No. 2 - October 30, 1995

OF SPECIAL CONCERN
CONTROL OF LICENSED RADIOACTIVE MATERIAL

All Responsible Users of radioactive material under the University's broad scope license need to be concerned about the physical control and security of the radioactive materials in their laboratories. Recent events elsewhere should underscore this concern. The Nuclear Regulatory Commission is presently investigating two serious incidents that occurred at large prestigious biomedical research institutions (institutions very similar to the University of Utah) which involved loss of control of licensed radioactive material. In each instance P-32 was deliberately or negligently mishandled, resulting in significant internal contamination of one or more research personnel. Attached to this Note is a copy of the NRC Information Notice 95-51 which provides more detailed information about these two incidents.

Control of licensed material is addressed in the Utah Radiation Control Rules:

R313-15-801 - "The licensee or registrant shall secure from unauthorized removal or access licensed or registered sources of radiation that are stored in controlled or restricted areas."

R313-15-802 - "The licensee or registrant shall control and maintain constant surveillance of licensed or registered radioactive material that is in a controlled or unrestricted area and that is not in storage or in a patient."

These State rules are identical to the those cited in the NRC Notice. The University and all Responsible Users are expected to comply with them at all times. If radioactive materials are misplaced, unaccounted for, accidentally disposed of as regular trash, or stolen, then proper control was not maintained and a violation of the applicable rule is assumed to have occurred.

What specific actions do you, as an RU, need to take to comply with the letter and the intent of the rules? Any one or combination of the following actions may be taken to comply with requirements to secure licensed radiation sources:

(1) LOCK UP THE SOURCES - Place all radioactive sources in a locked storage cabinet, refrigerator or freezer. The lock may be a keyed or combination lock. If you have a cabinet or refrigerator that doesn't lock, you can have the University key shop (call 1-8265) or Hospital key shop (1-2002) install a padlock and hasp for you. To comply with the rule, however, the storage location must be kept locked whenever the lab is unoccupied, and the key or combination should

not be accessible to a casual visitor. If it is impractical to keep your lab refrigerator locked, then install a locked box or container within the refrigerator to store your sources in. This container needs to be fastened to the cabinet or refrigerator shelf to prevent its removal.

(2) LOCK UP THE LABORATORY - Keep your lab locked whenever unoccupied. Locking the laboratory is less convenient than locking up the sources, especially for laboratories that have a number of employees who work in or must have access to your lab. But locking up an unoccupied lab also deters theft of other valuable materials or equipment.

(3) PAY ATTENTION - Keep your lab under constant surveillance. This works only if radiation users are in the lab at all times, the source location is always within their view, and they are not reticent about challenging anyone who enters the lab whom they do not know. For constant surveillance to be effective all your workers need to be reminded frequently to be alert.

Although any one of the three methods mentioned will comply with the requirements, the most effective approach to controlling your radioactive sources is to employ all three methods. This "defense-in-depth" will give you the greatest protection against noncompliance or unauthorized removal or mishandling of your licensed material.

The issue of proper control of licensed radioactive material has been stressed several times during recent inspections by the Utah Division of Radiation Control. In fact, DRC inspectors have made unannounced visits to several labs to evaluate our control of licensed material, and I expect that they will continue to do so. In addition, this issue is looked at during internal audits conducted by the University's Radiation Safety Committee, and will be emphasized by your Radiation Analyst during his/her routine lab surveys. Because of the two recent incidents described in the NRC Information Notice it is certain that this issue will receive even greater attention by regulators in the immediate future.

Please pass this information on to everyone in your research group and raise their security awareness. Add it to the agenda for your group meetings. You may also post this Note on your bulletin board and make copies as you see fit. If you have any questions regarding this issue feel free to call this office, or ask your Radiation Analyst. With everyone's participation the University of Utah won't get into the same pickle as the two institutions mentioned in the NRC Information Notice. Thanks for your interest and cooperation.

J. J. Thompson

10/30/95