RPPM 4.0 Auth to Use + Acquire Rad

4.1 Application to be an Authorized User of Ionizing Radiation

Faculty and staff may apply to be an Authorized User
Individuals who hold a permanent position at the University and who are appropriately trained and experienced in the use of radiation may apply to become an Authorized User under the authority of the University.
The Authorization process is initiated by the applicant upon the submission of a completed radiation use Authorization application (see RPPM 10A and 10E).
The RSO will pre-review the application and may contact the applicant for additional information or clarifications prior to the application being scheduled for Radiation Safety Committee (RSC) review and approval.

RSC review and approval of Authorization applications
An Authorization application (see RSO Forms) must include accurate and complete information describing the proposed use of radiation and showing that the proposed use meets the criteria for an Authorization under the University’s RPP.
The RSC will evaluate all information provided in the application, including:
The applicant’s relevant training and experience relative to the proposed use(s) of radiation described in the application. Acceptable training and experience includes, but are not limited to:
Principles and practices of radiation protection and safety applicable to the requested use (radionuclide or radiation machine) and all procedures associated with the use or proposed project;
Applicable radiation measurement techniques and instruments;
Radiobiological effects and risks, in general and specifically associated with the proposed use(s) of radiation.
Types and quantities of sources of radiation requested to be held and used under the authorization (i.e. – radionuclides or radiation machines);
The proposed use(s) of those sources of radiation;
All safety protocols and equipment the applicant will put in place to assure adherence to ALARA and the safety of workers, the general public and the environment;
The availability of radiation protection instruments specifically maintained to assure safety and compliance;
The suitability of the facilities the applicant proposes to use to store and use during the use of sources of radiation;
The estimated types and amounts of radioactive waste that may be generated under the Authorization.
Following a review and discussion of the contents of each application, the RSC will vote on approval of the application or provide the URSO with a directive for pursuing further clarification(s) or a modification of the proposed radiation use.
The RSC will review all on-going active Authorizations on a routine basis, including:
Amendment application reviews that are required for any proposed modification to:
The sources of radiation to be held in inventory (types and possession limits);
The previously approved type of use or when there are proposed major modifications in experimental design;
Frequency of use or quantity used per month +/or year;
Safety protocols or a reduction in the availability of safety equipment;
Facilities, such as remodeling or relocation that could impair safety;
Radioactive waste generation with a resulting increase in the amount or hazard(s) associated with the wastes.
An every 5 year RSC full review and renewal interval for all Authorizations
The RSC retains the right to suspend or formally terminate an active or inactive Authorization due to, but not limited to:
Willful disregard for safety or compliance to the policies of the University regarding radiation use and safety or the University’s Radiation Protection Program;
An Authorized User non-response or compliance to a directive of the URSO or RSC when the directive is associated with a known breach of personal or public safety;
A prolonged absence of an AU from their approved radiation use area(s) or a lack of appropriate and required supervision of the radiation workers listed on the Authorization.

4.2 Maintenance of a Radiation Use Authorization

Upon approval of an Authorization application, the URSO will contact the applicant and issue an Authorization cover sheet that will specify the conditions of the Authorization. The most current Authorization Cover sheet should be posted in the approved radiation use area.

All Authorizations must be:
Amended through the submission of an Authorization Amendment application prior to the implementation of any major change or modification;
Renewed on a five year basis by the submission and RSC review of an Authorization Renewal Application;
Formally deactivated (terminated) by the AU, working with the RSO, to decommission or transfer of responsibility of all restricted areas when the AU no longer needs the Authorization or the use of radiation approved under the Authorization (i.e. – use has ceased for an extended period of time) (see RPPM 10A).

The Authorized User (AU) is responsible for:
Inventory, control and security of all sources of radiation held by the Authorization;
Maintaining restriction to access and safety of all radiation use equipment and facilities;
Providing proper personal protective equipment, training and supervision to radiation workers working under the Authorization;
The proper handling and disposal of radioactive materials and wastes generated under the Authorization;
Maintaining compliance to all University policies and radiological license conditions;
Assuring the proper completion, maintenance and retention of all required records.
Submitting an Authorization Amendment application prior to making any substantial modifications to their radiation use(s) including:
Accepting an in-coming transfer to a source of radiation;
Changing the experimental design or type of use of materials or radiation sources already approved under the Authorization;
Initiating a process that will create “mixed waste” that was not approved under a current Authorization.
Introducing a new hazard (i.e. – ignitability; non-radiological toxicity; volatility) that was not originally identified at the time of review of an approved Authorization.
Submitting timely and complete Authorization renewal applications prior to the expiration of an on-going Authorization;
Maintaining control of all radiation sources and use facilities and equipment until the facility or equipment has been transferred to another qualified AU or properly decommissioned and free-released by the RSO.

4.3 Acquisition of Sources of Radiation through Purchase or In-coming Transfer

All acquisitions of sources of radiation must be pre-approved by the RSO and tracked from their receipt through to their disposal or transfer to another suitably licensed entity.

Purchases of Radioactive Materials from a Commercial Supplier
The University purchasing office accepts only field orders (F-orders) and blanket orders for the purchase of radioactive materials (see RPPM 10.A).

NOTE: Purchasing cards may not to be used to order or pay for radioactive materials.

The minimum Information required for an order involving Radioactive Materials includes:
Radionuclide name and chemical form;
Quantity (i.e. – mlligrams, ml, etc.) and activity (mCi/gram);
Authorized User (specified as the technical contact on the Departmental Requisition);
Contact information for the vendor and shipper.
Routine, repetitive orders of the same material during the course of a year may be accomplished through the University Purchasing Office using either repetitive F-orders or via an annual blanket order;
Annual Blanket Orders are issued by the purchasing office for radioactive materials users who routinely purchase specific radionuclides repetitively from the same vendor(s).
Initial and annually-renewed blanket purchase orders are reviewed and must be pre-approved by the Radiation Safety Office.

Guidance concerning the acquisition of approved radiation sources is provided for Authorized Users, radiation workers and supporting department office personnel in RPPM 3.4.2 and 10A, 10B, 10C.
The acquisition process includes the following steps:
Preparation and electronic submission to the RSO of an e-copy of a completed:
Purchase requisition form (BPPM 70.1 and RPPM 10.A);
Blanket order (BPPM 70.1 and RPPM 10.A);
Internal or external transfer request form (RPPM 10.E);
The submission via a MyResearch/Compliance/RSO of a web-based acquisition request made through the Authorization’s records system access privelage.
The legal record of the acquisition is tracked by either a web-based submission (via a “SUBMIT” button) or submission of a form as an email attachment on an email sent from the AU’s University email account or supporting departments business office email account;
All acquisition request forms must be pre-approved by the RSO and will be returned, with the RSO approval and date of approval indicated, to the University email address from which the request originated;
Prior to approving any acquisition, the RSO will assure:
The Authorization is properly approved for the specific radionuclide(s) or machine;
The Authorization is current and in good-standing;
All information required for RAM acquisition and tracking purposes is available;
The commercial provider or originator of the transfer is properly licensed and able to ship or transfer the material to the listed University address in a compliant manner.
The delivery instructions on all orders or transfers arriving on the Pullman campus must designate the Radiation Safety Office as the consignee and University Central Receiving as the delivery address for the receipt of the shipment.

NOTE: Departments or AUs should contact the RSO to verify delivery instructions when radioactive materials are being shipped to a non-Pullman campus alternate location.

All in-coming shipments or courier deliveries of packages containing radioactive materials must be scheduled for, and may only be accepted, during normal business hours by properly trained (DOT Hazardous Materials Shipper’s training) at a campus Central Receiving location.

NOTE: Any needed alternate delivery arrangement must be pre-approved by the RSO and may require the concurrent approval of University Public Safety.

At no time should a University worker or student who is not appropriately trained and pre-approved by the RSO for the function accept a package containing radioactive material.

Acceptance of Transfers of Radioactive Material
Internal transfers (Authorization to Authorization, or Reactor to Authorization)
Any internal transfer of radioactive material must be pre-approved and coordinated by the RSO, and documented and tracked in the RSO inventory database;
A Transfer Request form (RPPM 10.E) must be submitted to the RSO electronically and pre-approved before any material transfer takes place (administratively and physical location and control);
The recipient Authorization must be pre-approved by the RSC for the radionuclide and quantity/activity of material being transferred.
Transfers from another Licensee (NRC-licensee; State licensee; Federal lab, etc.)
All transfers from outside entities or donors (non-University) must be pre-approved by the RSO;
An AU planning to accept a transfer from a non-WSU individual or entity should call the RSO to discuss the transfer well in advance of the planned date of the transfer;
A completed Transfer Request form must be submitted (RPPM 10.E, RSO Forms) to formally provide the RSO with a written notice of the planned transfer/receipt and provide the required detailed information, including:
The individual initiating the transfer (donor) and their contact information;
The licensee (University, Federal lab, DOE, etc.) from whom the transfer will be initiated and the address where the package will be originating;

NOTE: The University cannot accept in-coming radioactive material transfer if the sender’s licensing is not correct and/or cannot be documented.

The person or entity initiating the shipment must be qualified to prepare shipping documents, package and ship the material in compliance with current DOT regulations;
The delivery address must specify receipt at a University Central Receiving facility or an work day location maintained by the RSO;
The RSO will verify that all compliance requirements will be met prior to authorizing the shipment and receipt of the material;
The RSO will notify the AU of the approval (or disapproval) of the transfer via an email from the RSO (wsu.edu) sent to the University email account of the AU, or a designee (radiation worker) listed on the Authorization.

Acceptance of a Transfer of Equipment Containing a Sealed Source
No equipment that contains a manufacturer-installed sealed source is to be acquired (by purchase, transfer or acceptance of a donation) without pre-approval of the RSO.
The University is not allowed or licensed to accept an item a regulatory agency would consider a depleted source or a recalled device.

NOTE: Both licensed entities and non-licensed “donors” may try to voluntarily transfer such equipment to another licensee as a means of waste disposal.

University staff should consult with the RSO Sealed Source program coordinator whenever considering acceptance of used equipment that contains a sealed source, even those acquired by private donors because the device was originally generally-licensed for distribution by a commercial provider.
All sealed sources arriving at a University location and that are to be held under the University Broadscope license must be tracked in the RSO tracking inventory as part of the University’s radioactive materials inventory.
All purchased or incoming transfers of sealed sources must arrive with documentation of an acceptable leak test or must be leak tested by the RSO upon their arrival and prior to any use.

Acquisition of a Radiation-Generating Machine
The RSO must be pre-notified of any planned purchase or transfer (internal or from a non-University source) of equipment that is capable of generating ionizing radiation (see RPPM Chapter 6 and D);
The RSO and/or RSC must pre-authorize the acquisition or fabrication of a radiation-generating machine that is to be housed and used under the authority of the University;
Departments or AUs must pre-notify the RSO of any planned acquisitions well in advance by contacting the Radiation Machines Program coordinator (wsu.edu) to avoid unnecessary delays in:
Pre-approval to receive or accept a radiation-generating machine;
Installation of a machine at a University location that may require licensing of the site as a use location through the WA DOH Office of Radiation Protection;
No machine is to be operated at a University location before:
The equipment has been listed on an RSC-approved Authorization;
The AU has been notified by the RSO that the machine is appropriately registered with the WA DOH and Department of Licensing.