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Program-Specific Guidance About Industrial Radiography Licenses - Final Report (NUREG-1556, Vol. 2)On this page: Download complete document The following links on this page are to documents in Adobe Portable Document Format (PDF). See our Plugins, Viewers, and Other Tools page for more information. For successful viewing of PDF documents on our site please be sure to use the latest version of Adobe. Table of Contents
Publication Information[ Next | Top of file ] Manuscript Completed: August 1998 Prepared by J. B. Carrico, A. C. White, D. J. Collins, D. A. Piskura, K. M. Prendergast, D. O. Nellis, M. E. Schwartz Division of Industrial and Medical Nuclear Safety Abstract[ Prev | Next | Top of file ] As part of its redesign of the materials licensing process, NRC is consolidating and updating numerous guidance documents into a single comprehensive repository as described in NUREG-1539, "Methodology and Findings of the NRC's Materials Licensing Process Redesign" and NUREG-1541, "Process and Design for Consolidating and Updating Materials Licensing Guidance" (to obtain, see Availability Notice). NUREG-1556, Vol. 2 is the second program-specific guidance developed for the new process. This document is intended for use by applicants, licensees, and NRC staff and will also be available to Agreement States. This guidance corresponds with the revision to 10 CFR Part 34 published in May 1997. This document combines and supersedes the guidance previously found in draft Regulatory Guide FC 401-4, "Guide for the Preparation of Applications for the Use of Sealed Sources and Devices for Performing Industrial Radiography," and in NMSS Policy and Guidance Directive FC 84-15, "Standard Review Plan for Applications for the Use of Sealed Sources and Devices for Performing Industrial Radiography." This report, where applicable, provides a more risk-informed, performance-based approach to industrial radiography licensing consistent with the current regulations. This final report should be used in preparing requests for licensing actions. NRC staff will use this final report in its review of requests for licensing actions. Figures[ Prev | Next | Top of file ] 8.2 Example Diagram of a Permanent Radiographic Installation 8.3 Material Receipt and Accountability 8.7 Surveillance and Posting at a Temporary Job Site with Multiple Floors and Access Points 8.9 The Well-Dressed Radiographer L.1 Diagram of Office and Device Storage Area United States Nuclear Regulatory Commission Form 313 Form 374 Sample Materials License(1 of 4) Form 374 Sample Materials License(2 of 4) Form 374 Sample Materials License(3 of 4) Form 374 Sample Materials License(4 of 4) Minimum Required Packing for Class 7 (Radioactive) Materials Package and Vehicle Contamination Limits Hazardous Material Shipping Certification Foreword[ Prev | Next | Top of file ] The United States Nuclear Regulatory Commission (NRC) used Business Process Redesign (BPR) techniques to redesign its materials licensing process. This effort is described in NUREG-1539 (to obtain, see Availability Notice). A critical element of the new process is consolidating and updating numerous guidance documents into a NUREG series of reports. Below is a list of volumes currently included in the NUREG-1556 series:
NUREG-1556, Vol. 2, "Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Industrial Radiography Licenses," dated August 1998, provides program-specific guidance for the new process. It is intended for use by applicants, licensees, NRC license reviewers, and other NRC personnel. It supersedes the guidance previously found in Regulatory Guide FC 401-4, "Guide for the Preparation of Applications for the Use of Sealed Sources and Devices for Performing Industrial Radiography," dated October 1984, and in NMSS Policy and Guidance Directive FC 84-15, "Standard Review Plan for Applications for the Use of Sealed Sources and Devices for Performing Industrial Radiography," dated October 1984. This guidance has been prepared to correspond to the new requirements and format established in the revision of 10 CFR Part 34 published in 1997. Appendix A provides a list of Technical Assistance Requests, Information Notices, and Policy and Guidance Directives applicable to radiography which have been considered in the development of this NUREG Report. This Appendix also identifies those documents that have been superseded. NUREG-1556, Vol. 2, takes, where applicable, a more graded (or risk-informed) and performance-based approach to licensing industrial radiography. A team composed of NRC staff from headquarters and regional offices prepared NUREG-1556, Vol. 2. The team drew on its collective experience in radiation safety in general and as specifically applied to industrial radiography. A representative of NRC's Office of the General Counsel provided a legal perspective. NUREG-1556, Vol. 2, "Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Radiography Licenses," dated August 1998, represents a step in the transition from the current paper-based process to the new electronic process. NUREG-1556, Vol. 2 is also available electronically by visiting NRC's Home Page <http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1556/v2/index.html>. This report describes and makes available to the public information on: methods acceptable to the NRC staff for implementing specific parts of the Commission's regulations; techniques the staff uses in evaluating applications, including specific problems or postulated accidents; and data the NRC staff needs to review applications for licenses. NUREG-1556, Vol. 2, "Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Industrial Radiography Licenses," dated August 1998, is not a substitute for NRC regulations, and compliance is not required. The approaches and methods described in this report are provided for information only. Methods and solutions different from those described in this report will be acceptable if they provide a basis for the staff to make the determinations needed to issue or continue a license. _________________________________________ Acknowledgments[ Prev | Next | Top of file ] The writing team thanks the individuals listed below for assisting in the development and review of both the draft and final reports. All participants provided valuable insights, observations, and recommendations. The team also thanks Kay Avery, Mary Carnahan, Angela Case, Elaine Gerdine, Alyce Martin, Tim Woods, Gina Thompson, and Tina Jordan of Computer Sciences Corporation, and Cindy Caldwell from the State of Texas. The Participants[ Prev | Next | Top of file ] Camper, Larry W. Abbreviations[ Prev | Next | Top of file ]
1 Purpose of Report[ Prev | Next | Top of file ] This NUREG report provides guidance to an applicant in preparing an industrial radiography (radiography) license application as well as NRC criteria for evaluating a radiography license application. The term "radiography" as used in this report means an examination of the structure of materials by nondestructive methods, using ionizing radiation to make radiographic images generally using gamma-emitting byproduct materials (radioisotopes). The radioisotopes most commonly used for radiography are cobalt-60 and iridium-192; however, other radioisotopes (e.g. californium-252) with unique radiological characteristics may also be used. This report does not address the research and development of radiography devices or associated equipment, or the commercial aspects of manufacturing, distribution, and service of such devices or equipment. This NUREG report identifies the information needed to complete NRC Form 313 (Appendix B), "Application for Material License," for the use of sealed sources containing byproduct material in radiography devices. The information collection requirements in 10 CFR Parts 30 and 34 and NRC Form 313 have been approved under the Office of Management and Budget (OMB) Clearance Nos. 3150-0017, 3150-0007, and 3150-0120, respectively. The format within this document for each item of technical information is as follows:
Notes, Boxes, and References are self-explanatory and may not be found for each item on NRC Form 313. NRC Form 313 does not have sufficient space for applicants to provide full responses to Items 5 through 11. As indicated on the form, the answers to those items are to be provided on separate sheets of paper and submitted with the completed NRC Form 313. Appendix C provides information on certain topics which may be used in the application and can be used to complete items 5 - 11 of NRC Form 313. Appendix C may also be used as a checklist that NRC staff can use to review applications and applicants can use to check for completeness. Appendix D is a sample radiography license. It contains the conditions most often found on these licenses, although not all licenses will have all conditions. 2 Agreement States[ Prev | Next | Top of file ] Certain states, called Agreement States (see Figure 2.1), have entered into agreements with the NRC that give them the authority to license and inspect byproduct, source, or special nuclear materials used or possessed within their borders. Any applicant other than a Federal agency who wishes to possess or use licensed material in one of these Agreement States needs to contact the responsible officials in that State for guidance on preparing an application; file these applications with State officials, not with the NRC. Naturally-occurring and Accelerator-produced Radioactive Material (NARM) and X-rays are always regulated by the states, not the NRC. In general, NRC's materials licensees who wish to conduct operations at temporary jobsites in an Agreement State should contact that State's radiation control program office for information about State regulations. To ensure compliance with Agreement State reciprocity requirements, a licensee should request authorization well in advance of scheduled use. In the special situation of work at Federally-controlled sites in Agreement States, it is necessary to know the jurisdictional status of the land in order to determine whether NRC or the Agreement State has regulatory authority. NRC has regulatory authority over land determined to be "exclusive Federal jurisdiction," while the Agreement State has jurisdiction over non-exclusive Federal jurisdiction land. Licensees are responsible for finding out, in advance, the jurisdictional status of the specific areas where they plan to conduct licensed operations. NRC recommends that licensees ask their local contact for the Federal agency controlling the site (e.g., contract officer, base environmental health officer, district office staff) to help determine the jurisdictional status of the land and to provide the information in writing, so that licensees can comply with NRC or Agreement State regulatory requirements, as appropriate. Additional guidance on determining jurisdictional status is found in All Agreement States Letter, SP-96-022, dated February 16, 1996. Table 2.1 provides a quick way to check on which agency, if any, has regulatory authority. Table 2.1 Who Regulates the Activity?
Figure 2.1 U.S. Map. Location of NRC Offices and Agreement States. Reference: A current list of Agreement States (including names, addresses, and telephone numbers of responsible officials) by visiting the NRC Office of State Programs' (OSP's) Home Page <http://www.hsrd.ornl.gov/nrc> and choose "Directories" and then "State Program Directors." Or may be obtained upon request from NRC's Regional Offices (see Figure 2.1 for addresses and telephone numbers). All Agreement States Letter, SP-96-022, dated February 16, 1996, is available by visiting OSP's Home Page <http://www.hsrd.ornl.gov/nrc>, choose "NRC-State Communications," and then choose "Other"; scroll down to find "1996" and then "SP-96-022." Or by calling OSP; call NRC's toll free number (800) 368-5642 and then ask for extension 415-3340. 3 Management Responsibility[ Prev | Next | Top of file ] The NRC recognizes that effective radiation safety program management is vital to achieving safe and compliant operations. NRC also believes that consistent compliance with its regulations provides reasonable assurance that licensed activities will be conducted safely. NRC believes that effective management will result in increased safety and compliance. NRC frequently finds ineffective management is the underlying cause of safety and compliance problems.
To ensure adequate management involvement, a management representative, (pursuant to 10 CFR 30.32(c)), must be a person duly authorized to act for and on behalf of the applicant or licensee) must sign the submitted application acknowledging management's commitments and responsibility for the following:
For information on NRC enforcement policy, see "General Statement of Policy and Procedures for NRC Enforcement Actions," (NUREG-1600), which is available from NRC upon request (to obtain, see Availability Notice). NUREG-1600 is also available on the Internet. Visit NRC's Home Page <http://www.nrc.gov>, choose "Nuclear Materials," then "Enforcement Program," "Enforcement Guidance Documents," and then " Enforcement Policy." For information on NRC's radiography inspection procedures, see Inspection Procedure 87120. 4 Applicable Regulations[ Prev | Next | Top of file ] It is the licensee's responsibility to have up-to-date copies of applicable regulations, read them, and abide by each applicable regulation. The following Parts of 10 CFR Chapter I contain regulations applicable to radiography devices:
To request copies of the above documents, call GPO's order desk in Washington, DC at (202) 512-1800. Order the two-volume bound version of Title 10, Code of Federal Regulations, Parts 0-50 and 51-199 from the GPO, Superintendent of Documents, Post Office Box 371954, Pittsburgh, Pennsylvania 15250-7954. The GPO may also be contacted at <www.gpo.gov> . Request single copies of the above documents from NRC's Regional or Field Offices (see Figure 2.1 for addresses and telephone numbers). Note that changes to NRC regulations are published in the Federal Register. 5 How to File[ Prev | Next | Top of file ] 5.1 Paper Application[ Prev | Next | Top of file ] Applicants for a materials license should do the following:
Deviations from the suggested wording of certain responses as shown in this document or submission of alternative procedures may require a custom review. All license applications will be available for review by the general public in NRC's Public Document Rooms. If it is necessary to submit proprietary information, follow the procedure in 10 CFR 2.790. Failure to follow this procedure may result in disclosure of the proprietary information to the public or substantial delays in processing the application. Employee personal information (e.g., home address, home telephone number, social security number, date of birth, radiation dose information) should not be submitted unless specifically requested by NRC. NRC's future licensing process will be faster and more efficient, in part, through acceptance and processing of electronic applications. NRC recommends using a signed NRC Form 313. Other components may be submitted in paper or electronic media. However, those components submitted in paper format will be scanned and converted to electronic format. To ensure a smooth transition, applicants are requested to follow these suggestions:
5.2 Electronic Application[ Prev | Next | Top of file ] As the electronic licensing process develops, it is anticipated that NRC may provide mechanisms for filing applications via diskettes or CD-ROM, and through the Internet. Additional filing instructions will be provided as these new mechanisms become available. 6 Where To File[ Prev | Next | Top of file ] Applicants wishing to possess or use licensed material in any State or U. S. territory or possession subject to NRC jurisdiction must file an application with the NRC Regional Office for the locale in which the material will be possessed and/or used. Figure 2.1 shows NRC's four Regional Offices and their respective areas for licensing purposes. Figure 2.1 also identifies Agreement States. In general, applicants wishing to possess or use licensed material in Agreements States must file an application with the Agreement State, not NRC. However, if work will be conducted at Federally controlled sites in Agreement States, applicants must first determine the jurisdictional status of the land in order to determine whether NRC or the Agreement State has regulatory authority. See the section on "Agreement States" for additional information. 7 License Fees[ Prev | Next | Top of file ] Each application for which a fee is specified, including applications for new licenses and license amendments, must be accompanied by the appropriate fee. Refer to 10 CFR 170.31 to determine the amount of the fee. NRC will not issue the new license prior to fee receipt. Once technical review has begun, no fees will be refunded; application fees will be charged regardless of the NRC's disposition of an application or the withdrawal of an application. Most NRC licensees are also subject to annual fees; refer to 10 CFR 171.16. Consult 10 CFR 171.11 for additional information on exemptions from annual fees and 10 CFR 171.16(c) on reduced annual fees for licensees that qualify as "small entities." Direct all questions about NRC's fees or completion of Item 12 of NRC Form 313 (Appendix B) to the Office of the Controller (OC) at NRC headquarters in Rockville, Maryland, (301) 415-7554. You may also call NRC's toll free number (800) 368-5642 and then ask for extension 415-7554. 8 Contents of an Application[ Prev | Next | Top of file ] The following comments apply to the indicated items on NRC Form 313 (Appendix B). 8.1 Item 1: License Action Type[ Prev | Next | Top of file ] THIS IS AN APPLICATION FOR (Check appropriate item)
Check box A for a new license request. Check box B for an amendment of an existing license and provide license number. See "Amendments and Renewals to a License," Section 9 of this document. Check box C for a renewal of an existing license and provide license number. 8.2 Item 2: Applicant's Name and Mailing Address[ Prev | Next | Top of file ] Response from Applicant: List the legal name of the applicant's corporation or other legal entity with direct control over use of the radioactive material; a division or department within a legal entity may not be a licensee. An individual may be designated as the applicant only if the individual is acting in a private capacity and the use of the radioactive material is not connected with employment in a corporation or other legal entity. Provide the mailing address where correspondence should be sent. Note: NRC must be notified in the event of transfer of control and bankruptcy proceedings; see below for more details. Timely Notification of Transfer of ControlRegulations: 10 CFR 30.34(b). Criteria: Licensees must provide full information and obtain NRC's prior written consent before transferring control of the license, directly or indirectly, or, as some licensees call it, "transferring the license." Discussion: Transfers of control may be the results of mergers, contractual agreements, buyouts, or majority stock transfers. Although it is not NRC's intent to interfere with the business decisions of licensees, it is necessary for licensees to obtain prior NRC written consent. This is to ensure the following:
For additional guidance, see IN 89-25, rev. 1 dated Dec. 7, 1994. Response from Applicant: None from an applicant for a new license; Appendix E identifies the information to be provided about transfer of control. Notification of Bankruptcy Proceedings Regulation: 10 CFR 30.34(h) Criteria: Immediately (within 24 hours) following filing of voluntary or involuntary petition for bankruptcy for or against a licensee, the licensee must notify the appropriate NRC Regional Administrator, in writing, identifying the bankruptcy court in which the petition was filed and the date of filing. Response from Applicant: None at time of application for a new license. 8.3 Item 3: Address(es) Where Licensed Material Will Be Used or Possessed
[ Prev | Next | Top of file ] Regulations: 10 CFR 30.33(a)(2), 10 CFR 34.11, 10 CFR 34.13(j), 10 CFR 34.33, 10 CFR 34.89, 10 CFR 34.101(c). Criteria: Applicants must provide a specific address for each location where radioactive material will be used or stored, or dispatched. Discussion: Specify the street address, city, and state or other descriptive address (such as on Highway 10, 5 miles east of the intersection of Highway 10 and State Route 234, Anytown, State) for each permanent storage or use facility and field station. A field station is a location where licensed material may be stored or used and from which the applicant will dispatch equipment to jobsites. A Post Office Box address is insufficient because NRC needs a specific address to allow an NRC inspector to find the use and/or storage location. If devices will NOT be stored at a dispatch site or field station, indicate this. Also the applicant should state whether a location will be used to perform radiographic operations or only for storage of sources and devices. Response from Applicant: If a device will be used in a permanent radiographic installation, give the specific address of each location. If applicable, describe the locations outside of the installation where radiographic operations will be conducted. If radiography equipment will be stored and /or used at a field station, give the specific address of each field station. If radiography operations will be conducted at temporary jobsites (i.e., locations where work is conducted for limited periods of time), specify "temporary jobsites anywhere in the United States where NRC maintains jurisdiction." Note: If radiography operations are expected to exceed 180 days at a temporary jobsite, then provide written notification to the appropriate NRC regional office prior to exceeding the 180 days (a license amendment is not required). 8.4 Item 4: Person to Be Contacted about this Application
[ Prev | Next | Top of file ] Identify the individual who can answer questions about the application and include his or her telephone number. This is typically the proposed radiation safety officer (RSO) or knowledgeable management official. The NRC will contact this individual if there are questions about the application. Notify NRC if the contact person or telephone number changes. This notice is for "information only" and does not require a license amendment or a fee.
8.5 Item 5: Radioactive Material
[ Prev | Next | Top of file ] 8.5.1 Sealed Sources and DevicesRegulation: 10 CFR 30.32(g), 10 CFR 30.33(a)(2), 10 CFR 32.210, 10 CFR 34.20. Criteria: Applicants must provide the manufacturer's (or distributor's) name and model number for each requested source assembly (sealed source), exposure device, and source changer. Licensees will only be authorized for radiographic exposure devices, source assemblies or sealed sources containing byproduct material and associated equipment meeting NRC performance requirements and specifically approved or registered by NRC or an Agreement State. Also, identify any depleted uranium that is used as shielding material (radiographic exposure devices, source changers and some collimators contain depleted uranium). Discussion: NRC or an Agreement State performs a safety evaluation of radiography source assemblies (sealed sources) exposure devices and source changers prior to distribution of these sources/devices to specific licensees. The safety evaluation is documented in a Sealed Source and Device (SSD) Registration Certificate issued to the manufacturer (or distributor). Therefore, if the source assemblies, exposure devices, or source changers are approved for use by NRC or an Agreement State agency, the applicant need only note the manufacturer's (or distributor's) name and model number of the sources/devices in its license application to demonstrate that the requirements are met. Consult with the proposed supplier to ensure that sources and devices conform to the sealed source and device designations registered with NRC or an Agreement State. For licensees to ensure that they use radiographic equipment in accordance with registration certificates, licensees may want to review the certificate, discuss with the manufacturer, or obtain a copy of the certificate. Licensees may not make modifications to exposure devices, source changers, source assemblies and associated equipment unless the design of any replacement component, including source holder, source assembly, controls or guide tubes would not compromise the safety features of the system. Consult with the manufacturer of the associated equipment (i.e., equipment that is used in conjunction with the exposure device that drives, guides, or comes in contact with the source) to be sure that the associated equipment is compatible with the sources and devices. Licensees must demonstrate that associated equipment meet the performance requirements in 10 CFR 34.20. Information Notice 96-20: "Demonstration of Associated Equipment Compliance with 10 CFR 34.20" (Appendix F) contains a number of ways that licensees can demonstrate that their associated equipment meets performance requirements. Response from Applicant:
Table 8.1 Industrial Nuclear Model Ir-100 Exposure Device Maximum Authorization -- 120 Ci
Table 8.2 Spec Model 150 Exposure Device Maximum Authorization -- 150 Ci
Table 8.3 Amersham Model 680 System Exposure Device Maximum Authorization -- 110 Ci
Table 8.4 Amersham Model 660 System Exposure Device Maximum Authorization -- 140 Ci
Note: For information on SSD registration certificates, contact the Registration Assistant by calling NRC's toll free number (800) 368-5642 and then asking for extension 415-7217. 8.5.2 Financial Assurance and Recordkeeping for DecommissioningRegulations: 10 CFR 30.34(b), 10 CFR 30.35, 10 CFR 34.13(k). Criteria: Industrial radiography licensees authorized to possess sealed sources containing byproduct material in excess of the limits specified in 10 CFR 30.35 must provide evidence of financial assurance for decommissioning. Licensees are required to maintain, in an identified location, decommissioning records related to structures and equipment where devices are used or stored and records related to leaking sources. Licensees must transfer these records important to decommissioning either to any new licensee before licensed activities are transferred or assigned in accordance with 10 CFR 30.34(b), or to the appropriate NRC regional office before the license is terminated. Discussion: The requirements for financial assurance are specific to the types and quantities of byproduct material authorized on a license. Most industrial radiography applicants and licensees do not need to comply with the financial assurance requirements because the thresholds for sealed sources containing byproduct material are 3.7 x 105 Bq (10,000 curies) of cobalt-60 and 3.7 x 106 Bq (100,000 curies) of cesium-137 or byproduct material with half-lives less than 120 days (e.g., iridium-192). Thus, a licensee would need to possess hundreds of sources before the financial assurance requirements would apply. Since the standard industrial radiography license does not specify the maximum number of sources that the licensee may possess (allowing the licensee flexibility in obtaining sources/devices as needed without amending its license), it contains a condition requiring the licensee to limit its possession of sources to quantities not requiring financial assurance for decommissioning. Applicants and licensees desiring to possess sources exceeding the threshold amounts must submit evidence of financial assurance. The same regulation also requires that licensees maintain records important to decommissioning in identified locations other than at any temporary jobsite. All industrial radiography licensees need to maintain records of structures and equipment where devices are used or stored. As-built drawings showing modifications to structures and equipment fulfill this requirement. If drawings are not available, licensees may substitute appropriate records (e.g., a sketch of the room, building or a narrative description of the area) concerning the areas and locations. In addition, industrial radiography licensees who have experienced unusual occurrences (e.g., leaking sources or other incidents that involve spread of contamination, such as S-tube breakthrough) also need to maintain records about contamination that remains after cleanup or contamination that may have spread to inaccessible areas. Response from Applicants: State: "Pursuant to 10 CFR 30.35(g), we shall maintain drawings and records important to decommissioning and to transfer these records to a new licensee before licensed activities are transferred, or to assign the records to the appropriate NRC regional office before the license is terminated." AND If financial assurance is required, submit evidence. Reference: Regulatory Guide 3.66, "Standard Format and Content of Financial Assurance Mechanisms Required for Decommissioning Under 10 CFR Parts 30, 40, 70, and 72," is available from NRC upon request. 8.6 Item 6: Purpose(s) for Which Licensed Material Will Be Used
[ Prev | Next | Top of file ] Regulations: 10 CFR 30.33(a)(1), 10 CFR 34.1. Criteria: Sources and devices will be used only for the purposes for which they were designed and in accordance with the manufacturer's recommendations for use as specified in an approved Sealed Source and Device (SSD) Registration Certificate. Discussion: The typical license authorizes persons to perform source exchanges and to conduct industrial radiography at temporary jobsites, field stations, and/or permanent radiographic installations. Unusual uses will be evaluated on a case-by-case basis and the authorized use condition will reflect approved uses. Applicants who plan to perform radiographic operations on lay-barges, on offshore platforms, or underwater must specifically request these operations. Response from Applicant:
OR
AND
8.7 Item 7: Individual(s) Responsible for Radiation Safety Program and Their Training and Experience
[ Prev | Next | Top of file ] 8.7.1 Radiation Safety Officer (RSO)Regulations: 10 CFR 34.13(f), 10 CFR 34.13(g), 10 CFR 34.42. Criteria: RSOs and potential designees responsible for ensuring that the licensee's radiation safety program is implemented in accordance with approved procedures must have adequate training and experience. Discussion: The person responsible for the radiation protection program is called the RSO. The NRC believes the RSO is the key to overseeing and ensuring safe operation of the licensee's radiography program. The RSO needs independent authority to stop operations that he or she considers unsafe. He or she must have sufficient time and commitment from management to fulfill certain duties and responsibilities to ensure that radioactive materials are used in a safe manner. The RSO may delegate certain day-to-day tasks of the radiation protection program to other responsible individuals (potential designees). For example, a large testing company with multiple field stations may appoint individuals designated as "site RSOs" who assist the RSO and are responsible for the day-to-day activities at the field stations. Licensees may also appoint other individuals who may "step-in" as an emergency contact when the RSO is unavailable. The potential designees do not need to meet the required RSO qualifications; however, these individuals should be qualified, experienced radiographers who are adequately knowledgeable of the activities to which they are assigned. Applicants do not have to identify other responsible individuals if day-to-day tasks, etc. will not be delegated. Typical RSO duties are illustrated in Figure 8.1. NRC requires the name of the RSO on the license to ensure that licensee management has always identified a responsible, qualified person and that the named individual knows of his or her designation as RSO. Provide NRC with a copy of an organizational chart showing the RSO (and other designated responsible individuals) to demonstrate that he or she has sufficient independence and direct communication with responsible management officials. Also, show in the organizational chart the position of the individual who signs the application in Item 13 of the NRC Form 313. To be considered eligible for the RSO position, an individual must be a qualified radiographer, have a minimum of 2,000 hours (one year full-time field experience) of hands-on experience as a qualified radiographer, and have formal training in establishing and maintaining a radiation protection program. This should be a course specifically designed to provide training in running a radiation safety program, a basic radiation safety course is not acceptable. While a course particular to industrial radiography would be highly encouraged, this is not required. Acceptable training programs would be would be a classroom course typical of those provided through universities or commercial training facilities. Hands-on experience means experience in all areas considered to be directly involved in the radiography process. This includes taking radiographs, surveying device and radiation areas, transporting the radiography equipment to temporary jobsites, posting, work sites, radiation area surveillance, completing and maintaining records, etc. Excessive time spent in only one or two of these operations (film development and/or area surveillance) should not be counted toward the 2,000 hours. Experience with radiography using x-rays can be included; however, the majority of experience should be in isotope radiography. Figure 8.1 Responsibilities. Typical duties and responsibilities of RSOs. Note: The NRC will consider individuals with alternative training and experience as RSOs. For example, a person certified in health physics or industrial hygiene with previous experience in managing a radiation safety program of comparable size and scope could be considered as an individual case. The qualifications, training, and experience required of the RSO may vary depending upon the complexity of the applicant's operations and number of radiography personnel. Response from Applicant: Provide the following:
AND
AND EITHER
OR
Note: It is important to notify NRC and obtain a license amendment prior to making changes in the designation of the RSO responsible for the radiation safety program. If the RSO leaves the organization before an amendment is approved by the NRC, a potential designee, who meets the RSO qualification requirements, is responsible for ensuring that the licensee's radiation safety program is implemented in accordance with the license and NRC regulations. Alternative responses will be reviewed against the criteria listed above. 8.8 Item 8: Training for Radiographers and Radiographer's Assistants
[ Prev | Next | Top of file ] Regulations: 10 CFR 19.12, 10 CFR 30.33, 10 CFR 34.13, 10 CFR 34.43. Criteria: Radiographers and radiographer's assistants must have adequate training and experience as outlined in 10 CFR 34.43. Discussion:
Refer to Appendix G as an aid to determining the specific training requirements for radiographers and radiographer's assistants. The applicant must submit a description of their training program for radiographers and radiographers assistants.
Because 10 CFR Part 34 contains different requirements for radiographers and radiographer's assistants, include training programs for each. When describing the training programs for these positions, include the sequence of events from the time of hiring through the designation of individuals as radiographers or radiographer's assistants. Experienced radiographers who have worked for another licensee should receive formal instruction similar to that given to prospective radiographer's assistants. This instruction must include training in your operating and emergency procedures, in the use of your exposure devices and associated equipment, and in the use of survey meters and other radiation monitoring devices. Instructors who provide classroom training to individuals in the principles of radiation and radiation safety should have knowledge and understanding of these principles beyond those obtainable in a course similar to the one given to prospective radiographers. Individuals who provide instruction in the hands-on use of radiography equipment should be qualified radiographers with at least 1 year of experience in performing radiography, or should possess a thorough understanding of the operation of radiographic equipment (e.g., a manufacturer's service representative). An internal inspection program (audit program) of the job performance of each radiographer and radiographer's assistant ensures that the Commission's regulations, license requirements, and the licensee's operating and emergency procedures are followed. The audit must include observation of the performance of each radiographer and radiographer's assistant during an actual industrial radiographic operation at intervals not to exceed 6 months. If a radiographer or radiographer's assistant has not participated in an industrial radiographic operation for more than 6 months, the individual must demonstrate knowledge of the training requirements by practical examination before participating in a radiographic operation. The person conducting internal inspections should have a minimum of one year actual experience as a radiographer. Response from Applicant: Submit an outline of the training to be given to prospective radiographers and radiographer's assistants. Submit your procedures for experienced radiographers who have worked for another licensee. Provide a copy of a typical examination and the correct answers to the examination questions. Indicate the passing grade. Prior to June 27, 1999, you may affirm that all individuals acting as radiographers will be certified in radiation safety in lieu of providing a description of your training and examination program in the topics listed in 10 CFR 34.43(g). (All other training program descriptions must still be submitted.) Specify the qualifications of your instructors in radiation safety principles and describe their experience with radiography. If training will be conducted by someone outside the applicant's organization, identify the course by title and provide the name and address of the company providing the training. Describe the field (practical) examination that will be given to prospective radiographers and radiographer's assistants. The NRC suggests using the checklist in Appendix H as a source of potential areas to review during the field examination. Describe the annual refresher training program, including topics to be covered and how the training will be conducted. Submit your procedures for verifying and documenting the certification status of radiographers and for verifying that their certification remains valid. As a minimum your procedures for newly hired, previously certified individuals should require documentation of your contacting the certifying entity and confirming the certification. Your procedures should also ensure you are aware of certification expiration dates and that individuals with expired certifications do not act a radiographers. Submit a description of your program for inspecting the job performance of each radiographer and radiographers' assistant at intervals not to exceed 6 months as described in 10 CFR 34.43(e).
8.9 Item 9: Facilities and Equipment
[ Prev | Next | Top of file ] Regulations: 10 CFR 20.1003, 10 CFR 20.1301, 10 CFR 20.1601, 10 CFR 20.1801, 10 CFR 20.1802, 10 CFR 30.33, 10 CFR 34.13(j), 10 CFR 34.33, 10 CFR 34.89. Criteria: Licensees must specifically identify and describe permanent radiographic installations and field stations, and any other locations where radiography will be conducted. Discussion: A permanent radiographic installation is an enclosed shielded room, cell, or vault in which radiography may be performed. A facility is considered "permanent" if it is intended to be used for radiography, even if radiography is rarely performed there. The nature of the facility, rather than the frequency of use, determines a permanent radiographic installation. All radiographic operations conducted at locations of use authorized on the license must be conducted in a permanent radiographic installation, unless specifically authorized by NRC. If licensees need to perform radiography at their place of business outside of a permanent facility due to unique circumstances (the item to be radiographed is too large for the facility), then the NRC must authorize this method of use. In this case two individuals must be present whenever radiographic operations occur outside of a permanent installation. The one primary (and perhaps the most important) reason licensees have for conducting radiography in a permanent radiographic installation is that they can limit access restrictions imposed at a work location. In order to ensure this control a permanent radiographic installation, if located on the ground, must be enclosed by a minimum of four shielded walls (otherwise the floor must also be shielded). The use of materials that do not realistically provide shielding, do not qualify. Areas outside of the facility generally should qualify as unrestricted areas. While the area outside of an installation should qualify as an unrestricted area (i.e., not exceed 2mr/hr), the regulation did not specify radiation limits in order to allow for design flexibility for moving equipment into and out of the installation, or other considerations. Radiation levels slightly exceeding these levels outside of the facility should only be considered or allowed when the higher levels are due to "sky shine" or the need for equipment movement. If the roof of the facility does not qualify as a restricted area, or if no roof exists, mechanical access restrictions (fence, etc.) must be utilized and additional administrative controls must imposed to ensure that unwanted access can be gained only through extraordinary effort. All entrance ways into the facility must be interlocked with 10 CFR Part 34 required control devices. Unless all entrance ways are locked, at least one radiographer must be present at the facility whenever radiography is being conducted. A field station is a facility where licensed material may be stored and/or used and from which equipment is dispatched. Radiographic operations may be conducted in a permanent radiographic installation or at the place of business in the same manner as described above. A restricted area is an area that licensees limit access for the purpose of protecting individuals from undue risks from exposure to radiation and radioactive materials. A restricted area cannot include areas used as residential quarters. Consequently, industrial radiography devices must not be stored in motel rooms or similar locations. Requirements for a permanent radiographic installation:
Figure 8.2 Example Diagram of a Permanent Radiographic Installation
Response from Applicant: Provide the following:
Variances will be considered if construction requirements preclude shielding the roof(1) in order to meet the requirement not to exceed 0.02 mSv (2 mrem) in any one hour. Provide the following information to obtain approval for a variance:
If radiation levels on the radiography installation roof1 exceed 1.0 mSv (100 mrem) in any one hour, then provide the following information in addition to the items above to apply for this variance:
Field Stations:
Note: Rem, and its SI equivalent Sievert, will be used in this report whenever units of radiation exposure or dose are required. This is done since 10 CFR Part 20 sets dose limits in terms of rem, not rad or roentgen, and the sealed sources used in radiography emit gamma rays, which means that 1 roentgen = 1 rad = 1 rem. 8.10 Item 10: Radiation Safety Program
[ Prev | Next | Top of file ] Regulations: 10 CFR 20.1101, 10 CFR 30.33, 10 CFR 34.13. Criteria: A radiation safety program must be established and submitted to the NRC as part of the application. The program must be commensurate with the scope and extent of activities for the use of licensed materials in industrial radiography. Each applicant for an industrial radiography license must develop, document, and implement a radiation protection program containing the following elements:
Discussion: The specific components of the applicant's radiation safety program are detailed in the following topics found in this NUREG. Some topics will not require the applicant to submit information as part of an application, but simply provide the applicant with guidance to comply with a specific NRC requirement. 8.10.1 Radiation Safety Program AuditRegulations: 10 CFR 20.1101, 10 CFR 20.2102. Criteria: Licensees must review the content and implementation of their radiation protection programs annually to ensure:
Discussion: Appendix I contains a suggested annual audit program that is specific to industrial radiography and is acceptable to NRC. All areas indicated in Appendix I may not be applicable to every licensee and may not need to be addressed during each audit. Audit records acceptable to NRC should contain the following information:
It is essential that once identified, problems be corrected in a timely manner. Information Notice (IN) 96-28, "Suggested Guidance Relating to Development and Implementation of Corrective Action," provides guidance on this subject. The NRC will review the licensee's audit results and determine if corrective actions are thorough, timely, and sufficient to prevent recurrence. If violations are identified by the licensee and these steps are taken, the NRC can exercise discretion and may elect not to cite a violation. The NRC's goal is to encourage prompt identification and prompt, comprehensive correction of violations and deficiencies. For additional information on NRC's use of discretion on issuing violations, refer to "General Statement of Policy and Procedures for NRC Enforcement Actions," (NUREG-1600) (to obtain, see below). Response from Applicant: The applicant is not required to submit its audit program applicable to 10 CFR Part 20 for review during the licensing phase. Appendix I, Radiation Safety Program Audit, provides an example of an acceptable annual audit. References: The following documents are available from NRC upon request: Inspection Procedure 87120, "Industrial Radiography Field Notes," NUREG-1600, "General Statement of Policy and Procedures on NRC Enforcement Actions," (to obtain, see Availability Notice) and IN 96-28, "Suggested Guidance Relating to Development and Implementation of Corrective Action." NUREG-1600 is also available on the Internet. Visit NRC's Home Page <http://www.nrc.gov>, choose "Nuclear Materials," then "Enforcement Program," "Enforcement Guidance Documents," and then "Enforcement Policy." 8.10.2 InstrumentsRegulations: 10 CFR 30.33(a)(2), 10 CFR 34.25, 10 CFR 34.31, 10 CFR 34.65. Criteria: A radiation survey meter intended for industrial radiography that utilizes sealed radioisotope sources should be capable of accurately measuring the radiation fields produced by the sealed radiography source currently in use, and be visually checked for damage and for proper operation with a check source or other appropriate means, such as an exposure device, before use on each day it is to be used. The survey meter shall be calibrated at intervals not to exceed 6 months and after each servicing, (except for battery changes). Written procedures are required for inspection and routine maintenance of the survey meters, which is to be performed at intervals not to exceed 3 months or before the first use thereafter to ensure proper functioning of components important to safety. Discussion: Licensee shall keep an adequate number of appropriate radiation survey instruments that are both calibrated and operable, at each location where radioactive material is present to make the required radiation surveys. The instruments shall be capable of measuring a range from 0.02 mSv (2 mrem) per hour through 10 mSv(1 rem) per hour. Each radiation survey instrument shall be calibrated at intervals not to exceed 6 months and after each instrument servicing, except for battery changes. Records of survey instrument calibrations will be retained for a minimum of 3 years (10 CFR 34.65). Records are to be made of equipment problems and maintenance performed and these shall be retained for 3 years (10 CFR 34.73). Response from Applicant: Provide the following:
AND
OR
Note: For detailed information about survey instrument calibration, refer to ANSI N323-1978, "Radiation Protection Instrumentation Test and Calibration." Reaffirmed 1993 copies may be obtained from the American National Standards Institute, 1430 Broadway, New York, NY 10018. 8.10.3 Material Receipt and AccountabilityRegulations: 10 CFR 30.34(e), 10 CFR 30.41, 10 CFR 30.51, 10 CFR 34.29, 10 CFR 34.63, 10 CFR 34.69. Criteria: Licensees must do the following:
Discussion: As illustrated in Figure 8.3, licensed materials must be tracked from "cradle to grave" in order to ensure accountability; identify when sources/devices may be lost, stolen, or misplaced; and ensure that the possession limit stated on the license is not exceeded. Conduct physical inventories (i.e., locate, verify the presence of the material, and account for it in material transfer records) at quarterly intervals (not to exceed 3 months) to account for all sealed sources and devices containing depleted uranium. Maintain inventory records that contain the following types of information:
Figure 8.3 Material Receipt and Accountability. Licensees must maintain records of receipt and disposal and conduct physical inventories quarterly (not to exceed 3 months). Response from Applicant: Provide the following: A statement that: "Physical inventories will be conducted and documented at quarterly intervals (not to exceed 3 months) to account for all sealed sources containing byproduct material and devices containing depleted uranium received and possessed under the license." 8.10.4 Minimization of ContaminationRegulations: 10 CFR 20.1406. Criteria: Applicants for new licenses must describe how facility design and procedures for operation will minimize, to the extent practicable, contamination of the facility and the environment, facilitate eventual decommissioning, and minimize, to the extent practicable, the generation of radioactive waste. Discussion: All applicants for new licenses need to consider the importance of designing and operating their facilities so as to minimize the amount of radioactive contamination generated at the site during its operating lifetime and to minimize the generation of radioactive waste during decontamination. Industrial Radiography applicants usually do not need to address these issues as a separate item since they are included in responses to other items of the application. Sealed sources and devices that are approved by NRC or an Agreement State and located and used according to their respective SSD Registration Certificates usually pose little risk of contamination. Leak tests performed as specified in 10 CFR 34.27 should identify defective sources. Leaking sources must be withdrawn from use and decontaminated, repaired, or disposed of according to NRC requirements. These steps minimize the spread of contamination and reduce radioactive waste associated with decontamination efforts. Other efforts to minimize radioactive waste do not apply to programs using only sealed sources and devices that have not leaked. Response from Applicant: The applicant does not need to provide a response to this item under the following condition. NRC will consider that the above criteria have been met if the applicant's responses meet the criteria for the following sections: "Radioactive Material - Sealed Sources and Devices," "Facilities and Equipment," "Radiation Safety Program - Leak Tests," "Radiation Safety Program - Operating and Emergency Procedures," and "Waste Management - Sealed Source / DU Device Transfer and Disposal." 8.10.5 Leak TestsRegulations: 10 CFR 30.53, 10 CFR 34.13(h), 10 CFR 34.27, 10 CFR 34.67. Criteria: NRC requires testing to determine whether there is any radioactive leakage from the source or from devices containing depleted uranium shielding. NRC finds testing to be acceptable if it is conducted by an organization licensed by NRC or an Agreement State, or conducted in accordance with procedures approved by NRC or an Agreement State. Discussion: Manufacturers, consultants, and other organizations may be authorized by NRC or an Agreement State to either perform the entire leak test sequence for other licensees or provide leak test kits to licensees. In the latter case, the licensee is expected to take the leak test sample according to the device manufacturer's and the kit supplier's instructions and return it to the kit supplier for evaluation and reporting results. Licensees may also be authorized to conduct the entire leak test sequence themselves. Measurement of the leak-test sample is a quantitative analysis requiring that instrumentation used to analyze the sample be capable of detecting 185 Bq (0.005 microcurie) of radioactivity. Sealed sources containing byproduct material must be leak tested at intervals not to exceed 6 months and DU devices tested at intervals not to exceed 12 months. Response from Applicant: Do either of the following:
OR
Note: Requests for authorization to perform leak testing and sample analysis will be reviewed on a case-by-case basis and, if approved, NRC staff will authorize via a license condition. 8.10.6 Occupational DosimetryRegulations: 10 CFR 20.1201, 10 CFR 20.1207, 10 CFR 20.1208, 10 CFR 20.1501, 10 CFR 20.1502, 10 CFR 34.47. Criteria: Licensees must: Provide to employees, film or TLD dosimetry processing that has been accredited under the National Voluntary Laboratory Accreditation Program (NVLAP) operated by the National Institute of Standards and Technology (NIST). Figure 8.4 Dose Limits. Dose limits for radiation workers. Discussion: The licensee may not permit any individual to act as a radiographer or a radiographer's assistant unless, at all times during radiographic operations each individual wears, on the trunk of the body, a combination of a direct-reading dosimeter (pocket dosimeter or electronic personal dosimeter), an operating alarm ratemeter, and either a film badge or a TLD. At permanent radiography installations where other appropriate alarming or warning devices are in routine use, wearing an alarming ratemeter is not required. The pocket dosimeters must have a range from zero to 2 mSv (200 mrems), must be recharged at the start of each shift, and must be checked for correct response to radiation at intervals not to exceed 12 months. Electronic personal dosimeters may only be used in place of ion-chamber pocket dosimeters. Alarm ratemeters must be preset to give an alarm signal at a dose rate of 5 mSv/hr (500 mrem/hr) and must be calibrated for correct response at intervals not to exceed 12 months. Film badges must be replaced at intervals not to exceed 1 month and TLDs must be replaced at intervals not to exceed 3 months. Response from Applicant: Provide the following:
8.10.7 Public DoseRegulations: 10 CFR 20.1003, 10 CFR 20.1301, 10 CFR 20.1302, 10 CFR 20.1801, 10 CFR 20.1802. Criteria: Licensees must do the following:
Figure 8.5 Storing Devices. Devices must be stored away from occupied areas and secured against unauthorized removal. Discussion: Operating and emergency procedures that address security and surveillance should be sufficient to limit exposure of the public during use and after accidents. Public dose is controlled, in part, by ensuring that devices not in use are stored securely (e.g., stored in a locked area) to prevent unauthorized access or use. If devices are not in storage, then authorized users must maintain constant surveillance. Public dose is also affected by the choice of the permanent radiographic installation and storage locations and conditions, as illustrated in Figure 8.5. Since radiation levels around a permanent radiographic installation or storage area will vary based on the type and strength of sources used, the frequency of use, and scatter radiation from radiographic operations, it is not sufficient to perform surveys with portable survey meters to determine the annual public dose. Use of area monitors such as environmental TLD is an acceptable means of demonstrating compliance with the annual limit of 1 mSv (100 mrem) in unrestricted areas. Use the concepts of time, distance, and shielding when choosing a permanent radiographic installation or storage location. Decreasing the time spent near radiographic operations, increasing the distance of the device from occupied locations, using shielding material (i.e., high density concrete, solid block, or lead sheets), and implementing conservative operating procedures (i.e., use of collimators or limiting the direction of exposures towards the floor) will reduce the radiation exposure of personnel and members of the public. Alternatively, the remote location of and access to a permanent radiographic installation could prevent members of the public from receiving 1 mSv (100 mrem) in a year. If, after an initial evaluation, a licensee makes changes affecting the permanent radiographic installation storage area (e.g., changing the location of devices within the storage area, removing shielding, adding devices, changing the occupancy of adjacent areas, moving the storage area to a new location), then the licensee must perform a new evaluation to ensure that the public dose limits are not exceeded and devices are properly secured. Response from Applicant: No response is required from the applicant in a license application, but this matter will be examined during an inspection. Appendix L provides additional information for determining that radiation doses for other licensee personnel and members of the public will not exceed allowable limits. 8.10.8 Quarterly MaintenanceRegulation: 10 CFR 34.31, 10 CFR 34.73, 10 CFR 71.101(g). Criteria: The licensee shall have written procedures for inspecting and maintaining radiographic exposure devices, source changers, associated equipment, transport and storage containers, and survey instruments. Inspection and maintenance must be conducted at intervals not to exceed every 3 months, or before the first use thereafter, to ensure the proper functioning of components important to safety. The licensee must also have procedures necessary to maintain the Type B packaging used to transport radioactive materials, ensure that Type B packages are shipped properly, and maintain Type B packages in accordance with the Certificate of Compliance (COC) issued by NRC or other agencies approving such transport packages. If equipment problems are found, the equipment must be withdrawn from service until repaired. Records are required. Discussion: These procedures are intended to allow the licensee's staff to evaluate equipment used in radiography for safe continued use, to provide a record of this evaluation, and to guide the staff in maintenance. Equipment found to be unsuitable for service must be withdrawn until repair and an evaluation for return to service is made. These procedures may be based on the manufacturer's recommendations. The procedures are to be specific to the equipment. For example, radiography drive cable assemblies should be cleaned and lubricated (when operationally appropriate) in accordance with the recommendations of the equipment manufacturer or the cable manufacturer or alternatively, with any lubrication and cleaning recommendations established by the industrial radiography community. Procedures are also required for Type B packaging used to transport radioactive materials. These procedures are to be used for shipping and maintenance, and may be properly drawn from the manufacturer's procedures and information submitted as a basis for the COC or other transport package approval. Response from Applicant:
AND
8.10.9 Operating and Emergency ProceduresRegulations: 10 CFR 34.13(d), 10 CFR 34.45. Criteria: Operating and emergency procedures must be established and submitted to the NRC as part of the application package. In addition, if radiographers will perform other operations such as source exchange, leak-testing, and quarterly (not to exceed 3 months) inspection and maintenance of equipment, appropriate procedures and instructions for these operations should be included in the operating and emergency procedures. Each licensee must develop, implement, and maintain operating and emergency procedures containing the following elements:
Discussion: The purpose of operating and emergency procedures is to provide radiography personnel with specific guidance for all operations they will perform. These topics should be included in the operating and emergency procedures and need not be presented in order of importance. A sequential set of procedures and instructions from the beginning to the end of the workday is an acceptable format. Instructions for non-routine operations, for example, quarterly (not to exceed 3 months) inspection and maintenance or instrument calibration, may be included as separate appendices. It is not necessary for operating and emergency procedures to be specific to a particular make and model of exposure device, source exchanger, or survey instrument. Procedures submitted to the NRC should provide sufficient guidance and instruction for each specific type of device. For example, you may submit a single operating procedure for crank-out regardless of the manufacturer and/or a single operating procedure for pipeliner exposure devices regardless of manufacturer. Applicants who plan to conduct lay-barge, offshore platform, or underwater radiography are required to have their procedures approved by the NRC. If you plan to conduct lay-barge, offshore platform or underwater radiography, your radiation safety program will be reviewed to assure that it contains procedures that specifically address:
Operating and emergency procedures must be submitted to the NRC for review.
8.10.9.1 Handling and Use of Sealed Sources and Radiography Exposure DevicesRegulations: 10 CFR 34.41, 10 CFR 34.45, 10 CFR 34.46, 10 CFR 34.47, 10 CFR 34.49, 10 CFR 34.51. Criteria: Licensees need to establish operating and emergency procedures. Discussion: There are two types of devices normally used for radiography, crankout, and pipeliner. There should be separate instructions for each type of device. Separate instructions are not necessary for each different model of a given type of device since the operation of each type is essentially the same regardless of the manufacturer. Some applicants may choose to use one basic instruction for all crankout devices; others may choose to have separate instructions for each model. Either approach is acceptable. Specific procedures should be required for performing source exchanges, including those at temporary jobsites, field stations, and in a permanent radiographic installations. The procedures should contain warnings of areas of concern during source exchanges. Recent incidents of sources becoming dislodged from the shielded position indicate the importance of training personnel in the appropriate techniques. Procedures should require the use of survey instruments, dosimetry, and surveys during and after movement of sources. Response from Applicant:
Appendix M provides information for applicants to consider when developing their procedures for operating radiography equipment. 8.10.9.2 Methods and Occasions for Conducting Radiation SurveysRegulations: 10 CFR 20.1301(a)(2), 10 CFR 20.1302(a)(1), 10 CFR 20.1906, 10 CFR 34.20(a), 10 CFR 34.21, 10 CFR 34.27(c)(1), 10 CFR 34.27(e), 10 CFR 34.49(b), 10 CFR 34.49(c), 49 CFR 172.403, 49 CFR 173.441. Criteria: Perform radiation surveys during use, movement, and storage of licensed material to ensure its safe use and comply with regulatory requirements. Discussion: In general, surveys need to be made whenever a source is manipulated or moved. Surveys should be made with a radiation survey instrument calibrated in accordance with 10 CFR 34.25. The following table provides examples of surveys, made during radiographic and associated operations, that should be included in the operating and emergency procedures. Table 8.5 Surveys Required for Radiographic Operations
Response from Applicant: Where applicable, the operating and emergency procedures must include each of the surveys included in Table 8.1 above. 8.10.9.3 Methods for Controlling Access to Radiographic AreasRegulations: 10 CFR 20.1801, 10 CFR 20.1802, 10 CFR 20.1902(a), 10 CFR 20.1902(b), 10 CFR 34.33, 10 CFR 34.41(a), 10 CFR 34.51, 10 CFR 34.53. Criteria: Each licensee must control access to areas where licensed material is either used or stored to prevent the unnecessary exposure of members of the public. This can be achieved through the use of posting, by locking devices and areas where licensed materials are stored, and by maintaining constant control and continuous surveillance of areas where radiographic operations are conducted. Operating and emergency procedures should include steps for radiographic personnel to ensure that access to licensed materials is controlled for the types of operations that will be performed. Discussion: Field/Temporary JobsitesAfter June 27, 1998, when radiographic operations are performed outside a permanent radiographic installation, at least two qualified radiographic personnel must be present. At least one of the individuals must be a radiographer; the other may be another radiographer or a radiographer's assistant. Both individuals must maintain constant surveillance of the operations and be capable of providing immediate assistance to prevent unauthorized entry to the restricted area. Operating procedures must comply with the two-man rule for radiographic operations at any locations other than permanent radiographic facilities. Radiographic personnel are required to maintain continuous direct visual surveillance of operations to protect against unauthorized entry to the high radiation area during radiographic operations. Radiographic personnel should be instructed to keep the perimeter of the restricted area under continuous surveillance to prevent unnecessary exposure of individuals. Operating procedures should specify steps for responding to unauthorized entry to the restricted area. For example, personnel should be instructed to terminate the radiographic exposure immediately, before confronting the person who entered the restricted area. Figure 8.6 Posting. A radiographer is likely to use only a single rope barrier. The radiation area and restricted area would be combined into one and located at the 2 mrem in any 1 hour boundary. All areas where radiographic operations are conducted require posting of the radiation areas and the high radiation areas as shown in Figure 8.6. Specific exemptions listed in 10 CFR 20.1903 do not apply to industrial radiography (10 CFR 34.53). However, it is acceptable to post the perimeter of the restricted area rather than the perimeter of the radiation area. Personnel should be instructed to post "Caution Radiation Area" signs at the point where radiation levels have been calculated to reach 0.02 mSv (2 mrem) in any one hour. A confirming survey during to the first exposure of the source should be conducted to confirm the location of the boundary and any necessary adjustments should be made. The perimeter of the high radiation area must be posted with a "Caution (or Danger) High Radiation Area" sign(s) at the point where radiation levels have been calculated to reach 1 mSv (100 mrem) in any one hour. A confirming survey of the high radiation area perimeter should not be conducted, since such a survey could lead to unnecessary exposure of personnel. Surveillance of the restricted area at facilities with multiple levels and multiple access points, or where members of the public are close to the radiographic operations (e.g., boilers, commercial manufacturing plants, or power plants during outages) can usually be performed only when more than two radiographic personnel are assigned to the job. Figure 8.7 provides one example of such a temporary jobsite. Operating procedures and instruction to personnel should include specific steps for these circumstances to ensure that access into the restricted area is properly controlled. These special instructions may include the use of additional personnel to assist radiographic personnel in controlling access into the restricted area, providing instruction to other workers in the area, or making announcements over the public address system before and during radiographic operations. Figure 8.7 Surveillance and Posting at a Temporary Job Site with Multiple Floors and Access Points. Adequate control of the restricted area at this type of job site requires several personnel and many postings. Permanent Radiographic InstallationsFor permanent radiographic installations, instruct personnel about posting each entrance to the facility with a "Caution (or Danger) High Radiation Area" sign(s), and provide procedures to ensure that the visible-audible signal system is operable. The operability of the visible-audible system must be checked daily. The following procedures may be used:
In the event that an entrance control device or an alarm fails to operate properly at the permanent radiographic installation, the installation may continue to operate for up to 7 days while the defective equipment is fixed, provided that:
Storage AreasRadiographic equipment containing licensed materials stored in controlled or unrestricted areas must be secured from unauthorized removal or access. Operating procedures should specify how stored licensed materials should be secured and who is authorized access to licensed material. A vehicle used to transport licensed material can also be used for storage at locations such as temporary jobsites or overnight lodging. If the applicant plans to use vehicles for storage, there should be procedures and instructions to personnel about proper posting of the vehicle. Vehicles should be posted with a "Caution - Radioactive Material" sign on the entrance to the area of the vehicle were licensed material is stored. A physical survey should be performed to confirm that the area around the storage facility is an unrestricted area. Radiation levels may not exceed 0.02 mSv/hr (2 mrem/hr) at 18 inches (45 cm) from any external surface of the vehicle and the vehicle shall be locked when it is used for storage. Radiographic equipment stored at temporary jobsites must be secured at a location that prevents access by unauthorized personnel. This usually requires that the equipment be locked in a cabinet or other secure area where key access is controlled by site management and radiographic personnel. It is not acceptable for a device to be chained to a post and left unattended at the place of use during lunch, breaks, or after hours. Storage of exposure devices at a private residence is unacceptable unless it has been identified and approved in a license. Note: All regulatory criteria applying to your normal place of business for conducting industrial radiography operations also apply to the location in which you store at your private residence. You must specify this storage location in you license application. Response from Applicant: Submit the procedures to control access to radiographic operations and storage areas. 8.10.9.4 Methods and Occasions for Locking and Securing Radiographic Exposure Devices, Storage Containers, and Sealed SourcesRegulations: 10 CFR 34.20, 10 CFR 34.23. Criteria: NRC regulations requires locking and securing radiographic equipment to protect the public and radiographers from an inadvertent exposure to radiation. Discussion: All radiographic devices, i.e., gamma cameras, sealed source storage containers, and source changers are required to have a lock or outer-locked container to maintain the sealed source in its shielded position. During radiographic operations the source must automatically be secured in the shielded position each time the source is returned. Radiographers must not attempt to circumvent the automatic securing features or tamper with the safety features of radiographic devices. As shown in Figure 8.8 radiographers must never leave the exposure device at the temporary jobsite without securing it properly from unauthorized removal or tampering. Radiographers and/or radiographers assistants must ensure that the exposure device and/or storage or source containers are maintained locked (and if key locked, with the key removed at all times) when they are not under the direct supervision of the radiographer or the radiographer's assistant, except at permanent radiographic installations. Response from Applicant: Submit operating and emergency procedures that include procedures for locking and securing radiographic equipment. Figure 8.8 Security. To avoid lost or stolen devices, licensees must keep the devices under constant surveillance, or secured against unauthorized use or removal. 8.10.9.5 Personnel Monitoring and the Use of Personnel Monitoring EquipmentRegulations: 10 CFR 34.45(a)(5), 10 CFR 34.47. Criteria: Provide procedures for appropriate use of personnel monitoring equipment. Discussion: As shown in Figure 8.9, all radiographers or radiographers' assistants are required to wear:
Film badges or TLDs must be assigned to and worn by only one individual. To ensure full-scale reading capability, direct reading dosimeters such as pencil (pocket) dosimeters or electronic personal dosimeters must be recharged or reset at the start of each shift so that the dosimeters will be capable of reading the full scale. Personnel should be instructed that direct reading dosimeters must be read and recorded at the beginning and end of each shift. Proper operation of alarm ratemeters must be checked each day before use to ensure that the alarm functions properly. The manufacturer's recommended procedures should be followed. Include instructions about how and where dosimetry devices are to be stored when not in use. The storage place should be dry, radiation free, and cool so that the devices will not be affected by adverse environmental conditions.
All radiographers or radiographers' assistants are required to wear alarm ratemeters except at permanent radiographic facilities where other appropriate alarm or warning devices (e.g., visible and audible alarms) are in routine use and are operable. Figure 8.9 The Well-Dressed Radiographer. The radiographer is equipped with the required personnel monitoring devices and survey instrument. Response from Applicant: The operating procedures must include instructions for proper use of personnel monitoring equipment. 8.10.9.6 Transporting Sealed Sources to Field Locations, Securing Exposure Devices And Storage Containers in Vehicles, Posting Vehicles, And Controlling Sealed Sources During TransportationRegulations: 10 CFR 71.5, 49 CFR Parts 171-178. Criteria: Licensees must develop, implement, and maintain procedures for transporting radioactive material to ensure compliance with DOT regulations. Discussion: Figure 8.10 illustrates some often overlooked DOT requirements. During an inspection, NRC uses the provisions of 10 CFR 71.5 and a Memorandum of Understanding with DOT to examine and enforce transportation requirements applicable to radiography licensees. Appendix N contains 1) a list of major DOT regulations applicable to transporting radiographic devices; 2) a condensed summary of DOT/NRC transportation requirements; and 3) two sample shipping papers, the second of which may be more useful for multiple-use, temporary jobsite activities. Figure 8.10 Transportation. Licensees often transport their radiographic devices to and from sites and must ensure compliance with Department of Transportation regulations. Instructions to personnel should not reference DOT requirements. Information should be extracted, paraphrased and placed into the instructions so that personnel know exactly what they are expected to do. The following items should be covered in instructions to personnel:
Because the licensee may have authorization to possess and use several sealed source/device combinations that are registered by NRC or an Agreement State and meet the safety performance requirements of 10 CFR 34.20, the applicant must, before using a new sealed source/device combination, develop written inspection and maintenance procedures for it and for the corresponding Type B transport package. In addition, the applicant must provide adequate training for radiographic personnel before using a new sealed source/device combination. Note: Before the 1997 revision of 10 CFR Part 34, a licensee who intended to transport a radiographic Type B package was required to submit a quality assurance program to NRC for approval, separate from the license approval. The 1997 revision to 10 CFR Part 34 requires written procedures for inspection and maintenance of radiographic Type B packages (10 CFR 34.31(b)). In conjunction with the revision to 10 CFR Part 34, the NRC also amended 10 CFR 71.101(g) to specifically state that if the applicant's written procedures for inspection and maintenance of radiographic Type B packages are approved, then the applicant also meets NRC quality assurance requirements in Part 71 and does not have to submit or maintain a separate quality assurance program to transport a Type B package. The application's inspection and maintenance procedures for radiographic equipment, which are also used for Type B packages, should ensure that these packages are shipped and maintained in accordance with their COC. Response from Applicant: Submit operating and emergency procedures for transporting sealed sources containing byproduct material, exposure devices, and source changers.
8.10.9.7 Daily Inspection and Maintenance of Radiographic EquipmentRegulations: 10 CFR 34.31, 10 CFR 34.33, 10 CFR 34.45(a)(7), 10 CFR 34.47, 10 CFR 34.73, 10 CFR 34.83. Criteria: The licensee shall perform visual and operability checks before using radiography equipment on each day it is used. Discussion: Visual and operability checks must be performed on radiographic exposure devices, survey meters, associated equipment, and transport and storage containers before use each day the equipment is used. These checks are intended to ensure that the equipment is in good working condition, that the sources are adequately shielded, and that required labeling is present. Licensees must check survey instrument operability using check sources or other appropriate means. The exposure device may be used as a check source. Inspection records shall contain information about equipment problems found in daily checks and quarterly (not to exceed 3 months) maintenance inspections. Records shall include the date of check or inspection, name of inspector, equipment involved, any problems found, and what repair and/or maintenance, if any, was done. Instructions to personnel using radiographic equipment must clearly state that inspections are to be made before the equipment is used each day. While not a requirement, good practice would be that if the equipment is used on more than one shift in the day, the equipment should be inspected before the start of each shift. The procedures should specify the items that are to be checked and the steps that are to be taken if any defects are found. If problems are found, the equipment must be removed from service until it is repaired. A list of items that should be checked in the daily inspection of radiography equipment can be provided by equipment manufacturers. Permanent radiographic installation visible and audible alarms must be checked for operability daily before use, and faulty radiographic equipment must be labeled and repaired within 7 days, with compensatory measures taken in the interim. Compensatory measure taken include:
Appendix O provides example instructions for daily inspection of radiographic devices and equipment. Response from Applicant: Submit operating and emergency procedures for daily inspection and maintenance of radiographic equipment. 8.10.9.8 Ratemeter Alarms or Off-Scale Dosimeter ReadingsRegulations: 10 CFR 34.43(b)(2), 10 CFR 34.45(a)(8), 10 CFR 34.47(d). Criteria: Licensees must instruct personnel in:
Discussion: If an individual's self-reading pocket dosimeter is found to be off scale, an individual's electronic personal dosimeter reads above 2 mSv (200 mrems), or an alarm ratemeter alarms (sounds, etc.) unexpectedly, the RSO or designee must be notified immediately. If radiation exposure cannot be ruled out by the RSO or designee as the root cause, the individual's film badge or TLD must be sent for processing within 24 hours. The affected individual may not resume work with licensed radioactive material until the RSO or designee has determined the individual's radiation exposure. There are no exceptions to this requirement. If any of the events described above should occur, personnel should be instructed to do the following at a minimum:
Response from Applicant: Submit operating and emergency procedures to address ratemeter alarms or off-scale dosimeters. 8.10.9.9 Procedure for Identifying and Reporting Defects and Non-compliance as Required by 10 CFR Part 21Regulations: 10 CFR 21, 10 CFR 30.50, 10 CFR 34.101(a)(3). Criteria: Licensees must notify NRC if defects are found in radiography equipment. Discussion: Equipment defects that could create a substantial safety hazard, or equipment failures involving NRC-regulated activities must be reported to NRC. For example, a failure of a lock box or a failure of the coupling between the source assembly and the control cable are defects that must be reported to NRC. Radiography personnel should be instructed to report any malfunction or defect in radiography equipment to management, so that management can take appropriate action. Response from the Applicant: Submit operating and emergency procedures for notifying management of equipment malfunction or defect.
8.10.9.10 Notification of Proper Persons in the Event of an AccidentRegulations: 10 CFR 30.50, 10 CFR 34. 45(a)(10), 10 CFR 34.101(a), 10 CFR 20.2201, 10 CFR 20.2202, 10 CFR 20.2203. Criteria: Operating and emergency procedures must ensure that appropriate notifications are made during and after an emergency. Discussion: The emergency procedures should clearly identify the names and telephone numbers of the RSO or other persons who can provide assistance in an emergency or accident. Such persons may also include the exposure device manufacturer and state and local agencies. The emergency procedures should always be available to radiography personnel during radiography and must be as up-to-date as possible. NRC regulations also require immediate notification upon the discovery of certain events. Notify NRC when radiographic devices are lost or stolen or if there is indication of overexposure. Refer to the regulations listed above or to Appendix P for additional guidance in the preparation of emergency procedures. Table 8.6 provides a description of events that require notification and/or reports. Table 8.6 Notifications in the Event of an Accident
Note: Telephone notifications shall be made to the NRC Operations Center at 301- 816-5100 except as noted. The Center is staffed 24 hours a day and accepts collect calls. NRC notification is required when licensed materials are lost or stolen or involved in an incident that may have resulted in doses in excess of NRC limits. Response from Applicant: Submit operating and emergency procedures that include appropriate instructions for notifying the RSO and/or other personnel in the event of an emergency. 8.10.9.11 Minimizing Exposure of Persons in the Event of an AccidentEmergency ProceduresRegulations: 10 CFR 34.45(a)(11). Criteria: To maintain exposures as low as possible in the event of an emergency Discussion: An emergency situation is considered to exist whenever an abnormal event occurs and/or the source has failed to return to the safe position. Since it is not possible to specify all possible situations that would constitute an emergency, a general instruction is acceptable as shown in Figure 8.11. This general instruction should describe licensee actions to maintain the dose at a minimal level after an abnormal event is identified. The instruction should include routine emergency actions such as posting the restricted area, maintaining surveillance of the restricted area, and notifying the RSO. Figure 8.11 Emergency Procedures. These steps provide guidance in an emergency. Appendix P provides an example of a routine Emergency Procedure. Response from Applicant: Submit operating and emergency procedures that include instructions for minimizing exposure of persons in the event of an accident. 8.10.9.12 Source RetrievalRegulations: 10 CFR 34.45(a)(12), 10 CFR 34.101(a), 10 CFR 34.101(b). Criteria: Each licensee who intends to perform source retrieval operations must have appropriate equipment, training, and procedures. Discussion: Applicants must develop source retrieval procedures if their own radiographic personnel with appropriate training and experience will conduct source retrievals. If procedures are submitted, the NRC will review and approve applicants to perform source retrieval. If source retrieval procedures are not submitted for review, then source retrieval activities must be conducted by an NRC or Agreement State licensee whose license specifically authorizes these activities.
NRC will review the applicant's procedures for source retrieval with respect to keeping exposures ALARA and controlling exposures to radiation. Since it is not possible to specify all potential exposure situations, a general procedure is acceptable. A retrieval procedure should contain the following elements:
Response from Applicant:
OR
8.10.9.13 Maintenance of RecordsRegulations: 10 CFR 34.45(a)(13), 10 CFR 34.47, 10 CFR 34.71, 10 CFR 34.73, 10 CFR 34.85, 10 CFR 34.87, 10 CFR 34.89. Criteria: The licensee shall meet NRC record requirements. Discussion: Personnel must generate and maintain certain records when performing radiography, including:
Other operations that may require records include quarterly (not to exceed 3 months) inspection and maintenance, instrument calibration, shipment of packages, etc. Radiography personnel should also be aware of the records that must be maintained at temporary jobsites. Radiographers performing radiographic duties should be given specific instructions for recordkeeping. These should not include instructions about records that are the responsibility of management and supervision. Response from the Applicant: Submit operating and emergency procedures which ensure proper maintenance of records. 8.11 Item 11: Waste Management
[ Prev | Next | Top of file ] 8.11.1 Disposal or Transfer of Radiography Sealed Sources Containing Byproduct Material or Devices Containing Depleted UraniumRegulations: 10 CFR 20.2001, 10 CFR 30.41, 10 CFR 30.51. Criteria: Licensed materials must be disposed of in accordance with NRC requirements by transfer to an authorized recipient. Appropriate records must be maintained. Discussion: Licensees who dispose of radiography sealed sources containing byproduct material, or dispose of radiography devices containing depleted uranium, must transfer them to an authorized recipient. Recipients authorized to accept radioactive waste from other persons, or another specific licensee authorized to possess the licensed material, i.e., whose license specifically authorizes the radionuclide and its use are the original manufacturer of the device, or a commercial firm licensed by the NRC or an Agreement State. Before transferring radioactive material, a licensee must use one of the methods described in 10 CFR 30.41 to verify that the recipient is properly authorized to receive it . In addition, all packages containing radioactive sources must be prepared and shipped in accordance with NRC and DOT regulations. Records of the transfer must be maintained as required by 10 CFR 30.51. Response from Applicant: The applicant does not need to provide a response to this item during the licensing process. However, the applicant should establish and include waste disposal procedures in its radiation safety program.
8.12 Item 12: License Fees
[ Prev | Next | Top of file ] On NRC Form 313, enter the fee category and the amount of the fee enclosed with the application. 8.13 Item 13: Certification
[ Prev | Next | Top of file ] Individuals acting in a private capacity are required to date and sign NRC Form 313. Otherwise, representatives of the corporation or legal entity filing the application should date and sign NRC Form 313. Representatives signing an application must be authorized to make binding commitments and to sign official documents on behalf of the applicant. As discussed previously in "Management Responsibility," signing the application acknowledges management's commitment and responsibilities for the radiation protection program. NRC will return all unsigned applications for proper signature. Note:
9 Amendments and Renewals to a License
[ Prev | Next | Top of file ] It is the licensee's obligation to keep the license current. If any of the information in the original application changes, the licensee must submit an application for a license amendment to reflect the change before the change takes place. Also, to continue a license after its expiration date, the licensee must submit an application for license renewal at least 30 days before the expiration date (10 CFR 2.109, 10 CFR 30.36(a)). Applications for license amendment, in addition to the following, must include the appropriate fee. For renewal and amendment requests, applicants must do the following:
10 Applications for Exemptions
[ Prev | Next | Top of file ] Various sections of NRC's regulations address requests for exemptions (e.g., 10 CFR 19.31, 10 CFR 20.2301, 10 CFR 30.11(a), 10 CFR 34.111)). These regulations state that NRC may grant an exemption, acting on its own initiative or on an application from an interested person. Key considerations are whether the exemption is authorized by law, will endanger life or property or the common defense and security, and is otherwise in the public interest.
Exemptions are not intended to revise regulations, are not intended for large classes of licenses, and are generally limited to unique situations and are reviewed on a case-by-case basis. Exemption requests must be accompanied by descriptions of the following:
11 Termination of Activities
[ Prev | Next | Top of file ] When terminating licensed activities, pursuant to 10 CFR 30.34(b), 10 CFR 30.35(g), 10 CFR 30.36(d) and (j), and 10 CFR 30.51(f), licensees must do the following:
OR
Appendix A: List of Documents Considered in Development of this NUREG
[ Prev | Next | Top of file ] Regulatory Guides (RGs) and Policy and Guidance Directives (PGs)
[ Prev | Next | Top of file ] (*) Marked items are superseded and are not to be used.
Information Notices (INs)
[ Prev | Next | Top of file ] (*) Marked items are superseded and are not to be used.
Technical Assistance Requests (TARS)
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Appendix B: United States Nuclear Regulatory Commission Form 313
[ Prev | Next | Top of file ] United States Nuclear Regulatory Commission Form 313 Appendix C: Suggested Format for Providing Information Requested in Items 5 through 11 of NRC Form 313
[ Prev | Next | Top of file ] Suggested Format for Providing Information Requested in Items 5 through 11 of NRC Form 313
Appendix D: Sample Radiography License
[ Prev | Next | Top of file ] Sample Radiography License This appendix contains an example of a radiography license that the NRC would issue to an applicant who meets the requirements in the 1997 revision to 10 CFR 34. The sample license includes a matrix of many currently approved source assemblies, exposure devices, and source changers; however, actual licenses should only include the specific items requested by the applicant. The following are descriptions of individual items or conditions as provided in the license:
Note: The authorizations in the sample license do not necessary reflect those normally provided to an applicant. For example, the authorization for source retrieval and leak testing require the applicant to have specific procedures approved by the NRC. Form 374 - Sample Radiography License
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Appendix E: Information Needed for Transfer of Control Application
[ Prev | Next | Top of file ] Information Needed for Transfer of Control Application Licensees must provide full information and obtain NRC's prior written consent before transferring control of the license; some licensees refer to this as "transferring the license." Provide the following information concerning changes of control by the applicant (transferor and/or transferee, as appropriate). If any items are not applicable, so state.
Appendix F: Information Notice 96-20, "Demonstration of Associated Equipment Compliance with 10 CFR 34.20"
[ Prev | Next | Top of file ] Information Notice 96-20, "Demonstration of Associated Equipment Compliance with 10 CFR 34.20"
[ Prev | Next | Top of file ] UNITED STATES April 4, 1996 NRC INFORMATION NOTICE 96-20: DEMONSTRATION OF ASSOCIATED EQUIPMENT COMPLIANCE WITH 10 CFR 34.20 Addressees All industrial radiography licensees and radiography equipment manufacturers. Purpose The U.S. Nuclear Regulatory Commission is issuing this information notice to inform radiography licensees of acceptable methods to demonstrate that their associated equipment used in radiographic operations meets the regulations in 10 CFR 34.20. It is expected that recipients will review the information for applicability to their facilities and consider appropriate actions. However, this information notice does not contain any new requirements; therefore, no specific action nor written response is required. Description of Circumstances Section 34.20 of 10 CFR Part 34 specifies performance requirements for radiography equipment. Paragraph (d) of 10 CFR 34.20 provided that all newly manufactured radiographic exposure devices and associated equipment (manufactured after January 10, 1992) acquired by NRC licensees must meet Section 34.20 requirements. Paragraph (e) of 10 CFR 34.20 provides that all radiographic exposure devices and associated equipment in use by NRC licensees after January 10, 1996, must comply with the requirements specified in 10 CFR 34.20. NRC amended the regulations in 10 CFR 34.20 to permit licensees to use an alternate value of torque for performance testing criteria and to allow licensees to use engineering analysis to demonstrate that a modest change in an already approved design is acceptable without the need to perform prototype testing. The changes were published in the Federal Register as a final rule on May 31,1995. NRC Information Notice (IN) 95-58: "10 CFR 34.20; Final Effective Date," issued on December 18, 1995, to all radiography licensees, reminded licensees of the final effective date implementing the regulations in 10 CFR 34.20. IN 95-58 also reminded licensees that associated equipment used with radiography cameras (i.e., source assemblies, drive cables, guide tubes, control tubes, source stops, etc.) were subject to 10 CFR 34.20 requirements. IN 95-58 went on to explain that, previously, certain associated equipment had not been independently registered and/or evaluated by the NRC or the Agreement States (AS). This includes drive cables, guide tubes, and source stops. Most new camera models and their basic associated equipment were registered as part of the gamma radiography system as described in the American National Standard N432-1980, "Radiological Safety for the Design and Construction of Apparatus for Gamma Radiography." Therefore, information concerning certain associated equipment to be used with the devices was included as part of the overall system evaluation and registration process. Some manufacturers have also been labeling their equipment with an identifier, such as the manufacturer's logo, to indicate that the equipment meets the requirements of 10 CFR 34.20. IN 95-58 went on to remind licensees that 10 CFR 34.20 makes the licensee responsible for ensuring that equipment meets regulatory requirements. NRC and AS review and evaluate radiography-associated equipment (guide tubes, exposure heads, and collimators) as well as sealed sources, radiographic exposure devices (cameras) and source changers for compliance with 10 CFR Part 34. On completion of this evaluation, acceptable components are identified on a registration certificate. Information is also included in a National Registry System maintained by NRC. Regulatory authorities use this information in their licensing and inspection activities. Discussion The regulation on performance requirements for radiography equipment--Section 34.20--requires that the radiographic exposure device and all associated equipment must meet the requirements of ANSI N432-1980, and other specific requirements listed in 10 CFR 34.20. Associated equipment includes source assemblies, drive cables, guide tubes, control tubes, cranks, "J" tubes, collimators, exposure heads, and source stops. In particular for guide tubes, 10 CFR 34.20(c)(5) states, "The guide tube must have passed the crushing tests for the control tube as specified in ANSI N432 and a kinking resistance test that closely approximates the kinking forces likely to be encountered during use." In addition, 10 CFR 34.20(c)(8) requires that the connection between the guide tube and exposure head be able to withstand the tensile test for control units specified in ANSI N432. Since Section 8.9 of ANSI N432-1980 specifies that radiography systems must withstand the endurance test described in that section, licensees must demonstrate that guide tubes and exposure heads will withstand the endurance test. Recently some questions were raised concerning what constitutes an exposure head vs. a guide tube. Exposure heads may be a separate or integral part of a guide tube. NRC's analysis of associated equipment (i.e., collimators, guide tubes, exposure heads) has shown that there is little risk of obstruction of source travel for equipment that guides a source assembly a distance less than 10 times the length of the source capsule. NRC's analysis included a review of equipment designs and incidents involving source travel obstructions. Based on these findings, NRC's policy is that associated equipment that guides a source assembly a distance greater than 10 times the length of the source capsule (i.e., exposure heads, "J" tubes, jet engine probes, source stops) is considered a guide tube and must meet the testing requirements for guide tubes. In addition, NRC's policy is that only associated equipment that comes in contact with the source (e.g., collimators that slip over the end stop) must meet the applicable testing requirements. The NRC has identified several ways licensees can demonstrate that their radiography equipment meets 10 CFR 34.20 requirements. First, the most direct method would be that the equipment that has been labeled by the manufacturer pursuant to a registration certificate. (If the label has worn off, you should contact the manufacturer or have support information as described below.) Alternatively, licensees can make this demonstration if they can provide a document trail to registered associated equipment. The equipment will be considered to meet the requirements, if the licensee has in its possession one of the following for each piece of equipment:
If a licensee possesses and intends to use radiography equipment that is not labeled by the manufacturer, or that the licensee cannot demonstrate that it meets 10 CFR 34.20 requirements, then the licensee must submit an application for a custom evaluation. Attachment 2 includes information on how to file an application for custom evaluation. Equipment cannot be used in radiographic operations until it has been approved for use by NRC or an AS. This information notice requires no specific action nor written response. If you have any questions about the information in this notice, please contact the technical contact listed below or the appropriate regional office. Signed by _________________________________________ Attachments: 1. Recognized Checklist for Associated Equipment
Attachment 1: Recognized Checklist for Associated Equipment
[ Prev | Next | Top of file ] IN 96-20 Checklist for Amersham's Model 591 ControlsTo assure the associated equipment you are using are approved Amersham-manufactured accessories, please perform a side-by-side comparison against a known (i.e., flying A is legible or POs are available) Amersham-manufactured piece. Perform a detailed mechanical and visual inspection of your equipment against the following checklist. If you have any questions, please call Amersham for assistance. Amersham Controls:
To the best of my knowledge the piece of equipment identified below (the equipment must be uniquely identifiable, either by labeling, marking, or tagging, or other means to signify which piece of equipment is certified as meeting the conditions of this checklist) has been manufactured after 1964, meets the conditions of this checklist, and is the same design as a similar piece of equipment that has been registered and approved by the NRC.
Attachment 1 Amersham Model 402, 489, and 676 Guide TubesTo assure the associated equipment you are using are approved Amersham-manufactured accessories, please perform a side by side comparison against a known (i.e., flying A is legible or POs are available) Amersham-manufactured piece. Perform a detailed mechanical and visual inspection of your equipment against the following checklist. If you have any questions, please call Amersham for assistance. Amersham Guide Tubes:
To the best of my knowledge the piece of equipment identified below (the equipment must be uniquely identifiable, either by labeling, marking, or tagging, or other means to signify which piece of equipment is certified as meeting the conditions of this checklist) has been manufactured after 1964, meets the conditions of this checklist, and is the same design as a similar piece of equipment that has been registered and approved by the NRC.
Attachment 2: Custom Evaluation of Associated Equipment
[ Prev | Next | Top of file ] IN 96-20 Custom Evaluation of Associated EquipmentThe information provided below applies to custom registration of associated equipment. Product RegistrationEither the manufacturer, distributor, or user of the radiographic equipment can submit the information outlined in 10 CFR 32.210 for evaluation. If the applicant is located within the jurisdiction of the U.S. Nuclear Regulatory Commission, the application should be sent to the following address:
Otherwise, the applicant should submit the information to the appropriate Agreement State. Application ContentsGeneral: Licensees are required to use only radiography equipment, including exposure heads and source guide tubes, that meets the requirements specified in 10 CFR 34.20. The regulations require that the exposure device and all associated equipment must meet the requirements in American National Standard N432-1980, "Radiological Safety for the Design and Construction of Apparatus for Gamma Radiography," and other specific requirements listed in 10 CFR 34.20. The standard defines the requirements for the design and method of qualifying (testing) prototypes of gamma radiography systems. Refer to Regulatory Guide 10.10, "Guide for the Preparation of Applications for Radiation Safety Evaluation and Registration of Devices Containing Byproduct Material" for information on what types of information needs to be included in your application. Attachment 2 Specific: Applications for registration for the equipment must, at a minimum, include the following documentation:
Prototype TestsEach associated equipment design (e.g., source guide tube, collimator, exposure head) must either pass the appropriate tests listed below, or demonstrate by engineering analysis that the designs would likely meet the test requirements. NRC's policy is that associated equipment that guides a source assembly a distance greater than 10 times the length of the source capsule (i.e., exposure heads, "J" tubes, jet engine probes, source stops) is considered a guide tube and must meet the testing requirements for guide tubes. Source Guide Tube TestsSource guide tubes are required to meet the following:
Attachment 2 Exposure Head and Collimator TestsExposure heads and collimators that are not considered guide tubes, need only meet the tests listed in item c, and d above. Engineering AnalysisEngineering analysis will be considered in lieu of actual testing if the analysis is based on a similar design that has been tested in accordance with the standard and has been approved by the NRC or Agreement State. The engineering analysis, at a minimum, must compare the tested design against the associated equipment you want evaluated and address the effects of the materials of construction (i.e., wear resistance, strength, corrosion properties); the wall thickness; the length (i.e., resistance); any bends, bend angles and the minimum bend radii over which the bends will be produced (curvature); and any other properties that would have an effect on the outcome of the endurance test. Appendix G: Radiographer and Assistant Radiographer Training
[ Prev | Next | Top of file ] Radiographer and Assistant Radiographer Training Table G.1 10 CFR Part 34 Radiographer and Assistant Radiographer Training Requirements
Appendix H: Six-Month Radiographer/Radiographer's Assistant Inspection Checklist
[ Prev | Next | Top of file ] Six-Month Radiographer/Radiographer's Assistant Inspection Checklist Date: __________ Time: ________ Radiographic Location: ________ Radiographer/Radiographer Assistant:________ Device Model No.: ________ Serial No.: ________ Survey Meter Functionality: Yes ________ No ________ Calibrated: Yes _______ No _______ Daily/Source For Operation: Yes _______ No ________ Dosimetry: TLD/Film Badge Pocket/Dosimeter: Yes ________ No _________ Calibrated: Yes ________ No ________ Alarming Dosimeter: Yes ________ No ________ Calibrated Yes ________ No ________
Remarks: Appendix I: Radiation Safety Program Audit
[ Prev | Next | Top of file ] Radiation Safety Program Audit Annual Radiation Protection Industrial Radiography Audit
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Note: Except where noted, references are to Title 10, Code of Federal Regulations (10 CFR) Organization and Scope of Program
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Training, Retraining, and Instructions to Workers
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Operating and Emergency Procedures
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Internal Audits or Inspections
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Facilities
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Equipment
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Materials
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Instrumentation
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Radiation Surveys
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Personnel Radiation Protection
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Receipt and Transfer of Radioactive Material
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Transportation (10 CFR 71.5(a) and 49 CFR 170-189)
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Auditor's Independent Measurements
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Notifications and Reports
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Posting and Labeling
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Recordkeeping for Decommissioning
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Bulletins and Information Notices
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Special License Conditions or Issues
[ Prev | Next | Top of file ] Evaluate special license conditions for data, actions Performance Evaluation Factors
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Appendix J: Model Procedure for Calibrating Survey Instruments
[ Prev | Next | Top of file ] Model Procedure for Calibrating Survey Instruments
Draft Regulatory Guide FC 413-4, "Guide for the Preparation of Applications for Licenses for the Use of Radioactive Materials in Calibrating Radiation Survey and Monitoring Instruments," is available from NRC's Regional Offices, whose addresses are listed in Section 2, "Filing an Application." Appendix K: Requests to Perform Leak Testing and Sample Analysis
[ Prev | Next | Top of file ] Requests to Perform Leak Testing and Sample Analysis
Note: An instrument capable of making quantitative measurements should be used; hand-held survey meters will not normally be considered adequate for measurements.
Note: Accuracy of standards should be within �5% of the stated value and traceable to a primary radiation standard such as those maintained by the National Institutes of Standards and Technology (NIST). Draft Regulatory Guide FC 412-4, "Guide for the Preparation of Applications for the Use of Radioactive Materials in Leak-Testing Services," is available from NRC upon request.
Note: As an ALARA and safety measure, the source should be transferred to a source changer before the S-tube is tested for breakthrough. The wipe test sample should be obtained from the areas of the tube where wear is likely to be most severe, at the first curve nearest the ends of the radiography device. The sample should be analyzed for alpha contamination. Alpha contamination present indicates that wear has broken through the S-tube to expose the depleted uranium. Alpha counting sensitivity should be able to detect 185 Bq (0.005 microcuries) of contamination. A worn S-tube could create equipment operating difficulties. Upon verification of the presence of alpha-particle emitting uranium, the radiographic exposure device should be removed from use until an evaluation of the wear of the S-tube has been made. Should the evaluation reveal that the S-tube is worn through, the device may not be used again. No user repairs are permitted. Appendix L: Guidance for Demonstrating That Individual Members of the Public Will Not Receive Doses Exceeding the Allowable Limits
[ Prev | Next | Top of file ] Guidance for Demonstrating That Individual Members of the Public Will Not Receive Doses Exceeding the Allowable Limits Licensees must ensure that:
Calculational Method
[ Prev | Next | Top of file ] For ease of use by most industrial radiography licensees, the examples in this Appendix use conventional units. The conversions to SI units are as follows: 1 foot (ft) = 0.305 meter (m); 1 mrem = 0.01 mSv. The calculational method takes a tiered approach, going through a three-part process starting with a worst case situation and moving toward more realistic situations. It makes the following simplifications: (1) each device is a point source, (2) typical radiation levels encountered when the source is in the shielded position are taken from either the Sealed Source & Device (SSD) Registration Sheet, the maximum dose levels allowed for a transport package (exposure device) labeled YELLOW III, or the manufacturer's literature, and (3) no credit is taken for any shielding found between the devices and the unrestricted areas. Part 1 of the calculational method is simple but conservative. It assumes that a member of the public is present 24 hours a day, and it uses only the inverse square law to determine if the distance between the device and the affected member of the public is sufficient to show compliance with the public dose limits. Part 2 considers not only distance, but also the time that a member of the public is actually in the area under consideration. Part 3 considers distance and the portion of time that both the device and the affected member of the public are present. Part 4 considers the distance, the portion of time that both the device and the affected member of the public are present and the shielding provided by the structural materials or shielding materials specifically added by the licensee. Using this approach, licensees make only those calculations that are needed to demonstrate compliance. In many cases, licensees will need to use the calculational method through Part 1 or Part 2. These calculations typically result in higher radiation levels than would exist at typical facilities, but provide a method for estimating conservative doses which could be received. Example 1
[ Prev | Next | Top of file ] To better understand the calculational method, Mo-Rad, Inc., a hypothetical radiography licensee, is demonstrated. Yesterday, the company's president noted that the new device storage area is close to his secretary's desk and he asked Joe, the Radiation Safety Officer (RSO), to determine if the company is complying with NRC's regulations. The secretary's desk is near the wall separating the reception area from the designated, locked device storage area, where the company is storing its two devices. Joe measures the distances from each device to the wall and assumes that each device would have the maximum dose rate allowed under NRC or DOT regulations: 2 mSv/hr (200 mrem/hr) on the surface and 0.1 mSv/hr (10 mrem/hr) at one meter. Figure M.1 is Joe's sketch of the areas in question, and Table M.1 summarizes the information Joe has on each device. Figure L.1 Diagram of Office and Device Storage Area. This sketch shows the areas described in Examples 1 and 2. Table L.1 Information Known about Each Device
Example 1: Part 1Joe's first thought is that the distance between the devices and the secretary's chair may be sufficient to show compliance with the regulation in 10 CFR 20.1301. So, taking a worst case approach, he assumes: 1) the devices are constantly present (i.e., 24 hr/d), 2) both devices remain in storage with no other use, and 3) the secretary is constantly sitting in the desk chair (i.e., 24 hr/d). Joe proceeds to calculate the dose she might receive hourly and yearly from each device, as shown in Tables M.2, and M.3 below. Table L.2 Calculational Method, Part 1: Hourly and Annual Dose Received from Device 1
Table L.3 Calculational Method, Part 1: Hourly and Annual Dose Received from Device 2
To determine the total hourly and total annual dose received, Joe adds the pertinent data from the preceding tables. Table L.4 Calculational Method, Part 1: Total Hourly and Annual Dose Received from Devices 1 and 2
Note: The Sum in Step 7 demonstrates compliance with the limit of 2 mrem in any one hour. Reevaluate if assumptions change. If the Sum in Step 8 exceeds 100 mrem/yr, proceed to Part 2 of the calculational method. At this point, Joe is pleased to see that the total dose that an individual could receive in any one hour is only 1.1 mrem in an hour, but notes that an individual could receive a dose of 9,580 mrem in a year, much higher than the 100 mrem limit. Example 1: Part 2Joe reviews his assumptions and recognizes that the secretary is not at the desk 24 hr/d. He decides to make a realistic estimate of the number of hours the secretary sits in the chair at the desk, keeping his other assumptions constant (i.e., the devices are constantly present (i.e., 24 hr/d), both devices remain in storage with no other use). He then recalculates the annual dose received. Table L.5 Calculational Method, Part 2: Annual Dose Received from Devices 1 and 2
Note: If Step 11 exceeds 100 mrem in a year, proceed to Part 3 of the calculational method. Although Joe is pleased to note that the calculated annual dose received is significantly lower, he realizes it still exceeds the 100 mrem in a year limit. Example 1, Part 3Again Joe reviews his assumptions and recognizes that the devices are not always in storage when the secretary is seated at the desk. As he examines the situation, he realizes he must consider each device individually. Table L.6 Calculational Method, Part 3: Summary of Information
Table L.7 Calculational Method, Part 3: Annual Dose Received from Devices 1 and 2
Note: If the result in Step 17 is greater than 100 mrem/yr, the licensee must take corrective actions. Joe notes that the result in Step 17 does not show compliance with the 100 mrem/yr limit. Since the result in Step 17 is higher than 100 mrem/yr, then Joe has to consider one or more of the following: Consider whether the assumptions used to determine occupancy and the time each device is in storage are accurate, revise the assumptions as needed, and recalculate using the new assumptions. Calculate the effect of any shielding located between the device storage area and the secretarial workstation. Listed below are typical half-value layers (HVL) for Ir-192 and Co-60. Table L.8 Half Value Layers (HVL) for Typical Shielding Materials
Take corrective action (e.g., move devices within storage area, move the storage area, move the secretarial workstation) and perform new calculations to demonstrate compliance Designate the area outside the storage area as a restricted area and the secretary as an occupationally exposed individual. This would require controlling access to the area for purposes of radiation protection and training the secretary as required by 10 CFR 19.12. Example 1, Part 4Joe decides to take into account the amount of shielding provided by the wall between the secretary's desk and the storage area where the two devices are located. The wall between the secretary's office and the storage area is a 4 inch thick concrete fire wall. Table L.9 Calculational Method, Part 4: Annual Dose Received from Devices 1 and 2
Note: If the result in Step 22 is greater than 100 mrem/yr, the licensee must take corrective actions. Joe is glad to see that the results in Step 22 show compliance with the 100 mrem in a calendar year limit. Note that in the example, Joe evaluated the unrestricted area outside only one wall of the device storage area. Licensees also need to make similar evaluations for other unrestricted areas and to keep in mind the ALARA principle, taking reasonable steps to keep radiation dose received below regulatory requirements. In addition, licensees need to be alert to changes in situations (e.g., moving any of the devices closer to the secretarial workstation, adding a device to the storage area, changing the secretary to a full-time worker, or changing the estimate of the portion of time spent at the desk) and to perform additional evaluations, as needed.
Combination Measurement - Calculational MethodThis method, which allows the licensee to take credit for shielding between the device and the area in question, begins by measuring radiation levels in the areas, as opposed to using manufacturer-supplied rates at a specified distance from each device. These measurements must be made with calibrated survey meters sufficiently sensitive to measure background levels of radiation. However, licensees must exercise caution when making measurements with currently calibrated radiation survey instruments. A maximum dose of 1 mSv (100 mrem) received by an individual over an interval of 2080 hours (i.e., a work year of 40 hr/wk for 52 wk/yr) is equal to less than 0.5 microsievert (0.05 mrem) per hour.
Instruments used to make measurements for calculations must be sufficiently sensitive. An instrument equipped with a scintillation-type detector (e.g., NaI(Tl)) or a micro-R meter used in making very low gamma radiation measurements should be adequate. Licensees may also choose to use environmental TLDs. TLDs used for personnel monitoring (e.g., LiF) may not have sufficient sensitivity for this purpose. Generally, the minimum reportable dose received is 0.1 mSv (10 mrem). Suppose a TLD monitors dose received and is changed once a month. If the measurements are at the minimum reportable level, the annual dose received could have been about 1.2 mSv (120 mrem), a value in excess of the 1 mSv/yr (100 mrem/yr) limit. If licensees use TLDs to evaluate compliance with the public dose limits, they should consult with their TLD supplier and choose more sensitive TLDs, such as those containing CaF2 that are used for environmental monitoring. in unrestricted areas next to the device storage area for monitoring. This direct measurement method would provide a definitive measurement of actual radiation levels in unrestricted areas without any restrictive assumptions. Records of these measurements can then be evaluated to ensure that rates in unrestricted areas do not exceed the 1 mSv/yr (100 mrem/yr) limit. Example 2
[ Prev | Next | Top of file ] As in Example 1, Joe is the RSO for Mo-Rad, Inc., a radiography licensee. The company has two devices stored in a designated, locked storage area that adjoins an unrestricted area where a secretarial work station is located. See Figure M.1 and Table M.1 for information. Joe wants to see if the company complies with the public dose limits at the secretarial station. During the winter while all the devices were in storage, Joe placed an environmental TLD badge in the secretarial work space for 30 days. Joe chose a winter month so he did not have to keep track of the number of hours that each device was in the storage area. The TLD processor sent Joe a report indicating the TLD received 100 mrem. Parts 2 and 3 are the calculated the same as Example 1. Table L.10 Combination Measurement - Calculational Method
Note: For the conditions described above, Step 3 indicates that the dose received in any one hour is less than the 2 mrem in any one hour limit. However, if there are any changes, then the licensee would need to reevaluate the potential doses which could be received in any one hour. Step 4 indicates that the annual dose received would be much greater than the 100 mrem in a year allowed by the regulations. In Step 2, Joe can adjust for a realistic estimate of the time the secretary spends in the area as he did in Part 2 of Example 1. If the results of Joe's evaluation in Part 2 show that the annual dose received in a year exceeds 100 mrem, then he can make adjustments for realistic estimates of the time spent in the area of concern while the devices are actually in storage as in Part 3 of Example 1. (Recall that the TLD measurement was made while all the devices were in storage -- i.e., 24 hr/d for the 30 days that the TLD was in place.) Appendix M: Information for Applicants to Consider When Developing Procedures for Operating Radiography Equipment
[ Prev | Next | Top of file ] Information for Applicants to Consider When Developing Procedures for Operating Radiography Equipment Crank-out Device
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Pipeliner Device
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Note: The NRC considers the following very important: surveys of the restricted area, continuous surveillance of the restricted area during an exposure, the survey of the device and guide tube, and locking the device. Source Exchange
[ Prev | Next | Top of file ] Removing the Old Source
Installing the New Source
Appendix N: Transportation
[ Prev | Next | Top of file ] Transportation The following are the major areas in DOT regulations most relevant for transporting radiographic exposure devices and source exchangers that are shipped as Type B quantities are:
Appendix O: Daily Maintenance Check of Radiographic Equipment
[ Prev | Next | Top of file ] Daily Maintenance Check of Radiographic Equipment The radiographer or radiographer assistant shall perform a daily maintenance check of the exposure device and related radiographic equipment. This inspection will be performed before using the equipment on each day the equipment is to be used. Report defective equipment to the RSO immediately. Do not attempt to use defective equipment. After the inspection, document the results of the inspection.
Note: RSO or calibration vendor should determine the acceptable meter reading for each survey meter and post the expected reading on each instrument. This reading shall be obtained and noted at the time of calibration.
Appendix P: Suggested Example of a Routine Emergency Procedure
[ Prev | Next | Top of file ] Suggested Example of a Routine Emergency Procedure Emergency Procedure
[ Prev | Next | Top of file ] If the source fails to return to the shielded position or if any other emergency or unusual situation arises (e.g., vehicle accident, off-scale dosimeter, etc.)
Follow the directions provided by the person contacted above. RSO and Licensee Management
[ Prev | Next | Top of file ] Discuss emergency operating procedures, and ensure no operations are conducted until the situation has been discussed with and approved by the RSO or other knowledgeable staff, consultants, or device manufacture. Management should have access to emergency equipment to keep doses to radiographers as low as reasonably achievable. Emergency equipment may include high range dosimeters, extra lead shielding, remote tongs, etc. Notify local authorities as well as the NRC as required. (Even if notification is not required, ANY incident may be reported to NRC by calling NRC's Emergency Operations Center at (301) 816-5100, which is staffed 24 hours a day and accepts collect calls.) NRC notification is required when sources or devices containing licensed material are lost or stolen and when radiographic sources or equipment are involved in incidents that may have cause or threatens to cause an exposure in excess of 10 CFR 20.2202 limits. Reports to the NRC must be made within the reporting time frames specified by the regulations. Notification and reporting requirements are found in 10 CFR 20.2201-2203, 10 CFR Part 21.21, 10 CFR 34.101, and 10 CFR 30.50. Appendix Q: Summary of Comments Received on Draft NUREG-1556, Vol. 2
[ Prev | Top of file ] Summary of Comments Received on Draft NUREG-1556, Vol. 2 On September 17, 1997, NRC announced in the Federal Register (62 FR 48904) that draft NUREG-1556, Vol. 2 was available for comment. NRC requested that comments be submitted by November 17, 1997. NRC also mailed copies of the document to its radiography licensees. NRC received three comments, two from licensees and the other from an industry consultant. The comments, two letters and an e-mail message, are available for inspection in NRC's Public Document Room. LettersIssue 1: The writer objects to the new provision in 10 CFR 34.43(a), which requires individuals acting as radiographers to be certified by a certifying entity. The writer believes that licensees with good radiation safety program should be allowed to certify their radiographers. Response to Issue 1: This comment is outside the scope of NUREG-1556, Vol. 2, similar comments were considered as part of the rule making process when Part 34 was revised. Issue 2: The writer objects to the new provision in 10 CFR 34.41(a), which requires at least two individuals to be present, both of whom must be observing the operations, whenever radiography is performed at a location other than a permanent radiographic installation. The writer believes that, in some instances, it should be acceptable to "assign the other individual to work in the darkroom to process film." Response to Issue 2: This comment is outside the scope of NUREG-1556, Vol. 2, similar comments were considered as part of the rule making process when Part 34 was revised. Issue 3: The writer refers to the appendix concerning transportation and questions the need for certain Department of Transportation requirements related to shipping papers and package labeling. Response to Issue 3: This comment is outside the scope of NUREG-1556, Vol. 2. Issue 4: The writer suggests that section 8.32, Item 10, "Maintenance of records" needs to make clearer which records need to be maintained or be available at field stations and temporary jobsites and, in some instances, what constitutes an acceptable record. Response to Issue 4: The writer appears to have misunderstood the purpose of this section of the guide. This section provides further information to licensees on developing operating procedures which provide radiography personnel with specific guidance on the records the workers will generate when conducting radiographic operations. The records that workers might be expected to generate are already clearly identified in this section or in 10 CFR Part 34. E-Mail MessagesIssue 1: The writer noted the need for a correction in Item 10, "Transportation" which indicated that when a vehicle is placarded, the exterior surfaces and passenger compartment must be surveyed to ensure radiation levels do not exceed 2 mrem/hr. The writer pointed out that there is no such regulatory requirement except under exclusive use requirements. Response to Issue 1: The section was revised to reflect this correction. Issue 2: The writer noted that Sample 2 of Appendix N was incorrect in stating "Exclusive Use" on the sample form. Response to Issue 2: The sample form was revised to reflect this correction. Issue 3: The writer had several comments concerning corrections to the content of Appendix N, pages N-3 and N-8. Response to Issue 3: These pages of Appendix N are copies of previously published documents and can not be modified at this time. However, the writer's comments will be considered when the documents are next revised and updated. Summary of Other ChangesThe writing team made other changes to the text in addition to those discussed above. These changes encompass the following:
[ Top of file ] 1. Facilities may or may not have a roof. Applicants are required to explain how these areas around the installation will be controlled to keep exposures to appropriate levels. |
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