ML20134F954

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Discusses Review of Draft Proposed Colorado Rule,Part 19, Radiation Safety Requirements for Irradiators, Dtd 961010.Proposed Part 19 Encl
ML20134F954
Person / Time
Issue date: 11/01/1996
From: Lohaus P
NRC OFFICE OF STATE PROGRAMS (OSP)
To: Quillin R
COLORADO, STATE OF
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ML20134F957 List:
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NUDOCS 9611080212
Download: ML20134F954 (44)
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I Mr. Robert Quillin, Director Radioactive Control Division Colorado Department of Public Health and Environment l

4300 Cherry Creek Drive South (RCD-DO-B1)

Denver, CO 80222-1530 1

Dear Mr. Quillin:

1 We have reviewed the draft proposed Colorado rule, Part 19, Ucensing and Rediation Safety Requirements for irradiators dated October 10,1996. The proposed rule was 0 viewed by comparison to the equivalent NRC regulations in 10 CFR Part 36. Dr. Stephen N. Saior. con acknowledged receipt on October 10,1996, of an earlier version of the proposed rule datcd September 18,1996, that was sent by your staff, Ms. Michelle Sime Moore, to Charles Hackney, Regional IV State Liaison Officer, on September 17,1996. Dr. Salomon received by facisimle on October 21,1996 your staff's follow up version dated October 10. The revised version included the omissions, mainly of a word processing nature, that Dr.

Salomon flagged to the attention of Mr. Chuck Mattson in a telephone call on October 10, i

1996. Also, Mr. Mattson flagged to Dr. Salomon several additional word changes that were incorporatad by him since the initial draft of September 18,1996, was sent.

As the result of the review of the October 10,1996, version, we have no comments.

Under our current procedure, a finding that a rule meets the compatibility requirements may only be made based on a review of the final text of the rule. However, we have determined that if the proposed rules were adopted without significant change, they would be compatible.

We request that when the proposed rules are adopted and published as final rules, a copy of the "as published" rules be provided to us for review. As requested in our All Agreement States Letter SP 96-027, " Request to Highlight Changes to Agree.T.ent State Regulations Submitted to NRC for Compatibility Review" (March 1,1996), please hignlight the final changes and send one copy in a computer readable format, if possible.

If you have any questions regarding the comments or any of the NRC rules used in the review, please contact me or Dr. Stephen N. Salomon of my staff at (301) 415-2368, or INTERNET: SNS@iNRC. GOV.

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.i Mr. Robert Quillin, Director Radioactive Control Division Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South (RCD-DO-B1) i

' Denver, CO 80222-1530 i

Dear Mr. Quillin:

We have reviewed the draft proposed Colorado rule, Part 19, Licensing and Radiation Safety Requirements for Irradiators dated October 10,1996. The proposed rule was reviewed by i

comparison to the equivalent NRC regulations in 10 CFR Part 36. Dr. Stephen N. Salomon l

acknowledged receipt on October 10,1996, of an earlier version of the proposed rule dated

^

September 18,1996, that was sent by your staff, Ms. Michelle Sime Moore, to Charles Hackney, Regional IV State Liaison Officer, on September 17,1996. Dr. Salomon received l

by facsimile on October 21,1996 your staff's follow up version dated October 10. The revised version included the omissions, mainly of a word processing nature, that Dr.

Salomon flagged to the attention of Mr. Chuck Mattson in a telephone call on October 10, 1996. Also, Mr. Mattson flagged to Dr. Salomon several additional word changes that were i

a j

incorporated by him since the initial draft of September 18,1996, was sent.

1 i

As the result of the review of the October 10,1996, version, we have no comments.

Under our current procedure, a finding that a rule meets the compatibility requirements may only be made based on a review of the final text of the rule. However, we have determined i

that if the proposed rules were adopted without significant change, they would be compatible.

i We request that when the proposed rules are adopted and published as final rules, a copy of the "as published" rules be provided to us for review. As requested in our All Agreement States Letter SP-96-027, " Request to Highlight Changes to Agreement State Regulations Submitted to NRC for Compatibility Review" (March 1,1996), please highlight the final changes and send one copy in a computer readable format, if possible.

if you have any questions regarding the comments or any of the NRC rules used in the i

review, please contact me or Dr. Stephen N'. Salomon of my staff at (301) 415 2368, or INTERNET: SNS@NRC. GOV.

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10/22/1996 11:00 303-782-5083 PAD.CCt1T. DIV. - C[tPHE PAGE 01 0 1 - PAGE NOTE DOCUMENT COVER SHEET

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10/22/1996 11:20 303-782-5083 PAD. CO IT. DIV. - C['.4E PAGE 02

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DRA T

October 10, 1996 1

PART 19 3

3

. LICENSES RADIATION SAFETY REQUIREMENTS FOR IRRADIAToRS 4

-Q b

GENERAL PROVISIONS I& O 6

7 8

RH 19.1 roome and Scone.

9

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10 19.1.1 Part 19 contains requiremente for the issuance of a license Al authorizing the use of sealed sources containing radioactive 12 materials in irradiators used to irradiate objects or materialu 13 using gamma radiation. Part 19 also containa requirements for 14 operating irradiators. The requiremento of this part are in I

'19 addition to the requirements of Parts 3, 4,

10, 12, 13, and 17.

16 Nothing in this part relieven the licenace from complying with 17 other applicable Federal, State and local regulations governing 18 the citing, zoning, land use, and building code requiremento for f

19 industrial facilities.

30 21 19.1.2 The regulations in this part apply to panoramic irradiators that l

22 have either dry or wet storage of the radioactive sealed sources 23 and to underwater irradiators in which both the source and the 24 product being irradiated are under water.. Irradiators whose dose 1

25 raten exceed 5 grays (500 rado) per hour at 1 meter from the 25 radioactive sealed sources in air or in water, as applicable for i

27 the irradiator type, are covered by this part.

2a 20 19.1.3 The regulatione in this part do not apply to self-contained dry-l

-30 novrce-ntorage irradiators (thooe in which both the cource and the 31 are a subject to irradiation are contained within a device and are j

32 not accencible by personnel), medical radiology or teletherapy, 33 radiography (the irradiation of materials for nondestructive 19 - 1

'10/22/1996 11:20 303-782-5083 PAD. CONT, DIV. - CIME PAGE.03 DRAFT october 10, 1996 1

testing purposes), gauging, or open-field (agricultural) 3 irradiations.

3 4

J 5

RH 19.2 efinitions.

/

6 7

" Annually

  • means either (1) at intervals-not to exceed 1 year or 8

(2) once per year, at about the same time each year (plus or minus

-9 1 month).

'10 11

" Doubly encapsulated sealed source" means a sealed source in which 12 the radioactive material is sealed within a capsule and that 13 capsule is sealed within another capsule.

14 15

/ "Irradiator" means a facility that usan radioactive sealed sources 16 for the irradiation of objects or materials and in which radiation 17 dose rates exceeding 5 grays (500 rads) per hour exist at 1 meter 20 from the sealed radioactive sources in air or water, as applicable 19 for the irradiator type, but does not include irradiators in which 20 both the sealed source and the area subject to irradiation are al contained within a device and are not accessible to personnel.

22 33 "Irradiator operator" means an individual who has successfully 24 completed the training and testing described in RH 19.18 and is 25 authorized by the terms of the license to operate the irradiator 26 without a supervisor present, j

27 28

" Panoramic' dry-source-storage irradiator" means an irradiator in 29 which the irradiations occur in air in areas potentially 19

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10/22/1996 11:20 303-782-5083 PAD. CONT.DIV.- CDPHE PAGE 04 t

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- DRAFT October-10, 1996 1

accessible'to personnel and in which the sources are stored in 2

shields made of solid materials. The term includes beam-type' dry-3 source-storage irradiatorn in which only a narrow beam of 4

radiation is produced for. performing irradiations.

I 5

~

6

" Panoramic irradiator" means an irradiator in which the 7

irradiations are done in'a'ir in areas potentially accessible to 8

personnel. The term includes beam-type irradiators.

3 9

/"Panoramicwetsource-storage irradiator" means an irradiator in 10 11 which the irradiations occur in air in areas potentially la accessible to personnel and in which the sources are stored under 13 water in a storage pool.

I 14 1'

15

" Pool irradiator" means any irradiator at which the sources are 16 stored or used in a pool of water including panoramic wot-source-17 storage irradiators and underwater irradiators.

18 19 V " Product conveyor system" means a system for moving the product to 20 be irradiated to, from, and within the area where irradiation 21 takes place.

22 23

" Radiation room" means a shielded room in which irradiations take 34-place. Underwater irradiators do not have radiation rooms 29 36

" Seismic area" means any area where the probability of a 37 hori2ontal acceleration in rock of more than 0.3 times the 28 acceleration of gravity in 250 years; in greater than 10 percent, 29 as designated by the U.S. Geological Survey.

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" Underwater irradiator a means an irradiator in which the nources 2

'alwayn remain shielded under water and humana do not have access 3

to the sealed sources or the space subject to irradiation without 4

entering the pool.

1 5

1 6

.:p' 7

Specific Licensing Requiremente 8

9 Ril 19.3 I

Apolication For a Seecific License.

10

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11 19.3.1 A person shall file an application for a specific license-12 authorizing the use of cealed sources in an irradiator pursuant to 13 Ril 3.8 of the regulations.

14 g

15 RH 19.4 Enecific Licenses for Irradiatore.

16 17 19.4.1 The Department will approve an application for a specific license 18 for the use of licensed material in an irradiator if the applicant 19 meets the requirementa contained in this section.

20 21 19.4.2 The applicant shall satisfy the general requirements specified in 22 RH 3.9 of the regulations and the requirements contained in this 23 part.

I 24 1

i 25 19.4.3 The applicant must describe the training provided to irradiator 26 operators including:

27 28 19.4.3.1 Classroom training; 29 I

19 - 4

10/22/1996 '11:20 303-782-5083 PAD.CCtiT.DIV. - CDPHE PAGE 06 4-

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DRAFT October 10, 1996 1

C 9.4.3.2 On-the-job or simulator training; 3-3

[9.4.3.3 Safety reviews; 4

5 19.4.3.4

. Means employed by t'he applicant to test each operator's 6

understanding of the Department'n regulations and licensing 7

requirements and the irradiator operating and emergency 8

procedures; and 9

1 10 19.4.3.5 Minimum training and experience of personnel who may provide

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11 training.

l 13 g[9.4.4 The application must include an outline of the written operating 13 14 and emergency procedures listed in RH 19.19 that describes the A5 radiation safety aspects of the proceduren.

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16 17 19.4.5 The application must describe the organizations'. structure for le managing the irradiator, specifically the radiation safety 19 responsibilities and authorities of the radiation safety officer 20 and thoec management personnel who have important radiation safety l

21 responsibilities or authorities. In particular, the application l

22 must specify who, within the management st.ructure, has authority 23 to stop unsafe operations. The application must also describe the 24 training and experience required for the positio., cf radiation 35 aafety officer I

26 37 9.4.6 The application must include a description of the acceen control 28 systems required by RH 19.8, the radiation monitora required by RH 39 19.11. the method of detecting leaking sources required by RH 19

-5

10/22/1996 11:20 303-782-5083 PAD.COtlT.DIV.- CDPHE PAGE 07 DRA FT October 10, 1996 1

19.22 including the sensitivity of the method, and a diagram of a

t.he facility that shows the locationn of all required interlocks 3

and radiation monitors.

4 5

19.4.7 If the applicant intends to perform leak testing of dry-nource-6 storage sealed nources, the applicant shall establish procedures 7

for leak testing and submit a description of these procedures to 8

the Departmunt. The description must include the:

9 10 19.4.7.1

/ Instruments to be used; 11 A2 19.4.7.2 Methods of performing the analycio; and 13 J

14 19.4.7.3 Pertinent experience of the individual who analyzes the 15 eamples.

16 17 19.4.8 V If licenaec personnel are to load or unload sources, the applicant 10 shall describe the qualificatione and training of the personnel 19 and the procedures to be used. If the applicant intendo to 20 contract for source loading or unloading at its facility, the 21 loading or unloading must be done by an organization specifically 22 authorized by the U.

S.

Nuclear Regulatory Commission or an 23 Agreement State to load or unload irradiator sources.

24 25 19.4.9

/ The applicant shall describe the inspection and maintenance l

26 checks, including the f requency of the checkn required by l

27 RH 19.23.

28 29 RH 19.5 s t a rt of cons t ruct i on.

19 - 6 l

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1 10/22/1996 11:20 303-782-5083 PAD. CONT.DIV.- CDPHE PAGE 08 DR AFT October 10, 1996 1

19.5.1 The applicant may not begin construction of a new irradiator prior 2

to the submission to the Department of both the application for a 3

license for the irradiator and the fee required by Part 12 of the 4

regulations. As used in this section, the term " construction" 5

includes the construction of any portion of the permanent 6

irradiator structure on the nite but does not includes engineering 7

and design work, purchase of a site, site surveys or soil testing, O

site preparation, site excavation, construction of warehouse or 9

auxiliary otructuren, and other similar tasks. Any activitica 10 undertaken prior to the issuance of a licence are entirely at the 11 risk of the applicant and have no bearing on the issuance of a 12 license with respect to the requirements of The Act, and rules, 1

13 regul tions, and ordero icoued under The Act.

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15 Ril 19.

unlications for Exemntions.

16 17 19.6.1/

Any application for a licence or for amendment of a license le authorizing une of a teletherapy-type unit for irradiation of 19 materials or objects may include propoecd altr,rnatives for the 20 requirements of this part. The Department will approve the 21 proposed alternatives if the applicant provides adequate rationale 22 for the proposed alternatives and demonstrates that they are 23 likely to provide an adequate level of safety for workers and the i

24 public.

I fec gg M73 qw, c s i n3, C h u e L IVicdison sa7a.3 cc,v e r ed W V o 27 Design and Performance Requirements for Irradiato gn ] 28 Y { /O f id h6 29 RH 19.7 Performance Cri t e ri a for Sealed Sourggg, / 19 - 7

10/22/1996 11:20' 303-782-5083 PAD. CONT. DIV. - CE7tE PAGE 09 DH AFT October 10. 1996 1 19.7.1 Requiremento. Scaled sources installed after January 1, 1997: 3 3 19.7.1.1 D Must have a certificate of registration issued by the U.S. 4 Nuclear Regulatory Commission or an Agreement State; 5 g!Mustbedoublyencapsulated; 6 19,7.1.2 I 7 g[Must.useradioactivematerialthat 8 19.7.1.3 is as nondispersible as 9 practical and that is an insoluble as practical if the 10 't source is used in a wet-source-storage or wet-source-change 11 irradiator; 12 13 19.7.1.4 h Must be encapsulated in a material resistant to general 14 . corrosion and to localized corrosion, such as 316L stainless 15 atnel'or other material.With equivalent resistance if the 16 sources are used in irradiator pools; and 17 18 19.7.1.5 v In prototype testing of the nealed source, must have been 19 leak-tasted and found leak-free after each of the testa 20 described in Rll 19.7.1.5.1 through 19.7.1.5.6. 21 j/ emperature. The test 22 19.7.1.5,1 T source must be held at - 4 0*C f or 23 20 minuten, 600*C f or 1 hour, and then be subjected to. 24 a thermal shock test with a temperature drop from 25 600'C to 20^C within 15 seconds. 36 l i 27 19.7.1.5.2 Pressure. The test source must be twice subjected for j 38 at least 5 minutes to an external pressure (absolute) 29 of 2 million newtons per equare meter. 19 - 0

10/22/1996 11:20 303-782-5083 PAD.CCD4T. DIV. -.CIME PACE 10 i .t 4 DR AFT October 10, 1996 p/ Impact, A 2-kilogram steel weight, 2.5 centimeters in 1 19.7.1.5.3 2 diameter, must be dropped' f rom a height of 1 noter 3 onto the test source. 4 5 19.7.1.5.4 / Vibration. The test source must be subjected 3 times 6' for 10 minutes each to vibrations sweeping from 25 hertz'to 500 hertz-with a peak amplitude of S times, 7 7 i e the acceleration of. gravity. In addition, each test 9 source must be vibrated for 30 minutes at each j 1 10 resonant frequency found. I. Al / 3 / la 19.7.1.5.5 Puncture. A 50-gram weight and pin, 0.3-centimeter pin j 13 diameter, must be dropped from a height of 1 meter i 14 onto the test cource. 7 A5 16 19.7.1.5.6 Dend. If the length of the source is more than 15 i 17 times larger than the minimum cross-sectional 18' dimension, the teot cource must be subjected to a j 19 force of 2000 newtons at its center equidistant from -) 20 two support cylindern, the distance between which is 21 10 times the minimum crous-sectional dimension of the l 32 /(f cource. \\Y 33 i 24 RH 19.8 j Access' Control. '35 26 19.8.1 b Each entrance to a radiation room at a panoramic irradiator must 27 have a door or other physical barrier to prevent inadvertent entry 20 of personnel if the sources are not in the shielded position. -29 Product conveyor systems may serve ao barriera as long as they 19 - 9

10/22/1996 11:00-393-782-5083 PAD. cot 1T.DIV. - CIME PAGE 11 ~ DRAFT October 10, 1996 I I i 1 reliably and consistently function as a barrier. It must not be a possible to move the sources out of their shielded position if the 3 door or barrier is open. Opening the door or barrier while the 4 sources are exposed must cause the sources.to return promptly to 5 their shielded position. The personnel entrance door or barrier '6 oust have a lock that to operated b'y the same key used to move the 7 sourc60. The doors and barriers must not prevent any individual in 8 the radiation room from leaving. 9 l 10 19.8.2 In addition, each entrance to a radiation room at a panoramic ~ 13 irradiator must have an independent backup access control to 12 detect personnel entry while the sources are exposed. Detection of ) i 13 -entry while the sources are exposed must cause the sources to 14 return to their fully chielded position and must also activate a 15 visible and audible alarm to make the individual entering the room 16 aware of the hazard. The alarm must also alert at least one other 17 individual who is onsite of the entry. That individual shall be 18 trained on how to respond to the alarm and be prepared to promptly 19 render or summon anaistance. ./. 21 19 8.3 .A radiation monitor must.be provided to detect the presence of 22 high radiation levels in the radiation room of a panoramic 23 irradiator before personnel entry. The monitor must be integrated 20 with personnel accese door' locks to prevent room access when 25 radiation levels are high. At. tempted personnel entry while the 26 monitor measures.high radiat. ion levels, must activate the alarm describedinRH19.8.2.}ThemonitormayLalocatedintheentrance3 27 h(normallyreferredtoasthemaze) but not in the direct radiation 28 29 beam. f k 8 C h) Lt t k hy e, n ot bMO d 19 - 30 C l wh y N prio wt. co ha g ~ % v eMQu ire. pal w ro J m +or u l. E.3 m g g.,m a; lad y am Yrvj e b 3d h hn b h n e'c I _3 M M e. % erpla i n, sfeut [" g fgon gjwm j

10/h2/1996 11:b0 303-780-5083 PAD.CalT.DIV.- CDPHE PACE 12 l DRAPT October 10, 1996 1 1 19.8.4 / Before the nources move from their shielded position in a ) a panoramic irradiator, the source control must automatically 3 activate conspicuous vinible and audible alarms to alert people in 4 the radiation room that the sources will be moved from their 5 shielded position. The alarma must give individuals enough time to 6 leave the room before the sources leave the shielded position. 7 8 19.0.5 Each radiation room at a panoramic irradiator must have a clearly 9 visible and readily acceocible control that would allow an 10 individual in the room to make the sources return to their fully la shielded position. 12 13 19.8.6 Each radiation room of a panoramic irradiator must contain a 14 control that prevente the cources from moving from the shielded 15 position unleon the control has been activated and the door or 16 barrier to the radiation room has been closed within a preset time 17 after activation of the control. AU 19 19.8.7,. Each entrance to the radiation room of a panoramic irradiator and 20 each entrance to the area within the personnel access barrier of 21 an underwater irradiator must have a sign bearing the radiation I 0 ymbol and the words, " Caution (or danger) radioactive material" 22 7 3 n < 3[,p Panoramic irradiators must. also have a sign otating j" Grave danger, vc 0 23 r ~ Yd very high radiation area"[ but the sign may be removed, covered, N(g IS,p\\eorotherwisemadeinoperative 24 \\ -{\\ 25 g when the sources are f ully shielded. 26 .@( \\ Y If the radiation room of a panoramic irradiator has roof plugs or 27 19.0 28 h hd other movable shielding, it must not be possible to operate the 29 gA. 3 irradiator unless the shielding is in its proper location. This \\b *- p v0 see y*$ 1902 oo ad Adf % Mb o >o3, pA

. _ _ = _ _ _.. _ _... _ _ _-m 10/22/1996 11:20 303-782-5083 PAD.CGIT. DIV. - C[ME PAE 13. 4 DRAFT October 10, 1996 a 1 requirement may be met by interlocks that prevent operation if shielding is'not placed properly or by an operating procedure i 3 requiring inspection of shielding before operacing. i s 5 19.0.9 / nderwater irradiatora must have a personnel access barrier around 6 the pool which must be locked to prevent acceso when the 7 irradiator is not attended. Only operatore and facility management a may have access to keys to the personnel access barrier. There 9 must be an intrusion alarm to detect unauthorized entry when the 10 personnel access barrier in locked. Activation of the intrusion 11 alarm must. alert an individual (not necessarily onsite) who is 12 prepared to respond or summon assistance. 13 S/ e k. RH 19.9 J)N 14 Shieldina. 4 15 16 19.9.1 The radiation dose rate in areas that are normally occupied during 17 operation of a panoramic irradiator may not exceed 0.02 9 1 18 millisievert (2 millirem) per hour'at'any location 30 centimeters 19 or more from the. wall of the room when'the sources are exposed. 30 The dose rate must be averaged over an area not to exceed 100 21 square'cantimeters having no' linear dimension greater than 20 22 centimeters. Areas where the radiation dose rate exceeds 2 23 millirem (0.02 millisieverto) per hour must be locked, roped off, ~ 34 or posted. 39 = l 26' 19.9.2 The radiation dose at 30 centimeters over.the edge of the pool of 4 4 27 a pool Arradiator'may not exceed 0.02 millisieverts (2 millirem) S 28 per hour when the sources are in the fully chielded position. 29 i 19 - 12 4 k l

10/22/1996. 11:20 303-782-5083 PAD. Cot 1T.DIV.- CNEE PAGE 14 pRAFT October 10, 1996 i 1 19.9.3 The radiation dose rate at 1 meter f rom the shield of a dry-2 source-storage panoramic irradiator when the source is shielded ~, 2 may not exceed 0.02 millisievert (2 millirem) per hour and at 5 4 centimeters from the shield may not exceed 0.2 millisievert (20 i ) millirem) per hour. i 6 \\Jj ' f g RH 19.10) I ' ire Protection, 7 f v s 8 9 19.10.1 The radiation room at a panoramic irradiator must have heat and 10 smoke detectors. The detectors must activate an audible alarm. The 11 alarm must be capable of alerting a person who is. prepared to 12 oummon anaistance promptly. The cources must automatically become l -13 fully shielded if a fire is detected. 14 / 15 19.10.2 The radiation room at a panoramic ir, radiator must be equipped with 16 a fire extinguishing system capable of extinguishing a fire 17 without the entry of personnel into the room. The system for the 10 radiation room must have a chut-off valve to control flooding into 19 unrestricted areas. 20 t iVj 21 RI! 19.11 Radi at ion Mg11ROIa. 23 Y 23 19.11.1 Irradiators with automatic product conveyor systema must have a 24-radiation monitor with an audible alarm located to detect loose 26 radioactive pources t. hat are carried toward the product exit. If 26 the monitor detects a pource, an alarm must cound and product 27 conveyors must stop automatically. The alarm must be capable of 28 alerting an individual in the facility who is prepared to summon 20 assistance. Underwater irradiators in which the product moves 19 - 13

-n. _ _ =. _, ~ 10/22/1996' 11:20 303r782-5083 PAD. CONT. DIV. - CIME PAGE 15 1 4 j A A s 4 DRA PT October 10, 1996 1 1 1-1 vithin an enclosed stationary tube are exempt from the a requiremente of this ' paragraph. I 3 . h/ 4 4 39.11.2 Underwater irradiators that are not' in a shielded radiation room ] 5 must have a radiation monitor over the pool to detect abnormal I 6 radiation levels. The monitor must have an audible alarm and a 7 visible indicator at. entrances to the personnel access barrier i 8 around the pool. -The audible alarm may have a manual shut-of f. The 9 alarm must be capable of alerting an individual who is prepared to e 4 10 respond promptly, t* 11 F 12 RH 19.1 E2Dtrol of Source Movement. 13 14 19.12.1 [/ The mechanism that moves the sources of a panoramic.irradiator j 15 must require a key to actuate. Actuation of the mechanism must i 16 cause an audible signal to indicate that the sources are leaving 3 17 the shielded pooltion. Only one key may be used at any time, and la only one operator or facility management may possess it. The key j 19 must be attached to a portable radiation survey meter by a chain t 30 or cable. The lock for source control must be designed so that the k 21 key may not be removed if the sources are in an unshielded 22 position. The door to the radiation room must require the same i 23

key, i

1 24 25 19.12.2 The console of a-panoramic irradiator must have a source position [ 1 26-j indicator that indicates when the. sources are in the fully a 37 shielded position, when they are in transit, and when the cources 20 j are exposed. 29 I 19 - 14 i i ) i

10/02/1996 11:00 303-782-5083 RAD. 00 4T. DIV. - CLME PAGE 16 2_R A F T october 10, 1996 / 2 19.12.3 The control console of a panoramic irradiator must have a control 2 at promptly returns the cources to the shielded position. 3 i ach control for a panoramic irradiator must be clearly marked as 4 19.12.4 E 5 to its f unction. 6 ,,/ v 7 R11 19.13 o Irig41ator Pools. / \\ or licennen 9 19.13.1 F initially icoued after January 1. 1997, irradiator 10 pooln must either: 11 12 19.13.1.1 lave a water-tight stainlcon steel liner or a liner 13 metallurg1cally compatible with other componento in the 14 pool; or 15 16 19.13.1.2 De constructed so that there is a low likelthood of 17 substantial leakage and have a surface designed to 18 facilitate decontamination. In either case. the licenoee 19 shall have a method to safely atore the pources during 20 repairs of the pool. 21 22 19.13.2 For licences initially issued after January 1, 1997 irradiator 33 pools must have no outleta nore than 0.5 meter helne the normal 24 low water level that c0uld allow water to drain out of the pool. 25 Pipes that have intakes more than 0.5 meter below the normal low l 26 water level and that could act as siphona munt have siphon l 27 breakers to prevent the siphoning of pool water. l l I 29 19.13.3 A means must be provided to replenich water losses from the pool. 19 - 15 I l

n.-.. 10/22/1996.11:20 303-782-5083 PAD.COrlT.DIV.- CDPKE_ PAGE' 17 r DRAPT October 10,'1996 p/A visible indicator must be provided in a clearly visible 1 19.13.4 location a to indicate if the pool water level is below the normal low water 3 level or above the normal high water level. 4 l )1rradiatorpoolsmustbeequippedwithapurificationayatem 5 19.13.5 6 designed to be capable of maintaining the water during normal 7 operation at a conductivity of 20 microsiemens per centimeter or 0 lass and with a clarity so that the sources can be seen clearly 9 (/A physical barrier. such an a railing or cover, must be used 10 19.13.6 11 around or over irradiator pools during normal operation to prevent 12 personnel from accidentally falling into the pool. The barrier may 13 be removed during maintenance, inspection, and service operatione. j/ 14 15 19.13.7 If long-handled tools or polen are used in irradiator pools, the 16 radiation dose rate on the handling areas of the tools may not 17 exceed 0.02 millinievert (2 millireme) per hour. 30 .y \\ 13 RH 19.14 / Source Rack Protection, g/ 31 19.14.1 If the product to be irradiated moves on a product conveyor 22 system, the source rack'and the mechanism that moves the rack must 33 be protected by a barrier or guides to prevent products and 24 product carriers from hitt2ng or touching the rack or mechanism. 25 ) 36 RH 19.15 Powar Fallureg. 27 / 38 19.15.1 If electrical power at a panoramic irradiator is loot for longer l 29 than 10 secondo, the sources must automatically return to the 19 - 10 I

m. 10/22/1996 11:00-303-782-5083 ~ PAD. col 4T.DIV.- CEM E PEE 18 l i I i E i i i DP A FT October 10, 1996 l 1 shielded ponition, a /' I 3 19.15.2 VThe lock on the door of the radiation room of a panoramic 4 irradiator may'not be deactivated by a power failure. t l 5 6 19.15.3 During a power failure, the area of any irradiator where sources

  • /

are located may be entered only when using an operable and i I 8 calibrated radiation survey meter. 9 M RH19.1Gfil. D 10 / ealan Recuiremquig, 11 i I 12' 19.16.1 Irradiators whose construction begins after January 1, 1997, must i 13 meet the design requirements of this section. [ t 14 y/ 15 19.16.1.1 Shielding. For panoramic irradiators, the licensee shall i 1G denign shielding walls to meet generally accepted building { r - 17 code requirements for reinforced concrete and design the ] 18 walls, Wall penetrations, and entranceways to meet the h 19 radiation shielding requirements of RH 19.9. If the t 30-irradiator will use more than 2 X 10" becquerels (5 million s t 21 curies) of activity, the licensee shall evaluate the effects i 22 of heating of the ahielding walla by the irradiator sources. [ l t L 23 i i 24 19.16.1.2 Foundatione. For panoramic irradiatore, the licensee shall [ j t 25 design the foundation, with consideration given to soil t 26 characteristics, to ensure it in adequate to support the 37 weight of the facility shield walls. l g/ l 28 29 19.16.1.3

Pool integrity. For pool irradiatorp, the licensee chall 1.

t 19 - 17 l t = L l i

..m 10/22/1996 11:00 ~303-782-5083 PAD.CCalT DIV. - CIME PAGE 19 l l l DRAFT October 10, 1996 l l I design the poo1J o aneure that it in leak resistant, that it t 2 is strong enough to bear the weight of the pool water and 3 shipping casks, that a dropped cank would not fall on sealed 4 sourcea, that all outlets or pipes meet the requirements of 5 RH 19.13.2, and that metal components are metallurgically ~ i G compatible with other components in the pool. i 7 8 19.16.1 4 Water handling system. For pool irradiators, the licensee 9 mhall verify that the design of the water purification l 10 system is adequate to meet the requirements of RH 19.13.5. Il The oyotem must be designed no that water leaking from'the l 12 nyatem does not drain to unrestricted areas without being 13 monitored. 14 \\! Radiation monitors. i 15 19.16.1.5 For all irradiators, the licensen shall 16 evaluate the location and sensitivity of the monitor to 17 detect sources carried by the product conveyor ayatem as 18 required by RH 19.11.1. The licensee shall verify that the l 19 product conveyor is designed to stop before a cource on the 20 product conveyor would cause a radiation overexposure to any 21 person. For pool irradiatore, if the licensee uses radiation i.. l 32 menitore to detect contamination under RH 19.22.2, the l 33 licensee shall verify that the design of radiation 24 monitoring systems to detect pool contamination includes 25 sensitive detectors located close to where contamination is 26 likely to concentrate. 27 / q / ource rack. For pool irradiators, i 38 19.16.1.6 S the licensee shall verify } 29 that there are no crevices on the cource or between the 1 4 4 19 - 18 I i i

.~ _ 10/22/1996 11:20 303-782-5083 PAD.CCt4T.DIV. - CIME Pt/E 20 l DMAFT October 10, 1996 1 source and source holder that would proacte corrosion on a a critical area of the source. Por panoramic irradiators, the j 3 licensee shall determine that source rack drops due to loss l f 4 of power will not damage the source rack and that source i 5 rack drops due to failure of cables (or alternate means of i 6 support) will not cause loca of integrity of eealed sources. 7 For panoramic irradiators, the licensee shall review the o design of the mechanism that moves the sources to assure 9 that the likelihood of a stuck ocurce is low and that, if 10 the rack sticks, a meano exista to free it with minimal risk i 11 to personnel. 32 / 13 19.16.1.7 6 Access control. For panoramic irradiators, the licensen 14 shall verify from the design and logic diagram that the j 15 access control ayatem will meet the requirementa of RH 19.8. 16 17-19.16.1.6 y Fire protection. For panoramic irradiators, the licensee 18 shall verify that the number, location, and spacing of the 19 omoke and heat detectors are appropriate to detect fires and 20 that the detectora are protected from mechanical and 31 radiation damage. The licensee chall verify that the design .23 of the fire extinguishing system provides the necessary 23 discharge patterna, densities, and flow characteristics for { i 34 complete coverage of the radiation room and that the ayatem 25 is protected from mechanical and radiation damage. j 23 27 19.16.1.9 Source retuzn. For panoramic irradiators, the licennen shall 20 verify that the cource rack will automatically return to the 29 fully shielded position if facility power is lost for more 19 - 19 3 v

- _.... ~. -.. - - 10/22/1996 11:20-303-782-5083 PAD.CQ1T.DIV.- Cle E Pyf 21 l p j jg Q]/ 6f 0 $ /d l / 0 8,'. c4co med dW ~ u she y,* + a &,, V_E_h_E_T +p a m, /o r pccMcjand l ve ai"' C $ 00 yy jg ctober 10 1996 y reog;/7 ct unikUe. /SC / M -19 was k c/ c s av em a, s e l 1 than 10 seconds. [-/ 6 7# dFO 2 i l 3 '19.16.1.10 Seismic. For panoramic irradiatorn to be built in seismic j hM 4 a re s s', the licensee shall design the rainforced concrete g radiation chields to retain their integrity in the event of Q

j. [ < ^ fob an earthquake by denicyning to the seis 6

cb appropriate source such as hrrentnationalstandardsor 7 p0 local building codem. 7g gg ey/ /d N 8 bu+ acc y loh/&. Sw e-w>o il Srnn Ch e,y l k nier. 10 19.16.1,11 [ Wiring. For panoramic irradiators, the licensee nhall verify a lsa l 11 that electrical wiring and electrical equipment in the ' YC)?v) 12 radiation room are selected to minimize failures due to f 7C /6 t 13 prolonged exposure to radiation. ( CL/YD j-14 b 15 RH 19.17 _onstruction Morli.igina and Accentance Testina. 16 j 17 19.17.1 derequirementsofthiscectionmustbe met for irradiators whose la construction begine after January 1, 1997. The requiremento must 19 be met prior to loading sources. 20 l l 21 19.17,1,1 hielding. For panoramic irradiators, the licensee shall 22 monitor the construction of the shielding to verify that its 23 construction mente design specifications and generally i 24 accepted building code requirements for reinforced concrete. 25 26 19.17.1.2 Foundations. For panoramic irradiators. the licensee shall 27 monitor the construct.lon of the foundations to verify that i 28 their construction meets design specifications. 29 4 1 J l 19 - 20 1

~.... 10/22/1996 11:30 303-782-5083 PAD. CO IT. DIV. - CIS'KE PACE 01 t l i DRAFT Octvber 10, 1996 i 1 1 1 19.17.1.3 Pool integrity. For pool irradiatora, the licenses shall a verify that'the pool meets design specifications and shall the integr'ty of the pool. The licensee shall verify 3 test i 4 that outlets and pipes meet the requirements of RH 19.13.2. h 5 6 19.17.1.4 ator handling system. For pool irradiators, the licensee l L 7 shall verify that the water purification system, the l { j 0 conductivity meter, and the water level indicatora operate 9 properly. l 10 L 11 19.17.1.5 Radiation monitors. For all irradiators, the licensee chall i 12 verify the proper operation of the monitor to detect sources f I 13 carried on the product conveyor system and the related I 14 alarma and interlocka required by RH 19.11.1. For pool ( 15 irradiators, the licensee shall verify the proper operation i 16 of the radiation monitors and the related alarm if used to l 1 ( 17 meet RH 19.22.2. For underwater irradiators, the licensee h 10 shall verify the proper operation of the over-the-pool f l l 19 monitor, alarms, and interlocks required by RI! 19.11.2. l 6 p/ 20 t 0 21 19.17.1.6 Source rack. For panoramic irradiatora, the licensee shall J 22 test the movement of the source racks for proper operatian t 23 prior to cource loading, and testing must include ocurce 24 rack lowering due to simulated loss of power. For all 35 irradiators with product conveyor systema, the licenses t 26 ahall observe and tent the operation of the conveyor system 27 to assure that the requirements in RH 19.14 are met for 20 protection of the source rack and the mechanism that moves 29 the rack. Testin, mese inc1ude tests of amy 1,m,< switches I i i 19 - 21 4 f l f i 1

... ~. .~ -. - - - - ~... 10/22/1996 11:30 303-782-5083 PAD.CC#1T. DIV. - CIME PFE 02 i i l i DRA FT October 10, 1996 i 1 and interlocka used to protect the source rack and mechanism a that moves the rack from moving product carriera. 3' E 4-19.17.1.7 y ccess control. For panoramic irradiators. the licensee 5 shall test the completed accest. control ayatem to assure { -6 that it f unctions as designed and that all alarms, controls, l 7 and interlocke work properly. f i 3 ^ 9 19.17.1.8 Fire protect' ion. For panoramic irradiators, the licensee 10 shall tcat the ability of the heat and smoke detectors to i l II detect a fire, to activate alarma, and to cause the source 12 rack to automatically become fully shielded. The licensee 13 shall test the operability of the fire extinguishing system. 14 3 ',/Sourcereturn.Forpanoramihirradiatore,thelicenseeshall ^ 15 19.17.1.9 16 demonstrate that the source racks can be returned to thqir 17 fully'ahielded positionn without offnite power. 18 19 19.17.1,10 Computer ayatems. For panoramic irradiators that use a 20 computer system to control the access control system, the 21 licensee shall verify that the access control system will 22 operate properly it ottaite power io lost and shall verify 23 that the computer has security features that prevent an l 24 irradiator operator f rom commanding the computer to override l 35 the access control system when it is required to be 26 operable. 27 28 19.17.1.11 Wiring. For panoramic irradiatoro, the licensee shall verify 29 that the electrical wiring and electrical equipment that 9 22 19 l

10/ 22/199E. 11:30 30?-782-5083 PAD. CO 1T. DI V. - CIGHE PAGE 02 p_ R A FT October 10, 1996 A and interlocks used to protect the source rack and mechanism 2 that moves the rack from moving product carriera. 3 4 19.17.1.7 k ccesa control. For panoramic irradiators, the licensee 5 shall test the completed acceos control system to assure 6 that it functions as designed and that all alarms, controls, 7 and interlocks-work properly. 0 9 19.17.1.8 Fire protection. For panoramic irradiators, the licenoce 10 chall test the ability of the heat and smoke detectors to 11 detect a fire, to activate alarmo, and to cause the source 12 rack to automatically become fully shielded. The licensee 13 chall tent the operability of the fire extinguishing system. 14 V 15 19.17.1.9 Source return. For panoramic irradiatore, the licensee shall 16 demonstrate that the source racks can be returned to their 17 tully chielded positionn without offnite power 18 19 19.17.1.10 Computer systemn. For panoramic irradiators that use a j 20 computer system to control the access control ayatem, the 21 licensee shall verify that the access control system will 22 operate properly it ottoite power 10 lost and shall verify 23 that the computer has security features that prevent an 24 irradiator operator from commanding the computer to override 25 the acceso control nyetem when it to required to be 26 operable. 27 s/ l 28 19.17.1.11 Wiring. For panoramic irradiators, the licensee shall verify 29 that the electrical wiring and electrical equipment that 19 22 l l I l

__m_ 10/22/1996 11:30 303-782-5083 PAD.COtIT. DIV. - CIME PACE 03 i I DRAFT October 10, 1996 1 1 were installed meet the design specifications. 3' l / 4-operation of Irradiators 9[y G RH 19,18 tainina. 7 8 19,18.1 ,/Before an ind'ividual la permitted to operate an irradiator without- -9 a supervisor present. the individual must be instructed in: 10 l 11 19.16,1,1 (/Thefundamentale;of'radiationprotectionappliedto ~ l irradiators (including the differencen between external 12 13 Lradiation and radioactive-contamination, units of radiation 14 do s e', Department dose limits, why Imrge radiation dosen must 15 be avoided, how shielding and acceso controla prevent large 16 doses, how an irradiator la designed to prevent 17 contamination, the proper use of survey meters and personnel ~ 18 desimeters, other radiation safety features of an l 19, irradiator, and the basic f unction of the irradiator); I 20 2A 19,18.1.2 t/ The requirements of Parts 4, 10 and 19 of these regulations i l 22 that are relevant to the irradiator; I 23 24 19.18.1.3 'The operation of the irradiator; i 25 26 19.18.1.4 tone operating and emergency procedures listed in Rll 19.19 27 that the individual is responsible f or performing; and 28' 39 19.18.1.5 ase histories of accidents or problems involving l 19 - 23

-- = =_ 4 10/22/1996 11:30 303-782-5083 PAD.COllT.DIV. - CDPHE PAGE 04 i l l t V ? I DR A PT October 10, 1996 i l' trradiators. 2 3 19.18.2 'g/ efore an individual is permitted to operate an irradiator without a supervisor present, 'the individual shall pass a written test on 4 t 5 -the instruction received consisting primarily of questions based i 6 on the licensee's operating and emergency procedures that the f 7 individual in responsible-for performing and other operations a neeessary to saf ely operate the irradiator without supervision, i t 9 e 10 19.18.3 Before an individual in permitted to operate an irradiator without ~ 11. a supervisor.present, the individual must have received on-the-job 12 training or. simulator training in the use of the'irradiator as '13 described in the license' application. The individual chall also 14 demonstrate the ability to perform those portions of the operating l 15 procedures that he or she is to perform. 16 e i i 17 19.18.4 The licensee shall conduct safety reviews for irradiator operators i is at least annually. The licensee shall give each operator a brief l 19 written test on the information. Each safety review must ~ include, 20 to the extent appropriate, each of the following: 21 22. 19.18.4.1 [yChangen in operating and emergency procedures since the last 23 review, if any; 24 25 to 10.4.2 g/ changes in regulations and licenne conditions since the last 26 review, if any; 27 l 20 19.'18.4.3 Reports on recent accidente, mistaken, or problema that have l l i 29 occurred at irradiatorn, if any; l c i i

10/22/19 % 11:30 303-782-5083 PAD.COIT.DIV. - CIME Pt/E 05 f DRAFT October 10, 1996 1 19,19.4.4 Relevant results of inspections of operator safety 'a. performances 3 4. 19.18.4.5 hvalevant results of the facility's inspection and 5 maintenance checks; and 6 9 A drill.to practice an emergency or abnormal event 7' 19.18.4.6 8-procedure. 9 10-19,18.5 The licennee shall evaluate the safety performance or each 11 irradiator operator at least annually to ensure that regulations, 12 license conditions, and operating and emergency procedures are 13 followed. The licensee shall discuss the results of the evaluation 14 with the operator and shall instruct the operator on how to 15 correct any mistakaa or deficiencies observed. 16 l ,/ 17 19,18.6 VIndividuale.who will be permitted uneocorted access to the j 18 radiation room of the irradiator or the area around the pool of an 19 underwater irradiator, but who have not received the training 20 required for operators and the radiation safety officer, shall be 21 instructed and tested in any precrations they should take to avoid 23 radiation exposure, any procedures or parts of procedures listed 23 in RH 19.19 t ha t, they are expected to perform or comply with, and 24 their proper response to alarms required in this part. Teats may I 25 he oral. 26 / l 27 '19.18.7 Individuals who must be prepared to respond to alarms required by 20 RH 19.8.2, 19.8.9, 19.10.1, 19.11.1, 19.11.2, and 19.22.2 shall be l 29 trained and tested on how to respond. Each individual chall be a 19 - 25

~, -... -. ~ ~. - ~.. -. - - - 10/22/1996 11:30 303-782-5083 RAD.CCtlT.T IV. - C[@tE PAGE 06 DR A FT October 10, 1996 1 ratested at least once a year. Teste may be oral. 2 M d .Y l l 3 Rlt 19.19 yta.I;.ing_And Eme rceqqyEpcedu re s. 4 r l 5 19.19.1 The licensee shall have and follow written operating procedures 6 fort 7 8 19.19,1.1~ 00peration of the irradiator, including entering and leaving e-the radiation roomi . 10 i t la 19.19.1.2 Use of personnel dosimeters; L t 1. /urveying the shielding of panoramic irradiators 13 19.19.1.3 S 14 l 15 19,19.1.4 Monitoring pool water for contamination while the water is j 16 in the pdol and before release of pool water to unrestricted l 17 areas; 18 ) 1 / l ' 19 19.19.1.b Leak testing of sources; i l 20 l 21 19.19.1.6 Inspection and maintenance checke required by RH 19.23; 23 v$bading, unloading, and repositioning sources, if the 23 19.19.1.7 24 . operations will be performed by the licensee; and 25 26 19.19,1.8 Inspection of movable shielding required by RH 19.8,B, if 27 applicable. 28. 29 19.19.2 The licensee shall have and follow emergency or abnormal event i 1 i i 19 - 26 4 l

.._m. 10/22/1996 11:30 5.03-782-5083 > RAD;C0 TIT.DIV.- CDPHE PACE 65 t t-i ] DRAFT October io, 1996 k i ratested at least once a year. Testa may be oral, k ~a ' .V { 3 RH 19.19' fp1IAIM9_AA4_.E!MLIq e njyEnge d u r e _e. t i e 4 5 ,19.19.1 The licensee shall have and follow written operating procedurea j 6 for I i 7-l B 19.19.1.1 eration of the irradiator, including entering and leaving i 1 9 the radiation room; 10 Al 19.19.1.2 Use of personnel dosimeters; { 12 /urveying the shielding of panoramic irradiators; 13 19.19.1.3 S i / 15 19,19.1.4 Monitoring pool water for contamination while the water is 16 in the pool and_before releano of pool water to unrestricted 17 areas; 1 t is / 19 19,19.1.5 Leak testing of sources; 20 t 21 19.19.1.6' Inspection and maintenance checks required by RH 19.?); 23 l 23 19.19.1 7 ading, unloading, and repositioning sources, if the 24 operations will be performed by the licensee; and 1 25 1 26 19.19.1.8 Inspection of movable shielding required by RH 19.8.9, if 27 applicable. 2B 29 19.19.2 The licensee shall have and follow emergency or abnormal event i I '19 - 26

10/22/1996 11:30 303-782-5083 PAD.CalT.DIV. - CEME PAGE 07 DRAFT October 10, 1996 i 1 procedures, appropriate for the irradiator type, far: 3 3 19.19.2.1 {f ources stuck in the'unnhielded positions 4 5 19.19,2.2 Personnel overexposurcui 6 7 19.19.2.3 . A radiation alarm from the product exit portal monitor or 8 pool monitor; 9 10 19.19,2.4 preetection of leaking sources, pool contamination, or alarm al caused by contamination of pool waters l 13 13 19.19.2.5 v/A low or high water level indicator, an abnormal water loss, i 14 or leakage f rom the source storage pool 15 5 16 19.19.2,6 A prolonged loss of electrical power; 17 18 19.19.2,7 V'A' fire alarm or explosion in the radiation room; le '20 19.19.2.0 An alarm indicating unauthorized entry into the radiation l l i l 21 l room, area around the pool, or another alarmed area; 22 l 23 19.19.2.9 V. Na tural phenomena, including an earthquake, a tornado, 24 flooding, or other phenomena as appropriate for the 25 geographical location of the facility; and g/' 27 19.19.2.10 The jamming of automatic conveyor systems. I 38. j 29 19.19.3 The licensee may revise operating and emergency procedures without i 19 - 27 l

30/22/19 % 11:30 303-782-5083 PAD.COtIT.DIV.- C[ftE PAGE 08 l .I l l DRAFT October 10, 1996 A Department approval only if all'of the following conditions are l .) .2 met -3 4 19,19.3.1 L#The revisions do not reduce the safety of theffacility, s + 6 19.19.3.2 7he revisions are consistent with the outline or summary of 7 procedurea submitted with the license application, 8 9 19.19c.3.3 Vhha revisions have been reviewed and approved by the I 10 radiation safety officer., and [ J 13 19.19.3.4 The usera'or operators are instructed and tested on the ] A) revised proce'dures before they are put into use. b 25 gj/PersonnelMQnitoring. v 15 Ril 19.20 16 17 19.20.1 Y Irradiator. operators shall. wear either a film badge or a i 18 thermoluminescent _ dosimeter (TLD) while operating a panoramic 19 1rradiator or while in theLarea around the pool or an underwater 20 irradiator. The film badge or TLD processor must be accredited by 21-the National Voluntary Laboratory Accreditation Program for high 22 energy photons in the normal-and accidental done rangen (see RH < r. 23 4.17.3). Each film badge or TLD must be assigned to and worn by

24 only one individual. Film badges must be processed at least j

25 monthly, and TLD's must be processed at least quarterly. 36 27 19,20.2 Other individuals' who enter the radiation room of a panoramic 1 28 1rradiator shall wear a dosimeter, which may be a pocket j 29 dosimeter. For groups of visitors, only two people who enter the 19 - 28 I l

10/22/1996 -lli30 303-782-5083 PAD.COllT.DIV. - CIf4E PAGE 09 i l r l i DD APT October 10, 1996 i i L -A radiation room are required to wear dosimeters. If pocket a dosimeters are used to meet the requirements of this paragraph, a 3 check of their response to radiation must be done at least l 4 annually. Acceptable dosimaters must read within 130 percent of i 5 the true radiation dose. le c l d -/ RH 19,21' / adiaMan_RyrveVA. F 8' l 9 19,21.1 A radiation survey of the area outaide the shielding of the l 10 radiation room of a panoramic irradiator must be conducted with la the sources in the exposed position before the facility starts to la operate. A radiation survey of the area above the pool of pool A3 irradiators must be conducted after the nources are loaded but 14 before the facility starts to operate.-Additional radiation l 15 surveys of the chielding must be performed at intervals not to 26 exceed 3 years and before resuming operation after addition of new 17 -sources or. any modification to the radiation room chielding or le structure that'might increase dose rates. 19 20 19,21.2 If the radiation levels specified in RH 19.9 are exceeded, the al facility.must be modified to comply with the requirements in 22 RH 19.9. I 23 24 19.21,3 ' Portable radiation survey meters must be calibrated at least 29 annually to an accuracy of 220 percent for the gamma energy of the 26. sources in use. The calibration must be done at two points on each 27 scale or, for digital instruments at one point per decade over the 20 range that will be used. Portable radiation survey meters must be 29 of a type that does not saturata and read zero at high radiation i l 19 - 29 5 .._i

10/ 22/ l et T, 11: 30 303-782-5083 PAD.CfflT.DIV.~ CLPHE PME 10 l DR A FT October 10, 1996 1 doce rates. t 3 3 19.21.4 Water from the irradiator pool, other potentially contaminated 4 liquido, and pedimento from pool vacuuming must be monitored for 5 radioactive contamination before release to unrestricted areas. 6 Radioactive concentrations must not exceed those specified in Part 7 4, Appendix B, Table I, " Annual Limits on Intakes (ALI*a) and 0 Derived Air Concentrationu (DAC'u), or Table III, " Release to 9 sewero". 10 11 19.21.5 Before releasing resinn for unrestricted une, they must be ,h 7 6) monitored before 12 release in an area with a background level leon 13 than 0.5 microsievert (0.05 millirem) perhour]Theresinsmaybe q} d released only i the survey doca not detect radiation levels above 14 (Ad1 A IDW 15 o y b background levels. The survey mater used must be capable of fgfc,b jr) detecting radiation levela of 0.5 microoievert (0.05 millirem) per 16 I 17Co*f(\\bI hour. 4 (k(1 0 M g(hut [ b.N10D< FVC [O f /c 9( y h d[ pjon 19 RH 19.22 4 etection of Liakinc7 Sources. [$ 'r n 'J S S / ] A b 04 O U D Ih 9 20 /Each dry-source-storage sealed source munt be tested for leakageW4fdisayny / 21 19.22.1 22 at intervale not to exceed 6 months using a leak test kit or 23 method approved by the U.S. Nuclear Regulatory Commission or an 24 Agreement State. In the absence of a certificate from a transferor 25 that a test han been made within the 6 montha before the transfer, t 26 t.he sealed source may not be uued until tested. The test must. be 27 capable of detecting the presence of 200 becquercio (0.005 20 microcuric) of radioactive material and must be performed by a 29 person approved by the U.S. Nuclear Regulatory Commission or an 19 .,. -.~. ~. .. -.. - ~ - . ~ ~ ~ ~ -.... . ~ - ~.... ..... _~. 10/22/1996 11:30 303-782-5083 ' PAD. CONT.DIV.- CDPHE PA3E 11 l R_R_A_E_I October 10, 1996 l I i 1 Agreement' State to perform the test. 2 3 19.22.2 For pool irradiatora, sources may not be put into the pool unless 4 the licensee testa the sources for leaks or has a certificate f rom ? 9 a transferor that a leak test has been done within the 6 months-e 6 before the transfer. Water f rom the pool must be checked for '7 contamination each day the irradiator operates. This check may be 0 done either by using a radiation monitor on a pool water a r 9 circulating eyetem or by analysis of a sample of pool water. If a 10 check for contamination is done by analyals of a sample of pool j 11 water, the results must be available within 24 hours. If the 12 licensee uses a radiation monitor on a pool water circulating l 13 system, the detection of above normal radiation levela must 14 activate an alarm. The alarm oct-point must be set as low as 15 practical, but high enough to avoid f alse alarms, The licensee may la reset the alarm set-point to a higher level if necessary to 17 operate the pool water purification system to clean up le contamination in the pool if specifically provided for in written 19 emergency procedures. 20 21 19.22.3 L If a leaking source is detected, the licensee shall arrange to 22 remove the leaking source from service and have it decontaminated, 23 repaired, or disposed of by a U.S. Nuclear Regulatory Commission 24 or Agreement State licensee that is authorized to perform these i 35 f unctions.' The licensee shall promptly check its personnel, 26 equipment, facilities, and irradiated product for radioactive I 27 contamination. No product may be shipped until the product hao been checked and found free of contamination. If a product hae 20 l 29 been shipped that may have' been inadvertently contaminated, the i 19 31

~ 10/22/1996 'll: 30 303-782-5083 PAD.COIT. DIV. - CEStE PAGE 12 d PRA FT October 10, 1996 4 1 licensee shall arrange to locate and survey that product for 3 contamination. If any personnel are found to be contaminated, 3' decontamination must be performed promptly. It contaminated 4 equipment, facilities, or products are found, the licenace shall S arrange to have them decontaminteed or disposed of by a U.S. 6 Nuclear Regulatory Commission or Agramment State licensee that is 7 1 authorited to perform these functions. If a pool 18 contaminated, i } 8 the licensee shall arrange to clean the pool until the 9 contamination levela do not exceed the appropriate concentration 10 in Part 4, Appendix D, Table III. (See RH 4.52 and 4.53 of these 11 regulations for notification and reporting requiremente.) N 4 13 RH 19.23 Insoection and Maintenangg. /v 14 15 19.23.1 (/ he licensee shall perform inspection and maintenance checks that 1 16 include, as a minimum, each of the following at the frequency 17 specified in the license or license application: 1 18 19 19.23.1.1 g perability of each aspect of the access control system 30 required by RH 19. 0. 21 1 23 19.23.1 2 4 Functioning of the source position indicator required by i 23 Rll 19.12.2. 24 y herability of the radiation monitor for radioactive g 35 19.23.1.3 2G contamination in, pool water required by RH 19.22.2, using a 27 radiation check source, if applicable. 30 J 29 19.23.1.4 Operability of the over pool radiation monitor at underwater 19 32'

. -. ~ ~. _. ~ - - - -. - -..... _ ,..... -. -~. 10/22/1996 11:30 303-782-5083 L PAD.COllT. DIV. - CIME PArz 13. g t i f f DkAPT October 10, 1996 I 1 irradiators as required by RH 19.11.2. 2 .e 3 19.23.1.5 Operability of the product exit monitor required by 4 RH 19.11.1. f i 5 6 19.23.1.6 s-Operability of the emergency source return control required l 7 by RH 19,12.3. l< f 0 9 19 23.1.7 Leak-tightness of systems through which pool water 10 circulates (visual inspection). 11 13 19.23.1.8 V Operability of the heat and smoke detectora and. extinguisher 13 system required by RH 19.10 (but without turning l 14 extinguishers on). 1 15' -16 19.23.1.9 Operability of the means of pool water replenishment 17 required by RH 19.13.3. I 18 v!perabilityof'theindicatorsofhighandlowpoolwater 19 19.23.1.10 O 20 levels required by RM 19.13.4. ] 21 j g/ Operability of the intrusion alarm required by RH 19.8.9, 22 19.23.1.11 if 23 applicable, l 24 t 25 19.23.1.12 Punctioning and wear of the system, mechanisms and cables 26 used to raise and lower sources. 27 j 20 19.23.1.13 Condition of the barrier to prevent products from hitting i j 29 the sources or source mechaniom as required by RH 19.14. J 19 - 33 i

10/22/1996 11:30 303-782-5083 PAD. CC21T. DIV. - CNtE PAGE 14 j l v i f D R A P_T October 10, 1996 i yl Amount of water added to the pool l 1 19.23.1.14 to determine if the pool j 3 is leaking. I l 3 Y lcetrical wiring on required safety systema for radiation 4 '19.23.1.15 E j 5 damage. 6 3 f I 7 19.23.1.16 Pool' water conductivity measuremento and analysia as t 8 required by Ri! 19.24.2. t y 10 19.23.2 Malfunctions and defects found during inspection and maintenance 11 checka must be repaired without undue delay. la \\J g[ool 13 RH 19.24 Water Puriev. i 14 i 15 19.24.1 Pool water purification nyatem must be run sufficiently to 16 maintain the conductivity of the pool water below 20 microslemens l 17 per centimeter under normal circumstances. It pool water 1 18 conductivity rises above 20 microniemena per centimeter, the 19 licensee shall take prompt actions to lower the pool water 20 conductivity and shall take corrective actions to prevent future f 21 recurrences. / 22 g/ 23 19.24.2 The licenece shall measure the pool water conductivity frequently 24 enough, but no less than weekly, to assure that the conductivity 25 remains below 20 microsiemens par centimeter. Conductivity metera 3G must be calibrated at least annually. l 27 V 28 Ri! 19.25 Attendance During Operations. j' 4 39 ? I e i 19 - 34 t l l l L

- ~. -... -. - -,.. -. - .~... -.. ~ 10/22/1996 11:30 303-782-5083 PAD.COilT ' DIV. - CGtC PAGE 15' l l DRAFT October 10, 1996 /oth an irradiator operator and at least one individual, 1 19.25,1 B who is 3 trained on how to respond and prepared to promptly render or 3 summon assistance if the access control' alarm sounds, shall be i 4 present onsite: r 1 5 6-19.25,1,1 Whenever the irradiator is operated using an automatic j 7 product conveyor systemi and 0 9 19.25.1.2 Whenever the product 1e moved into or out of the radiation 10 room when the irradiator is operated in a batch mode. 11 ' 12 19.25.2 t-a panoramic irradiator at which static irradiations (no 13 movement of the product) are occurring,

a. person who has received 14 the training on how to respond to alarma described in RM 19,18.7 15 must be onsite.

16 i l 17 19.25.3 At an underwater irradiator, an irradiator operator must be -10 present at the facility whenever the product is moved into or out l 19 of the pool. Individuals who move the product into or out of the l 20 pool of an underwater irradiator need not be qualified aa al irradiator operators; however, they must have received the 22 training described in RM 19.18.6 and 19.10.7. Static irradiations +:, l 23 may be performed without a person present at the facility. 24 k d_narlpq and Leavinq the._,Jrr_adiation Room. j 25 RH 19.26 - 36 l

7 19.26.1.

Upon first entering the radiation room of a panoramic irradiator 28 after an irradiation, the irradiator operator shall use a survey l 29 meter to determine that the source has returned to its fully l ) 19 - 35 i j v w 9

_..m..._ 10/22/1996 11:30 303-782-5083 PAD.CollT.DIV.- CDPHE PAGI 16 __ i i ) i l P_K_A_f_I' october 10, 1996 I 1 ' shielded position. The' operator shall check the functioning of the 2 survey meter with a radiation check source prior to entry. 3 4 19.26.2 Before' exiting:from and locking the door to the radiation room of j l 5 a panoramic irradiator. prior to a planned irradiation, the 6 irradiator operator shall: 7 hiaually inspect the entire radiation room to verify that no 8 19.26.2.1 9 one else is in it; and 10 11 19,26.2.2 Activate a control in the radiation room that permite the 13 sources to be moved from the shielded position only if the 13 door to the radiation room in locked within a preset time 14 after netting the control. 15 16 19.26.3 During a power failure, the area around the pool of an underwater -17 irradiator may not be entered without using an operable and 18 calibrated radiation survey meter unless the over the-pool monitor l 19 required by Ri! 19.11.2 to operating with backup power. 20 D 4 21 RH 19.27 krradiggionofExolosiveorFlammableMaterials. 22 33 19,27.1 Irradiation of explosive material is prohibited unless the 24 licensee has received prior written authorization from the 25 Department. Authorization will not be granted unless the licensee 36 can demonotrate that detonation of the explosive would not rupture 27 the sealed sources, injure personnel, damage cafety systema, or I 20 cause radiation overexposures of personnel. 2D 19 - 3G I i

10/22/1996 11:30 303-782-5083 PAD.CColT.DIV. - CCME Pt/d 17 DRAFT October 10, 1996 1 19,27.2 Irradiation of more than small quantities of flammable material 3 (flash point below 140*C) is prohibited in panoramic irradiators 3 unless the licenace han veeeived prior scatte.. nullevi16etivas fwm 4. the Department. Authorization will not be granted unless the 1 5 licensee can demonstrate that a fire in the radiation room could 6 be controlled without damage to the sealed sources or safety 7 systema and without radiation overexposures of personnel. l 9 Records 10 'N 11 Ri!.19.28 [HecordsandRetentionPeriods. 13 13 19.28.1 The licensee shall maintain the following records at the 14 irradiator for the periods specified: 15. l 16 19.28.1.1 A copy of the license, license conditions, documents 17 incorporated into a'licenne by reference, and amendments 18 thereto until superseded by new documents or until the l' 9 Department terminates the 1icense for documents not 20 superseded. 21 22 19.28.1.2 Records of each individual's training, tests, and safety 23 reviews provided to meet the requirements of Ril 19.10.1, 24 19.10.2, 19.10.3, 19.10.4, 19.10.6, and 19.18.7 until 3 25 years after the individual terminates work, i 26 27 19.28.1.3 Records of the annual evaluations of the safety performance 20 of irradiator operators required by RH 19.18.5 for 3 years { 29 after the evaluation. ! 37 ( l

. -. ~ ,.~ -.-. ~, .c ~ 10/22/1996 11:30-303-782-5083 PAD. CO IT. DIV. - CWtE PAGE 18 P_E A F T October 10, 1996 l l 1 19.20 1.4 A copy of the current operating and emergency procedures 3 required by Ri! 19.19 until superseded or the Department 3 terminates the license. Records of the radiation safety -l 4 officer's review ad approval of changes in procedures as l 5 required by RH 19.19.3.3 retained for 3 years from the date 6 of the change 7 l 'O 19.28.1.5 Film badge and TLD results required by RH 19.20 in 9 accordance with RH 4.46 of these regulations. 10 11 19.20.1.6 VRecords of radiation surveys required by RH 19.21 for 3 12 yearn from the date of.the survey. 13 l! ecords of radiation survey meter calibrations required by 14 19,28.1.7 R f 15 RH 19,21.3 and pool water conductivity meter calibrationo l 16 required by RH 19,24.2 until 3 years'from the date of l 17 cal 2bration. 18 19 19.20.1.0 ' Records of the results of leak tests required by RH 19.22.1 l l 20 and the results of contamination checke required by RH 21 19.22.2 for 3 years from the date of each test. l 22 23 19.28.1.9 Records of inspection and maintenance checks required by 24 RH 19.23 for 3 years. l 35 l l-4 l 26 19.28.1.10 Records of major malfunctions, algnificant defects, i 27 operating difficulties or irregularitica, and major 20 operating problems that involve required radiation safety 2D equipment for 3 yearo after repairs are completed. 19 - 38 i

._____.__.m .. _ _ _ _ _ _ - _ _ _ -. - _ ~. _ _. _. _ .10/22/1996 11:30 303-782-5083 PAD. CONT.DIV.- CI7tE PAGE 19 l-DRAFT October 10, 1996 !ecordsofthe l 1 19.28,1,11 R re ceipt., transfer,. and disposal of all l 3 licensed sealed sources as required by RH 3.22 and RH 4.48 3 of thcae regulations. l 4 5 19.28.1.12 Records on the design checks required by RH 19.16 and the construction control checks as required by RH 19.17.until 6 7 the license is. terminated. The records must be signed and ~ 8 dated.-The title or qualification of the person signing must 9 d be included. p 10 I / -I ' 11 19.28.1.13 Records related to decommissioning of the irradiator as hb ,.{requiredbyRH3.16.6.8 of theat Regu_lations. 12. 13 Th i.s ws or13'mm (k tJ Ifh dN3 C> (.A-8 CMb C t' ca e. ead corts.' fM b Ri!.19.2D'S the e erew e. s, _ acac 14-i i /n addition to the reporting requirements in other' parts of the 16 19.29.1 I i 17 regulations, the licensee shall report the following events: 18 19 19.29.1.1 d ource stuck in an unshielded position. 20 21 19.29.1.2 3 Any fire or explosion in a radiation room. i 22 23 19.29.1.3' Damage to the pource racks. 24 25 19.29.1.4 Failure of the cabin or drive mechaniam used to move the 26 source racks. I 27 / l l 28 19 29.1.5 Inoperability of the access contzol system. 29-i j 19 - 39 s l l l

10/22/19 % 11:30 303-782-5083 PAD.CC# 1T. DIV. - CI14E Pt/E 20 DDAFT October 10, 1996 1 19.29.1.6 etection of radiation source by the product exit monitor. 2 j !Detectionofradioactivecontaminationattributableto 3 19.29.1.7 4 licenned radioactive material. 6 19.29.1.8 Structural damage to the pool liner or walla. 7 8 19.29.1.9 Abnormal water loss or leakage from the source atorage pool. 9 10 19,29.1.10 Pool water conductivity exceeding 100 microsiemens per 11 centimeter. / 13 19.29.2 The report must include a telephone report within 24 hours as 14 described in Ri! 4.52.2, and a written report within 30 days as 15 described in R11 4. 53.1. 2 of these regulations. g g yp e n e S e. M 3 GTE 16 19 - 40

h% hp A y PtJL. EXECUTIVE TASK MANAGEMENT SYSTEM <<< PRINT SCREEN UPDATE FORM >>> TASK # - 6S246 DATE-10/03/96 MAIL CTRL. - 1996 TASK STARTED - 10/02/96 TASK DUE - 10/22/96 TASK COMPLETED - / / TASK DESCRIPTION - COLORADO REGS - LICENSING AND RADIATION SAFETY ..____~~~~~~~~~~ REQUIREMENTS FOR IRRADIATORS FOR REVIEW REQUESTING OFF._...___..______ - RIV REQUESTER - C. HACKNEY WITS - 0 FYP - N PROG.- SNS PERSON - STAFF LEAD - SNS PROG. AREA - PROJECT STATUS - OSP DUE DATE: 10/23/96 PLANNED ACC. -N LEVEL CODE - 1 i i ~l l I r l I l}}

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