Question 228: A licensee (e.g., radiographer, moisture
density gauge operator, well logger) has a source that the
licensee transports to temporary job sites in a
licensee-owned vehicle. 10 CFR 20.1906 (f) exempts the
licensee from doing contamination surveys during routine
operations, but does not exempt the licensee from
performing surveys for radiation levels. (a) When must
the licensee perform such surveys (i.e., when is the
package "received")? Is it only after returning to the
storage location at the end of the day? (b) Or is each
transport from one temporary site to another considered a
shipment, with a "receipt" at each job site?
Answer: (a) The source should be surveyed at the end of
the work day, just prior to or immediately after storage.
If the package contains quantities less than a Type A
quantity, the licensee is not required to survey the
surface of the package for radiation levels. If the
package contains quantities of radioactive material in
excess of a Type A quantity, as defined in 10 CFR 71.4 and
Appendix A to 10 CFR Part 71, the licensee, in accordance
with 10 CFR 20.1906 (c), shall perform monitoring as soon
as practicable but not later than 3 hours after the package
is received at the licensee's facility if it is received
during the licensee's normal working hours, or not later
than 3 hours from the beginning of the next working day if
it is received after working hours.
(b) No. The package "is received at the licensee facility"
when it is returned to the storage location at the end of
the day. It is not necessary to survey radiation levels at
temporary job sites. (Reference: 10 CFR 20.1906, 71.4)