Information Notice 1991-49, Enforcement of Safety Requirements for Radiographers
&
-
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
WASHINGTON, D.C.
20555
1
August 15, 1991
NRC INFORMATION NOTICE NO. 91-49:
ENFORCEMENT OF SAFETY REQUIREMENTS
FOR RADIOGRAPHERS
Addressees
All Nuclear Regulatory Commission (NRC) licensees authorized to use sealed
sources for industrial radiography.
Purpose
This information notice is being issued to alert licensees to new safety
requirements, to remind licensees to perform required radiation safety surveys, and to describe related changes to NRC's Enforcement Policy. New rules went
into effect on January 10, 1991, that, among other items:
(a) require
radiographers to wear audible alarm ratemeters, in addition to using survey
meters; (b) provide for new reporting requirements; and (c) specify performance
requirements for radiography equipment. It is expected that licensees will
review this notice, distribute it to responsible staff, and consider actions, as appropriate, to ensure compliance with NRC requirements. Suggestions
contained in this information notice do not constitute any new NRC
requirements. However, you are responsible for ensuring that radiographic
operations are performed in a safe manner, in accordance with license
conditions and NRC regulations.
No written response to this information notice
is required.
Background
On January 10, 1990, NRC published a final rule in the Federal Register
(55 FR 843), establishing additional safety requirements for industrial
radiography equipment (see Attachment 1).
The rule requires use of audible
alarm ratemeters (Section 34.33) and establishes reporting requirements for
certain incidents (Section 34.30), and became effective on January 10, 1991.
The rule also establishes new safety requirements for radiography equipment
(Sections 34.20 and 34.21), which will be phased in from 1992 to 1996.
In addition to the new radiography safety requirements, the final rule also
modified NRC's Enforcement Policy (10 CFR Part 2, Appendix C) to reflect the
regulatory changes.
Specifically, the modified Enforcement Policy put licensees
on notice that the failure to implement the requirements for dosimetry and
---...equipment by the required date will be considered a serious violation. Licensees
who fail to use required radiation safety equipment and personnel monitoring
devices will now be cited with a Severity Level III violation, which may lead
to a civil penalty (monetary fine) or other appropriate enforcement action.
9109210
a
IN 91-49 August 15,
1991 Finally, licensees are reminded of the existing requirements to conduct
radiation surveys, as stated in 10 CFR 34.43 and 20.201(b).
Failure to survey
will be now cited as a serious violation under the modified Enforcement Policy.
Compliance with the 10 CFR Part 34 radiation safety survey requirements is
critical for safe radiography operations.
Discussion:
NRC wants to emphasize to licensees that it is extremely important to perform
appropriate surveys and use appropriate personnel monitoring equipment when
using radiography sources. A number of significant overexposure incidents
occurred in this past year, that might have been avoided if proper surveys had
been performed and if alarming ratemeters had been worn (see Information Notice 91-23, "Accidental Radiation Overexposures to Personnel due to Industrial
Radiography Accessory Equipment Malfunctions").
Since the final rule became
effective on January 10, 1991, the use of alarm ratemeters is now required.
You should be aware that NRC staff takes strong enforcement action for failures
to perform adequate surveys.
In the past 18.months, NRC removed six radiogra- phers from licensed activities for, among other reasons, failing to perform
radiation surveys and willfully violating NRC regulations. In some cases, these violations caused significant overexposures or led to unnecessary
exposure to a member of the general public. We issued orders suspending or
modifying licenses for these failures, and we proposed substantial civil
penalties.
The Enforcement Policy now gives the following example of a Severity Level III
violation, which could lead to a civil penalty or other strong enforcement
action:
"Failure, during radiographic operations, to have present or use
radiographic equipment, radiation survey instruments, and/or personal
monitoring devices as required by Part 34."
In cases of willfulness, concealment, or repetition of similar serious
violations, we will consider actions stronger than civil penalties, such as
orders to modify, suspend, or revoke radiography licenses.
Based on inspections in the past year, we are concerned that radiographers
working independently in the field are not always complying with regulations
and license conditions. These lapses in radiation safety concern us, and we will take appropriate, strong enforcement action to prevent continued
degradations in safety. To ensure that your radiography sources are used
safely, we recommend that management conduct audits of your field radiography
programs, in addition to the audits already required by 10 CFR 34.11(d).
Licensee management should also meet with licensee radiographers to discuss
management expectations and NRC's heightened concern regarding the safe use of
these sources.
IN 91-49 August 15, 1991 Radiography involves relatively large quantities of radioactive material that
can be dangerous if not properly controlled.
Performing radiography requires
constant attention to detail and vigilant care because of its repetitive
nature, frequently in difficult field conditions. Through strong internal
radiation safety programs, including management audits, you can ensure that
licensed material is being used in a safe manner.
No specific action or written response is required by this information notice.
If you have any questions about this matter, please contact the technical
contact listed below or the appropriate regional office.
.~
.
Richard E. Cunningham, Director
Division of Industrial and
Medical Nuclear Safety
Office of Nuclear Material Safety
and Safeguards
Technical Contact:
Scott W. Moore, NMSS
301-492-0514 Attachments:
2. List of Recently Issued NMSS Information Notices
3. List of Recently Issued NRC Information Notices
II I I .
I
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Attachment 1
UNITED STATES NUCLEAR REGULATORY COMMISSION
RULES and REGULATIONS
TITLE 10. CHAPTER 1. CODE OF FEDERAL REGULATIONS-ENERGY
34.8(a)
34.1 PART
LICENSES FOR RADIOGRAPHY AND RADIATION SAFETY
l34
REQUIREMENTS FOR RADIOGRAPHIC OPERATIONS
6ec.
34.1
Purpose
and scope.
34.2 DefinitIons.
34.3 Applications for specific licenses.
34.4 Maintenance of records.
34.8 Informnaton collection requiremenuta
OMB approval.
Subpart A-Spedfic Ucensln tequlrements
34.11 Issuance of specific licenses for use Of
sealed sources In radIography.
Subpart B-Redibtihn Safely Requirements
EqUTMEM Co0zot
34.20 Pexformsnce requirements for
radiogaphy cquwpmcnn
34.21 Limits on levels of rndlstion for radi.
ographic exposure devices and storage
containers.
34.22 Locking of redlographbc exposure de.
vices. storage containers, and source
changers.
34.23 Storyge precuUions
34.24 Radiation survey Instruments
34.25 Leak testing, repair, tagging, open
Ing. modification and replacement 01
sealed sources.
34.26 Quarterly inventory.
34.27 Utilization logs.
34.28 Inspection and maintenance of radio
graphic exposure devices, storage con
taLner
and source chners
34.29 Permanent
radiographic
Installa
tions.
REPORTING
34.30 Reporting requirements.
PimsoxAL RAIATIsON
SArsT Rzm
rox RADIOORZsmw A"N RAviocRAmsus
Asslsrxirra
34.31 Training.
24.32 Operating
and emergency
proce
dures.
34.33 Personnel monitoring.
ParnoNsAc POCIoRS
RAZIoGRNC OMAT031
34.41 SecurIty.
34.42 PostIng.
34.43 RadIation surveys.
34.44 Supervision of radlographers' sails
ants.
Exrnoas
34.51 ApplicatIons for exemptions.
Arnntzr A
I-.
Autordty- Seac. 8.18.182,183.826 Stat.
835.8,16.354 e a amended (42 U S.C. 2111.
J=1, ZlOL) se. Sll.
Stat. 242.5a
amended 142 UMSC. 58 Section
.2 also Issued under sec. 2U6, e Stat u46 (42U SC. l4w
F lbs
mp 1f 23 2234 .U Shat $
341 (a) and
)K
U.2 W342 34.25 e)a
fb and (d) 34.2 wa.2
31 (a) and (t
Kn
3 (a1, Cs d) nd a
4M UAM
s~s a)*
ndfc ad 44ue sued
under sec. 1Itb 68 Stat 94.a amended (42 U.SC. 2201(h) and 1134.1(d); 3425({c) and
(434kB. 32.
W4.81b). 24.9(c) 3.0
f 34.1(c,
345.3 b) and (a) and 343(d) arm
sued under ec 1610,8 Stat. 930 as
Iamended (42 U.SC. 2201(o))
I § 34.1
Purpose
and scope.
This part prescribes requirements for
the issuance of licenses for the use of
sealed sources containing byproduct ma- terial and radiation safety requirements P
for persons using such sealed sources In a
radiography. The provisions and require- -
ments of this part are in addition to, and
n
L
not in substitution for, other require- ments of this chapter. In particular, the
provisions of Part 30 of this chapter
apply to applications and licenses subject
to this part. Nothing in this part shall
apply to uses of byproduct material for
medical diagnosis or therapy.
§ 34.2 Defmitions.
As used in this part:
'Permanent radiographic
installation" means a shielded
installation or structure designed or
Intended for radiography and In which
radiography is regularly performed.
"Radiographer"
means any Indi- vidual who performs or who, in atten- dance at the site where the sealed source
or sources are being used, personally
supervises radiographic operations and
- I who is responsible to the licensee for
a assuring compliance with the require-
^ ments of the Commission's regulations
and the conditions of the license;
"Radiographer's assistant, means
any individual who, under the personal
supervision of a radiographer, uses radio- graphic exposure devices, sealed sources
46i related handling tools, or radiation
survey Instruments in radiography;
"Radiographic
exposure device"
means any instrument containing a saled
source fastened or contained therein, in
which the sealed source or shielding
thereof may be moved, or otherwise
changed, from a shielded to unshielded
position for purposes of making a radio- graphic exposure;
"Radiography" means the exami- nation of the structure of materials by
nondestructive methods, utilizing sealed
sources of byproduct materials;
"Sealed source" means any by- product material that is encased in a
capsule designed to prevent leakage or
escape of the byproduct material;
"Source changer" means a device
designed and used for replacement of
sealed sources in radiographic exposure
devices, including those also used for
transporting and storage of sealed
sources:
"Storage area" means any location.
facility, or vehicle which is used to
store, to transport. or to secure a
radiographic exposure device, a storage
container, or a sealedgsource when it is
not In use and which is locked or has a
physical barrier to prevent accidental
exposure. tampering with, or
unauthorized removal of the device.
container, or source.
"Storage container
means a de- vice in which sealed sources ar trans- ported or stored.
_
SU A ppciaons for apeie iceneeL
A person may fle an application r
specific license for se of sealed sources
r;In radiography In duplicate on NRC
Form 313, "Applicatfon for Materlal
.Ucense," in accordance with the
provhisons of £ 30.32 of thIs chapter.
f 34.4 Maintenance of records.
Eacn recoro required by this part mun
lbe legible throughout the retention
period specified by each Commission
regulation. The record may be the
original of a reproduced copy of a
microform provided that the copy or
..microform Is authenticated by
a authorized personnel and that the
microform is capable of producing a
X clear copy throughout the required
retention period. The record may also be
stored in electronic media with the
capability for producing legible.
accurate. and complete records during
the required retention period. Records
such as letters. drawings. specifications.
must include all pertinent Information
such as stamps. initials. andsignatures.
The licensee shall maintain adequate
safeguards against tampering with and
loss of records.
9-I S4.
usfemationi oslctloA
requiemsfta OMS approvL
(a) Thn Nuclear Regulatorv
E Commission has submitted the
i nformation collection requirements
contained in this part o the Office of
Management and Budget (OMB) for
approval as rquired by the Paperwork
Reduction Act of 198 (44 U.S.C. 235 et
March 29, 1991 (reset)
34-1
34.8(a)
PART 34 0 LICEidES FOR RADIOGRAPHY AND RADIATi'ON SAFETY- .
3420(C)' .
.
.
seq.). OM1 has approved the
information collection requirements
contained In this part under control
number 3150-0
.
(b) The approved Inomatio
collection requirements contained In this
part appear In 11 34.11.3424 34.24
342A 342. 34283 U.= 34. 534
34.33 and 34.43 (cl This paut contains informtioa
2 collection requirements in addition to
Adthose approved under the control
number specifed Is parsgrapb (a} of this
sectio. These information collecton
requirements and the control numbers
under which they are approved ar as
follows
(1)In 1 34. For NRC-33R Is
approved under control number 35-
-0021.
Subpart A-Specific Licensing
Requirements
§ 34. 11
Issuance of specific licenses
for use of sealed sources In radiog- raphy.
An application for a specific license
for use of sealed sources in radiography
will be approved if, (a) The applicant satisfies the general
requirements specified in §30.33 of this
chapter;
(b) The applicant will have an ade- q quate program for training radiographers
£ and radiographers assistants and submits
W to the Commission a schedule or de- scription of such program which specifies
the:
(I) Initial training;
(2) Periodic training;
(3) On-thejob training;
(4) Means to be used by the licensee
to determine the radiographer's knowl- edge and understanding of and ability to
comply
with Commission regulations
and licensing requirements, and the oper- ating and emergency procedures of the
applicant; and
(5) In lieu of describing its initial
training program for radlographers in
the subjcts outlined in appendix A of
this part, and the description of and the
means used to determine the
radiographer's knowledge and
understanding of these subjects. the
applicant affirrms that all individuals
acting as radiographers will be certified
In radiation safety through the
Certification Program for Industrial
Radiography Radiation Safety Personnel
of the American Society for
Nondestructive Testing Inc. (ASNT-
3 IRRSP) prior to commencing duties as
radiographers From April18 1991. to
the date of the renewal of an existing
license, an approved license application
Is deemed to Include the option for
individuals who are certified in
radiation safety through the ASNT-
IRRSP, to substitute ANST-IRRSP
certification in lieu of the described
means to determine a radiographer's
knowledge and understanding of the
subjects in I 34.14(a)(1) This paragraph
March 29, 1991
I does not affect the licensee's
responsibility to assure that
radiographers are properly trained in
accordance with I 34.31(a))
(8) Means to be used by the licensee
to determine the radiographer's assistant's
knowledge and understanding of and sbil- ity to comply with the operating and
emergency procedures of the applicant;
(c) The applicant has established and
-
submits to the Commission satisfactory
l
written operating and emergency proce-
_dures as described in §34.32;
(d) The applicant has established and
submits to the Commission a description
of its inspection program adequate to
ensure that its radiographers and
radiographers' assistants follow the
Commission's regulatory requirements
and the applicant's operating and
emergency procedures. The Inspection
program must:
(1) Include observation of the
performance of each radilographer and
2 radiographer s assistant during an
actual radiographic operation at
X Intervals not to exceed three months:
(2) Provide that, If a radiographer or a
radlographer's assistant has not
participated in a radiographic operation
for more than three months since the
last inspection. that Individual's
performance must be observed and
recorded the next time the individual
participates In a radiographic operation;
and
(3) Include the retention of inspection
records on the performance of
radiographers or radiographers'
assislants for three years.
(e) The applicant submits a descrip- tion of its over'all organizational strnc- ture pertaining to the radiography pro- ram, including specified delegations of
authority and responsibility for operation
of the program; and
(f) The applicant who desires to con- duct his own leak tests has established
adequate procedures to be followed In
leak testing sealed sources, for possible
X leakage and contamination and submits
- to the Commission a description of such
procedures including
(l) instrumentation to be used,
(2) Method of performing test, e.g.,
points on equipment to be smeared and
method of taking smear, and
(3) Pertinent experience of the person
who will perform the test.
Subpart -Radiation Safety
Requirements
EQUIPMENT CONTROL
rFtun pe.fomae requirements tof
l radiorphy equIpment
2
Equipment used in industrial
£ radiographic operations must meet the
> folowing minimum criteria
a(a) Each radiographi exposure device
and ail associated equipment must meet
342 the requirements specified in American
National Standard N432-180
"Radiological Safety for the Design and
Construction of Apparatus for Gamma
Radiography," (published as NBS
Handbook 1386 issued January 1951).
This publication has been approved for
incorporation by reference by the
Director of the Federal Register in
accordance with 5 U.S.C. 552(a). This
publication may be purchased from the
Superintendent of Documents. U.S.
Government Printing Office.
Washington, DC 20402 and from the
American National Standards Institute.
Inc.. 1430 Broadway. New York, New
York 10018 Telephone (212) 642-4900.
Copies of the document are available for
inspection at the Nuclear Regulatory
Commission Public Document Room.
2120 L Street NW. Lower Level
Washington. DC 20555. A copy of the
document is also on file at the Office of
the Federal Register. 1100 L Street NW..
Room 8301. Washington. DC 2040&
(b) In addition to the requirements
specified in paragraph (a) of this section.
the following requirements apply to
radiographic exposure devices and
associated equipment.
(1) Each radiographic exposure device
must have attached to it by the user, a
durable, legible, clearly visible label
bearing the- E (i) Chemical symbol and mass number
of the radionuclide in the device
(Ii) Activity and the date on which this
activity was last measuredi
(III) Model number and serial number
of the sealed source.
fiv) Manufacturer of the sealed
source; and
(v)ULicensee's name, address, and
telephone number.
(2) Radiographic exposure devices
intended for use as Type B transport
containers must meet the applicable
requirements of 10 CFR part 71.
(3) Modification of any exposure
devices and associated equipment is
prohibited, unless the design of any
replacement component, including
source holder, source assembly, controls
or guide tubes would not compromise
the design safety features of the system.
(c) In addition to the requirements
specified in paragraphs (a) and (b) of
this section. the following requirements
apply to radiographic exposure devices
and associated equipment that allow the
source to be moved out of the device for
routine operation.
(1) The coupling between the source
assembly and the control cable must be
designed in such a manner that the
source assembly will not become
disconnected if cranked outside the
guide tube. The coupling must be such
that It cannot be unintentionally
disconnected under normal and
reasonably foreseeable abnormal
conditions.
(2) The device must automatically
secure the source assembly when It is
cranked back into the fully shielded
position within the device. This securing
system may only be released by means
34.20(c)
PART 34 0 LICENSES FOR RADIOGRAPHY AND RADIATION SAFETY---
3426 iI
of a deliberate operation on the
exposure device.
(3) The outlet fittings, lock box. and
drive cable fittings on each radiographic
exposure device must be equipped with
safety plugs or covers which must be
installed during storage and
transportation to protect the source
assembly from water, mud, sand or
other foreign matter.
(4) Each sealed source or source
assembly must have attached to It or
engraved in It, a durable, legible. visible
label with the words: "DANGER-
RADIOACrIVE." The label must not
interfere with the safe operation of the
exposure device or associated
equipment
(5) 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.
(6) Guide tubes must be used when
moving the source out of the device.
(7) An exposure head or similar
device designed to prevent the source
assembly from passing out of the end of
the guide tube must be attached to the
outermost end of the guide tube during
radiographic operations.
(8) The guide tube exposure head
connection must be able to withstand
the tensile test for control units specified
in ANSI N432.
(9) Source changers must provide a
system for assuring that the source will
not be accidentally withdrawn from the
changer when connecting or
disconnecting the drive cable to or from
a source assembly.
(d) All newly manufactured
radiographic exposure devices and
associated equipment acquired by
licensees after January 10,1992 must
comply with the requirements of this
section.
(e) All radiographic exposure devices
and associated equipment In use after
January 10. 1996 must comply with the
requirements of this section.
§ 34.21
Limits on levels of radiation
for radiographic exposure devices and
storage container.
(a)Radiographic exposure devices measur--
Ing less than four t4) inches from the
sealed source storage position to any
exterior surface of the device shall have
no radiation level in excess of SO miii- roentgens per hour at six (6) inches from
any exterior surface of the device. Radio- graphic exposure devices measuring a
minimum of four (4) Inches from the
sealed source storage position to any
exterior surface of the device, and all
storage containers for sealed sources or
for radiographic exposure devices, shall
have no radiation level in excess of 200
mfiiroentgens per hour at any exterior
surface, and ten (10) milliroentgens per
hour at one meter from any exterior
surface. The radiation levels specified are
with the sealed source in the shielded
(i.e.. -oftr position.
(b) Paragraph (a) of this section
applies to all equipment manufacturedt-
E prior to January 10, 1W992 After January
l 10. 19k. radiographic equipment other
than storage containers and source
changers must meet the requirements of
1 34.20. and 1 3421 applies only to
storage containers (source changers).
34M Locking of radiographic exposure
devices. storage containers, and soucre
changers.
(a) Each radiographic exposure device
shall have a lock or outer locked
container designed to prevent
unauthorized or accidental removal of
the sealed source from its shielded
position. The exposure device or Its
container shall be kept locked when not
under the direct surveillance of a
radiographer or a radiographer's
assistant or as otherwise may be
authorized In
34.41. In addition. during
radiographic operations the sealed
source assembly shall be secured in the
shielded position each time the source is
returned to that position.
(b) Each sealed source storage
container and source changer shell have
ir a lock or outer locked container
U designe to prevent unauthorized or
- accidental removal of the sealed source
from its shielded position. Storage
containers and source changers shall be
kept locked when containing sealed
sources except when under the direct
surveillance of a radiographer or a
radiographer's assistant
§ 34.23
Storage precautions
Locked radiographic exposure devices
and storage containers shall be physically
secured to prevent tampering or removal
by unauthorized personnel.
§ 34.24 Radiation survey instruments.
The licensee shall maintain sufficient
calibrated and operable radiation survey
instruments to make physical radiation
surveys as required by this part and Part
20 of this chapter.
Each radiation survey instrument shall
be calibrated at intervals not to exceed
three months and after each instrument
servicing and a record shall be maintained
8 of the resuts of each instrument calibra-
3 tion and date thereof for three years after
the date of calibration.
i
- nstrumentation required by this sec- tion shall have a range such that two
milliroentgens per hour through one
roentgen per hour can be measured.
[§ 34.25 Leak testing, repair, tagging, l
opening, modification and replace-
ment of sealed sources
(a) The replacement of any sealed
E source fastened to or contained in a
- radiographic exposure device and leak
testing, repair, tagging, opening or any
other modification of any sealed source
343 I shall be performed only by persons ape- cifically authorized by the Commission to
do so.
.
(b) Each sealed source shall be tested
° for leakage at intervals not to exceed 6 months. In the absence of a certificate
-from a transferor that a test has been
made within the 6 months prior to the
transfer, the sealed source shall not be
_put into use until tested.
E
(c The leak test must be capable of
detecting the presence of 0.0
microcurie of removable contamination
on the sealed source. An acceptable
leak test for sealed sours in the
possession of a radiography licensee
would be to test at the nearest
a accessible point to the sealed-source
storage position, or other appropriate
c measuring polnt by n procedure to be
approved pursuant to 134.11(f) Each
record of lea'test results must be kept
in units of microcuries Lor
disintegratlona per minute (dpm)J and
retained for inspection by the
Commission for three years after It Is
made.
(d) Any test conducted pursuant to
paragraphs (b) and (c) of this section
which reveals the presence of 0.005 microcurie or more of removable radio- active material shall be considered evi- dence that the sealed source is leaking.
The licensee shall immediately withdraw
the equipment involved from use and
shall cause it to be decontaminated and
repaired or to be disposed of, in accor- dance with Commission regulations A
report shall be filed, within 5 days of the
test, with the Director of Nuclear Mate- rial Safety and Safeguards, U.S. Nuclear
Regulatory
Commission, Washington, DC. 20S55, describing the equipment
involved, the test results, and the correc-
10 tive action taken. A copy of such report
ro shall be sent to the Adminitrtor
E of the appropriate Nuclear Regulatory
R Commission's
Re- gioual Office listed m Appendix D of Part
20 of this chapter "Standards for Protec- tion Against Radiation."
(e) A sealed source which is not fas- tened to or contained in a radiographic
exposure device shall have permanently
attached to it a durable tag at least one
(1) inch square bearing the prescribed
ratiation caution symbol in conventional
colors, magenta or purple on a yellow
background, and at least the instructions
"Danger-Radioactive
Material-Do Not
Handle-Notify
Civil
Authorities
if
Found."
r
34.26 Quarterly inventory.
g
Each licensee shall conduct a quarterly
physical inventory to account 1 for all
sealed sources received and possessed
under his license. The records of the
Inventories shall be maintained for three
March 29, 1991 (reset)
3426
34.32(i) ..
PART 34 0 LICENSES FOR RADIOGRAPHY AND RADIATION SAFETY..
years from the date of the inventory for
inspection by the Commission, and shall
include the quantities and kinds of by- product
material, location of sealed
sources, and the date of the inventory.
134 Utiation lo9s.
Each licenses shall maintain current
alogs, which shall be kept vailable for
three years from the dtab of Xh
recorded event. for inspection try the
CommissIon. at the addreu specified in
the license, showing for each sealed
source the following informatbon
r
(a)
A description (or make and model
lnumber) of the radiographic exposure
- device or storage container in which the
sealed source is located;
a
(b) The identity of the radiographer
o to whom assigned; and
l
(c) The plant or site where used and
Ldates of use.
F
8 tnspiettonandimstntenancoot
radiographexposure deviceo6 s crags
containers, and source changers.
( a)The licensee shall check for
a obvious defects in radiographic
exposure devices. storage containers
and source changers prior to use each
Lday the equipment is usd.
(b) The licensee shall conduct a
program for inspection and maintenance
of radiographic exposure devices.
storage containers and source changers
I at intervals not to exceed three months
-
or prior to the first use thereafter to
ensure proper functioning of
components important to safety. The
licensee shall retain records ofthese
insiections and maintenance for three
eyars.
F 3t29 PCunanert radlographi
Ihstsalations.
(a) Permanent radiographic
installations having high radiation area
entrance controls of the types described
in I 20-203(c) (2)(il). (2Xili). or (4) shaD
also meet the following special
requirement
° A Each entrance that Is used for
5 personnel access to the high radiation
X area in a permanent radiographic
Installation to which this section applies
shall have both visible and audible
warning signals to warn of the presence
of radiation. The visible signal shali be
ectuated by radiation whenever the
source is exposed. The audible slgua'
shall be actuated when an attempt is
made to enter the installation while the
source Is exposed.
(c) The alarm system must be tested
vat
intervals not to exceed thre months
aa or prior to the first use thereafter of the
2 source in the installation. The licensee
M shall retain records of these tests for
Athree years.
- L
C1 Reporting
1 34.30 ReportIng requirements
(a) In addition to the reporting
requirements specified under other
sections of this chapter. each licensee
shall provide a written report to the U.S.
Nuclear Regulatory Commission:
Division of Industrial and Medical
Nuclear Safety; Medical. Academic and
Commercial Use Safety Branch;
Washington. DC 20555. with a copy to
the Director. Office for Analysis and
Evaluation of Operational Data, U.S.
Nuclear Regulatory Commission.
Washington. DC 20555. within 30 days of
the occurrence of any of the following
incidents involving radiographic
equipment:
(1) Unintentional disconnection of the
source assembly from the control cable.
(2) Inability to retract the source
assembly to its fully shielded position
and secure it in this position.
(3) Failure of any component (critical
E to safe operation of the device) to
properly perform its intended function.
(b) The licensee shall include the
following information in each report
submitted under paragraph (a) of this
section:
(1) A description of the equipment
problem.
(2) Cause of each incident, If known.
(3) Manufacturer and model number
of equipment involved in the incident.
(4) Place, time and date of the
incident.
(5) Actions taken to establish normal
operations.
(6) Corrective actions taken or
planned to prevent recurrence.
(7) Qualifications of personnel
involved in the incident.
(c) Reports of overexposure submitted
under 10 CFR 20.405 which involve
failure of safety components of
radiography equipment must also
include the information specified in
paragraph (b) of this section.
PERSONAL RADIATION SAFETY
REQUIREMENTS FOR
RADIOGRAPHERS AND
RADIOGRAPHERS' ASSISTANTS
1 34.51 Training.
(a) The licensee shall not permit any
individual to act ass radiographer until
such individual:
(1) Has been instructed i~the subjects
- outlined in Appendix A of this part;
(2) Has received copies of and
i instruction in NRC regulations contained
in this part and in the applicable
sections of Parts 19 and 20 of this
chapter. NRC license(s) under which the
radiographer will perform radiography.
and the licensee's operating and
emergency procedures;
(3) Has demonstrated competence to
use the licensee's radiographic exposure
devices, sealed sources, related
handling tools, and survey instruments;
and
(41 Has demonstrated understanding
of the instructions in this paragraph (a)
by successful completion of a written
test and a field examination on the
subjects covered.
(b) The licensee shall not permit any
individual to act as s radiographer's
assistant until such individual:
(1) Has received copies of and
instruction in the licensee's operating
and emergency procedures;
(2) Has demonstrated competence to
- use. under the personal supervision of
c the radiographer. the radiographic
X exposure devices, sealed sources.
survey instruments that the assistant
will use; and
(3) Has demonstrated understanding
of the instructions in this paragraph (b)
by successfully completing a written or
orai test and a field examination on the
subjects covered.
(c) Records of the above training.
including copies of written tests and
dates of oral tests and field
examinations, shall be maintained for
three years.
334.32 Operating and emergency proce.
dures.
The licensee shall retain a copy of
current operating and emergency
X procedures as a record until the
> Coissioaterninates the license that
' authorizes the activity for which the
procedures were developed and if
superseded. retain the superseded
material for three years after each
change. These procedures must include
instructions in at least the following
(a) The handling and use of licensed
sealed sources and radiographic expo- sure devices to be employed such that
no person Is likely to be exposed to ra- diation doses in excess of the limits es- tablished in Part 20 of this chapter
-Standards for Protection Against Ra- diation"
(b) Methods and occasions for con- ducting radiation surveys:
(c) Methods for controlling access to
radiographic areas;
(d) Methods and occasions for lock- ing and securing radiographic expo- ta sure devices, storage containers and
sealed sources;
(e) Personnel monitoring and the
use of personnel monitoring equip- ment;
(f) Transporting sealed sources to
field locations, including packing of ra- diographic exposure devices and stor- age containers In the vehicles, posting
of vehicles and control of the sealed
sources during transportation;
(g) Minimizing exposure of persons
i In the event of an accident;
(h) The procedure for notifying
. proper persons In the event of an acci- o dent; and
(I) Maintenance of records.
34.4
January 31, 1990
34.320
PART 34
- LICENSES FOR RADIOGRAPHY AND RADIATION SAFETYApp. A(V)
I
(4) Be calibrated at periods not to
- §14- Supervisih n of radlographera as-
9 (J) The Inspection and maintenance
exceed one year for correct response to
sistanta.
" of radiographic exposure devices and
radiation: Acceptable ratemeters must
Whenever a radiographer's assistant
e storage containers, alarm within plus or minus 20 percent of
usradiogrphic exposure devices
Lthe true radiation dose rate.
uses sealed sources or related source
handling tools,, or conducts radiation
(k) Steps that must be taken Imme- e PZCTr
610ky PR:R
IN
surveys required by I 34.43(b) to deter.
diately by radiography personnel in
AVIoRAC OrPEATIoNs
mine that the sealed source has re- e the event a pocket dosimeter Is found
8 turned to the hielded position after
Ito be off-scale.
I 84.41 Security, aan exposure he shall be under the
During each radiographic operation
e Pcnoi Supervision
of
a
radio-
5 the radlographer or radlogrpher's es.
pher. The personal Supervision
and) The procedure(s)
ror
Identnying
dst nt Shan
p
maintain a direct surveil.
S hal Include: (a) The radiographer's
arid reporang defects nd noncomp
I lance of the operation to protect
Per onal Presence at the Bite where
ance. As required by Part 21 of this
aginst unauthorized entry into a high
the sealed sources re being used (b
chapter
rdiation area, as defined In Part 20 of
the ability of the radiograPher to give
this chapter. except (a) where the
immediate SS31sttInce if required, and
34.13 ersonnel msoniorn.
high radiation area Is equipped with a
(c) the radogrpher's watching the a-
)0- (a) The licensee may not permit any
control device or an alarm system as Lstant'
performance of the oper.
individual to act as a radiographer or a
described in I 20.203(cX2) of this chls
itIons referred to In this section.
radlographer'sassistant uness.atal
ter. or (b) where the high radiation
each suc individual wears a direct
thorized or accidental entry.
£ 84.61 Applications for exemptions.
reading pocket dosimeter. an alarm
84.42 Psting.
The Commission may, upon %pplica.
ratemeter. and either a film badge or a
Notaltstng
sny
ovidons In
Won
bY
licensee or upon Its own
exthermoluminescentfdomaneterdiolal)
1120.204(c) of this chapter, areas in
Initiative, grant such exemptions from
axcept that for pemanent r
adiography
which radiography is being performed
the requirements of the regulations in
E faciliies
where other appropriate ishl
be conspicuously posted as re- this P5rt as It determines are author.
g alarmingorwarningdevices arein
quired by 120.203(b) and (cX1) of this
lIzed by law snd will not result in
routine use, the wearing of an alarming
chapter.
undue hard to life or property.
ratemeter is not required. Pocket
JAprzzx A
dosimeters must have a range from zero
I 34.3 Radbation surveys.
to at least 200 mllroentgens and must
The licensee shall ensure that:
L Fuusmiarra or RsnuTzox Sfrm
be recharged at the start of each shift.
(a) At least one calibrated and
A. Characteristls of anmms radiation.
Each film badge and TLD must be
operable radiation survey instrument is a
L UnIts of radiation doe (Mm) and
assigned to and wom by only one
available at the location of it
- cuantitt of radloactivity (curie).
Lndiidul.
C Hazards of exposure to radtiation.
Individual
radiographic operations whenever
°
D. evels of radiation from licensed mate.
radiographic operations are being
uILL
r
fb) Pocket dosimeters must be mead
performed, and at the storage area, as
It Methods of eontroUlins radiation dose:
and exposures recorded daily. The
defined in 342 whenever a
1. Wor tme.
- liceneee Shall retain each record qf these
radiographic exposure device, a storage
W.
Sheldin
In expos.re for th years fter the
container, or source Is being placed in
11. RAwnnox Dirzcnow IN5ThU32TAoNt
ILrecord is made.
storage.
To B Urn
r(c) Pocket dosimeters
ali
be
(b) A survey with a calibrated and
A. Use of radiation survey Instruments:
checked at periods not to exceed one
operable radiation survey Instrument Is
1. operation.
year for correct response to radiation
made after each exposure to determine
-2. CSlibfLtUn
e Acceptable
dosimeters
shall
read
that the sealed source has been returned
D. muriey tat niques
e within plus or minus 30 Percent of the
to its shielded position. The entire
u
true radiation exposure.
circumference of the radiographic
>C. Use Of personnel monitoring equip- (d) If an individual's pocket dosime- exposure device must be surveyed. If the
mnt
es
d thermoluminent d
ter Is discharged beyond Its range, his
radiographic exposure device has a
simetera brd's
d
Lfilm
badge or TLD shl be mmediate- source guide tube, the survey must
2. Pocket dosimeters.
ly sent for processng
include the guide tube.
3. Alam ratemeters
(c) A survey with a calibrated and
.
te) Rq
ve
d t
the film
operable radiation survey instrument Is 11.
RtzomuNc EQu"Wzxy To Bc Urn'
badge or MD processor mt be
made at any time a radiographic
Remote handling equipment
f
da for
tilte
exposure device is placed In a storage
I
IL R
exposure devices.
Commssaion terinates each bcense
- rea as defined in I 34. to determine
. SUorage eobtainers.
' that to
the
actiit tht
b
Itat the sealed source is in Its shielded
E IV tsrnow mm MMtDIAxcz Pzreom
s ubject to the
position. The entire circumference of the j
5? T3K RAntocitaoo m
radiographic exposure device must be
V. CAs Hisroaza or Rznzocwwp
Iff Each alarm ratemeter must- surveyed.
-Acx.
I
(1) Be checked to ensure that the
(dl A record of the storage survey
L
alarm functions properly (sounds) prior
required In paragraph (c) Is made and is
to use at the start of each shiftf
retained for three years when that
lNot
d
S PR Iff31
(2) Be set to give an alarm signal at a
storage survey Is the last one performed
B preset dose rate of am0 mR/hr4 in the work day.
(3) Require special means to change
the preset alarm function; and
34-5
5January 31,
1990
-1
Attachment 2
August 15, 1991 LIST OF RECENTLY ISSUED
NMSS INFORMATION NOTICES
Information
Date of
Notice No.
Subject
Issuance
Issued to
91-44
91-39
Improper Control of Chemicals
in Nuclear Fuel Fabrication
Compliance with 10 CFR Part 21,
"Reporting of Defects and
Noncompliance"
07/07/91 All nuclear fuel facilities.
06/17/91
All Nuclear Regulatory
Commission (NRC) material
licensees.
91-35
Labeling Requirements for
Transporting Multi-Hazard
Radioactive Materials
06/07/91
All U.S. Nuclear
Commission (NRC)
Regulatory
licensees.
91-30
91-26
Inadequate Calibration of
Thermoluminescent Dosimeters
Utilized to Monitor Extremity
Dose at Uranium Processing and
Fabrication Facilities
Potential Nonconservative
Errors in the Working Format
Hansen-Roach Cross-Section
Set Provided with The Keno
and Scale Codes
Accidental Radiation Over- exposures to Personnel due
to Industrial Radiography
Accessory Equipment Malfunc- tions
Unmonitored Release Pathways
from Slightly Contaminated Re- cycle and Recirculation Water
Systems At A Fuel Facility
Recent Safety-Related Inci- dents at Large Irradiators
91-23
04/23/91
All fuel cycle licensees
routinely handling unshield- ed uranium materials.
04/02/91
All fuel cycle licensees
and other licensees, in- cluding all holders of
operating licenses for
nuclear power reactors, who use physics codes to
support criticality
safety in the use of
fissile material.
03/26/91 All Nuclear Regulatory Com- mission (NRC) licensees
authorized to use sealed
sources for industrial
radiography.
03/06/91 All fuel cycle facilities.
03/05/91
All Nuclear Regulatory
Commission (NRC) licensees
authorized to possess and
use sealed sources at
large irradiators.
91-16
91-14
I
Attachment 3
August 15, 1991 LIST OF RECENTLY ISSUED
NRC INFORMAT.IpN NOTICES
C
.-,
[
k 't Ii
bi
.
I
J8 I'V
If:
1~ l.
Information
Date of
Notice No.
Subject
Issuance
Issued to
91-48
91-47
89-56, Supp. 2
91-46
91-45 False Certificates of Con- formance Provided by West- inghouse Electric Supply
Company for Refurbished Com- mercial-Grade Circuit
Breakers
Failure of Thermo-Lag
Fire Barrier Material to
Pass Fire Endurance Test
Questionable Certification
of Material Supplied to
the Defense Department by
Nuclear Suppliers
Degradation of Emergency
Diesel Generator Fuel Oil
Delivery Systems
Possible Malfunction of
Westinghouse ARD, BFD, and
fiBFD Relays, and A200 DC
and DPC 250 Magnetic Con-
-tactors
Improper Control of
Chemicals in Nuclear Fuel
Fabrication
Recent Incidents Involving
Rapid Increases in Primary- to-Secondary Leak Rate
Plant Outage Events
Involving Poor Coordina- tion Between Operations
and Maintenance Personnel
During Valve Testing and
Manipulations
08/09/91
All holders of OLs or CPs
for nuclear power reactors.
08/06/91
All holders of OLs or CPs
for nuclear power reactors.
07/19/91
All holders of OLs or CPs
for nuclear power reactors.
07/18/91
All holders of OLs or CPs
for nuclear power reactors.
07/05/91
All holders of OLs or CPs
for nuclear power reactors.
07/08/91 All nuclear fuel facilities.
07/05/91
All holders of OLs or CPs
for preisurized-water
reactors (PWRs).
06/27/91
All holders of OLs or CPs
for nuclear power reactors.
91-44
91-43
91-42 OL = Operating License
CP = Construction Permit
IN 91- August , 1991 Radiography involves relatively large quantities of radioactive material that
can be dangerous if not properly controlled.
Performing radiography requires
constant attention to detail and vigilant care, because of its repetitive
nature, frequently in difficult field conditions.
Through strong internal
radiation safety programs, including management audits, you can ensure that
licensed material is being used in a safe manner.
No written response is required by this information notice.
questions about this matter, please contact the appropriate
this office.
If you have any
regional office or
Richard E. Cunningham, Director
Division of Industrial and
Medical Nuclear Safety
Office of Nuclear Material Safety
and Safeguards
Technical Contact:
Scott W. Moore, NMSS
301-492-0514 Attachments:
2. List of Recently Issued NMSS Information Notices
3. List of Recently Issued NRC Information Notices
MSS/Editor*
Kraus
el 2'ffiious
concurrence*
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- 7/30/91
- 7/30/91
1
- 8/7 /91
- 8/7
8g/91 OFFL.lAL KtUVKU
.uri
RADIOGRAPHY/IN
IN 91-49 August 15, 1991 Radiography involves relatively large quantities of radioactive material that
can be dangerous if not properly controlled.
Performing radiography requires
constant attention to detail and vigilant care because of its repetitive
nature, frequently in difficult field conditions. Through strong internal
radiation safety programs, including management audits, you can ensure that
licensed material is being used in a safe manner.
No specific action or written response is required by this information notice.
If you have any questions about this matter, please contact the technical
contact listed below or the appropriate regional office.
Richard E. Cunningham, Director
Division of Industrial and
Medical Nuclear Safety
Office of Nuclear Material Safety
and Safeguards
Technical Contact:
Scott W. Moore, NMSS
301-492-0514 Attachments:
2. List of Recently Issued NMSS Information Notices
3. List of Recently Issued NRC Information Notices
ISS/Editor*
Kraus
629tevi ous concurrence*
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ATE :7/30/91
- 7/30/91
- 7/30/91
- 8/
/91
- 8/ /91
- 8/ /91
- 8//D/91
OFFICIAL RECORD COPY
RADIOGRAPHY/IN
IN 91- August , 1991 take appropriate, strong enforcement action to prevent continued degra
ions
in safety.
To ensure that your radiography sources are used safely
e recommend
that management conduct audits of your field radiography program , In addition
to the audits already required by 10 CFR 34.11(d).
Licensee anagement should
also meet with licensee radiographers to discuss managemen expectations and
NRC's heightened concern regarding the safe use of th
sources.
Radiography involves relatively large quantities o radioactive material that
can be dangerous if not properly controlled. P
orming radiography requires
constant attention to detail and vigilant carr, because of its repetitive
nature, frequently in difficult field cond ions. Through strong internal
radiation safety programs, including man ement audits, you can ensure that
licensed material is being used in a s e manner.
No written response is required b 'this information notice.
If you have any
questions about this matter, p1 se contact the appropriate regional office or
this office.
Richard E. Cunningham, Director
Division of Industrial and
Medical Nuclear Safety
Office of Nuclear Material Safety
and Safeguards
Technica Contact:
Scott W. Moore, NMSS
301-492-0514 Atta
ments:
List of Recently Issued NMSS Information Notices
3. List of Recently Issued NRC Information Notices
MSS/Editor
Kraus
e420{e~ious concurrence*
FC
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ATE :7 / 30 /91 : 7/ 30 /91
- 7 / 30 /91 : /
/91 : /
/91 : /
/91 : /
/91
OFFICIAL RECORD COPY
RADIOGRAPHY/IN
-
IN 91- August , 1991 Although radiography is not complex, it does use relatively large qua ities of
radioactive material that can be dangerous if not properly control d.
Performing radiography requires constant attention to detail an
igilant
care, because of its repetitive nature.
Through strong inte
al radiation
safety programs, including management audits, you can ens e that licensed
material is being used in a safe manner in a field en
niment.
No written response is required by this informatio
notice.
If you have any
questions about this matter, please contact the
propriate regional office or
this office.
Richard E. Cunningham, Director
Division of Industrial and
Medical Nuclear Safety
Office of Nuclear Material Safety
and Safeguards
/
Technical Contact:
. 'Scott W. Moore, NMSS
301-492-0514 Attachments:
2. Lis 'of Recently Issued NMSS Information Notices
3. L t of Recently Issued NRC Information Notices
MSS/Editor
Kraus
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- IM
IMOB
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- RCunningham
ATE :7 / 30/91 :
/91 V 7/j /91: /
/91 :
/91 :
/91 :
/91
OFFICIAL RECORD COPY
RADIOGRAPHY/IN