ML20040B968

Reg Guide 10.6,Revision 1, Guide for Presentation of Applications for Use of Sealed Sources & Devices for Performing Industrial Radiography. Abstract of Comments Received & NRC Response Encl

ML20040B968
Person / Time
Issue date:	12/31/1981
From:	NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To:
References
REGGD-10.006, NUDOCS 8201270114
Download: ML20040B968 (34)

Text

Revision 1*

/ g,,g4 U.S. NUCLEAR REGULATORY COMMISSION December 1981

+

O ge s$

(M.%,st! REGULATORY GUIDE OFFICE OF NUCLEAR REGULATORY RESEARCH REGULATORY GUIDE 10.6 (Task TP 602 4)

GUIDE FOR THE PREPARATION OF APPLICATIONS FOR USE OF SEALED SOURCES AND DEVICES FOR PERFORMING INDUSTRIAL RADIOGRAPHY

1. INTRODUCTION hlaterial", 10 CFR Part 71, " Packaging of Radioactive Material for Transport and Transportation of Radioactive 1.1 Purpose of Guide Material Under Certain Conditions"; and 10 CFR Part 170, "I ees for Facilities and Materials Licenses and Other The purpose of this guide is to provide assistance n the Regulatory Services Under the Atomic Energy Act of 1954, preparation of an application for a Nuclear Regulatory as Amended." The applicant should carefully read these Commission (NRC) heensc for possession and use of sealed regulations and this guide and should submit all information sources and devices for performing industrial radiography.

requested.

" Radiography," as used in triis gdide, means the examina-tion of the structure ofinaterials by nondestructive methods that use scaled sources of byproduct nuteruls tradioisotopes).

1.3 As Low As h Reasonably Achievable ( AL AR A)

'Ihe radioisotopes most commonly used for radiography are cobalt 40 and mdium 192.

Paragraph 20.l(c) of 10 CFR Part 20 states, in part,

. persons engaged in activities underlicensesissued by the t his guide is mtended only for general guidance in Nuclear Regulatory Commission pursuant to the Atomic preparation of the license application and should not be Energy Act of 1954, as amended,and the Energy Reorganita-9 considered a substitute for the applicant's careful safety tion Act of 1974 should,in addition to complying with the evaluation of the proposed use of scaled sources and requirements set forth in this part, make every reasonable devices. Ihc applicant most ensure that the application effort to maintain radiation exposures, and releases of j

correctly and adequately describes the radiation safety radioactive materials in effluents to unrestricted areas, as measures and procedures to be followed to provide adequate low as is reasonably achievable." Regulatory Guide 8.10, protection.

" Operating Philosophy for Maintaimng Occupational Radiation Exposures As Low As k Reasonably Achievable,"

1.2 Applicable Regulations provides the NRC staf f position on this important subject.

License applicants should give consideration to the ALARA Commission regulations that apply to radiography and phdosophy, as described in Regulatory Guide 8.10, in the that should be used in conjunction with this guide are deselopment of plms for work with licensed radioactive 10 CFR Part 19, " No tic es, Instructions and Reports to materials.

hrkers; inspections" 10 CFR Part 20, " Standards for Protection Against Radiation"; 10 CFR Part 21, " Reporting of I)efects and Noncompliance",10 CFR Part 30, " Rules

2. LICENSE FEES of General Apphcability to 1)omestic Iicensing of flyproduct M a t erial" 10 Cl R Part 34, " Licenses for Radiography and A license fee is required for most types of licenses and Radiation Safety Requirements for Radiograplue Opera-renewals and amendments to licenses. The applicant should tions" 10 CFR Part 40, "llomestic Licensing of Source refer to { l70.31, " Schedule of Fees for Matenals Licenses and Other Regulatory Services," of 10 CFR Part 170 to determine the amount of fee that must accompany the Ine subst muai number of i nances in inis rmsion nas made it imna.a o. maimoe ine inanen enn nne. n the marvm.

application. Review of the application will not begin until hI Q4811231 10.006 R PDR usNnc nr ouuuony auim,

comments snound be sent to tne secretary or tne commission, U.S.

Nuclear H equla t or y Commission, Washingt on, D.C. 20555, Ufotalatory Guide $ are 1%ued to de5c rthe and make avaslable to the attention: oocueting and service orancn.

pu blic m et hi n1s

.n c ept able to the NRC staf f of im plemen t mq

%iset t fic part5 of the Calm mt$5 eon's reQulat idn%, to delineate tech.

The guides are issued m the f ollowmq ten broad divisions:

n* ques u sett by the Staf f in evaluating $pecif tc problem 5 or postu-lat ed a( c idell t 5, of to Orthrede quedanc e to applicants. Pequlatory

).

Power HeJc tors

6. Pr od uc t s

(.u mes are not su turit u tes for requiations, and comphance wit h

2. nesearch and Test neactors

/. Transocria. ion g

them as not requered. Methods and sohsteong def terent f rom those set

3. I ucis and Materials F ac elitie5

8. Occupational Health out m the quedeg will be ac(eptable et they proy'4e a baseg for the a, t hvironmerital and Set mq

9. Antitrust and f inancist Review hndane resguigste to the 1%uance or COntinuar a

of a permit Or

5. MJterialg and plant Protection 10. Gener al II( en%e by t he Comma %gon.

Copies of issued guides may be purchased at the current Government r ht1 Quade was j%ued af ter con %hteration of c ammenti received f rom printing of t cc price. A subscription service for f uture guides in spe-the pu blet. Comments and SuQ9estion% f0r impr ovements m the5e ctfic divt5 son 5 15 availat' e through the Government Printing Of fice.

Quide % ate encouraged at all times, and quedes wili be revlied, 35 Information on the Subscription ServlCe and Current GPO prices may appropetJte, to accommodJte Comment 5 and to leflect new informa-be obtamed by wratmo the U.S. Nuclear Regulatory Commission, tion or espertence.

W a5h a n9to n.

O.C.

20555, Attent6on: Pubhcation. Sale. Manager.

the pioper fee is received by the NRC Checks should be contained in the application is accurate. Improperly identi-made paphie to the U.S. Nuclear Regulatory Commission.

fied equipnioit may require additional correspondence.

3. FILING AN APPLICATION hem 6/a). If a permanent radiographic installation will be used for performance of radiography, a detailed descnp-An apphcation for a license must be fded on l'orm tion of the installation that includes the following informa-N R(M l 3 R, "Apphcation f or liyproduct Nlaterial bcense -

tion should be submitted:

Use of Scaled Sources in Radiography" (1:xhibit A), and should contain all the infonnation specified in the applica-

a. Annotated drawings or sketches of the installation tion fo r m. the spate prouded on the form is limited; and its surroundings, including (1) dimensions of each therchue, the applicant should append additional sheets to enclosed area;(2) thickness, density, and type of shielding proude complete inf ormation.

matenal on all sides, above, and below;(3) identification of entranceways; and (4) a desenption of the nature of and t he application should be completed ir triplicate. Ihe distances to all areas adjacent to, above, and below each ongmal and one copy should be mailed 'o the Nlatenals exposure area.

1. ice nsuig Hrant h, IMision of Fuel Cycle and Nlatenal Saf ety. ()thce of Nutlear Niaterial Saf ety and Safeguards,

b. A description of the area secunty safeguards, such as U.S. Nuclear Regulatory Com nussion. Waslungton, D.C.

locks, signs, warning lights and alarms, and iaterlocking 2055% ()ne copy of the applitation with all attachments systems for each enclosed exposure area and adjacent areas.

should be retamed by the apphcant, since the hcense wdl Particular attention should be given to the description of reipure, as a t omhtion, that the hcense,' follow the state-the high radiation area entrance controls that are required ruents and representations set forth in the apphcation and by s 34.29 The applicant should describe the means for any supplements to it.

ensuring that the interlock systems required by @ 34.29 are not easdy defeated by the radiographer. This may be

4. CONTENTS OF AN APPLICATION accomphshed through system design, e.g., replacement of simple switches by direct winng or key switches under i

l l he f ollowing ihscussion deals with specific items on the centrol of the radiation safety officer, or through stnet I

apphcation form. Ihc inf ormation decit ted in Items I control procedures, e.g., direct supervision of the operJtion through 3 of the appbcation is explamed in the instruction by the radiation safety officer.

sheet accompanymr the apphcation form, and item 7 is self-e x pla na t ory. I he mtormation needed for items 4, 5,

c. The results of calculations or radiation level measure-and 6 of the apphcation form is thscussed bdow. In com, ments showmg mnimum anticipated radiation levels in all ple t mg the appheation, especially items 4 and 5, the areas adjacent to each exposure area, including the roof or apphcant should coser anticipated expansion and changes ceiling. As a basis for calculations, the type of source, in the progr.un and thus reduce the need for future license actnity of the source, and position of the source within the amendmer.ts.

installation should be identified.

Item -/ l he scaled sourct s, includmg cabbration sources Particular attention should be given to radiation levels that the appheant wi!! possess and use, should be hsted by on the roof of the installation. If those levels may exceed 2 radmisotope, manu tx t u re r.

and model nu m ber. The milliroentgtns per hour, the application should show how mnunum.unount of rahoxtiut) in cash source should be access to the roof wdl be controlled. If the calculations or spet itied. Ihe number of sources that the apphcant wdl measurements show that rathation levels on the roof might pouess at any one tune need not be specitically stated exceed 100 mdhroentgens per hour, the applicant should unless any one soun e c ont.uns more than 100 cunes of consider the use of colhmating devices or additional shielding cobalt 4 0 in the roof or ceihng.

I

/ tem.5 Rmhogupluc exposure deuces should be desig-A properly shielded installation will permit the perfor-nated by manutacturer and model number and should be mance of radiography within the facdity with the areas key e f alphabetical l) to lhe sources hsted in item 4 with outside the facility considered as unrestricted areas if they w!nt h they wdt. be used brecify m 5(a) of the apphcation meet the radiation lesel limitations in paragraph 20.105(b) t oim i of 10 CFR Part 20. A radiation level of not more than 2 nulbroentgens per hour at a distance of I8 inches from any li soun e aangers w di be used, the source changers external surfate of the facility will be considered acceptable should be identificil by n.anututurer and model number for considenng the area as an unrestricted area.

and should be key ed alphabetically to the source. device combmations with wlut h they will be used tspecify in 5(bl if field radiography will be performed, the applicant d the apphcation form k should desenbe how radiography equipment will be stored at temporary job sites, it nec e ssa r y, the supphers of eqinpment should be contat ted cont erm ng the model nu m bers of sources, Jtem 6/h) Suney instruments shoubt be identified by deus es, and source t hangen to ensure that the inf ormation ty pe t re., ionization, G31., scintillation) and exposure l

10.6-2

ra n ge. Instruments to be used for suneys are rtquired by item 6/f). The appbcant should proside a description of s 34.24 to measure f rom a minimum of two milbroentgens the complete traming program for radiographers, radiog-f per hour through one roentgen per hour.

raphers' assistants, and experienced radiographers and radiograp hers' assatants. This description should include item 6(r). Section 34.24 requires that radiation survey appropriate references to any instructions given by outside mstruments used in radiographic operations be cabbrated at service apenaes. t he name, training, and experience with intervah not to exceed 3 months anti af ter cath inoniment radiation of each pe rson 'who will provide su bst antial servicing. Appendix A contains a description of an acceptable input for the instruction, examination, or qualification of procedure f or tabbratmg survey instruments.

trainees should be given in suf ficient detail to estabhsh his or her quahfications to perforni these services. If an indi-If inst ru men t cabbration wdl be pe rf ormed by an vidual will teach only certain parts of the course, this organdation other than the apphcant. the applhatum should be specified. Appendix C desenbes the elements of should include the name, addrew, and NIK or Agreement an acceptable training program.

States' bcense number of the organuation.

In certam cases where a radiography program is limited if an apphcant wishes to ;ahbrate survey instruments to a tew indniduals and personnel turnoscr is not anticipated, in-house, the following information should be submitted:

a traming program may not be necessary provided each mdnidual has had adequate traimng and expenence. In a.

l'h e type (radioisotope, manuf acturer, and model such a situation, the application shouhl request that specific number) and actnity of any sourte to be used for cabbration.

mdividuals be named on the hcense in lieu of subnuttmg detads of a complete traming program. t he application

b. 't he accuracy

• of t he source.

should explam why it is not necessary to estatdish a training program. Ihe quahfications of each individual designated as Ihe specific protedures to be used for cabbration, a radiographer or rathographer's assntant should be desenbed t.

mcluding rachation saf ety procedures to be f ollowed for use and should include the followmg information:

of the sourt e.

a.

lhe endnaduali name and the capacity in which that

d. 't he name and pertment expenence of cash indnnlu-d inda nlual will func tion tradiographer or radiographer's who wdl peitorm mstrument (abbration. Ihis information assist a n t )

may be omitted if the ndn uinal is a radiographer and the apphcant hn an adequate program for the trammg of

b.,\\ detaded description of each indnidual's training radiographers tsee hq f u that mtlades instrument tabbration and experience in the pnnciples of radiation and radiation p roc ed u r es 11 radiographers w ill perf orm instmment safet y. the information prosided should specif y when calibration, speahc instructions and procedures should be hiates) and whcre training was reemed. I'he name of the wntten for use by radmpraphers and shouhl be mcluded mdnidual who prouded the tranung should he mditated it m the operating and emergency procedures (see 6t eJ L traming other than that of a commercially offered program w as used.

Irem old). ihe apphtant shoubt speuty the type of personnel monitoring deuse (for example, film badge or

c. 'lhe spo :he experience of each indnidual in the use thennotununesi ence dosuneter) that wdl be used, and the and hmitmg of the type of c<piipment specified in the names and addresses of the suppl ers that : a) be used. ihe apphcation. the information should inchide n a m es of f requent y of t hange of film badges or thermolununes. nice preuous employ ers, dates employed. type of equipment dosimeters should be specified.

used, and length of tune the equipment was used for each p r es inu s e m ploy er.

lhe range of pot ket do oneters to be used should be identihed. Set tion 14 33 requues that pocket dosimeters

d. A desenption ot the msuuction that each prospective hne a rang from tero to at least 2OO nulliroentgent Dosun.

radiographer and radiographer's assistant has received in the cren with an extremely high range, for example, dosuneters appl cant's operating and emergency pro edures.

s deugned f or ('n d I)ctense pur poses. which hue a range trom rero to 100 roentrens, are dif f cult to read in the zero

e. A desnption of the means used to deterimne com-to 200 nullucientrens range and are not consulcre.' Jccept-pClence of Indnlduals to act Js radiographCTs and by whoin aNc. Pr oc edu r es for t heckmg pocket Josuneter exposure such deteimmation is made. Copies of exauunations gnen and energy response, as required by paragr aph 34.3 3(c),

to deternune knowledge and understandmg of the topics in l

should be desi nbed Appendix A of Part 34, the appl cant \\ operatmg and j

emergens ) procedures Commission regulations, and use ol

/rrm 6[r/ t he appih Jnt stumld de% ribe the operalinf.

equipnient should be subinitted.

and emergenc y prot alutes that will be f ollowed by r.nhop raphy personnel. Appendn H dewr.besitems and procedures

1. A desenplion of the means used to determine com-that should be mtluded.

pctente of mdniduals to act n radiographers' assistants and by whom such determination is made. Copies ot

• u.um n the maunnem demnon of ibe nommal uluc of the mumMmm pn M del s m-ud N.mding of the u.un e trom the une olae i hn in rormanon n nor m alt

• Pr"ude I M ihe m.mut nius er.

htense/s operJting a9d eme!gency procedtires and incJin 10.6-3

used to determme conipetente to use radiograpluc and frem 6/h). l'aragraph 34.11(c) requires that the license related equipment should be submitted, appheant submit a descnption of the overall organizational structure pertaining to the radiography program, including

g. A description of the periodic traming program for specific delegations of authority and responsibility for the personnel.

program, 'Ihe applicant should describe how active control over the radiography program is exercised by management Ihr hmitations imposed m hcenses when the apphcant personnel in positions of authority.1:ach individual in the has not established a compleie program for trammg radiog-hne of authority should be identified by name and title. In raphers and rathographers' assistants should be clearly under-addition, the applicant should provide the name, training, stood. I he hcense wdi specihcally rume cat h mdividual autho-and experience of that individual in management who will n/cd to act as a radiographer or rathographer's assistant.

he assigned duties established by the licensee for maintaining Should all rathographers who are nanted in the hcense become an active management control of the radiation program unavadable, the licensee would not be permitted to perform and radiographic operations. Appendix D describes accept-radiography under the license and therefore would have,in able quahfications for such individuals and the responsibil-etlect, authontation to possess the hcensed byproduct mate-ities of the positions. If persons of lesser authority will mal f or storage purposes only. 'I he individuals named on the assume some of the duties and responsibilities normally bcense must be quahtied to perform all radiographic opera-reserved for management, the application should identify tions conducted under the beense, includmg the manipula-those persons and specify how management wdl ensure that tion of equipment and the perf ormance of radution surveys.

their duties are properly performed.

Alttu> ugh application may be made for the addition or sub-statution of names of other mdividuals in the hcense, the time needed for preparation and submiuton of the applica-hem 6(i). Ihe appheant should submit a desenption of lion and for the Couumssion to iwue an amendment conht the leak-testing program for the scaled sources as follows:

itelay the program. No mdividual may act as a radiographer's awistant unlew the htense has been amended to provide for

a. It the apphcant wi,hes to be beensed by the Commis-

.m mihvidual to att m that capacity. An mdnidual shouhl smn to use a commercially available leak-test kit, the not enter mto on thegob traming untd the license has been application shoubt identity each kit to be usell by designating amended to pemot that trammg.

the kit suppher and the kit model number. Only leak-test kits that are identihed wdl be authorized. ~lhe application hem olet 't he apphcant should provide a desenption of should aho identity the individuals who will perform the the mternal mspection sy stem f or controlhng the reteipt.

leak test (using the kit).

l possemon, and use of radioat tise material. I he description should show how the sy stem ensures that license conthlions,

b. Il the sersiees of a consultant or conunercial organiza-Com m imon regulatmns, and operatmg and emergency tion licensed by the Commission to take the necessary test procedures are f ollowed by radiographers and radiographers' samples (smea rs ), evaluate the samples, and report the assntank as icquired b) p.nagraph 34.11(d L results to the customer are used, the name, address, and hcense number of the consultant or commercialorganization

()ther management controls shouhl be specified m the shouhl be specified.

apphcation. Ihese controls shouh:.nclude a desenption of (1 ) the ty pe of mternal mspections to be made and their

c. It an appheant wishes to be licensed by the Commis-hequency,(2 ) the quahheations of each penon responsib!e for sion to perform leak tests, includmg takmg and evaluating nuunt.nmng suc h cont rol,(D the icsponsibihties of cat h grson the smears, paragraph 34.11(f ) requires the apphcant to m lhe piogram, t4) the procedure f or retordmg and reporting describe the protedures to be used. The following mforma-dehcienties to appropriate management personnel, and (5) tion should be included:

the educatmn and tollowup program to be used m correctmg deficienties noted dunny mspections. Ihc ty pe and estent (l) a desenption of the instrumentation to be used in of the radiography program to be conducted will usually deter-evaluating the smears, including its sensitivity and accuracy; nnne the nature of the sy stem and the mspechon frequency.

paranaph 34.lHJ) requires that an mternal mspettion be (2) a desenption of the cahbrating and standardi/ing pertonned at mtenals not esceding three months and that procedures with a sample calculation showing conversion of records ol such m spec tion be rc t amed for two y ears.

results to the required microcune units. Survey instruments are generally not designed for such measurements and may Internal msFct:ons, mtluding esaluation of radmgraphers, not be acceptable f or this use; should be made by a penon of authenty m m.magement.

l hese Unpet tions Inay be anninint ed or tillannimnced as (3) a dek ription ()! the inaterial to be used in taking necesur) to ensine comphance with Part 34. l his penon the smean. the points on the equipment that will be should h.nc a thorough knowledge of eqmpment, proce-smeared hmears are not normally taken direttly from the dures. and regulations and lesel of to.upetense at or abose surf ace of a source;sce paragraph 34. '5(c)),

that c\\ pes led of a radiographer. Manuement should make a cimlinising resiew ot quartell) InsentoTie% u t ih/ 3 t ii di 14 ) t he radiatitm %ifety pnhedures to be [tdloWed logs, res ords of res cipt and dnpoul of htensed matenal, dunng the smeanng process, the method f or handhng and l

penonnel momeonny results, and sur c) results.

disposing of the smears; and 10tA

(5) a desc ription of the pertinent training and tions, or deletions. References to previously submitted experience of cath persoa who will take or evaluate the information and documents should be clear and specific f

smears.

and should identify the pertinent information by date, page, and paragraph.

Distributors of sealed sources usually supply a certificate with each source giving the results and date of the last leak The application for license amendment must be accom-test performed on a source if such a certificate is not panted by the proper fee (see s 170.31).

retened, the source may not be used until a leak test has been performed and the results of the test showing that the

6. RENEWAL OF A LICENSE sourte is not leaking 01 contaminated have been received.

Ihereaf ter, the source must be tested for leakage anJ Byproduct material licenses are issued for a period not cantamination at intervals not to exceed 6 nionths. Records exceeding 5 years.

of the testing identifying each source tested, the date of the test, and the results of the test in units of microcuries must An application for renewal of a license must be filed at be maintained for Commission inspection.

least 30 days prior to the expiration date as provided for in paragraph 30.37(b) to ensure that the license does not

5. AMENDMENTS TO LICENSES expire until final action on the apphcation has been taken by the NRC.

I icensees are required to conduct their programs in accordance with statements, representat;.ns,and procedures Renewal applications must be filed on Form NRC-313R contamed in the beense application and supportive docu-appropriately supplemented and should contain complete ments and in the conditions of the license. The hcense must and up-to-date information about the applicant's current there f ore be amended if the licensee plans to make any program. The renewal application must be accompanied by changes in tacdtties, equipment (including monitoring and the proper fee (see 170 31).

surs ey instruments), procedures. personnel, or byproduct materul to be used.

10 facihtate the resiew p rocess, the application for l

renewal should be submitted without reference to previously l

Apphcations for license amendments may be filed either submitted documents and information. If such references on the appheation form or in letter form. The application cannot be avoided, they should be clear and specific and should identity the license by number and should clearly should identify the pertinent information by date, page, p

describe the exact nature of the requested changes. addi-and paragraph.

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l 10.6-5

e APPENDIX A CAllBR ATION OF INSTRUMENTS

1. Cahbrahon of suncy meters should be performed with inverse square law may be used with any point source to rathonnchde sou rces

• that approumate point sou rces, calculate the exposure rate at other distances. The radio-active decay law may be used to calculate the output at any

a. 'Ihe source acinities should be traceable within time after the specified date.

50 accuracy to the U.S. National Bureau of Standards

( NllS i cah bra tion s.

a. Inverse Square Law

b. Section 34.24 requires that survey instruments be if R, is the exposure rate at a distance D from a a

calibrated at intervals not exceedmg 3 months and after point source and R is the exposure rate at a 6 stance D b

b servicing from the same point source, then

c. I ath scale in the range from two mdlaroentgens RUa" NU a

b per hour through one roentgen per hout is required to be cabbrated. Other scales should also be cahbrated.

Note:

R, and Rb must be in the same units of exposure rate (e.g., mR/ hour, R/ hour, etc.) and D nd Db must be a

d.

De lughest and lowest points used to calibrate in the same units of distance (e.g., centimeters, meters, cat h st.de of the instrument should be separated by at least etc.).

50'? of the s; ale.

if R,, D '

"d U, are known, Rb can be calculated from a

t e.

lhe exposure rate measured by the instrument l

shouhl be wohin t20 ? of the exposure rate specified for 9 2 the standard source.

R

• N b

a b

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f. A cabbration chart or graph contaming the cabbra-tion f actor, the date of last cahbration, and due date of

b. Radioactive Decap Law nest t abbration should be af fixed to the suney meter.

The exposure rate of a standard source at a time, t, after

2. ihe use of the small theck source that is mcorporated a specified cahbration date is given by mto some suncy meters is not approprute or acceptable y

for cahbration purposes.

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3. Section 34.24 requires that records of the calibrations w here i

discussed in item I he maintaine l.

l Il is the exposure rate at a time t :ifter the source t

4 Ihe mscrse square law and radioat tive decay law may calibration date be used f or cahbration. A calibrated source will have a calibration certificJte gWing itS output Jt a fuen distance R

is the exposure rate on the day of Calibration g

measured on a specified date by the manufacturer. The t

is the time elapsed since the calibration date T., is the radionuchde half 4ife i

'Sourt es of t e'eu rn-13 7. radium-2 26.or (obalt-60 are approrrute for use in cahbrahons. I he actant) or the whbrahon standarJ should be sunioent to abbrate the surves metsrs on all ranges up to one Note:

R, and R must be in the same umts of exposure g

roentren per hour. If there are higher ranges, they should at least be rate (em m RMour, R/houn etcJ and t and T nmt be in thetked for operation and ap pr o u m at el) correc t response to gz ra hahon the same units of time (e.g., seconds, days, years, etc.).

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APPENDlX B OPERATING AND EMERGENCY PROCEDURES Section 34.32 of 10 Cl;R part 34 requires each licenser mstruction should also state the steps to be taken if the to provide radiography personnel with operating and si.ney lesels exceed acceptable limits.

emergency procedures, lhe purpose of this reipiirement is to provide radiography personnel with clear and specific (3) If radiography personnel will perform instrument mstructions in the topics hsted in s 34.32 and in other cabbration, step-by-step inst ructions should be in the duties and responsibthties that radiography personnel ma) procedures.

hase. Other duties could include instrument cabbration, leak testmg, quarterly inspection and preventive maintenance (4) If radiography personnel wdl perform leak testing 1

of equipment, and shipment of sources and destees. ihe of scaled sources, specific instructions for performing the operatmg and emergency procedures for personnel should leak test should be in the procedures. If the applicant will not contam information that does not apply specifically to use commercially available leak-test kits, the instructions the duties of radiography personnel; for example, reither and procedures provided by the kit suppliers should be the trainmg program nor the management control program modified to fit the applicant's program. For example, many should be irstuded in the operating and emergency proce-kit procedures indicate that the manufacturer of the source i

dures should be notified if a survey of the leak-test sample indicates a potentially leaking source. In3tructions should The operating and emergency procedures should be mdicate that management will be informed since dealing I

tadored to fit the program proposed in the apphcation. The with suppliers is usually a management function.

procedures and instructions should be complete and self-I contained in a single document or in a clearly desigruted

b. Alethods and Occasiems for Cemducting Radiation part of a broader scope document that includes related Surreys. The procedu res should identify when sur eys material such as a description of the management control should be made, w hat should be surveyed, acceptable p rogra m. Inf orm ation contained in eqmpment manuals radiation levels for the surveys, the steps to be taken if and other publications should be extracted and inserted accept able les els are exceeded, and records of survey into the operating and emergency procedures so that the results. In general, a survey should be performed each time mstrut tions to personnel are clear, speedie, and appropriate a source is manipulated or mosed. Surveys that need to be for the proposed procram. lhe instructions contamed m performed include:

the operatmg and e me rge ncy procedures should be in language that can be easily understood by radiography (1) Determination after each ex posure that the personnel. Where appbcable, in st ruction s for u se and source has returned to the safe storage position. The entire handhng of desices incorporated mto permanent radiographic circumference of the radiographic device must be surveyed.

installations should be separate and distmet from those for if the radiographic exposure device has a source guide mobde or pos table devices.

tube, the suncy must include the guide tube.

ihere is no speutic format for optratmg and emergene)

(2) Determination of the boundiry of the restricted area.

procedures. Ilowever, a sequentul set of instructions that cosers rathography operations f rom the beginning of the (3) Determination of radiation levels at external workday to the end of the workday is an acceptable format.

surfaces of storage facilities.

lorics that shouhl be meluded in the operating and emer-gency procedures are (4) Deternunation of radiation levels in and around schicles used for transporting or storing sources and desices.

a. Ilandime and Ihe of ficensed Scaled Sources. Radio-graphic Evpomre flerices Source Eschangers, and instru-t5 > Determination that the source is in a safe storage ment Calibration Equi;> ment, position prior to secu ring a radiographie ex posure or storage container.

t!) Step-b> -step inst rut tions of the " cookbook" type for the use and handhng of radioguphie exposure desites (6) Determination that containers prepared for ship-j

/

and related equipment should be prosided.When appropriate, ment comply with the requirementsm Department of Frans-1 the procedures should include instructions for use of radia-portation regulations (for example,10 mR/hr at 3 feet from tion collunating cones or other ausdiary shieldmg materut, an> surface and 200 mR/hr at the surface of the contamer).

(

12) It source exchange will be performed by radiog-Ihe acceptable radiation levels for surveys should be raphy personnel, step-by-step inst ructions for sou rce expressed in nulbroentgens per hour.

eschange, moluding sur e)s to be performed durmg the source cu hange and t'or shipment and acceptable radiation Section 20.401.md paragraph 34.43(c) require that les els for these survey s, should be in the procedures. Such records of specific surveys be maintained. Judgment by 10.6-7

l NRC bcensees a reapared for nuintaining records of other wntten and avadable. Instructions should further specify suncys respured by the regulations in winch maintenance that surveys to determine that the sealed source has returned

(

of the inonh n not specified in the regulations. NRC does to the shielded position alter an exposure are required l not espec t rashographers to record cah and every reading by M 34.43 and, in the case of a radiographer's assistant, taken dunng a suncy. llowewr, recorth should be com-they snust be inade under the personal supervision of a piele enough to show cleaily that proper surveys have been radiographer ( Q 34.44). Sec tion 34.43 requires that a done record of the last suney inade prior to locking the radio-graphic exposure device and ending direct surveillance be Stethods for Controlhng,1ccru to Radurgraphic.f reas.

niaintained f or two years.

t.

Insina tions for con t rolh ng actess to rathographic areas should be speethcally stated in the procedures.

Instructiorn and procedur s for storage of sources and deuces at both pernianent and temporary job sites, including

(

the boundanes of raihation areas and high radiation locking of devn.cs, posting of storage areas, and surveys areas are re<puted to be posted. "Cautnin' Radiation Area" around the storage areas, should be in the procedures. The l

s!yns shouhl be posted at the boundary of the restrich d area outside storage areas should niert the requirements for I

area, and "('autnin' liigh Raihahon Area" signs shoulu 7e an unrestncted area.

posted at the boundary of the lugh radiat on area. llish i

I raduhon area signs shouhl not be used at the boundary of a

e. Personnel 3fonitoring and the Use of Personnel Ston-restncted area. these signs shouhl be used only at the itoring Fr;uipment. 'the instructions should contain require-bound.n y of a lugh raihalion area.

ments for radiography personnel to w"ar their personnel monitonng desices so that any exposure received wdl be Ngns, by themsches. do not pnevide an adequate means acc urately reflet ted by the devices. lhe instructions should of an ess tont ro!. l or ia hographic operations pertornied be specific.

outside a pennanent rashographic installation, instructions re.pming sonedlance of the area to present unauthorved l'requent readmgof pocket dosimetersshould be required penons trom entenng the area are necessary. l'or penna-so that personnel may be aware of the exposure that they nuy nent r aJ o ig ra pluc unt alla tions specific instructions con-hase receised. An instruction concernmg steps that must be termny use of mtcihn king deuces and sy stems locking of taken unmediately by radiography personnel m the event a the f at ih t ). sn unty of key s, use of warmng hghts and dosimeter is found to be ott scale should be included in the alanns eit., sin nild be included m t he procedu res.

protedures, this instruction should indude the requirement stated in paragraph 34.33(c) that an imhvidual's fdm badge

{

I lhe mst rut t u ms for c on t r ol of access to permanent or ~1 1 1) be precessed immediately if that inthvidual\\

r.nhographic installations should be separate and dntmt t pocket dosuneter n thscharged beyond its range. Instruc-Inun the mst r uc t ions f or temporary job-site operations tions for storage of permnnel monitonng deuces should be included m the procedures.

A spet dat ahon of a rathahon level of 2 nnihroentgens per hour f oi the boundary of the restncted area and 100

t. Iransporting Scaled Sources to Field l.ocations, PacA-nulhioe n t ge ns per hour for the bou n d.iry of the lugh aang of Expomre Derices and Storage Containers in the radiation area n.n ceptable. A physwal survey with a sune) fehicles, Postmg of I'ch#cles, and Control of Scaled Sources meter should be performed to t onium the 2 mdhroentgens Durmg fransportation. Most transport of radiography per Inio r raihation level for the rest nt led area boundary sou rces in exposure devices or storage containers over alter the wurce has been esposed it n neither nec essar) pubhc roads is subject to the regulations of the I)epartment nor desnable f or a phyucal suncy to be made to contum of I ra nspor t a tion (49 CI R Parts 17018u, 390-397).

the ra harion lesci at the boundary of the high radiahon t hese regulations cover, among other things, permissible area sun e suc h a 3uncy could lead to unnecessary exposure radiahon levels around and within a selucle and placarding i

of penonnel, of the schicle dunng transport. I:ven in those cases in which the Department of I ranspiirta tion regulations are not Appht ant s may unh to tram their radiographers in the normally appheable (such as in t rast a t e transportation),

j use of the 2 mdhrem m any one hour cntenon and thus 10 Cl R Part 71 of the Nuclear Regulatory Commission's peinut raduhon lesch m unrestncted.ucas to cu eed 2 nulli-regulations requires conformance to the standards and 1

toentrens per hour, in flus t ase the operatmg and emergent >

icquuements of the 1)erartment of Iransportation.

pu eduies should int lude step-by -step untructions for con-trolhne the durahon of and reconhng eac h esposure to lhe procedu res should contain ins t ru c tion s on how enmre that the Imots of 2 nulbrem in any one hour ami 100 e s posu re deuces or storage containers w dl be secured nulhicm m any 7 t onsecutn e days are not exceeded.

withm the transporting schitle to present shifting within the schicle. ihere should be instructions for placarding of d Methodi and ficcanons for loc Amr and Securing the schu le dunng transport. t he llepartment of I ransporta-Radmgraphic f tpomre Derices, Storage Contamers, and lion regulations reqture "R AI)lOAUllVI." placards on all i

Scaled Source t hatint tions ic puring sec u rm g of the four sides of the ulucle when a par kage with a " Radioactive I

aposure deut e af ter t ompletmn of the e-nosure should be Yellow-Ill" 1. 'cl is shipped. Ihere should be instructions f

for suneys in and around the vehicle. 'Ihe radution level m n u D.mm the passenger compartment shouhl not exceed 2 milliroent-10 (,-M

l gens per hour. Although it is not specifically required for should contain specific inst ructions for inspection of L

transport, there are occauons when the area outside the equipment and the actions to be taken if any defects are velucle should be considered an unrestricted area so that a found. A checkhst should be contained in the procedures specific a tion of a radiation level of 2 milliroentgens per hsting the items that should be cosered in the daily inspec-hour at a datance of I8 inches from any external surface of tion. Equipment manufacturers may be helpfulin providing i

the vehicle should be provided.

information concerning dady inspections.

l When a vehkle is used for storage,i.e., when the sources inspection and presentise maintenance of equipment at

(

are not being transported, the posting requirements in intervals not to exceed three months or prior to the first 10 CFR part 20 are apphcable, and the schicle should use thereafter are also required by @ 34.28. If radiography therefore be posted with Taution-Radioactne Matenal" personnel will conduct these inspections, the procedures sign s.

ihe area outside a schitle used for storage is an should contain clear and specific instructions for inspection l

unrestricted area, and the radiation level at 18 inche3 f rom and maintenance. As part of the inspection and presentne i

the surface of the vehicle should not exceed 2 milliroentgens mamtenance program, all connectors, drne cables, source per hour.

guide tubes, on-off indicator mechanisms, and moving parts should be chccked for defects and excessne wear. Cables p, Jhnirmring I'xpomre of Penons in the lirent of an should be cleaned and lubricated, and all detective and

.f cchlen t. Instnictions to personnel shouhl include proce-e st essn ely worn components repaired or replaced. If dures for minnninng the exposure of persons in the event components essential to the sale operation of the desice are I

of an accident or other anusual occurrence, possible malfunc-found to be defective or in poor operating condition, the l

tions of equipment should be considered, and sters to follow device should be immediately remmed from service until m each case of malfunction should be specifically set f orth.

repans can I,e made. An instruction to be followed in this

(

event shouhl be written. Records of quarterly inspections lhe protedures should contam c, ir and spetilic instruc-and maintenante must be kept for two years.

tions concerning emergency situations. ihe steps to be taken by radiography personnel should, in general, be Visible and audible warning systems used in a permanent knuted to (l ) suncymg the area,(2) establishing a restricted radiographic installation should be tested and records made area, 0 ) notdy mg appropriate persons, and (4) maintaining thereof at intervals not to exceed three months pursuant to ihrect su n edlance and control over the area until the y 34.28. Other area safeguards, which may melude door situation a corrected.1.unitations on action that may be and equipment interlocks or access-door locking devices, taken by rathography personnel should be clearly specified.

should be tested for proper operation at least once escry six F

the at tem pted recos cry of a source that has become months. lhe procedures should contam instructions for detacheit trom an exposure devite, an operation that may performing suc h inspections if they are to be performed by result m exposure to lugh levels of radiation, should not be radiography personnel.

attempted bs radiography personnel u nless specifically trained and expenenced in source retrieval.

k. Off-Scale PocAet I)osimeter Readings. procedures to be taken unmediately by radiogra phy personnel in the

h. Procedure for Notsfying Proper Persons in the 1: cent event a pocket dosuneter is found to be ottscale should of an.f ccident. lhe names and tePphone numbers of the intlude the followmg instructions:

persons to be contacted in tasc of m accident should be spet t hed.

t1) Stop work immediately;

i. RecordAcepme. lhe mstructions to personnel should t2) Initiate emergency procedures if the source is sproty those records that must be mamtamed by personnel exposed and cannot be retracted; otherwne, tetract the j

during the course of their woik. Among the records that are source safely;

(

normally kt pt b) radmgraph) personnel are dosuneter icadmgs, suncys, and daily inspection of equipment. Other O) Notify the ladiation safety ofhcer immediately.

records should be included if they are the responsibdity of In this regard the name of the radiation safet) of ficer and ramography personnel. Records for which manacement and the manner in which this individual can be reached should su pe n nor) penonnel have responsibihty shouhl not be be included, intludcJ m the operating and emelpency p roc edu res.

L Product Slalfunctions and Ibefects. If the radinerapher

t. Inspection and liaintenance of Radweraphy Frpoinre datosers any malfunction or defect in the equipment, the I)n scri. Ntorage Contamen, and Source Changers. Sec tmn radiographer should notify the radiation sately officer.

I 34.28 requires a check for obsions defects m radiographic procedures to be followed in such an esent should tell the esposure devices, stoiace contamers, and source changers radiographer what to report, when to report the problem.

poor to use cath day the equipment a used, the procedures and the indnidual to whom it should be reported.

10.6 9

APPENDIX C TRAINING PROGRAM radiography lhense a required to and the method to be used to determine each trainee's com-An apphcant for a have an adequate program f or the traimng of radiographers petence in accordance with 4 34.31 should be ini.luded in and radiographers' awntants. With respect to radiogrJphy the program dest nplion.

ptw m nel, two im por t a n t ponits should be understood:

( 2) Un thedob fraining, flie penad of on-the-job (1) lhe duties and responsibihhes of the rathographer training under the supervision of experienced personnel, may not he delerated to the radiographer's awstant. A including trainee use ind observation of the use of radio-radiographer must be physically present at the location graphic exposure devices and associated equipment,should w here ra(horiaphy is bemg performed. A rathographer's be specified. liowever, no individual should be permitted to awstant niay pertorni source mampulation. surveys of the enter into on-the-job training untd completing the require-raihorraphh deuce to determine source location etc., only ments for a radiographer's assistant. The content of on-the-m the phyucal presence of a radiographer, in accordance job traimng and the minimum time that wdl be spent in it w it h i 14.44.

wdl be dictated by the appbcant's scope of operation, the sancty of the work, and the aptitude of the tramee and 12 6 Any mdanlual who awsts a radiographer by mamp-should be specified in the application. Usually a mimmum ulating r.nhographic e x posu re devices, scaled sou rces, of three months of full-time equisalent work as a radiog-related handhny tools, or sursey instruments is actmg m the rapher's assistant should be provided.

l carat if y of a rathographer's asustant and must meet the I

icqunements of paragraph 34.3 )(b).

(3) Examinations. A com prehensive examination i

lhe destoption of the wmplete traimng program should containmg approximately 50 questions cmcring all items in mtlude the seepiente of events m the traimng of a penon to Appendix A to Part 34 would be considered to be an l

hecome a ra.horiapher or ra.horrapherN assistant from the adequate cxamination to quahfy md.viduals as ra diog-lune of hump through the tune the job begins. '; int e raphers. In addition, a practical or field examination should l l'ar t 34 has dif f erent requucments for radiographers and be administered to determine the competency of radio-rad o yra phers' aw stan t s.

se pa r a t e narratnes pertam.ng graphic trainees to perform surveys, posting, operate equip-to the tramme of indanloals f or each category should be ment, etc. Additional information is provided m Item 3, subuntled. In aihhtmn, a finrd narratne pertanung to the

'lesting Proc e d u res.'

Successful candidates should be trauung of mJnnloah who are hired with presious traisung gnen aJditionalinstruction in those areas where the examina-and e s pc nent e mn be de v ra ble. lhe narratne should tion indicates weakness.

mtlude apprornate ref erentes to the more detaded desenp-hon of cat h of the unous parts of the training program dew nbed m ao ordance with the items identified below.

b. Radiographers' Assistants

1. Imtial I raimng (l) Classroom Traini. A desenption of the trainmg program for radiographers' assistant trainees should be given.

a liadso craph rri Paragraph 34.31(b) specifies training requirements and the subjects in which radiographers' awistants must demonstrate (1 i Claurnom Iraming. A dest nption of the manner u nderstandmg and competence. The description should m winch rathographer trainees wdl be instructed in all areas contain a detailed outhne of those items covered in the of \\ppenihx A to 10 ('l R part 34 should be gnen ~l h e operating and emergency procedures and the use of radio-sounc wnt e n t should mtlude a detailed outhne of the graphic equipment and should specify the approximate lophs m Appendix A to Part 34 and the JpprosimJte time tuae to be spent on each major item listed in the outline.

to be spent on cas h maior.nea of mst ruc tion should be spet thed. l'or Indniduals with no presn eus trainmg, approxi-match W hours of clissroom traimng should be nrouded

( 2) lixaminarmns. A comprehensive exanonation con-m the subjects nientined m AppenJn A to part 34.

taming approxinutely 25 questions caering tne applicant's operatmg and emergency procedures and the use of radio-A traimng worse gn en by an ou t u de se rvice graphic equipment would be considered to be an adequate organuat on usually will not in st ruc t the trainee with examination to gtuhty individuals as radiographers' assistants.

respect to an apphcant's partwular equipment. lat ihties, Additmnal information is proviJed in item 3, "Testmg l

and prm rdures. lherefore, if outside tr.nmng is to be used.

Procedures." Successful candidates should be given addi-mstructum gnen to supplement that traming with respett tional mstruction m those areas where the exammation to the appla ant's ow n capiipment, facihties. and proc edures mdicates weakness.

10.6-10

(

l

(

c. Expenenced Radiographers and Radiographers' A list of subject areas for the field examination should A ssistants be given and should include, as a minirnum, performance of C

radiation surveys, posting, operation of equipment, emer-I liecause of diff erences in procedures, equipment, etc.

gency procedures, and other items of radiation safety that it is unkkely that a new employee will be adequately may be encountered in the discharge of duties.

prepared to work in a particular program without some training specifically related to that program. Also, each A description of the testing procedure is not complete t

hcensee is required by @ 34.31 to determine that each indi-without a clear and specific description of the criteria and t

vidual is quahfied to act as a radiographer or radiographer's procedure to be followcd in evaluating test results and awistant m its own program. ihe applicant should therefore determining whether an individual is qualified to act as a destnbe the procedure for determining the knowledge and radiographer or radiographer's assista n t.

'Ihe relative c om pe t enc y of individuals and for providing ad.htional unportance assigned to cach question or area uf performance, training af needed.

the minimum acceptable number of correct answers orpioper responses, and retesting procedures should all be given.

2. periodic Iraining

}

The points within the training program at which each l

perioche tr.uning should include a descnption of the test wdl be given should be clearly indicated. Ilor example,

}

content and scheduhng of traimng sessions gnen for the som e trainmg programs include a written or oral exam i

purpose of ensuring (i) the knowledge and proficiency of following the initial training pilase, followed by an oral and J

radiographers and radiographers' assistants with respect to practical exam at the close of the on-the-job training phase.

new regulations, procedures, poheies, and equipment and l

(2) continumg proficiency with present equipment and Note that testing procedures must ensure compliance procedures. penodic training should be conducted at least with s 34.31. If a trainee is to be utdized as a radiographer's annually.

assistant during the training period, the trainee should be tested and qualified as a radiographer's assistant before 4 lesting procedures assumir g those duties.

A dew nption of exh test to be given should be submitted.

4. Instructor's Qualifications i

Radiographers must successtully complete a wntten test and a field examination of the subjects covered in traimng.

The person who makes the final determination of the Radiographers' assista n t s must successfully complete a adequacy of a traince's knowledge and competency should w ntten or oral test and a field exauination of the subjects he a qualified radiographer with a strong background of sovered in training. A desenption of an oral or written test training and experience with radiation. On-the-job trainin; may be given by submitting a sample test with an answer must be given by someone who is, as a minimum,a qualified f or each tpiestion.

radiographer.

The ellectiveness of any test is reduced if the test is

5. Records gnen repeatedly so that the students gam knowledge ofits content. 'Ihe course desenption should clearly indicate that A copy of tests gnen to each trainee, records showing each test is a sample only and that the test content will be trainee performance in each examination (includmg oral changed at a stated nunimum f requency.

and practical examinations), and the examiner's overall evaluation of the trainee as qualified to act as a radiographer A descnption of an oral ex annnation should be gnen m or radiographer's assistant must be maintained for a period the same form as a wntten exanunation, of three y ears.

10.6-11

91 APPENDlX D i

PROGRAM RESPONSIBILITIES AND MANAGER QUALIFICATIONS

'Ihc individual assigned the duties of maintaining active

7. INamining and determining competence of radio-management control of the program should be a qualified graphic personnel.

radiographer with traming in the use of the types of equip-ment proposed in the appheation and should bear the title

8. listablislung anti maintaining storage facilities.

of Radiation Saf ety Of ficer, Radiation Protection Of ficer, or other smular designation.'lhorough knowledge of rnanage-

9. Ntaintainmg exposure devices, radiography facilities, ment policies, company administrative and operatmg proce-and associated equipment, dures, and safety procedures related to protection against radiation esposures should be prerequisites for the position.

10. listablishing and mamtaining the leak-testing program.

Alternates meetmg the same quahfications should be desig-l nated to assume these functions when necessary.

I1. listablishing and maintaining the internal inspection system.

A hst of the duties that may be performed by the

12. Performing source replacement operations, licensee's management personnel is presented below. It is not intended to be all inclusive noi should it be interpreted

13. Conducting quarterly inventories and maintaining as a requirement that any one person assume all of the utdization logs.

hsted duties. Some duties may be delegated to persons of lesser authont y.

14. listablishing and conducting a survey instrument calibration program, i

I. Serving as the hc e nsee's liaison officer with the

15. listablishing and maintaining the licensee's record-Nuclear Regulatory Comnussion on license matters.

keeping system.

2. Mamtaining control of procurement and disposal of

16. Reviewing and ensuring maintenance of those records htensed material.

kept by others.

3. llevelopmg and maintammg up-tostate operating and

17. Assuming control and instituting corrective action in emeigency procedures emergency situations.

l 4.1 stabhshing and maintaining a prisonnel monitonng

18. Investigating the cause of incidents and determining pr ogr a m.

necessary preventive action.

5. Proconng and maintaming radiation survey instru-19 Acting in an advisory capacity to the licensee's manage-ments.

ment and radiography personnel, f>. 1-1stabhshmg and conducting the traming program for

20. I:stablishing a procedure for evaluating and reporting radiographers and rathographers' assistants.

defects and noncompliance pursuant to 10 CFR Part 21.

l l

l Ol l

10.6 12 l

EXHIBIT A l

l'orm NRC.313R U.S. NUCLE AR REGULA TORY COMMISSION Q

'7-778 APPLICATION FOR BYPRODUCT MATERIAL LICENSE-Approved by GAO 10 Cl R 34 15180255(R0335)

USE OF SEALED SOURCES IN RADIOGRAPHY

~

(SEE ATTACHED FORM NRC-313R INSTRUCTIONS AND NRC REGULATORY GUIDE 10.6-USE SUPPLEMENTAL SHEETWHERE NECESSARY)BE SURE ALL ITEMS ARE COMPLETED AND THAT ALL NECESSARY ATTACHMENTS ARE FURNISHED. IF ANY PORTION OF THE APPLICATION IS NOT APPLICABLE SPECIFICALLY SO STATE.

DEFICIENT OR INCOMPLETE APPLICATIONS MAY BE RETURNED WITHOUT CONSIDERATION. LICENSE FEE HEOUIRED, SEE ITEM 7 OF 1"CT'"JCTIONS.

Io: NAME AND ADOkt % OF APPuc. ANT AND fit i PHGNE NOMHEH 2 T HIS IS AN APP LIC A TION F CR ; (Check appropodfe stem)

A. U NEW LICENSE B C AME N DME N T TO LICE NSE NO.

Ithi TE Lk : eiON E NO. Area Coste (

)

Aa ndiv ;fuoi E_l A portaesship 0 A Corporge.on0 Aa 1 LOC AfiON(5l wHf et 5f Alf D SOURCES will flE USED AND,OR STOntD. f 8f wee 1(- ) APPti( ANT 15 l

Id M lesW here )

Ua.a< oepo,o ed Aisne. oho.

Othes if opphtoat is o** or eboa on sad id s

wel. the oppi.s ob's se e.oa on the ve,eese s.de mvd he < ompleted 4,

LL A LE D SOU RCE S TO BE USE D IN R A DIOG R APHY ( Attas.h supplement.sry pages, if necessary )

^

MAX UM ACTIVITY S U HCE MODE L NUMfiE R N AME Of M ANUF ACTURE H NUMBliR OF SOURCES f le n f rd a

p A

A A

A.

A.

II U

U R

0.

C C.

C C.

C.

5(al H ADIOG R APHIC E M POSU HE DE VICES ( Atts h s.spplementary pages, it necessary )

MODF L NUMBE R N AME OF M ANUf ACTU RE R (Incfdde descrPfion sf custom nhedel A

A O

O g

\\

C C.

1 a ted H ADIOGH APHIC SOURCE CH AN GE HS ( Attach supplementary pagers, et necessary )

S VODE L NUMHf R N AME OF M ANUF ACTU RE R (/ncierde desenpfron,f custom madel A

A 11 B

C C

6 f HE FOttOwinG INFOeM Af TON 15 Aff ACHf D A5 A PAei OF THis APPtiCAfiON (Chea appeope. blodi and o*och n 8ermet.on coiled for sa che.aseewheas..sh th e form )

Not Applicable Ase thed Preweously submefted n

(o) De.ce pboa of rodmgraphs. hw e..h-s L ashwttion 6 - c) l on (c a'e i tbl Desie ption of eo4ahon dete< eion svinhumea's to be used (lathutt.on 6-b)

]

oo (caul (4

la.*vmea* <eht. oe a peosedures nashw.on 6 4 e

on (cate)

(d) P.sonaef nion.io.ng ego pment (las=w..oa 6-d)

]

oo (cate) lel Operohag and emeegency peotedures (latant.ca 6 -el o,,

( A fro.n.ag pregeom ilastevet.on 041

] on to in mol..peo.oa., em e, o+ee o-gemen. coauoi pas.sw..o *-o O

oe.

~ O.e.o,1 e.g,a....

e,.,...~. ;,e,s

...e. 6. m o,,

i I

i.i t ea.

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EXHIBIT A (Page 2)

F OHM N HC 31JH ( /- 71)

LEGAL STRUCTURE OF APPLICANT l

If appl. cont is o c orporot.on, tortiplete items d tNrough 11; if oppigant es o portnership, complete l' ems i 2 through ) 4, if opphtont is on unincorporoted ossorsoten or o legal entity other than a pc<merth.p or corporotron, complete items 15 and 16 Attach separote sheets where space prov.ded proces in.

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VALUE/ IMPACT STATEMENT

1. BACKGROUND quarter. The present guide only recommends that such procedures be implemented; revision is necessary to retlect Industnal radiography accounts for more than two-thirds the new requirement.

of overexposures greater than 5 rems to the whole body and greater than 75 rems to extremities and 90% of over-

4. Section 34.29 was amended to require an alarm exposures greater than 25 rems to the whole body and system for warning anyone er.tering a permanent radio-greater than 375 rents to extremities.

graphic installation during source exposure. The present

)

guide asks for a description of such a system only if it is Lffective March 3.1980,10 CFR Part 34 was revised to present in the faedity. Revision of the guide is necessary to reduce operator exposure. ~Ihe new amendments place reflect the new requirement.

stricter requirements on trammg. supersision, and periodic performante evaluation of radiographers and radiographers'

5. Section 34.31 was amended to require documented assistants. Also, stricter mspection and sursey procedures testing of radiographers (written and practical) and radiog-for exposure devices and sources before use each day and raphers' assistants (written or oral and practical). The each tmic the source is retracted to its shielded position will present guide only recommends testing and does not reduce exposures caused by equipment malfunction and specify the type; revision is necessary to reflect the new operator error. Further requirements on alarnts for permanent requirement and to specify the manner of testing and the radiographic installations, on avadabihty of survey instru-materials to be covered.

s ments, and on use of personnel monitonng devices are designed to make the operator more aware of the hazards

6. Section 34.43 was amended to require surveys of of radiation.

radiographie exposure desices, including the source guide tube, after each exposure. The present guide only recom-1

2. THE PROPOSED ACTION mends that the survey of the guide tube be made; revision is necessary to reflect the new requirement.

2.1 Dncription m

7. Section 34.44 was amended to require the physical

,-j lhe appheant for a heense to use industrial radiography presence of a radiographer at the site where sources are sourses is requaed to develop a program that complies with being used by radiographers' assistants. The present guide Commnsion regulations and to describe this program in the does not address itself to this situation; revision is necessary appheation for the license. Regulatory Guide 10.6 Jetails to reflect the requirement.

radiography program requirements and provides guidance in estabbshing a comprehensne radiation safety program. The 2.3 Value/ Impact proposed resision incorporates the latest amendments to the regulations.

2.3.1 NRC 2.2 Need The review and approval of applications for use of radiography sources are considerably facditated by the use lhe recent amendments to 10 CFR Part 34 necessitate of a standard format, the instructions for which are provided extensive reusion to the regulatory guide Ihe amendments in the regulatory guide. The guide clearly details the regula-and guide changes are as follows:

tions to be followed and the information required for licensmg and implementmg an acceptable program for the

1. Section 34.1I w as amended to require that an use of industrial radiography sources. Staff review time is mternal inspection program of a heensee's operations be shortened because of the use of the standard format and conducted at intervals not exceedmg 3 months. The present the reduction of unnecessary correspondence resulting from guide only recommends a program of inspection; revision is the lack of sufficient detail in license applications. Revision I

necessary f o rellett the new requirement.

of the guide will reduce additional correspondence that would result because of the regulation changes.

2 Section 34 22 was amended to require securmg of the f

sourt e m each radiographic exposure device each tune the 2.3.2 Other Government Agencies soo n e is returned to its slucided posit:on, t he present gmde only recommends that such procedures be imple-Other government agencies should not be affected.

f mented; reusion is necessary to reflect the new requirement.

2.3.3 Industry

-]

3. Section 34.28 w as amended to require that radio-J yra phic exposure desices. storage containers, and source

!he regulatory guide contributes to the reduction in thangers be checked for obsious damage each day before time required for industry's preparation of a license applica-use an I be comprehenmely inspected and maintamed each tion. Industry will spend less time trying to interpret NRC f

10.6-15

l regulations and requirements for subminion of inforrnation.

4.2 Discussion

\\ lore importantly, the revised guide will provide information for the design and unpNmentation of a more elfective radta-A guide is the more ef fective way to transmit informa-tion safety program, thereby nunimiting the radiation to tion about regulations and licensing requirements. A guide wor kers.

ensures umfo.m transmission ofinf ormation to the licensee.

Indnidual letters would be ine'ficient and, dependmg on 2.1-1 Public the resiewing ottiaal, may not uniformly consey the same information to each hcensee. Contmuance and revision of No impact on the public is foreseen.

the guide is the most ef fectne alternative.

2.1. 5 WorArr

5. STATUTORY CONSIDERATIONS lhe worker wdl benefit f rom the restsion of tFe guide 5.1 NRC Authority through reduced radiation exposure diwussed in item 2.3.3 above.

Ihis guide interprets regulations promulgated in 10 CI R Part 34 2.4 Decision 5.2 Need for NEPA Assessment Ihe revision of this regulatory guide should be initiated because of the benefits previously discussed.

Ihe proposed action is not a major action as defined by 10 CI R s 51.5 and does not require an environmentalimpact statement.

3. TECHNICAL APPROACH G. FIE LATIONSHIP TO OTHER EXISTING OR PROPOSED llus set tion is not applicable since the propi.ed at tion REGULATIONS OR POLICIES is procedural. i.e. resision of a regulatory guide net essitated by regulation changes.

No conthe ts or oscrlaps appear to exist.

4. PROCEDURAL APPROACH

7.

SUMMARY

AND CONCLUSIONS 4.1 Alternatives The proposed revision to Regulatory Guide 10.6, when dissenunated, will assist the NRC in its resiew of applica-t he regulatory guide presently exists. Resision of the tions for use of industrial radiographie sources and will guule is necessary because of amendments to the regulation.

provide industry with guidelines for subnutting applications the only alternatne is to discontinue use of the guide and implementing optimum radiation safety programs. The altogether in f asor of indnidual letters to licensees.

proposed revision should be issued.

O 10.6-16 1

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UNITE D STATES I

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