XI.     Special Provisions for Outlying Sites

            The radiation safety program at WSU was originally designed for users of radioactive materials and radiation machines who were located on the Pullman campus.  However, the use extended to several outlying sites, i.e., to the WSU branch campuses and the research and extension centers.  The Radiation Safety Office, positioned on the Pullman campus, is responsible for encompassing the outlying sites with the WSU radiation safety program.  The considerable distances separating some of the outlying sites from the Pullman campus render this task difficult, at best.  The RSO is required to visit each outlying site, at which users are present, at least twice annually.  Both provision of services and enforcement of regulations must be modified to accommodate the circumstances peculiar to the outlying sites.  The purpose of this section is to bring together those portions of foregoing sections which pertain directly to the outlying sites, and to add further explanations with the goal of ensuring applicability and comprehensibility of the program for these locations.

XI.A.    Scope

            In theory all aspects of the radiation safety program apply directly to outlying sites, but in reality various areas of the program require modification.  The scope of this section is to detail the user requirements for outlying sites, first by examining portions of each of the pertinent foregoing sections in some detail, and second by including an RSO brief summary of instructions for users at outlying sites.

XI.B.    Clarification of Program Features by Section (Sections I, II, IV, and VI require no modification.)

XI.B.1.            Authorization to Use Sources of Ionizing Radiation (Section III)

            A physical inspection by RSO personnel of the facilities and equipment of an applicant for authorization, generally constituting part of the RSO review of an application, may be delayed until the next scheduled visit of RSO personnel to the site.  However, the time of the visit may be adjusted somewhat to accommodate the needs of an applicant.

XI.B.2.            Acquisition of Sources of Ionizing Radiation (Section V)

            Specific provisions for users at outlying sites are set forth in Subsections V.B.4. (purchases of radioactive materials) and V.B.5.b. (transfer of radioactive materials).  However, references in Subsection V.B.6.d. to disposals via incineration and the sanitary sewerage system do not apply at outlying sites; such disposals are performed only on the Pullman campus (possibly including wastes collected from outlying sites by RSO personnel).

XI.B.3.            Disposition of Sources of Ionizing Radiation (Section VII)

            Specific provisions for users at outlying sites are set forth in Subsection VII.A.  In Subsection VII.B.2. the reference to the RSO "routinely" collecting radioactive waste must be construed in terms of the two or more annual visits to the site.  Mixed waste guidance has been provided in several RSO memoranda (see Section XVI.)  The reference in Subsection VII.B.4. to disposal to the sanitary sewer system contains a reminder that outlying sites are excluded from this discussion.  Similarly, Subsection VI.B.6. refers to incineration, which is conducted only at the WSU Pullman incinerator.

XI.B.4.            Radiation Protection Standards and Guidelines (Section VIII)

            Training, which is addressed in Subsection VIII.B., differs slightly for outlying sites.  However, all topics in the basic syllabus are covered in a shorter course offering.

            The bioassay program is discussed in Subsection VIII.C.2.  At present there is no general plan to enable personnel at outlying sites to participate in the bioassay program.  In the event that circumstances require such participation, appropriate arrangements will be made on a case-by-case basis.

XI.B.5.            Laboratory Monitoring (Section IX)

            The comprehensive laboratory survey program described in this section envisions a general schedule of surveys by RSO staff as well as by laboratory personnel.  Clearly, the schedule set forth for the RSO staff must be modified in the case of laboratories situated at outlying sites.  The frequency of those surveys is determined by the visitation schedule, with a goal of inspecting twice a year.  (This specification was approved by DoH, in recognition of the unique circumstances pertaining to the outlying sites.)

            In Subsection IV.B.3. provisions for storing sealed sources in the cave at the Nuclear Radiation Center (Pullman campus) are discussed.  In the case of outlying sites, the RSO reviews and approves all locations where radioactive materials are used or stored.

XI.B.6.            Emergency and Other Abnormal Situations (Section X)

            In this section are discussed numerous situations in which laboratory personnel are required, invited, or encouraged to contact the Radiation Safety Office for assistance.  In the case of such situations at outlying sites, the assistance would of necessity be provided by telephone consultation.  Incident reports must be filed by the authorized user in every case.

 

XI.C.   Radiation Safety Instructions Off Campus Research/Extension Centers

 

XI.C.I. Introduction

            In an effort to manage the uses of radioactive materials at WSU's non-Pullman permanent locations, the RSO has designated a site radiation safety representative.  That individual coordinates and assists the RSO in the safe use of radioactive materials at that location.  The RSO and site radiation safety representative will work closely together to ensure that uses of radioactive materials meet all safety and regulatory requirements.

XI.C.2.            Acquisition of Radioactive Materials

            The approval to acquire radioactive material is granted by the RSC through the issuance of a radioactive material authorization.  All requisitions and blanket orders for use of radioactive materials must be forwarded to the RSO for approval and documentation.

XI.C.3.            Delivery and Receipt of Radioactive Material

            The direct delivery of radioactive materials to off campus locations is permitted, provided that the following protocol is adhered to:

a.         Delivered packages must be secured from unauthorized access.

b.         The site RSO representative or the requesting authorized user must be contacted immediately for pickup.

c.         The following "Procedures for Safely Opening Packages Containing Radioactive Materials" must be adhered to:

 

PROCEDURES FOR SAFELY OPENING PACKAGES CONTAINING RADIOACTIVE MATERIALS

(1)       Visually inspect package for any sign of damage, such as moisture or broken/crushed outside surfaces.

(2)       Measure exposure rate at 3-ft (1-meter) and at the surface of the package.

            (a)  If 3-ft reading exceeds 10 mR/hr stop immediately

            & notify the RSO.

            (b)  If contact reading exceeds 200 mR/hr stop immediately & notify the RSO.

(3)       Put on gloves.

(4)       Wear safety glasses or goggles if a potential for a splash hazard exists.

(5)       Wipe survey the external surface (100 cm2) of the package. Count using appropriate analytical instrumentation (LSC, planchet or some other appropriate fixed-geometry detector/scaler combination). If removable contamination on the external surface exceeds 2200 dpm/100 cm2, rewipe and recount to confirm the results.  If confirmed, inform the RSO immediately and detain the delivery person, if feasible.  The RSO will inform the supplier, the carrier, and regulatory authorities, as necessary.

(6)       Open the package and verify contents, through review of shipping paperwork.  Visually inspect the inner container and/or packing materials for evidence of damage.  Wipe the inner vial for contamination.  If vial is contaminated, be cognizant of the levels and use routine contamination control during use, and wear gloves.  Some decontamination efforts may be necessary.  If you need assistance, call the RSO.

(7)       Record all radiological survey data on the Radioactive Shipment Record (RSR).

(8)       Survey empty package and packing materials for contamination. (Segregate and label, as radioactive, any suspect materials.)  If the package and the packing material are free of contamination, you must deface all references to radioactive materials, and then you may discard the materials as non-radioactive.

d.         Complete all remaining portions of the RSR, copy, and forward original to RSO - Pullman for documentation and inventory control.

XI.C.4.            Laboratory Surveys

            The required radiological surveillance and record keeping does not differ from that utilized in Pullman (see Section IX).

XI.C.5.            Radioactive Waste - (Please review Section VII.)

            (The RSO will supply necessary waste forms for appropriate documentation and inventory control.)

a.         Dry Waste:  Must be stored, secured, and shielded (appropriately) in a 2 ft2 waste box until picked up by the RSO.

b.         Liquid Waste:  These wastes may be divided into two general groups (Non-Dangerous Liquid Wastes and Dangerous Liquid Wastes).

c.         Scintillation Vials:  These wastes are treated as a mixed waste, and therefore must be segregated from all other waste streams.

d.         Animal Carcasses:  A mechanism for interim storage in an appropriately posted freezer is required.  The RSO will be required to package any animal carcasses on-site and transport to the RSO - Pullman or an appropriate waste disposal facility.

e.         Storage for Decay:  Any storage of radioactive waste for decay must be specifically approved by the Radiation Safety Office.

XI.C.6.            Shipment of Radioactive Material

            Radioactive material shipped to the Pullman campus or to any other institution must meet Department of Transportation regulations.  A copy of the recipient's Radioactive Materials License must be on file at the RSO prior to shipment.  The Radiation Safety Office must be notified and will coordinate and oversee the transfer.