Radiation Safety Refresher Training for 2007

1. Radiation Safety Refresher Training for 2007 Sue Dupre, Radiation Safety Officer Stephen Elwood, Assistant RSO

2. Training topics for 2007 • The results of the intensive audits of several labs conducted in 2006 by the Radiation Safety Committee • The procedure for ordering & transferring radioactive materials • The procedure for receiving and securing rad packages in the labs • Two contamination episodes • A few administrative reminders • A discussion of the Agreement State process initiated by NJ to take over all regulation of radioactive material

3. Audit Findings Each year, the Radiation Safety Committee’s audit teams find fewer significant issues. But some problems are recurring: • Although we believe that researchers consistently perform postoperational surveys, some people do not record their surveys in the Survey Logs. • Remember: it is a requirement of the University license to document your postoperational surveys • If you use H-3, also be sure to enter the wipe test results into the Survey Log.

4. Audit Findings (cont’d) • EHS staff observed a person performing radioisotope work without a lab coat. • Certain protective clothing must be worn for work with any open source: • Lab coat • Gloves • Closed-toe shoes (no sandals permitted)

5. Ordering Radioactive Materials There were two cases this past year in which orders for radioactive materials were mistakenly placed as non-rad reqs: • In one case, a new administrative assistant did not know she was ordering rad materials and used the wrong Commodity Code in PeopleSoft • In the 2nd case, the lab manager was on vacation. The lab members who filled in for the lab manager did not realize that there is a special PeopleSoft Commodity Code for radioisotopes • The correct Commodity Code for rad materials is RAD37 • As a result these orders were not routed to EHS for approval. However, other precautions exist to catch incorrect orders.

6. Ordering Rad Materials (cont’d) • Not everyone is familiar with the terminology for radioactive materials. Make sure that the person who actually places the req in PeopleSoft knows that the req is for radioactive material. • Train new admin assistants and lab managers in how to place rad orders!

7. Replacement Orders • Our vendors are generally willing to replace orders if you believe the material that arrived is of poor or questionable quality (for instance, if the dry ice is all gone) • Do not call the vendor to request a replacement. Instead, call EHS. EHS will work with Purchasing and the vendor to get you a replacement order.

8. Generally Licensed Devices • Generally Licensed Devices are devices that contain radioactive material and which are allowed by regulation to be purchased without any special license from the NRC. • Some examples include Electron Capture Detectors in gas chromatographs, self-luminous exit signs, static eliminators, lead paint analyzers, liquid scintillation counters, etc. • However, such devices often have special requirements for leak • tests and special disposal requirements that must be managed • through the Radiation Safety Officer at the facility. If you receive a device that contains a notice that it contains radioactive material, notify EHS immediately!

9. Ordering X-ray Equipment • A new x-ray machine was discovered as it was being unloaded at the loading dock. • EHS did not know this machine had been ordered. • NJ DEP requires that x-ray units be registered and surveyed. Special x-ray safety training and radiation monitoring badges must be provided to x-ray users. • Consult EHS ASAP if you plan to acquire x-ray equipment.

10. Transferring Radioactive Materialsbetween University Labs • If you loan radioactive materials to another lab, you must go to the EHS website to check whether the borrowing lab is authorized to possess that radioisotope. • At the EHS website, click on Radiation Safety and then click on Radioisotope Transfer on the side menu. • You’ll see a form (see the next slide) which will allow you to enter the name of the borrowing lab, the name of your lab, the isotope, and the amount to be transferred. • After you click Submit, you will see a screen that tells you whether you can proceed to transfer material to the borrowing lab. • At the same time, an automatic e-mail notice is sent to EHS to notify EHS that a transfer has been made.

11. Transferring Radioactive Materials between University Labs

12. Receipt & Security of Rad Materials Recently a rad package was found unsecured on a lab bench in an empty lab. This is a violation of our license conditions. When a rad package is delivered to the lab: • Lock the package away immediately or remove the stock vial from the packaging and lock the vial away.  • Do not set the package aside with the intention of securing it later.  • If you are unable to lock the package away right away, do not sign for the package. Ask someone else to sign for the package or ask that it be redelivered later. • Promptly notify the end user that the package has arrived.

13. Contamination Episode No.1 • An instance of wrist contamination occurred when wash water leaked inside gloves during clean-up of glassware. Contamination was detected and was washed away immediately. • EHS was notified immediately and verified that the skin had been successfully decontaminated. • EHS must be notified about any condition of skin contamination even if you believe it has been completely cleaned. • This was a very minor incident, but it demonstrates that skin contamination can be dealt with very easily if it is found promptly.

14. Contamination Episode No. 2 First thing in the morning, a hybridization tube containing P-32 was discovered to have leaked inside an oven located near the main lab entrance. As a first step, the researcher carried the tube down the center of the lab to the radioisotope hood for disposal. How would you have responded?

15. Contamination Episode No. 2 Hopefully, you would have left the tube right where it was in the oven and then would have called EHS immediately. This is what happened as a result of moving that leaking tube …. After moving the tube, the researcher called EHS. When Sue Dupre arrived at the lab, she immediately surveyed the vicinity of the oven and found substantial contamination on the floor in front of the oven … and then eventually in a number of other places on the floor between the oven and the hood. The shoes of everyone who had entered the lab so far that morning were contaminated. Always suspect floor contamination. If nothing else is available, wrap your shoes in saran wrap. Shoes were decontaminated or were bagged and set aside for a few months.

16. Contamination Episode No. 2 Most of the lab surveys and decontamination were performed by Mike Fredericks, Sue, and two other radioisotope users in the lab. It is very important to realize that any lab members involved in a contamination incident are expected to stop what they are doing and work with us to survey, decontaminate, and close out the incident.

17. Administrative & Other Matters

18. Reminder: Declared Pregnant Worker Program • A pregnant woman may choose to formally “declare” her pregnancy. • The fetal dose limit is 500 mrem for a Declared Pregnant Worker. • If you become pregnant, consider consulting with Sue Dupre for additional information and to determine if it makes sense to declare your pregnancy. Sue would be happy to keep your inquiry confidential. • More details are available at the EHS website.

19. New Chair of the Radiation Safety Committee Prof. James Broach has been the Chair of the Radiation Safety Committee for over a decade, but he has just retired. The new Chair is Prof. Elizabeth Gavis (Molecular Biology). Feel free to contact Prof. Gavis at lgavis@princeton.edu with your comments, complaints, or compliments on the radiation safety program.

20. Web-Based Dose Reports • Each time a new set of dose reports arrives, EHS sends out an e-mail notice to everyone who is badged. • Log in through DBToolbox, using your NetID and LDAP password. Enter your Badge Participant Number. • Any problems? A few browser-related problems have occurred. Please let EHS know if you have any problems seeing your report.

21. Lab Survey Reports Once a month our radiation safety techs visit your lab to perform contamination surveys and compliance inspections. After the survey, EHS sends a survey report to the lab manager or the lab contact. A portion of the report is shown here. Sometimes lab members are concerned when wipes with activity greater than Minimum Detectable Activity is reported (as shown above).

22. Lab Survey Reports (cont’d) What if your report indicates the presence of activity > MDA? Is that a condition of concern?

23. Lab Survey Reports (cont’d) • Remember that counting radioactivity is a statistical process. Background varies and could be unusually low. • EHS always expects to see some wipes that exceed MDA (~ 5 – 10 dpm). • EHS regards activity of 15-20 dpm or more as truly indicative of contamination. • EHS will contact the lab by phone or e-mail when contamination > 100 dpm is found on a wipe or if a pattern of low-level contamination is found, for instance, if several contaminated wipes with activity < 100 dpm are found.

24. NJDEP and the Agreement State Process • When the regulatory process for radioactive materials was first established by Congress many years ago, the regulation of most radioactive materials was turned over to the federal government. • However, Congress established a process by which a state could apply to the Nuclear Regulatory Commission and take over the regulation of radioactive materials under certain conditions. When a state reaches such an agreement with the NRC, the state is called an Agreement State. • In May of 2006, Gov. Corzine notified the NRC that NJ wants to pursue Agreement State status.

25. The Agreement State Process (cont’d) • NJDEP is fast-tracking the process and expects to take over all radioactive materials oversight by August 2009. • The NRC will take a year to review NJ’s application for Agreement State status. • NJ’s regs must be at least as conservative as the NRC’s, though they are permitted to be even more conservative. NJ regulations are expected to be in conformity with NRC regs initially. • NRC periodically reviews Agreement State programs and may rescind Agreement State status if a state does not perform satisfactorily.

26. The Agreement State Process (cont’d) • The two biggest changes that will result from Agreement State status are: • The University will be charged annual fees by NJ DEP (the NRC exempts non-profit educational institutions from fees, but Agreement States typically do not have such exemptions). • Our inspections will be conducted by NJDEP staff who may have a different perspective and a different degree of experience than NRC inspectors. • We hope that the switch to Agreement State status will have little impact for University researchers. • Expect further updates as we get closer to August 2009.

27. Conclusion Your questions, comments and feedback are welcome. Contact Sue at 8-6252 or Steve at 8-6271