This section contains the following topics:

Topic

When a Permit is Required

Categories of Permits

How to Apply for a Permit

Submitting Permit Applications for Review

When a Permit is Required

Only permanent USDA employees will be issued a Permit. Temporary duty employees can become an associate user on another individual's Permit.

Since the USDA has been issued a specific license that regulates the use of byproduct material by the NRC, the control of all radioactive materials (even some radioactive materials exempt from licensing) is required.

One exception exists to this requirement. USDA locations at State universities are required to use that university's radiation safety program. This occurs only when the university and the USDA have a specific agreement in place that allows the university to control radioactive materials and x-ray producing equipment. Individuals who wish to perform cooperative research with universities should discuss the requirements with the Radiation Safety Office at the university and the USDA Radiation Safety Staff.

Categories of Permits

The USDA Radiation Safety Staff issues Radiation Source Permits in five general categories. Applications for permits can include more than one category, and may address a specific research or program requirement that is outside of the categories listed. The five most common categories of permits issued are:

- General Radioactive Materials

General Radioactive Materials covers general research and program activities involving unsealed radioactive materials and small sealed sources.

Requests for human studies, large animal research (such as cows, sheep, swine, and horses), greenhouse studies, and field applications where an environmental release of radioisotopes may occur are also covered under this category. Individuals should discuss the requirements for these research activities with the USDA Radiation Safety Staff.

Categories of Permits, Continued

- Moisture/Density Gauges

Moisture/Density Gauge applications apply to the use of portable nuclear gauges used to measure the moisture content and density of soils and asphalt.

- Electron Capture Detectors

Electron Capture Detector (ECD) applications apply to the use of detector cells containing radioactive materials to aid in the analysis of chemical compounds. ECDs are used in conjunction with gas chromatographs.

- Self-Shielded Irradiators

Self-Shielded Irradiators are used within USDA for irradiation studies of lower animals, insects, plants, seeds, chemicals, infectious agents, and agricultural products, and for sterile insect release programs.

- X-ray Producing Equipment

X-ray producing equipment applications covers all devices that emit x-rays. This includes a wide range of equipment types such as:

Medical and dental x-ray units;

Cabinet x-ray units;

X-ray diffraction units;

Baggage X-ray units;

Electron Microscopes; and

Bone Densitometers.

How to Apply for a Permit

Based on the research or program requirements, various combinations of forms need to be completed and submitted to the USDA Radiation Safety Staff, after review by the LRPO and location management. These are described in detail below.

- Radiation Worker Registration

The Radiation Worker Registration (Form RSS-10) provides the personnel information required by the Radiation Safety Staff to review an individual's training and experience and to determine if that individual meets the minimum requirements to become an independent authorized user of radiation sources. These requirements are defined in the radioactive materials license possessed by the USDA.

Specific training requirements are described in Section 5.2.

This form must be completed by the individual applying to become a Permit Holder and by all other individuals who will work independently as Associate Users under the Permit Holder's authorization. This form must be completed whether or not an individual is likely to receive a radiation dose. It is needed to track individuals who are participating in the radiation safety program.

- Application to Use Radiation Producing Sources

The Application to Use Radiation Producing Sources (Form RSS-20) provides the address information needed to allow contact with the Permit Holder and provides for the review and approval of the application by Location and Agency Management, if required by Agency policy.

This form must be completed by the individual applying to become a Permit Holder and must be included in all applications.

How to Apply for a Permit, Continued

- Application for Radioactive Materials Use

The Application for Radioactive Materials Use (Form RSS-21) allows the Permit Holder to list the radioisotopes, physical forms, chemical compound, and activity to be possessed. The rooms where the materials will be used, analyzed, and stored are listed on this form as are the radiation detection instruments to be used by the Permit Holder to survey for fixed and removable contamination and for sample analysis.

Small sealed sources can be listed on this form. A Sealed Source Inventory Record (Form RSS-28) must be completed for each source listed.

A general research protocol is needed for typical laboratory research applications. However, if the scope of the research involves human research, large animal research, or the potential release to radioactive materials to the environment as part of a field study, significant additional information must be submitted to the Radiation Safety Staff for their review. Individuals are encouraged to discuss these applications with RSS prior to their formal submission.

All applications must describe how radioactive waste will be managed. The applicant is encouraged to discuss their research program with the facility's Location Radiation Protection Officer (LRPO) to determine if the waste management resources available at the facility meet their needs. Current restrictions on the disposal of low-level radioactive waste in the United States make waste management a critical point in the review process.

The applicant is also required to commit to several program requirements. These requirements point out several critical areas relating to safety and regulatory compliance.

A Continuation Sheet (Form RSS-21a) is available if additional radioisotopes and compounds need to be listed on the application.
 

Summary of Forms Required

In summary, an individual wishing to apply for a permit to conduct general research using unsealed radioactive materials will need to complete the following forms:

- Radiation Worker Registration (Form RSS-10)

- Application to Use Radiation Producing Sources (Form RSS-20)

- Application for Radioactive Materials Use (Form RSS-21)

- Application for Radioactive Materials Use

Continuation Sheet (Form RSS-21a) (if required); and

- Sealed Source Inventory Record (Form RSS-28) (if required).

- Application to use Moisture/Density Gauges

Individuals applying to use nuclear gauges must complete an Application to Use Nuclear Gauges (Form RSS-22).

A diagram of the permanent storage area must be submitted for review.

The applicant is also required to commit to several program requirements. These requirements point out several critical areas relating to safety and regulatory compliance.

In addition, a Sealed Source Inventory Record (Form RSS-28) must be completed for each gauge to be possessed.

Summary of Forms Required

In summary, an individual wishing to apply for a permit to use nuclear moisture/density gauges will need to complete the following forms:

- Radiation Worker Registration (Form RSS-10)

- Application to Use Radiation Producing Sources (Form RSS-20)

- Application to Use Nuclear Gauges (Form RSS-22) and

- Sealed Source Inventory Record (Form RSS-28).

- Application to use Electron Capture Detectors

Individuals applying to use electron capture detectors must complete an Application to Use Electron Capture Detectors (Form RSS-23).

A diagram of the permanent storage area must be submitted for review.

The applicant is also required to commit to several program requirements. These requirements point out several critical areas relating to safety and regulatory compliance.

In addition a Sealed Source Inventory Record (Form RSS-28) must be completed for each ECD to be possessed.

Summary of Forms Required

In summary, an individual wishing to apply for a permit to use electron capture detectors will need to complete the following forms:

- Radiation Worker Registration (Form RSS-10)

- Application to Use Radiation Producing Sources (Form RSS-20)

- Application to Use Electron Capture Detectors (Form RSS-23) and

- Sealed Source Inventory Record (Form RSS-28).

- Application to use Self-Shielded Irradiators

Individuals applying to use Self-Shielded Irradiators must complete an Application to Use Self-Shielded Irradiators (Form RSS-24).

A diagram of the irradiator use or storage area must be submitted for review.

The applicant is also required to commit to several program requirements. These requirements point out several critical areas relating to safety and regulatory compliance.

In addition a Sealed Source Inventory Record (Form RSS-28) must be completed for each irradiator to be possessed.

Summary of Forms Required

In summary, an individual wishing to apply for a permit to use Self-Shielded Irradiators will need to complete the following forms:

- Radiation Worker Registration (Form RSS-10)

- Application to Use Radiation Producing Sources (Form RSS-20)

- Application to Use Self-Shielded Irradiators (Form RSS-24) and

- Sealed Source Inventory Record (Form RSS-28).

 Application to use X-ray Producing Equipment

Individuals applying to use x-ray producing equipment must complete an Application to Use X-ray Producing Equipment (Form RSS-25).

The applicant is also required to commit to several program requirements. These requirements point out several critical areas relating to safety and USDA program compliance.

In addition a X-ray Producing Equipment Inventory Record (Form RSS-29) must be completed for each x-ray unit to be possessed.

Summary of Forms Required

In summary, an individual wishing to apply for a permit to use x-ray producing equipment will need to complete the following forms:

- Radiation Worker Registration (Form RSS-10)

- Application to Use Radiation Producing Sources (Form RSS-20)

- Application to Use X-ray Producing Equipment (Form RSS-25) and

- X-ray Producing Equipment Inventory Record (Form RSS-29).

Submitting Permit Applications for Review

- New and Renewal Applications

All new and renewal applications must be reviewed by the location LRPO and by location management. A space is available on the application (Form RSS-20) for management concurrence.

After management concurrence, the application package is forwarded to RSS.