Text

Responds to 961227 & 30 Ltrs Requesting Concurrence on Results of Review of Qualifications of Individual Selected for Position of RSO for Type a Broad Scope Univ License
	ML20133G750
Person / Time
Issue date:	01/07/1997
From:	Bangart R; NRC OFFICE OF STATE PROGRAMS (OSP)
To:	Mount D; NORTH DAKOTA, STATE OF
References
	NUDOCS 9701160149
	Download: ML20133G750 (7)
	v • d • e

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- Mr. DInu E. Moont, P.E., Dir:ctor l Division cf Environm:ntal Engineering ,

Department of Health *

' 1200 Missouri Avenue, Room 304

Bismarck, ND 58506-5520

]

Dear Mr. Mount:

This is in response to your December 27,.1996 and December 30,1996 letters requesting !

our concurrence on the results of your review of the qualifications of an individual selected 4 for the position of Radiation Safety Officer (RSO) for a type A broad scope university license.

We have reviewed the information submitted to you by the licensee along with your analysis and we concur in your finding that the individual proposed as the RSO lacks

sufficient training And experie.nce to qualify for this position.' The guidance we apply i states that the RSO of type A broad licenses should have an academic degree in physical

!- or biological science or engineering, specific training in radiation health sciences and at i

least 5 years experience with a broad spectrum of radioactive material related to the types, quantities, and uses of the licensee's program (pp.16-17 of Draft Regulatory Guide DG-0005). Additional background information and guidance relating to RSO qualifications at a broad scope license is also enclosed (pp.-21-22 and Appendix 1 of Nureg-1516). The areas <

j covered in this guidance are consistent with the areas covered in your review of Mr. Glass' I j credentials. It provides for. example that the RSO should have experience in such areas as !

2 laboratory auditing, personnel monitoring, bioassay, contamination control, investigation of ;

incidents, training of personnel, instrumentation and calibration, material inventory and ,

E accountability, radioactive waste disposal and transportation. A thorough knowledge of l l

regulatory requirements is also essential.

i

, ~ We hope that our response to your request is timely and of assistance. if you have any questions, please contact me or Lloyd Bolling at 301-415-2327.

Sincerely, Originalsigned By RICHARD L. BANGART Richard L. Bangart, Director Office of State Programs

Enclosures:

As stated Distribution:

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UNITED STATES I

S NUCLEAR REGULATORY COMMISSION 1

E WASHINGTON, D.C. 20066 0001

% # January 7,1997

! Mr. Dana K. Mount, P.E., Director j Division of Environmental Engineering Department of Health l 1200 Missouri Avenue, Room 304

Bismarck, ND 58506-5520

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Dear Mr. Mount:

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This is in response to your December 27,1996 and December 30,1996 letters requesting i our concurrence on the results of your review of the qualifications of an individual selected for the position of Radiation Safety Officer (RSO) for a type A broad scope university j license.

! We have reviewed the information submitted to you by the licensee along with your l analysis and we concur in your finding that the individual proposed as the RSO lacks

] sufficient training add experience to qualify for this position. The guidance we apply states that the RSO of type A broad licenses should have an academic degree in physical j or biological science or engineering, specific training in radiation health sciences and at i least 5 years experience with a broad spectrum of radioactive material related to the types, l quantities, and uses of the licensee's program (pp.16-17 of Draft Regulatory Guide DG-

] 0005). Additional background information and guidance relating to RSO qualifications at a broad scope license is also enclosed (pp. 21-22 and Appendix I of Nureg-1516). The areas covered in this guidance are consistent with the areas covered in your review of Mr. Glass'

credentials. It provides for example that the RSO should have experience in such areas as

laboratory auditing, personnel monitoring, bioassay, contamination control, investigation of incidents, training of personnel, instrumentation and calibration, material inventory and accountability, radioactive waste disposal and transportation. A thorough knowledge of

regulatory requircments is also essential.

We hope that our response to your request is timely and of assistance. If you have any questions, please contact me or Lloyd Bolling at 301-415-2327.

! Sincerely, f

)

i i

k isd b 3au m Richard L. Bangart, Director Office of State Programs i

Enclosures:

As stated i

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U.S. NUCLEAR REGULATORY COMMISSION October 1994 g 0FFICE OF NUCLEAR REGULATORY RESEARCH Division 10

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Task DG-0005 ie -

DRAFT REGULATORY GUI0E 4

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Contact:

J.L. Telford (301)415-6229 ;

P.K. Holahan (301)415-7847 t

4 i

DRAFT REGULATORY GUIDE DG-0005 l

(Second Proposed Revision 2 to Regulatory Guide 10.5) f (Previously issued as Draft FC 408-4)

APPLICATIONS FOR LICENSES OF BROAD SCOPE

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This regulatory guide is being issued in draft form to involve the pubite in the early stages of the develop-sent of a regulatory position in this area. It has not received complete staf f review and does not represent an of ficial NRC staff position.

Public comments are being solicited on the draft guide (including any implementation schedule) and its assoc 1-ated regulatory analysis or value/ impact statement. Comments should be accompanied by appropriate supporting data. Written consents may be submitted to the Regulatory Publications Branch. DFIPS. Office of Administre-tion. U.S. Nuclear Regulatory Connission. Washington, DC 20555 Copies of cossents received may be examined at the NRC Public Document Room. 2120 L Street NW., Washington. DC. Comments will be most helpful if received by January 25, 1995.

Requests for single copies of draft guides (which may be reproduced) or for placement on an automatic distri-bution list for single copies of futurt draft guides in specific divisions should be made in writing to the U.S. Nuclear Regulatory Commission. Washington, DC 20555. Attention: Office of Administration. Distribution and Mail Services Section. -

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An application should describe the frequency of RSC meetings and the ,

criteria for selecting RSC members; it should include a specific and detailed description of the control functions of the RSC and the administrative proce-dures by which these functions are carried out. The RSC at a medical institu-tion is required by 10 CFR Part 35 to meet at least quarterly. Appendix G of this guide provides an outline of the duties and responsibilities of the RSC l

that are acceptable to the NRC staff.

7.3 Radiation Safety Officer Broad scope licensees are required to appoint an RSO pursuant to 10 CFR l 33.13(c) and 33.14(b). The RSO should be responsible for oversight of the day-to-day radiation protection program established by the RSC, should communicate with senior management and the RSC regarding program implementa- ,

tion and compliance status, and should be available to provide advice and assistance on radiological safety matters.

The RSO should have an academic degree in physical or biological sr.ience or engineering, specific training in radiation health sciences, and consider- ,

able professional experience (generally about 5 years) with a broad spectrum

of radioactive materials. The RS0's professional experience should include the application of this training to the management and administration of a !

l radiation safety program related to the types, quantities, and uses of the J

radioactive material to be used under this license. A previous background in j program and staff management is also desirable.

The training and experience of the RSO in radiation protecti_on and with radiation and radioactive materials should be listed and described. If he or che is not a full-time employee of the organization, describe the individual's !

affiliation with the institution and state how many hours per week the indi- l vidual will be available to oversee the NRC-licensed program. Also specify l provisions for contacting this individual during emergencies and off-hours and l provide a general description of his or her other obligations. Generally, the j NRC staff does not consider the use of consultants or part-time RS0s accept- !

l able for broad scope programs; in most cases, the position of RSO is a full-time commitment. The RSO should report directly to senior management, have ready access to all levels of the organization, and have the authority to 16

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4 i' immediately terr av; any activities that are found to be a threat to public

health, safety, or property. -

A statement should be included in the application delineating the RSO's

! duties, responsibilities, and authority for carrying out the radiation safety :

program. The extent of these responsibilities and duties will depend on the l

proposed broad scope license. Appendix H to this guide provides an outline of

duties and responsibilities of the RSO under a broad scope license, represen- ;

j tative of those considered acceptable to the NRC staff.

7.4 Radiation Safety Office Staff i

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The RSO is supported by a staff of health physics professionals who assist in the maintenance and control of the licensed program. The number and f qualifications of these professionals will vary with the scope of the program.

) The application should include a description of the duties and responsibili-

ties of the radiation safety office staff and an assessment of the staffing ;

levels and qualifications of this support staff. The assessment should be sufficient to demonstrate that the technical staff are adequate to implement, h

npport, and oversee the proposed radiation protection program. If the current staffing is considered minimally acceptable, a projected timetable for i

achieving full staffing should be included. A projection of future needs 4

would also be useful.

4 i ITEM 8: TRAINING FOR INDIVIDUALS WORKING IN OR FRE0 VENTING RESTRICTED AREAS l

A broad scope licensee must provide initial and refresher training to all individuals who will use, or may come in contact with, radioactive material.

Employees who will need training include all users; laboratory supervisors and technicians; radioactive material incinerator and waste compactor operators; housekeeping, nursing, and security personnel; and radiation safety office staff. It is understood that training programs will vary from licensee to licensee. The detail and content will depend on the scope of the program (i.e., Type A, Type B, or medical broad scope), possession limits, type of isotopes used, size of the program in terms of the number of laboratories and 17

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NUREG-1516 .

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l Management of i Radioactive Material j Safety Programs at !

l Medical Facilities Draft Report for Cornment l

Manusenpt Completed: November 1994 Date Published: January 1995 l L W. Camper. J. Schlueter, P. Henderson, H. Bermudez, '

M. Fuller, J. Jones, V. Campbell, J. Montgomery, K. Allen

i Division ofIndustrial and Medical Nuclear Safety Omce of Nuclear Material Safety and Safeguards '

U.S. Nuclear Regulatory Commission i

j Washington, DC 20555-0001 4

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} *Dmsion of Phive Material

{ Department of Nuclear Safety

1035 Outer Park Drive j Springfield,IL 62704 i

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4 SELECTING A RADIATION SAFETY OFFICER 4.2.1 Limited Specific Licensee 4.1 Introduction Re limited specific licensee usually performs routine .

l diagnostic or therapeutic procedures or both with Food He RSO is a critical component of the management and Drug Adnunistration (FDA) approved radio-triangle because the RSO, with the assistance of the Pharmaceuticals and sealed sources. NRC's trainmg RSC, is responsible for implementing and maintaining and experience criteria for quahfymg an RSO for a the licensed radiation safety program. Executive limited specific program are described in 10 CFR Part mawgement is obligated to select an RSO who has 35, Subpart J, and allow three trammg pathways:

sufficient training and experience to address all facets certification by professional boards wapsed in the of the radiation safety program. However, compliance regulations, specific classroom traming, and work and with the trammg and experience criteria described in clinical experience. Being listed as an authorized user the regulations, whether they are NRC or State on the license is also acceptable. Additionally, indi-criteria, may not be sufficient qualifications for the viduals may qualify if they have been previously individual to be effective. For example, the RSO authorized as RSOs at a facility of similar size and candidate should also possess good management skills, scope. NRC requires that the training and experience welcome the responsibility, and be willing to dedicate be obtained within five years preceding the date of the enough time to ensure that the required tasks to imple.

application, or that the applicant should have had snint or maintain the radiation safety program are related continuing education and experience since properly performed. ne careful selection of the RSO completing the required training. NRC's traimng and is a crucial task for executive management. Derefore, experience requirements for limited specific licensees to assist licensees in this selection process, this chapter are outlined in Appendix H. (Agreement State diesca nummum RSO qualifications for different regulations have cifferent requirements.)

types of licenses, as well as the advantages and dis.

advantages of certain categories of RSO candidates, Some pmfessional boards are remgmzed in NRC and makes suggestions for locating qualified candidates.

regulations because, as part of the certification criteria, applicants have successfully completed a radiation safety component determined by NRC to be adequate.

An alternate pathway consists, at a mimmum, of basic classroom and laboratory traming in courses related to 4.2 QualricationS radiation safety and direct work experience under the

. supervision of an RSO in a medical facility of sumlar or larger size and smular or broader scope.'Iypically, Tb implement the radiation safety program, the RSO is responsible for overseeing the day-to-day operations classroom and laboratory trammg comprises course and should have unhampered access to all levels of the work in radiation physics and instrumentation, radiation orgamzation. Executive mancgement should empower protection, basic mathematics, radiation biology, and I

the RSO to terminate an unsafe activity immediately radiopharmaceutical chemistry. Although appropriate without being challenged and, in some cases, without classroom and laboratory training is an important j prior coordination with the RSC or executive manage- benchmark for demonstrating adequate qualifications, ment. Herefore, executive management should select the practical experience gained while working under an individual m whom at has confidence to delegate this the supervision of an RSO in a medical facility cannot authority. be overstated. It is through this practxal experience that an individual learns to apply the technical knowledge gained from classroom and laboratory trammg. NRC regulations require a minimum of 1 year he nature of activities conducted under a limited specific versus broad scope license can be extremely of practical experience.

different. De magnitude of potential safety-related problems requires the RSO of a broad empe bcense to 4.2.2 Broad Scope Licensee ,

bt more knowledgeable in various aspects of health j Broad scope medical licensees are authorized to use a '

physics. Because NRC criteria for acceptable trammg variety of radiopharmaceuticals and scaled sources for and experience for the RSO of the two types of licen- d sees are different, in the next two sections the staff diagnostic and therapeutic patient procedures and other human use, and for both medical and nonmedical diews mmunum NRC training and experience research. Because of the nature of this varied program, criteria for each category of licensee.

21 NUREG-1516

Manageme6t of Parhaarrive Material Safety Programs at MedmalIncilities l l

broad scope licensees generally need more finreuhty in Appends J contains a checkhst that licensees of broad rg gir.g their programs than do imuted specific scope facilities can use to analyze an RSO applimat's licana**= For sample, the RSC, with the asustance of training and wh;c. However, this checklist should the RSO, typically approves facilities, eqmpment, uses, not be considered all inclusive. I 1r*==**a are encour-and usen. For this reason, broad scope licensees should aged to develop criteria that addren the unique needs have staff including the RSC, and particularly the RSO, of their facilities. The checkhst is simply a tool that can who are eminently gaaWid to review and approve be used to identify acceptable RSO candidates easily, these requests. De checkhst may also be useful for preparms and submitting documentation of credentials to regulatory 0-aa any, an RSO at a broad scope facihty should have g,g RSO experience using and supervising a broad spectrum of

isD2 Pes, activities, and uses. Almough &is RSO is not After establishing appropriate criteria for evaluating j required to have direct expenence with all isotopes candidates, holders of broad scope licenses should used in the broad scope facdity, the RSO should know establish and define a process to review the traming when to ask fw amistance from ineviduals who han and experience of each apphcant. The selection process me appropriate apertise. Applicants fw me RSO can be time intensive; therefore, if the RSC has been Position should also have pmetical experience in certain estabbshed, it may conader setting up a anbranmit***

tasks before being conadered acx:eptable candidates for to review the credentials of all applicants and to pre-et Posten. An RSO in a broad scope facHity shald pare a preferred candidates lin.He credentials of how =a- ta= in such areas as labwatay au& ting, these selected can& dates can then be carefully Personnel maitwing, bmamay, conta ninarian contml, reviewed by the entire membership of the RSC. De innstigation d hts, training pemanel, instm- RSC can rate the candidates and recommend the most mentation and calbration, niaterial inantwy and quahfied indmdual to executive management. Several acmuntabiHty, M waste esposalm other methods have also proved to be equally effective,-

portation, and the use of an RDRC and an IRB. See but the actual selection process is left to the discretion Section 3.6 for further chacussion on R.DRCs and IRBs.

of executive management. Although the licana** is d

obligated to select the RSC's candidate, the final Also denrable in a ranAriate are such management approval of an RSO for a facility is the authority and abilities as developing and admmistering a budget, responsibdity of the regulatory agency, superviang a staff, being famdiar with human resource matters, and having good writing and oral communi- 4.3 IDierper$0Dal Skill 8 cation skills. A thorough knowledge of regulatory requirements is essential to maintaining c~aaHa= for In addition to finding an in&vidual who is Fwany an RSO of any type of heenaart program; however, this Competent, not unlike any other peannel selecten, knowledge becomes entical for the more complicated ee hr*na~ simuld anemp to find one who wwks weH program of a broad scope lic a. Wie oeer People. After au, an RSO depends on o$er in&viduals to follow procedures and complete tasks, and should interact with them as needed to ensure an Appends I provides saida= on the type and length of effective radiation safety program. An RSO's effective-formal edumtion, certification, and experience that ness in managing the program is often et on NRC staff mmenda for RSOs of broad scope the ability to convey L gi.ht regulatory and tachnirm1 programs. His gnidant* is based on mmdar guidance information from one group to another, and the descrbed in NRC Draft Regulatory Ouide OP 722 4, rapport estahlinhart with members of the organization.

"Quahfications for the Ra&ation Safety Officer in a large-Sale Non-Phel-Cycle Radionuclide Program." De RSO should convey iqformation to alllevels of the The gedance in I can be used to determine if organization, from the esecutive management of the j a candida'* has t practical or apphed health facihty to the laboratory staff. AdditinnaHy, the RSO phymus experience based on education or certification. should convey heensee policy and regulatory require.

De higher the degree of formal education in health ments for the use of radmactive material to prhaary physics or radiological health, the less applied health users and laboratory staff; should work with the RSC to phyncs experience is required. Regardless of education, identify failures or wantra- in the r=&atian safety however, the licensee should thoroughly review each program; should raan==aad corrective actions to evoki candidae*'s g+W.1 Arena == cf broad scope health and afety problems and =-- ;" =:and programs should ask each potential caaeda** to should counsel esecutive reanagement so it can make disclose complete information about previous training infonned decisions regarding appropnate diariplina'y and exponence. areiana for infractions against a licensee's pohey or j

NUREG-1516 22

1 i , 1 APPENDIX I NRC'S SUGGESTED COMBINATIONS OF TRAINING AND EXPERIENCE l CRITERIA FOR RSOs AT A BROAD SCOPE MEDICAL LICENSEE (A, or B, or C, etc.) l FORMAL EDUCATION AND CERTIFICATION EXPERIENCE l

A. Bachelor's degree in health physics or A. Four years of applied health physics radiological health AND experience in a program with radiation safety problems similar to those in the program to be managed B. Bachelor's degree in a physical science or a B. Same as A biological science with a physical science minor, and one year of graduate work in health physics AND C. Master's degree in health physics or C. Three years of applied health physics radiologicalhealth AND experience in a program with radiation safety problems similar to those in the program to be managed D. Doctorate degree in health physics or D. Two years of applied health physics experience radiological health AND in a program with radiation safety problems similar to those in the program to be managed E. Comprehensive certification by the American E. Same as D Board of Health Physics AND E Certification by the American Board of F. Same as D Radiology in Medical Nuclear Physics AND G. Certification by the American Board of Science G. Same as D in Nuclear Medicme in Radiation Protection AND H. Certifk:ation by the American Board of H. Same as D Medical Physics in Medical Health Physics 83 NUREG-1516 s.

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EXECUTIVE TASK MANAGEMENT SYSTEM !

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TASK # - 6S324

...... DATE- 12/31/96 MAIL CTRL. - 1996 TASK STARTED - 12/27/96 TASK DUE -

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TASK DESCRIPTION - 12/27/96 & 12/30/96 LTRS " TAR" TO REVIEW QUALIFICATIONS OF J. GLASS TO BE RSO FOR UNIVERSITY OF NORTH DAKOTA REQUESTING OFF. - ND REQUESTER - D. MOUNT WITS -

0 FYP - N PROG.- LAB PERSON - STAFF LEAD - LAB PROG. AREA -

PROJECT STATUS - OSP DUE DATE:

PLANNED ACC. -N LEVEL CODE - 1

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[' - NORTH DAKOTA s DEPARTMENT OF HEALTH W:

ENVIRONMENTAL HEALTH SECTION .

1200 Missouri Avenue e P.O. Box 5520 "

December 30, 1996 Bismarck, North Dakota 5djig6-5520 Fax #701328-5200 z OOm Richard Bangart, Director 2 o m- :

l Office of State Programs ~ yl

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US Nuclear Regulatory Commission 5 l Washington, DC 20555 i I

Dear Mr. Bangart:

[ l In response to Lloyd Bolling's telephone conversation with Greg Krause ;

l on December 30, 1996, the North Dakota Department of Health would like to amend its technical assistance request submitted December 27, 1996.

i !

1 l Enclosed is a copy of the Department's review of Mr. John Glass' ;

credentials to be the radiation safety officer at the University of l North Dakota. Although Mr. Glass has training, experience, and l credentials in worker safety, his radiation protection training and '

experience is limited to one college course and three cases where he :

.was involved in decommissioning or cleanup of facilities that had some .j radioactive material use. Mr. Glass does not have the recommended five ,

years of experience with various isotopes. Based on the Department's l assessment, it-appears he has approximately 19 weeks of experience

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l l including 13 weeks of academics. The North Dakota Department of Health I has determined that John Glass does not meet the requirements to be radiation safety officer at a Type A broad scope license of UND's size l and scope. Does the Nuclear Regulatory Commission concur with the North Dakota Department of Health's position on this matter?

If you have any questions or require additional information, please )

contact Greg Krause of my staff at (701) 328-5188. I j Sincerely, t .

M - "

i Dana K. Mount, P.E.

Director, Division of \

Environmental Engineering l

DKM/GK:csv Enc:

Environmental Health Section Environmental Municipal Waste Water and Enforcement Engineering Facilities Management ouality 701 328-5150 701-328-5188 701-328-5211 701-328-5166 701-328-5210 l[7 ) '

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Printedon recycled paper.

PLEA.SE NOTE You should already have copies of all of the following pertinent letters:

1. Letter from Jim Uhlir, UND to Ken Wangler dated 12/10/96: This was the initial request to name John B.

Glass, Jr. as RSO, the letter included John Glass': (a)

Curricula Vitae, and (b) Continuing Education, Conferences, and Seminars.

2. Letter from John Glass, UND to Greg Krause dated 1 12/18/96: This was in response to a telephone request j for addidional training and experience information.

3. Letter from Dana Mount, North Dakota Health Department to James Uhlir, UND dated 12/19/96: This was a formal request for additional information specific to the duties of the RSO. It includes a list of RSO duties from UND's radiation safety handbook. ;

4. Letter from Jim Uhlir, UND to Dana K. Mount dated I 12/23/96: This is UND's response to the 12/19/96 letter listing John Glass' training and experience with respecti to the specific RSO duties. The enclosed review is based mainly on this letter. I You should also have a copy of an internal document generated by this department, listing a chronology of events involved in the RSO situation. 1 l

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l Review of Mr. John Glass' Credentials to be the Radi.tien Safety Officer at the University of North Dakota i I

Overall: !

1. Mr. Glass attended 1 college course at Temple University:

Isotope Methodology in 1989 (assumed to be 13 week 3 of experience).

2. Apparently Mr. Glass was involved in the decommissioning or cleanup of three sites that had experienced some radioactive material use. In at least one instance Mr. Glass used a pancake ,

probe and took contamination wipes. In a phone conversation with '

Greg Krause on 12/18/96, Mr. Glass stated that the only time he had to wear a radiation badge was at one of the sites, which was an aerospace facility (assumed to be 6 weeks of experience). l

3. It appears that Mr. Glass has had three years of experience ,

as a director responsible for an OSHA compliance program, and 2 1 years as a operations manager for an environmental company.

1

4. It appears that Mr. Glass has several years (not well ;

documented) of experience in worker safety and he has numerous '

safety credentials.

Review of Mr. Glass' training and experience with respect to the i specific duties assigned to the Radiation Safety Officer in the j University's Radiation Safety Handbook. (Copy of duties is l listed in the 12/19/96 letter sent to UND by the Department.)

a. Calibration of survey instruments: UND's response stated I that Mr. Glass performed one calibration using Tc-99 in 1990, in correspondence on 12/18/96 Mr. Glass stated that the Isotope class included use and calibration of Geiger Mueller tubes and liquid scintillation detectors. Based on the submittals and a phone conversation between Mr. Glass and Greg Krause, the department does not feel his level of experience is not adequate to perform University calibrations using UND's Cs-137 calibrator,

b. Complete radiation surveys: Other than performing clearance surveys with a pancake probe it appears that Mr. Glass has no experience performing dose rate surveys to show compliance with public dose limits or to establish workplace levels. Note: UND currently has a situation in which a storage area is creating an elevated dose rate in a heavily used hallway, i

c. Complete contamination surveys: Apparently Mr. Glass has i some training from his Isotope class and was on three sites where contamination surveys were performed. It is unclear if Mr. Glass l

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l was involved in the planning of any of the surveys or just took l readings and wipes where instructed. The material submitted does j not appear to show a sufficient level of expertise to be l

. responsible for contamination surveys at UND. Note: Problems with contamination surveys was a recurring violation in UND's ,

l last inspection, indicating that the authorized users need j special assistance in this area.

l d. Leak testing: Mr. Glass has no training or experience in l l performing leak tests. There is no indication that he would be l l aware of the special safety precautions or of how to properly i l wipe a source housing to detect leakage. l

e. Inspection of facilities and equipment: Mr. Glass appears to ,

have experience performing workplace inspections for OSHA l l compliance, but is unfamiliar with radiation protection rules and practices. He does not appear to have the experience necessary l to readily identify potential problems during a laboratory ;

i inspection. !

f. Review of procurement of radioactive materials: Mr. Glass l has no experience in. ensuring compliance with radioactive i material possession limits. Note: During the last inspection'the l department discovered that the previous RSO had concerns about UND's ability to adequately inventory all material in waste disposal and authorized user possession. The previous RSO felt that UND may already be in violation of possession limits. Since the inspection,-UND claims to have developed a new computer program to closer track inventory but the system is new and has not been reviewed by the Department.

g. Management of waste disposal service: Although Mr. Glass is a Certified Hazardous Materials Manager he has no apparent training or experience in handling radioactive waste. Note:

During the last inspection UND records revealed that at least on one occasion a waste bottle with significant external l contamination was moved from a laboratory to a common waste storage room, and if not for a nonroutine wipe would have been l transported across campus. Due to the current waste handling l l

procedures, contaminated waste containers could conceivably be transported across campus. Also the waste storage vault is j filled past capacity. The entire waste disposal program is in j need of updating,

h. Coordinating UND's film badge service and maintaining exposure records: UND's response states that Mr. Glass has maintained

dosimetry information in the past. However, there is no l evidence that Mr. Glass has been involved in radiation dosimetry.

{ Perhaps the response relates to monitoring exposure to other i substances.

i I

i

.l

i. Preparation of an annual report for the committee: It appears that Mr. Glass has no training or expe'rience in auditing a radiation safety program. He is not familiar with radiation protection regulations. In a 12/18/96 phone call with Greg Krause, Mr. Glass asked if he had to send in license application forms for each of the 40 researchers on campus. Mr. Glass apparently does not understand the concept of a broad scope i license. i

j. Maintain the Radiation Safety Handbook: Although Mr. Glass does have documented experience and credentials in OSHA compliance and worker safety, he has no radiation protection experience that would qualify him to review or maintain the radiation safety handbook.

k. Maintain minutes of the radiation safety committee: No e comment.

2. Training: UND's RSO has traditionally given a short i radioisotope safety course to all users of radioactive material on campus. Mr. Glass does not appear to have the training or experience to offer a course that would meet the worker training i requirements in the regulations.

Additional review of the 12/23/96 letter: In the final paragraph UND implies that the RSO position is primarily a management effort, with the technical expertise lying on the individual radioactive user.

This view is contrary to the regulatory intent and to information collected by the US Nuclear Regulatory Commission. The l Background information for the NRC's Advanced Notice of Proposed '

Rulemaking on Specific Domestic Licenses of Broad Scope for Byproduct Material states that recent. events at broad scope licenses were often the result of weak controls by either the RSC or the RSO. The RSO is responsible for the day to day operation of the radiation safety program and as such must have significant radiation safety training and experience.

Based on the review of Mr. Glass' credentials, it is the Department's opinion that Mr. Glass' training and experience does not appear to be adequate to perform most of the tasks assigned to the Radiation Safety Officer at UND. Therefore, Mr. Glass is not acceptable as RSO at UND.

i

MS g G

ft. [ NORTH DAKOTA ' 6 s DEPARTMENT OF HEALTH M

        %**,l                                                                 DSNk % 4 s-329                   4-ENVIRONME AL HEALTH SECTION
                                                                                                                              \

l 1200 Missourt Avenue P.O. Box 5520 l December 27, 1996 Bismarck, North Dakota 585g520 Fax #701328-5200 c3

                                                                                                                  ?1 m

Richard Bangart, Director Office of State Programs S] 3 O j

~~

US Nuclear Regulatory Commission '1 Washington, DC 20555 " cs

Dear Mr. Bangart:

As discussed in a telephone conversation between Greg Krause of my , staff and Lloyd Bolling on December 26, 1996, the North Dakota i Department of Health is submitting this technical assistance request j for the NRC to review the qualifications of John Glass to be radiation l safety of ficer for the University of North Dakota (UND) . UND's license j expires on December 31, 1996; therefore, we request that you process this as soon as possible. We request that this review be limited only to determining whether or not the qualifications of John Glass would be acceptable as a radiation safety officer for a Type A broad scope license. A copy of the University of North Dakota's license is enclosed. The University has approximately 40 authorized users, the majority of which use unsealed isotopes such as P-32, C-14, H-3 and iodines in areas of medical and biological research. In addition, the physics department has five one-curie Pu:Be sources, and UND performs its own-survey meter calibrations using a cesium 137 source, has several moisture density gauges, a specifically licensed gas chromatograph which is located in an airplane for doing atmospheric studies, and a large number of fixed level / density gauges which it uses in pilot plant scale coal-fired power plants. The University is not currently licensed to perform any experiments on humans, however, there are a number of on-going experiments utilizing laboratory animals including one using iron-55 and iron-59 in beagles. The University released the previous radiation safety officer in May 1996. The Department performed an inspection of UND on May 20-22, 1996

                                                                                                        'M dh Environmental Health Section   Environmental           Municipal                Waste                      Water and Enforcement            Engineering            Facihties            Management                    Quality 701 328-5150            701 328-5188          701 328-5211            701-328-5166               701 328-5210
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( i Mr. B ngart 2 December 27, 1996 e and identified a number of serious program short-comings resulting in escalated enforcement action. Several of the issues discovered during the inspection should have been identified by members of the radiation safety committee but had been overlooked for the past two years. The University's radiation safety staff mentioned in some of the responses to this Department consist of Jason Uhlir - currently the University of North Dakota's hazardous materials coordinator, and student helpers. Jason Uhlir has held the hazardous materials coordinator position for approximately two years and prior to that was a student helper at the safety office while obtaining his undergraduate degree. Jason Uhlir was trained by the previous radiation safety officer to perform wipe tests, leak tests, inventories and to pick-up, transport and store radioactive waste. He does not have any formal training in radiation safety other than the four hour course given to all radioactive material users at the University. In November, the University hired John B. Glass, Jr. to fill the radiation safety officer position. After the Department made several requests for information, UND submitted a letter and a Curricula Vitae to the Department on December 13, 1996. A copy of the letter and the Curricula Vitae are enclosed. The Department made two requests to get additional clarifying information concerning Mr. Glass' qualifications. John Glass submitted a letter on December 18, 1996 in response to a Department phone call for information, a copy is enclosed. Upon receiving this letter, the Department sent a second request for information in letter form dated December 19, 1996, a copy of the letter is enclosed. This letter specifically asked for a description of Mr. Glass' training and experience with regards to the specific responsibilities of the radiation safety officer as written in UND's radiation safety handbook. UND faxed a response to this Department dated December 24, 1996, a copy of this fax is enclosed. If you have any questions or require additional information, please contact Greg Krause of my staff at (701) 328-5188. Sincerely, n g4 ~ Dana K. Mount, P.E. l Director, Division of Environmental Engineering DKM/GK:csv Enc: i

i a . . J l North Dakota Radiological Health Rules in Subparagraph 33-10-03-05.4.b(3)(b) requires a Type A )

broad scope licensee to appoint a " radiation safety officer who is qualified by training and experience l

j m radiation protection".

North Dakota has adopted the Nuclear Regulatory Commission's Broad Scope Regulatory Guide for ,

applications for licenses. Although regulatory guides are not regulations, they supply guidance to l licensees on how to meet the regulatory requirements. In clarifying how an institution should comply i

( with the training and experience regulation the guide states that the RSO should have: l i

                       " considerable professional experience (generally about 5 years) with a broad spectrum of                        )

radioactive materials. The RSO's professional experience should include the application of j this training to the management and administration of a radiation safety program related to i the types, quantities, and uses of the radioactive material to be used under the license." Tne following is a chronology of events concerning the hiring of a Radiation Safety Officer in 1996; ! 5/1 Greg Krause phoned UND for Dale Patrick, RSO, and was told that Dale was out of the l office but would return the call. u ! 5/3 Tried to contact Dale Patrick without success.

5/7 Tried to contact Dale Patrick without success.

l 5/9 Tried to contact Dale Patrick. Greg Krause told the receptionist that Dale Patrick's failure to l return calls was a serious matter. The receptionist then stated that Dale Patrick was leaving 4 the position and had not been around much. Mr. Krause stated that Dale Patrick leaving . without a replacement RSO was a very serious matter which should have been reported to i the Department as soon as it was known that Dale Patrick was leaving. i l 5/9 James Uhlir called the Department and stated that they would have an interim RSO appointed

and would then hire a full time RSO in a timely manner. An inspection date was set for May j 20.

l

5/20 Inspectors met with Dr. Richard Baltisberger and received a copy of his resume and a letter )

l requesting his appointment as interim RSO. The majority of his training and expe'rience was l gained from 1%3 to 1968 at a DOE facility. l ! 5/22 A copy of the page listing RSO qualifications from the NRC's regulatory guide was given tt j UND at the inspection close-out meeting. At that time it was pointed out that although the I guide used the word "should" for all intents and purpose it means "must" : j Inspection findings indicated that the radioactive material program was in a state of decline

!                      and resulted in a Notice of Violation, an escalated level of enforcement rarely used by the radiation control program i

I 6/19 During the inspection Dr. Baltisberger raised concerns that he would not be able to continue

l ,

1 )* as RSO once the school year began Responding to Department questions concerning the amendment to UND's license, James Uhlir phoned and stated that Dr. Baltisberger had ] agreed to act as RSO through September 1,1996. :

i i 6/25 License amendment authorizing Dr. Baltisberger as interim RSO was sent to UND The i letter contained the statement: l "UND should make every effon to fill the Radiation Safety Officer position and j amend this license prior to September 1,1996 or the license will expire and UND may be in possession of radioactive material without a valid radioactive material license."

j 7/22 Following publication of UND's " Staff Position Announcement", Ken Wangler phoned James Uhlir and stated that the phrase: " Specific training in radiation health sciences with considerable professional experience preferred." was inadequate. Mr. Wangler explained the 1 minimum qualifications and emphasized the importance of the new hire meeting those i requirements. Mr. Uhlir assured the Depanment that they would hire someone with adequate j experience. ; i 8/5 James Uhlir sent a letter to the Department requesting an extension of Dr. Baltisberger as I ' RSO until 11/1/96. Mr. Uhlir stated that "An extension would allow UND more time to fill ! the Safety Officer position." I i 8/20 UND's license was amended to expire November 1,1996, with the same wording as the June amendment. ; l l 10/22 James Uhlir sent a letter to the Depanment to request extending Dr. Baltisberger as RSO j until December 31. In the letter Mr. Uhlir stated that UND will select a new safety officer j the week of October 28,1996. UND hoped that the new director would start sometime j before the first of the year so extending Dr. Baltisberger to December 31 would give the new { person a chance to settle in. The letter also stated that: "As soon as we make the selection l for the position and we receive confirmation from the selected applicant, UND will forward ! credentials to the NDSDH for review." 10/28 The Department made the decision to let UND's license expire but allow UND to continue l using radioactive material under timely renewal through December 31,1996. The decision to i allow timely renewal status was based on the information submitted in the October 22 letter. l Timely renewal is a regulatorally defined status to allow a licensee time to resolve licensing

issues.

11/47 James Uhlir phoned Greg Krause and stated that a new safety officer had been extended an offer and had tentatively agreed to accept.

11/12 During a conversation about Uranium ore found stored in UpsonII room 17A, Greg Krause: told Jason Uhlir that the Department had to review and approve the new radiation safety i officer so UND needed to get the safety officer candidate's qualifications to the depanment l as soon as possible. Jason Uhlir replied that he would be sure to tell James Uhlir.

4 4 4 h i

1 1

12/9 A letter dated 12/6 was sent to UND. The letter stated that: "Unless UND takes significant steps to renew the license, authorization to possess and use radioactive material will j terminate on December 31,1996." The letter also requested that UND submit information regarding the new safety officer so that the department could review the qualifications in 3

order to extend the timely renewal status. i j 12/13 The Department received a letter requesting a meeting in Bismarck between James Uhlir and l John Glass, the newly hired safety officer candidate, of UND and the Health Department staff

on Tuesday, December 17,1996. Due to adverse weather UND personnel did not make it to l the meeting. UND personnel did not contact the Department to cancel or to reschedule the

! meeting. i .i j The Department received a copy ofJohn Glass' training and qualifications. The only mention j of radiation experience was in a four sentence paragraph at the bottom of the cover letter. l The 7 page Curricula Vitae or his 6 page list of " Continuing Education, Conferences and ! Seminars" did not contain any reference to radiation training or experience. I j 12/18 Greg Krause phoned John Gass to request additional information on his radiation training

               - and experience. Mr. Glass admitted that he really didn't have much experience other than

! what was already listed on the earlier letter. It was requested that he elaborate on the information submitted. Mr. Glass also stated that he was going to New Jersey December 20 1 and would not return until January 6,1997. ! l l John Glass faxed a narrative concerning all of his radiation experience and training. 1 ! 12/20 John Glass phoned Greg Krause concerning his application as RSO. Mr. Glass was told that he would probably be turned down as RSO and that a letter had already been drafted for the i Division Directors signature. If Mr. Glass was turned down the letter would probably be j coming later in the day. l The Department faxed a letter dated 12/19/96 to James Uhlir stating that from the j information submitted, John Glass does not meet the requirements to be RSO. The letter also included the US NRC's standard Type A Broad Scope RSO information request in order for the department to obtain the level and depth ofinformation necessary to submit a Technical l Assistance Request to the NRC, if necessary, for a third party evaluation. The letter closed with the following: "Due to severe time constraints currently faced by UND with the pending j December 31,1996 license expiration, please make every effon to remain in contact with this i Department as you address this issue." 1 h a

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[ 3 NORTH DAKOTA ff . N t I. DEPARTMENT OF HEALTH k g ENVIRONMENTAL HEALTH SECTION 1200 Missoun Avenue P.O. Box 5520 October 28, 1996 Bismarck, North Dakota 58506 5520 Fax #701328 5200 James Uhlir, Director Auxiliary Services University of North Dakota P.O. Box 9031 Grand Forks, ND 58202-9031

Dear Mr. Uhlir:

In response to your request dated October 22, 1996, the expiration date of the University of North Dakota's radioactive material license no. 33-12827-01 has been extended to December 31, 1996. Until that date, your license is considered to be under timely renewal. If you have any questions, please feel free to contact Greg Krause of my staff at (701) 328-5188. Sincerely, Dana K. Mount, P.E.

                                .W Director, Division of Environmental Engineering DKM/GK:csv Environmental Healtn Section   Environmental         Municipal            Waste                       Water and Enforcement           Engineenng           Facihties         Management                     ovahty 701 328 5150            701 328 5188       701 328 5211         701-328 5166                701-328-5210 Pnnted on recycled paper.

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                                                                                        )MS DEPARTMENT OF HEALTH b

EN ONM L ON August 20, 1996 1200 Missouri Avenue P.O. Box 5520 Bismarck, North Dakota 58506-5520 Fax e701328-5200 Dr. Richard Baltisberger, RSO University of North Dakota occupational Safety and Environmental Health Office Box 9031 l University Station Grand Forks, ND 58202

Dear Dr. Baltisberger:

Enclosed is a copy of Amendment No. 20 License No. 33-12827-01 renewed and amended in its entirety by the North Dakota Department of Health in response to your application dated August 5, 1996. This amendment authorizes UND to posses two 2 curie cesium-137 sources. This authorization was inadvertently removed from UND's license in 1985. This amendment also extends the expiration date of the license from, September 1, 1996 to November 1, 1996. UND should make every effort to fill the radiation safety officer position and amend this license prior to November 1, 1996, or the license will expire and UND maybe in possession of radioactive material without a valid radioactive material license. Although the Department has made a determination that your use of radioactive materials as authorized by this license may be performed so as to protect the health and safety of the public, it is the licensee's - responsibility to maintain compliance with Article 33-10 of the North Dakota Administrative Code, including Chapter 33-10-04.1, " STANDARDS FOR PROTECTION AGAINST RADIATION" and the conditions of the enclosed license. Please review this license carefully and notify us of any errors or omissions. If you have any questions, please feel free to contact this Department. Sincerely, Q AA&f) Greg K ause Environmental Engineer Radiation Control Program Div. of Environmental Engineering GK:csv Enc: xc: Jim Uhlir, UND Environmental Health Section Environmental Municipal Waste Water and Enforcement Engineenng Facihties Management Quality 701 328 5150 701-328-5188 701 326-5211 701 328-5166 701 328 5210 Pnnted on recycled paper.

i l SFN 6733 I FORM Page 1 of 6 pages NORTH DAKOTA DEPARTMENT OF HEALTH Amendment No. RAD 686 __2.Q__ RADIOACTIVE MATERIAL LICENSE Pursuant the Northto Dakota Section 23-20.1-01 through Section 23-20.1-11 of Chapter 23-20 1 of Century Code, and Article 33-10 of the Administrative Code, North Dakota and in reliance on statements and representations heretofore mide by the licensee designated below, a license is hereby issued authorizing such j licsnsee to transfer, receive, possess, and use the radioactive materials for the i purpose (s) and at the place (s) designated below. This license is subject to all I epplicable rules, regulations and orders now or hereafter in effect of the North Dakota Department of Health and to any conditions specified below: Licensee 3. License Number 33-12827-01

1. Name is amended in its entirety. I University of North Dakota 1

4. Expiration Date

2. Address Grand Forks, ND 58202 November 1, 1996

5. Reference Number 102

6. Radioactive Materials 7. Chemical and/or 8. Maximum quantity l

(element and mass physical form l number) which licensee may possess at any one time A. Any radioactive A. Unsealed A. 18,500 mega-material between Atomic Numbers becquerels 1-96 inclusive, (500 milli-curies) per radionuclide. B. Any radioactive B. Sealed sources B. No single source material between Atomic Numbers to exceed 7400 3-96 inclusive. megabecquerels (200 millicuries) supplemental sheet

                 . ~ . . . .         .--         . - .      ..  -     - . . - . . - . . .-      --     .. - -..     . , - .

l I l_ 1-2 SFN 6733 Form Page ,,,2,,,of 1 NORTH DAKOTA DEPARTMENT OF HEALTH RAD 686A l License No. 33-12s21-01 ' RADIOACTIVE MATERIAL LICENSE Amendment No, 1 supplemental sheet C. Hydrogen 3 C. Sealed sources C. No single source (Safety Light to exceed 7400-Corporation- megabecquerels Model 508-3 (200 millicuries) i source within l a ScienTech, Inc. j Model ECD-289 i l Electron Capture Detector) { D. Americium 241: D. Sealed' source D. No single source l Beryllium (Troxler drawing l to exceed 370 i number A-102700) megabecquerels j (10 millicuries). E. Americium 241: E. Sealed source E. No single. source I Beryllium (Campbell Pacific I to exceed 1850 Nuclear Model megabecquerels CPN 131) (50 millicuries). F. Plutonium 239 F. Sealed Sources F. Five Sources not to exceed 37 gigabecquerels (1 curie) each. G. Cesium 137 G. Sealed Sources G. Two Sources not to exceed 37 gigabecquerels (1 curie) each and two sources not to exceed 74 giga-becquerels (2 curies) each.

      ..      .        -.     -   -  - ~ . . , -       . -      - - .            -- . . - ,           .  . . - _ . _ _ - - -

d SFN 6733 * . Forin P:ga 2.,of f._ NORTH DAKOTA DEPARTMENT OF HEALTH RAD 686A

      #                                                                                   License No. 31-12a27-01 RADIOACTIVE MATERIAL LICENSE           Amendment No, 1 supplemental sheet i '

l rf H. Uranium H. Natural Uranium H. 5500 pounds in the form of

cylindrical slugs canned in aluminum.

i i 9. Authorized Use: 4 A. & B. Research and development (as defined in North Dakota j Radiological Health Rules Section 33-10-01-04). C. For use in ScienTech, Inc. Model TAG-4000 or Model GC-20 gas chromatograph. When used in a laboratory, aircraft, or other

enclosed environment, the gas chromatograph shall be properly vented to the outside or to a fume hood to prevent off-gassed Hydrogen 3 j from entering the enclosed environment. !

t D. For use in Troxler Model 4301 depth moisture gauge, to conduct soil moisture / density measurements. ! 1 E. For use in Campbell Pacific Nuclear Corporation Portaprobe 503 to conduct soil moisture / density measurements. , F. For use in the Neutron Howitzer. G. For use in Level Density gauges. i j H. Storage for disposal only. 4 E CONDITIONS

10. The authorized place of use is the University of North Dakota in Grand Forks,-with the following exceptions:

  ,              A. Moisture density gauges may also be used at temporary job sites throughout the State of North Dakota.

B. The ScienTech, Inc. Model TAG-4000 or Model GC-20 gas chromatograph 3 i i

l

 . srN s733     .     ,

Form ptgi _,g_. of 6 NORTH DAKOTA DEPAR'DfENT OF HEALTH i RAD 686A License No. 33-12927 01 RADIOACTIVE MATERIAL LICENSd Amendment No. 1 supplemental sheet l l l 1 (containing a ScienTech, Inc. Model ECD-289 electron capture j detector) may also be mounted in a University of North Dakota ' research airplane and used in atmospheric research anywhere in the ! State of North Dakota. C. Fe-55, Fe-59, Dr. McClarin and Tc-99m may be used under the supervision of and P-32, S-35 and I-125 may be used under the 4 supervision of Dr. Hayworth at the UND Medical Education Center in Fargo.

11. A.

The licensee shall comply with the provisions of Chapter 33-10-04.1, 1

              " STANDARDS FOR PROTECTION AGAINST RADIATION," and Chapter 33-10-10,
              " NOTICES, INSTRUCTIONS AND REPORTS TO WORKERS - INSPECTIONS."

B. An annual fee as prescribed in Chapter 33-10-11 " Fees for Issuance of License and Registration Certificates and Inspections" shall be paid I no later January first of each year the license is active. l C. The licensee shall comply with all State and Federal environmental regulations. In addition, the licensee shall comply with all local

12. A.

Radioactive materials should be used by or under the supervision of individuals designated by the Radiation Safety Committee. B. The Radiation Safety Officer shall be Dr. Richard Baltisberger.

13. A.

Each sealed source containing radioactive material, other than Hydrogen 3, with a half-life greater than thirty days and in any form other than gas shall be tested for leakage and/or contamination at intervals not to exceed six months. In the absence of a certificate from a transferor indicating that a test has been made within six months prior to the transfer, the sealed source shall not be put into use until tested. B. Not withstanding the periodic leak test required by this condition, any licensed sealed source is exempt from such leak tests when the source contains 3700 kilobecquerels (100 microcuries) or less of beta and/or gamma emitting material or 370 kilobecquerels (10 i microcuries) or less of alpha emitting material.

_ _ ~ . ._ . _ _ _ . _ _ . _ _ _ . . , . - _ _ _ _ _. ,_ _ _ _ -=___ _ .__-._=... _ __ m SFN 6733 ' - Foria P g2 ,,1., of _f,,, NORTH DAKOTA DEPARTMENT OF HEALTH

A RAD 686A i License No. 33-12a27-01 RADIOACTIVE MATERIAL LICENSE Amendment' No. 2,Q,,,

supplemental sheet i l i C. The periodic leak test required.by this condition, does not apply to sealed sources that are stored and not being used. The sources excepted from this test shall be tested for leakage prior to any use or transfer to another person unless they have been leak tested , l within six months prior to the date of use or transfer. D. The test shall be capable of detecting the presence of 185 becquerels (0.005 microcurie) of radioactive material on the test

safple. The test sample shall be taken from the sealed source or from the surfaces of the device in which the sealed source is permanently mounted or stored on which one might expect contamination to accumulate. Records of leak test results shall be kept in units of becquerels or microcuries and maintained for inspection by the Department.

E. If the test reveals the presence of 185 becquerels (0.005 microcurie) or more of removable contamination, the licensee shall immediately withdraw the sealed source from use and shall cause it to be decontaminated and repaired or to be disposed of in accordance : with Department regulations. l l F. A report shall be filed within 5 days of the test with the Director, Division of Environmental Engineering, North Dakota State Department ! of Health and Consolidated Laboratories, 1200 Missouri Avenue, Box l 5520, Bismarck, North Dakota 58502-5520, describing the equipment involved, the test results and the corrective action taken.

14. Sealed sources containing radioactive material shall not be opened.

l ~ Installation, relocation, maintenance, repair, and initial radiation survey of devices containing radioactive material and instal 3ation, replacement, and disposal of sealed sources containing radioactive material used in devices shall be performed only by the manufacturers of the devices listed under Item 9, or by other persons specifically 1 ! authorized by the Department, another Agreement State, or the U.S. 4 Nuclear Regulatory Commission, to perform such services. 15.

The licensee shall not use licensed material in or on human beings or in field applications where activity is released, r

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l SFN 6733 Form Pige ,5,,,,of 1 NORTH DAKOTA DEPARTMENT OF HEALTH

. RAD 686A l License No. 33-1282*1-01 RADIOACTIVE MATERIAL LICENSE Amendment No.,,JJ2,,,, i supplemental sheet 1

4 ! 2 I i j 16. Experimental animals administered licensed materials or their products shall not be used for human consumption. 17. Each sealed source containing licensed material to be used outside of a ' shielded exposure device shall bear a durable, legible, and visible tag 1 permanently attached to the source. The tag shall be at least one (1) 3 inch square, shall bear the conventional radiation symbol prescribed in Section 33-10-04.1-13 of the North Dakota Radiological Health Rules, and a minimum of CAUTION-RADIOACTIVE MATERIAL or DANGER-RADIOACTIVE MATER DO NOT HANDLE - NOTIFY CIVIL AUTHORITIES IF FOUND. i Repair or l { replacement of tags shall be accomplished by persons specifically j licensed by the Nuclear Regulatory Commission or an Agreement State to { perform this. service. l

18. The licensee shall conduct a physical inventory every three months to I account for all sealed sources received and possessed under the license.

The records of the inventories shall be maintained for inspection by the Department and shall include the quantities and kinds of radioactive ! material, location of sealed sources and the date of the inventory. !

19. Except as specifically provided otherwise by this license, the licensee !

shall possess and use radioactive material described in Items 6, 7, and l 8 of this license in accordance with statements, representations, and ! procedures contained in application received by this Department on October 24, 1995, University of North Dakota Radiation Safety Handbook 1995, letter dated December 7, 1995, letter dated May 16, 1996, and letter dated August 5, 1996. FOR THE NORTH DAKOTA DEPARTM f OF HEALT Date: [ By: 4d 7 r K. Mount, Div.ofEnviro/.E., Director nmental Engineering

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     ,              UNI VE R,S I T                          OF                            N O R               H         D A K O TA 4

i i December 10,1996 C M ATI NAL sAFm AN N ^ 4 1o A I NG s P.O. BOX 9031 GRAND FORKS. NORTH DAKOTA 58202-9031

(701) 777 3341 FAX (701) 777 4132 l M I2/ /f Ken Wangler D c3 fk6 North Dakota State Dept. of Health c.Y .. f ? 1200 Missouri Avenue " N-

                                                                                                                                      $g l                     Box 5520                                                                    <j ENy;;

l I Bismarck, ND 58502 % %: i

                                                                                                    "@g82 E .:",'

RE: Request for approval of UND's RSO

Dear Mr. Wangler:

l The University of North Dakota requests your approval to appoint John B. Glass, Jr. as the Radiation Safety Officer commencing January 1,1997. Mr. Glass is certified by the American Board ofIndustrial Hygiene for Comprehensive Practice, the National Environmental Training

l. Institute as a Certified Environmental Trainer, and The Institute of Hazardous Materials L Management as a Certified Hazardous Materials Manager at the Masters Level. In addition, the
Board of Certified Safety Professionals has approved his application to become a Certified Safety .

j Professional. ' The examination results should arrive shortly.

While completing a Masters Degree in Environmental Health for Temple University, Mr. Glass had successfully completed the course Isotope Methodology which was presented through the University's College of Pharmacy. This course was designed for Health and Safety l' Professionals and emphasized the gathering and interpretation of radiological data related to worker exposure, contamination assessment and environmentallevels. Project experience specific

;                    to radiological safety includes the clearance of multiple research laboratories for reoccupation.-

j Also, the collection and disposal of radioisotopes at a New York City Research University. i If you have any questions or concerns, please contact me at (701)777-3755. i Sincerely, wd 5 Jim ir

;                    Director of Auxiliary Services I

e 1 l Enclosures UND D an equal oppommHy/aHltmative Etton insatutkm

.t 1 CURRICULA VITAE I JOHN B. GLASS, JR., CIH, CET, CHMM University of North Dakota Post Office Box 9031 Grand Forks, North Dakota 52802 i E-Mail: jbgcih@ix.netcom.com Mr. Glass has over ten years of experience in the environmental consulting and industrial hygiene field. He has conducted numerous plant-wide and process-wide industrial hygiene audits encompassing full regulatory compliance, employer liability, and worker satisfaction. His experience includes studies in noise, toxic exposures, emergency equipment, S.O.P. implementation, superfund oversight, emergency response, industrial ventilation and plan / specification design. He has written and presented training courses, keynote addresses and I seminars on industrial hygiene, safety and environmental issues. His training experience includes the creation and presentation of worker health and safety courses for compliance with OSHA requirements. He has also conducted numerous indoor air quality investigations, property transfer investigations and has directed underground storage tank removals. Mr. Glass has provided I Expert Testimony in the asbestos and air quality fields to law firms and public interest groups, and l is a Mentor to the Hahneman University and Philadelphia College ofMedicine, Industrial Hygiene ; Program. In addition to his professional accomplishments, Mr. Glass is active in his community I as evidenced by his participation on the Tabernacle Rescue Squad, local political groups and community organizations. EDUCATION: M.S., Environmental Health-Industrial Hygiene / Occupational Health and Safety, Temple University B.S., Environmental Planning and Design, Rutgers University PROFESSIONAL LICENSE: C.I.H., Certified in the Comprehensive Practice ofIndustrial Hygiene by the American Board ofIndustrial Hygiene; #6157 C.E.T. Certified by the National Environmental Training Association as a Certified Environmental Trainer for Occupational Safety and Health; #96518 C.H.M.M. Certified by the Institute of Hazardous Materials Management as a Certified Hazardous Materials Manager at the Master Level; #7500

1 i J. Glass. CIH. CET. CHMM { Curricula Vitae Page 2 { New Jersey State Depanment ofHealth, Certified Right to Know Trainer i New Jersey State Department of Health, Licensed Emergency Medical Technician i j New Jersey Department of Community Affairs, Asbestos Safety Technician, #00371 ! PROFESSIONAL EXPERIENCE: i I University of North Dakota j P.O. Box 9031 ) Grand Forks, North Dakota 58202 ! Director of Occupational Safety and Environmental Health Office 1996-Present i As Director, Mr. Glass is responsible for the overall health and safety of over 1,300 l employees 11,000 students and 200 buildings. He is the director of the University Safety { Committee, Radiation Safety Committee, and BioSafety Committee. His duties include { Office Management, program development, accident investigation, hazardous material

response and employee training.

2 Tyler Scientific Company j Principal,1992-Present a Mr. Glass is the founder and operator of a professional industrial hygiene and ; environmental consulting firm. Projects range from homeowners to industrial building j $ decommissioning. He has performed plant-wide health and safety audits, compliance l inspections and compliance training as well as environmental training for state licensure. Projects have included indoor air quality investigations, wastewater treatment facility j services, and health and safety compliance program design. Mr. Glass is responsible for business development, project management and all aspects of technical operations. i Omni Environmental Corporation Senior Consultant,1994 to 1995 As Senior Consultant, he personally oversaw all industrial hygiene projects and research. i Mr. Glass developed, monitored and serviced a growing client base in the health and safety field. These services included auditing, program development and implementation, training, j j emergency response and compliance services. He also presented informative seminars and

]                     keynote addresses to trade groups and the public. Mr. Glass had articles and newsletters j                      published on a periodic basis for existing clients. He has continued to service this client base 1

on a contract basis through the present. l 1 s

J. Glass. CIH. CET. CHMM Curricula Vitae Page 3 Hillmann Environmental Company Director of Occupational Health, 1989-1992 General Manager of Mid-Atlantic Region, 1988-1989 Industrial Hygienist, 1987-1988 As Director of Occupational Health and Safety, Mr. Glass was responsible for assuring full compliance of the Corporation with all OSHA requirements. As Manager of the Mid-Atlantic Region, Mr. Glass was responsible for all facets of operations, quality assurance and project review. 3 Thompson Land Company 4 Environmental Consultant / Planner, 1986-1987 He has performed numerous land audits, based on environmental factors and l comparison of surrounding properties. Audits included; estimation of wetlands / flood plains areas, zoning, topography, soil structure, geological base, aerial photography, soil tests and others. These factors, compared to neighboring properties were used to determine an appropriate market valuation. ADDITIONAL EXPERIENCE: Elkin-Sinn, Inc., Pharmaceutical Manufacturing; Industrial Hygienist / Intern , Developed industrial hygiene programs including respiratory protection, hearing conservation, emergency equipment and medical monitoring. Also, monitored the fumigation of sterile areas while under level B personal protection, developed sound level maps, created a j comprehensive database to coordinate all industrial hygiene activities and computerized the "Right to Know" annual reports. i Philadelphia Naval Shipyard; Industrial Hygienist / Intern Performed monitoring and evaluation of exposure potential in various situations including the cleaning of chromic acid and cyanide containing compounds, noise level / dosimetry, asbestos, lead and other exposures to workers on an aircraft carrier. Analysis and control procedures were suggested for each event. PROFESSIONAL ASSOCIATIONS AND /1 CTIVITIES:

Diplomate, American Board ofIndustrial Hygiene

Member, American Academy ofIndustrial Hygiene

   - . . . - .      .-           .   .= . . . . - .- .       -    .- . -     .   .     --    . -. .   .

N !x 1 i o 3 J. Glass. CIH. CET. CHMM , Curricula Vitae L Page 4 i

=

Full Member, National American Industrial Hygiene Association

Diplomate, Institute of Hazardous Materials Management

               =                                                                                           l Member, AIHA New Jersey Section, Delaware Valley Section                              !

! = Member, National Environmental Training Association

t Member. AIHA Hazardous Waste Committe

Member, Society ofMilitary Engineers'

Member, American Red Cross-Instructor & Certified

Member, National Asbestos Council'

Member, Burlington County Chamber of Commerse

NJ Notary Public

Member, Tabernacle Rescue Squad

Brother, Knights of Columbus (Past Officer)

Industrial Hygiene Student Mentor, Hahneman University & Philadelphia College ofMedicine

Member, Tabernacle Republican Club, Vice President, Municipal Vice Chairman '

Member, SJRA, Committee Chairman

County Committee, Vice Chair

Elected Official Riverside Township Committee

Local Emergency Management Coordinator *

Local Emergency Planning Committee, Chairman *

                  *Past ' Activity / Expired Term PROFESSIONAL OUALIFICATIONS AND TRAINING
          =

ABIH Certified Industrial Hygienist, #6157

AlHA Registry for Airborne Asbestos

Aseptic Techniques Training

Comprehensive Review ofIndu> trial Hygiene - University of Cincinnati

DEL State Certified Asbestos fiUI Technician

EPA Model, Lead Inspector, Werker & Contractor

Emergency Medical Technician - Level A, N.J. Department of Health

Hazardous Material Management Review - NJIT

O J. Glass. CIH. CET. CHMM Curricula Vitae Page 5 -

 =      IHMM Certified Hazardous Materials Manager, Master; #7500
 =

Incident Command Training - New Jersey State Police

 =      MD State Licenced Asbestos Project Designer
 =      NETA Certified Environmental Trainer, #96518
 =      NIOSH 582 Cenified - Temple University, Center for Environmental Studies
 =      NJ DOH Emergency Medical Technician
 =      NJ DCA Certified Asbestos Safety Technician
 =      NJ DOH Certified Lead Inspector / Risk Assessor
 =      NY State Certified Air Sampling Technician
 =      NY State Certified Asbestos Worker
 =

NY State Certified Instructor - All Licensing Classes

NYC/NJ Certified Asbestos Worker & Supervisor

OSHA 1910.120 HAZWOPER Training - Environmental Training Institute

 =      OSHA 1910.134 Respiratory Protection
 =      OSHA 1910.146 Permit Required Confined Space Entry
 =      OSHA 1910.147 Control of Hazardous Energy (LOTO)
 =      OSHA 1910.1025 Lead Standard
 =      OSHA 1910.1030 Bloodborne Pathogens
 =

OSHA 1910.1200 Hazard Communication Standard a USEPA AHERA Certified Asbestos Project Supervisor

USEPA AHERA Certified Building Inspector / Management Planner

 =      USEPA AHERA Certified Project Designer
 =      USEPA Lead Inspector / Risk Assessor                                                        ,

a USEPA/NJ Lead Abatement Project Planner / Designer TEACHING EXPERIENCE: i Mr. Glass has extensive experience providing professional training and worker education in every facet of health and safety. A partial list of the courses he has instructed includes:

        =       Access to Medical Records

AHERA Inspector / Management Planner l

j

4 e J. Glass. CIH. CET. CHMM Curricula Vitae Page 6 l

           =          AHERA/NJ Brake and Clutch Repair Tecimiques
           =          Asbestos Awareness
           =          Asbestos Handler / Supervisor
           =          Bloodborne Pathogens                                                              j
           =          Chemical Hygiene / Lab Safety                                                     I i
           =          Confined Space Entry Training                                                     !
            =         Hazard Communication Standard Training                                            i
            =         Hazardous Waste Operations
            =         Hazardous Materials Awareness / Operations / Technician
            =         Hearing Conservation Training
            =         Industr:al Hygiene Practice
            =         Lead Abatement
            =         Lead Awareness a         Lead Inspection and Analysis
            =         Lockout Tagout Training
            =         NIOSH 582
            =         NJ PEOSHA Right-To-Know
            =         NYS Worker / Supervisor / Inspector / Restricted Handler
            =         OSHA Compliance Overview
            =         Respiratory Protection Training
             =         Safety Seminars
             =        Trenching and Shoring
             =         Various Red Cross Certified Courses a         Walking / Working Surfaces l

PUBLICATIONS: ) l Glass, J. B., " Health and Safety Compliance; A Comprehensive Approach, New Jersev ) EfUuents. Vol. 27, No. 7, Winter 1995. Glass, J. B., Editor, Health and Safety Recon A Quarterly Newsletter, December 1994. Glass, J. B., " Health and Safety Compliance; Written Programs, New Jersev EfUuents. Vol. 23, No. 2, Summer 1995.

'n

a J. Glass. CIH. CET. CHMM Curricula Vitae Page 7 1

1 4 l PRESENTATIONS: Trenching and Shoring, and other Safety Issues; New Jersey Water Pollution Control Association, South Jersey Section, December Keynote Address,1994 ; i I Health and Safety Compliance; Water Environment Association, Central Jersey Section, l Annual Education Seminar,1995. 4 Industrial Hygiene Practice; Hahneman University and Philadelphia School for Medicine, Industrial Hygiene Program, OSHA Seminar, September 1995. 2 RELEVANT SKILLS: i Computer Literate: Knowledgeable of various software packages including; Quicken / Quick Books, Word Perfect, Lotus 1-2-3, Quattro Pro, l Powerpoint, MS Publisher, Norton Utiljties, Paradox, Edlin, Print i Shop, MultiMate, et. al.

Proficient in both DOS and Windows environments. ! = Limited programming ability in Fortran and Basic. 1 i ! = Familiar with online data retrieval and searches. l l l l REFERENCES AVAILABLE UPON REOUEST

9 JOHN B. GLASS, JR., CIB, CET

                ' CONTINUING EDUCATION, CONFERENCES AND SEMINARS 1987 Sampling and Evaluating Airborne Asbestos Dust; Presented by Hillmann Environmental Company, Union, NJ. October 1987,30 hours.

19 % New Jersey Asbestos Safety Technician; Presented by NJ Department of Community Affairs, Trenton, NJ. June 15th through 18th,1988,24 hours. New Jersey /New York City /New York State /AHERA Dual Certification in Asbestos Abatement , Worker / Supervisor; Presented by National Asbestos and Environmental Training Institute, Ocean, NJ. June 20th through 24th,1988,40 hours. AHERA Inspector; Presented by National Asbestos and Environmental Training Institute, Ocean, NJ. October 24th through 26th,1988,24 hours. AHERA Management Planner; Presented by National Asbestos and Environmental Training Institute, Ocean, NJ. October 27th through 28th,1988,16 hours. Annual BOMA Convention; Presented by Building Owners and Management Association, Washington, DC. November 2nd through 4th,1988,24 hours. 1989 Powerful Presentations, Newark Holiday Inn, Newark, NJ. January 31,1989, 8 hours. National Asbestos Council, Annual Conference; Presented by National Asbestos Council, Anaheim, CA. March 28th through 31st,1989,32 hours. Stress Management; Presented by Burlington County Chamber of Commerce, Viscount Hotel, Mt. Laurel, NJ. April 18th,1989,2 hours. , I Ethics in Business; Presented by Burlington County Chamber of Commerce, Viscount Hotel, Mt. j Laurel, NJ, May 31st,1989,2 hours. l l l _a

l 4 - . . i l J. Glass, CIH, CET

Continuing Education '

Page 2

Advanced Lifesaving and Water Safety, American Red Cross; Presented byConners Beach Club,: . Atlantic Highlands, NJ. July, 1989,21 hours.

) NYS/AHERA Inspector / Management Planner Refresher; Presented by National Asbestos and l Environmental Training Institute, Ocean, NJ. August 25th,1989, 8 hours. 9th Annual Northeastern Industrial Hygiene Conference and Exposition; Presented by New Jersey Section, American Industrial Hygiene Association, Princeton Hyatt, Princeton, NJ. December 1st,1989,8 hours. ! 1990 1 i Introduction to Health Services Education; American National Red Cross, GE Aerospace, Moorestown, NJ. February 4,1990,4 hours. Sampling and Evaluating Airborne Asbestos Dust, NIOSH 582; Presented by Eagle Industrial Hygiene Associates, Inc., Huntingdon Valley, PA. February Ilth through 16th,1990,40 hours. Cardiopulmonary Resuscitation and Emergency Care for the Professional Rescuer; Presented by American National Red Cross, GE Aerospace, Moorestown, NJ. March loth,1990,6 hours. Community CPR, Instructor; Presented by American National Red Cross, GE Aerospace, Moorestown, NJ. March 9th through 1Ith,1990,20 hours. Aseptic Techniques; Presented by Elkin Sinn Pharmaceutical Company, Training Department, Cherry Hill, NJ. June 7th,1990, 6 hours. Good Manufacturing Practices / Hazard Communication; Presented by Elkin Sinn Pharmaceutical Company, Training Department, Cherry Hill, NJ. June 15th,1990,6 hours Advanced Lifesaving and Water Safety, American Red Cross; Presented by Ramblewood Country Club, Mount Laurel, NJ. July, 1990,21 hours. 10th Annual Northeastern Industrial Hyg:ene Conference and Exposition; Presented by New York Section, American Industrial Hygiene Association, Princeton Hyatt, Princeton, NJ. December 6th,1990,8 hours. Sampling and Evaluating Airborne Asbestos Dust, NIOSH 582; Presented by Temple University, Center for Environmental Studies, Philadelphia, PA. December 17th through 21st,1990,40 hours.

Y

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f l J. Glass, CIH, CET Continuing Education l Page 3 l i 1921 Powers and Duties ofMunicipal Governing Bodies; Presented by Rutgers University, Department i of Government Services, New Brunswick, NJ.L January 1991, 8 hours. NYS/AHERA Inspector / Management Planner Refresher; Presented by National Asbestos and . Environmental Training Institute, Ocean, NJ. February 19th,1991, 8 hours. NYS Restricted Handler II; Presented by Hillmann Environmental Company, Union,, NJ. March j 2nd through March 3rd,1991,16 hours. 2 NJ Incident Command System; Presented by NJ Department of Law and Public Safety, Office of Emergency Management, Mount Holly, NJ. May 18th through 19th,1991,16 hours.

1Ith Annual Northeastern Indur-ial Hygiene Conference and Exposition; Presented by Delaware i Valley Section, American Industrial Hygiene Association, Princeton Hyatt, Princeton, NJ.

j December 6th,1991,8 hours. l I a g Lead Awareness for 29 CFR 1910.1025; Presented by Hillmann Environmental Company, Voorhees, NJ. January 1992,8 hours. Comprehensive Review for Industrial Hygiene Professionals; Presented b: University of Cincinnati, Institute of Environmental Health, Florence, KY. March 9th through 13th,1992,4 CEU,40 hours. NYS/AHERA Asbestos Supervisor / Contractor Refresher; Presented by National Asbestos and Environmental Training Institute, Ocean, NJ. May 6th,1992, 8 hours. American Industrial Hygiene Conference Exposition; Presented by AIHA and ACGIH, Boston Massachusetts. May 30th through June 2nd,1992,24 hours. Emergency Medical Technician-Ambulance; Presented by NJ Emergency Management Agency and NJ Department of Health, Evesham, NJ. June through September, 1992,110 hours. NYS/AHERA Inspector / Management Planner Refresher; Presented by National Asbestos and Environmental Training Institute, Ocean, NJ. November 6th,1992, 8 hours.

             .~        ..   .       .
                     .                                                                                     ?

a J. Glass, CIH, CET Continuing Education Page 4 l

12th Annual Northeastern Industrial Hygiene Conference and Exposition; Presented by New Jersey Section, American Industrial Hygiene Association, Princeton Marriott, Forrestal Village { Princeton, NJ. December 4th,1992, 8 hours. 1 l 1221 Hazardous Waste Operations and Emergency Response; Presented by Environmental Training Institute, Cinnaminson, NJ January 26th through 29th,1993,40 hours. Cardiopulmonary Resuscitation and Emergency Care for the Professional Rescuer; American Heart Association. August 1Ith,1993,4 hours. Hazardous Waste Operations and Emergency Response Refresher; Presented by National Asbestos and Environmental Training Institute, Ocean, NJ. November 18th,1993, 8 hours. J jl 13th Annual Northeastern Industrial Hygiene Conference and Exposition; Presented by New York l Section, American Industrial Hygiene Association, Princeton Marriott, Forrestal Village Princeton, NJ. December 3rd,1993, 8 hours. 1994 Lead Inspection, Assessment and Health Effects; Presented by Tyler Scientific Company, Tabernacle, NJ. January 1994,16 hours. Hazardous Waste Operations and Emergency Response Refresher; Presented by National Asbestos and Environmental Training Institute, Ocean, NJ. June 17th,1994, 8 hours. Cardiopulmonary Resuscitation and Emergency Care for the Professional Rescuer; American Heart Association. August 30th,1994,4 hours NJ Incident Command System; Presented by NJ Department ofLaw and Public Safety, Office of Emergency Management, Medford, NJ. October, 1994,16 hours. Air Pollution Control Systems for Manufacturing Processes, John A Bassano; New Jersey Section, American Industrial Hygiene Association, Edison, NJ. November 17th,1994,0.25 CM, I hour.

    .           .      ,                                                                                     l t

i J. Glass, CIH, CET Continuing Education Page 5 Maximizing Effectiveness of Medical Programs, Dr. John Dougherty, MD; New Jersey Section, American Industrial Hygiene Association, Edison, NJ November 17th,1994,0.25 CM, I hour. 14th Annual Northeastern Industrial Hygiene Conference and Exposition; Presented by Delaware Valley Section, American Industrial Hygiene Association, Princeton Marriott, Forrestal Village Princeton, NJ. December 2nd,1994,1 CM,8 hours. 1995 Educational Seminar; New Jersey Environmental Association, Central Section, Bridgewater, NJ. January 11th,1995,8 hours. Passive Air Sampling Monitors, Kim Chapman; New Jersey Section, American Industrial Hygiene Association, Edison, NJ. January 19th,1995, 0.3 CM, I hour. Photoionization Detection, Mary Ann Harasymiw; New Jersey Section, American Industrial Hygiene Association, Dover, NJ. February 16th,1995,0.3 CM, I hour. Managing a Process Safety Management Inspection, Neil P. Malvery; New Jersey Section, American Industrial Hygiene Association, Edison, NJ. March 16th,1995,0.3 CM, I hour. Hazardous Waste Operations and Emergency Response Refresher; Presented by National Asbestos and Environmental Training Institute, Ocean, NJ. April 7th,1995, 8 hours. Cardiopulmonary Resuscitation and Emergency Care for the Professional Rescuer; American Heart Association. August 17th,1995,4 hours AHERA/ Maryland Asbestos Project Designer; Presented by Environmental Training Institute, Cinnaminson, NJ. November 13th through 16th,1995,24 hours. Delaware State Asbestos Field Technician Refresher; Presented by Central Delaware Training Academy, Inc., Dover, DE. November 28th,1995, 8 hours.- 15th Annual Northeastern Industrial Hygiene Conference and Exposition; Presented by New Jersey Section, American Industrial Hygiene Association, Princeton Marriott, Forrestal Village Princeton, NJ. December 1st,1995,1 CM,8 hours.

i l { i J. Glass, CIH, CET

Continuing Education 1 Page 6

)

,      1996 5 Day Model New Jersey / EPA /HUD Lead Inspector / Risk Assessor; Presented by National Asbestos and Environmental Training Institute, Ocean, NJ. February,12th through 16th,1996,40 hours.

2 5 Day Model New Jersey / EPA /HUD Lead Supervisor; Presented by National Asbestos and Environmental Training Institute, Ocean, NJ. March 1Ith through 15th,1996,40 hours. i

Hazardous Waste Operations and Emergency Response Refresher; Presented by National ;

i Asbestos and Environmental Training Institute, Ocean, NJ. April 24th,1996, 8 hours. Measurement of Performance ofIH & Safety Programs; Colin J. Brigham, CIH, CSP, CPE; Delaware Valley American Industrial Hygiene Association, Doubletree Guest Suites, Philadelphia International Airport, Philadelphia, PA. April 16th,1996, I hour. Managing Safety and Health for Business Advantags, Christopher C. O' Leary, CIH, CSP; l Delaware Valley American Industrial Hygiene Association, Doubletree Guest Suites, Philadelphia . International Airport, Philadelphia, PA. April 16th,1996, I hour. i 56 Hour Model New Jersey / EPA /HUD Lead Project Planner / Designer; Presented by National 3 Asbestos and Environmental Training Institute, Ocean, NJ. Apri 29th through 30th,1996,16 hours. i i Hazardous Material Management, Comprehensive Review; Presented by New Jersey Insttute of Technology, Atlantic County Community College, Atlantic City, NJ. June 17th to 19th,1996,20 hours. Hazardous Waste Operations and Emergency Response Refresher; Presented by National Asbestos and Environmental Training Institute, Ocean, NJ. September 16th,1996,8 hours.

j U N I ,V E RSI T O F N O R - H D A K O TA ; 1 l l OCCUPATIONAL SAFETY AND ENVIRONMENTAL HEALTH OFFICE i ENVIRONMENTAL TRAINING INSTITUTE f P.O. BOX 9031 - GRAND FORKS. NORTH DAKOTA s8202-903 (701) 777 334 FAX (701) 777 4132 December 18,1996 e,xCD 4 W5 @,

                                                                                                              ,4 Mr. Greg Krause                                                                 y Environmental Engineer                                                         $     ^               %},

Y Radiation Control Program Division of Environmental Engineering G Ri:.G. i h,I g i EM -g 1200 M,ssoun i Avenue {4 + PO Box 5520 "#/ 4' Bismarck, ND 58506-5520 C3 l RE: Radiation Background of John Glass, Jr. for Approval to be Appointed as Radiation Safety Officer at the University of North Dakota

Dear Mr. Krause:

I would like to thank you for taking the time to speak with me today and provide your guidance in furthering this application process. I look forward to actually meeting you in person. Hopefully we can arrange this before the spring thaw! My radiation experience is primarily academic with a few projects which dealt with radioactive isotopes or radiation safety. The primary radiation safety course I have taken is a graduate course titled Isotope Methodology, this course was presented as part of a Masters degree in Environmental Health at Temple University in the Graduate School of Pharmacy. This course was 4 credits and entailed both lecture and Laboratory. The lecture dealt with nuclear theory including the methodology to monitor radioactive energy and its molecular origin. The laboratories included the use and calibration of geiger mueller tubes and liquid scintillation detectors. The most commonly used isotopes were "Tc, "C and 3H. A final research paper regarding the biological effects ofIsotopes ofIodine on the Thyroid and other organs was required. Specific project experience included the clearance oflaboratories for general use after previous radioactive experiments. This was done using a Victoreen Model 190 with a Pancake Probe. All laboratory surfaces, cabinets and drawers were monitored for contamination. Any reading in excess of 3 times background would need to be wipe tested to determine source of radioactive contamination. Another project involved collecting, taking inventory, and lab packing over 750,000 containers of hazardous material. Several of the laboratories worked with radioisotopes, which were included F: DTTA JACK RADIO IKiD UND is an equal opporturwty/amtmanve acnon insntunon

         -                   .      .            . _ -           _-.       . . . _ - . . . -    . = . -

1

I

  ,                  .         .                                                                                i
  ).

4 .

Mr. Greg Krause December 18,19%

Page 2 in the laboratory chemical management effort. These substances were monitored to determine ! total activity and disposed of or segregated until 10 halflives could be documented. A third project involved the decommissioning of an aerospace engineering / manufacturing facility l on the east coast. All equipment within the facility had to be determined to be free of hazard prior j to shipment. Often this required decontamination of the equipment prior to transport. j ' Although my experience in direct dealing with radioisotopes is limited, my experience in assuring l a safe and healthful workplace is extensive. The theory and techniques involved in radiation ! protection are familiar to me, and the laws and regulations are a ready resource for additional guidance. With the assistance of Jason Uhlir, UND's Hazardous Material Coordinator, and the members of the Radiation Safety committee, I have continuous access to seasoned veterans to consult with when unique situations arise. In order to continue my education in this, and all safety issues, I will be taking the UND Radiation Safety Course in Febmary, and am initiating a PhD l program which will undoubtedly address radiation protection in great detail. 1 I thank you in advance for your time and consideration. If you have any additional questions or concerns, please feel free to contact me at (701) 777-3341. Sincerely ours, l h John B. s, Jr., CIH, CSP, CHMM Director of Occupational Safety & Emironmental Health 1

JG:jbg CC: F: DATA JACK RADIO BGD l

[. [ \ NbRTH DAKOTA i I DEPARTMENT OF HEALTH L f,,* W / . . . . _ . _ , , , , , -- ENVIRONMENTAL HEALTH SECTION 1200 Missouri Avenue December 19, 1996 P.O. Box 5520 Bismarck North Dakota 58506-5520 Fax #701328-5200 l Mr. James Uhlir ) Director of Auxiliary Services l University of North Dakota l P.O. Box 9031 Grand Forks, ND 58202-9031

Dear Mr. Uhlir:

You have requested that John B. Glass, Jr. be named Radiation Safety Officer (RSO) on your license. It appears from the information submitted that Mr. Glass does not meet the training and experience requirements to be RSO for a Type A broad scope license. The description of the training and experience of your proposed RSO must address the full scope of uses of licensed material authorized under your license. Please describe, item by item, Mr. Glass' j practical radiation safety experience with each of the duties of the RSO which are described in your 1995 Radiation Safety Handbook, excerpted as follows:

                  "C.      Radiation Safety Officer Primary responsibility for radiation safety rests with the

, individuals utilizing radiation. The Radiation Safety Officer i has the responsibility of administering the radiation safety program. Consulting services on all aspects of radiation protection will be provided by the RSO to University faculty and staff. The RSO will assure that all activities involving radiation sources are conducted according to the policies and procedures established by the Committee and by all governmental regulations. The RSO has the authority to stop any operation which may endanger health or lead to serious contamination problems and to present promptly, details of the operation to the committee for final disposition. The RSO reports to the administration of the University through the Associate Vice-president for Business / Operations.

1. Duties Environmental Health Secten Environrnental Municipal Waste Water and Enforcement Engineenng Facilities Management ouality 701 328-5150 701 328-5188 701 328 5211 701 328-5166 701-328-5210 PrHed on rec}dedpaper.

Mr. Uhlir 2 Dsccmbar 19, 1996 it shall be the responsibility of the RSO to assure that the following items.are accomplished and proper records kept:

a. Calibration of survey and monitoring equipment.

b. Completion of radiation surveys in the vicinity of radioactive sources and radiation producing machines.

c. Completion of contamination control surveys at all ~

locations where radioisotopes are used or stored.

d. Leak testing of sealed sources of radioactive

material.

4 e. Inspection of facilities and equipment where a radioactive materials and machines are used. I

f. Review of all requisitions for the procurement of radioactive materials or radiation producing machines.

g. Management of the waste disposal service.

h. Coordinating a University-wide film badge service and maintaining personnel exposure records.

l i. Preparation of an annual. report for the Committee.

j. With the advice and approval of the Committee, preparation and maintenance of the Radiation Safety Handbook. l

k. Minutes of meetings of the Radiation Safety '

Committee. i

2. Training l

4 Periodically the RSO will arrange for training and orientation lectures for personnel on the proper procedures for the use of

Mr. Uhl.ir. 3 D: camber 19, 1996 s' radioactive materials. These lectures may be used to supplement on-the-job training or formal course work." i In addition to the above items also specify how Mr. Glass' training I and experience relate to the regulatory requirement to perform an annual radiation safety program review to ensure compliance with license conditions and rules and make a report of the findings to I management. Also state how Mr. Glasn' training -and experience address the requirements listed in the NRC's broad scope regulatory guide that was adopted for use by this Department. That document , offers specific guidance to ensure that an RSO candidate meets the regulatory requirements in 3 3 03 -05. 4.b (3 ) (b) that the RSO must be, " qualified by training and experience in radiation protection". Specifically the regulatory guide states that the RSO should have i considerable ,rofessional experience (generally about 5 years) with a broad spectrum of radioactive materials. The RSO's professional experience should include the application of this training to the management and administration of a radiation safety program related to the types, quantities, and uses of the radioactive material to be used under the license." I i Due to the severe time constraints currently faced by UND with the pending December 31, 1996 license expiration, please make every i effort to remain in contact with this Department as you address this issue. If you have any questions or concerns please contact Ken Wangler or Greg Krause of my staff at 701-328-5188. a ! Sincerely,

                  / f n           -

Dana K. Mount,-P.E. 4 Director, Division of Environmental Engineering DKM/GK:csv 4 s f

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12/2096 TI'E 11il'2 FAI' 701 777 4132 SAFETY @002

     ?         UN l' V $ 'R S I TY                     OF                        N O R T H            D A K O TA 4

December 23,1996 OCCUPATIONAL sAPETY AND ENVIRONMENTAL HEALTH OFFICE i Dana K. Mount, P.E. ENVlltONMENTAL TRAINING INSTITUTE Director, Division of Environmental Engineerin8 c,RANo roRKs. NORTH oAKOTE 5'81 - North Dakota State Department of Health (7en 777.ss4: 1200 Missouri Avenue, P.O. Box 5520 m7 u 777maz Bismarck, ND 58506-5520

Dear Mr. Mount:

We are in receipt ofyour letter concerning the application of the RSO for the University ofNorth Dakota. We appreciate your time in reviewing Mr. Glass' credentials and qualifications. The University agrees the RSO is a vital position within the University structure and deserves the utmost consideration and priority. Once again we have reviewed the specific duties and responsibilities of the RSO as listed in the University of North Dakota Radiation Handbook, section I-4, paragraph C. We have addressed l each of these individual duties separately and have provided some background as to the ability of i Mr. Glass to perform these duties: Number 1:

                +       Al        As a Certified Industrial Hygienist (CIH), Mr. Glass has used many different types l                                  of monitoring equipment. All types of monitoring equipment require some form of calibration. He has extensive experience in the calibration of all equipment in his

) field. Mr. Glass used a Technetium 99 Source to calibrate a survey meter in 1990, and therefore has experience in calibrating such equipment. Calibration of the , Universities radiation survey meters will be done with the same thoroughness and detail as all calibrations he performs. 9 Bi As ex-officio of the Radiation Safety and Hazardous Materials Committee, Mr. Glass will be present to review applications for radioactive sources and radiation i producing machines. The location in which these machines will be used has, and will continue to be, reviewed by the committee. As a representative of the committee, Mr. Glass will visit the site (s) in question and take proper measures to insure that radioactive doses to both the public and employees remain As Low As Reasonably Achievable (ALARA).

                +       fd        Mr. Glass has experience doing survey smear tests analyzed by liquid scintillation.

This experience was gained from the Pharmacutical Chemistry Department of Temple University. Contamination control surveys at the University ofNorth Dakota will be conducted in the manner in which they have previously proven

 ,                                themselves effective. Individual authorized users ofradioactive materials are 4

required to submit monthly survey smear reports to the RSO. These results are entered into a computer data base when received. For quality control purposes original hard copies of these documents are also kept in each authorized users file. t

    , g g . g g g g g g - --                                                , - - - - - - - -                            -

1 j ' i i . I l Mr. Dana Mount ! December 23,1996 Page 2 { The Safety Office staff will review and report to Mr. Glass any users who fail to i submit their monthly survey smear reports. Such users will be contacted immediately and directed to complete their surveys, and informed of the 3 importance of document submission in a timely fashion in accordance with their

user authorization and the North Dakota Radiological Health Rules. In addition,

! the Safety Office conducts contamination control surveys, unannounced, every six ! months. These surveys are conducted in all areas where radioactive materials are j used. (See attached memo dated 12-20-%) l

Di As previously mentioned, Mr. Glass has experience with contamination control and the use ofliquid scintillation. Leak testing and inventory ofsealed sources at the University of North Dakota will be conducted in the manner in which they have

{ previously proven themselves effective. Scaled sources will be inventoried every l three months, with a leak test being done every other time an inventory is done. } This will put the leak tests on a six month time schedule. The inventories and leak

l tests will be conducted by Safety OfEce staff and under the direction of Mr. Glass.

El Mr. Glass has been performing compliance audits dealing with worker protection j since 1987. He has read and reviewed the ND State Radiological Health Rules i and understands each of the requirements there-in. The inspections required under Section E of the handbook will be conducted with the same thoroughness and detail as his previous inspections, taking into account all rewirements of the ND

{ State Radiological Health rules previously mentioned. !

El UND has established a comprehensive tracking system for the purchase of all j radioactive material. This system is complete with redundant conformation of j existing user quantities, allowable user quantities, existing UND quantities and j allowable UND quantities. This data is maintained via hard copy signed records and a computerized database; all must coincide for a purchase to be approved.

Mr. Glass's background in office management, data interpretation and computer j database manipulation, make him uniquely qualified to oversee this requisition l process which has already proven itself to be effective. His graduate education in j isotope methodology has made him throughly familiar with the first order decay
equations, enabling him to determine current and fbture activity levels for any l isotope. UND is granted a broad scope radioactive materials license form the ND

[ State Department of Health. Individual users must submit an application to use i radioactive materials under the general license. These applications are reviewed by 1 the Radiation Safety and Hazardous Materials Committee and must be approved j by them prior to beginning the above mentioned purchase process. 1

G1 Being a Certified Hazardous Materials Manager (CHMM), Mr. Glass is uniquely

} qualified to oversee all of UND's waste streams, including medical and radioactive J l

    . 12/24/98 TI'E 11:13 FAI 701777 4132                    SAFETY                                              004 a    ,

Mr. Dana Mount December 23,1996 Page 3 wastes. As with all other wastes, radioactive waste is collected by trained technicians and tracked using state of the art computer information. For quality assurance purposes, signed original documents are maintained in our waste management files for conformation as to the odgin, content, activity and possible contamination ofeach waste item.

Hi As a CIH and Certified Safety Professional (CSP), Mr. Glass has been monitoring personnel exposures for many years. His philosophies and practices have been shown to maintain accurate dosimetry information and assured a safe and healthful working atmosphere. The University has a long standing contract with Landauer laboratories to analyze all of our radiation personnel exposure film badges. His experience in dealing with hundreds of subcontracted analytical labs leaves him well versed in the intricacies of managing an effective service agreement. The data obtained from Landauer is analyzed by Mr. Glass and the entire Radiation Safety Committee prior to placing the information in it's permanent file, which is available to all users and technicians. In addition, this information is delivered to each authorized user with their film badge (s) each month. In addlition, the UND has begun receiving year end exposure reports from Landauer. The above mentioned report is enclosed for your review.
It This report is compiled for the safety Office as a whole and given to the President at the end of our fiscal year, June 30th. l
h The Radiation Safety Handbook has been revised periodically to update changes in the ND State Radiological Health rules.
K: The minutes of each Radiation Safety Committee are maintained at the Safety Office. They are approved by the committee at the following meeting, along with any corrections committee members may have.

Number 2:

Lainingt As a Certified Environmental Trainer (CET), Mr. Glass has provided numerous different types of training seminars and workshops. If situations arise such that he '

does not posses the technical knowledge necessary to provide training, a private consultant will be hired to provide the needed technical expertise until such time that Mr. Glass, or another UND employee, acquires the level of technical expertise deemed necessary by the NDSDH. .I

12/24/96 TI'E 11;,,14 FAI 701 777 4132 -.-SAFEIT -- Q)o05 [- . . i-Mr. Dana Mount December 23,1996 l Page 4 1

It is the University's belief that the Radiation Safety Officer position is ptimarily a management effort, with the technical expertise lying on the individual radioactive user. Mr. Glass's j managerial background, health and safety expertise and familiarity with radiological data, make j him an excellent candidate for this position. In keeping with the direction and comments of NDSDH, we will continue to emphasize the importance of technical ability. We will provide the utmost suppon for significant radiological training for Mr. Glass and our support staff.

It is our hope that the North Dakota State Department ofHealth will review and consider the information submitted here and will allow us a temporary extension until such time as Mr. Glass' credentials can be fully documentated by NDSDH and, if necessary, the Department of Energy. incerely, A Mr. Uhlir Director of Auxiliary Services JEU /nch enclosures cc: UND President Kendall Baker Al Hoffarth, Vice President, Operations File I e - ,-, --,, n--

_ 12/24/96. TL'E 11:14 FAI 701977 4132 SAFETY @ 006 U N I V E'AS ITY O F NO R TH O A K O TA OCCUPATloNAL 5AFETY AND ENVIRONMENTAL HEALTH OFFICE ENvlRONMENTAL TRAININo INSTITUTE P.O. BOX 9031 CAAND 10RKs. NORTH DAKOTA 58102 9031 (701)777 s341 FAX (701) 777 4132 i MEMORANDUM i TO: Tammy Torgerson ) Clerk Admin' t stive i i FROM: Jack Glass Safety Dir r DATE: Decembe/20,1996 SUBIECT: Monthly Wipe & Smear Reports ,

l Please provide me with a report by the 5th day of each month for our current radioactive users / researchers who are completing the Survey & Smear Data Report Form. Also, indicate any who have not supplied us with this report. The purpose in this action is to monitor and tract all research labs for proper handling of radioactive materials. 1 i l 1 l

OCCUPATIONAL. EXPOSURE RECORD FOR A MOMTORMG PERIOD Prepared by .- cn This form is for use in place of certain reports required by NRC t licensees, OSHA and state regulations. It reflects data provided E to or by yow accomt and contains information for NRC Form 5 avid other equivalent forms. { { * { ACCOUNT WURIBES SE9EE Curif PARTICFAkt IRaeft 37558 AKR 88720 w.., i . 2sa. a ci.,,%,i.,,,m, 23im . 3 Telephone: Doel 73J-7000 Paesesnile: Deel 755-7016 4

5. DeatAE S A5T, flRST. Meelt sueltM) 2. NEWIiTEA10(pt IstmentE 3. El itPt 4. III 5. BATE Of BitTB *r!

RUIT KEN 135-48-5987 SSN K] ==i --l n u 05/01/61 y e,tKtast useestat18 ** "'

e. isesstomuus PERE 00 7. LKlestE assasE X attnMa X noerur U 04/15/9El - 01/f4/97 UNIV 0F N DAKOTA ,,,,,,,, ,3, ,

B8A. BASWEBCUBE 100 As leC. h00DE 100 INIAEE lu PCI DEEP DOSE EQUIVALENT B00 ND EYE DOSE E0t!! VALENT TS THE LENS OF THE EYE lLDO ND SHALLOW DOSE [GUIVALENT, WHulE BODY 15K, wm ND

SHALLOW DOSE EQUIVALENT, MAX EXTREWIY h ) (SDE. MEl ue 1 -f l

(cEDEl i . COMMTTE0 EFfECTNE D0$E EQUIVALENE r-- c0MMTTED DOSE EQUtVALENT. g p MANIMALLY EXPOSE 0 GRGAN TOTAL EFFECTIVE DOSE EQUWALENT 17.

                              ,Q                                      p                                                                                                                                                                                                                                         ND (BLOCKS 11 + 15) (TEDE) f yp g

TOTAL ORGAN DOSE EQUIVALENT, M AX ORGAN (st0CKS ff

f6) (TODE) i t.

g 3 ~ """" PERMANENT TO DATE ( IN REM)

'((

q 4 b8 U

3 j DDE LDE SDE,WB: SDE,ME: ND ND ND l TEDE : ND 25,1sLIIAfsRt - t a[th5ti SAft SIMIfD 2 4. G Aft PR[PARfD g.Jy f

FORMS A NI L 1 1 1F INCEPTION DATE: 04/15/96 ONLY PAGE 1 8,

_ - - - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - __ ~

Accredited by the National Institute of Standards and Technology through I (This report may Contain data from dosimeters not subject to NVLAP accreditation. Call for details.)

;            I                                                                                                                                                                                                                                                                                      *

! PAfVACY ACT STATEMENT NOT3CE TO WORKERS s A C.' Thle repast is fuseished to rees andes eene psawlsione of one er enese of Stes a CO Purseant TO S U.S.C. StaatellM, enested inte law by Sectlen 3 et the Pelvecy C Aes of 1974 Puenfle Low 93 4 711 she following stecernent is fuseished to felpoweny roses and segerseises, you acenetd geeeerve this repost for fuesenes ladivlaksels who supply Inforseea6en to the U.S. leeclear Stegesetesy Cesnsmissies refesernce. Heteranced suses med regutselens lnctisde, hue are not sostwicted es: een NRC Forma 5 This talossmation la sta6neessed in a systeem et receeds des 6gmesed as MAC 17 and descrie>ed me 55 Fedese8 Register 33*84 (August 20, Nucleas Regutesery Correaission segelseien, 10 CFIt Part IS 19906, os the esost recent Federet fieg6 ster pamp4Lceeben of the Nuclear Regulatory q Commission's ~9epubliemeles of Systeses of Reseres Notices" that le available et Alaan- Chapees 42e-2 28, Rodnetien Centeel, flees 420 2-28.10 o the seRC Pubtie Doceanene Heesrg Gelman Sullding. Leaver Level, 2124 L Stsoet Ashenses Deparement of Hesteh flegulatlene see6tled "Stemderds los Protectlen ea NW, Washinglos( D.C. Agelnse Radletiert" Cemes.ie S.ete Depas-t e, Nee. n Seswice. negadecie.s; s.en ,de f.e t

t. AUTidOftlTY: seetiens 53, 63. 86. S t.103,104, tattit, and 16ttal Protection Against Rediatlass .a; et she Atoanic Energy Act of 1964 es essended (42 U.S.C. 2073, 2993, Colorado Aeles med Aegulee6ees Parteleing to hadteilen Control, Past to 2095, 2 II1. 2 333. 2134. 22eltst. and 230 lin2. The authos6ty for flesiste Department ed Health and Itehstriliteeive Services sogaleonen entitled Chapter gf seticiting the seclel securley enerwbos is to CFR Pese 29. 100-9 8, Centret of Radieteen 94steedt . g,,

Geespie Rule 331 4 7.e7 ee ;

2. PEllO0CtP AL PURPOSES- The ledereneesen is used by the PtitC in les litanois Depastament of feuclear Safety Aegulatines fas Radiatloc Protectiesa (37 IL evaluaties of the sisk of sediatiesa empenere associated week she Elconsed Adren. Code 4000 {

ectivity used Asi essescistng les stoestery sospensibility to onenlear one inwa Depastseems of Pet >Ile 04eelth's Rute S4 8 40.28 Il3eC3 regulate the safety and heetth psecticoe of its licensees. The data permles atenses Astomististsesive Aute and Repuhellen 28-3C-334 e ameaningeet em==lsen of besen current end long-seven esposaae Reseechy Cateisnet for lesman Assesuces' sedletten regefeeices esperience among eypes of tieansees and among licensees within each toulstene Radiation Protectlen Aegelesions, L AC 33 XV. Chapees to i type, Data on yone espesure to sadlaelen is evellebte to you upea yous Maine Deparemset of thasnan Seew6ces Aegulations fee the Central of medletians Past J (A s ectees t. Mississippi State Board of Heelsh Regulations los Centret of Radiasiers, SecIlan J $;

3. ROutlNC USEISL The inforsenecien essey be essed to psewide deem to other Hebraske stegulatiees los Castros of Sadedies - tenia ^mnq Section Ste gr i Weevadal NAC e59.700 to 459.794 e-f ederal and State egencies loweeved in anonitesing andses eveteating redsation esposene received by isodavidents esopeoyed as radiassen vocekers New RAemico Aediatsen Protecties Regulations, Past 10 '". ;

on a possemeneet er temperary basis and esposure received try senadtered Deew Veebl Part 18. New Vosk $0ete Sanitasy Code andfas Past 38 f12 NYCRR 38) wisseces. The isidossumation may else be disetosed to an appropriate Fedeset, esedler Seceden 175.64 sf the NY Clay Ofeelsh Code State, es Becal ageecy in the evees gene information inestcases a wiegation os feenth Carotine Section ISA seCAC I 4.3000; NOTICES, toestfluCYtONS, , poteseeial violation of low and in the course es en administrattwo es l=dicial IIIEPORTS AesD INSPECTIO80$ proceeding. 90erth Daheta State Redeelegical fleellin Potos 9dorgh Dakoes Arhem5ggggg[yg Code chapees 33-e0-ID6

4. WHCTHER DeSCLOStsRF IS M A8eDATORY Oft VOLUNY ARY Aldo IFFECT Rhode tseend Rules and flegulations for the Comesel of And!stiest shamr==t A.8 i ON INDIVIDUAL Of NOT PftOVtOING INFORM AT4008: le is weluntasy that Souah Caroline Departseems of >teellh med Enwisonmented Centrol's fledacties Centrol you feweists the resquested leforetellast tecluding necial secterHy vesseher; Regulaelens ;

howeves. the 86censee seuse coseptete NRC Fesee 5 en each ladlwidual 8er Tomas Regulatises f as Centret of stadiatloe, Port 22 ! whom possemeel neonitoriseg le rosysised sender 10 CFR 29.2198. Fedtsere to Utses Administrative Code Section 51383-18 33 de se sney subject the liceesee to enfescasnent ocelese 4rs acceedence with Waeoningsen State Deportensas af Neatest, Division of Aediation Prefectiers flastes and ' 10 CFR 29.1403. The sected sectardly numbee le essed to essess that feRC Hoguincipes for Radiation Psetection has era occurate 6dee46fies met setsject to tene selnc6desace al siseniles mennes ce bleetsdates among the large ousnber of peseens en menom data is ! mainteneed. mder te camp 4y wbtIn NRC segalee6cas. Landunes now substHules M W

5. SYSTENI htANAGERfSI AND ADORES $; d*'**'*"'*0#*' ""# " ** ** '9"I 'd **O '** U '"**'d "* ;

REIRS Project meanager sendesseoed thof M esfers te chose dose agedwaleats'below the seistmassa { Office of Nucleme Rege(story itessesch seposambem steentity for a given dosisneter and itsee peries, and steen mot eneae t - , d.s. we. riot .o.ected. U.S N,,ucleas W e ,, ,,,,e,

                                      ,Regu,lat,o,r,y c g            Cosnmission LAND /UER                                                                                                                                                                                 -

n m . s, -, tw is.t 2 we s.se e ned r,h.se-ed. mie.as ho425-e n mcphone: ne88 tss-7eco rhas.sla: ness m-wis .

                                        @ 88        SAITIT
                                                                                                     @ 009 landauer                               9/24/96 Last Name           First Name       Contact Title ACHEN               VIRGINIA           RAD - 88717 ADKJNS             ISTEVE              PHS -00345 i

BALLANTINE .T A_ CH - 00135 BEAULIEU INICHOLAS RSO - 88722 BENEDICT ICINDY PHL - 88708 BIANCO BOB SBC - 88696 BLAKE W CHAEL PHB - 88620 l BO- XU PHE - 00374 BODE IANN PHS - 00233

                            .BOESHANS          KAREN                SBC - 88677
                            !_BORG             !KURT                PKB - 88703
                            ;BREKKE            DAVID               -ERC - 00042 BUCKLEY            IARTHUR             PHM - 88613 BUCKLEY            DONNA               -PHM - 88617 CAMERON            k'RAIG              AKR - 88728 CARLSON-DIETZ     lANN                 PHH - 88678 CHEN              lYAN                 <PHK - 88653 CLARK              JAN               _I SBI - 00372 CULTICE            TERRY               ERC -88669 DAVIDS             CHRISTINA           GEO - 88690 DENOME             ROGER               DBI - 00360 DENOME             SYLVIA             lYMB - 00298 DOLL              MARK                 PHH - 00342 ELDER             IJOHN JR.            HBI - 00375 ELF               !PAMKT A             YMB - 88633 ENIT.MINGER       R                    ERC - 00308 EPSit1N           PAUL                 PHE     88625 PENG               NI                  PHO - 88643 FIVIZZANI          A                   lAKR - 00023 -

FLOWER ANN FLW - 88714 TOERS7ER ' CURT ERC - 88609 FORSMAN N GEO - 00045 FOSTER HENRY ERC -00287 lFOSItx JAMIE NBC - 88607 IFRETLAND ADRIAN PHH - 88699 i

                           .GAN              DAI-DI                HIL - 88711 tGERLA             @lm1 TP               GEO - 00275 GOEBEL            IDEAN                ERC - 88594 GOLUBOUVSKAYA     MA                   SBI - 88645 GOSCHEN            ALICE               SH - 00002 GREEN              EDITH               PHS - 00377 GROHS             KEN                  ERC - 88670 I                      -   ;GUSTAFSON         'AROL C                    KBC - 88719
                                                  =      -

     *12/24/96 TUE 11:16 FAI 701 777 4132        SAFETY                                      @olo landauer                             9/24/96
   ,                           Last Name  I        First Name      Contact Title
                        ' HALL             REBECCA               FLW - 88715 HASS              BRIAN               lSBC -88729 HATCHER           EMIKO               PHG - 00355 HENDERSON         TOM                 'HIL -00240                           {

HERMANSEN RATEAN MBC - 88673 ! HILL TOM HIL - 88710 I HOFFMAN SCOTT SMB - 00362 s HOLDER BOBBY GEO - 88691 HUANG BING-OUAN SBI - 88647 ' l HUBBARD ITRENT kiEO - 88692 l l HUGHES ' OLIN C MBI -00348 l HULI. A JANISE PHL - 88705 l ! JIANG IWEN PHH - 88667 l l JOHNSON KYAN RSO - 88709 i KAPPHAHN hfARK ISBC -00351 l KATRINAK KARIN ERC 88652 i KAY IJOHN ERC -88651 ,

KRAllK PATRICIA PHE 88684 KRUMENACKER IJOSHUA PHM - 88701 l l LADUKE l JOHN LBI - 00329 l LARSON lERIK HBI - 88731 i

LAVOI bC.ATHLEEN WHB - 00344___ l LECHNER D ERC - 00047 l LEFF MATTHEW IPHH - 00379 i LIANG CIANGRONG PHE - 88675 l LYKKEN 'G THY - 00059 l MAYER iGALE ERC - 88610 MELLAND IREBECCA @IBI - 88648 I MILAVETZ BARRY NfBC - 00198 l ,, MOEN !RJ -

                                                                 >HB - 88681 i                         MORGAN           @ILL                   FLW - 88727 l                         MUHOHEN          lWALLACE                SBC - 88635 j                         MURPHY           iTONYA                  PHS - 00343 2

NGUYEN HUGH @HL - 88693 k NILLES lANDREW $IIL - 88713 l NORDLIE R 'NBC - 00016 i 01CEEFE iC ERC - 88626 3 OLSON lAMY RSO - 88723 i PALMER (ROGER CH - 88697 PALMISCNO L lSH - 00001 i PATRICK __ DALE 1 5 0 - 00202

.                        PERRY              CHERYLL              kAD 00349 j                         PERRYMAN          IWENDY                lAKR - 88721 _

3 l

      . .                              landauer                                      9/24/96 i          .   . .

{( l Last Name First Name Contact Th RADA JODY RAD 88716 l REINTIZ CATHRYN SBC - 88674 - I REMME CHRIS RSO - 88694 RESCH ZACK PHS - 88725 RODRIGUEZ 4 SAM PHL - 88707 RUIT KEN AKR - 88720 iRUSTAN UMOTHY PHL - 88706 l 'SACHS JOEL HBI - 88732

SAMSON Wtr in PHS - 00347

! :SHABB JOHN SBC -00352 j SHERIDAN WILLIAM SBI - 00371

                'SHLANNA           KEVIN               '

SMB - 88718

ISLOVR MICHET T F RAD - 88726 i ;SOLC JAORSLAV ERC - 88612

{ ISPANIER JONATHAN SMB - 00331 i : SPARE : BIO -00091 ! ISPARE ERC - 00110

                ! SPARE                                 ERC - 00111 i                ' SPARE                                 ERC - 00158 j                ! SPARE                                  ERC -00161 ISPARE                                   HBI - 88662                            '

i, ! SPARE PHS -00251 l . iSPARE PHS - 00258 1 i

                ' SPARE                                  RSO - 00060                             :

l SPARE RSO - 00061 l

!STAHL LOTWAR CH 88680 j i UHERKA KARA PHS - 88704 -

l UHLIR JASON RSO - 00332 i VALJAVEC-GRATIAN M HIL - 88724 , l VARGAS TRINI PHS - 88698 l l VETHANAYAGAM JOE PHS - 88689 I VOLKER WARREN KBC - 88702

WENGER JONATHAN LBI - 88687 j WESLEY TRACY kSO - 88712

. iWESTERMAN DG ERC - 00311 l WILKERSON NEAL CH - 00357 3 YIN XIANHUA PHE - 88654 ~

YOUNG KEVIN YMB - 88730 j ZHANG MINGYU PHG - 88672 I

i 4 4 i}}

ML20133G750

Contents

Text

Dear Mr. Mount:

Enclosures:

Dear Mr. Mount:

Enclosures:

Contact:

Dear Mr. Bangart:

Dear Mr. Bangart:

Dear Mr. Uhlir:

Dear Dr. Baltisberger:

Dear Mr. Wangler:

Dear Mr. Krause:

Dear Mr. Uhlir:

Dear Mr. Mount:

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ML20133G750

Text

Dear Mr. Mount:

Enclosures:

Dear Mr. Mount:

Enclosures:

Contact:

Dear Mr. Bangart:

Dear Mr. Bangart:

Dear Mr. Uhlir:

Dear Dr. Baltisberger:

Dear Mr. Wangler:

Dear Mr. Krause:

Dear Mr. Uhlir:

Dear Mr. Mount:

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