Radiation Safety Manual

Introduction

Radiation Generating Equipment and Radioactive Materials

Miami University is authorized to procure, use, store, and dispose of radiation-generating equipment (RGE) and radioactive materials (RAM) on the Oxford campus by registration and under a broad scope type B materials license, respectively, issued by the Ohio Department of Health (ODH). The registration and license are administered through a university radiation safety program to ensure that:

  • Operators of RGEs and users of RAM are qualified by training and experience, have the facilities and equipment for safe handling and storage, and establish a protocol that offer an acceptable level of protection.
  • Safety standards established or referenced by regulatory agencies relevant to RGEs and RAM are observed.
  • Records of the receipt, storage, use, transfer, and ultimate disposal of all RGEs and regulated RAM at Miami University are maintained.
  • Monitoring of personnel and property for ionizing radiation is conducted.

Miami University is subject to periodic inspections by the ODH. Inspections are thorough and include the review of user qualifications, laboratory inspection results, area survey and personal monitoring results, and procurement and disposition records. Violations can result in a variety of regulatory actions with the most severe being the revocation of our registration and/or license.

Why Ionizing Radiation Is Regulated

Ionizing radiation is among the most versatile and useful tools of physical science research. However, like many other instruments of science, ionizing radiation is potentially harmful to human health and the environment unless used with strict adherence to safety rules and procedures.

Regulations and procedures governing equipment and materials that emit ionizing radiation have been developed to protect the health and safety of exposed and potentially exposed individuals. Exposure to ionizing radiation can result in biological damage to current as well as future generations. Compliance with established rules and procedures will minimize potential radiation exposures to well below established regulatory levels.

As Low As Reasonably Achievable (ALARA) Philosophy

Whereas radiation safety is a shared responsibility, individuals approved to operate RGEs and use RAM at Miami University are held accountable for their actions and for failure to comply with established rules and procedures through the radiation safety program. Practices and techniques that reduce potential and expected radiation exposures to levels As Low As Reasonably Achievable (ALARA) are expected and include: minimizing duration of exposure, establishing a reasonable distance from a source, and provision of shielding; control of personnel access into and around a controlled area; proper ventilation; use of trays or plastic-backed absorbent liners; and the use of gloves, lab coats, and eye protection. The ALARA philosophy is stated in the U.S. Nuclear Regulatory Commission (NRC) regulation 10 CFR 20.1101.

The Radiation Safety Manual

The Miami University Radiation Safety Manual (RSManual) describes rules and procedures for the procurement, use, storage, and disposal of RAM at Miami University. It is designed as a regulatory reference and training tool and is based on the terms of the ODH Materials License Agreement with Miami University. All federal, state, and local codes and regulations expressed in this manual are available for review through the Radiation Safety Office (RSOffice). Any questions or clarifications regarding this manual or radiation safety, in general, should be directed to the Radiation Safety Officer.

It should be noted that specific rules and use procedures addressing RGEs are not contained in this manual; however, procurement requirements, operator information and training, RGE inventory, general information regarding devices, and disposition procedures are contained herein. Contact the RGE Supervisor of the RGE in question for specific information.

The RSManual focuses on RAM issues in research and teaching at Miami University unless specifically noted to include RGEs. Requirements pertaining to the healthcare x-ray unit are not addressed in this manual.

Program Management

The ultimate responsibility for RGE and RAM management and regulatory compliance lay with the President of Miami University. The Certifying Official representing the President is the Senior Vice President for Finance and Business Services or designee who serves as the senior management representative in all matters of radiation safety.

Three primary groups participate in the radiation safety program (RSProgram) and have varying degrees of management responsibility. They are the Radiation Safety Committee, Radiation Safety Office, and Approved Users/RGE Supervisors. A management tool integral to the success of the RSProgram, with respect to RAM, is the Radiation Safety (yellow) Binder maintained by each Principal Investigator (PI) in their primary laboratories. Many of the RSProgram records and references as they relate to the day-to-day activities of PIs in research laboratories are maintained in a radiation safety binder. The participatory groups and binder are addressed below.

Radiation Safety Committee

The Radiation Safety Committee (RSC) is appointed by and reports to the President of Miami University. At minimum, membership of the RSC shall consist of:

  1. The Senior Vice President for Finance and Business Services or a designated representative.
  2. A representative for academic departments that operate RGEs.
  3. Representatives from each of the academic departments deemed major users of RAM.
  4. A representative from the Office for the Advancement of Scholarship and Teaching.
  5. A representative from the Office of Purchasing
  6. The Radiation Safety Officer (RSO). Business brought before the RSC including the authorization of Approved Users and approval of proposals for RAM use require a quorum. A quorum is defined as the RSC Chair, RSO, the technical committee member representing the department from where the proposal originated, and any other committee member whose field of expertise may be necessary to address pertinent safety matters.

Minutes of all RSC meetings shall be recorded and distributed to RSC members and to the University Secretary (upon RSC approval). The RSC has dispensed with the reading of the minutes and are automatically approved two weeks after distribution of the draft. Meetings shall be held as often as necessary to conduct business (e.g., quarterly).

The RSC addresses RGEs and RAM used in research and teaching endeavors. Requirements pertaining to the healthcare x-ray unit are not addressed by the RSC. The functions of the RSC include:

  1. Approving local regulations pertaining to the operation of RGEs and use of RAM at Miami University. Local regulations are rules and procedures more stringent than ODH regulations and are addressed in this manual.
  2. Reviewing periodic activities of the RSProgram to ensure the adequacy of the current management control system to include:
    • RSOffice records.
    • Routine reports from the RSO.
    • Results of laboratory/user inspections.
    • Material use protocols.
    • Procedure addressing the procurement, inventory, and transfer of RAM.
    • Possession limits.
    • Monitoring results.
    • Disposal activities.
  3. Granting Approved User status, approving use proposals, and approving facilities prior to installation of controlled areas.
  4. Reviewing training and testing criteria for each worker classification.
  5. Considering methods for maintaining records of committee proceedings and safety evaluations of proposed users, protocol, and facilities.
  6. Reviewing the RSManual as necessary to ensure proper program management, education of persons working with RAM, and good health physics practices.
  7. Specifying and approving permissible revisions to the ODH material license application without notification to the regulatory agency. These revisions include:
    • Rule changes dictated by ODH.
    • Changes in internal management forms.
    • Members of the RSC except those specifically listed on the material license.
    • Specific dates.
    • Changes in contractors for bioassay, waste disposal, dosimetry, or for the servicing or calibrating equipment.
    • Changes in percentage of total waste disposed by disposal method.
    • References to specific equipment.
  8. Reviewing and approving RAM training courses for staff and students.
  9. Administering the RSProgram through the RSO.

Radiation Safety Office

The RSOffice provides a variety of administrative and technical services designed to achieve compliance with the ODH Materials License agreement and with rules and procedures established by the RSC. The RSOffice is a function of the Environmental Health and Safety Offices (EHSO), and is staffed by the RSO and trained professional staff responsible for RSProgram management.

The RSO acts on decisions made by the RSC and has the authority to immediately stop a procedure involving RAM or an RGE if, in the opinion of the RSO, it is unsafe to continue. The RSO shall direct the RSOffice in the following activities:

  1. Determine compliance with the ODH materials license, RSC rules and procedures, and the conditions of use proposals specified by the RSC.
  2. Monitor all activities involving RAM including routine monitoring and special surveys of all areas in which RAM is used.
  3. Provide radiation safety consultation to personnel at all levels of responsibility.
  4. Supervise the receipt, survey, and release of RAM packages arriving and the packaging and shipping of all RAM leaving Miami University.
  5. Supervise the distribution of personnel monitoring equipment and determine the need for bioassays. Monitor personnel exposure and bioassay records. Notify individuals and their supervisors of unusual exposures and recommend appropriate remedial action.
  6. Conduct and/or supervise training programs that present RSProgram procedures for the use of RAM.
  7. Supervise and coordinate the radioactive waste disposal program.
  8. Monitor the storage of RAM not currently in use.
  9. Perform or arrange for leak tests on sealed sources.
  10. Schedule the calibration of radiation survey instruments.
  11. Maintain an inventory of all radioisotopes and ensure that individual and total quantities are in accordance with amounts authorized by the current materials license.
  12. Terminate any activity found to be a threat to health or property.
  13. Supervise significant decontamination and recovery operations.
  14. Supervise maintenance of radiation safety program records in accordance with the current regulatory requirements.

Approved User/RGE Supervisor

Approved User status is granted by the RSC based on training and experience. It carries responsibilities that include procurement, storage, and use of RAM and other sources of ionizing radiation in their research. Approved Users are expected to provide the day-to-day supervision of students and staff under their direction and radiation safety training (RSTraining) specific to their research. A Principal Investigator (PI) is a faculty member with Approved User status who has one or more radioisotope use proposals approved by the RSC. PIs are held accountable for managing the RSProgram as it relates to their research and for maintaining records in the radiation safety binder.

RGE Supervisor status is granted by the RSC based on training and experience. RGE Supervisors are expected to provide the day-to-day direct supervision of students and staff under their direction and radiation safety training (RSTraining) specific to their research.

Radiation Safety (Yellow) Binders

Radiation safety binders (referred to as Yellow Binders) are maintained in primary use laboratories where RAM is used. They are an important management tool that links PI activities with RSProgram management. A Yellow Binder is provided to each PI and must be kept in the primary use laboratory in a location where it may be located without obstruction (on a desktop or in an open bookshelf, not in a drawer or cabinet). Each Yellow Binder contains information and records regarding the users, isotopes, and monitoring conducted in the primary and secondary laboratories. Each binder contains:

  1. Radiation Emergency Procedures - This information is a reprint of the Emergency Procedures section in this manual for easy access in the event of a release or fire involving radiation. It is provided on laminated card stock for protection and easy decontamination.
  2. Isotope Use Records - When radioisotopes are released to a PI by the RSOffice, an Isotope Use Record (IUR) used for inventory control accompanies the package. Upon receipt, the PI places the IUR in the Yellow Binder. It is used by the PI and the RSOffice for inventory control and inspection purposes. (See Isotope Use Record).
  3. Wipe Tests - A floor plan diagram of rooms where RAM is used and the Controlled Area Wipe Testing Record is maintained for compliance and inspection purposes. Note that although printouts of liquid scintillation counter results must be kept on file for three years, the RSOffice may request that any printouts stored in the Yellow Binder for more than a 90-day period be removed by the PI for archiving. (See Wipe Testing for Removable Contamination).
  4. Approved Protocol – Copies of all proposals approved for use in the laboratory by the RSC are available for reference and review. Originals are maintained by the RSOffice.
  5. Certifications - Applications/Certifications of individuals who work with RAM in the laboratory must be readily available for verification. Certifications are mailed to the PI for placement in the Yellow Binder. Anyone who handles RAM in any manner or is in a controlled area but does not have a certification on file must be identified to the RSOffice immediately. Their actions could place Miami University in violation of our material license agreement.
  6. Inspection Reports - The RSOffice suggests that PIs file their Inspection Reports in the Yellow Binder.
  7. Radiation Safety Updates - Periodic updates used to disseminate changes made to the RSManual as well as information relative to federal, state, and local regulations that complement the RSManual. The PI is responsible for ensuring that his/her staff and students review each RSUpdate before posting it in the Yellow Binder.
  8. Miscellaneous - Reserved for future use. May be used to file isotope manufacturer quotes, isotope reference sheets, etc.
  9. Miami University Radiation Safety Manual.

Actions in response to Non-Compliance

Compliance is defined as meeting or exceeding current mandates of ODH, agreements made as part of our material license application and subsequent amendments, and local regulations established by the RSC. Although non-compliant conditions or acts do not always result in a written violation from the ODH, they reflect the RSC’s ability to maintain effective management control through the RSProgram at Miami University. It is important to note that the procurement and use of RGEs and RAM are not a right but a privilege granted by the regulatory agencies. The non-compliant conditions or acts of a single user can jeopardize our entire program through monetary penalties, restrictions imposed by ODH, or a revocation of our equipment registration and/or material license. Therefore, accountability within the RSProgram is imperative to protect that privilege for everyone.

Non-compliance is typically reported to the PI in writing via a quarterly inspection report (see Semi-annual Inspection Report) with a copy to the appropriate RSC departmental representative. Inspections involving RAM are conducted quarterly and RGE inspections are conducted semi-annually. A summary of each inspection is provided to the RSC and a verbal report made at each RSC meeting. If necessary, items of non-compliance are discussed for clarification.

Actions taken by the RSC in response to non-compliance should be interpreted as a demonstration of management control of the RSProgram and as an effort to maintain accountability among the users. Non-compliance with inspection report items 1, 2, 4, 5, and 9 are in direct violation of ODH regulations and shall result in the following actions if they occur within a period defined by two or more consecutive inspections or within an academic year, whichever is most restrictive:

  • 1st Occurrence - The inspection report will serve as written notification to the PI and respective RSC departmental representative. No further action will be taken.
  • 2nd Occurrence - A memo from the RSC Chair addressing the repeat violation and the corrective action required of the PI shall be issued. If no response is received from the PI by the specified date, the violation will be elevated to a 3rd occurrence violation.
  • 3rd Occurrence - Termination of all protocol and possible RSC expropriation of RAM. Use restrictions and/or reporting assignments may be placed on RGE operators.

Notifications of violations at all levels of occurrence may be contested in writing to the Chair of the RSC by a PI. The RSC will review the details of the alleged violation and the written appeal. Prior conditions and acts of non-compliance will be taken into consideration. If the violation is deemed valid, the violation will stand but may be downgraded to a local violation (LV, a violation of Miami University regulations that are more stringent than ODH regulations). Alleged violations successfully contested will be removed from the record and a response written to the PI.

The remaining items on the inspection report and other regulatory issues (e.g., personal dosimeter exchange, survey meter calibration, protocol updates) demonstrate management control while assisting users and the RSC in their compliance efforts. Non-compliance with those items/practices and other safety and health issues (e.g., food and drink in laboratories) shall be handled on a case-by-case basis. Repeat occurrences and patterns of non-compliance may be interpreted by ODH as a breakdown in management control and, therefore, may result in actions described above.

Radioactive Material Users

User Definitions

Refer to Radiation Generating Equipment Operators and Devices for information regarding equipment operator definitions and responsibilities.

Approved User

Approved User status may be granted to faculty, students at the graduate level or above, or unclassified staff who have met the minimum training and experience requirements established by the RSC. Requirements for Approved User status are:

  1. A baccalaureate degree in the physical or biological sciences or in a discipline where radiological health is addressed.
  2. Training in RSProgram practices and procedures with at least 40 hours of experience in radiation physics and instrumentation, radiation protection, related mathematics, and radiation biology. The types and forms of RAM used in the past will be compared with the expected research at Miami University when determining status approval. (See Statement of Prior Training and Experience for Approved User Status).
  3. Completion of Miami University’s Radiation Worker Training Course and a passing grade of at least 80 percent on the written test.
  4. Approval of the RSC.

Other Approved User responsibilities may include:

  1. The day-to-day supervision of Radiation Workers under their direction and direct supervision of any guest faculty, student, staff, or visitor not recognized by the RSProgram who enters a room where RAM is used or stored.
  2. Providing performance-based and other RSTraining specific to their research.
  3. Providing direct supervision to a Radiation Worker until confidence in his or her abilities and understanding of applicable rules and procedures have been achieved.
  4. Maintaining records, logs, and other documentation as required by the RSProgram.

Principal Investigator

Only a faculty member with Approved User status may become a PI—an individual having one or more approved protocol granted by the RSC. the PI status carries with it an increased level of accountability including direct responsibility for aspects of RSProgram management as it relates to the approved protocol (e.g., recordkeeping, wipe testing, inventory, security, quarterly inspection requirements).

Radiation Worker

A Radiation Worker is any person engaged in activities related to research and development that involves the procurement, handling, use, or disposal of RAM. A Radiation Worker must:

  1. Complete the Miami University Radiation Worker Training Course and achieve a passing grade of at least 80 percent on the written test.
  2. Work under the supervision of an Approved User.
  3. Receive performance-based training conducted by an Approved User. Individuals are encouraged to document that training as it can be used toward Approved User status.

Short-term Radiation User

An individual expecting to work at Miami University for one academic year or less and whose activities in controlled areas will be limited in scope may seek status as a Short-Term Radiation User. User certification may be extended beyond one year as determined by the Radiation Safety Officer and the Principal Investigator. Short-term Radiation Users shall:

  1. Complete an abbreviated Radiation Safety Course and achieve a passing grade of at least 80 percent on the written test.
  2. Receive performance-based training conducted by an Approved User. Individuals are encouraged to document this training as it can be used toward Approved User status.
  3. Work under the supervision of an Approved User.

The Short-Term Radiation User status does not lead to Radiation Worker or Approved User status. While Short-term Radiation Users may perform experiments involving RAM in a research environment, responsibilities for radiation monitoring, maintenance of recordkeeping, and ordering RAM shall not be delegated to those individuals.

Student Radiation User

A student in a controlled academic laboratory (classroom) environment that may handle microcurie quantities of RAM under the direct supervision of an Approved User is considered a Student Radiation User. The purpose of this status is to permit instruction and demonstration of safe RAM handling techniques with limited handson opportunities for the student. Radiation safety training will be provided by the Approved User(s) associated with the course.

Ancillary Staff

Ancillary Staff are employees or contractors of Miami University who do not handle or use RAM but have the potential for exposure given the nature of their support function. Ancillary Staff shall be provided a level of training necessary to gain an understanding of the possible radiation hazards associated with their respective job functions and to safely perform their assigned duties.

User Responsibilities - General

All persons engaged in activities involving RAM are responsible for the safe use of materials in their possession. At a minimum and when applicable, every user must:

  1. Keep exposures as low as reasonably achievable (ALARA).
  2. Wear the prescribed monitoring equipment (i.e., personal dosimeters) in controlled and radiation areas.
  3. Survey hands, shoes, and body for radioactivity and remove all loose contamination before leaving a controlled area.
  4. Utilize all appropriate protective measures to include:
    • At a minimum, wearing easily removable protective clothing–a lab coat is most common. Do not wear protective clothing outside the laboratory. Note that street clothes are not considered protective clothing.
    • At a minimum, wearing disposable gloves. Remove gloves before leaving a controlled area. Always presume the gloves being worn are contaminated unless you have demonstrated otherwise.
    • At a minimum, wearing eye protection appropriate for the hazard (e.g., a splash hazard requires chemical splash goggles).
    • Using protective shields and other physical barriers whenever possible.
    • Using mechanical devices to reduce distance and exposure (e.g., tongs).
    • Using mechanical pipetting devices. Never pipette by mouth.
    • Using a laboratory hood or certified biological safety cabinet that has been commissioned for use of radioactive materials if an inhalation hazard exists.
    • Using the minimum quantity of radioactivity relative to the objectives of the protocol.
  5. Prohibit smoking, eating, drinking, and applying cosmetics in laboratories. Laboratory space includes any office areas, work desks, or work stations within a room listed on an approved protocol.
  6. Prohibit the use of refrigerators/freezers in laboratories for the storage of food and drinks intended for human consumption.
  7. Maintain good personal hygiene. This includes:
    • Keeping fingernails short and clean.
    • Avoiding all work with RAM if there is a break in the skin below the elbow.
    • Wash hands and arms thoroughly before handling any object which goes to the mouth, nose, or eyes.
  8. Monitor the controlled areas for contamination at least once each day RAM is used. A record of these surveys and results should be maintained. Removable contamination must be reduced to less than 200 counts per minute (cpm) above background. A contaminated area greater than 2000 cpm should be decontaminated immediately and the RSO notified.
  9. Practice good housekeeping.
    • Keep controlled areas as separated from non-radioactive work areas as possible.
    • Work areas should be free from equipment and materials not required for the immediate procedure.
    • Store and transport RAM in a manner that prevents breakage and spillage (e.g., tube holders in a tray) while ensuring adequate shielding.
    • Use plastic-backed absorbent paper in a tray or pan to contain a potential spill.
  10. Isolate and label equipment used in conjunction with RAM. This equipment shall not be used for other work nor shall it leave a controlled area until it has been demonstrated to be free of contamination.
  11. Request RSOffice supervision of any emergency repair involving equipment that is contaminated or contains RAM. At no time shall servicing personnel be permitted to work on equipment in controlled areas without the supervision of an Approved User.
  12. Immediately report any incident of inhalation, ingestion, or injury involving RAM to the PI and to the RSO. An individual shall cooperate in any and all attempts to evaluate an exposure and shall carry out prescribed corrective measures.
  13. Prevent the spread of contamination to other areas in the event of a release and carry out decontamination procedures.
  14. Comply with RSOffice requests for body burden measurements. This may involve a whole body counter or urine samples for radioassays.

Approved User Responsibilites

Approved Users are accountable for the actions of users under their supervision and for:

  1. Adequate planning. Before RAM can be procured, an Approved User must determine the types and amount of radiation or RAM to be used in a well-defined procedure. An evaluation shall be conducted by questionnaire, experimental plan, and written protocol review and submitted to the RSOffice for RSC approval (see Evaluation of Proposed Uses and Facilities). A rehearsal, or “dry run” is recommended and may be required to identify any unexpected circumstances before a procedure is actually performed with radiation. The RSO is available for consultation in the preparation of the proposal.
  2. Training. Approved Users must instruct all users under their supervision in safe techniques and the application of approved radiation safety practices.
  3. Requesting the addition and/or deletion of personal dosimeters for users under their supervision through the RSOffice.
  4. Requesting RAM waste drums through the RSOffice.
  5. Furnishing the RSOffice with current information regarding individuals in their areas.
  6. Contacting the RSOffice whenever changes in operational procedures, new techniques, and facility alterations are anticipated. Approval by the RSC may be required prior to implementation.
  7. Contacting the RSOffice prior to an extended absence from the laboratory. This may require appointing another Approved User or PI to assume responsibility for laboratory management or temporarily deactivating experimental protocols.
  8. Complying with the rules, procedures, and regulations governing the use of RAM as established by Miami University, ODH, other applicable governmental agencies having jurisdiction.
  9. Following the procedures for the procurement of RAM by purchase or transfer (see Procurement).
  10. Posting areas where RAM is stored or used or where radiation areas exist.
  11. Recording the use and disposal of RAM.
  12. Consigning solid radioactive waste to the RSOffice for disposal.
  13. Restricting the use of a RAM to RSC-approved users.
  14. Keeping quantities of stored RAM to a minimum and in controlled areas.
  15. Maintaining adequate records as required by the RSC.
  16. Complying with the procedures for employee resignation or termination.
  17. Shipping all RAM through the RSOffice.
  18. Promptly returning personnel monitoring devices to the RSOffice.

Radiation Generating Equipment Operators and Devices

Operating Definitions

RGE Supervisor

RGE Supervisor status may be granted to faculty/staff that have met the minimum training and experience requirements set forth by the RGE manufacturer and/or the department operating the equipment. The RGE Supervisor oversees and coordinates RGE operations and maintenance to ensure appropriate and safe usage. Additionally, the RGE Supervisor serves as a conduit for communications between the RSO (and the RSCommittee) and the RGE users in matters concerning RGE operations, inspections, and safety.

The Radiation Safety Committee departmental representative from the department housing the RGE nominates the RGE Supervisor for approval by the Committee. The RGE supervisor should be an RGE User who has sufficient knowledge, experience, and administrative authority to reasonably assure safety, oversight, and control of the RGE(s).

RGE Supervisor responsibilities may include:

  1. Develop training programs for RGE Users-in-Training.
  2. The day-to-day direct supervision of RGE Users-in-Training under their direction and direct supervision of any guest faculty, student, staff, or visitor not recognized by the department who enters a room where RGEs are used.
  3. Providing performance-based and other RSTraining specific to the RGE being used until confidence in a RGE User-in-Training abilities and understanding of applicable rules and procedures have been achieved.

RGE User

Faculty, staff, or students that have met the minimum training and experience requirements set forth by the RGE manufacturer and or the department operating the equipment and have been authorized by the RGE Supervisor to use specific RGEs independently.

RGE User in Training

Faculty, staff, or students unfamiliar with RGEs and who are receiving instruction and hands-on training will be considered RGE Users-in-Training. An RGE User-in-Training must work under the direct supervision of a RGE Supervisor.

Ancillary Staff

Ancillary Staff are employees or contractors of Miami University who do not operate RGEs but have the potential for exposure given the nature of their support function. Ancillary Staff shall be provided a level of training necessary to gain an understanding of the possible radiation hazards associated with their respective job functions and to safely perform their assigned duties.

RGE Supervisor Responsibilities

RGE Supervisors are accountable for the actions of RGE Users and RGE Users-in-Training under their supervision and for:

  1. Adequate planning and safe operation of RGE under their authority.
  2. Providing instruction to RGE Users-in-Training.
  3. Requesting the addition and/or deletion of personal dosimeters for users under their supervision through the RSOffice.
  4. Returning personnel monitoring devices to the RSOffice promptly.
  5. Furnishing the RSOffice with current information regarding individuals in their areas.
  6. Contacting the RSOffice whenever changes in operational procedures, new techniques, and facility alterations are anticipated. Approval by the department operating the RGE may be required prior to implementation.
  7. Complying with the rules, procedures, and regulations governing RGEs as established by Miami University, ODH, other applicable governmental agencies having jurisdiction.
  8. Following the procedures for the procurement or disposal of RGEs by purchase or transfer.
  9. Posting areas where radiation areas exist.
  10. Restricting the operation of RGEs to RGE Users or RGE Users-in-Training.
  11. Maintaining adequate records, logs, and other documentation as required by the RSC.

RGE Users Responsibilities

RGE Users are accountable for the proper use and safe operation of RGE(s) and for:

  1. Adequate planning and safe operation of RGE under their authority.
  2. Complying with the rules, procedures, and regulations governing RGEs as established by Miami University, ODH, and other applicable governmental agencies having jurisdiction.
  3. Notify the RGE Supervisor if unsafe conditions exist or of unauthorized use.
  4. Maintaining adequate records, logs, and other documentation as required by the RSC.

RGE Supervisors, Users, and Users-in-Training Responsibilities - General

All persons engaged in activities involving RGEs are responsible for the safe use of devices in their possession. At a minimum and when applicable, every user must:

  1. Keep exposures as low as reasonably achievable (ALARA).
  2. Wear the prescribed monitoring equipment (i.e., personal dosimeters) in radiation areas.
  3. Utilize all appropriate protective measures.
  4. Prohibit smoking, eating, drinking, and applying cosmetics in laboratories.
  5. Prohibit the use of refrigerators/freezers in laboratories for the storage of food and drinks intended for human consumption.
  6. Maintain good personal hygiene.
  7. Practice good housekeeping.
    • Keep areas of operation clearly identified.
    • Work areas should be free from equipment and materials not required for the immediate procedure.
    • Store and transport x-ray generating tubes in a manner that prevents breakage.
  8. Request RGE Supervisor for any emergency repair involving any RGE.
  9. Immediately report any incident of exposure to the RSC departmental representative and to the RSO. An individual shall cooperate in any and all attempts to evaluate an exposure and shall carry out prescribed corrective measures.

Radiation Generating Equipment Devices

Table 1 - Radiation Generating Equipment and RGE Supervisors
Device Location Department RGE Supervisors
GE Proteus x-ray equipment Student Health Service x-ray Rebecca Rader
Contact Karan Krammer
Scintag X1 Powder Diffractometer 46 Shideler Hall Geology John Rakovan
Amy Wolfe
Mark Krekeler
Bruker APEX Diffractometer
Serial # 002142
48 Shideler Hall Geology Chemistry John Rakovan
Bruker AXS Micro Star
Serial # 2964
22 Hughes Hall Chemistry Chemistry Michael Kennedy
Shuisong Ni
Bruker D8 Quest
Serial # 209671
42 Hughes Hall Geology John Rakovan
Minishot M@%NH
Serial # 14892
064 EGB Paper Science Steve Keller
Thermo Scientific Niton XL3t 955
Serial # 89304
46 Shideler Hall Geology Jason Rech

Current list as of 09/20/2016

X-ray Diffraction

X-ray diffraction machines are designed for and regulated as analytical devices. The mode of operation for x-ray diffraction involves a primary beam from an x-ray tube emerging through a collimator, striking a sample, and measured by a detector. This radiation chain is fully contained in a shielded, fail-safe cabinet sometimes referred to as cabinet radiography. The diffraction of x-radiation from sets of planes within a crystalline sample, typically a single-crystal on the order of 100 microns in size (single-crystal diffractometry) or a powdered sample (powder diffractometry), provides an examination of the macroscopic structure of materials by nondestructive methods.

The primary beam in x-ray diffractometry is highly-collimated. In conjunction with the shielded and interlocking cabinet, x-ray diffraction machines are inherently safe and, therefore, do not present a radiation hazard when properly operated. However, Approved Operators are required to maintain utilization logs. Operators may be instructed to wear personal monitoring and conduct and record radiation surveys.

Electron Microscopy

Electron microscopy (EM) encompasses a wide variety of technologies in which a coherent beam of electrons is used to generate a magnified image of a specimen. The two most common types of electron microscopes are transmission and scanning electron microscopes (TEM and SEM, respectively). In general, EM involves the following process:

  1. Free electrons are generated via a thermionic source (tungsten hairpin filament or a single LaB6 crystal) or via a hot or cold field emission effect
  2. Free electrons are collated into a coherent beam via an electrostatic lens
  3. Collated beam is accelerated through a single step linear accelerator (100 eV to 40 KeV for an SEM and 40- 200, KeV for a TEM. Higher accelerations use two stages)
  4. Beam is focused via a series of electromagnetic lenses onto the specimen.

In a TEM, the majority of electrons pass through the specimen and strike either a phosphorus screen, a photographic film plate, or a CCD array where they produce an image. In an SEM, the electron beam is focused to a fine point which is rastered across the specimen to produce a variety of signals generated via electron-electron, electron-proton interactions. These signals are detected with differing types of detectors and are displayed on a CRT rastered in sync with the beam raster.

Since an electron beam in EM will only travel about 6 mm before degradation, the microscopes are operated under a high vacuum. Various safety interlocks prevent the operation of an electron microscope without a vacuum which are in place to prevent damage to the microscope and not the operator.

The radiation exposure potential is from the excess photon emissions. X-radiation is produced with an energy range of about 1 eV to 35 KeV while the electron microscope is in operation. Shielding is inherent in the design of the microscope–massive copper and iron electromagnetic lenses and the brass and stainless steel framed construction requirements of a high vacuum environment. SEMs are completely enclosed with these materials. TEMs have a phosphorescent viewing screen which is viewed through a uranium-doped glass view port.

Health Care Radiology

Provided for information purposes only. A fixed diagnostic xray unit is maintained and operated by the Student Health Service. No individual shall be permitted to hold patients during exposures except during emergencies. If a patient must be held by an individual, that individual must be protected with appropriate shielding devices positioned so that no part of the body, except hand and arms, will be struck by the useful beam. The primary beam must be collimated to a field size no greater than the size of the image. Exposure techniques for procedures are posted in or near the control booth. Techniques employed in diagnostic radiological examinations shall be selected to provide the required information with a minimum dose to the patient. Recommended operating techniques are posted on the radiographic unit.

Radiation Safety Training

Training is in accordance with Ohio regulation (reference NRC 10 CFR 19.12) and at a level based on past training, experience with the use of RAM, and the type of work to be performed. In order to effectively train individuals having a wide range of education and experience, courses and awareness programs are structured accordingly. Emphasis is placed on performance-based training for persons supervised by Approved Users. Ancillary staff shall be provided a level of training necessary for them to gain an understanding of the possible radiation hazards associated with their respective job functions and to safely perform their assigned tasks.

Radiation Worker Training

Anyone planning to use RAM at Miami University must successfully complete the online Radiation Basics modules and attend the 2-hour Radioactive Materials Class offered by the RSOffice once each month. Following successful completion of these courses, individuals will be granted the status of Radiation Worker. Radiation Worker Training is the only course that will lead to an Approved User status.

Web-based Radiation Basics modules

This course is designed to provide a basic understanding of radiation through completion of the following six computer training modules:

  • Radiation Properties
  • Background Radiation
  • Biological Effects
  • Regulations
  • External & Internal Dose Limits
  • Radiation Monitoring

Following completion of the Radiation Basics training modules, participants must successfully complete the online Radiation Basics Test before attending the Radioactive Materials Class.

Radioactive Materials Class

This course addresses the details of RSProgram management and the control of RGEs and RAM at Miami University. User definitions and responsibilities, procurement procedures, recordkeeping, radiation surveys, emergencies, and waste management will be presented. A multiple choice/short answer take-home test will be distributed at the end of the course and requires a passing grade of 80 percent or better. If tests are not returned within ten days of distribution, the student may be required to attend Radioactive Materials Class the following month and a new test completed.

Student Radiation User Training

Students will receive specific practical instruction and education in radiation safety as part of approved academic coursework. All aspects of instructional training, material handling through disposal, monitoring for contamination, and recordkeeping will be the responsibility of the Principal Investigator under an experimental plan approved by the RSC. This user category does not lead to a Radiation Worker or Approved User status.

Radiation Safety Awareness

Persons working in laboratories and other areas where RGEs and RAM are located are encouraged to attend this one-hour awareness program designed to provide attendees with an appreciation for radiation safety. This program does not lead to a Radiation Worker or Approved User status.

Continuing Education

The RSOffice will disseminate radiation safety information through a periodic newsletter titled RSUpdate. This document is intended to inform the user community of regulatory changes that have not been integrated into the RSManual and of other information related to the operation of the RSProgram and the safe handling of materials. Distribution will be to all PIs and members of the RSC. It is the responsibility of each PI to inform all users under his/her supervision of this information. Ancillary Staff will be provided refresher training as required.

Radiation Generating Equipment Training

Training requirements are specific to the type of RGE. The State of Ohio requires that any operator of a health care radiographic unit be licensed through ODH. Training is provided by RGE Supervisors for all other devices. Table 1 reflects the RGE Supervisors relative to the RGE under their authority at Miami University.

Analytical Devices

X-ray diffraction units at Miami University are categorized by ODH as industrial analytical devices once referred to as cabinet radiography. Prior to operating a device, an individual must meet with the RGE Supervisor for training specific to each device. That training can lead to RGE User status or RGE Supervisor status granted by the RSC. At minimum, an RGE User-in-Training must:

  1. If applicable, read NRC Regulatory Guide 8.13, Instruction Concerning Prenatal Radiation Exposure. The guide provides information to women who become pregnant to help them make an informed decision regarding their choice to formally declare their pregnancy in accordance with regulations.
  2. The User-in-Training must successfully complete Miami’s Web-based Radiation Basics modules. The RGE Supervisor is responsible for contacting the RSOffice to verify this training has been completed.
  3. Participate in performance-based training. A User-in-Training must receive instructions for use and a demonstration of the safe use of the device. The User-in-Training must then become familiar with the operation of the device and demonstrate a competent degree of familiarity in the presence of an RGE Supervisor.
  4. Operate the device under the direct supervision of the RGE Supervisor until a level of competence is achieved and RGE User status is granted.

Electron Microscopy

Users are provided training prior to the operation and use of an electron microscope. Users receive direct supervision during operation; however, unsupervised access may be granted after successfully passing a practical examination.

Health Care Radiology

For informational purposes only. 

The operation of the x-ray unit at the Student Health Service is under the strict authority of the certified X-ray Technician on duty. Operators must complete the required course of study relative to their practice and possess a radiological license from ODH.

Performance-Based Training

Training that provides instruction or develops a person’s proficiency using a task-based approach and objectives written with an action verb is commonly defined as performance-based training. Students prove competency to an Approved User/RGE Supervisor by the actual performance of defined objectives. Performance-based training is commonly practiced in the laboratory environment; however, it is typically offered informally and without documentation by Approved Users/RGE Supervisors. Although not required, the RSOffice encourages documentation of performance-based training to enhance an individual’s records.

Control of Procurement and Use

General Use Procedures

The following procedures address use requirements expressed by regulation and are applicable to all aspects of registered RGEs and/or licensed RAM at Miami University.

Proper Marking of Work Areas and Equipment

  1. A “RADIOACTIVE MATERIAL USED IN THIS ROOM” sign placed at the entrance of rooms where one or more specific areas within the room are labeled and used as controlled areas.
  2. A “CAUTION RADIOACTIVE MATERIAL” sign or equivalent label tape shall be conspicuously placed in controlled areas where RAM is being stored or used.
  3. Containers in which materials are transported or stored shall bear a durable, clearly visible label having the radiation caution symbol and the words “CAUTION RADIOACTIVE MATERIAL” or equivalent label tape. This labeling shall reflect the isotope and activity in the container, the date of assay, and the Isotope Use Record (IUR) number for reference to the corresponding form.
  4. Controlled areas and locations around RGEs and RAM may be defined as radiation areas—locations where radiation levels could expose individuals to 5 millirems at 30 cm in any one hour or a dose in excess of 100 millirems in any five consecutive days from any surface through which radiation penetrates. Radiation areas shall be posted with a “CAUTION RADIATION AREA” sign.
  5. Disposal sinks shall be demarcated with RAM label tape and a sign posted designating the sink is suitable for the disposal of radioactive isotopes.
  6. All equipment contaminated with RAM shall be marked with radiation signs, decals, tape, or by other conspicuous means. Labeling is not required for laboratory containers such as beakers, flasks, or test tubes used in laboratory procedures if those containers are in the controlled area or in the possession of trained personnel at all times and if those items are decontaminated immediately following the procedure.
  7. Signs and labels referred to in this part, with the exception of RAM label tape, are available through the RSOffice. All signage posted by the RSOffice must not be removed except under the direction of the RSO.

Shielding of Sources

Radiation sources shall be shielded in such a manner that the radiation levels in any unrestricted area will not expose individuals more than 2 millirems in any one hour. 

Beta Radiation

Beta radiation can penetrate through the following shielding materials: 

  1. Air (easiest to penetrate)
  2. Water
  3. Plastic
  4. Concrete
  5. Glass
  6. Aluminum
  7. Iron
  8. Lead
  9. Copper (hardest to penetrate)
Gamma Radiation

Gamma radiation can penetrate through the following shielding materials:

  1. Water (easiest to penetrate)
  2. Concrete
  3. Steel
  4. Lead (hardest to penetrate)

Aerosols, Dusts, and Gaseous Products

  1. Procedures that generate airborne contamination such as aerosols, dust, or gaseous products shall be conducted in a functioning laboratory hood, certified biosafety cabinet, or other ventilation device approved by the RSOffice.
  2. Incorporate traps into the experimental plan to ensure environmental releases will be as low as possible. All releases from such systems shall not exceed the maximum permissible concentration as defined in 10 CFR 20 Appendix B.
  3. Radioactive gases or materials with gaseous radioactive daughters must be stored in gas-tight containers and stored in areas having adequate ventilation.
  4. The performance of laboratory hoods and biosafety cabinets used for radionuclide work should be certified at least annually.

Sealed Sources

  1. Procurement of sealed radioactive sources must be made through the RSOffice. An amendment to our ODH Material License may be required prior to procurement of the source.
  2. The RSOffice, in cooperation with individual users, shall establish strict accountability procedures when sources are contained within portable units.
  3. Sealed sources shall be leak tested by the RSOffice upon receipt and quarterly thereafter. Sealed sources placed in storage within three months after receipt do not require leak testing until it is removed from storage.

Radioactive Material in Gas Chromatography Equipment

  1. Radioactive foils used in gas chromatography cells must be procured through the RSOffice. An amendment to our Materials License may be required prior to ordering of the source.
  2. Each cell containing a radioactive foil shall be labeled or tagged with
    1. Signage bearing the radiation caution symbol and the words “CAUTION RADIOACTIVE MATERIAL”
    2. The identity and activity of the RAM.
  3. The radioactive foil shall not be removed from its cell.
  4. The following notice shall appear in a conspicuous location on the outside of each gas chromatography unit:
    • “This equipment contains a radioactive source and is registered with the Radiation Safety Office at Miami University. Removing the source or transferring the equipment must be approved by the Radiation Safety Officer prior to removal or transfer”.
  5. Radioactive cells in gas chromatographic equipment shall be vented via an approved exhaust system or approved trap to avoid possible exposure of personnel and contamination of the work area.
  6. Radioactive cells are sealed sources and shall be leak tested by RSOffice personnel prior to initial use and quarterly thereafter.

Work Surfaces

All work surfaces including bench tops, laboratory hoods, and biosafety cabinets should be constructed of non-porous material and designed to contain spills and with decontamination in mind (e.g., one-piece stainless steel with coved corners and edges) in the event of an unexpected release. Cover work surfaces with plastic-backed absorbent paper or equivalent for easier clean-up. It is recommended that storage areas and surfaces adjacent to set-ups and sinks be covered as well. The use of stainless steel or plastic trays, uncracked glass plates, or other impervious containment is encouraged. Always assume plastic-backed absorbent paper, trays, plates, etc. are contaminated. Frequent monitoring or replacement will prevent the spread of radioactive contamination.

Equipment Removal and Repair

  1. Once used in a RAM procedure, equipment shall not be used for other work or be released from a controlled area until it has been demonstrated to be free of contamination by using monitoring procedures outlined in this manual.
  2. Equipment to be repaired by the Central Instrumentation Laboratory, Physical Facilities Department, or by commercial service contractors shall be monitored for contamination as outlined in this manual and shall not be released by the Approved User for service until it has been demonstrated to be free of contamination. If it becomes necessary to make emergency repairs on contaminated equipment, the work will be supervised by the RSOffice to ensure that all necessary safeguards are taken. It is the responsibility of the Approved User to request this supervision from the RSOffice.

Notification of Radiation Generating Equipment Procurement

Prior notification must be made to the RSO that new RGE devices are being procured. An amendment to our ODH equipment registration will be necessary prior to acquisition. Manufacturer name, equipment make/model, tube type, power output, room location, anticipated date of receipt, and expected date of initial operation are necessary to update RSOffice files and to request an amendment.

The RSOffice will work closely with the Approved Operator to expedite compliance with ODH regulatory requirements. Special design and construction materials may be necessary depending on the type of device installed. Seeking consultation through the RSOffice in the preliminary stages of room construction, renovation, and/or equipment acquisition will assist in our compliance efforts and avoid unnecessary delays.

Application for Use of Radioactive Materials

Application must be made through the RSOffice to the RSC prior to any procurement or use of RAM. An Application and Certification for Radiation Worker/Approved User Status form must be acquired from the RSOffice, 58 Hughes Hall. The form provides the following information:

  • Part A – Applicant Data. Information that includes Banner ID number and date of birth is required for the issuance of personal radiation dosimetry devices. It is the responsibility of the applicant to identify the Approved User will be working under so a certification document can be mailed. However, if an Approved User is unknown or undecided at the time of application, that information must be left blank.
  • Part B - Applicant signature certifying receipt and understanding of course content.
  • Part C - RSOffice approval and Approved User status information.

Evaluation of Proposed Uses and Facilities

A written proposal for experiments using RAM shall be submitted to the RSOffice for RSC approval prior to any procurement or use of RAM. A peer review process provides the PI with input from experienced researchers and support staff. The process is important in maintaining RSC management control of activities involving licensed RAM.

Laboratories and other rooms must be commissioned (evaluated and approved) prior to the use or storage of RAM. An evaluation of facilities is conducted by the RSOffice and is based on the activity and form of isotopes to be used and the experiments to be performed. Consideration is given to shielding, containment, area controls, remote handling equipment, and monitoring instruments as they relate to the proposed use. The RSC approves facilities based on a recommendation by the RSO.

Laboratories and other rooms should be released for unrestricted use if the use or storage of RAM is being discontinued in those areas. Released for unrestricted use demonstrates that a room is free of contamination and removes the room from further consideration in the RSProgram.

Proposal for Radioisotope Use

The Proposal for Radioisotope Use at Miami University form provides the RSC information required to conduct a peer review. The original form must be signed by the PI. The proposal (typically referred to as the “protocol”) must be submitted to the RSOffice for distribution and subsequent review by the RSC. The proposal will be dated upon receipt and it will be assigned a unique protocol number. Approved Users are encouraged to consult with the RSO during proposal development. A quorum of the RSC may grant tentative approval until reviewed and final approval is sought at the next RSC meeting. Approved protocol will be maintained by the RSOffice with a copy filed in the PI’s Yellow Binder. The proposal consists of:

  • Part A - Questionnaire. Applicant information, clarifications about facilities and monitoring, and RSTraining course information.
  • Part B - Experimental Plan.
    • Radioactive Material. Isotopes and their chemical form, maximum activities per purchase, and maximum monthly usage must be determined and listed. Note that the activities approved by the RSC may affect procurement. The RSOffice will deny an order if it exceeds maximum activities reflected on an approved protocol.
    • Surveys/Monitoring. The frequency of wipe testing is based on material license agreements, PI preference, and RSC determinations in special circumstances. Minimum frequency of wipe testing is 30 days when one millicurie or less of any RAM is used or disposed of in a 30 day period. If more than one millicuries are used or disposed of in a 7 day period, conduct wipe tests for that period. If isotopes are used that cannot be monitored with a survey meter (e.g., 3H, 14C, 35S, 45Ca), wipe tests are recommended after each use to detect contamination.
      Whole body and ring dosimeters shall be issued by the RSOffice whenever the risk of exposure in one year is ten percent of established limits for an adult or declared pregnant woman (see Table 3). Dosimeters may be issued for lower risks of exposure at the request of the Approved User.
    • Waste Disposal. An estimate of the percentage of radioactive waste streams for each isotope complements management control and helps determine waste drum requirements. Current disposal options include aqueous waste disposal via the sanitary sewer system, storage for decay, and incineration. (See Radioactive Material Waste Management).
  • Part C - Written Protocol. Details of the proposal must be described in a typed document not to exceed three pages and should be written to convince the RSC that the PI will be using RAM safely and in accordance with applicable regulations. The written protocol should include an introduction to and purpose of the research, a step by step process that involve isotopes (expressed in microcuries), rooms/locations that specific processes occur, storage practices, and disposal activities. Safety procedures and equipment must be addressed and protocol must reflect consideration of the ALARA philosophy.

Procurement

Orders of all regulated RAM shall be placed through and approved by the RSOffice. A PI must initiate an order; however, Procurement authorization may be granted to any Radiation Worker on the PI’s research team. The PI must provide the RSOffice with the name of each person authorized to order on his/her behalf.

Each isotope ordered must agree with maximum activities stated in the RSC-approved protocol on file which will be verified by the RSOffice prior to placing an order. Information necessary to place an order includes the isotope, its chemical form, and amount; manufacturer and catalog number; purchase order number; and RSC-approved protocol number. That information shall be entered onto an Isotope Order and Receipt Form by the RSOffice for inventory control and recordkeeping purposes. Orders shall be submitted to the RSOffice by one of the following procedures:

  1. Miami University Requisition - Requisitions for RAM procurement must be initiated by the PI and forwarded to the RSOffice for approval prior to submission to Purchasing. (NOTE: The Manager of Academic Procurement will only honor requisitions or limited purchase orders (LPOs) for RAM that have been approved by the RSOffice)
  2. Telephone Orders - Orders can be made through the RSOffice by telephone. As a necessary measure of control, only the PI or member of his/her research team on the procurement authorization list may place an order.

Splitting Orders Between Principal Investigators

A cost savings can sometimes be realized when multiple units of RAM are ordered or a volume is split between two or more PIs. While that is an acceptable practice, only one PI can place the order. Therefore, a split shall be approached as a transfer of material. The process must be approved by the RSOffice prior to placing the order (see Transfer of Equipment or Material). Coordination by the RSOffice is necessary to maintain inventory control of RAM.

Receipt and Distribution of Packages

All radioisotope packages shall be delivered directly to the RSOffice by common carrier for inspection and processing during normal business hours. Although highly unusual, special circumstances that would necessitate delivery of a package at another time shall be coordinated by the RSOffice. The integrity of the package and its contents shall be verified and control of the RAM shall be maintained by the RSOffice until released to the PI or member of his/her research team on the procurement authorization list.

The RSOffice shall conduct the following receipt and distribution procedures:

  1. The RSOffice shall monitor the package for radiation and radioactive contamination upon receipt. The wipe testing procedure requires opening of the package. The PI or a member of his/her research team on the procurement authorization list is notified that the package is ready for pick-up. An Isotope Use Record will be provided with the package.
    • Until its has been demonstrated that the package is free of removable contamination, gloves shall be worn when handling a package.
    • Packages are inspected for signs of leakage and damage.
    • Contents shall be compared with the packing slip.
    • Package surfaces shall be surveyed as appropriate to ensure that external radiation and contamination limits are not exceeded pursuant to current regulations.
    • Wipe testing shall be conducted to determine removable contamination on the exterior and interior of the package and on the exterior of the pig or packaging containing the RAM.
    • Results of package monitoring are maintained by the RSOffice.
  2. The PI or a member of his/her research team on the procurement authorization list is notified that the package is ready for pick-up. An Isotope Use Record will be provided with the package.
  3. Contaminated shipping containers and packaging materials shall not be disposed as regular trash; however, all RAM packages are surveyed and wipe tested prior to release by the RSOffice and have been demonstrated to be free of removable contamination. Upon receipt of a RAM package, the research group must: If a contaminated package is suspected, immediately isolate the package and contact the RSOffice.
    • Immediately remove the shipping pig that contains the RAM (by end of business day) from the shipping container.
    • Remove all dry ice and dispose accordingly.
    • Remove or deface all labels and language referencing radioactive material. Only then may the container and packaging material be discarded as regular trash.
      If RAM is not removed and the container is used for storage beyond the pick-up date, the container and packing materials are presumed contaminated. Wipe testing must then be conducted by the PI prior to disposal to demonstrate that the package is not contaminated.
  4. If a contaminated package is suspected, immediately isolate the package and contact the RSOffice.

Isotope Use Record

An Isotope Use Record (IUR) is an inventory and tracking document that will accompany each radioisotope package distributed by the RSOffice. The responsibility for the maintenance and correctness of each IUR issued lies with the PI. Inventory of that material is maintained by the RSOffice. An IUR might not be issued if RAM 1) is used only for its radiation attributes, 2) is not to be removed from its original container, and 3) volume will not change.

The IUR is designed to track the amount of isotope that is in use, in storage, decayed, disposed via the sanitary sewer (via an approved hot sink), discharged as gases to the air, and has been placed in a radioactive waste drum for eventual pick up and disposal by the RSOffice. Each IUR will reflect a unique isotope number and general information identifying the PI and isotope ordered. All transactions must be recorded in microcuries. Indelible ink must be used.

The following is a brief explanation of how the IUR is used.

  1. Date - Identifies each IUR transaction.
  2. A blank that may be used for noting discharged gases to air, container volume, or for calculation.
  3. Decayed - Calculated decay of material currently in use and in storage only. Do not decay any isotope that has been disposed via the hot sink or placed in a radioactive waste drum; however, decay should be calculated and recorded at that time, if applicable. Decay must be calculated and recorded at least monthly or every half-life, whichever is longer. The sum of the column provides the total isotope decayed.
  4. In Use - Activity of isotope that has been removed from the original container and is currently in process or is being held for eventual hot sink disposal or placement in a radioactive waste drum. Accumulating and storing radioactive waste in a small bag or jar (e.g., in a laboratory hood) with the intent of placing the waste in a radioactive waste drum or disposing it down the drain when a waste container is full is an efficient and acceptable practice; however, waste accumulating (e.g., in a hood) is not yet disposed and must be calculated as isotope In Use for inventory control purposes. Only the last transaction should reflect current isotope In Use.
  5. Unused - Activity of unused isotope in the original container. Only the last transaction reflects current isotope In Storage.
  6. Sewer - Activity of aqueous waste isotope disposed via the hot sink. Accumulated and stored waste prior to hot sink disposal is considered isotope In Use (see In Use above). The sum of the column provides the total isotope disposed via the hot sink.
  7. Drum - Activity of solid waste placed in a radioactive waste drum. Accumulated and stored waste prior to placement in a drum is considered isotope In Use (see In Use above). The sum of the column provides the total isotope placed in a drum.

The accuracy of RAM inventory is a dynamic process and is primarily dependent upon the PI’s timely maintenance of the IUR. Furthermore, the RSProgram database is most accurate when the PI promptly completes and returns the IUR to the RSOffice when all RAM has been depleted, disposed, or placed in a radioactive waste drum.

Transfer of Equipment or Material

A materials transfer is defined as the conveyance of RGE or RAM to a person or organization authorized by a regulatory agency to receive said material or equipment. Any materials transfer shall be approved by and coordinated through the RSOffice prior to its implementation. The splitting of isotope orders as described above under Procurement shall be considered a materials transfer.

Security and Control of Radioactive Material

A controlled area is identified for storage, use, and disposal of RAM and may include bench tops, laboratory hoods, refrigerators/freezers, and cold rooms. Access to those areas is not restricted except by security and control measures practiced by RAM users. A wide variety of people not certified as Radiation Workers have access to laboratories and to controlled areas—delivery persons, technical staff, colleagues, friends, and family. Responsibilities for security and control of RAM lay primarily with the PIs who use them. Although the RSProgram requires the use of an IUR for inventory purposes that can assist in the control process, physically securing RAM in the laboratory and controlling access to it can only be achieved by the user.

Three levels of security and control have been established and will deter unauthorized persons from accessing RAM at Miami University:

  • Lock the door - Locking the door to the laboratory limits access to the room to those individuals having a key. It is understood that others have key access (e.g., department personnel, maintenance); therefore, locking the door is considered the lowest level of security and control.
  • Lock the refrigerator/freezer or utilize a lock-box - A good line of defense against unauthorized access is keeping RAM in a locked refrigerator/freezer. If refrigerator/freezer access must be provided to others in a laboratory, the use of a durable lock-box that can be stored in the refrigerator/freezer is acceptable.
  • Line-of-site view of RAM - The best method of security and control is having a clear view of the laboratory, your RAM, and who is entering and leaving the area.

The above steps do not address deliberate acts by persons familiar to you. Contact the RSO and University Police if you suspect theft or contamination of a suspicious nature. Be proactive. Approach and challenge anyone you do not know who enters your laboratory or contact University Police for assistance.

Radiation Monitoring

Monitoring for radiation involves surveying and wipe testing of rooms where RAM is used or stored, surveying radiation areas, and personal dosimetry. The timely maintenance, calibration, and turn-around of associated equipment and dosimetry helps minimize the potential spread of removable contamination (RAM) and radiation exposures (RGE and RAM). Surveys and wipe testing shall be conducted by the PI. Semi-annual surveys and wipe testing, monthly and quarterly personal dosimetry, and annual calibrations shall be conducted/coordinated by the RSOffice.

Surveying for Radiation

Surveying areas for radiation can identify the need for additional shielding of sources or can locate areas that require decontamination. Surveys shall be conducted at a the minimum frequency identified in Part B of the applicable RSC-approved protocol and as specified by RGE regulations. Note that monitoring with a survey meter does not take the place of wipe testing.

  1. Each PI approved to use applicable isotopes (e.g., P32, P33, I125) shall purchase and maintain a portable or semi-portable survey meter approved by the RSO (see Monitoring Equipment and Devices).
  2. Care should be taken to prevent the contamination of the survey meter. Always presume contamination. Avoid placing the meter in any controlled area or using the meter with gloved hands. Covering the probe window with a low density plastic wrap that can be easily removed and disposed will protect it against unexpected contact with contaminated surfaces.
  3. Surveys shall be conducted using generally accepted practices. At minimum, the survey meter probe window should be held about one inch from the surface being monitored and a 2 seconds per foot traverse used.

Survey Meter Operations Check

Prior to each daily use, a survey meter must be checked against a radiation source for verification of operation.

  1. Check battery level. Follow manufacturer’s instructions for this check and, if necessary, for replacing the battery.
  2. Locate the calibration label on the meter and determine the check source level in mrem/hr or cpm. If no calibration label is present, contact the RSOffice.
  3. Set the function switch of the meter to read the expected level. If unsure, begin at a higher multiplication setting to avoid pegging the needle.
  4. Hold the probe window up to the check source attached to the meter and measure the radiation level.
  5. If the level is not within 20 percent of the expected measurement, the survey meter should not be used. Contact the RSOffice.

Wipe Testing for Removable Contamination

Wipe testing surfaces demonstrates radiation control, provides evidence of good laboratory technique and, provides the RSOffice an opportunity to review housekeeping practices. Wipe tests shall be conducted at a the minimum frequency identified in Part B of the applicable RSC-approved protocol and should be conducted as often as necessary to verify that controlled areas are within acceptable limits of removable contamination.

While background levels are desirable, ALARA levels have been established at 200 net counts per minute (~210-350 dpm, depending on machine counting efficiencies). Contamination above 200 counts per minute (cpm) requires decontamination and a follow-up wipe test to demonstrate that the desired levels have been achieved. If contamination is 2000 cpm or greater, follow procedures as above and inform the RSOffice the following business day. Areas, where contamination cannot be reduced to below 200 cpm, must be demarcated and the RSOffice contacted the following business day.

Wipe testing procedures are as follows:

  1. Develop a floor plan diagram of your room and identify wipe testing locations (e.g., bench tops, fume hoods, refrigerators/freezers, hot sinks). Include the floor where RAM is used and one location where you would not expect contamination (e.g., keyboard, telephone, door knob). Minimum locations will be established in concert with the RSO when establishing or modifying RAM use in a laboratory. Attach to back of wipe test tab separator.
  2. Swab or wipe a representative 100 cm2 area where RAM is used.
  3. Prepare an unwiped swab as a control. Count the blank to determine background radioactivity.
  4. Count the sample for gross counts per minute using a liquid scintillation counter or, if applicable, dry gamma counting methods. For greater accuracy, counting windows may be set for the energy level of the radioisotopes used in the laboratory. Only biodegradable liquid scintillation cocktail may be used.
  5. Record the wipe test results in gross counts per minute on the Controlled Area Wipe Testing Record located behind the Wipe Test tab in the Yellow Binder.

Determining Wipe Test Frequency

Determine the expected level of activity in a given month. If the total expected cumulative activity is less than or equal to 1 millicurie, conduct wipe testing at least every 30 days. If the total expected cumulative activity used is greater than 1 millicurie in a given 7 day period, conduct wipe testing at least every 7 days. If any procedure involves 5 millicuries or more, conduct wipe testing daily until the procedure is complete. Wipe test frequencies approved in Part B of the PI’s RSC-approved protocol that is more restrictive take precedence. For example, if the protocol reflects a 7-day wipe test schedule and the total expected cumulative activity used is less than 1 millicurie, the PI must wipe test and record the results at least every 7 days.

Table 2 - Criteria for Monitoring Radioactive MaterialsSurveys and Wipe Tests
Level of Use Radioisotope Survey(w/GM Meter) Frequency Wipe Test Minimum Frequency
≤1 mCi/month
(total expected cumulative activity)
3H, 14C, 35S No NA* Yes 30 days
32P, 33P, 125I, 45Ca, and others Yes During and after use Yes 30 days
>1 mCi/week
(total expected cumulative activity)
3H, 14C, 35S No NA* Yes 7 days
32P, 33P, 125I, 45Ca, and others Yes During and after use Yes 7 days
≥5 mCi/procedure 3H, 14C, 35S No NA* Yes daily
32P, 33P, 125I, 45Ca, and others Yes Durng and after use Yes daily
In storage 3H, 14C, 35S No NA* Yes Semi-annually
32P, 33P, 125I, 45Ca, and others Yes Semi-annually Yes Semi-annually

* Although a typical survey meter used at Miami University will not effectively monitor 14C or 35S sources, some level dose rate may be measured verifying the presence of a radiation hazard.

Using the Controlled Area Wipe Testing Records

  1. Record the wipe test results for locations that correspond with the floor plan diagram in gross cpm. A background activity must be included. (Note: Although it not necessary to store machine counter printouts in the yellow binder, they must be made available for inspection upon request. Verify that the date and locations on the machine counter printout correspond with the Controlled Area Wipe Testing Record, print the primary room location and machine counting efficiency on the printout, and file it. Those printouts must be kept by the PI for three years after the record has been made and be available for review upon request.)
  2. If gross cpm are above 200 for any given location, take steps to reduce the removable contamination and conduct a follow-up wipe test in that location. Record the former and latter results to demonstrate effort to reduce the contamination. Only those locations exceeding 200 cpm need retesting.
  3. If RAM is not handled, used, or disposed in a given wipe test period or in specific locations as referenced on the form, “NEP” may be entered across the results section or in the specific location(s) cell in lieu of wipe testing, unless otherwise instructed by the RSC. Should the PI not anticipate using RAM for an extended period (i.e. several months) NEP may be entered into the wipe test record in advance. Should RAM use re-start during this period the PI can strike a line through NEP and continue wipe testing. Any handling of RAM can result in some level of contamination requiring wipe testing. The abbreviation NEP, or “No Experiments Performed,” refers to no actions involving RAM.

Note: The Controlled Area Wipe Testing Record is designed to provide the information necessary to calculate wipe test results in gross cpm to dpm. Locate the machine counting efficiency on each scintillation counter. Contact the RSOffice if assistance is needed.

Personal Monitoring Program

In accordance with the ALARA philosophy, personal dosimeters shall be issued by the RSOffice whenever the risk of exposure in a year is 10 percent of established limits for an adult or declared pregnant woman (see Table 3). However, dosimeters are generally recommended and may be issued at the request of the Approved User. Other methods of monitoring radiation exposures shall be instituted by the RSO as required. Personal dosimeters will be processed by a contract service on a monthly or quarterly basis depending on the dosimeter type.

Table 3 - Guidelines for Maximum Permissible Doses (Dose in millirems)
Organ1 Annual ALARA2
Whole Body 5,000 500
Any Organ 50,000 5,000
Lens of Eye 15,000 1,500
Skin 50,000 5,000
Extremities 50,000 5,000
Embryo/Fetus of Declared Pregnant Women 500 50
1 - For information on specific tissues not listed, contact the RSO.
2 - ALARA levels are established at 10% of the allowable limits unless otherwise noted. 

In addition to the above:

  1. Individuals who are exposed to ionizing radiation below the ALARA levels on a regular basis may be issued a personal whole-body dosimeter.
  2. Individuals who handle quantities of RAM greater that 5 mCi on a regular basis may be issued a finger (ring) dosimeter.
  3. Personal whole body dosimeters must be worn exterior to any garment worn, located between the neck and waist, and generally between the person and the source. Finger dosimeters must be worn under a protective glove on the hand that is primarily used to handle or remain in the vicinity of a radiation source.
  4. The RSO will promptly review all exposure reports to identify individuals whose exposure is unexpectedly high or low. This procedure only applies to the dosimetry of record and does not apply to backup dosimeter types (e.g., pocket ionization chambers).
  5. Other individuals who are potentially exposed to radiation on an occasional basis such as emergency response personnel, Physical Facilities Department staff, or departmental support staff will not normally be issued personal dosimeters.

Bioassays

Current and anticipated usage quantities do not require bioassays. Should usage requirements change significantly, appropriate monitoring based on nuclide, quantity, and types of use will be initiated. In the event of incidental exposure, appropriate biosampling will be accomplished through the University of Cincinnati, Department of Nuclear Medicine, Cincinnati, Ohio.

Monitoring Equipment and Devices

Survey meters are most often used for monitoring beta and gamma radiation. A survey meter is a Geiger-Mueller (G-M) counter and probe connected to a count rate meter with a scale reading in R/hr, mrem/hr, or cpm. Each survey meter must be calibrated annually in coordination with the RSOffice. The cost of battery replacement between annual calibrations and any repairs of the survey meter are the responsibility of the PI.

Liquid scintillation counting involves dissolving a sample directly into a solvent media cocktail and counting low energy beta particles that scintillate as they pass through the cocktail. Counts may be calculated to disintegrations based on background radiation and equipment efficiency. Equipment efficiencies are calculated annually by the RSOffice and posted on each unit. The efficiencies are necessary to calculate disintegrations from net counts.

Thermoluminescent dosimeters (TLDs) and film badges are personal monitoring devices that may be provided monthly or quarterly by the RSOffice. Personal dosimetry may be required when a person is working with or in the vicinity of:

  • Beta emitters whose maximum energy is greater than 1 MeV.
  • Gamma emitters.
  • Neutron sources or neutron-generating devices.
  • X-ray generating equipment.

Personal dosimeters are not required by regulation where it has been established by the RSO that exposures cannot exceed 25 percent of the maximum permissible dose. This determination will be based upon the intensity and energy of the radioisotopes used as well as techniques used in and the working conditions of a controlled area. As noted, the conservative approach at Miami University results in the issuance of personal dosimetry more often than required by regulatory requirements.

Emergency Procedures

Minor Spills of Liquids or Solids (typically <100 μCi)

  1. Notify persons in the area that a spill has occurred.
  2. Prevent the spread of contamination by covering the spill with absorbent material (e.g., paper towels). Wear the appropriate personal protective equipment.
  3. Clean up the spill using absorbent paper. Carefully fold the absorbent paper with the clean side out and place in a plastic bag for transfer to the appropriate radioactive waste drum. Place disposable gloves and any other contaminated disposable material in the bag.
  4. Monitor the area as appropriate (survey meter or wipe testing). Check the area around the spill. Check your hands, clothing, and shoes for contamination.
  5. The PI shall follow up on the cleanup of the spill and submit a report addressing spill clean-up efforts and monitoring results to the RSO within 7 days of the incident.

Major Spills of Liquids or Solids (typically ≥100 μCi)

  1. Evacuate if spill is of a volatile material.
  2. For non-volatile materials all persons not involved in the spill should vacate the room.
  3. Prevent the spread of contamination by covering the spill with absorbent material (e.g., paper towels). Survey all personnel who may have been contaminated and immediately remove contaminated shoes or clothing.
  4. Shield the source only if it can be done without further contamination or a significant increase in radiation exposure.
  5. Exit and secure the room.
  6. Inform the PI and the departmental RSC representative as listed on page i of this manual. Contact the RSO. Outside normal business hours, call University Police at 911 to notify the RSO.
  7. Unless you are confident in approaching the clean-up of the contamination at hand, prohibit entry into the room. RSOffice personnel will have authority over the scene when they arrive.
  8. Decontamination of the facility will begin at the perimeter of the spill and proceed toward the center, or higher area of contamination. An appropriate level of personal protective equipment shall be worn. Surface decontamination will be accomplished using soap and water or other response materials appropriate for the chemistry of the spill. Work shall be slow and deliberate with a continuous survey of radiation levels.
  9. The PI (or RSO if present) shall supervise the cleanup of the spill. The PI shall complete a report addressing spill clean-up efforts and monitoring results to the RSO within 7 days of the incident.

Fires Involving Radiation

  1. Pull the fire alarm. Contact University Police at 911 of a fire situation involving a radioactive material at your location and follow building evacuation procedures. University Police will contact the fire department and the RSO.
  2. If the fire is confined and you have received training in the operation of the fire extinguisher, attempt to put the fire out. If the fire is not manageable, evacuate the building and await University Police and the fire department. It is extremely important to the safety of the emergency responders that they be informed of the radiation and/or chemical hazards involved in the fire.

Decontamination

Skin

It is important to follow procedures 1 through 6 in the order they are presented. You should also take care not to abrade or scratch the skin. Avoid spreading contamination, protect uncontaminated areas with tape or plastic, and discontinue any step when less than 5 percent of the surveyed contamination is removed. It is recommended that a skin lotion be applied after decontamination of skin. All materials contaminated during cleanup shall be treated as radioactive waste.

  1. Immediately wash wounds with copious amounts of water. Spread the edges of the wound to permit flushing action by the water. Protect the wound with waterproof bandage.
  2. Gently brush or wipe loose particles from the skin and into a bag or sink. Survey the contaminated area of the skin.
  3. Rinse the area with water and survey the contaminated area of the skin.
  4. Wash with a mild soap and warm water building a thick lather. A soft brush may be used on the skin. Wash fingernails and callused areas of the skin with a stiffer brush. Survey the contaminated area of the skin.
  5. Scrub with a 1:1 mixture of commercial laundry detergent and cornmeal or use an acceptable skin decontamination foam. Survey the contaminated area of the skin. 
  6. If contamination remains, induce perspiration by covering the area with plastic. Then wash the affected area again to remove any contamination that was released by the perspiration.

Ingestion by Swallowing

If the material is not a corrosive, immediately induce vomiting and have the victim drink large amounts of water. Excretion analysis and/or a bioassay may be required to determine the amount of body burden.

Surface and Equipment

  1. Clothing - If levels permit, wash the clothes as usual. Wash water must be below maximum permissible level for sewer disposal. If levels do not permit washing, dispose as radioactive-contaminated waste.
  2. Glassware and laboratory tools - Wash in soap or detergent and water. Monitor wash water and hot sink.
  3. Walls, Floors, and Benches - Wash with soap or detergent and water. Detergents should first be tested on surfaces.

Animal Studies

General Animal Care Instructions

  1. All work must be conducted in accordance with regulations as described in the RSManual.
  2. Animals must be housed in the Animal Care Facility located and in accordance with IACUC standards.
  3. Animals, cages, and used bedding used in conjunction with RAM must be segregated from non-radioactive animals, cages, and bedding.
  4. Animals, cages, and used bedding used in conjunction with RAM shall be presumed contaminated. At minimum, gloves, eye protection, and protective clothing shall be worn whenever animals or cages are handled or bedding is changed.
  5. Bedding used in conjunction with RAM must be collected in a manner determined by the RSO and incorporated into the written protocol for approval by the RSC.
  6. Prior to releasing cages to the Animal Care Facility for cleaning, the PI shall perform a wipe test, record the results in the Yellow Binder, and report the results to the Laboratory Animal Resources Director. Counts above 200 net cpm shall be reported to the RSO prior to cage cleaning. Wipe testing of cage washers after the cleaning process may be necessary.
  7. Cages must be constructed of a material easily decontaminated and approved by the Laboratory Animal Resources Director.
  8. This section, Animal Studies, shall be posted in all rooms used in conjunction with RAM.

Handling Radioactive Animals, Cages, and Bedding

  1. Injections of RAM in animals shall be performed by or under the supervision of a PI in a controlled area.
  2. If volatile RAM is used, work shall be performed in a functioning laboratory hood or certified biocabinet that is mechanically exhausted to the building exterior.
  3. Cages used in conjunction with RAM shall be clearly posted with a “CAUTION RADIOACTIVE MATERIAL” sign or equivalent label tape and with the following information:
    • Name and form of the radioisotope.
    • Amount and activity of the radioisotope injected into each animal.
    • Date of the injection(s).
    • Name and telephone numbers (work and home) of the PI.
  4. The PI is responsible for correct labeling, posting of signs, and the posting of the animal care instructions as stated above.

Waste Disposal

  1. Animal excreta must be treated as radioactive waste.
  2. Radioactive carcasses and dissected parts must be wrapped in absorbent paper, sealed in a watertight bag or container, double-bagged, clearly labeled as radioactive material (see Packaging Instructions), and include the following information:
    • Name and form of the radioisotope.
    • Activity of the radioisotope at time of packaging.
    • Name and telephone number of the PI.
  3. Package animals in double plastic bags using as small a volume as possible. Teeth, bones, claws and other sharp edges must not puncture the plastic bags. Waste shall be appropriately labeled, frozen, and stored by the PI until disposal by the RSOffice.
  4. When possible, radioactive carcasses shall be blended (liquefied) using a blender or garbage disposal and disposed via the sanitary sewer system at an approved hot sink.

Equipment and Material Disposal

Disposal of radiation Generating Equipment

Sale or Transfer

Prior to release of any RGE device, documentation must be provided to Miami University demonstrating acceptance or approval by the governmental regulatory authority administering radiation protection rules for buyer/transferee to receive, possess, or use the device being sold/transferred. Documentation may include, but not be limited to:

  • Copy of license or registration from governmental regulatory authority
  • Copy of relevant regulatory code, rules, or regulation addressing exemption to receive, possess, or use the RGE device being sold/transferred
  • Other governmental regulatory document reflecting allowance or approval to receive, possess, or use the RGE device being sold/transferred. The buyer/transferee must certify in writing that the RGE device and the supplies used in connection with that device will not be installed or placed in operation until all requirements of the buyer's/transferee’s governmental authority have been satisfied.

Disposal

X-ray tubes must be removed from the RGE device and disposed through the RSOffice. Documentation of the disposal will be prepared and submitted as required by regulation. the equipment housing the x-ray tube may be disposed through normal methods after the tube has been removed and disposed through the RSOffice.

Radioactive Material Waste Management

All forms of RAM waste (aqueous, solid, contaminated product) shall be disposed by one of five methods: decay in storage, sanitary sewer system, release to the atmosphere, incineration, contracted licensed broker. Activity and volume limitations are established by federal and state regulatory agencies and by our material license agreement.

General Collection and Storage

  1. Segregate RAM waste from non-radioactive waste. Keep volumes/quantities of waste to a minimum.
  2. Avoid unnecessary accumulation of RAM waste. Decontaminate containers and noncombustible items to background levels for disposal via non-radioactive waste streams. 
  3. Secure and control RAM waste as it remains a licensed material and must not be stored in unsecured areas.
  4. Clearly identify and segregate RAM waste by isotope and from other work in the area.
  5. Maintain RAM waste records. Waste records are subject to inspection by the RSOffice staff and the RSC and will remain a principal item of inspection by regulatory agencies.
  6. Account for all RAM received. Proper waste handling is dependent on waste segregation and adherence to the packaging procedures described below. Handle and dispose of all radioactive waste in accordance with established procedures.

Radioactive Waste Drum System

Radioactive waste drums are color-coded to designate segregated waste streams. Waste drums are lightweight and are delivered ready to use including a plastic double liner with absorbent material to provide appropriate containment for residual fluids that might leak from the waste. The fiber drums and the plastic bags that contain the waste do not provide significant shielding from radiation. Additional shielding may be required depending on the storage location of the drums and the isotope the drums hold for disposal.

Radioactive waste drums are used for decay in storage, incineration, and contracted licensed broker methods of disposal. Drums are delivered to and collected from approved areas through the RSOffice and at the request of a PI.

Color-Coded Drums

Drums are color-coded orange and yellow for easy identification in the laboratories and in storage at the Hazardous Residuals Facility. Each drum is issued a unique ID number for tracking purposes. Yellow drums are used for radioactive-contaminated solid waste containing 3H, 14C, or other isotopes with a half-life of greater than 120 days. The contents of yellow drums will be disposed by either incineration or through a contracted licensed broker. Orange drums are used for radioactive-contaminated solid waste containing 32P, 33P, 35S, 125I, or other isotopes having a half-life of 120 days or less. The contents of orange drums will be disposed by using decay in storage methods.

Packaging Instructions
General

Place solid waste in approved bags tightly sealed with a twist tie or fashion a bundle and tape the waste in absorbent paper about the size of an American football (i.e., a size that can be easily handled with one hand). Labels, tapes, pigs, and any other item containing word or symbol references to “radioactive materials” must be removed or defaced before being placed in a drum. Wadding the tape up into a ball or blackening the label with an indelible marker is acceptable. Instructions for using the type of RAM waste drum issued are provided with each drum.

The following are general restrictions when packaging a RAM waste drum:

  • Remove or deface all labels referencing radiation and radioactive material. Waste in an orange drum is destined for a sanitary landfill. Removing labels, rolling labels up into a ball, or marking out all radiation symbols and the words “RADIOACTIVE MATERIALS”, or similar wording with a black indelible marker are acceptable.
  • No loose waste. All waste must be sealed in smaller bundles or bags for handling and placed inside the double-lined drum.
  • No chemical waste. Flammable and non-flammable solvents (including alcohols), corrosives, and toxic compounds are strictly prohibited. Contact the Environmental Health and Safety Offices for the disposal of chemical waste.
  • No Sharps. Pointed and sharp objects that include pipettes, blades, needles, capillary tubes, microscope slides, and broken glass are strictly prohibited. Decontaminate contaminated glass and metals to background levels and dispose via non-radioactive waste streams.
  • Do not overfill a drum. The drum lid must fit securely and completely on the drum. Drums that are overfilled cannot be stacked for storage and the PI will repack the drum before it is removed from the assigned room.
Orange

Orange drums are eventually stored in the Hazardous Residuals Facility for a period determined by multiplying the half-life of the isotope in the drum by ten (i.e., at least ten half-lives). Although the heat-resistant bags provided by the RSOffice may be used, the waste is not handled in a high hazard situation and any sturdy 1-2 gallon-sized clear plastic bag may be used.

Yellow

Waste in yellow drums is typically disposed through a licensed waste broker but may be incinerated by RSOffice staff. Proper packaging is imperative to the safe handling of the waste during a high-risk operation. The use of high heat resistant bags and the size of the packages greatly reduce the risk to staff during waste incineration. The following are in addition to the general packaging instructions above:

  • Packaging. All waste must be bundled or packaged and sealed in bags. Note: High heat-resistant bags used in packaging waste in yellow drums must be acquired through the RSOffice. a) Place solid waste in high heat-resistant bags provided by the RSOffice and tightly seal with a twist tie or b) bundle waste in absorbent paper about the size of an American football and seal with tape before placing in a drum. Loose waste or use of any other plastic bag in a yellow drum may delay removal of the drum and require repacking by the PI.
  • No glass or foil. The incinerator will not accommodate glass or metals at this time.
Drum Log

Packaged waste that is placed in a drum shall be recorded on a Radioactive Waste Drum Log. When a drum is issued, it is given a unique ID number reflected on the log sheet. The following information shall be recorded legibly on the log and in indelible black ink:

  1. Date the bag or bundle was placed in the drum.
  2. Brief description of the waste (e.g., paper, gloves, pipette tips).
  3. Activity of the bag or bundle. Record the activity in microcuries. DO NOT use the phrase “trace amounts” or mathematical symbols such as approximation (~), less than (<), or greater than (>). A mass balance of inventory must be maintained and the users are in the best position to determine an estimate to the nearest microcurie.
  4. Initials of the individual making the entry.
Drum Pickup and Delivery

Radioactive waste drums are transported by the Environmental Health and Safety Offices. However, the PI must contact the RSOffice to request an empty drum and to request pick-up of a full drum. Before the drum is removed from the area, it will be inspected to verify the following information:

  1. Log entries are complete and legible.
  2. Proper segregation (only one isotope per drum).
  3. Waste has been packaged as described above.
  4. All radiation labels have been removed or defaced from materials with a half-life of less than 120 days placed in the drum.

Radioactive waste drums inconsistent with the procedures described in this section shall be corrected by the PI prior to pick-up of full drums.

Sanitary Sewer (Hot Sink) Disposal

Radioactive water-soluble liquids shall be disposed via approved hot sinks and in amounts not to exceed the recommended permissible quantities indicated in Table 4. Exceedances may be permissible on a case-by-case basis with prior approval from the RSO.

When disposing of small quantities of radioactive water-soluble liquids, carefully pour the liquid directly into the drain so not to pour or splash it onto the gasket between the drain and the sink. Avoid pouring liquid onto the gasket. Decontaminating the gasket is extremely difficult and not always successful. Follow the waste with copious amounts of tap water until monitoring of the drain indicates background levels of radiation.

Large volumes of diluted aqueous waste, such as a tub of contaminated wash water from glassware, should be carefully poured into the sink to avoid splashing and followed with copious amounts of tap water. The sink, surrounding work surfaces, and the immediate area of the floor should be thoroughly washed, rinsed, and monitored for radiation.

Hot sinks are often found contaminated to some degree. Decontamination must be performed as necessary to achieve ALARA levels.

Decay

Storage in Decay waste shall be stored for at least ten half-lives until it has decayed to background radiation levels and below 0.1 microcuries. A survey of the waste will be performed to demonstrate background levels. The contents will be inspected to ensure that all radioactive labeling has been removed. The waste will then be discarded as nonradioactive waste via regular trash. The date of disposal, background radiation, dose rate of waste, model and serial number of the survey meter used, and the name or initials of the responsible person shall be recorded on the Radioactive Waste Drum Log.

Incineration

Radioactive waste may be incinerated at the Steam Plant when boilers are using coal as a fuel source. Combustible waste products contaminated with 3H and 14C are candidates for incineration. The following requirements have been established when incineration of waste is conducted:

  1. Incineration shall be conducted at a time when adequate temperatures and contact time can be ensured (e.g., during the heating season) and shall be coordinated with the Steam Plant Superintendent.
  2. Wipe testing shall be conducted before and after incineration. Monitoring will include the floor where waste was handled, in the respective ash pit, and any other areas or items where contamination is suspected. Ash shall not be released until it has been demonstrated by the RSOffice that the ash is at background levels of radiation.
  3. The handling and incineration of radioactive waste shall be under the direction of the RSO.
  4. Records are maintained by the RSOffice indicating the isotopes and amount of activity per incineration. A dated and signed entry is placed in the Steam Plant log reflecting the isotopes and activity disposed.

Other Waste

De Minimus

De minimus radioactive waste is limited to 3H and 14C in liquid form with an activity of less than 0.05 μCi/mL. Under the supervision of the RSO, de minimus waste may be disposed without regard to its radioactivity.

Impervious materials (e.g. glassware, solid waste) may be disposed in regular trash if:

  1. The material has a background activity as determined with a portable survey meter.
  2. Wipe testing of the material surface reveals less than twice the background count for an alpha or beta emitter.
Animals

Package animals in double plastic bags using as small a volume as possible. Teeth, bones, claws and other sharp edges must not puncture the plastic bags. Waste shall be appropriately labeled, frozen, and stored by the user until disposal by the RSOffice. When possible, radioactive carcasses shall be blended (liquified) and disposed via the sanitary sewer system at an approved hot sink. (See Waste Disposal).

Table 4 - Sanitary Sewer DisposalMaximum Permissible Activities
Isotope1 Max. Activity/Month
3H 5000 μCi
14C 5000 μCi
32P 5000 μCi
55Fe 1000 μCi
33P 1000 μCi
35S 1500 Ci
45Ca 5000 μCi
65Zn 500 μCi
99Tc 500 μCi
125I 500 μCi

Contact the RSOffice for permissible activities of isotopes not listed.

Activities of Radioactive material disposed via the sanitary sewer are consistently well below the allowable monthly average concentration as defined in 10 CFR 20, Appendix B, Table 3. The following equation is used to determine activities of radioactive material that may be disposed via the sanitary sewer by a Principal Investigator in any given month (reference 10 CFR 20.2003(a)(4):

~MPAI = (DD× MAR) ÷ (12 months × PIT)

Where:

MPAI = Maximum permissible activity of isotope that may be disposed via the sanitary sewer system in μCi/Month.

DDI = Ratio of total isotope disposed. 3H = 1; 14C = 1; All other isotopes = activity of isotope sink disposed ÷ sum of all other isotopes sink disposed. 

MAR = Maximum annual releases per isotope category. 3H = 5 curies. 14C = 1 curie, and all other isotopes combined = 1 curie.

PIT = Number of Principal Investigators typically using isotope I in a given year.

I/DDI/PIT/MAC(FY2001): H3/1/5/1 E-2; C14/1/5/3E-4; P32/.99/10/9E-5; P33/.99/10/9E-5; P33/.1/1/8E-4; S35/.1/1/1E-3; Ca45/.1/1/2E-4; I125/.2/2/2E-5