ML20044F202

Forwards Conceptual Model of Radiography std,10CFR34,for Circulation to States for Comment.Comments Should Be Submitted by 930514

ML20044F202
Person / Time
Issue date:	04/01/1993
From:	Cool D NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To:	Miller V NRC OFFICE OF STATE PROGRAMS (OSP)
References
NUDOCS 9305270197
Download: ML20044F202 (75)

Text

{{#Wiki_filter:MEMORANDUM FOR: Vandy L. Miller, Asst. Director State Agreements Program Office of State' Programs FROM: Donald A. Cool, Chief Radiation Protection and Health APR Effects Branch I M3 Division of Regulatory Applications Office of Nuclear Regulatory Research l

SUBJECT:

RADIOGRAPHY RULE CHANGES Attached is a copy of the conceptual model of Radiography Standard,10 CFR Part i 34, which we would like to have circulated to the states for comment. We need [ to have comments by May 14, 1993. We will adopt these comments to the exter.t possible before sending the proposed rule on to the Commission and we will l indicate which comments could not be adopted in the Commission Paper. Please note that the conceptual model is presented in a side-by-side format with the i existing Part 34 to facilitate comparison. In order to assist in developing the impacts for the regulatory analysis of this rule, the we would appreciate answers to the questions listed in Attachment 2. j Please forwared this list of _ questions to the Agreement States with the' t conceptual rule language, and request their assistance in anwering the questions. j This memorandum and the Attachments will be placed in the Public Docunent Room. Original Signed By: Donald A. Cool, Chief Radiation Protection and Hea'th ( Effects Branch i Division of Regulatory Applications ~ Office of Nuclear Regulatory Research Attachments: 1 1. Discussion of the Conceptual Model i t 2. Questions for the Agreement States i Distribution: [AGREEMNT.ST) circ:chron t DACool/RPHEB rf CTrottier MLThomas 1 Offc: RPH :D .RP RA R Name: ML CT tier D ool Date: (t <////93 f(/ / /93 l RECORD COPY OFFICIAL,i j f j 5 9305270197.930401 i 8 PDR ORG NREA PDR g l a

(. r t i a F L t Discussion of the Conceptual Model 'i r l i. t f i 1 l J l ? l F

/ ? Discussion of the Conceptual Model I Table of Contents The draft Table of Contents contains eight subparts. The organization f is as follows: Subpart A-General Provisions j Subpart B-Specific Licensing Provisions Subpart C-Equipment i Subpart D-Radiation Safety Requirements Subpart E-Recordkeeping Requirements Subpart F-Notification of Incidents Subpart G-Exemptions Subpart H-Enforcement i 1 This organization follows the same general format used in 10 CFR Part l 39, which addresses radiation safety requirements for well logging. Each I subpart will be discussed separately. b Subpart A-General Provisions This subpart covers items of a general nature, such as listing definitions, and OMB approvals. It also describes the purpose and scope of the rule. 'i I ll t 'r 2 J t i i

Section 34.1 Purpose and scope, is basically unchanged from the existing regulation. Other NRC regulations which apply to radiography licenses are referenced in this section. Section 34.3 Definitions, contains the following new terms: "ALARA", " Becquerel", " Field station", " Radiation Safety Officer", " Sievert", and " Temporary jobsite". These definitions were added to define terms used in requirements not previously addressed in Part 34. The term "ALARA", which means as low as reasonably achievable, has been added to include procedures now explicitly required in Part 20. Previously this was only addressed in regulatory guides. The terms " Becquerel" and " Sievert" were added to reflect the Commission's policy on use of metric units in all new or revised regulations. The terms " field station" and " Temporary jobsite" were added since the use of radioactive material frequently occurs at sites that may not be listed on the license and there has been some confusion on whether special requirements must be met at these locations. The term "fleid station" is being used to designate those locations where radiography equipment is stored and from which equipment is dispatched to " temporary jobsites" where radiography is conducted. The term " Radiation S;fety Officer" was added to address the duties and qualifications of this individual. While the role of the RSO has long been recognized by the NRC as a vital function in the safe use of radioactive material, the current Part 34 does not address the duties and qualifications of this individual. f; The terms " Associated equipment," " Control device," " Exposure head," " Field examination," " Licensed material," " Periodic training," " Personal 3 r a

supervision," " Projection sheath," " Shielded position," and " Source assembly," while used in the existing regulation, were not previously defined. Both licensees and Agreement State representatives requested clarification of these terms. Discussicn of changing the definition of " radiographer's assistant" occurred at the November 1992 workshop in Dallas, Texas. Some Agreement States use the term, " trainee" to refer to a " radiographer's assistant" and require training similar to that required of a radiographer. The term " radiographer's assistant" has been retained but.the language in this draft rule, but the training requirements are upgraded to provide additional assurance that radiographer's assistants are sufficiently knowledgeable of NRC regulations. The rule language has been written to provide the flexibility for the second person to have training beyond that of a radiographer's assistant. This position could then equally be filled by a " trainee." The definition of a " Permanent radiographic installation" was modified to define what is meant by permanent, since some licensee's have been confused on when a facility was required to meet the requirements of a permanent radiographic installation. The definitions of " storage area" and " storage container" were modified to remove references to transportation. Specific transportation requirements are addressed in 6 34.35. t l Section 34.5 Interpretations, is standard regulatory language to state j that only the General Counsel of the NRC has the authority to provide interpretations of the regulations which will be binding on the Comission. I; Section 34.7 Information collection requirements: OMB approval, is unchanged from the current regulation, except for changing the section numbers 4 1 i i

which apply to the format of the draft rule and any new requirements. OMB clearance will be obtained prior to publication of any rule. Subpart B-Specific Licensing Provisions j i This proposed subpart provides the basic requirements for submittal of a I l license application. This draft subpart contains sections basically unchanged from the existing Part 34. I Section 34.11 Application for a specific license, is worded the same as Section 34.3 in the current Part 34. i l I Section 34.13, Specific license for radiography, is worded the same as Section 34.11 in the current Part 34, except for the following: Section 1 34.13(e), proposes a reduction in the frequency of field inspections of radiographers and radiographer's assistants from quarterly to semi-annually. For individuals whe have not performed radiographic operations for more than three months, an inspection of job performance would be required as in the existing rule prior to their participation in a radiographic operation. This reduction is in response to comments made at the Radiography Workshop conducted in November, 1992. A new requirement for conducting annual safety reviews has also been added to provide cJditional assurance that radiographers will be knowledgeable of current procedures and requirements. In addition, i the basic requirements for conducting thb field inspections have been relocated to i 34.43(d) to more accurately reflect its role in the training program. Section 34.13(g) is added which requires the licensee to designate 5

an individual on the license to fulfill the duties of the RSO. The qualifications and duties of this individual are specified in s 34.41. Section 34.13(i) is a new section which would require a list and description of all permanent radiographic installations and all permanent storage locations to be included in the license application. A permanent storage location is described as storage for more than 180 days in a calendar year. The time under which an area could be used temporarily for storage was chosen to agree with the length of time an Agreement State licensee may operate in NRC jurisdiction under reciprocity. Subpart C-Equipment This subpart describes the requirements for radiographic equipment performance and use. Some of the requirements in this subpart are changed from the current Part 34 as described below. F Section 34.20 Performance requirements for radiography equipment, is slightly changed from Section 34.20 of the current rule. Section 34.20(b) is revised to prohibit modification of any exposure device. Many licensees have expressed confusion over what the current rule intended in permitting modification. Modification of any safety component was never intended. The ~ proposal removes this ambiguity. Modification of any non-safety equipment would still be permitted. Section 34.20(b)(2) has been revised to specify i; that radiographic exposure devices used as Type B transport containers must meet the QA program requirements outlined in 671.105. While this always has been true many licensees have been unaware of this requirement. Section 6

l 34.20(f) is added to require labeling of all associated equipment acquired after January 10, 1996 to identify that the components have met the requirements of this section. Section 34.21 Limits on levels of radiation for radiographic exposure devices, storage containers, and source changers, is basically unchanged from Section 34.21 of the current rule, with the following exceptions. Metric equivalents to the values previously cited have been included. While it is recognized that radiation exposure instruments currently use units of + roentgens to measure radioactivity, the language has been modified to use the terms millisieverts and millirems. Rather than making the transition from i roentgens to coulombs per kilogram (in air), the terms millisieverts and millirems were chosen since a quality factor of 1 is appropriate in dealing with gamma-ray emitting radiography sources. Measurements taken in roentgens may be recorded in terms of millisieverts or millirems for purposes of demonstrating compliance with the rule. Section 34.23 Locking and relocation of radiographic exposure devices, storage containers, and source changers, is slightly changed from section t 34.22 of the current rule, as described below. Section 34.23(a) describes i locking of radiographic exposure devices. A requirement to remove the key of any keyed lock is inclulded. Should the key remain in the camera there is an increased likelihood of the accidental or intentional removal of the sealed I; source when the radiographic camera is unattended. The term " manually" is -. added to clarify what is meant by securing the source assembly. Section 34.23(b) is added which specifies requirements for ensuring that the sealed 7

source is in the shielded position prior to movement of the device and associated equipment, since a number of overexposures have occurred while radiographic devices were being moved from one location to another. i Section 34.25 Radiation survey instruments, that replaces 134.24 in the current rule, has been updated to reflect current calibration standards for different types of survey meters. This is to provide appropriate guidance I to address the variety of survey instruments currently available. An additional requirement to perform an operability check prior to use is includtd. While this is routinely part of all survey instrument specifications, a failure to determine whether an instrument was operable prior to use has been a contributing factor in overexposures both in radiography and other licensed activities. Section 34.27 Leak testing and replacement of sealed sources. Most of the language in the draft is the same as section 34.25 of the existing rule, but the language has been reformatted to clarify the requirements. A new requirement is also included to specify that the method used in performing a leak test must be one approved by the Commission or an Agreement State. This is presently only addressed in regulatory guides. The words " repair, tagging, opening, and modification" of sealed sources have been removed since these activities are only approved for individuals specifically licensed to do so, and are not considered routine activities that should be performed by anyone i; holding a radiography license. The language in the-current rule is confusing as written, since it was never intended that radiographers would be permitted 5 8

to perform these activities without special authorization from the Commission or an Agreement State. Section 34.29 Quarterly inventory is basically unchanged from the existing regulation, with the exception of moving all recordkeeping requirements to Section 34.69. Section 34.31 Inspection and maintenance of radiographic exposure devices, storage containers, associated equipment, and source changers includes several proposed changes from 5 34.28 in the current rule, which are described below. A listing of associated equipment has been added. This listing would include various items used for specific tasks which may not be supplied with the radiographic device. Experience has shown that defects in associated equipment can have an equally significant effect on safety as the other listed components. Section 34.31 (a) has been revised to clarify the intent of the daily visual check, and the required actions if defects are found. In Section 34.31(b) the term " routine maintenance" is now used to clarify that licensees are not required to perform all maintenance. Many equipment repairs may require returning the device to the manufacturer. Language has been added to specify that defective equipment be removed from j service until repaired and a record of the defect, as well as~ corrective j actions taken, be made. While this seems to be obvious, there have been numerous instances where the use of defective equipment continued and l subsequently resulted in overexposures of personnel occurring as a direct result of the defects. Recordkeeping requirements have been moved to 9 i

s 34.73. The records to be kept are specified and include: date of check, individual performing check, equipment involved, any defects found, and repairs made. Section 34.31(c) is included which requires surveys for depleted uranium (DU) contamination in the "S" tube of radiographic devices at least once every 12 months. The depleted uranium is used as a shielding material in most radiographic devices, replacing the lead shielding that was used in older model s. The presence of DU contamination in the "S" tube, (a hard metal, such as titanium, tube through which the radioactive source travels), is an 1 indication that the control cable has worn a groove through the "S" tube into the uranium shielding. This condition could lead to binding of the control cable in the groove with the resultant inability to retract the source which leads to an increased potential for personnel overexposures. Section 34.33 Permanent radiographic installations is basically 4 unchanged from the existing requirements in Part 34, with the exceptions noted below. Section 34.33 (c) includes a requirement to perform a daily alarm system check. This is to be performed by checking the warning light and i audible alarm with the source exposed, and is to be performed prior to use of the room each day. A defective alarm would require repair before radiographic operations could resume. This is included because there have instances where i failures in alarm systems have resulted in personnel overexposures upon entry i; into a-high radiation area. l l I I 10

i Section 34.35 Labels, storage, and transportation precautions is a new section proposed to place requirements into Part 34 which specify labeling and security precautions for radioactive material storage and transportation. Section 34.23 of the current rule describes storage precautions for exposure devices and storage containers but did not address transportation or labeling requirements. In s 34.35 of the proposed rule, there are labeling requirements for source changers and storage containers. The draft rule has specific requirements to lock and physically secure transport packages. The draft rule also requires licensees to store licensed material in a manner to minimize the danger from explosions or fire. The requirement for a QA program, as described in s 71.105, has been added to the draft rule because there have been numerous cases where radiography licensees were unaware of l this requirement and failed to comply. The addition of these requirements addressing labelling, and transportation are necessary because in the past serious personnel and public exposures have occurred from the failure to properly safeguard radioactive material during storage and transportation. Subpart D-Radiation Safety Requirements This subpart describes basic radiation safety requirements for i radiographic operations and includes training, safety procedures, personnel monitoring and surveys. New requirements describing the duties of the radiation safety officer are included. t i; Section 34.41 Radiation Safety Officer, is proposed which lists t,he qualificaticns and duties of the RSO. This section is added to place the requirements for this key individual into the regulations which were 11 l

previously only referenced in regulatory guides. The RSO is the key individual for ensuring safe operations. While this function has not previously been a requirement, it has been general practice to name an individual on the license to be the RSO. The qualifications listed for the RSO in the draft rule include:

1) completion of the training required for a radiographer as described in Part 34; and 2) 2 years of documented experience in industrial radiography with at least 40 hour:: of formal classroom training with respect to oversight of radiation protection programs. The duties of the RSO in the proposed rule include overseeing procedure implementation and employee training, and monitoring radiation surveys, leak tests, and personnel monitoring results. A key duty of the RSO is to ensure the safe conduct of operations and to stop unsafe operations and institute corrective actions.

Section 34.43 Training, contains several new requirements which are discussed below. Section 34.43(b), which lists training requirements for radiographer's assistants, includes additional training in NRC regulations (30.7,30.9,30.10, and Parts 19, 20, and 34), in addition to the licensee's operating and emergency procedures. This change is to ensure that radiographer's assistants are knowledgeable of the safety requirements applicable to handling radioactive material in the conduct of radiography. Section 34.43(c) describes a proposal to conduct periodic training of radiographers and radiographer's assistants. In the current rule, p'eriodic training is required although there are,no requirements on topics to be 9 addressed. A number of violations involving personnel overexposures have resulted from licensee's failure to provide adequate training. The proposal includes training on revised operating and emergency procedures, new 12

j equipment, and safety issues. This review can be combined with the semi-annual inspection of job performance required by 9 34.43(d). Section 34.43(d) has been relocated from & 34.13, and describes the requirements for routine inspections of job performance for radiographers and radiographer's assistants. The draft rule reduces the frequency of these j I inspections from quarterly to semi-annually for individuals regularly conducting radiographic operations. For individuals who have not performed radiographic operations for more than three months, an inspection of their job performance would be required prior to their participation in a radiographic operation. With several of the other changes addressed in this rulemaking, such as, specifying requirements for periodic training and having two individuals at a temporary jobsite, the need for a quarterly review could be modified to semi-annual. i t Proposed 5 34.43(e) specifies that recordkeeping requirements can be found in 5 34.79. The requirements for records are unchanged from the current Part 34. Proposed 134.43(f) contains the subjects currently listed I in Appendix A of Part 34. Several proposed additional requirements are included. These include: pictures or models of source assemblies; training in storage, control, and disposal of licensed materials; and pertinent Federal regulations, i.e., Dept. of Transportation, and Occupational Safety and Health Administration. i; Section 34.45 Operating and emergency procedu'res. Minor changes were i made to the existing Part 34 requirements to include: procedures for source 13

recovery if the licensee intends to perform emergency source recovery. This is added since many of the steps in a source recovery would be the same in any circumstance and, in the past, a number of personnel overexposures have occurred during emergency source recovery operations because basic radiation ~ protection precautions were overlooked. Additional requirements are proposed for transportation procedures to include placarding of vehicles, and reference to the DOT regulations in 49 CFR 173. A number of violations have resulted from licensees failing to follow DOT regulations in the transportation of radioactive material. Section 34.45(b) is included which specifies that the recordkeeping requirements can be found in 5 34.81. Sections 34.89 and 34.91 specify that copies of current operating and emergency procedures are to be I maintained at field stations and temporary jobsites, to ensure that adequate documents are available where radiographic operations occur. l Section 34.47 Personnel monitoring. Several changes are included as follows. The existing requirement specifies that pocket dosimeters have a range from zero to at least 200 milliroentgens. The draft rule has dropped the term "at least." This is to prevent the use of pocket dosimeters with very high ranges where the users would be unable to properly determine their exposure. Use of pocket dosimeters with a range higher than 200 t milliroentgens would be approved on a case by case basis. Additional requirements are included on the replacement fregesncy for film and TLDs. In l the existing regulation no replacement frequency is specified. A monthly i; i frequency is proposed because the high intensity sources used in radiography can lead to significant exposures, so that monthly monitoring is necessary to l P 14

( 1 q maintain an adequate knowledge of the individuals exposure to date and to prevent overexposures. l i Section 34.47(b) addresses the use of pocket dosimeters. A requirement is included to read dosimeters at the beginning and end of each shift. This j is added to ensure that the dose is correctly estimated. The existing l regulation only specifies a daily reading which does not provide sufficient instruction on how licensees should handle any readings which remain on the pocket dosimeter after recharging. Since it is nearly impossible to recharge a pocket dosimeter to zero, licensees must take a reading before and after use j i and subtract the difference to accurately determine the dose. Section j 34.47(d) addresses an off-scale pocket dosimeter. The draft rule specifies-that in the case of a pocket dosimeter being off-scale the individual will'not' be permitted to work with licensed material until a determination of the I worker's radiation exposure by the RSO or his\\her designee is made. _ The 'l current rule requires sending the film badge or TLD for processing but did not' t specify when the individual would return to work. The proposed revision i i .provides the criteria that must be met to permit the individual to return to j i work. l i Section 34.47(e) is proposed which requires a worker to cease _ work i whenever a film badge or TLD is lost or damaged, until a replacement is available. This is added to ensure that there is a means to accurately -l r: i determine the worker's radiation dose. a l, 15 h -t f

Section 34.49 Radiation surveys. There are several proposed changes from the existing regulation. The existing regulation requires a survey of the camera circumference and the guide tube. A number of violations have occurred because of failure to follow this requirement. In reviewing the regulation the NRC staff has decided to revise the survey requirements to remove the current requirements and specify a requirement to turn on the survey instrument on approaching the guide tube. A requirement is specified to survey the camera to determine that the sealed source has returned to the shielded position. The draft rule language places the responsibility for conducting an adequate survey with the licensee. In the majority of cases, a survey of the camera ports should be adequate to make this determination. Section 34.51 Security. This section is unchanged from 6 34.41 of the current rule. Section 34.53 Posting. This section is unchanged from 6 34.42 of the current rule. Section 34.55 Supervision of radiographer's assistants. This section is unchanged from 6 34.44 of the current rule. Section 34.57 Requirements for conducting radiographic operations outside of a permanent radiographic installation, is added to address proposed i; requirements for conducting radiography when the special safety requirements of a shielded facility are not available. The proposed requirement specifies that either two radiographers or a radiographer and an ir.dividual with 16 i

l i training at least equivalent to a radiographer's assistant must be present to observe the operations and to provide assistance and control of the area i against unauthorized entry. The basis for this provisiion is to ensure that I in the ab:;ence of the safety features outlined in Section 34.33, there will be j sufficient qualified personnel available to ensure safe radiographic operations. In October 1992, the International Union of Operating Engineers (IV0E), Iocal No. 2 petitioned the NRC to amend its regulations regarding l radiography to require a minimum of two radiographic personnel when performing e industrial radiography at temporary jobsites. The petitioners identified a i number of problems associated with the use of licensed material by one I radiographer at temporary jobsites. Sor.a of these included: 1) difficulty l keeping the area under constant turveillance while radiographic operations are ongoing; 2) difficulty in maintaining surveillance when working in trenches;

3) difficulty in obtaining assistance in the event of an emergency if there is only one individual; and the petitioners believe that the suggested change is necessary to ensure a safe working environment. The drat rule would constitute a partial granting of the petition.

l Subpart E-Recordkeeping Requirements This subpart does not appear in the current Part 34. It is included to place all recordkeeping and notification requirements in one location. Most of the recordkeeping requirements are unchanged from the existing Part 34. l Proposed changes are discussed below. -r 17 t

Section 34.61 Specific license for radiography. This section requires i the licensee to maintain a copy of the license until it is terminated by the f Commission. i b Section 34.63 Records of receipt and transfer of sealed sources. This describes recordkeeping requirements which are not in the current Part 34. l This is added to provide a record showing the disposition of sources to verify source location in the event of loss or theft. i Section 34.65 Records of radiation survey instruments. This is proposed as currently written in Section 34.24. Licensees would be expected to i maintain calibration records for radiation survey instruments for 3 years after the record is made. I Section 34.67 Records of leak testing, repair, tagging, opening, modification and replacement of sealed sources. This is included as currently written in 5 34.25(c), and would require licensees to maintain records of leak tests for 3 years after the record is made. i Section 34.69 Records of quarterly inventory. This is included as currently written 6 34.26, and would require licensees to maintain records of l quarterly inventories for 3 years after the record is made. l Section 34.71 Utilization logs. This is proposed much as currently l written in 134.27, and would require licensees to maintain utilization logs i; t for 3 years after the record is made. The draft rule has added several additional pieces of information to the logs; the serial number of device in { which the sealed source is located, the radiographer's signature, and the 18 E

i dates the device is removed and returned to storage. This information is l needed to locate sources in the case of theft or loss. Section 34.73 Records of inspection and maintenance of radiographic exposure devices, storage containers, associated equipment, and source changers. This section is proposed much as currently written in 134.28(b), and would require licensees to maintain inspection and maintenance records for l three years after the record is made. The draft rule has added what i information must be included in the inspection records: date of check, name j of inspector, equipment inspected, any defects found and repairs made. l [ Section 34.75 Records of permanent radiographic installations. This section is proposed as currently written in 134.29(c) and would require licensees to maintain records of alarm system checks for 3 years after the record is made, t a Section 34.79 Records of training. This section is proposed as currently written in 6 34.31(c), with the additional requirement for maintaining records of periodic training, and would require licensees to i maintain records of initial and periodic training, and field examinations, j including copies of tests, dates administered, and topics covered in the periodic retraining. l ) Section 34.81 Copies of operating and emergency procedures. This-I section is proposed as currently written in 6 34.32 and would require 19 -l l

licensees to maintain copies of emergency and operating procedures until the Comission terminates the license. Section 34.83 Records of personnel monitoring. This section is proposed l i as currently written in 5 34.33, and would require licensees to maintain records of pocket dosimeter readings and operability checks for 3 years from i the date the record was made, to maintain records of film badge or TLD reports until the Comission terminates the license. i Section 34.85 Records of radiation surveys. This section is proposed as currently written in 9 34.43(d), and would require records of the exposure device surveys for 3 years from the date the record was made. Section 34.87 form of records. This section is proposed as currently written in i 34.4, and specifies how records must be maintained, including permitting records to be stored in electronic media. Section 34.89 Documents and records required at field stations. This new proposed section, which list documents and records required at field stations, was added to ensure that licensees have available sufficient records to demonstrate compliance with NRC regulations. The field station is often far removed from the home office, therefore records necessary to maintain safe operation should be readily available. The records listed are only a subset of the records required at a licensee's nor' mal place of business. These records include copies of pertinent regulations, copies of operating and emergency procedures, instrument calibration records, leak test results, 20

inventory records, utilization logs, training and survey records. These records are those licensees would need to safely handle radioactive material. Section 34.91 Documents and records required at temporary jobsites. This proposed section, which list documents and records required at temporary ( jobsites, was added to ensure that licensees have available sufficient records to demonstrate compliance with NRC regulations and to have the records necessary to maintain safe operations. The records listed are a smaller f subset of the records required for a field station. These records include copies of pertinent regulations, evidence of latest instrument calibrations, latest survey records, shipping papers, and Agreement State license if operating under reciprocity. These records are those needed for licensees to safely handle radioactive material. Subpart F - Notification of Incidents This subpart is basically unchanged from the current Fart 34 with the exception of minor wording changes. i ( Subpart G - Exemptions l This subpart addresses exemptions and is basically the same as the current Part 34 with the exception of minor wording changes. Subpart H - Enforcement Thissubpartaddressesenforcemenhandisnotinthecu_rre.ntPart34. The language used in this subpart is the same as appears in all newer NRC regulations and describes what legal action the NRC may take for any failure 5 21 I

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CURRENT RULE STRAWMAN RULE LANGUAGE PART 34 -- LICENSES FOR RADIOGRAPHY PART 34 -- LICENSES AND RADIATION AND RADIATION SAFETY SAFETY REQUIREMENTS REQUIREMENTS FOR RADIOGRAPHIC FOR RADIOGRAPHIC OPERATIONS OPERATIONS Subpart A -- General Provisions l Sec. Sec. 34.1 Purpose and scope. 34.1 Purpose and scope. 34.2 Definitions. 34.3 Definitions. 34.3 Applications for specific See S 34.11. licenses. 34.5 Interpretations. 34.4 Maintenance of records. See S 34.87. 34.8 Information collection 34.8 Information collection requirements: OMB approval. requirements: OMB approval. C Subpart A -- Specific Licensing Subpart B -- Specific Licensing Requirements Requirements See S 34.3. 34.11 Application for a specific license. 34.11 Issuance of specific licenses 34.13 Specific license for for use of sealed sources in radiography. radiography. i Subpart B -- Radiation Safety Requirements Equipment Control Subpart C - Equipment 34.20 Performance requirements for 34.20 Performance requirements for radiography equipment. radiography equipment. 34.21 Limits on levels of radiation 34.21 Limits on levels of radiation for radiographic exposure devices for radiographic exposure devices, e and storage containers. storage containers, and source changers. i l 34.22 Locking of radiographic 34.23 Locking and relocation of exposure devices, storage radiographic exposure devices, containers, and source changers. storage containers, and source changers. j 34.23 Storage precautions. See S 34.35. F

7 J 34.24 Radiation survey instruments. 34.25 Radiation survey instruments. 34.25 Leak testing, repair, tagging, 34.27 Leak testing and replacement-opening, modification and of sealed sources. replacement of sealed sources. 34.26 Quarterly inventory. 34.29 Quarterly inventory. 34.27 Utilization logs. See S 34.71. 34.28 Inspection and maintenance of 34.31 Inspection and maintenance of radiographic exposure devices, radiographic exposure. devices, storage containers, and source storage containers, associated changers. equipment, and source changers. o 34.29 Permanent radiographic 34.33 Permanent radiographic i installations. installations. i See S 34.23. 34.35 Labels, storage, and transportation precautions. Reporting l 34.30 Reporting requirements. See Subpart F, S 34.101. Personal Radiation Safety Subpart D -- Radiation Safety Requirements for Radiographers and Requirements Radiographers' Assistants 34.41 Radiation Safety Officer. 34.31 Training. 34.43 Training. 34.32 Operating and emergency 34.45 Operating and emergency procedures. procedures. l .34.33 Personnel monitoring. 34.47 Personnel monitoring. Precautionary Procedures in Radiographic Operations 34.41 Security. See S 34.51. 34.42 Posting. See S 34.53. 34.43 Radiation surveys. 34.49 Radiation surveys. See S 34.41. 34.51 Security. ~

e t See S 34.42. 34.53 Posting. 34.44 Supervision of radiographers' 34.55 Supervision of radiographers' assistants. assistants. l 34.57 Requirements for radiographic operations conducted outside of a i permanent radiographic installation. i Exemptions i 34.51 Applications for exemptions. See Subpart G, S 34.111. Appendix A See S 34.43(f). Subpart E -- Records 34.61 Records of specific license for radiography. .i 34.63 Records of receipt and f transfer of-sealed sources. l See S 34.24, 34.65 Records of radiation survey instruments. See s 34.25(c). 34.67 Records of leak testing and replacement of sealed sources. See S 34.26. 34.69 Records of quarterly inventory. See S 34.27. 34.71 Utilization logs. See S 34.28(b). 34.73 Records of inspection and i maintenance of radiographic exposure devices, storage containers, associated equipment, and source changers. r 34.75 Records of permanent radiographic installations. See.S 34.31(c). 34.79 Records of training. See S 34.32. 34.81 Records of. operating and emergency procedures. l See S 34.33(b and e). 34.83 Records of personnel monitoring. See S 34.43(d). 34.85 Records of radiation surveys. See S 34.4. 34.87 Forms of records. f

1: l 34.89 Documents and records required at field stations. l-34.91 Documents and records required at temporary jobsites. Subpart F -- Notification of incidents See S 34.30, 34.101 Notification of incidents. Subpart G -- Exemptions i See S 34.51. 34.111 Applications for exemptions, i Subpart H -- Enforcement 34.121 Violations. 34.123 Criminal penalties. Authority: Secs. 81, 161, 182, 183, Authority: Secs. 81, 161, 182, 68 Stat. 935, 948, 953, 954, as 183, 68 Stat. 935, 948, 953, 954, as amended (42 U.S.C. 2111, 2201, 2232, amended (42 U.S.C. 2111,-2201, 2232, 2233); sec. 201, 88 Stat. 1242, as 2233); sec. 201, 88 Stat. 1242, as l amended (42 U.S.C. 5841). amended (42 U.S.C. 5841). Section 34.32 also issued under sec. 206, 88 Stat. 1246 (42 U.S.C. 5846).For the purposes of sec. 223, 68 Stat. 958, as amended (42-U.S.C. 2273); Section 34.20(a)-(e), 34.21 (a) and (b), 34.22, 34.23, 34.24, 34.25 (a), (b), and (d), 34.28, 34.29, 34.31 (a) and (b), 34.32, 34.33 (a), (c), (d), and (f), 34.41, 34.42, 34.43 (a), (b), and (c) and 34.44 are issued under sec. 161b, 68 Stat. 948, as amended (42 U.S.C. 2201(b); and Section 34.11(d), 34.25 l-(c) and (d), 34.26, 34.27, 34.28(b), 34.29(c), 34.30, 34.31(c), 34.33 (b) and (e) and 34.43(d) are issued ~ under sec. 1610, 68 Stat. 950, as amended (42 U.S.C. 2201(o)). L I'

Subpart A -- General Provisions Section 34.1 Purpose and scope. Section 34.1 Purpose and scope. This part prescribes requirements This part prescribes requirements i for the issuance of licenses for the for the issuance of licenses for the use of sealed sources containing use of sealed sources containing byproduct material and radiation byproduct material and radiation safety requirements for persons safety requirements for persons using such sealed sources in using the sealed sources in radiography. The provisions and industrial radiography. This rule requirements of this part are in does not apply to medical uses of addition to, and not in substitution byproduct material. The provisions for, other requirements of this and requirements of this part are in j chapter. In particular, the addition to, and not in substitution 1 provisions of Part 30 of this for, other requirements of this chapter apply to applications and chapter. In particular, the licenses subject to this part. requirements and provisions of Parts Nothing in this part shall apply to 19, 20, 21, 30, 71, 150, 170 and 171 uses of byproduct material for of this chapter apply to medical diagnosis or therapy. applications and licenses subject to this part. Section 34.2 Definitions. Section 34.3 Definitions. As used in this part: As used in this part: "ALARA" (acronym for as low as reasonably achievable) means making every reasonable effort to maintain i exposures to radiation as far below the dose limits specified in Part 20 as is practical and consistent with the purpose for which the licensed activity is undertaken. " Associated Equipment" means equipment that is used in conjunction with a radiographic exposure device to make radiographic exposures that drive, guide or come in contact with the source, (i.e., guide tube, control tube, crank, removable source stop, "J" tube). " Becquerel" (Bq) means one disintegration per second. "Collimator" means a device used to limit the size, shape, and direction of the primary radiation beam. i

" Control (crank-out) device" means the control cable, the protective. sheath, and control drive 1 mechanism used to move the sealed source from its shielded position in the radiographic device or camera to an unshielded position outside the device for the purpose of making a radiographic exposure. " Control tube" means-protective sheath for guiding the control i cable. The control tube connects the control drive mechanism to the radiographic exposure device. I " Exposure head" means a device that locates the gamma radiography sealed source in the selected working ~ position. An exposure head is also known as a-source stop. " Field examination" means a demonstration of practical application of the principles. learned in the ' classroom that should - include use of all appropriate equipment and procedures. l " Field station" means a facility where-licensed material may be-stored or used and from which' equipment is dispatched. .l " Periodic training" means a periodic review conducted or provided by the licensee for its i employees on radiation safety aspects of radiography. The review may include, as appropriate, the 4 results of internal inspections, new procedures or equipment,-accidents l or errors'that have been observed, and opportunities'for employees to i ask safety questions. Permanent radiographic " Permanent radiographic l installation" means a shielded installation" means an enclosed installation or structure designed shielded room, cell, or vault in or intended for radiography and in which radiography is performed. i which radiography is regularly performed. j i

e " Projection sheath" (guide tube) means a flexible or rigid tube (i.e., "J" tube) for-guiding the - source assembly and the attached control cable from the exposure device to the exposure head or working position. " Radiation Safety Officer" means an individual named by the licensee who has knowledge of, responsibility for, and authority to ensure compliance with appropriate radiation protection rules, standards, and practices on behalf of the licensee and who meets the requirements of 34.41. Radiographer means any " Radiographer" means any individual who performs or who, in individual who performs or who, in attendance at the site where the attendance at the site where the sealed source or sources are being sealed source or sources are being used, personally supervises used, personally supervises radiographic operations and who is radiographic operations and who is responsible to the licensee for responsible to the licensee for assuring compliance with the ensuring compliance with the-requirements of the Commission's requirements of the Commission's regulations and the conditions regulations and the conditions of of the license; the license. Radiographer's assistant" " Radiographer's assistant" means any individual who under the means any individual, who under the personal supervision of a personal supervision of a radiographer, uses radiographic radiographer, uses radiographic exposure devices, sealed sources or exposure devices, sealed sources or related handling tools, or radiation related handling tools, or radiation survey instruments in radiography; survey instruments in radiography. Radiographic exposure " Radiographic exposure device" device means any instrument means any instrument containing a containing a sealed source fastened sealed source fastened or contained or contained therein, in which the therein, in which the sealed source i sealed source or shielding thereof or shielding thereof may be moved, may be moved, or otherwise changed, or otherwise changed, from a from a shielded to unshielded shielded to unshielded position for-i position for purposes of making a purposes of making a radiographic radiographic exposure; exposure, (i.e., a camera or a projector).

Radiography means the " Radiography" means the examination of the structure of examination of the structure of materials by nondestructive methods, materials by nondestructive methods, utilizing sealed sources of utilizing sealed sources of byproduct materials; byproduct materials. Sealed source means any " Sealed source" means any byproduct material that is encased byproduct material that is encased in a capsule designed to prevent in a capsule designed to prevent leakage or escape of the byproduct leakage or escape of the byproduct material; material. " Shielded position" means the location within the radiographic exposure device or source changer where the sealed source is secured and restricted from movement. In this position the radiation exposure will be at a minimum. This position incorporates maximum shielding for the radioactive source. " Sievert" means the SI unit of any of the quantities expressed as dose equivalent. The dose equivalent in rems is equal to the absorbed dose in rads multiplied by the quality factor (1 Sv = 100 rems). I " Source assembly" means consists of the sealed source and a conncctor that attaches the source i tot he control cable. The source assembly mcy also include a stop ball used to secure the source in the shielded position. Source changer means a " Source changer" means a device device designed and used for designed and used for replacement of replacement of sealed sources in sealed sources in radiographic radiographic exoosure devices, ex,>osure devices, including those including those also used for alo used for transporting and transporting and storage of sealed storage of sealed sources. sources; Storage area" means any " Storage area" means any location, facility, or vehicle which location, facility, or vehicle which is used to store, to transport, or is used to store or to secure a to secure a radiographic exposure radiographic exposure device, a i device, a storage container, or a storage container, or a sealed sealed source when it is not in use source when it is not in use and and which is locked or has a which is locked or has a physical physical barrier to prevent barrier to prevent accidental 1 i

accidental exposure, tampering with, exposure,-tampering with, or or unauthorized removal of the -unauthorized removal of the device, device, container, or source. container, or source. Storage container means a " Storage container" means a device in which sealed sources are device in which sealed sources are transported or stored. stored. " Temporary jobsite" means a place where licensed materials are present for the purpose of performing radiography other than any permanent radiographic installation. Section 34.5 Interpretations. Except as specifically authorized by the Commission in writing, no interpretation of the meaning of the regulations in this part by any officer or employee of the Commission. 9ther than a written interpretation by the General Counsel, will be recognized to be binding upon the Commission. Section 34.3 Applications for See S 34.11. specific licenses. A person may file an application for specific license for use of sealed sources in radiography in duplicate on NRC Form 313, Application for Material License, in accordance with the provisions of Section 30.32 of this chapter. Section 34.4 Maintenance of records. See S 34.87. Each record required by this part must be 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 authorized personnel and that the microform is capable of producing a clear copy throughout the required retention period. The record may also be

l l l stored in electronic media with the capability for producing legible, accurate, and complete records l during the required retention i period. Records such as lettera, drawings, specifications, must i include all pertinent information such as stamps, initials, and signatures. The licensee shall maintain adequate safeguards against tampering with and loss of records. Section 34.8 Information collection Section 34.8 Information collection requirements: OMB approval. requirements: OMB approval. (a) The Nuclear Regulatory (a) The Nuclear Regulatory Commission has submitted the Commission has submitted the information collection requirements information collection requirements contained-in this part to the Office contained in this part to the Office of Management and Budget (0MB) for of Management and Budget (0MB) for approval as required by the approval as required by the Paperwork Reduction Act of 1980 (44 Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.). OMB has U.S.C. 3501 et seq.). OMB has approved the information collection approved the information collection requirements contained in this part requirements contained in this part under control number 3150-0007. under control number 3150-0023. (b) The approved information (b) The approved information collection requirements contained in collection requirements contained in this part appear in Section 34.11, this part appear in SS 34.13, 34.20, 34.24, 34.25, 34.26, 34.27, 34.28, 34.25, 34.27, 34.29, 34.31, 34.33, 34.29, 34.31, 34.32, 34.33, and 34.43, 34.45, 34.47, 34.49, 34.61, 34.43. 34.63, 34.65, 34.67, 34.69, 34.71, 34.73, 34.75, 34.79, 34.81, 34.85, 34.87, 34.89, 34.91, 34.101, and 34.111. (c) This part contains (c) This part contains information collection requirements information collection requirements in addition to those approved under in addition to those approved under the control number specified in the control number specified in. paragraph (a) of this section. paragraph (a) of this section. These information collection These information collection requirements and the control numbers requirements and the control numbers under which they are approved are as under which they are approved are as follows: follows: (1) In Section 34.3, form (1) In S 34.11, Form NRC-313 is NRC-313R is approved under control approved under control number number 3150-0023. 3150-0120. (2) Reserved.

-l l L Subpart A -- Specific Subpart B -- Specific Licensing Licensing Requirements Requirements See S 34.3. Section 34.11 Application for a j specific license. A person may file an application for specific license for l use of sealed sources in radiography. in duplicate on NRC Form 313, " Application for Material License," in accordance with the provisions of S 30.32 of this chapter. Section 34.11 Issuance of specific Section 34.13 Specific license for licenses for use of sealed sources radiography. in radiography. An application for a specific The Commission will approve an license for use of sealed sources in application for a specific license radiography will be approved if: for the use of licensed material in i radiography if the applicant meets ~ the following requirements:- l (a) The applicant satisfies the (a) The applicant shall satisfy general requirements specified in the general requirements specified Section 30.33 of this chapter; in S 30.33 of this chapter for byproduct material,L as appropriate, and any special requirements i contained in this part. (b) The applicant will have an (b) The applicant shall develop adequate program for training an adequate program for training l radiographers and radiographers' radiographers and radiographer's assistants and submits to the assistants and submit to the Commission a schedule or description Commission a description of this - of such program which specifies the: program which apecifies the - - l (1) Initial training; (1) Initial and periodic (2) Periodic training; training; (3) On-the-job training; (2) On-the-job training; (4) Means to be used by the (3) Means the applicant will licensee to determine the use to demonstrate the radiographer's knowledge and radiographer's knowledge and understanding of and ability to understanding of and ability to i comply with Commission comply with the Commission's regulations and licensing regulations and licensing requirements, and the operating and requirements and the applicant's emergency procedures of the operating and emergency procedures; applicant; and and 1 i

n See S 34.ll(b)(6), (4) Means the applicant will use to determine the radiographer's assistant's knowledge and understanding of and ability to comply with the applicant's operating and emergency procedures. (5) In lieu of describing its (c) In lieu of describing its initial training program for initial training program for radiographers in the subjects radiographers in the subjects outlined in Appendix A of this part, outlined in S 34.43(f), and the and the description of and the means description of and the means to to determine the radiographer's determine the radiographer's knowledge and understanding of these knowledge and understanding of these subjects, the applicant affirms that subjects, the applicant affirms that all individuals acting as all individuals acting as radiographers will be certified in radiographers will be certified in radiation safety through the radiation safety through the Certification Program for Industrial Certification Program for Industrial Radiography Radiation Safety Radiography Radiation Safety Personnel of the American Society Personnel of the American Society for Nondestructive Testing, Inc. for Nondestructive Testing, Inc. (ASNT-IRRSP) prior to commencing (ASNT-IRRSP) prior to commencing duties as radiographers. From April duties as radiographers. From April 18, 1991, to the date of the renewal 18, 1991, to the date of the renewal of an existing license, an approved of an existing license, an approved license application is deemed to license application is deemed to include the option, for individuals include the option, for individuals who are certified in radiation who are certified in radiation safety through the ASNT-IRRSP, to safety through the ASNT-IRRSP, to substitute ASNT-IRRSP certification substitute ASNT-lRRSP certification in lieu of the described means to in lieu of the described means to determine a radiographer's knowledge determine a radiographer's knowledge and understanding of the subjects in and understanding of the subjects in 34.31(a)(1). (This paragraph does S 34.43(a)(1). This paragraph does not affect the licensee's not affect the licensee's responsibility to assure that responsibility to ensure that radiographers are properly trained radiographers are properly trained in accordance with S 34.31(a)). in accordance with S 34.43(a). (6)Means to be used by the See S 34.13(b)(4). licensee to determine the radiographer's assistant's knowledge and understanding of and ability to comply with the operating and emergency procedures of the applicant; (c) The applicant has (d) The applicant shall submit established and submits to the to the Commission written adequate Commission satisfactory written operating and emergency procedures operating and emergency procedures as described in S 34.45. as described in Section 34.32;

i (d) The applicant has (e) The applicant shall y established and submits to the establish and submit to the Commission a description of its Commission its program for i i l inspection program adequate to semiannual inspections of the job i ensure that its radiographers and performance of each radiographer and radiographers' assistants follow the radiographer's assistant as Commission's regulatory requirements described in s 34.43(d). i and the applicant's operating and emergency procedures. The inspection program must: l (1) Include observation of the See S 34.43(d)(1). performance of each radiographer and radiographer's assistant during an actual radiographic operation at intervals not to exceed three j months; l I (2) Provide that, if a See 534.43(d)(2). radiographer or a radiographer's assistant has not participated in a radiographic operation for more than three months since the last inspection, that individual's j performance must be observed and I recorded the next time the l individual participates in a radiographic operation; and I (3) Include the retention of See S 34.79. inspection records on the performance of radiographers or l radiographers' assistants for three 1 years. i (e) The applicant submits a (f) The applicant shall submit description of its over-all a description of its overall organizational structure pertaining organizational structure as it to the radiography program, applies to the radiation safety including specified delegations of responsibilities in radiography, authority and responsibility for including specified delegations of operation of the program; and authority and responsibility. (g) The applicant shall designate a Radiation Safety Officer I responsible for implementing the licensee's radiation safety program. The Radiation Safety Officer shall meet the qualifications and duties described in s 34.41. l l l (f) The applicant who desires (h) If an applicant intends to I to conduct his own leak tests has perform leak testing of sealed established adequate procedures to sources, the applicant shall be followed in leak testing sealed identify the manufacturers and the sources, for possible leakage and model numbers of the leak test kits contamination and submits to the to be used. If the applicant 1

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A { I v Commission a description of such intends to analyze its own wipe l samples, the applicant shall l procedures including: . establish procedures to be followed ' - i i and submit a' description of these procedures to the Commission.. The description must_ include the -- (1) Instrumentation to be used, (1) Instruments to be used; (2) Method of performing test, (2) Methods of performing the j L e.g., points on equipment to be analysis; and smeared and method of taking smoar, and l (3) Pertinent experience of the (3) Pertinent experience of person who will perform the test. the person who will analyze the wipe

samples, j

(i) The applicant shall submit to the Commission a list and i description of permanent radiographic installations which are at their place of business and j storage locations where radioactive l material is stored for more than.180 l days in a calendar year, j - Subpart B -- 1 Radiation Safety Requirements i EQUIPMENT CONTROL Subpart C - - Equipment i Section 34.20 Performance Section 34.20 Performance requirements for radiography requirements for radiography equipment. equipment. Equipment used in industrial Equipment used in. industrial radiographic operations must meet radiographic operations must meet the following minimum criteria: the following minimum criteria: . (a) Each radiographic exposure (a) Each radiographic exposure device and all associated equipment device and all associated equipment must meet the requirements specified must meet the requirements specified-in American National Standard in American National Standard N432-1980 " Radiological Safety for N432-1980 " Radiological Safety for the Design and Construction of the Design and Construction of-Apparatus for Gamma' Radiography," Apparatus for Gamma Radiography," (published as NBS Handbook 136, (published as NBS Handbook.136, issued January 1981). This issued January 1981). This l. publication has been approved for publication has been approved for incorporation by reference by the incorporation by reference by the Director of the Federal' Register in Director of the Federal Register in accordance with 5 U.S.C. 552(a) accordance with 5 U.S.C. 552(a). This publication may be purchased .This publication may be purchased from the Superintendent of from the Superintendent of 't

Documents, U.S. Government Printing Documents, U.S. Government Printing Office, Washington, DC 20402 and Office, Washington, DC 20402 and from the American National Standards from the American National Standards Institute, Inc., 1430 Broadway, Institute, Inc., 1430 Broadway, New York, New York 10018, Telephone New York, New York 10018, Telephone (212) 642-4900. Copies of the (212) 642-4900. Copies of the document are available for document are available for inspection at the Nuclear Regulatory inspection at the Nuclear Regulatory Commission Public Document Room, Commission Library, 7920 Norfolk l 2120 L Street NW., Lower Level, Avenue, Lower Level, Bethesda, Washington, DC 20555. A copy of the Maryland, 20814. A copy of the document is also on file at the document is also on file at the Office of the Federal Register,1100 Office of the Federal Register, 800 L Street NW., Room 8301, Washington, North Capitol Street NW., DC 20408. Washington, DC 20408. (b) In addition to the (b) In addition to the requirements specified in paragraph requirements specified in paragraph (a) of this section, the following (a) of this section, the following requirements apply to radiographic requirements apply to radiographic exposure devices and associated exposure devices and associated i equipment. equipment. (1) Each radiographic exposure (1) Each radiographic exposure device must have attached to it by device must have attached to it by the user, a durable, legible, the user, a durable, legible, clearly visible label bearing the -- clearly visible label bearing the -- (i) Chemical symbol and mass (i) Chemical symbol and mass number of the radionuclide in the number of the radionuclide in the device; device; (ii) Activity and the date on (ii) Activity and the date which this activity was last on which this activity was last measured; measured; (iii) Model number and serial (iii) Model number and number of the sealed source; serial number of the sealed source; (iv) Manufacturer of the sealed (iv) Manufacturer of the source; and sealed source; and (v) Licensee's name, address, (v) Licensee's name, and telephone number. address, and telephone number. (2) Radiographic exposure (2) Radiographic exposure devices intended for use as Type B devices intended for use as Type B transport containers must meet the transport containers must meet the applicable requirements of 10 CFR applicable requirements of 10 CFR part 71. Part 71, including documentation of the QA program requirements outlined in S 71.105.

(3) Modification of any (3) Modification of any exposure devices and associated exposure devices and associated equipment is prohibited, unless the equipment is prohibited. design of any replacement component, including source holder, source l assembly, controls or guide tubes would not compromise the design l safety features of the system. [ (c) In addition to the (c) In addition to the i requirements specified in paragraphs requirements specified in paragraphs (a) and (b) of this section, the (a) and (b) of this section, the j following requirements apply to following requirements apply to i radiographic exposure devices and radiographic exposure devices, associated equipment that allow the source assemblies, and associated source to be moved out of the device equipment that allow the source to for routine operation, be moved out of the device for routine operation. 1 (1) The coupling between the (1) The coupling between the source assembly and the control source assembly and the control' cable must be designed in such a cable must be designed in such a manner that the source assembly will manner that the source assembij will not become disconnected if cranked not become disconnected if cranked outside the guide tube. The outside the guide tube. The coupling must be such that it cannot coupling must be such that it cannot-be unintentionally disconnected be unintentionally disconnected under normal and reasonably under normal and reasonably foreseeable abnormal conditions. foreseeable abnormal conditions. (2) The device must (2) The device must automatically secure the source automatically secure the source assembly when it is cranked back assembly when it is cranked back ) into the fully shielded position into the fully shielded position within the device. This securing within the device. This securing i system may only be released by means system may only be released by means of a deliberate operation on the of a deliberate operation on the exposure device. exposure device. t (3) The outlet fittings, lock (3) The outlet fittings,-lock box, and drive cable fittings on box, and drive cable fittings on each radiographic exposure device each radiographic exposure device must be equipped with safety plugs must be equipped with safety plugs or covers which must be installed or covers which must be installed during storage and transportation to during storage and transportation to protect the source assembly from protect the source assembly from water, mud, sand or other foreign water, mud, sand or other foreign matter. matter. l (4) Each sealed source or (4) Ecch sealed source or source assembly must have attached source assembly must have attached to it or engraved in it, a durable, to it or engraved in it, a durable, i l 1

legible, visible label with the legible, visible label with the words: words: DANGER -- RADI0 ACTIVE. The label " DANGER -- RADI0 ACTIVE." must not interfere with the safe The label must not interfere with operation of the exposure device or the safe operation of the exposure associated equipment. device or associated equipment. (5) The guide tube must have (5) The guide tube must have passed the crushing tests for the passed the crushing tests for the control tube as specified in ANSI control tube as specified in ANSI N432 and a kinking resistance test N432 and a kinking resistance test that closely approximates tne that closely approximates the kinking forces likely to be kinking forces likely to be encountered during use. encountered during use. (6) Guide tubes must be used (6) Guide tubes must be used when moving the source out of the when moving the source out of the

device, device.

(7) An exposure head or similar (7) An exposure head or similar device designed to prevent the device designed to prevent the source assembly from passing out of source assembly from. passing out of the end of the guide tube must be the end of the guide tube must be attached to the outermost end of the attached to the outermost end of the guide tube during radiographic guide tube during radiographic operations. operations. (8) The guide tube exposure (8) The guide tube exposure head connection must be able to head connection must be able to withstand the tensile test for withstand the tensile test for control units specified in ANSI control units specified in ANSI N432. N432. (9) Source changers must (9) Source changers must provide a system for assuring that provide a system for ensuring that-the source will not be accidentally the source will not be accidentally withdrawn from the changer when withdrawn from the changer when connecting or disconnecting the connecting or disconnecting the drive cable to or from a source drive cable to or from a source-assembly. assembly. (d) All newly manufactured (d) All newly manufactured radiographic exposure devices and radiographic exposure devices and associated equipment acquired by associated equipment acquired by-licensees after January 10, 1992 licensees after January 10, 1992, must comply with the requirements of must comply with the requirements of this section. this section. (e) All radiographic exposure (e) All radiographic exposure devices and associated equipment in devices, source assemblies, and use after January 10, 1996 must associated equipment in use after comply with the requirements of this January 10, 1996, must comply with section. the requirements of this section.

(f) All associated equipment acquired after January 10, 1996, must be labelled to identify that the components have met the requirements of this section. Section 34.21 Limits on levels of Section 34.21 Limits on levels of radiation for radiographic exposure radiation for radiographic exposure devices and storage containers. devices, storage containers, and source changers. (a) Radiographic exposure (a) Radiographic exposure devices measuring less than four (4) devices measuring less than 10 inches from the sealed source centimeters (4 inches) from the storage position to any exterior sealed source storage position to surface of the device shall have no any exterior surface of the device radiation level in excess of 50 shall not have a radiation level in milliroentgens per hour at six (6) excess of 0.5 millisieverts (50 inches from any exterior surface of millirems) per hour at 15 the device. centimeters (6 inches) from any exterior surface of the device. Radiographic exposure devices Radiographic exporure devices measuring a minimum of four (4) measuring a minimt..n of 10 inches from the sealed source centimeters (4 inches) from the storage position to any exterior sealed source storage position to surface of the device, and all any exterior surface of the device, storage containers for sealed and all storage containers for sources or for radiographic sealed sources or for radiographic exposure devices, shall have no exposure devices, shall not have no radiation level in excess of 200 a radiation level in excess of 2 milliroentgens per hour at any millisieverts (200 millirems) per exterior surface, and ten (10) hour at any exterior surface, and milliroentgens per hour at one meter 0.1 millisieverts (10 millirems) per from any exterior surface. The hour at one meter from any exterior radiation levels specified are with surface. The radiation levels the sealed source in the shielded specified are with the sealed source (i.e., "off) position. in the shielded (i.e., "off") position. (b) Paragraph (a) of this (b) Paragraph (a) of this section applies to all equipment section applies to all equipment manufactured prior to January 10, manufactured prior to January 10, 1992. After January 10, 1996, 1992. After January 10, 1996, radiographic equipment other than radiographic equipment other than storage containers and source storage containers and source changers must meet the requirements changers must meet the requirements of Section 34.20, and Section 34.21 of S 34.20. Section 34.21 applies applies only to storage containers only to storage containers. (source changers). l L.

d Section 34.22 Locking of Section 34.23 Locking and relocation radiographic exposure devices, of radiographic exposure devices, storage containers, and source storage containers, and source changers. changers. (a) Locked radiographic exposure devices and storage containers must be physically secured to prevent tampering. (a) Each radiographic exposure (1) Each radiegraphic exposure device shall have a lock or outer device must have e lock or outer locked container designed to prevent locked _ container designed to prevent unauthorized or accidental removal unauthorized or accidental removal of the sealed source from its of the sealed source from its-shielded position. The exposure shielded position. The exposure device or its container shall be device or its container must be kept kept locked when not under the locked (and if a keyed lock, with direct surveillance of a the key removed at all times), when radiagrapher or a radiographer's not under the direct surveillance of assistant or as otherwise may be a radiographer or a radiographer's i authorized in Section 34.41. In assistant or as otherwise may be addition, during radiographic authorized in S 34.51. In addition, operations the sealed source during radiographic operations the assembly shall be secured in the sealed source assembly must be shielded position each time the manually secured in the shielded source is returned to that position. position each time the source is returned to that position in those exposure devices manufactured prior to January 10, 1992. (b) Each scaled source storage (2) Each sealed source storage container and source changer shall container and source changer must have a lock or outer locked have a lock or outer locked i container designed to prevent container designed to prevent unauthorized or accidental removal unauthorized or accidental removal of the sealed source from its of the sealed source from its shielded position. Storage shielded position. Storage containers and source changers shall containers and source changers must be kept locked when containing be kept locked when containing sealed sources except when under the sealed sources except when under the direct surveillance of a direct surveillance of a radiographer or a radiographer's radiographer.or a radiographer's assistant. assistant. (b) R&diographic exposure devices, source changers, and storage containers, prior to being moved from one location to another, must be disassembled, safety plugs or covers applied, locked and physically secured to prevent ) accidental loss, tampering or removal of licensed material and 1

I l l l ) L must be surveyed to assure that the l sealed source is in the shielded l position. i Section 34.23 Storage precautions. See S 34.35. Locked radiographic exposure devices and storage containers shall .l be physically secured to prevent tampering or removal by unauthorized personnel. I Section 34.24 Radiation survey ' Section 34.25 Radiation survey instruments. instruments. The licensee shall maintain (a) The licensee shall keep sufficient calibrated and operable sufficient calibrated and operable radiation survey instruments to make radiation survey instruments at each L physical radiation surveys as field station and temporary jobsite required by this part and Part 20 of to make.the radiation surveys this chapter. Each radiation survey required by this part and by Part 20 ? instrument shall be calibrated at - of this chapter. Instrumentation intervals not to exceed three months required by this section must be and after each instrument servicing capable of measuring a range from and a record shall be maintained of 0.02 millisieverts (2 millirems) per l the results of each instrument hour through 0.01 Sievert (I rem) calibration and date thereof for per hour. Survey instruments must three years after the date of be checked for operability prior to l' calibration. Instrumentation use. This may be accomplished by required by this section shall have evaluating the instrument response a range such that two milliroentgens to the previously measured fields at per hour through one roentgen per the projection sheath port or the hour can be measured. control cable sheath port on a l radiographic exposure device. ~ (b) The licensee shall have each radiation survey instrument . required under paragraph (a) of this section calibrated -- (1) At intervals not to exceed i 6 months and after instrument-l servicing, except for battery a changes; (2) For linear scale instruments, at two points located approximately 1/3 and 2/3 of full-scale on each scale; for. logarithmic scale instruments, at midrange of each decade, and at two i I,

~ -- - ~ -l points of at least one decade; and for digital instruments, at appropriate points; and j (3) So that: an_ accuracy within - plus or minus 20 percent of the- 'i calibration standard can be demonstrated on each scale. ] (c) The licensee shall maintain records of the results of the instrument calibrationsiin accordance with's 34.65. j t 1 Section 34.25 Leak testing, repair, Section 34.27 Leak testing and l tagging, opening, modification replacement of-sealed sources. and~ replacement of sealed sources. (a) The replacement of any (a) The replacement of any sealed source fastened to or sealed source fastened to or. contained in a radiographic exposure contained in a radiographic exposure device and leak testing, repair, device.and leak. testing of any j tagging, opening'or any other sealed source. must be performed only modification of any_ sealed source by persons specifically authorized shall be performed only by persons by the Commission or an Agreement' ) specifically authorized by the State to do so. Commission ~to do so. 4 (b) Each sealed source shall be (b) Testing and recordkeeping-tested for leakage at intervals not requirements. to exceed 6 months. In the absence (1) Each licensee who usesfa of a certificate from a transferor ~ sealed source'shall have the source that a test has been made within the tested'for leakage at intervals not l 6 months prior to the transfer, the to exceed 6 months. sealed source shall not be put into (2) The licensee shall. use until tested. maintain records of the leak tests - in accordance with 5-34.67. (3) In the absence of a _ certificate from the transferor that a test has been'made within the 6 months before the transfer, the sealed source may not be used until j tested. ~ (c) The leak test must be (c). Method of testing...The capable of detecting the' presence of wipe of: a sealed. source must be O.005 microcurie of removable performed using-a leak' test' kit or contamination on the sealed source. method approved by the Commission or 1 An acceptable leak' test ~for sealed an Agreement State. The wipe' sample- } sources in the possession of a -must be taken from the nearest . radiography licensee would be to accessible point to the sealed test at the nearest accessible point source where contamination ~might - i to the sealed-source storage' accumulate. The wipe' sample must be i

position, or other appropriate analyzed for radioactive measuring point, by a procedure to contamination. The analysis must be be approved pursuant to Section capable of detecting _the. presence of l 34.11(f). Each record of leak test 185 Bq (0.005 microcuries) of results must be kept in units of radioactive material on the test microcuries [or disintegrations per sample and must be performed by a j minute (dpm)] and retained for person approved by the Commission or inspection by the Commission for an Agreement State to perform the three years after it is made, analysis. (d) Any test conducted pursuant (d) Any test conducted pursuant to paragraphs (b) and (c) of this to paragraphs (b) and (c) of this section which reveals the presence section which reveals the presence of 0.005 microcurie or more of of 185 Bq (0.005 microcuries) or removable radioactive material shall more of removable radioactive be considered evidence that the material must be considered evidence sealed source is leaking. The that the sealed source is leaking. l licensee shall immediately withdraw The licensee shall immediately the equipment involved from use and withdraw the equipment involved from shall cause it to be decontaminated use and shall cause it to be and repaired or to be disposed of, decontaminated and repaired or to be in accordance with Commission disposed of in accordance with regulations. A report shall be Commission regulations. A report filed, within 5 days of the test, must be filed, within 5 days of the i with the Director of Nuclear test, with the Director of Nuclear Material Safety and Safeguards, U.S. Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Nuclear Regulatory Commission, Washington, D.C. 20555 describing Washington, D.C. 20555, describing the equipment involved, the the equipment involved, the test test results, and the corrective results, and the corrective action action taken. A copy of such report taken.. A copy of such the must be [ shall be sent to the Administrator sent to the Administrator of the of the appropriate Nuclear appropriate Nuclear Regulatory t Regulatory Commission's Regional Commission's Regional Office listed Office listed in Appendix 0 of Part in Appendix D of Part 20 of this 20 of this chrpter Standards for chapter " Standards for Protection Protection AgLinst Radiation. Against Radiation." (e) A sealed source which is (e) A sealed source which is i not fastened to or contained in a not fastened to or contained in a radiographic exposure device shall radiographic exposure device must ha',e permanently attached to it a have permanently attached to it a durable tag at least one (1) inch durable tag at least one (1) inch i l l square bearing the prescribed square bearing the prescribed radiation caution symbol in radiation caution symbol in conventional colors, magenta or conventional colors, magenta, purple purple on a yellow background, and or black on a yellow background, and at least the instructions: Danger at least the instructions: " Danger -- Radioactive Material -- Do Not -- Radioactive Material -- Do Not Handle -- Notify Civil Authorities Handle -- Notify Civil Authorities if Found.' if Found." (f) Each exposure device using i DU shielding and an "S" tube l' l l

i configuration must be periodically tested for depleted uranium contamination. This test may be performed by the licensee using available test kits'or the exposure device may be returned to the manufacturer for such testing. This test must be undertaken at intervals not to exceed 12 months and should such testing reveal the presence of DU contamination, the exposure t device must be removed from use and-arrangements for proper disposal in accordance with 10 CFR Part 61 must be made. A record of the DU leak-test must be made in accordance with S 34.67. Section 34.26 Quarterly inventory. Section 34.29 Quarterly inventory. Each licensee shall conduct a (a) Each licensee shall cenduct quarterly physical inventory to a quarterly physical inventory to account for all sealed sources account for all sealed sources received and possessed under this received and possessed under this license. The records of the license. inventories shall be maintained for three years from the date of the (b) The licensee shall inventory for inspection by the maintain records of the quarterly Commission, and shall include the inventory in accordance with. quantities and kinds of byproduct S 34.69. material, location of sealed sources, and the date of the ) inventory, i l Section 34.27 Utilization logs. See S 34.71. j Each licensee shall maintain current logs, which shall be kept i available for three years from the date of the recorded event, for inspection by the Commission, at the address specified in the license, j showing for each sealed source the l following information: ) (a) A description (or make and. i model number) of the radiographic exposure device or storage container I in which the sealed source is located; (b) The identity of the l radiographer to whom assigned; and ( o

l' l (c) The plant or site where used and dates of use. Section 34.28 Inspection and Section 34.31 Inspection and maintenance of radiographic exposure maintenance of radiographic exposure devices, storage containers, and devices, storage containers, source changers. associated equipment, and source changers. f (a) The licensee shall check (a) The licensee shall visually for obvious defects in radiographic check for obvious defects in exposure devices, storage radiographic exposure devices, containers, and source changers storage containers, associated prior to use each day the equipment equipment, and source changers prior is used. to use_each day the equipment is ~ used to ensure that the equipment'is i in good working condition and that required labeling is present. If defects are found, the equipment must be removed from service until repaired, and a record must be made in accordance with 5 34.73. (b) The licensee shall conduct (b) Each licensee shall have a a program for inspection and program for inspection and routine maintenance of radiographic exposure maintenance of radiographic exposure devices, storage containers, and devices, source changers, associated source changers at intervals not to equipment and storage containers at exceed three months or prior to the intervals not to exceed.3 months and first use thereafter to ensure prior to the first use thereafter to proper functioning of components ensure the proper functioning of important to safety. The licensee components important-to safety. shall retain records of these Records of these inspection and inspections and maintenance for maintenance performed must be made three years. in accordance with S 34.73. If defects are found, the equipment must be removed from service until -) repaired, and a record must be made in accordance with S 34.73. t Section 34.29 Permanent radiographic Section 34.33 Permanent radiographic i installations. installations. i ) (a) Permanent radiographic (a) Permanent radiographic 1 installations having high radiation installations must have high area entrance controls of the types radiation area entrance controls of described in Section the types described in 20.203(c)(2)(ii), (2)(iii), or (4) S 20.1601(a)(2),(a)(3), or (b) of of this chapter shall also meet the this chapter and must also meet the following special requirement. following special requirements. i

(b) Each entrance that is used (b) Each entrance that is used for personnel access to the high for personnel access to the high radiation area in a permanent radiation area in a permanent radiographic installation to which radiographic installation to which this section applies shall have both this section applies must have both visible and audible warning signals visible and audible warning signals to warn of the presence of to warn of the presence of radiation. The visible signal shall radiation. The visible signal must be actuated by radiation whenever be actuated by radiation whenever the source is exposed. The audible the source is exposed. The audible signal shall be actuated when an signal must be actuated when an attempt is made to enter the attempt is made to enter _the installation while the source is installation while the source is

exposed, exposed.

(c) The alarm system must be (c) The alarm system must be tested at intervals not to exceed tested for proper operation at three months or prior to the first intervals not to exceed 3 months and use thereafter of the source in the the beginning of each day of installation. The licensee shall equipment use. The equipment use retain records of these tests for test must include a check of the three years. visible and audible signals by a crank out of the exposure device prior to use of the room. If a control device or alarm is operating improperly, it must be immediately labeled as defective and repaired before industrial radiographic operations are resumed. Test records must be maintained in accordance with S 34.75. REPORTING Section 34.30 Reporting See S 34.101. 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: u

I (1) Unintentional disconnection of the source assembly from the ,.l' 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 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. 1 (2) Cause of each incident, if known. (3) Manufacturer and model number of equipment involved in the i incident. (4) Place, time and date of the incident. 1 (5) Actions taken to establish i normal operations. (6) Corrective actions taken or i planned to prevent recurrence. 1 (7) Qualifications of personnel involved in the incident. i (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. See S 34.23. Section 34.35 Labeh, storage, and transportation precautions. (a) Labels. (1) The licensee may not use a source changer or container,to store licensed material unless the~ source changer or the container has securely attached to it a durable, legible, and clearly visible-label. The label must contain the' radiation symbol specified in S 20.1904 of this chapter and the wording l CAUTION (OR DANGER) RADIOACTIVE MATERIAL-DO NOT HANDLE

NOTIFY CIVIL AUTHORITIES (OR NAME OF COMPANY) l (2) The licensee may not transport licensed material unless the material is packaged, labeled, marked, and accompanied with appropriate shipping papers in accordance with regulations set out-in 10 CFR Part 71, including documentation of the QA program requirements outlined in S 71.105. (b) Security precautions during storage and transportation. (1) Locked radiographic-exposure devices and storage i containers must be physically secured to prevent tampering or removal by unauthorized personnel. The licensee shall store licensed material in a manner which. will minimize danger from explosion or fire. (2) The licensee shall lock and physically secure the transport package containing licensed material in the transporting vehicle to prevent accidental loss, tampering, or unauthorized removal of the licensed material from the vehicle. Subpart D -- Radiation Safety Requirements Section 34.41 Radiation Safety Officer. 1he Radiation Safety Officer shall ensure that radiation safety activities are being performed in accordance with approved procedures . and regulatory requirements in the daily operation of the licensee's. program. (a) The RS0's qualifications must include: (1) Completion of the training and testing requirements of-S 34.43(a); and (2) Two years of documented' experience in industrial t 1

radiographic operations, with at least 40 hours of formal classroom training with respect to the oversight of radiation protection programs. (b)-The specific duties of the RSO include, but are not limited to,. the following: (1) To establish and oversee operating, emergency, and ALARA procedures, and to review them regularly to ensure that the procedures are current and conform with '.hese rules; ti) To oversee and approve all phases of the. training program for radiographic personnel so that appropriate and effective radiation protection practices are taught; (3) To ensure that required radiation surveys and leak tests are performed and documented in accordance with these rules, including any corrective measures, when levels of radiation exceed established limits; (4) To ensure that personnel monitoring devices are calibrated and used properly by occupationally-exposed personnel, that records are kept of the monitoring results, and that timely notifications are'made as required by 5 20.2203; and-(5) To ensure that operations are conducted safely and to assume control and have the. authority to institute corrective actions including stopping of operations when necessary in emergency .i situations or unsafe conditions. Section 34.31 Training. Section 34.43 Training. (a) The licensee shall not (a) The licensee shall not permit any individual to act as a permit any individual to act as a t radiographer until such individual: radiographer until the individual --- (1) Has been instructed in the (1) Has been instructed in the subjects outlined in Appendix A of subjects outlined in S 34.43(f) of this part;- this part; (2) Has received copies of and (2) Has received copies of and-1 instruction in NRC regulations instruction in NRC regulations contained in this part; in S 30.7, i

contained in this part and in the 30.9, and 30.10; and in the applicable sections of Parts 19 and applicable sections of Parts 19, 20, 20 of this chapter, NRC license (s) and 71 of this chapter, in 49 CFR under which the radio;;rapher will Parts 171-173, in the NRC license (s) perform radiography, and the under which the radiographer will licensee's operating and emergency perform radiography, and the procedures; licensee's operating and emergency procedures; (3) Has demonstrated competence (3) Has demonstrated competence to use the licensee's radiographic to use the licensee's radiographic exposure devices, sealed sources, exposure devices, sealed sources, related handling tools, and survey related handling tools, and survey instruments; and instruments; and (4) Has demonstrated (4) Has demonstrated understanding of the in:tructions in understanding of the instructions in this paragraph (a) by successful this paragraph (a) by successful completion of a written test and a completion of a written test and a field examination on the subjects field examination on the subjects covered. covered in S 34.43(f). (b) The licensee shall not (b) The licensee shall not permit any individual to act as a permit any individual to act as a radiographer's assistant until such radiographer's assistant until the individual: individual -- (1) Has received copies of and (1) Has received copies of and instruction in the licensee's instruction in NRC regulations operating and emergency procedures; contained in this part; in S 30.7, 30.9, anns for exemptions. The Commission may, upon-application of any interested person

l or upon its own initiative, grant such exemptions from the. requirements of the regulations in this part as it determines are authorized by law and will not endanger life or property or the common defense and security and are otherwise-in the public interest. Subpart H -- Enforcement Section 34.121 Violations. (a) An injunction or other court. order may be obtained to prohibit a violation of any provision of this part. (b) A court order may be obtained for the payment of a civil penalty imposed for violation of this part. (c) Any person who willfully violates any provision of this part issued under section 161 b., i., or

o. of the Atomic Energy Act of'1954, as amended, or the provisions cited in the authority citation at the beginning of this part may be guilty of a crime and, upon conviction, may_

be punished by fine or imprisonment, or both, as provided by law. Section 34.123 Criminal penalties. (a) Section 223 of.the Atomic Energy-Act of 1954, as amended, provides-for criminal sanctions-for willful violation of, or conspiracy to violate, any regulation issued under sections 161b, 161i, or.1610.of the Act. For purposes of section 223, all the regulations in part 34 are issued under one or more of section 161b, 1611, or 1610, except for the sections listed in paragraph (b) of ' this section. j (b) The regulations of part 34 that are not issued under sections 161b,1611, or 1610 for the purposes-of section 223 are as follows: SS

34.1, 34.2, 34.3, 34.4, 34.8, 34.11, 34.51, 34.61, and 34.63.

• • • END OF DOCUMENT ***

a e 4 W

3, t t t i r l h t s 'I ATTACHMENT 2 1 Questions for the Agreement States ( i -t ..i p a h J t 1 -1 ^l J 1 1 -' l t i j l

't t i 1. Do you currently have the two-person rule in your regulations? 2. If yes, what was the economic impact to implement the two-person rule by -{ your licensees? 3. Do you currently have the requirement to designate a Radiation Safety j Officer (RS0) in your regulations? t 5. If yes, what was the economic impact to implement this requirement by your licensees? 6. Do you currently have the requirement to have visible and audible alarms l on permanent radiographic installations? l l 7. If yes, what was the economic impact to implement this requirement by your l licensees? 8. What will be the economic impact on small versus large businesses to implement these requirements? f i } !l r l 1 1 I l f

s ALL AGREEMENT STATES TRANSMITTAL OF STATE AGREEMENTS PROGRAM INFORMATION (SP-93-010) Your attention is invited to the attached correspondence which contains: INCIDENT AND EVENT INFORMATION....... PROGRAM MANAGEMENT INFORMATION....... TRAINING COURSE INFORMATION.......... TECHNICAL INFORMATION................ OTHER INFORMATION....................XXX Supplementary information: Enclosed is a " working draft" of the conceptual model of Radiocraphy Standard, 10 CFR Part 34. Please note that the conceptual model is presented in a side-by-side format with the existing Part 34 to facilitate comparison. The Commission is also requesting your assistance in developing a sound regulatory analysis of the proposed rule by responding to the questions submitted in Enclosure 2 To assure full consideration we are asking that your comments on the model rule and responses to the questionnaire be returned to our office not later than May 7, 1993 If you have further questions regarding this correspondence, please contact the individual named below: POINT OF CONTACT: Jim Myers TELEPHONE: (301) 504-2328 FAX (301) 504-3502 Vandy L. Miller, Assistant Director for State Agreements Program Office of State Programs

Enclosure:

As stated

ALL AGREEMENT STATES TRANSMITTAL OF STATE AGREEMENTS PROGRAM INFORMATION (SP-93-010) Your attention is invited to the attached correspondence which contains: INCIDENT AND EVENT INFORMATION....... PROGRAM MANAGEMENT INFORMATION....... 1 TRAINING COURSE INFORMATION.......... TECHNICAL INFORMATION................ OTHER INFORMATION....................XXX Supplementary information: Enclosed is a " working draft" of the conceptual model of Radiography Standard, 10 CPR Part 34. Please note that the conceptual model is presented in a side-by-side format with the existing Part 34 to facilitate comparison. The Commission is also requesting your assistance in developing a sound regulatory analysis of the proposed rule by responding to the questions submitted in Enclosure 2 To assure full consideration we are asking that your comments on the model rule and responses to the questionnaire be returned to our office not later than May 7, 1993 If you have further questions regarding this correspondence, please contact the individual named below: POINT OF CONTACT: Jim Myers TELEPHONE: (301) 504-2328 FAX (301) 504-3502 Vandy L. Miller, Assistant Director for State Agreements Program Office of State Programs j

Enclosure:

As stated i Distribution: CKammerer VLMiller SSchwartz DIR RF SA RF JMyers ALL AS File RSAOs RSLOs CTrottier/RES DCool/RES ALL AS File s i i i i 0FC SP:SA SP:SA:A_D SP:D ____4__ _4, _ _,, _,,4, __ _ _. JMyers:dd VMiller NME 4.CKammerer _ 4. ____4.,_ _,4_ __4_ __4__ _ _, e i DTEl04/13/93 l 04/ /93 s04/ /93 SP93010.jhm

..s TO: Assistant Director for State Agreements Program

SUBJECT:

RESPONSE TO ALL AGREEMENT STATES LETTER (SP-93-010) CONCEPTUAL MODEL OF RADIOGRAPHY STANDARD, 10 CFR PART 35 Please check one of the following: 0 We acknowledge receipt of the referenced letter and have no comments. O We acknowledge receipt of the referenced letter and providing comments which are attacaed. {Short responses may be faxed to (301) 504-3502.} O Other (please explain under comments). Comments (use additional sheets as appropriate): l Please complete the following information: Signature: Name:

Title:

Date: State Programs

Contact:

Jim Myers State Agreements Letter Number: (SP-93-010) Response Due: NAY 7, 1993 PLEASE TYPE OR PRINT YOUR STATE ABREVIATION HERE: i 6}}