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Program-Specific Guidance About Industrial Radiography Licenses - Final Report (NUREG-1556, Vol. 2)On this page: Download complete document The following links on this page are to documents in Adobe Portable Document Format (PDF). See our Plugins, Viewers, and Other Tools page for more information. For successful viewing of PDF documents on our site please be sure to use the latest version of Adobe. Table of Contents
Publication Information[ Next | Top of file ] Manuscript Completed: August 1998 Prepared by J. B. Carrico, A. C. White, D. J. Collins, D. A. Piskura, K. M. Prendergast, D. O. Nellis, M. E. Schwartz Division of Industrial and Medical Nuclear Safety Abstract[ Prev | Next | Top of file ] As part of its redesign of the materials licensing process, NRC is consolidating and updating numerous guidance documents into a single comprehensive repository as described in NUREG-1539, "Methodology and Findings of the NRC's Materials Licensing Process Redesign" and NUREG-1541, "Process and Design for Consolidating and Updating Materials Licensing Guidance" (to obtain, see Availability Notice). NUREG-1556, Vol. 2 is the second program-specific guidance developed for the new process. This document is intended for use by applicants, licensees, and NRC staff and will also be available to Agreement States. This guidance corresponds with the revision to 10 CFR Part 34 published in May 1997. This document combines and supersedes the guidance previously found in draft Regulatory Guide FC 401-4, "Guide for the Preparation of Applications for the Use of Sealed Sources and Devices for Performing Industrial Radiography," and in NMSS Policy and Guidance Directive FC 84-15, "Standard Review Plan for Applications for the Use of Sealed Sources and Devices for Performing Industrial Radiography." This report, where applicable, provides a more risk-informed, performance-based approach to industrial radiography licensing consistent with the current regulations. This final report should be used in preparing requests for licensing actions. NRC staff will use this final report in its review of requests for licensing actions. Figures[ Prev | Next | Top of file ] 8.2 Example Diagram of a Permanent Radiographic Installation 8.3 Material Receipt and Accountability 8.7 Surveillance and Posting at a Temporary Job Site with Multiple Floors and Access Points 8.9 The Well-Dressed Radiographer L.1 Diagram of Office and Device Storage Area United States Nuclear Regulatory Commission Form 313 Form 374 Sample Materials License(1 of 4) Form 374 Sample Materials License(2 of 4) Form 374 Sample Materials License(3 of 4) Form 374 Sample Materials License(4 of 4) Minimum Required Packing for Class 7 (Radioactive) Materials Package and Vehicle Contamination Limits Hazardous Material Shipping Certification Foreword[ Prev | Next | Top of file ] The United States Nuclear Regulatory Commission (NRC) used Business Process Redesign (BPR) techniques to redesign its materials licensing process. This effort is described in NUREG-1539 (to obtain, see Availability Notice). A critical element of the new process is consolidating and updating numerous guidance documents into a NUREG series of reports. Below is a list of volumes currently included in the NUREG-1556 series:
NUREG-1556, Vol. 2, "Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Industrial Radiography Licenses," dated August 1998, provides program-specific guidance for the new process. It is intended for use by applicants, licensees, NRC license reviewers, and other NRC personnel. It supersedes the guidance previously found in Regulatory Guide FC 401-4, "Guide for the Preparation of Applications for the Use of Sealed Sources and Devices for Performing Industrial Radiography," dated October 1984, and in NMSS Policy and Guidance Directive FC 84-15, "Standard Review Plan for Applications for the Use of Sealed Sources and Devices for Performing Industrial Radiography," dated October 1984. This guidance has been prepared to correspond to the new requirements and format established in the revision of 10 CFR Part 34 published in 1997. Appendix A provides a list of Technical Assistance Requests, Information Notices, and Policy and Guidance Directives applicable to radiography which have been considered in the development of this NUREG Report. This Appendix also identifies those documents that have been superseded. NUREG-1556, Vol. 2, takes, where applicable, a more graded (or risk-informed) and performance-based approach to licensing industrial radiography. A team composed of NRC staff from headquarters and regional offices prepared NUREG-1556, Vol. 2. The team drew on its collective experience in radiation safety in general and as specifically applied to industrial radiography. A representative of NRC's Office of the General Counsel provided a legal perspective. NUREG-1556, Vol. 2, "Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Radiography Licenses," dated August 1998, represents a step in the transition from the current paper-based process to the new electronic process. NUREG-1556, Vol. 2 is also available electronically by visiting NRC's Home Page <http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1556/v2/index.html>. This report describes and makes available to the public information on: methods acceptable to the NRC staff for implementing specific parts of the Commission's regulations; techniques the staff uses in evaluating applications, including specific problems or postulated accidents; and data the NRC staff needs to review applications for licenses. NUREG-1556, Vol. 2, "Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Industrial Radiography Licenses," dated August 1998, is not a substitute for NRC regulations, and compliance is not required. The approaches and methods described in this report are provided for information only. Methods and solutions different from those described in this report will be acceptable if they provide a basis for the staff to make the determinations needed to issue or continue a license. _________________________________________ Acknowledgments[ Prev | Next | Top of file ] The writing team thanks the individuals listed below for assisting in the development and review of both the draft and final reports. All participants provided valuable insights, observations, and recommendations. The team also thanks Kay Avery, Mary Carnahan, Angela Case, Elaine Gerdine, Alyce Martin, Tim Woods, Gina Thompson, and Tina Jordan of Computer Sciences Corporation, and Cindy Caldwell from the State of Texas. The Participants[ Prev | Next | Top of file ] Camper, Larry W. Abbreviations[ Prev | Next | Top of file ]
1 Purpose of Report[ Prev | Next | Top of file ] This NUREG report provides guidance to an applicant in preparing an industrial radiography (radiography) license application as well as NRC criteria for evaluating a radiography license application. The term "radiography" as used in this report means an examination of the structure of materials by nondestructive methods, using ionizing radiation to make radiographic images generally using gamma-emitting byproduct materials (radioisotopes). The radioisotopes most commonly used for radiography are cobalt-60 and iridium-192; however, other radioisotopes (e.g. californium-252) with unique radiological characteristics may also be used. This report does not address the research and development of radiography devices or associated equipment, or the commercial aspects of manufacturing, distribution, and service of such devices or equipment. This NUREG report identifies the information needed to complete NRC Form 313 (Appendix B), "Application for Material License," for the use of sealed sources containing byproduct material in radiography devices. The information collection requirements in 10 CFR Parts 30 and 34 and NRC Form 313 have been approved under the Office of Management and Budget (OMB) Clearance Nos. 3150-0017, 3150-0007, and 3150-0120, respectively. The format within this document for each item of technical information is as follows:
Notes, Boxes, and References are self-explanatory and may not be found for each item on NRC Form 313. NRC Form 313 does not have sufficient space for applicants to provide full responses to Items 5 through 11. As indicated on the form, the answers to those items are to be provided on separate sheets of paper and submitted with the completed NRC Form 313. Appendix C provides information on certain topics which may be used in the application and can be used to complete items 5 - 11 of NRC Form 313. Appendix C may also be used as a checklist that NRC staff can use to review applications and applicants can use to check for completeness. Appendix D is a sample radiography license. It contains the conditions most often found on these licenses, although not all licenses will have all conditions. 2 Agreement States[ Prev | Next | Top of file ] Certain states, called Agreement States (see Figure 2.1), have entered into agreements with the NRC that give them the authority to license and inspect byproduct, source, or special nuclear materials used or possessed within their borders. Any applicant other than a Federal agency who wishes to possess or use licensed material in one of these Agreement States needs to contact the responsible officials in that State for guidance on preparing an application; file these applications with State officials, not with the NRC. Naturally-occurring and Accelerator-produced Radioactive Material (NARM) and X-rays are always regulated by the states, not the NRC. In general, NRC's materials licensees who wish to conduct operations at temporary jobsites in an Agreement State should contact that State's radiation control program office for information about State regulations. To ensure compliance with Agreement State reciprocity requirements, a licensee should request authorization well in advance of scheduled use. In the special situation of work at Federally-controlled sites in Agreement States, it is necessary to know the jurisdictional status of the land in order to determine whether NRC or the Agreement State has regulatory authority. NRC has regulatory authority over land determined to be "exclusive Federal jurisdiction," while the Agreement State has jurisdiction over non-exclusive Federal jurisdiction land. Licensees are responsible for finding out, in advance, the jurisdictional status of the specific areas where they plan to conduct licensed operations. NRC recommends that licensees ask their local contact for the Federal agency controlling the site (e.g., contract officer, base environmental health officer, district office staff) to help determine the jurisdictional status of the land and to provide the information in writing, so that licensees can comply with NRC or Agreement State regulatory requirements, as appropriate. Additional guidance on determining jurisdictional status is found in All Agreement States Letter, SP-96-022, dated February 16, 1996. Table 2.1 provides a quick way to check on which agency, if any, has regulatory authority. Table 2.1 Who Regulates the Activity?
Figure 2.1 U.S. Map. Location of NRC Offices and Agreement States. Reference: A current list of Agreement States (including
names, addresses, and telephone numbers of responsible officials) by visiting
the NRC Office of State Programs' (OSP's) Home Page <http://www.hsrd.ornl.gov/nrc> All Agreement States Letter, SP-96-022, dated February 16, 1996, is available
by visiting OSP's Home Page <http://www.hsrd.ornl.gov/nrc>, 3 Management Responsibility[ Prev | Next | Top of file ] The NRC recognizes that effective radiation safety program management is vital to achieving safe and compliant operations. NRC also believes that consistent compliance with its regulations provides reasonable assurance that licensed activities will be conducted safely. NRC believes that effective management will result in increased safety and compliance. NRC frequently finds ineffective management is the underlying cause of safety and compliance problems.
To ensure adequate management involvement, a management representative, (pursuant to 10 CFR 30.32(c)), must be a person duly authorized to act for and on behalf of the applicant or licensee) must sign the submitted application acknowledging management's commitments and responsibility for the following:
For information on NRC enforcement policy, see "General Statement of Policy and Procedures for NRC Enforcement Actions," (NUREG-1600), which is available from NRC upon request (to obtain, see Availability Notice). NUREG-1600 is also available on the Internet. Visit NRC's Home Page <http://www.nrc.gov>, choose "Nuclear Materials," then "Enforcement Program," "Enforcement Guidance Documents," and then " Enforcement Policy." For information on NRC's radiography inspection procedures, see Inspection Procedure 87120. 4 Applicable Regulations[ Prev | Next | Top of file ] It is the licensee's responsibility to have up-to-date copies of applicable regulations, read them, and abide by each applicable regulation. The following Parts of 10 CFR Chapter I contain regulations applicable to radiography devices:
To request copies of the above documents, call GPO's order desk in Washington,
DC at (202) 512-1800. Order the two-volume bound version of Title
10, Code of Federal Regulations, Parts 0-50 and 51-199 from the GPO,
Superintendent of Documents, Post Office Box 371954, Pittsburgh, Pennsylvania
15250-7954. The GPO may also be contacted at <www.gpo.gov> 5 How to File[ Prev | Next | Top of file ] 5.1 Paper Application[ Prev | Next | Top of file ] Applicants for a materials license should do the following:
Deviations from the suggested wording of certain responses as shown in this document or submission of alternative procedures may require a custom review. All license applications will be available for review by the general public in NRC's Public Document Rooms. If it is necessary to submit proprietary information, follow the procedure in 10 CFR 2.790. Failure to follow this procedure may result in disclosure of the proprietary information to the public or substantial delays in processing the application. Employee personal information (e.g., home address, home telephone number, social security number, date of birth, radiation dose information) should not be submitted unless specifically requested by NRC. NRC's future licensing process will be faster and more efficient, in part, through acceptance and processing of electronic applications. NRC recommends using a signed NRC Form 313. Other components may be submitted in paper or electronic media. However, those components submitted in paper format will be scanned and converted to electronic format. To ensure a smooth transition, applicants are requested to follow these suggestions:
5.2 Electronic Application[ Prev | Next | Top of file ] As the electronic licensing process develops, it is anticipated that NRC may provide mechanisms for filing applications via diskettes or CD-ROM, and through the Internet. Additional filing instructions will be provided as these new mechanisms become available. 6 Where To File[ Prev | Next | Top of file ] Applicants wishing to possess or use licensed material in any State or U. S. territory or possession subject to NRC jurisdiction must file an application with the NRC Regional Office for the locale in which the material will be possessed and/or used. Figure 2.1 shows NRC's four Regional Offices and their respective areas for licensing purposes. Figure 2.1 also identifies Agreement States. In general, applicants wishing to possess or use licensed material in Agreements States must file an application with the Agreement State, not NRC. However, if work will be conducted at Federally controlled sites in Agreement States, applicants must first determine the jurisdictional status of the land in order to determine whether NRC or the Agreement State has regulatory authority. See the section on "Agreement States" for additional information. 7 License Fees[ Prev | Next | Top of file ] Each application for which a fee is specified, including applications for new licenses and license amendments, must be accompanied by the appropriate fee. Refer to 10 CFR 170.31 to determine the amount of the fee. NRC will not issue the new license prior to fee receipt. Once technical review has begun, no fees will be refunded; application fees will be charged regardless of the NRC's disposition of an application or the withdrawal of an application. Most NRC licensees are also subject to annual fees; refer to 10 CFR 171.16. Consult 10 CFR 171.11 for additional information on exemptions from annual fees and 10 CFR 171.16(c) on reduced annual fees for licensees that qualify as "small entities." Direct all questions about NRC's fees or completion of Item 12 of NRC Form 313 (Appendix B) to the Office of the Controller (OC) at NRC headquarters in Rockville, Maryland, (301) 415-7554. You may also call NRC's toll free number (800) 368-5642 and then ask for extension 415-7554. 8 Contents of an Application[ Prev | Next | Top of file ] The following comments apply to the indicated items on NRC Form 313 (Appendix B). 8.1 Item 1: License Action Type[ Prev | Next | Top of file ] THIS IS AN APPLICATION FOR (Check appropriate item)
Check box A for a new license request. Check box B for an amendment of an existing license and provide license number. See "Amendments and Renewals to a License," Section 9 of this document. Check box C for a renewal of an existing license and provide license number. 8.2 Item 2: Applicant's Name and Mailing Address[ Prev | Next | Top of file ] Response from Applicant: List the legal name of the applicant's corporation or other legal entity with direct control over use of the radioactive material; a division or department within a legal entity may not be a licensee. An individual may be designated as the applicant only if the individual is acting in a private capacity and the use of the radioactive material is not connected with employment in a corporation or other legal entity. Provide the mailing address where correspondence should be sent. Note: NRC must be notified in the event of transfer of control and bankruptcy proceedings; see below for more details. Timely Notification of Transfer of ControlRegulations: 10 CFR 30.34(b). Criteria: Licensees must provide full information and obtain NRC's prior written consent before transferring control of the license, directly or indirectly, or, as some licensees call it, "transferring the license." Discussion: Transfers of control may be the results of mergers, contractual agreements, buyouts, or majority stock transfers. Although it is not NRC's intent to interfere with the business decisions of licensees, it is necessary for licensees to obtain prior NRC written consent. This is to ensure the following:
For additional guidance, see IN 89-25, rev. 1 dated Dec. 7, 1994. Response from Applicant: None from an applicant for a new license; Appendix E identifies the information to be provided about transfer of control. Notification of Bankruptcy Proceedings Regulation: 10 CFR 30.34(h) Criteria: Immediately (within 24 hours) following filing of voluntary or involuntary petition for bankruptcy for or against a licensee, the licensee must notify the appropriate NRC Regional Administrator, in writing, identifying the bankruptcy court in which the petition was filed and the date of filing. Response from Applicant: None at time of application for a new license. 8.3 Item 3: Address(es) Where Licensed Material Will Be Used or Possessed
[ Prev | Next | Top of file ] Regulations: 10 CFR 30.33(a)(2), 10 CFR 34.11, 10 CFR 34.13(j), 10 CFR 34.33, 10 CFR 34.89, 10 CFR 34.101(c). Criteria: Applicants must provide a specific address for each location where radioactive material will be used or stored, or dispatched. Discussion: Specify the street address, city, and state or other descriptive address (such as on Highway 10, 5 miles east of the intersection of Highway 10 and State Route 234, Anytown, State) for each permanent storage or use facility and field station. A field station is a location where licensed material may be stored or used and from which the applicant will dispatch equipment to jobsites. A Post Office Box address is insufficient because NRC needs a specific address to allow an NRC inspector to find the use and/or storage location. If devices will NOT be stored at a dispatch site or field station, indicate this. Also the applicant should state whether a location will be used to perform radiographic operations or only for storage of sources and devices. Response from Applicant: If a device will be used in a permanent radiographic installation, give the specific address of each location. If applicable, describe the locations outside of the installation where radiographic operations will be conducted. If radiography equipment will be stored and /or used at a field station, give the specific address of each field station. If radiography operations will be conducted at temporary jobsites (i.e., locations where work is conducted for limited periods of time), specify "temporary jobsites anywhere in the United States where NRC maintains jurisdiction." Note: If radiography operations are expected to exceed 180 days at a temporary jobsite, then provide written notification to the appropriate NRC regional office prior to exceeding the 180 days (a license amendment is not required). 8.4 Item 4: Person to Be Contacted about this Application
[ Prev | Next | Top of file ] Identify the individual who can answer questions about the application and include his or her telephone number. This is typically the proposed radiation safety officer (RSO) or knowledgeable management official. The NRC will contact this individual if there are questions about the application. Notify NRC if the contact person or telephone number changes. This notice is for "information only" and does not require a license amendment or a fee.
8.5 Item 5: Radioactive Material
[ Prev | Next | Top of file ] 8.5.1 Sealed Sources and DevicesRegulation: 10 CFR 30.32(g), 10 CFR 30.33(a)(2), 10 CFR 32.210, 10 CFR 34.20. Criteria: Applicants must provide the manufacturer's (or distributor's) name and model number for each requested source assembly (sealed source), exposure device, and source changer. Licensees will only be authorized for radiographic exposure devices, source assemblies or sealed sources containing byproduct material and associated equipment meeting NRC performance requirements and specifically approved or registered by NRC or an Agreement State. Also, identify any depleted uranium that is used as shielding material (radiographic exposure devices, source changers and some collimators contain depleted uranium). Discussion: NRC or an Agreement State performs a safety evaluation of radiography source assemblies (sealed sources) exposure devices and source changers prior to distribution of these sources/devices to specific licensees. The safety evaluation is documented in a Sealed Source and Device (SSD) Registration Certificate issued to the manufacturer (or distributor). Therefore, if the source assemblies, exposure devices, or source changers are approved for use by NRC or an Agreement State agency, the applicant need only note the manufacturer's (or distributor's) name and model number of the sources/devices in its license application to demonstrate that the requirements are met. Consult with the proposed supplier to ensure that sources and devices conform to the sealed source and device designations registered with NRC or an Agreement State. For licensees to ensure that they use radiographic equipment in accordance with registration certificates, licensees may want to review the certificate, discuss with the manufacturer, or obtain a copy of the certificate. Licensees may not make modifications to exposure devices, source changers, source assemblies and associated equipment unless the design of any replacement component, including source holder, source assembly, controls or guide tubes would not compromise the safety features of the system. Consult with the manufacturer of the associated equipment (i.e., equipment that is used in conjunction with the exposure device that drives, guides, or comes in contact with the source) to be sure that the associated equipment is compatible with the sources and devices. Licensees must demonstrate that associated equipment meet the performance requirements in 10 CFR 34.20. Information Notice 96-20: "Demonstration of Associated Equipment Compliance with 10 CFR 34.20" (Appendix F) contains a number of ways that licensees can demonstrate that their associated equipment meets performance requirements. Response from Applicant:
Table 8.1 Industrial Nuclear Model Ir-100 Exposure Device Maximum Authorization -- 120 Ci
Table 8.2 Spec Model 150 Exposure Device Maximum Authorization -- 150 Ci
Table 8.3 Amersham Model 680 System Exposure Device Maximum Authorization -- 110 Ci
Table 8.4 Amersham Model 660 System Exposure Device Maximum Authorization -- 140 Ci
Note: For information on SSD registration certificates, contact the Registration Assistant by calling NRC's toll free number (800) 368-5642 and then asking for extension 415-7217. 8.5.2 Financial Assurance and Recordkeeping for DecommissioningRegulations: 10 CFR 30.34(b), 10 CFR 30.35, 10 CFR 34.13(k). Criteria: Industrial radiography licensees authorized to possess sealed sources containing byproduct material in excess of the limits specified in 10 CFR 30.35 must provide evidence of financial assurance for decommissioning. Licensees are required to maintain, in an identified location, decommissioning records related to structures and equipment where devices are used or stored and records related to leaking sources. Licensees must transfer these records important to decommissioning either to any new licensee before licensed activities are transferred or assigned in accordance with 10 CFR 30.34(b), or to the appropriate NRC regional office before the license is terminated. Discussion: The requirements for financial assurance are specific to the types and quantities of byproduct material authorized on a license. Most industrial radiography applicants and licensees do not need to comply with the financial assurance requirements because the thresholds for sealed sources containing byproduct material are 3.7 x 105 Bq (10,000 curies) of cobalt-60 and 3.7 x 106 Bq (100,000 curies) of cesium-137 or byproduct material with half-lives less than 120 days (e.g., iridium-192). Thus, a licensee would need to possess hundreds of sources before the financial assurance requirements would apply. Since the standard industrial radiography license does not specify the maximum number of sources that the licensee may possess (allowing the licensee flexibility in obtaining sources/devices as needed without amending its license), it contains a condition requiring the licensee to limit its possession of sources to quantities not requiring financial assurance for decommissioning. Applicants and licensees desiring to possess sources exceeding the threshold amounts must submit evidence of financial assurance. The same regulation also requires that licensees maintain records important to decommissioning in identified locations other than at any temporary jobsite. All industrial radiography licensees need to maintain records of structures and equipment where devices are used or stored. As-built drawings showing modifications to structures and equipment fulfill this requirement. If drawings are not available, licensees may substitute appropriate records (e.g., a sketch of the room, building or a narrative description of the area) concerning the areas and locations. In addition, industrial radiography licensees who have experienced unusual occurrences (e.g., leaking sources or other incidents that involve spread of contamination, such as S-tube breakthrough) also need to maintain records about contamination that remains after cleanup or contamination that may have spread to inaccessible areas. Response from Applicants: State: "Pursuant to 10 CFR 30.35(g), we shall maintain drawings and records important to decommissioning and to transfer these records to a new licensee before licensed activities are transferred, or to assign the records to the appropriate NRC regional office before the license is terminated." AND If financial assurance is required, submit evidence. Reference: Regulatory Guide 3.66, "Standard Format and Content of Financial Assurance Mechanisms Required for Decommissioning Under 10 CFR Parts 30, 40, 70, and 72," is available from NRC upon request. 8.6 Item 6: Purpose(s) for Which Licensed Material Will Be Used
[ Prev | Next | Top of file ] Regulations: 10 CFR 30.33(a)(1), 10 CFR 34.1. Criteria: Sources and devices will be used only for the purposes for which they were designed and in accordance with the manufacturer's recommendations for use as specified in an approved Sealed Source and Device (SSD) Registration Certificate. Discussion: The typical license authorizes persons to perform source exchanges and to conduct industrial radiography at temporary jobsites, field stations, and/or permanent radiographic installations. Unusual uses will be evaluated on a case-by-case basis and the authorized use condition will reflect approved uses. Applicants who plan to perform radiographic operations on lay-barges, on offshore platforms, or underwater must specifically request these operations. Response from Applicant:
OR
AND
8.7 Item 7: Individual(s) Responsible for Radiation Safety Program and Their Training and Experience
[ Prev | Next | Top of file ] 8.7.1 Radiation Safety Officer (RSO)Regulations: 10 CFR 34.13(f), 10 CFR 34.13(g), 10 CFR 34.42. Criteria: RSOs and potential designees responsible for ensuring that the licensee's radiation safety program is implemented in accordance with approved procedures must have adequate training and experience. Discussion: The person responsible for the radiation protection program is called the RSO. The NRC believes the RSO is the key to overseeing and ensuring safe operation of the licensee's radiography program. The RSO needs independent authority to stop operations that he or she considers unsafe. He or she must have sufficient time and commitment from management to fulfill certain duties and responsibilities to ensure that radioactive materials are used in a safe manner. The RSO may delegate certain day-to-day tasks of the radiation protection program to other responsible individuals (potential designees). For example, a large testing company with multiple field stations may appoint individuals designated as "site RSOs" who assist the RSO and are responsible for the day-to-day activities at the field stations. Licensees may also appoint other individuals who may "step-in" as an emergency contact when the RSO is unavailable. The potential designees do not need to meet the required RSO qualifications; however, these individuals should be qualified, experienced radiographers who are adequately knowledgeable of the activities to which they are assigned. Applicants do not have to identify other responsible individuals if day-to-day tasks, etc. will not be delegated. Typical RSO duties are illustrated in Figure 8.1. NRC requires the name of the RSO on the license to ensure that licensee management has always identified a responsible, qualified person and that the named individual knows of his or her designation as RSO. Provide NRC with a copy of an organizational chart showing the RSO (and other designated responsible individuals) to demonstrate that he or she has sufficient independence and direct communication with responsible management officials. Also, show in the organizational chart the position of the individual who signs the application in Item 13 of the NRC Form 313. To be considered eligible for the RSO position, an individual must be a qualified radiographer, have a minimum of 2,000 hours (one year full-time field experience) of hands-on experience as a qualified radiographer, and have formal training in establishing and maintaining a radiation protection program. This should be a course specifically designed to provide training in running a radiation safety program, a basic radiation safety course is not acceptable. While a course particular to industrial radiography would be highly encouraged, this is not required. Acceptable training programs would be would be a classroom course typical of those provided through universities or commercial training facilities. Hands-on experience means experience in all areas considered to be directly involved in the radiography process. This includes taking radiographs, surveying device and radiation areas, transporting the radiography equipment to temporary jobsites, posting, work sites, radiation area surveillance, completing and maintaining records, etc. Excessive time spent in only one or two of these operations (film development and/or area surveillance) should not be counted toward the 2,000 hours. Experience with radiography using x-rays can be included; however, the majority of experience should be in isotope radiography. Figure 8.1 Responsibilities. Typical duties and responsibilities of RSOs. Note: The NRC will consider individuals with alternative training and experience as RSOs. For example, a person certified in health physics or industrial hygiene with previous experience in managing a radiation safety program of comparable size and scope could be considered as an individual case. The qualifications, training, and experience required of the RSO may vary depending upon the complexity of the applicant's operations and number of radiography personnel. Response from Applicant: Provide the following:
AND
AND EITHER
OR
Note: It is important to notify NRC and obtain a license amendment prior to making changes in the designation of the RSO responsible for the radiation safety program. If the RSO leaves the organization before an amendment is approved by the NRC, a potential designee, who meets the RSO qualification requirements, is responsible for ensuring that the licensee's radiation safety program is implemented in accordance with the license and NRC regulations. Alternative responses will be reviewed against the criteria listed above. 8.8 Item 8: Training for Radiographers and Radiographer's Assistants
[ Prev | Next | Top of file ] Regulations: 10 CFR 19.12, 10 CFR 30.33, 10 CFR 34.13, 10 CFR 34.43. Criteria: Radiographers and radiographer's assistants must have adequate training and experience as outlined in 10 CFR 34.43. Discussion:
Refer to Appendix G as an aid to determining the specific training requirements for radiographers and radiographer's assistants. The applicant must submit a description of their training program for radiographers and radiographers assistants.
Because 10 CFR Part 34 contains different requirements for radiographers and radiographer's assistants, include training programs for each. When describing the training programs for these positions, include the sequence of events from the time of hiring through the designation of individuals as radiographers or radiographer's assistants. Experienced radiographers who have worked for another licensee should receive formal instruction similar to that given to prospective radiographer's assistants. This instruction must include training in your operating and emergency procedures, in the use of your exposure devices and associated equipment, and in the use of survey meters and other radiation monitoring devices. Instructors who provide classroom training to individuals in the principles of radiation and radiation safety should have knowledge and understanding of these principles beyond those obtainable in a course similar to the one given to prospective radiographers. Individuals who provide instruction in the hands-on use of radiography equipment should be qualified radiographers with at least 1 year of experience in performing radiography, or should possess a thorough understanding of the operation of radiographic equipment (e.g., a manufacturer's service representative). An internal inspection program (audit program) of the job performance of each radiographer and radiographer's assistant ensures that the Commission's regulations, license requirements, and the licensee's operating and emergency procedures are followed. The audit must include observation of the performance of each radiographer and radiographer's assistant during an actual industrial radiographic operation at intervals not to exceed 6 months. If a radiographer or radiographer's assistant has not participated in an industrial radiographic operation for more than 6 months, the individual must demonstrate knowledge of the training requirements by practical examination before participating in a radiographic operation. The person conducting internal inspections should have a minimum of one year actual experience as a radiographer. Response from Applicant: Submit an outline of the training to be given to prospective radiographers and radiographer's assistants. Submit your procedures for experienced radiographers who have worked for another licensee. Provide a copy of a typical examination and the correct answers to the examination questions. Indicate the passing grade. Prior to June 27, 1999, you may affirm that all individuals acting as radiographers will be certified in radiation safety in lieu of providing a description of your training and examination program in the topics listed in 10 CFR 34.43(g). (All other training program descriptions must still be submitted.) Specify the qualifications of your instructors in radiation safety principles and describe their experience with radiography. If training will be conducted by someone outside the applicant's organization, identify the course by title and provide the name and address of the company providing the training. Describe the field (practical) examination that will be given to prospective radiographers and radiographer's assistants. The NRC suggests using the checklist in Appendix H as a source of potential areas to review during the field examination. Describe the annual refresher training program, including topics to be covered and how the training will be conducted. Submit your procedures for verifying and documenting the certification status of radiographers and for verifying that their certification remains valid. As a minimum your procedures for newly hired, previously certified individuals should require documentation of your contacting the certifying entity and confirming the certification. Your procedures should also ensure you are aware of certification expiration dates and that individuals with expired certifications do not act a radiographers. Submit a description of your program for inspecting the job performance of each radiographer and radiographers' assistant at intervals not to exceed 6 months as described in 10 CFR 34.43(e).
8.9 Item 9: Facilities and Equipment
[ Prev | Next | Top of file ] Regulations: 10 CFR 20.1003, 10 CFR 20.1301, 10 CFR 20.1601, 10 CFR 20.1801, 10 CFR 20.1802, 10 CFR 30.33, 10 CFR 34.13(j), 10 CFR 34.33, 10 CFR 34.89. Criteria: Licensees must specifically identify and describe permanent radiographic installations and field stations, and any other locations where radiography will be conducted. Discussion: A permanent radiographic installation is an enclosed shielded room, cell, or vault in which radiography may be performed. A facility is considered "permanent" if it is intended to be used for radiography, even if radiography is rarely performed there. The nature of the facility, rather than the frequency of use, determines a permanent radiographic installation. All radiographic operations conducted at locations of use authorized on the license must be conducted in a permanent radiographic installation, unless specifically authorized by NRC. If licensees need to perform radiography at their place of business outside of a permanent facility due to unique circumstances (the item to be radiographed is too large for the facility), then the NRC must authorize this method of use. In this case two individuals must be present whenever radiographic operations occur outside of a permanent installation. The one primary (and perhaps the most important) reason licensees have for conducting radiography in a permanent radiographic installation is that they can limit access restrictions imposed at a work location. In order to ensure this control a permanent radiographic installation, if located on the ground, must be enclosed by a minimum of four shielded walls (otherwise the floor must also be shielded). The use of materials that do not realistically provide shielding, do not qualify. Areas outside of the facility generally should qualify as unrestricted areas. While the area outside of an installation should qualify as an unrestricted area (i.e., not exceed 2mr/hr), the regulation did not specify radiation limits in order to allow for design flexibility for moving equipment into and out of the installation, or other considerations. Radiation levels slightly exceeding these levels outside of the facility should only be considered or allowed when the higher levels are due to "sky shine" or the need for equipment movement. If the roof of the facility does not qualify as a restricted area, or if no roof exists, mechanical access restrictions (fence, etc.) must be utilized and additional administrative controls must imposed to ensure that unwanted access can be gained only through extraordinary effort. All entrance ways into the facility must be interlocked with 10 CFR Part 34 required control devices. Unless all entrance ways are locked, at least one radiographer must be present at the facility whenever radiography is being conducted. A field station is a facility where licensed material may be stored and/or used and from which equipment is dispatched. Radiographic operations may be conducted in a permanent radiographic installation or at the place of business in the same manner as described above. A restricted area is an area that licensees limit access for the purpose of protecting individuals from undue risks from exposure to radiation and radioactive materials. A restricted area cannot include areas used as residential quarters. Consequently, industrial radiography devices must not be stored in motel rooms or similar locations. Requirements for a permanent radiographic installation:
Figure 8.2 Example Diagram of a Permanent Radiographic Installation
Response from Applicant: Provide the following:
Variances will be considered if construction requirements preclude shielding the roof(1) in order to meet the requirement not to exceed 0.02 mSv (2 mrem) in any one hour. Provide the following information to obtain approval for a variance:
If radiation levels on the radiography installation roof1 exceed 1.0 mSv (100 mrem) in any one hour, then provide the following information in addition to the items above to apply for this variance:
Field Stations:
Note: Rem, and its SI equivalent Sievert, will be used in this report whenever units of radiation exposure or dose are required. This is done since 10 CFR Part 20 sets dose limits in terms of rem, not rad or roentgen, and the sealed sources used in radiography emit gamma rays, which means that 1 roentgen = 1 rad = 1 rem. 8.10 Item 10: Radiation Safety Program
[ Prev | Next | Top of file ] Regulations: 10 CFR 20.1101, 10 CFR 30.33, 10 CFR 34.13. Criteria: A radiation safety program must be established and submitted to the NRC as part of the application. The program must be commensurate with the scope and extent of activities for the use of licensed materials in industrial radiography. Each applicant for an industrial radiography license must develop, document, and implement a radiation protection program containing the following elements:
Discussion: The specific components of the applicant's radiation safety program are detailed in the following topics found in this NUREG. Some topics will not require the applicant to submit information as part of an application, but simply provide the applicant with guidance to comply with a specific NRC requirement. 8.10.1 Radiation Safety Program AuditRegulations: 10 CFR 20.1101, 10 CFR 20.2102. Criteria: Licensees must review the content and implementation of their radiation protection programs annually to ensure:
Discussion: Appendix I contains a suggested annual audit program that is specific to industrial radiography and is acceptable to NRC. All areas indicated in Appendix I may not be applicable to every licensee and may not need to be addressed during each audit. Audit records acceptable to NRC should contain the following information:
It is essential that once identified, problems be corrected in a timely manner. Information Notice (IN) 96-28, "Suggested Guidance Relating to Development and Implementation of Corrective Action," provides guidance on this subject. The NRC will review the licensee's audit results and determine if corrective actions are thorough, timely, and sufficient to prevent recurrence. If violations are identified by the licensee and these steps are taken, the NRC can |
and choose "Directories" and then "State Program Directors." Or may be
obtained upon request from NRC's Regional Offices (see Figure 2.1
for addresses and telephone numbers).