ML20237A951

Rev 1 to Radiation Safety Program

ML20237A951
Person / Time
Site:	07100641
Issue date:	10/23/1987
From:	Basile G, Rodneshia Green UNITED STATES TESTING CO., INC.
To:
Shared Package
ML20237A884	List: ML20237A882 ML20237A900 ML20237A907 ML20237A951
References
28709, UST-985, NUDOCS 8712150364
Download: ML20237A951 (165)

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r 'N a,t hE!~~% g/ \\ 4. RADIATION SAFETY PROGRAM INDEX I. Program Plan II. Operating and Emergency System Procedure III. Operating and Emergency Procedures IV. Maintenance Procedure V. Calibration of Radiation Survey Instruments Procedure VI. Source Shipping / Receiving Instruction Procedure VII. Leak Testing Procedure l VIII. Qualification Procedure IX. Training Procedure X. Audit Procedure XI. Corrective Action Procedure XII. Documentation Procedure XIII. Forms Procedure XIV. Agreement States Procedure NO. TITLE REV. PAGE UST INDEX 985-0 1

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^ KEN,NE JERSEY 07030 (201) 792 2400 (212) 943 4 488 RADIATION SAFETY POLICY STATEMENT l The whole saf ety movement, which exhibits man's concern for himself and his fellow man, deserves to be recognized for its worth at any time. Theref ore, the importance of Radiation Saf ety cannot be ove r emphasized. The goal of United States Testing Company, Inc. is to eliminate radiation safety incidents. This can and will be accomplished by making safety an integral part of the daily job. The Radiation Safety Program f or United States Testing Company contains those rules and guidelines to assist company employees in achieving compliance with State and/or Federal re gula ti ons. Each employee is, theref ore, responsible f or complying with saf ety regu-la ti ons. Mr. Robert E. Green, Corporate Radiation Saf ety Director, shall have overall authority and responsibility to administer and enf orce the Radiation Saf ety Program. He will direct periodic sur-veys to determine whether the Program is achieving compliance. Em-I ployee(s) willfully or deliberately violating safety requirements shall be subj ect to appropriate disciplinary action. Employees shall make compliance with saf ety regulations a top priority item. / Gene Bas ile President

• HoBoKEN, NJ
• oRLANDo, FL
• CHATRNooGA, TN
• Colorado SPRINGS, Co
• MEMPHIS, TN
• MIAMI, FL
• CALGARY, CAN
• ERKERSFIELD, CA
• LoS ANGELES, CA
• MoDEsTo, CA
• FOSTER CITY, CA
• SAN ofEGo, CA
• SAN LEANDA.o, CA MEMBER OF THE SGS ORoup (socETE QENERALE DE $VWEILLANCE)

Unitech Services Group RADIATION SAFETY PROGRAM UST 985 SECTION I PROGRAM PLAN 985-0 Original Issue TWC 09/30/85 r.DISICN EFFECTIVE 30. DESCRIPTICH BY DATE

r lA?\\ RADIATION SAFETY PROGRAM 1.0 OBJECTIVE - This plan defines the Radiation Safety Program IProgram) of U.S. Testing, Unitech Services Group. The ele-ments and methods, described herein, are based on the Nuclent Regulatory Commission (NRC) Federal Regulations

10CFR20, 10CFR 21,

10CFR30, 10CFR34 and radiography regulations of Agreement States.

2.0 APPLICATION - U.S. Testing, Unitech Services Group (Company) personnel and facilities. 3. PROCEDURE 3.1 The Program, described herein, and the Radiation Safety Pro-cedures in this manual, outline the basic methods and prac-tices and delineate the organizational elements used to as-sure the effectiveness of radiation safety efforts. 3.1.1 This Program is an integrated sys tems coproach to opera-

tions, emergencies,

training, quali fi ca ti ons,

organiza-tions, documentation and audit conditions. 3.1.2 Each procedure covers a specifi-area of radiation safety as identified by its title. The controlling documents for radiation safety are as follows. II. Operating and Emergency System Procedure III. Operating and Emergency Procedures IV. Maintenance Procedure v. Calibration of Radiation Survey Instruments Proce-dure VI. Source Shipping / Receiving Instruction Procedure VII. Leak Testing Procedure VIII. Qualification Procedure IX. Training Procedure X. Audit Procedure NO. TITLE REV. PAGE UST - I PROGRAM PLAN 985-0 1 of 4

m%w RADIATION SAFETY PROGRAM 3.3 The Company utilizes three (3) manuals for control of radi-ation safety. 3.3.1 Radiation Safety Program Manual defines the system of con-trol. 3.3.2 Operating and Emergency Procedures (OSE P) is the working document for Radiographer. 3.3.3 Radiographer Training Manual is the study material for Ra-diographic Personnel. (Example: Working Safely in Gamma Radiography - h13 REG /BR0024.) 3.3.4 All revisions to the Program or Procedures shall be by let-ter designation as directed by the RSD and approved by the Executive Safety Committee. NO. TITLE REV. PAGE UST - I PROGRAM PLAN 985-0 3 of 4

APPENDIX A @', mmm Radiation Safety Organization Executive Safety Committee l Gene Basile President Donald Dcmey Vice President I i Robert E. Green Radiation Safety Director Bill Cain Jerry Grinm Western Region Radiation Safety Eastern Region Officer Radiation Safety Officer Project Managers / Supervisor i Monitors as Required i I Radiographer t Assistant Trainee Radiographer Radi ogr aph e r s PAGE REV TITLE NO. of 4 985-0 PROGRAM PLAN UST - I

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,. ~ A n ~ Unitech Services Group l RADIATION SAFETY PROGRAM UST 985 SECTION 1I OPERATING AND EMERGENCY SYSTEM PROCEDURE 985-0 Original Issue TWC 09/30/85 KEV!LICN EFFECTIVE MO. DESCRIPT!CN BY DATE

( RADIATION SAFETY PROGRAM 1.0 OBJECTIVE - Present the administration system for normal op-erations and handling radiation emergencies. The specific emergency actions to be taken by the Regional Radiation Safety Officer (RS0) are also included in this procedure. 2.0 APPLICATION - U.S. Testing, Unitech Services Group (Company) l operations that control, handle and/or store sealed sources. 3.0 PROCEDURE 3.1 Oaerating and Emergency Procedures (OSE P) The 06E P is t:1e Radiographer's and Assistant Radiographer's controlling document for routine operations and handling radiation emer-gencies. The 06E P will be used in all field and laboratory operations. i 3.1.1 Each Assistant Radiographer, Radiographer and Safety Monitor i shall - have an 06E P available whenever they are working with or around a sealed source. i 3.1.2 Operating personnel are directed by the 06E P to report all-radiation emergencies, as defined under Paragraph 3.2.1, first to the Project Manager / Supervisor then to the RSO. In the absence of the Project Manager / Supervisor, emergencies shall be reported to the Monitor or the RSD. 3.1.3 Radiation safety requirements of Agreement

States, which 1

vary from the OSE P, will be issued as addenda to Procedure XIV. Field personnel working in Agreement States will have-available the proper addenda. 3.2 Radiation Hazard Severity The degrees of radiation hazard are a r bi t ra r il;- identified as Emergency, Class B Incident and Class A Incident. The definitions for these terms are as follows. 3.2.1 Emergency - A condition which may have caused, or threatens to cause, one (1) of the following.to occur. 3.2.1.1 Exposure a) Whole Body - three (3) REM or more. b) Hands, Forearms, Ankles and Feet .45 REM or more. NO. TITLE REV. PAGE UST - II OPERATING AND EMERGENCY SYSTEM PROCEDURE 985-0 1 of.12

I - - w. RADIATION SAFETY PROGRAM 3.2.1.2 Contamination - Any release of radioactive material. 3.2.1.3 Work Loss - The loss of four (4) hours work or more in any facility. 3.2.1.4 Damage - Damage to property in excess of $500.00. Note: An Emergency includes all Class B and A Incidents. 3.2.2 Class B Incident A condition which may have caused, o threatens to cause, one (1) of the following to occur. 3.2.2.1 Exposure: a) Whole Body - 5 REM or more. b) Hands, Forearms, Ankles and Feet - 75 REM or more. 3.2.2.2 Contamination - Any release of radioactive material. 3.2.2.3 Work Loss - The loss of one (1) work day or more of the op eration of any facility affected. 3.2.2.4 Damage - Damage of property in excess cf $2,000.00 3.2.3 Class A Incident A condition which may have caused, o threatens to cause, one (1) of the following to occur. 3.2.3.1 Exposure: a) Whole Body - 25 REM or more, b) Hands, Forearms, Feet and Ankles - 375 REM or more. 3.2.3.2 Contamination - Any release of radioactive material. 3.2.3.3 Work Loss - The loss of one (1) workweek or more for the op eration of any facility affected. 3.2.3.4 Damage - Damage of property in excess of $200,000.00. 3.3 Handling an Emergency 3.3.1 Radiation emergency reports will be handled by the RSO o the approved alternates identified in the Program Plan. PAGE REV TITLE NO. 2 of 12 985-0 OPERATING AND EMERGENCY SYSTEM PROCEDURE UST - II

) u- % w. RADIATION SAFETY PROGRAM 3.3.2 The reporting Radiographer will be asked to answer the fol-lowing questions and provide information covered in Para-graph 3.3.3. a) Have all personnel been removed from the radiation area? b) Has the radiation area been posted? c) Is the area being controlled by a responsible person? d) Is there any immediate danger of. personnel receiving radiation exposure? e) Were there any personnel injured? f) What is the nature of the incident? 3.3.3 Three (3) Emergency Action Guidelines are included in this paragraph. The RSO shall select and use the appropriate guideline to plan the emergency action. Supplemental ac-tions may be imposed by the RSO. Reference Type of Emergency Paragraph Personnel Overexposure 3.3.3.1 Exposure Device Malfunction 3.3.3.1 Source Out of Guide Tube 3.3.3.1 Loss of Source on the Jobsite 3.3.3.1 Source Separated from Device 3.3.3.1 Other Conditions Not Listed Below 3.3.3.1 Missing or Stolen Device -3.3.3.2 Plant or Area Fire 3.3.3.3 3.3.3.1 Emergency Action Guidelines for All Conditions except plant or area fires, and a missing or stolen source. a) Determine if the source is properly shielded. b) Verify personnel are clear of the exposure area, c) Verify the radiation area has been posted. NO. TITLE REV. PAGE UST - II OPERATING AND EMERGENCY SYSTEM PROCEDURE 985-0 3 of 12

I ) u~ s.~ m RADIATION SAFETY PROGRAM d) Verify the area is under surveillance. e) Determine if personnel are in danger of receiving fur-ther exposure. f) Determine if.any personnel were injured. g) Determine which personnel-with radiation training are available at or near the site. h) Determine the dosimeter readings of personnel in-volved. 1) Determine the radiation exposure of personnel in-volved. j j) Determine the nuclide and serial number (S/N) of the source to establish the field stiength. k) If the condition is a Class a Incident and there is no immediate, danger, interrupt the reporting at this point to perform the notifications. j 1) Class A Incidents shall be reported immediately and l Class B Incidents within 24 hours. Reporting shall be by telephone or telegraph to the following person. Radiation Safety Director (RSD) U.S. Testing, Unitech Services Group 2506 Dmris St. Sm1 LanWho, CA 94577 (415) 562-7500 m) Verify the exact source location known, or direct the location be determined by triangulation as explained in Exhibit 4 of the 06E P. n) Direct the radiation area posting be corrected, if nec-essary, and the high radiation area be. posted, o) Determine what shielding is available which could be used to minimize exposure during recovery. PAGE REV TITLE NO. ,_n c, .nc

j u ~a RADIATION SAFETY PROGRAM 1 p) Determine the need for additional personnel including civil authorities and/or technical assistance during. the pla nning stage and at the site. If extensive de-lays will occur, plan for surveillance of the area. q) Determine the method of recovery which will produce the minimum exposure to the personnel. r) Review the radiation history of each trained person-who is available to assist in recovery. s) Establish a step-by-step procedure for recovery. Spe-cify on the written procedure the maximum allowa bl e time for each step (Retreat Time) 'which will take place within the radiation or high radiation area, t) Calculate the personnel exposure expected for each' step. Determine the need for new film badges prior to recovery. u) Review the -procedure in detail with the person who -will perform the recovery (Recoverer). Assure the times are realistic. Any changes in - times will re-quire recalculation of the exposure.- Have the Recover-er read the precedure to the RSO for proofing. v) The procedure shall be followed exactly. Changes will be made only by the RSO. w) The Recoverer shall assign a responsible person as- ] Timekeeper. The RSO shall verify that the Timekeeper i unde r s ta nds each step of the procedure and the impor-tance of the " Ret rea t Time". x) The Timekeeper shall immediately noti fy the Recoverer if the Retreat Time of a step has been reached. The l Recoverer shall then immediately leave the radiation l area and report to th.e RSO for further instructions. i y) Upon elimination of the. emergency, proceed with Post- -Emergency Action per Paragraph 3.4. 3.3.3.2 Emergency Action Guidelines - for Missing or Stolen Sources ~. a) Determine what nuclide and S/N is missing. 0 _NO. _ ___, _ _ _ _ _T L E _ _ _ _ _ _ _ _ _ _ _ _ _RE_V. _ PA_GE TI

f ) u-s.v c-. RADIATION SAFETY PROGRAM b) Determine if the exposure device, storage container or source changer, containing the source, is missing. c) Determine if the source containing the equipment was locked. Is there evidence the locking mechanisms were br oken? d) Determine if any personnel at the site have informa-tion as to the possible location of the ' source. e) Direct the Radiographer to immediately contact the'su-pervisor of the company at the jobsite and make the su-pervisor aware of the hazard. Determine the need for clearing work areas until a survey is conducteo.. De-termine the advisibilit .of conducting a physical search of specific areas.y f) Direct the Radiographer to rope off the area wher'e the source was last seen to protect any evidence. g) Interrupt the reporting at this point to perform the notifications. h) Report immediatel by telephone or-telegraph to the following person. y Radiation Safety Director U.S. Testing, Unitech Services Group 2506 Davis St. San Ieandro, CA 94577 (4M). 562-7500 i) Det e rmin e the need for additional personnel and/or technical assistance during the planning stage and at the site. If extensive delays will occur, plan for continuous surveillance of the area. j) Review the radiation history of ' each trained person who is available,to assist in recovery. k) Establish a written step-by-step procedure for ' recov-ery. PAGE REV TITLE NO. 6 of 12 985-O' OPERATING AND EMERGENCY SYSTEM PROCEDURE UST'- II

fu- ~ ~ RADIATION SAFETY PROGRAM 1) Direct the Recoverer to write the procedure verbatim as given by the RSO. Have the Recoverer read the pro-cedure to the RSO for proofing. 1 m) The procedure shall be followed actly. Changes will J be made only by the RSO. n) Upon elimination of the emergency, proceed with Post Emergency Action per Paragraph 3.4. i I 3.3.3.3 Emergency Procedure for Plant or Area Fire. a) Determine if the source is exposed. If it is exposed, can it be safely secured and removed from the danger area? b) Determine the location of the fire with relation to the source. I c) Determine if personnel are clear of the exposure area. d) Determine if personnel a re in danger of receiving fur-ther exposure. e) Assure that the fire crew and plant supervision have been warned of the radiation hazard. f) Determine if the radiation area is posted. g) Determine if the radiation area can be maintained un-der surveillance. h) Determine if any personnel were injured. i) De t e rmin e which personnel with radiation training are available at or near the site. j) Determine the radiation e x po.su r e. of personnel in-volved. k) De t e rmin e the dosimeter reading for each person in-volved. 1) D et e rmin e the nuclide and S/N of the source to estab-lish the field strength. _NO. _ _ TITL_E - - - - REVa @Ci@@ _ oe

u- - c. RADI ATION SAFETY PROGRAM m) If the condition is a Class A Incident, interrupt the reporting at this point to perform the notifications. n) Class A Incidents shall be reported immediately and Class B Incidents within 24 hours by telephone or tele-graph to the following person. Radiation Safety Director (RSD) U.S. Testing, Unitech Services Group 2506 Davis St. San Inandr', CA 94577 o (415) 562-7500 j o) Verify the source location is known or direct the loca-tion be determined by triangulation as explained in Ex-hibit 4 of the OGE P. p) birect the radiation area posting be corrected, if nec-essary, and high radiation area be posted. q) Determine what shielding is available which could be used to minimize exposure during recovery, r) Determine the need for' additional personnel and/or technical assistance during the planning stage and at the site. If extensive delays will occur, plan for continuous surveillance of the area. s) Determine the method of recovery-which will produce the minimum exposure to personnel, t) Review the radiation history of each trained person who is available. to assist in recovery. u) Establish a step-by-step procedure for recovery. Spe-cify on the written p(ro c e du re,the maximum all owa bl e time for each step Retreat Time) which will take place within the radiation or high radiation area. v) Calculate the personnel exposure for each step and de-termine the need for new film badges prior to recov-ery. ,'PAGE REV _ __ _T I_T L_E __ NO.

I u, ~ RADIATION SAFETY PROGRAM w) Review the procedure, in detail, with the pe r so n who will perform the recovery (Recoverer). . Assure the times are realistic. Any changes in times will re-quire recalculation of the exposure. x) Direct the Recoverer to write tne procedure verbatim as given by the RSO. Have the Recoverer read the pro-cedure to the RSO for proofing. y) The Recoverer shall assign a responsible person as Timekeeper. The RSO shall verify that the Timekeeper understands each step of the procedure and the impor-tance of the "Retrea t Time". z) The RSO shall maintain telephone contact throughout the recovery, if at all possible. aa) The procedure shall be followed exactly. The Timekeep- .er shall immediately notify the Recoverer if the Re-treat Time of a step has been reached. The Recoverer shall then immediately leave the. radiation area and re-i po rt to the RSO for further instructions. j bb) Upon elimination of the emergency, proceed with Post Emergency Action per Paragraph 3.4. 3.4 Post Emergency Action 3.4.1 Film badges of all personnel involved shall be processed on an expedited basis. Exposed ' personnel are barred f rom po-tential radiation exposure assignments until the results of the film badges are a va ila bl e and the employee is released by the RSO and approved by the RSD. 3.4.2 Equipment that may have been damaged during the. incident shall be removed f rom service until an inspection, mainte-nance and calibration (.i f required) has been performed to the satisf action of the RSO and RSD. 3.4.3 Proj e ct. Manager / Supervisor will obtain and implement formal corrective action for all radiation emergencies. 3.4.4 Prepare and submit to the RSD (copy RS0) a com report of all safety incidents within five (5) plete written working. days. NO. TITLE REV. PAGE UST - II OPERATING AND EMERGENCY SYSTEM PROCEDURE 985 9 of 12

( www RADIATION SAFETY PROGRAM 3.5 Personnel History Records 1 3.5.1 The RSD shall make a reasonable effort to obtain the previ-ous radiation history of each new employee. 3.5.2 The RSD shall originate, maintain and submit Form NRC-4 in-accordance with 10CFR20. 3.5.3 The RSD shall maintain individuals' accumulated whole bo dy dose records (comparable to hPC-5). 3.5.4 The RSD shall report to the Nuclear Regulatory Commission (NRC ) and to all terminated employees their accumulated whole body dose information during employment within 30 days after the exposure has been determined -(10CFR19 13c, 10CFR20.409). 3.5.5 The RSD shall submit an annual report to the NRC, stating the total number of persons monitored as required by 10CFR20.407. 3.6 Emergency Records - Complete records of radiation emergen-cies will be maintained by the RSD. 3.7 Posting Requirements 3.7.) The Project Manager / Supervisor shall be responsible for as-suring Form NRC-3 or Agreement State Notice to Employee, if applicable, is posted on the project. 3.7.2 The Project Manager / Supervisor shall be responsible for post-ing a " NOTICE" (conspicuously located) to comply with the requirements of 10CFR19 Paragraph 19.11 (b),10CFR21 Paragraph 21.6 (sample Paragraph 3.7.2.1) or Agreement States Rules and Regulations (sample Paragraph 3.7.2.2). 3.7.2.1 Sample NOTICE This notice is published to comply with the re-quirements of 10CFR19 Paragraph 19.11 and 10CFR21 Paragraph 21.6. 1 PAGE REV TITLE NO. ) 10 of 12 985-0 OPERATING AND EMERGENCY SYSTEM PROCEDURE UST - II J

==% i RADIATION SAFETY PROGRAM A COPY OF

10CFR19, 10CFR20,

10CFR21, U.S.

TESTING, UNITECH SERVICES GROUP'S RADI0 ACTIVE MA-TERIAL LICENSE AND OPERATING PROCEDURES ARE AVAIL-ABLE IN THIS OFFICE AND MAY BE EXAMINED BY CONTACT-ING THE PROJECT MANAGER / SUPERVISOR. 3.7.2.2 Sample NOTICE. This notice is published to comply with the re-quirements of Agreement States Rules and Regula-tions. A COPY OF THE AGREEMENT STATES RULES AND REGULA-TIONS, U.S. TESTING, UNITECH SERVICES GROUP RADIO-ACTIVE MATERIAL LICENSE AND OPERATING PROCEDURES ARE AVAILABLE IN TFIS OFFICE AND MAY BE EXAMINED BY CONTACTING THE PROJECT hMNAGER/ SUPERVISOR. 3.7.3 The Proj ect Manager / Supervisor shall be responsible for i posting a copy of Section 206 of the Energy Reorganization Act i of 1974. 3.7.4 The Project Manager / Supervisor shall be responsible for post-ing emergency phone numbers ("IN CASE OF EMERGENCY CALL").on the outside entrance (s) of facility as required. 4.0 SAFETY PROCEDURES - It should be.the aim of the Project Man-ager/ Supervisor to develop ways to reduce and/or eliminate incidents through training and. knowledge of the regulations. 4.1 It shall be the responsibility of the Project Manager / Super-visor to control, and have available for employees, the fol-lowing: 1 a) Radiation Safety Program; b) Radiation Safety Training Manual; c) NRC or Agreement States Regulations. l NO. TITLE REV. PAGE UST - II OPERATING AND EMERGENCY SYSTEM PROCEDURE 985-0 .11 of 12

( ~~~ RADIATION SAFETY PROGRAM I 5.0 EMPLOYEE INFORMATION 5.1 The Project Manager / Supervisor shall inform employees of their rights of access to records. 5.1.1 The Project Manager / Supervisor shall, upon request, assure the access of each employee to records relevant to the employee. 5.2 Monthly dosimetry reports (film badge reports) shall be made available to each employee by posting or other means. l ) PAGE REV TITLE NO. 12 of 12 985-0 OPERATING AND EMERGENCY SYSTEM PROCEDURE UST - II

1 s s. es Unitech Services Group RADIATION SAFETY PROGRAM PROCEDURE N0. III l OPERATING AND EMERGENCY PROCEDURES IN CASE OF RADIATION EMERGENCY l CONTACT PADIATION SAW DIRE"O3 (415) 562-7500 WESTEM RSO (415) 562-7500 EASTEM RSO (201) 792-2400 985-0 Original Issue TWC 09/30/85 REV!510.1 EFFECTIVE RO. DESCRIPT!CN BY DATE

i fj{l} ______e_. RADIATION SAFETY PROGRAM TABLE OF CONTENTS ]

1.0 INTRODUCTION

1 1 1.1 Scope of Your Authority 1 1 1.1.1 Radiographer Trainee 1 1.1.2 Assistant Radiographer 1 1.1.3 Radiographer 1 1.1.4 Monitor 1 1.1.5 Project Manager / Supervisor 2 1.1.6 Radiation Safety Of ficer 2 1.1.7 Radiation Safety Director (RSD) 2 2.0 QUARTERLY SAFETY hEETINGS/ REFRESHER TRAINING 2 3.0 PERSONNEL MONITORING 3 3.1 Dosimeter 3 3.2 Film Badge 4 3.3 Permissible Dose Levels 5 3.4 Survey Meter 5 3.5 Use of Monitoring Equipment 6 4.0 GETTING THE SOURCE TO THE JOB 6 4.1 Removal from Storage 6 4.2 Daily Equipment Inspection 6 4.3 Carrying the Exposure Device 6 5.0 CONTROLLING THE AREA 7 5.1 Responsibility of the Radiographer 7 5.2 Preliminary Control 7 6.0 SETTING UP THE EXPOSURE 7 6.1 Source Tube 7 6.2 Exposure Device Assembly 8 7.0 POSTING THE AREA 8 7.1 Final Control 8 l NO. TITLE REV. PAGE UST - III OPERATING AND EMERGENCY PROCEDURES 985-0 i of lii

f u- - w. RADIATION SAFETY PROGRAM 8.0 USE OF EXPOSURE DEVICE 9 9.0 STORAGE OF EXPOSURE DEVICES 12 10.0 USE OF X-RAY EQUIPMENT - FIELD 13 11.0 PERMANENT RADIOGRAPHIC INSTALLATION 13 12.0 COMPLETING THE RECORDS 15 l 13.0 RADIATION SAFETY RECORDS MAINTAINED ON PROJECT 15 14.0 TRANS PORTING THE SOURCE 16 1 14.1 Approved Vehicle 16 14.2 Approved Drivers 16 14.3 Preparation for Transport 16 14.4 Securing the Vehicle 17 14.5 Posting 17 14.6 Surveying 17 14.7 Overnight Stops 17 14.8 Key Control 18 15.0 HANDLING THE EMERGENCY 18 15.1 Introduction 18 15.2 Application 18 15.3 Responsibility 18 15.4 Emergency 18 15.5 Radiographer' Action 19 15.6 Personnel Involved 19 15.7 Equipment Involved 19 15.8 Locating a Lost Source Using Your Survey Me-20 ter 15.9 Violation 20 16.0 AGREEMENT STATES REQUIREMENTS 20 16.1 Instructions 20 16.2 Conflicts 20 17.0 INTERPRETATIONS 20 O.___ N PA_GE REV_ ._ TIT _LE _

([ )u- - ~ RADIATION SAFETY PROGRAM 18.0 INSPECTION AND MAINTENANCE PROCEDURE 21 18.1 Equipment 21 18.2 Maintenance / Calibration Label 21 18.3 Exposure Device 21 18.3.1 Daily Inspections 21 18.3.2 Field Maintenance 21 18.4 Special Inspection 21 18.5 Survey Instrument 21 18.6 Reject Tag 22 19.0 CONTROLLED DOCUMENTS 22 19.1 Appendices 22 20.0 DEFINITIONS 22 Byproduct Material 22 Curie (Ci) 22 Dosimeter 22 High Radiation Area 22 Radiation Signs 23 Radiographer 23 Assistant Radiographer 23 Radiographic Exposure Device 23 Radiography 23 Roentgen Equivalent Man (REM) 23 Restricted Area 23 Roentgen (R) 23 Sealed Source 24 Shielding Material 24 Storage or Shipping Container 24 Survey 24 Personal Supervision 24 21.0 FORMS 24 l l i NO. TITLE REV. PAGE UST - III OPERATING AND EMERGENCY PROCEDURES 985-0 iii of lii

( u~ % c RADIATION SAFETY PROGRAM l

1.0 INTRODUCTION

The Operating and Emergency Procedures (06E P) is your guide to safe operation when working with radio-l active sources. Have an 06E P available whenever you are using a source of radiation. The 06E P includes detailed ir.s t ru ct i o n on performing your job in a safe manner, the rules you must follow in your work and useful bits of reference information. I 1.1 Scope of Your Authority Federal' and/or Agreement State Regulations specify the tasks a person is allowed to per-form when working with radioactive sources. The complexity l of tasks allowed are based on the radiation safety training i and experience of the employee. The levels of training, ex-l perience and/or authority, as used by the Company, are iden-l tified as Radiographer Trainee, Assistant Radiographer, Ra-diographer, Monitor, P roj ec t Manager / Supervisor, Radiation Safety Officer (RS0) and Radiation Safety Director (RSD). 1.1.1 Radiographer Trainee A Radiographer Trainee is an employ-l ee who is in t raining for the position of Assistant Radio-grapher. During this period of training, the individual shall not act in the capacity of handling and/or using sources. 1.1.2 Assistant Radiographer An employee who uses radiographic exposure devices, sealed sources, x-ra y equipment, survey instruments and related equipment while under the personal (direct) supervision of a Radiographer. The Radiographer may not delegate his/her responsibility to the Assistant Ra-diographer. Any person who assists the Radiographer by ma-nipulating radiographic exposure devices, sealed sources, x-ray equipment, survey instruments and rela ted equipment, is acting as an Assistant Radiographer and mus t have be en certified to that level by the RSD. 1.1.3 Radiographer An employee who performs radiography or is in attendance a t the radiographic site to personally super-vise radiographic operations. The Radiographer is directly responsible for assuring the job is performed in accordance with the safety requirements of the OSE P. 1.1.4 Monitor Certified Radiographer with extensive experience and training in radiation safety who have been appointed (as required) to assist the Project Manager / Supervisor in maintaining a high standard of radiation safety. His job in-cludes training and qualifying all levels of radiation safety certifications. NO. TITLE REV. PAGE UST - III OPERATING AND EMERGENCY PROCEDURES 985-0 1 of 24

) - s RADIATION SAFETY PROGRAM 1.1.5 Proiect Manager / Supervisor - The administrative head of each p roj ect. On matters of radiation safety, reports to the RSO and then to the RSD. The Project Manager shall be held directly responsible for all safety on the project. 1.1.6 Radiation Safety Of ficer - (Management) Representative respon-sible for all phases of the Program in the absence of the RSD and will report directly to the RSD. The job shall include training and qualifying all levels of radiation safety. The RSO will be responsible to see that each Project Manager /Su-pervisor within the territory complies with all safety re-quirements. 1.1.7 Radiation Safety Director (RSD) - The member of the manage-ment team of the Company with full authority and responsi-bility to administer and enforce the Program. The RSD shall have the authority to stop radiographic activity until safety requirements have been satisfied and to discharge or suspend any individual who violates the rules and regulations in mat-ters relative to radiation safety. The RSD reports directly to the President or Vice President of the Company. 2.0 QUARTERLY SAFETY MEETINGS / REFRESHER TRAINING - Project Manag-ers/ Supervisor shall be responsible for insuring that re-fresher training for all Radiographer and Assistant Radio-graphers under their sup(ervision be conducted at intervals not to exceed quarterly. Safety meetings may be conducted at more frequent invervals.) 2.1 Such training shall include, but not be limited to the follow-ing items. a) Agreement States or Nuclear Regulatory Commisssion (NRC) Rules and Regulations, Parts 19, 20, 21 and 34 (latest revisions). b) Agreement States or NRC Radioactive Material License. c) Radiographic equipment and detection instrumentation to b= used. d) The Operating and Emergency Procedures. PAGE REV TITLE NO. 2 of 24 985-0 OPERATING AND EMERGENCY PROCEDURES UST - III

I u- ~ ~ i RADIATION SAFETY PROGRAM i i f e) Fundamentals of radiation safety. f) Prevention of overexposure to personnel. 1 g) NRC case histories. l h) Training in the transfer, packing and transport of radio-active material. 2.2 Project Managers / Supervisors shall maintain, available for I inspection, records of safety meetings /ref resher training, in-I cluding: i a) name(s) of instructor (s); j l b) names of individuals attending; c) dates and duration of training; l d) topicCs) discussed. 1 Your personal saf ety ' depends on the 3.0 PERSONNEL MONITORING use of radiation monitoring devices. Before working with a radioactive source, you must have available the following items: a) Radiation Safety Certification; b) Certification; c) Operating and Emergency Procedures / License; d) Dosimeter on person; e) Film Badge on person; f) Survey-Meter. 3.1 Dosimeter The dosimeter measures total a cc umula t e d dose from zero to at least 200 milliroentgen (mr). It can show you when your accumulated dose is abnormally high. Prior to each work shif t, zero (+ 5 mr; record actual reading) your dosineter using (the Dosimeter Charger. Record this 160a Exhibit 1), Form 160b (Exhibit 2) or reading on Form NO. TITLE REV. PAGE UST - III OPERATI.NG AND EMERGENCY PROCEDURES 985-0 3 of 24

] **"* " *~a \\ 4 RADIATION SAFETY PROGRAM / I Form 160c (Exhibit 3). Check your dosimeter frequently to assure you are operating in a safe manner. lihenever the reading is above 50 mr, record it on Form 160a, 160b or 160c, and recharge the dosimeter. A saturated (of f-scale) reading means danger stop work. immedia tely and contact your Project Manager / Supervisor. If your dosimeter is lost, stop work immediately.and contact your Proj ect Manager / Super-visor for a replacement..D0 NOT work without your dosimeter.. l 3.1.1 Dosimeter shall be calibrated yearly 'for correct response to radiation. 3.2 Film Badge Your monthly film badge. is the most accurate record of your total radiation exposure. 11ea r. i t on your belt or pants waist band. Do not let anyone wear your badge. The badge will be processed by a qualified ' film badge service and the exposure data reviewed by the RSO. DO NOT work without your film badge. The data shall in- -l clude: 3.2.1 Frequency of processing. 3.2.2 Sta rting date of badge use and processing date. i l 3.2.3 Reporting date. [ 3.2.4 Employee name, social security number and date of birth. 3.2.5 Current dose (MREM). l 3.2.6 Cumulative dose (MREM). 3.2.7 The badge should be stored with a control badge during-non-working hours at an authorized' location..Do not store your film badge in an area where accidental exposure could oc-cur. If your badge is. lost sto work immedia tely - and call your Proj ect Manager / Supervisor.pfor replacement. 3.2.8 Film badges lost or not returned by individuals shall be in-vestigated by the Proj ect Manager / Supervisor. A report shall-i be made as to the reason for the badge not -being returned. The. individual's corrective action for the prevention of re-currence shall be forwarded to the RSD. Individual's dosime-PAGE REV TITLE NO. l 4 of 24 985-0 OPERATING AND EMERGENCY PROCEDURES. UST - III l

( u- ~ %. l l RADIATION SAFETY PROGRAM ter readings for the period of use, taken from Form 160a, 160b or 160c, will be totaled and used for the exposure re-ceived during t ha t period. The dosimeter report will.be forwarded to the film processing facility in pla c e of the lost badge, with a copy to the RSD. 3.3 Permissible Dose Levels 3.3.1 An individual, 19 years of age or over, may receive a dose I to the whole body of three (3) REMS per calendar quarter provided that: I a) the Company has on file the individual's history of ac-cumulated occupational dose to the whole body, b) The individual's dose to the whole bo dy, when added to the previously accumulated dose to the whole

body, shall not exceed 5 (N-18) REM where "N" equals the indi-vidual's age in years at his last birthday.

3.3.2 Individuals may receive a dose to the whole body of only 1.250 REM per calendar quarter when the requi rements. o f l Paragraph 3.3.1 a re not met, i l 3.3.3 Indi vid ual s, who receive a dose in excess of three (3) REM or 1.250 REM per calendar quarter, when applicable, will be l notified of the amount of the exposure in writing by the RSD, who will require the individual to submit a written ex-planation of the circumstances of the overexposure. 3.3.4 Radiographic personnel should make every reasonable effort to maintain radiation exposures as low as is rea sona bl y achievable. 3.4 Survey Meter The survey meter measures the radiation field strength and shall have a range such that two. (2) MREM /hr. through one (1) R/hr. can be measured. Use this meter to: a) establish the isodose lines (perimeters); b) assure source is in full retracted (safe) position; c) assure source is in full expose position when using a collimator; (meter reading should fall off n o t i cea bl y as source enters collimator;) N0. TITLE REV. PAGE UST - III OPERATING AND EMERGENCY PROCEDURES 985-0 5 of 24.

)~~~ RADIATION SAFETY PROGRAM d) locate the source (see Exhibit 4); e) predict the accumulated dose for several ex po sur es ; check the survey meter each shift for normal function-ing and current calibration date; calibration is re-quired every 90 days; if functioning is abnormal or the date has expired, do not use the meter. Film badges and dosimeters 3.5 Use of Monitoring Equiment shall be used by anyone 18 years of age and over who is likely to receive a dose of 300 MREM pe r calendar quarter. A survey meter shall be used every time a person enters a " Radiation Area" or is required to work around a storage container or exposure device. 4.0 GETTING THE SOURCE TO THE JOB 4.1 Removal' from Storage Survey all surfaces of the storage container for abnormal radiation levels using the survey me-ter. Radiation levels of a storage container shall not ex-l ceed two (2) mr/hr. Unlock and open the container. Survey i the exposure device for abnormal radiation levels before re-moving it from the container. Remove the exposure device and survey the ext e rio r ci r c um f e r enc e. No exposure device shall have an exterior surface reading in excess of 200 mr/ hr. 4,2 Daily Ec uipment Inspection - The daily inspection of the ex-posure c:evice is f or your safety. Equipment, which is main-tained in good working order, seldom causes an emergency situation. Perform the daily inspection of the exposure de-vice by following the instructions and completing the Daily Inspection of Exposure Device, Form 16 0a (Exhibit 1) or Form 160b (Exhibit 2). 4.3 Carrying the E x po sur e Device The total time an ex po sur e device is hand-carried should be kept to a minimum. Remem-ber, the radiation level on the ex po sur e device's surface may be as high as 200 mr/hr. During hand-carrying, your legs can be ex po se d to this field. A good practice is to use a hand truck or cart whenever you are doing a lot of transporting. PAGE REV TITLE NO.

i ( ) umens om. ~ RADIATION SAFETY PROGRAM 5.0 CONTROLLING THE AREA 5.1 Responsibility of the Radiographer - The Radiographer is re-sponsible for establishing the controlled " Radiation" and "High Radiation" areas and assuring unauthorized personnel are not allowed to enter the restricted area. The Assis-ta nt Radiographer may perform these duties only under the personal supervision of the Radiographer. 5.2 Preliminary Control - Prior to setting up the exposure de-vice, the Radiographer will establish preliminary controls by conspicuously posting an area that will prevent anyone from entering and receiving, at the perimeter of these i areas, a dose in excess of two (2) mrem in any one (1) hcur, i The approximate perimeters of the radiographic area shall be established and po s te d with " Caution--Radiation Area" j signs by referring to the Radiation Intensities and Dis-l tance Charts (Exhibit 5). The approximate perimeter of the i High Radiation Area (100 mrem /hr. or more) will be calculated i from the Radiation Intensities and Distance Charts men-tioned above. Conspicuous posting of this area will be ac-j complished by using, " Caution--High Radiation Area" signs. " Caution--High Radiation Area" signs may not be used on the j perimeters of the " Radiation Area". These areas are de- ) fined in Paragraph 20 (Definitions) of this procedure. The I signs shall be the conventional magenta and yellow colors used to indicate radiation areas. It is recommended that perimeters be established us ing radiation barrier tape or rope (magenta or yellow colors). ) l 5.2.1 The Radiographer is responsible for clearing the restricted area of unauthorized personnel at the time the preliminary j control is established. i 1 6.0 SETTING UP THE EXPOSURE l Secure the source positioning tip in the de-i 6.1 Source Tube sired position and distance from the obj ec t to be radio-graphed. Attach one (1), two (2) or three (3) lengths of l ex device. Do 1 source tubes, as needed, to reach the (7)posure not use more than three (3), seven foot tubes. The source tubes should be laid out as straight as po s si ble, avoiding bends, particularly bends of sharp radius. Colli-mation shall be used whenever applicable. Secure the colli-1 mator to the source positioning tip. l NO. TITLE REV. PAGE ) UST - III OPERATING AND EMERGENCY PROCEDURES 985-0 7 of 24 ]

i ,m ([b '"""" ~ ~ RADIATION SAFETY PROGRAM { j { Unlock the control. Remove the 6.2 Exposure Device Assembly storage cover. Attach the control cable to.the source pig-tail. ~ Lock exposure device. Remove the safety plug. Con-nect the source tube to the exposure device. Unlock the de-vice and crank the control handle in the expose direction. to move the source out of the' exposure device through' the source tubes and into the source positioning tip. CAUTION: Undue pressure in either direction could damage the connec-tion and even release the source from the cable; therefore, it is important that you do not force the crank. If undue resistance is. encountered while moving the source into the exposure position, return the source to the exposure device and correct the cause of the resistance..D0 NOT' attempt to force the source beyond the resistance. If undue resis-tance is encountered, while returning the source to the expo-sure device, reverse the direction of the. cranking until the unit operates smoothly. If, after a few reversals, cranking is still difficult, or there is reason to believe the source is loose f rom the drive cable, po s t a guard and contact your Proj ect Manager / Supervisor. i 7.0 POSTING THE AREA 7.1 Final Control - Af ter the exposure device is readied for op-eration, the source is driven to the end of the source tube and a survey performed to establish the restricted area. Survey the perimeter of the area which was posted during the preliminary control and correct the positioning of the signs, as necessary, to reflect the two (2) mrem in any one (1) hour field and record on Form 160a. Surveys shall be required for each shif t and/or when the source-target con-figuration is substantially different from that of the pre-exposure. Survey meter readings in excess of two-ceding /hr. (2) mr are permissible at perimeters of the restricted area when the total exposure time during any one (1) hour is less than 60 minutes. Any One Hour (60 min.) Maximum Allowable Example: x 2 = Exposure Minutes mr/hr. The' maximum allowable mr/hr. at the perimeter of restricted area for a job requiring five (5) exposures of four (4) min-utes each would be figured as follows: __ _ITLE___ . _ NO. _ PA_GE_ REV T

u- ~ ~ RADIATION SAFETY PROGRAM 6 mr/hr. x 2 = 5x4 All signs shall be magenta or purple on yellow background and display the conventional three-bladed radiation safety l symbol. I i The Radiographer is responsible 8.0 USE OF EXPOSURE DEVICE for the safety of all personnel entering the restricted area. No one shall enter the area without the consent of the Radiographer for each specific entry. If any person j persists in entering the posted area, secure.the source un-til the person leaves. Report the problem to your Proj ect J Manager / Supervisor. Note: When you warn persons of the danger of radiation, state the f acts. Do not exaggerate. During an exposure, all personnel shall stay outside the re-stricted area and the Radiographer and Assistant Radiograph - i er (if used) shall act as guards. They must be alert at all times to prevent anyone f rom entering the area. 8.1 Upon completion of an exposure, the Radiographer must: re-turn the source to the radiographic exposure device by turn-ing the hand crank in the retract direction until a posi-tive stop is encountered. 8.2 Upon assuring yourself the source has been returned to the safe position, proceed toward the exposure device with a survey meter in hand, carefully examining the meter read-ings. ] 8.3 When reaching the exposure device, immediately survey the area where the source tube connects to the device and the entire circumference of the device shall be surveyed to see that the source has been retracted to the saf e position. If the. radiographic exposure device has a source guide j tube, the survey shall include the guide tube. 8.4 Upon assuring your sel f the source is _ in a saf e po sition, lock the exposure device. This procedure shall be con-ducted after each exposure. Note 1: When using (for an ex-- ample) INC's Model IR100 exposure : device, locking the NO. TITLE REV. PAGE UST - III OPERATING AND EMERGENCY PROCEDURES 985-0 9 of.24

( ) u- - % RADIATION SAFETY PROGRAM source in the safe position is accomplished by fully re-tracting (source) into the exposure device. This may be ob-served by the " pop-up" indicator. Note 2: When using (for an example) T/0 Model 660 e x po sur e device, locking the source in the safe position can be accomplished by rotating the s el e c't o r from the OPERATE position to the LOCK position and securing with the device's lock mechanism. 8.4.1 Radiographer and Assistant Radiographer shall be required to remove keys from all locked exposure devices except dur-ing authorized use or when under the direct surveillance of said individuals. 8.5 Upon completion of the scheduled radiographic operations in the established restricted area, the following procedure will be observed. a) Survey prior to locking the radiographic exposure device to assure the source is in the safe shielded position. Record the survey reading in the "OUT" column of the Ra-diation Safety Report (Form 160a). b) Lock the exposure device. c) Remove the source tube and insert the saf ety plug. d) Dismantle the se t-up and remove barricades, e) Return exposure device to the storage area (s) provided. 8.6 An exposure device that is not returned to the storage area, and will be left unattended, must be locked and physi-cally secured to prevent tampering or removal by unautho-rized personnel. The device left in this condition must be barricaded and posted to a two (2) mr/hr. level. 8.7 Cobalt-60 Device In Excess of 50 Curies - This paragraph pre-sents the steps that should be taken when using Cobalt-60 sources in excess of 50 curies at temporary jobsites. These requirements shall be in addition to those detailed in this procedure. 8.7.1 Project Manager / Supervisor should physically inspect the area where radiography is to take place. 8.7.2 Proj ect Manager / Supervisor should decide on location (s) for the exposure device and source tube positioning. PAGE REV TITLE NO. 10 of 24 985-0 OPERATING AND EMERGENCY PROCEDURES UST - III

l ) w~ w-- u-, i l I RADIATION SAFETY PROGRAM l l 4 8.7.3 Written or verbal request should be received and approval l given f rom the RSO/RSD prior to initiation of the radiographic 1 operation. l 8.7.4 Request shall contain the following information. a) Location of operation. b) Make, model and serial number (S/N) of exposure device. i c) Specific time period (date, time, of f-shif t, etc.). I d) Detailed diagram of proposed exposure area (s) showing: 1

1) placement of exposure device - taking consideration j

for maximum safe access in case of equipment malfunc-tion l

2) source tube positioning; I

3) co111mation;

4) additional shielding;

5) approximate perimeter lines and calculated dose i

ra te ;

6) calculated exposure time (s);

7) estimated number of exposures to be taken.

8.7.5 Records of such activities shall be maintained. 8.8 Agreement States Notification - States require licensees to notify the agercf, by phone and/or in writing, prior to engag-ing in unauthorized temporary radiographic operations within their state. Notification is for locations other than those specifically listed on state licenses or registrations for nonagreement states. Radiographer are required to contact the RSO or RSD, prior to engaging in temporary radiographic operation, who in turn will notify the proper agency. 8.8.1 The following information is required when notifying the RSO or RSD. NO. TITLE REV. PAGE UST - III OPERATING AND EMERGENCY PROCEDURES 985-0 11 of 24

{ ) u~ - ~ RADIATION SAFETY PROGRAM 8.8.1.1 Location of operation (state, city, company, etc.).. 8.8.1.2 Make, model and S/N of exposure device. 8.8.1.3 Specific time period (date, time, of f-shif t, etc.). 8.8.1.4 Individual (for the customer) who will be contacted. 8.8.2 Radiographer shall contact the RSO or RSD as soon as prac-tical so that the required notice, in writing, can be com-pleted and sent to the respective agency. 8.8.3 Radiographer are required to have a current copy of each of the following documents prior to engaging in temporary radiographic operations. 8.8.3.1 Respective Agreedent State License (if not licensed in the State, copy of our NRC and/or California license). 8.8.3.2 NRC or Agreement State Regulations, i f applicable. 8.8.3.3 Operating and Emergency Procedures. 9.0 STORAGE OF EXPOSURE DEVICES 9.1 When not in

use, radiographic exposure devices will be placed in the storage areas provided.

All storage areas 1 shall have a sign bearing the words, " CAUTION--RADIOACTIVE MATERIAL" with the radiation symbol (magenta on yellow back-ground). The sign shall be posted on the outside perimeter of the storage area. 9.2 A survey of the storage area containing the exposure de-vices shall be made on the outside perimeters and the read-ing shall not exceed two (2) mr/hr. 9.2.1 Survey of storage areas shall be made each. time an exposure device is removed or returned to storage. 9.2.1.1 Survey of field storage areas shall be made each time an ex-posure device (additional or new source) is adde.d. __PAGE,, REV TITLE NO.

i ( uaa a s c,.o RADIATION SAFETY PROGRAM 9.3 Storage areas shall be kept locked at all times, except j when in use. 9.4 In the event radiographic operations are being ' conducted at a distance remote f rom the permanent storage area provided for the exposure device, the vehicle transporting the de-vice may be used for storage by complying with Paragraphs 14.3, 14.4, 14.5, 14.6, 14.7 and 14.8 of this procedure. 10.0 USE OF X-RAY EQUIPMENT - FIELD 10.1 Safety procedures of this paragraph shall apply to-opera-tions with x-ray producing machines, where applicable. 10.1.1 Survey meters shall be used in the same manner as when uti-11 zing ' radioactive material. They shall be used to deter-mine that the x-ray unit is of f except in cases where..the main power source is disconnected. j 10.1.2 No x-ray unit shall be lef t unattended whereby unauthorized personnel could cause the unit to be energized, resulting in a hazard. The control panel and/or po we r cables shall be stored or locked if unit is to be left unattended. 10.1.3 It will be the Radiographer's responsibility to complete Ra-diation Safety Report Form 160c. Form 160c will have in-structions far ce,,pletion printed on the reverse side. 3 10.1.4 No individual shall operate an x-ray. machine until such in-dividual has received a copy of, instruction in and. demon-strates an understanding of, the operating procedures for said unit. 10.2 The X-Ray Equipment Procedure, although brief, does not re-lieve the Radiographer and/or Assistant Radiographer of any of the other detailed requirements of the 06E P, which' does not pertain directly to the operation or use of an exposure device. 11.0 PERMANENT RADIOGRAPHIC INSTALLATION ' - Safety procedures.of i this paragraph shall a pply to radiographic operations using pe rmanent installations (shielded radiation ex po sur e r ooms ). Requi rement s shall be in addition to those de-tailed in this procedure. l NO. TITLE REV. PAGE UST - III OPERATING AND EMERGENCY PROCEDURES 985-0. 13 o f 2 4

~~% RADIATION SAFETY PROGRAM 11.1 Exposure rooms shall be used only with those sources of ra-diation authorized by licenses and the RSD. 11.2 Sources of radiation to be exposed only in areas as autho-rized for each particular room. having s requirements (other than paragraph) pecial 11.3 Exposure

rooms, as required by the RSD, shall be listed in this complied with.

11.3.1 Those requirements shall be pos ted at the radiographic in-sta11ation. 11.3.2 The RSD shall maintain a ie,.cd of those special require-ments. 11.4 Exposure rooms shall be equipped with a visible and audible alarm signal. 11.4.1 Alarm shall be generated so that an individual attempting to enter the area would be aware of the hazard during an ex-posure. 11.4.2 Ala rm shall be generated so that the Radiographer would be aware of any unauthorized entry during an exposure. 11.4.3 Equipment inoperable shall be repaired or replaced immedi-ately. Note: Exposure rooms may be us e d until equipment is re-paired or replaced by complying with the field radio-graphy requirements of this procedure. 11.5 Exposure rooms shall have available, a functioning and cur-rently calibrated survey meter. 11.6 Exposure rooms shall be checked, prior to each exposure, to assure the area is cleared of personnel. 11.7 If an ex po sur e device is to be left unattended, the device shall be returned to the shielded and locked position. 11.8 Upon completion of the scheduled radiographic operation, or the Radiographer's shift, the exposure device shall be re-turned to the storage condition. 1 PAGE REV TITLE NO. 14 of 24 985-0 OPERATING AND EMERGENCY PROCEDURES UST - III

u- - w. l l l RADIATION SAFETY PROGRAM ) 11.9 Ex po sur e rooms, utilizing x-ray equipment, shall be inter-locked such that the unit will not operate unless all open-i ings are securely closed. l i 12.0 COMPLETING THE RECORDS 12.1 Records are your evidence of compliance with the procedures of the O6E P. 12.2 It shall be the Radiographer's responsibility to complete the following records. a) Radiation Safety Report - Fo rm 16 0a, Exhbit 1 (Field Ra-diography). Radiation Safety) Report Form 160b, Exhibit 2 (Labora-b) tory Radiography. Form 160c, Exhibit 3 (X-Ray c) Radiation Safet Field) y Report

Machine,

{ 12.3 Each f orm you use will have the instructions for. completion printed on the reverse side. These' instructions are self-i explanatory. Complete the record and distribute the copies per the instructions. Make sure your signature and the date l l are legible. 13.0 RADIATION SAFETY RECORDS MAINTAINED ON PROJECT l 13.1 The following copies of records shall be maintained on the project, which are necessary for ins by the Compa-ny, Agreement State or NRC auditor (s)pections a) Film Badge Reports. b)' Radiation Safety Reports (160a, 160b or 160c). c) Radiation Safety Program (Controlled Copy). d) NRC License and Agreement State License (when applica - ble), la test amendments. _ NO. __ _ITLE __ __ _______ ._PAGE1 T REV.

( --w RADIATION SAFETY PROGRAM e) Records of radiation safety meetings / refresher training subj ects and individuals attending. f) Quarterly Inventories (Form 507). g) Leak Test Certificate, if applicable, h) Survey Meter Calibration Certification. 1) Individual's Radiation Safety Certification. for current level held. j) Source Decay Charts. k) Exposure Device-Inspection - Quarterly.(Form 502a). 1) Radiation Safety Training Manual. m) Source Receipt, Transfer and Disposal Log. n) Radiographer List - Quarterly (California), o) Safety Audits (System, Facilities and Equipment / Person-nel). p) All required survey records. 13.2 Records for call-out jobs and proj ects, when less'than six (6) months duration (temporary location), shall be main-tained in the office of the RSO/RSD and/or on the jobsite where call-out is authorized. 14.0 TRANSPORTING THE SOURCE Vehicles, approved by the RSD, RSO or 14.1 Approved Vehicles Monitors, are the only vehicles to be used for transporting sealed sources. Approved

vehicles, carrying sealed-14.2 Approved Drivers sources, may be driven by Company employees with a current driver's license.

Packaging of exposure devices 14.3 Preparation for Transport and/or storage containers, containing radioactive material, shall be designed and selected to meet with all the~ require-PAGE REV TITLE NO. 16 of 24 985-0 OPERATING AND EMERGENCY ~ PROCEDURES UST - III

l u RADIATION SAFETY PROGRAM ments of the U. S. Department of Transportation (DOT), ex-cept when transported within the confines of the plant' or other authorized location of use. 14.3.1 Procedure for the packaging requirements of exposure de-vices and/or storage containers can be found in Procedure VI of this Program (Source Shipping / Receiving Instruction Procedure). i 14.3.2 Shipping containers / exposure devices shall be securely fas-I tened in vehicle to prevent shifting in transit. 14.3.2.1 Shipping containers / exposure devices shall be placed in the vehicle in such a manner to prevent unnecessary exposure to personnel. 14.4 Securing the Vehicle - Close and lock the door to.the stor-age area. This door must be kept locked until you arrive at the jobsite. 14.5 Posting Placard all four (4) sides of the vehicle - with signs reading, " Radioactive", if required. The radioactive placard must have the top. portion yellow with the symbol black. The lower portion. must be white with the inscrip-tion, " Radioactive", in black. Note: Requirements for.the placarding of vehicles is deter-mined by the transport index found in Procedure VI of this Program (Source Shipping / Receiving Instruc-tion Procedure). 14.6 Surveying Survey the exterior surfaces and passenger com-partment of the vehicle to ensure that the radiation levels-do not exceed 2 mr/hr at 18 inches from any exterior surface and 2 mr/hr in the passenger compartment. 14.7 Overnight Stops - A radiation emergency-could occur by: a) unauthorized persons tampering with your equipment; b) another vehicle striking your vehicle. The chances of these emergencies-occuring can be minimized. by considering the following guidelines when you park.

1) Make sure your vehicle is locked.

NO. TITLE REV. PAGE UST - III OPERATING AND EMERGENCY PROCEDURES 985-0 17 of 24

1 ) m-a RADIATION SAFETY PROGRAM

2) Park in a well lit area.

3) Do not park on streets carrying heavy traffic.

14.8 Key Control - The keys to the vehicle give you control 'over the. radioactive source during transport. Do not loan your keys to persons other than: a) Company Certified Radiographer or Examiner; b) another employee during the time you are pe r so nally with the vehicle. Note: .Do not hide a spare key in or around the vehi-cle. l 15.0 HANDLING THE EMERGENCY This procedure is your instruction for han-15.1 Introduction dling an emergency involving a radioactive source. Follow the "Four Key-Steps". The RSO/RSD will provide step-by-step-procedures for elimination of the emergency.. The obj ective is to minimize the radiation exposure of all personnel in-i volved. 15.2 Application - These instructions apply to all field and lab-ora tory operations. The Radiographer, who. has been assigned-15.3 Responsibility the equipment, is responsible for the emergency' action, j 15.4 Emergency - An emergency is a condition, or potential condi-tion, which may cause one (1) of the following. a) Overexposure, or potential overexposure, of.any person in excess'of the regulations. b) Mal funct ioni ng, damaged, stolen or missing survey in-strument. c) Malfunctioning, damaged, stolen'or missing ( osure de-vice. d) Vehicle accidents, fires or other relative situations. PAGE REV TITLE NO. 18 of 24 985-0 OPERATING AND. EMERGENCY PROCEDURES UST .III l

ve RADIATION SAPETY PROGRAM The above emergencies, or potential emergencies, will be handled using the relative steps listed in Pa ragraphs 15.5, 15.6, 15.7 and 15.8. 15.5 Radiographer' Action Follow the instructions linted be-1 low. l I "THE POUR KEY STEPS" Step 1 - Assure all personnel are clear of radiation area. Step 2 - Survey and post the area with " Caution--Radiation Area" signs. (Refer to Paragraph 7.0 of this pro-cedure, " Posting the Area"). In the event the sur-vey instrument is damaged or malfunctioning, the procedure described in Paragraph 5.2 (Preliminary Control) shall be followed and maintained. No one shall be allowed to enter this area until the loca-tion of the sealed source has been determined by the Radiographer. The safe position of. the sealed source shall be determined by securing. an operable survey instrument. Step 3 - Maintain surveillance of the area until you can be relieved by a re s ponsi bl e person. Empha si z e to your relief the importance of keeping all persons out of the posted area. Step 4 - Contact the Project Manager / Supervisor for further instructions. Supervisory personnel will then call the 24 hour telephone ' number (415) 562-7500 Addi-i tional telephone numbers are listed on cover sheet of this procedure. DO NOT PROCEED WITHOUT SPECIFIC INSTRUCTIONS FROM THE RSO/RSD. The RSO/RSD will ask-questions about the emergency to determine the safest method of correction. Carefully follow RSO's/RSD's instructions. 15.6 Personnel Involved Personnel involved in the eme rge nc y are barred from further work with or around radioactive sources until released by the RSD. 15.7 Equipment Involved - Equipment, which may have been damaged as a result of the emergency, shall not be used until re-leased by the RSD. NO. TITLE REV. PAGE UST - III OPERATING AND EMERGENCY PROCEDURES 985-0 19 of 24

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RADIATION SAFETY PROGRAM 15.8 Locating a Lost Source Using Ye ir Survey Meter In the event a source should become lost, imm edia t el y secure the suspected ' area of the loss by ba rricades, ropes and/or guards to prevent overexposure to personnel and proceed with the technique for locating a lost source as described in Exhibit 4. 15.9 Any i n di vi d ual, who believes that a violation of Company, Federal and/or State regulations has occurred or could pos-sibly occur, should notify the RSO or RSD of the alleged vio-lation. 16.0 AGREEMENT STATES REQUIREMENTS - Agreement States are those i states that have accepted the responsibility from the NRC fo r control of radioactive material within their bound-aries. The regulations governing radioactive ma terial with-in each agreement state parallel very closely to the regula-tions of the NRC. They do impose some additional require-ments,'however, and each Radiographer shall be required to be familiar with these additional requirements. 16.1 Instructions Each Radiographer and Assistant Radiographer shall have available copies of the Agreement States require-i ments for the pa r ti c ula r state in which the are working, and when applicable, Agreement Sta tes License.y 16.2 Conflicts When the. Agreement States and 06E P conflict, the most stringent requirement shall apply. If you are not j sure which one to follow, contact the RSO/RSD. 17.0 INTERPRETATIONS 17.1 Except as specifically authorized by the RSD in writing, no l interpretation of the meaning of U.S. Testing, Unitech Ser-1 vices Group procedures by radiographic personnel will be recognized to be binding on the requirements. 17.2 The RSO/RSD shall be responsible to provide meaningful inter-pretation of procedures based on State and/or Federal Regula-tions. i I 17.3 Conflicts on interpretation of regulations will be resolved { by the Executive Safety Committee. I I S _PAGE _EV NO. R TITLE ~

i l I unn en s m omo RADIATION SAFETY PROGRAM Inspection and Main-j 18.0 INSPECTION AND MAINTENANCE PROCEDURE tenance Procedures are the daily actions taken by a Radio-J grapher to assure his equipment is in good working order. 18.1 Equipment shall be maintained in good condition by' periodic inspection, testing, calibration and maintenance. 18.2 A maintenance / calibration label, when applicable, shall be placed on equipment to identify the date for the next ser-vicing / calibration. 18.3 Exposure Device 18.3.1 Daily Inspections shall be conducted by the Radiographer in the field per the instructions of Form 160a (Exhibit 1) or by the Radiographer in the laboratory per the instructions of Form 160b (Exhibit 2). 18.3.2 Field Maintenance a) Servicing of the equipment, to correct minor deficien-cies uncovered by the inspection, may be performed by the Project Manager except when abnormally hi gh radia-j tion levels are involved. b) Unit s which show abnormal radiation levels ~shall be im - mediately removed f rom service and the Project Manager shall be contacted. Inspection shall be conducted whenever 18.4 Special Inspection equipment is malfunctioning or has been subj ected to severe damage or stress, such as dropping or submersion in water, etc. Exposure devices involved in emergencies shall be in-spected per the instructions of the RSO/RSD. The report shall be identified "Special Inspection" and include a descrip-tion of the abnormal situation encountered. 18.5 Survey Instrument a) Inspect the survey instrument at the beginning of. each shift for normal functioning and current calibration date. b) Calibration is required each 90 days. l 1 NO. TITLE REV. PAGE UST - III OPERATING AND EMERGENCY PROCEDURES 985-0 21 of 24 l

~~* \\ RADIATION SAFETY PROGRAM Note: DO NOT use survey instruments with expired cali-bration da tes. 18.6 Reject Tag Any equipment found to be inoperable and/or out of calibration shall have a rej ect tag affixed and shall be removed f rom service. 19.0 CONTROLLED DOCUMENTS 19.1 Appendices ) A. NRC License B. 10CFR19 C. 10CFR20 D. 10CFR21 E. 10CFR34 F. Agreement State License (if applicable) 20.0 DEFINITIONS _ Byproduct Material Any radioactive material, except sgqial nuclear ma terial, yielded in, or made radioactive by exposure to radiation incident to the process of produc-ing or utill: lng special nuclear material, for example, Co-balt-60 and Iridium-192. Curie (C1) The unit of activity for measuring the quantity of radioactive material. -One 10(1) Ci is that amount of material which yields 3.7 X 10 disintegrations per s econd, or the activity approximately equivalent to that of one (1) gram of radium. Dosimeter A device for measuring the amount of expo-sure to ionizing radiation received by an individual. High Radiation Area Any area accessible to personnel in which there exists radiation at such levels that a major-portion of the body could receive, in any one (1) hour, a dose in excess of 100 mr. f PAGE-REV TITLE NO. 22 of 24 985-0 OPERATING AND EMERGENCY PROCEDURES UST - III

g _. 4 RADIATION SAFETY PROGRAM l i Radiation Signs - Signs which warn of the presence of l ionizing radiation or material that emits radiation. They display the conventional t h re e-bl ad e d radiation symbol in I 1 magenta, or purple, on a yellow background. I Radiographer - Any individual who performs, or who is in attendance at the site and personally supervises radio-l graphic testing operations, and who is responsible to the licensee for assuring compliance with the requirements of NRC Regulations, Regulations of Agreement Sta tes, the condi-tions of the license and these procedures. Any individual who, under the Assistant Radiographer personal supervision of a Radiographer, uses exposure de-vices or survey instruments in radiography. Radiographic Exposure Device - Any device containing a radiographic sealed source fastened therein, in which radio-graphic sealed source, or shielding thereof, may be moved or otherwise changed from a shielded to an unshielded posi-tion, with respect to the source, for purpose of making a radiographic exposure. Sealed sources may also be trans-po rt e d in these devices when appropriate conditions are met. Radiography The nondestructive testing of materials by the production of an image on a radiation-sensitive sur-face, such as a photographic film, by the use of sealed sources containing radioactive material, or a beam of x-j rays. ) Roentgen Equivalent Man (REM) - A REM is a measure of dose of any ionizing radiation to body tissue relative to i the estimated biological effect of exposure of one (1) R of x-ray. For the purpose of this procedure, one (1) " REM" and one "R" are identical for the reason that the sealed sources utilized in industrial radiography do not emit Al-pha or Beta radiation outside of the stainless steel cap-l sule. Restricted Area Any area acces s which is controlled for the purpose of protection of individuals from exposure to radiation. Roentgen (R) - A Roentgen is a measure of the ionizing radiation in the air produced by x or gamma radiation. NO. TITLE REV. PAGE j UST - III OPERATING AND EMERGENCY PROCEDURES 985-0 23 of 24 )

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1 RADIATION SAFETY PROGRAM i i Sealed Source - Any radioactive material that is en-q cased in a capsule designed to prevent leakage or escape of the radioactive ma terial. Shielding Material - Any material used to absorb radia-tion, and thereby, reduce its amount of intensity. Storage or Shipping Container - A shielded device in which sealed sources are placed for storage or transporta-tion. Survey - The measurement and recording of radiation in-tensities at various locations i an area where ioni zing ra-diation exists. Personal Supervision of a Assistant Radiographer by a Radiographer means supervision in which the Radiographer is physically present at the site where sealed sources are be-ing used and watching the Assistant when the Assistant uses j radiographic exposure devices, sealed sources or related j source bandling tools, or radiation survey instruments in i radiography. i 21.0 FORMS EXHIBIT FORM NO. NO. 1 Radiation Safety Report (Field) 160a 2 Radiation Safety Report (Labora-160b tory) 3 Radiation Safety Report (X-Ray Ma-160c chines) 4 Lo ca t in g a Lost Source Using 516 the Survey Meter 5 Radiation Intensities and Dis-tance Charts 6 Iridium-192 Decay Factors PAGE REV TITLE NO. 24 of 24 935-0 OPERATING AND EMERGENCY PROCEDURES UST - III

1 I l 1 j u,=.c s-G I J EXHIBIT 1 ) l l l ) I l 1 RADIATION SAFETY REPORT FACUTY (JOBSITE) WEEK ENDNG UTILIZATION ANO DOSIMETER LCO EXPOSURE otviCE MAKE MODEL S/N 9 R ADIOGR APHE R II) $URFACE SURVEY METE R ASSl3 TANT RADIOG R APH E R (2) DOSIM ETE R DATE LOCATION MR/HR DEVICE MODEL/SN TR AINEi R ADIOG R APNE R 131 IN OUT IN CUT $UN IN (t) (2) i OUT (3) i MON IN (tl l l 121 l OUT 13) i TUE IN (1) l (2) OUT 131 WEQ IN (11 (2) l OUT (31 TMU IN (1) (2) OUT (3) F Ri IN (f) (2) OUT 13) SAT IN (1) (2) OUT f31 I PHY31 CAL RADIATION SURVEY DOSE R ATE - OISTANCE - SMtELDING $UN MON TUE WED THU FR1 SAT SUN MON TUE WED THU FRt SAT MR MR pa R HR FT FT g y SC SC 4 4 SC SC SC = 5HIEL0iNG CCDE: W TUNGSTEN Fe=5ffEL C = CONCRETE PheLEAD QTHER DAILY INSPECTION OF EXPOSURE DEVICE SUN MON TUE WED THU FRI SAT EXPO $UR E DEVICE -Lect, Fitting - Laces - P%g - inresos - etc. CR ANK ASSEMBLY - Loose Maraware - Freedom of Movement - etc. SOURCE TUSE - Threms - Ciear Openings - L oow Fitting - etc. drive CABLES & SOURCE CONNECTOR - Eneewwe Wes. - Good Fst - etc RADIOGRAPHER 40848 the elsede

IIJSTIi J ilONS I 1 This form (Form 160a) Radiation Gafety Hi.r (Fieia) ;s desqnuo to fulfill NRC and Agreement State regulation f requirements in Radiation Safety. Th,s for clienad toward the exposure device, i.e., one form will 4 be used for one device for one week. On the days the svice is not used, tne words NOT USED will be entered in the " Location" column in the Utilization Log. When oroperly fdled out, it will fulfill the requirements mentioneo above. UTILIZATION AND DOSIMETER LOG 1 Make, Model, and S/N of Exposure De.> ice wil! be entered in saaces provided. 3 Enter the date the device is used in "Date" cclumn corresoondir.g to the days of the week. The name of the site where the dev.ce is used wi!! be entereu in the " Location" column except, on those days, when the device is not used, the wonis NOT USED will be enteied. " Surface MR/HR Device" When the requirements of paragraph 4.1 of the Operating and Emergency Procedures (Survey i removal from storage) have been complied with enter the survey n.eter reading obtained in the g' column. When the requirements of Paragraph 8.5 a) of the operating and Emergency Procedures (last survey prior to locking device at completion of radiographic operations) have been complied with enter in the "OUT" colurnn the reading obtained f rnm the survey meter. The radiographer, the assistant rac;iographer, arc Trainev R6diographer, if app licable will record their names in the column " Radiographer (1) Asst. Radiographer (2) Trainee (3)" and the dosimeter reading of each, prior to the work shift, in the column " Dosimeter IN". The cosimeter readirig at the conclusion of the work shift in the column " Dosimeter OUT" Whenever the readirig is above 50 mr. record the reacing in the additional spaces ! provided. PHYSICAL RADIATION SUPVEY The location of tne source is the raciauon s ritooi. " MR "is the reading on the survey n cler at the penmeter i.f the restr!cted area. "FT" is the number of feet frcm the source to the perimeter or the resuicted area. "SC" is the shieldino material used wnen apalicable. These three entries are always made in all tour duections as required by paragrapn 5.2 ana paragraoh 7 of the Operating and Emergency Procedures. DAILY INSPECTION OF EXPOSURE DEVICE Prior to removal from the storage a 'ea. an insaection of the e::cc';urt device will be accomplished by complet-ing the checklist provided. Any damaged equipment will be repaired or replaced before using. The radiographer making the inspection will sign his name in the colutnn provideo. Distribution: Original RSO Copy Rett.inea by P.oiect I.iana;;er Note: Form 160a to be niaile.i m (rE's whee, no wua two u m Y. nmo" at toe loilomny week. (

b ,m ( aE 8 \\sN 1 s i 4 EXHIBIT 2 e i RADIAT10N SAFETY REPORT LA3CRATCRY T AO:L:""Y WEEK E::CIiG (3AT) UT:L:n? er Aro 00s;*r?!? Laa i I ZXPCSURI OtV:02: MAKI MCOEL s '. aH.... E. "U P' J n,, f. '"f SURVEY METER DC5!METI; (RCCM NC.) J CA?! L OC? !"'t 00:0!?0? CF !!V'0! wC* C, f 1'r PA0 !c 07).pt E P cy i I I I 6 l t F l l 0A*LY *:f 5P!M:0'! cr ZXPC$rp2 p;c=4 g =J rr/*~3 EXPCSUPI ROCM EXPC5'lRZ OEV 02 CRA,7 A33EM3LY $CURCO ?J323 CPERA. RA :A7:C;T gCCR AVOI3;t

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INSTRUCTIONS This forn (Farm 1606) Radiation Safety Report (Laboratory) is designed to fulfill AEC and Agreemont S tate regulation requirements in Rad;ation Safety. This form is oriented towarc the exposure device, i.e., one form will be used for one device for one ween. On the days the device is not used, the words NOT USEO will be entered in the " Location" column in the Utilization Log. When properly filled out, it will fulfill the requirements mentioned above. UT!*.::AT! N A:a ;cS:M.E?ta Lc0 Make, Model, and S/N of Exposure Device will be entered in spaces provided. Enter the date the device is used in "Date" column corresponding to the days of the week. Numcer of the room in which the device is used will be entered in the "Lecation" column excep on those days wnen the device is not used, the words NOT USEL will be entored. '4 hen the requirements of paragrapn 7.5d of the Operating and Emergency Procedures have been i compliec witn, the word 'Yes" will te entered in the " Source in Shielded Conditicn" column and the readings of tne survey will be entered in "MR/HR Cn Surface of Device" column. The mocel and S/N of the survey neter used durAng the radiographic operation will be entered in the column "Surve'/ Meter". radiographer wt11 record nis name in the column "Radiograpr.er" and the dosimeter reading l The c: eacn, prior to the wor < shif t, in the column "Dosameter IN*. The dosimeter reading at the cony clusion of tne work snift in the column "Oortmeter CUT".

x:r. NS7tericN er sxrcSURt :Ev:cE Fr:ar to ra ;ographic operation, an inspection of the exposure room and device will be accoma p1;s.ec r/ :ompleting the checklist provided. Any damage: equipment will be repaired or replaced before usana. The radatgrapner maning the inspection will be the sane individual sho's name is recorded an :ne utlizzati:n leg space "Radt:grapher" for that day.

" Radiation Levels at Access

sor, etter tne reacing Octained fr:m the survey mor.er.

"MR/HR On Surface of Oevice", enter the. resa;ng ottaine: fr:m tne survey.eter as requireJ vf paragraph 3.1 of the Operating and Irergency Prece:ures. - ;str;cuta:n: -r ginal R30 C;;y F.etained :y Prt]ect Manager Sote: 7:r* .t b :: ce Nat.ec in >R30's rff; e! ne later than tnt "uesday of the following wec<.

I l - O,.,um.cns.,v=ame l f \\ } EXHIBIT 3 ~ RADIATION SAFETY REPORT X RAY PRODUCING MACHINES - FIELD ., CILITY U083178) WEEK (NOING UTILIZATION ANO DOSIMETER LOG m AoioCm Apwic otvect MAK8 MODEL $1h l LeCArioN o, oesn ATieu lserviskal suavev Matin .Aosoon A, wen ti, j oosiM Tin oars I suavt y i MoogL i s, N ASST. R AOiOG R APME R 121 6 IN iOUT l l l l til l i l l 1 l lm i i aow m i I j l l I I I I m I i l Im I i l Im i I

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LINGTM 08 MA PER $(Tur i LONGEST EXPOSURE I j SETUP } setup l Situp j j j CONTROL l7033 CASLES l No.1 l No. 2 I NO. 3 ($ETUP i5ttup lStTUp RA0loGRAPHtR M'I I W*I lM3 I NO., KV MA s No, i KV t M A I NO. 6 x y i MA sum I I I i i i l i l I 8 I l j i i t i t i I l I I i i l l Nf f f 4 l l f i l l 1 I l l e

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INSTRUCTIONS This form (Form 160c) Radiation Safety Report (X. Ray Producing Machines - Field)is designed to fulfill Agreement State regulation requirements in Radiation Safety. This form is oriented toward the Radiographic device,i.e., one form will be used for one device for one week. On the days the device is not used, the words NOT USED will be entered in the ' Location of Operation' column in the Utilization Log. When properly filled out,it will fulfill the requirements mentioned above. UTILIZATION AND DOSIMETER LOG Make, Model, and S/N of Radiographic Device will be entered in spaces provided. Enter the date the device is used in 'Date' column corresponding to the days of the week. The name of the nte (area not jobsite) where the device is used will be entered in the ' Location of Operation' column r except, on those days when the device is not used, the words NOT USED will be entered. Number of setups per radiation survey will be entered in space provided. The number of setups will be the number completed without a change in the physical radiation survey dose rate, if a change in the radiation survey dose rate occurs, an additional report is to be completed for that day. If more than three (3) setups per survey are conducted, an additional report will be required. The model and S/N of the survey meter used during the radiographic operation will be entered in the column ' Survey Meter'. The radiographer and the assistant radiographer,if applicable, will record their names in the column ' Radiographer (1) Asst. Radiographer (2)' and the dosimeter reading of each, prior to the work shift,in the column ' Dosimeter IN'. The dosimeter reading at the conclusion of the work shift in the column ' Dosimeter OUT'. PHYSICAL RADIATION SyRVEY The location of the source is the radiation symbol. ,M R, HR is the reading on the survey meter at the perimeter of the restricted area. ' F T* is the number of feet from the source to the perimeter of the restricted area. 'S C' is the shielding material used when applicable. These three entries are always made in all four directions as required by paragraph 4.2 and section 6 of the Operating and Emergency Procedures. Method of Controlling Area will be completed by an X in the applicable box or boxes. If other is to be used, describe. All area survey reports must be completed at the time the survey is made - not at the end of the day's shif t. I l i l DAILY INSPECTION / EXPOSURE INFORMATION i l Prior to removal from the storage area, an inspection of the Radiographic device will be accomplished by completing the l checklist provided. Any damaged equipment will be repaired or replaced before using. Number of Exposures Per Setup - will be the total number of exposures taken using the same setup. Length of Longest Exposure - will be the longest exposure time used for the same setup. If more than three (3) setups per survey are conducted, an additional report will be required. The radiographer completing the inspection / exposure information will sign his name in the column provided. Distribution: Original RSO Copy Retained by Project Manager Note: Form 160c to be mailed in (RSO's office) no later than the Tuesday of the following week.

l ) u- - % l EXHIBIT 4 j LOCATING A LOST SOURCE USING THE SURVEY METER gg Decreasing Maximum Decreasing (k s 900 / N / \\ / I \\ / \\ / \\ / 1 N / %m N / ow \\ / 8 N / = N / I N / Lost Source 900 \\ l N \\ \\ N \\ .5 N i Restricted Area \\ 8 N N i N j Radiation Area Perimeter l I g I a 1 1. Survey the area in two (2) straight paths that are 900 to each ] other. 1 3 1 2. Identify the location of maximum reading on each path. I 1 3. Visually project a line at 900 to each path. The intersec-tion of the projected lines will be the source location. Re-l member, these paths lead into the high radiation area. ] I Form 516

EXHIBIT 5 Radiation Intensities at Various v~ ~ an, Distances from Unshielded Source Iridium-192 Exposure Distance Exposure Distance Time From Time From In Perimeter In Perimeter Any of Any of One Restricted ar/hr. One Restricted ar/hr. Hour Area Level Hour Area Level 20 Curies Strength 30 Curies Strength 60 min. 245 ft. 2 mr/hr. 60 min. 300 ft. 2 mr/hr. 30 min. 170 ft. 4 mr/hr. 30 min. 210 ft. 4 mr/hr. 10 min. 100 ft. 12 mr/hr. 10 min. 120 ft. 12 mr/hr. 5 min. 70 ft. 24 mr/hr. 5 min. 85 ft. 24 mr/hr. 1 min. 30 ft. 120 mr/hr. I min. 40 ft. 120 mr/hr. 40 Curies Strength 50 Curies Strength 60 min. 360 ft. 2 mr/hr. 60 min. 395 ft. 2 mr/hr. 30 min. 250 ft. 4 mr/hr. 30 min. 280 ft. 4 mr/hr. 10 min. 140 ft. 12 mr/hr. 10 min. 160 ft. 12 mr/hr. 5 min. 100 ft. 24 mr/hr. 5 min. 115 ft. 24 mr/hr. i 1 min. 45 ft. 120 mr/hr 1 min. 50 ft. 120 mr/hr. l I 60 Curies Strength 70 Curies Strength l 60 min. 430 ft. 2 mr/hr. 50 min. 460 ft. 2 mr/hr. 30 min. 305 ft. 4 mr/hr. 30 min. 325 ft. 4 mr/hr. 10 min. 175 ft. 12 mr/hr. 10 min. 190 ft. 12 mr/hr. 5 min. 125 ft. 24 mr/hr. 5 min. 135 ft. 24 mr/hr. I min. 55 ft. 120 mr/hr. I min. 60 ft. 120 mr/hr. 80 Curies Strength 90 Curies Strength 60 min. 495 ft. 2 mr/hr. 60 min. 525 ft. 2 mr/hr. 30 min. 350 ft. 4 mr/hr. 30 min. 370 ft. .4 mr/hr. 10 min. 200 ft. 12 mr/hr. 10 min. 215 ft. 12 mr/hr. 5 min. 145 ft. 24 mr/hr. 5 min. 155 ft. 24 mr/hr. 1 min. 65 ft. 120 mr/hr. 1 min. 68 ft. 120 mr/hr. l 100 Curies Strength , Intensities of Iridium -192 60 min. 555 ft. 2 mr/hr. 30 min. 390 ft. 4 mr/hr. 10 min. 230 ft. 12 mr/hr. 5 min. 160 ft. 24 mr/hr. 5.90 R/hr. from 1 curie at I ft. I min. 72 ft. 120 mr/hr. .55 R/hr. from 1 curie at 1 meter Half and Tenth Value Thickness (Inches) Ir192 Co'60 Lead - Half .19 .49 - Tenth .64 1.62 Steel - Half .53 .87 - Tenth 1.8 2.90 Concrete - Half 1.9 2.7 - Tenth 6.2 9.0 Tungsten - Half .12 .31 - Tenth .40 1.04 Ha'If value thicknesses reduce radiation to 1/2-Tenth value thickness. Reduce radiation to 1/10.

( -~ EXHIBIT 5 (CONT'D.) Radiation Intensities at Various Distances from Unshielded Source Cobalt-60 Exposure Distance Exposure Distance Time From Time From In Perimeter In Perimeter Any of Any of One Restricted ar/hr. One Restricted mr/hr. Hour Area Level Hour Area Level 5 Curies Strength 10 Curies Strength 60 min. 190 ft. 2 mr/hr. 60 min. 270 ft. 2 mr/hr. 30 min. 135 ft. 4 mr/hr. 30 min. 190 ft. 4 mr/hr. 10 min. 80 ft. 12 mr/hr. 10 min. 110 ft. 12 mr/hr. 5 min. 60 ft. 24 mr/hr. 5 min. 80 ft. 24 mr/hr.l 1 min. 25 ft. 120 mr/hr. 1 min. 35 ft. 120 mr/hr. 20 Curies Strength 30 Curies Strength 60 min. 385 ft. 2 mr/hr. 60 min. 470 ft. 2 mr/hr., 30 min. 270 ft. 4 mr/hr. 30 min. 330 ft. 4 mr/hr.' 10 min. 160 ft. 12 mr/hr. 10 min. 190 ft. 12 mr/hr. 5 min. 110 ft. 24 mr/hr. 5 min. 135 ft. 24 mr/hr.I 1 min. 50 ft. 120 mr/hr. 1 min. 65 ft. 120 mr/hr..! 50 Curies Strength Intensities of Cobalt-60 60 min. 605 ft. 2 mr/hr. 30 min. 430 ft. 4 mr/hr. 10 min. 250 ft. 12 mr/hr. 5 min. 175 ft. 24 mr/hr. 14.50 R/hr. from 1 curie at 1 ft. I min. 80 ft. 120 mr/hr. 1.35 R/hr. from 1 curie at 1 meter Radiation Intensities at Various Distance from Unshielded Source Distance From M111iroentgens Per Hour Per Curles Source (Feet) Co60 Ir192 1 14,500 5,900 5 580 236 10 145 59 15 65 26 20 36 15 25 23 9 30 .16 6.5

i v= wa-m-3 i EXHIBIT 6 Iridium-192 Decay Factors Factor - 0.0093203 (1 day) Tg = 74.37 days Days 0 1 2 3 4 5 6 7 8 9 l 1 0 1.000 .9907 .9815 .9724 .9634 .9545 .9456 .9368 .9281 .9195 10 .9110 .9026 .8942 .8859 .8777 .8695 .8615 .8535 .8455 .8377 20 .8299 .8222 .8146 .8070 .7996 .7921 .7848 .7775 .7703 .7632 30 .7561 .7491 .7421 .7352 .7284 .7217 .7150 .7083 .7018 .6952 40 .6888 .6824 .6761 .6698 .6636 .6574 .6513 .6453 .6393 .6334 ) 50 .6275 .6217 .6159 .6102 .6045 .5989 .5934 .5879 .5824 .5770 ] 60 .5716 .5663 .5611 .5559 .5507 .5456 .5406 .5355 .5306 .5257 70 .5208 .5160 .5112 .5064 .5017 .4971 .4925 .4879 .4834 .4789 80 .4744 .4700 .4657 .4613 .4571 .4528 .4486 .4445 .4403 .4363 90 .4322 .4282 .4242 .4203 .4164 .4125 .4087 .4049 .4012 .3974 l 100 .3937 .3901 .3865 .3829 .3793 .3758 .3723 .3689 .3655 .3621 110 .3587 .3554 .3521 .3488 .3456 .3424 .3392 .3360 .3329 .3298 120 .3268 .3238 .3207 .3178 .3148 .3119 .3090 .3061 .3033 .3005 t 130 .2977 l.2949 .2922 .2895 .2868 .2841 .2815 .2789 .2763 .2738 140 . 2712 l. 2687 .2662 .2637 .2613 .2589 .2565 .2541 .2517 .2494 150 .2471 .2448 .2435 .2403 .2380 .2358 .2336 .2315 .2293 .2272 160 .2251 .2230 .2209 .2189 .2169 .2148 .2128 .2109 .2089 .2070 170 .2051 .2032 .2013 .1994 .1976 .1957 .1939 .1921 .1903 .1886 180 .1868 .1851 .1834 .1816 .1800 .1783 .1766 .1750 .1734 .1718 ,190 .1702 .1686 .1670 .1655 .1640 .1624 .1609 .1594 .1580 .1565 I I I EXAMPLE: You have a source which originally was 105 curies on April 30, 4 1982. Determine the age, in days, of the source (33 days as of June 2, 1982). Find the decay factor for 33 days on the chart (.7352). Multiply the original (105) curies times the decay factor (.7352). The answer (77.196) is the number of curies for the source on June 2, 1982. -____-______ _ _ _ _ a

= :_ azaxx.t. e ?. - a ,e. y. e v.w;-:en.m x g-s-M M m m,5 p m y y g-wggy3y g y,, %RC Form 374 1 80 } f U.S. NUCLEAR REGULATORY COMMISSION PAGE OF PAGES MATERIALS LICENSE Amendment No. 3 Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974 (Public Law 93-438), and Title 10, Code of Federal Regulations, Chapter 1, Parts 30,31,32,33,34,35,40 and 70, and in reliance on statements and representations heretofore made by the licensee, a license is hereby issued authorizing the licensee to receive, acquire, possess, and transfer byproduct, cource, and specir.1 nuclear material designated below; to use such material for the purpose (s) and at the place (s) designated below; to i deliver or transfer such material to persons authorized to receive it in accordance with the regulations of the applicable Part(s). This Dicense shall be deemed to contain the conditions specified in Section 183 of the Atomic Energy Act of 1954, as amended, and is subject to all applicable rules, regulations and orders of the Nuclear Regulatory Commission now or hereafter in effect and to any sonditions specified below. accordance with letter Jated August 14, 1987 5-United States Testing Company, Inc.

3. License number 04-23240-01 is amended in Unitech Services Broup its entirety to' read as follows 9'

• C

)' h=, 2506 Davis Street 5i i .Spefebruary 28, 1991

4. Ex reti San Leandro, California 94

()

5. Docket or 's/

.\\ Reference No. 030-20402

i. Byproduct, source, and/or

7. Chemical and/or physical (Imay possess at any one time B. Maximum amount that licensee special nuclear material form N

f* /,/ ' under this license l ,,/ Cobalt 60 'I ' A.' . Gamma Industries

'f A.b.Nottoexceed b

7 tiode A4-A s T ,I 100 curies q {' seal, d sp6rcef pj Oper source Iridium 192 'B. $ Nam n$t idi [ B.kNottoexceed /, (r, ( [ 100 curies Nodel T-1-T v + sealed sources,t

• per source 4

i t '! Iltl h E,.. Gam (a In ustrie! q (s c Cobalt 60 s.._A' Not to exceed p C i' 'tiodel T4-T tr'tio'ns ' h, 200 curies "-V ~ Technical Opera per source y/g( ', Model A-453-1> sealed sources \\ = /} Q Industrial,Nuc D. Not to exceed l Iridium 192 D. f'iodel, I sealed] ear.) sources 100 curies g per source -i i ). Iridium 192 E. Industrial Nuclear E. Not to exceed l Model 2 or Model 8 200 curies sealed sources per source Iridium 192 F. Industrial Nuclear F. Not to exceed o Model 7 sealed sources 100 curies per source 1 Iridium 192 G. Industrial Nuclear G. Not to exceed g Model 8 sealed sources 100 curies 1>j F per source i A

w.ccar2:1xrwxramnmcams,ca,cemmmxccamxmo. q NAC Fo+m 374 A U.S. NUCLE AR REGULATORY COMMIS$lON 2 7 pg g, ,3cgg License nurnber MATERIALS LICENSE ~ 35Y$45 SUPPLEMENTARY SHEET Amendment No. 3 (continued) !6. BYPRODUCT, SOURCE, AND/0R

7. CHEMICAL AND/0R PHYSICAL

8. MAXIMUM AMOUNT THAT LICENSEE SPECIAL NUCLEAR MATERIAL FORM MAY POSSESS AT ANY ONE TIME UNDER THIS LICENSE f

M. Iridium 192 H. Industrial Nuclear H. Not to exceed Model 32 sealed 100 curies sources per source t I l: O, e 2. Iridium 192 I I. Not to exceed - [. Technical Vperations j . -Nodel A-424-1 V', ' 100 curies sealed sources 1 per source G. Cobalt 60 J. Technical Operations J. Not to exceed Model A-424-2 18 curies sealed sources k. Cobalt 60 f per source K. Technical Operations K. Not to exceed Model A-424-5 5 curies 3 sealed sources per source Cobalt 60 L. Technical Operations L. Not to exceed Model A-424-14 100 curies sealed sources per source Cobalt 60 M. Technical Operations. M. Not to exceed Model A-424-15 10 curies l sealed sources per source Cobalt 60 N. Technical Operations N. Not to exceed e i k Nodel A-453-1 or 75 curies Gamr.ia Industries per source F Model T-2-T d sealed sources Cobalt 60 0. Technical Operations 0. Not to exceed 3 Model 32411 200 curies sealed sources per source Cobalt 60 P. Technical Operations P. Not to exceed Model 34500 .30 curies sealed sources per source Cobalt 60 Q. Technical Operations Q. Not to exceed Model 36907 200 curies sealed sources per source 1i

___-___------__----m wau.cxxxerxrrrrn'1*x1'1rramrxmmm:wrrKw==."m.v e; 1 N AC Form 374 A U.S. NUCLE AR REGULATORY COMMISSION 3 7

• ")

PAGE or ,,ces License number MATERIALS LICENSE 04-23240-01 SUPPLEMENTARY SHEET 3,,,,,,,3,,,,,,,,,,,3,, 030-20402 4 Amendment No. 3 $f1 (continued)

3. BYPRODUCT, SOURCE, AND/0R

7. CHEMICAL AND/0R PHYSICAL

8. MAXIMUM AMOUNT THAT LICENSEE SPECIAL NUCLEAR MATERIAL FORM MAY POSSESS AT ANY ONE TIME UNDER THIS LICENSE 1

I. Cobalt 60 R. Technical Operations R. Not to exceed Model 41706 20 curies I sealed sources per source l S. \\ tiodel 41701A orTecbnical Ope lra(ioris'y \\ 1-l. Iridium 192 S. Not to exceed - (-, sg, ' 100 curies 41705A sealed sources per source Cobalt 60 T. Sealed sources T. hot to exceed g($ 15 millicuries l per source Cesium 137 U. Sealed sources U. Not to exceed f e 90 microcuries >( per source e g& 1 [' Cesium 137 V. Sealed sources V. Not to exceed i 10 microcuries k= per source Iridium 192 W. Technical Operations W. Not.to exceed F a Model A-424-9 100 curies sealed sources per source Iridium 192 X. Gamma Industries X. Not to exceed g Model T-3-T 100 curies sealed sources per source h Iridium 192 Y. Gamma Industries Y. Not to exceed f Model IN-1-T 100 curies /p sealed sources per source Cesium 137 Z. Technical Operations 2. Not to exceed W-Model 77302 165 mil 11 curies N sealed sources per source Iridium 192 AA. Technical Operations AA. Not to exceed Model 87703 100 curies sealed sources N@ per source l

rrrrrrrrrrrrrrrrrrrrrmwESTrrrmin:ac.c we Traxcwrrumy NRC Form 374 A U.S. NUCLE AR REGULATORY COMMISS80N 4 7 15 W PAGE or PAGES License number MATERIALS LICENSE 04-23240-01 SUPPLEMENTARY Y SHEET 3,,,,,,,y,,,,,,,,,3,, 030-20402 Amendment No. 3 9. Authorized use p f A. For use in Gamma Industries Model 100 exposure devices for industrial radiography,fp B. For use in Technical Operations Model 533 exposure devices for industrial radiography and in Gamma Industries Model C-10 source changers for storage and replacement of sources. C. For use in Technical Operations Model 500 exposure devices for industrial radiography. t ii For use in Technical Operations ~ Mode 1 ~ 533 ' expo / ssure' devices for industrial D. radiography and in Industrial Nuclear Model 50 source <: hangers for storage and { replacement of sources. For use in Source Productior and Equipment Company Model SPEC 2-T exposure devices for industrial radiography. For use in Technical Operations Model 660 exposure devices for industrial radiography and in Industrial Nuclear Model IR50 source changers for storage f j and replacement of sources. p p For use in Gamma ' Industries Gama Century SA or Gamma Century SA Universal exposure devices and in Industrial Nuclear Model 50 source changers for storage 'g and replacement of sources. g For use in Industrial Nuclear Model IR100 exposure devices for industrial A radiography and in Industrial Nuclear Model 50 or Model 130 source changers for 9$ storage and replacement of sources. N For use in Technical Operations Model 533 exposure devices for industrial radiography. g &p For use in Technical Operations Model 402 exposure devices for industrial d radiography. f For use in Technical Operations Model 525 exposure devices for industrial radiography and in Technical Operations Model 416 source changers for storage h. and replacement of sources, i For use in Technical Operations Model 680 exposure devices for industrial radiography. For use in Technical Operations Model 684 exposure devices for industrial A d radiography. . 'I E; For use in Technical Operations Model 446 exposure devices for industrial radiography. For use in Technical Operations Model 1061M exposure devices for industrial l radiography. k b

b _. _ _. _.. _. _. .=.x _.. _.=., _..~ W AC Form 374 A U.S. NUCLE AR REGULATORtf COMMISSION 5 7 4 8'8 PAGE o, ,,ats License number MATERIAL,5 LICENSE 04-23240-01 i SUPPLEMENTARY SHEET oocket or nererence number 030-20402 Amendment No. 2 9. Authorized use k' lh (continued) P. For use in Nuclear Systems Model 52 exposure devices for industrial radiography. Q. For use in Technical Operations Model 151 exposure devices for industrial radiography. R. For use in Technica? Operations Model 51B exposure devices for industrial radiography. F I... J ' p, 5 For use in Technical Operations' Mode"l 5100A TxposureAevices for industrial radiography. (,'M ' d, f s-For use in Technical Operations Model 571 source rods for calibration of f instruments. p k 1 For use in Technical Operations Model 541-205 dosimeter calibrators for calibration of instruments. g For use in Victoreen dosimeter calibrators for calibration of instruments. For use in Technical Operations Model 660 exposure oevices for industrial (p i radiography and in Industrial Nuclear Model 50 or Technical Operations Model-414 4 or Model 650 source changers for storage and replacement of sources. For use in Technical Operations Model 660 exposure devices for industrial radiography and in Gama Industries Model C-10 source changers for storage and replacement of sources. I For use in Industrial Nuclear Model IR-100 exposure devices for industrial radiography and in Gamma Industries Model C-10 source changers for storage and 1 replacement of sources, p For use in Technical Operations Model 773 calibration devices for calibration of instruments. L. For use in Industrial Nuclear Model IR100 exposure devices for industrial ,1 radiography and in Amersham-Technical Operations RPD Model 650 and Automation industries Model 500 SU source changers for storage and replacement of sources. CONDITIONS Licensed material may be stored at 1415 Park Avenue, Hoboken, New Jersey, and may be used at temporary job sites of the licensee anywhere in the United States { i where the U. S. Nuclear Regulatory Commission maintains jurisdiction for' regulating d the use of licensed raterial. 6 h l,

~pA-_. .va ruxmra-A Aurrravrzre mrAmrcrATan.Ya5=c = n TE*+ 3 *-wrCAArgi $RC Fcem 374A U.S. NUCLE AR REGULATORY COMMISSION 6 7 4 883 p,gg o, p3cg3 License number MATERIALS LICENSE 04-23240-01 SUPPLEMENTARY SHEET nocket or nererence number 030-20402 Amendment No. 3 i I CONDITIONS continued) 1. A. Notwithstanding the periodic leak test required by 10 CFR 34.25(b), such requirement does not apply to radiography sources that are stored and not being used. The sources excepted from this test shall be tested for leakage before use or transfer to another person. B. Sealed sources authorized for a use"other than radiography shall be tested as radiography sources inkc' osiance'With!1Q~4FR 34.25. c r} Q f.Thelicenseeisauthorizedtoreceive, possess,andusesealedsourcesof iridium 192 or cobalt 60 where the radioactivity exceeds the maximum amount of radioactivity specified in 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; i B. Records of the licensee show that no more than the maximum amount of radioactivity per source specified in this license was ordered from the i supplier or transfero of the byproduct material; and d>M L The levels of radiation for radiographic exposure devices and storage {1 C. containers do not exceed those specified.in 10. CFR 34.21. p Pursuant to 10 CFR Part 40, " Domestic l.icensing of Source Material", the- @f licensee is authorized to possess, use, transfer, and import up to 999 kilograms of uranium contained as shielding material in the radiography exposure devices and source changers authorized by this license. g The licensee may transport licensed material in accordance with the provisions fi q of 10 CFR Part 71, " Packaging and Transportation of Radioactive Material". g t 9 lY ~ d>- l 4

I f d'1*1"li"UI'32 H.r.a*f h7 7'IPPEET G'Ef fE W CaNeiE*d*grrmATrha-hlh 3AC Form 374 A U.S. NUCLEAR R EGULATORY COMMISSION PAGE OF PAGES License aumber MATERIALS LICENSE 3dYd45 SUPPLEMENTARY SHEET i Amendment No. 3 ) i G l f< CONDITIONS [ continued) j

15. Except as specifically provided otherwise in this license, the licensee shall I

conduct its procram in accordance with the statements, representations, and procedures contained in the documents including any enclosures, listed below. 1 The Nuclear Regulatory Commission's regulations shall govsrn unless the statements, representations and procedures in the licensee's application and ] correspondence are more restrictive:than the egulations. , gl t-8 tL {f(< A. Letter dated Novemberg27,-1585 l B. Letter dated December 16,1985 l C. Letter dated December 18, 1985 D. Letter dated February 'O.1986 E. Examinations originai, Jbmitted With letter l dated December 22, 1983 by Geo Construction Testing l F. Letter dated December 1,1986 G. Letter dated Harch 31, 1987 H. Letter dated August 14, 1987 I. Technical Operations Model 773 Operations Manual received on September 4,1987 r,1 J. Letter cated ' September 8,1987 i 1 1: i 1 A lf -i 4 FOR THE U.S. NUCLEAR REGULATORY COMMISSION te By bff 0W/ 9$nxhh 8etY A. 'Riedlingerd Health Physicist (Licensing) Nuclear Materials Safety Section Region V ~ d $r h t ee

i ATTACIDiENT A Please be advised that unless your license has been terminated, you must conduct your program involving radioactive materials in accordance with the conditions of your NRC license, representations made in your license application, and NRC regulations. In particular, note that you must: 1. Operate in accordance with NRC regulations 10 CFR Part 19. " Notices, Instructions and Reports to Workers; Inspections",10 CFR Part 20, i l " Standards for Protection Against Radiation", and other applicable regulations. 2. Possess radioactive material only in the quantity and form indicated in your license. 3. Use radioactive material only for the purpose (s) indicated in your license. 4. Notify NRC in writing of any change in mailing address (no fee required i if the location of radioactive material remains the same). 5. Request and obtain appropriate amendments if you plan to change ownership of your organization, change locations of radioactive material, or make any other changes in your facility or program which are contrary, to your license conditions or representations made in your license application and any supplemental correspondence with NRC. A license f ee may be charged for the amendments if you are not in a f ee-exempt category. 6. Submit a complete renewal application with proper ~ fee or termination request at least 30 days before the expiration date on your license. You will receive a reminder notice approximately 90 days before the expiration date. Possession of radioactive material after your license expiras is a violation of NRC regulations. 7. Request termination of your license if you plan to permanently discontinue activities involving radioactive material. You will be periodically 1 %spected by NRC. Failure to conduct your program in accordance with NRC regulations, license conditions, and representations made in your license application and supplemental correspondence with NRC will result in enforcement action against you. This could ir. elude issuance of a notice of violation, or imposition of a civil penalty, or an order suspending, modifying or revoking your license as specified in the General Policy and Procedures for NRC Enforcement Actions, 10 CFR Part 2 Appendix C. Since serious consequences to employees and the public can result from failure to comply with NRC requirements, prompt and vigorous enforcement action will be taken when dealing with licensees who do not achieve the necessary meticulous attention to detail and the high standard of compliance which the NRC expects of its licensees. Thank you for ';our cooperation. t

1 l l Unitech Services Group { RADIATION SAFETY PROGRAM i UST 985 i SECTION IV MAINTENANCE PROCEDURE l _985-0 Original Issue TWC 09/30/85 I EFFECTIVE NO. CESCRIPTICH BY DATE

~ i mmm ~ RADIATION SAFETY PROGRAM Provide safe equipment operation and assure 1.0 OBJECTIVE sealed sources are controlled. 2.0 APPLICATION - U.S. Testing, Unitech Services Group (Company) equipment of the types listed below. 2.1 Sealed Source. 2.2 Exposure Device. 2.3 Shielded Room. 2.4 Survey Meter. 2.5 X-Ray Equipment. 3.0 PROCEDURES - Equipment will be maintained in good condition by periodic inspection and calibration. 3.1 A Maintenance / Calibration Label placed on the equipment (if applicable), will identify th,e date for the next servic-ing. j 3.2 Sealed Source 3.2.1 Leak testing will be performed every six (6) months and af-ter any equipment accident that could have caused damage to the capsule. a) Leak tes ting. will be performed by a RSO, Mo ni t o r_, or a designa ted individual, per the directions of Form 505, Leak Testing of Sealed Sources (Semi-Annual). b) The leak test will be sent to the Radiation Safety Direc-- tor (RSD), who will forward it to an approved labora-tory for analysis. c) _The laboratory will' report _the results to. the RSD. 1 d) Reports, which id enti fy capsule leakage, will require immedia te action per the Operating and Emergency _ Proce-dures (06E P). l NO. TITLE REV. PAGE UST - IV MAINTENANCE PROCEDURE 985 1 of,6

RADIATION SAFETY PROGRAM 3.2.2 Quarterly Inventory a) Quarterly physical inventories of sealed sources will be conducted by the Proj ect Managers / Supervisors under the direction of the RSD. Form 507, Source Quarterly Inven-tory, will be completed. b) Any sources, which cannot be accounted for, constitutes a Class A Incident requiring immedia t e action per the 06E P. 3.3 Exposure Device 3.3.1 Daily Inspections will be conducted by the Radiographer per the instructions of Form 160a or Form 160b, Exposure Device Inspection (Daily). 3.3.2 Quarterly Inspection shall be conducted by the Proj ect Man-ager/ Supervisor, or designated individual, at the end of each calendar quarter. 3.3.2.1 Form 5023, Exposure Device Inspection (Quarterly), shall be used when performing the step-by-step inspection procedure. 3.3.2.2 Inspection shall be conducted per Form 502a, on the follow-ing items, a) Shield Assembly. b) Source Pigtail Assembly. c) Source Tubes and Cable Housings. d) Crank Assembly. e) Cable (source drive). f) Mechanical Compatibility of Components. 3.3.2.3 Items found to be defective and/or inoperable shall be "Re-paired" or " Replaced" before being returned to service. 3.3.2.4 Inoperable and/or defective items, unable to be repaired or replaced, shall have a rej ect tag affixed and shall be removed from service. PAGE REV TITLE NO. 2 of 6 985-0 MAINTENANCE PROCEDURE UST - IV l

{ ! = % o, 1 l RADIATION SAFETY PROGRAM 3.3.2.5 Equipment rej ect tagged shall be returned to the appropriate equipment and/or source manufacturer for maintenance and/or overhaul as directed by the RSD. 3.3.3 Special Insmection - Inspections will be conducted on equip- ] ment that ,1a s been s ubj ec t ed to severe stress or damage (dropping or submersion in. wa t e r ). Expo sur e devices in- ) volved in emergencies will be inspected per the instruc-tions of the RSO/RSD. The report shall be identified "Special Inspection" and include a. description of the abnormal situa- ) tion encountered. 3.3.4 Field Maintenance I a) Servicing of the equipment to correct minor deficien-- cies uncovered by the daily inspections may be per-formed by the Radiographer except when abnormally high radiation levels are involved. l Note: Minor deficiencies are defined as Preventive Maintenance only. b) Units, which show abnormal radiation,-shall be immedi-ately removed f rom service and the Proj ect Manager / Super-visor contacted. 3.. 5 Source Replacement - Maintenance and required overhaul will i be performed prior to installation of each new source. 1 a) Exposure devices containing Iridium-192 will be over-hauled by an appropriate equipment / source manuf acturer or qualified individual designated by the RSD per the in-structions of Form 504, Exposure Devices Maintenance and Overhaul Checklist. I b) Exposure devices containing Cobalt-60 will. be -returned to an a pp ropria te equipment manufacturer for mainte-nance, overhaul.and source changes. 3.3.5.1 Operating Instructions - Source Changing (IR 192 Sources) a) Sur.vey shipping container with a calibrated survey ' me-ter. i NO. TITLE REV. PAGE UST -IV MAINTENANCE PROCEDURE 985-0 3 of 6

f u-w w. RADI ATION SAFETY PROGRAh! Note: If surface reading exeeds 200 mR/hr., place con-tainer in a safe area and contact your RSO/RSD (Emergency Procedures) and then the supplier. b) Locate source changer and exposure device in an area where the source may be exposed. c) Set up exposure device as for an exposure, d) Attach one (1) end of the transfer tube to the camera in the usual manner. Remove' shipping plug from changer. Remove adaptor plug from dust cap, attach it to source changer lock body. Connect the other end of the exposure tube to the adaptor plug on the empty side of the source changer. Position the equipment in such a manner as to permit free travel of the source assembly in the tube. e) Position the drive crank the maximum distance from the exposure device. f) Quickly crank the source out of the camera and into the source changer. Survey the changer to verify the inser-tion of the source. g) Secure the source changer lock. Test pigtail to verify source is securely held by closed lock. This may be done by attempting to retract the source after the lock has been closed. h) Unscrew the adaptor coupling connecting the exposure. tube and the source changer. Disconnect the source from the drive cable in accordance with the camera manu-facturer's instructions. 1) Remove the dust cap on the lock body with the new source tag. j) Install the dust cap on the lock body containing the spent source. Remove the spent source nameplate from the camera. Wire seal the spent source nameplate to the dust cap and lock body. k) Align the exposure device and source tube with source changer. The exposure tube should be straight and free of kinks with the end of the drive cable protruding one-half (1/2) inch from the end of the housing. PAGE REV TITLE NO. 4 of 6 985-0 FMINTENANCE PROCEDURE UST - IV

(Ag u- - ~ j x i' I RADIATION SAFETY PROGRAM f 1) Connect the new source to the drive cable in accordance with the manufacturer's instructions. m) Connect the source tube and adapt or coupling to the source changer lock body. n) Position the camera drive crank the maximum distance from the camera. o) Unlock the safety feature securing the new source in the source changer. p) Quickly crank the new source into the camera. Survey the camera to verify safe position of the source. j q) Lock the camera and replace the adaptor and shipping plug. Attach the new source identification plate to I the exposure device. 3.3.5.2 A copy of the source changer instructions should be pro-I vided with each source shipment. Source changing should be in strict accordance with the manuf acturer's instructions. Example: Industrial Nuclear Company's Source Changer, IR50, or Tech / Ops Source Changer, Model 650, Refer to Section VI, Source Shipping / Receiving 3.3.5.3 Shipping Instruction Procedure, before returning source changer to the appropriate manuf acturer. Inspection of shielded rooms will be con-3.4 Shielded Room ducted at six (6) month intervals by the Proj ect Manager /Su-pervisor, or designated individual, per the instructions of l Form 503, Shielded Room Inspection (Semi-Annual). Maintenance will be performed, as re-3.5 Survey Inst-ruments quired, prior to each calibration and after damage or mal-j function. The maintenance of survey instruments will be performed by a facility that has Nuclear Regulatory Commis-l sion (NRC) approval. 3.6 X-Ray Eouipment 3.6.1 All x-ray equipment shall be maintained in accordance with manufacturers' recommendations. ) i I NO. TITLE REV. PAGE UST - IV MAINTENANCE PROCEDURE 985-0 5 of 6 s

i g_ t I RADIATION SAFETY PROGRAM 3.6.2 All x-ray equipment control panels shall be labeled with " Caution X-Rays - This Equipment Produces X-Rays When Ener-gized" with the radiation symbol (magenta on a yellow back-ground). i 3.6.3 Daily inspections will be conducted by the Radiographer per the instructions of Form 160c. 3.6.4 Quarterly inspection shall be conducted by the Project Man-ager/ Supervisor, or designated individual, at the end of each calendar quarter. 3.6.4.1 Form 5 02b, X-Ray Equipment Inspection (Quarterly), shall be used when performing the step-by-step inspection procedure. 3.6.4.2 Inspection shall be conducted.per Form 502b, on-the follow-ing items, a) X-Ray Tube. b) Control Panel. c) Control Cable. d) Power Cable. 3.6.4.3 Items found to be defective and/or inoperable' shall be "Re-paired" or " Replaced" before being returned to' service. 3.6.4.4 Inoperable and/or defective items, unable to be repaired or replaced, shall have a rej ect tag affixed and shall be removed. 1 from service. 3.6.4.5 Equipment reject tagged shall be returned to the appropriate equipment manufacturer for maintenance and/or overhaul as required. 3.6.5 Quarterly.. inventory will be conducted by' Project Manager /Su-pervisor, or designated. individual,' per the instructions of Form 506, X-Ray Equipment Inventory (Quarterly). NO. TITLE REV. . PAGE i 2 9 - Inv MAfmvamawrda wrdrdaam a~ @M-E G -a# g

l Unitech Services Group RADIATION SAFETY PROGRAM UST 985 l SECTION V CALIBRATION OF RADIATION SURVEY INSTRUMENTS PROCEDURE 985-0 Original Issue TWC 09/30/85 I i i u YISICN EFFECTIVE NO, DESCRIPTICM BY DATE

Q.-._. RADIATION SAFETY PROGRAM 1.0 OBJECTIVE Provide a calibration program to assure radia-tion survey instruments will produce reliable data. 2.0 A_P_ PLICATION - U.S. Testing, Unitech Services Group (Company) rac2ation survey instruments. 3.0 PROCEDURE 3.1 Calibration shall be conducted by U.S. Testing, Unitech Ser-vices Group or Indust rial Nuclear Company on a quarterly (90 day) basis and af ter each instrument maintenance or servicing. 1 3.1.1 The approved facility report shall contain the following, a) Certification of maintenance and calibration identifi-able to the model and serial number (S/N) of the instru-ment. b) The date of certification. 8 c) Extent of servicing and items repaired or replaced. d) Signature and date of the person performing calibra-tion. 3.2 Instr "e.nts

• hall be identified with a Maintenance /Calibra-tion babel which states the recalibration date.

3.3 Recall of survey instruments for recalibration is the re-sponsibility of the Radiation Safety Director (RSD). 3.4 The RSD shall maintain the following records of calibra-tion. 3.4.1 Verification of the calibration facilities. 3.4.2 Verification of calibration for each survey. instrument cur-rently in use. NO. TITLE REV. PAGE CAL { BRA ION OF RADIATION _ ~

Unitech Services Group RADIATION SAFETY PFOGPAM i 3.5 Procedure for Calibration of Fadiation Survey hbters (U.S. Testing, Unitech Services Group) ) j 3.5.1 This procedure is to be used for calibration of radiation survey mters which are used by U.S. Testing, Unitech Services Group for j industrial radiography. 3.5.2 Personnel Qualification - Only the individuals specifically approved by the RSD may perform or directly supervise radiation survey meter calibration. 3.5.3 Facilities 3.5.3.1 he Fbdel 'IO 571 or 773 mter calibration kit manufactured by 'Ibchnical Operations, Inc., will be used as the calibra. tion source for the radiation survey meter calibration. He ur.it is a mlded steel, lead filled storage container. It contains a 600 port, a novable source capsule,, locking bar, and a padlock for securing the source against unauthorized use. L e container is equipped with a 15 millicurie Cobalt 60 source in a sliding capsule which allows the source to be moved from the stored position to the directional port window, but not removed from the container. He dose / distance computer and metric tape are fastened to the container for ready reference. 3.5.3.2 2e 'IO 571 or 773 meter calibration kit can be used in any area to which access can be restricted for a distance of ten feet. We restricted area must be under direct surveillance and posted conspicuously with " Caution-Radiation Area" signs. 3.5.4 Procedures for Calibration 3.5.4.1 In use, the inverse square law is applied by placing the survey meter at the appropriate distance for the desired radiation field. These correct distances can be determined. immediately from the dose / distance computer mounted on the container; and distances can be measured directly with the built-in netric tape. 3.5.4.2 Place the container on a long bench in an area to which access can be restricted for a distance of about 10 feet. NO. TITII REV. PAGE CALIBRATION OF PADIATION UST-V SURVEY INSTRLNENI'S PROCEDURE 985-0 2 of 4

r l Unitech Services Group i RADIATION SAFETY PROGPAM f 3.5.4.3 Set the age of the source on Scale A opposite the calibrated source size shown on Scale B and tighten the holding screws. 3.5.4.4 Pead the appropriate distance on Scale D under the dose level desired shown on Scale C. 3.5.4.5 Place your survey neter at the correct distance, lift the source capsule to "open" position and read the meter. 3.5.4.6 Check each instnment at two or nere points on each scale. If the instrument readings correspond to calculated values, within a range of plus or minus 10 percent, it can be cor-sidered to be properly calibrated. Minor adjustments can oftentimes be made which will bring the instiiment within the desired range. 3.5.4.7 If the instrument cannot be adjusted in order for the readings to fall within the calculated range it should be returned to the manufacturer or a qualified instrument repair laboratory for repair and calibration. 3.5.4.8 For 'IO 773 meter calibration kit see attached operation manual. i NO. TITLE REV. PAGE CALIBRATION OF RADIATION UST-V SURVEY INSTRUMENTS PROCEDURE 985-0 3 of 4 l

) Waneen W Grove 1 RADIATION SAFETY PROGRAM EXHIBIT 1 C rsfpM F W i @e.1.;::. m:>' 6 W W*Bf t.Y. N'tyA.4 LQUn.nts:.S k -.. G- >=vt %M tj -.,r:.7, f s \\ yff 9 re f s*. kis' Q 6

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FQ42$3'$f ~.s.. p to sm _. - y%% sL hklfrhhk$ ..sounca Decay inoicaron NO. TITLE REV. PAGE CALIBRATION OF RADIATION UST-V SURVEY INSTRUMENTS PROCEDURE 985-0 4 of 4

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, _... t,._ s v Teca/O.as Noce' 773 Instrument Ca i3 ration Device O3eration Manual l Sr'T..t. A N. I ^ ~ .ii A l r .&.9.

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~ ,. r.c f f I l e Tech / Ops, Inc. Radiation Products Division Burlington, Mass. 01803 Phone (800) 2251383 (toll free) l [in Mass. call (617) 272 2000) ( o

shnical Data of 165 mci. The "' Cesium source emits gamma radiation which can cause injury if improperly 9: 5 in (12.7 cm) wide,5 in (12.7 used. Disassembly of the device or removal of the cm) deep,8.5 in (21.6 cm) high source requires special equipment. We fght: (with attenuators) 52 lbs. (24 recommend that any service requiring kg) disassembly of the device or removal of the (without attenuators) 45 lbs. source be performed by the manuf acturer. (20 kg) cree: Model 77302, "'Ceslum,165 Instrument Devices millicuries asport DOT Specification 7A Type Although the device has radiation levels which Dus: A Package are well below the maximum radiation level per. mitted on storage containers, personnel should siding Lead Approx. 29 lbs. (13 kg) not stay close to the device any longer than lerial: necessary. precautions should be taken to store the instrul Eeral ment calibration device in an area that meets 9 Model 773 is a small portable radiation survey the requirements of Title 10 Code of. Federal

rument calibration device authorized to Regulations 20.202(b) (2), 20.203(b) and

)tain up to 165 mci of "' Cesium. The ' Cesium 20.203(e). o tree is permanently attached to a moveable it is recommended that personnel operating the irce rod which is installed in a lead shield equipment use a calibrated and operable survey ting. The source is exposed by raising the instrument and wear appropriate personnel wce rod which positions the source in a 36' x monitoring devices. The radiation level at the j colimated beam port. source rod when the source is in the " operate" > unit is equipped with three attenuators position is approximately 50 milliroentgen per Insmission of 0.25,0.10 and 0.10) to allow a hour. l sey instrument with three ranges to be Movement of the source rod should be ac. brated at 20% and 80% of each range complished as expeditiously as practicable. An sout changing the position of the survey in. alternative method of raising the source rod cment. The Model 773 can be u. sed to would be the use of a string and pulley arrange. brate survey instruments with ranges up to ment. 0 rr.illiroentgens per hour, in no case should anyone enter the area of the unit is equipped with a carrying handle radiation beam or expose any part of his body ch also serves as a source locking bar to to the radiation beam. I vent unauthorized use of the calibrator. A sping cover is also attached to provide and i 'itional means of securing the source. Preparation for Use Belving Place the source shield in a restricted area so that the directional port is aimed horizontally. vey the device for excessive radiation levels. To minimize the effects of scattered radiation, > device should have radiation levels less the unit should be 16 feet from any wall in the a 200 mR/hr at the surface snd less than 10 direction of the primary beam. /hr at three feet from the surface. inspect Position a support horizontally from the Model device for shipping damage and insure that 773 Instrument Calibration Device as shown in device is locked. Figures 1 and 2. Restrict access to the area where the radiation bty Precautions level is in excess of 2 milliroentgen per hour. ( ee ure 4 > Model 773 Meter Calibration Device contains ' Cesium source which has a maximum activity

Dperation move the shipping plate. Remove all the attenuators from the radiation beam. l ]ote: To properly calibrate a survey instrument

6. Standing away from the radiation beam,

) is necessary to check the instruments expose the source by manually raising i esponse at two points on each of the in. the source rod. Note and record the ) truments ranges. These points must be survey meter reading, return the source sparated by at least 50% of the full scale to the stored position. The actual intensi-pading. The instruments reading should agree ty is 800 mr/hr. If the reading is within 1th the actual radiation intensity within 20o/c 10% of the actual intensity, continue > be in. proper calibration, checking the instrument, if the instru-Ne following procedure is designed for a ment reading is not within-10% of the Jrvey instrument with three scales and a range actual intensity, the instrument must be 701000 mr/hr. For instruments with different adjusted and recalibrates. Inges, the procedure will be similar but the CAUTION: Do not enter the area of the l

nnts will dif fer-radiation beam while the source is expos.

ed. J. Turn on the survey meter and allow it to

7. Place the 0.25 attenuator in the beam.

" warm up" for approximately 10 minutes. Repeat step 6; the actualintensity is 200 L Determine the activity of the source on mr/h r. l the date of calibration from the decay

8. Remove the 0.25 attenuator from. the' chart provided with the source.

and place a 0.10 attenuator in the beam.

1. Determine the distance from the source Repeat step 6; the actual intensity is 80 at which the radiation intensity would be m r/hr.

800 mr/hr (use Figure 3).

9. Place the 0.25 attenuator in the beam.

,. Using the tape measure attached to the Repeat step 6; the actual intensity is 20 i Model 773, place thp survey meter such mr/hr. j that the axis of the detector is located at

10. Remove the 0.25 attenuator from the i

the proper distance from the source as beam and place the other 0.10 attenuator i determined above. In the beam. Repeat step 6; the actualin.

Ste, tensity is 8 mr/hr.

11. Place the 0.25 attenuator in the beam.

@ survey meter should be located so that Repeat step 6; the actual Intensity is 2 e center of the detector is at the correct mr/hr. itance and centered on the center line of t radiation beam. The axis of the detector guld be perpendicular to the centerline of Leak Testing ys cal e of your u vey instrument i The Tech / Ops Model 773 Meter Calibration Kit ly be necessary to mount it somewhat contains a mCeslum source which must be leak lher than the bench surf ace. When the pro-tested at intervals not to exceed six months. r geometry for your instrument has been This may be accomplished using the TechlOps 3blished, use the same physical arrange. Model 518 leak test kit. at consistently in future calibration ppera.

1. Place the Model 773 calibrator in a re-as.

stricted area. @hort distances, using survey instruments

2. Remove the lock and rotate the handle h large detector volumes, the radiation in.

from the top of the source rod. Remove Sity will not.be uniform across the detec-the shipping cover, Consideration should be given to this ef-

3. Moisten the leak test' swab with EDTA

? when determining the radiation inten-solution. Blot off the excess. @s to be checked.

4. Wipe around the top of the source rod.

5. Standing away from the beam port, raise,.

Unlock the handle of the Model 773. Re-the so^urce rod to the open position and m

wipe the exposed source rod thoroughly. THE IDENTIFICATION SHEET.

6. Place the leak test swab in the plastic

9. If the swab should show more than 0.2

envelope, mr/hr. DO NOT MAIL. Contact Technical

7. Set the survey meter on its most sensitive Operations, Inc. for specific instructions, range and place the meter in a low background area. Move the swab, in its N ot e**

plastic envelope, to the meter, not the l meter to the swab. The wipe test swab will be subjected to a l

8. If the meter indication is less than 0.2 precise radioassay when received by l

mr/hr above background, place the TechlOps and a leak test certificate will be l plastic envelope with the swab into the mailed promptly. This certificate must be l mailing box and mail to Technical Opera-kept with your records as it is subject to tions, Inc., Burlington, Massachusetts. N.R.C. Inspection. BE SURE TO FILL OUT AND RETURN ss _e'<* e > } (.i W *^ _ L ' [s.,[ 3 .73 BT4 [b' s 1, hg,ad* g,?n; j%,A:uthe) q+ y.,. a i*A4 ~ n law n:c.g 5fm., i + v

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@h/ Ops, Inc. e-oe laahen Prococts Dwision SOURCG sonn a,,,u, Heion umunasem oin3 CERTIFICATE pp5one (617) 272 2000 7 Esd2cnuelade: Cettun-137 Source Model: 7730: f Source Serial: 5-353 l 1 l l Measured Equiselent Activity: 144.0 n2112 curies on 28-Oct-81 Decay Data Date Act2vity Date A:tavaty E-Oct-El 144.0 20-Mar-89 121.4 IE-Jen-E 143.2 16-Jun-E5 1:0.7

E-A;r-5:

142.4 IE-Sep-69 120.0 5-Jul-E: 14T.E 15-Dec-89 119.3 '

3-Oct-52 140.E 15-Mer-90 118.E 21-Jan-E3 140.0 13-Jun-90 116.0 21-Apr-E3 135.0 11-Sep-90 117.3 00-Jul-E3 135.4 10-Dec-90 115.E IE-Oct-53 137.5 10-Mar-91 115.0 16-Jan-E4 135.8 OE-Jun-91 115.3 15-Apr-E4 13E.7 OE-Sep-91 114.7 14-Jul-E4 135.3 05-Dec-91 114.0 10-Oct-E4 134.5 04-Mar-92 113.4 10-Jen-E5 133.7 02-Jun-92 112.7 10-Apr-E5 133.0 31-Avo-92 112.1 09-Jul-55 130.2 29-Nev-92 111.4

'07-Oct-E5 131.5 27-Feb-93 110.E CE-Jen-EE 130.7 lE-Mey-93 110.2 05-Apr-EE 130.0 25-Aug-9: 109.5 i 04-Jul-EE 129. 24-Nov-93 106.9 f 0:-Oct-BE 125.5 22-Feb-94 106.3 31-Dec-EE 127.6 23-May-94 107.7 31-Mar-E7 127.0 21-Aug-94 107.1 29-Jun-57 10E.3 19-Nov-94 10E.5 27-Sep-E7 105.5 17-Feb-95 105.9 2E-Dec-97 124.9 IE-May-95 105.3 IE-Mar-b6 1:4.2 15-Aug-95 104.7

3-Jun-BE 103.5 14-Nov-95 104.1 01-Sep-SE 122.E 12-Feb-9E 103.5 20-Dec-EE 122.1 1~-May-95 102.9 2

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INDUSTRIAL NUCLEAR COMPANY r PLEASE REMIT TO-A Subsidiary of Research & Testing Co., Inc 1124 CHE55 ORIVE e FCSTER CITY.CALIFORNI A 94404 * (415) 349 6367 INDUSTRI AL NUCLEAR CO, g 3 P.O. BOX 3189 HOBOKEN, NJ 07030 CUSTOMER NO. T ORDER NO. DEPT NO. / 3 LL TO: INVOICE NO. INVOICE DATE q j P.O. NO. l SHIP VIA TERMS: CASH j. LIANTITY QUANTITY UNIT DESCRIPTION AMOUNT %DERED SHIPPED PRICE 1 l 1 ) l 1 1 NOTE: SURVEY METERS ARE CALIBPATED 'IO THE FBCtfr OF TFE OUTER CASE AT TFE G4 'IUBE I.OCATION. 4 m to certify inat the above named articies ce properly oescribed, pactaged, marmed. and lateied and REMARKS 'O en propet condition for transportation according to the applicable regulations of the Department of onsoortation PARTS GALTH PHYSICS SURYtY M survey is the result of readings taken af ter mettrel is ccmpletely packaged and ready for snipment berPum $urface Rad 4 tion M R!H R tax MR/HR 9 3 Ft. Approved for sniemen, LABOR NUCLE A#t SAFtty stCTION yvey itstrument Cal &gtros omme rey c*erations are made with Cobalt 60 A comple:e record of esca lastrument m mamtemed SERVICE CALL i our faes senery checks ud routme prevente mamtenance e, eso inctoded as part of tne carreration @3edure. ,,,,,,,,,,,,,,,,,,,,,,,,,, 3 CALIBR ATION (sst. $cale mA!ht espesure inst reading mR/hr gyggggygg aa" a ' th' ***$ 8 **a' '" $a'c d'c sioc 800 1. rep.,','o one, 'w'e suvanise en p,'"a mstaued i, us..ui n a100 200 2. do not guarantes or pretend to guarantee otrier parts in MINIMUM CHG. the apparatus We guataite no,ma,,,,to,m nc,,on,,,s your unit wdl be festored to a10 80 s ,, m,,,,, n,, on d,,,o n,,,0, att 20 4. completion of our resan la the event of dissatisfaction SHIPPING with u, nit performance. we m,ust be notifeed within seven l at 8 5 da,s, te, yo,,cce,1,nc,0,h e,,0,,,c,,n,i. TOTAL a1 2 6. ~"""***"""**""*"*"*"""~~'T aut Csieration Date Tecancan_ NOT(: A monthly FINANCE CHARGE of 2% win be S. ?*?.' ?#! ' .'? ?$ 9 ,,~u a-- e on n

i 1 Unitech Services Group RADIATION SAFETY PROGRAM UST 985 SECTION VI SOURCE SHIPPING / RECEIVING INSTRUCTION PROCEDURE l 985-0 Original Issue TWC 09/30/85 REY 51CN EFFECTIVE MO. DESCRIPTION BY DATE

} s %.. -Q' i b y UNITECH SERVICES GROUP PADIATION SAFETY PROGPAM 1.0 OBJECTIVE - W e objective of this procedure is to assure the proper methods and practices are used to insure em pliance with Federal in accordance with 10 CPR Part 71 and 10 CFR Part 49, or State and Capany regulations which effect the transporting, shipping and receiving of radioactive material. %e final responsibility for the Quality Assurance Program for Part 71 requirements rests with United States Testing, Unitech Services Group. 2.0 APPLICATION - U.S. Testing, Unitech Services Group (Ccupany) personnel transporting, shipping and/or receiving radioactive material outside 4 the confines of the plant or other authorized location of use. 3.0 PROCEDURE The Radioactive Paterial (source) Shipping / Receiving Instruction Procedure, described herein, outlines the basic methods and practices used by the Campany to treet the objectives of the regulations. 3.2 h is procedure is your guide for the instructions used whenever you are shipping and/or receiving rad'.oactive material. It shall be made available for review when shipping or receiving source naterial. 3.3 Th'is procedure is subject to modification or revision due to changes in Federal Department of Transportation (DOT), State and/or Ccnpany requirements. 3.3.1 Procedure modifications or revisions shall be coordinated by the Radiation Safety Director (RSD). 3.3.2 he RSD is responsible for transmittal of modifications or revisions to all facilities. 3.3.3 he Project Manager / Supervisor shall be responsible for maintaining this procedure on the project. 3.4 h e RSD shall be made aware of all radioactive shipments. 4.0 PACKAGING - Packaging of radioactive material shall be designated and selected to meet with all the requirements of D0r. 4.1 W e Radiation Safety Officer shall assure that all radioactive material shipping packages are designed and manufactured under a OA Program approved by the Nuclear Regulatory Ccnmission for all packages designed or fabricated after January 1,1979. mis requirement will ' be satisfied by receiving a certification to this effect frcm the reanufacturer. NO. TITLE REV. PAGE SOURCE SHIPPING / RECEIVING UST - VI INSTRUCTION PROCEDURE 985-0 1 of 4

f w. h %.Q-) UNITECH SERVICES GROUP PADIATION SAFEIY PROGRAM 5.0 PREPARATION FOR SHIPPING 5.1 A survey neter shall be used every tine a person is required to ship radioactive materials. 5.2 Insoection of Radiographic Dcoosure Device (Iridium - 192) { ~l 5.2.1 Survey surface of device for surface radiation levels. l Note: No device shall have a' reading in excess of 200 mr. 5.2.2 Attach wire seal through safety plug, then to device. 5.2.3 Place exposure device in shipping container provided. a) Exposure device, having DCrr approved Type "B" (Example: IR100), will be placed.in an overpack (black drum) labelled with Certificate No. USA 9157/ Type B. b) Exposure device, without DCYT approved Type "B" (Example:

• * 'IO533), vill be placed in a DUT approved Type "B" package (yallow drum) labelled with Certificate No. USA 6717/ Type B.

) 1 5.3 Shipoing Container 5.3.1 Shipping container shall be a DCrr approved type "B" package. 6.0 SHIPPING 6.1 'Ihe following instructions are mandatory to meet with the requirements of DUT and/or Canpany. 6.1.1 Affix address label on shipping container (remve or cover old label). If shipped by air (Federal Express) -- the Airbill can be used as the address label. 6.1.2 'Ihoroughly remve Radioactive Yellow Shipping Labels fram-previous shipnent. 6.1.3 Canplete Radioactive Yellow-II or III Labels and place on-opposite sides of shipping container. Do not ship without two (2) Radioactive Yellow labels (on opposite sides of container). For information required on ' labels see Appendix 1. PAGE REV TITLE NO. - SOURCE SHIPPING / RECEIVING

\\ vg UN: TECH SERVICES GROUP l l RADIATION SAFETY PROGRAM 6.1.4 Container shall have affixed a " DANGER PELIGRO CARGO AIR-CPAPT ONLY" label (for shipnents by air) - See Appendix 2. l 6.1.5 Container shall be labeled with the basic description of the material. ("PADIQACTIVE MATERIAL SPECIAL IDRM N.O.S. UN 2974.") 6.1.6 Container shall be labeled with certificate number and type of l package. Example: USA 9157/ Type B (IR100) or USA 6717/ Type B l (70533). 1 6.1.7 Container shall have affixed a package certificate of approval. I 6.1.8 Ccruplete Radioactive Material Transfer Report - Appendix 3. (Exclusive-Use Vehicles, Paragraph 6.3.2, are exempt.) Note: Place a copy in the shipping container. 6.2 Shipoed Bv Air " Cargo Only Aircraft" 6.2.1 Ca$lete Air Bill (Federal Express Form - Appendix 4). j i a) Radioactive material shipnents can be shipped either Priority One (P-1) or Standard Air. a 6.2.2 Complete Shioper's Certification for Materials Classified as Radioactive Material (Federal Express Form - Appendix 4). j 6.3 Shipoed by Truck 6.3.1 Cmron Carrier - Cmplete wavbill (Trucking Bill of lading - Appendix 5). 6.3.2 Canpany Vehicles (Exclusive-Use Vehicles) - Canplete Radioactive Materia.1 Shipping Docunent Capany Vehicles - Appendix 6. 6.4 Only those individuals cualified (by training) to handle radio-active material shall prepare and sign shipnents. 6.4.1 Qualified individuals are: RSO, Project Managers / Supervisors, 2 bbnitors, Radiographer or designated individuals by the RSO/RSD, and only after receiving required training. -l 2 NO. TITLE REV. PAGE l SOURCE SHIPPIE/ RECEIVING 1 UST - VI INSTRUCTION PROCEDURE 985-0 3 of 4

E i %, s k ' UNITECH SERVICES GROUP j PADIATION SAFEPY PROGRAM 6.5 Check to see that ycu have empleted all reauired items. 6.6 Place device in the DCrr approved shipping container. 6.7 Secure container with a wire seal or other neans approved by the RSD. I 7.0 RD2IVmG 7.1 Picking Up Shigent - Each licensee, who picks up_ shi}xnents frcm a carrier's ternunal, shall do so expeditiously upon receipt of notification. 'Ihe shipnent shall be monitored as soon as practicable after receipt for surface radiation levels of container. 7.2 Beceivina Shipnent - Monitoring shall be performed as soon as practicable after receipt, but no later than three (3) hours after the package is received at the facility if received during norral working hours, or 18 hours if receivM aft.er normal working hours. 7.3 If radiation' levels are found on external surfaces of container in excess of 200 mr/hr., or at three -(3) feet frm external surface in ' excess of ten (10) mr/hr., the individual shall imediately notify the RSD at (415) 562-7500. 8.0 ENTOTCEMENT OF REQUIREMENTS l i 8.1 It shall be the responsibility of the RSO, Project Manager / Supervisor and/or the RSD to enforce the requirements of this procedure. 8.2 RD"DRDS - A list of records of shiprnents and storage locations will I be maintained by the Radiation Safety Officer. t I i PAGE REV TITLE NO.- SOURCE SHIPPING / RECEIVING 4 or 4 985-0 INSTRUCTION PROCEDURE UST - VI

mmm APPENDIX 1 i RADI0 ACTIVE YELLOW LABELS l 1 "RADI0 ACTIVE YELLOW-II" " RADIOACTIVE YELLOW-III" 0.5 to 50 mrem /hr. on the surface. 50 mrem /hr. on surface but 200. h> 10. Not over 1.0 mrem /hr. at 3 ft. 1.0 mrem /hr. at 3 ft, but 1 I l a a DewslU s a HANDLE CAREFULLY ~ ] [" HANDLE CAntFULLY tis k " " 'fd'.bbbf[h " L. ' 5 j( ) (( l'" Co NT ENT5:.......................... !.' 'lo",a,8; N O. o F CU R!ES:............................ CONTENTS:.... q,. NO. OF CURIES:;....t............... "7.Ull'"#4' "'"7 " '* "la p "U'?d d "'o;'f ll" i bd dd 7 7 Contents: Iridum-192 or Cobalt-60 No. of Curies: Amount of Curies of Shipment Transport Index: See Example Below 1 Transport Index: The highest amount of radiation measured at 36" from any surface of the shipping container. Example: If the meter reads .5 mr/hr. at 36",.8 mr/ place a.5 in the box. If the meter reads hr. place .8 in the box, etc. Transport Index of more than 10 Do not ship material Contact the l RSD. " Radioactive Yellow II" -- Does not require vehicle placards for shipment by highway. " Radioactive Yellow III" Requires vehicle placards on all four (4) sides. 1 1

== Description:== Label is Yellow, Black and White with Red Bars. l l I I

rn APPENDIX 2 ( d) --- DANGER-PELIGR0 LABEL CARGO AIRCRAFT ONLY l 1 DANGER-PELIGR0 i 49 gf 'l ~ 5 ~.., EK b i / h~

• l 34 k

x.-_ e w Q E2 % ~:~ \\ \\ 7 A ~ z-r- LABE LMAST E R. CHICAG O. lL L. 60660 L 20 CARGO AIRCRAFT ONLY LABEp All air shipments require shipping containers to have affixed (one) " Danger Peligro-Cargo Aircraft Only" Label. This label is not required for ground ship-ments. Label is Orange and Black in color. I l l

~ 1 APPENDIX 3 UNITED STATES TESTING COMPANY, INC. RADIOACTIVE MATERIAL TRANSFER REPORT JOBSITE DATE ISOIOPE CAPSULE S/N CURIES EXPOSURE DEVICE MAKE bODEL S/N TRANSFERRED FR N 'IO REASON FOR TRANSFER: NEW SOURCE REQUESTED l l SOURCE RETURNING l l MALFUNCTIONING OR DAMAGED l -l l 1 LIST ANY MECHANICAL Dtztus OR MALFUNCTIONS SHIPMENT PREPARED BY AUTHORIZED BY SHIPPING CONTAINER Conta2.ner shall be a Type B designed to meet with the requirements of DOT. 1. Shipping Container S/N 6. Labeled with " Radio-active, Material Special 2. Condition of Shipping Container Form N.O.S." 3. Danger Peligro Cargo Aircraft 7. Labeled with " Type B" Only Iabel Affixed 8. Shipping Label Affixed 4. Package Certification or 9. Radioactive Yellow Approval Affixed Labels Affixed i 5. Iabeled with Package Certificate Type of Label: Yellow II l l (hbdel or Identification No.) Yellow II' l l -) l SURVEY OF MATERIAL PRIOR 'IO SHIPMENT SURFACE OF EXPOSURE DEVICE MR/HR AT 39" MR/HR SURFACE OF CONTAINER MR/HR AT 39" MR/HR oco************************************************************************************ occoo********************************************************************************** l 1 SURVEY OF MATERIAL AS RECEIVED SURFACE OF CONTAINER MR/HR AT 39" MR/HR SURFACE OF EXPOSURE DEVICE MR/HR AT 39" MR/HR 1 DATE RECEIVED j i CONDITION AS PECEIVED RECEIVED BY (Shipper complete top half of report and ship with exposure device. Individual re - l ceiving material emplete bottan (survey of material and condition as received) and l return by mail to originator (jobsite) with a copy to the RSO.) ) i ___._______________ ___ _ ___ _ _ _ _ _ _ O

q ( APPENDTX 4 l Unresca Se.weses Group RESTRICTED ARTICLES AIRBILL 1 i i Shipments orginating from Activity Net Quantity l l Foster City - Enter FEC Acct. Enter the number or curies j No. here Category of Labels Shipments Originating from Enter Yellow II or Yellow III field sites - Enter FEC Acct. No. here Transport Index Enter TI as recorded on See Instructions on Back Yellow Labels Appendix 1 Note: Sample illustrates shipments to the Foster City Office. I Mi-TYJ','..";l"T!2bA*.M'.h.'.;'M" ' E ' M ' I Ir [llfilillIII] l !,u.. ' t c l

Pro f. e M.n ere'r

~- ~ 'I'***-**

,-. l' ;* '.M*.', ~ ~- 'l sc,

... ~ I r S IMPL I FI ED uW"" "5""' 'N ba " *c h T* " 5 a= M '. '.' - I 5" PRIORITY 1 or. L. SELECTION OF...- V. 4 n,.te c>.n uriv. v - 8( n m c.n oe s - ~ r. N ch. u.s. In.e.c cie. %,o ro c4 = STANDARD AIR,,,,3%a%39 f?"f'N~o I.. Drr.-=.i:2'.9.l 'T-5'l. ~r i i ( S ERVI C E---- "-*'7.=.7~ ?G.L.~.T.I.'~. '-lT $ ( 5 DOMESTIC l FOR ORM 's ~:-- - =--$- n7.g r-- !5$N7:{IE55 d ! ( AIRBILL l AND RADI0 ACTIVE E. i - E~- ~ ---. e PORTION I MATERI AL ONLY cG...;.. l. :.;.w.r :,,-,i S.'.',. ~ ~~ $( i \\..... j ..g s..,

g g,-.. {(i y i i

%z. r-y3._ ~ ;,. RESTRICTED.. - .'o====..: 4 E.m;. J ,7" ARTI C LE 1.d.,,._.vs' = dm% . =.. J ( / c--- i - - - -, 7. SERVICE ISlinF*' WlE'" ~"~ - - - - - i ( 1 l PRE-CHECKED EASY-TO-lssssssss. sss..>ea s uamarone asua cTeo 4arictess s s s 3 p"

• 3' k

s a. FOLLOW m;ij p.- i .m. g - A

• oi--. 1 (

m-c.c a u. x.re '- ' c a * = " - ~ ~.--.- '- INSTRUCTIONS t !/

m. so.cciv. n.c.ri.i so.ei.i rot. s.o.s.

r ON BACK wam curi 0F FORM / m a--< -A SHIPPER'S AIRBILL,n=M,, l l'x.tio-a# i CERTIFIC-NUMBER w', ne e-tridii= t'2 se.ciai ror= typ. s CATION CROSS umma; c"ri'.. =m.c PORTION REFERENCED ,..ua. s i t 0 N SHI PPER ' S,,... ..,,,,v.s.... ~,..c s,.uc..a,c. Mtmf m. MHwa3 C ER T I F I C ."."f 8V CE.*FT T.bs.f.fts. CassitWil 0F het Cow 1.C w..rf..g Fut.6T M ...c., . S ,, cc.c..._,.

c...a.

. o. m., )> I CATION ss u,gLTOttepts.O40015 Of

1. 0.t.. -)

POR TI. ON....... c.u..~a_ac......... ~== = ~~~ . - ~om co -~ =a =~= =< a es each airbill i.. --... .o a.- .3 n....no uti. a.r. I atu m.ooo isi.,x.r. complete record of shipment for regulatory compliance. TOR CUSTOMER ASSISTANCE ANYTIME, CALL 800 238-5355 (in Tennessee 800 542-171)

APPENDIX 5 e o,

s.,

TRUCK SHIPMENTS COMMON CARRIER 'i Weight (lbs) of material being shipped Class or Rate Il06/lbs min. \\ UN'ronse eTR AIGHT BILL OF LADING-ORIGINA -NOT NEGOTIABLE y ARKANSAS BCST FRE!GHT SYSTEM. INC. (ABFSI ,f 301 SOUTH tith ST. Sa.8** '# FT. SMITH. AREANSA3 72301 C***'** 0e TO: \\ FROM: co ,a Company's Name and Address \\ sn.ow Unitech Testing. Inc. su to which Material is Being . '\\ I.ocation's Complete Address s i,... pber of packages 'o.. e,... 3 hipped z.o coa. z.o coo. \\ l v.a.c m%w \\ l Numcer i .....a- .. s.. is

s. c.

a e neir 1 Radioactive Material Soecial Form \\ 66c /lb min. C o O 70 'L , oe,,.,, pn shipping Iri di-N.O.S. UN 2974 h. "f';"l"*,,f,,ja;, W*:l h192 Devices use

• '" ".;";E,,,,G."::,E;**{

0 s 3 ample Ieidfum 192 curies =.,,f.,. ;;, g,,g g. _/- Cobalt 60 curies 's-** l o \\ / 'n shipping Cobalt-rf ie11ow II,,4r III coOames b m,,,,,,,,,,,,,,,,,,,,,,

Transfer Index

• ' * '"."#L *' ::"3 ". 74 Devices use this

r: ~ 0 0 ". 11.l::

IThis'is to certify that the above named materials are '%--;;;?,rar.,~,,,,,, ecle (properly cla$sified, described. packaged, marked, labeled 2::T 7." r'.'::'T. 'll='= \\ l / fare in proper condition for transportation according to j .n i / l ebe apolicable regulations of the DEPARntENT OT TRANSPOR.icoo nI' ver the number of f.o;... Wh-.- ng'A. ~.* C';;;".*L". ".::" "':; * ".~C:.r.?/*-. = O r,.,,~,.;.,;;; y,.,,,,,.; Amf..y.,,,, 7; ;;,;= '",'c', T="# ; *.". " O'.*

• 7J.

>ies at the time

.r._..s. ::.:."=j.g=.,m: : :. r.:. r : =.

r.=-~. :.r.: : =. : :e.:.==. = a..M....s l .the shipment > 1 y. ,g y . ;...,....~.,. ; _ 7; ;,.-% -.... g a r.,- l N c m.. es. A es. Daft x TRANSPORT INDEI SHIPPER'S CERTIFICATION The highest amount of radia-Must appear on bill of lad-tion measu: ed at 36" from anY ing. surface of the shipping con-tainer. Same as recorded on Yellow II labels. 4 ) .y _-_~_____._---___________---_a

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o E "M. 1 t { Unitech Services Group l RADIATION SAFETY PROGRAM UST 985 SECTION Vil LEAK TESTING PROCEDURE 985-0 Original Issue TWC 09/30/85 CM EFFECTIVE MO. DESCRIPT!CN BY DATE

m u--c 1 RADIATION SAFETY PROGRAM i 1.0 OBJECTIVE - Detect leakage of a sealed source. 2.0 APPLICATION - U.S. Testing, Uniteph Services Group (Company) sealed sources. I l 3.0 PROCEDURE 3.1 Leak test shall be performed on each sealed source every I six (6) months. l 3.2 Sources transferred to the Company shall be accompanied by I a current Certification of Sealed Source and Leak Test Anal-l ys is (Semi-Annual), containing the follcwing, or be sub-j ected to retesting. j 3.2.1 Nuclide. 3.2.2 Source se rial number (S/N). 3.2.3 Activity. 3.2.4 Date sample collected. 3.2.5 Date of analys is. 3.3 Industrial Nuclear Company shall perform the leak test anal-ysis and certification of sealed sources with the following exceptions. 3.3.1

RSO, or designated individuals, shall perform such test of Iridium-192 and/or Cobalt-60 sources.

The leak test kit furnished by the analyzing laboratory will be used. 3.3.2 Supplier performing source changes and/or maintenance. 3.4 Retest Notification The RSD is responsible for implement-ing the action for leak testing. RSO/RSD may direct the de-vice containing the sealed source be returned, or the Project Manager / Supervisor, or designated individuals, to perform the leak test per the instructions on Form 505. NO. TITLE REV. PAGE UST - VII LEAK TESTING PROCEDURE 985-0 1 of 2

) - - -. RADIATION SAFETY PROGRAM 3.5 Any analyses that show a level of contamination of.005 mi-cro curies or greater, constitutes a Class A Incident. The RSD shall immediately implement the required emergency ac-tion. 3.6 Each report will be reviewed and filed by the RSD. 3.7 RSD will supply a copy of the analysis to the pr oj e ct to which the source is assigned. i PAGE REV TITLE NO. 2 of 2 985-0 LEAK TESTING PROCEDURE UST - VII

1 Unitech Services Group RADIATION SAFETY PROGRAM l UST 985 l l SECTION VIII QUALIFICATION PROCEDURE 'l l I I l 985-0 Original Issue T11C 09/30/85 l RE/151CM EFFECTIVE l RO' DESCRIPT!CN BY DATE --_-___a

i ( 1 RADIATION SAFETY PROGRAM Assure personnel are competent in radiation 1.0 OBJECTIVE safety to the level required by their job assignment. 2.0 APPLICATION - U.S. Testing,. Unitech Services Group (Company) personnel. 3.0 PROCEDURE 3.1 Definitions 3.1.1 Qualification - Compliance with the requirements of certifi-cation. 3.1.2 Certification - Writ ten tes timony of qualifications. 3.1.3 Certifying Agency - U.S. Testing, Unitech' Services Group. j 3.1.4 Radiographer Trainee - An employee who is in training. for I the position of Assistant Radiographer. 3.1.5 Assistant Radiographer - An individual who uses radiograph-ic exposure devices, sealed sources, related handling. tools and survey instruments' while under the personal supervision of a Radiographer, and is certified in accordance with this procedure. 3.1.6 Radiographer - An individual who performs radiography or is in attendance at the radiography site to personally super-vise radiographic operations. The Radiographer is directly responsible. to the Radiation Saf ety Of ficer (RS0) for assur-ing that ' radiography is performed in accordance with the Program and is certified in accordance with this procedure. 3.1.7 Project Manager / Supervisor - The administrative head of each project with extensive experience in radiation safety and may be certified Radiographer who performs training and examina-tion of Trainees, Assistant Radiographer and Radiographer as authorized by the RSD. 3.1.7.1 Project Managers / Supervisors, authorized to perform training (formal) and examination of radiographer, shall be' required to complete the examination requirements of a Monitor in ac-cordance with this procedure. NO. TITLE REV. PAGE UST - VIII QUALIFICATION PROCEDURE 985-0 1 of 8

( ) u- ~ %. RADIATION SAFETY PROGRAM 3.1.8 Monitor - An individual with extensive experience and train-ing in radiation safety who has been appointed, as re-quired, to assist the Project Manager / Supervisor in maintain-ing a high standard of radiation safety. Monitors are direct-ly responsible for assuring that radiography is performed in accordance with the Program. He performs training and'exami-nation of Radiographer Trainees, Assistant Radiographer and i Radiographer and is certified in accordance with this proce- { dure. 3.1.9 Radiation Safety Of ficer - An individual with extensive exper-ience in radiation safety who performs training and examina-tion of Radiographer Trainees, Assistant Radiographer, Ra-biographers and Monitors and shall meet the qualification of this procedure in accordance with the requirements of the RSO. 3.2 Authority - The radiation safety portion of personnel quali-fication and certification shall be vested with the RSD. 3.3 Levels of Qualification 3.3.1 Radiographer Trainee - All Trainees shall be trained in ba-sic radiation saf ety as specified in Procedure IX, Train-ing. The employee shall be required. to complete a. writ ten quiz prior to starting the on-the-job training assignment. ( 3.3.2 Assistant Radiographer The radiation saf ety. requirements - f or an Assistant Radiographer are as follows. a) Minimum age - 18 years. b) No known history of previous radiation exposures which would prohibit or cause restriction of activity. c) Free from physical handicaps which could endanger him-self/herself or others during perf ormance of the job. d) Completion of the radiation saf ety' t raining require-ments for Assistant Radiographer as defined in Proce-dure IX, Training. e) Satisfactory comple.tio n of the Assistant Radiographer examinations. PAGE-REV TITLE NO. 2 a# $ @es-@ annisveavvam maemmea a v - WERT

RADIATION SAFETY PROGRAM 3.3.3 Radiographer - The radiation safety requirements for a Ra-diographer are as follows. a) Previous qualification as an Assistant Radiographer or compliance with b), c) and d) below. b) A minimum of three (3) months expe ri e nc e as an Assis-tant Radiographer. c) Completion of the radiation safety training require-ments for Radiographer as defined in Procedure. IX,- Training. Note: Consideration may be taken to substitute formal documented education to fulfill the required hours of instruction on a case basis approved by the RSO/RSD. Formal education to have-been com-pleted by an authorized educational facility. d) Satisfactory comple tio n of the Radiographer examina-I tions. 3.3.4 Monitor The radiation safety requirements for a Monitor are as follows. a) Certified Radiographer. b) Satisfactory experience (minimum one (1) year) in indus-trial radiography involved in isotope handling, as ap-proved by the RSD. 3.3.5 Radiation Safety Of ficer (RS0) - The radiation saf ety require-ments for a RSO are as follows. a) Previous qualification as a Radiographer. b) A minimum of five (5) years experience in industrial ra-diography with at least two (2) years involved in iso-tope handling. Equivalent experience and. education may be substituted to fulfill this requirement on a case ba-sis approved by the RSD. If the " equivalent" method is used, a written justification for this action shall be retained in the employee's personnel file. c) Completion of the radiation safety training require-ments in Procedure IX, Training. NO. TITLE REV. PAGE UST - VIII QUALIFICATION PROCEDURE 985-0 3 of 8-

( - - =.o RADIATION SAFETY PROGRAM 1 3.4 Examination A five (5) question written quiz 3.4.1 Radiographer Trainee will be given to each Trainee. It will be directed toward avoiding accidental e x po sur e. An oral review will also be used to assure the points are ' understood. This quiz will be conducted and evaluated by a qualified individual. 3.4.2 Assistant Radiographer a) General - The general examination shall contain a mini-mum of 10 questions on. basic radiation safety (closed book). b) Specific - The specific examination shall contain a min-imum of 15 questions on the Operating and Emergency Pro-cedures (06E P) (open book). c) Practical - The practical examination shall measure the employee's proficiency in performing required func-tions. Individuals will be required to demonstrate com-petence to use the radiographic exposure

devices, sealed sources, related handling tools and survey - in-struments.

d) Oral Review - An oral review shall' be conducted with-the employee to clarify any questions -and. correct misunder-standings. e) Examinations will be administered and evaluated by a qualified individual. f) The RSD shall review the examinations prior to issuance of certification. 3.4.3' Radiographer a) General The general examination shall contain at least 20 questions on basic radiation safety (closed book). b) Specific The specific examination shall contain at least 30 questions (open book) based on: 1) 06E P, PAGE REV TITLE NO. 4 of 8 985-0 QUALIFICATION PROCEDURE-UST - VIII

( ) ~ ~ ~e RADIATION SAFETY PROGRAM 2) 10CFR20 and 10CFR34, and 3) Exposure Devices and Survey Meters. c) Practical The practical examination shall measure the employee's proficiency in performing required func-tions. Individuals will be required to demonstrate com-i petence to use the radiographic exposure

devices, sealed sources, related handling tools and survey in-struments.

j d) Oral Review - An oral review shall be conducted with the employee to clarify any questions and correct misunder-standings. e) Examinations will be administered and evaluated by a qualified individual. 1 l f) The RSD shall review the examinations prior to issuance I of certification. I 3.4.4 Monitor a) General The general examination shall contain at least 20 questions on principles of radiation safety i l (closed book). b) Specific The specific examination shall contain at least 50 questions (open book) based on: 1) OSE P; ) 10CFR20 and 10CFR34; and 3) conducting and evaluating examinations. l c) Practical - The practical examination shall measure the Examiner's proficiency in performing required functions as defined in the 06E P, including instructing person-nel in the saf e use of radiographic equipment. d) Oral Review - An oral review shall be conducted to eval-uate the Examiner's understanding of the radiation safe-ty philosophy used by the Company. This philosophy is implemented through the 06E P. l NO. TITLE REV. PAGE UST - VIII QUALIFICATION PROCEDURE 985-0 5 of 8

i - - o.. RADIATION SAFETY PROGRAM e) Examinations will be administered and evaluated by a qualified individual. f) The RSD shall review the examinations prior to issuance of certification. Passing grade for the general and specific 3.5 Passing Grade examinations for all certifications will be 70 percent or greater. Certification can be disapproved for inability to demonstrate understanding and/or knowledge of safety re- ) quirements. 1 3.6 Re-examination - Re-examination, af ter failure of an employ-J ee to satisf actorily complete a certification examination, shall not be conducted without a reasonable retraining peri-od. The period shall be determined by the person who con-ducted the original examination and approved by the RSO/RSD. The RSD's authority for issuing certifica-I 3.7 Certification tions for all certifications shall not be delegated. 3.7.1 Certification Restrictions and Extensions a) Restrictions may be placed on a certification as deemed necessary by the RSO/RSD. Restrictions shall, in no case, constitute a waiver of the requirements of

10CFR20, 10CFR34 or the OSE P.

b) Extensions may be added to the certification as testimo-ny of cap bilities beyond the requirements of that lev-el. Extensions will require the employee be trained and demonstrate to the RSD competence in understanding and performing the required function. Documentation of such capability shall become a part of the employee's personnel record. 3.7.2 Personnel Records - The personnel records of a Radiographer Trainee shall contain: a) nane of certified individual; I b) level of certification c) statement indicating satisf actory completion of the re-quirements in Procedure IX, Training; l l l i PAGE_ _REV __ _____ TITLE _ _ _ _ _ _ _ NO._ _ j

v - w. RADIATION SAFETY PROGRAM d) date of certification; e) sigrature of RSD; f) copy of the examination taken. The-personnel records of all other cer-3.7.3 Personnel Records tified individuals shall include: a) name of. certified individual; b) level of certification; c) educational background and experience; d) statement indicating satisf actory completion of the re-quirements in Procedure IX, Training;- e) actual grades obtained on each examination; f) date of certification and/or decertification. g) signature of RSD. 3.7.4 Certification Card - Certification cards will be issued (ex-cept to Trainees) in accordance with Procedure XIII, Forms'. Radiographer shall be decertified at i 3.8 Recertifications least onTe every three -(3) years by one (1) of the follow-ing criteria. 3.8.1 Evidence of continuing satisfactory performance as subs ta n-tiated by audits. ~ 3.8.2 Re-examination in accordance with the original examination requirements or an alternate ' method approved by the RSD. 3.8.3 Decertification examinations can be administered by individ-uals designated by the RSD. 3.9 Certification Withdrawals. - The RSD shall have the author-ity to withdraw certifications for: a) violation of. safety procedures or disregard for safety practices; NO. TITLE REV. PAGE UST - VIII QUALIFICATION PROCEDURE 985-0 7 of 8

( --~ RADIATION SAFETY PROGRAM b) inability to demonstrate correct procedures during au-dits; c) reassignment to functions no longer requiring the certi-fication; d) termination of the employee. I l t l l l l l l l l l PAGE REV TITLE' NO. 8 of 8 985-0 QUALIFICATION PROCEDURE UST - VIII

i , i. SY,'. 1% t l Unitech Services Group l RADIATION SAFETY PROGRAM UST 985 i-SECTION IX TRAINING PROCEDURE l 985-0 l Original Issue TWC 09/30/85 l REmten EFFECTIVE NO. DESCRIPTION BY DATE

)mmm RADIATION SAFETY PROGRAM-Its

function, necessity, how it is 2)

Film Badge used and the importance of its being worn on the job at all times. 3) Dose Rate - R/hr. and mr/hr. 4) Radiation Survey Meters - Their function, operation and necessity in radiography,

Time, distance and 5)

Controlling Radiation Dose shielding. 3.1.1 At the time of presentation of the lecture, the Trainee is issued a film badge. 3.1.2 Upon completion of the four (4) hours of informative in-struction, the Trainee is given' a written Basic Radiation Quiz and an oral review on basic radiation safety. This is to verify understanding of the subjects covered as listed above. 3.1.3 A minimum of two (2) weeks (80 hours) of documented on-the-job training shall be required before a Trainee can become qualified for the position or title of Assistant Radiograph-er. During this period of on-the-job training, the Trainee shall not act in the capacity of handling and/or using sources. 3.1.4 The on-the-job training period includes' coverage of the fol-lowing subjects. a) Operating and Emergency Procedures (OSE P) 1) The Trainee shall be instructed in each section-of the OSE P using the procedures as the text for this instruction. This instruction shall include 12 hours of classroom training and will be given by a Radio-grapher, Monitor or Project Manager / Supervisor. Un-derstanding of the procedures shall be attested to 1 by the successful completion of the General, Specific and Practical examinations for Assistant' Radiograph-er in radiation safety. 2) The OSE P shall be made available to the Trainee and referred to - whenever needed for clarification and understanding of th'e procedures. PAGE REV TITLE NO. 2.of 10 985-0 TRAINING PROCEDURE. UST IX

m-a~ RADIATION SAFETY PROGRAM l The objective 'o f this procedure is to as'su r e 1.0 OBJECTIVE consistent training of personnel and to verify the under- ~; standing of training by both examination and demonstration. This verification will be by written examination and oral review. The training procedure is cutlined in detail to provide qualified training for all levels of responsibility in radiation safety. l 2.0 APPLICATION - U.S. Tes ting, Unitech Services Group (Company) radiographic personnel. 3.0 PROCEDURE - The training program is presented in the follow-ing sequence to provide t raining areas commensurate with I the employee's responsibility and the extent of the radia-l tion danger involved, a) Radiographer Trainee No previous experience with _ or in the field of radiography. Training to become an As-sistant Radiographer. b) Assistant Radiographer Training to become a Radio-grapher. c) Radiographer Periodic training as outlined in Para-l graph 3.3. 1 1 Periodic training as c.utlined in Paragraph j d) Monitors 3.3. j e) Radiation Safety Officer - Periodic training as outlined 1 in Paragraph 3.4. 3.1 Radiographer Trainee - No previous experience. Radiograph-er Trainees are given a four (4) hour lecture of informa-tive instruction. This instruction is given by a RSO, Monitor or Proj ect Manager / Supervisor. The lecture includes cover-- age of the following subj ects. a) Basic Radiation Safety i b) Needs and Requirements for Personnel Monitoring 1.) Dosimeter Its functions, necessity,. how it is used and the importance of it being carried at all times when on the job. NO. TITLE REV. PAGE UST - IX TRAINING PROCEDURE 985-0 1 of 10

( iu- ~ ~ RADIATION SAFETY PROGRAM 4) Radioactive isotopes. 5) Curie. i 6) Roentgen. 7) Decay and hal f-life. This is a description of Basic Radiation Phys ics with j emphasis placed on the origin of gamma radiation and ra-1 dioisotope decay process. The approximate time fo r this presentation is one (1) hour, b) Characteristics of X-Rays and Gamma Rays 1) Energy. 2) Wavelength. 3) Intensity. 4) Elect romagnetic spect rum. This is a discussion of the relationship between energy and penetration characteristics. The approximate time for this presentation is one-half (1/2) hour. + c) Interaction of Radiation with Matter 1) Penetration. 2) Absorption. l 3) Scatter. i 4) Ionization. 5) Bremsstrahlung. 6) Half and tenth value layers (shielding). A general description of the various forms of ioniza-tions and the use of half and tenth value layer calcula-tions for shielding. The approximate time for this pre-1 l sentation is one (1) hour. PAGE REV TITLE NO. 4 of 10 985-0 TRAINING PROCEDURE UST - IX

i l ( ~%% RADIATION SAPETY PROGRAM b) Radiography Equipment 1) The Trainee shall be instructed in the use of radio-I graphy equipment by using the manuf acturers' operat-ing manuals as a text for instruction. This in-i struction shall be given by a Radiographer, Monitor { or Project Manager / Supervisor. j l 2) The Trainee shall be assigned to a radiography team { and will observe the operations, procedures and techniques used by the team and shall not act in the capacity of handling or using. radioactive sources during this two (2) week training period. ) 3.1.5 After completion of two (2) weeks (80 hours) on-the-job train-ing, the Trainee will be eligible for a written examination 4 and an oral review. In addition, the Trainee must satisfac-torily demonstrate com petence to use, under the instructions of a Radiographer, radiographic exposure devices, radiation survey instruments, sealed sources and related handling -tools which will be used in per forming duties -as an Assistant Ra-diagrapher. 3.1.6 Upon successful completion of the writ ten examination, oral review, and demonstration, the Trainee becomes eligible for certification as an Assistant Radiographer. After at least three (3) months 3.2 Assistant ' Radiographer on-the-job training as an Assistant Radiographer, the em-ployee becomes eligible for advancement to the position of Radiographer upon successful completion of 'the.following training procedure. 3.2.1 A lecture totaling 24 hours of instruction and demonstra-tion is given to all Assistants before they can become Ra-biographers. This lecture and demonstration include cover-age of the following subj ects. a) Origin and Nature of Radiation 1) Structure of the atom. 2) Periodic table of elements. 3) Isotope. NO. TITLE -REV. PAGE i UST - IX TRAINING PROCEDURE '985-0 3 o f 10

i--~ RADIATION SAFETY PROGRAM 6) Equipment calibration. 7) Operations. 8) Limitations. A general description of dosimetry, monitoring devices and techniques. The approximate time for this presenta-tion is two (2) hours. h) Survey Techniques 1) Safe Storage Position. 2) Boundaries of restricted area. 3) Storage facilities. 4) Transporting vehicles. ] 5) Radiographic exposure or storage container. A general description of how and when surveys should be made, what should be surveyed, acceptable levels and re-cords required. The approximate time for the presenta-tion is two (2) hours. i) Radiographic Equipment 1) Exposure devices. 2) Storage containers. 3) Remote handling equipment. 4) Operation and control of x-ray equipment (i f appli-ca bl e ). 5) Inspection and maintenance performed. This presentation is to cover description, demonstra-tion, inspection and maintenance of devices and equip-ment. The approximate time for this presentation is two (2) hours. PAGE REV TITLE NO. 6 o f 10 985-0 TRAINING PROCEDURE UST - IX l

W una asmo cme i i RADIATION SAFETY PROGRAM 1 d) Biological Effects of Radiation 1) Effect of radiation on the organs and tissues,of-the body. 2) Nature and consequences of radiation exposure. The approximate time for this presentation is one' and one-half (1 1/2) hours. i e) Unit s of Radiation Dose 1) Dose rate R/hr. ) 2) Level of radiation from licensed material. 3) REM. The approximate time for this presentation is one (1) hour. f) Methods of Controlling Radiation Dose l 1) Inverse square law. ) 1 2) Time. 3) Distance. 4) Shielding. This is a general description of radiation control prin-cioles. The approximate time for this presentation is two (2) hours. ~ g) Radiation Detection and Measurement 1) Purpose of dosimetry. 2) Dosimeters. 3) Film badges. t 4) Survey meters. 5) Survey techniques. NO. TITLE REV PAGE UST - IX TRAINING PROCEDURE 985-0 5 of 10

_ ( ~~~ RADIATION SAPETY PROGRAM b) Conduct the course in the sequence outlined in Pa ra - graph 3.2 of this procedure. c) Each subject in the outline will be covered within the scope specified. d) Each item in the outline will be covered to the extent s pec i fi ed. Radiographer' shall complete a refresher 3.3 Radiographer training and rece rt i fi ca t i on every three (3) years and/or i when deemed necessary by the RSD because of changes in Nu-clear Regulatory Commission (NRC ) and/or Agreement State Regulations, equipment and OSE P. Upon satisfactory comple-tion of the ref resher ' training, the Radiographer is eligi-ble for decertification.(Procedure VIII, Paragraph 3.8). 3.3.1' The RSD and/or RSO shall conduct-yearly ref resher training for Proj ect Managers / Supervisors because of chan ge, s in NRC and/or Agreement States Regulations, equipment and Compa-ny's OSE P. 3.4 Radiation Safety Officer - Training requirements for RSO in-clude, but are not limited to, the following. 3.4.1 The satisfactory completion of requirements, in accordance with Procedure VIII, Qualification and Certification. 3.4.2 Satisfactory completion of training. covering general and specific areas as follows. a) Principles of radiation safety. b) OSE P. c) State and Pederal regulations. d) Conducting and evaluating examinations. e) Expected radiation levels during various' operations. f) Detection of equipment defects and/or malfunctions. g) Identification of hazardous situations. PAGE REV TITLE NO.. 8 of 10 985-0 TRAINING PROCEDURE' UST IX

u- - o, RADIATION SAFETY PROGRAM j) Case Histories of Radiography Accidents (Events) ' A general review of radiation o verexpos ures, unnecessary exposures and other unusual events associated with r.a - diography o p e ra t ions. The a ppro xima t e time for this presentation is two (2) hours. k) Transfer, Packaging and Transport of Radioactive Materi-a,1, 1) Company and DOT regulations. 2) Public highways / exclusive use vehicle. 3) Placarding. 4) Surveys / radiation levels. The approximate time for this presentation is two (2) hours. 1) Requirements of Federal or Agreement' States Regulations - This is on interpretation of pertinent regulations. The approximate time for this presentation is two (2)

hours, m)

Term s and Conditions of the Radioactive Material 'Li-The approximate time for this presentation is-cense one (1) hour, n) Instruction of the Requirements of UST/USG's Program with E xmpha s i s on the 06E P This instruction is in addi-tion to that given on-the-job. The approximate time of ~ this presentation is four (4) hours. 3.2.2 Upon completion of the 24 hours of instruction, demonstra-tion and examination, the Assistant is eligible for certifi-cation as a Radiographer. 3.2.3 The guidelines for conducting training will be as follows. a) The course of instruction will be completed within a reasonable period of time. In the event the course is not completed within the time frame, as dete rmined by the Rad:.ation Safety Director (RSD), it will be neces-sary to begin the instruction over again. NO. TITLE-REY. PAGE UST - IX TRAINING PROCEDURE 985-0 7 e f 10

i ) - - w. RADIATION SAFETY PROGRAM 3.5.3.1 Upon completion of these requirements, radiographic pe r so n-nel with previous experience will be eligible for certifica-tion to t:1e level for which they are qualified. i PAGE REV TITLE NO. 10 of 10 985-0 TRAINING PROCEDURE UST - IX

1 1 l 3 Unitech Services Group l RADIATION SAFETY PROGRAM UST 985 i SECTION X AUDIT PROCEDURE 985-0 Original Issue TWC 09/30/85 REV!LIGN EFFECTIVE N0* DESCRIPTICH BY DATE

I .e 4 }} u- ~ ~ l RADIATION SAFETY PROGRAM 1.0 OBJECTIVE - The audit provides continuing surveillance to insure compliance with Federal, State and Company radiation safety regulations and timely information to management re-4 garding the eff ectiveness of activities which affect radia-tion safety. 2.0 APPLICATION - U.S. Testing, Unitech Services Group (Company) proj ects and laboratories. 3.0 PROCEDURE - The Radiation Saf ety Director (RSD) is responsi-l bl e for planning, scheduling, conducting and follow-up of l radiation safety audits. The categories of audits to be I performed are: System, Facilities, Equipment and Person-nel. 3.1 System Audits are performed to determine adequacy of the ra-diation safety system. 3.1.1 Audit checklists shall be used to assure consistent evalua-tion of all areas of radiation safety. 3.1.2 Each project and laboratory shall be audited at least annu-ally for compliance with the radiation safety system. 3.2 Facilities and Eouipment Audits are designed to reduce radi-l ation safety incidents resulting from equipment failures. l 3.2.1 On-site audits of facilities and equipment shall be per-formed with checklists for compliance with procedures. 3.2.2 Audits will be performed for documentation of maintenance and calib-ration records in the RSD's office and' in the field. 3.3 Pe r so nnel Audits will assure consistent training and verify that only qualified employees are performing radiography. 3.3.1 Audits of personnel will use checklists to verify compli-ance with training. 3.3.2 Personnel will be checked to insure that work being per-formed is within the limits of their qualification. NO. TITLE REV. PAGE F7T - X AUDIT PROCEDURE 985-0 1 of 3

( ~%~ RADIATION SAFETY PROGRAM 3.3.3 Personel audits shall be conducted for certified Radicgraph-ers and Assistant Radiographer at intervals not to exceed three (3) months. a) Individuals failing to be audited within three (3) months of the due date will be subject to having their certifica-tion temporarily revoked. .) Certifications being revoked shall remain so until au-1 dited and reinstated by the RSD. 3.3.4 Individuals being certified by examination shall be immedi-l ately audited af ter receiving c_ certification. j 3.4 Audits will be planned and scheduled-by the RSD. 3.4.1 Audit planning delineates procedures, forms and checklists j to be used and identifies specific areas of emphasis. 3.4.2 A schedule of audits shall be maintained by the RSO/RSD. This schedule should show status of audits: planned, in process or complete. 3.5 Audits will be performed by designated representatives _ as follows. 3.5.1 System, Fatility and Equipment Audit s) President; b) Vice President; c) RSD; d) RS0; e) Quality Control Manager; or f) Individual (s) designated by the RSD. Note: Designated individuals shall be a certified radio- ~ grapher with at least one (1) year of experience in. isotope handling. The individual shall also have been given a letter, from the RSD, authorizing him/her to act in the capacity _of management. l PAGE REV TITLE NO. 2 of 3 985-0 AUDIT-PROCEDURE-UST - X

N Serame Gous RADIATION SAFETY PROGRAM 3.5.2 Personnel Audits a) Individual as listed in Paragraph 3.5.1. b) Project Manager / Supervisor, c) Monitors. 3.5.3 Audits may be announced or unannounced. 3.6 All audits will be doc umen t e d with reports filed in the RSD's office. 3.7 Radiation Safety Of ficers, Monitors, or designated representa-tives, should conduct spot inspections in addition to sched-uled audits. 3.8 Project Managers / Supervisors should establish frequent unan-nounced inspections of their operations for compliance with all safety procedures and records shall be maintained. 3.9 Deficiencies found by an audit will be reviewed by the RSO and RSD for appropriate corrective action taken. NO. TITLE REV. PAGE UST - X AUDIT PROCEDURE 985-0 3 of 3 __A

v'Y.'. 1 2 1 1 1 Unitech Services Group RADIATION SAFETY PROGRAM UST 985 1 SECTION XI CORRECTIVE ACTION PROCEDURE 1 I i l l l 985-0 Original Issue TWC 09/30/85 i l l l l GM j EFFECTIVE e MO. DESCRIPT!CN BY DATE

I I u- % %. l 4 1 I RADIATION SAFETY PROGRAM 1 l 1 To assure positive action is taken to prevent 1.0 OBJECTIVE recurrence of incidents, hazardous conditions and audit de-ficiencies. To provide a system of determining causes.of adverse conditions and verifying the effectiveness of cor-rective actions. 2.0 APPLICATION - U.S. Tes ting, Unitech Services Group (Company) personnel proj ects and laboratories. 3.0 PROCEDURE - Corrective action shall be applied to.all radia-tion incidents, radiation hazardous conditions and audit de-ficiencies as nec es sa ry in the judgment of the Radiation Safety Director (RSD). 3.1 All radiation incidents shall be docume'nted, analyzed as to cause and appropriate corrective action assigned. 3.1.1 All corrective action to incidents shall be in writing and approved by the RSO/RSD and shall consist of the following: a) the corrective steps which have been taken and the re-sults achieved; I b) corrective steps which will be taken to avoid further occurrence; 1 .1 c) the date when full compliance will be achieved. 3.1.2 Follow-up to assure compliance shall be documented to pro-vide feedback and prevent recurrence. j i 3.2 All radiation hazardous conditions shall be reported.to the RSO/RSD for review and assignment of formal corrective action. 3.3 All audit deficiencies shall be reviewed and, where signifi- ) cant, formal corrective action shall be executed at the dis-cretion of the Radiation Saf ety Director. 3.4 RSD shall assure that adequate corrective action is accom-plished to eliminate the causes of discrepancies and to pre-u vent the recurrence of simflar discrepancies. 3.5 RSD shall maintain a log of all formal corrective actions i with current status of follow-up and/or audit. 1 1 NO. TITLE REV. PAGE .UST - XI CORRECTIVE ACTION PROCEDURE 985-0 1'of 2 l o

I (f ) m--is i RADIATION SAFETY PROGRAM 3.6 1.e RSO/RSD shall schedule appropriate re-audit s to determine effectiveness of corrective measures. 3.7 Formal corrective action distribution should include the President and Vice President. 3.8 Noncompliance with RSD's corrective action directions shall be resolved with the Executive Safety Committee. PAGE REV TITLE NO. 2 of 2 985-0 CORRECTIVE ACTION PROCEDURE UST - XI J

1 l Unitech Services Group RADIATION SAFETY PROGRAM UST 985 SECTION XII l DOCUMENTATION PROCEDURE 985-0 Original Issue TWC 09/30/8S l i REVISICN EFFECTIVE M0. DESCR!PTICN BY DATE ~ --~

j (h)"--* l l RADIATION SAFETY PROGRAM 1 1.0 OBJECTIVE - To maintain a complete, current record system l which will control changes, assure scheduling and document l significant occurrences. l 1 l 2.0 APPLICATION - Procedures, f o rm s, practices, certifications l and schedules. { l 3.0 PROCEDURE 3.1 Program procedure masters shall be maintained by the Radia-tion Safety Director (RSD) with the latest revisions. 3.1.1 Effective date of procedural changes shall be established l by the RSD. l 3.1.2 Program revisions and equipment or facility changes, requir-ing Nuclear Regulatory Commission (NRC) notification and/or approval, shall be coordinated by the RSD. I 3.1.3 Prof. revisions shall be accomplished by printing with a I new distinctive cover identification. 3.1.4 The RSO/RSD is responsible for transmittal of revisions to all affected personnel. 3.2 Notification of required maintenance will be sent by the RSD with appropriate records prior to due date. 3.2.1 Completed records of performance of maintenance shall be processed and filed in the RSD's office. 3.3 Calibration records and calibration schedules are the re-sponsibility of the RSD. 3.4 Personnel Radiation Safety Certification records are the re-sponsibility of the RSD. 3.4.1 All personnel examinations, and re-examinations relative to radiation safety, shall be on file in the RS0's office. 3.5 Incident documentation and records of appropriate and time-ly not i fi ca t i on of Federal, State and Company officials shall be the responsibility of the RSD. NO. TITLE REV. PAGE UST - XII DOCUMENTATION PROCEDURE 985-0 1 of 2

,, ~~ ) ~ ~ w, RADIATION SAFETY PROGRAM 3.6 The filing and control of audit schedules and audit reports shall be the responsibility of the RSD. 3.7 Records of corrective action notification and schedule of follow-ups shall be maintained by the RSD. i l i l i PAGE REV TITLE NO. 2 of 2 985-0 DOCUMENTATION PROCEDURE UST - XII

.\\ e Unitech Services Group I l l RADIATION SAFETY PROGRAM l l UST 985 SECTION XIII FORMS PROCEDURE I i l 985-0 Original Issue T11C 09/30/85 i i j AEVISICN DESCRIPTICH BY DA

_-_-------y u- - w. RADIATION SAFETY PROGRAM 1 l Define the procedure for organization, use and 1.0 OBJECTIVE control of forms. Forms required and recommended ' for operation I 2.0 APPLICATION of the Program are included as appendices to.this proce- ) dure. The time and manner of application are defined in -) other procedures of the Program. 1 3.0 PROCEDURE l 3.1 Origination of new forms shall be at the ' direction, and ) with the approval of, the Radiation' Safety Director (RSD). 3.2 Revisions of forms shall be identified by sequential letter changes. All changes shall be approved by the RSD. 3.3 Effective date of changes will be determined by the RSD. 3.4 Form instructions and distribution are found on the reverse-side of forms, a.s applicable. 3.5 Forms used by the Radiographer are also included in the Op-erating and Emergency Procedures (OSE P). 'l 1 l l l l l NO. TITLE REV. PAGE UST-XIII FORMS PROCEDURE 985-0 1.of 1

I w um-om l I FORMS INDEX l Form No. Description 501a Audit - System, Facilities and Equipment 501b Audit - Personnel 502a Exposure Device Inspection (Quarterly) 502b X-Ray Equipment InsFection (Quarterly) 503 Inspection of Shielded Room (Semi-Annual) 504 Exposure Device Maintenance Checklist l 505 Set ' Source - Leak Testing (Semi-Annual) 506 X-Ray Equipment Inventory (Quarterly) 507 Sealed Sources Inventory (Quarterly) ) 508 Survey Instrument Maintenance and Calibration (Quarterly) l 510 Radiation Safety Meeting - Monthly Record 511 Radiation Survey Report Storage Area 512 Radioactive Material Shipping Document - Company (Exclusive-Use) Vehicle 513 Film Badge Control 514 Source Receipt, Transfer and Disposal Record Page i of i

h )) u--~~. AUDIT SYSTEM, FACILITIES AND EQUIPMENT RADIATION SAFETY Jobsite: Date: Project Manager: Enter in Space Provided Yes, No, N/A, Remarks RADIATION SAFETY PROGRAM 1. Radiation Safety Program at site? 2. Is the Program available for personnel review? 3. Does the Program contain the NRC License? a) Latest amendment number available 4. Does the Program contain a State License? a) Latest amendment number available 5. Does the Program contain the latest 10CFR19, 10CFR 20, 10CFR21 and 10CFR34? POSTING REQUIREMENTS 6. Notice to Employees - Form NRC-3 7. Notice to Employees - State 8. Emergency Phone Numbers 9. Requirements of

10CFR19, 10CFR21 and Agreement States 10.

Section 206 (ERA 1974) TRAINING 11. Monthly radiation safety meeting held? 12. NRC case history discussed? Form S01a Page 1 of 4

13. Training in transfer, packaging and transport of radioactive material being conducted? 14. Records of topics discussed and personnel in atten-dance available? (Items 11, 12 and 13) 15. Personnel adequately trained to the level for which they are qualified? PERSONNEL 16. Current personnel radiation safety certification on file? 17. Copies of Personnel Audits on file? 18. Personnel know who to contact in case of an emer-gency? 19. Personnel's knowledge of State and/or Federal regu-lations/ license adequate? 20. Frequent unannounced inspections conducted and re-cords maintained? MONITORING DEVICES 21. Film badges and dosimeters being properly used and worn by personnel? 22. Film badges being properly stored during nonwork-ing hours? 23. Are dosimeters in current calibration? j 'f 24. Are dosimeters being zeroed prior to work shift? 25. Survey meters in current calibration, operational and being used properly? 26. Dosimeter charger (s) in good order and operational? 27. Permanent source room (s) signal or warning devices and interlocks operable? 1 Form 501a Page 2 of 4

( u- ~ ~ x RECORDS 28. Film badge reports on file? 29. Radiation Safety Reports? 30. Quarterly Inventories? 31. Leak Test Certificate? l 32. Survey' Meter Calibration Reports? 33. Source Decay Charts? 34. Exposure Device Inspection (Quarterly)? 35. Radiation Safety Training Program? 36. Source Receipt and Transfer Report (s)? 37. Previous jobsite audit reports on flie? 38. Source Shipment Documentation?- l RADIATION AREAS 39. Radiation areas adequately. controlled and posted? l 40. High radiation areas posted? 41. Storage areas being surveyed? 42. Vehicle storage adequate? EXPOSURE DEVICE / EQUIPMENT 43. Is exposure device / equipment properly maintained? 44. Equipment properly labeled? 45. Equipment being handled and used properly? ~46. Exposure device / equipment inspected and surveyed prior to use? 47. Qualified personnel using exposure devices? 48. Exposure devices placed in storage areas when not in use? Form 501a Page 3 of 4-

l 49. Are collimators being used? 50. Are storage areas locked? 51. Are Radiographer instructed in the proper

use, handling and control of equipment?

Remarks ( ) No items of noncompliance or unsafe conditions found. Items of noncompliance: 1. ( ) 10. ( ) 19. ( ) 28. ( ) 36. ( )

44. (

) 2. ( ) 11. ( ) 20. ( ) 29. ( ) 37. ( )

45. (

) 3. ( ) 12. ( ) 21. ( ) 30. ( ) 38. ( )

46. (

) 4. ( ) 13. ( ) 22. ( ) 31. ( ) 39. ( )

47. (

) 5. ( ) 14. ( ) 23. ( ) 32. ( ) 40 ( )

48. (

) 6. ( ) 15. ( ) 24. ( ) 33. ( ) 41. ( )

49. (

) 7 ( ) 16. ( ) 75. ( ) 34. ( ) 42. ( )

50. (

) 8. ( ) 17. ( ) 26. ( ) 35. ( ) 43. ( )

51. (

) 9. ( ) 18. ( ) 27. ( ) Were items of noncompliance discussed with the Manager? Yes ( ) No ( ) Audit Conducted By: m cc: Radiation Safety Officer Jobsite File Form 501a Page 4 of 4 ~

(SDg ""'""""" " I AUDIT PERSONNEL RADIATION SAFETY Jobsite: Date: Individual: Radiographer ( ) Assistant Radiographer ( ) Enter in Space Provided Yes, No, N/A, Remarks PERSONNEL 1. Copy of individual's certification on file? 2. Certification card on person? 3. Individual has on person a current film badge and dosimeter? 4. Film badge / dosimeter worn on the belt or waist hand? 5. Dosimeter in current calibration? a) Serial Number b) Calibration Due Date c) mr Reading 6. Is a copy of the 06E P available to the individu-al? 7. Individual knows who to contact in case of an emer-gency (four (4) key steps)? 8. Individual has knowledge of State and/or Federal regulations / license? 9. Has individual attended recent safety meetings? 10. Individual's knowledge of radiation safety adequate? PAPERWORK 11. Radiographer / Assistant Radiographer have a copy of Radiation Safety Report? 12. Daily inspection of the exposure device completed prior to use? 13. Dosimeter readings, in and/or out, logged on Radia-tion Safety Report? 14. Physical radiation survey (s) completed as required? 15. Utilization Log completed as required? Form 501b Page 1 of 2

/ 1 / RADIATION AREAS 16. Is the restricted area properly established and posted? 17. Is continuous and direct surveillance of the area being performed during exposures? 18. Is the high radiation area posted? 19. Is a survey meter present, operable, calibrated and being used as required? EXPOSURE DEVICE / EQUIPMENT 20. Exposure Device Type -- Model S/N Curies 21. Was the exposure device / equipment inspected prior to use? [ 22. Was a survey performed when removed from storage? L j 23. Is the equipment being handled and used properly? 24. Is the exposure device left unattended? 25. If device is left unattended, is it physically se-cured to prevent tampering or removal? [ 26. Is the device locked after each exposure? 27. Is the device and _ source tube surveyed af ter each exposure? 28. Is a collimator being used? Remarks ( ) No items of noncompliance or unsafe conditions found. Items of noncompliance: 1. ( ) 6. ( ) 11. ( ) 16. ( ) 21. ( ) 25. ( ) 2. ( ) 7. ( ) 12. ( ) 17. ( ) 22. ( ) 26. ( ) 3. ( ) 8. ( ) 13. ( ) 18. ( ) 23. ( ) 27. ( ) 4. ( ) 9. ( ) 14, ( ) 19. ( ) 24. ( ) 28. ( ) 5. ( ) 10. ( ) 15. ( ) 20. ( ) Were items of noncompliance discussed with the Manager? Yes ( ) No ( ) Audit Conducted By: Individual: cc: Radiation Safety Officer Jobsite File e9 Form 501b Page 2 of 2

u- % %. N EXPOSURE DEVICE INSPECTION (OVARTERLY) RADIATION SAFETY Assignee Due Date Qtr. 19 Exposure Device Model S/N Location Accept Repaired Replaced SHIELD ASSEMBLY 1. Check for excessive or abnormal ra-diation levels on the surface of the shield assembly. 2. Inspect safety plug for proper con-dition. 3. Check locking mechanism for proper operation and for firm attachment to the shield assembly. 4. Inspect for proper alignment of "S" tube with entrance and exit ports. 5. Inspect carrying and hold-down com-ponents for proper condition. 6. Inspect for proper labeling. SOURCE PIGTAIL ASSEM"LY 7. Inspect connector for proper condi-tion using T/0 Gauge 550, when - ap-plicable. SOURCE TU3ES AND CABLE HOUSINGS 8. Inspect for

rust, dirt or sludge build up inside the tubes.

Form 502a Page 1 of 2

9. Inspect tube connectors for proper condition. 10. Inspect for kinks, crushed sections or other damage that could prevent operation. CRANK ASSEMBLY 11. Check for operating characteris-tics. 12. Inspect for excessive wear or dam-age to components. CABLE 13. Inspect connector for proper condi-tion using T/0 Gauge 550, when ap-plicable. 14. Remove and inspect entire cable for flexibility,

wear, rust, broken wires and length.

MECHANICAL COMPATIBILITY OF COMPONENTS 15. Check connectors on source pigtail assembly and cable for a proper fit and the possibility of accidental disconnection. 16. Check connectors on shield assembly and tubes for a proper fit. Remarks Signature Date Form 502a Page 2 of 2

(' ,>www Ns X-RAY E0lllPMENT INSPECTION (0llARTERLY) RADIATION SAFETY Assignee Due Date Qtr. 19 Tube Head Model S/N Control Panel Model S/N Accept Repaired Replaced X-RAY TUBE 1. Check gas pressure (if applicable). 2. Check power cord connector. 3. Check general tube condition. 4 Check condition of label " CAUTION, X-RAYS. THIS EQUIPMENT PRODUCES X-RAYS WHEN ENERGIZED". CONTROL PANEL 5. Check general case con'dition. 6. Check meter movement condition. 7. Check timer. 8. Check power and control cord connec-tors. 9. Check x-ray "0N" and "0FF" lights. 10. Check key switch and lock. CONTROL CABLE 11. Check both connectors. 12. Check insulation full length. Form 502b Page 1 of 2

POWER CABLE 13. Check connector and electrical plug. 14. Check insulation full length. Remarks Signature Date Form 502b Page 2 of 2

/ Urvesen serv =.e ome 1 INSPECTION OF SHIELDED ROOM (SEMI-ANNllAL) RADIATION SAFETY Assignee Due Date Location Room No. Accept Repaired Replaced DOOR INTERLOCKS 1. Operative 2. Condition 3. Adjustment EQUIPMENT INTERLOCKS 4. Operative 5. Condition AUDIBLE AND VISUAL WARNING DEVICES 6. Audible Operative 7. Audible Condition 8. Visual Operative 9. Visual Condition 10. Warning Signs Correct 11. Warning Signs Condition ACCESS DOOR 12. Seals Properly 13. Lock 14. Key RADIATION LEVELS (Source Exposed) Side 1 mr/hr (North) Side 2 mr/hr (East) Side 3 mr/hr (South) Side 4 mr/hr (West) Ceiling mr/hr Remarks Signature Date Form 503 Page 1 of 1

( u- % % EXPOSURE DEVICE MAINTENANCE CHECKLIST RADIATION SAFETY (TO BE COMPLETED BEFORE THE DEVICE IS LOADED WITH A NEW SOURCE.) Exposure Device Mfg. Model S/N Accept Repaired Replaced SHIELD ASSEMBLY 1. Shield Casting (if aaplicable) 2. "U" Bolt (if applica31e) 3. Shim (if applicable) 4. "S Tube 5. Shipping Plug 6. Front Female Nut and Retaining Ring 7. Female Connector Assembly 8. Dust Cap 9. Lock Assembly (Key, Spring, Screw) REEL AND CRANK ASSEMBLY 10 Frame 11. Crank Housing 12. Bearings 13. Drive Gear and Drive Gear Pin 14 Source Drive Cable (Condition and Length) 15. Male Plug Connector Assembly 16. Drive Cable Housing ~~ 17 Source Tube 18. Source Stop DRIVE CABLE CONNECTOR (MALE) 19. Ball Shank Length 20. Ball Shank Diameter 21. Ball Diameter SOURCE CABLE CONNECTOR (FEMALE) 22. Source Connector Hole Remarks Designated Representative Date Form 504 Page 1 of 1

Deveun Sommes Gawwo SEALED SOURCE - LEAX TESTING (SEMI-ANNUAL) l RADIATION SAFETY 1 l Assignee Due Date Exposure Device Model S/N Source Model S/N Curies Location 1. Check the kit to assure you have the following items. a) Flexible wet swab. b) Plastic envelope, c) Identification sheet. 2. Be sure source is fully retracted into the exposure device. Use a survey meter to be sure that radiation levels are normal. 3. Remove shipping plug or source tube from face of shield. 4. Wipe the interior of the hole thoroughly with damp swab. 5. Withdraw swab and place in plastic envelope, taking care not to touch the swab. 6. Monitor the swab using the most sensitive range on the survey me-ter. Place the meter in a low background area and move the swab, in its plastic envelope, to the meter, not the meter to the swab. 7. If the meter reading is more than one (1) mr/hr. above background, contact the Radiation Safety Officer (RS0) for instructions. 8. If the meter reading is less than one (1) mr/hr., mail the leak test to the RSO, 1118 Chess Drive, Foster City, CA 94404. Designated Individual Date Form 505 Instructions on Reverse Side Page 1 of 1

FORM 505 INSTRUCTIONS ASSIGNEE: Designated individual assigned the responsibility for action. DUE DATE: Date action to be completed. EXPOSURE DEVICE MODEL, S/N, ETC: Self-explanatory. LOCATION: Site where source is being used. The above information will be entered by the RSO. The designated individual will follow the detailed instructions

1. through 8.,

sign and date the form when the task is completed. Return completed form with the wipe sample to the RSO. I O e 9 9

i u- - - X-RAY EQUIPMENT li4VENTORY (00ARTERLY) RADIATION SAFETY Assignee Due Date Location Qtr. 19 Control Panel Tube Head Max. ~ Manufacturer Model S/N S/N KV MA 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. Remarks DesignateJ Individual Date Form 506 Instructions on Reverse Side Page 1 of 1

1 FORM 506 INSTRUCTIONS ASSIGNEE: Designated individual assigned responsibility for complet-ing the inventory. DUE DATE: Date inventory to be completed. LOCATION: Site where x-ray equipment is being used. QUARTER 19 The 1st, 2nd, 3rd or 4th quarter of the year 19 The above will be completed by the RSO. All other spaces provided should be self-explanatory. Designeted individual to sign and date form upon completion of insen-tory. l Return one (1) copy to Radiation Safety Officer (RS0). Retain one (1) copy for jobsite file. l i

/ SEALED S0 LEES INVENTORY (OVARTERLY) RADIATION SAFETY Assignee Due Date Location Qtr. 19 Isotope Camera Source Ir-192 or Co-60 Model_ l S/N S/N Curies 1. 2. 3. l 4. j s. i 1 6. 7. 1 8. 9. 10. I 11. 12. 13. 14. 4 Reina rks l l l Designated Individual Date Form 507 Instructions on Reverse Side Page 1 of 1

FORM 507 INSTRUCTIONS ASSIGNEE: Designated individual assigned responsibility for complet-ing the inventory. DUE DATE: Date inventory to be completed. 1 LOCATION: Site where sources are being used. QUARTER 19 The 1st, 2nd, 3rd or 4th quarter of the year 19 The above will be completed by the Radiation Safety Officer (RS0). fS0 TOPES, CAMERA, SOURCE: Self-explanatory. Designated individual to sign and date form upon completion of inven-tory. Return one (1) copy to RSO. Retain one (1) copy for jobsite file. ,4-I

.( u-SURVEY INSTRUMENT MAINTENANCE AND CAllBRATi0tl (00ARTERLY) i RADIATTON SAFETY Assignee Date Due Instrument S/N __ Mfg. and Model No. Location Ship To SHIPPING i 1. Package the instrument carefully and in'clude a copy of this form. 2. Label the package with the shipping label and " DELICATE INSTRU-MENT" warning signs which accompanied this form. 3. Ship to address above. Reason for Transfer l No Longer Needed Calibration Due Malfunctioning or Damaged l List Malfunctions and/or Damage Designated Individual Date i I h an,aam a-- no n nn n .n

FORM 508 INSTRUCTIONS ASSIGNEE: Designated individual assigned responsibility for action. j DATE DUE: Date action to be completed. I TNSTRUMENT S/N, MFG, and MODEL: Self-explanatory. LOCATION: Site where instrument is being used. SHIP TO: Address where meter will be calibrated. Above will be completed by Radiation Safety Officer (RS0). Radiographer will follow instructions 1. through 3., sign, date and re-turn copy of form to RSO upon completion of action, i (

1 l "~ ~ RADIATION SAFETY MEETING MONTHLY RECORD RADIATION SAFETY Jobsite Date TO~ PICS Radiation Safety Note: See reverse side for selection of topics required. I.oss Control TOPICS DISCUSSED -- Minutes of the Meeting 1 i m ) EMPLOYEES ATTENDING MEETING 1. 8. 15. ~ 2. 9. 16, 3. 10. 17. 4. 11. 18. 5. 12. 19. 6. 13. 20. 7. 14. 21. Length of Meeting: i NAME OF INDIVIDUAL GIVING LECTURE l Title APPROVED BY Date Title Form 510 Page 1 of 1

MONTHLY SAFETY MEETINGS / REFRESHER TRAINING Project Managers shall be responsible for conducting refresher training for all Radiographer and Assistant Radiographer under their supervision at interval-s not to exceed monthly. Such training shall include, but not be limited to, one (1) of the following items each month. 1 Radiation Safety a) Agreement States or Nuclear Regulatory Commission (NRC) Rules and Regulations, Parts 19, 20, 21 and 34. b) Agreement States or NRC Radioactive Material License. c) Radiographic equipment and detection instrumentation to be

used, i

d) The Operating and Emergency Procedures. ^ e) Fundamentals of radiation-safety, f) Prevention of overexposure to personnel. ' l g) NRC case histories (monthly). h) Training in the transfer, packing and transport of radioac-tive material. Loss Control A_"

Unnsen Semcee Gmus I RADIATION SURVEY REPORT -- STORAGE AREA i Jobsite Date: From To Dose Rate ar/hr. Perimeters of Storage Area Survey Meter Date Model S/N Radiographer i l l l I l l l l l I l l Note 1: Asterisk the date of receipt of a new or additional source. (Section 3,- Paragraph 9 2.1.1) Note 2: Diagram of storage area and instructions on reverse side. Form 511 Page 1 of 1

FORM 511 INSTRUCTIONS This form complies with the requirement of Section III, Paragraph 9 of Operating and Emergency Procedures Storage of Exposure De-vices. 1. When not in use, exposure devices will be placed in the stor-age areas provided. All storage areas shall have a sign bear-ing the words, " CAUTION -- RADI0 ACTIVE MATERIAL" with the ra-diation symbol (magenta on yellow background). These signs shall be posted on the outside of the. storage areas. 2. A survey of storage areas containing exposure devices shall be made on the outside perimeters and the reading shall not exceed two (2) mr/hr. Surveys shall be made each time an ex-posure device is removed or returned to storage. 3. Survey of Field Trailer storage areas shall be made each time an exposure device is added (additional or new source) and/or at the start of each workweek. The reading of that survey shall be recorded in spaces provided Dose Rate mr/hr. Perimeters of Storage Area, 1 through 5 (see diagram). 4. Storage areas shall be kept locked at all times, except when in use. 5. All information required in spaces provided should be self-ex-planatory. Storage Area O Q Top Front / Lock

1 ~ ~ w. RADI0 ACTIVE MATERIAL SHIPPING DOCUMENT COMPANY (EXCLUSIVE-USE) VEHICLE ) IRIDIUM-192 WEEK ENDING Shipper: Consignee: 1 Exposure Surface (TI) Device No. of ar/hr. of mr/hr. Signature of Date Jobsite Location S/N Curies Contciner at 36" Radiographer l Sun l l l l i Mon Tue Wed Thu Fri Sat _ DESCRIPTION OF PIECES AND CONTENTS Radioactive Material Special Form N.O.S. UN 2974 Class 7 Iridium 192 105 Curies Maximum Yellow Label II Transport Index Not Over 1 This is to certify that the above named materials are properly classified, de-scribed, packaged, marked, labeled and are in proper condition for transportation according to the applicable regulations of the DEPARTENT OF TRANSPORTATION. " Radioactive Yellow-II Label" - 0.5 to 50 mree/hr. on the surfree and not over 1.0 mrem /hr. at 3 ft. Yellow-II Label does not require vehicle placards for shipment by highway. Note: DO NOT TRANSPORT if surface of container is over 50 mrem /nr. and/or over 1.0 mrem /hr. at 3 ft. (additional shielding shall be required to meet shipping requirements of " Radioactive Yellow-II Label"). IF there is any question on the correct procedure, DO NOT TRANSPORT. Call the Radiation Safety Director (RSD) for clarification. m-am o __-_______n,_ n .n

TNSTRUCTXONS This Radioactive Material Shipping Document is designed to fulfill DOT require-ments for transportation. This form is oriented toward Company vehicles transport-ing radioactive material to field sites (outside the confines of jobsites). One (1) form will be used for one (1) device, each day, each location, for each week. Shioper and Consignee - The jobsite address shall be entered in spaces p ro vided. This is the office and storage location address. Date - Enter date the exposure device is transported. Jobsite Lccation - Enter the field site address where the exposure device is to be us ed. Exposure Device S/N - Enter serial nu=ber of the device (XRE #). Number of Curies - Enter the number of curies as of the day being transported. i Surface mr/ hr. of Container and cr/hr. at 36" - Enter the surface reading of the shipping container and enter the reading at 36" from container (which is the trans-port index). Sienat ure of Radiographer - The R& biographers completing form will sign their name in the column provided. Packaging (Type B Drum )- Packaging of radioactive material shall meet with all the requirements of DOT. Preparation for Shipping - (Remove from storage per the O&E P) 1. A survey meter shall be used every time a person is required to work with or around radioactive material. 2. Inspection of radioactive exposure device per Form 160a. Note: No device shall have a reading in excess of 200 mr. 3 Place exposure devf ce in shipping container. 4 Shipping container shall have affixed, an address label (same as used for shipper and consignee). 5. Shipping container shall have affixed two (2) " Yellow-II" labels. Informa-tion required on labels is as follows: Contents: Iridium-192 Note: DO NOT TRANSPORT if T ra ns-Number of Curies: 105 maximum port Index is over 1 (addi-Transport Index: Not Over 1 tional shielding will be re-quired ). 6. Seal and lock shipping container. 7. Radioactive Material Shipping Document Ccxnpany Vehicles shall be re-quired to accompany each shipment. 8. Cover " Yellow-II" labels when shipping drum is not being used to transport radioactive material. Note 1: If there is any question on the correct procedure, do not transport -- Call the Radiation Safety Director (RSD). for clarification. Note 2. Shipping document is to be mailed each week with Form 160a. Required pro-cedure for shipping of Iridium-192 or Cobalt-60 sources, refer to O&E P, Paragraph 14 and Section VI of the Safety MLnual. k _... _ _ _ __.________________i

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INSTRUCTIONS j l Film badges and dosimeters shall be used by anyone over 18 years of age who is likely to receive a dose of 300 mrem per calendar quarter. Individuals receiving film badge shall have his/her name entered in the space provided (" Individuals"). A check will be entered in the column " issued" for the month in which it was issued. Film badges re-turned for that month, a check will be entered in the column " return" and a film badge will be issued for the next month and so on. Film badges not returned shall be investigated by the Project Manager. A report shall be made as to the reason for the badge not 'being re-turned along with the individual's corrective action for the preven-tion of its recurrence and a copy forwarded to the Radiation Safety Of-ficer (RS0). Individuals' dosimeter readings for the month, taken from Form 160a, 160b or 160c, will be totaled and used for the expo-sure received during that month. Dosimeter reports will be forwarded to the film processing facility in place of the lost badge, with a copy to the RSO. Distribution: Original RSO Copy retained by Proj ect Mana'ger s Note: Form to be mailed upon completion (return) of December's film badges. 1 i i L __ _ _ _. _ _ _. _ _ _ _ _ _ _

1 't u- - %. SOURCE RECEIPT, TRANSFER AND DISPOSAL RECORD I i i Source Source Camera Received Date Shipped Date q co-60 or Ir-192 S/N S/N Prom Received To Shipped l j l l l . we~ i l 1. 1 i l i l i l Form 514 Page 1 of 1

1 l I Unitech Services Group l l 1 RADIATION SAFETY PROGRAM UST 985 1 l l l 1 SECTION XIV i AGREEMENT STATES PROCEDURE 1 985-0 Original Issue TWC 09/30/8! l i AEW CN EFFECTIVE E0* CESCRIPTICM BY 'DATE l

'l RADIATION SAFETY PROGRAM This procedure will establish those-special re-1.0 OBJECTIVE quirements of each Agreement State. 2.0 APPLICATION - All U.S. Testing, Unitech Services Group (Com-pany) personnel working in an Agreement State. Specific Agreement State requi.;ments are de-3.0 PROCEDURE fined as follows. 3.1 Each Agreement State, that has special requirements differ-ing from the Federal regulations, shall be covered in a spe-cific appendix. 3.2 The State appendix shall enumerate all expressed require-ments of that State. 3.3 Revisions of State's regulations will result in the revi-sion of the Program as an appendix. (Revising will be the responsibility of the Radiation Safety Director (RSD)). 3.4 Copies of all appendices will be with all assigned Programs, where applicable, a) Each Radiographer and Assistant Radiographer shall have available copies of the appendices for the particular state in which they will be working. 3.5 No Agreement State regulation shall be reason for not con-forming to the Company Program or Federal regulations. NO. TITLE REV. PAGE UST _XIV AGREEMENT STATES PROCEDURE-985-0 1:of 1}}