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U.S. NUCLEAR REGULATORY WMM6SSION September 1976

@ REGMOPY GJDJEOFFICc OF STANDARDS DEVELOPMENii

REGULATORY GUIDE 10.6GUIDE FOR THE PREPARATION OF APPLICATIONS FOR

USE OF SEALED SOURCES AND DEVICES FOR THEPERFORMANCE OF INDUSTRI AL R ADIOGRAPHY.

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1. INTRODUCTION Energy Reorganization Act of 1974 shou!d, m additionto complying with the requirements set forth in tlus*

1.1 Purpose of Guide part. make esery reasonable effort to mamtain radiatione xposures, rd releases of radioactive materials m

The purpose of this guide is to pronde guidance in effluents to unrestricted areas, as low is reasonably

patio % "Operatmg.1the preparation of an appheation for a Nuclear Reguia. a c h i e vable." Regulatory Guide

n Radiationtory Commi~.on (SRC) lie rnse for possession snd use Philosophy for Maintaining Oof scaled ateces and desices for perfor mance of Exposures As low As isjReas ably hevable,"

industnal ra60 graphy. "Ra60 graphy," as used m this prosides the NRC staff p K .this importantguide, means the e xamm ation of the structure of subject. Ucense applic t sh d give consideration to

the ALARA philosc(Mo,,pmen) of plans for work withIsy gs d ~ ibed in Regulatorymaterials by nondestructne methods utilizmg scaledGuide 8.10. in Qd desources of by prc. duct matenals. The radioisotopes

(byproduct matenals) most commonly used for ra60 bcensed radioact ve teg,\graphy are cobah.60 and in6um.192. .

s

h , LICENSE FEES1.2 Applicable Regulations [ *

Ahp,pheben fee is required for most types of,

9 apphcant should refer to Q 170.31.(@li(enseg. 'Qe

Commission regulations that apply to radiographyngfule of Fees for Matenals Licenses." of 10 CFRand should be used m conjunction with this guide are 10.

C FR Part 19. " Notices. Instructions, and Reporf . Pgl70 to determine the amount of fee which mustWorkers; Inspecu ms." 10 CFR Part 20. " Standard for accompany the applicatic.. Review of the apphcation

30." les , mil not bepn unt0 the proper fee is received by theProtection Against Ra6ation;" 10 CFR Pary$, proof General Applicabihty to Licensing gr NRC.-

Material;" 10 CFR Part 34. " Licenses fof Radiog(aphyand Ra6ation Safety Requirements for diographic 3. FILING AN APPLICATIONOperations;" 10 CFR Part 71,"Packagmg of adioactiveMaterial for Transport and, Transportation of Ra6o- An apphcation for a license should be filed on Formactive Material Under Ce tain' Con 6tions;" and 10 CFR N RC-313 R. " Application for Byproduct Matenal

itief sid Matenals Ucenses License-Use of scaled Sources in Radiography,"* andPart 170, " Fees for Fat lUnder the Atomic Energy Act of 1954. as Amended." should contain all the information specified in the apph-

The appheant shfid ca'refull[ read these regulations and cation form. The space provided on the form is hmited;this guide and sh uld submit all information requested. therefore, the apphcant should append additional sheets

2A to provide complete information.1.3 AsIm As is Reasonabli Achiesable (ALARA)

[ \ The apphcation should be completed in inphcate.Parapaph 203(c) of 10 CFR Part 20 states that The nnpnal and one copy should be maded to the. persons engaged in actisities under liccnses issued"

*,by the Nuclear Regulatory Commission pursuant to the * Form NRC 313R mas formerly desipated Form AEC-313R.Atomic Energy Act of 1954. as amended, and the E ustuit copes of Form AEC 31.1R may still be used.

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Raiotsotopes Lacensmg Branch, Dmsson of Fuel Cycle shiel6ng materia: on all cdes, above and below; (3)and Matenal Safety, Of0cc of Nuclear Matenal Safety identification of entrancr* /s, and (4) a anscri;tjun ofand Safeguards, U.S. Nuclear Regulatory Commission, the nature ef, and distances to, all areas adjacent to,

Washmgton, D C. 20555. One copy of the apphcation, above, and below each exposure area.

with all attachments, should be retained by the appli-cant, since the hcense will require, as a condition, that b A descnption of the . area secunty safeguards,the hcensee follow the statements and representations such as locks, signs, warning hghts, and interlockmset fcrth m the appheation and any supplement to it. systems for each enclosed exposure area and ade.ent

are as.

4. CONTENTS OF AN APPLICATION c. The results of calculations or radiation level .

measurements showing maumum anticipated ra6ation .

The following discussion deals with specific items on levels m all areas adjacent to each exposure areathe apphcation fc.rm The information specified in items inclu6ng the rocf or cedmg. As a basis for calculauons. ,

1 through 3 of the apphcation is explained in the e type of soma, quanuty M acunty m the sowa,instruction sheet accompanymg the apphcation form, and position of the source withm the facdity should beand item 7 is self<xplanatory. The followmg informa- identified'tion deals with items 4,5, and 6 of the apphcstion form.

The objective nf a shielded facdity is to permitfrem 4. The scaled sources that the apphcant wishes Performance of radiography within the facdity so that

to possess and use should be hsted by radioisotope, areas outside the facuity may be considered unrestnctedmanufacturer, and model number. The maximum areas and will meet the ra6stion level hmitauons inamoun t of raioactinty in each source should be Paragraph 20.105(b) of 10 CFR Part 20. A radiauonspecified. The number of sources that the apphcant level f n t m te than 2 nulbroentgens per hour at adesires to possess at any one time need not be specifi- 18 inches hom any extemal smfan M beanacally stated facihty will be consiuered acceptable for considenng the

area as an unrestncted area.if sources are to be used for mstrument cabbration

and are not the same sources that wd! be used for perfor- / rem 6/b). Instruments should be identified bymame of ra6epaphy, specific *nformanon concerntng manuf acturer. model number. and range of tnstrumentman uf acturer. model number, r a dioisot ope, and For mstruments to be used for surveys, the mstrumentsquantity of raioactive matenal m each source should be must have a capabihty of measunng a mmimum of twospeciGed. milbroen; gens per hour through one roentger per hour.

/ rem 5 The radiographic exposure devices m which Item 6/c). Section 34.24 of 10 CFR Part 34 requiresthe sources wdl be used should be oesipiated by manu- that radiation survey mstruments used m ra6ugraphictacturer and model number The sources identified in at inwals not to emed 3perau ns e ca aeIterr 4 should be keyed to the deuces in whith they will m nths and after e..i. mstrument serviemg. The smallbe used check scurce that is mcorporated into several models of

suncy insnuments is not acaptaNe Nr a W auonif source changers will be used. the source changers Purposes. To properly cabbrate a sune; mstrument. its

should be idennfied by manufacturer and model number resp n e must be checked at two ur hiore points on ushand should be keyed 'to the source-deuce combmations aew J s ma gamma radianon d appropnatewith which they wdl be used stre n gth and energy. The highest and lowest poin ts

scale should be yeparated b3 at leaste onT he supphers or equipmen t shouki be contacteJ "* ' ' " " " " ' " " ' ' ' " ""'"

soncernmg the model numbers of sourcet deuces. and to duW dues wh a range d t E. Me insuu- ,

shangers to assure that the inf ormanon contamedsou r s e ent ma e wnsidered properly cahbrated a

m the apphcanon is accurate improperb iden tifie dequipment may require additional correspondence. 11 an a phant wishes to cahbrate his instruments. the ,

follownig ofc,rmat on should be subnntted/rm Na s it a permanent. shielded faihty wdl be

u sc J t . < pewrounc of radiocraph . a detadcJ deknpton a the txihn shou;J he subnuticd whish mshiJes a The type t ra dioisotope nun ais t ure r andrl e h 4 wme model numberi .ind aetnits of tbc sour e to be useds

knetatcJ Juwmp m Actsbes et the txihn b The specinc proscJures to be used f or 64! hia-i

b'eh cJtion mJudmc r Junon safets pro d cexhmJuu Juu i: iJo en ros ai g.m e o

ma m a ,u_ msm ,a u m. ~ ,m _ ,memmse

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c The name and pertinent expenence of each a. The Handhng and Use of thenied Scaledindmdual who will perform instrument calibration. If Sources and Radwg:sphie Exposure Devtces. Step by-N radographers will perform instrument cabbration. step instructions of the " cookbook" type for the usespecific mstructions and procedures should be wntten and handhng of radiographic exposure devices andfor use by ra6cgraphers. related equipment should be provided When appro-

pnate, the procedures should melude mstructions for useif mstrument cahbration wdl be performed by an of radiation colhmating cones or other auxdiary

organization other than the apphcant, the apphcation shielding matenal.should include (1) the name and addren of the organoration. (2) a descnption of the cabbration procedure. If source exchange will be performed by radio-and (3) a copy of the kind of data concernmg the graphy personnel, step by-step mstructions for sourcemstrument cabbration which will be furnished to the ewhange. meluding suneys to be performed dunng theappbcant. source exchange and for shipment and acceptable radia-

*tion levels for the suneys should be in the procedures.

Item 6/d/. The name of the film badge suppher ort h e rmolurrunescent dosirr-ter suppher should be If radiography personnel will perform instrumentidentified. The frequency of change of film badges or cahbration step-by step mstructions including radiationthermolummescent dosimeters should be specified. safety precautions and procedures to be followed should

be in the procedures.The manufacturer, model number, and range of

pocket dosimeters to be used should be ident;fied. The b Methods and Occasions for Conducting Ra6a.frequency of dosimeter cahbration and how dosimeters tion Surveys The procedures should idennfy whenwill be cahbrated should be specified. surveys shall be made, specifically what should be

surveyed. and acceptable radiation levels for the surveysItem 6/e/ Section 34.31 of 10 CFR Part 34 requires in gercral. a survey should be performed each time a

cach heensee to provide radiography personnel with source is manipulated or moved. Surveys which need tooperatmg and emerFency procedures. The purpose of be performed include

ttus requirement is to provide sa6ography personne.3)with clear and specific mstructions in the topics hsted in

34.32 and m other duties and responsibthfies that s urce has returned to the safe storage pesuic,n. Thim#.

ra6ography persennel may have. Other dutias could survey should mclude both the guide tube, if appro-priate, and the device itself.include instrument cabbration, leak testing, quarterly

inspectior' .tnd preventive maintenance of equipment,ternunation of the penmeter of theanJ shipment of sources and deuces. The operating and

restncred aieaemegency procedures fcr personnel should not containmformation that does not apply specifically to the duties

(3) Determination of radiation levels at ex.of radiography personnc!, for example, neither the tram-ternal surfaces of storage facdities.mg program descnphon nor the management control

program should be presented m the operatmg and em-(4) Deterrrunation of radiation levels in andergency procedures.

around vehides used for transportmg sources andd ' * i" 'The operatmg and emergency procedures should be

tadored to fit the program proposed in the .ppbcation.Tbc pmcedures and mstructions should be complete and (5) Deterrrunation that the source is m a safeself<ontamed m a single document Information con- ""''ge pa hon poor to seconng a radiographie expo-tand in equipment manuals and other pubhcations sure deuce or storage container.

she,Ad oc extracted and mserted mto the operatmg andemergency procedures so that the mstructions to person- Detemmanon that contamers prepared fur

nel are cirar, specific, and appropnate for the proposed shipment comply with the requirements in Department

program. The instructions contamed m the operating f Dansp nm n regulan ns (10 mr/hr at 3 feet fromand emergency procedures should be m language tha't any surface and 20C .ar/hr at the surface of the con-

''#'"can be easdy unbrstood by radiography personnel } } { ') }There is no specific format for operatmg and emer The acceptabit r Aation levels for su rvey s

gency procedures A sequential set of instructions tnat should be expressed n milbroentgens per hour. Radia-covers radiography operanons from the begmnmg of the tion levels should not be expressed in terms of potentialworkday to the end of the workday n an aceptable dose

forma t The following comments may be helpful withrespect to the topas that should be meluded in 'ne oper c Meth ds for Cont rolhng A u ess to R adio-ating and emerg-no pro <edures graphic Aren Inuruchons for controlhng access to

10 6 1

radiographic areas should be specifica!!y stated in the receised will be accurately reflected by the devices Theproced ures instructions should be specific.

The perimeter of the restncted area and trie perim- Frequent resing of pocket dosirneters should beeter of the high radiation area should be posted required so that personnel may be aware of exposure" Caution (or Danger) Radiation Area" signs should ba that they may have recuved An instruction concerningpested at the penmeter of the restncted area, and steps ' rat must be taken tmmediately by radiography6.. ', DangerFHigh Raiation Area" signs should personnel in the event a dosimeter is found to be off.

be posted at the pc. cater of the high radiation *rea scale should be in the procedures Instructions forThe use of high radiation area signs is not acceptable at storage of personnel monitoring devices should be in thethe penrneter of the restncted area, these signs should be proceduresused onh at the perimeter of the high radiation area

f Transporting Scaled Sources to Field Locations.Signs, by tH uehes do not provide an adequate Iacking of Exposme Desices and Storage Containers in ,

means of ac< , control For radiographic cperations the Vehicles Posting of Vehicles, and Contrc.1 of Scaledperformed outside a perm.1ently estabbshed. shielded Sources Dunng Tr ansportation. Most traraport overfacdity. instructions requ:nng survedlance of the area to pubhc roads of radiography sources in exposure devicesprevent unauthorued persons from entenng the area are or storage containers is subget to the regulations of thenecessary For permanently estabbshed facdities, specific Department of Transportation. These regulations cover.instructions concerning use of mtarlocking devues and among other things, permnsible radiation levels aroundsystems, locking of the facdity, secunty of keys. use of and within a vehicle and placardirig of the whicle dunngwarmng hghts. etc., should be included in the proce. transport In those cases in which the Department ofdures Transportation regulations are not appbcable (such as

intrastate transportationt 10 CFR Part 71 of the NuclearThe instrudions for control of access to perma. Regul. tors Commission's regulations nonetheless

nent!> estabbv,ed f acthties should be sepa rate and '

requires conformance to the standards and requirementsdistinct f - ine instructions for temporary site opera' of the Department of Transportationruns

The procedures should contaan instructions onA specifbation of a radiation lesel at 2 .th. how exposure devices or storage containers should be

roentgens per hour for the penmeter of the restncted secured within the t ran sporting vehicle to presentarea and 10( milbroentgans per hour for the penmeter shifting within the schicle There should be trsstructionsof the hid radiation area is acceptable A physical for placarding of the schicle dunng transport. The De-survey with a suney meter should be perforr ed t" partment of T ransporta tion regulations requireconfi m the 2 rrulbroentgens per hour radiation lesel for .. RADIO ACTIVE" placards on all 4 sides of the vehiclethe .enneted area af ter the source has been exposed It Thcre should be instructions for surveys in and aroundis neither necessan 1. v deurable t ,r a phs sical saney to the schicle For the passenger compartment. the radia-be made to confirm the radianon lesel at the penmeter tion level should not exceed 2 rrulbroentgens per hourof the hith radiation area since sush a <unes could lead Although it is not specifically reqci ed for transport.to unnuessars exposure of gnonnel there are occasions when the vehicle may be used for

storage and the area outside the vehicle should beJ Methods and Occ asians for 1 ocking and

onsidered an unrestric red area so that a specification ofSes unr.g RaJiographa i sposure Demes Storage Con. n level of 2 mdhroentgens per hour at aa.u, ar.d Sca cd 50 m. Thre sh mld he an inuru' distance of iS irnhes from any external surface of theon requmnp Imkis J 'he e powe deshe aten g g

lor7 enan of the sunes to determine that the sour ehas returned to the sate storage posmon When . vehhle is used for storage. the posting

requirements in 10 CFR Part 20 are apphcable. and,

murus nons and pros edures f or storage of mutses g .

and demes at hoth permane.- and temporan Joo sites-R& W h M'W M W dM Wincluding posting of storage areas and sur ey s around the

a ea outside a parked vehicle used for storage is an un-storage arcat should be in the rmcedures The area out- gg ;g gude m rage ucas sh , d d be s mdcred a unresirk ted

the surfa e of the schkle should not exceed : milh*"roentgens pei hout

e Penonnel Momtomg M te I se et Personne!Momionng I quipmerr The u n na s sh >uld serta n g. %nimizirg I sposure of Persons in the ben' m.

w ear their an A o idem t r e ruenons to penannel should in ludereq uacmem s r.6 e n rersonn'i

oct m e' m m o c o ure r sedurcs to mimmizen of exposure tc reNeo

.

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156 266

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@ the event of an accidert or other unusual occurrence. Area safeguards used during radiographic oper?Po ssible malfunctions of equipment should be tiens in a shielded facibty should be tested for properconsidered, and steps to follow in each case of malfunc- operation at least once every 6 months. The area safe.tion should be spc! fica!!y set forth. guards may include door or equipment interlocks,

audible or visible warnmg, or access door lockmgThe procedures should contam clear and specific devices. Instructions for performance of such mspections

instructions concernmg emergency situations. The steps should be in the procedures if they are performed by :

to be taken by radiography personne! should, m general, radiography personnel.be hrr.ited to (1) surveymg the area, (2) estabbshing arestricted area (3) notifymg appropnate persons, and / tem 6/f). An apphcant for a radiography license(4) maintainmg direct survei.Ilance and control oser the must have an adequate program for the traming of radio-area until the situation 's corrected. Limitations on paphers and radiographers' assistants. With respect toaction that may be taken by radiography personnel radiography personnel, two important pomis should be,

should be cleaily specified. The attempted recosery of a understood : (1) The dunes and responsmilines of thesource that has become detached from an exposure radiographer may not be delegated to the radiographer'sdevice, an operation that may result m exposure to high assistant. A radiographer must be physically present atlevels of radiation, should not normally be attempted by the location where radiography is being performed. Aradiography personnel without quahfied help. radiographer's assistsnt may not independently perform

any source manipulation, survey, etc., unless a radio-h. The Procedure for Notifying Proper Persons m gr.pher is physically present. (2) Any indmdual who

the Event of an Accident. The names and telephone ass |sts a radiographer by manipulatmg radiographicnumbers of the persons to be contacted should be exposure devices, sealed sources, related handhng tools,specified. or suney instruments is acting m the capacity of a radio-

Recordkeeping. The instrucnons to personnel grapher's assistant and raust meet the requirements of1.

shculd specify those records that must be developed by paragraph 34.31(b) of 10 CFR Part 34

them dunng the course of their work. Among therecords that are normally made by radiography person- A narrative desenption of the complete train:ng pro-nel are dosimeter readmgs, surveys, and daily inspection g r a rn , in cluding appropriate references to any

@of equipment. Othei recoids shou:d be included if the) instructions to be gisen by outside semce organizations,are the responsibility of radiography personnel. Records should be provided. Such a narrative should descnbc. mfor which management and supervisory personnel have general terms, the sequence of events in the trammg of aresponsibility should not be included in the operating person to become a radiographer or radiographer'sand emergency procedures. assistant from the time he is hired through the time he

j. Inspection and Maintenance of Radiography g es n the job. Since 10 CFR Part 34 has differentExposure Devices and Storage Contamers. The proce- requirements for radiographers and radiegraphersdures should contam specific mstructions for inspection asustants, it may be desirable to submit separateof radiographic equipment poor to use on each day on n8tf8tive5 Pertain'ns to the traming of mdmduals forwhich the equipme,r is used. A checkhst should be each category. tri .dd: tion, a third narrative pertammg tocontained in the procedures hstmg the items that should the traming of ud viduals who are hired with previousbe covered m the daily mspection Equipment manu- traming and expenence may be desirable. The n.trrative

should include appropriate references to the morefacturers may be helpful in providmg mformationconcerning da$ly inspections. detailed desenption of each of the vanous parts of the

traming program described m eccordance with theQuarterly inspecnon and preventne mamtenance fU *maMem5

of equipment should be carned out. If radiographygrsonnel will conduct these mspections. clear and a. Initial (" Classroom"n Trammg. A descopnon ofspecific mstructions for inspection and mamtenarr- the manner in which radiognpher trainees will beshould be in the procedures. As part of the mspecoon mstructed m all areas of Appendix A of 10 CFR Part 34and preventive mamtenance program, all connectors, should be gnen it should include a detailed outimednve cables, source guide t ubes, on-off mdicator (more detailed than Appendix A of 10 CFR Part 34) ofmechanisms, and all movmg parts should be checked for the course content includmg specificanon of thedefects and excessive wear. Cables should be cleaned and approximate time to be spent on each major area oflubricated and all defec t ne and excessnely worn mstrucnon.

}{[camponents repaired or replaced. If componentseufntial to the safe operation of the device are found to if mdmduals are to be tramed 'o be radiographers'be def-ove or in poor operatmg condition, the device assist an t s. the traming program description shouldshould be immediately remosed from se m ce unnl mclude this. Note that the content of a traming courserepairs can be made. for radiographers' nsstants need not m,lude all of

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10td

Appendix A of 10 CFR Part 34 Please set parapaph Practical or on-the job demonstration examinmg34.31(b) for subjects m which radiographer, a"istants procedures may be descnbed m terms of the areas ofmust demonstrate understanding and competencc performance to be checked by the examiner such asNote: A trainmg course pen by an outside service performance of radiation surveys, postir.g. and operationorganization usually will not mstruct the tramee with of equipment.respect to an applicant's parttcular equipment. facilities.and procedu-es Therefore, if outside trammg is to be A description of the test'ng procedure a omused, instruction pven to supplement that trammg with complete without a clear and specific desenption of therespect to the apphcant's own egnpmen' tacilitie: and criteria and procedure to be foilowed in evaluating testprocedures and the method to be used I determine each results and determinmg whether an individual istrainee's competence in accordance with 34.31 of 10 qualified to act as a radiographer or radiopapher'sCFR Part 34 should be included in the propam desenp- assistant. The relative importante ampied to each queption. If an outude semcc orgamzation will be used, the tion or area of performance, the mimmum acceptablename of the orgamiation should be specified numbe. of correct arswers or proper responses, a:J *

b. On-the-Job Trainmg. A penod of on the joo retestmg procchres M an h pen.trainmg, mcludmg tramee observation of the use ofradiopaphic expmure devices and associated equipment The pomts withm the traimng program at which

by expenenced persennel and the tramee s use of such each test will be given should be clearly indicated. For

equipment under the supemston of expenenced person- example, some trainmg programs include a wntten or

nel, should be descnbed. The mimmum time that will be mal exam f U *Ing 6e initial trammg pbsc, Mowdspent m, and the content of, on-the-job trammg should by an oral and practical exam at the close of the on the-

be specified. N "''*"E I ''

c. Trammg of Expenenced Radiographers and Note that testing procedures must ensure com-Radiographers' Assistants. Due to differences in proce- pliance will. @34 31 If a trunee is to be utdized asdures. equipment etc .it is unhkely that a new employee a radiographer's assistant dunng his traming penod, hewill be adequately prepared to work m a particular pro- should be tested and quahGed as a radiographer'sgram without some traming specifically related to that assistant before assummg inose duties.program. Also, each hcensee is required by Q34.31 tomake a determination that each mdnidualis quahfied to f. Instructor's Quahfications. The name, trainmg,act as a radiographer or radiopapher's assistant in its and expenence with radiation of each person who is toown specific prograrn. The appheant should. therefore, participate m the mstruction, exammation, or quahfica-drsenbe the procedure for determinmg the knowledge tion of t:amees should be given m sufficient detail toand competency of such mdniduals and for providmg estabhsh his or her quahfications to perform theseadditional trammg. if needed semces. If an individual will teach only certain parts of

" " ' " Id Penodic Trammg Thn should mclude a des-cnpiion of the content and schedulmg of trainmg The person who makes the final determmation of

sessions given for the purpose of ensuring (1) the the adequacy of a trainee's knowledge and competencyshould have a st ron g background of training andknowledge and protiaency of radiographers and radio.

graphers' assistants w it h respe c t to new regulat:ons. e x pe nence with radiation and be a quahfied radio-procedures. pohciet and equipment and ( 2) contmuing grapher On.thegob trammg should be gnen by someone

profi iencs with present cauipment and prmedures who n as a mmimum a quahfied radiographer

This neno dic trammg should be t onduc ted at least g ,p 4 g g gg g'"""'

record s show ng t ramee performance m each exame. Temng Pmedres A des nrnon H ea<h test (including oral and practical cumu. and the exammer'ss

to N gnen CulJ be submnred A den nptmn M a overall esaluanon of the tumre as quablied to act as awntten test mas he Fnen hs submittine a sample test radiographer or radiographer's assistant sh ould bewth an answer f or each question main t a m e d .

T he ef festneness at ans test a reduced it the test in cenam cases where a radiographs propam nn gnen repeatedh so that the stude?ts ga:n knaw! edge bmited to a few indniduals and personnel turnmer nof its s entent. The ,ourse decirta n <hould death not anticipated a traming program mJ) not be neCestarxindide that enh 'es n a uMe ork md that the test provided each mdnidual has adequee trainmg andcontent d N hged r a oca mm e ueq;enty expenence. In such a situation. the arphcation should

request that specifk mJniduals be named on tFe hcenseA deknpMn of an eh eum nor shou!d me in heu of submittmg detalk of a complete trammg pro-

gnen m the same tim as a w nnen em na' ion gram The apnbsation @ould e x t' lain whs n n noi

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156 268

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@necessary to estabhsh a trainmg program The quahfica heensed by product material f or stor. ige purpovs onktions of each mdividual designated as a radiopapher or The individuals named on the hcense are required to

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radiographer's assistant should be descnbed and should perform all radiographic operations conducted under the

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incirde the following mformation: heense, mcluding the manipulation of equipment andthe performance of radiation survey, Although apphca-

a. The individual'; name and the capacity in tion inay be m4Je for the addition or substitution ofwhich he wdl function (radiographer or radiographer's names of other individuals in the hcense, the time

mist a n t ). needed for preparation and submission of the apphea-tion and for the Commission to issue an amendment

b. A detailed description of each individua s could delay the propam. No individual may act as artrammg and experience in the principles of radiation and radiographer's assistant unless the hcense is amended tonadiation safe t y. The information provided should proside for an mdividual to act in that capacityspecify when (dates) and where training was receised., Item 6/g). The applicaten should include a descop-The name of the individual who provided the trainmg

tioa of the int rnal mspection sy stem f or controlhng theshould be mdicated if trainiag other than that of areceipt, possession, and e- of radioactive matenal Thecommercially offered program was used.sy st er.1 should ensure that heecse conditions. Commis-sion regulations, and ,perating ed emergency proc?c. The specific experience of each mdividual indures are followed by .adiographers and radiopapherCthe use and handling of the type v equipment specifieda s a st a nt s'in the application. The information should include

names of previous employers, dates employed, type of Parapaph 34.11(d) requires that the hcense apphcar.tequipment used, and length of time the equipment was submit a descnption of nis internalinspection system orused for each previous employer. Other management control. This should include a

descuption of (1) the quahficatwns of each persond. A descnption of the in struc tion that each responsible for mamtaimng su:h control,(2) the ty pe of

prospective radiographer and radiographer's assistant has internal inspections to be made and their frequency,(3)received in the applicant's operating and emergency the responsibihties of each person in the propam, (4)procedures. the procedure for recordmg and reporting deficiencies to

@appropriate management personnel, and (5) the educa-

e. A description of the means used to determine tion and followup program to be used in correctingcompetence ofindividuals ta :ct as radiographers and by deficiencies noted durmg inspections. The type andwhom such determination is made. Copies of examma- extent of the radiogr.iphy program to be conductad willcons given to determine knowledge and understandmg usually determme the nature of the system and theof the topics in Appendix A of Part 34, the applicac . inspection frequency .operating and emergency procedures, Commissionregulations, and use of equipment should be submitted. Penodic (at least quarterly) mspecti?ns of radio-

graphy operations should be made by a person ofauthority in management on both an announced andf. A description of the means used to determmeunannounced basis. This person should have a thorough

competence of individuals to act as radiographers' knowledge of equipment, procedures, and reculationsassistants and by whom :uch determination is made.and a level of competence at or above that expected of aCopies of c.aminations given to determine under. radiographer. Management should make a continuing

standmg of the hcensee's operating and emergency review of quarterly mventcnes, utthzation logs. records> r cedures and means used to determine competence t of receipt and disposal of hcensed matenal, persor.nelun radiographic and related equipment snould be monitonng results, and surveys.submitted.

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Item 6/li). Active controt over the radiopaphy pro-g A des.nption of the penodic trammg pro gram must be exercised by management personnel inam

for personnel positions of autbonty. Paragraph 34.ll(e) requires thatthe hcense apphcant submit a desenption of the overall

The brnitations imposed in hcen.ses when the ap- organizational structure pertainmg to the radiographyphcant has not estabbshed a complete program for program, including specific delegations of authonty andtraining radiopaphers and radiographerv assistants responsiblity for the program.should be clearly underitood. The hcense will speci-fically name each mdividual authorized to act as a Each .ndividuai in the hne of authority should beradiographer or rad ographer's assistant.Should aH radio. identified by name. and his duties and responsibilitiespaphers who are named in the hcense become relatmg to the radiography program should be descnbedunanilable, the hcensee would not be permitted to in detail. The trammg and experience of each mdividualperform radiography under the license and therefore that quahfies him to perform his duties and accept hiswould have, m eff(ct, authortzation to possess :he responsibilities should also be desenbed.

. 156 2691067

Those mdividuals in management who will be p. Reviewtng and ensuring maintenance of thoseassigned duties estabbshed by the bcea m .t: words . ept by others,maintaining an active management control of the pro-gram should be identified. The individual (s) assigned q. Assummg control and instituting correctuethese duties may bear the titk of Radiation Safety action in emergency situations.Ofncer, k . aion Protection Officer, or some similardesignatior. D.z following list describes duties that may r. Investigating the cause of incidents and deter.be performed by the licensee's management personnel. mming necessary preventive action.The hst is not mtended to be allincluuve nor should it beinterpreted as a requirement that any one person assurne s. Actmg in an advisory capacity,to the hcensee'sall of the hsted duties. Information pertaming to the management and radiography personnel.

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applicant's specific program should be submitted andshould include duties that may be performed by manage. Item 6(i). Distributors of scaled sources usuallyment personnel such as the following: supply a certificate with each source giving the results '

and date of the last leak test performed on a source, ifa. Serving as the licensee's liaison officer with the such a certificate is not received, the source ss not to be

Nuclear Regulatory Commission on license matters. used until a leak test has been performed and the resultsof the test received showing that the source is not

b. Maintaining control of procurement and leaking or contammated. Thereafter, the source must bedisposal oflicensed material. tested for leakage and contamination at intervals not to

exceed 6 months. Recc <ds of the testing of each sourcec. Developing and maintaining up.to.date operat- identifying the source tested, date of the test, and the

mg and emergency procedures. results of the test in units of miciocuries must be rnam-

d. Establishmg and maintaining a personnelnrnitoring program. The leak testmg of sealed sources may be performed

only by persons who are specifically authorized by thee. Procuring and maintammg radiation survey Commission to do so. In establishing a program for leak

instruments. testing one of three approaches may be used:

f. Establishtng and conducting the training pro- a. The services of a consultant or commercialgram for ladiographers and radiographers' assistants. organization licensed by the Commission to take the

necessary test samples (" smears"), evaluate the samples,g. Examining and determining competence of and report the results to the customer may be used.The

radiographic personnel. name, address, and license number of the consultant orcommercial organization should be specified in the apph.

h. Estabhshing and maintaining storage facihties. ca tion.

i. MamtJnmg exposure devices, radiography b. The applicant may be licensed by the Comtrus.facilities, and associated equipment. sion to use a commercially available leak test kit. The

application should specifically identify each kit to bej. Estabbshmg anu mamtaming the leak. testing used by designating the kit supplier and the kit model

p ogram. number. Only leak test kits that are specifically iden.tified will be authorized

k. Estabhshing and mamtaining the internalinspection sy stem. The apphcation should identify those who will

*perform the leak test (usmg the kit). If radiographicpersonnel will perform the leak test. specific instructions1. Performing source rc placement and source

uggmg operations. shou.d be mcluded in the operating and emergencyprocedures for personnel. The mstructions and proce.

m. Conductmg quarterly mventones and main. dures provided by leak test kit supphers should betaming utilization logs. modified to fit the applicant's program. For example,

many kit procedur s indicate that the manufacturer ofn. Estabbshmg and conductmg a survey instru. the source should be notified if a survey of the ;eak test

ment calibration program. sample indicates a potentially leakmg source. Instruc.tions to radiographic personnel should indicate that

o. Estabbshmg and maintaming the licensee's management should be informed since deshng withrecord keeping system. suppliers is usually a management function.

156 270- ~

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An appheant may be hcensed by the Commis. momtonng and suney mstruments), prosedures, person-$.

/ , un to perform his own leak tests, includmg takmg and nel or by product matenal to be used.# evaluatmg the smears Should the apphcant destre to

conduct his own leak ;ests, he should submit the mfor- Apphcations for heense amendments may be filed_ mation required by paragraph 34.11(O This should either on the apphca' ion form or in letter form. The

in lude desription of the instrumentation to be used appheation should identify the thense bs number andin evaluating the sc. cars, includmg its sensinvity and should clearly desenbe the cust nature of the requestedaccuracy, and a descnption of the cahbratmg and c h a n g es, additions. or deletions Re fere nces tostandardamg proceJees with a sample calculation pievmusly submitted mformation and documents shouldshowing conversion of results to the required microcurie be tieu and specific and should identify the pertinentunits. Sune) instruments are generally not designed for mformation by date, page, and paragraph-

such measurements and may not t'e acceptable for thisuse. A descnf tion of the matenal to be used in taking 6. RENEWAL OF A LfCENSEthe smears, the pomts on the equipment that will be,

smeared (smears are not norma"y taken directly from An application for renewal of a heense should be filedthe sur'ne of a source, see paragraph 34.25(c)), the at least 30 days prior to the expration date as providedradiation safety procedures to be followed dunng the for in paragraph 30.37(b) of 10 CFR Part 30. This willsmeanng process, the method for handhng and disposmg ensure that the hcense does not expire until final actionof the smears, and the pertinent traimng and expenence on the apphcation has been taken by the NRC.of exh person who will take or esaluate the smearsshould also be included. If radiographic personnel will

Renewal apphcations should be filed on I ormper form the test, specific instructions should beNRC-313R, appropnately supplemented, and should

contamed in the operating and emergency procedurescontam complete and up-todate information about the

5. AMENDMENTS TO LICENSES apphcant's current program.

Licensees are required to conduct their programs m in order to facthtate the review process, the apphea-accordance with statements, representations, and proce- tion for renewal should be submitted without referencedures contained in the hcense apphcation and supportne to prev.ously submitted documents and mf ormation. If

'- documents and in the conditions of the hcense. The such references cannot be asoided, they should be clear. . licene must therefore be amended if the licensee plans and specific and should identify the pertinent mforma.

to make any changes m facihties, equipment (includmg tion by date, page, and paragraph

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156 271

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