ML20235H783
| ML20235H783 | |
| Person / Time | |
|---|---|
| Site: | 07100669 |
| Issue date: | 02/10/1989 |
| From: | Hiersche R COMO TECH INSPECTION SERVICE (FORMERLY COMO TECH |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 25178, NUDOCS 8902240039 | |
| Download: ML20235H783 (38) | |
Text
-
-- ~
So
.9
.f potgD gsgRC IECEP/D ne t"SS' } g S-D, i
=
e 4
"hht0M
%j(gtcitRE -
February 10, 1989-9 to 6
g q
. Office-of' Nuclear Safet
. Safeguards j
U.S.
Nuclear Regulatory Commission: Bldg. #396
~
4 Washington, DC 20555 FEBl41989 Y-i d' u,g.HUCLEAR REGutATORY ~J DOMMiss1011 NMSS-Dear Sir; cy yalisectiori Ur p
This letter and accompanying COMO Tech, Inspection Division's-Quality Assurance Manual are directed to your office to register in writing that COMO Tech, Inc. Kansas Materials License No.
21-B629-01 is a user of NRC approved containers used to transport-t type B quantities of licensed material'throughout the State of.
Kansas and bordering NRC non-agreement states.
i COMO Tech, Inspection Division's.Q.A. Program and Q.A. Manual are structured and implemented in accordance with 10.CFR Part 71.10-0.A.
Program requirements.
Accompanying this c-correspondence'is the proper license fee in the amount of one hundred and. fifty dollars.
Should there be any questions'or need for-additional information please call Raymond E..Hiersche 913-585-1037.
(
. Respectfully, e
Raymond.E. Hiersche 0.A. Manager COMO Tech, Inc.
P.O.
Box 292
.DeSoto, Ks. 66018 l
_ _ _ _ fd(("
~
l/v 0 l
J C0 1'
k lo U i
l
> xtsj.. _ _
y 1011 M)...... _.
i s
w npfo9 I
L-8902240039 890210 PDR ADOCK 071*****
PDC C'
25178
g.
- s s:
DOCKET Ny.
!-Oh CONTROL f{0. ;__
[6/7/[
DATE Of D00.Knet1&rU lD,19R9 DATE RCVD.
'Chdiard (M [98f E
FCUF PDR d
~FCAF LPDR I& E REF, SAFEGUARDS -
FCIC OTHER 1.
DATEh)
INITIAL --
1
)
I 1
l
- p. '
g, Page 1 of_ 3._Pages i
STATE OF KANSAS RADIOACTIVE MATEIUALS LICENSE n'
V Pursuant to the Nuclear Development and Radiation Control Act (L.1963, ch. 290 and the Radiation Protection Regulations, Part 3, and in reliance on statements and representations heretofore made the licensee designated below, a license is hereby issued authorizing such licensee to transfer, receive, possess and use t e radioactive desig-nated below; and to use such radioactive materials for the purpose This is subject to all applicable rules, regulations, and orders now or he(s) and at the place s) designated below.
reafter in effect of t ic State Department of IIealth and j
to any conditions specified below.
l Licensee
- 3. License number 21-B629-01
- 1. Name COMO Tech, Inc.
- 4. Expirauon date 4
33680 West 83rd Street January 31, 1991 (A 91)
L Address Desoto, KS 66018
- s. Reference number
- 6. Radioactive materials
- 7. Chemical ar.d/or physical form
- 8. Alaxhnum quantity licensee may (element and mass number) possess at any one time A.
Iridium-192 A.
Sealed Source (Technical A.
No single source to exceed Operations Model A-424-9) 100 curies B.
Cesium-137 B.
Sealed Source (Tech / Ops B.
No single source to exceed Model 77302) 165 millicuries C.
Cobalt-60 C.
Sealed Source (Tech / Ops C.
No single source to exceed fm A424-14) 100 curies V
CONDITIONS
- 0. Authorized use. (Unless otherwise specilled, the authorized place of use is the licensee's address stated in Item 2 above.)
A.
To be used in a Tech / Ops Model 660 or 713 exposure device for industrial radio-graphy and in Gulf Nuclear Model G-1, C-4, C-10 or GNI 130, Model RC-6C Tech / Ops Model 414 or 650 source changer for source replacement or storage.
L To be used in a Tech / Ops Model 77302 calibration unit for calibration of radiation survey instruments.
C.
To be used in a Tech / Ops Model 680 exposure device for industrial radiography and in Tech / Ops Model 416 or 488 source changer for source replacement or storage.
- 10. Radioactive material may be used at 33680 West 83rd Street, Desoto, Kansas and at temporary job sites of the licensee anywhere in the State of Kansas where the State of Kansas, Department of Health and Environment maintains jurisdiction for regulating the use of radioactive material.
11.
The licensee shall comply with the provisions of Part 4, Kansas Radiation Protection Regulations, " Standards for Protection Against Radiation" and Part 10, Kansas Radiation Protection Regulations, " Notices, instructions and Reports to Workers; Inspections".
O V Data FOR TI!E STATE DEPARTMENT OF IIEALTl!
r>y
.e,
.....a
,e.....
Pag-2 af 3
bgn
,c STATE OF KANSAS
's, RADIOACTIVE MATERIALS LICENSE' t
(v';;plementary Sheet License Number 21-R629-01
- 12. The licensee shall comply with the provisions of Kansas Radiation Protection Regulations, Part 4, " Standards for Protection Against Radiation", Part 7, "Special Requirements for Industrial Radiographic Operations" and Part 10, " Notices,' Instructions and Reports to Workers; Inspections."
- 13. The licensee is authorized to receive, possess, and use sealed sources of Iridium 192 or Cobalt 60 where the radioactivity exceeds the maximum amount of radioactivity specified in Item 8 of this license provided:
A.
Such possession does not exceed the quantity per source specified in Item 8 by more than 20% for Iridium 192 or 10% for Cobalt 60; B.
Records of the licensee show that no more than the maximum amount of radioactivity per source specified in Item 8 of the license was ordered from the supplier or transferor of the radioactive material; and C.
The levels of radiation for radiographic exposure devices and storage containers do not exceed those specified in Regulation 28-35-275.
- 14. Pursuant to Kansas Radiation Protection Regulations, Part 3, " Licensing Sources of Radiation," the licensee is authorized to possess, use, transfer, and import up to 999 kilograms of uranium contained as shielding material in the radiography exposure devices q
and source changers authorized by this license.
j y
4 15'.
The radiation safety officer in this program shall be Raymond E. Hiersche.
16.
Except as specifically provided otherwise by this license, the licensee shall possess and use radioactive material described in Items 6, 7, and 8 of this license in accordance with statements, representations, and procedures contained in the following documents:
i (a) The application dated January 2, 1989 signed by Raymond E. Hiersche with attachments. l 17.
A.
Pursuant to Regulation 28-35-279, the licensee is authorized to perform tests for leakage or contamination of the sealed. sources authorized by this license in accordance with procedures contained in COMO Tech, Inc. Emergency and Operation Procedures Manual dated January 2, 1989.
B.
Notwithstanding the periodic leak test required by Regulation 28-35-279a, such requirement does not apply to radiography sources that are stored and not being used.
The sources excepted from this leak test shall be tested for leakage prior to any use or transfer to another person unless they have been leak tested within six (6) months prior to the date of use or transfer.
i C.
Sealed sources authorized for a use other than radiography shall be tested as radiography sources in accordance with Regulation 28-35-279a.
I
/]
FOR THE STATE DEPARTMENT OF HEALTH V
& ENVIRONMENT l
Date By O
~
Gerald W. Allen, Director Bureau of Radiation Control
Page 1
af 1
Pages g,'
STATE OF KANSAS RADIOACTIVE MATERIALS LICENSE Qplementary Sheet License Number 21-R629-01
- 18. The individuals listed below are the only persons authorized by this license to act as radiographer or radiographer' assistants as defined in Section 28-35-135(ee)and (ff) respectively, of Kansas Radiation Protection Regulations.
A.
Radiographer (i)
All individuals authorized to act as radiographer pursuant to a valid license issued to the licensee by the Department, the United States Nuclear Regulatory Commission or another Agreement State covering the uses and radioactive materials authorized by this license.
(ii)
Individuals designated by the Radiation Safety Officer, also who have met the criteria established in item 5, 8 and 9 of the COMO Tech, Inc. Radioactive j-Material Application dated January 2, 1989.
L O
l 7
O roa+at =T^Tc ocriarucxT or ac^'Ta
/!
& ENVIRONMENT YhO&
,. \\ ' ry,'f
/
('
vu sy O
~")GeraldW; Allen
~
Director Bureau of Radiation Control
- o; L
COMO TECH, Inc.
-(/
Item-#10 Radiation Detection-Instruments A.
Survey Meters COMO TECH, Inc.'will maintain an appropriate number of operable and calibrated survey meters for proper and safe operations.
With the following conditions:
1.
Survey meters must have a range ~of 2 milliroentgen per hour thru 1' roentgen per hour.
2.
Survey meters in use must be calibrated each three months and.after each repair by.an authorized calibration service.
3.
Survey meters must be calibrated within an accuracy of a plus or minus of 20% of the actual values ofLeach range of the meter.
4.
The authorized calibration agency will furnish a-calibration sticker and a calibration chart / graph showing results of the calibration.
1 5.
A calibration sticker must be affixed to each
,_s
('")
survey meter verifying the last calibration date and the next due date.
6.
Calibration records for each survey meter must be maintained in permanent file by the RSO for three (3) years after each calibration.
7.
Defective survey meters must be immediately removed.from service and reported to the RSO.
)
Radiography operations must be discontinued until j
a replacement is available.
J 8.
Survey meters must have a battery check.
j 9.
Survey meters must be protected from impact, 1
moisture, and battery corrosion.
B.
Authorized calibration firms COMO TECH,Inc. will use for survey meter calibration.
j 1.
G.E.
Smith & Associates, Inc.
l Pasadena, TX Texas License Number LOO 991 2.
Nebraska Testing Corn.
(~)
Omaha, NB
'~'
Nebraska License Number 01-22-01 l
l e,;
v. e..s.
u)
O 4c COMO TECH, Inc.
(X E
,).
Item #10 Radiation. Detection Instruments l
B.
Authorized calibration firms COMO TECH, Inc. will use for survey' meter calibration, Continued.
3.
Tech Check Inc.
Tulsa, OK U.S.N.R.C. License. Number 35-26918-01 4.
In future we will purchase Tech / Ops Model' 773 Calibration device.
At that time survey meters will be calibrated by authorized personnel.
Item #11 Method,. Frequency, and Standards.Used in Calibrating Instruments-Listed in Item'#10.
Method:
Cal'ibrated Reference Standard Frequency:
Every 90 Days Calibrations per National Bureau of Standards /
ANSI N323-1978 SURVEY METER CALIBRATION g-1)
A.
Personnel Requirements Survey meter calibration shall be performer only by an individual qualified as a Radiological Technician, q
B.
General Requirements 1.
Radiation survey meters shall be calibrated at intervals not to exceed three months and after each instrument servicing.
2.
Survey meters with ranges from 0 to 1000 mR/ hour shall be calibrated using Models 773 calibration devices.
3.
The calibration device shall be located at least 10 feet from any wall in the direction of the primary radiation to minimize the effects of scattered radiation.
The survey meter shall be located at least four feet from any wall exposed
- j by the primary radiation beam.
.----__._,---._------------.---------__x.--.____-.
A
\\
COMO TECH, Inc.
\\/
. Item #11 Method, Frequency, and Standards Used in Calibratin Instruments Listed in Item #10. Continued.
4.
Survey meters shall be calibrated by measuring the response to two radiation intensities on each l.
range.
The two intensities must be separated by at least 50% of the full scale reading.
The instrument is in satisfactory calibration if the response at each point checked is within 120 %
of the actual applied intensity.
C.
Procedure for Calibrating Survey Meters 1.
Determine the points to be checked for the instrument to be calibrated.
Either by calculation or by the use of the slide scale, determine the distance from the source at which the meter shall be placed to check each of these points.
2.
Place the survey meter such that the axis of the detector is perpendicular to and centered on the axis of the collimated beam and that the axis of the detector is at the prescribed
,- m
(,)
distance from the source.
3.
Expost the source by raising the scurce rod.
NOTE:
Do not enter or expose any part cf the primary beam.
If it is necessary to adjust the meter, return the source to the stored position.
4.
Note and record the survey meter reading on the Survey Meter Calibration Log (attached)
If the reading is within i 20% of the actural applied intensity, continue checking the survey meter at the required points.
If the reading is not within this limit, adjust the meter and recalibrates.
5.
Complete the Survey Meter Calibration Record.
Attach a calibration tag to the survey metei i
indicating the date of calibration, the next I
due date and the technician's initjals.
I I
('\\
\\
t M
COMO TECH, Inc.
.,z A'
Survey. Meter Calibration Record
/']
j Manufacturer:
Model Number:
Serial Nunber:
Assigned to:
Actual Initial Indicated Applied (as found)
Intensity Error Intensity Indicated (mR/ hour)
(%)
(mR/ hour)
Intensity Date:
(mR/ hour)
Source:
Activity:
Serial:
Calibrator-Model:
Serial:
r8U Technician Sign Actual Initial Indicated Applied (as found)
Ir. tens ity.
Error Intensity Indicated (mR/ hour)
(%)
(mR/ hour)
Intensity Date:
(mR/ hour)
Source:
Act'vity:
Serial:
Cali'trator Madel:
Seria;.
(
r~~N Technician Sign.
i l
1 t
l,1
~
V COMO TECH, 'Inc.
',/
g-4
)
N/
It'em #12 Film, Badges, Dosimeters,and Personal Alarm Personnel Dosimetry-Termoluminescent dosimetry:
readout every 30 days by Termo Analytical.Inc.
p.o. box 3874, Albuquerque, NM 87190-3874 Pocket-type. quartz fiber electroscope dosimeters, Dosimeter Corp. Model 862. -Zeroing of pocket dosimeters by use of Dosimeter Corp. Model 909 dosimeter charger.
Each radiography personnel must have a pocket dosimeter, TLD.(or film badge), survey meter and Personal Alarm before entering a restrictedorea or handling radioactive materials.
A.
Thermoluminescent Dosimeter (TLD) 1.
A TLD must be worn by radiography personnel before entering a' restricted area or handling radioactive materials.
2.
Only the TLD issued to each radiography personnel by the RSO shall be worn by.that person.
Exchanging TLD's among personnel is strictly
("T-prohibited.
Gl 3.
TLD's must be protected from-impact and abrasion.
4.
TLD's must be shielded from radiation when not in use.
5.
Lost or damaged TLD's must be immediately' reported to the RSO.
6' TLD(or film badge) reports must be maintained in permanent file by.the RSO until the NRC authorizes their. disposal.
B.
Pocket Dosimeter j
1.
Dosimeters must have a range of 0-200 mR.
2.
Dosimeters must be recharged at the beginning of each work shift.
3.
Dosimeters dosages must be recorded on the Personal Yearly Log at the end of each work shift.
\\>
Ij
l
'y E'
COMO TECH, Inc.
r
~ky
/
' Item #12 Film, Badges, Dosimeters, and Personal Alarm Continued 4.
Dosimeters must be worn between the waist and lapel.
5.
Dosimeters must be protected from impact, dust, and moisture (including condensation caused'by temperature changes).
6.
Dosimeter' dosage should be checked frequently during any operation involving exposure to radiation.
7.
If an individual's dosimeter goes "off scale" the RSO will immediately submit that individual's TLD for processing.
8.
Dosimeters must be calibrated yearly to verify a plus.or minus 30% accuracy.
Calibration records shall be maintained in permanent files by the RSO for three years.
C.
Personal Alarm l'.
A Personal Alarm must-be worn by radiography fs jj' personnel before entering a restricted area orLhandling radioactive materials.
2.
A Personal Alarm must be protected from impact and abrasion.
3.
A Personal Alarm can be tested by placing near a source, to be sure it will alarm.
D.
Survey Meter 1.
Survey Meters must have a range of 2mr/hr to 1000 mr/hr.
2.
Survey meters in use must be calibrated each (3) three months and after each repair by an authorized calibration service or by COMO TECH, Inc.
w.
c.>
4 -
4" COMO TECH,.Inc.
?-(m)s.
(Safety) Program Item #14-Radiation Protection 1:
It is the responsibility of the Radiation Safety Officer to administer a radiatiori safety program that complies I
with the terms of this license, a11' applicable governmental regniations, and the principle of ALARA.
The applicable Nuclear Regulatory Commission regulations and; Agreement State regulations which must be passed ar.d satisfied are:
" Notices, Instructions and-Reports to Workers; Inspections" 10 CFR Part 20,
" Standards for Protection Against Radiation" 10 CFR Part 21,
" Reporting of Defects and Noncompliance"
)
" Rules of General Applicability to Domestic Licensing of Byproduct Material" 10 CFR Part 34,
" Licenses for Radiography and Radiation Safety Requirements for-Radiographic Operations"
\\'
10 CFR'Part 40,
" Domestic Licensing of Source Material" 10 CFR Part 71,
" Packaging and. Transportation of l
Radioactive Material" 10 CFR Part 170, " Fees for Facilities and Material Licenses" K.A.R.
Part 3,
" Licensing of Sources of Radiation" K.A.R.
Part 4,
" Standards for Protecticn Against Radiation" K.A.R.
Part 7, "Special Requirements for Industrial Radiographic Operationr" e
K.A.R.
Part 10,
" Notices, Instructions and Reports to Workeru: Inspections" The attached radiation safety program defines minimum safety requirements in the following areas" 14.1 Internal Inspection Program and Other Management Control O
i
'COMO TECH, Inc.
- p.,
E-Item #14. Radiation Protection'(Safety) Program Continued 14.2 Operating and Emergency Program-(Personnel Maintaining Equipment / Radiation Detection Instruments) 14.3 Leak Testing Program NOTE:
The principal of ALARA (As Low as Reasonable Achievable) requires that the radiation safety program include _the responsibility of reducing occupational exposure to radiation to the lowest practical level-below those specified in 10 CFR Part 20 " Standards for Protection Against Radiation".
4 '
v 1
i l
1
COMO TECH, Inc.
h Item #14 Radiation Protection Program Item #14.1 The Internal Inspection System and Other Management Control The Interral Inspection Program shall be administered by the RSO.
The purpose of the program is to verify that NRC and Agreement States Regulations, l
Licenses provisions, and the Operating and Emergency Procedures of COMO TECH, Inc. are followed by all Radiographer and Radiographer's Assistants.
The program shall consist of the following actions:
14.1.1 Inspection of radiography operations at temporary job sites.
14.1.2 Inspection of records completed by radiography personnel.
14.1.3 Correction of deficiencies.
Item #14.1.1 Inspection of radiography operations at temporary job sites.
lll A.
Inspections shall be conducted by the RSO.
B.
Each radiographer and radiographer's assistant shall be inspected at intervals not to exceed three (3) months.
C.
The RSO shall attempt to inspect radiography personnel who have not engaged in radiography for a period of three (3) months the first time such personnel performs radiography thereafter.
D.
Half of all inspections vill be unannounced.
E.
An Inspection Checklist shall be completed by the RSO for each inspection and maintained on file for a period fo three (3) years.
See
" Internal Inspection Checklist".
Item #14.1.2 Inspection of records corp.ieted by radiography personnel.
The fo11oving records shall be reviewed by the RSO on a weekly basis.
A.
Radioactive Material Utilization Log Daily Operations and Survey Report B.
C.
SP'pper Declaration for Dangerous Goods (See Attached Forms)
". 7 *
.COMO TECH,.Inc.
i Item:#14 Radiation Protection Program Continued Item #14.1.3 Correction of Deficiencies.
Deficiencies by radiographic personnel as determined I
by' internal inspections and records 1
reviews shall be coreected by the RSO immediately.
Such corrections may include any of the following actions; A.
Informal discussion B.
Formal retraining C.
Suspension or dismissal Records of corrective action must.be signed by the personnel. involved and maintained for three (3) years.
i
()
--._-------..--,--w-
---w--------
COMO TECH, Inc.
/l)
Item #14.1.4a Internal Inspection Checklist This form is to completed by the Radiation Safety Officer during inspection of personnel engaged in radiographic operations at a temporary job site.
Date:
Unanounced Inspection?
Yes No Job and Location:
Radiographer or Assistant:
Did the above personnel have the following items on hand?
Company license (s)
Company O&E Procedures NRC Regulations Daily Operations & Survey Report Dosimeter'and charger TLD (or Film badge)
Calibrated survey meter
" Radioactive" shipping labels Vehicle Placards Barrier tape and signs Decay chart Other:
\\
Did'the above personnel perform the following actions properly?
Inspect equipment Complete reports Post restricted area Post high radiation area Verify posting (1st exp)
Survey after each exposrue Maintain surveillance Maintain security (exp device)
Adhere to O&E Procedures Transportation regulations Other:
Comments on violations: _
Corrective action: _ _ _
RSO:
Empicyee: __
Signature Signature This form must be retained for a period of three (3) years.
Od
COMO TECH, Inc.
- t o SHIFFING PAPrRS **itti P.O. Box 292 q..................I.le.S..o.HL.o..,...K..s... 6..i6 0.1. 8..............__.....NAI A800US-.-
a 1
RAD 10 ACTIVE MATER!AL=SPECIAL FORM-N.D.S. IRIDIUM-192 UN 2974 C.O.C.-13 NO. USA /9023/*o(U)
TYPE B(U)-PACYAGE I 1
TEANSP0isi IN0El.5 YELLOW LABLE 11 APPLIED I
/m
-.__........ 1 s..........................................................................__............................--
I
!ST TRANSPORT 1
2ND TRANSPORT 3RD TRANSPORT I
4TH1RANEPOR!
I I
i.........==_-
I MRH I
MRH 1
ERH 1
MRH I MEH I
MRH I
MRH I
MRH
.I 1
1 SURFACE '!
INCEI I
SURFACE I IN:El
! SURFACE I INDEX
! SUFJACE I INDEI I
CURIES 1
= =............I 1
1 1
==. I I
I SUN.
LV....I............I...........I_...........I-1 1
1 1
1 I..... AR....I........... 1...........I............I.....
I.......... I............i.
... 1.............I..............I I MDM.
LV....I............I...........I............!
I= - -
---...=
-...I.............!
1
-]
..AR....I....=
I...........I............I...........I....-
...I............I............I.............I............._l-1 TUES.
LV....I-
=...I...........I............I...........I...
I............I
-.....I.............I i
1
=
I........AR... 1............I I
I I
!_.......__..I I
I..............I
-............i............ 1 I
I I EED.
LV....I............I...........I............I...........I............I.......
I........AR....I...........I__.........I............I.......... 1........... 1............!............!.-
1 1 THUR.
LV... 1............I...........I......_.. _.I...........I....
I...........I.............I..
...I I
1....AR....I...........1..........1...........1...........i............i..........i...........1............1..............I I FRI.
LV.
'l I
I...........!............!
1
.I.............I._
I I........AR.
I I
I I
i...........1..._-
SAT.
LV...I.._......._.I...........I..........i.......... 1............!=--
-...I.....__.....I.............I 1
1....... 4R....!.......-
I_..........I............I...........!............!.....-
_= !
SOURCE UNIT N:.
MODEL..............................
SERIAL Na,..........................................
VEHICLE SURVEY...................
SERVEY METER No.
WEEK END (SAT.)
..........=-
....................___...==-
I SECURITY & UTILlIATION LO3 I
,.,3 g...............g..._
. =,, - -
...g...........g...............g..=-
=..............g........................g
()
1 001 0F STE.
IN SIG.
I INSP.
I 10iAL I
I g
g.......g.......g......g.......i.......-!
MAINT, 1 I
i w
1 DATE 1 TIME I S!GN I T!hE I ffH I S!0N I CHECK ! EXf05URE I
CUST0MER I
LOCAT10h g...............g.......;.......g.......g...__.g....__..t...........g...............g.......................g......................._gl
!.. SUN..........I...... 1.......i.......!...... 1....... 1.....__....I...............i.......................i........................I I.. MON..........!.......I.......I.......I.......I........I...........!...............I.......................i................_
--- l.
1..IUES.__.....I...... 1.......I.......i.......!........!...........I I
- - =..
-==..-=
1..WED......... 1.......I.....I.......I.......I........I...........I...............I..--
I..THUR.........!._.... 1...
.. 1...... 1..__.. 1........!......__.. 1...............I..
--..........i..-
!..FRI..........I.......!-
.. 1.......I I
I I
i 1...................._..
1 1
_...........I I.. SAT......... 1.......!.......!.......!.......!.......!.......... 1.........
1....-
....
I--
...I..__...!...,...!.......!.......I........I.......... I.__............!.......................I........................f THYSICAL RADIATION 52RVEY
)'
i 1 SUN.i ?CN.! TUE3! WED.! THURI FRI.I SAT.I D03E RATE I
I SL'N.1 N0h,1 IUISI WED,1 THURI FRiil SAT.!
l XRH I.....I.... 1.....i....!.....!.... 1___.
1 D! STANCE I MRH I.....l..
. !..... !..... !..-. !.... i..... !
1 71
]..... !..... !...... !.... 1..... !..... !..... I i fHIELDINS I I FT. I i
f f.
I.... J...... l..... !
4 4
! SC 1...
4.... 1.... 1.... !.....!--,. !..... !
-I SC 1....
1_... 1.... 1.... 1...._1.....!.....!
- 1..... !..... I..... I..... I.... I-...I.....!.....!
I.....i_...
1
!.....!.... 1.... 1....
1 e
e Sugrct e
t I
1 $UN.! HON.! TUESI WED.! THURI FRI ! SAT,1 1
4
! !)N.! MON.I TUE51 WED.! THORI FRI.! SAT.!
i I t RH I..... !..... !..... !..... i..... !... 1 _.., !
.....I.....I.....I e
l ERH I.....!...!.....I-
~
,- 1 FI 1
!.....!.....!.....!.....!.....!.....I i
- I FT. i -...l.....i.....!.... I.....!.....!.....!
t.
'l SC I.....I.....!... !.
1 SC 1.... 1.... 1.....!.....!.....!.... 1___.
1
!.....!.....!.....I.....I.....i.....!.....!.....I I.....I.....I.....I.....I.....!.....!.....!.....I
'~#
4
~
COMO TECH, Inc.
Item 14.1.4b Radioactive Material Utilization Log e
This form is to be completed by a radiographer each time an exposure device is removed from and returned to its storage container.
(forms attached)
I O
9 I
N e
I" t',i
'l,
w
DAILY OPERATION REPORT I
COMO TECH, Inc.
O Exposure Device Inspection Checklist (Check space to indicate "OK")
Safety plug Source tag Guide tube fitting Name plate Lock Caution Labels Handle S/N of devices rejected from use due to defects:
Are rejected devices clearly marked " DEFECTIVE"?
Yes No Control and Guide Tube Inspection Checklist (Check to indicate "OK")
Operates easily Free of foreign matter Conduit fittings Conduits Drive cable Drive cable connector Source tube body Source tube fittings O
Connector linking control assembly to exposure device Was any equipment rejected from use due to defects? Yes No Are they clearly marked " DEFECTIVE"?
Yes No O
~
_----,--_----_-u-
COMO TECH, Inc.
Item #14.1 The Internal Inspection System and Other Management Control Item #14.1.5 Preparing Radioactive Materials for Shipping.
1.
The radiation Safety Officer shall be responsible for preparing all radioactive materials for shipping via commerical carrier.
Other radiography personnel may be instructed to assist but only under the direct surveillance of the RSO.
A survey of radiation levels around the containers prepared for shipment will be made to determine compliance with Department of Transportation regulations and for appropriate ship-ping papers.
2.
The Radiation Safety Officer shall be responsible for preparing all Shipping Papers required for the transportation of radioactive materials via commer-cial carrier.
3.
Records of materials shipped will be kept on file for three (3) years.
Item #14.1.6 Receiving Radioactive Material 9hipments lll The Radiation Safety Officer shall be responsible for checking in all radioactive material shipments and exchanging sources.
Cther radiography personnel may be required to assist, but only under the direct surveillance of the RSO.
Record of shipments will be kept on file for three (3) years.
(See attached form)
Item #14.1.7 Quarterly Inspection and Maintenance of Equipment The Radiation Safety Officer shall be responsible for performing a quarterly inspection / inventory of all radiographic equipment. Recording condition and status of said equipe2nt.
As well as performing maintenance as necessary or replacement of said equipment.
Records of these Quarterlies will be kept on file for three (3) years.
O
'4.
b COMO TECH, Inc.
RECEIVED. SHIPPED ISOTOPE (S) n PHYSICAL-SURVEY REPORTS V-Shipper's Name & Address:
Shipper's Transportation Weightbill
- Name & Title of Signatory:
Type of Material Shipped:
Radioactive Material Special Form N.O.S.
Class / Division UN# or ID#
Type-Quanitity Proper Packina:
Type A Type B(U)
Type B(M)
Overpack Used,_,
Yes
'No, If so, Marked & Labled Yes No Proper package l'abeling & Packina Instructions:
Number of Radioactive Labels Contents Activity
-V'm)'
Yellou II Yellov III Transport Index If Air Cargo _ Danger Label (s)
Yes No Piece Count Agrees with Shipper Yes No Security Seal Intact Radiation Survey at Surface of Shippina:
MR/Hr.
l Survey Instrument:
Make.____
Model SN Date of Last Calibrati.cn 4
l Location of Received Material (s):
]
1 Delivered to COMO Tech,Inc.
1 Cargo Carrier Name & Invoice #
i COMO TECH, INc. Pick-up Delivery at: (Naue & Address of Carao Carrier &
Billing number Checked By:
Signature Date/ Time
=
k COM0' TECH, Inc.
\\~-
Item #14.2 Operating 'and Emergency' Procedures Scope:
The. purpose of COMO TECH, Inc. Operating and Emergency procedures is to' provide all individuals i
involved in the company's radiography program with clear and specific instructions for all functions performed.in Radiographic operations.
The understanding and following of these procedures-vill ensure compliance of all Federal and State regulations as well as provide a safe guidance for working with radioactive material with minimized radiation exposure to'all individuals.
Table of Contents 1.
Preparations before entering a restricted area or handling radioactive material.
2.
Removing radioactive material from storage container.
3.
Daily maintenance inspection of radiographic equipment.
4.
Preparing radioactive material for transportation to temporary job site.
U,% -
^
5' Transporting radioactive material to temporary job site.
^6.
Preparing temporary job site for radiographic operations.
7.
Radiographic operations.
8.
Discontinuing radiographic operations.
9.
Securing radioactive material in storage container.
- 10. Review of records to be completed'by radiography personnel.
i
- 11. Emergency procedures.
"12. ALARA NOTE:
All radiography personnel are required tc possess, understand, and strictly adhere to these procedures.
A copy of the-Operating & Emergency Procedures must be provided tc each personnel for use at temporary job sites.
O
l q
COMO TECH, Inc.
.7,
.,<),
Item #14.2 Operating and Emergency Procedures l
(
Item #14.2.1 Preparat!ons before entering a restricted area _or. handling radioactive materials.
1 Personnel Monitoring equipment when not in use will be stored inthe Personnel Monitoring equipment
-Storage Room.
The following actions must be conducted by all radiography personnel at the beginning of each vork shift:
1.
Recharge your direct reading pocket dosimeter according to the following:
a.
Remove protective cap from charging end of dosimeter.
b.
Remove protective cap from charging post of dosimeter charger.
c.
Gently insert charging end of dosimeter on charging post of charger.
Caution:
The charging pin at the charging end of the dosimeter is fragile.
(7 d.
While looking throught vieving end of
\\--
dosimeter, firmly press dosimeter-onto post until the charger light activates.
While viewing dosimeter scale through e.
the viewing end of the dosimeter adjust scale hairline to zero by rotating adjustment knob on charger.
f.
Abruptly lift dosimeter away frcm charger and examine to verify that the hairline is on zero (approximately).
L g.
If hairline has moved off zero repeat above procedure.
3 IMPORTANT IT YOUIi DOSIMETZR GOES "OF? SCALE" AT ANY TIME DUR!NG CR AT THE END OF THL WORK SHIF1 YOU MUST:
STOP WORK iMMEDIATELY, SECURE SOURCE / EXPOSURE DEVICE REPORT TO RSO AND TURN IN TLD IMMEDIATELY LAVOID ADDITIONAL EXPOSURE UNTIL NOTIFIED BY THE ESO 2.
Entering starting dosimeter reading on Daily l
Operations and Survey Report.
()
3.
Att'ach Focket Dosimeter to your body or place inside shirt pocket.
r
COMO TECH, Inc.
4 (q. '
Item #14.2 Operating & Emergency Procedures j
i Item #14.2.1 Preparations before entering a restricted H
area or handling radioactive material Continued.
4.
Attached TLD (or. film badge) between groin and throat.
EACH RADIOGRAPHY PERSONNEL MUST USE THE TLD ASSIGNED BY THE RSO.
EXCHANGING TLD'S IS STRICTLY PROHIBITED IMMEDIATELY NOTIFY THE RSO IF YOUR TLD IS DAMAGED OR MISPLACED. ONLY THE RSO MAY PROVIDE A REPLACEMENT..
5.
Obtain a' survey meter capable of measuring intensities fro 2mr/hr to 1000 mr/hr and
. conduct the following inspection.
a.
Check battery strength.
Replace weak batteries.
b.
Check calibration sticker affixed to survey meter to verify that the meter is within the specified calibration period.
Survey meters must be calibrated every 90 days and after each repair.
i
)'
('
c.
Verify that the survey meter is' operable by placing in a known radiation field of low intensity to verify that the meter responds.
(A check source, the surface of an exposure device or the surface of the storage vault may be suitable for this purpose).
IMPORTANT THE ABOVE SURVEY METER INSPECTION IS MANDATORY AND ESSENTIAL TO ENSURE YOUR SAFETY.
DO NOT USE A SURVEY METER THAT DOES NOT SATISFY THE ABOVE REQUIREMENTS!
6.
Immediately remove inoperable or unqualified dosimeters and survey meters from service and report to the RSO.
Clearly mark each defective item "D0 NOT USE" to prevent accidental use.
i g' ~
IF THE SURVEY METER FAILS TO OPERATE WHILE IN USE THE RADIOGRAPHY OPERATIONS MUST BE IMMEDIATELY TER!!INATED UNTIL A CALIBRATED 1
AND PROPERLY OPERATING SURVEY METER IS OBTAINED.
?
if COMO TECH,. Inc.
\\
~
f
/~
(_)Y
-Item 14.2 Operating and Emergency Procedures Item 414.2.2 Removing Radioactive Material from Storage Container FOR IRIDIUM 192 EXPOSURE DEVICES:
a.
Adjust survey meter to 10X scale b.
Survey exterior perimeter of exposure device from a distance of six (6) inches.
The. radiation intensity must not exceed 50mr/hr.
Adjust survey meter to 100X scale survey. exterior surface of exposure device.
The radiation intensity must not exceed 200 mr/hr, yet should not exceed intensities-detected by the survey of the previous-shift.
Notify the RSO if excessive intensities.
are detected.
c.
Enter survey results on " Daily Operations and Survey Report" FOR COBALO'60 EXPOSURE DEVICES
.a.
Adjust survey meter to 100X scale.
()
b.
Survey exterior surface of exposure device.
The radiation intensity must not exceed 200mr/hr, yet should not exceed the. intensities detected.
by the survey of the previous shift.
Notify the RSO if excessive intensities are detected.
c.
Enter survey results on " Daily' Operating and Survey Report" IMPORTANT:
By referring to the survey results of the previous shift you are able to indicate if the survey meter is continuing to. operate properly.
If the same survey meter, exposure device and radioactive source are used,.the radiation intensities should be approx-imately equal.
Otherwise the survey meter is no longer providing accurate to radiation or the radioactive source is not secured in the same location within the exposure device.
This procedure allows you to perform a test of accuracy of the survey meter on a daily basis that is simular to the calibration procedure required quarterly.
g
.'d
.A r
.COMO TECH, Inc.
(_%)1 Item.#14.2 Operating and Emergency Procedures Item #14.2.3 Daily Maintenance Inspection Of Radiographic Equipment 1.
Exposure: Device a.
Inspect safety plug to verify proper installation.
b.
Remove safety plug and inspect guide tube fitting for defects such as being loose, bent, cracked or worn.
c.
Inspect pigtail cable for defects such-as broken or unwound strands.
d.
Inspect lock mechanism for proper operation.
The mechanism should operate freely and should, securely lock the pigtail assembly.
in place when-engaged.
e.
Inspect exposure device to verify that a source tag, name plate, daily' inspection decal and two " Caution Radioactive" decals are attached and legible.
f.
Inspect exposure device handle and other attachments and fittings for obvious damage.
g.
Record the results of the above inspection in the " Daily' Inspection and Survey Log".
DO NOT USE A DEFECTIVE EXPOSURE DEVICE.
NOTIFY RSO IF'ANY DEFECTS EXIST.
2.
Control Assembly a.
Lay out control assemble.
b.
Inspect for loose, broken, excessively worn fittingc..
c.
. Inspect for cut, broken or. melted conduits d.
Inspect drive cable connector for defects such as being bent, broken, excessively f
worn or loosely attached to tre drive l
cable.
' P, V
e' COMO TECH, Inc.
-j j
. f3 A)
Item #14.2 Operating and Emergency Procedures j
i Item #14.2.3' Daily Maintenance Inspection of Radiographic Equipment Continued e.
Inspect drive cable at the connector for defects such as broken strands or inflexibility due to rust.
f.
Record inspection results on " Daily Operations-and Survey' Log".
DO NOT USE A DEFECTIVE CONTROL ASSEMBLY, NOTIFY THE RSO IF ANY DEFECTS EXIST.
3.
Guide Tube a.
Inspect guide tube for defects such as cuts, dents, melted area, loose or inoperative fittings.
I b.
Record inspection results in Daily Operations Survey Log.
.f.(
D0' NOT USE A DEFECTIVE GUIDE TUBE, NOTIFY THE RSO.IF ANY DEFECTS EXIST.
d '~
Item #14.2.4 Preparing Radioactive Material for Transportation to-Temporary Job Sites.
1.
Survey the exterior of the storage container or shipping drum.
Radiation intensity must not exceed 200 mr/hr at the surface or 10 mr/hr-at one meter.
2.
Determine which catagory of RADIOACTIVE LABEL to use.
a.
Use RADIOACTIVE III labels if:
1.
The radiation level measured at any surface of the storage container or shipping drum equals or exceeds 50 mr/hr.
OR 2.
The radiation level. measured at a distance of one meter from the storage container or shipping drum equals or exceeds Imr/hr l
NOTE:
The radiation level measured at d
L one meter is the " Transport Index".
l,
(~)'
s
_.--._.__._._...-.__._.____-_s--_---
n;
- j. ' '
COMO, Tech, Inc.
r~N l
- (.,I Item.#14.2 Operating and Emergency Procedures l
Item.#14.2.4' Preparing Radioactive Material for Transportation to Temporary Job Sites Continued B.
Use RADIOACTIVE II Labels if:
1.
The surface radiation level is less than 50 mr/hr.
AND 2.
The transport index is less than 1.0 3.
Prepare two. RADIOACTIVE Labels as follovs:
a.
Write " Iridium-192 and actual number of curies on the appropriate lines.
Write the transport index in.the blank bcx (use, decimals).
I b.
Affix RADIOACTIVE labels on two opposite
. sides of the storage container.
4.-
Affix DOT " RADIOACTIVE" placards to each of the four sides of the transport vehicle if
-3ADICACTIVE III labels are used.
(IF RADIOACTIVE II Labels are used no vehicle placards re-required.
l k_
5.
Survey exterior surfaces of the-transport vehicle.
'The maximum radiation intensity allowed is 2 mr/hr inside the passenger compartment.
Reposition ofthe shipping drum or install sheilding in the storage container as needed if higher intensity is_ measured.
Resurvey the vehicle to verify that theabove requirements have been satisified.
6.
Maintain a survey meter with vehicle driver.
7.
Obtain copies of the follouing documents:
a.
Company's NRC License and agreement state license (s) b..
Company's Operating and Emergency Procedures.
c.
Company 's Daily Operatir.g and Survey Report.
d.
Title 10 CFR Parts 19,20,& 34.
K.A.R.
Parts 4.7, and 10.
e.
Shipping Declaration for Dangerous Goods.
1 l
t*
j COMO TECH, Inc
-l 1
rw)
.( "
, Item.#14.2 Operating'and-Emergency Procedures L
~
Item #14.2.4 Preparing Radioactive Material for Transportation to Temporary Job Sites Continued
{
f.
. Certificate of Compliance for Radioactive Materials Packages.
'l g.
Applicable Radioactive Source Material Decay Charts.
NOTE: Each of the above documents are made available to you by the RSO.
Immediately notify the RSO if replacements.for misplaced copies are required.
you must have these documents with you while you are located at a temporary job site.
8.
Proceed to job site.
See'section 5 " Transporting Radioactive Material t.o Temporary job site.
I Item # 14.2.5 Transporting Radioactive Material to a Temporary Job Site l'.
The vehicle driver must possess an operable and calibrated survey meter.
O 2.
The-vehicle driver must possess the documents =
provided by the RSO described in Section 4.8 of these Procedures.
3.
If placards are required on the vehicle (when RADIOACTIVE III labels are required on the shipment) the driver must. proceed-to the job site via the most direct route and avoid unnecessary delays.
4.
If the vehicle is temporarily stopped in j
route to job site (ie; Lunch) a " Caution Radioactive Material" sign must be affixed to the locked darkroom door.
f m
5.
In the event of an accident refer to Section v
11 Emergency Procedures" j
(
6 If the vehicle used for transport is also used as storage on or at temporary job sitos or in overnight travel to or from a tenporary i
job site, proper pesting of the vehicle
)
is required.
i ds)v
i..
COMO TECH, Inc.
s
(_)
Item #14.2 Operating and Emergency Procedures-l-
Item #14.2.5 Transporting Radioactive Material to a I,
Temporary Job Site Continued.
I 6.
If transporting a package.with RADIOACTIVE YELLOW III labels and: transport placards reading " RADIOACTIVE" are used.
Then'during periods of non-transport placards shall be changed to read " Caution-Radioactive-Material".
If transporting. packages with RADIOACTIVE YELLOW II labels, then during periods of non-transport. vehicle shall be posted with " Caution-Radioactive _ Material". In either situation a survey of radiation levels shall be made and levels may not exceed 2 milliroentgen per hour at 18" from any external surface of the vehicle.
The vehicle and darkroom shall be locked when-used for storage.
Item #14.2.6 Preparing Temporary Job Site For Radiography Operations.
1.
Establish and Post Restricted Area a.
Based upon source strength and the anticipated
()'
exposure durationper hour, calculate the-minimum distances to the Restricted Area boundary and the High Radiation Area boundary.
1.
The restricted Area boundary must be located where the radiation intensity is sufficient to expose an individual to a dose of2mr/hr in one hour.
OR Where the radiation intensity is sufficient to expose and individual to,a dose of 100 mr/hr in seven (7) consecutive days.
2.
The'High Radiation Area bound 6.ry must be located where the radiation intansity is sufficient toexpose an individual to a dose of 100 mr/hr in one (1) hour.
(~N -
U
= _____. - _ _ _ _ _ _
_ - = - _. _ _ _.
'e;s.
COF.0 ' TECH, Inc.
,)
I'T
(_/
Item #14.2LOperating and Emergency Procedures
- Item #14.2.6 Preparing Temporary Job Site'for Radiography Opera t ions ~ Cont i.'ued.
b.
Post " Caution-Radiation Area" signs at any conspicuous location necessary to warn individuals from entering the restricted area.
Use barrier rope to supplement signs in locations where signs alone may be. insufficient.
c.
Post " Caution _High Radiation Area" signs at any conspiciouslocation necessary to warn individuals from entering the highradiation area.
Use barrier' rope to supplement. signs in locations where signs alone may be insufficient.
d.
A confirming survey of only the established restricted' area perimeter will be made after the source has been exposed.
Adjust perimeter if necessary.
1 IMPORTANT THE RADIOGRAPHER MUST MAINTAIN DIRECT VISUAL SURVEILLANCE OF THE RESTRICTED AREA TO PREVENT UNAUTHORIZED ENTRY!
Item #14.2.7 Radiography Operations IF THE RADIOGRAPHER'S ASSISTANT IS INSTRUCTED TO OPERATE THE RADIOGRAPHY EQUIPMENT OR CONDUCT A RADIATION SURVEY IT MUST BE PERFORMED UNDER THE DIRECT VISUAL SURVEILLANCE OF A RADIOGRAPHER !
1.
Verify that survey meter is operating properly by activating the battery check and confirming that the meter responds to radiation by placing it near the exposure device.
2.
Remove exposure device from vehicle and survey to verify that the source is in the sheilded i
. position.
a.
Remove the safety plug from the exposure device.
4 b.
Install the source tube to the outlet end of
)
exposure device.
Gently pull to verify a J
proper connection.
f i
1 l_._.'_____m___._
___._.___m_.
..______.._____--___.-.____.__-m_____
a
}'
COMO TECH, Inc.
I)
Item #14.2' Operating and Emergency Procedures Item #14.2.7 Radiography Operations Continued c.
Install a collimator to the end piece of the source tube (if applicable).
Gently pull to verify the proper installations.
In order to comply with the. principle of ALARA a collimator MUST be used for all radiography exposures unless the use of a collimator would restrict the technical aspects of the radiography program.
d.
Position radiography equipment for initial exposure.
3.
-unlock exposure device and crank source out completely to the end of the guide tube.
4.
Survey the Restricted Area boundary to verify that the actual radiation level is not greater than the calculated boundary.
If the radiation level is higher than calculated the source must be retracted and boundary repositioned
[)
to the correct location.
Do not survey the High Radiation Area boundary.
5.
Survey after each exposure accorading to the following:
a.
Fully retract' source into exposure device then approach exposure device with survey meter in hand.
b.
Survey the exposure device beginning with the cutlet end at a distance of one foot from the device, then the entire circumference of the device, then the source tube alnong the entire length to l
the collimator.
I c.
Lock the expsoure device and survey the surface of the device at a predetermined location (i.e. side of device at the lock end).
(_/
_m_._.__.m__
i r; e
L
[o' COMO TECH,' Inc.
g t,) -
Item #14.2.Operat'ing and Emergency; Procedures l
ItemL#14.2.7 Radiography Operations Continued NOTE:
Surveying the exposure device at the same location after each expsoure allows you to determine if any potential safety-hazard exists.
If the. radiation level changes from one survey to the next either:
i 1.
The source is not being retracted to fully shielded position within the exposure device, or 2.
The survey meter is no' longer operating properly.
6.
If.a unauthorized individual enters the Restricted
-Area while the source is exposed the radiographer must immediately warn &ha parson andoretract the source as needed in order to protect the individuals satety.
7.
If the source cannot be retracted to the shielded position after an exposure refer to the EMERGENCY PROCEDURES.
( )'
Item #14.2.8 Discontinuing Radiography Operations 1.
when the radiography operations are discontinued for limited periods, (i.e rest break)~the exposure device must be locked, surveyed and either (a) maintained within the direct visual surveillance of a radiographer within the Restricted Area, or (b) Locked within a storage container (such as a darkroom) which is posted with " Caution-Radioactive i
Material" sign.
The door to the darkroom must be locked.
NOTE:
A survey must be performed to verify that the radiation level measured at 18 inches from the storage container does not exceed 2mr/hr.
I l
2.
When radioactive operations are discontinued I
for limited periods and the following conditions are satified; a.
The expsoure device is located wherc extraordinary effort would be required for an individual to gain access to it.
(~s l
l x__-_________-___----___.
.g
~~J i, '
,COMO TECH'Inc.
!mm)
Item.#14.2 Operating and Emergency Procedures
~
Item #14.2.8 Discontinuing Radiography Operations Continued b.
The radiographer is able to maintain complete visual surveillance of all access routes to the locked exposure' device and thereby ensure that unauthorized tampering or removal cannot occur.
AND c.
Relocating the exposure' device would be difficut and represents a potential safety-risk, the device may remain secured within the Restricted Area. Thid RARE situation might occur when performing radiography in a plant or building
.under construction.
3.
When Radiography operations are discontinued
.at the end of a work shift the exposure device must be locked and surveyed.
4.
The exposure device must be secured within the vehicle inaccordance with the same procedures described in section #4 " Preparing Radioactive l
(^T Material For Transportation to Temporary Job Site".
i Item #14.2.9 Securing Radioactive Material in Storage Container.
At the end of each work shift in.which the exposure device is returned to the storage container the procedures listed below must be followed upon arrival at the facility.
1.
Survey the exterior of the storage container within the vehicle and verify that the radiation level has not increased in transit. This survey must be compared with the exposure device survey conducted at the end ofthe work shift.
Notify the RSO if the radiation level har increased.
l 2.
The final exposure device survey results must be recorded on the Daily Operations and Survey Re po;r t.
3.
Complete the Radioactive Material Utilization Lod by entering the date and time the device (s) were returned to the storage containers.
k l
M
---,1A,-----__---__----_----------_a-.--
9 4
e COMO TECH, Inc.
f-
'm)
Item #14.2 Operating and Emergency Procedures Item #14.2.9 Securing Radioactive Material in Storage Container Continued.
4.
Examine dosimeter and record final dosage on Daily Personal Log Report.
Include dosage accumulated if dosimeter was recharged during the work shift.
NOTE:
Teh Radiographer must verify that the radiographer's assistant has entered his daily dosage.
5.
Report any equipment malfunctions or defects on the Daily Operations and Survey Report.
Defective equipment, including survey meters, must be clearly marked with a warning tag to prevent accidental usage.
Item #14.2.10 Review of Records to be Completed by Radiography Personnel.
The following records shall be completed by radiography personnel.
All applicable entries must be made l
at the time the required action is performed.
1.
Radioactive Material Utilization Log:
The utilization f~)#
Log must be completed by a radiographer each time an exposure device (or storage device containing a radioactive source) is removed from the company's permanent storage container.
The following information must be included:
a.
a.
Model and serial number of device.
b.
Serial number of the radioactive source.
c.
Name of the radiographer responsible for the use of the device.
d.
Location where device is to be used.
l e.
Time and date device is removed from the storage building.
\\
f.
Time and date device is returned to the storage building.
1
/ 'N I
N)
I i
i
w s
'o *
,COMO TECH, Inc.
7
(_)
Item #14.2 Operating and Emergency Procedures
' Item #14.2.10 Rev.iew of Records to be Completed by Radiography.
Personnel Continued.
3.
Shipping Declaration for Dangerous Goods:
Radiographer's shall be responsible for preparing this form before transporting any radioactive material to temporary job sites in a " exclusive use" vehicle The following information must be included:
a.
Shipper's name and Condignee's name b.
Proper shipping name c.
Class or division number d.
UN or Id number e.
Quantity and type of packing f.
Packing instructions g.
Authorizations h.
Declaration of document accuracy, initials or signature of preparer Item #14.2.11 Emergency Procedures An emergency exists anytime an abnormal occurance
(')
results in a potentia 11 dangerous situation.
The most common emergency is being unable to return the radioactive device to the shielded position of the expsoure. device.
The following procedures must be followed in an emergency:
1 Move a safe distance away from the exposed source.
2.
Immediately warn others who may be in the hazardous area.
3.
Pause!
Allow yourself to relax and think calmly, remember, a t. this point no injury has occured.
By your calm response you will be able to ensure that no injury does occur.
4.
Establish a restricte6 area at the locations where the radiation level is 2 mr/hr.
5.
Send for help while maintaining direct survelliance of the restricted area, until situation is corrected i
or another qualified individual relives you.
6.
DO NOT TRY TO RECOVER A SOURCE NOT IN THE SHIELDED POSITION OR RETRIEVE A DISCONNECTED SOURCE.
(3 L) l l
i l
l
-.5
N ' c l
f8 COMO TECH, Inc.
i p -.\\
q j.
Item #14.2 Operating and Emergency Procedures
. Item #14.2.11 Emergency Procedures Continued 7.
In the order listed, attempt to contact.the following individuals until assistance is reached.
Raymond E.
Hiersche Phone: 913-585-1037 Vick Becker, Consultant Phone: 1-800-225-1383 Local Police or Fire Dept.
Phone: 911 1
Nuclear Regulatory Comm.
Phone: 817-860-8100 Phone: 301-951-0550 off Hours Kansas State Regulatory Phone: 913-2961560 offical Phone : 913-2963102 Off Hours If the vehicle transporting radioactive material l
is involved in a traffic accident a survey of the exterior of the vehicle must be performed I
to verify that the source is in the shielded position.
Inform accident response personnel accordingly (i.e. police).
Source Retrievals Source retrievals will be conducted by Raymond
(~>;
Hiersche, triangulation will be used to locate y
(-
a lost source, and 6 foot long handling tongs will be used to return the source to a shield.
Vick Becker will provide consultation service or direct assistance as needed.
Item #14.2.12 As low as reasonable achievable "ALARA" The philosophy of ALARA requires that each person should make every reasonable effort to maintain radiation exposures as low as possible~.
In 10 CFR Part 20 the maximum limits of radiation exposure are described, yet the goal of management is to reduce exposure as much as possible below the required levels.
In accordance with the above statement, it is the policy of this company to require all radiography personnel to continually strive to avoid unnecessary radiation exposure. Failure to comply with this policy may result in suspension or dismissal at the discretion of the RSO.
(_/
i 4
4
. [*
COMO TECH, Inc.
.()
Item #14.3 Leak Testing All sealed source shall be tested for leakage at intervals not to exceed six months.
In the absence of a certificate from a transfer that a leak test has been made within the six monthperiod prior to transfer, the sealed source shall not be put into use until leak tested.
The leak test shall be capable of detecting the presence of 0.005 micro-curies of removable contamination.
Leak tests shall be made by wiping appropriate accessible surfaces and measuring the level of transferred contamination on the wipes.
Records to leak tests results shall be kept in units of micro-curies and maintained for a period of three (3) years.
If any leak test reveals the presence of 0.005 microcuries i
or more of removable radioactive material, it shall be conclusively presumed that the sealed' source is leaking.
The licensee, COMO TECH, Inc. Shall immediately withdraw the equipment involved from use and shall cause it to be decontaminated and repaired, or to be disposed of, in accordance with regulations of the department.
Within five (5) days after obtaining results of any leak test, the licensee, COMO TECH, Inc. shall file a report with
(N the USNRC and Kansas EA0 & RC describing the equipment
\\/
involved, the test re.sults, and the corrective action taken, if any Raymond Hiersche, company RSO will be responsible for the leak testing.
COMO TECH, Inc. Will use:
Amersham Corporation 12960 E 182 St'So.
Bixby, Ok 74008 Item #15 Waste Management All sealed sources and other licensed radioactive material to ce possessed ~b) COMO TECH,Inc. shall be disposed of by transfer to:
l Amersham Corporation The Radiation Safety Officer will be responsible to maintain all disposal records in permanent file.
o
- - _ _ _ _ _ _ -. - _ _ _ _ _