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Radioactive Materials Licensees

Q. My radioactive materials license authorizes use and storage of licensed material at "temporary job sites" within Illinois. What qualifies as a "temporary" job site?

A. A temporary job site is defined relative to a "permanent site" where radioactive material is stored or used under the same license (as referenced in 32 Illinois Administrative Code, Part 331, Appendix A, Category 14). A permanent site is any site where licensed material is stored or used for more than 180 days during any 12-month period. A temporary job site is defined as any location where licensed material is used other than a permanent site.
(Note that if material is stored or used at a temporary job site for more than 180 days during any calendar year, then that site is no longer considered temporary and must be amended to your license as a permanent location.)

Q. How long will it take to get my license? Amendment?

A. This depends on the type of material/use and the quality of the application. In general, for new industrial radioactive material license applications (i.e., fixed or portable gauge) you should anticipate anywhere from 2-4 weeks for issuance. For more complex licenses such as manufacturing or broadscope licenses, it may take 2-6 months for issuance since these applications address a number of complex issues and generally require several rounds of correspondence. Amendments also vary depending on the complexity but generally can be issued much quicker. If the application for amendment is complete and addresses a single aspect of an existing license, these amendments can often be issued in a single day.

Q. Do I still renew my license every five years even though I pay fees annually?

A. Yes. In fact, we offer "expedited" renewals for those facilities that do not implement many procedural changes over the course of the renewal cycle.

Q. What do I need to do to move my facility?

A. Two things must happen as part of this process. You must submit an application for amendment for the new location. These types of requests must be submitted 30 days prior to vacating any premises in accordance with 32 Ill. Adm. Code 340.1310 and should include annotated diagrams of all areas where radioactive material will be used or stored as follows:

A) Specify the diagram scale. (All diagrams should be large enough to easily identify areas of interest within each room, such as use/preparation areas, waste storage areas, package receipt areas, hot sinks, etc.)

B) Indicate the direction of north.

C) Clearly mark or identify all areas adjacent (above, beside and below) to radioactive material use/storage rooms or areas (e.g., offices, hallways, restrooms, outside, etc.).

D) Specify the building, floor, room number and principal use of each room or area.

E) Note the presence of shielding in rooms or areas on the diagram and indicate thickness and composition.

F) Specify any additional radiation safety equipment for rooms or areas such as fume hoods, L-blocks, remote handling equipment, storage and transport containers, source safes, portable shielding, etc.

G) Clearly identify all area(s) assigned for receipt, storage (including waste), preparation and measurement of radioactive material.

H) Specify all pertinent airflow rates and directions, room pressures, filtration equipment and monitoring instrumentation available in rooms or areas in which radioactive material could become airborne.

I) Indicate all lockable doors, storage containers and security measures for all use/storage locations for radioactive material.

You must also remove/transfer of all radioactive material from the current site in accordance with 32 Ill. Adm. Code 340.1320. This should include accountability records of all material and closeout surveys for facilities using numerous radioactive sources or unsealed radioactive material. Generally, this process is handled as a two step amendment that approves both sites initially to allow for the transfer of materials from one site to the next as the first step. The second step includes the submission of closeout surveys/accountability records verifying that the previous site is free of all radioactive materials.

Q. If I am authorized for 32 Ill. Adm. Code 335.7010, can I obtain the new intravascular brachytherapy devices without first having my radioactive materials license amended?

A. No. Since these devices are used in the surgical suite and include numerous operating and safety procedures not addressed by the regulations, an amendment is necessary to allow use in the surgical suite and tie down the operating procedures. The Department also specifically names these devices on licenses so that regulatory updates regarding this new technology can be sent to specific licensees.

Q. Can I fax my response to the Department?

A. Yes. As long as there is a signature on the document.

Q. Can I e-mail my response to the Department?

A. No. Responses must have a signature on the document. However, e-mail can be used to send draft responses for preliminary review to expedite the process.

Q. What is the Recovery and Remediation Fee?

A. The Recovery and Remediation Fee goes into a special "fund" to be used for the recovery and remediation of radioactive materials. This fund would be used when the costs cannot be recovered in a timely manner from a responsible party or available financial assurance.

Q. What is financial assurance?

A. Financial assurance requirements are specific to the quantity and type of radioactive material possessed by the licensee. Financial assurance arrangements are made so that in the event a licensee fails to or is unable to properly dispose of all radioactive material when the license is to be terminated, the department has money to ensure proper disposal. If the licensee properly terminates their license, financial assurance arrangements (such as a certificate of deposit) are returned to the licensee.

Q. Can I get an extension for the time period for my response to a deficiency
letter?

A. Yes, for extenuating circumstances. However, this will only be allowed once during the review period. If you need to extend it again, you must withdraw the request and reapply when you have obtained the required information.

Q. How can I get a list of licensees?

A. You must submit a written Freedom of Information Act request to our Legal Department. You should tailor your request to meet your needs. For example, you may want to request only a specific category of licenses (i.e., medical, industrial gauges, etc.) or a specific location.

Q. Previously I was required to send money in with a request to add additional permanent sites to my license. Is this still true?

A. No. The Department will bill you for the pro-rated annual fees after the license is amended.

Q. Do I need to send in a check with my new license application?

A. No. Please do not send any money with your application. You will be sent a bill for the pro-rated annual fees (based on the date the application is received in the Department) and the first installment of the R&R fee. New licenses will not be issued until all fees are paid in full.

Q. What do I need to do to provide adequate security for my radioactive materials?

A. The department has specific guidelines for providing security of licensed material. Security advisories have been sent to licensses and interogatories on security may appear in responses to licensee's submittals.

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