1 Ci= 3.7 x 1010 Bq Absorbed dose            rad                rad                gray                    Gy              I rad    IlcGy = 10.2 Gy = 10-2 J/k Dose Equivalent          rem                rem                sievert                  Sv              I rem = I cSv = 10.2 Sv Exposure                roentgen            R                                                          I R = 2.58 x 10-4 C/kg Conversion to the new SI units provided in this table will now be considered in compliance with this guidance.


1.10 Checks on Posting of Caution Signs, Labels, Signals, Controls, and Notices to Employees The radiation safety staff should perform surveil-lance at least weekly to ensure that signs, labels, 8.23-5 radiation alarm signals, other access controls, and re-quired Notices to Employees, copies of licenses, and otiier items are properly posted, legible, and opera-tive, as required by 10 CFR Part 19, "Notices, In-structions and Reports to Workers; Inspections,'" and Part 20 or by license conditions.
&823-9


Radiation alarm sig-nals should be routinely tested for operation by use of appropriate check sources to ensure proper function-ing of the alarms. Microswitches on which these in-struments depend for operation should also be tested to ensure that they will function reliably in normal operations or as expected under emergency condi-tions. Care should be taken to minimize exposure to personnel from the tests themselves.
REFERENCES*
I.    Regulatory    Guide 8.10, "Operating Philosophy for                13,  IAEA Technical Report Series No. 133, "Handbook Maintaining      Occupational Radiation Exposures As                    on Calibration of Radiation Protection Monitoring Low As Is      Reasonably Achievable,"        U.S. Nuclear              Instruments," 1971.


Any signs, labels, or notices found to be missing should be promptly provided.
Regulatory      Commission (NRC), Washington, D.C.


Temporary signs, signals, or bar-riers, together with appropriate worker notification and instruction, may be used in the interim when items specified in Parts 19 and 20 are not available, but acceptable corrections should be provided as soon as practicable.
20555.                                                              14.  IAEA Safety Series No. 25, "Medical Supervision of Radiation Workers," sponsored jointly by IAEA,
2.    National Commission on Radiological Protection                          WHO, and International Labor Organization, 1968.


1.11 Leak Tests of Sources Sealed sources containing (a) more than 100 mi-crocuries of a byproduct material with a half-life of more than 30 days (except iridium-192 seeds encased in nylon ribbon) (see paragraph
(NC-RP) Report No. 8, "Control and Removal of Radio active Contamination in Laboratories," December 15,                15. International Commission on Radiological Protection
35.14(b)(5))
        1951.                                                                   (ICRP) Publication 5, "Handling and Disposal of Radioactive Materials in Hospitals and Medical
or (b)more than 10 microcuries of an alpha emitter (see paragraph
3.     NCRP Report No. 9, "Recommendations for Waste                            Research Establishments," 1964.
31.5(b)(2)(ii))
must be leak tested for con-tamination or leakage at intervals not to exceed 6 months unless a different interval is specified for a particular manufactured source under the provisions of paragraph
32.74(b) of 10 CFR Part 32, "Specific Domestic Licenses to Manufacture or Transfer Cer-tain Items Containing Byproduct Material." Further provisions and exceptions to leak-testing require-ments are established in paragraphs
35.14(b) and 35.14(e)(1)
of 10 CFR Part 35. Any specific license conditions must also be followed.1.12 Calibration and Source Checks of Radiation Safety Instruments Portable survey instruments should be calibrated at least annually to within +/-1 0 percent (or _+/-20 percent with a calibration curve supplied)
of two points (at a minimum) at approximately
1/3 and 2/3 of each scale in order to examine readability, operability, and ac-curacy. Instruments should be calibrated with radia-tion sources of appropriate emission and intensity.


Each source used for calibration should be certified in radioactivity content to within 15 percent by the supplier, as recommended by the International Com-mission on Radiological Units and Measurements (Ref. 15), and should be corrected for decay as of the day on which the source is used for survey instrument calibration.
Disposal of Phosphorus-32 and Iodine-131 for Medi cal Users," November 2, 195 I.                                      16. ICRP Publication 12, "General Principles of Moni toring for Radiation Protection of Workers," 1969.


All decay corrections should be included in the radiation safety records system. A posted graph for each source is convenient, helpful in avoiding calculational errors, easily available for inspection, and acceptable for obtaining source intensity within the required accuracy.A calibration should be performed after each maintenance adjustment or repair, and no less fre-quently than at 12-month intervals, by exposing the instrument to an appropriate field of radiation and checking the response of the instrument at a minimum of two points near '/3 and 2/3 of full scale.The readings obtained from the calibration verifica-tion should be recorded, preferably by plotting the reading on the instrument calibration curve where ap-plicable.
4.    NCRP Report No. 10, "Radiological Monitoring Methods and Instruments," April 7, 1952 (revised                    17. [CRP Publication 25, "The Handling, Storage, Use edition published in 1978).                                              and Disposal of Unsealed Radionuclides in Hospitals and Medical Research Establishments," 1977.


Other instruments should be calibrated at frequencies suggested by the manufacturer.
5.    NCRP Report No. 37, "Precautions in the Manage ment of Patients Who Have Received Therapeutic.                    18.  American Association of Physicists in Medicine Amounts of Radionuclides," 1970.                                        (AAPM) Monograph No. 1, "Biophysical Aspects of the Medical Use of Technetium-99m," J.G. Kereiakes
6.    NCRP Report No. 48, "Radiation Protection for                            and Karen R. Corey, Editors (available from AAPM,
      Medical and Allied Health Personnel," August 1,                          Dr. James G. Kereiakes, E555 Medical Sciences
        1976.                                                                  Building, University of Cincinnati, Cincinnati, Ohio
                                                                                45267), 1976.


Check sources should be used to check the continued accu-racy of all instruments each time they are used in the field, preferably before and after each series of meas-urements. (See also Regulatory Guide 10.8., "Guide for the Preparation of Applications for Medical Pro-grams. ")1.13 Surveys of Protective Clothing Before and After Laundry Surveys of protective garments and linens should be performed prior to release to a conventional laun-dry'. Garments and linens should be released to such a laundry only if contamination levels do not exceed those given on line 3 of Table 2. Items contaminated with short-half-life material that exceeds the levels given on line 3 of Table 2 should be contained in leakproof bags arld transported in carts to controlled storage areas for decay'. Items contaminated with long-half-life material may be disposed of as radioac-tive waste or sent for decontamination to a laundry licensed by the NRC or by an Agreement State.1.14 Ventilation Surveys Where enclosures such as fume hoods are used to protect workers from unencapsulated radioactive material, measurements of the face velocity at the en-closure entrance should be made and recorded quar-terly to ensure that the airflow is adequate.3 Such measurements should be made by using a properly calibrated thermoanemometer or velometer to deter-mine whether the airflow has been reduced to unac-ceptable levels by filter loading or by the malfunction of blowers, fans, etc. The minimum average face velocity for a fume hood with the sash in the operat-I Where filtered exhausts are employed, devices such as U-tube manometers should be provided to indicate the pressure drop across the filters, thus affording an early indication of airflow loss at enclosures.
7.    NCRP Report No. 57, "Instrumentation and Moni toring Methods for Radiation. Protection," 1978.                   19. Deigl, H., "Guidelines for Determining Frequency-of Wipe Samples," in Health Physics Operational Moni
8.    NCRP Report No. 58, "A Handbook of Radio                                toring, Vol. i, C.A. Willis and J.S. Handloser, Eds.,
      activity Measurements Procedures," 1978.                                 Gordon and Breach, New York, p. 385, 1972.


8.23-6 ing position or for an opening in a special enclosure should be 100 ft/min, as determined from at least five different measurement points. Corrective action should be taken as soon as possible when the face velocity is found to be deficient.
9.     NCRP Report No. 59, "Operational Radiation Safety                  20.  C. B. Meinhold,    "Facility    Monitoring Programs, Programs," 1978.                                                        Techniques, and Problem Solving," Health Physics Operational Monitoring, Vol. 1, C.A. Willis and
10.'  International Atomic Energy Agency (IAEA) Techni                        J.S. Handloser, Eds., Gordon and Breach, New York, cal Report Series No. 120, "Monitoring of Radioac                        p.363, 1972.


1.15 Surveys in In-Hospital Unrestricted Areas Unrestricted areas should be surveyed periodically to ensure that radiation and radioactive material are adequately confined in restricted areas, except in cases where these materials must be transported be-tween areas. Recommendations in References I1 and 12 should be followed when transporting radioactive materials or patients emitting radiation from licensed radioactive materials through hallways or other unre-stricted areas of the hospital.
tive Contamination on Surfaces," 1970.


Such transportation should be surveyed and planned with a member of the radiation safety staff.1.15.1 Surface Contamination Surveys Removable surface contamination surveys in un-restricted areas in which unencapsulated radioactive materials are used or where contamination may be likely to occur should be performed and recorded at frequencies consistent with the potential for spreading contamination but no less frequently than quarterly.
21.  C.A. Willis, "Safe Specific Activity: A Useful Concept
11.    IAEA Safety Series No. 38, "Radiation Protection                        in Monitoring Areas Containing Activated Materials,"
      Procedures," 1973.                                                      Health Physics Operational Monitoring, Vol. 1, C.A. Willis and J.S. Handloser, Eds., Gordon and
12.     IAEA Safety Series No. 1, "Safe Handling of Radio                      Breach, New York, p. 373, 1972.


Random smear testing of floors alone is acceptable for most unrestricted areas. In cafeterias and snack bars, furniture and equipment, as well as floors, should also be surveyed.
nuclides," 1973 Edition, Code of Practice Sponsored by the International Atomic Energy Agency and the                  22.  R.L. Kathren, "Instruments in thi Field: Use, Abuse, World Health Organization (WHO), 1-973.                                 and Misuse," Health Physics Operational Monitoring, Vol. 2, C.A. Willis and J.S. Handloser, Eds., Gordon and Breach, New York, p. 811, 1972.


If such surveys reveal that radioactive contamination is being transferred out of restricted areas, immediate corrective action should be taken to eliminate such transfers.
23.  W.P. Howell and R.L. Kathren, "Calibration and NCRP reports may be obtained from NCRP Publications, P.O.


Decontamination efforts should be repeated until it is evident that subsequent efforts would not significantly reduce contamination levels. If contamination is found, unrestricted areas should be surveyed more frequently (e.g., daily or weekly) until a trend of negative results is again es-tablished.
Box 30175, Washington, D.C. 20014.                                             Field Use of Ionization Chamber Survey Instruments,"
    IAEA reports may be obtained from UNIPUB, Inc.. P.O. Box 433,              Health Physics Operational Monitoring, Vol. 2, New York, N.Y. 10016.


The applicant or licensee may propose and justify permissible contamination levels, following de-contamination efforts described above, for unrestricted areas. The limits given on line I of Table 2 are accept-able to the NRC staff and need not be justified by the licensee or applicant.
ICRP reports may be obtained from Pergamon Press, Maxwell                  C.A. Willis and J.S. Handloser, Eds., Gordon and House, Fairview Park, Elmsford, New York 10523.                                Breach, New York, p. 925, 1972.


1.15.2 Radiation Surveys Radiation surveys in unrestricted areas adjacent to restricted areas should be performed and recorded at frequencies consistent with the types and quantities of material in use but no less frequently than quarterly.
ICRU reports may be obtained from ICRU Publications, P.O.


These surveys should be made in areas adjacent to re-stricted areas and, when exposures may occur, in all areas through which radioactive materials are trans-ferred and temporarily stored before shipment.
Box 30165, Washington. D.C. 20014.


Radia-tion levels in these areas should be evaluated to deter-mine whether they comply with the requirements of§20.105 of 10 CFR Part 20.1.16 Surveillance
NUREG-series documents may be obtained at current rates from the Distribution Services Section, Division of Technical Information      24. F.E. Gallagher, A.N. Tschaeche, C.A. Willis, J.C.
1.16.1 Surveillance by Individual Performing Surveys The term "surveillance," as used in this sec-tion, refers to observations of radiological working conditions in restricted areas made by the person who performs the routine radiation and contamination sur-veys. Such surveillance is one of the more important aspects of a radiation protection program. Through surveillance, radiation safety personnel acquire de-tailed knowledge of each operation as necessary (a)to identify ways of preventing or minimizing occupa-tional exposures, (b) to select appropriate times for making radiation safety measurements, and (c) to adequately prepare for emergency conditions.


Radia-tion safety personnel should be sufficiently familiar with each activity to explain it in detail, to describe potential hazards and the precautions taken to minimize exposures, and to discuss how this knowl-edge of procedures within each activity has influ-enced the selection of appropriate times for perform-ing radiation safety measurements.
and Document Control, U.S. Nuclear Regulatory Commission,                      Evraets, and J.C. Rogers, "Progress on Surface Washington, D.C. 20555 or the National Technical Information Ser vice, Springfield, Virginia 22161.                                            Contamination Standards," Health Physics Opera-
                                                                    8.23-11


1.16.2 Regular Inventory of Radioactive Mate-rial, Audit of Procedures, and Instruc-tion of Personnel The surveillance program includes: a. Regular inventory of radioactive materials and their locations, b. Frequent audits of radiation safety procedures and the uses and amounts of material in process com-pared to licensed possession limits, and c. Discussions with personnel to ensure their continued awareness of safety procedures and the ap-propriateness of their instruction and training for the tasks they are performing.
tional Monitoring, Vol. 3, C.A. Willis and J.S. Hand      29. Regulatory Guide 10.8, "Guide for the Preparation of loser, Eds., Gordon and Breach, New York, p. 1767, Applications for Medical Programs,"
      1972.                                                                                               NRC.


These surveillance activities may be performed during the performance of other survey measurements or tests. The surveillance should be performed at least annually by the Radiation Safety Officer, in the presence of a management representative, as a man-agement audit. The management audit should be comprehensive enough to provide management with an awareness of the nature and importance of ac-tivities conducted for personnel protection and hos-pital safety. A sample checklist that can be useful in auditing as well as in carrying out radiation surveys is presented in Appendix B.8.23-7
30.  Regulatory Guide 1.86, "Termination of Operating
2. Frequency of Surveys The frequency of routine surveys depends on the nature, quantity, and use of radioactive materials, as well as the specific protective facilities, equipment, and procedures that are designed to protect the worker from external and internal exposure.Generally, surveys should be performed before radioactive materials are used in a new procedure and area in order to establish a baseline of background radiation levels and radioactivity from natural sources, including structural components of the facil-ity, and any already existing operations with radia-tion sources in nearby rooms or facilities.
25. Sommers, J.F., "Sensitivity of G-M and Ion Chamber Licenses for Nuclear Reactors," NRC.


These baseline surveys should be performed under the vari-ous conditions to be expected in routine hospital pro-cedures.Surveys should be repeated after routine proce-dures begin with normal levels of radioactive material and with potentially exposed persons present and car-rying out their functions.
Beta-Gamma Survey Instruments," Health Physics, Vol. 8, p. 755, 1975.                                    31.  Regulatory Guide 8.18, "Information Relevant to Ensuring that Occupational Radiation Exposures
26.   International Commission on Radiation Units and                                                                  at Medical Institutions Will Be As Low As Reasonably Measurements (ICRU) Report 12, "Certification of Achievable," NRC.


Surveys should also be conducted after significant changes in the quantities of radioactive material handled or in the quantities present at any one time or after changes in protective equipment or procedures.
Standardized Radioactive Sources," September 15,
      1969.                                                    32.  NUREG-0267, "Principles and Practices for Keeping Occupational Radiation Exposures at Medical Institu tions As Low As Reasonably Achievable," NRC, 1977.


Although the frequencies of routine surveys de-pend on many factors, as stated above, and should be designed for the specific medical practices and facilities involved to maintain exposures as low as is reasonably achievable (ALARA), minimum fre-quencies acceptable to the NRC staff for meeting the requirements of §20.201 of 10 CFR Part 20 are given in Table I of this guide.3. Records of Surveys Referenice should be made to §§20.401 and 30.51 and to 10 CFR Parts 31-35 for recordkeeping re-quirements regarding surveys related to the receipt, use, packaging, transfer, and disposal of byproduct material.
27.  Regulatory Guide 8.20, "Applications of Bioassay for
    1-125 and 1-131," NRC.                                     33. Blatz, Hanson, "Radiation Hygiene Handbook,"
                                                                    McGraw-Hill, New York, pp. 22-27, 1959.


Section 20.401 requires that licensees main-tain records in the same units used in Part 20. Thus, external exposure rates should be recorded in esti-mated maximum dose equivalent units to relevant parts of the body as specified in Part 20. Air concen-tration measurement results should be recorded in units of uCi/ml, and surface contamination meas-urement results should be recorded in units of dpm/100 cm 2 or tkCi/100 cm 2 (or as in §20.5).Record retention requirements are specified in the regulations cited abov
28. Regulatory Guide 8.26, "Applications of Bioassay for
                                                                34. Cember, Herman, "Introduction to Health Physics,"
    Fission and Activation Products," NRC.


====e. Paragraph ====
Pergamon Press, New York, pp. 334-339, 1969.
20.401(c)(2)
re-quires that survey records be preserved for 2 years, except that records of air monitoring and (in the ab-sence of personnel monitoring data) records of sur-veys to determine external radiation dose (see para-graph 20.401(c)(2)(ii))
are to be maintained until the NRC authorizes their disposition.


Records may be maintained in logbooks or on spe-cial forms as long as they are clear, legible, under-standable, and authenticated by authorized personnel.
8.23-12


The signature of the person making the record and the date should be on the same page as the record and should immediately follow each record entry. Either the original or a reproduced copy or microform (duly authenticated)
APPENDIX A
may be maintained to meet the storage requirements of §20.401.
                                      SURVEYS OF RADIOACTIVE XENON-133 RELEASES
    Surveys associated with the use of xenon-133 should be           4.     Emergency Procedures sufficient to show compliance with requirements for protection of persons in restricted and unrestricted areas                  Check to determine that all personnel using xenon-I 33 (see §§20.103 and 20.106) and with the terms and condi              have been trained in the established emergency procedures tions of the N RC Materials License. Surveys may consist of          to he followed in case of an accidental release of xenon-I133.


==D. IMPLEMENTATION==
either measuremcents of airborne radioactivity or of calcula tions supported by records of xenon-133 used and measure            5.     Air Concentrations of Xenon-133 in Restricted Areas ments of pertinent ventilation and air effluent volumes.
The purpose of this section is to provide informa-tion to applicants and licensees regarding the NRC staff's plan for using this regulatory guide.Except in those cases in which the applicant or licensee proposes an acceptable alternative method for complying with specified portions of the Com-mission's regulations, the staff will use the methods described herein after October 1, 1979, in evaluating applications for specific materials licenses for medi-cal institutions or (in conjunction with inspections of performance)
for evaluating survey programs estab-lished by licensees.


If an applicant or licensee wishes to use the method described in this regulatory guide on or before Oc-tober 1, 1979, the pertinent portions of the applica-tion or the licensee's performance will be evaluated on the basis of this guide.8.23-8 TABLE I SURVEY FREQUENCIES
The procedures outlined below are acceptable for surveying                  Check to determine that air concentrations of xenon- 133 xenon-I 33 concentrations in medical institutions.                  in restricted areas meet the requirements of §20.103. This may be done by making physical measurements. Alterna Acccptable surveys would be indicated by records of the         tively. this may be done by r'vicwing the use of xenon- 133 following information, procedures, or conditions:                    (Item L.a above), checking the ventilation rate in each area, and performing calculations sinuilar to those submitted with I.    Quantities Used                                              the license application (see Regulatory Guide 10.8, "Guide for the Preparation of Applications for Medical Programs"l.
1. All elution, preparation, and injection areas should be surveyed daily with a survey meter and decontami- nated if necessary.


2. Laboratory areas where only small quantities of radioactive material (less than I millicurie)
a. Verify that patient information records (Items 1-3        If the results of the calculations indicate that air concentra below) are in order; compare with similar information                tions of xenon- 133 (as averaged over one calendar quarter I
are used should be surveyed monthly.3. All other laboratory areas should be surveyed weekly.4. The weekly and monthly surveys should consist of: a. A measurement of radiation levels with a survey meter sufficiently sensitive to detect 0.1 mR/h.b. A series of smear tests to measure contamination levels. The method for performing smear tests should be sufficiently sensitive to detect the limits in Table 2 to one significant digit.c. Any air sample measurements necessary to determine compliance with §20.103 of 10 CFR Part 20 in cases where calculations alone are not sufficient.
submitted to NRC in support of request for xenon-133.               approach or exceed I x 10-" microcurie per milliliter, the licensee should consider and implement methods of increas (I )  Number of studies per week.                         ing ventilation rates or of reducing patient load.


TABLE 2 LIMITS FOR REMOVABLE
(2)   Activity administered to each patient.             6.     Methods of Xenon-133 Disposal
SURFACE CONTAMINATION
          (3)  Comparison of numberofstudiesand average                  a. Dilution through exhaust systems activity administered to each patient with information submitted in application.                         Licensees who dispose of xenon-133 by release to the atmosphere through an air exhaust syslem are
IN MEDICAL INSTITUTIONS*
      1h. Verify that possession limits are controlled and required to perform surveys (i.e.. measurements or calcula corrected for differences in calibration date anti date            tions) to ensure that they are in compliance with para of use; compare with possession limits stated in license.           graph 20.1(c) and §20.106 of 10 ('FR Part 20. Para graph 20.1(c) requires that the concentrations of xenon-13
Type of Radioactive Material**
2.     Survey Records for Use and Storage Areas                    in effluents to unrestricted areas be as low as is reasonably achievable by the current state of technology, and § 20.106
Type of Surface Alpha Emitters Beta or X-Ray Emitters Low-Risk Beta or X-Ray (/xCi/cm 2) (,Ci/cm 2) Emitters (,Ci/cm 2)1. Unrestricted areas 10-1 10-6 10-5 2. Restricted areas 10-6 10-5 10-4 3. Personal clothing worn 10.1 10-6 10-5 outside restricted areas 4. Protective clothing worn 10.6 10-1 10-4 only in restricted areas 5. Skin 10-6 10-6 10-s* As adapted from Table I of Reference
      ('heck ventilation quarterly in all areas in which          requires that the concentrations averaged over a period of xenon-133 is used anti stored to ensure that airflow rates          I year should not exceed 3 x 10"7 microcurie per milliliter.
4. Averaging is acceptable over inanimate areas of up to 300 cm2 or, for floors, walls, and ceiling, 100 cm 2.Averaging is also acceptable over 100 cm 2 for skin or, for the hands, over the whole area of the hand, nominally
300 cm 2.** Beta or x-ray emitter values are applicable for all beta or x-ray emitters other than those considered low risk. Low-risk nuclides include C-14, H-3, S-35, Tc-99m, and others whose beta energies are <0.2 MeV maximum, whose gamma or x-ray emission is less than 0. 1 R/h at 1 meter per curie, and whose permissible concentration in air (see 10 CFR Part 20, Appendix B, Table I) is greater than 10-6 pbCi/ml.8.23-9 REFERENCES*
I National Commission on Radiological Protection (NCRP) Report No. 8, "Control and Removal of Radioactive Contamination in Laboratories," is-sued December 15, 1951.2. NCRP Report No. 9, "Recommendations for Waste Disposal of Phosphorus-32 and Iodine-131 for Medical Users," issued November 2, 1951.3. NCRP Report No. 10, "Radiological Monitoring Methods and Instruments," issued April 7, 1952 (revised edition to be published in 1978).4. International Atomic Energy Agency (1AEA)Technical Report Series No. 120, "Monitoring of Radioactive Contamination on Surfaces." 1970.5. IAEA Safety Series No. 38, "Radiation Protec-tion Procedures,~
1973.6. IAEA Safety Series No. I, -Safe Handling of Radionuclides,'" 1973 Edition, Code of Practice Sponsored by the International Atomic Energy Agency (IAEA) and the World Health Organiza-tion (WHO), 1973.7. IAEA Technical Report Series No. 133, "Hand-book on Calibration of Radiation Protection Monitoring Instruments," 1971.IAEA reports may be obtained from UNIPUB. Inc.. P.O. Box 433, New York. N.Y. 10016.ICRP reports may be obtained from Pergamon Press, Maxwell House. Fairview Park. Elmsford, New York 10523.ICRU reports may be obtained from ICRU Publications, P.O.Box 30165, Washington.


D.C. 20014.NCRP reports may be obtained from NCRP Publications.
are maintained in accordance with statements made in the license application.                                                           Make physical measurements to determine compli ance with &sect;20.106 anti paragraph 20.1(c). Alternatively.


P.O.Box 4867, Washington, D.C. 20014.8. IAEA Safety Series No. 25, "Medical Supervi-sion of Radiation Workers,"'
3.     Procedures for Routine Use                                  measure ventilation rate and. using xenon-133 data from Item L.a above, perform calculations similar to those sLibmitted with the license application (See Regtilatory a. ('heck to determine that procedures being followed        Guide 10.8).
sponsored jointly by IAEA. WHO, and ILO, 1968.9. International Commission on Radiological Pro-tection (ICRP) Publication
for routine use of xenon-133 are in accordance with pro cedures described in license application. ('heck to determine                  If the results indicate that air concentrations of that all personnel using xenon-133 have been trained in            xenon-133 (as averaged over I year) approach or exceed these procedures for routine use of xenon- 133.                     3 x 10i7 nicrocurie        per milliliter. the licensee should consider and implement methods of increasing ventilation rates. reducing patient load, or decreasing amount of b. Check to determine that special apparatus for             xenon-133 released (e.g., through use of a chaicoal trap).
12, "General Princi-ples of Monitoring for Radiation Protection of Workers," Pergamon Press, 1969.10. AAPM Monograph No. 1, "Biophysical Aspects of the Medical Use of Technetium-99m," J. G.Kereiakes and Karen R. Corey, Editors (available from American Association of Physicists in Medicine, Dr. James G. Kereiakes, E555 Medi-cal Sciences Building, University of Cincinnati, Cincinnati, Ohio 45267), 1976.11. NCRP Report No. 48, "Radiation Protection for Medical and Allied Health Personnel," issued August 1, 1976.12. NCRP Report No. 37, "Precautions in the Man-agement of Patients Who Have Received Therapeutic Amounts of Radionuclides," 1970.13. Diegl, H., ''Guidelines for Determining Fre-quency of Wipe Samples,'
administration anti collection of xenon-133 is being used as specified in the license application.                                       If tile exhaust is released to a restricted area. e.g.. a roof to which access is controlled, surveys should include c. ('heck to determine that special procedures are          checks to determine the effectiveness and continued being usLd to reduce leakage (e.g.. use of nose clamps or          implementation of provisions submitted with lith license special enclosures) as specified in the license application.       application to do the following:          control access to the
in Health Physics Operational Moniloring, Vol. 1, C. A. Willis and J. S. Handloser, Eds., Gordon and Breach.New York, 1972.14. Sommers, J. F., "Sensitivity of G-M and Ion Chamber Beta-Gamma Survey Instruments,''
                                                            8.23-13
Health Physics 28, 755, 1975.15. International Commission on Radiation Units and Measurements (ICRU) Report 12, "Certification of Standardized Radioactive Sources,''
Sep-tember 15, 1968.8.23-10
APPENDIX A SURVEYS OF RADIOACTIVE
XENON-133 RELEASES Surveys associated with the use of xenon-133 should be sufficient to show compliance with re-quirements for protection of persons in restricted and unrestricted areas (see &sect;&sect;20.103 and 20.106) and with the terms and conditions of the NRC Materials License. Surveys may consist of either measurements of airborne radioactivity or of calculations supported by records of xenon-133 used and measurements of pertinent ventilation and air effluent volumes. The procedures outlined below are acceptable for survey-ing xenon-133 concentrations in medical institutions.


Acceptable surveys would be indicated by records of the following information, procedures, or condi-tions: 1. Quantities Used a. Verify that patient information records (Items 1-3 below) are in order; compare with similar infor-mation submitted to NRC in support of request for xenon- 133.(1) Number of studies per week.(2) Activity administered to each patient.(3) Comparison of number of studies and aver-age activity administered to each patient with infor-mation submitted in application.
restricted area; post appropriate warriing signs; instruct persons who may enter the area in accordance with &sect; 19.1 2      ing basis at the frequency specified in the license applica of 10 CFR Part 19; monitor personnel entering the area:          tion. Include monitoring of traps to determine wheil saturation occurs and when the filter must be replaced.


b. Verify that possession limits are controlled and corrected for differences in calibration date and date of use. Compare with license condition.
and survey the area.


2. Survey Records for Use and Storage Areas Check ventilation quarterly in all areas in which xenon-133 is to be used and stored to ensure that all airflow rates are maintained in accordance with statements made in the license application.
Check the procedures for handling saturated filters, including the provisions of adequate shielding b. Adsorption onto charcoal traps                                                                                and ventilation. Calculations should be made of average concen trations of xenon-133 in air at the exhaust and compared Surveys should be made to check leakage from charcoal trapping devices. If the exhaust is vented to the        to the allowable limit.


3. Procedures for Routine Use a. Check to determine that procedures being fol-lowed for routine use of xenon-133 are in accordance with procedures described in license application.
outdoors or other unrestricted area, check to determine that air concentrations of xenon-] 33 averaged over 1 year                            USEFUL CONVERSIONS
do not approach or exceed 3 x 00"7 microcurie per milli I mCi      = 103 WCi liter. See Item 6.a above.


Check to determine that all personnel using xenon-133 have been trained in these procedures for routine use of xenon-133.
1 ft 3    = 2.832 x  10 2 m 3 = 2.832 x 0 4 nul Record measurements to check the efficiency and            lft 3 /min = 1.699 x  106 ml/h general performance of collection and trapping devices                          = 6.796 x  107 ml/40-h week according to specifications, both initially and on a continu-                   = .1.488 x 1010 ml/yr I week = 168h
                                                          8.23-14


b. Check to determine that special apparatus for administration and collection of xenon-133 is being used, as specified in the license application.
APPENDIX B
                                      SAMPLE CHECKLIST FOR RADIATION SURVEYOR
                                                                          g. 10 CFR Part 19 signs.


c. Check to determine that special procedures are being used to reduce leakage (e.g., use of nose champs or special enclosures), as specified in the license application.
Initiate contamination survey report for each lab.


4. Emergency Procedures Check to determine that all personnel using xenon-133 have been trained in the established emer-gency procedures to be followed in case of an acci-dental release of xenon-133.
4. Observe general laboratory conditions:
  a. Check card for previous survey results, e.g., suc cessive red circles, nobody in.                                    a. Food and drink preparation and use in radioactive b. Fill in name of Authorized User, Department, Build                      material areas?
      ing and' Room Number, and Survey Date.                              b. Waste container overfilled?
  c. Sketch floor plan.                                                  c. Dosimeters being worn?
                                                                          d. Mouth pipetting?
t. Ask lab personnel (and record answers on report form):
  a. What isotopes are being used? (Compare with what                  5. Conduct laboratory survey using portable survey meter.


5. Air Concentrations of Xenon-133 in Restricted Areas Check to determine that air concentrations of xenon-133 in restricted areas meet the requirements of &sect;20.103. This may be done by making physical measurements.
User is cleared for.)
  b. Where in the lab are they used?                                      a. Record external dose rate from accessible storage c. Where are isotopes stored?                                                surfaces.


Alternatively, this may be done by reviewing the use of xenon-133 (Item l.a above), checking the ventilation rate in each area, and per-forming calculations similar to those submitted with the license application.
d. What was last order? (Compare with card record.)                   b. Record exposure rate from contaminated surfaces.


If the results of the calcula-tions indicate that air concentrations of xenon-133 (as averaged over one calendar quarter) approach or ex-ceed 1 x 10-1 microcuries per milliliter, then the licensee should consider and implement methods of increasing ventilation rates or of reducing patient load.6. Methods of Xenon-133 Disposal a. Dilution through .exhaust systems Licensees who dispose of xenon-133 by release to the atmosphere through an air exhaust system are required to perform surveys (i.e., measurements or calculations)
e. Is Authorized User available if needed?            If not, give reason, e.g., on leave, out of country, terminated
to ensure that they are in compliance with paragraph
                                                                        6. Conduct smear survey:
20.1(c) and &sect;20.106 of 10 CFR Part 2
        employment.


===0. Paragraph ===
f. In what other labs are isotopes used? (Compare                      a. Take first smear near or in lab entrance.
20.1 (c) requires that the concentrations of xenon-133 in effluents to unrestricted areas be as low as is reasonably achievable by the current state of technology, and &sect;20.106 requires that the concentra- tions averaged over a period of 1 year should not ex-ceed 3 x 10-7 microcuries per milliliter.


Make physical measurements to determine com-pliance with &sect;20.106 and paragraph
with card record.)                                                 b. Take several smears from floor and benches and g. Where is waste stored and disposed of?                                  equipment as indicated by answers to earlier ques tions.
20.1(c). Alter-natively, measure ventilation rate and, using xenon-133 data from Item L.a above, perform calculations similar to those submitted with license application.


If the results indicate that air concentrations of xenon-133 (as averaged over 1 year) approach or ex-ceed 3 x 10' microcuries per milliliter, then the licensee should consider and implement methods of increasing ventilation rates, reducing patient load, or decreasing amount of xenon-133 released (e.g., through use of a charcoal trap).8.23-11 If the exhaust is released to a restricted area, e.g.. a roof to which access is controlled, or from a tall stack, Sutton's equation (Refs. 1 and 2) may be used to calculate the concentrations at the nearest unrestricted area. If this approach is used, record the location of the exhaust system outlet as used for the calculation model, including proximity to unre-stricted areas, air intakes, and open windows.b. Adsorption onto charcoal traps Surveys should be made to check leakage from charcoal trapping devices. If the exhaust is vented to the outdoors or other unrestricted area, check to de-termine that air concentrations of xenon-133, aver-aged over 1 year, do not -approach or exceed 3 x 10-1 microcuries per milliliter.
3. Check labeling.


See Item 6.a above.Record measurements to check the performance of collection and trapping devices according to spec-ifications, both initially and on a continuing basis.Include monitoring of traps to determine when sat-uration occurs and when the filter must be replaced.Check the procedures for handling saturated fil-ters, including the provisions of adequate shielding and ventilation.
7. Discuss 10 CFR        Part 19 (Instructions  to Workers)
    a. Lab door-"Caution, Radioactive Material" (CRM)                      requirements.


Calculations should be made of aver-a2e concentrations of xenon-133 in air at the exhaust and compared to the allowable limi
b. Liquid waste sink-"Contaminated Liquid Waste"
        (survey card should indicate radioactive sink-RS).              8. Complete results:
        Is sink log posted? Is it being used?
    c. Radioactive hood-"Caution, Radioactive Material"                    a. Count smears and list results on survey form.


====t. USEFUL CONVERSIONS====
(survey card should indicate radioactive hood-RH).                 b. Notify lab personnel of contamination, and note on
1 mCi 103 'uCi 1 ft 3  = 2.832X10-2 m 3= 2.832x10 4 mI 1 ft 3/min = 1.699X 106 mi/h= 6.797x 10' ml/40-h week= 1.484X 10 1 0 ml/yr I week = 168h REFERENCES
        "Air Flow Check" white label with date no older than                    form who was called and date of notification.
1. Blatz, Hanson, "Radiation Hygiene Handbook," McGraw-Hill, New York, 1959, pp. 22-7.2. Cember, Herman, 'Introduction to Health Physics," Pergamon Press, New York, 1969, pp.334-9..23-12 APPENDIX B SAMPLE CHECKLIST
FOR RADIATION
SURVEYOR I. Initiate contamination survey report for each lab a. Check card for previous survey results, e.g., successive red circles, nobody in.b. Fill in name on Authorized User, Department, Building and Room Number, and Survey Date.c. Sketch floor plan.2. Ask lab personnel (and record answers on report form)a. What isotopes are being used? (Compare with what User is cleared for.)b. Where in the lab are they used?c. Where are isotopes stored?d. What was last order? (Compare with card record.)e. Is Authorized User available, if needed? If not, give reason, e.g., on leave, out of country, terminated employment.


f. In what other labs are isotopes used? (Compare with card record.)g. Where is waste stored and disposed of?3. Check labeling a. Lab door--"Caution, Radioactive Material' (CRM).b. Liquid waste sink--"Contaminated Liquid Waste" (survey card should indicate radioactive sink-RS).Is sink log posted? Is it being used?c. Radioactive hood-"Caution, Radioactive Material" (survey card should indicate radioactive hood-RH). "Air Flow Check" white label with date no older than 1 year required.d. Refrigerator and other storage areas-'"CRM,'" including those in corridors.
4 months required.                                                 c. Identify all abnormal radiation safety conditions d. Refrigerator and other storage areas-"CRM," includ                      on survey form.


e. Radioactive waste containers--"CRM'" or "Contaminated Waste" should be lined with yellow plastic bag.f. Any area with external radiation over 2.5 mR/h should be labeled with "Caution, Radiation Area" (CRA) and should be noted on survey form. (See paragraph
ing those in corridors.
20.202(b)(2)
and &sect;20.203 of 10 CFR Part 20.)2. 10 CFR Part 19 signs.4. Observe general laboratory conditions a. Food and drink preparation and use in radioactive material areas.b. Waste container overfilled.


c. Dosimeters being worn.d. Mouth pipetting.
d. Complete survey card, replace in file, and mail survey e. Radioactive waste containers-"CRM" or "Contami                          form copy to User.


5. Conduct laboratory survey using portable survey meter a. Record external dose rate from accessible storage surfaces.b. Record exposure rate from contaminated surfaces found.6. Smear survey a. Take first smear near or in lab entrance.b. Take several smears from floor and benches and equipment as indicated by answers to earlier questions.
nated Waste" should be lined with yellow plastic bag.               e. If lab has contamination (significant), call User, f. Any area with external radiation over 2.5 mR/h                          request cleanup, and resmear.


7. Discuss 10 CFR Part 19 (Instruction to Workers) requirements.
should be labeled with "Caution, Radiation Area"                    f. Resmear when notified or call User if no resmear (CRA) and should be noted on survey form. (See                          was called for.


8. Results a. Count smears and list results on survey form.b. Notifylab personnel of contamination, and note on form who was called and date of notification.
paragraph 20.202(bX2) and &sect;20.203 of IOCFR                          g. File carbon copy of results form.


c. Identify all abnormal radiation safety conditions on survey form document.d. Complete survey card, replace in file, and mail survey form copy to User.e. If lab has contamination (significant), call User, request cleanup, and resmear.f. Do resmear when notified or call User if no resmear was called for.g. File carbon copy of results form.8.23-13 UNITED STATES NUCLEAR REGULATORY
Part 20.)
COMMISSION
                                                                  8.23-15}}
POSTAGE WASHINGTON, D. C. 20555 U.S. NUCLE CO OFFICIAL BUSINESS PENALTY FOR PRIVATE USE, $300 120555011962
1 SO US NRC.Or:FICE OF THE COMMISSIONERS
OR .JOSEPH HENDRIE CHAIRMAN H1149 WASHINGTON
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Latest revision as of 11:29, 28 March 2020

Radiation Safety Surveys at Medical Institutions
ML003739603
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Issue date: 01/31/1981
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RG-8.23 Rev 1
Download: ML003739603 (14)


Revision 1 Jaonia1y 11 U.S. NUCLEAR REGULATORY COMMISSION

REGULATORY GUIDE

OFFICE OF STANDARDS DEVELOPMENT

REGULATORY GUIDE 8.23 RADIATION SAFETY SURVEYS AT MEDICAL INSTITUTION

A. INTRODUCTION

Surveyst are a necessary supplement to personnel monitoring, which measures individual radiation exposures Paragraph 20.201(b) of 10 CFR Part 20, "Standards for by the use of devices worn by the workers (Refs. 4, 6, 12, Protection Against Radiation," requires that each licensee 14. and 16.

make or cause to be made such surveys as may be necessary for that licensee to comply with the regulations in Part 20.

C. REGULATORY POSITION

As used in Part 20. the term "'survey" means an evaluation of the radiation hazards incident to the production, use. Methods and procedures in this guide are acceptable to release, disposal, or presence of. radioactive mate'rials or the NR( staff for establishing survey programs in accord other sources of radiation under a specific set of conditions. ance with the as low as is reasonably achievable (ALARA)

This guide identifies the types and frequencies of surveys philosophy. Generally, medical institutions licensed by thc that are acceptable to the NRC staff for use in medical. NRC should have a health physics staff available for consul institutions licensed by the NRC to use radioactive materials ration to design a survey program appropriate to the for purposes of diagnosis, therapy, or human research institution's use of radioactive material. Nothing in this involving the administration of radioactive materials or guide should be construed to preclude or discourage the

  • radiation to patients or the use of radioactive materials for patient services.

design of survey programs containing provisions other than those in this guide, when such programs are accepted by the NRC licensing staff as providing ALARA exposure conditions for a particular institution.

B. DISCUSSION

1. Types of Surveys Surveys are considered to be part of a comprehensive 1.1 General Description protection program established by the licensee consistent with the philosophy and principles of Regulatory Guide 8.10,

Surveys performed in compliance with §20.201 of

"Operating Philosophy for Maintaining Occupational

10 CFR Part 20 should include those necessary to evaluate Radiation Exposures As Low As Is Reasonably Achievable."

external exposure to personnel, surface contamination (Ref. 1). Principles, methods, and instrumentation for levels, and concentrations of airborne radioactive materials carrying out radiation and contamination surveys were in the facility and in effluents from the facility.

developed early in the atomic energy program and have been discussed in reports of the National Council on Environmental monitoring is beyond the scope of this Radiation Protection and Measurement (Refs. 2-9), the guide. However, the radiation safety program should International Atomic Energy Agency (Refs. 10-14), and the include surveys or records that indicate control of the International Commission on Radiological Protection quantities of radioactive material released in air and water (Refs. 15-17). Other publications (Refs. 17- 34) contain addi to unrestricted areas as required by Part 20. In miny tional information for use in establishing radiation survey medical institutions, surveys of effluents or calculations to programs and selecting methods and equipment for their ensure that permissible concentration limitsare not exceeded implementation. are included as a regular part of the health physics survey t

The word "survey," often used synonymously with "survefl lance," "monitoring," or "area monitoring," is used in this guide to connote the jpes*oa inspection of vsulouS locations in a facility

0

"Lines indicate substantive changes from the February 1979 ver using radioactive materials, with or without accompanying ments, to determine the effectiveness of measures to protectmeasure sion that was issued for public comment. against exposure to radiation.

USNRC REGULATORY GUIDES

Comments should be sent to the Secretary U.S. Nuclear Regulatory Commission, of the Commission, Regulatory Guides are Issued to describe and make available public methods acceptable to the NRC staff of implementing to the Attention: Docketing and Service Branch. Washington, D.C. 20555, specific parts of the Commission's regulations, to delineate niques used by the staff in evaluating specific problems tech The guides are Issued in the following tan broad divisions:

or postu lated accidents or to provide guidance to applicants. Regulatory Guides are noi substitutes for regulations, and compliance 1. Power Reactors 6. Products them Is not required. Methods and solutions different from with 2. Research and Test Reactors 7. Transportation out in the guides will be acceptable if they provide a basisthose set 3. Fuels and Materials Facilities 8. Occupational Health findings requisite to the issuance or continuance of a for the 4. Environmental and Siting 9. Antitrust license by the Commission.

Permit or 5. Materials and Plant Protection 10. General and Financial Review Comments and suggestions for improvements in these guides Copies of issued guides may be purchased at the current Government are encouraged at all times, and guides will be revised, as appropriate, Printing Office price. A subscription service for future guides in spe to accommodate comments and to reflect new information cific divisions is available through the Government Printing Office.

experience. This guide was revised as a result of substantive or Information on the subscription service and current GPO prices may ments received from the pu 'ic and additional staff review. com be obtained by writing the U.S. Nuclear Regulatory Washington, D.C- 20555. Attention: Publications Sales Commission, Manager.

program. Often these calculations may he made by estimat Surveys are not acceptable for routine compliance with ing the amotints of radioactive material washed down the personnel monitoring requirements of §20.202. How designated sinks and dividing them by the quantities ever, in the event of accidental loss of personnel dosimetry of sewage released from the hospital, as indicated on the data. e.g., as a result of losing the dosimeter or chemical or hospital's water or sewage bills. This procedure normally physical damage to the dosimeter, the best alternative suffices to show compliance with the effluent limits of means of estimating the exposure may be to use survey dllat Part 20. Amounts of radioactive material released in air in conjunction with appropriate occupancy factors. In such within hospitals or exhausted to the outside from hospitals case, the estimate, including the survey data used. should bh are generally small, but these amounts may sometimes be documented and retained indefinitely (see para estimated by calculational techniques if not by air-monitoring graph 2 0. 4 01(c)(2)tii)). Survey results should be reviewed procedures.' Appendix A to this guide describes surveys to carefully by the Radiation Safety Officer to identify be made of radioactive xenon-I 33 releases. potentially hazardous situations and unfavorable trends.

Radiation protection programs should include the types 1.3 Measurements of Radioactive Material Concentrations of surveys discussed belo

w. In Air

1.2 Surveys of External Radiation Exposure Levels It may ofterr be sufficient in medical institutions to show by calculation, together with monitoring of ventilation Areas to he surveyed should include any locations where rates, that air concentrations are well below levels that individuals may be exposed to -radiation intensities that would require routine air sampling. However. concentrations might cause the occupational radiation dose to exceed of radioactive material in air should be measured at tre-,

10 percent of the limits of paragraph 20.101(a) in any qucncics described in Section ('.2 and specified in Table 1 calendar quarter or where an individual is working with any for areas where operations could at any time expose workers radiation source that could produce radiation levels greater to 10 percent or more of the concentration values given in than 1.0 mR/h at 1 meter. These areas typically include Table 1. Column I. of Appendix B to 10 CFR Part 20.

shipping and receiving areas: radionuclide laboratories Special requirements for such monitoring may also be made in nuclear medicine; diagnostic areas in nuclear medicine; a condition of the license.

intracavilary .source preparation areas in radiation therapy;

patients' rooms where treatments are given with intracavi Air samples obtained in accordance with §20.103 tary. interstitial, or radiopharmaceutical therapy sources; should be representative of the air in the workers' breathing operating rooms, control (console) areas for teletherapy zones. In cases where breathing zone sampling is not accom equipment rooms; waste packaging and disposal areas; plished, air samples taken outside the breathing zone

.radiation instrument calibration areas; and any other areas closer to the source, where the concentration of radioactive where persons might be exposed (e.g., areas occupied by material can be or is expected to be equal to or greater than technologists, nursing staff, visitors. patients. or any other the concentration in the breathing zone. are acceptable.

persons who may be exposed to radioactive materials When measuring the quantity of radioactive 'material handled by others). deposited on an air sample filter. corrections should he made for absorption of alpha or beta particles by the filter Preoperational, routine, and special surveys of these media and by material collected on the filter. [he quantity areas should be performed by the radiation protection staff of air that has passed through the filter should be accurately as described in Section C.2 of this guide. Results of these measured and corrections made for any loss of flow rate surveys should be recorded as described in Section (.3. In caLised by the accumulation of material on the filter.

addition to thisý survey program, the Radiation Safety Officer should institute and maintain a program of surveys Continuous breathing zone or general air sampling performed by workers other than health physics personnel should be conducted while the work is in progress unless who may be exposed to external radiation levels that could experience with sample* results or calculations has demon exceed any of the limits of paragraph 20.101(a). Surveys by strated that the concentration of radioactive material in such workers may consist of no more than occasional the breathing zone is not likely to exceed 25 percent of the instrument. observations during work with radioactive' values given in Table I, Column 1, of Appendix B to materials. These personal surveys are particularly appropriate 10 CFR Part 20. The use of personal (lapel) samplers is in nuclear medicine activities. Personnel should he properly acceptable for breathing zone sampling. If the air sanipl instructed in conducting such surveys and should perform ing is not continuous, the frequency and the times selected the surveys each day during and after work with radioactive for the sampling should be based on the nature of the nmaterials, as necessary to determine the need to limit process involved and the probability that the airborne worktime and to use protective procedures to reduce expos radioactive material will be present. When assessing this ures as far below the paragraph 20.101(a) limits as is probability is difficult, frequencies based on information reasonably achievable. The survey results obtained by these given in Section ('.2 and Table I of this guide are accept workers need not be recorded. However, the Radiation able.

Safety Officer should maintain records to show that the appropriate training for, and implementation of, the worker 1.4 Surface Contamination Surveys survey program has been provided and is a continuing part of the survey program. Workers should be instructed to report Regular surveys for radioactive contamination that could unusual survey findings to the Radiation Safety Officer. be present on surfaces of floors, Walls, furnishings. and

8.23-2

equipment are a necessary part of the survey program. Any d. Sample, background, and test counts and times, surveys carried out in accordance with NRC license condi and tions will be considered consistent with the level of safety provided by recommendations in this guide. e. Signatures and dates at the bottom of each page.

Control of surface contamination is necessary to limit Provision should also be made on the diagram for recording external dose rates and the resuspension in air of loose an instrument check with an appropriate check or calibra radioactive materials that may enter the body through tion source for each batch of smear samples counted.

inhalation, ingestion, or skin absorption.

The surveys discussed above are regularly scheduled and

1.4.1 Removable Contamination recorded on the survey diagrams. In addition, it may be necessary to conduct more frequent, informal, and unre For the purposes of this guide. removable contamination corded surveys in nuclear medicine areas or other areas means radioactivity that can be transferred from a surface where loose radioactive contamination may occur. Such to a snmear test paper by rubbing with moderate pressure. surveys can be made with a thin-end-window (less than Information is available on the selection and use of instru 2 mg/cm 2 ) detector held close to a dry smear sample ments for performing removable surface contamination immediately after it is taken in the work area. When ambient surveys appropriate to the radionuclides used in medlical external radiation levels in the laboratory are low enough to institutions (Refs. 2, 4-7, 10, and 13). Methods and instru maintain external radiation exposures below the limits of ments used in surface contamination surveys should be paragraph 20.101(a), any appreciable surface contamination sufficiently sensitive to detect the nuclides being monitored can be detected by simply holding the detector in a fixed (Refs. 22 and 25). For optimum detection of low-energy position and moving the smear sample close to and away beta emitters (e.g., 11-3 and C-14)as well as of alpha emitters from the detector several times. This method may be used and low-energy x- or gamma-ray emitters (e.g., 1-125), for the vast majority of radionuclides used in diagnostic and liquid scintillation counting or internal proportional count therapeutic medical practice.

ing is normally necessary with the use of appropriate constancy checks on counter efficiency. Part 20 does not specify limits for surface contamination.

Each applicant may propose and justify the levels of remov The collection of smear samples may be preceded by a able surface contamination that will be allowable before rapid survey with a portable thin-end-window detector in decontamination. must be performed. These limits should order (a) to ensure that gross contamination levels are not be based on the need to avoid transfer of significant already too high for counting with sensitive equipment, amounts of contamination to unrestricted areas and to (b) to minimize (in some cases) the chance for inadvertent maintain exposures as low as is reasonably achievable. The spread of con tainination by the contamination survey' or contamination limits for restricted areas presented on line 2 other activities to be performed in the meantime, and (c) to of Table 2 of this guide are acceptable to the NRC staff and determine which areas require greater attention in smear need not be justified by the licensee or applicant.

testing. The instrument used for this purpose should (a) have a short enough time constant to facilitate detection or (b) be provided with a speaker for aural indication of 1.4.2 Fixed Contamination count-rate.

For the purposes of this guide, fixed contamination A standardized method for smear testing of a relatively means radioactivity remaining on a surface after repeated uniform area should be used in order to allow comparison decontamination attempts fail to significantly reduce the of relative levels of contamination at different times and contamination level. A total contamination survey using places. A dry smear taken from an area of about 100 cm 2 is instruments suitable for the radionuclides involved should acceptable to indicate levels of removable contamination. be conducted simultaneously with each removable conthm ination survey. The applicant may propose and justify the A layout diagram for each laboratory routinely surveyed levels of total contamination that will be allowable for -both is helpful for recording survey results in a uniform manner restricted and unrestricted areas before decontamination to aid review and observation of trends and for satisfying must be performed. The limits appearing on lines I and 2 of regulatory requirements for availability of survey records. Table 2. multiplied by a factor of 5, are acceptable to the On these diagrams, it is helpful to specify key locations that NRC staff and need not be justified by the licensee or are smear tested at each survey and also to provide space applicant.

reminding the recorder to include:

1.5 Protective and Personal Clothing Contamination a. Contamination levels converted to radioactivity Surveys units specified in 10 ('FR Part 20,

Individuals working in areas where a potential for skin or b. Make and model number of the instruments used in clothing contamination exists should be provided with the survey and in counting the smear samples, suitable protective clothing. Laboratory coats and protective gloves, as described in References 5 and 6, are usually c. Disintegration rate of each instrument test or calibra adequate for any procedures in medical institutions. Protec tion source. tive clothing should be surveyed by the wearer after use if

8.23-3

significant contamination is possible. Contaminated protec direction of Radiation Safety Office personnel or a medical live clothing should be removed and placed in special consultant should be repeated until (a) such attempts cease laundry containers before leaving a restricted work area. to effect significant reductions or(b) such attempts threaten Disposable gloves should be discarded in radioactive waste to irritate or harm the skin. 2 When decontamination containers. After gloves are removed, hands should- he attempts are terminated, there should le no further concern washed and surveyed. if the residual contamination does not exceed preselected levels. Such levels may be proposed and justified by the When protective clothing contamination levels may be applicant or licensee. The limits given on line 5 of Table 2 expected to exceed preselecled limits, workers should be will be accepted without justification. If residual contani instructed to take care to avoid dispersal of contamination ination exceeds the selected limits, the affected individual and to report the situation to the Radiation Safety Office. may be released (since his contamination is now rela A member of the radiation safety staff should then make tively fixed and not likely to enier the body), but periodic surveys and supervise any necessary decontamination or surveys should be made until the limits are no longer clothing disposal. The applicant may propose and justify exceeded. The resulting dose should be determined and protective clothing contamination limits considered adequate entered in the individual's personnel dosimetry record.

for use in each restricted area. The limits on line 4 of Complete records should be maintained of each incident of Table 2 are acceptable to the NRC staff and need not be this nature.

justified by the licensee or applicant.

Since medical personnel may often handle open vials or Contamination levels observed and procedures followed containers with millicurie or higher levels of volatile forms during the survey and decontamination of personal clothing of certain nuclides such as 1-125 or 1-131, which in certain should he recorded. The written record should include the forms may concentrate in the thyroid or other body organs, names of persons surveyed, a description of prior work bioassay monitoring is sometimes made a condition of the activities, the probable causes, steps taken to reduce further license. Acceptable criteria for such programs are published incidence of contamination, times and dates, and the in Regulatory Guides 8.20, "Applications of Bioassay for surveyor's signature. This information may be entered in a 1-125 and 1-131," and 8.26, "Applications of Bioassay for logbook. Workers' surveys of themselves need not be Fission and Activation Products." Additionally, guidance routinely recorded unless the limits on line 4 of T'able 2 on bioassay monitoring is available from the Material are exceeded. The radiation safety staff should conduct Licensing Branch, Office of Nuclear Material Safety and spot checks monthly to ensure that the workers continue Safeguards. In addition to these programs, placing the their own personal contamination surveys. detector against the neck close to the thyroid is often useful for monitoring for internal deposition of these In restricted areas with little potential for surface nuclides during surveys for skin contamination; however, contamination, personal clothing is often worn beneath for I-I 25, a thin-crystal scintillation probe would be needed protective clothing. Such personal clothing should be to obtain adequate sensitivity. In this way, appropriate surveyed by the wearer before he or she leaves the restrict personnel may be more frequently monitored for internal ed area. (Ilowever, this is neither practicable nor necessary exposure while they are also being monitored for external for employees working with only microcuric quantities of contamination. Any positive indications of exposure or tritium or carbon-14.) Workers should be instnrcted to contamination from these types of surveys should be report the situation to the Radiation Safety Office when recorded in the radiation safety logs. Indications of internal personal clothing contamination levels exceed preselected depositions should be reported to the Radiation Safety limits. A member of the radiation safety staff should then Office.

make surveys and gupervise any necessary decontamination or clothing disposal. The applicant or licensee may propose 1.7 Surveys of Equipment Prior to Release to Unrestricted and justify personal clothing contamination limits; the Areas limits given on line 3 of Table 2 are acceptable to the NR("

staff and need not be justified by the applicant or licensee. Before the uncontrolled release of potentially contam Records should be maintained in the same manner as those inated medical instruments or equipment from restricted to for protective clothing contamination. unrestricted areas, surface contamination surveys should be conducted on such instruments and equipment for both

1.6 Personal Surveys removable and fixed contamination. If contamination is detected, decontamination procedures should be instituted Alt.hough personal contamination in excess of the value and repeated until additional efforts do not significantly given on line 5 of Table 2 is unusual in medical institutions, reduce contamination levels. The applicant or licensee may individuals who work in restricted areas under conditions in propose and justify total and removable contamination which they may become contaminated should survey all limits below which uncontrolled release of equipment is exposed areas of the body before donning personal clothing permitted. The limits given in Table 3 of this guide, as

2 or leaving (he restricted area. Particular attention should be Decontamination attempts without supervision or instruction paid to the hody, hair, bottoms of the shoes or feet, anti from the licensee's medical consultant should be restricted to washing with mild soap and water unless other safe procedures have the hands. Workers should be instructed to report the already been approved and personnel have been properly instructed dcleclion of contamination on the body to the Radiation in using them. If such attempts do not reduce the contamination to acceptable levels, the aid of the licensee's medical consultant should Safety Officer. l)econtamination attempts under the be obtained.

8.23-4

I adapted from Table I of Regulatory Guide 1.86, "Termina on which these instruments depend for operation should tion of Operating Licenses for Nuclear Reactors," are also be tested to ensure that they will function reliably in acceptable to the NRC staff and need not he justified by normal operations or as expected under emergency condi the licensee or applicant. Decontamination guidelines are tions. Care should be taken to minimize exposure to available from the Material Licensing Branch. Office of personnel from the tests themselves. Any signs, labels, or Nuclear Material Safety and Safeguards. notices found to be missing should be promptly provided.

Temporary signs, signals, or barriers, together with appro

1.8 Ingestion priate worker notification and instruction, may be used in the interim when items specified in Parts 19 and 20 are not Surveillance should be included in the radiation safety available, but acceptable corrections should be provided as program to ensure that workers properly observe rules to soon as practicable.

prevent ingestion of radionuclides, e.g., rules against eating, drinking, or smoking in work areas or while wearing poten 1.11 Leak Tests of Sources tially contaminated clothing. storing foods in work areas;

pipetting by mouth; and wearing contaminated laboratory Sealed sources containing (a) more than 100 inicrocuries coats to the cafeteria or other unrestricted areas. Water of a byproduct material with a half-life of more than fountains close to work areas where radioactive materials 30 days (except iridium-192 seeds encased in nylon ribbon)

are used should be smear tested regularly. (see paragraph 35.14(bX5)) or (b) more than 10 micro curies of an alpha emitter (see paragraph 31.5(cX2Xii))

1.9 Surveys of Packages Received and Packages Prepared must be leak tested for contamination or leakage at inter for Shipment vals not to exceed 6 months unless a different interval is specified for a particular manufactured source under the External radiation measurements and tests of external provisions of paragraph 32.74(b) of I OCFR Part 32, "Speci surfaces of packages received or packaged for shipment fic Domestic Licenses to Manufacture or Transfer Certain

"should be carried out near the receiving or packaging point Items Containing Byproduct Material." Further provisions to avoid unwarranted radiation exposures and inadvertent and exceptions to leak-testing requirements are established contamination of personnel or the hospital. Surveys and in paragraphs 35.14(b) and 35.14(eXl) of 10 (FR Part 35.

labeling must comply with the NRC's regulations (see Any specific license conditions must also be followed.

§§20.203. 20.205. 32.19. and 32.70 through 32.74 of

10CFR Parts 20 and 32) and with any specific license 1.12 Calibration and 3 Source Checks of Radiation Survey conditions. Delivery of packages within the hospital should Instruments also be monitored. Any delivered containers of radioactive material must be labeled as required by paragraph 20.203(f). An adequate calibration of survey instruments cannot be All packages bearing yellow II or yellow III Department of performed with built-in check sources. Electronic calibra Transportation (DOT) labels should be transported by cart. tions that do not involve a source of radiation are also not Only adequately shielded sources should be transported. adequate to determine the proper functioning and response Internal containers of packages containing significant of all components of an instrument.

amounts of radioactive materials should not be ope-ned until the containers have been placed in the appropriate Daily constancy checks of survey instruments should be protective facility (e.g., hood). made before and after each use and should be supplemented at least every 12 months with a battery check and two-point All personnel, including security guards, should be i-alibration (at about 1/3 and 2/3 of full scale) on each scale adequately- instructed in performing at least an initial of the instrument to be used for radiation protection inspection survey for leakage or damage before transporting surveys. Survey instruments should also be calibrated after any packages of radioactive materials through hospital repair or maintenance that may affect the calibration of the areas. The written instructions should clearly indicate instrument.

which packages should be transported by cart rather than hand-carried. A survey instrument may be considered properly cali brated at one point when the exposure rate measured by

1.10 Checks on Posting of Caution Signs, Labels, Signals, the instrument differs from the true exposure rate by less Controls, and Notices to Employees than 10 percent.

T1he radiation safety staff should perform surveillance Each source used for calibration shouId be certified during the surveys described in Table 1 to ensure that (Ref. 25) in radioactivity content to within 5 percent by signs, labels, radiation alarm signals, other access controls. the supplier. Alternatively, each source may be calibrated and required Notices to Employees, copies of licenses, and

3 other items are properly posted, legible, and operative, as in order to keep personnel exposures ALARA, high-range scales (e.g., above I R/h) should not be calibrated when they will not be required by 10 (FR Part 11), -Notices, Instructions and needed in a particular installation. Also, a sufficient variety of Reports to Workers- Inspections." and Part 20 or by license instruments should be available and calibrated on all scales as needed for the types of radiation and the ranges of intensity or conditions. Radiation alarm signals should be routinely exposure to be measured. Item 9 of Regulatory Guide 10.8 (Ref. 29)

tested for operation by use of appropriate check sources specifies certain types of instruments generally required in a typical nuclear medicine laboratory and information on instrumenltation to to ensure proper functioning of the alarms. Microswitches be submitted with a license application.

8.23-5

for dose rates at given distances. Each source should also be Icorrected for decay as of the day on which the source is used for survey instrument calibration. All decay corrections

1. 15 Surveys in In-Hospital Unrestricted Areas Unrestricted areas should be surveyed periodically to should he included in the radiation safety records system. A ensure that radiation and radioactive material are adequately posted graph for each source is convenient" helpful in confined in restricted areas, except in cases where these avoiding calculational errors, easily available forinspection. inaterials must he transported between areas. Recommenda and acceptable for obtaining source intensity within the tions in References 4, 5, I1. and 14 should be followed required accuracy. For automatic range-changing instru when transporting radioactive materials or patients emitting ments or instruments with more than one decade on a radiation from licensed radioactive materials through logarithmic scale, a calibration near the mid range of hallways or other unrestricted areas of the hospital. Such each decade should be adequate. except that a two-point transportation should be surveyed and planned with a check should be used on at least one of the decade ranges. member of the radiation safety staff.

Readings obtained from the calibration verifications 1.15.1 Surface Contamination Surveys should be recorded, preferably by plotting the reading on the instrument calibration curve where applicable. Other Removable surface contamination surveys in unrestricted instruments should be calibrated at frequencies suggested areas in which linencapsulated radioactive materials are by Ihe manufacturer. Check sources should he used to used or where contamination may be likely to occur should check the continued accuracy of all instruments each time be performed and recorded at frequencies consistent they are used in the field, preferably before and after each with the potential for spreading contamination but no less series of measurements. (See also Regulatory Guide 10.8, frequently than quarterly. Random smear testing of floors

"Guide for the Preparation of Applications for Medical alone is acceptable for most unrestricted areas. In cafeterias Programs" (Ref. 29).) and snack bars, furniture and equipment, as well as floors.

should also be surveyed. If such surveys reveal that radio

1.13 Surveys of Protective Clothing Before and After active contamination is being transferred out of restricted Laundry areas, immediate corrective action should be taken to eliminate such transfers. Decontamination efforts should be Surveys of protective garments and linens should be repeated until it is evident that subequent efforts would not performed prior to release to a conventional laundry. significantly reduce contamination levels. If contamination Garments and linens should be released to such a laundry is found, unrestricted areas should be surveyed more only if contamination levels do not exceed those given on frequently (e.g., daily or weekly) until a trend of negative line 3 of Table 2.. Items contaminated with short-half-life results is again established. The applicant or licensee may material that exceeds the levels given on line 3 of Table 2 propose and justify permissible contamination levels should be contained in leakproof bags and transported in following decontamination efforts described above for carts to controlled storage areas for decay. Items contami unrestricted areas. The limits given on line I of Table 2 arc nated with long-half-life material may be disposed of as acceptable to the NRC staff and need not le justified by radioactive waste or sent for decontamination to a laundry the licensee or applicant.

licensed by the N RC or by an Agreement Start.

1.15.2 Radiation Surveys

1.14 Ventilation Surveys Radiation surveys in unrestricted areas adjacent to Where enclosures such as fume hoods are necessary to restricted areas should be performed and recorded at protect workers'from unencapsulated radioactive material. frequencies consistent with the types and quantities of measurements of the face velocity at the enclosure entrance material in use but no less frequently than quarterly. These should be made quarterly to ensure that the airflow is surveys should be made in areas adjacent to restricted areas adequate.4 Such measurements should be made by using a and, when exposures may occur, in all areas through which properly calibrated thermoanemometer or velometer to radioactive materials are transferred and temporarily stored determine whether the airflow has been reduced to unaccept before shipment. Radiation levels in these areas should be able levels by filter loading or by the malfunction of "evaluated to determine whether they comply with the blowers, fans, etc. The mninimum average face velocity for a requirements of § 20.105 of 10 CFR Part 20.

fume hood with the sash in the operating position or for an opening in a special enclosure should be 100 ft/min as 1.16 Surveillance determined from at least five different measurement points. Airflow monitoring devices such as inclined manom 1.16.1 Surveillance by Individual Performing Surveys eters should also be available for the user to check for proper airflow during each use. Corrective action should be The term "surveillance." as used in this section. refers to taken as soon as possible when the face velocity is found to observations of radiological working conditions in restricted be deficient. Records should be kept of airflow measure areas made by the person who performs the routine radia ments and any corrective actions. tion and contamination surveys. Such surveillance is one of

4 Where filtered exhausts are employed, devices such as U-tube the more important aspects of a radiation protection pro manometers should be provided to indi~ate the pressure drop across gram. Through surveillance, radiation safety personnel the filters, thus affording an early indication of airflow loss at enclosures. acquire detailed knowledge of e:ich operation as necessary

8.23-6

(a) to identify ways of preventing or minimizing occupa Although the frequencies of routine surveys depend on tional exposures, (b) to select appropriate times for making many factors, as stated above, and should be designed for radiation safety measurements, and (c) to adequately prepare the specific medical practices and facilities involved to for emergency conditions. Radiation safety personnel should maintain exposures as low as is reasonably achievable, be sufficiently familiar with each activity to explain it in minimum frequencies acceptable to the NRC staff for detail, to describe potential hazards and the precautions meeting the requirements of § 20.201 of 10 CFR Part 20

taken to minimize exposures, and to discuss how this are given in Table I of this guide.

knowledge of procedures within each activity has influenced the selection of appropriate times for performing radiation safety measurement

s.

3. Records of Surveys

1.16.2 Regular Inventory of Radioactive Material, Audit of Procedures, and Instruction of Personnel. Reference should be made to § § 20.401 and 30.51 and to 10 CFR Parts 31-35 for recordkeeping requirements The surveillance program includes the following: regarding surveys related to the receipt, use, packaging, transfer, and disposal of byproduct material. Section 20.401 a. Regular inventory of radioactive materials and requires that licensees maintain records in the same units their locations, used in Part 20 (see Table 4). Thus, external exposure rates should be recorded in estimated maximum dose equivalent b. Frequent audits of radiation safety procedures and units to relevant parts of the body as specified in Part 20.

the uses and amounts of material in process compared to Air concentration measurement results should be recorded licensed possession limits, and in units of pCi/ml, and surface contamination measurement results should be recorded in units of dpm/100cm 2 or c. Discussions with personnel to ensure their continued uJCi/100cm 2 (or as in §20.5).

awareness of safety procedures and the appropriateness of their instruction and training for the tasks they are performing. Record retention requirements are specified in the regulations cited above. Paragraph 2 0.401(cX2) requires These surveillance activities may be performed during that survey records be preserved for 2 years, except that the performance of other survey measurements or tests. records of air monitoring and (in theabsence of personnel The surveillance should be performed at least annually by monitoring data) records of surveys to determine external the Radiation Safety Officer in the presence of a manage radiation dose (see paragraph 20.401(cX2Xii)) are to be ment representative as a management audit. The manage maintained until the NRC authorizes their disposition.

ment audit should be comprehensive enough to provide management with an awareness of the nature and impor Records may be maintained in logbooks or on special tance of activities conducted for personnel protection and forms as long as they are clear, legible, understandable, and hospital safety. A sample checklist that can be useful in authenticated . by authorized personnel. Survey records auditing as well as in carrying out radiation surveys is should include the model and serial numbers of instruments presented in Appendix B. used and efficiencies of counting where appropriate. The signature of the person making the record and the date

2. Frequency of Surveys should be on the same page as the record and should immediately follow each record entry. Either the original or The frequency of routine surveys depends on the nature, a reproduced copy or microform (duly authenticated) may quantity, and use of radioactive materials, as well as the be maintained to meet the storage requirements of § 20.401.

specific protective facilities, equipment, and procedures that are designed to protect the worker from external and D.i IMPLEMENTATION

internal exposure.

The purpose of this section is to provide informnation to Generally, surveys should be performed before radioac applicants and licensees regarding the NRC staff's plan for tive materials are used in a new procedure and area in order using this regulatory guide.

to establish a baseline of background radiation levels and radioactivity from natural sources, including structural com Except in those cases in which the applicant or licensee ponents of the facility, and any already existing operations proposes an acceptable alternative method for complying with radiation sources in nearby rooms or facilities. These with specified portions of the Commission's regulations, the baseline surveys should be performed under the various staff will use the methods described herein after April 1, conditions to be expected in routine hospital procedures. 1981, in evaluating applications for specific materials licenses for medical institutions or (in conjunction with Surveys should be repeated after routine procedures inspections of performance) for evaluating survey programs begin with normal levels of radioactive material and with established by licensees.

potentially exposed persons present and carrying out their functions. Surveys should also be conducted after significant If an applicant or livensee wishes to use the method changes in the quantities of radioactive material handled, in described in this regulatory guide on or before June 1, 1981,1 the quantities present at any one time, or in protective the pertinent portions of the application or th. licensee's equipment or procedures. performance will be evaluated on the basis of this guide.

8.23-7

Table 1 SURVEY FREQUENCIES

I. All elution, preparation, and injection areas should be surveyed daily with a survey meter and decontaminated if necessary.

2. Laboratory areas where only small quantities of radioactive material (less than 200

l.Ci at any one time) are used should be surveyed monthly.

3. All other laboratory areas should be surveyed weekly.

4. The weekly and monthly surveys should consist of the following- a. A measurement of radiation levels with a survey meter sufficiently sensitive to detect

0.1 mR/h.

b. A series of smear tests to measure contamination levels. The method for performing smear tests should be suffi ciently sensitive to detect the limits in Table 2 to one significant digit.

c. Any air sample measurements necessary to determine compliance with § 20.103 of 10 CFR Part 20 in cases where calculations alone are not sufficient.

Table 2 RECOMMENDED ACTION LEVELS FOR REMOVABLE SURFACE CONTAMINATION

IN MEDICAL INSTITUTIONS*

Type of Radioactive Material**

Low-Risk Beta or Alph Emitters Beta or X-Ray Emitters X-Ray Emitters Type of Surface (tICi/em2) (dpm/10Ocm 2 ) (tJCil/m 2 ) (dpm/100cm 2 ) (PjCi/cm 2 )1 (dpm/1iOcm2 I. Unrestricted areas 10"- 22 10-6 220 10-s 2,200

2. Restricted areas 10-6 220 10-1 2,200 10.4 22,000

3. Personal clothing worn 10"1 22 10-6 220 10"s 2,200

outside restricted areas

4. Protective clothing worn 10-6 220 10"5 2,200 10"4 22.000

only in restricted areas

5. Skin 106 220 10-6 220 10s 2,200

  • OAsacapted from Table I of Reference 10. Averaging is acceptable over nonliving areas of up to 300

cm2 or, for floors, wall, and ceiling, O0cm'. Averaging is also acceptable over 0 cm forskin or, for the hands, over the whole area of the hand, nominally 300cm .

    • Beta- or x-ray emitter values are applicable for all beta- or x-ray emitters other than those considered low C-14, H-3, S-35, Tc-99m, and others whose beta energies are less than 0.2 risk. Low-risk nuctides include at I meter per curie, and whose permissible concentration in air (see to CFRMeV maximum, whose gamma-or x-ray emission iý le,.s than 0.1 R/h Part 20. Appendix B, Table I ) is greater than 10 IA.i/ml.

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Table 3*

ACCEPTABLE SURFACE CONTAMINATION LEVELS FOR UNCONTROLLED RELEASE OF EQUIPMENT

Nuclidea Averageb,e Maimumb,d Removablebc U-nat, U-235, U-238, and 5,000 dpm ct/l00 cm 2 15,000 dfpm cV'100 cm 2 1,000 dpm c1 0 0 cm 2 associated decay products Transuranics, Ra-226, Ra-228, 100 dpm/100 cm 2 300 dpm/100 cm 2

20 dpm/100 cm 2 Th-230, Th-228, Pa-23 1, Ac-227,

1-125, 1-129 Th-nat, Th-232, Sr-90, Ra-223, 1,000 dpm/100 cm 2 3,000 dpm/100 cm 2 200 dpm/100 cm 2 Ra-224, U-232, 1-1.26, 1-131,

1-133 Beta-gamma emitters (nuclides 5,000 dpm *100 cm 2 15,000 dpm BV1100 cm 2 1,000 dpm $V100 cm 2 with decay modes other than alpha emission or spontaneous fission) except Sr-90 and others noted above.

Adapted from Regulatory Guide 1.86 (Ref. 30).

aWhere surface contamination by both alpha- and beta-gamma-emitting nuclides exists, the limits established for alpha- and beta-gamma-emitting nuclides should apply independently.

bAs used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as determined by correcting the counts per minute observed by an appropriate detector for background, efficiency, and geometric factors associated with the instrumentation.

cMeasurements of average contaminant should not be averaged over more than I square meter.

For objects of less surface area, the average should be derived for each such object.

dThe maximum contamination level applies to an area of not more than 100 cm 2 .

eaThe amount of removable radioactive material per 100 cm 2 of surface area should be determined by wiping that area with dry filter or soft absorbent paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency. When removable contamination on objects of less surface area is determined, the pertinent levels should be reduced pro portionately and the entire surface should be wiped.

Table 4"

CONVERSION FACTORS FROM OLD TO NEW RADIATION UNITS

Quantity Old Unit Symbol New Unit Symbol Conversion Factor Activity curie Ci becquerel Bq 1 Ci= 3.7 x 1010 Bq Absorbed dose rad rad gray Gy I rad IlcGy = 10.2 Gy = 10-2 J/k Dose Equivalent rem rem sievert Sv I rem = I cSv = 10.2 Sv Exposure roentgen R I R = 2.58 x 10-4 C/kg Conversion to the new SI units provided in this table will now be considered in compliance with this guidance.

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REFERENCES*

I. Regulatory Guide 8.10, "Operating Philosophy for 13, IAEA Technical Report Series No. 133, "Handbook Maintaining Occupational Radiation Exposures As on Calibration of Radiation Protection Monitoring Low As Is Reasonably Achievable," U.S. Nuclear Instruments," 1971.

Regulatory Commission (NRC), Washington, D.C.

20555. 14. IAEA Safety Series No. 25, "Medical Supervision of Radiation Workers," sponsored jointly by IAEA,

2. National Commission on Radiological Protection WHO, and International Labor Organization, 1968.

(NC-RP) Report No. 8, "Control and Removal of Radio active Contamination in Laboratories," December 15, 15. International Commission on Radiological Protection

1951. (ICRP) Publication 5, "Handling and Disposal of Radioactive Materials in Hospitals and Medical

3. NCRP Report No. 9, "Recommendations for Waste Research Establishments," 1964.

Disposal of Phosphorus-32 and Iodine-131 for Medi cal Users," November 2, 195 I. 16. ICRP Publication 12, "General Principles of Moni toring for Radiation Protection of Workers," 1969.

4. NCRP Report No. 10, "Radiological Monitoring Methods and Instruments," April 7, 1952 (revised 17. [CRP Publication 25, "The Handling, Storage, Use edition published in 1978). and Disposal of Unsealed Radionuclides in Hospitals and Medical Research Establishments," 1977.

5. NCRP Report No. 37, "Precautions in the Manage ment of Patients Who Have Received Therapeutic. 18. American Association of Physicists in Medicine Amounts of Radionuclides," 1970. (AAPM) Monograph No. 1, "Biophysical Aspects of the Medical Use of Technetium-99m," J.G. Kereiakes

6. NCRP Report No. 48, "Radiation Protection for and Karen R. Corey, Editors (available from AAPM,

Medical and Allied Health Personnel," August 1, Dr. James G. Kereiakes, E555 Medical Sciences

1976. Building, University of Cincinnati, Cincinnati, Ohio

45267), 1976.

7. NCRP Report No. 57, "Instrumentation and Moni toring Methods for Radiation. Protection," 1978. 19. Deigl, H., "Guidelines for Determining Frequency-of Wipe Samples," in Health Physics Operational Moni

8. NCRP Report No. 58, "A Handbook of Radio toring, Vol. i, C.A. Willis and J.S. Handloser, Eds.,

activity Measurements Procedures," 1978. Gordon and Breach, New York, p. 385, 1972.

9. NCRP Report No. 59, "Operational Radiation Safety 20. C. B. Meinhold, "Facility Monitoring Programs, Programs," 1978. Techniques, and Problem Solving," Health Physics Operational Monitoring, Vol. 1, C.A. Willis and

10.' International Atomic Energy Agency (IAEA) Techni J.S. Handloser, Eds., Gordon and Breach, New York, cal Report Series No. 120, "Monitoring of Radioac p.363, 1972.

tive Contamination on Surfaces," 1970.

21. C.A. Willis, "Safe Specific Activity: A Useful Concept

11. IAEA Safety Series No. 38, "Radiation Protection in Monitoring Areas Containing Activated Materials,"

Procedures," 1973. Health Physics Operational Monitoring, Vol. 1, C.A. Willis and J.S. Handloser, Eds., Gordon and

12. IAEA Safety Series No. 1, "Safe Handling of Radio Breach, New York, p. 373, 1972.

nuclides," 1973 Edition, Code of Practice Sponsored by the International Atomic Energy Agency and the 22. R.L. Kathren, "Instruments in thi Field: Use, Abuse, World Health Organization (WHO), 1-973. and Misuse," Health Physics Operational Monitoring, Vol. 2, C.A. Willis and J.S. Handloser, Eds., Gordon and Breach, New York, p. 811, 1972.

23. W.P. Howell and R.L. Kathren, "Calibration and NCRP reports may be obtained from NCRP Publications, P.O.

Box 30175, Washington, D.C. 20014. Field Use of Ionization Chamber Survey Instruments,"

IAEA reports may be obtained from UNIPUB, Inc.. P.O. Box 433, Health Physics Operational Monitoring, Vol. 2, New York, N.Y. 10016.

ICRP reports may be obtained from Pergamon Press, Maxwell C.A. Willis and J.S. Handloser, Eds., Gordon and House, Fairview Park, Elmsford, New York 10523. Breach, New York, p. 925, 1972.

ICRU reports may be obtained from ICRU Publications, P.O.

Box 30165, Washington. D.C. 20014.

NUREG-series documents may be obtained at current rates from the Distribution Services Section, Division of Technical Information 24. F.E. Gallagher, A.N. Tschaeche, C.A. Willis, J.C.

and Document Control, U.S. Nuclear Regulatory Commission, Evraets, and J.C. Rogers, "Progress on Surface Washington, D.C. 20555 or the National Technical Information Ser vice, Springfield, Virginia 22161. Contamination Standards," Health Physics Opera-

8.23-11

tional Monitoring, Vol. 3, C.A. Willis and J.S. Hand 29. Regulatory Guide 10.8, "Guide for the Preparation of loser, Eds., Gordon and Breach, New York, p. 1767, Applications for Medical Programs,"

1972. NRC.

30. Regulatory Guide 1.86, "Termination of Operating

25. Sommers, J.F., "Sensitivity of G-M and Ion Chamber Licenses for Nuclear Reactors," NRC.

Beta-Gamma Survey Instruments," Health Physics, Vol. 8, p. 755, 1975. 31. Regulatory Guide 8.18, "Information Relevant to Ensuring that Occupational Radiation Exposures

26. International Commission on Radiation Units and at Medical Institutions Will Be As Low As Reasonably Measurements (ICRU) Report 12, "Certification of Achievable," NRC.

Standardized Radioactive Sources," September 15,

1969. 32. NUREG-0267, "Principles and Practices for Keeping Occupational Radiation Exposures at Medical Institu tions As Low As Reasonably Achievable," NRC, 1977.

27. Regulatory Guide 8.20, "Applications of Bioassay for

1-125 and 1-131," NRC. 33. Blatz, Hanson, "Radiation Hygiene Handbook,"

McGraw-Hill, New York, pp. 22-27, 1959.

28. Regulatory Guide 8.26, "Applications of Bioassay for

34. Cember, Herman, "Introduction to Health Physics,"

Fission and Activation Products," NRC.

Pergamon Press, New York, pp. 334-339, 1969.

8.23-12

APPENDIX A

SURVEYS OF RADIOACTIVE XENON-133 RELEASES

Surveys associated with the use of xenon-133 should be 4. Emergency Procedures sufficient to show compliance with requirements for protection of persons in restricted and unrestricted areas Check to determine that all personnel using xenon-I 33 (see §§20.103 and 20.106) and with the terms and condi have been trained in the established emergency procedures tions of the N RC Materials License. Surveys may consist of to he followed in case of an accidental release of xenon-I133.

either measuremcents of airborne radioactivity or of calcula tions supported by records of xenon-133 used and measure 5. Air Concentrations of Xenon-133 in Restricted Areas ments of pertinent ventilation and air effluent volumes.

The procedures outlined below are acceptable for surveying Check to determine that air concentrations of xenon- 133 xenon-I 33 concentrations in medical institutions. in restricted areas meet the requirements of §20.103. This may be done by making physical measurements. Alterna Acccptable surveys would be indicated by records of the tively. this may be done by r'vicwing the use of xenon- 133 following information, procedures, or conditions: (Item L.a above), checking the ventilation rate in each area, and performing calculations sinuilar to those submitted with I. Quantities Used the license application (see Regulatory Guide 10.8, "Guide for the Preparation of Applications for Medical Programs"l.

a. Verify that patient information records (Items 1-3 If the results of the calculations indicate that air concentra below) are in order; compare with similar information tions of xenon- 133 (as averaged over one calendar quarter I

submitted to NRC in support of request for xenon-133. approach or exceed I x 10-" microcurie per milliliter, the licensee should consider and implement methods of increas (I ) Number of studies per week. ing ventilation rates or of reducing patient load.

(2) Activity administered to each patient. 6. Methods of Xenon-133 Disposal

(3) Comparison of numberofstudiesand average a. Dilution through exhaust systems activity administered to each patient with information submitted in application. Licensees who dispose of xenon-133 by release to the atmosphere through an air exhaust syslem are

1h. Verify that possession limits are controlled and required to perform surveys (i.e.. measurements or calcula corrected for differences in calibration date anti date tions) to ensure that they are in compliance with para of use; compare with possession limits stated in license. graph 20.1(c) and §20.106 of 10 ('FR Part 20. Para graph 20.1(c) requires that the concentrations of xenon-13

2. Survey Records for Use and Storage Areas in effluents to unrestricted areas be as low as is reasonably achievable by the current state of technology, and § 20.106

('heck ventilation quarterly in all areas in which requires that the concentrations averaged over a period of xenon-133 is used anti stored to ensure that airflow rates I year should not exceed 3 x 10"7 microcurie per milliliter.

are maintained in accordance with statements made in the license application. Make physical measurements to determine compli ance with §20.106 anti paragraph 20.1(c). Alternatively.

3. Procedures for Routine Use measure ventilation rate and. using xenon-133 data from Item L.a above, perform calculations similar to those sLibmitted with the license application (See Regtilatory a. ('heck to determine that procedures being followed Guide 10.8).

for routine use of xenon-133 are in accordance with pro cedures described in license application. ('heck to determine If the results indicate that air concentrations of that all personnel using xenon-133 have been trained in xenon-133 (as averaged over I year) approach or exceed these procedures for routine use of xenon- 133. 3 x 10i7 nicrocurie per milliliter. the licensee should consider and implement methods of increasing ventilation rates. reducing patient load, or decreasing amount of b. Check to determine that special apparatus for xenon-133 released (e.g., through use of a chaicoal trap).

administration anti collection of xenon-133 is being used as specified in the license application. If tile exhaust is released to a restricted area. e.g.. a roof to which access is controlled, surveys should include c. ('heck to determine that special procedures are checks to determine the effectiveness and continued being usLd to reduce leakage (e.g.. use of nose clamps or implementation of provisions submitted with lith license special enclosures) as specified in the license application. application to do the following: control access to the

8.23-13

restricted area; post appropriate warriing signs; instruct persons who may enter the area in accordance with § 19.1 2 ing basis at the frequency specified in the license applica of 10 CFR Part 19; monitor personnel entering the area: tion. Include monitoring of traps to determine wheil saturation occurs and when the filter must be replaced.

and survey the area.

Check the procedures for handling saturated filters, including the provisions of adequate shielding b. Adsorption onto charcoal traps and ventilation. Calculations should be made of average concen trations of xenon-133 in air at the exhaust and compared Surveys should be made to check leakage from charcoal trapping devices. If the exhaust is vented to the to the allowable limit.

outdoors or other unrestricted area, check to determine that air concentrations of xenon-] 33 averaged over 1 year USEFUL CONVERSIONS

do not approach or exceed 3 x 00"7 microcurie per milli I mCi = 103 WCi liter. See Item 6.a above.

1 ft 3 = 2.832 x 10 2 m 3 = 2.832 x 0 4 nul Record measurements to check the efficiency and lft 3 /min = 1.699 x 106 ml/h general performance of collection and trapping devices = 6.796 x 107 ml/40-h week according to specifications, both initially and on a continu- = .1.488 x 1010 ml/yr I week = 168h

8.23-14

APPENDIX B

SAMPLE CHECKLIST FOR RADIATION SURVEYOR

g. 10 CFR Part 19 signs.

Initiate contamination survey report for each lab.

4. Observe general laboratory conditions:

a. Check card for previous survey results, e.g., suc cessive red circles, nobody in. a. Food and drink preparation and use in radioactive b. Fill in name of Authorized User, Department, Build material areas?

ing and' Room Number, and Survey Date. b. Waste container overfilled?

c. Sketch floor plan. c. Dosimeters being worn?

d. Mouth pipetting?

t. Ask lab personnel (and record answers on report form):

a. What isotopes are being used? (Compare with what 5. Conduct laboratory survey using portable survey meter.

User is cleared for.)

b. Where in the lab are they used? a. Record external dose rate from accessible storage c. Where are isotopes stored? surfaces.

d. What was last order? (Compare with card record.) b. Record exposure rate from contaminated surfaces.

e. Is Authorized User available if needed? If not, give reason, e.g., on leave, out of country, terminated

6. Conduct smear survey:

employment.

f. In what other labs are isotopes used? (Compare a. Take first smear near or in lab entrance.

with card record.) b. Take several smears from floor and benches and g. Where is waste stored and disposed of? equipment as indicated by answers to earlier ques tions.

3. Check labeling.

7. Discuss 10 CFR Part 19 (Instructions to Workers)

a. Lab door-"Caution, Radioactive Material" (CRM) requirements.

b. Liquid waste sink-"Contaminated Liquid Waste"

(survey card should indicate radioactive sink-RS). 8. Complete results:

Is sink log posted? Is it being used?

c. Radioactive hood-"Caution, Radioactive Material" a. Count smears and list results on survey form.

(survey card should indicate radioactive hood-RH). b. Notify lab personnel of contamination, and note on

"Air Flow Check" white label with date no older than form who was called and date of notification.

4 months required. c. Identify all abnormal radiation safety conditions d. Refrigerator and other storage areas-"CRM," includ on survey form.

ing those in corridors.

d. Complete survey card, replace in file, and mail survey e. Radioactive waste containers-"CRM" or "Contami form copy to User.

nated Waste" should be lined with yellow plastic bag. e. If lab has contamination (significant), call User, f. Any area with external radiation over 2.5 mR/h request cleanup, and resmear.

should be labeled with "Caution, Radiation Area" f. Resmear when notified or call User if no resmear (CRA) and should be noted on survey form. (See was called for.

paragraph 20.202(bX2) and §20.203 of IOCFR g. File carbon copy of results form.

Part 20.)

8.23-15