Part Two - Radioactive Materials Use
Three - Radioactive Waste Management
Part Four - Ionizing Radiation-Producing Equipment (RPE)
Part Five - Radiation Exposure Monitoring and Personnel Protection
Part Six - Signs and Labels
Part Seven - Radiological Accidents
Part Eight - New York State Department Of Health Sanitary Code
Chapter 1, Part 16, Ionizing Radiation
10 NYCRR Part 16
Part Nine - New York State Department of Environmental Conservation
Rules and Regulations for Prevention and Control of Environmental Pollution by Radioactive Materials
6 NYCRR Part 380
Part Ten - Reference Material
Part Eleven - Radiation Protection Program Forms
Foreword
Radioactive materials and radiation-producing equipment are highly regulated. Many aspects of acquisition, use, storage and disposal of these materials are subject to government regulation and inspection. The ability of Syracuse University to provide its researchers access to these materials is dependent upon satisfying the requirements of Federal, State and local regulatory agencies.
This Radiation Protection Program Handbook contains Syracuse University policies and procedures as well as applicable New York State Department of Health (NYSDOH) and New York State Department of Environmental Conservation (NYSDEC) regulations. This Handbook is an integral part of the Radiation Protection Program and provides guidance to ensure the safety of University personnel while allowing flexibility in the conduct of research. All work involving radioisotopes and radiation producing equipment must be done in accordance with the policies and procedures established in this Handbook, unless a written waiver has been obtained from the University's Radiation Safety Committee (RSC).
Suggestions for improving the Radiation Protection Handbook should be directed to the Radiation Safety Officer (RSO). Detailed information on regulatory requirements and additional reference materials dealing with radiation protection, radiation measurement and radiation biology are available on loan from the Environmental Health Office (EHO). A list of the references available from the RSO is provided in Part Ten of this Handbook. A copy of the NYS Sanitary Code Chapter 1 Part 16 is included in Part Eight this Handbook.
Return to Table of ContentsStatement of Policy
It is the policy of Syracuse University that all activities involving ionizing radiation shall be conducted in such a manner so as to keep exposure as low as reasonably achievable. Persons involved in such activities must comply with the New York State regulations and all rules and guidelines issued by Syracuse University.
A Radiation Safety Committee has been established following guidelines issued by the New York State Department of Health. The Radiation Safety Committee has the responsibility to provide direction to the Radiation Safety Program, to assure that proper documentation is maintained, to review the program's effectiveness and to determine any changes which should be made. The Radiation Safety Committee is also responsible for resolving questions and issues pertaining to the Radiation Protection Program.
Return to Table of Contents ALARA Statement
Syracuse University is committed to the program described in this Handbook for keeping radiation exposures ALARA (as low as is reasonably achievable). In accordance with this commitment, we hereby describe an administrative organization for radiation safety that will develop the necessary written policies, procedures and instructions to foster the ALARA concept at Syracuse University. The organization will include a Radiation Safety Committee (RSC) and a Radiation Safety Officer (RSO).
To ensure our ALARA commitment, a formal annual review of the Radiation Protection Program will be made. This review shall include reviews of operating procedures, radiation exposure records, inspections and consultations with the Radiation Safety staff and Radiation Safety consultants.
Modifications to operating and maintenance procedures will be made where possible. Improvements and modifications to equipment and facilities will be made where they will reduce radiation exposures at reasonable costs per risk evaluation.
Doses to individuals will be maintained as far below the limits as reasonably achievable and the sum of the doses received by all exposed individuals will also be maintained at the lowest practicable level. However, it would not be desirable, for example, to hold the highest doses to individuals to some fraction of the applicable limit if this involved exposing additional people and significantly increasing the sum of the radiation doses by all involved individuals.
In addition, discharges of radioactive materials to the environment will also be kept as far below the effluent release limits as reasonably possible. Whenever possible, engineering or process controls will be employed to minimize the release of radioactive materials to the environment and radiation exposures due to these releases.
The Radiation Safety Committee will be delegated the authority to thoroughly review the qualifications of each radiation supervisor with respect to the types and quantities of materials and equipment and uses for which he or she has applied to ensure that the applicant will be able to take appropriate measures to maintain exposures ALARA. When considering a new use of radioactive material, the Radiation Safety Committee will review the efforts of the applicant to maintain exposures ALARA. The user should have systematized procedures to ensure the ALARA concept and shall have incorporated the use of special equipment where appropriate in his/her proposed use.
The RSC will also ensure that the user justifies his/her procedures and that doses will be ALARA, both individually and collectively. The Radiation Safety Committee will delegate authority to the Radiation Safety Officer for enforcement of the ALARA concept. The RSC will support the RSO in those instances where it is necessary for the RSO to assert his authority. The Radiation Safety Committee will also encourage all users to review current procedures and policies and develop new procedures as appropriate to implement the ALARA concept.
It will be the duty of the Radiation Safety Committee to evaluate Syracuse University's overall efforts to maintain exposures ALARA on an annual basis. This review will include the efforts of the RSO, authorized users, approved workers and the management of Syracuse University.
Syracuse University stands ready to support and defend the ALARA concept. It is our commitment to provide a safe working environment in regard to the use of radioactive materials and radiation-producing equipment.
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Part One
Program Organization and Training Requirements
Section
1.2 Radiation Safety Officer
1.3 Radiation Supervisors
1.4 Radiation Workers
1.5 Non-Radiation Workers Required to Enter/Work in Radiation Areas
1.6 Training
Return to Table of Contents1.1 Radiation Safety Committee
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The Radiation Safety Committee (RSC) consists of the following: the Radiation Safety Officer (RSO), Sr. Vice President of Business, Finance, and Administrative Services, Vice President of Research and Computing, faculty and staff representatives from laboratories and departments using radioactive material or radiation sources, the Director of Risk Management and the Director of the Environmental Health Office. Prospective members of the RSC are approved by NYSDOH as required in 10 NYCRR Part 16 prior to confirmation.
- Ensuring that all individuals who work with or who may receive a workplace exposure to ionizing radiation have sufficient training and/or experience to enable them to perform their duties safely and in accordance with NYSDOH regulations and the conditions of the University's License.
- Ensuring that all use of radioactive materials and radiation-producing equipment is conducted in a safe manner and in accordance with NYSDOH regulations and the conditions of the License.
- Be familiar with New York State regulations (10 NYCRR Part 16, 6 NYCRR Parts 380 and 381), the terms of the University's radioactive materials License and any information submitted in support of request for the License and its amendments.
- Review the training and experience of all individuals who use radioactive materials or radiation-producing equipment and determine that their qualifications are sufficient to enable them to perform their duties safely and in accordance with applicable regulations and the conditions of the License.
- Review and approve all requests for use of radioactive materials and radiation-producing equipment within the University.
- Be responsible for monitoring the University's program to maintain individual and collective doses as low as reasonably achievable.
- Establish a table of investigational levels for occupational radiation exposure, which when exceeded, will initiate an investigation and consideration of action by the RSO.
- Review semi-annually, with the assistance of the RSO, occupational radiation exposure records of all monitored personnel.
- Establish a program to ensure that all individuals whose duties may require them to work in the vicinity of radioactive material or radiation producing equipment (i.e. security and housekeeping personnel) are properly instructed as required by Section 16.13 of 10 NYCRR Part 16.
- Prescribe special conditions that will be required during a proposed use of radioactive material such as requirements for bioassays, physical examinations of users, special monitoring procedures, etc.
- Review the entire Radiation Protection Program at least annually to determine that activities are being conducted safely and in accordance with NYS regulations and the conditions of the License. The review shall include an examination of records, reports from the RSO, results of NYS inspections, written safety procedures and the adequacy of the University's management control system.
- Recommend remedial action to correct any deficiencies identified in the Radiation Protection Program.
- Maintain written records of all Committee meetings, actions, decisions and recommendations.
- Ensure that the radioactive materials license is amended, when necessary, prior to any changes in facilities, equipment, policies, procedures, personnel, radioactive material and possession limits, as specified in the License.
- Oversee or delegate a sub-committee to oversee the administration of the University's Diagnostic X-ray Quality Assurance Program.
- Be responsible for monitoring the University's program to maintain releases of radioactive materials to the environment as low as reasonable achievable and inaccordance with 6 NYCRR Part 380.
- The Radiation Safety Committee shall meet as often as necessary to conduct its business, but not less than once in each calendar year.
- A quorum shall consist of at least one-half of the Committee's membership, including the RSO and the management representative consisting of either the V.P. for Research and Computing or the Sr. V.P. for Business, Finance, and Administrative Services.
- All issues requiring Committee action, with the exception of applications for use of radiation sources, will be approved or disapproved based on the majority opinion of all members of the Committee. Applications for use of radiation sources will be approved or disapproved based on the majority opinion of the technical members of the Committee only.
- Coordinating the Radiation Safety Committee (RSC) review of the safety evaluations of proposed uses of radioactive material and radiation-producing equipment.
- Overseeing activities involving radioactive material and radiation-producing equipment including monitoring users through routine lab inspections performed at least twice per year and special surveys conducted at the request of the RSC or at the discretion of the RSO.
- Determining compliance with rules and regulations, License conditions and the conditions of project approval as specified by the RSC.
- Overseeing the receiving, opening and delivering of all shipments of radioactive material arriving at the University.
- Assuring that University guidelines and applicable regulations are adhered to in the shipping of all radioactive material leaving the University.
- Maintaining an inventory of radionuclides at the University and limiting when necessary, the quantities of radionuclides to the amounts authorized by the Licensee.
- Supervising, coordinating and maintaining accurate recordkeeping of the radioactive waste storage and disposal program.
- Directing the proper storage of radioactive materials.
- Distributing personnel monitoring devices and arranging for their processing.
- Determining the need for and evaluating bioassays and keeping records of personnel exposures.
- Performing or arranging for calibration of radiation safety-related instruments.
- Assuring the performance of leak tests on sealed sources.
- Conducting training programs and instruction of personnel in the rules, guidelines and regulations regarding the use of radioactive materials and radiation-producing equipment.
- Consulting on aspects of radiation safety to personnel at all levels of responsibility, including laboratory design, shielding and other radiation exposure controls.
- Supervising decontamination when necessary and appropriate.
- Maintaining appropriate records.
- Assuring that efforts are made to maintain discharges of radioative materials to the environment as low as reasonably achievable and monitoring these releases as applicable.
- Reviewing the quality control activities performed with regard to the University's Diagnostic X-ray Quality Assurance Program.
- Investigating personnel exposures in excess of the investigational limits established by the RSC.
- Providing adequate facilities, equipment, instruments, supervision and instructions to control radiation hazards and to comply with the requirements of this Handbook and/or the RSC.
- Submitting requests for approval of all procedures involving the use of ionizing radiation to the RSC. This is accomplished by completing and submitting an "Application For Use of Radiation".
- Maintaining with the RSO an up-to-date listing of areas in which ionizing radiation is stored, used or handled.
- Maintaining with the RSO an up-to-date listing of the names of individuals who may be handling radioactive material or operating radiation-producing equipment, or who may be occupationally exposed to ionizing radiation in his/her laboratory.
- Keeping an inventory of the quantity of radioactive materials and/or the type of radiation-producing equipment possessed.
- Keeping records of disposal of all radioactive material.
- Making periodic radiation surveys of each area in which ionizing radiation is used as required by the RSC.
- Controlling the entry to rooms which are specified as controlled areas, for reasons of radiation protection.
- Informing the RSO of changes in existing work which may increase the radiation exposure or the potential for radiation exposure.
- Providing security against unauthorized removal or use of radioactive materials and/or radiation-producing equipment.
- Ensuring that radiation workers under their supervision wear radiation exposure monitors during periods of possible exposure and that these monitors are stored in an appropriate location.
- Ensuring that radiation workers under their supervision are properly instructed and that this instruction is documented prior to performing any procedure which may involve possible exposure to ionizing radiation.
- Ensuring that all ionizing radiation procedures are conducted in a manner consistent with the University's policy of maintaining exposures as low as reasonably achievable.
- Properly storing, handling, labeling and tracking radioactive wastes generated and stored in their laboratory and emphasizing the importance of waste minimization.
- Responding within the specified time frame to all requests for remediation or corrective action.
- Providing, in writing to the RSO, 60 days advanced notice of the intent to vacate a controlled area.
- Ensuring that only approved procedures involving the use of radioactive materials or radiation-producing equipment are performed and that these procedures conform to the terms of his/her "Application for Use", State and Federal regulations and this Handbook.
- Notifying Radiation Safety Staff prior to the performance of procedure(s) which could result in a release of radioactive material to the environment.
- Ensuring that all exposures to radiation sources for which the Supervisor is responsible, are maintained within or below regulatory limits.
- Applicable regulations and license conditions (Radiation Protection Program Handbook, RSO lectures and regulatory review)
- Radiation hazards, biological effects and risk assessment (videotapes, Supervisor instruction and RSO lecture)
- Radiation safety procedures including work rules, exposure monitoring, survey instrument use and contamination monitoring (Supervisor, RSO lecture, and Handbook)
- Obligation to report unsafe working conditions
- Emergency procedures
- Right to be informed of radiation exposure and bioassay results
- Posting and License location
An examination will be given at the completion of the Stage One training requirements (with the exception of sealed source user) to evaluate the individual's knowledge of the University's Radiation Protection Program, biological effects, associated hazards, related rules and regulations, radiation terminology, etc.
Stage One requirements must be completed and documented prior to working with radiation (see details on exception for radioactive material users with adequate previous experience provided in Section 2.3). Following the successful completion of Stage One, conditional approval to work in radiation areas is granted. After receiving conditional approval, Stage Two training begins. Stage Two training should be completed and documented within four months of obtaining conditional approval.
Stage Two: Documented and directed by Radiation Supervisor (RMS/RES)
Training in the following areas:
- Training specific to the type of radiation work that will be performed:
- Radioactive Material: areas where radioactive materials are stored, used and disposed; location and use of radioactive material; inventory and disposal records
- Radiation Equipment: theory of operation; start up and shut down procedures; interlocks and safety devices
- Sealed Source Users: areas where sources are stored and used, source use log, source security, leak tests and inventory
- RSC approved "Application for use..." conditions including approved procedures, restrictions, possession limits, etc.
- Locations of personnel exposure monitors, lab coats, gloves and monitoring equipment
- Location of radiation safety related documents, postings and manuals
- Location of eye wash, safety shower and emergency contact list
- Hazards of radiation and safety precautions specific to the laboratory
- Radioactive material workers using open sources must document 40 hours of direct supervision and instruction in related techniques and use of equipment (some or all may this requirement be waived if adequate previous experience using radioactive materials in applications similar to those anticipated to be performed at Syracuse University can be documented)
- Radiation equipment operators must document procedural training specific to the equipment that will be used, conducted by the appropriate RES
Responsibilities
The Committee is responsible for:
Duties
The Committee shall:
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1.2 Radiation Safety Officer
The University's Radiation Safety Officer (RSO) receives his/her authority from the Radiation Safety Committee (RSC). The RSO is authorized to initiate remedial action or to temporarily halt or immediately terminate a project that is found to be a threat to health, safety or property or otherwise in violation of Federal, State or local regulations.
Responsibilities include:
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1.3 Radiation Supervisors
All operations involving the use of radioactive materials or radiation-producing equipment at Syracuse University must be carried out under the direction of a Radioactive Materials Supervisor (RMS) or a Radiation Equipment Supervisor (RES), respectively. Designation as a RMS or RES is granted by the Radiation Safety Committee (RSC) to individuals who demonstrate that they are sufficiently knowledgeable of radiation protection principles, related compliance issues, proper procedures for the safe use of radiation and associated hazards.
The responsibilities of a Radiation Supervisor include, but are not limited to:
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1.4 Radiation Workers
Radiation workers are individuals authorized by the RSO to work with radioactive materials or operate radiation-producing equipment. An individual must obtain Radiation Worker status prior to independently performing any procedure involving ionizing radiation. Radiation workers are required to have a basic understanding of radiation protection practices and the hazards associated with the use of ionizing radiation. Each must act in accordance with the guidelines established in this Handbook, rules established by the RSC and their supervisor and all applicable laws and regulations. Workers must also make every effort to maintain their exposure to ionizing radiation as low as reasonably achievable. An overview of the University's Radiation Worker training requirements are provided in Section 1.6 of this Handbook
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1.5 Non-Radiation Workers Required to Enter or Work in Radiation Use Areas
Non-radiation workers who, during the course of employment, are required to perform assigned duties in or about controlled radiation areas (i.e., custodians, maintainence, dishwashers) must be informed of the radiation hazard present. These individuals must be directly supervised by an approved radiation worker while in a controlled area and must never enter these areas when unattended. If a non-radiation worker will be performing duties in a controlled area on a regular basis or over an extended period of time, Radiation Safety staff must be notified so that an appropriate exposure evaluation may be performed as necessary. Information regarding the training required for non-radiation workers prior to entry into controlled radiation areas is provided in Section 1.6.4 of this Handbook.
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1.6 Training
1.6.1 Radiation Worker Training
Syracuse University is obligated by 10 NYCRR Part 16 to ensure that individuals who work with ionizing radiation at the University are supervised and instructed in the hazards of radiation and related regulations and are competent to safely use radioactive materials and/or radiation producing equipment. Each individual who wishes to work with ionizing radiation at Syracuse University, therefore, must complete the Radiation Worker Training Program. This training provides an overview of principles and practices of radiation protection, monitoring techniques, biological effects, regulations and job specific instruction. Once individuals have completed the required training, they receive Approved Radiation Worker status. This status requires the completion of required annual refresher training.
The Radiation Worker Training Program consists of two stages. This Section provides a general overview of the training provided in each stage of the training program. Specific details for becoming either a Radioactive Material Worker, a Sealed Source User or a Radiation Equipment Operator are provided in Sections 2.4.2, 2.12.4 and 4.3 respectively.
Stage One: Documented and directed by Radiation Safety staff
Training in the following areas:
Final approval of radiation worker status is obtained upon the satisfactory completion and documentation of Stage One and Stage Two. This status is maintained by completing annual refresher training requirements.
Training records will be retained by EHO for a minimum period of three (3) years after an individual has left the University.
1.6.2 Radiation Worker Training - Radioactive Materials Supervisors Responsibilities
Radioactive Material Supervisors (RMSs) shall ensure that each new radioactive material worker under their supervision completes a "Laboratory Orientation" form, has it signed by the RMS and returns it to the RSO prior to commencing any work with radioactive materials in the laboratory. Each worker must also document forty (40) hours of direct supervision and instruction on radiation related techniques and equipment specific to the laboratory. This instruction can be provided by the RMS or another approved radiation worker in the laboratory and must be documented on a "Supervised Training" form. Completed training forms must be submitted to the RSO for review and approval. Each worker should complete this process within four months of obtaining conditional approval to obtain final approval. Requests for additional time to complete this process must be made to the Radiation Safety staff.
1.6.3 Radiation Worker Training - Radioactive Equipment Supervisors Responsibilities
Radiation Equipment Supervisors (RESs) shall ensure that each new radiation equipment operator under their supervision completes a "Laboratory Orientation" form, has it signed by the RES and returns it to the RSO prior to commencing any work with radiation equipment. RESs must also provide each new radiation equipment operator with training on procedures specific to the radiation equipment to be used prior to allowing them to operate the equipment independently. This training must be documented on an "Analytical X-ray Procedural Training" form. The completed form must be signed by the RES and returned to the RSO for review and approval. Each operator should complete this process within four months of obtaining conditional approval to obtain final approval. Requests for additional time to complete this process must be made to Radiation Safety staff.
1.6.4 Instructions to Non-Radiation Workers Non-Radiation Workers (clerical, housekeeping, public safety, lab workers, etc.) whose duties may require them to work in the vicinity of radioactive materials or radiation producing equipment are informed of radiation hazards through the University's Hazard Communication Program. Additional training, specific to individual job requirements, is provided by Radiation Safety staff to occupationally exposed individuals. It is the responsibility of the laboratory's RMS/REW to ensure that all individuals with the potential for occupational exposure are properly trained prior to entering a controlled area. Only authorized personnel are allowed contact with containers and work areas identified with radiation hazard labels, symbols or tape.
Return to Table of ContentsPart Two
Radioactive Material Use
2.2 Application to Use Radioactive Material (Supervisors Only)
2.4 Radioactive Material Inventory Control
2.5 Procedures for Ordering Radioactive Materials
2.6 Active Use Storage
2.7 Transporting/Shipping Radioactive Materials
2.8 Transfers of Radioactive Materials
2.9 Surveys and Inspections of Radioactive Material Use Areas/Equipment
2.10 Radioactive Laboratory Guidelines--Rules for the Safe Use of Radioactive Materials
2.11 Instrument Calibration
2.12 Radioactive Sealed Sources
2.13 Use of Radioactive Materials in Vertebrate Animals
2.14 Vacating Controlled Areas
2.15 Enfocement Policy for Radiation Safety Infractions
Return to Table of Contents2.1 General
Radioactive material use at Syracuse University is bound by the limits and requirements established in the University's New York State Department of Health issued Broad Scope Radioactive Materials License. This License imposes limits on the quantities, types and forms of radioactive materials that can be possessed at the University and outlines specific requirements that must be encompassed in the University's Radiation Protection Program. All aspects of the purchasing, use and disposal of radioactive materials at the University must comply with the terms of the University's Radioactive Material License and New York State regulations.
This Section of the Radiation Protection Program Handbook outlines the requirements and procedures for purchasing and using radioactive materials at Syracuse University. It also provides detailed information on the requirements for becoming an approved Radioactive Material Supervisor and a Radioactive Material Worker.
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2.2 Radioactive Material Supervisor - Application for Use of Radioactive Material
Radioactive Material Supervisors (RMSs) are principle investigators, in general, who have authorization to perform specific procedures involving radioactive materials from the University's Radiation Safety Committee (RSC). Prior to commencing work with radioisotopes, these individuals must complete and submit an "Application for Use of Radioactive Material" (Application) to the RSC for review and approval. The RSC will grant approval, conditional approval, or disapprove of the Application based on the information provided, the applicant's experience with radioisotopes, and the effect the proposed use will have on University property and the safety and health of the University community. This Section of the Handbook describes the application process used at Syracuse University to evaluate prospective RMSs and proposed uses of radioactive materials.
2.2.1 Completing and Submitting an Application Prospective Radioactive Material Supervisors may obtain an Application from science department offices or from the Environmental Health Office. The Application must be completed in full and typed to ensure legibility. The following information must be provided in or as an attachment to the Application:
- A list of all individuals who will be working with radioactive materials under the applicant's supervision
- A justification of the need to use radioactive materials
- Procedures for proposed operations which involve the use of radioactive materials sufficiently detailed for evaluation of the associated hazards
- A copy of the applicant's current Curriculum Vitae
- A description of applicant's previous training and experience with radioactive materials including dates, locations, isotopes, processes, etc.
- A floor plan of the radiation use areas, including major pieces of equipment to be used (i.e. refrigerators, freezers, fume hoods, centrifuges)
- A description of the equipment that will be available to survey, control and/or minimize the radiation hazard
- Estimates of the types and quantities of radioactive waste that will be generated
Detailed instructions for completion of an Application are provided with the Application. Radiation Safety staff will provide further assistance and answer questions related to the Application upon request.
Once the Application is complete, the applicant must submit it along with any attachments to the Radiation Safety Committee (RSC) via the Radiation Safety Officer (RSO). The RSO will complete a radiological safety evaluation of the Application consisting of a review of the Application, an interview with the applicant, and a visit to the applicant's laboratory (as necessary). Upon completion, the RSO will summarize the evaluation in writing. This evaluation summary will consist of an item-by-item analysis of the Application and the RSO's recommendation(s).
The Application, attachments, and RSO evaluation are then forwarded to each member of the Radiation Safety Committee for comment and action. Questions from members of the RSC will be addressed appropriately by either the RSO or the applicant. Approval, disapproval or conditional approval will be by majority opinion of the technical members of the Radiation Safety Committee. Records of applications, evaluations and RSC actions will be kept for review by EHO.
Following approval by the RSC, the Radioactive Material Supervisor becomes responsible for all radiation related activities performed or required to be performed in accordance with the conditions of approval. Responsibilities include, but are not limited to, the purchase, use and storage or all radioactive sources; the handling and tracking of radioactive waste; the performance and documentation of required surveys; etc. The RMS is responsible for ensuring that individuals in their laboratory who work with ionizing radiation or who are exposed to ionizing radiation as a result of activities conducted under their supervision, are properly trained and aware of the related hazards. The RMS must also ensure that only approved radioactive material procedures are performed in the laboratory and that the RSO is notified of any changes in use areas, individuals or procedures. A summary of the responsibilities of a RMS are provided in Section 1.3 of this Handbook.
Any additions or modifications to approved procedures or radioactive material use in the laboratory that could potentially increase or modify the radiation hazard previously evaluated or introduce a new hazard, must be approved by the RSC prior to commencement. Amendment requests including a revised "Application for Use of Radioactive Material" should be submitted to the RSC via the RSO.
2.2.2 Evaluation of an Application
Applications for use of radioactive material are evaluated in terms of the qualifications of the applicant and the use(s) of radioactive material proposed. A Prospective Radioactive Material Supervisor is evaluated based on the isotopes and activities proposed for use and his/her past experience with radioactive materials in terms of time, toxicity, activity and type used. The following table is a guideline for evaluating a prospective user's training and experience, however, this table is not the sole method used to judge an applicant's authorization:
| |
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| I. 0-10 control units* of any nuclide for which the university is licensed. | 1 year chemistry, biochemistry, including some experience with handling radioactive material. |
| II. 10-500 control units* of any nuclide for which the University is licensed. | 1 year experience using radio-isotope of similar form, activity, toxicity, etc., as requested for authorized possession. |
| III. More than 500 control units* of any nuclide for which the University is licensed. | 3 years or greater experience using radioisotopes and related processes of similar form, activity, toxicity, as requested for authorized possession. |
*Control units of any radioisotope correspond directly to the quantities listed in Section 10.4 of this Handbook.
Proposed uses of radioactive material and associated operations are generally evaluated based on the following items. However, other items or concerns specific to particular applications may also be taken into consideration in the evaluation.
- The isotopes requested for use, their requested possession limits and their associated classification of toxicity
- The applicant's justification of the need to use radioactive materials
- The potential for exposure to personnel, the methods that will be employed for personnel monitoring and the steps that will be taken to insure that the potential exposures are kept "as low as reasonably achievable" (ALARA)
- The facility and equipment available to the applicant, including personnel protective equipment, shielding, survey instruments and the availability of fume hoods and/or glove boxes
- The types and quantities of wastes expected to be generated
- The types of containment that will be used when working with radioactive materials, including primary and secondary containment when working with liquids
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2.3 Procedure to Become an Approved Radioactive Materials Worker
Syracuse University requires that anyone who wishes to work with radioactive materials has a thorough understanding of regulations and hazards associated with the use of ionizing radiation. This is accomplished through a two stage radiation worker training program. Stage One of this program involves a series of videotapes, a class room lecture and an examination. Stage Two is completed in the laboratory under the direct supervision of an approved radioactive material worker. Individuals who do not have adequate, previous experience in using radioactive material must complete Stage One requirements prior to commencing work with radioactive materials. Adequately experienced individuals may complete Stage One and Stage Two requirements concurrently. The following lists the steps for completing both stages of the required radiation worker training program:
Stage One
- Notify the Radiation Safety Officer (RSO) of your intention to become a radioactive material worker by completing a "Radiation Worker Sign-Up" form. This form may be obtained from the Environmental Health Office at 029 Lyman Hall, ext. 4132.
- If you have ever been monitored for radiation exposure or are currently being monitored for radiation exposure at another institution, complete a "Radiation Exposure History Request" form. This signed form will allow the University to request and receive your exposure history from the other institution.
- Sign out a copy of the University's Radiation Protection Program Handbook and read it to familiarize yourself with the terms and concepts of radiation protection. Particular emphasis should be placed on understanding rules and regulations for using radioactive materials at Syracuse University.
- Schedule a time with the Radiation Safety staff, ext. 9130, to view videotapes on the safe use and handling of radioactive materials, radiation hazards and associated risks, and emergency procedures. These tapes may be viewed at EHO during normal working hours.
- If you have previously used radioactive materials in applications similar to those anticipated to be used at Syracuse University:
- Summarize your experience in writing and submit it to the RSO for review, including dates, locations, isotopes, activities, and an explanation of related experimentation.
- Take a preliminary examination which will evaluate your knowledge with respect to radiation safety, associated hazards and the use of radioactive materials.
- Upon satisfactory completion of the examination and authorization from the RSO, you will be granted a conditional approval to work with radioactive materials in the laboratory under direct supervision and may begin completing the Stage Two training requirements. Dosimetry will be issued to monitor your external radiation exposure (as applicable).
- The retention of the conditional approval is contingent upon your attendance at the next radiation worker training class and the completion of the remaining Stage One requirements. If these requirements are not met with in 3 months of obtaining conditional approval, your conditional approval will be revoked until the requirements are completed.
- If you do not satisfactorily complete the examination or if the RSO determines that your previous experience is insufficient for your intended radioactive material use at Syracuse University, conditional approval will not be granted until completion of all Stage One training requirements.
- Attend the next Radioactive Material Worker Training Session (offered as needed, approximately 4 times a year). This session covers rules, regulations, and procedures as well as proper surveying methods and monitoring devices. This session generally lasts for three hours and is mandatory for every new open source, radioactive materials worker.
- Take an examination which evaluates your knowledge of the elements of the University's Radiation Protection Program, general radioactive materials use, biological effects, associated hazards, related rules and regulations, and radiation terminology.
- Schedule a meeting with the RSO to review your test results and go over any questions you may have.
- Upon the successful completion of these requirements you will be conditionally approved as a radioactive material worker. Work with radioactive material may be performed only under direct supervision by an approved radiation worker. Dosimetry will be issued to monitor your external radiation exposure (as applicable).
Stage Two
- Prior to using any radioactive materials in the laboratory, complete a radioactive material laboratory orientation with your radioactive material supervisor or an approved radiation worker. Document this training on the "Laboratory Orientation" form and return the completed form to the RSO, 029 Lyman Hall.
- Complete 40 hours of supervised on-the-job training as related to radioactive materials and/or processes and document this training on the "Supervised Training" form. This training should be completed within 4 months of obtaining conditional approval. If additional time is necessary, a written request must be submitted to the RSO. Return the completed form to the RSO.
If you have documented adequate, previous experience using radioactive materials in applications similar to those anticipated to be used at Syracuse University, some or all of the required 40 hours of supervised training may be waived at the discretion of the RSO.
- Once you have satisfactorily completed the above process, you will be granted approved radioactive material worker status. The status may be continued perpetually by completing the required annual refresher training.
Return to Table of Contents2.4 Radioactive Material Inventory Control
Syracuse University's Radioactive Material License requires that an active inventory of all of its non-exempt radioactive sources, including open sources, sealed sources and sources enclosed in equipment (i.e. gas chromatograph), be maintained. To ensure compliance with this requirement, Radiation Safety staff must be notified prior to the purchase or receipt of any radioactive material. All requests for purchase of radioactive materials must be reviewed by Radiation Safety staff to ensure that possession limits will not be exceeded. Radioactive material purchases will not be authorized if the additional activity will cause the RMS to exceed maximum possession limits. All radioactive material deliveries must be received at the Radiation Safety Laboratory, room 034 Lyman Hall, so that the necessary inventory information can be recorded.
A database of active radioactive material sources possessed at the University is maintained by Radiation Safety staff to track the sources from purchase to disposal. Each radioactive material source received is assigned an inventory number and recorded in the database. When Radiation Safety staff deliver the radioactive material source to the RMS, it is accompanied by an inventory sheet indicating the isotope and activity of the source and the assigned inventory number. All use and disposal of the radioactive material must be entered onto this sheet, as indicated. The sheet must be kept up to date and may be stored in Section 12 of this Handbook for easy reference. The RSO will review the sheet(s) periodically to ensure that inventory records are being properly maintained. When all of the material has been used or when the remaining material is surrendered to Radiation Safety staff, the inventory sheet must be returned to the EHO. Upon its return, the material referenced on the sheet will be deleted from the RMS's possession and an out of inventory date will be entered into the database. Returned inventory sheets will be maintained by EHO for a period of 7 years.
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2.5 Procedures for Ordering Radioactive Material
2.5.1 General Purchase Requisitions
All purchase requests for radioactive material must be approved by the Radiation Safety staff. It is the obligation of the Radiation Safety staff to assure that all purchases of radioactive materials are for authorized radioactive materials and within the possession limits of the University's License. To ensure this requirement, the following procedure must be followed: (specific details for requisitions for standing orders of radioactive material are provided in Section 2.5.2):
- All purchase requests for radioactive materials must identify the purchase as "Radioactive Materials" by noting this in capital letters on the purchase requisition.
- The purchase requisition must be sent to the Environmental Health Office, 029 Lyman Hall, Attention: Radiation Safety Officer. The purchase request must contain:
- Isotope identity
- Compound/chemical form
- Activity requested
- Vendor
- Signature of the Radioactive Materials Supervisor
- The purchase requisition is reviewed and then processed in the following manner by Radiation Safety staff:
- The requesting supervisor's authorization and possession limits are checked to ensure that the supervisor is approved to possess the type and quantity of material requested for purchase.
- If the request is not within the authorization limits, it is returned to the RMS.
- If the request is within the authorization limits:
- The requisition is stamped to indicate to Purchasing personnel that the request is allowed for purchase.
- The purchase requisition is checked to ensure all of the appropriate information has been provided and that it indicates that packages should be delivered to :
- Environmental Health Office
029 Lyman Hall 108 College Place
Syracuse, NY 13244
- RSO or his delegate then signs and dates the requisition and forwards it to Pre-Audit for approval
- Pre-Audit forwards the requisition to Purchasing for processing
Note: Purchasing personnel will not process any request for radioactive materials without prior approval from the RSO or designee.
- Approved purchase requests are assigned an inventory number at the time of approval for purchase. The inventory number, RMS and specific information regarding the purchase are then logged into the "Receiving Log Book".
The following information must be recorded:- Inventory number
- Isotope
- Activity and calibration date
- Form
- Vendor
- Radiation Materials Supervisor's name
- Storage location
- P.O. number
- Once the requisition is processed by Purchasing, Purchasing contacts EHO with the purchase order number and any pertinent delivery information. A copy of the purchase requisition is returned to the Environmental Health Office with the assigned purchase order number.
- Upon delivery of the purchase to EHO, the package is surveyed appropriately by Radiation Safety staff. The results of the survey and the receiving information are logged in the "Receiving Log Book".
Note: Deliveries are accepted only during normal working hours.
- The package is delivered to the laboratory by Radiation Safety staff.
2.5.2 Standing Order Purchase Requisitions
All purchase requests for standing orders of radioactive material must be approved by the RSO. It is the obligation of the Radiation Safety Officer to assure that all purchases of radioactive material are for authorized radioactive materials and within the possession limits of the License. To ensure this requirement, the following procedure must be followed when establishing a Standing Purchase Order for radioactive materials:
- Standing order purchase requisitions for radioactive materials must identify the purchase as "Radioactive Materials Standing Order" by noting this in capital letters on the purchase requisition.
- The purchase requisitions must be sent to the Environmental Health Office, 029 Lyman Hall, Attention: Radiation Safety Officer. The purchase request must contain:
- Isotope(s) identity
- Compound(s)
- Activity(s) requested
- Supplier
- Signature of the Radiation Materials Supervisor
- "Orders to be telephoned in as needed"
- The purchase requisition is reviewed and then processed in the following manner by the RSO or his delegate:
- The supervisor's authorization and possession limit are checked to ensure that the supervisor is approved to possess the type of material and quantity of each item listed on the order.
- If the request is not within the authorization limits, it is returned to the RMS.
- If the request is within the authorization limits:
- The requisition is stamped to indicate to Purchasing personnel that the request is allowed for purchase.
- The purchase requisition is checked to ensure all of the appropriate information has been provided and that it indicates that packages should be delivered to :
Environmental Health Office
029 Lyman Hall 108 College Place
Syracuse, NY 13244
- RSO or his delegate then signs and dates the request and sends it to Pre-Audit for account approval.
- Pre-Audit forwards the requisition to Purchasing for processing
Note: Purchasing personnel will not process any request for radioactive materials without prior approval from the RSO or designee.
- No information is entered into the receiving log and no inventory numbers are assigned until a telephone order is placed by the requesting laboratory.
- Upon processing by Purchasing, a copy of the purchase requisition is returned to EHO with the assigned purchase order number.
- Telephone request sheets are then filled out by Radiation Safety staff (one sheet for each item/quantity ordered). These request sheets are sent to the labs for completion at the time the actual order is placed.
- Laboratory personnel must contact the Radiation Safety staff prior to placing each telephone order. Radiation Safety staff will verify that the order will be within the RMS's possession limit and enter the specific information regarding the purchase in the Receiving Log. An order that will cause a possession limit to be exceeded will not be approved for purchase.
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2.6 Active Use Storage
Radioactive materials may be stored only in areas which have been approved by the Radiation Safety Officer. The RSO must be kept informed of all changes in storage or use areas and will provide assistance in the selection of these areas as necessary to ensure compliance with NYSDOH regulations. Food, drink, tobacco, and/or cosmetics must not be stored or used in the same area as radioactive material.
Radioactive material storage/use areas must be chosen to minimize the probability of the radioactive material being involved in an explosion, fire, or flood. These areas must be shielded, as necessary, to ensure that the sources do not cause the dose in any unrestricted area to exceed 2 mrem in any one hour and do not result in a total effective dose equivalent to any non-occupationally exposed individual in excess of the 0.5 mrem in a year.
In addition, radioactive material use and storage areas must be labeled in accordance with 10 NYCRR Part 16.12 and Section 6 of this Handbook. All storage areas must be kept secured at all times when not in direct attendance, to prevent the unauthorized removal of radioactive material. Radioactive liquids must be stored in non-breakable, sealable containers and be provided with secondary containment capable of holding the contents of the primary vessel. Volatile radioisotopes must be stored in fume hoods or other exhausted locations or in frozen solutions.
The RSO must be notified immediately upon discovery of a lost, missing or stolen source so that appropriate steps can be taken.
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2.7 Transporting/Shipping Radioactive Materials
2.7.1 Transporting Radioactive Materials on Campus
Laboratories may occasionally need to move radioactive materials outside of approved use areas through non-controlled areas (i.e. hallways, campus sidewalk). This type of transport may only be performed when authorized by the RSO or RSC. Authorization may be obtained by indicating the need to perform such transport in the supervisor's "Application for Use of Radioactive Material" or by submitting a request in writing to the RSO/RSC for approval. All requests for transport outside of controlled areas must be accompanied by a transport protocol specific to the situation. The following is provided as a guide to aid in developing transport protocols:
- Containers should be chosen to ensure no loss of material even in unusual circumstances. Three layers of containment are required for non-sealed radioactive material (primary vessel plus two other non-breakable vessels). One containment vessel may be sufficient for some sealed sources.
- The dose at the surface of the outer container must be limited to a maximum of 2 mrem in any one hour and must not result in a total effective dose equivalent in excess of 0.5 mrem to any non-occupationally exposed individual. These limits may be met by increasing the size of the container and/or adding additional shielding.
- The outer container must be labeled as specified in Part 6 of this Handbook.
- The outer container must be wipe tested to demonstrate surface contamination levels below the limits listed in Section 2.9.4 of this Handbook.
- The move must be accomplished safely and only by approved radiation workers.
- The container must not be left unattended while it is outside of a controlled area.
Radiation Safety staff will provide assistance with any transportation questions or concerns.
2.7.2 Transporting/Shipping Radioactive Materials Off Campus
The transport of radioactive materials over public streets and highways must be done in accordance with State and Federal regulations. This includes transportation by the US mail, common carriers, or an individual. All transports of this type must be reviewed by the RSO prior to commencement to ensure that all applicable regulations are met. Individuals shipping/transporting radioactive material off-campus or requesting radioactive material be shipped to them, must review this with the RSO before any shipment is arranged. These individuals must also follow the procedure for the transfer of radioactive materials to or from an off campus location provided in Section 2.8.2 of this Handbook, to ensure accuracy in inventory records and compliance with the University's licensed possession limits.
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2.8 The Transfer of Radioactive Materials
Syracuse University Approved RMSs may transfer radioactive material to/from another approved institution or another Syracuse University supervisor only with approval of the RSO. Procedures for transferring radioactive material between Syracuse University RMSs or to/from another institution are provided in this Section. These procedures must be followed to ensure that the University is aware of those individuals who have radioactive material for which the University is responsible and that the proper documentation has been maintained. Once a transfer has been approved, the actual movement or shipment of the radioactive material must be done in accordance with applicable regulations and Section 2.7 of this Handbook.
2.8.1 Transfers Between Syracuse University Approved Radiation Supervisors The following procedure must be followed when transferring radioactive materials between approved RMSs at Syracuse University:
- The RMS releasing the material must complete the "Transfer of Radioactive Material Form" including:
- All of the "Materials Transferred Section"
- Releasing RMS information
- Receiving RMS information
- Send or deliver the transfer form to the RSO.
- Radiation Safety staff will verify that the receiving RMS is authorized to possess the material to be transferred.
- If the receiving RMS is not authorized to possess the transfer material, Radiation Safety staff will notify both labs that the transfer cannot occur.
- If the receiving RMS is authorized, the releasing RMS is responsible for the proper packaging and transfer of the material.
- The releasing RMS must indicate on the material's original inventory sheet, the amount and date of transferred material.
- Radiation Safety staff will assign the transferred material a new inventory number and inventory sheet. This inventory sheet must be maintained by the receiving RMS.
2.8.2 Transfers To/From Another Institution
The institution receiving/shipping the radioactive material must provide proof of their authorization to receive the material. This proof must be in the form of a radioactive material license or certificate of registration. The following procedure must be followed when transferring radioactive material between an approved radioactive material supervisor at Syracuse University and another institution:
- Supervisor releasing/receiving the material must complete the "Transfer of Radioactive Materials Form" including:
- All of the 'Materials Transferred Section"
- Releasing RMS/Institute information
- Receiving RMS/ Institute information
- The transfer form must be delivered or sent to the RSO.
- Radiation Safety staff will verify that the receiving institute or RMS is licensed to receive the transfer material and notify the Releasing RMS/Institute accordingly.
- The Syracuse University RMS involved in the transfer is responsible for the actual transfer of the material. The material to be transferred must meet all appropriate packaging, shipping, and transport regulations as specified in 49 CFR Part 173.
- All material transferred onto campus must be delivered directly to the Radiation Safety Laboratory. Radiation Safety staff will perform the required surveys and assign the material an inventory number and inventory sheet. The inventory sheet must be maintained by the Syracuse University RMS receiving the material.
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2.9 Surveys and Inspections of Radioactive Material Use Areas and Equipment
Radioactive contamination is the presence of radioactive material in undesirable locations. Radioactive contamination is a potential health hazard since it can be a source of internal and/or external exposures. It may be easily spread through out a facility, jeopardizing the success and accuracy of experiments. Although the use of good laboratory organization and operating procedures can help to minimize radioactive contamination, the potential for contamination still exists. Radiation area surveys are an effective way of locating radioactive contamination and confirming that contaminated areas are effectively remediated.
Laboratories which use or store radioactive materials must implement contamination control and ambient radiation exposure monitoring surveys. The purpose of these surveys is to identify and limit the spread of radioactive contamination and to ensure that radiation levels in the laboratory are kept as low as reasonably achievable. In addition, Radiation Safety staff will periodically perform air monitoring in laboratories where there is a reasonable expectation for airborne contaminants.
Records of all radiation surveys must be maintained for a minimum of three years.
2.9.1 Removable Contamination Surveys
Removable contamination is radioactive contamination that can be removed from the contaminated surface. A wipe test is the accepted method for removable surface contamination monitoring. A wipe test (a.k.a. swipe or smear) is performed by rubbing a cloth filter paper or similar material over the surface (100 cm2) of the object/area being tested. The "wipe" is then analyzed to determine if removable radioactive contamination is present on the object/area wiped.
Laboratories containing unsealed radioactive materials are required to monitor for removable surface contamination.
Monthly Comprehensive Survey
All laboratories which use and/or store unsealed radioactive materials must perform a monthly removable contamination survey. The monthly survey is a comprehensive survey of the laboratory encompassing all areas and equipment that come in contact or have the potential to become contaminated with radioactive materials. The monthly survey sites are generally pre-characterized by Radiation Safety staff and must include:
- All radioactive use and storage areas (benches, equipment, sinks, etc.)
- All radioactive waste storage locations
- Adjacent non-controlled areas (floors, benches)
Monthly surveys must be submitted to Radiation Safety staff on or about the last day of each month for analysis.
Limited Weekly Survey
A weekly removable contamination survey must be performed in laboratories for each week in which a single use of open source radioactive material exceeds 250 uCi (exclusive of stock container extractions of less than 250 uCi). The performance of weekly wipe tests may be limited to those sites where quantities in excess of the threshold level (250 uCi) are used. The sites may include all or a portion of the sites tested in the comprehensive monthly survey and may change from week to week depending on usage in the laboratory. Weekly surveys must be submitted to Radiation Safety staff on or about the last working day of the week for each week in which they are required. If only one use of 250 uCi or more is anticipated during any one working week, it is recommended that the weekly wipe survey be performed immediately following that use.
For all removable contamination surveys, the analysis of the wipe tests must be, at a minimum, sensitive enough to detect the removable contamination action level indicated in Section 2.9.4. for contaminant(s) involved. The preferable method for counting the wipe tests is liquid scintillation counting (for beta and low energy gamma emitters). All other counting methods used for analysis of the wipe tests must be approved by Radiation Safety staff prior to use. It is recommended that the analysis of the wipe tests be performed by Radiation Safety staff as part of the Removable Contamination Survey Analysis Program (see Section 2.9.2).
A permanent record of each contamination survey, including negative results as numerical values, must be maintained and must include:
- A cover sheet indicating the time period for the survey (i.e. month of), the name of person conducting the survey and the date conducted.
- A drawing of the area surveyed indicating relevant features of the area, including all radioactive use areas and equipment, and identifying and coordinating all survey site locations and survey results.
- Information on the analysis method used including equipment manufacturer, model number, etc. and pertinent counting efficiencies.
- Analysis results in dpm/100 cm2
- Remediation actions and post remediation results
2.9.2 Removable Contamination Survey Analysis Program
The Environmental Health Office offers a program for the analysis of removable contamination wipe tests. Laboratories are encouraged to take part in this program to ensure appropriate analysis of the wipe tests. In the program, wipe tests of pre-characterized sites are performed by laboratory personnel and sent to Radiation Safety staff for analysis. Monthly surveys must be performed and sent on or about the last day of each month and weekly surveys must be performed and sent on or about the last working day of the week for each week in which they are required. Radiation Safety staff perform the analysis of the wipes and generate a result sheet with corresponding wipe site locations. The results are returned to the laboratory along with a request for remediation of areas in excess of the removable contamination limits (Section 2.9.4).
2.9.3 Area Surveys
Radioactive use areas must be surveyed for contamination after each use of radioactive material. All work areas and equipment used in conjunction with radioactive material must be surveyed with a meter appropriate to detect the type of radiation used. Survey results in excess of limits established in Section 2.9.4 should be immediately remediated.
2.9.4 Surface Contamination Remediation Action Levels
Action must be taken to eliminate surface contamination when the levels of contamination exceed the limits listed on the "Surface Contamination Limits" Table below. Total activity refers to all detectable emissions from a surface. Removable contamination is defined in Section 2.9.1 of this Handbook.
| Application | Alpha Total dpm/100cm2 | Alpha Removable dpm/100cm2 | Beta/gamma Total mR/hr |
Beta/gamma Removable dpm/100cm2 |
Radioiodines Total mr/hr |
Radioiodines Removable dpm/100cm2 |
| Controlled Areas | ||||||
| *Work Area | 1500 | 200 | 0.5 | 1000 | 0.1 | 200 |
| *Clean Area | 500 | 100 | 0.1 | 500 | 0.02 | 20 |
| Non-Controlled Areas | ||||||
| Skin and Personal Objects | ND | ND | ND | ND | ND | ND |
| Object Removed from Controlled Area | 200 | 50 | 0.1 | 500 | 0.02 | 20 |
| Release of Facilities | 200 | 50 | 0.1 | 500 | 0.02 | 20 |
- Total beta/gamma is measured at 1cm from surface
- ND= Non-detectable
- Beta/Gamma limits include all beta/gamma emitters except special nuclear material, transuranics, natural uranium
- Radioiodine limits include all radioactive Iodine isotopes ( i.e. I124, I131, I129, etc.)
2.9.5 Ambient Radiation Monitoring
Ambient radiation monitoring is the measurement of radiation exposure at various locations in the laboratory. Weekly monitoring is required to be performed in all laboratories or areas containing 200 uCi or more of radioactive materials (not including H3, S35, Tc99 and C14). The measurements must be performed with a survey meter sensitive enough to detect 0.1 mR/hr.
Ambient exposure measurements must be taken at locations which are representative of areas where exposures are likely to occur. The survey locations must be indicated on a site map, repeated from week to week and include the following:
- Active source storage locations
- All radioactive use areas
- Radioactive waste storage locations
Exposure measurements, in mR/hr, should be logged onto the "Ambient Exposure" form with corresponding site locations. Permanent records of ambient exposure surveys must maintained in the laboratory. The survey records, which will be reviewed periodically by the RSO, must include:
- Location, date performed, identification of equipment used, (manufacturer, model number, detector model number, etc.) and pertinent counting efficiencies
- Name of person conducting the survey
- Drawing of area surveyed, identifying and coordinating survey site locations and survey results
- Background radiation measurement
- Net results in mR/hr
- Remediation actions and post remediation results
An action level of 0.5 mR/hr has been established for ambient exposures. Measurements at any site greater than 0.5 mR/hr require remediation. Remediation actions may include:
- Returning unshielded source(s) to shielded storage area
- Adding shielding around a radiation source
- Removing contamination causing radiation exposure, etc.
Post remediation survey measurements and the method(s) of remediation must be documented in the permanent ambient radiation monitoring record.
2.9.6 Laboratory Air Sampling
Periodic air sampling will be performed in the laboratories pursuant to NYSDEC and NYSDOH regulations and as deemed necessary by the RSO. The air sampling will be performed by Radiation Safety staff and will be appropriate for the type and form of potential airborne contamination in the area and/or effluent. In addition, if personnel have a potential for exposure to airborne radioactivity, an evaluation may be performed.
2.9.7 Miscellaneous Surveys
Protective devices such as fume hoods, filters, lead lined aprons and gloves, and interlocks must be maintained in good repair and proper operating condition. These devices must be inspected at intervals specified in the regulations and/or as directed by the RSO.
2.9.8 Semi-Annual Laboratory Inspections
Radiation Safety staff will perform a complete inspection of all radioactive material use laboratories twice a year. Each laboratory will be notified approximately one month in advance of the impending inspection and provided with a pre-inspection checklist. The inspection will include removable contamination wipe testing, gross contamination surveys, a laboratory operations review, a review of required radiation records, etc. A summary of the results of the inspection will be provided in writing to the laboratory supervisor. The inspection summary will inform the supervisor of the inspection results including cited infractions and the associated classification and severity level of each. Remedial action(s) to correct an infraction(s) must be taken as soon as practicable and submitted in writing, as indicated in the summary, to the RSO. Enforcement action(s) imposed for cited infractions will be determined by the RSO/RSC, based on the University's Radiation Infraction Enforcement Policy (Section 2.15).
Return to Table of Contents2.10 Radioisotope Laboratory Guidelines--Rules for the Safe Use of Radioactive Material in Laboratories
Contamination control is an essential part of working with radioactive material. External and internal radiation exposure can be minimized by careful planning and good judgment. The following is a list of "Rules for the Safe Use of Radioactive Materials in Laboratories". These rules must be posted conspicuously in each laboratory where radioactive materials are used and each radiation supervisor and radiation worker must be familiar with them.
- Wear laboratory coats or other protective clothing at all times in areas where radioactive materials are used.
- Wear disposable gloves at all times while handling radioactive material.
- Properly monitor hands and clothing and all areas after each use of radioactive materials or before leaving the controlled area.
-
- Do not eat, drink, smoke, or apply cosmetics in any area where radioactive materials are used or in areas where radioactive materials are stored.
- Do not store food, drink, or personal effects with radioactive material or in areas where radioactive materials are used.
-
- Wear appropriate personnel monitoring devices at all times while in areas where radioactive materials are used or stored. These devices should be worn appropriately. (Whole body monitors at the waist or chest level; extremity monitors where highest exposure is likely to occur.)
- Personnel monitoring devices, when not being used to monitor occupational exposures, must be stored in a central designated low background area.
- Dispose of radioactive waste only in specially designated and properly shielded receptacles.
- Never pipette by mouth; never cross contaminate pipettes. Pipettes used for radioactive materials should not be used with non-radioactive materials.
- Confine radioactive solutions in covered containers plainly labeled with the name of the compound, radionuclide, date, activity, and radiation level, if applicable.
- Work should be planned ahead whenever possible. A dry run using non-radioactive materials should be made to test the procedure.
- The laboratory should be kept neat and clean. Equipment or material not being used should be stored in a place away from the work area.
- Radioactive materials must be labeled as indicated in Section 6 of this Handbook.
- Caution and other warning signs must be posted as described in Section 6 of this Handbook and must not be removed without proper authority. Articles labeled with a radioactive warning sign cannot be disposed of without the consent of the RSO.
- Radioactive material in liquid form must be transported in sealable secondary containers which will retain their integrity when dropped.
- All injuries and contaminations in areas containing radioactive materials, no matter how minor, must be reported to the lab's RMS as soon as possible.
- An Emergency Procedure relating to the work performed in the laboratory must be posted and its contents made known to all individuals in the laboratory. The procedure must include the names and telephone numbers of all personnel to be contacted in case of an emergency.
- The location and operation of emergency equipment (i.e. fire extinguishers, safety showers) must be familiar to all laboratory employees.
- All equipment intended to provide features of safety must be evaluated periodically to ensure that they are providing the safety features intended.
- Flammable liquids such as ether, benzene, or acetone must be segregated as much as possible away from stored radioactive materials.
- Pressure bottles or tanks containing gas must be secured to the wall, bench, floor, or other rigid objects.
- All items coming into contact with unsealed radioactive material must be checked, and cleaned as necessary, to ensure levels of contamination are below those listed in Section 2.9.4, before the items are used in other work.
- Floors, benches and other surfaces in unsealed radioisotope work areas must be smooth, non-porous, and easily decontaminated. Manipulations of unsealed radioactive material must be carried out on a double layer of absorbent paper backed by plastic. The use of edged trays is encouraged.
- All work involving volatile radioisotopes or which may generate airborne radioactive particles or vapors should be done in a fume hood which as been approved for radioisotope use.
- Re-capping needles used in conjunction with radioactive materials without the use of a capping block or other approved method, is strictly prohibited.
Return to Table of Contents2.11 Equipment Calibrations
2.11.1 Survey Instrument Calibration
Monitoring equipment must be routinely calibrated against standard radiation fields to determine the equipment's detection efficiency. Survey instruments will be calibrated annually by Radiation Safety staff. Survey instruments with scales in mR/hr and CPM will be calibrated for count rate (CPM) only. A calibration sticker will be placed on each instrument following the calibration indicating:
- Calibration date
- Calibration source
- Battery and speaker check results
- Calibration angle
- Instrument's efficiency for various isotopes
- Correction factor for each scale calibrated (for converting the CPM to mR/hr)
2.11.2 Survey Instrument Calibration Documentation
Documentation of all radiation instrumentation calibrations must be maintained for a minimum of 5 years and must include:
- The owner/user of the equipment
- A description of the equipment (i.e. manufacturer, model, serial number)
- A description of the calibration source(s)
- The calculated and actual exposure rate at each calibration point
- Battery check reading (if applicable)
- The angle between the radiation flux field and the detector (parallel or perpendicular for external detectors and the angle for internal detectors)
- Calibration results, correction factors, efficiencies
- The name of the person who performed the calibration and the date the calibration was performed
2.11.3 Quantitative Measuring Equipment Calibration
Instruments used for quantitative measurement must be calibrated at least every six (6) months. This includes liquid scintillation counters and other equipment used to quantify radioactive material. All calibrations must be performed with sources appropriate to the material to be quantified (i.e. sources with similar energy and type of radiation).
Return to Table of Contents2.12 Radioactive Sealed Sources
A sealed source is a source of radioactive material that is permanently bonded or fixed in a capsule or matrix. The capsule or matrix must be designed to prevent the release and dispersion of the radioactive material during conditions which are likely to be encountered in normal use and handling. Sealed sources are generally used for didactic purposes, as reference standards and in devices such as gas chromatographs, ionizing chambers, and sample irradiators.
2.12.1 Use, Possession, and Control of Sealed Sources
The use of and possession of sealed sources is governed by the Radiation Safety Committee. Individuals wishing to be authorized to possess and use or direct the use of a radioactive sealed source(s) must submit an "Application to Use Radioactive Material" with the RSC via the RSO. Individuals working with sealed sources under the direction of a Radioactive Materials Supervisor must complete the radiation worker training program.
Sealed sources must be properly labeled, shielded, and secured from unauthorized removal at all times. A sealed source(s) may be assigned to an single authorized Radioactive Materials Supervisor. This RMS is responsible for this source and its use. If a source or sources are shared by two or more authorized RMS or if they are collectively stored in a central location, a Sealed Source Custodian must be assigned to the sources. This individual is responsible for properly securing and shielding the source(s) when in storage. Individual uses of the source(s), however, are always the responsibility of the RMS and must be done in accordance with RSC approval.
The Sealed Source Custodian/RMS must log the date and time of the removal and return of all sources used in the sealed source log assigned to the particular area. Also included in this log should be the name of the authorized individual removing the source and the location of use of the source. The Sealed Source Custodian/RMS may release a source only to an authorized RMS or an authorized Radioactive Materials Worker. All sources should be returned to storage on the same day they are removed. If sources are to be removed from storage for longer periods of time, the Radioactive Materials Supervisor is responsible for properly shielding and securing the source from ANY AND ALL unauthorized removal. Sources unexpectedly not returned to the Sealed Source Custodian/RMS must be immediately reported to the RSO as missing.
2.12.2 Handling Sealed Sources
All sealed sources greater than 100 mR/hr at the surface must be handled with remote handling devices. All other sealed sources should be handled with remote handling devices whenever possible to reduce individual exposure. Sealed sources must be shielded when not in active use to 2 mR/hr or less at the outside surface of the shield. This shielding must also be sufficient to ensure that the exposure in any unrestricted area does not exceed 2 mrem in any one hour and does not result in a total effective dose equivalent to any non-occupationally exposed individual in excess of the 100 mrem in a year.
Sealed sources cannot be opened or altered in any way. Care must be taken not to rupture thin windows covering some types of source material. If a sealed source is found to be dented, ripped, altered or compromised in any fashion, the RSO must be notified immediately.
2.12.3 Leak Testing of Sealed Sources
Periodic leak tests are required on sealed sources containing radioisotopes other than tritium, with a half life of more than thirty days, in a form other than gas. Beta and/or gamma emitting sources containing less than 100 microcuries of activity are also exempt from this leak testing requirement. The testing interval for all other sources in use must not exceed three months for alpha emitting sources and six months for beta/gamma emitting sources. Leak testing of sealed sources will be performed on a regular basis by Radiation Safety staff.
All sources, including those exempt from the leak testing requirements, must be inventoried every three months. The Sealed Source Custodian/RMS is responsible for performing and documenting the inventory of all sources in his/her custody at least quarterly. This inventory should indicate the source, the date, the location of the source and the name of the person conducting the inventory.
2.13.4 Sealed Source User Training
Syracuse University requires that anyone who wishes to use radioactive sealed sources have a thorough understanding of regulations and hazards associated with the use of ionizing radiation. This is accomplished through a sealed source user training program which includes a series of videotapes and a class room lecture. The training program, which is performed by Radiation Safety staff, must be completed prior to handling any radioactive sealed sources. Upon the successful completion of the training requirements an individual will be approved to use radioactive sealed sources under the direction of a sealed source supervisor. A sealed source laboratory orientation form must be completed with the sealed source supervisor and returned to the RSO for review prior to commencing unsupervised source use. Dosimetry will be issued to monitor external radiation exposure (as applicable). For more information regarding the sealed source training or to sign up to the next sealed source user lecture, contact Radiation Safety staff at x-9130.
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2.13 Use of Radioactive Materials in Vertebrate Animals
The handling, housing, and care of vertebrate animals used in conjunction with radioactive materials requires special consideration. Any procedure involving the use of radioactive materials in vertebrate animals must be approved, prior to commencement, by the RSC and the Institutional Animal Care and Use Committee.
2.13.1 Housing and Care of Radioactive Animals*
(*Vertebrate animals only)
Radiation exposure to animal handlers and other individuals who may frequent the area can occur from direct radiation exposure, exposure to airborne radioactive contaminants from the exhalation of metabolized radioactive compounds or from exposure to contaminated animal wastes, bedding or cages. To reduce this exposure to humans, the following guidelines have been established:
- All radioactive animals and associated caging or housing must be segregated from the housing of other animals.
- All caging or housing containing radioactive animals must be labeled with a "Caution Radioactive Animals" or "Caution Radioactive Materials" sign. The housing must also be labeled with the following information:
- Radioisotope used
- Amount of radioactive material used per animal
- Date of administration
- Exposure rate at outside surface of cage (if applicable)
- Number of animals occupying the cage
- Principle Investigator's name and emergency phone number(s)
- If contamination from excretion or exhalation from the animal is likely to be encountered, the use of metabolic-type cages or other appropriate housing may be required.
- If airborne radioactive contaminants are likely to be produced by the animal, a mechanism to capture and exhaust these contaminants should be available. The housing should contain a label indicating this hazard.
- Animal excretion from radioactive animals must be collected and properly disposed of as radioactive waste. Excretion mixed with sawdust, wood shavings or other bedding may be collected in plastic bags, sealed, and placed in appropriate containers supplied by the Radiation Safety Office. Activity levels must be properly tallied and maintained. Liquid wastes may be disposed via the sanitary sewer system, but appropriate records must be maintained if this disposal method is used (see Sewer Disposal Requirements Section 3.4.1).
- Animal handlers must be instructed by the responsible investigator as to the handling and care requirements of the radioactive animals and animal wastes in each and every case. The Principal investigator is also responsible for maintaining all required documentation.
- When housing has been vacated by the radioactive animal, a proper survey and/or wipe test(s) must be performed and documented to demonstrate that the cage is free of radioactivity. Once free of radioactive contamination, the labels must be removed and properly defaced.
- The rules, guidelines, and general provisions for work with unsealed radioactive sources should be followed where applicable.
2.13.2 Inspection and Dissection of Vertebrate Animals
The injection of radioactive materials into vertebrate animals and dissection of such animals must be performed in trays lined with absorbent material. Where trays are inappropriate, surfaces should be lined with plastic backed absorbent paper. Protective gloves and clothing must be worn by all associated personnel during these procedures. Individuals and the use area should be appropriately monitored after each procedure. If materials are found to be contaminated, they must be decontaminated or dealt with as radioactive waste.
2.13.3 Disposal of Radioactive Carcasses and Wastes
Radioactive animal carcasses, excretion, and bedding must be properly labeled and handled as radioactive wastes. The labeling and handling requirements and procedures are outlined in Section 3.2.5 of this Handbook.
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2.14 Decommissioning and Vacating Controlled Areas
Once an area has been designated as a controlled area for the use of radioactive material by the RSC, it shall remain so until it has been found suitable for non-radioactive uses and released by Radiation Safety staff. Radiation Safety staff will direct the close-out procedure performed by the vacating RMS and will also independently verify the results. Signs identifying radioactive material storage and work areas must not be removed until authorized by Radiation Safety staff. Equipment which was designated and labeled for use in conjunction with radioactive materials must also remain labeled until surveyed and released by Radiation Safety staff. The limits for radioactive surface contamination for the release of facilities are provided in Section 2.9.4 of this Handbook.
It is the obligation of the Radioactive Materials Supervisor to notify the RSO, in writing, 60 days in advance of the intended date to vacate.
Radiation Safety staff will retain site maps of all current and previous controlled radiation areas and records of all decommissioning activities until disposal is authorized by NYSDOH.
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2.15 Enforcement Policy for Radiation Safety Infractions
The Radiation Protection Program Enforcement Policy is designed to inform University radiation supervisors of the sanctions that may be imposed for various radiation safety infractions cited during radiation laboratory inspections (i.e. semi-annual inspections, laboratory visits, informal investigations, etc.). The Policy will assist Radiation Safety staff in uniformly assigning enforcement actions to the infractions identified. The Policy was is based on Nuclear Regulatory Commission guidance.
2.15.1 Identification of Infractions
When a radiation safety infraction is identified by Radiation Safety staff during a laboratory inspection the infraction is noted on the inspection form. If the infraction poses an immediate risk to health, safety or the environment or a potentially imminent health hazard, appropriate action(s) will be taken immediately to control or eliminate the hazard/risk. These actions may include cessation of radioactive material activities, restricting access to the laboratory, locking out the power supply to radiation producing equipment, etc. Examples of imminent hazards/risks include, but are not limited to: a lost or missing radioactive source, extensive amounts of contamination, excessive exposures, and malfunctioning radiation producing equipment.
If no imminent hazard/risk is posed, the infraction will be discussed with the laboratory supervisor and/or other laboratory personnel, as appropriate, at the completion of the inspection. Formal notification of the inspection findings will be provided to the laboratory's supervisor in the inspection summary sent by Radiation Safety staff.
2.15.2 Infraction Notification
Following each laboratory's radiation safety inspection, an inspection summary will be sent to the laboratory's supervisor. The inspection summary will indicate the infraction(s) found during the inspection and the associated enforcement classification and severity level(s), as well as recommendations regarding radiation use in the laboratory. The inspection summary will request the supervisor to remediate the infraction(s) and notify the RSO in writing, when applicable, of the corrective action(s) taken. Corrective actions taken at the time of the inspection will be noted on the inspection summary and no further action will generally be required. Supervisors will be notified during the inspection of situations found which require immediate action. If required, laboratory operations will be interrupted until the infraction(s) is corrected.
2.15.3 Types of Infractions
For the purpose of this enforcement policy, infractions are classified into two groups: violations and deviations. The infraction's classification will be noted on the inspection form and on the supervisor's inspection summary.
- Violation: A violation is a failure to comply with a regulatory requirement such as a rule, regulation or license condition.
- Deviation: A deviation is a failure to satisfy a written commitment (i.e. the supervisor's "Application for use of Radiation"), a program requirement, or a Radiation Safety staff directive.
Once the infraction has been classified as a deviation or violation, its level of severity is determined. The severity level will be assigned, at the discretion of Radiation Safety staff, based on the safety significance of the infraction. Six severity levels have been established in this Enforcement Policy, with Level I being the most serious, and Level VI being the least serious.
- Level I: The highest level of severity. Results from a violation that is reportable to a regulatory agency having jurisdiction (i.e. NYSDOH, NYSDEC, USEPA, etc.) and causes an immediate/high risk to safety, health or the environment, and/or a potential action against the University's Radioactive Material License.
- Level II: A serious infraction that presents immediate/high risk to safety, health or the environment, and/or a potential action against the University's Radioactive Material License, but is not reportable to a regulatory agency having jurisdiction.
- Level III: A serious infraction that presents a significant risk to health, safety and/or the environment.
- Level IV: A less serious infraction, that presents a minimal to moderate risk to health, safety and/or the environment.
- Level V: A minor infraction, typically a record keeping issue, that presents a minimal risk to health, safety and/or the environment.
- Level VI: Generally not a regulatory related issue, but one to which a modification is recommended and/or required.
2.15.5 Enforcement Actions
The imposed enforcement action(s) will be determined based on the classification of infraction (i.e. violation or deviation) and its assigned level of severity. The Enforcement Table will be used as a guide for determining the appropriate enforcement action(s). The Enforcement Table provides typical actions which may be imposed, at the discretion of the Radiation Safety Officer and/or the Radiation Safety Committee, for cited infractions. This Table is not meant to be all inclusive and other actions may be imposed as necessary and/or appropriate.
Supervisors will be advised of the imposed enforcement action(s) in writing. Concerns, grievances, etc., regarding the inspection findings or imposed enforcement actions, will first be discussed with the Radiation Safety Officer. Unresolved issues will be submitted to and addressed by the Radiation Safety Committee.
2.15.6 Repetitive Infractions
A repetitive infraction is when the same infraction is noted during two consecutive inspections or when a similar infraction re-occurs because a previous infraction was not properly remediated. The enforcement action(s) for a repetitive infraction will be based on the next higher severity level than used for the previously cited infraction.
2.15.7 Enforcement Action Table
This table lists only typical enforcement actions and is not meant to be an all inclusive list. The actual enforcement action(s) imposed will not be limited to this table.
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All Violations and Class II and III Deviations require written notification to the RSO as to the corrective actions taken and/or planned.
Note: There cannot be a Level I Deviation since any infraction requiring notification to NYSDOH would be a violation. There also cannot be a Level VI Violation, since a violation, by definition is a regulatoryissue.
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Part Three
Radioactive Waste Management
3.1 General
3.2 Radioactive Waste Management in Laboratories
3.3 Laboratory Radioactive Waste Pick-ups
3.4 Radioactive Waste Disposal
3.5 Radioactive Waste Minimization
3.6 Radioactive Wastes Which Require Special Attention
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The generation, storage, transport and disposal of radioactive waste is governed by various Federal, State and Local agencies. Due to the complicated nature of these wastes, the regulations imposed by these agencies are frequently reviewed and revised. In addition, disposal options for radioactive waste are limited and costly. These issues compel the University to emphasize the need to minimize waste generation whenever possible.
The generator of the radioactive waste is assumed to be the most knowledgeable of its contents. In the laboratories, Radioactive Material Supervisors are considered to be the generators. They are responsible for monitoring all waste generated by individuals under their supervision to ensure that the waste complies with related regulations. This Section of the Handbook should be used as a guide by generators to ensure proper management of radioactive waste and compliance with related regulations.
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3.2 Radioactive Waste Management in Laboratories
All radioactive waste generated at the University must:
- be stored in a "Controlled Area"
- be properly stored/packaged
- be properly shielded (as necessary)
- be properly documented
- be properly labeled
- be appropriately segregated
Radioactive wastes must be segregated according to isotope and waste form. The waste must be tallied to ensure proper disposal and reporting. All labels depicting "Radioactive" or radioactive symbols must be obliterated prior to disposal. Wastes that are found to be improperly labeled, packaged, etc. will be returned to the laboratory for necessary remediation.
3.2.1 Dry, Solid Waste
Dry, solid radioactive wastes are waste materials such as paper, plastic, gloves, etc., that are contaminated with radioactive materials. Any liquids present in the waste must be strictly incidental (i.e. a drop at the end of a pipette tip, a microliter at the bottom of a vial or moisture on the sides of a beaker). Animal carcasses, scintillation vials, containers of liquids, syringes and sharps are not considered dry, solid radioactive waste. Also, dry wastes may not contain any materials which are pathogenic or infectious.
In the laboratories, dry wastes are generally accumulated in 12 gallon fiber waste drums or in 5 gallon metal pails. These waste receptacles must be segregated by isotope, shielded appropriately and located within a controlled area. All receptacles must also be lined with a 4 mil plastic bag and labeled with:
- Isotope
- Total Activity
- "Caution Radioactive Material"
A tally sheet is recommended for each container to aid in keeping an accurate record of the total activity of the radioactive waste in the container. Dry solid radioactive waste containers will be picked up for disposal by Radiation Safety staff (Section 3.3 provides details on radioactive waste pick-ups). Prior to pick-up the liner must be securely closed with a twist tie or tape, the container lid must be closed with a locking ring and the container must be wipe tested for removable contamination. Any removable contamination detected greater than twice background (2xbkg/100 cm2) must be remediated to acceptable levels. The results of the wipe tests must be written on the back of the waste container tag.
3.2.2 Aqueous Liquid Waste
Aqueous liquid wastes containing radioactive materials must be accumulated in unbreakable containers not exceeding one gallon in capacity unless specifically approved by the RSO prior to use. The liquid waste containers must prohibit the release of volatile radionuclides and must be in a secondary containment vessel capable of holding the maximum volume of the primary container. The primary liquid waste container must have a "Caution Radioactive" label affixed to it and it must be labeled with:
- Volume
- Isotope
- Activity
- Chemical components
A tally sheet is recommended for each container to aid in keeping an accurate record of the total activity of the radioactive waste in the container. Liquid waste containers will be picked up for disposal by Radiation Safety staff (Section 3.3 provides details on radioactive waste pick-ups). Prior to pick-up the container must be sealed, wipe tested for removable contamination, placed in a 4 mil plastic bag and securely closed with a twist tie or tape. Any removable contamination detected greater than twice background (2xbkg/100 cm2) must be remediated to acceptable levels.
3.2.3 Non-Aqueous/Organic/Hazardous Chemical Liquid Waste
The generation of non-aqueous, organic, or hazardous chemical radioactive liquid waste is prohibited unless specifically authorized by the RSC. (Section 3.6 provides details on determining if a liquid radioactive waste that will be generated will contain hazardous properties/chemicals). If generation of this type of radioactive liquid waste is authorized, it must be accumulated separate from the aqueous radioactive wastes and in a non-breakable container not exceeding one gallon in capacity. The waste container must prohibit the release of volatile radionuclides/chemicals, be properly shielded and be contained by a secondary containment vessel capable of holding the maximum volume of the primary container. The primary liquid waste container must have a "Caution Radioactive" label affixed to it and it must be labeled as to:
- Volume
- Isotope
- Activity
- Chemical components ( all components of mixture with no abbreviations or chemical formula)
- pH
Generators must ensure that incompatible compounds are not mixed together and that mixtures which may cause the release of volatile radioactive materials or gases are not created.
A tally sheet is recommended for each container to aid in keeping an accurate record of the total activity of the radioactive waste in the container. This type of waste must never be disposed of through the sanitary sewer system. Liquid waste containers will be picked up by Radiation Safety staff (Section 3.3 provides details on radioactive waste pick-ups). Prior to pick-up the container must be sealed, wipe tested for removable contamination, placed in a 4 mil plastic bag and securely closed with a twist tie or tape. Any removable contamination detected greater than twice background (2xbkg/100 cm2) must be remediated to acceptable levels.
3.2.4 Liquid Scintillation Waste
Radioactive scintillation wastes must be stored in the vials in which they are counted and placed in 4mil-lined waste containers (generally, in approved 5 gallon pails). Biodegradable, non-hazardous, high flash point liquid scintillation cocktails must be used unless specific authorization to use alternative cocktail is received from the RSO/RSC. Liquid scintillation wastes must be separated by isotope and by flash point (i.e. low flash point, <180 degree F, from high flash point, > 180 degree F).
Liquid scintillation wastes containing 0.05 uCi/ml or less of C14 or H3 are considered de-regulated and must be segregated from radioactive vials. Scintillation wastes that cannot be differentiated from background (<2 x bkg) are considered to be non-radioactive and must be separated from radioactive scintillation waste.
Tally sheets must be provided for each scintillation vial waste container and the container must be labeled with:
- Flashpoint (>180 degree F or < 180 degree F)
- Cocktail Name and Manufacturer
- Total volume in milliliters
- Isotope or "non-radioactive"
- Total Activity
Radioactive, de-regulated and non-radioactive scintillation vial waste will all be picked up by Radiation Safety staff (Section 3.3 provides details on radioactive waste pick-ups). All scintillation vial waste containers must be securely closed prior to pick-up and wipe tested for removable contamination. Any removable contamination detected greater than twice background (2xbkg/100 cm2) must be remediated to acceptable levels.
3.2.5 Vertebrate Animal Carcasses
Vertebrate animal carcasses and tissue containing radioisotopes must be separated by isotope. Any carcasses containing pathogens must undergo procedures necessary to neutralize the pathogen prior to disposal. Each carcass must be wrapped in absorbent materials and placed in individual plastic bags. Individually wrapped carcasses may be placed in large, 4 mil, transparent plastic bags, not to exceed 2 kg of total weight. Each bag must be labeled with:
- Isotope
- Total activity
- Total weight of the carcass or tissue
- Date
- Supervisor's name
Animal carcasses and/or tissue must be kept frozen at all times prior to disposal. Since the University's Radioactive Waste Storage Facility has a limited amount of freezer space, radioactive animal carcass and tissue waste pick-ups will be scheduled with the generator as space allows. It is the responsibility of the generator to properly label, package and store carcasses until a disposal option or storage space is available.
Animal carcass waste pick-ups will be completed by Radiation Safety staff. Prior to pick-up, the waste containers/bags must be securely closed and wipe tested for removable contamination. Any removable contamination detected greater than twice background (2xbkg/100 cm2) must be remediated to acceptable levels.
Animal carcasses containing 0.05 uCi/gm or less of C14 or H3 may be disposed of as non-radioactive. Records of the disposal indicating the assay of the carcass and the date and method of disposal must be maintained indefinitely.
3.2.6 Radioactive Sharps
All "Sharps" materials such as razor blades, needles, broken glass, syringes (with or without needle attached), etc., that are contaminated with radioactive material must be accumulated in a puncture proof container designated and labeled for radioactive waste only. The sharps containers must be segregated by isotope, marked radioactive and labeled with the isotope, the activity and the date. Radioactive sharps waste containers will be picked up for disposal by Radiation Safety staff (Section 3.3 provides details on radioactive waste pick-ups). The waste containers must be wipe tested for removable contamination prior to pick-up. Any removable contamination detected greater than twice background (2xbkg/100 cm2) must be remediated to acceptable levels. If the sharps waste contains any biological, pathogenic, or infectious material it must undergo procedures necessary to neutralize the biological hazard prior to pick-up for disposal.
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3.3 Laboratory Waste Pick-ups
Laboratories may request a radioactive waste pick-up by completing a "Waste Pick-up" form and sending it to the Environmental Health Office. Radioactive waste pick-ups will be scheduled and completed by Radiation Safety staff.
Radiation Safety staff will perform the transfer of the radioactive wastes to the University's Radioactive Waste Storage Facility. All radioactive waste must be tallied, packaged and labeled in accordance with Section 3.2 of this Handbook, prior to arrival of Radiation Safety staff. All liners must be intact and securely closed with twist ties or tape. Waste which requires special packaging or which does not fall into a specific category outlined in Section 3.2, must be packaged under the direction of Radiation Safety staff.
The generating laboratory must wipe test the radioactive waste container for removable contamination prior to pick-up and indicate the results of the survey on the reverse side of the waste container tag. Any removable contamination detected greater than twice background (>2x bkg/100 cm2) must be remediated to acceptable levels prior to pick-up. Waste container tallies and removable contamination survey results must be retained by the generating laboratory for a minimum of one (1) year.
At the time of pick-up, Radiation Safety staff will inspect the waste for radioactive labels, sharps, syringes, lead, etc. Wastes containing any of these materials will be refused for pick-up until properly removed by the generating laboratory. Radioactive waste tags will be completed for wastes which are found to be suitable for pick-up. These tags will indicate the contents of the waste container including isotope, activity, volume, waste form and generator. The generating laboratory will be requested to sign the waste tag to authorize that the waste information provided is accurate.
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3.4 Radioactive Waste Disposal
The disposal of radioactive waste generated at Syracuse University will be accomplished by means of sewer disposal, decay in house or transfer to an authorized recipient. With the exception of sewer disposal, only Radiation Safety staff may dispose of radioactive waste.
Laboratories which generate radioactive waste must provide accurate information regarding the waste (i.e. activity, volume, contents) to Radiation Safety staff at the time of pick-up. This information will be used to ensure proper storage and disposal, for calculating decay dates, for manifesting, etc. Generating labs m