Section 1-9: Environmental Management/Radiation Safety
1-9-00 Policy
10 Procedures
20 Guidance and Information
30 Reporting Requirements (Reserved)
1-9-00 Policy
This section describes the general requirements and specific goals for managing environmental issues on NIH campuses, including:
• Bulk storage facilities.
• Hazardous materials storage and handling.
• Hazardous waste storage and handling.
• Radiation safety.
• Solid waste management and recycling.
• Wastewater discharges.
Attention to environmental management issues and proper waste handling is a key element of the NIH overall goals of ensuring the health and well-being of NIH employees, visitors, and neighbors, and maintaining the NIH campus atmosphere.
The DRM requirements regarding environmental management on the NIH campus encompass the current federal and state of Maryland regulations regarding environmental management issues. They also include the requirements of local governments and agencies such as the WSSC and Montgomery County, Maryland. Federal laws applicable to environmental management on the NIH campus include:
• Clean Air Act.
• Clean Water Act.
• Hazardous Materials Transportation Act.
• National Environmental Policy Act.
• Resource Conservation and Recovery Act.
• Safe Drinking Water Act.
• Toxic Substances Control Act.
• Worker Safety Requirements.
Certain environmental issues have been excluded from this section of the DRM and addressed elsewhere. See Chapter 3: Civil Engineering & Site Development for storm water management, sediment control, erosion control, wetlands and use of fertilizers in landscaping. Refer to Section 1-10: Integrated Pest Management for use of pesticides. It is the goal of NIH to fully comply with all federal and state requirements in these areas.
Sediment and Erosion Control (SEC) drawings shall be prepared for all projects that result in ground disturbance. See Chapter 3: Civil Engineering & Site Development Section 3-1-20-B “Sediment and Erosion Control”.
A. National Environmental Policy Act (NEPA):
NEPA applies to all projects regardless of size. This is a joint process between the Project Officer, DEP, and DFP to determine the appropriate action. Based on a preliminary project description (scope), it may be possible to determine that no further action is necessary. Possible further actions include categorical exclusion, development of an Environmental Assessment (EA), or an Environmental Impact Statement (EIS). A flowchart of the NEPA process has been prepared and is maintained by DEP.
1-9-10 Procedures
All NIH facilities shall be designed to minimize the use of hazardous substances. The use of alternative non-hazardous or nontoxic materials is preferred in all new construction and renovations. The A/E shall develop a plan for eliminating the use of hazardous substances. Where hazardous substance use is unavoidable, the A/E shall demonstrate that alternate non-hazardous substances are either not available, inferior to the hazardous substance, or cost prohibitive. Examples of hazardous substances that shall be avoided include, but are not limited to: oil-based paints and caulks; hazardous cleaning, surface preparation, and paint-stripping solvents; and petroleum-based contact adhesives.
In general, most new construction will result in the release (off-gassing) of odors that can affect occupant comfort. If hazardous substances are avoided in construction, these odors will generally be nonhazardous; however, they can still have a detrimental effect on indoor air quality. Examples of nonhazardous substances that can affect indoor air quality include systems furniture, carpets, and latex paints.
New facilities shall be allowed to off-gas prior to occupancy. Ventilation systems of new construction shall be operated for a minimum of one month before the building is occupied. For renovations, where it is not feasible to isolate NIH employees from the off-gassing, materials that will off-gas and affect indoor air quality shall be allowed to air out and off-gas in a warehouse or in a well ventilated, unoccupied area before they are installed.
Insecticidal dusts, such as boric acid, shall not be applied in wall cavities, voids, and/or chase areas as part of the facility construction or renovation.
1-9-20 Guidance and Information
A. References:
The A/E design firm shall use and comply with the design and safety guidelines, and references listed in Appendix A and cited throughout this chapter, as well as other safety guidelines received from the NIH Project Officer or as required by the program. The A/E shall utilize the latest editions of reference design and safety guidelines available at the time of the design contract award.
B. Hazardous Substances Receiving, Storage, Staging Areas and General Handling:
B.1 Receiving Areas:
Hazardous substances used at the NIH fall into two categories. They are either substances used in the facility directly for research activity such as laboratory chemicals used to perform analyses; or substances used in support of the facility such as chemicals used for washing glassware, cage washing, or neutralizing wastewater discharges.
Hazardous substances used in a laboratory are delivered directly to the end-user laboratory from the loading dock. Staging and temporary storage areas shall not be required in the receiving area for these materials.
Materials used in support of a facility must be placed in a hazardous-substance storage area. In general, these materials are received in 220 L drums or larger. Some neutralization chemicals may be stored in bulk containers up to 1,600 L. Storage capability shall be provided for up to ten drums. Buildings utilizing these hazardous substances shall be designed with a receiving and storage area located at or near the point of use of the materials and shall be used for long term storage of hazardous materials.
B.2 Storage and Staging Areas:
Hazardous-substance storage areas shall be out of the normal flow of personnel traffic and shall be located near the loading dock for easy access to the trucks used to transport the waste for processing. See Section 4-2-10-D.1 Loading docks & Shipping and Receiving Areas,” and Sections 2-3-10-G.7 and 2-4-10-H.10 “Loading Dock Space Descriptions and Requirements.” Convenient access from the storage room to the freight elevator shall be provided without having to traverse heavily used corridors so as to minimize the risks to the building occupants during the transport of the waste.
The storage and staging area shall be large enough to store the hazardous substances and provide room for loading and unloading the drums or containers. If multiple substances are stored, the design shall allow incompatible materials to remain segregated while in storage.
Spill containment in each section of the storage room shall be designed to contain any spills of hazardous waste resulting from mishandling the waste materials. The A/E shall propose alternative means for spill containment within the storage room. Options include a spill-containment curb around the room, secondary containment bins, shelving designed to contain spills, or a combination thereof. Any curb used for containment spills shall be designed to allow convenient ingress/egress using a drum trolley. Each section of the storage area shall be designed to contain a spill of a minimum of 4 L of liquid. The configuration of the storage area shall be designed to facilitate spill cleanup. Interior surfaces of the storage area shall be cleanable, corrosion resistant, and non-reactive.
A chemical-resistant coating shall be applied to the walls and floor in this area to facilitate the cleanup of spills. These areas shall be thoroughly caulked and sealed to minimize pest harborage and exclude pests.
Safety equipment including emergency eyewash, emergency shower, and a telephone shall be provided for each storage room and staging area. The telephone to contact emergency response personnel shall be located either in the room or within 10 m of the room. Fire protection design requirements shall apply if flammable materials are stored.
B.3 Hazardous Waste Storage and Handling at On-Campus Buildings:
Laboratory and animal research facility buildings on the NIH campus shall be designed with a room for temporary storage of hazardous waste and radioactive wastes. Mixed waste (hazardous waste that is also radioactive) shall be treated as radioactive waste in this temporary storage area. Hazardous waste is generally stored in this room for several hours or overnight. Refer to Section 1-9-10-F.3 “Radioactive Waste Storage.”
Layout and Size: Two individual sections shall be designed: one for hazardous waste and one for radioactive waste. The storage room shall be large enough to provide for temporary storage of the hazardous waste and radioactive waste, and for storage of specialized carts to transport the hazardous waste from the laboratories. The hazardous waste storage section shall be 2.5 m x 3.5 m minimum. The radioactive waste storage section shall be 0.75 m x 1.5 m minimum.
Storage Cabinets: A minimum of three 2 m-high storage cabinets shall be provided in each room to provide segregated storage of incompatible materials. Open floor space in the storage room shall accommodate one 1 m-long waste cart and allow access to the storage cabinets and shelving.
Spill Containment: Waste materials are normally transported using specialized carts that provide spill containment. Spill containment shall be designed per Section 1-9-20-B.2.
Floors and Walls: Floor and walls shall be designed per Section 1-9-20-B.2.
Ventilation System: A separate ventilation system shall be installed for the storage room. Exhaust shall be directed away from the building and surrounding buildings’ air intake. This ventilation system shall be connected to the building's emergency power system.
Lighting: Standard illumination requirements apply to this room.
Fire Protection: Sprinkler protection in the room shall be designed to meet the requirements for Ordinary Hazard Group 2.
Safety Equipment: Safety equipment shall be designed per Section 1-9-20-B.2.
Design Review and Approval: The DRS shall review all designs for hazardous waste storage rooms and shall provide the final approval of the design. The Project Officer shall coordinate this review and approval.
B.4 Hazardous Substances Storage and Handling within Laboratories on the NIH Campus:
Laboratory Modules: All laboratory modules shall be designed for the safe storage of hazardous substances while discouraging the storage of excessive amounts of hazardous substances. All wet laboratories shall contain an approved ventilated acid (corrosive) cabinet and an approved flammable materials storage cabinet. The sizes of these cabinets shall be based on the volume of corrosive and flammable materials used in the laboratory. The location of radioactive storage cabinets shall be standardized in the laboratories to assist emergency response personnel, optimally located near the laboratory door for convenient access by the technician collecting the hazardous waste. For laboratory modules with a service corridor, the storage area shall be located near the service entrance rather than the hall entrance, avoiding the transport of hazardous waste through the main corridors of the laboratory building. There shall be no flammable storage cabinets located under fume hoods. Acid storage cabinets shall be ventilated and are typically located beneath fume hoods. If no fume hood is present, exhaust ventilation must be provided to these cabinets. Acid cabinets and flammable material storage cabinets shall be located diametrically opposed from each other and towards the back of the laboratory away from the laboratory entrance.
Hazardous Waste Storage and Handling at Off-Campus Buildings: Laboratory buildings located in Montgomery County, Maryland, but not located on the NIH campus shall be designed per this section. Hazardous waste may be stored in these rooms from 60 to 90 days.
Location: The storage room shall be located near the loading dock for easy access to the trucks that will be used to transport the waste to the NIH campus for additional processing. Since this waste will be transported over public roads, the room shall also be used to prepare the hazardous waste for shipment. Processing conducted in this room includes bulking waste into larger containers, laboratory packing individual waste containers, and labeling and manifesting the containers for shipment.
Convenient access shall be provided from the storage room to the freight elevator without having to traverse heavily used corridors. Since these laboratories are typically leased space, it may be difficult to meet these criteria. In this case, consideration shall be given to alternate uses of this leased space that will not generate hazardous wastes.
Layout and Size: The storage room shall be divided into two sections. The first section shall be large enough to provide for temporary storage of the hazardous waste as it is received from the laboratories and after it has been packed for shipment. The second section shall be used for bulking and packaging the waste. Space for preparing manifests and other documentation shall be provided, either in the storage area or in an additional space outside the room. Space for storing specialized carts used to transport the hazardous waste from laboratories shall also be provided.
Spill Containment: Spill containment shall be designed per Section 1-9-20-B.2.
Floors and Walls: Floor and walls shall be designed per Section 1-9-20-B.2.
Ventilation System: The ventilation system shall be designed per Section 1-9-20-B.3 plus the following:
• The ventilation system shall be spark proof.
• The ventilation system shall be designed to allow easy access for routine or emergency maintenance from outside the containment area.
Safety Equipment: Safety equipment shall be designed per Section 1-9-20-B.2.
Fume Hood: A walk-in fume hood shall be provided in the bulking and packaging area, where exposure to harmful fumes is possible.
Explosion-Proof Design: An explosion panel designed to dissipate the impact of an explosion shall be provided in the storage room.
Lighting: Explosion-proof lighting shall be provided in both areas.
Fire Rating: Storage room walls shall have a two hour fire rating.
Design Review and Approval: DEP, DRS, and DOHS shall review all designs for hazardous waste storage rooms and shall provide final approval of the design. The Project Officer shall coordinate this review and approval.
C. Hazardous Substances Storage and Handling within Laboratories Not on the NIH Campus
C.1 Modules:
All laboratory modules shall be designed for the safe storage of hazardous waste generated by laboratory activities. The volume of hazardous waste generated by a laboratory is a function of the type of work being performed in the laboratory. The A/E shall consider the function of the laboratory to determine the space necessary for hazardous waste storage. At a minimum, a 0.75 by 0.75 m area shall be required.
The A/E must also recognize that some types of hazardous waste may be incompatible and shall design the hazardous waste storage area to accommodate multiple containers. The A/E shall investigate the possibility of stacked containers that will provide sufficient storage space while minimizing the footprint in the laboratory. However, hazardous containers shall not be stacked. Each storage container shall be designed to provide secondary containment of hazardous wastes. This storage area shall have a minimum of two physically separated sections to allow segregation of incompatible materials. Some laboratories may require three segments depending on the types of hazardous waste that will be generated. Storage areas shall be designed per Section 1-9-20-B.4
The location of the hazardous waste storage area in laboratories shall be standardized to assist emergency response personnel and shall be designed per Section 1-9-20-B.4
C.2 Bulk Storage Facilities:
Above Ground Storage Tanks: The A/E shall consider the use of clean-burning fuels such as natural gas or liquid propane. Above ground storage tanks shall be provided in accordance with state of Maryland and Montgomery County, Maryland, requirements if fuel storage is required (i.e., a day tank ensuring uninterrupted availability of fuel).
All above ground storage tanks shall be double walled, be provided with secondary spill containment, and meet the requirements of the American Petroleum Institute and the NFPA. The tanks shall also be consistent with the NIH Spill Prevention, Control, and Countermeasures Plan.
Above ground storage tanks shall be located to provide access for delivery trucks. Concurrently, the tanks shall be sufficiently isolated and protected from traffic flow to minimize the risk of accident. The tanks shall be placed in a location to minimize the aesthetic impact of the tank on the surroundings, including the use of beams and landscaping to block the view of the tanks.
Spill Control: All bulk storage facilities and above-ground storage tanks shall be equipped with secondary containment to prevent discharge of the material in the event of a spill or a leak. For single storage tanks, the secondary containment shall be large enough to contain the volume of the tank and rainfall from a 10 year, 24 hour storm. For multiple storage tanks, the secondary containment shall be large enough to contain the volume of the largest tank and rainfall from a 10 year, 24 hour storm.
Materials used to provide the secondary containment shall be impervious to the substance contained in the storage tank. The containments shall be equipped with a normally closed valve to prevent accidental discharge of the substance from the containment. This valve can be manually opened to discharge accumulated rainwater after it has been determined that the water is not contaminated.
Other potential spill areas for hazardous substances on the campus are loading docks where spills can occur during the loading and unloading of hazardous substances or hazardous wastes.
Loading docks shall be designed to contain spills of hazardous substances and minimize the contamination of storm water runoff. The loading dock shall be provided with grate drains equipped with a normally closed valve to prevent accidental discharge of spilled substances, and to accumulate any spilled substances at the base. Uncontaminated runoff would be diverted from this drain by a second grate drain and a small berm. An overhang would divert direct rainfall from the base of the loading dock to the uncontaminated runoff drain. The A/E may propose alternative designs that meet this objective. For control of storm water runoff and water quality, see Chapter Civil Engineering & Site Development “Storm Water Management” Section 3-1-10-C.
C.3 Wastewater:
Wastewater Discharge: Only uncontaminated storm water runoff shall be discharged from the NIH campus to the receiving stream. All wastewaters generated on the NIH campus shall be discharged to the sanitary sewer. Wastewaters generated on the NIH campus include domestic sewage from the lavatory facilities, nonhazardous waste discharged from laboratory or research area sinks, waters used for cage washing and animal care, waters used in cafeteria operations, and all floor drains.
Wastewater Sampling: The NIH campus is connected to the WSSC sanitary sewer system. The NIH is permitted to discharge wastewater to the WSSC system through a Discharge Authorization Permit. Under the terms of this permit, the NIH must sample its wastewater four times every six months and submit an Industrial User Effluent Compliance Permit report to WSSC twice per year.
The wastewater sampling is conducted at two locations where NIH sewers connect to the WSSC system. However, for new laboratory and animal facility construction, the sanitary system shall be designed to allow for sampling at the discharge point from the individual building. This will allow for testing and troubleshooting of individual building wastewater streams.
The sampling point shall be designed to allow for installation of a continuous pH monitor, installation of a programmable sampler, and personnel access for grab sampling. Cage washing facilities and laboratory facilities shall be provided with a continuous pH monitor and recorder. The pH monitor shall provide an alert to the building automation system.
Wastewater Treatment: Since the NIH utilizes the WSSC system, it is normally not necessary to perform wastewater treatment on campus. However, it may be necessary to provide neutralization and equalization of wastewater streams from some laboratory and animal care buildings to comply with WSSC requirements and to minimize the risk of damage to NIH campus piping infrastructure.
Biomedical Laboratory Buildings: To allow for these circumstances, the waste systems for new buildings shall be arranged to allow for installation of an active-type pH neutralization system to serve laboratory and cage wash areas, and other potentially corrosive waste streams. The pH neutralization system shall be capable of neutralizing acid and caustic wastes without requiring installation of future pumping systems for any but the lowest levels of the building that could not otherwise drain by gravity. The potential future arrangement provisions shall be planned and described in the Basis of Design document or on drawings. Sufficient planning shall be provided in the design arrangement to preclude the need for significant repiping of the waste systems or other major disruptions in the event such systems become a future requirement.
Animal Research Facilities: In general, the sanitary system for new facilities that include animal care areas shall be equipped with an active pH treatment system or a continuous automatic pH monitoring system. Each pH monitor shall be arranged to permit maintenance and calibration without requiring disruption to building operations.
Tanks: Tanks used for equalization and neutralization of wastewaters can accumulate sludge and hazardous wastes, require maintenance, and cause odor problems. Therefore, equalization and neutralization tanks shall not automatically be installed in new construction. The A/E shall investigate the potential use of the building and attempt to characterize the potential wastewater stream on the basis of this proposed use. One of the following shall be provided for laboratory, clinical, vivaria facilities, depending on facility needs:
• An automatic pH monitor shall be installed on the laboratory waste line from each building. The pH monitor shall incorporate a normally closed lockable bypass to permit maintenance without requiring disruption of building operations. Buildings provided with automatic pH treatment systems for the main laboratory/vivarium effluent shall incorporate the pH monitor as part of the treatment system, and shall not require a separate monitor. The system shall include a chart recorder or preferably an electronic recorder to record pH excursions. The pH sensor shall be designed to preclude the trapping of solids.
• Laboratory and vivarium buildings shall incorporate an active pH treatment system, capable of automatically neutralizing both acidic and caustic waste streams. The system shall include a chart recorder or preferably electronic record to record pH excursions. The treatment system shall be designed to automatically handle normal solids and minimize accumulation of sludge. Passive systems consisting of tanks requiring use and refill of solid media (i.e. limestone or marble chips) shall not be utilized. The system shall include a lockable bypass or other means to allow for continued operations during maintenance; however, the bypass arrangement shall not bypass continuous pH monitoring capability.
Silver Recovery: Any facility designed with darkrooms or photo processing facilities shall have a processing facility for recovering silver from the wastewater stream from the photo processing rooms.
D. Solid Waste
D.1 Waste Minimization:
All biomedical laboratory and animal research facilities at the NIH shall adhere to the Environmental Protection Agency (EPA) solid waste management hierarchy, encouraging reduction of waste at the source. This hierarchy emphasizes waste minimization as the first step in sound solid waste management. The utilization of reusable products, which also has the effect of reducing the overall solid waste stream, is also encouraged. Waste products that cannot be reused shall be investigated to determine whether they can be recycled. Only those products that cannot be reused or recycled shall enter the waste stream for energy recovery or land filling. In general, solid waste management is an operational function. However, the requirements for environmentally friendly solid waste management shall be included in the design of new construction in order for the solid waste management system to be efficient and convenient to use. Ease and convenience are keys to implementation of a successful solid waste management program. All facilities shall be designed with modern and sanitary waste compaction equipment. This equipment shall minimize spillage of wastes and debris, and the attraction of pests.
Hazardous substance storage capacity can assist in laboratory waste minimization. The A/E shall closely examine the anticipated use of the laboratory to determine a reasonable volume of hazardous substances stored in the laboratory to allow efficient laboratory operations. Excessive storage space in a laboratory can result in over purchasing, hoarding of hazardous substances, and possible storage beyond useful shelf life, resulting in excessive hazardous waste generation.
D.2 Recycling:
The NIH campus has an active solid waste recycling program. The program is administered by ORF. This program establishes white office paper, baled corrugated cartons, aluminum cans, and polypropylene as primary recycling materials. Mixed paper, wood pallets, scrap metal, polystyrene, food and beverage containers, and yard waste are designated as secondary recyclable materials.
All new construction on the NIH campus shall be designed to be recycling friendly. Collection containers placed at convenient locations throughout the building enable NIH employees to accumulate recyclable materials. The selection of recyclables to be collected; the type, size, and number of collection containers; and the locations for the collection containers shall be determined by the A/E on the basis of the planned use of the new facility. The A/E shall coordinate this selection with DEP.
Support facilities for recycling shall be included in all new construction. These support facilities include space in the loading dock area for storing recyclable materials. Paper products, particularly white paper, must be kept clean and dry to maintain market value and be stored in a way so as not to attract pests or offer them harborage, requiring either a room for storage or an enclosed container. Other recyclable materials also require sufficient container space. Multi-compartment recycling roll off containers are commercially available and may be used for recyclable storage and transportation. The potential for attraction of pests, such as flies, wasps, or rodents, to these containers shall be considered when designing a placement site. The placement of these containers shall not affect personnel using the loading dock.
A can-flattener shall be considered for any facility expected to generate sufficient aluminum cans. The selection of the recycling support facilities and equipment required for all new construction shall be made by the A/E in coordination with DEP. Potential options for the loading dock design have been developed by the ORF and can be used per program requirements by the A/E.
D.3 Hazardous Waste:
All hazardous waste generated on the NIH campus shall be handled in accordance with the NIH’s generator and Treatment Storage and Disposal (TSD) permits. Generally, this requires accumulation of the waste at the generation point, temporary (one day or less) staging at the building loading dock, and transportation to Building 21 for processing. Any facility that cannot meet this format shall be considered a special exception to the DRM. The A/E shall develop the solid and hazardous waste design for this building in consultation with DOHS and DEP.
E. Decommissioning:
NIH campus facilities shall be decommissioned prior to renovation. In this context, decommissioning is defined as all work required resulting in a facility free of chemical, biological, radiological, or other hazardous materials; and prepares the area for reasonable, unrestricted demolition. Decommissioning shall include an indepth facility assessment by a qualified environmental engineer, approved by the DOHS and DEP.
The facility assessment shall identify any environmental or other site hazards that could result in the release of hazardous substances during demolition or could pose a hazard to workers.
Potential hazards addressed during the facility assessment include, but are not limited to, asbestos containing building materials (ACBM), polychlorinated biphenyls (PCB), lead and lead paint, mercury, underground storage tanks, hazardous substance storage areas, and spills of hazardous materials. Potential hazards are outlined in the “Checklists for Hazardous Substances” available from DEP. Because new and changed regulations have an impact on the decommissioning process, Project Officers and A/E’s must obtain the latest edition of this document from DEP for each project.
E.1 Condition Assessments:
The condition assessment shall include the following quantitative data to substantiate the qualitative assessment:
• Review of records regarding the design, construction, and use of the building to be demolished and the site.
• Review of records regarding responses to hazardous substances spill incidents or other emergencies.
• Visual inspection of the building and site.
• Sampling and analysis of subject materials.
Condition assessments are required for every NIH renovation project, regardless of facility type. The end result of the condition assessment shall be a Decommissioning Plan for the facility, which shall include all recommended procedures for decontamination.
E.2 Decommissioning Guidelines:
Decommissioning guidelines are under development by the DEP. Draft guidelines are outlined in the “Assessment and Decontamination of NIH Facilities for Alterations and Decommissioning” available from DEP. Until final guidelines are published by DEP, ORF guidelines requiring a site/facility assessment prior to demolition shall be required.
E.3 Decommissioning Plan Review:
The DEP shall review and approve all decommissioning plans.
E.4 Recycling Demolition Debris:
Prior to mobilization on the site, the demolition contractor shall be required to submit a waste disposal and recycling plan for the demolition activity to DEP. This plan shall identify each type of waste material generated by the demolition. The wastes shall be classified as hazardous waste, general waste, or recyclable waste. The alternatives for disposing or recycling of each type of waste material shall be discussed in the plan, with the objective of recycling the maximum amount of demolition materials. For any material not recycled, the contractor shall be required to document in the plan, to the satisfaction of the DEP, why recycling is not feasible.
F. Radiation Safety:
Work performed at NIH laboratories involves the potential for occupational exposure to radioactive materials and other sources of ionizing and non-ionizing radiation. While laboratory procedures identify good radiation safety practices and techniques essential to minimize potential exposure to radiation, the security, containment, and shielding of this material and equipment through the use of good facility design are other extremely important elements.
The intent of this section is to provide A/E’s with a working knowledge of the facility design parameters required for the construction of facilities, which shall provide for the control and containment of these radiation hazards. Not all sources of ionizing radiation are covered by NRC licensing. The non-licensed sources are, however, controlled by regulations issued by the DRS Officer upon recommendation by the radiation safety officer. Non-licensed sources include x-ray machines, high-voltage accelerators, electron microscopes, and radioactive materials from sources other than reactor by-products. In addition to the protection of occupationally exposed workers, DRS must ensure that the general public and surrounding environs are also provided with an adequate and similar degree of protection.
F.1 Background:
DRS web site http://www.nih.gov/od/ors/ds/rsb/index.html provides guidance and technical information concerning the use of radioactive materials as well as policies and procedures for radiation-producing machines and areas. Radiation safety control, containment, and shielding design and laboratory practices have been developed to minimize the potential for radiation exposure to workers and radiation release to the environment.
F.2 Specific Areas of Concern:
The following key radiation issues are identified relative to laboratory activities:
• Radiation safety requirements for laboratories using radionuclides.
• Radioactive airborne and liquid effluent sampling.
• Radiation safety requirements for devices used in medical research, such as x-ray machines, accelerators, and irradiators.
• Radiation safety requirements for non-ionizing radiation (only including MRI and high-intensity lasers (e.g., CO2).
• Radioactive materials security requirements.
All radioactive materials stored at any NIH facility shall be secured. Unattended laboratories in which radionuclides are in use or stored shall be locked, or radioactive materials shall be locked in containers, refrigerators, or freezers. Other security options such as card key access shall be coordinated with DPSM.
F.3 Radioactive Waste Storage:
Radioactive Waste Storage Buildings On Campus and Off Campus: All new biomedical laboratory and animal research facility buildings on campus and off campus shall be provided with a minimum of one radioactive waste storage room located inside and directly adjacent to the loading dock. The room shall provide a minimum of 14 m² of floor space. Only card key access shall be provided to the room. Other unique requirements for the radioactive waste room shall include:
Storage Requirements: Adjustable height bi-level metal shelving with lipped edges and corrosion resistant coating for spill containment to provide segregated storage of wastes of various compatibility classes shall be provided.
Flooring Specifications: A 100 mm (3’-0”) high containment floor berm shall be provided at the entrance to the room for specified containment and be sloped to allow carts and dollies to easily pass. Two alternates are also acceptable:
• Room flooring designed 100 mm (3’-0”lower than corridor flooring with smooth transition ramp leading into room; or
• Room flooring designed to gradually slope away from the entrance to provide the same containment capacity.
No floor drains shall be located in this room. Flooring shall be of impervious material; highly resistant to organic solvents; non-slip; and with no cracks, joints, or drains. Floor and wall junctures shall be coved and of the same material as the floor.
Electrical Specifications: One duplex electrical outlet on each wall of the room shall be provided.
Medical Waste Cold Box: Medical waste cold boxes used to store MPW shall be used to store animal carcasses, tissues, and bedding contaminated with radioactive materials. Medical waste cold box storage room shall be located inside and directly adjacent to the loading dock. Contact DEP for medical waste cold box specifications.
Radioactive Waste Storage On-Campus Facilities: Laboratory buildings shall be designed with a separate area for the temporary staging of hazardous and radioactive waste. Mixed waste (hazardous waste that is also radioactive) shall be treated as radioactive waste in this temporary staging area described in previous sections of this chapter. Only specific issues that are directly related to radioactive waste are discussed here. Information on the carts and equipment for the transfer of radioactive waste currently in use can be obtained from DRS. The staging area shall be sized to provide for temporary storage of the radioactive waste and the specialized carts used to transport the radioactive waste from the laboratories. The staging area shall be designed to contain any spills of radioactive waste that may occur during handling of the waste materials. This can be accomplished using specialized carts; however, the A/E may propose alternate means for spill containment. Special consideration shall be given to this area in the fire protection design per NRC Information Notice 90-09, specifying the fire protection and suppression systems to minimize the likelihood and extent of fire.
Coolers and/or walk-in freezers shall be located in each building with laboratories conducting biomedical research with radioactive materials.
Radioactive Waste Storage Off-Campus Facilities: Laboratory facilities not located on the NIH campus shall be designed with a room for use in processing and staging hazardous and radioactive waste. Mixed waste shall be treated as radioactive waste in this room. Only specific issues directly related to radioactive waste are discussed here. A 2 hour-rated wall shall be designed to separate radioactive waste and hazardous waste storage areas. The waste shall be transported to the NIH campus for additional processing and shipping to the long-term radioactive waste storage facility. Since the waste is transported over public roads, this room shall be used to prepare the radioactive waste for shipment. Processing conducted in this room shall include bulking of waste into large containers, laboratory packing of individual waste containers, and labeling and manifesting the containers for shipment. A bulking hood to perform these activities shall be provided. A service elevator on the premises shall be available to transport the radioactive waste to the appropriate marshalling area in the building. If a service elevator is not available, the use of a passenger elevator may be appropriate; however, dedicated times shall be required to transport the radioactive waste.
The staging room shall be divided into two separate sections. The first section shall be large enough to provide for temporary storage of the radioactive waste as it is received from the laboratories and after it is packed for shipment. The second section shall be used for bulking and packaging the waste. Sufficient space shall be provided for storing the specialized carts used to transport the radioactive waste from the laboratory. The staging room shall be designed to contain any spills of radioactive waste that may occur during handling of the waste materials. Spill containment in the bulking and packaging area may be accomplished with a curb around the area, secondary containment bins, or a combination thereof. These areas shall be thoroughly caulked and sealed to minimize pest harborage and exclude pests. It is important to note that prior to contracting for leased space that will require remodeling, renovation, or other extensive architectural or engineering work, DRS shall be informed and provide the necessary technical assistance.
Laboratory Module Requirements: All laboratory modules shall be designed for the safe storage of radioactive waste. The volume of radioactive waste generated by a laboratory is a function of the type of work being performed. The A/E shall consider the function of the laboratory to determine the space necessary for radioactive waste storage; recognize that some types of radioactive waste require segregation from other types; and design the radioactive waste storage area to accommodate multiple containers. All laboratories shall be designed to fit the appropriate low-level radioactive waste (LLRW) storage receptacles and/or containers. Contact DRS for specifications on these containers. Five LLRW streams have been identified from the NIH Waste Disposal Calendar, current edition:
1. Liquids - Aqueous waste and/or solvents/other hazardous chemical constituents (mixed waste)
2. Dry or solid waste (dry active waste) - Disposable lab ware and/or sharps (can also be categorized as MPW)
3. Liquid scintillation vials and/or bulk liquid scintillation media
4. Animal carcasses and/or tissues
5. Animal bedding and/or solid excreta
The size of the space dedicated to each of the containers shall be based on the volume of radioactive materials generated and/or research activities performed in the laboratory. Standard-sized containers are available from the radioactive waste contractor. Container placement locations shall be considered in the design. A standard location of the radioactive waste storage in laboratories shall be established to assist emergency response personnel. For laboratory modules with a service corridor, this storage shall be located near the service entrance rather than the hall entrance, eliminating the need for moving radioactive waste through the main corridors of the laboratory building. The configuration of the radioactive waste storage area in the laboratory shall be designed to facilitate radioactive material spill cleanup and decontamination. Interior surfaces of the storage area shall be readily cleanable for ease in decontamination. Corridors and public space shall not be designated and used for storage, and equipment such as refrigerators and freezers shall not be designated to store this material in these areas. The A/E shall include the following in the design:
• Physical security measures and mechanisms against unauthorized access in all laboratories.
• Security for all radioactive materials in laboratories when unattended.
• Space for shielding waste containers.
• Appropriately sized laboratory and marshalling areas for reduction of storage and/or waste accumulation.
• Appropriate spill containment for all storage areas.
• Potential shielding requirements between adjoining or adjacent laboratory bench areas for high-energy beta emitter radionuclides.
• Compensation for the additional weight required for lead shielding in the design of countertops and hoods if the laboratory is used for high-energy gamma emitter radionuclides.
• Secure equipment alcoves for storage of radioactive materials and/or irradiator equipment.
• Security provisions in construction specifications (e.g., locks as part of the integrated system, to secure this equipment) when storing radioactive materials in refrigerators and/or freezers.
F.4 Module Requirements:
Beta barriers for shielding energetic beta emitters (P-32), often transparent plastic sheets, 0.95 cm to 1.27 cm thick, shall be provided to protect personnel in adjacent and close work areas.
F.5 Ventilation Systems:
Ventilation systems used for controlling airborne radioactive discharges require the following:
• Laboratory exhausts shall be manifolded into the regular building exhaust.
• Hoods for bulking radioactive materials shall have sampling capability.
• Mechanical room space shall be designed to provide for future additional filtration capability.
If the facility requires additional hoods, specifically for the use of iodination techniques, then the exhaust from these installations shall be equipped with HEPA or charcoal filtration capability. A distinct installation shall be considered separate from the main exhaust system.
F.6 Radioactive Airborne and Liquid Effluent Discharges:
DRS prohibits discharge of radioactive material into laboratory sinks. Provision shall be made in the design for installation of appropriate sampling probes for sampling capability to assess airborne and liquid effluent discharge streams, including main exhaust systems, sufficient to demonstrate compliance with the requirements of 10 CFR 20.1302. Liquid effluent monitoring can be accomplished by batch, composite, or continuous sampling prior to discharge into the sanitary sewer system. Design and construction considerations for airborne radioactive effluent monitoring shall include the following:
• All systems for use with radioactive materials shall have the capacity to sample the airborne effluent being discharged, primarily gases and vapors.
• Sufficient capacity shall be provided for sampling the combined discharge, specifically gases and vapors, at a common point located inside the mechanical room downstream of the filters and fans.
• Where iodination is performed in specific laboratories, those hoods shall be equipped to accept appropriate HEPA and charcoal filters.
• Air-borne radioactive effluent monitoring systems shall be designed in accordance with ANSI Standard N13.1, Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities (1969), specifically Appendix A, Guides for Sampling from Ducts and Stacks.
• A single-nozzle sample probe shall be designed inside the air stream for sampling gas and vapors, as specified in ANSI Standard N13.1.
Laboratory design considerations shall include state-of-the-art design considerations, as specified by ANSI, and other acceptable industry standards, such as the following:
• National Council on Radiation Protection and Measurements (NCRP), Report No. 59, Operational Radiation Safety Program, Chapter 3, November 1, 1980.
• Hanson and Blatz, Radiation Hygiene Handbook, Section 9, Facility Design, 1959.
• Epoxy coatings, laminates, floor coverings, and protective coatings shall be utilized for ease of decontamination and to provide a protective coating that can be readily removed without extensive damage to the existing facility and surfaces.
• Sinks shall be either plastic composite or coated with epoxy or the equivalent to ease decontamination of surfaces. Stainless steel is also an option for sinks. Soapstone shall not be used.
Air filtration systems (activated charcoal/HEPA filtration) shall be installed and tested in accordance with ANSI/American Society of Mechanical Engineers Standard N510- 1980, Testing of Nuclear Air Cleaning Systems. The activated charcoal and HEPA filters shall be tested with current state-of-the-art methods and techniques for filter efficiency and compliance with technical specifications at the factory and after installation at NIH facilities. Chemical fume hoods for radionuclide use shall be designed in accordance with the following industry criteria and technical specifications:
• Landis and GYR Powers, Inc., Laboratory Control and Safety Solutions Application Guide, 1993.
• ACGIH, Industrial Ventilation: A Manual of Recommended Practice (current edition).
• Hoods shall have a minimum face velocity of 100 m/s.
A typical chemical fume hood designed for hazardous materials is acceptable as a radioisotope fume hood. The hood design shall include smooth, nonporous surfaces for ease of decontamination. The fume hood shall be constructed of materials that will not generate mixed waste if the surfaces and the construction materials interact with the radioactive materials.
F.7 Vacuum Systems:
Vacuum systems shall be protected with appropriate filtration (0.3 micron hydrophobic filter or the equivalent) to minimize the potential for contamination of vacuum pumps. Filters shall be on the suction side of the pumps, with exhaust to the outside of the facility and not recirculated into the mechanical spaces. Filters shall be located as close as possible to the laboratory in order to minimize the potential contamination of vacuum lines and to preclude and minimize decontamination and decommissioning costs. Filter housings shall be designed for easy filter replacement in order to minimize the possibility of maintenance worker contamination and to provide for easy disposal.
F.8 Irradiators Utilized in Medical Research:
DRS shall be contacted when designing/installing an irradiator. Irradiators are designed to contain significant amounts of radioactive material and therefore are designed with engineering controls, as well as adequate shielding to perform the necessary functions utilized in medical research. The following facility design parameters shall be evaluated and satisfied for the construction to adequately house this equipment:
• Adequate structural integrity of floor loads given the amount of shielding, and associated weight, of this equipment.
• Adequate available means for moving this equipment to its location (e.g., loads on elevators and pathways).
• Feasibility and preference to locate equipment on the lower floors of a facility (e.g., ground floor, basement, or subbasement) due to shielding requirements.
• Security or the capability to be secured (locked) for the room and/or facility housing the irradiator.
F.9 Radiation-Producing Equipment and/or Machines:
DRS shall be notified when there is any change in the setup of radiation-producing equipment or machines. This includes purchase and installation of new equipment, changes in shielding, changes in the output of the radiation, or changes in usage of the unit. With respect to the use of radiation producing equipment and/or machines, the following design guidance shall be used:
• National Council on Radiation Protection and Measurements (NCRP), Report No. 102, Medical X-Ray, Electron Beam and Gamma-Ray Protection for Energies up to 50 Mev (Equipment Design, Performance and Use, 1989).
• NCRP, Report No. 49, Structural Shielding Design and Evaluation for Medical Use of X-Rays and Gamma Rays of Energies up to 10 MeV, September 15, 1976.
• NCRP, Report No. 17, Structural Shielding Design for Medical X-Ray Imaging, November 19, 2004.
The documents referenced above shall be used by DRS to:
• Implement an “as low as reasonably achievable” (ALARA) program to minimize radiation exposure to occupationally exposed individuals and the general public.
• Provide the appropriate design criteria as they relate to radiation-producing equipment and/or machines.
• Provide structural shielding requirements for any new installations or installations under-going renovations or changes.
The following factors, such as W (workload), U (use factor), and T (occupancy factor), as defined in the appropriate NCRP handbooks, shall be utilized to calculate and design the necessary shielding requirements. The dose equivalent limit for design purposes shall be 10-mRem public exposure and 500-mRem occupational exposure.
F.10 Non-Ionizing Radiation:
This section applies only to MRI and high-power intensity lasers. With respect to the use of MRI devices, the following regulations and design considerations apply:
• U.S. Food and Drug Administration (FDA) regulations 21 CFR 892.1000, Magnetic Resonance Imaging.
• Security requirements for housing and enclosing the equipment.
• Warning placards, signs, and postings, which may also include barriers.
• Warning requirements for cardiac pacemakers as well as other prosthetic devices and/or equipment.
• Shielding requirements to minimize radiation exposure to electric and magnetic fields.
• Posting concerning electrical hazards.
With respect to the use of lasers, specifically high-power intensity lasers, the following regulations and design considerations apply:
• FDA regulations 21 CFR 1040, Performance Standards for Light-Emitting Products.
• ANSI Standard for the Use of Lasers, ANSI Standard 2136.1, 1986.
• Conference of Radiation Control Program Directors, Frankfort, Kentucky. Suggested State Regulations for Control of Radiation, Volume II: Non-Ionizing Radiation (latest edition).
• Security requirements for housing and enclosing the equipment.
• Warning placards, signs, and postings, which may also include barriers.
• Appropriate personal protective equipment warnings prior to entering and/or working with the equipment to mitigate and prevent eye and skin exposure.
A Class III laser system is a medium-pulse system requiring control measures to prevent viewing of the direct beam. Design and control measures emphasize preventing direct access to the primary or reflected beam. Safety eyewear is necessary and required with this class of laser. High-power intensity lasers (e.g., CO2 lasers) are classified as Class IV lasers in 21 CFR 1040. These lasers produce radiation so powerful as to cause injury with a direct or reflected exposure, even when the beam is scattered or diffused by a rough surface or smoke screens. Class IV radiation lasers emit more than 0.5 W continuous output. Laser facilities shall be designed to minimize the use of reflective/refractive surfaces to provide additional protection to occupational personnel.
(508 compliant)
