Radioactive Material Policy

Introduction

Radioactive materials are occasionally brought shipboard by scientists for use in theirresearch. The primary hazards of radioactive materials are those of the harmful biological effects brought on by exposure to ionizing radiation; although, some isotopes are also toxic by ingestion when found in concentrations greater than normally used shipboard. Radioactive materials typically found onboard when properly used and handled present no danger to the scientist or crew. To ensure this is the case the scientist and crew must follow prescribed protocols and procedures including: monitoring, clean-up, and record-keeping. The use, storage, transportation, labeling, and disposal of radioactive material brought shipboard is regulated through the Nuclear Regulatory Commission (NRC) using 10 CFR (Code of Federal Regulations) as the regulatory basis and 49 CFR (Transportation).(The CFR's are available at no cost on the internet at http://www.access.gpo.gov/nara/cfr/index.html.) The activity and quantity of radioactive material used by the scientist are controlled by license issued to the operating institution for whom the scientist works and is called the Nuclear Regulatory Commission Byproduct Material License or equivalent.

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Radioactive Materials Management

The guiding protocols for proper radioactive materials management shipboard are three fold:

Obtain a Coast Guard approval to handle isotopes shipboard

The first protocol (Coast Guard approval) is accomplished early on in the planning process for investigative work using radioisotopes at sea. The Chief scientist will indicate whether isotopes will be used on the ship in the online Healy cruise planning questionaire. The Coast Guard will notify the scientist of approval to use radioisotopes only after review of the completed application forms. The institution’s Radioisotope Users Committee (or equivalent) will review and approve the proposed research and the Radiation Safety Officer (RSO) will authorize possession and use of the desired radioisotope. Both approvals are required prior to performing work involving radioisotopes onboard Coast Guard cutters and shall be presented with the above forms. Prior to the scientist reporting shipboard and prior to the Coast Guard accepting any supplies involved in the investigative work, the cutter (ice breaker) shall have received the following:

Completion of the following form:

USCG Radioisotope Project Use Request form

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Follow accepted radiological work practices

The second protocol (work practices) shall be the radiological work practices enforced at the authorizing institution and approved by the RSO. The scientist will be responsible for adapting the work practices established at the authorizing institution to the shipboard work areas. The scientist will provide and post all required radiological signs, provide all containments and/or anti-contamination clothing, do monitoring, clean-up of any spills, maintain dosimetry/dosimetry records, and perform final clean-up and survey of the work space for "free release" of the work space. All laboratory work involving radioactive material shall be conducted in the science van. Any in-situ/experimental work outside the van involving radioactive material shall only be conducted in areas approved by the Marine Science Officer. Note: the Coast Guard will not provide any monitoring or survey equipment; the scientist will bring all emitter appropriate equipment shipboard and remove the equipment at the end of the voyage. Coast Guard personnel are not trained or authorized to handle radioactive material and shall not assist the scientist in ways that risk isotope radiation exposure. Once the scientist is shipboard and familiar with the work area, he/she shall brief the Marine Science Officer (or designated representative) on the required radiological work practices and how radioisotopes are involved in his/her work.

Upon arriving shipboard the scientist shall provide the Marine Science Officer the following:

  1. A description of experimental/investigative protocol. This should include the proposed location of work where radioisotopes might be used, procedures for storage, manipulation, isolation, control, containment, clean-up of spills and disposal of the radioactive material.

The following equipment is required for out-of-laboratory incubation experiments:

  1. In-situ incubation shall utilize polycarbonate jars with polyethylene caps or equivalent
  2. On-deck incubation requires as a minimum for spill recovery a 55 gallon, 49 CFR approved liquid non-bulk hazardous material container and three five gallon cubit containers or equivalent equipment as agreed to by the sponsoring institution’s RSO. The 55 gallon container shall contain sorbant material

It is required that isotope isolation vans have a "clean bill of health" from the Miami SWAB Group prior to emplacement on Healy. Wearing of special footwear in the vans is mandatory. The vans must, therefore, have an area in which it is possible to change footwear and clothes (e.g., foul weather gear). This will help isolate isotope contamination in the van from spreading throughout the ship.

Circumstances may occur in which the above procedures will place an undue burden upon a scientific party, in that some experiments may not be feasible within the constraints of the policy, or that, while feasible, meeting the policy would place an unreasonable logistic burden upon the program. In such a case a detailed justification will be required outlining a special protocol indicating a awareness of the potential effects on contamination outside the working area of the vans and a proposed monitoring program to detect potential spills. The Isotope Committee in that case may stipulate conditions associated with a waiver.

Monitoring of potential radioactive spills is imperative. For this reason the following procedures are considered to be of prime importance. At the end of each leg of Healy during which radioisotopes have been used, a SWAB test of the isotope isolation vans, as well as the deck and laboratory spaces, will be performed by the Miami SWAB test laboratory. If for some reason (e.g., remoteness or inaccessibility of the ship) the SWABoperation cannot be carried out by the Miami group, the resident marine technician, in collaboration with the PI, could be requested to carry out the SWAB according to Miami instructions. Samples can then be forwarded to Miami. In case a SWAB test cannot be accomplished, it will be imperative to lock the vans to access by anyone until the tests can be performed. This is particularly a necessity because of clean-up responsibilities of the parties involved in the radioisotopes usage. If two subsequent legs will have radioisotope usage with different investigators, then a SWAB test must be carried out between these legs. The above test program does not preclude the requirement of regular swab tests by the isotope users, which should be carried out at least before the start of isotope work, once a week at a minimum during the cruise, after a suspected spill, and at the end of the cruise.

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Detailed record-keeping

The third protocol (record-keeping) shall be at a level of detail to prevent the loss of control of radioactive material and prevent the inadvertent spread of radioactive contamination. This shall include documentation of any spills and clean-up actions. The scientist must review and implement the record-keeping requirements of Form A11 Radioactive Materials Report found in the ship’s Welcome Aboard Packet. The scientist shall provide the Coast Guard with the following prior to departing from the vessel after completion of the investigative work:

  1. Radioisotope inventory documenting disposition of all quantities of the isotopes used in the investigative work; including a reconciliation of the quantity brought on board and removed from the ship as either waste, unused material, or samples. (See Form A11).
  2. Documentation of surveys performed in the work space; as a minimum initial (prior to isotope use) and final (“free release”) work space surveys shall be performed. (Attach to Form A11).

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Rules for Radioactive Material Disposal

Radioactive material considered waste shall not be discharged at sea but retained in containers for disposition by the authorizing institution. Drain disposal is prohibited. It is the responsibility of the scientist to arrange for the proper shore side disposal of all forms of any radioisotopes remaining onboard at the completion of the voyage.

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