ML20140A849

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Requests Addl Info Re 850420 Request to Amend License 50-23363-01.Rev to Radiation Safety Manual,Attachment E Re Appointments by Radiation Safety Officer Requested within 30 Days.Rev 2 to Reg Guide 10.6 Forwarded.W/O Encl
ML20140A849
Person / Time
Site: 03020969
Issue date: 05/29/1985
From: Riedlinger B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Heiken D
ULTRA TECHNOLOGY, INC.
Shared Package
ML20140A783 List:
References
70184, NUDOCS 8603210241
Download: ML20140A849 (2)


See also: IR 05000233/1963001

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Docket No. : 030-20969

License No.: 50-23363-01

Control No.:

70184

Ultra Technology, Inc.

509 West Third Avenue

Anchorage, Alaska 99503

Attention: Donald S. Heiken

Radiation Safety Officer

Gentlemen:

This is in reference to your letter dated April 20, 1985 to amend your

byproduct material license. In order to complete our review, we need the

following additional information:

1.

Pages 4 and 5 of Attachment E of your Radiation Safety Manual states

that the Radiation Safety Officer may appoint instructors for training

and retraining of radiographers.

Page 10 of the enclosed licensing guide states that, " Individuals who

provide instruction in the use of equipment should be qualified

radiographers with at least 1 year of experience in performing

radiography. The name of each individual who will conduct training and

the topics in which they will provide instruction should be specified".

You should amend and resubmit pages 4 and 5 of Attachment E to

incorporate the criteria stated in the licensing guide.

2.

Page 5 of Attachment H of your Radiation Safety Manual states that the

senior radiographer may " appoint a Deputy to act on his behalf during

brief absences from the field site".

The duties of the senior

radiographer include radiation safety responsibilities.

Page 6 of the enclosed licensing guide states that, "Any individual who

is responsible for the day-to-day management or supervision of the

radiography program should have had a minimum of 1 year of actual

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experience as a radiographer". Also, the names and titles of these

individuals should be submitted with your amendment request.

You should amend and resubmit page 5 of Attachment H.

8603210241 851015

REG 5 LIC30

50-23363-01

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3.

Page 4 of Attachment E of your Radiation Safety-Manual states that other

training courses approved by the Commission may be substituted, either

totally or in part, for the Ultra Technology, Inc. training program.

You should note that other courses which have been approved by the

Commission will still need to be supplemented by your company - specific

training which describes your operating and emergency procedures and

equipment use. All of the appropriate exams should be administered to

be consistent with your training procedures and to assure compliance

with 10 CFR 34.31. Partial training from other licensee training courses

cannot be accepted, as it would not be clear which topics were covered

and which were not.

You should amend and resubmit page 4 of Attachment E.

4.

We believe that there is an error on page 4' of Attachment E of your

Radiation Safety Manual. We believe that the last sentence on that page

should read, " Personnel who are graduates of Weld-236 will be evaluated

as per b) above".

Your procedure specifies that credit can be given

only for Chapters 2 through 7 of your training course. Ultra Technology

is responsible for all other training and for administering all of the

appropriate examinations.

You should amend and resubmit this portion of your procedures.

5.

Item e.1. of page 3 of Chapter 11 of your Radiation Safety Manual

describes the radiation survey to be conducted at the completion of an

exposure.

10 CFR 34.43 requires that the entire circumference of the radiographic

exposure device be surveyed. It also requires that a record of the.

survey be maintained when the survey is the last one made prior to

locking the radiographic exposure device and ending direct surveillance

of the operation.

You should amend and resubmit this portion of your procedures to

reference the requirements of 10 CFR 34.43.

We will continue the review of your amendment request upon receipt of this

information. You should submit your response within thirty (30) days from the

date of this notice. Please reply in duplicate, and refer to Mail Control No.

70184.

Sincerely,

Beth A. Riedlinger

Health Physicist (Licensing)

Nuclear Materials Safety Section

Enclosure:

Proposed Revision 2 to Regulatory Guide 10.6

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