[ RadSafe ] radiation protection survey for RIA

[Brunette, Jeffrey J., CHP]

Mike,

RIA kits actually are not exempt, they are generally licensed.  (I know
it's splitting hairs but the hair splitting does become significant as
I'll try to demonstrate.)  See 10 CFR 31.11 at
http://www.nrc.gov/reading-rm/doc-collections/cfr/part031/part031-0011.h
tml.  As per the regulation, they are generally licensed if you can keep
your inventory on-hand to less than 200 microcuries and the general
license exempts you from most other regulations.  If the RIA facility
possesses more than 200 microcuries of photon emitting RIA material,
then they aren't generally licensed and all the regulations come back
into play.  (In a prior job I held in the '90s, we had a physically
separate RIA lab and did whatever we could to stay below the 200
microcurie limit to maintain the general license and thus the
exemptions.)

For the nuclear medicine survey and other related issues, I'd suggest
you look at some of the guidance materials that the NRC has such as the
appendices in NUREG-1556v9 (at
http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1556/v9/r2/
, specifically appendix L on audits if that is what you mean by "survey"
or appendix R if you asking about daily/weekly surveys).  


Jeff Brunette
brunette.jeffrey at mayo.edu

-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On
Behalf Of Dale Boyce
Sent: Thursday, March 12, 2009 9:43 PM
To: Mike; radsafe at radlab.nl
Subject: Re: [ RadSafe ] radiation protection survey for RIA

If memory serves, most RIA kits are exempt from licensing. Good
Laboratory 
Practices pretty much guarantee adequate radiation safety. Waste
disposal 
can be problematical. Treating it as biohazard waste is the most
pragmatic, 
but some regulators may not agree with this.

----- Original Message ----- 
From: "Mike" <manosph at gmail.com>
To: <radsafe at radlab.nl>; <manosph at gmail.com>
Sent: Thursday, March 12, 2009 3:07 PM
Subject: [ RadSafe ] radiation protection survey for RIA


> hi to everyone!,
>
> I am new to this mailing list, so forvive me if I have posted an
already
> anwered question. But before I posted this question I did a little
search.
> My question is whether there is proper bibliography that can help me
into
> finding out all the details in order to write a survey about the
radiation
> protection in RIA and diagnostic nuclear medicine.
> To the best of my knowledge, RIA does not have many issues, as the
sources
> involved are minute and do not offer much of a risk. Is this correct?
But 
> I
> need to find all the arguments that properly support such an argument.
>
> Thanks in advance for any help,
>
> Mike
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