[ RadSafe ] Eating and Drinking (UNCLASSIFIED)

Sandy Perle sandyfl at cox.net
Wed Apr 4 13:07:17 CDT 2007



Here is some information that may help::





61 Forsyth Street, Suite 23T85, Atlanta, GA 30303


No. II-00-10 

February 7, 2000


Ken Clark (Phone: 404/562-4416, E-mail: kmc2 at nrc.gov )

Roger Hannah (Phone 404/562-4417, E-mail: rdh1 at nrc.gov )

NRC Staff Proposes $2,750 Fine Against West Virginia University for
Radioactive Materials Violation

The Nuclear Regulatory Commission staff has proposed a $2,750 civil penalty
against West Virginia University in Morgantown, West Virginia, for a
violation of NRC license requirements related to the security of radioactive
materials the university uses for teaching and research.

The NRC has notified the university that the violation, found during an
inspection in November 1999, includes several examples of the university
staff failing to secure licensed materials from unauthorized removal or

On at least four occasions (including during the time of the November NRC
inspection), WVU failed to adequately secure or maintain constant
surveillance of portable gauges containing radioactive materials stored in
an area of the Civil Engineering Building. In addition, during the November
inspection, laboratories in the Mary Babb Randolph Cancer Center, the Health
Sciences Center North and the Agricultural Sciences Center containing
radioactive materials were found unlocked and unattended. 

At a predecisional enforcement conference with the NRC, WVU outlined
corrective actions designed to address the violations and prevent future
problems. The NRC staff determined that since the university's own Radiation
Safety Department had previously identified security problems with the
gauges, the corrective actions, while comprehensive, were not initially
effective in preventing recurrence. 

The NRC also cited the university for several other violations that the
agency felt did not warrant a proposed civil penalty. These less significant
violations included the failure to prohibit eating and drinking in
radioactive material work areas, failure to make proper surveys of
radioactive material work areas, improper labeling of radioactive waste and
failure to adequately post radiation signs in radioactive material work
areas. Although the violations were not included in the proposed civil
penalty, the agency was concerned that many of them had been previously
identified by the Radiation Safety Department, but not effectively

The university has 30 days from receipt of the Notice of Violation to either
pay the fine or protest its imposition.

                         NUCLEAR REGULATORY COMMISSION
                         WASHINGTON, D.C.  20555-0001
                               October 27, 1995

                               CONTROL OF LICENSED MATERIAL
All material and fuel cycle licensees.
The U.S. Nuclear Regulatory Commission is issuing this information notice to
alert addressees to two recent incidents involving potential loss of control
of licensed material, resulting in internal contamination of individuals.
is expected that recipients will review the information for applicability to
their facilities and consider actions, as appropriate, to avoid similar
problems.  However, suggestions contained in this information notice are not
new NRC requirements; therefore, no specific action nor written response is
Description of Circumstances
Recently, NRC was informed of and responded to two incidents involving
phosphorus-32 (P-32) internal contamination of individuals at biomedical
research facilities.  P-32 is widely used in research institutions, as are
many other radionuclides.  Although these incidents both involved P-32, the
inherent security issues extend to all facilities using licensed material.
Case 1:   On June 30, 1995, a licensee informed NRC that an incident
          internal contamination of a female researcher had been reported to
          the licensee's radiation safety office the previous evening.  The
          researcher was in her fourth month of pregnancy at the time of the
          incident.  Contamination was detected when the researcher's
          who worked with her at the licensee's facility, performed a
          survey of their lab.  The licensee identified the radionuclide as 
          P-32.  Accidental contamination appeared unlikely because the
          had stopped working with radioactive material in their lab about a
          month before, and because the radioisotope (P-32) identified in
          bioassay samples is not of the same type her lab used.  Licensee
          security officials and the Federal Bureau of Investigation are
          investigating the possibility that the woman ingested food or
          liquids deliberately contaminated with the radioisotope.  Initial
          calculations (now being refined by NRC, the licensee, and the
          researcher's own technical experts) estimated that the researcher
          ingested tens of megabecquerels (hundreds of microcuries) of P-32.
9510260330.                                                      IN 95-51 
                                                      October 27, 1995
                                                      Page 2 of 5
          Subsequent licensee surveys identified a few droplets of P-32 on
          floor in front of a refrigerator in a lounge adjacent to labs the
          couple use and an internally contaminated water cooler in the same
          building.  Urine bioassays of other workers identified
          25 additional individuals who have low-level internal P-32
          contamination.  In early July 1995, NRC sent an Augmented
          Team to investigate the circumstances surrounding the
          incident.  While the inspection and investigations are ongoing,
          has obtained licensee agreement to improve the control of
          radioactive materials used in its biological and medical research
Case 2:   On October 16, 1995, a licensee informed NRC that an incident
          involving internal contamination of a researcher had occurred at
          facility almost 2 months earlier.  Licensee officials told NRC
          that they had not reported the incident earlier because their
          analyses suggest that the researcher's internal dose was below the
          10 CFR Part 20 reporting criteria.
          According to the licensee, the researcher discovered that he was
          contaminated during a routine survey of his work area.  Also
          according to the licensee, it subsequently detected P-32
          contamination on an item of clothing that the researcher had worn
          earlier that week, when he had last handled P-32 in the
          The licensee performed urine bioassays, and informed the
          that he may have ingested what was described as a drop of P-32
          containing 21.4 megabecquerel (579 microcuries).  The researcher
          told licensee campus police that he believes the contamination was
          not accidental.  NRC and campus police are investigating his
          allegation.  Also, the researcher has requested that an
          consultant prepare a second dose estimate.
          The licensee initially secured all radioactive materials in the
          after discovery of the contamination event.  Since then, the
          licensee has permitted work with radioactive material to resume,
          after requiring more stringent inventory and accountability in the
          lab and tightening security.  On October 17, 1995, NRC dispatched
          Incident Investigation Team to the licensee's site to begin an
          immediate investigation of the incident.  NRC also sent a letter
          the licensee requiring that certain steps be taken, ensuring among
          other things that control of radioisotopes is adequate to provide
          reasonable assurance against another such incident.  NRC's
          investigation is ongoing.
.                                                      IN 95-51 
                                                      October 27, 1995
                                                      Page 3 of 5
The two recent P-32 internal contamination incidents raise a number of
and regulatory issues.  NRC is reviewing its regulations to determine if
need to be revised in light of these events.  Among these issues are
radioactive material security and accountability, survey procedures,
preparation for bioassays, and reporting requirements.  Each of these issues
is addressed separately below.
      a.  Security.  In controlled or unrestricted areas, licensees are
          required by 10 CFR 20.1801 and 20.1802 to secure stored material,
          and to control and maintain, under constant surveillance, licensed
          material that is not in storage.  Access to restricted areas is
          required to be controlled to prevent unauthorized access to
          material.  Licensees should review their programs to ensure that
          they have a radiation safety program in place that will prevent
          deliberate misuse of radioactive materials in all licensee areas.

      b.  Accountability.  10 CFR Part 20 requires the reporting of theft or
          loss of materials above defined levels.  In addition, the Draft
          Regulatory Guide DG-0005, "Applications for Licenses of Broad
          Scope," published for comment in October 1994, states that license
             ... should develop and maintain a strong inventory and
             accountability system.  The institution should have the
             capability to continually track incoming shipments of
             licensed material and account for material usage, decay,
             transfer, and disposal.  A licensee's inventory and control
             system should have the capability to ensure that licensed
             possession limits are not exceeded and that material is
             accounted for throughout the institution at any given time. 
          In light of these events, licensees should review their programs
          determine whether they need to improve their radioactive material
          accountability systems, commensurate with the scope of their
      c.  Detecting licensed material.  NRC emphasizes that conducting
          with adequate, calibrated equipment is a crucial step in
          safe operations.  Many commercially available survey instruments,
          such as Geiger-Mueller detectors, are capable of detecting P-32,
          even after ingestion, in the activity range used in research
          facilities.  In both of these cases, internal contamination was
          originally detected when the researchers conducted routine surveys
          of their laboratories and detected high background readings. 
          Licensees should review their programs to ensure that they are
          conducting surveys with adequate, calibrated equipment..
IN 95-51 
                                                      October 27, 1995
                                                      Page 4 of 5
      d.  Bioassay preparation.  All licensees are responsible for
          to incidents.  Some licensees already have bioassay programs in
          place to comply with the requirement in 10 CFR 20.1502 to monitor
          workers whose intake is likely to exceed 10 percent of the
          occupational dose limits.  Interpretation of bioassay data, when
          regulatory thresholds are approached, may be difficult.  Important
          information on the proper conduct of a bioassay program is
          in Regulatory Guide 8.9, Rev. 1, July 1993, "Acceptable Concepts,
          Models, Equations, and Assumptions for a Bioassay Program" and
          NUREG/CR-4884, "Interpretation of Bioassay Measurements."
          that need immediate medical consultation to respond to an ongoing
          internal contamination event can contact the Radiation Emergency
          Assistance Center/Training Site (REAC/TS), which is funded by the
          U.S. Department of Energy to provide consultation in such
          situations.  The NRC Operations Center can connect callers with
          If internal contamination is detected, health physics consultants
          are commercially available to assist with bioassay and other
          response measures.  However, licensees that plan to use
          may want to identify and make arrangements for those resources
          rather than wait until an incident occurs.  Licensees that need
          in identifying health physics services should contact professional
          societies or organizations for references. 
      e.  Food and beverage storage.  Generally, licensees have procedures
          prohibiting eating, drinking, and smoking in radiologically
          restricted areas.  In light of these events, licensees should
          their programs to determine how food, particularly lunches, snack
          foods, and beverages in unsealed containers, are permitted or
          in their facilities.
      f.  Contact NRC if deliberate misuse of licensed material is
          NRC considers deliberate misuse of licensed material to be of
          significant regulatory interest, and expects to be contacted in
          situations.  Although the magnitude of the dose could be within
          NRC's regulatory limits, the possibility that such a dose was
          delivered intentionally, and possibly with malice, raises concerns
          about a licensee's, a contractor's, or any employee's deliberate
          misconduct, as addressed in 10 CFR 30.10, 40.10, 70.10, and 72.12.

          In addition, pursuant to 10 CFR 30.9(b), 40.9(b), 70.9(b), and
          72.11(b), each licensee is required to "... notify the Commission
          information identified ... as having for the regulated activity a
          significant implication for public health and safety ...." 
          Notification shall be provided in such cases to the Regional
          Administrator within 2 working days.  
 .                                                      IN 95-51 
                                                      October 27, 1995
                                                      Page 5 of 5
The issues raised in these two cases should lead licensees to consider
reexamining their own methods to prevent and, if necessary, respond to
internal contamination incidents.
The information in this notice is preliminary, and the investigations and
inspections in these two cases are ongoing.  NRC may issue further guidance,
as necessary, once results are known and conclusions drawn on these two
This information notice requires no specific action or written response.  If
you have any questions about the information in this notice, please contact
the technical contacts listed below or the appropriate regional office.
                              /S/'D BY DACOOL
                              Donald A. Cool, Director
                              Division of Industrial and
                                Medical Nuclear Safety
                              Office of Nuclear Material Safety
                                    and Safeguards
Technical contacts:  Scott Moore, NMSS          B. J. Holt, RIII
                     (301) 415-7875             (708) 829-9836
                     Mohamed Shanbaky, RI       Thomas Kozak, RIII
                     (610) 337-5209             (708) 829-9866
                     John Potter, RII           Linda Howell, RIV
                     (404) 331-5571             (817) 860-8213
1.  List of Emergency Contacts
2.  List of Recently Issued NMSS Information Notices
3.  List of Recently Issued NRC Information Notices
                                             Attachment 1
                                             IN 95-51
                                             October 27, 1995
                                             Page 1 of 1
                                   LIST OF EMERGENCY CONTACTS
I.    NRC Operations Center
      Telephone:  301-816-5100  (will accept collect calls)
II.   Radiation Emergency Assistance Center/Training Site (REAC/TS)
      Daytime Telephone:  423-576-3131
      24-hour Telephone:  423-481-1000 (ask for REAC/TS)
      (to consult with a physician)


U.S. Nuclear Regulatory Commission

Technical Assistance Request, Authorization of Employee Eating and Drinking
Areas in Labs at Veterans Administration Medical Center, Martinez,

HPPOS-318 PDR-9306280312

Title: Technical Assistance Request, Authorization of

Employee Eating and Drinking Areas in Labs at Veterans

Administration Medical Center, Martinez, California

See the memorandum from J. E. Glenn to R. J. Pate dated

March 27, 1992. This NMSS memo responds to a technical

assistance request from Region V, dated January 17, 1992,

regarding designation of two employee eating and drinking

areas in research laboratories at the Veterans

Administration Medical Center in Martinez, California

(VA-Martinez). Review of this issue reveals a number of

health physics considerations. However, NMSS cannot

justify an absolute requirement that all areas for eating

and drinking be separated from use areas by physical

barriers such as doors.

The eating and drinking areas may be authorized, provided

the following radiation safety concerns are sufficiently

addressed by VA-Martinez:

1. The licensee must specify the typical procedures

carried out, quantities involved, and radioactivity

measured for each isotope in each lab. Large quantities of

radioisotopes may cause greater health and safety concerns.

For example, the procedures conducted in lab area 113A may

involve the use of phosphorous-32 or iodine-125 in

millicurie quantities which could result in considerable

spread of contamination and could not be approved without a

barrier such as a door.

2. The licensee must develop sufficient safety

measures to assure that there is no transfer of food,

drink, or radioactive materials between the radioactive

material use area and the eating area. For example, what

measures will be taken to assure that employees remove

their protective gloves and wash their hands before

entering the eating area?

3. The licensee must detail how the eating area will

be separated from the working area and how the flow of

radioactive material into the area will be restricted. For

example, the area could be marked by tape and posted with

signs, provided such notices are clearly visible to prevent

inadvertent entry with radioactive material.

4. The licensee must confirm that food, drink, or

personal effects will not be stored with radioactive

materials. Specifically, does the eating area designated

in room 112A also serve as a radioactive storage area (is

radioactive material stored in the freezer, refrigerator,

or cabinet)?

5. The licensee must designate one sink in each lab

that will only be used for non-radioactive hand, utensil,

and/or dish washing. The sink must be restricted from

radioactive material and, if possible, should be in close

proximity to the eating area. This sink should be included

in the routine laboratory surveys.

6. The licensee must address the frequency of

radiation surveys and types of measurements to be made in

each of the labs. Alternatively, the licensee may provide

evidence that the existing frequency of scheduled surveys

for each lab and corresponding air filtration systems will

be effective in monitoring the safety of the designated

eating areas. For example, one area of concern is whether

wipe tests for removable contamination of tritium and

carbon-14 will be performed at effective intervals in area


7. The licensee must describe both initial and

periodic training. The training must specifically inform

employees of the restrictions in place and precautions to

be followed. Both new and current laboratory personnel,

including janitorial and other assisting staffs who have

access to the laboratory, must receive training.

8. The licensee must assure that entry and exit to the

designated eating and drinking areas can be obtained

without bringing food and drink through a radioactive

materials use area. This appears to be a problem with room


The determination of the adequacy of the responses provided

by VA-Martinez to authorize the two eating and drinking

areas is the decision of the regional office.

Regulatory references: 10 CFR 20.1201, 10 CFR 20.1501

Subject codes: 5.0, 11.2

Applicability: All





Sandy Perle 

Senior Vice President, Technical Operations 

Global Dosimetry Solutions, Inc. 

2652 McGaw Avenue

Irvine, CA 92614


Tel: (949) 296-2306 / (888) 437-1714 Extension 2306 

Tel: (949) 419-1000 Extension 2306

Fax:(949) 296-1144


Global Dosimetry Website: http://www.dosimetry.com/ 

Personal Website: http://sandy-travels.com/ 



-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On Behalf
Of Borisky, Michael (Civ, ARL/ADLO)
Sent: Wednesday, April 04, 2007 10:50 AM
To: radsafe at radlab.nl
Cc: peggy.purcell at ars.usda.gov
Subject: [ RadSafe ] Eating and Drinking (UNCLASSIFIED)


Classification:  UNCLASSIFIED 

Caveats: NONE


Dear Radsafers,


Can someone point this sealed source and X-ray machine user to the NRC

regulation or Reg Guide that prohibits eating or drinking in areas with

unsealed rad materials.  Thanks!!!


Mike Borisky

Army Research Lab


Classification:  UNCLASSIFIED 

Caveats: NONE


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