Re: Isotope Transfer Documentation Requirements

[Karl Von Ahn <kxv@po.cwru.edu>]

Bill Stephany,

We have faced a similar problem in the past, and have recently reduced the
scope of these transfers.  We use radioactive materials in about 17 different
buildings with researchers collaborating with several other licenses.

Since Georgia is an agreement state, I will presume that the requirements
match those of the NRC.  If you do not have a copy of the NRC sections
referenced here or by others, the NRC has the complete text of 10CFR at their
web site.

Since you stated that the facilities are physically connected, I assume by a
tunnel or covered walkway (as in a bridge), the materials may be transported
as you would safely move materials from one laboratory to another in the
hallways.  If the transfer involves going outside the building, DOT
requirements need not be met if the transfer does not involve the use of a
motorized vehicle (or plane, rail car, or waterway).

The issue of transferring the material is defined in 10 CFR 30.41 (transfer of
byproduct material) .  This requires that you have a copy of the other persons
current license to verify that they can accept the transfer.  (That is why
your isotope vendors periodically call to verify that they have a copy of your
current license.)  As a programmatic issue, we have a designated form for the
transfer of isotopes within our institution between AU's, and another transfer
form for taking radioactive materials off campus.  This is part of our
Radiation Safety program as defined and required by  10 CFR 20.1101.  Thus
when material needs to be transferred within the campus or off, we use a
standardized form that addresses the  issues of transport mode (hand, cart,
vehicle, FedEx etc), verify recipients authorization to receive the material
(we  apply this from international shipments to transfers within the same
campus building).  This also allows us to verify the appropriate mode and
safety precautions for the transfer of radioactive materials.

An alternative to transfers of radioactive materials within the facility, is
to have what is termed a "dual licensed AU", that is the same person and room
location under two separate licenses.  This  has to be coordinated between the
two radiation safety committees (assuming that you are operating under the
equivalent of 10 CFR part 35).  We have essentially phased out this type of
arrangement that we had with a local institution after many years.  This
option creates many headaches and paperwork for all parties involved.  Take
for instance, if there is a spill or personnel contamination issue which
license was the isotope under and which licensee is responsible for the
reporting and cleanup (or from the labs point of view, who do you call for
help).    From prior experience, this is only a last resort method, or use
under very narrow conditions.

The record keeping requirements typically vary from three to five years after
the transfer or disposal of radioactive materials.