GPR 1860.1.pdf

DIRECTIVE NO. GPR 1860.1D APPROVED BY Signature: Original Signed By

EFFECTIVE DATE: January 5, 2017 NAME: Richard D. Barney

EXPIRATION DATE: January 5, 2022 TITLE: Director, Safety and Mission Assurance

CHECK THE GSFC DIRECTIVES MANAGEMENT SYSTEM AT

http://gdms.gsfc.nasa.gov TO VERIFY THAT THIS IS THE CORRECT VERSION PRIOR TO USE.

08/16

Goddard Procedural Requirements (GPR)

COMPLIANCE IS MANDATORY

Responsible Office: 360/ Safety Division

Title: Ionizing Radiation Protection

TABLE OF CONTENTS

1.0 GSFC RADIATION SAFETY PROGRAM

1.1 Introduction

1.2 Radiation Safety Organizational Chart

1.3 Radiation Safety Responsibilities

1.3.1 Management

1.3.2 Safety Division

1.3.3 Ionizing Radiation Safety Committee (IRSC)

1.3.4 Radiation Safety Officer (RSO)

1.3.5 Radiation Protection Program Support Staff

1.3.6 Custodians

1.3.7 Approved Users

1.4 Nuclear Regulatory Commission (NRC)

1.5 Categories of Sources

2.0 IONIZING RADIATION AUTHORIZATION

2.1 Obtaining Authorization to be an Approved User and/or Custodian of Ionizing Radiation Sources or Devices

2.2 Personnel Training Requirements

2.3 Personnel Experience Requirements

2.3.1 Supervision of Inexperienced Radiation Workers

2.4 Obtaining Authorization to use Ionizing Radiation Sources or Devices

2.5 Facilities Evaluation

2.6 Inspection and Inventory Requirements

2.7 Obtaining Approval to Purchase Ionizing Radiation Sources or Devices

2.8 Amendments to Authorizations

2.9 Record Keeping

2.10 Inactive Status

2.11 Approval for Onsite Movement of Sources

2.12 Approval for Use of a Source Offsite

3.0 RADIATION PROTECTION PRINCIPLES

3.1 Exposure

3.2 Time

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DIRECTIVE NO. GPR 1860.1D Page 2 of 51

EFFECTIVE DATE: January 5, 2017

EXPIRATION DATE: January 5, 2022

3.3 Distance

3.4 Shielding

3.5 Internal Exposure

3.6 Fundamental objectives of radiation protection measures

3.7 Radiation Safety Rules

4.0 RADIATION SAFETY OPERATING PROCEDURES

4.1 Written Procedures

4.2 Use of Sources in Launch Operations or Other Offsite Functions

4.2.1 Radioactive Materials Launch List

4.2.2 Approval for Launch Operations

4.3 Environmental Testing Certification (Thermal-Vacuum)

5.0 ACQUISITION OF RADIATION SOURCES OR DEVICES

5.1 Purchasing Radioactive Materials or Ionizing Radiation Devices

5.2 Radiation Protection Office (RPO) Review

5.3 Receipt and Delivery of Radioactive Orders

6.0 RADIOACTIVE MATERIAL INVENTORY

6.1 Inventory of Devices

6.2 Inspection and Inventory Requirements

6.3 Sealed Source Leak Tests and Inventories

7.0 RADIATION CONTROL PROCEDURES

7.1 Radioactive Source Use – Sign out Log

7.2 Facility Radiation Safety Equipment

7.3 Calibration of Survey Instruments

7.4 Radiation Levels

7.5 Radiation Protection Office (RPO) Surveys

7.5.1 Meter and Contamination Surveys

7.5.2 Testing for Contamination

7.5.3 Leakage/Contamination Levels for Sealed Sources

7.6 Removal or Transfer of Laboratory Equipment

7.7 Acceptable Surface Contamination Levels for Uncontrolled Release of Equipment

7.8 Vacating Laboratory Spaces

7.9 New Laboratory Setup

7.10 Posting and Labeling

7.10.1 Labels for Radiation Sources and/or their Containers

7.10.2 Signs for Radiation Control Areas

7.11 Eating, Drinking, Smoking and Application of Cosmetics in the Laboratory

7.12 Fume Hoods

7.13 Personal Protective Measures

7.13.1 Protective Clothing

7.13.2 Disposable Gloves

DIRECTIVE NO. GPR 1860.1D Page 3 of 51

7.13.3 Respiratory Protection

7.14 Transporting Radioactive Materials (On Campus)

7.15 Security of Radioactive Materials

8.0 RADIOACTIVE WASTE GUIDELINES

9.0 PERSONNEL EXPOSURE MONITORING

9.1 External Exposure

9.1.1 Limits for External Radiation Exposure for Radiation Workers

9.1.2 Limits for External Radiation Exposure to Members of the Public

9.2 Monitoring Requirements

9.2.1 Procedures for Monitoring Devices (Badges)

9.2.2 Personnel Monitoring Protocol

9.2.3 Use of Personnel Monitoring Devices

9.3 Personnel Monitoring Reports

9.4 GSFC Pregnant Employee - Fetal Dose

9.5 Internal Exposure

9.5.1 Bioassay Program

9.5.2 Notification Requirements

9.5.3 Analysis and Records Keeping

9.6 Physical and Medical Examinations

10.0 CUSTODIAN RECORDS AND REQUIRED NOTIFICATIONS

11.0 SHIPPING, RECEIVING OR TRANSFER OF RADIOACTIVE MATERIALS

11.1 On Campus Transfers

11.2 Off Campus Transfers

11.3 Shipping Requirements

11.4 International Shipments

11.5 Incoming Shipments

12.0 ALARA PROGRAM

12.1 ALARA Procedures

12.2 ALARA Investigation Levels and Reporting

13.0 EMERGENCY PROCEDURES

13.1 Radioactive Material Spills

13.1.1 Personnel Protection

13.1.2 Contamination Control

13.2 Serious Injury with Radiation Exposure or Contamination

13.3 Fire or Explosion in a Radionuclide Area

13.4 High Radiation Exposure without Contamination

13.5 Decontamination Procedures

13.5.1 Limits for Skin Contamination

DIRECTIVE NO. GPR 1860.1D Page 4 of 51

13.5.2 Surface Contamination Limits

13.6. Airborne Contamination Limits

13.7 Radiation Event Reporting and Investigation

APPENDIX A: Definitions

APPENDIX B: Acronyms

APPENDIX C: At Sea/Field Use of Radioactive Material

DIRECTIVE NO. GPR 1860.1D Page 5 of 51

PREFACE

P.1 PURPOSE

This directive describes the Goddard Space Flight Center (GSFC) Radiation Protection Program approved by the Ionizing Radiation Safety Committee for ionizing radiation. It contains the program’s organizational and procedural requirements. It further provides radiation protection information to ensure that necessary radiation exposure shall be kept As Low As Reasonably Achievable (ALARA).

Goddard’s Radiation Protection Program operates in compliance with two Radioactive Materials

Licenses issued by the Nuclear Regulatory Commission, which includes a Type A broad scope license.

P.2 APPLICABILITY

a. These requirements are applicable to all GSFC personnel, facilities, and activities, including all permanent and temporary sites. These requirements also apply to all GSFC tenant organizations, contractors, grantees, clubs and other persons operating under a GSFC license or on GSFC property as required by law and as directed by contractual, grant, and agreement documents. This directive applies only to ionizing radiation. Other types of radiation are covered in other documents.

b. In this directive, all document citations are assumed to be the latest version unless otherwise noted.

c. In this directive, all mandatory actions (i.e., requirements) are denoted by statements containing the term “shall.” The terms “may” or “can” denote discretionary privilege or permission; “should” denotes a good practice and is recommended but not required; “will” denotes expected outcome; and

“are/is” denotes descriptive material.

P.3 AUTHORITY

a. U.S. Nuclear Regulatory Commission (NRC) Byproduct Materials Licenses 19-05748-02 and 19-

05748-03

b. NPD 1800.2, NASA Occupational Health Program

P.4 APPLICABLE DOCUMENTS AND FORMS

a. NPR 1800.1, NASA Occupational Health Program Procedures

b. NPR 8715.3, NASA General Safety Program Requirements

c. Title 10 Code of Federal Regulations Part 20 (10 CFR 20)

d. Consolidated Guidance About Materials Licenses: Program-Specific Guidance About Licenses of

Broad Scope (NUREG-1556, Volume 11)

e. GSFC Form 23-6I, Request for Ionizing Radiation Safety Committee Action – Ionizing Radiation

Source Approval http://gdms.gsfc.nasa.gov/ http://nodis3.gsfc.nasa.gov/library/lib_docs.cfm?range=1___ http://nodis3.gsfc.nasa.gov/library/lib_docs.cfm?range=1___ http://nodis3.gsfc.nasa.gov/library/lib_docs.cfm?range=8___ http://www.access.gpo.gov/nara/cfr/waisidx_02/10cfr20_02.html http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1556/v11/ http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1556/v11/

DIRECTIVE NO. GPR 1860.1D Page 6 of 51

f. GSFC Form 23-6ID, Request for Ionizing Radiation Safety Committee Action - Ionizing Radiation

Producing Device Approval

g. GSFC Form 23-26, Radioactive Material Shipping and Receiving Record

h. GSFC Form 23-27, Health Physics Activity Report

i. GSFC Form 23-28I, Ionizing Radiation Source Questionnaire

j. GSFC Form 23-28ID, Ionizing Radiation Producing Device Questionnaire

k. GSFC Form 23-35IP, Ionizing Radiation Source Personnel Approval and Continuation Sheet

l. GSFC Form 23-59, Initiator’s Acquisition Checklist

m. GSFC Form 20-4, Transfer/Shipping Request

n. GSFC Form 23-42, Radioactive Material Onsite Transfer

NOTE: All FORMS listed above can be found at: NASA Electronic FORMS website

P.5 CANCELLATION

a. GPR 1860.1C, Ionizing Radiation Protection

b. 360-PG-6400.1.1: Packaging and Shipping of Radioactive Materials

P.6 SAFETY

Safety requirements and numerous safety-related procedures are identified throughout this directive.

Specific requirements applicable to procedures resulting from this GPR are described where appropriate.

P.7 TRAINING

Training requirements are specified in Section 2.2.

P.8 RECORDS

Record Title Record Custodian Retention/Schedule

GSFC Form 23-6I Request For Ionizing Radiation Safety Committee Action - Ionizing Radiation Source Approval

Radiation Protection Office (RPO) keeps original; users maintain duplicate sets.

*NRRS 8/23.5

CUTOFF ANNUALLY. DESTROY

WITH CONCURRENCE OF CENTER

OR NASA COUNSEL'S OFFICE 75

YEARS AFTER CUTOFF OR WHEN

NO LONGER NEEDED,

WHICHEVER IS LATER.

GSFC Form 23-6ID [Device] Request For Ionizing Radiation Safety Committee Action - Ionizing Radiation Device Questionnaire

RPO keeps original;

users maintain duplicate sets.

NRRS 8/23.5

GSFC Form 23-26 Radioactive Material Shipping and Receiving Record

RPO keeps original; users maintain duplicate sets.

NRRS 8/23.5

https://nef.nasa.gov/nef/?ACSREQUESTID=K6711d449aaf3d3f7d2b0ff2a657954a622905376

DIRECTIVE NO. GPR 1860.1D Page 7 of 51

GSFC Form 23-27 Health Physics Activity Report

RPO NRRS 8/23.5

GSFC Form 23-28I Request For Ionizing Radiation Safety Committee Action - Ionizing Radiation Source Questionnaire

RPO NRRS 8/23.5

GSFC Form 23-28ID [Device] Request For Ionizing Radiation Safety Committee Action - Ionizing Radiation Device Questionnaire

RPO NRRS 8/23.5

GSFC Form 23-35IP Request For Ionizing Radiation Safety Committee Action - Ionizing Radiation Source Personnel Approval

RPO keeps original;

users maintain duplicate sets.

NRRS 1/130

RECORDS ARE KEPT FOR 2

YEARS. IF EMPLOYEE DOES NOT

WISH TO BE RENEWED FOR THE

POSITION AT THE END OF 2-

YEAR PERIOD, THE RECORD IS

REMOVED AND PLACED IN AN

INACTIVE FILE. RECORDS ARE

RETAINED AT GSFC UNTIL

DESTROYED. DESTROY WHEN 75

YEARS OLD.

Radiation Safety Operating Procedures

RPO keeps original;

users maintain duplicate sets.

NRRS 8/23.5

Records associated with NRC licenses

RPO 10 CFR 20.2102(b)

The licensee shall retain the records required by paragraph (a)(1) of this section until the Commission terminates each pertinent license requiring the record.

Records of personnel experience and training

Supervisors NRRS 1/130

Records of inspections and evaluations of facilities, equipment, location, and inventory

RPO or designee NRRS 8/23.5

Records of equipment and facilities, including model numbers, serial numbers, and calibration requirements

User organization, as part of their Radiation Safety Operating procedures

NRRS 8/23/5

DIRECTIVE NO. GPR 1860.1D Page 8 of 51

Safety Analysis Reports RPO NRRS 8/23.5

Reports of violations, contamination, decontamination, etc.

RPO NRRS 8/23.5

Radiation monitoring records (dosimeters, etc., including levels, names, locations, etc.)

RPO NRRS 8/23.5

Records of shipments and transfers of radioactive materials

RPO NRRS 6/7

RETIRE RECORDS TO FRC

WHEN 3 YEARS OLD. DESTROY

WHEN 13 YEARS OLD.

*NRRS 1441.1 – NASA Records Retention Schedules

P.9 MEASUREMENT/VERIFICATION

To assess and provide quality assurance of the GSFC Ionizing Radiation Protection Program, the

GSFC Ionizing Radiation Safety Committee during their quarterly meetings shall:

a. Monitor the program to maintain occupational doses as low as reasonably achievable (ALARA).

b. Review and approve (or disapprove) each new (or renewing) user of radioactive material and/or radiation producing devices.

c. Review and approve (or disapprove) each proposed method of use of radioactive material and radiation producing device and ensure it complies with Nuclear Regulatory Commission (NRC) requirements, and other Federal regulations, professional standards, and sound health physics practices.

d. Control possession and use of X-Ray producing machines, particle accelerators, accelerator-produced radioisotopes, or radium and its daughter products/sources of ionizing radiation.

e. Review and approve (or disapprove) procedures and radiation safety program changes prior to submittal to the NRC for licensing action.

f. Review non-compliance reports, including cause, immediate corrective actions taken and action to prevent recurrence.

g. Review occupational radiation exposure records of personnel working with radioactive material and radiation producing devices.

h. Review incidents involving radioactive material with respect to cause and subsequent actions taken.

i. Establish a table of occupational dose levels that, if exceeded, shall initiate investigations and considerations of action by the RSO.

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DIRECTIVE NO. GPR 1860.1D Page 9 of 51

PROCEDURES

1.0 GSFC RADIATION SAFETY PROGRAM

1.1 Introduction

The purpose of the Goddard Space Flight Center (GSFC)’s Radiation Protection Program is to ensure that operations involving ionizing radiation producing sources are conducted in a safe and secure manner

The GSFC emphasizes safety education and training as the primary means of achieving this goal. While the Radiation Protection Office (RPO) provides guidance and performs periodic radiation safety inspections; Custodians, Approved Users, and supervisors are directly responsible for maintaining an atmosphere that promotes full compliance with GSFC’s safety policies and procedures.

With regard to ionizing radiation safety matters, the GSFC Ionizing Radiation Safety Committee (IRSC) establishes radiation policies and procedures for the GSFC in accordance with requirements set forth by

NASA and Federal regulatory agencies. These policies are implemented by the Radiation Safety Officer

(RSO), who directs the RPO.

Essential elements of the GSFC radiation safety program are presented in this Goddard Procedural

Requirement (GPR). The safety program has been carefully developed to assist all radiation users in utilizing the unique advantages of radiation sources while meeting their safety responsibilities in as efficient and non-intrusive manner as possible. In addition, radiation safety principles and regulatory agency licenses include a goal of maintaining all exposures As Low As Reasonably Achievable"

(ALARA). The policies and procedures found in this GPR were designed to promote the achievement of this goal.

GSFC is authorized by the Nuclear Regulatory Commission (NRC) to use radioactive material in operations, research, and development activities on GSFC campus; at temporary job sites of the licensee anywhere in the United States; and on board ships in U.S. coastal waters, at sea, and in inland water where the U.S. NRC maintains jurisdiction. The GSFC NRC license authorizes individuals to use radioactive material. Prospective users shall submit proposals to the IRSC for review and approval.

Although this provision allows the Center flexibility in dealing with a multitude of radioactive materials and research uses at various Center locations, it places equally great responsibility on Custodians and administration to handle radioactive materials safely and to comply with NRC regulations and license conditions so that this flexibility may continue.

This GPR summarizes the license conditions, standards, and regulations applicable to the use of various radioactive materials and ionizing radiation devices. Copies of special precautions, regulations, and other operating procedures specified by the IRSC or RSO as a condition for approval to utilize ionizing radiation sources and devices needs to be posted at the approved work area and made available to approved personnel. Everyone involved with the use of ionizing radiation sources and devices shall be familiar with the provisions of this GPR.

DIRECTIVE NO. GPR 1860.1D Page 10 of 51

1.2 Radiation Safety Organizational Chart

Center Director

NASA – Goddard Space Flight Center

Director, Safety and Mission Assurance

Code 300

RADIATION PROTECTION OFFICE

(Support Contract)

Code 360

Radiation Safety Officer

Directors Of, Center Directorates

Chief, Safety Division

Code 360

Head, Radiation Protection Office

Radiation Safety Officer

Code 360

Center Managers

Radiation Workers

Chair

Safety Council

Chair

Goddard Safety Committee

Chair

Ionizing Radiation Safety Committee

DIRECTIVE NO. GPR 1860.1D Page 11 of 51

1.3 Radiation Safety Responsibilities

1.3.1 Management

GSFC line management has primary responsibility for the radiation safety of personnel working under their jurisdiction and shall designate Custodians of sources of ionizing radiation and radiation producing devices.

Supervisors shall ensure that radiation sources and/or devices are used only by individuals approved by the IRSC and that all procedures and requirement are met.

1.3.2 Safety Division

Safety Division will be responsible for program oversight and ionizing radiation protection at GSFC facilities and will support all GSFC organizations in matters involving ionizing radiation, including the

IRSC. The RPO is a part of the Safety Division who maintains the records associated with the NRC licenses. The Chief, Safety Division will:

a. Ensure a qualified RSO is hired and that there are adequate Contractual personnel available to support the radiation protection program.

b. Sign off on appointment letters for members of the IRSC

c. Review and approve IRSC meeting minutes

1.3.3 Ionizing Radiation Safety Committee (IRSC)

The IRSC is responsible for establishing GSFC’s policies governing the procurement, use, storage and disposal of radioactive material and radiation producing devices, which ensures compliance with all

NASA, Federal and NRC regulations. The Committee includes individuals experienced in the use of radioactive material and radiation producing devices in research on GSFC’s bases. The Committee consists of a Chairman, RSO, representatives of management, and members from divisions on the

Center that work with or use radioactive material and/or ionizing radiation producing devices. The duties of the Chair and Committee are listed in the IRSC Charter and the Committee meets at least once each calendar quarter.

1.3.4 Radiation Safety Officer (RSO)

The RSO has administrative responsibility for the Center's radiation safety program. The RPO staff provide a wide range of specific radiation protection services such as personnel monitoring, waste disposal, laboratory surveys, maintenance of records, consultation on the safe use of radioactive materials, and training.

The RSO is responsible for radiation protection on the Center, including general surveillance of overall activities involving radioactive material and all areas where sources are used. He/she is also responsible for compliance with applicable state regulations and NRC license conditions.

All applications for radioactive materials and use of radiation-producing devices, including location, procedures, and possession limit changes, are reviewed by the RSO. The RSO recommends approval or disapproval (to the IRSC) of applications for the use of ionizing radiation sources and devices. The RSO

DIRECTIVE NO. GPR 1860.1D Page 12 of 51 may approve an increase in possession limit for radionuclides. He/she may suspend any activity that they determine to be a threat to health or property.

The RSO is responsible for investigating overexposures, accidents, spills, losses, thefts, unauthorized receipts, uses, transfers, disposals, and other deviations from approved radiation safety practice, and implementing corrective actions as necessary.

1.3.5 Radiation Protection Program Support Staff

This staff is made up of personnel provided through a service support contract with qualified health physics personnel positioned at the Greenbelt Radiation Protection Office (RPO) and safety personnel positioned and GSFC sites like Wallops Flight Facility and White Sands Complex. These staff members accomplish many requirements associated with the Radiation Protection Program (i.e. radiation surveys, inspections) and support the RSO to ensure that all uses of ionizing radiation sources and devices is done in a safe fashion and meets all federal, state, NASA and local regulations.

1.3.6 Custodians

Custodians are approved by the IRSC and are directly responsible for compliance with all regulations governing radiation safety under their authorization. Custodians are responsible for ensuring that personnel using radioactive materials under his/her authorization are trained in safe laboratory practices, are familiar with the terms of the authorization and are complying with Center policies and applicable regulations. The Custodian will normally be the principal investigator of a research project or the member responsible for a field exercise in which radioactive materials and/or radiation producing devices are used and are responsible for:

a. Ensuring that individuals working under their authorization are using safe work habits to prevent unnecessary exposures to themselves and others.

b. Maintaining an active inventory and knowledge of the various forms and quantities of radioactive material or radiation producing devices that are present in their work areas.

c. Understand the risks associated with the possession, use, and shipment of all radioactive materials.

d. Maintain constant surveillance and immediate control of radioactive material to prevent unauthorized removal or tampering.

e. Ensure that all radioactive material and radiation producing devices in their area are properly labeled.

f. Ensure instruction is given to female radiation workers on the risks associated with working with radioactive materials during pregnancy.

g. Ensure designation of a responsible individual to oversee work conducted under their authorization for short absence and a stand-in custodian with the required committee approvals during extended absences greater than 30 days.

h. Use ionizing radiation sources and devices according to their IRSC approved procedures

1.3.7 Approved Users

Employees that have been approved by the IRSC to be users of radioactive material and/or radiation-producing devices at the GSFC and will be responsible for knowing and observing all applicable

DIRECTIVE NO. GPR 1860.1D Page 13 of 51 radiological safety regulations. They shall immediately stop operations and report to their supervisor and the RSO all unsafe conditions or operations involving radiation sources or devices. They are also free to raise safety concerns to anyone including the RSO and the NRC.

1.4 Nuclear Regulatory Commission (NRC)

GSFC holds two NRC licenses to use radioactive material for research purposes. GSFC is authorized to possess, use, and transfer byproduct material in accordance with the conditions stated in the licenses.

1.5 Categories of Source Uses/Operations

All ionizing radiation source uses shall be categorized by the RSO, based on their hazard and risk for exposure. The categories are as follows:

LOW: No one could be permanently injured by this amount of radiation. Radiation exposure during normal operations or emergency situations will not exceed radiation dose limits for individual members of the public defined in 10 CFR 20.1301. To ensure that occupational doses and doses to members of the public are as low as reasonably achievable (ALARA), probability will be determined based on the potential for dose above background.

MODERATE: Marginal: It is very unlikely that anyone would be permanently injured by this amount of radiation. However, this amount of unshielded radiation, if not safely managed or securely protected, has the potential to exceed ALARA Notification Levels listed in section 12.2.

HIGH: This amount of radiation, if not safely managed or securely protected, could cause permanent injury to a person who handled it, or were otherwise in contact with it. The amount of radiation produced from this material or equipment has the potential for exceeding occupational dose limits defined in 10 CFR 20.1201.

2.0 IONIZING RADIATION AUTHORIZATION

All Approved Users, Custodians, and uses of ionizing radiation sources or devices, including the radiation sources themselves, require approval by the IRSC. All authorizations are subject to conditions of the NRC licenses held by GSFC and the conditions imposed by the IRSC. Violations of the approved conditions regarding users, uses, or location may result in revocation of the authorization.

2.1 Obtaining Authorization to be an Approved User and/or Custodian of Ionizing Radiation

Sources or Devices

The procedure for obtaining authorization is as follows:

a. For most applications to use radioactive material, interim approval may be given by the RSO for up to 30 days until the Ionizing Radiation Safety Committee gives final approval.

b. The proposed individual shall complete a GSFC Form 23-35IP, listing their training and experience working with sources and/or devices, a listing of the sources and/or devices they will be using, and the signature of the Custodian for the sources and/or devices

DIRECTIVE NO. GPR 1860.1D Page 14 of 51

c. Submit the form to the appropriate project manager/branch head (or higher authority) for concurrence. If satisfied with the request, the branch head (or higher) shall forward the request to the RPO for IRSC approval.

d. The RPO shall review the request to ensure that the individual has the education, training, and experience necessary to handle the ionizing radiation sources or devices requested.

e. The IRSC will approve or disapprove the request and the RPO will notify the individual by providing a copy of the approved or disapproved GSFC Form 23-35IP. Interim approval for a request may be granted by the IRSC Chairman between IRSC meetings and then finalized at the next IRSC meeting.

f. Triennial refresher training is required to maintain User Approval.

Civil service and contract employees are allowed to be either an Approved User or Custodians of ionizing radiation sources or devices at GSFC or GSFC-approved locations. GSFC civil servants, contractors and other personnel operating offsite under GSFC license are subject to all provisions of

Goddard’s Radiation Protection Program.

2.2 Personnel Training Requirements

Personnel completing a GSFC Form 23-35IP are required to list the radiation safety training they have received. Specific training will be required of each individual based on the hazard of the source(s) they are seeking authorization to use and the manner in which the sources are used. Depending on the use, specialty training may also be required (e.g. Radiation Detector Usage).

2.3 Personnel Experience Requirements

Experience in working with hazardous radiation sources is crucial. A person should have previous experience in handling or operating radiation sources or devices. Experience for this requirement can include that obtained from universities, former employment, and work supervised by a Custodian (who are responsible for keeping records of this experience). This experience will be documented on the individual’s GSFC Form 23-35IP. Experience required should be commensurate with the hazard involved and is at the discretion of the Ionizing Radiation Safety Committee. Table 2.3 provides a guideline for assessing the minimum experience necessary to work with radiation sources or devices:

Table 2.3: Experience Requirements

Source Category Experience Required*

LOW None

MODERATE 8 hours with these sources

HIGH 40 hours with these sources

*Other requirements may be substituted for experience as determined appropriate by the RSO.

2.3.1 Supervision of Inexperienced Radiation Workers

Completing radiation safety training does not ensure that inexperienced workers are competent to use all categories (Low, Moderate, High) of radioactive materials or devices without supervision.

Inexperienced personnel needing to use radioactive sources or devices will submit a GSFC 23-35IP.

DIRECTIVE NO. GPR 1860.1D Page 15 of 51

Block #5 will be marked YES for “direct supervision during all operations”. The Custodian shall ensure that inexperienced workers are directly supervised during radiation use until such time that the

Custodian is comfortable that the worker can handle sources or devices of radiation safely and competently. Once the Custodian is comfortable with this worker’s experience a request will be submitted to the RPO to have the original GSFC 23-35IP modified to change Block #5 to NO. This request should include the dates that the worker was supervised.

2.4 Obtaining Authorization to use Ionizing Radiation Sources or Devices

Requests for approval to use ionizing radiation sources are initiated by submitting a GSFC Form 23-6I

(which describes the who/what/where/why of using the source) and a GSFC Form 23-28I (which is a description of the source) to the RPO. Appendix C addresses the specific requirements for using radioactive sources onboard ships.

Requests for approval to use ionizing radiation emitting devices (such as X-Ray machines, accelerators, scanning electron microscopes, etc.) are initiated by submitting a GSFC Form 23-6ID (which describes the who/what/where/why of using the device) and a GSFC Form 23-28ID (which is a description of the device) to the RPO.

Requests shall be submitted by the Approved User or Custodian to the RPO at least 2 weeks prior to the need date to guarantee processing. Complicated projects, extremely hazardous operations, offsite activities, and flight activities need to be coordinated with the RSO in early planning stages to ensure that there is no impact to mission schedules.

Approvals are valid for a maximum of 3 years and may contain conditions that restrict the use of the material for specific purposes at GSFC and approved off-site locations.

The procedure for obtaining authorization is as follows:

a. For new sources or devices; the originator shall prepare the GSFC Form 23-28I or 23-28ID describing the ionizing radiation sources or devices involved and identifying their nominal strengths or settings. For established sources or devices, the originator will list the assigned

Docket Number(s) in the appropriate section of the GSFC Form 23-6I or 23-6ID.

b. The originator shall prepare the GSFC Form 23-6I or 23-6ID describing the intended use of the source or device along with safety procedures, showing that the source or device can be properly used, stored, disposed, and transferred with minimum exposure to personnel or damage to property. All operations will be in compliance with GSFC and other applicable regulations. The location and availability of proper equipment (including model numbers, serial numbers, and calibration requirements as applicable) and facilities will be included in the procedures.

c. The originator submits the above forms to the RPO for IRSC approval.

d. When the RPO receives the request, they will perform a health physics evaluation to determine the adequacy of the equipment, facilities, and location of the particular use of the radiation source or device. Operating procedures and source handling techniques will be discussed and evaluated, including final source disposal options. On the basis of the evaluation, the RPO may impose additional conditions to ensure safe operation. Any additional conditions or explanation of non-approval should accompany the request.

DIRECTIVE NO. GPR 1860.1D Page 16 of 51

e. In some cases, the RPO may require the applicant to submit a safety analysis that indicates probability of a serious incident, its consequences, and mitigation. The RPO shall determine the requirements on a case-by-case basis.

f. The IRSC shall approve or disapprove the request for use of ionizing radiation sources and/or devices, and the RPO will notify the originator by providing a copy of the approved or disapproved GSFC Form 23-6I or 23-6ID. The IRSC may also impose additional requirements.

g. The procedures approved in the request become the conditions under which the Custodian and his/her personnel are approved to use ionizing radiation sources and devices. Any subsequent change in procedure regarding the use, storage or disposal of sources/devices shall be reviewed and approved in writing by the RSO prior to instituting the change.

Contractors operating under a self-license and on contractor-owned facilities shall submit a copy of the applicable license and a full description of their programs to the RSO. The RSO will review submissions and establish any necessary conditions or restrictions as set forth in this GPR.

2.5 Facilities Evaluation

The review of radioactive material use requests shall include an evaluation by the RSO of the adequacy of the proposed facilities. Depending on the quantity of material involved, the type of source and the complexity of the proposed procedures, the following need to be considered:

a. isolation from general laboratories and public areas

b. availability of radiation detection instrumentation

c. adequacy of ventilation and fume hoods

d. appropriate work surfaces and floors (non-porous)

e. provisions for shielding and secure storage of sources

2.6 Inspection and Inventory Requirements

Facility inspections, equipment inspections, and source storage location inspections should be performed annually by the RSO (or designee) to ensure compliance with the approved GSFC Form 23-6I and/or 23-

6ID. Source inventory shall be completed (at a minimum) every 6 months by the RPO staff and source inventory, in the same manner, will be required to be verified by the Custodian annually. The possible loss of any source shall be immediately reported to the RSO.

All radiation sources will be subject to inspection and inventory as required by the NRC license. RPO staff will personally view the location of sources during inventory (at a minimum every 6 months).

2.7 Obtaining Approval to Purchase Ionizing Radiation Sources or Devices

The individual requesting the source or device shall be an Approved User and/or Custodian. For sources they will submit GSFC Form 23-28I and for devices a GSFC Form 23-28ID. The requesting individual will follow the requirement in Section 5.

a. The request shall be submitted to the appropriate branch head (or higher authority) for concurrence. If satisfied with the request, the branch head (or higher) forwards the request to the

RPO.

DIRECTIVE NO. GPR 1860.1D Page 17 of 51

b. The RPO will review the NRC license to ensure that no limits are exceeded by this request. The

RPO will direct the requesting individual to follow the requirement in Section 5.

c. The initiator shall also submit a GSFC Form 23-59 to the Safety Division on this request.

2.8 Amendments to Authorizations

a. A memo to the RSO shall be submitted for an increase in possession limits, changes in use and storage areas and other minor changes.

b. A Custodian shall submit a new request if other radionuclides are to be used or if procedures change significantly alter radiological hazards under their control.

c. A Custodian who needs to use ionizing radiation sources or devices in a manner other than that already approved shall submit a new GSFC Form 23-6I or 23-6ID, describing the new use to the

RSO for IRSC approval.

2.9 Record Keeping

A copy of all forms that have received IRSC approval will be maintained in the Custodian’s radiation safety records. The original forms are kept at the RPO. GSFC 23-35IP forms will be maintained by the

Custodian and the RPO as long as the individual’s employment actively involves use of the ionizing radiation sources or devices. Upon termination or transfer, the form may be archived or removed from the records per GSFC Retention Schedule listed in Section P.8.

2.10 Inactive Status

A Custodian may request in writing to the RSO that his/her authorization to use and store radioactive materials be temporarily changed to an Inactive Status. This status allows for performing and documenting survey/wipe tests and inventories on a less frequent basis. This provision is designed for laboratories that are not planning on using radioactive materials for at least six months. The Custodian may not use radioactive materials with this status (this is a storage only authorization). The Custodian shall submit a request to the RSO to return to active status when so desired. Requirements levied on the work area (i.e. no eating, drinking, smoking, etc.) remain in effect during the inactivity unless the area is cleared by a final clearance survey per 7.8.

2.11 Approval for Onsite Movement of Sources

GSFC Form 23-6I shall be submitted for all actions involving movement of sources on Center (loans, shipments, different users, etc.) from building to building. This requirement does not apply to devices or the movement of a source inside the same building.

Radioactive sources can only be transferred within a building with the authorization of the source

Custodian to an Approved User and to a location approved in advance by the RSO. If a source is transferred for more than 90 days, the Custodian shall submit a request for a permanent transfer and obtain approval from the IRSC using GSFC Form 23-6I. Temporary movement of the source will be documented on a “Radioactive Source Sign-Out Log”, which will be maintained in the original source storage area.

DIRECTIVE NO. GPR 1860.1D Page 18 of 51

2.12 Approval for Use of a Source Offsite

Approval from the IRSC shall be obtained to use GSFC licensed material at a temporary job site. This will be in the form of an approved GSFC 23-6I or 23-6ID FORM The user organization is responsible for generating this document, and requires approval by the IRSC at least 6 months prior to offsite material use.

Timely submittal of these documents is recommended because obtaining some approvals can be time-consuming, and additional time may be necessary for correction of procedural discrepancies. Similarly, if international shipments are involved, coordination of International Traffic in Arms requirements with the GSFC Transportation Officer shall occur at least six months in advance.

3.0 RADIATION PROTECTION PRINCIPLES

The body may be irradiated in two general ways: externally from radioactive material or radiation sources, or internally from radioactive material deposited in the body. External doses can be the result of exposure to gamma, X-Ray, or high-energy beta emitters. Low-energy beta and alpha emitters lack the energy needed to penetrate the outer layer of skin and subsequently present less of an external hazard; they are of more concern when internalized. The external dose an individual receives depends on the following factors: exposure, time, distance, and shielding.

3.1 Exposure. The "strength" (activity, mrem/hr, etc.) of the radiation source. By utilizing only the amount of radioactive material needed for an experiment or lowering the current settings on a radiation-producing machine, exposure can be reduced.

3.2 Time. The total dose received from an external source also depends on the amount of time actually exposed to the source. Therefore, any time that is spent near a source shall be minimized and used effectively.

3.3 Distance. By increasing the distance between the source of exposure and an individual, the dose received can be significantly reduced. When an individual doubles his/her distance from a source, the dose will usually be reduced by approximately three-fourths.

3.4 Shielding. When radiation sources are being used, absorbing material or shields can be incorporated to reduce exposure levels. The specific shielding material and thickness is dependent on the amount and type of radiation involved.

3.5 Internal exposure results from the absorption, ingestion or inhalation of radioactive material.

This material can be incorporated in the body in several ways: (1) by breathing radioactive gases, vapors or dust; (2) by consuming radioactive material transferred from contaminated hands, tobacco products, food or drink; (3) by entering through a wound; and (4) by absorption through the skin.

3.6 Fundamental objectives of radiation protection measures are: (1) to limit entry of radionuclides into the human body (via ingestion, inhalation, absorption, or through open wounds) to quantities ALARA and always within the established limits; and (2) to limit exposure to external

DIRECTIVE NO. GPR 1860.1D Page 19 of 51 radiation to levels that are within established dose limits and as far below these limits as is reasonably achievable.

3.7 Radiation Safety Rules

a. Eating, drinking, smoking, chewing gum and the application of cosmetics are prohibited in a room where radioactive materials are used or stored.

b. Protective gloves shall be worn when handling contaminated or potentially contaminated items.

c. Personnel working with unsealed radioactive sources shall wear some type of outer-garment to prevent contamination of personal clothing and exposed skin. The wearing of skirts, opened toed shoes, bare midriffs, etc. are prohibited.

d. Pipetting radioactive solutions by mouth is prohibited.

e. Persons with open wounds will be particularly careful when working with radioactive materials

(the wound shall be properly covered).

f. Disposable absorbent pads and remote handling devices shall be utilized whenever possible.

g. Hands will be washed thoroughly after handling radioactive materials, especially before eating.

After handling possible sources of contamination, personnel shall contact the RPO to be surveyed for contamination prior to leaving the controlled area.

h. Food items shall not be stored in areas or equipment designated for radioactive materials.

i. Personnel monitoring badges shall be worn in restricted areas as determined by the RSO.

j. Radioactive waste shall be kept in labeled containers.

k. Radioactive shipments shall be handled and stored in specially designated locations.

l. Good housekeeping should be maintained at all times. Contamination/spills shall be cleaned up immediately.

m. Follow the established emergency procedures in the case of an accident.

n. When using volatile radionuclides (e.g. iodine) or heating radioactive solutions, always perform work in a properly operating fume hood.

o. Transport radioactive materials in such a manner as to prevent spillage or breakage and ensure adequate shielding.

p. Label all containers of radioactive materials, to include radionuclide, activity and date of activity.

All containers, except those in immediate use, shall be labeled.

q. Utilize shielding when necessary to maintain radiation levels as low as reasonably achievable

(ALARA).

r. Store radioactive material in locked cabinets/refrigerators and keep the laboratory door locked when lab personnel are not present.

s. Laboratory glassware used with radioactive materials shall not leave the controlled area.

4.0 RADIATION SAFETY OPERATING PROCEDURES

The user organization shall develop documented safe operating procedures with regard to the use of the ionizing radiation source or device. These procedures will describe the control methods to be used in each application and will be submitted with the GSFC Form 23-6I or 23-6ID when requesting authorization and when renewing every 3 years. Requirements differ, depending on the type of source(s) and the operation, but the following minimum safety operations need to be covered:

DIRECTIVE NO. GPR 1860.1D Page 20 of 51

Table 4.0: Radiation Safety Operating Procedures Requirements

Source Type Procedures Required (Minimum)

LOW Storage and Security aspects and final disposition

MODERATE Detailed description of source/device use, storage, security, and final disposition

HIGH Clear, detailed operating procedures for all phases of the operation including use, handling, storage, security, and final disposition.

In addition to the items described in the Table 4.0, the following requirements shall be addressed. This is not an all-inclusive list, and further items and controls may be necessary depending on the particular use.

a. State that only persons approved by the IRSC may use the sources or device

b. Specify that no eating, drinking, or smoking is permitted in the source use or storage area and that storage of food, drinks, or personal effects is not allowed in these areas

c. Specify necessary personal protective equipment, e.g., gloves, lab coats, safety glasses, respirators, etc., and state that these items shall not leave the radiation area unless verified to be free of contamination.

d. If required, state personnel monitoring requirements, i.e. Whole Body Dosimeter, extremity badge (Wrist, ring), etc.

e. Specify storage and security methods

f. Specify that the source shall be secured from unapproved personnel whenever it is not under the immediate control of an Approved User

g. Specify any special area monitoring, i.e., procedures for checking for area or personnel contamination when required

h. Describe emergency procedures, such as in the case of fire, contamination of source by chemicals, a spill of liquid sources, release of gaseous sources, etc.

i. Specify methods for disposal of radioactive waste (if applicable)

j. Identify specific equipment and facilities, including equipment model numbers, serial numbers, and calibration requirements

k. Specify required warning signs and labels

4.1 Written Procedures

The written Radiation Safety Operating Procedure, documented with the GSFC Form 23-6I or Form 23-

6ID, shall be posted at each radiation source or device work area. These procedures will list the

Approved Users (along with their Docket Number) for this work area at the end of the procedures. Each

Approved User will review and sign these procedures acknowledging that they understand the radiation safety procedures required to use these sources or devices.

Custodians shall ensure that sources and/or devices are used only according to their IRSC approved procedures. These procedures are subject to renewal every 3 years or when the procedures require modification.

DIRECTIVE NO. GPR 1860.1D Page 21 of 51

4.2 Use of Sources in Launch Operations or Other Offsite Functions

4.2.1 Radioactive Materials Launch List

In coordination with GSFC flight projects, the RPO will compile and submit to NASA Headquarters a list of launches involving radioactive material. GSFC launch and project organizations will furnish the

RPO with the launch and source information described in NPR 8715.3 series (Chapter 6), at least 6 months prior to the scheduled launch. The RPO will prepare its report to NASA Headquarters in accordance with established procedures. Coordination shall start with the earliest knowledge or radioactive material involvement.

4.2.2 Approval for Launch Operations

The coordination to launch radioactive material shall occur early enough to ensure timely receipt of range approvals for these materials and conformity with GSFC procedural and licensing requirements.

Timely submittal of these documents is recommended because some ranges require as much as 90 days prior notice of intent to use radiation sources.

The RSO will submit an appropriate usage request, in accordance with the usage site’s requirements to the appropriate range or site, which will include the following information:

a. Listing and descriptions of all radioactive sources to be delivered to the site, including the associated experiment, whether for ground or in-flight use, and description of activity and date of activity

b. Any available diagram(s) of locations of experiments containing radioactive materials on the spacecraft, sounding rocket, etc.

c. A list of radiological monitoring instrumentation (including calibration dates) and emergency equipment to be made available at the site and the responsible organizations who will provide for these items

d. Descriptions of types of shielding for radioactive materials

e. Applicable licenses for handling the radioactive material

f. Summary of the method of use, storage, monitoring requirement, and precautions to be observed

g. Description of the shipping plan that details the receipt and return of the sources from the use site

4.3 Environmental Testing Certification (Thermal-Vacuum)

The RPO shall ensure the stability of sources that are to be used in adverse conditions. This is to be accomplished by subjecting the source to expected conditions in a controlled situation in a vacuum chamber or other appropriate environment acceptable to the Custodian. The RPO reserves the right to require independent certification of sources.

Source design criteria (other than NRC-approved sealed sources) shall be reviewed and approved by the

RSO prior to use.

All sources to be launched, and any source(s) used in thermal vacuum chambers at GSFC during integration of payload(s), shall be thermal-vacuum qualified.

DIRECTIVE NO. GPR 1860.1D Page 22 of 51

5.0 ACQUISITION OF RADIATION SOURCES OR DEVICES

5.1 Purchasing Radioactive Materials or Ionizing Radiation Devices When ordering radioactive materials, the appropriate GSFC Form 23-28I or GSFC Form 23-28ID will be sent directly to the RSO. A GSFC Form 23-59 shall be submitted to the Safety Division to get approval for this acquisition. Initiators of purchase request will ensure that these approvals are obtained before processing of the purchase.

A unique GSFC source serial number will be obtained from the RSO and shall be designated on the purchase request to be placed on the source during manufacture. This number is required on other approval forms for radioactive material purchases. Such approvals can be obtained simultaneously with other approvals, such as approval for use or approval of sources or devices.

5.2 Radiation Protection Office (RPO) Review

The RPO shall review the order request to determine the following:

a. The user has been approved to use the type and quantity of radioactive material being ordered.

The name of the Custodian shall be clearly indicated on the order.

b. The radioactive material being ordered will not cause the Custodian's inventory limits to be exceeded

c. The Custodian has no unresolved items of safety noncompliance, including responses to survey reports and training notices

d. The Custodian's radionuclide inventory reports are current

When the…