ML20202C542

Forwards Amend 10 to License SNM-356

ML20202C542
Person / Time
Site:	07000391
Issue date:	02/22/1986
From:	Wurtz E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Faust J PRINCETON UNIV., PRINCETON, NJ
Shared Package
ML20202C526	List: ML20202C522 ML20202C542
References
104963, NUDOCS 8604110414
Download: ML20202C542 (2)

Text

I O O FEB 2 21986 License No. SNM-356 Docket No. 070-00391 Control No. 104963 Princeton University ATTN: Jack C. Faust Director Occupational Health / Safety Forrestal Campus Princeton, New Jersey 08544 Gentlemen:

Please find enclosed an amendment to your NRC Material License.

Please review the enclosed document carefully and be sure that you understand all conditions. If there are any errors or questions, please notify the Region I Material Licensing Section, (215) 337-5239, so that we can provide appropriate corrections and answers.

Please be advised that you must conduct your program involving licensed radioactive materials in accordance with the conditions of your NRC license, representations made in your license application, and NRC regulations. In particular, please note the items in the enclosed, " Requirements for Materials Licensees."

Since serious consequences to employees and the public can result from failure to comply with NRC requirements, the NRC expects licensees to pay meticulous attention to detail and to achieve the high standard of compliance which the NRC expects of its licensees.

You will be periodically inspected by NRC. A fee may be charged for inspections in accordance with 10 CFR Part 170. Failure to conduct your program safely and in accordance with NRC regulations, license conditions, and representations made in your license application and supplemental correspondence with NRC will result in prompt and vigerous enforcement action against you.

This could include issuance of a notice of violation, or in case of serious violations, an imposition of a civil penalty or an order suspending, modifying or revoking your license as specified in the General Policy and Procedures for NRC Enforcement Actions,10 CFR Part 2, Appendix C.

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We wish you success in operating a safe and effective licensed program.

l. Sincerely,

! Original signed B71

{ Edwin A. Wurts Edwin A. Wurtz, Ph.D.

Nuclear Materials Safety Section B Division of Radiation Safety

, and Safeguards

Enclosures:

I 1. Amendment No. 10

2. Requirements for Materials Licensees

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O o Princeton University omce of occupational Health & Safety James Forrestal Campus Princeton, New Jersey 08544 609 452 5294 January 20, 1986 License Nos: 29-0 85-24 Docket Nos: 030-00882

-356) 070-00391 SUD-381 040-05259 John E. Glenn, Ph.D., Chief Nuclear Materials Safety, Section B Division of Radiation Safety & Safeguards U.S. Nuclear Regulatory Commission, Region I 631 Park Avenue King of Prussia, PA 19406

Dear Dr. Glenn:

Enclosed you will find materials relating to recent changes in the Princeton University Radiation Safety Guide. These materials include instruction sheets directing actions necessary as well as a Revision Log and the Guide changes dated October 23, 1985.

Our records indicate that you have one copy of the Prince-ton University Radiation Safety Guide and we ask that you integrate the enclosed pages as indicated on the instruction sheets.

Very truly yours, 1_x .c - s - c5 Linda K. Tompkins -

Office Manager co' ikt C A

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s P < 1 o f* 2 Instructions Sheet for Radiation Safety Guide Revision The instructions below should be followed carefully. Obsolete pages are listed in the column headed " Remove following Pages." New and replacement pages are listed in the column headed " Insert Following Pages." It is important to follow the instructions in both columns. ,

Noto: Changes in policy and procedures are described briefly below; any other changes are of an editorial nature.

Remove following Pages Insert Following Pages Section (Dated December 5, 1979) (Dated October 23, 1985) Description of Changes Master Revision Sheet

• Revision Log

• O Title page* Title page*

Table of Contents i - iv i-u 1 1.1 - 1.5 1.1 - 1.6 Paragraph 1.B.1.a: ALARA philosophy formally stated 2 2.1 - 2.4 2.1 - 2.4 4 4.1 - 4.6 4.1 - 4.6 Paragraph 4.B.l.c: Departmental role in determining Authorization Number eligibility added 6 6.1 - 6.3 6.1 - 6.3 Paragraph 6.F: Keeping of survey lll records made obligatory Paragraph 6.I: Radiation worker training requirements and program changed 9 9.1 - 9.3 9.1 - 9.5 Paragraph 9.A: Posting requirements for various licenses and laboratories clarified

• Date does not appear in lower right corner

T 2 cf 2 Remove Following Pages Insert Following Pages Section (Dated December 5,1979) (Dated October 23, 1985) Description of Changes 10 10.1 - 10.5 10.1 - 10.7 Paragraph 10.D: Operational survey requirements changed Paragraph 10.E: Personal survey' requirements changed Paragraph 10.F: Eating and food storage restrictions clarified Paragraph 10.P: Securityrequiremeh clarified 11 11.1 - 11.3 11.1 - 11.3 Paragraph 11.B: Finger dosineter policy explicitly stated 12 12.1 - 12.4 12.1 - 12.5 Throughout Section 12: Criteria for bioassays and frequency of bioassays changed O

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REVISION LOG To help ensure that your University Radiation Safety Guide is kept complete and current, the following log is provided to you as a summary of revisions made to the 4th Edition of the Guide. This log should be kept in the front of your Guide until the next revision and its accompanying revision log are issued.

All pages in the Guide are dated December 5, 1979, except for the following pages:

) Dated December 7,1979 Pages 15.1 - 15.7 Dated March 15, 1983 Pages B.1 - B.14 Dated September 20, 1985 Pages A.1 - A.3 Dated October 23, 1985 Pages 4-v 1.1 - 1.6 1

2.1 - 2. 4 4.1 - 4.6 6.1 - 6.3 9.1 - 9.5 10.1 - 10.7 11.1 - 11.3 12.1 - 12.5 1

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O O PRINCETON UNIVERSITY RADIATION SAFETY GUIDE RULES, REGULATIONS & PROCEDURES Edited by j the Health Physics Staff I of the l

t Office of Occupational Health and Safety and Approved by

.i the Radiation Safety Comittee

, and a

the Comittee on Occupational Safety and Health

First Edition June,1962 Second Edition June, 1965

Third Edition September,1967 3

Fourth Edition December,1979 5 Fourth Edition: Revised October, 1985 met N )

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O O TABLE OF CONTENTS P.agg PREFACE i

1. RADIATION SAFETY PROGRAM A. Introduction 1.1 B. Radiation Safety Program 1.2

2. DEFINITIONS 2.1

3. RESPONSIBILITY FOR COMPLIANCE WITH UNIVERSITY AND GOVERNMENT RADIATION SAFETY REGULATIONS A. Ultimate Responsibility 3.1 B. Responsib111 ties of the Health Physics Section 3.1 C. Committee Attention 3.1 D. Government Regulations 3.1 E. License Conditions 3.2

4. AUTHORIZATION FOR RADI0 ISOTOPES (INCLUDING ACTIVATED MATERIALS) AND AUTHORIZATION PROCEDURES A. Authorization 4.1 B. Classes of Authorizations: Description 4.2 C. How to Apply for Authorization 4. 5 D. Processing and Review of Applications for Authorization 4.5

5. AUTHORIZATION AND REGISTRATION FOR " RADIATION PRODUCING MACHINES AND DEVICES" A. Approval 5.1 B. Authorization Procedure 5.1 C. State Registration 5. 2 D. Requirements 5.2 E. Purchase Orders 5.2 F. Changes in Responsibility or Location 5.2

6. THE " AUTHORIZED USER'S" RESPONSIBILITIES A. Acquisition of Authorization 6.1 B. Supervisory Responsibility 6.1 C. Familiarity with Radiation Safety Guide 6.1 D. Compliance with Government Regulations 6.1 E. Radiation Safety 6.1 F. Records 6.1 G. Survey Instruments 6.2 H. Reporting of Incidents 6.2 I. Training and Orientation of Personnel 6.2

_e J. " Radiation Worker List" 6.3 October 23. 1985 l

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O TABLE OF CONTENTS cont.

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J. Airborne Radioactivity 10.5

{ K. Pipetting 10.5 L. Dummy Runs 10.6 j M. Working Surfaces 10.6

! N. Labelling 10.6 O. Opening of Shipments 10.6

P. Security 10.6 Q. Special Equipment and Requirements 10.6 R. Animal Use and Care 10.7 i

11. EXTERNAL DOSE CONTROL AND PERSONNEL MDNITORING l A. Control 11.1

, B. External Monitoring Requirement 11.1

{ C. Centralized Personnel Monitoring Program 11.1 j D. Suspected Overexposures 11.2

E. Exposure of Minors 11.3

! F. Exposure of Pregnant Women 11.3 G. Exposure of Visitors 11.3 l

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12. INTERNAL DOSE CONTROL AND BI0 ASSAYS 1

A. Control 12.1 l B. Internal Monitoring Requirement 12.1 1

13, LEAK TESTING REQUIREMENTS FOR " SEALED SOURCES" AND

" GENERALLY LICENSE 0 DEVICES" e A. " Sealed Sources" 13.1 l B. " Generally Licensed Devices" 13.2 C. Leakage Defined 13.2 O. Filing of Report 13.2 .

E. Performance of Test 13.2 l

14. TRANSPORTATION AND SHIPMENT OF RADI0 ACTIVE MATERIALS

! A. Intra Campus Transportation 14.1

! 8. Off Campus Transportation 14.1

) C. Selected Shipping Regulations 14.2 3 15. RADIOACTIVE WASTE DISPOSAL A. Centralized Radioactive Waste Disposal Program '

15.1

B. Sanitary Sewage System 15.2 Incineration and Burial C. 15.3 ',

j D. Radioactive Waste Disposal Procedures 15.3

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v i O O l TABLE OF CONTENTS cont. i l

E. Roentgens, Rads. Rems and Other Units

F. Gamma and Beta Dose Rate Data l G. Neutron Dose Data

H. Relative Hazard from Absorption of Various Radioisotopes into

the Body

I. Hazards of Analytical X-Ray Equipment I

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1. RADIATION SAFETY PROGRAM A.

• Introduction l

In September 1971 a consolidation and reorganization of the Princeton University safety organization was completed, and a comprehensive, integrated occupational health and safety program established. This was done, in the words of former President Goheen. "... to better carry out the responsibility we [the University) assume to prevent, to the best of our ability, injury and death to students, staff and members of the general public...and to enable the institution to dischar'ge its legal, moral and regulatory obligations more effectively and efficiently." Since radiation safety is an integral part of the University's health and safety program, an understanding of the overall structure and organization is essential to an understanding of the radiation safety program.

The four primary components or elements of the University's safety organization include a University Committee on Occupa-tional Safety and Health, responsible for policy; an Office of Occupational Health and Safety, responsible for monitoring the implementation of the Committee's decisions; a network of

" Departmental Health and Safety Coordinators"; and an explicit statement of health and safety policy.

The University Committee on Occupational Safety and Health is i appointed by the Dean of the Faculty on behalf of the President and consists of faculty research staff members, and University administrators and those ex officio members necessary for the conduct of the Committee's business. The Committee ' normally meets several times during the academic year and is responsible for developing health and safety policy, advising the President and monitoring the progress of the health and safety program.

A list of the membership is included in Appendix A.

The Office. of Occupational Health and Safety is a division of the University's Health Services. Its staff, consisting of health physicists, industrial hygienists, safety engineers, a sanitarian and supporting clerical and technical staff, functions in an advisory'and consultive capacity. They assist the academic and operating departments in the implementation of the health and safety policy and in maintaining compliance with

all applicable Federal, State and local health ' and safety regulations and standards. The health and ~ safety staff provides a variety of services, consultations, evaluations and audits. The Director of the Office of Occupational Health and Safety is responsible to the Director of the University Health

( Services who, in turn, is responsible to the Vice President for i Administrative Affairs. The Director also serves as Executive i

Secretary for the Committee. A list of the senior Occupational I

Health and Safety staff is included in Appendix A.

October 23, 1985

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2. Radiation Safety Committee The Radiation Safety Comittee is appointed by the Dean of the Faculty on behalf of the President on recomendation of the Chairman of the Committee on Occupational Safety and ,

It consists of faculty, research staff members,

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and University administrators, several of whom are knowl-edgable in the safe use of " Sources of Radiation," and certain ex officio members. The Radiation Safety Comittee develops and recommends radiation safety policy to its parent committee and monitors the progress and continuity of the radiation safety program. Additionally, and in accordance with the requirements of the various University radioactive materials licenses. the Comittee reviews. and either approves or denies applications for proposed usage of " Sources of-Radiation." Since most of the work of this Committee is done on a continuing basis, formal meetings of the Comittee are infrequent . normally one or two per year. A list of the membership is included in Appendix A. p

3. Health Physics Section The " Health Physicists" and supporting technical staff comprise the Health Physics Section of the Office of Occupational Health and Safety. The Head of the Health Physics Section reports to the Director of the Office of Occupational Health and Safety. The " Health Physicists" are listed in Appendix A.

The health physics staff provides a variety of radiation safety services, evaluations and audits, all directed towards assisting the " Authorized User" and his or her department in implementing the radiation safety policy and in controlling exposure to radiation and radioactive materials. The group functions with a strong service orientation, informing the " Authorized User" of his or her obligations and assisting the " User" to anticipate and '

identify potential radiation safety problems. In carrying out these responsibilities, every reasonable cffort is made to relieve the research and operating staffs of as much of the mandated administrative and record keeping detail as is possible. In addition, a number of technical measure-ments and evaluations are made as a service to the " Author-ized User." However, it is neither possible nor desirable to relieve the " Authorized User" of the binding responsibility to ensure that " Sources of Radiation" under his or her control are used safely and in accordance with all' applicable rules and regulations.

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o. auditing the progress and continuity of the radiation safety program

p. developiag and refining radiation detection, shielding and health protection techniques

q. when appropriate, representing the University at public hearings concerned with questions of radiation safety

r. provision of advice and assistance to academic and i

operating departments for the acquisition of radiation' detection and dosimetry equipment

s. provision of assistance in the design of new and renovated laboratories in which " Sources of Radiation" are to be used

t. acting as primary liaison between the University, the

" Authorized Users" and the various regulatory agencies and accompanying regulatory personnel during their inspection of any University operation.

5. Radiation Safety Responsibilities of the " Departmental Health and Safety Coordinator" The role of the " Departmental Health and Safety Coordina-4 tor" has been described elsewhere; however, there are specific responsibilities in those departments where

" Sources of Radiation" are used. These include:

a. reviewing and approving, denying or acknowledging, on behalf of the Department, applications for authoriza-tion for " Sources of Radiation";

b. arranging for the appointment of an alternate coordina-tor during an extended absence. The Office of Occupa-tional Health and Safety should be notified of a,ll such appointments and the effective dates; and,

c. other duties as assigned by the department chairman.

6. Broad License The existence of a comprehensive University radiation safety program enables the University to hold a Nuclear Regulatory Commission broad byproduct materials license.

Under this concept the Nuclear Regulatory Commission delegates its responsibility to license the possession and  :

use of radioactive materials to the University Radiation L Safety Committee in accordance with the procedures and i:

guidelines established in this Guide and in the Universi-ty's license application. This _ concept has over the October 23, 1985 f.

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2. DEFINITIONS l When any of the following defined terms appear in the text of this Guide, their meaning is as defined below, and they appear within quotation marks, and the first letter of each word is capitalized.

A. " Airborne Radioactivity Area" Any room, enclosure, or operating area in which airborne radioactive materials exist or are likely to exist in concen-trations in excess of the amounts specified in Table 1. Column 1 of Appendix B, or in which they exist in concentrations which when averaged over the number of hours in any week during which individuals are in the area, exceed 25 percent of the amount specified above.

B. " Authorized User" The individual who has been authorized (licensed) by the Radiation Safety Committee to possess and use " Sources of Radiation." This includes individuals possessing Authorization Numbers and/or Limited Possession Numbers and individuals authorized to possess and/or use " Radiation Producing Machines and Devices."

C. " Byproduct Material" Any radioactive material (except "Special Nuclear Maurial")

yielded in or made radioactive by exposure to the radiation incident to the process of producing or utilizing "Special Nuclear Material."

0. " Controlled Area" See " Restricted Area."

E. " Departmental Health and Safety Coordinator" The individual (s), appointed by the department chairman or office head, who is responsible for the departmental health and safety effort and who is the department's primary liaison with the staff of the Office of Occupational Health and Safety.

F. " Generally Licensed Devices" Devices and equipment into which radioactive materials are built, the distribution of which to the general public is authorized under the terms of a general license, in accordance with 10 CFR Part 31.

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2.3 O O N. " Radiation Producing Machine or Device" i

A machine or device capable of generating radiation . such as

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X-ray producing machines, particle accelerators, high voltage l power supplies, electron microscopes, high voltage rectifiers, I high voltage projection equipment, and other types of high voltage machines.

In general, each single unit capable of producing radiation must be considered as a separate device; however, at the discretion of the " Health Physicist " a number of units which

- form an administrative, spatial, or functional entity, and which may be combined, modified, and/or separated during the course of a research program, may be considered one device.

O. " Radiation Worker List" A list generated and maintained by the Office of Occupational Health and Safety on which the " Authorized User" provides the names and supplemental information for individuals working with " Sources of Radiation" under his or her authorization.

P. " Restricted Area" Any area, access to which is controlled by the department or

" Authorized User" for the purpose of protecting individuals from exposure to radiation and radioactive materials. The State of New Jersey uses the term " Controlled Area."

3 NOTE: Restricted Area" includes all " Radiation Areas," "High Radiation Areas." rooms or areas in which there are present radioactive materials in such quantities that " Caution:

i Radioactive Material" signs are required in accordance with l

Section 9 of this Guide, and certain other areas which may be so defined by the " Health Physicist."

l i Q. " Sealed Source" A radioactive material that is permanently bonded or fixed in a capsule or matrix designed to prevent release and dispersal

{ of the radioactive material under the most severe conditions i which are likely to be encountered in normal use and handling

] and which is used in that configuration.

I R. " Source Material" Uranium or thorium or any combination thereof, in any physical or chemical form; or ores which contain by weight 0.05 percent-or more of uranium, thorium, or any combination thereof.

" Source Material" does not include "Special Nuclear Material."

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O O I4, AUTHORIZATION FOR RADI0 ISOTOPES (INCLUDING ACTIVATED MATERIALS) AND AUTHORIZATION PROCEDURES A. Authorization

1. All persons planning to possess or use radioisotopes at Princeton University must obtain prior approval of the

, Radiation Safety Committee and/or the " Health Physicist" i for each radioisotope. Persons not qualified for authori-zation, according to the requirements stated in Section B below, must use radioisotopes only under the supervision i

of an " Authorized User."

2. The first step to obtain authorization is the filing of an application through the Office of Occupational Health and Safety. Applicants are advised that the application process may take several weeks (or longer if an amendment to a University license must be obtained) and are, there-fore, urged to submit their application sufficiently in advance of the planned starting date to avoid delays. The filing of an application sets in motion a procedure which provides for a thorough review of the . radiation safety aspects of the proposed usage. The final step in -the procedure is the issuance by the Office of Occupational Health and Safety of an Authorization Number or a Limited Possession Number.

3. Temporary Approval The " Health Physicist" is authorized by the Committee to grant a temporary approval, if specifically requested by the applicant. However, such approval, is granted at the

} discretion of the " Health Physicist" and is dependent upon

receipt of a completed application. Temporary approval is

! valid for 30 days and is normally issued within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> of l receipt of a properly completed application.

4. Duration of Authorization 4

Each Authorization Number and Limited Possession Number is

! coterminous with the applicable University license or l terminates with the severance from the University of the

" Authorized User." In some instances specific expiration -

dates are established at the request of the " Health Physicist."

l S. Revocation The Committee has the right and responsibility to revoke

! any authorization granted by it i f, in its opinion.

l sufficient justification exists for such action.

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d. The amount of . radioactive material and the scops of work permitted under an Authorization Number is, in general, limited by the terms and conditions of the relevant University license.

2. Limited Possession Numbers ,

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a. A Limited Possession Number is a restricted or limited l Authorization Number. The scope of the activities permitted and the required qualifications of the applicant differ in the following ways: 1 1

1) The applicant does not have to meet the qualifica- l tions established for a " Principal Investigator."  !

Less emphasis is placed on previous experience  !

with " Sources of Radiation." Therefore, the scope of work permitted is restricted.

2) The maximum amount of radioactivity authorized for use by an individual holding a Limited Possession Number is limited to 100 times the amount listed in column A of Appendix C of a single radioisotope or the equivalent prorated quantity of sev$1 as illustrated in the footnote to Appendix C, except that the total amount for any radioisotope may not exceed 15 mC1. However, persons holding at least one valid Authorization Number and therefore meeting' the qualifications of a "Princi-pal Investigator may hold an unlimited number of Limited Possession Numbers, provided no single quantity authorized exceeds the amount described above for a single radioisotope.

. 3) Limited Possession Numbers are issued at the discretion of the " Health Physicist" and without Committee review, although the Committee is periodically informed of all new limited Possession Numbers issued. The " Health Physicist" may, at his or her discretion, elect to require full Committee review.

b. Limited Possession Numbers are also issued to authorize possession of " Generally Licensed Devices " such as smoke detector heads, spark gaps, thickness gauges, etc., which contain radioactive material. The licenses 1 for all such devices have general requirements, the specifics of which are dealt with in the application process.

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1) The person desiring the activation must demonstrate to the Office of Occupational Health and Safety that his or her organization is duly authorized to  :

possess and use the requested materials under the l provisions of an appropriate government license.

$ 2) The " Health Physicist" is responsible for reporting l the transfer on the next monthly radioisotope

inventory and the next State Report, indicating the i amount of activity, and the date of transfer, the

, recipient, and the address of organization. ,

c. An "offsite" activation .is one performed for Princeton

University personnel at an off campus facility not

! owned or operated by the University when the resulting l radioactivity, however small or purified, is to be i brought on campus. Persons desiring such an activation

must obtain an Activation Authorization Number.

C. How to Apply for Authorization

1. Obtain the necessary forms from the Office of Occupational

Health and Safety and discuss the proposed work with the

! " Departmental Health and Safety Coordinator" and the

" Health Physicist."

2. Complete the forms, making sure that they are consistent j with the guidelines given in Section B above for Authoriza-tion Numbers or Limited Possession Numbers. Please type or

print in black ink.

3. Consult with the " Health Physicist" to review the proposal and to obtain any assistance needed to complete the j

application.

4. Sign the completed application and obtain the signature of the " Departmental Health and Safety Coordinator" (or in his or her absence the signature of the department chair-man). Forward the completed application to the Office

of Occupational Health and Safety.

, D. Processing and Review of Applications for Authorization

1. Authorization Numbers

, Upon receipt of a completed application:

a. The " Health Physicist" reviews the application, i

interviews the applicant, inspects .. the proposed facilities, and, on the basis of the information obtained, recommends either that the application be 1

October 23, 1985

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6. THE " AUTHORIZED USER'S" RESPONSIBILITIES ,

A.' Acquisition of Authorization Before any person can begin work with " Sources of Radiation,"

he or she must satisfy the Radiation Safety Comittee and/or the " Health Physicist" through the authorization process that he or she is qualified by training and experience and that the laboratory is properly equipped to handle them safely. Persons not meeting the requirements _for authorization must work with i

" Sources of Radiation" only under the supervision of an

" Authorized User."

B. Supervisory Responsibility -

The " Authorized User" assumes responsibility for the actions of those persons using " Sources of Radiation" under his or her supervision.

C. Familiarity with Radiation Safety Guide i The " Authorized User" shall become acquainted and comply with the Radiation Safety Guide and shall ensure that other persons under his or her supervision also are acquainted and comply with this Guide. The Radiation Safety Guide must, at all times, be available to these persons.

D. Compliance with Government Regulations The " Authorized User" shall become acquainted and comply with all applicable government regulations and shall ensure that all persons under his or her supervision also are acquainted and comply with them.

E. Radiation Safety The acceptance of an authorization obligates the " Authorized User" to ensure radiation safety to him or herself, to all others who can be affected by the presence or use of his or her " Sources of Radiation " and to University property. Prior to short absences the " Authorized User" shall appoint a specific individual to be responsible for radiation safety in his or her absence. An extended absence of the " Authorized User" necessitates a change in responsibility which, in general, means that another individual must obtain the neces-sary authorization.

F. Records i

" Authorized Users" are obligated to maintain certain records.

These include those items needed for orderly management of the laboratory such as receipt, use, transfer and disposal records.

The " Authorized User" must also keep those. records needed to J

October 23, 1985

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. > . . O O 1 J. " Radiation Worker List" The " Authorized User" is responsible for reporting the names of all radiation workers under his or her supervision to the Office of Occupational Health and Safety so that essential radiation safety services, such as personnel monitoring, bioassay services, radiation safety training, prenatal exposure information for women, and special services, are provided for-these workers.

To this end the Office of Occupational Health and Safety sends to each " Authorized User," three times a year, a " Radiation a Worker List" update to which names can be added or deleted.

However, an " Authorized User" should report changes in labora-tory personnel immediately, without waiting for the arrival of the " Radiation Worker List" update, so that the essential services can be provided most efficiently.

K. Exposure Control The " Authorized User" has the responsibility to control work assignments and to ensure that work is carried out in such a manner that the radiation dose to any person from external

" Sources of Radiation" and internally deposited radionuclides under his or her control does not exceed the dose limits listed in Appendix 0.

L. Emergency Response The " Authorized User" is responsible for establishing radiation emergency procedures appropriate to the activities in his or her laboratory, and is responsible to ensure that all individu-als under his or her supervision are familiar with these procedures and those described in OHS Form #12 and in Section 17 of this Guide. Section 17 provides guidelines which may be useful in formulating emergency procedures for some of the common types of radiation emergencies.

M. Terminations In the event that an " Authorized User" severs his or her association with the University or discontinues work with

. " Sources of Radiation," he or she shall inform the Office of Occupational Health and Safety, shall ensure that proper and safe disposal and/or transfer of " Sources of Radiation" is

, affected, and shall ensure that his or her facility is left in a radiologically safe condition.

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9. POSTING, LABELLING TAGGING, AND SIGNALLING REQUIREMENTS i

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• Posting of Required Documents 4

l By regulation each laboratory using " Sources of Radiation" i must have posted certain documents. The specific documents to be posted vary, depending on whether the " Sources of Radiation" used by the " Authorized User" are regulated by the Nuclear Regulatory Commission (NRC) or by .the State of New Jersey and under which license the laboratory operates. These documents must be posted in a conspicuous place where they will be seen

by all persons working in or frequenting a Restricted Area."

The following listing describes the documents which must be 4 posted for each of the various Federal or State licenses under I which an " Authorized User" may operate. If the " Authorized i User" operates under more than one license or category, all l the relevant categories described below apply. The Office of i Occugational Health and Safety will supply the " Authorized User during the authorization process or machine registration j process with the documents appropriate to his or her activi-

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ties.

1. Laboratories in which NRC licensed " Byproduct Material" is l used must have posted:

a. Form NRC 3. " Notice to Employees" i

b. OHS Form #12, "Accider.t Procedures and Emergency Phone Numbers"

c. OHS Form #31, " Emergency Information" l

d. Additionally, the following documents need not be i posted but a notice

• must be posted which describes

the documents and states where they may be examined

1) "10 CFR Part 19" and "10 CFR Part 20" i 11) Princeton University Radiation Safety Guide 2

111) NRC Broad License #29-05185-24

2. Laboratories in which NRC licensed " Source Material" is used must have posted:

j a. Form NRC-3, " Notice to Employees"

b. OHS Form #12. " Accident Procedures and Emergency Phone Numbers"

c. OHS Form #31 " Emergency Information" i *A poster suitable for this purpose is provided to the " Authorized i

User" during the authorization process.

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a. Form BRP-014 " Notice to Employees"

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b. OHS' Form #12. " Accident Procedures and Emergency Phone Numbers" l c. OHS Form #31. " Emergency Information"  ;

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d. Additionally, the following documents need not be  !

i posted, but a notice

• must be posted which describes i the documents and states where they may be examined:

! 1) New Jersey Radiation Protection Code j ii) Princeton University Radiation Safety Guide i 4 iii) New Jersey License #80066 l 4

l 6. Laboratories in which " Radiation Producing Machines or Devices" 4

are used must have posted:

! a. Form BRP-D14. " Notice to Employees" i b. OHS Form #12. " Accident Procedures and Emergency Phone Numbers" -

c. OHS Form #31, " Emergency Information"

d. Additionally, the following documents need not be i posted, but a notice

• must be posted which describes the documents'and states where they may be examined:

)

1) New Jersey Radiation Protection Code

11) Princeton University Radiation Safety Guide a

B. Design Specifications for Signs, Labels, Tags, and Signals 1 All signs, labels, tags, and signals, used to indicate the j presence of " Sources of Radiation" or to post an area as a

" Radiation Area," "High Radiation Area " or " Airborne Radioac-tivity Area" must conform with "10 CFR Part 20" or the New Jersey Radiation Protection Code as appropriate.

i Caution: Some commercially available items may not meet 1

speci fications.

C. Posting of Radiation Areas

1. Each " Radiation Area" as defined in Section 2 shall be conspicuously posted with a sign or signs bearing the t

radiation symbol and the words:

l 1 *A poster suitable for this purpose is provided to the " Authorized j User" during the authorization process.

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9. 5

.. e . O E. Labelling of Equipment and Containers

• 1. Any equipment (vaults, refrigerator, etc.) or container in which radioactive material is stored or used in an amount greater than that listed in column A of Appendix C (except that the amount for natural uranium or thorium is ten times that given in Appendix C) shall bear a durable, clearly visible label bearing the radiation symbol and the words:

CAUTION RADI0 ACTIVE MATERIAL This label shall, when practicable, also identify the

! radioisotope, the amount in Curie units, and the date of assay.

The outside of a shielded container must also bear this label as well as the inner container.

2. Labels are not required on laboratory containers such as beakers, flasks, test tubes, etc., used transiently in laboratory procedures under supervision or if the concen-tration of the radioactive material in the container does not exceed that specified in Table I, Appendix B.

F. Tagging of " Sealed Sources" All " Sealed Sources" shall bear a durable, legible and visible tag permanently attached to the source. The tag shall be at least one inch square, shall bear the standard radiation symbol and at least the following:

CAUTION - RADI0 ACTIVE MATERIAL - DO NOT HANDLE NOTIFY CIVIL AUTHORITIES IF FOUND NOTE: Properly designed tags are available from the Office of

Occupational Health and Safety. If tagging is not feasible or desirable due to source design, properly inscribed pressure-sensitive tape is also available.

G. " Radiation Producing Machines and Devices" There are special requirements for labels, signs, and signals for " Radiation Producing Machines and Devices." The details

, are found in Section 16.

October 23, 1985

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10. LABORATORY PROCEDURES FOR RADI0IS0 TOPES o

A.* Radioisotope Inventory i

In each laboratory a Radioisotope Inventory Log shall be maintained, containing an inventory of radioisotopes, noting the element, its mass number, date received, amount received, dates of withdrawal for use and amount withdrawn, date of disposal of waste, manner of disposal, and estimated amount of waste. In short, a continual record must be maintained from receipt to disposal or decay.

The maintenance of an inventory of target activity levels for the targets which are routinely activated and investigated at the Jadwin Cyclotron is difficult because of the broad spectrum of activities and activity levels met in these targets.

However, it is possible to estimate activity levels or to express the data in mr/ hour at some specified distance. It is necessary that a record be kept indicating the disposition of these materials.

B. Reports At present, two monthly reports must be filed by the " Author-ized User" with the Office of Occupational Health and Safety:

an inventory of_ radioisotopes on hand and a summary of radio 1-sotope disposals. The State of New Jersey requires that all radioactive materials be registered, but the Office of Occupa-tional Health and Safety .has negotiated an agreement whereby the State will accept a periodic inventory report in lieu of the radioisotope registration requirement. The Office of Occupational Health and Safety collects and collates the inventory data from all " Authorized Users" and files the required State Report. The " Authorized User's" inventory report (using OHS form #5a) is filed with the Office of Occupational Health and Safety no later than the eighth day of each month and identifies all radioactive material on hand, including wastes. The forms for these reports are available from the Office of Occupational Health and Safety.

C. Survey Equipment A person using open or " Sealed Sources " opening packages containing radioisotopes, or performing physical or chemical manipulation of radioisotopes must have immediately available a suitable, operative radiation detector. This detector must  :

be able to indicate either dose rate or activity as may be I proper considering the nature and activity of the source. ,

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E. Personal Surveys 4'

1. Survey Requirements

, a. When manipulating open sources of radioactive material, thorough surveys of one's person and clothing must be performed:

1) at the end of an experiment and at the end of each day for multi-day procedures;

2) during manipulation of mil 11 curie quantities of open sources (the frequency and exact timing of this type of survey is left to the judgement of the .

i individual performing the experiment);

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3) during and following the opening of radioactive l material packages;

) 4) following withdrawals from stock sources containing millicurie quantities; and,

5) prior to exiting the restricted area.

b. Records of such surveys must be kept. The records should include the name of the surveyor, the date, the

survey results, whether positive or negative, and the follow-up actions taken if contamination is found.

2. Contamination Limits 1

The limits for contamination on personal protective clothing and the skin are:

Low Risk Beta, Gamma Beta, Gamma i

Alpha or X-ray or X-ray Emitters Emitters Emitters

• Personal i Protective 220 dpe/ 2,200 dpe/ 22,000 dpa/

Clothing 100 cm 100 cm* 100 cm 2

220dpy/ 220 dpe/ 2,200 dps/

Skin 100 cm 100 ca 100 ca* '

I

• Low risk beta, gamma, or X-ray emitters are those isotopes l with beta energies less than 0.2 MeV, and/or X-ray emis-sions less than 0.1 R/hr at I meter per curie and with i permissible air concentrations greater than 10~' micro-curies per milliliter.

j October 23, 1985

-- ye. , ,.------,-.-.-m rw- .,_-._7,_ --.-,---,.r ,.--------,y -.rrm, v-+,-- -

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10.5

_- . . O O I. Fume Hoods and Glove Boxes Experiments involving the use of open radioactive sources which could result in airborne radioactivity should be carried out in fume hoods or glove boxes. Because even ordinary laboratory ,

manipulations can result in the release of airborne radioac- l

! tivity, all " Users" are strongly urged to use a chemical fume hood or glove box for any physical or chemical manipulation j of radioisotopes.

, Any use of a biological safety cabinet for radioactive mate-i rials should be discussed beforehand with the " Health Physi-2 cist." Biological safety cabinets may not be suitable, for instance, for volatile substances such as'radioiodine, since in j many cases some air from the cabinet is exhausted to the room.

l Except as noted below, hoods for radioisotope work must have an average face velocity of at least 50 linear feet per minute.

i Experiments involving alpha-emitting radioisotopes and radio 1-

odines must be performed in hoods with an average face velocity j of at least 95 linear feet per minute. Hood and glove box

surfaces should be protected to prevent contamination of fixed surfaces that may be difficult to decontaminate.

3 In consideration of University maintenance personnel who may be

called to repair possibly contaminated hoods, all hoods which I have been used for radioisotope work are labelled by the Office of Occupational Health and Safety. "This Hood used for Radioac-tive Material." Any " User" who wishes to use an unlabelled hood for radioisotope work should obtain the proper label from j the Office of Occupational Health and Safety.

J. Airborne Radioactivity i For experiments that may result in the release of airborne j radioactive material, a routine air sampling and bloassay

. program may be required. No operation may be planned and

! performed that will knowingly result in the release of airborne

radioactivity in excess of permissible levels given in Appen-dix B.

f j Caution: It should be remembered that the use of volatile or powdered radioisotopes may result in significant airborne l concentrations of radioactive material.

! K. Pipetting Mouth pipetting of radioactive material is prohibited.

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, October 23, 1985 i

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R. Animal Use and Care The use and care of animals used for 4t v.Lvo experiments with

radioisotopes must be done in compliance with the provisions of the Animal' Welfare Act of 1970 and amendments thereto, as determined by the Animal Care Subcommittee of the University Research Board. In addition to those requirements, considera-tion must be given to the special problems of animal waste

, collection, the disposal of carcasses, airborne radioactivity

, resulting from exhaled radioactive materials, and the cleaning and decontamination of cages. Required precautions, as determined byrthe " Health Physicist " are generally made I conditions or approval for authorization.

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11. EXTERNAL DOSE CONTROL AND PERSONNEL MONITORING A.* Control

- As a matter of policy and practical necessity, the " Authorized User" must be the individual responsible for controlling the dose received by personnel under his or her supervision and/or using " Sources of Radiation" under his or her authorization so that no person receives a total dose in excess of the maximum permissable limits specified in Appendix 0. The total dose includes both that due to exposure to external " Sources of Radiation" and exposure to internally deposited radioisotopes.

The monitoring of radiation dose provides information essential to the control process. The program under which external dose is monitored is described below while the program under which the dose due to internally deposited radioisotopes is monitored is described in Section 12.

B. External Monitoring Requirement By regulation any person who receives or is likely to receive more than 25 percent (5 percent for minors) of the maximum permissible dose (see Appendix D) or who enters a "High Radiation Area" must be provided with and must wear personnel monitoring devices. Additionally, persons manipulating millicurie quantities of Phosphorous-32. Iodine-125, or other sources that may cause significant hand exposure shall be provided with and must wear finger dosimeters. The " Authorized User" is responsible for ensuring that persons under his or her supervision and/or using " Sources of Radiation" under his or her authorization are provided with suitable personnel monitors and that these monitors are actually worn when appropriate. Any question of interpretation of this section shall be referred to the " Health Physicist."

C. Centralized Personnel Monitoring Program The Office of Occupational Health and Safety administers a centralized personnel monitoring program which is utilized by all laboratories requiring personnel monitoring. In the operation of this program the Office of Occupational Health and Safety provides, upon request, personnel monitors for routine and temporary use, distributes personnel monitors to the departments, collects personnel monitors from the departments after use, ships the monitors to the personnel monitoring service vendor for interpretation, receives and distributes the dose reports to the departments, maintains centralized records, investigates unusual or excessive doses, and honors requests for dose history summaries. The " Authorized User" continually reviews the need for personnel monitoring and requests person-nel monitoring service from the Office of Occupational Health I and Safety, notifies that office when service is no longer I needed, arranges for the distributior and collection of personnel monitors in accordance with departmentally October 23, 1985 l

1

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• - . O o 11 3 of Occupational Health and Safety must be notified immedi-  !

• ately. The " Health Physicist" will take steps to determine the actual dose, investigate and document the circum-stances, file reports if required, and recommend corrective or preventative action.

2. Individuals who are believed to have been overexposed shall be suspended from further work with " Sources of Radiation" pending the outcome of the " Health Physicist's" investiga-tion.

Exposure of Minors E.

Because the allowable dose to persons under 18 is limited to 10% or less of the limits specified in Appendix D, it is recommended that minors not be employed as full-time radiation workers.

F. Exposure of Pregnant Women There are special requirements relating to the dose limits for pregnant women (see Appendix D). Because of this, each female radiation worker, at the time of the beginning of work with

" Sources of Radiation," is provided by the Office of Occupa-tional Health and Safety with an information packet discussing the risks of prenatal exposure and the special requirements.

A female radiation worker who discovers she is pregnant is strongly encouraged to discuss future work assignments with the " Authorized User."

G. Exposure of Visitors

1. The host, i.e. the person visited, bears the responsibility of ensuring that his or her visitors, who may include guests, maintenance and repair personnel, etc., are informed of the hazards, comply with all applicable rules, regulations, and procedures, and wear personnel monitors when appropriate.

2. There are very few circumstances in which any real contri-bution to the scientific community can result from the visit of a child to a " Restricted Area." For this reason, such visits shall be discouraged and should not be permit-ted without benefit of careful consideration. Prolongedor frequent visits by children to " Restricted Areas are prohibited.

October 23, 198S

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12. INTERNAL DOSE CONTROL AND BI0 ASSAYS J A.' Control l As a matter of policy and practical necessity, the " Authorized User" must be the Individual responsible for controlling the dose received by personnel under his or her supervision and/or using " Sources of Radiation" under his or her authorization so that no person receives a total dose in excess of the maximum permissible limits specified in Appendix D. The total doso includes both that due to exposure to internally deposited radioisotopes and exposure to external " Sources of Radiation."

The monitoring of radiation dose provides information essential to the control process. The program under which the internal dose is monitored is described below. The program under which the external dose is monitored is described in Section 11.

Exposure investigations, regulatory notifications and physician referrals all depend on the outcome of bioassays performed as required by this section. The University is legally required to initiate these actions via license conditions and the regulations in 10 CFR Part 20. The cooperation of the "Princ1-pal Investigator" and the individual is essential to ensure compliance with this section of the Radiation Safety Guide.

B. Internal Monitoring Requirement The " Authorized User" is responsible for ensuring that persons under his or her supervision or using radioisotopes under his or her authorization are provided with bioassay services.

Arrangements for bioassays are made by contacting the Office of Occupational Health and Safety when the criteria given below are met.

Bioassays commonly involve urinalysis, external counting of the thyroid, breath analysis, or whole body counting.

1. Special Bioassays Bioassay analyses may be required of any person or persons who:

a. have been exposed to air or water concentrations of radioactive material equal to or in eFCess of 25 percent of those specified in Table I of Appendix l 8 or

b. have been involved in a spill, an incident, or other occurrence during which radioactive material may have been taken into the body either by inhalation, ingestion, or by absorption through the ,

skin or a wound. l October 23, 1985 I

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4) Frequency of Routine Bioassays Routine bioassays samples should be submitted within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of the initial exposure to i tritium and then once a month while routine use of tritium continues. When work with tritium is on an infrequent basis (less frequently than every two weeks) bioassays should be performed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the end of the work period during which tritium is handled.

5) Types of Required Bioassays The tritium bioassay program for each individu-al should consist of the following bioassays:

a) Baseline (within one month prior to the j beginning of any tritium use requiring bioassay)

! b) Routine 1 .

c) Post operational (within one month follow-ing last tritium use) j d) Follow up (to follow the course of a significant uptake of tritium)

b. Radioiodine Routine bioassays are required for those persons who conditions:

handle I-125 or I-131 under the following

1) Use in an open room or bench top with possible release

• Amount Requiring Form Routine Bioassay **

Volatile 1 mC1 Bound to non-volatile agent 10 mC1

• Possible release means that the possibility of a significant l

airborne release of radioactive material exists because 1) the 'i techniques used to process the material may create an aerosol, 2) the material is inherently volatile, or 3) the techniques used to process the material may increase its volatility.

• • The amount requiring routine bioassay is considered as the '

cumulative quantity handled by an individual during a 3-month period or on one or more occasions in that period by opening  ;

stock reagent containers from which radioiodine may escape.

October 23, 1985

_. O O a) Baseline (within one month prior to the 4

beginning of any use of radiciodine 1 ' '

requiring bioassay) b) Routine 4

c) Post iodination (within 6 to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the end of a procedure in which 5 mC1 or

, more of free iodine is used) 1 d) Post-operational (within one month follow-i ing the last possible exposure to radio-iodine, when work is being discontinued) i e) Follow-up (to follow the course of a significant uptake of radioiodine)

6) Depending on the nature of the work and if a significant uptake of radioiodine is found for one individual, other persons who frequent

, the laboratory may be required by the " Health

! Physicist" to obtain bioassays.

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\ ._ .--.-,.- - -._,......-.- - - _- ._. . . , ..... - -

?!

'5(1.itIh: k'illiae. O. P. illerO Chief 0o 70~

License Fee P.ar. gement Eranch -

M /16 Oferic*e'of Adrinistration -

jg g John E. Glenn, Chief Nuc1 car Materials Section 8 . l Division of Engineering and --

j Technical Programs LICENSE FEE TRAN5MITTAL -

. 1 A. REG 10N

1. _ APPLICATION ATTACHED Applicant / Licensee: hrinc phn ( TOWrNIV I

Application Dated: 1 Do M Control No.: 104 63 License No.:  % WO - %5(,,

2 FEE ATTACHED Amount: D Check No.: ci

3. COMMENTS

..~~ Signed S Rren dr> 9t h t. f Date i 29, 8(3

6. LICENSE FEE MANAGEMENT ERANCH

1. Fee Category and Amount: O' / /d

2. Correct fee Paid. App 1tcation may be processed for: ,

/c.end:ent .

Renewal License signed f7Oc,,/<..,..,_

Date

> /Pri 10N I FORM 213 RCH 1983) _