Introduction And Background Information
For many years NRC (AEC)-licensed activities using by-product materials have been taking place at Michigan Technological University. Early in 1991, the University changed from an NRC broad scope license to one based on the laboratory use of small quantities of by-product material.
The University Radiation Safety line of authority is briefly as follows:
- All use of licensed material is done by or under the direct supervision of Documented Responsible Users (DRU).
- These DRU persons are closely associated with the Radiation Safety Officer (RSO).
- The RSO is both a member of and responsible to the Radiation Safety Committee (RSC).
- The RSO, acting for the committee, reports to the Executive Director of Compliance Integrity and Safety.
- The Radiation Safety Committee and Chair act on behalf of the Michigan Technological University executive management team.
The use of radioactive materials and other sources of ionizing radiation are common techniques of scientific investigation. However, since these ionizing radiation techniques are potentially hazardous, it is necessary to exercise certain precautions.
In order to establish and maintain standards for the utilization of sources of ionizing radiation on the campus and properties of Michigan Technological University, a Radiation Safety Committee, RSC, has been established. The committee is responsible for the radiation safety of all machine sources and the safe use and handling of all radioisotopes. A radiation safety officer who is directly responsible to the RSC helps ensure compliance with University, state, and federal standards with regard to the use of radiation and radiation- producing devices. The committee and the Radiation Safety Officer facilitate the use of radiation and radioisotopes as much as possible for personnel who wish to use radiation for teaching and research.
Some activities of the committee are governed by federal rules and regulations. For example, the procurement of those radioisotopes, which are not generally licensed or otherwise exempt, are governed by regulations under which a license is required.
Such a license has been granted to Michigan Technological University, allowing the procurement of reasonable amounts of selected radioisotopes. License amendments may be requested to cover additional specific nuclides not presently listed on the license. In granting this license, the U.S. Nuclear Regulatory Commission requires that a local safety committee be established to examine and evaluate the individual users with regard to the safety of their operations. At Michigan Technological University, this committee is the Radiation Safety Committee.
Another requirement for obtaining the license is the issuance of a set of rules for the use and handling of radioactive materials. Most applications, and the procurement of radioisotopes, are regulated by NRC. The State of Michigan also has laws which establish regulations on the use and the users of X-ray radiation. Each X-ray producing machine is registered with the State of Michigan and the responsible person is identified on the license.
The Radiation Safety Committee presents in this manual the local procedures and requirements covering all sources of ionizing radiation used on the Michigan Technological University campus or under the responsibility of Michigan Technological University at other locations. The Nuclear Regulatory Commission published its rules and regulations concerning radiation protection in the Federal Register where they became part of the Code of Federal Regulations (10-CFR-part 20).
The State of Michigan's regulations have been published as "Regulations Governing the Use of Radioactive Isotopes, X-Radiation, and all Other Forms of Ionizing Radiation." Copies of both the State and Federal regulation are on file in the Office of Environmental Health and Safety. In all cases, operations shall be undertaken only within the limits of the applicable government regulations.
The RSC holds quarterly meetings (at least 3 per year). They require an annual inventory of all radiation producing devices and biannual inventory of licensed materials on campus.
The Office of Environmental Health and Safety maintains the radiation safety files and provides communication support.
All DRU personnel will have to attend at least one meeting each year with the RSC. The RSC believes this annual forum will help provide for safer operations, aid the exchange of ideas, and reinforce NRC regulations.
Michigan Tech has one NRC License: 21-00278-02, "The use of small quantities of by-product material for lab research." The content of this manual is concerned entirely with license # 21-00278-02.
Radiation Safety Program
Documented Responsible User (DRU)
A Documented Responsible User of radioactive materials (DRU) is a person who has been approved by the Nuclear Regulatory Commission (NRC) as having adequate training and work related experience to use radioactive isotopes licensed under by-product material license No. 21-00278-02 at Michigan Technological University. A DRU is permitted to use only the isotopes, forms, and activities for which they have supplied documentation to the NRC through the Michigan Tech radiation safety officer (RSO). The license lists the specific permission for each DRU by name.
DRU status can be revoked through RSC initiated actions for noncompliance with the following list of duties and responsibilities:
Duties and Responsibilities
- Can prepare a purchase order for a radioisotope using the Michigan Tech NRC license number.
- Upon receiving a radioisotope will perform the necessary opening, inspection and damage, and swipe test for leakage of the containers, and record the information in the log book.
- Will keep a log book of the receipt, use, and disposition of their radioisotopes.
- Will decide on film badge needs and place orders through OSHS.
- Will keep a swipe test log (monthly swipes) if liquid radioisotopes are opened and used in the laboratory. Once each quarter, a signed statement must be filed with the RSC that the tests and records of the prior 3 months are in order.
- Will be familiar with the availability and use of survey instruments (not necessarily stored in each laboratory), and also be specifically knowledgeable about the location and use of the standard test source to confirm that the instrument is in working order. Monthly entries of the testing should be made in the swipe test log book to provide an operational history.
- Will be completely responsible for the waste and storage and final waste disposal aspects of their laboratory work.
- Understands that all work done under his/her DRU status is a responsibility, since only with the NRC approval can another person become a DRU. Therefore, no other person can use licensed material without being under the clear and certain supervision of a DRU. It is a NRC license violation to allow unauthorized persons to act as a DRU.
- Will make sure that all users under his/her responsibility are knowledgeable about radiation safety and will arrange special instruction for them by the RSO as appropriate.
- Knows that during an absence from the university community (out of town) another DRU must serve as the designated substitute if isotope use is to continue.
- Knows that when a laboratory will no longer be used as a radioisotope laboratory, that the laboratory must be tested and certified to be clean by the DRU.
Radiation Safety Committee Program Review Statement Radiation
20.1101 Radiation Protection Programs
- Each licensee shall develop, document, and implement a radiation protection program commensurate with the scope and extent of licensed activities and sufficient to ensure compliance with the provisions of this part.
- The licensee shall use, to the extent practicable, procedures and engineering controls based upon sound radiation protection principles to achieve occupational doses ad doses to members of the public that are as low as is reasonably achievable (ALARA).
- The licensee shall periodically (at least annually) review the radiation protection program content and implementation.
Each year the Radiation Safety Committee will review the annual report from the RSO and each member will sign a statement endorsing the effectiveness of its radiation protection program with regard to the above NRC rule.
Training In The Use Of Radioactive Materials
DRU Associates and Others Using Radioactive Materials
All DRU associates, students, and staff who work with radioactive materials will be trained in the safe use of radioactive materials by viewing the following lecture series on video tape before working with radioactive materials:
Lecture 1: Fundamentals of Nuclear Radiation.
Origin, nature, properties, hazards, interaction with material, effects on living things, shielding, flux, dose, measurements, and dosimentry techniques.
Lecture 2: Nuclear Laboratory Techniques.
Receiving radioactive material, radioactive badges, maintenance of log book, swipe tests, safety precautions when working with radioactive materials, monitoring and disposal of radioactive material, emergency procedures.
Lecture 3: Rules and Regulations.
NRC rules and regulations, individual rights. A videotape, Radiation Protection Standards from Radiological Training Services that addresses these issues will be shown.
All three lectures have been videotaped so that students and staff can view them whenever they want. After attending the lectures, the DRU will provide students and staff with clarifications and for information of more specific procedures to be followed in their laboratory. Students and staff will then sign the statement below confirming that they have received the training and understand the hazards and procedures of working with radioactive materials.
An annual refresher training session will also be attended by the users described above.
Results Of Non-Compliance Issues Detected By Unannounced Inspections
1st Violation: Verbal notification, written form left at laboratory at time of inspection, written notification sent from RSC to the department head.
2nd Violation: Written notification of violation(s) sent to the RSC chairman and to the department head with copies sent to the appropriate Dean.
3rd Violation: Violator called with the department head to the appropriate Dean, possible temporary (or permanent) suspension of permission to use radioactive material.
4th Violation: Permanent suspension of permission to use radioactive material (if not imposed for 3rd violation).
Radioactive Materials Purchase
Only DRU personnel can purchase radioactive material under our NRC license #21-00278-02 and they must follow the following procedure.
- When making out their standard Michigan Tech purchase order they will also complete a purchase approval form, which includes: DRU name, date, current inventory of the isotope being purchased, the waste stored in the laboratory, inventory after the receipt of the proposed purchase, NRC possession limit for this isotope and signature.
- Both the Michigan Tech purchase order and the special form will be sent to the RSO. The RSO will confirm the possession limit will not be exceeded and sign the documents. The RSO will send the Michigan Tech purchase order to the purchasing department, and a copy of the special form to the OSHS. Both the RSO and the OSHS will maintain radioisotope inventory books.
The Michigan Tech purchasing department is free of any concern as to whether or not a radioactive material is being ordered. By the time the purchase order gets to Purchasing, they can freely place the order. All the responsibility for identifying the material as radioactive and filing the information with the RSO is the direct sole responsibility of the DRU.
Laboratory Rules For All Radioisotope Users
- Record isotope usage immediately before use.
- Monitor your work area immediately before use and immediately after use. If you find the area radioactive, the last person to use the area is to clean it.
- You must wear double gloves, a lab coat, and eye protection when working with radioactive material. When working with P-32 or I-125, you should be behind a plexiglass shield and wearing a film badge.
- You may not leave any contaminated materials in the hood. They must be disposed of or cleaned immediately.
- All hybridization reactions which are radioactive must be placed in a tray to prevent leakage.
- Record all liquid waste that you dispose down the sink.
The following rules are mandatory!
General Procedures For Radioisotope Usage
- Read all notices in radioisotope use areas. Plan your experiment ahead of time and don't rush.
- When receiving an isotope shipment, check for contamination of containers, eg. Monitor for P-32, I-125; swipe for S-35, C-14, and H-3, on the inside of secondary container per 20.1906 of 10CFR20.
- Enter radioisotope use in the log book.
- Discarding radioisotope: Empty all primary radioisotope containers, e.g., vials, and
high level solid P-32 and I-125 (active at 10X setting on the Geiger counter) into
the shielded large plexiglass container. Low level solid radioisotope waste (less
than 200 on the 10X setting) should be disposed of in the small plexiglass container.
- Pipette tips etc. should be placed in round plexiglass containers and when they are full transfer them into the large plexiglass container.
- High level P-32 liquid waste should be kept in the bottle designated for this waste. We will store until it decays and then we will dispose of it properly.
- Low level liquid waste may be disposed of through the sink designated as radioactive hot sink bearing in mind that we are allowed to dispose 100 μCi of total isotope/day. Make sure that you flush the sink with a sufficient amount of water to dilute the radioisotope that is being disposed of through the sink, at least 53 gallons/ 100 μCi.
- Before using the hot hood, monitor the hood carefully for contamination. Any contamination should be reported to the DRU. Monitor the hood carefully after you are done. Also, monitor your gloves, pipetman, microfuge, door handles, etc., for contamination. If contamination has occurred, clean it up immediately!
- Enter hot sink usage on appropriate sheets. Clean your glassware from hot sink immediately!
- Use the heat sealer properly. Use setting 3 or 4. Check for contamination of the sealer when you use it for sealing hybridization bags containing "HOT" probe.
- Radioisotope usage should be limited to "hot" hood. If you want to use your bench for any reason, make sure you use benchcoat and proper shielding. Monitor carefully for any contamination before and after use of radioactive materials.
- If contamination is found, clean it up and keep records to prove the clean up.
General Procedure For Swipe Tests
In order to monitor for possible radioactive contamination, every month a survey of various spots in the lab will be done by performing swipe tests. Note the floor plan and the logical spots for swipes. These spots are numbered and should be keyed to the swipe test results.
Procedure For Swipe Tests
- Cut 1 cm. squares of Whatman 3 filter paper and soak them in the biodegradable scintillation cocktail.
- Number scintillation vials corresponding to the swipe test areas of the lab and put 5ml of scintillation fluid in each vial.
- Wearing gloves and using a forceps to hold the filter paper wipe the area and put the filter paper in the corresponding numbered vial.
- Once the swipes are made, count them in the scintillation counter with reference to blank or background. If any of the numbers show contamination, eg., above 100 CPM for 32P, go back to that spot (corresponding to the number on the floor plan) and clean the area properly. After cleaning the area do a re-swipe for that area and count. Repeat this process until the CPM has reached the background.
- After all swipe tests have been completed and all areas tested have reached the background, fill out the table on the back of the floor plan diagram. Put the date, remarks, and sign your name. Swipe test records will be kept in the file.
Note: When you are making a swipe for refrigerators, ovens and incubators, make sure you wipe the handles. Also, when you see a swipe area number in front of a lab bench or hood, you need to make a swipe of the floor in front of the bench or hood.
Radioactive Material Storage And Disposal At Michigan Tech
Radioactive material received at Michigan Tech under license #21-00278-02 must be used, stored, and disposed of according to 10CFR/20 rules. Each DRU has a copy of these rules and is expected to follow all of them. Herein is a summary of the rules specific to Michigan Tech. Licensed material either must be stored until it has decayed for 10 half lives, stored until the day it can be shipped to an approved receiver, or under special conditions, disposed of to the sewer.
Waste Disposal And Storage
Decay in Storage
Material held for decay in storage (must have a half-life less than 120 days), either liquid or solid, must be marked with the following information on the outermost container:
- DRU Name
- Date into Storage
- Planned Date from Storage (after at least 10 half lives)
- DRU Signature on Tag
- Initial Activity
- Dose reading (mr/hr) on contact at the hottest spot on decay start date
- Dose readings on contact and background reading just prior to disposal
Upon removal, the material is considered not radioactive. Each DRU must care for their own generated waste. Storage packaging should provide double barriers, i.e., plastic bags in plastic drums. Keep a log of what goes into each storage barrel.
Solid Waste Without Decay in Storage Potential
Use a well constructed plastic type barrel with a sealable lid, double containment, and a complete understandable log of what is placed into the barrel. The log must include date, quantity (mC or uC) with chemical and physical form like paper towels, pipettes, etc., and signatures of persons placing material into the barrel.
Disposal By Release Into Sanitary Sewerage (20.2003)
A licensee may discharge licensed material into sanitary sewerage if each of the following conditions is satisfied:
- The material is readily soluble (or it is readily dispersible biological material) in water; and
- The quantity of licensed or other radioactive material that the licensee releases into the sewer in 1 month divided by the average monthly volume of water released into the sewer by the licensee does not exceed the concentration listed in Table 3 of Appendix B to 20.1001- 20.2401; and
- If more than one radionuclide is released, the following conditions must also be satisfied:
- The licensee shall determine the fraction of the limit in Table 3 of Appendix 3 to 20.1001-20/.2401 represented by discharges into sanitary sewerage by dividing the actual monthly average concentration of each radionuclide released by the licensee into the sewer by the concentration of that radionuclide released by the licensee into the sewer by the concentration of that radionuclide listed in Table 3 of Appendix B to 20.1001-20.2401; and
- The sum of the fractions for each radionuclide required by paragraph (A), (3), (i) of this section does not exceed unity; and
- The total quantity of licensed and other radioactive material that the licensee releases into the sanitary sewerage system in a year does not exceed 5 curies (185 GBq) of Hydrogen-3, 1 curie (37 GBq) of Carbon-14, and 1 curie (37 GBq) of all radioactive materials combined.
Disposal Of Specific Wastes (20.2005)
A licensee may dispose of the following licensed material as if it were not radioactive:
- 0.05 micro curie (1.85 kBq), or less of Hydrogen-3 or Carbon-14 per gram of medium used for liquid scintillation counting; and
- 0.05 micro curie (1.85 kBq), or less of Hydrogen-3 or Carbon-14 per gram of animal tissue, averaged over the weight of the entire animal.
A licensee may not dispose of tissue under item 2) of this section in a manner that would permit its use either as food for humans or animal feed. The licensee shall maintain records in accordance with 20.2108.