[ RadSafe ] Eating and Drinking (UNCLASSIFIED)
Sandy Perle
sandyfl at cox.net
Wed Apr 4 13:07:17 CDT 2007
Mike,
Here is some information that may help::
NRC NEWS
U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF PUBLIC AFFAIRS, REGION II
61 Forsyth Street, Suite 23T85, Atlanta, GA 30303
_____
No. II-00-10
February 7, 2000
CONTACT:
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
access.
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
corrected.
The university has 30 days from receipt of the Notice of Violation to either
pay the fine or protest its imposition.
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
WASHINGTON, D.C. 20555-0001
October 27, 1995
NRC INFORMATION NOTICE 95-51: RECENT INCIDENTS INVOLVING POTENTIAL LOSS OF
CONTROL OF LICENSED MATERIAL
Addressees
All material and fuel cycle licensees.
Purpose
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.
It
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
required.
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
involving
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
husband,
who worked with her at the licensee's facility, performed a
routine
survey of their lab. The licensee identified the radionuclide as
P-32. Accidental contamination appeared unlikely because the
woman
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
the
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
approximately
25 additional individuals who have low-level internal P-32
contamination. In early July 1995, NRC sent an Augmented
Inspection
Team to investigate the circumstances surrounding the
contamination
incident. While the inspection and investigations are ongoing,
NRC
has obtained licensee agreement to improve the control of
radioactive materials used in its biological and medical research
programs.
Case 2: On October 16, 1995, a licensee informed NRC that an incident
involving internal contamination of a researcher had occurred at
its
facility almost 2 months earlier. Licensee officials told NRC
staff
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
laboratory.
The licensee performed urine bioassays, and informed the
researcher
that he may have ingested what was described as a drop of P-32
containing 21.4 megabecquerel (579 microcuries). The researcher
has
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
independent
consultant prepare a second dose estimate.
The licensee initially secured all radioactive materials in the
lab
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
an
Incident Investigation Team to the licensee's site to begin an
immediate investigation of the incident. NRC also sent a letter
to
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
Discussion
The two recent P-32 internal contamination incidents raise a number of
safety
and regulatory issues. NRC is reviewing its regulations to determine if
they
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
licensed
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
applicants:
... 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
to
determine whether they need to improve their radioactive material
accountability systems, commensurate with the scope of their
programs.
c. Detecting licensed material. NRC emphasizes that conducting
surveys
with adequate, calibrated equipment is a crucial step in
conducting
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
responding
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
provided
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."
Licensees
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
REAC/TS.
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
consultants
may want to identify and make arrangements for those resources
now,
rather than wait until an incident occurs. Licensees that need
help
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
review
their programs to determine how food, particularly lunches, snack
foods, and beverages in unsealed containers, are permitted or
stored
in their facilities.
f. Contact NRC if deliberate misuse of licensed material is
suspected.
NRC considers deliberate misuse of licensed material to be of
significant regulatory interest, and expects to be contacted in
such
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
of
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
cases.
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
Attachments:
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,
California
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
115A.
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
112A.
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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