FAQ REGARDING SECURITY OF RADIOACTIVE MATERIALS
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ANSWERS TO FREQUENTLY ASKED QUESTIONS
REGARDING THE SECURITY OF RADIOACTIVE MATERIAL
This question and answer set is being provided to clarify some frequently asked questions regarding the security of radioactive material at the University of Virginia.
Background
Security of radioactive material is addressed in two paragraphs of the Federal Regulations. These are:
- 10 CFR 20.1801 Security of stored materials
- The licensee shall secure from unauthorized removal or access licensed materials that are stored in controlled or unrestricted areas.
- 10 CFR 20.1802 Control of material not in storage
- The licensee shall control and maintain constant surveillance of licensed material that is in a controlled or unrestricted area and that is not in storage.
Compliance with the regulations
The test for compliance is straightforward: Can someone remove radioactive material from your laboratory without you, or another person in your lab, knowing it? If the answer is yes, then the security in the lab is not satisfactory. That is the test that EHS will use in evaluating individual laboratory security plans. It is also the test that will be used when EHS personnel make random security checks of radioactive material-use rooms and areas.
Question Summary
Questions 1-13 : What needs to be secured?1. What forms of radioactive material must be secured?
2. If a room is posted "Caution Radioactive Material," do I have to lock the door even if there is no radioactive material in the room?
3. Can an area be locked instead of individual rooms?
4. Can a radioactive material work room across the hall from where I'm working be left open if I'm moving back and forth between the rooms?
5. If I'm in an office or other room inside my lab, can I leave the main lab unlocked?
6. Can I leave the door to the lab unlocked or open if all radioactive material (including waste) is locked in a cabinet or refrigerator?
7. May I leave the door to my lab open and not under my surveillance if I install an entry alarm system? 8. Does equipment that contains radioactive material (e.g. freezers and LSC) stored in hallways need to be locked?
9. My radioactive material cold room cannot be locked. Can I leave radioactive material in this area unsecured?
10. All my radioactive material is secured properly and I have empty waste containers in the lab. Do I have to lock the room?
11. I have a liquid scintillation counter which has a radioactive sealed source as an integral part of it. Do I have to secure it?
12. Are there activity limits below which security rules do not apply?
13. How can I make changes to my security plan?
Questions 14 -19: Security problems which occur as a result of others
14. What should I do if I notice an unlocked, unoccupied radioactive room or area which is not under my control?
15. How can I ensure that personnel who work in my lab, but do not use radioactive material, do not violate the security requirements?
16. How can I prevent people who don't work in my lab from violating the security rule?
17. Housekeeping staff opens my radioactive material-use rooms after working hours and doesn't lock them when they are finished. What should I do?
18. My lab was broken into during the night. What should I do?
19. I always lock my radioactive material-use rooms. However, renovators came in during the weekend, worked, and left the door open while they were on their lunch break. Am I responsible and how can I prevent this from happening?
Question 20: Consequences of failure to secure
20. What are the consequences if I fail to secure a radioactive material room, area or piece of equipment?
1. What forms of radioactive material must be secured?
- The following must be secured without regard to activity. That is, there is no lower limit that can be disregarded:
- Stock vials and other containers of radioactive material
- Radioactive material in experiments, including material and check sources in liquid scintillation vials
- Radioactive material contained in waste
- The following are not subject to the security plan:
- Low-level contaminated items such as pipettes and lab glassware
- Low-level items that are labeled with "radioactive material" tape
- Radioactive check sources secured to Geiger counters
- Radioactive sources which are integral parts of equipment which cannot be easily removed (e.g. internal standardization source)
- No. However, an NRC inspector pointed out during the last inspection that it might confuse the lab security issue. If lab communications are poor, someone may start using radioactive material in the room without others being aware. You will also have to explain why your room isn't locked if EHS personnel notice it's unsecured.
3. Can an area be locked instead of individual rooms?
- Yes. If you can secure areas such as hallways, suites, and building sections, the rooms within this area may be left unlocked or open. However, the entrances to the secured areas must be locked at all times.
- No, unless you have constant control over the entrance to the lab that contains radioactive material. The test is to ensure that no unauthorized individual can enter and remove radioactive material without being challenged. If this will be a routine practice, it should be added in writing to the security plan your Authorized User has filed with EHS.
5. If I'm in an office or other room inside my lab, can I leave the main lab unlocked?
- No, unless you have constant control over the entrance to the lab that contains radioactive material. The test is to ensure that no unauthorized individual can enter and remove radioactive material without being challenged. If this will be a routine practice, it should be added in writing to the security plan your Authorized User has filed with EHS.
- Yes.
- Yes. This is allowed if you can hear the alarm when someone enters the room, and you respond to the alarm by investigating each entry.
- Yes.
- No. The acceptable alternatives are:
- Find a cold room that can be locked. Amend your authorization as required
- Place the radioactive material in a locked cabinet within the cold room
- Have a lock installed on the cold room door
- Prior to installing any lock on any door (cold room, lab door or hallway door) you must contact FP&C to ensure that the lock is an approved type and design. If you install a lock that has not been approved, you will bear the expense of replacing it with a proper type.
- No.
- No. However, the calibration vials and the sample vials must be secured. If you have samples in the LSC, you must either lock the room, lock the unit, or otherwise maintain immediate control while the material is in the counter.
12. Are there activity limits below which security rules do not apply?
- No.
13. How can I make changes to my security plan?
- The Security Plan which is on file with EHS must be adhered to at all times. You must submit your change in writing, prior to proceding with any changes to security practices in your areas.
- No actions are required of you. However, we suggest that you notify the Authorized User that the room was found unsecured.
- The security requirements apply to the material, not the people. Therefore, all personnel in your lab shall be trained and held responsible for radioactive material security.
16. How can I prevent people who don't work in my lab from violating the security rule?
- University employees and students: Although these persons should have received some level of radiation safety training, you should remind them not to leave your room(s) unsecured.
- Non-UVA personnel: These persons most likely have not received training. You must oversee their activities while they are in your lab or instruct them on security requirements. You are responsible for the actions taken by non-UVA personnel that you allow in your lab.
- Contact EHS when this happens. All Environmental Services and Facilities Management housekeeping personnel should have received a short course in radiation safety. In addition, you should communicate with the housekeeping staff about safety in your labs.
18. My lab was broken into during the night. What should I do?
- Immediately call both the UVA Police and EHS to report the break-in.
- Supervision of UVA Facilities Management personnel and outside contractors is the responsibility of UVA Facilities Planning and Construction (FP&C). Their managers have received training regarding the requirements for calling the appropriate EHS group for assistance and approvals prior to working in radioactive material-use rooms. However, don't assume that EHS has been notified about work in your radioactive material-use rooms. If you have advance knowledge of renovations or maintenance work, please call EHS and give us the scheduled times and dates. We will assist FP&C in developing a plan that includes security of your radioactive material-use rooms.
- If lab personnel will not be present during renovation work, instructions should be given to renovators or maintenance personnel to lock the door whenever workers leave the area.
- In any case, if you discover that security in your lab has been violated by the renovators or maintenance personnel, call EHS so we can contact FP&C and take corrective action. You will not be held responsible.
- This depends on the circumstances and the past security history of the lab. A report must be filed with EHS and further actions will be determined by the Radiation Safety Committee. Willful violation of the UVA radioactive material security program may lead to suspension or revocation of one's authorization to use radioactive material. Refer to the Radiation Safety Committee Sanctions.
END FAQ