Consolidated Guidance 

About Materials Licenses

Program-Specific Guidance About

Industrial Radiography Licenses

Draft Report for Comment

Office of Federal and State Materials and

Environmental Management Programs

NUREG-1556

Volume 2, Rev. 1
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Consolidated Guidance 

About Materials Licenses

Program-Specific Guidance About

Industrial Radiography Licenses

Draft Report for Comment

Manuscript Completed: November 2011

Date Published: November 2011

Prepared by

J. B. Carrico

L. C. Dimmick

C. Z. Gordon

T. L. Simmons

R. J. Torres,

A. M. Troxler

Office of Federal and State Materials and

 Environmental Management Programs

NUREG-1556

Volume 2, Rev. 1
ii

COMMENTS ON DRAFT REPORT 

Any interested party may submit comments on this report for consideration by the NRC staff. 

Comments may be accompanied by additional relevant information or supporting data. Please 

specify the report number, NUREG-1556, Volume 2, Revision 1, in your comments and send 

them by the end comment period specified in the Federal Register notice announcing the 

availability of this draft. 

To submit comments: 

Cindy Bladey, Chief, Rules, Announcements, and Directives Branch 

Office of Administration 

Mail Stop: TWB-05-B01M 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 

Fax: (301) 492-3446 

For any questions about the material in this report, please contact: 

Tomas Herrera 

Mail Stop: T-8E24 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 

Phone: (301) 415-7138 

E-mail: tomas.herrera@nrc.gov 

Please be aware that any comments that you submit to the NRC will be considered a public 

record and entered into the Agencywide Documents Access and Management System 

(ADAMS). Do not provide information you would not want to be publically available. 
iii 

ABSTRACT 

This technical report contains information intended to provide program-specific guidance and 

assist applicants and licensees in preparing applications for materials licenses for industrial 

radiography. In particular, it describes the types of information needed to complete U.S. 

Nuclear Regulatory Commission (NRC) Form 313, “Application for Materials License.” This 

document describes both the methods acceptable to the NRC license reviewers in 

implementing the regulations and the techniques used by the reviewers in evaluating the 

application to determine if the proposed activities are acceptable for licensing purposes. 

This NUREG references information collection requirements that are subject to the Paperwork 

Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These information collections were approved 

by the Office of Management and Budget, approval numbers 3150-0014; 3150-0011; 3150-

0021; 3150-0151; 3150-0155; 3150-0008; 3150-0002; and 3150-0093. 

The NRC may not conduct or sponsor, and a person is not required to respond to, a request for 

information or an information collection requirement unless the requesting document displays a 

currently valid OMB control number.

Paperwork Reduction Act Statement

Public Protection Notification

v

CONTENTS

ABSTRACT ............................................................................................................................... iii 

FOREWORD ............................................................................................................................. ix 

ACKNOWLEDGMENTS ............................................................................................................ xi 

ABBREVIATIONS.................................................................................................................... xiii 

1 PURPOSE OF REPORT ....................................................................................................... 1 

2 AGREEMENT STATES ......................................................................................................... 3 

3 MANAGEMENT RESPONSIBILITY ...................................................................................... 7 

 3.1 Safety Culture ........................................................................................................... 8 

4 APPLICABLE REGULATIONS ............................................................................................. 9 

5 HOW TO FILE .................................................................................................................... 11 

 5.1 Paper Application .................................................................................................... 11 

 5.2 Where to File ........................................................................................................... 11 

 5.3 Transfer to Electronic Format .................................................................................. 12 

6 IDENTIFYING AND PROTECTING SENSITIVE INFORMATION ........................................ 13 

7 APPLICATION AND LICENSE FEES ................................................................................. 15 

8 CONTENTS OF AN APPLICATION .................................................................................... 17 

 8.1 Item 1: License Action Type ................................................................................ 18 

 8.2 Item 2: Applicant's Name and Mailing Address .................................................... 18 

 8.2.1 Notification of Bankruptcy Proceedings ..................................................... 18 

 8.3 Item 3: Address(es) Where Licensed Material Will Be Used or Possessed ......... 19 

 8.4 Item 4: Person To Be Contacted About This Application ..................................... 20 

 8.5 Item 5: Radioactive Material ................................................................................ 21 

 8.5.1 Sealed Sources and Devices .................................................................... 21 

 8.5.2 Financial Assurance and Recordkeeping for Decommissioning ................ 22 

 8.6 Item 6: Purpose(s) for Which Licensed Material Will Be Used ............................. 23 

 8.7 Item 7: Individuals Responsible for Radiation Safety program and 

 Their Training and Experience .............................................................................. 24 

 8.7.1 Radiation Safety Officer ............................................................................ 24 

 8.8 Item 8: Training for Radiographers and Radiographer's Assistants ..................... 27 

 8.9 Item 9: Facilities and Equipment .......................................................................... 29 

 8.10 Item 10: Radiation Safety Program .................................................................... 34 

 8.10.1 Audit Program ........................................................................................ 34 

 8.10.2 Radiation Monitoring Instruments ........................................................... 35 

 8.10.3 Material Receipt and Accountability ....................................................... 36 

 8.10.4 Minimization of Contamination ............................................................... 38 

 8.10.5 Leak Tests ............................................................................................. 38 

 8.10.6 Occupational Dose ................................................................................. 39 

 8.10.7 Public Dose ............................................................................................ 40 

 8.10.8 Quarterly Maintenance ........................................................................... 42 

 8.10.9 Operating and Emergency Procedures .................................................. 43 
vi

 

 8.10.9.1 Operating and Emergency Procedures: Handling and 

 Use of Sealed Sources and Radiography Exposure 

 Devices ................................................................................. 44 

 8.10.9.2 Operating and Emergency Procedures: Methods and 

 Occasions for Conducting Required Radiation Surveys ........ 45 

 8.10.9.3 Operating and Emergency Procedures: Methods for 

 Controlling Access to Radiographic Areas ............................. 47 

 8.10.9.4 Operating and Emergency Procedures: Methods and 

 Occasions for Locking and Securing Radiographic Exposure 

 Devices, Storage Containers, and Sealed Sources...... ......... 50 

 8.10.9.5 Operating and Emergency Procedures: Personnel 

 Monitoring and Use of Personnel Monitoring Equiprment ...... 51 

 8.10.9.6 Operating and Emergency Procedures: Transporting Sealed 

 Sources to Field Locations, Securing Exposure Devices and 

 Storage Containers in Vehicles, Posting Vehicles, and 

 Controlling Sealed Sources During Transportation............. ... 52 

 8.10.9.7 Operating and Emergency Procedures: Daily Inspection 

 and Maintenance of Radiographic Equipment ....................... 54 

 8.10.9.8 Operating and Emergency Procedures: Ratemeter Alarms 

 or Off-Scale Dosimeter Readings .......................................... 55 

 8.10.9.9 Procedures for Identifying and Reporting Defects 

 and Noncompliance As Required By 10 CFR Part 21 ............. 56 

 8.10.9.10 Notification of Proper Persons in the Event of an 

 Accident .............................................................................. 57 

 8.10.9.11 Minimizing Exposure of Persons in the Event of an 

 Accident .............................................................................. 58 

 8.10.9.12 Source Retrieval .................................................................. 59 

 8.10.9.13 Maintenance of Records ...................................................... 61 

 8.10.10 Security Program ................................................................................. 61 

 8.11 Item 11: Waste Management ............................................................................ 62 

 8.11.1 Disposal or Transfer of Radiography Sealed Sources Containing 

 Byproduct Material or Devices Containing Depleted Uranium ................ 62 

 8.12 Item 12: License Fees ....................................................................................... 63 

 8.13 Item 13: Certification .......................................................................................... 63 

9 AMENDMENTS AND RENEWALS TO A LICENSE ........................................................... 65 

 9.1 Timely Notifcation of Transfer of Control .............................................................. 65 

10 APPLICATIONS FOR EXEMPTIONS ................................................................................. 67 

11 TERMINATION OF ACTIVITIES ......................................................................................... 69
vii

APPENDICES 

A. LIST OF DOCUMENTS CONSIDERED IN DEVELOPMENT OF THIS NUREG ......... A-1 

B. U.S. NUCLEAR REGULATORY COMMISSION FORM 313 ....................................... B-1 

C. SUGGESTED FORMART FOR PROVIDING INFORMATION REQUESTED IN ITEMS 5 

THROUGH 11 OF U.S. NUCLEAR EGULATORY COMMISSION FORMS 313 .......... C-1 

D. LICENSING GUIDANCE FOR LAY-BARGE AND OFFSHORE RADIOGRAPHY ....... D-1 

E. RADIOGRAPHER AND ASSISTANT RADIOGRAPHER TRAINING .......................... E-1 

F. SIX-MONTH RADIOGRAPHER/RADIOGRAPHER'S ASSISTANT INSPECTION 

CHECKLIST ................................................................................................................ F-1 

G. RADIDIATION SAFETY PROGRAM AUDIT ................................................................ G-1 

H. MODEL PROCEDURES FOR CALIBRATING SURVEY INSTRUMENTS .................. H-1 

I. REQUESTS TO PERFORM LEAK TESTING AND SAMPLE ANALYSIS .................... I-1 

J. GUIDANCE FOR DEMONSTRATING THAT INDIVIDUAL MEMBERS OF THE PUBLIC 

WILL NOT RECEIVE DOSES EXCEEDING THE ALLOWABLE LIMITS ..................... J-1 

K. INFORMATION FOR APPLICANTS TO CONSIDER WHEN DEVELOPING 

PROCEDURES FOR OPERATING RADIOGRAPHY EQUIPMENT ............................ K-1 

L. TRANSPORTATION............ ....................................................................................... L-1 

M. DAILY MAINTENANCE CHECK FOR RADIOGRAPHIC EQUIPMENT ....................... M-1 

N. SUGGESTED EXAMPLE OF A ROUTINE EMERGENCY PROCEDURE ................... N-1 

O. INFORMATION NEEDED FOR TRANSFER OF CONTROL APPLICATION .............. O-1 

P. SAFETY CULTURE STATEMENT OF POLICY .......................................................... P-1 
viii

FIGURES 

Figure 2.1 U.S. map: locations of NRC offices and Agreement States. ............................... 3

Figure 8.1 Location of use. ................................................................................................. 19 

Figure 8.2 Typical duties and responsibilities of RSOs. ...................................................... 26 

Figure 8.3 Example diagram of a permanent radiographic installation ................................ 31 

Figure 8.4 Material receipt and accountability ..................................................................... 37 

Figure 8.5 Dose limits for radiation workers. ....................................................................... 39 

Figure 8.6 Storing devices. ................................................................................................. 41 

Figure 8.7 Posting ............................................................................................................... 48 

Figure 8.8 Surveillance and posting at a temporary jobsite with multiple floors and access 

points ................................................................................................................. 49 

Figure 8.9 Security. ............................................................................................................. 51 

Figure 8.10 The well-dressed radiographer. ......................................................................... 52 

Figure 8.11 Transportation.................................................................................................... 53 

Figure 8.12 Emergency procedures. ..................................................................................... 59 

TABLES 

Table 2.1 Who Regulates the Activity? ................................................................................ 4 

Table 8.1 Surveys Required for Radiographic Operations ................................................. 46 

Table 8.2 Regulatory-Required Notifications ..................................................................... 57 

 
ix

FOREWORD 

The U.S. Nuclear Regulatory Commission’s (NRC’s) NUREG-1556 technical report series 

provides a comprehensive source of reference information about various aspects of materials 

licensing and materials program implementation. These reports, where applicable, describe a 

risk-informed, performance-based approach to licensing consistent with the current regulations. 

The reports are intended for use by applicants, licensees, license reviewers, and other NRC 

personnel. The NUREG-1556 series currently includes the following volumes: 

Vol. No. Volume Title 

1 Program-Specific Guidance about Portable Gauge Licenses 

2 Program-Specific Guidance about Industrial Radiography Licenses 

3 Applications for Sealed Source and Device Evaluation and Registration 

4 Program-Specific Guidance about Fixed Gauge Licenses 

5 Program-Specific Guidance about Self-Shielded Irradiator Licenses 

6 Program-Specific Guidance about 10 CFR Part 36 Irradiator Licenses 

7 Program-Specific Guidance about Academic, Research and Development, and 

Other Licenses of Limited Scope 

8 Program-Specific Guidance about Exempt Distribution Licenses 

9 Program-Specific Guidance about Medical Use Licenses 

10 Program-Specific Guidance about Master Materials Licenses 

11 Program-Specific Guidance about Licenses of Broad Scope 

12 Program-Specific Guidance about Possession Licenses for Manufacturing and 

Distribution 

13 Program-Specific Guidance about Commercial Radiopharmacy Licenses 

14 Program-Specific Guidance about Well Logging, Tracer, and Field Flood Study 

Licenses 

15 Guidance about Changes of Control and about Bankruptcy Involving Byproduct, 

Source, or Special Nuclear Materials Licenses 

16 Program-Specific Guidance about Licenses Authorizing Distribution to General 

Licensees 

17 Program-Specific Guidance about Special Nuclear Material of Less Than 

Critical Mass Licenses 
x

18 Program-Specific Guidance about Service Provider Licenses 

19 Guidance for Agreement State Licensees About NRC Form 241 “Report of 

Proposed Activities in Non-Agreement States, Areas of Exclusive Federal 

Jurisdiction, or Offshore Waters” and Guidance for NRC Licensees Proposing 

to Work in Agreement State Jurisdiction (Reciprocity) 

20 Program-Specific Guidance about Administrative Licensing Procedures 

21 

22 

Program-Specific Guidance about Possession Licenses for Production of 

Radioactive Materials Using an Accelerator 

Reserved 

The current document, NUREG-1556, Volume 2, Revision 1, “Consolidated Guidance about 

Materials Licenses: Program-Specific Guidance About Industrial Radiography Licenses,” is 

intended for use by applicants, licensees, license reviewers, and other NRC personnel. This 

revision provides a general update to the previous information contained in NUREG-1556, 

Volume 2, dated August 1998. Appendix A to this report provides a list of generic 

communications applicable to radiography, which the NRC staff considered in the development 

of this NUREG report. 

This report takes a risk-informed, performance-based approach to licensing the use of sources 

in industrial radiography. A team composed of staff from NRC Headquarters, NRC regional 

offices, and Agreement States prepared this document, drawing on their collective experience 

in radiation safety in general and as specifically applied to industrial radiography. 

NUREG-1556, Volume 2, Revision 1, is not a substitute for NRC regulations. The approaches 

and methods described in this report are provided for information only. Methods and solutions 

different from those described in this report may be acceptable if they include a basis for the 

staff to make the determinations needed to issue or continue a license. 

Brian J. McDermott, Director 

Division of Material Safety and State Agreements 

Office of Federal and State Materials and Environmental Management Programs 
xi

ACKNOWLEDGMENTS 

The working group thanks the individuals listed below for assisting in the review and update of 

the report. All participants provided valuable insights, observations, and recommendations. 

The working group would like to thank the staff in the regional offices of the U.S. Nuclear 

Regulatory Commission and all of the States who provided comments and technical 

information, which assisted in the development of this report. 

The Participants for this Revision 

Bielecki, Jessica 

Carrico, J. Bruce 

Chidakel, Susan 

Dimmick, Lisa 

Gordon, Craig 

O’Donnell, John 

Olmstead, Joan 

Orendi, Monica 

Simmons, Toye 

Torres, Roberto 

Troxler, Ann 

Weidner, Tara 

White, Duane 

Wright, Megan

xiii

ABBREVIATIONS 

ALARA as low as is reasonably achievable 

ANSI American National Standards Institute 

Bq becquerel 

CFR Code of Federal Regulations 

Ci curie 

cm centimeter 

COC certificate of compliance 

cpm counts per minute 

DOT U.S. Department of Transportation 

dpm disintegrations per minute 

DU depleted uranium 

FSME Office of Federal and State Materials and Environmental Management Programs 

GPO Government Printing Office 

GPS global positioning system 

h hour 

HVL half-value layer 

IN information notice 

μCi microcurie 

MDA minimum detectable activity 

mR milliroentgen 

mrem millirem 

mrem/h millirem per hour 

mSv millisievert 

mSv/h millisievert per hour 

NIST National Institute of Standards and Technology

NMSS Office of Nuclear Materials Safety and Safeguards 

NRC U.S. Nuclear Regulatory Commission 

NSTS National Source Tracking System 

NVLAP National Voluntary Laboratory Accreditation Program 

OMB Office of Management and Budget 

R roentgen 

RIS regulatory issue summary 

RQ reportable quantities 

RSO radiation safety officer 

SI International System of Units (abbreviated SI from the French Le Systeme 

Internationale d’Unites) 

SSD sealed source and device 

Sv sievert 

TEDE total effective dose equivalent 

TI Transport Index 

TLD thermoluminescent dosimeter 

1

1. PURPOSE OF REPORT 

This report provides guidance to an applicant applying for an industrial radiography 

(radiography) license and provides the U.S. Nuclear Regulatory Commission (NRC) with criteria 

for evaluating such applications. This document uses the terms “byproduct material,” “licensed 

material,” and “radioactive material” interchangeably. 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. The radionuclides most commonly used for 

radiography are cobalt-60 and iridium-192; however, other radioisotopes (e.g., ytterbium-169) 

with unique radiological characteristics might 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 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 Office of Management and Budget (OMB) has approved the 

information collection requirements in Title 10 of the Code of Federal Regulations (10 CFR) 

Part 30, “Rules of General Applicability to Domestic Licensing of Byproduct Material”; 

10 CFR Part 34, “Licenses for Industrial Radiography and Radiation Safety Requirements for 

Industrial Radiographic Operations”; and NRC Form 313 under 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: 

• Regulations—references the regulations applicable to the item 

• Criteria—outlines the criteria used to judge the adequacy of the applicant’s response 

• Discussion—provides additional information on the topic sufficient to meet the needs of 

most readers 

• Response from Applicant—provides suggested response or responses, offers the option 

of an alternative reply, or indicates that no response is needed on that topic during the 

licensing process 

Notes and references are self-explanatory and may not be found for each item on NRC 

Form 313. Appendix A includes specific NRC references used in the development of this 

guidance document. 

NRC Form 313 does not have sufficient space for applicants to provide full responses to 

Items 5 through 11, as indicated on the form. Applicants should address those items on 

separate sheets of paper and submit them along with the completed NRC Form 313. For the 

convenience and streamlined handling of industrial radiography applications, Appendix C, 

“Suggested Format for Providing Information Requested in Items 5 through 11 of U.S. Nuclear 

Regulatory Commission Form 313,” may be used to provide supporting information. 

In this document, dose or radiation dose means absorbed dose, dose equivalent, effective dose 

equivalent, committed dose equivalent, committed effective dose equivalent, or total effective 

dose equivalent (TEDE), as defined in 10 CFR Part 20, “Standards for Protection against 

Radiation.” Rem and its International System of Units (SI) equivalent, sievert (Sv) (1 

rem = 0.01 Sv), are used to describe units of radiation exposure or dose. This is done because 
2

10 CFR Part 20 sets dose limits in terms of rem, rather than rad or roentgen. When the 

radioactive material emits beta and gamma rays, for practical reasons, 1 roentgen is assumed 

to equal 1 rad, which is assumed to equal 1 rem. For alpha-emitting radioactive material, 1 rad 

is not equal to 1 rem. Determination of dose equivalent (rem) from absorbed dose (rad) from 

alpha particles requires the use of an appropriate quality factor (Q) value. These Q values are 

used to convert absorbed dose (rad) to dose equivalent (rem); Tables 1004(b)(1) and (2) in 

10 CFR 20.1004, “Units of radiation dose,” address the Q values for alpha particles. 
2

Certain States, called Agreement States 

the NRC that give them the authority to license and inspect byproduct, source, and special 

nuclear materials, in quantities not sufficient to form a critical mass

possessed within their borders. Any applicant, other than a Federal entity, who wishes to 

possess or use licensed material in one of these Agreement States should contact the 

responsible officials in that State for guidance on preparing an application. 

should be filed with State officials,

jurisdiction within an Agreement State, NRC continues to be the regulatory authority

Figure 2.1 U.S. map: locations

In the special situation of work at Federally controlled sites in Agreement States, it is necessary 

to ascertain the jurisdictional status of the land to determine whether the NRC or the Agreement 

State has regulatory authority. These areas can also include tribal lands of federally recognized 

3

2. AGREEMENT 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, and special 

in quantities not sufficient to form a critical mass, which are used or 

borders. Any applicant, other than a Federal entity, who wishes to 

possess or use licensed material in one of these Agreement States should contact the 

responsible officials in that State for guidance on preparing an application. These

ld be filed with State officials, and not with the NRC. In areas under exclusive federal 

jurisdiction within an Agreement State, NRC continues to be the regulatory authority

map: locations of NRC offices and Agreement States

In the special situation of work at Federally controlled sites in Agreement States, it is necessary 

the jurisdictional status of the land to determine whether the NRC or the Agreement 

These areas can also include tribal lands of federally recognized 

2.1), have entered into agreements with 

the NRC that give them the authority to license and inspect byproduct, source, and special 

used or 

borders. Any applicant, other than a Federal entity, who wishes to 

possess or use licensed material in one of these Agreement States should contact the 

These applications 

In areas under exclusive federal 

jurisdiction within an Agreement State, NRC continues to be the regulatory authority. 

and Agreement States

In the special situation of work at Federally controlled sites in Agreement States, it is necessary 

the jurisdictional status of the land to determine whether the NRC or the Agreement 

These areas can also include tribal lands of federally recognized 
4

Indian Tribes1

. The NRC has regulatory authority over land determined to be “exclusive 

Federal jurisdiction,” while the Agreement State has jurisdiction over nonexclusive Federal 

jurisdiction land. Applicants are responsible for determining in advance the jurisdictional status 

of the specific areas where they plan to conduct licensed operations. The NRC recommends 

that applicants contact their local office for the Federal agency controlling the site (e.g., contract

officer, base environmental health officer, district office staff) for assistance in determining the 

jurisdictional status of the land and to provide the information in writing to ensure compliance 

with NRC or Agreement State regulatory requirements, as appropriate. Additional guidance on 

determining jurisdictional status is found in the All Agreement States letter (SP-96-022), dated 

February 16, 1996, which is available at http://nrc-stp.ornl.gov/. Once on the Web site, use the 

link for FSME Letters in the left hand column under Resources & Tools. The link will take you 

to another Web page where you can search for letters to the Agreement States. 

Table 2.1 provides a quick way to check on whether the NRC or an Agreement State has 

regulatory authority. 

Table 2.1 Who Regulates the Activity? 

Applicant and Proposed Location of Work Regulatory 

Agency 

Federal agency or Federally recognized Indian Tribe2 regardless of location 

(except the U.S. Department of Energy and, under most circumstances, its 

prime contractors are exempt from licensing, in accordance with 

10 CFR 30.12, “Persons using byproduct material under certain Department 

of Energy and Nuclear Regulatory Commission contracts”) 

NRC 

Non-Federal entity in non-Agreement State, District of Columbia, U.S. 

territory, or possession, or in offshore Federal waters NRC 

Non-Federal entity in Agreement State at non-Federally controlled site Agreement State

Non-Federal entity in Agreement State at Federally controlled site not

subject to exclusive Federal jurisdiction Agreement State

Non-Federal entity in Agreement State at Federally controlled site subject to 

exclusive Federal jurisdiction NRC 

 

1

For the purposes of this guidance, an “Indian tribe” is defined as an Indian or Alaska Native tribe, band, 

nation,pueblo, village, or community that the Secretary of the Interior acknowledges to exist as an Indian tribe 

pursuant to the Federally Recognized Indian Tribe List Act of 1994. A list of federally recognized tribes is available 

at www.doi.gov/bureau-indian-affairs.

2

 The NRC can exercise jurisdiction as the regulatory authority on tribal land of a Federally recognized Indian Tribe. 

Section 274b Agreements do not give States the authority to regulate nuclear material in these areas. However, 

there are few States that exercise regulatory authority over these areas. Companies owned or operated by Federally 

recognized Indian Tribe members or non-Indians that wish to possess or use licensed material on tribal lands should 

contact the appropriate NRC regional office to check the jurisdictional status of the tribal lands and request a license 

application from the appropriate regulatory agency.
5

Non-Federal entity in Agreement State at a reactor facility with an operating 

license subject to exclusive Federal jurisdiction Agreement State

Non-Federal entity in Agreement State at a reactor facility under 

construction, prior to the issuance of an operating license subject to 

exclusive Federal jurisdiction. 

Agreement State

Reference: A current list of Agreement States (including names, addresses, and telephone 

numbers of responsible officials) is available at the Office of Federal and State Materials and 

Environmental Management Programs (FSME) public Web site, http://nrc-stp.ornl.gov. As an 

alternative, a request for the list can be made to an NRC regional office.

7

3. MANAGEMENT RESPONSIBILITY 

The NRC recognizes that effective radiation safety program management is vital to achieving 

safe and compliant operations. Consistent compliance with NRC regulations provides 

reasonable assurance that licensed activities will be conducted safely and that effective 

management will result in increased safety and compliance. 

“Management” refers to the processes for conduct and control of a radiation safety program 

and to the individuals who are responsible for those processes and who have authority to 

provide necessary resources to achieve regulatory compliance. 

Pursuant to 10 CFR 30.32, “Application for specific licenses,” each application shall be signed 

by the applicant or licensee or a person duly authorized to act for and on their behalf. The 

person signing the application should be a duly authorized management representative. A 

signature by a management representative acknowledges management’s commitments and 

responsibilities to the following: 

• Radiation safety, security, and control of radioactive materials and compliance with 

regulations; 

• Completeness and accuracy of the radiation safety records and all information provided 

to the NRC (10 CFR 30.9, “Completeness and accuracy of information”); 

• Knowledge about the contents of the license and application; 

• Compliance with current NRC and U.S. Department of Transportation (DOT) regulations 

and the licensee’s operating and emergency procedures; 

• Commitment to provide adequate resources (including space, equipment, personnel, 

time, and, if needed, contractors) to the radiation protection program to ensure that the 

public and workers are protected from radiation hazards and compliance with 

regulations is maintained; 

• Commitment to report defects, noncompliances, or reportable events in accordance with 

regulations; 

• Selection and assignment of a qualified individual to serve as the radiation safety officer 

(RSO) for licensed activities and confirmation that the RSO has independent authority to 

stop unsafe operations and will be given sufficient time to fulfill radiation safety duties 

and responsibilities; 

• Commitment to ensure that radiation workers have adequate training; 

• Prohibition against discrimination of employees engaged in protected activities 

(10 CFR 30.7, “Employee protection”); 

• Commitment to provide information to employees regarding the employee protection 

and deliberate misconduct provisions in 10 CFR 30.7 and 10 CFR 30.10, “Deliberate 

misconduct,” respectively; 

• Commitment to obtain NRC’s prior written consent before transferring control of the 

license (see Section 9.1 of this report); and 
8

• Notification of the appropriate NRC regional administrator in writing, immediately 

following the filing of petition for voluntary or involuntary bankruptcy (10 CFR 30.34(h)), 

as discussed further in Section 8.2.1 of this report. 

For information on NRC inspection, investigation, enforcement, and other compliance 

programs, see the current version of the NRC’s Enforcement Policy and Inspection Procedures 

available in the NRC’s online library at http://www.nrc.gov/reading-rm.html. 

3.1 Safety Culture

It is the NRC’s expectation that individuals and organizations performing regulated activities 

establish and maintain a positive safety culture commensurate with the safety and security 

significance of their activities and the nature and complexity of their organizations and 

functions. This applies to all licensees, certificate holders, permit holders, authorization 

holders, holders of quality assurance program approvals, vendors and suppliers of safetyrelated components, and applicants for a license, certificate, permit, authorization, or quality 

assurance program approval, subject to NRC authority. 

“Nuclear safety culture” is defined as the core values and behaviors resulting from a collective 

commitment by leaders and individuals to emphasize safety over competing goals to ensure 

protection of people and the environment. Individuals and organizations performing regulated 

activities bear the primary responsibility for safely handling and securing these materials. 

Experience has shown that certain personal and organizational traits are present in a positive 

safety culture. A trait, in this case, is a pattern of thinking, feeling, and behaving that 

emphasizes safety, particularly in goal conflict situations (e.g., production versus safety, 

schedule versus safety, and cost of the effort versus safety). 

The NRC, as the regulatory agency with an independent oversight role, reviews the 

performance of individuals and organizations to determine compliance with requirements and 

commitments through its existing inspection and assessment processes. However, NRC’s 

safety culture policy statement and traits are not incorporated into the regulations. Many of the 

safety culture traits may be inherent to an organization’s existing radiation safety practices and 

programs. For instance, the annual refresher training required for radiographers and 

radiographer assistants may correspond with the “continuous learning” safety culture trait in that 

the training provides an opportunity to learn about ways to ensure that safety is sought out and 

implemented. 

Refer to Appendix P for the NRC’s safety culture policy statement. More information on NRC 

activities relating to safety culture can be found at: http://www.nrc.gov/aboutnrc/regulatory/enforcement/safety-culture.html.
9

4. APPLICABLE REGULATIONS 

It is the applicant, licensee, or registrant’s responsibility to obtain and have available up-to-date 

copies of applicable regulations, to read and understand the requirements of each of these 

regulations, and to comply with each applicable regulation. The following parts of Title 10 of the 

Code of Federal Regulations contain regulations applicable to industrial radiography. Some of 

these parts are specific to one type of license, while others are general and will apply to many if 

not all licensees. 

The current versions of these parts can be found under the “Basic References” link at the 

NRC’s online library at http://www.nrc.gov/reading-rm.html; if viewing in a browser, the following 

list includes a direct link to the rules: 

• 10 CFR Part 2, “Rules of Practice for Domestic Licensing Proceedings and Issuance of 

Orders” 

• 10 CFR Part 19, “Notices, Instructions and Reports to Workers: Inspection and 

Investigations” 

• 10 CFR Part 20, “Standards for Protection Against Radiation” 

• 10 CFR Part 21, “Reporting of Defects and Noncompliance” 

• 10 CFR Part 30, “Rules of General Applicability to Domestic Licensing of Byproduct 

Material” 

• 10 CFR Part 32, “Specific Domestic Licenses to Manufacture or Transfer Certain Items 

Containing Byproduct Material” 

• 10 CFR Part 34, “Licenses for Industrial Radiography and Radiation Safety for Industrial 

Radiographic Operations” 

• 10 CFR Part 40, “Domestic Licensing of Source Material” 

• 10 CFR Part 71, “Packaging and Transportation of Radioactive Material” 

• 10 CFR Part 73, “Physical Protection of Plants and Materials” 

• 10 CFR Part 110, “Export and Import of Nuclear Equipment and Material” 

• 10 CFR Part 150, “Exemptions and Continued Regulatory Authority in Agreement States 

and in Offshore Waters under Section 274” 

• 10 CFR Part 170, “Fees for Facilities, Materials, Import and Export Licenses and Other 

Regulatory Services Under the Atomic Energy Act of 1954, as Amended” 
10

• 10 CFR Part 171, “Annual Fees for Reactor Licenses, and Fuel Cycle Licenses and 

Materials Licenses, Including Holders of Certificates of Compliance, Registrations, and 

Quality Assurance Program Approvals and Government Agencies Licensed by the NRC” 

Copies of the above documents may be obtained by calling the Government Printing Office 

(GPO) order desk toll free at (866) 512-8600, or in Washington, DC, at (202) 512-1800, or 

online at http://bookstore.gpo.gov. 

A single copy of the above documents may be requested from the NRC’s regional offices (see 

Figure 2.1 for addresses and telephone numbers). In addition, 10 CFR Parts 1 through 199 

can be found on the NRC’s Web site at http://www.nrc.gov/reading-rm/doc-collections/ under 

Regulations (10 CFR). 

NRC regulations and amendments can also be accessed from the “NRC Library” link on the 

NRC’s public Web site at http://www.nrc.gov. The NRC and all other Federal agencies publish 

amendments to their regulations in the Federal Register. 
11

5. HOW TO FILE 

5.1 Paper Application

Applicants for a materials license should do the following: 

• Use the most recent guidance in preparing an application. 

• Complete NRC Form 313 (Appendix B), Items 1 through 4, 12, and 13, on the form 

itself. 

• Complete NRC Form 313, Items 5 through 11, on supplementary pages or use 

Appendix C. 

• Provide sufficient detail for the NRC to determine that equipment, facilities, training, 

experience, and the radiation safety program are adequate to protect health and safety 

and minimize danger to life and property. 

• For each separate sheet other than NRC Form 313 and Appendix C submitted with the 

application, identify and cross-reference submitted information to the item number on 

the application or the topic to which it refers. 

• Submit all documents, typed, on 8-1/2 x 11-inch paper. 

• Avoid submitting proprietary information and personally identifiable information. 

• If submitted, proprietary information and other sensitive information (e.g., personal 

privacy and security related) should be clearly identified per 10 CFR 2.390, “Public 

inspections, exemptions, requests for withholding” (see Chapter 6). 

• Submit an original, signed application and one copy. 

• Retain one copy of the license application for future reference. 

Applications must be signed by the applicant, licensee, or a person duly authorized as 

required by 10 CFR 30.32 (c) (see Section 8.13). 

5.2 Where to File

Applicants wishing to possess or use licensed material in any State, U.S. territory, or 

U.S. possession subject to NRC jurisdiction must file an application with the NRC regional office 

for the locale in which the material will be possessed or used. Figure 2.1 identifies NRC’s four 

regional offices, and their respective areas for licensing purposes, and the Agreement States. 

Note that all materials applications are submitted to Regions I, III, or IV. All applicants for 

materials licenses located in the Region II geographical area should send their applications to 

Region I. 

In general, applicants wishing to possess or use licensed material in Agreement States must file 

an application with the Agreement State and not with the NRC. However, if work will be 

conducted at Federally controlled sites, or federally recognized Indian Tribal lands, in 

Agreement States, applicants must first determine the jurisdictional status of the land in order to 
12

determine whether the NRC or the Agreement State has regulatory authority. See Chapter 2 

for additional information. 

5.3 Transfer to Electronic Format

Paper applications received by the NRC are scanned through an optical character reader and 

converted to an electronic format. To ensure a smooth transfer to an electronic format, 

applicants should do the following: 

• Submit printed or typewritten—not handwritten—text on smooth, crisp paper that will 

feed easily into the scanner. 

• Choose typeface designs that are sans serif, such as Arial, Helvetica, Future, or Univers 

(the text of this document is in the Arial font). 

• Use 12-point or larger font. 

• Avoid stylized characters, such as script or italics. 

• Ensure that the print is clear and sharp. 

• Ensure that there is high contrast between the ink and paper (black ink on white paper is 

best). 

It is anticipated that the NRC may provide mechanisms for filing applications through the 

Internet. If this occurs, the NRC will provide additional filing instructions as the agency 

implements these new mechanisms. 
13

6. IDENTIFYING AND PROTECTING SENSITIVE INFORMATION 

All licensing applications, except for portions containing sensitive information, will be made 

available for review in the NRC’s Public Document Room and electronically at the NRC Library. 

For more information on the NRC library, visit www.nrc.gov. 

The licensee should identify, mark, and protect sensitive information against unauthorized 

disclosure to the public. Licensing applications that contain sensitive information should be 

marked as indicated below, in accordance with 10 CFR 2.390, before the information is 

submitted to the NRC. Key examples are as follows:

• Proprietary Information/Trade Secrets: If it is necessary to submit proprietary 

information or trade secrets, follow the procedure in 10 CFR 2.390(b). Failure to follow 

this procedure could result in disclosure of the proprietary information to the public or 

substantial delays in processing the application. 

• Personal Privacy Information: Personal information about employees or other 

individuals should not be submitted unless specifically requested by the NRC. 

Examples of private information are social security number, home address, home 

telephone number, date of birth, and radiation dose information. If private information is 

submitted, it should be separated from the public portion of the application and clearly 

marked: “Privacy Act Information—Withhold under 10 CFR 2.390.” For further 

information, see Regulatory Issue Summary (RIS) 2007-04, “Personally Identifiable 

Information Submitted to the U.S. Nuclear Regulatory Commission,” dated 

March 9, 2007, which can be found on the NRC’s Generic Communications webpage 

under Regulatory Issue Summaries: http://www.nrc.gov/reading-rm/doc-collections/gencomm/. 

• Security-Related Information: Following the events of September 11, 2001, the NRC 

changed its procedures to avoid release of information that terrorists could use to plan 

or execute an attack against facilities or citizens in the United States. As a result, 

certain types of information are no longer routinely released and are treated as sensitive 

unclassified information. For example, certain information about the quantities and 

locations of radioactive material at licensed facilities, and associated security measures, 

are no longer released to the public. Therefore, sensitive security-related information in 

an application should be marked: “Security Related—Withhold under 10 CFR 2.390.” 

For further information, see RIS 2005-31, “Control of Security-Related Sensitive 

Unclassified Non-Safeguards Information Handled by Individuals, Firms, and Entities 

Subject to NRC Regulation of the Use of Source, Byproduct, and Special Nuclear 

Material,” dated December 22, 2005, which can be found on the NRC’s Generic 

Communications webpage under Regulatory Issue Summaries: 

http://www.nrc.gov/reading-rm/doc-collections/gen-comm/.

Additional information on procedures and any updates is available at 

http://www.nrc.gov/reading-rm/sensitive-info.html. 
15

7. APPLICATION AND LICENSE FEES 

Each application for which a fee is specified must be accompanied by the appropriate fee. 

Refer to 10 CFR 170.31, “Schedules of fees for materials licenses and other regulatory 

services, including inspections, and import and export licenses,” to determine the amount of the 

fee. The NRC will not issue a license until the fee is received. Consult 10 CFR 170.11, 

“Exemptions,” for information on exemptions from these fees. Once the technical review has 

begun, no fees will be refunded; application fees will be charged regardless of the NRC’s 

disposition of the application or the withdrawal of the application. 

Most NRC licensees are also subject to annual fees; refer to 10 CFR 171.16, “Annual fees: 

Materials licensees, holders of certificates of compliance, holders of sealed source and device 

registrations, holders of quality assurance program approvals, and government agencies 

licensed by the NRC.” Consult 10 CFR 171.11 for 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 the NRC’s fees or completion of Item 12 of NRC Form 313 to the 

Office of the Chief Financial Officer at NRC Headquarters in Rockville, MD, (301) 415-7554. 

Information about fees may also be obtained by calling NRC’s toll free number, (800) 368-5642, 

extension 415-7554. The e-mail address is Fees.Resource@nrc.gov. 
17

8. CONTENTS OF AN APPLICATION 

The following comments apply to the indicated items on NRC Form 313 (Appendix B). 

All items in the application should be completed in enough detail for the NRC to determine that 

the proposed equipment, facilities, training and experience, and the radiation safety program 

satisfy regulatory requirements and are adequate to protect health and minimize danger to life 

and property. Consideration shall be given, when developing the application, to the concepts of 

keeping exposure as low as reasonably achievable (ALARA) and minimizing contamination. 

In 10 CFR 20.1101(b), the NRC states: “The licensee shall use, to the extent practicable, 

procedures and engineering controls based upon sound radiation protection principles to 

achieve occupational doses and doses to members of the public that are as low as is 

reasonably achievable (ALARA).” Regulatory Guide 8.10, “Operating Philosophy for 

Maintaining Occupational Radiation Exposures As Low As Reasonably Achievable,” discusses 

the ALARA concepts and philosophy. The application should document ALARA considerations, 

including establishing administrative action levels and monitoring programs. 

In 10 CFR 20.1406, “Minimization of contamination,” the NRC requires applicants for licenses to 

describe how facility design and procedures for operation will minimize, to the extent 

practicable, contamination of the facility and the environment; facilitate eventual 

decommissioning; and minimize, to the extent practicable, the generation of radioactive waste. 

As with ALARA considerations, applicants should address concerns for all aspects of their 

programs. 

All information submitted to the NRC during the licensing process may be incorporated as part 

of the license and will be subject to review during inspection. 
18

8.1 Item 1: License Action Type

This is an application for (check appropriate item): 

Type of Action License No.

[ ] A. New License Not Applicable 

[ ] B. Amendment XX-XXXXX-XX 

[ ] C. Renewal XX-XXXXX-XX 

Check box A for a new license request. 

Check box B for an amendment to an existing license, and provide license number. 

Check box C for a renewal of an existing license, and provide license number. 

8.2 Item 2: Applicant’s Name and Mailing Address

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. A post office box number is an acceptable mailing address. 

Notify the NRC of changes in the mailing address; these changes do not require a fee. 

Note: The NRC must be notified before control of the license is transferred (see Section 9.1) 

or when bankruptcy proceedings have been initiated. See Section 8.2.1 below for more details. 

8.2.1 Notification of Bankruptcy Proceedings 

Regulation: 10 CFR 30.34(h) 

Criteria: Immediately following the filing of a 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. 

Discussion: Even though a licensee may have filed for bankruptcy, the licensee remains 

responsible for all regulatory requirements. The NRC must know when licensees are in 

bankruptcy proceedings in order to determine whether all licensed material is accounted for and 

adequately controlled and whether there are any public health and safety concerns 

(e.g., contaminated facility). The NRC shares the results of its determinations with other 

involved entities (e.g., trustee), so that health and safety issues can be resolved before 

bankruptcy actions are completed. 
19

Response from Applicant: None required at the time of application for a new license. 

Licensees must immediately notify in writing the NRC following the filing of a voluntary or 

involuntary petition for bankruptcy for or against the licensee. 

Reference: See NUREG-1556, Volume 15, “Guidance About Changes of Control and About 

Bankruptcy Involving Byproduct, Source, or Special Nuclear Materials Licenses.” 

8.3 Item 3: Address(es) Where Licensed Material Will Be Used or Possessed

Specify the street address, city, and State or other descriptive address (e.g., on Highway 10, 

5 miles east of the intersection of Highway 10 and State Route 234, Anytown, State). In 

addition, global positioning system (GPS) coordinates, as appropriate, may be provided for 

each permanent storage or use facility and field station located in a remote area. A field station 

is a location where licensed material may be stored or used and from which the applicant will 

dispatch equipment to jobsites. The descriptive address should be sufficient to allow an NRC 

inspector to find the facility location. If devices will not be stored at a dispatch site or field 

station, the applicant should indicate this. The applicant should also state whether a location 

will be used to perform radiographic operations or only for storage of sources and devices. 

A post office box address is not acceptable (see Figure 8.1). Documents that give exact 

location of use should be marked “Security-Related Information—Withhold under 

10 CFR 2.390.” 

RPh17a.ppt

082898

32 Elm St.

City, ST 12345 P.O. Box XXXX

City, ST 12345

32 ELM St.

Figure 8.1 Location of use. An acceptable location of use specifies street address, city, 

State, and zip code and does not include a post office box number. 

An NRC-approved license amendment is required before receiving, using, and storing licensed 

material at an address or location not listed on the license (10 CFR 30.3, “Activities requiring 

license”). 
20

Being granted an NRC license does not relieve a licensee from complying with other 

applicable Federal, State, or local regulations (e.g., local zoning requirements). 

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 or used at a field station, give the specific 

address of each field station (and the GPS coordinates, if available). 

• 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: Locations where licensed material may be stored or used and from which equipment is 

dispatched are considered field facilities which, as specified in 10 CFR 34.13(j), must be 

identified in the application. 

Note: If radiography operations are expected to exceed 180 days at a temporary jobsite, then 

provide written notification to the appropriate NRC regional office before exceeding the 

180 days (a license amendment or authorization by the NRC regional office is not required). 

Note: As discussed later in Section 8.5.2, “Financial Assurance and Recordkeeping for 

Decommissioning,” licensees must maintain permanent records describing where licensed 

material was used or stored while the license was in effect. This is important for making future 

determinations about the release of these locations for unrestricted use (e.g., before the license 

is terminated). Acceptable records are sketches, written descriptions of the specific locations or 

room numbers where licensed material is used or stored, and any records of spills or other 

unusual occurrences involving the spread of contamination in or around the licensee’s facilities. 

8.4 Item 4: Person To Be Contacted about This Application

Identify the individual who can answer questions about the application, and include his or her 

telephone number. This individual, usually the RSO, will serve as the point of contact during 

the review of the application and during the period of the license. If this individual is not a fulltime employee of the licensed entity, his or her position and relationship should be specified. 

The NRC should be notified if the person assigned to this function changes or if his or her 

telephone number changes. Notification of a contact change is for information only and would 

not be considered an application for license amendment, unless the notification involves a 

change in the contact person who is also the RSO. 

As indicated on NRC Form 313 (Appendix B), Items 5 through 11 should be submitted on 

separate sheets of paper. Applicants may use Appendix C for this purpose and should note 

that using the suggested wording of responses and committing to use the model procedures in 

this report will expedite the NRC’s review. 
21

8.5 Item 5: Radioactive Material 

8.5.1 Sealed Sources and Devices 

Regulation: 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 (the sealed source and a connector that attaches the 

source to the control cable), exposure device, and source changer. Licensees will only be 

authorized for radiographic exposure devices, source assemblies, or sealed sources containing 

byproduct material meeting NRC performance requirements and specifically approved or 

registered by the NRC or an Agreement State. In addition, identify any depleted uranium that is 

used as shielding material (radiographic exposure devices, source changers, and some 

collimators contain depleted uranium). 

Discussion: The NRC or an Agreement State performs safety evaluations of radiography 

source assemblies, exposure devices, and source changers before distribution of these sources 

and 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 

NRC or an Agreement State agency approves the source assemblies, exposure devices, or 

source changers for use, the applicant must note the manufacturer’s (or distributor’s) name and 

the model number of the sources and devices in its license application to demonstrate that the 

requirements are met. Manufacturers and distributors of industrial radiography equipment may 

voluntarily include the items of associated equipment that were used in the industrial 

radiography system with their sealed sources and devices that are registered. To include 

associated equipment in the certificate of registration, the manufacturer’s or distributor’s 

application must include information that demonstrates the associated equipment meets the 

minimum criteria in 10 CFR 34.20, “Performance requirements for individual radiography 

equipment.” 

Consult with the proposed supplier to ensure that sources and devices conform to the sealed 

source and device designations registered with the NRC or an Agreement State. 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 

design 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 meets the performance requirements 

in 10 CFR 34.20. RIS 2005-10, “Performance-Based Approach for Associated Equipment in 

10 CFR 34.20,” dated June 10, 2005, alerts licensees to the difference between items of 

equipment that are considered to be associated equipment and items of equipment that are not. 

For example, the portion of the connector that is attached to the end of the control cable is 

actually a component of the source assembly and is subject to the safety evaluation that must 

be completed by the NRC or an Agreement State before the source assembly may be 

specifically authorized for use by a licensee. RIS 2005-10 also contains a number of ways that 
22

licensees can demonstrate that their associated equipment meets the performance 

requirements stated in 10 CFR 34.20. 

Radiography sources are usually at or above Category 2 quantities. Applicant/licensee 

information on manufacturers, model numbers, and possession limits is sensitive and should be 

marked accordingly (see Chapter 6). Category 1 and Category 2 sources regulated by the 

NRC and Agreement States must be tracked in the National Source Tracking System (NSTS). 

Response from Applicant:

• Identify each radionuclide that will be used. Identify the manufacturer (or distributor) 

and model number of each sealed source, source assembly, exposure device, or source 

changer to be possessed. Identify any depleted uranium that is used as shielding 

material. 

• For each source model, identify the radionuclide, maximum activity per source, and total 

possession limit. 

• Confirm that each sealed source, device, and source/device combination possessed is 

registered as an approved sealed source or device by the NRC or an Agreement State 

and will be possessed and used in accordance with the conditions specified in the 

registration certificate. Obtain from the manufacturer/distributor a copy of the SSD 

certificate and provide the SSD registry number with the application. 

• Confirm that associated equipment is compatible with the exposure devices, source 

changers, and sealed sources containing byproduct material. 

• Identify by radionuclide and manufacturer (or distributor) and model number any other 

sealed sources containing byproduct material (i.e., any source that will not be used for 

performing radiography). 

• Confirm that all radiographic exposure devices, source assemblies, or sealed sources, 

and all associated equipment which meet the requirements specified in 10 CFR 34.20, 

will be used in radiographic operations. 

Mark the section related to possession of sealed sources and devices with manufacturers, 

model numbers, and possession limits as follows: “Security-Related Information—Withhold 

under 10 CFR 2.390.” 

8.5.2 Financial Assurance and Recordkeeping for Decommissioning 

Regulations: 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, “Financial assurance and 

recordkeeping for decommissioning,” 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, as well as records related to 

leaking sources. Licensees must transfer these records important to decommissioning either to 

an NRC or Agreement State licensee before licensed activities are transferred or assigned in 
23

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 3.7×105

 becquerels (Bq) 

(10,000 curies (Ci)) of cobalt-60 and 3.7×106 Bq (100,000 Ci) 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. 

Applicants and licensees desiring to possess sources exceeding the threshold amounts should 

submit evidence of financial assurance. Licensees may follow the guidance provided in 

NUREG-1757, Volume 3, “Consolidated NMSS Decommissioning Guidance—Financial 

Assurance, Recordkeeping and Timeliness.” 

NRC regulations also require 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 or 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. Leak-test results are part of the 

decommissioning records. 

Response from Applicants: State the following: “Pursuant to 10 CFR 30.35(g), we shall 

maintain drawings and records important to decommissioning and to transfer these records to 

an NRC or Agreement State 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 of financial assurance following the guidance 

of NUREG-1757, Volume 3. 

Reference: NUREG-1757, Volume 3, “Consolidated NMSS Decommissioning Guidance—

Financial Assurance, Recordkeeping and Timeliness.”

8.6 Item 6: Purpose(s) for Which Licensed Material Will Be Used 

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 SSD registration certificate. 

Discussion: The typical license authorizes persons to perform source exchanges and to 

conduct industrial radiography at temporary jobsites, field stations, or permanent radiographic 

installations. Unusual uses will be evaluated on a case-by-case basis, and the authorized use 
24

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:

• Check off on Appendix C that the equipment will only be used for industrial radiography. 

OR 

• Specify the purposes for which the source(s) and device(s) will be used other than those 

included in the manufacturer’s recommendations, as specified on the SSD registration 

certificate. 

AND 

• In addition, specify any plans to perform radiography under water, on lay-barges, or on 

offshore platforms. Refer to Appendix D. 

8.7 Item 7: Individuals Responsible for Radiation Safety Program and Their 

Training and Experience 

8.7.1 Radiation Safety Officer 

Regulations: 10 CFR 34.13(f), 10 CFR 34.13(g), 10 CFR 34.42, 10 CFR 34.43 

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 have adequate 

knowledge of the activities to which they are assigned. Designees should have management 

support and decisionmaking authority necessary to manage daily program activities. Applicants 

do not have to identify other responsible individuals if day-to-day tasks will not be delegated. 

Figure 8.2 illustrates typical RSO duties. The 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 the 

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 
25

communication with responsible management officials. Also, show in the organizational chart 

the position of the certifying officer who signs the application in Item 13 of 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 (1 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 

managing and implementing 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 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, securing the material, posting work sites with necessary 

warning signs, conducting radiation area surveillance, completing and maintaining records, and 

other tasks. Excessive time spent in only one or two of these operations (film development 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. 
26

Figure 8.2 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: 

• The name of the proposed RSO and other potential designees who will be responsible 

for ensuring that the licensee’s radiation safety program is implemented in accordance 

with approved procedures. 

AND 

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Receipt, transfer, disposal

Transportation

Audits

Personnel Monitoring

Stop unsafe licensed activities

Proper use and maintenance of

approved sources and devices

Personnel training

Monitor emergency events

Device security

Material disposal

Device security

Interaction with NRC, other authorities

Records maintenance

Six-month worker audits

Survey meter calibration and

maintenance
27

• Demonstrate that the RSO has sufficient independence and direct communication with 

responsible management officials by providing a copy of an organizational chart, by 

position, demonstrating day-to-day oversight and coordination with management in 

radiation safety activities. 

AND EITHER 

• The specific training and experience of the RSO and other potential designees. Include 

the specific dates of certification or training, or both, in radiation safety. 

• Documentation to show that the RSO has a minimum of 2,000 hours of hands-on 

experience as a qualified radiographer in industrial radiographic operations. 

• Documentation to show that the RSO has obtained formal training in the establishment 

and maintenance of a radiation protection program. 

OR 

• Alternative information demonstrating that the proposed RSO is qualified by training and 

experience (e.g., certification by the American Board of Health Physicists, completion of 

a bachelor’s or master’s degree in the sciences with at least 1 year of experience in the 

conduct of a radiation safety program of comparable size and scope). 

• Documentation to show that the RSO has obtained formal training in the establishment 

and maintenance of a radiation protection program. 

Note: It is important to notify the NRC and obtain a license amendment before making 

changes in the designation of the RSO responsible for the radiation safety program. 

8.8 Item 8: Training for Radiographers and Radiographer’s Assistants 

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, “Training.”

Discussion: 

• A radiographer is a person who performs or personally supervises industrial radiography 

and is responsible for ensuring compliance with NRC regulations, license conditions, 

and the safe use of radioactive materials. 

• A certified radiographer is an individual who has been certified by a certifying entity that 

he or she has met established radiation safety, testing, and experience criteria. 

• A radiographer’s assistant is an individual, who under the direct supervision (in the 

physical presence) of the radiographer, uses radiographic equipment (sealed sources 

containing byproduct material or related handling tools, exposure devices, and radiation 

survey instruments) in performing industrial radiographic operations. 
28

The regulations in 10 CFR 34.43 describe specific training requirements for radiographers and 

radiographer’s assistants and require that all radiographers be certified. The regulations also 

address annual refresher training and semiannual audits of radiographers and radiographer’s 

assistants. 

The applicant must submit a description of its training program for radiographers and 

radiographer’s assistants. Refer to Appendix E as an aid to determining the specific training 

requirements for radiographers and radiographer’s assistants. No licensing actions are 

required when radiographers are certified. The NRC will verify radiographer certification during 

routine NRC inspections. 

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 in company operations 

similar to that given to prospective radiographer’s assistants. This instruction must include 

training in the applicant’s operating and emergency procedures, in the use of the applicant’s 

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 1 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. 

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. 
29

Describe the field (practical) examination that will be given to prospective radiographers and 

radiographer’s assistants. The NRC suggests using the checklist in Appendix F 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. Topics for discussion might include examples such as those found 

in Appendix E. 

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 that you contacted the 

certifying entity and confirmed the certification. Your procedures should also ensure that you 

are aware of certification expiration dates and that individuals with expired certifications do not 

act as radiographers. 

Submit a description of your program for inspecting the job performance of each radiographer 

and radiographer’s assistant at intervals not to exceed 6 months, as described in 

10 CFR 34.43(e). Appendix F provides a sample checklist. 

X-ray training by itself will not be considered adequate experience for performing gamma 

radiography. 

8.9 Item 9: Facilities and Equipment 

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 the NRC. 

If licensees need to perform radiography at their place of business outside of a permanent 

facility because of 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. 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 

2 millirem in any 1 hour), the regulation did not specify radiation limits to allow for design 

flexibility for moving equipment into and out of the installation or other considerations. 
30

Radiation levels slightly exceeding these levels outside of the facility should only be considered 

or allowed when the higher levels result from “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 (e.g., fence) must be utilized, and additional administrative controls must be 

imposed to meet regulatory exposure requirements in 10 CFR 20.1301, “Dose limits for 

individual members of the public,” and 20.1601, “Control of access to high radiation areas,” and 

security requirements in 10 CFR 20.1801, “Security of stored material,” and 20.1802, “Control 

of material not in storage,” (see Section 8.10.10). All entrance ways into the facility must be 

interlocked with control devices required by 10 CFR Part 34. 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 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. 

Note: A temporary jobsite is a location where radiographic operations are conducted and 

where material may be stored other than the locations of use authorized on the license. 

The following requirements in 10 CFR 34.33, “Permanent radiographic installations,” apply to a 

permanent installation: 

• Visible-audible signals 

Each access point is equipped with a visible-audible signal system. The visible signal is 

activated by radiation whenever the source is exposed. The audible signal will sound if anyone 

tries to enter the installation while the source is exposed. The requirement for the visibleaudible signal system is in addition to other measures that may be taken to prevent access to 

the installation, such as locked doors. 

As an alternative to the visible-audible alarm system, it is acceptable to use a control system 

that will reduce the radiation level if the entrance to a high-radiation area is opened while the 

source is out. The system must be automatic and independent of radiography personnel 

action. If this alternative is planned, provide a description of the system. 

• Diagram depicting the shielding, layout, and visible-audible alarms 

A diagram of the installation is helpful in evaluating the shielding and determining compliance 

with regulations regarding restricted and unrestricted areas, location of access points, and 

locations of audible-visible signals. Figure 8.3 shows an example installation diagram. 

Diagrams of facilities should be marked: “Security-Related Information—Withhold under 

10 CFR 2.390.” 
31

Security-Related Information—Withhold under 10 CFR 2.390* 

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All primary shield

walls are

constructed of solid

concrete block

7” wide by 10”

high door 0.625”

steel plate & 2

layers 0.5” lead

Exposure

area

4’

6’

4’

12’

11’

3’

6”

10’

8”

Exposure prohibited

area

Exposure room

capped with 36” solid

concrete

20’ - 12”

Visible-Audible Alarm

Interlocked Door

*This diagram is an example only and does not contain real security-related information.

Figure 8.3 Example diagram of a permanent radiographic installation 

• Calculations or survey results of radiation levels

For a determination of installation adequacy, provide information showing that the radiation 

level in all directions around the installation, including the roof, will not exceed a dose of 

0.02 millisievert (mSv) (2 mrem) in any 1 hour. Take into account the highest quantity of 

radioactive material that will be used in the installation and any limitations on source positioning 

in the installation. Radiation levels in all directions around the installation that are below 

0.02 mSv (2 mrem) in any 1 hour are considered acceptable. If the radiation levels will exceed 

0.02 mSv (2 mrem) in any 1 hour, then steps should be taken (use lower activity source, use 

collimator, or move setup farther away) to reduce the radiation to the acceptable level. 

A radiation level on the roof that exceeds 1.0 mSv (100 mrem) in 1 hour at 30 centimeters from 

the surface is considered a “high-radiation area” and requires special precautions to control 

access to the area. Licensees should make efforts to lower a radiation level exceeding 1.0 mSv 

(100 mrem) in any 1 hour by using additional shielding, collimators, or other engineering 

controls. The roof of a fixed radiography cell is a potentially occupied area, and applicants must 

demonstrate that no individual member of the public could receive effective doses in excess of 

0.02 mSv (2 mrem) in any 1 hour or 1 mSv (100 mrem) in a year. 

Response from Applicant: Provide the following: 

If radiography is planned in a permanent radiography installation or installations (including field 

stations with permanent exposure cells), provide the following information for each installation: 
32

• An annotated sketch or drawing of the facility and its surroundings (properly marked as 

“Security-Related Information—Withhold under 10 CFR 2.390”). 

• The scale to which the sketch or drawing is made. The same scale should be used for 

all sketches and drawings. The recommended scale is 1/4 inch = 1 foot. Drawings to 

this scale that do not fit on 8-1/2 x 11-inch paper may be provided as sectional 

drawings. 

• The type, thickness, and density of shielding materials on all sides, including the floor 

and the roof. 

• The locations of entrance ways and other points of access to the facility. 

• A description of the areas adjacent to the facility and the distance to these areas. 

Include information on areas adjacent to, above, and below the facility. 

• A description of the general location of each proposed permanent installation listed in 

Item 3 (e.g., located in an industrial park, an office complex) and its current use. If any 

proposed permanent installation is a private residence, provide diagrams of the 

installation that include the building, the proposed restricted area or areas, and adjacent 

areas, including above and below the restricted areas; provide commitments that 

restricted areas do not include residential quarters, and explain how radiation levels in 

unrestricted areas will be maintained at less than 1 mSv (100 mrem) per year. 

• A description of the visible-audible signal system or entrance control system and its 

location. 

• The results of radiation-level calculations or actual radiation measurements adjacent to, 

above, and below the installation. The radiation level in all directions around the 

installation, including the roof, should not exceed 0.02 mSv (2 mrem) in any 1 hour. 

Clearly identify the type of source (isotope), the amount of radioactive material in the 

source, and the position of the source within the installation for the calculations or 

measurements. 

Note: Mark drawings and diagrams that provide exact location of materials or depict specific 

locations of safety or security equipment as “Security-Related Information—Withhold under 

10 CFR 2.390.” 
33

Variances will be considered if construction requirements preclude shielding the roof1

 to meet 

the requirement not to exceed 0.02 mSv (2 mrem) in any 1 hour. Provide the following 

information to obtain approval for a variance: 

• Procedures for ensuring that no individual is on the roof or could gain access to the roof 

during radiography. 

• Means of preventing access to the roof. 

• A commitment that the roof will be posted with signs stating “Caution (or Danger) 

Radiation Area”. 

• Steps taken to minimize radiation on the roof. 

• Limitations (if needed) on positioning of sources or type (isotope) and amount of 

radioactive material that may be used in the installation to ensure that areas adjacent to, 

above, and below the installation will be unrestricted areas during the performance of 

radiography. 

If radiation levels on the radiography installation roof1

 exceed 1.0 mSv (100 mrem) in any 

1 hour, then provide the following information in addition to the items above to apply for this 

variance: 

• A commitment that the roof will be posted with signs stating “Caution (or Danger) High 

Radiation Area”. 

• Evidence of constant surveillance of the roof by closed-circuit television. 

• A description of a control device that would automatically reduce the radiation level to 

1 mSv (100 mrem) in any 1 hour at 30 centimeters from the radiation source if someone 

enters the roof. 

• A description of a control device that activates a visible-audible signal so that both an 

individual entering the roof and the radiographer on duty are made aware of the entry. 

Field Stations

Describe the storage location or locations at the address or addresses listed in Item 3 of the 

application and submit a diagram showing where the radiography camera will be stored at the 

field stations. Indicate whether or not radiography will be performed at the place of business 

outside of a permanent radiography installation. If radiography will be performed at a site 

outside of a permanent radiography installation, provide a diagram of the location where 

radiography may be performed and its surroundings, including a description of adjacent 

property. 

Note: Mark drawings and diagrams that provide exact location of materials or depict specific 

locations of safety or security equipment as “Security-Related Information—Withhold under 

10 CFR 2.390.” 

 

1 Facilities for exposures only may or may not have a roof. Applicants are required to explain how these 

areas around the installation will be controlled to keep exposures to appropriate levels.
34

Note: Certain records described in the regulations that pertain to radiation safety should be on 

file at these field stations and each temporary jobsite. Applicant or licensee’s records 

containing security-related information should meet the applicant’s or licensee’s own security 

program requirements for marking documents. 

Note: An NRC licensee must implement enhanced security measures (Section 8.10.10) before 

licensed material may be transferred to a new field station. In addition, the new field station 

must be authorized on the license before licensed material is transferred to it. 

8.10 Item 10: Radiation Safety Program 

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: 

• Steps to keep radiation exposures ALARA. 

• Description of equipment and facilities adequate to protect personnel, the public, and 

the environment. 

• Conduct of licensed activities by individuals qualified by training and experience. 

• Written operating and emergency procedures. 

• Program to inspect the job performance of radiographic personnel. 

• Description of organization structure and individuals responsible for ensuring 

implementation of radiation safety program. 

• Records management. 

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 Audit Program 

Regulations: 10 CFR 20.1101, 10 CFR 20.2102 

Criteria: Licensees must review the content and implementation of their radiation protection 

programs annually to ensure the following: 

• Compliance with NRC and DOT regulations (as applicable) and the terms and 

conditions of the license. 

• Occupational doses and doses to members of the public are ALARA. 

• Records of audits and other reviews of program content are maintained for 3 years. 
35

Discussion: Appendix G contains a suggested annual audit program that is specific to 

industrial radiography and is acceptable to the NRC. Since all areas indicated in Appendix G 

may not be applicable to every licensee and all items may not need to be addressed during 

each audit, licensees may wish to develop a program-specific audit checklist. 

The NRC encourages licensee management to conduct performance-based reviews by 

observing work in progress, interviewing staff, and spot-checking required records. As a part of 

the audit program, applicants should consider performing unannounced audits of industrial 

radiography to observe whether radiation safety procedures are being followed. 

It is essential that, once identified, problems are corrected comprehensively and 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. Licensees must maintain records of audits and other reviews 

of program content and implementation for 3 years from the date of the record. The NRC has 

found audit records that contain the following information acceptable: 

• Date of audit. 

• Name of person or persons who conducted the audit.

• Names of persons contacted by the auditor or auditors. 

• Areas audited. 

• Audit findings and corrective actions. 

• Follow-up. 

Response from Applicant: No response required. The licensee’s program for auditing its 

radiation safety program will be reviewed during inspection. 

References: The current version of the NRC’s Enforcement Policy is included on the NRC’s 

Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement.html. IN 96-28, “Suggested 

Guidance Relating to Development and Implementation of Corrective Action,” dated 

May 1, 1996, can be found on the NRC’s Generic Communications webpage under Information 

Notices: http://www.nrc.gov/reading-rm/doc-collections/gen-comm/. 

8.10.2 Radiation Monitoring Instruments 

Regulations: 10 CFR 30.33(a)(2), 10 CFR 34.25, 10 CFR 34.31, 10 CFR 34.65 

Criteria: A radiation survey meter intended for industrial radiography that utilizes sealed 

radionuclide sources should be capable of accurately measuring the radiation fields produced 

by the sealed radiography source currently in use and be visually checked for damage and for 

proper operation with a check source or other appropriate means, such as an exposure device, 

before use on each day it is to be used. The survey meter shall be calibrated at intervals not to 

exceed 6 months and after each servicing (except for battery changes). Written procedures are 

required for inspection and routine maintenance of the survey meters, which is to be performed 

at intervals not to exceed 3 months or before the first use thereafter to ensure proper 

functioning of components important to safety. 

Discussion: The licensee shall keep an adequate number of appropriate radiation survey 

instruments that are both calibrated and operable at each location where radioactive material is 

present to make the required radiation surveys. The instruments must be capable of measuring 
36

a range from 0.02 mSv (2 mrem) per hour through 10 mSv (1 rem) per hour. Each radiation 

survey instrument shall be calibrated at intervals not to exceed 6 months and after each 

instrument servicing, except for battery changes. Records of survey instrument calibrations will 

be retained for a minimum of 3 years (10 CFR 34.65, “Records of radiation survey 

instruments”). Records are to be made of equipment problems and maintenance performed, 

and these shall be retained for 3 years (10 CFR 34.73, “Records of inspection and maintenance 

of radiographic exposure devices, transport and storage containers, associated equipment, 

source changes, and survey instruments”). 

Response from Applicant: Provide the following: 

• A statement that: “We will possess and use calibrated and operable radiation survey 

meters.” 

AND 

• If calibration is performed by a person or firm outside the applicant’s organization, 

specify that the calibration will be performed by an NRC or Agreement State licensee 

specifically authorized to perform instrument calibration. 

OR 

• If the calibration is to be performed in-house, either state that the model procedures in 

Appendix H will be followed or describe alternative procedures. Identify the 

qualifications of the individuals who will perform the calibrations. 

8.10.3 Material Receipt and Accountability 

Regulations: 10 CFR 20.2207, 10 CFR 30.34(e), 10 CFR 30.41, 10 CFR 30.51, 

10 CFR 34.29, 10 CFR 34.63, 10 CFR 34.69, 

Criteria: Licensees must do the following: 

• Maintain records of receipt, transfer, and disposal of sources and devices. 

• Update transactions in the NSTS, including an annual inventory reconciliation. 

• Conduct physical inventories at quarterly intervals (not to exceed 3 months) to account 

for all sealed sources containing byproduct material and for devices containing depleted 

uranium. 

Discussion: As illustrated in Figure 8.4, licensed materials must be tracked from “cradle to 

grave” to ensure accountability; identify when sources/devices may be lost, stolen, or 

misplaced; and ensure that the possession limit stated on the license is not exceeded. 

Physical inventories, which should be conducted at intervals not to exceed 3 months, should 

account for all sealed sources and devices containing depleted uranium (i.e., locate, verify the 

presence of the material, and account for it in material transfer records). 
37

Inventory records should be maintained for 3 years and contain the following types of 

information: 

• Radionuclide and amount (in units of becquerels or curies) of byproduct material in each 

sealed source. 

• Manufacturer’s name, model number, and serial number of each sealed source 

containing byproduct material. 

• Manufacturer’s name, model number, and serial number of each device containing 

depleted uranium or byproduct material. 

• Location (e.g., permanent facility, field station, temporary jobsite) of each sealed source 

and device. 

• Date of the inventory. 

• Name with signature of individual performing inventory. 

Figure 8.4 Material receipt and accountability. Licensees must maintain records of 

receipt and disposal and conduct physical inventories quarterly (not to exceed 

3 months).

Response from Applicant: Provide the following statements: 

• “Physical inventories will be conducted and documented at quarterly intervals (not to 

exceed 3 months) to account for all sealed sources containing byproduct material and 

devices containing depleted uranium received and possessed under the license.” 

AND 

• “We will comply with the NSTS reporting requirement as described in 10 CFR 22.2207.” 

rad0002a.ppt

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Cradle to Grave Accountability

Disposal or Transfer

Quarterly

Inventory:

Jan

7 April

7

Transfer

or

Disposal

Record

Receipt

Receipt

Record
38

8.10.4 Minimization of Contamination 

Regulations: 10 CFR 20.1406 

Criteria: Applicants for new licenses must describe how facility design and procedures for 

operation will minimize, to the extent practicable, contamination of the facility and the 

environment; facilitate eventual decommissioning; and minimize, to the extent practicable, the 

generation of radioactive waste. 

Discussion: All applicants for new licenses need to consider the importance of designing and 

operating their facilities so as to minimize the amount of radioactive contamination generated at 

the site during its operating lifetime and the generation of radioactive waste during 

decontamination. Sealed sources and devices that are approved by the NRC or an Agreement 

State and located and used according to their respective SSD registration certificates usually 

pose minimal risk of contamination. Industrial radiography applicants usually do not need to 

address these issues as a separate item since they are included in responses to other items of 

the application. 

Leak tests performed as specified in 10 CFR 34.27, “Leak testing and replacement of sealed 

sources,” should identify defective sources. Leaking sources must be withdrawn from use and 

decontaminated, repaired, or disposed of according to NRC requirements. These steps 

minimize the spread of contamination and reduce radioactive waste associated with 

decontamination efforts. Other efforts to minimize radioactive waste do not apply to programs 

using only sealed sources and devices that have not leaked. 

Response from Applicant: The applicant does not need to respond to this item under the 

following condition. The NRC will consider that the above criteria have been met if the 

applicant’s responses meet the criteria for the following sections: “Radioactive Material—

Sealed Sources and Devices”; “Facilities and Equipment”; “Radiation Safety Program—Leak 

Tests”; “Radiation Safety Program—Operating and Emergency Procedures”; and “Waste 

Management—Sealed Source/DU Device Transfer and Disposal.” 

8.10.5 Leak Tests 

Regulations: 10 CFR 30.53, 10 CFR 34.13(h), 10 CFR 34.27, 10 CFR 34.67 

Criteria: The NRC requires testing to determine whether there is any radioactive leakage from 

the source or from devices containing depleted uranium shielding. The NRC finds testing to be 

acceptable if it is conducted by an organization licensed by the NRC or an Agreement State or 

if it is conducted in accordance with procedures approved by the NRC or an Agreement State. 

Discussion: The NRC or an Agreement State may authorize manufacturers, consultants, and 

other organizations to either perform the entire leak-test sequence for other licensees or 

provide leak-test kits to licensees. In the latter case, the licensee is expected to take the leaktest sample according to the device manufacturer’s and the kit supplier’s instructions and return 

it to the kit supplier for evaluation and reporting results. Licensees may also be authorized to 

conduct the entire leak-test sequence themselves. Measurement of the leak-test sample is a 

quantitative analysis requiring that instrumentation used to analyze the sample be capable of 

detecting 185 Bq (0.005 microcurie (μCi)) of radioactivity. 
39

Sealed sources containing byproduct material must be leak tested at intervals not to exceed 

6 months, and depleted uranium devices must be tested at intervals not to exceed 12 months. 

Response from Applicant: State either of the following: 

• “Leak tests will be performed by an organization authorized by NRC or an Agreement 

State to provide leak testing services to other licensees; or by using a leak test kit 

supplied by an organization licensed by NRC or an Agreement State to provide leak test 

kits and/or services to other licensees and according to the instructions provided in the 

leak test kit.” 

OR 

• “Leak testing and analysis will be done by the applicant.” Provide the information in 

Appendix I supporting a request to perform leak testing and sample analysis and either 

state that you will follow the model procedures in Appendix I or submit a description of 

alternative procedures. 

Note: Requests for authorization to perform leak testing and sample analysis will be reviewed 

on a case-by-case basis and, if approved, the NRC staff will authorize these activities via a 

license condition. 

8.10.6 Occupational Dose 

Regulations: 10 CFR 20.1201, 10 CFR 20.1207, 10 CFR 20.1208, 10 CFR 20.1501, 

10 CFR 20.1502, 10 CFR 34.47 

Criteria: Licensees must evaluate the potential occupational exposure of all workers and 

monitor occupational exposure. Provide to employees film, thermoluminescent dosimeters 

(TLDs), or other personal dosimetry processing that has been accredited under the National 

Voluntary Laboratory Accreditation Program (NVLAP) operated by the National Institute of 

Standards and Technology (NIST). 

Figure 8.5 Dose limits for radiation workers

Dose Limits for

Radiation Worker

(10 CFR 20.1201)

Total effective dose equivalent TEDE

(whole body) 0.05 Sv (5 rems)

Eyes (Lens)

0.15 Sv

(15 rems)

Skin

0.50 Sv

(50 rems)

Elbows

to hands

0.50 Sv

(50 rems)

Knees to feet

0.50 Sv

(50 rems)
40

Discussion: The licensee may not permit any individual to act as a radiographer or a 

radiographer’s assistant unless, at all times during radiographic operations, each individual 

wears, on the trunk of the body, a combination of a direct-reading dosimeter (pocket dosimeter 

or electronic personal dosimeter), an operating alarm ratemeter, and a film badge, TLD, or 

other personal dosimetry device that is NVLAP processed. At permanent radiography 

installations where other appropriate alarming or warning devices are in routine use, wearing an 

alarming ratemeter is not required. The pocket dosimeters must have a range from zero to 

2 mSv (200 mrem), must be recharged at the start of each shift, and must be checked for 

correct response to radiation at intervals not to exceed 12 months. Electronic personal 

dosimeters may only be used in place of ion-chamber pocket dosimeters. Alarm ratemeters 

must be preset to give an alarm signal at a dose rate of 5 millisievert per hour (mSv/h) (500 

millirem per hour (mrem/h)) and must be calibrated for correct response at intervals not to 

exceed 12 months. 

Film badges must be replaced at intervals not to exceed 1 month, and TLDs or other personal 

dosimetry device that are NVLAP processed must be replaced at intervals not to exceed 

3 months. 

Response from Applicant: Provide the following: 

• A statement that film, TLD, or other personal dosimetry device is processed and 

evaluated by an NVLAP-accredited processor. 

• A statement that film, TLD, or other personal dosimetry device will be exchanged at the 

required frequency and will be assigned to and worn by radiographic personnel. 

• A statement that the required personnel monitoring equipment, including 0-to-2 mSv 

(200 mrem) dosimeters or electronic personal dosimeters, will be worn by radiographic 

personnel. 

• A statement that alarming ratemeters will be worn by all radiography personnel except 

those at permanent radiography installations where other appropriate alarming or 

warning devices are in use. 

• A statement that pocket dosimeters and alarm ratemeters will be checked for correct 

response at intervals not to exceed 12 months. If adjustment is necessary, state either 

that the devices will be returned to the manufacturer or describe in-house procedures if 

adjustments are made in-house. 

Note: Information on NVLAP accreditation and directory of accredited laboratories can be 

obtained from the Internet at http://ts.nist.gov/nvlap. 

8.10.7 Public Dose 

Regulations: 10 CFR 20.1003, 10 CFR 20.1301, 10 CFR 20.1302 

Criteria: Licensees must do the following: 

• Ensure that radiography devices will be used, transported, and stored in such a way that 

members of the public will not receive more than 1 mSv (100 mrem) in a year, and the 

dose from licensed operations in any unrestricted area will not exceed 0.02 mSv 

(2 mrem) in any 1 hour. 
41

rad0004d.ppt

072298

Device Storage

Properly stored: a sufficient

distance from personnel and

secured against unauthorized

access or removal Not properly stored : too close to

personnel, inadequate shielding and not

secured against unauthorized access or

removal

Figure 8.6 Storing devices. Devices must be stored away from occupied areas and

secured against unauthorized removal.

Discussion: Operating and emergency procedures that address security and surveillance 

should be sufficient to limit exposure of the public during use and after accidents. Public dose 

is controlled, in part, by ensuring that devices not in use are stored securely (e.g., stored in a 

locked area) to prevent unauthorized access or use. If devices are not in storage, then 

authorized users must maintain constant surveillance. 

Public dose is also affected by the choice of the permanent radiographic installation and 

storage locations and conditions, as illustrated in Figure 8.6. Since radiation levels around a 

permanent radiographic installation or storage area will vary based on the type and strength of 

sources used, the frequency of use, and scatter radiation from radiographic operations, it is not 

sufficient to perform surveys with portable survey meters to determine the annual public dose. 

Use of area monitors, such as environmental TLDs, is an acceptable means of demonstrating 

compliance with the annual limit of 1 mSv (100 mrem) in unrestricted areas. 

Use the concepts of time, distance, and shielding when choosing a permanent radiographic 

installation, field location, or storage area. Decreasing the time spent near radiographic 

operations, increasing the distance of the device from occupied locations, using shielding 

material (i.e., high-density concrete, solid block, or lead sheets), and implementing conservative 

operating procedures (i.e., use of collimators or limiting the direction of exposures towards the 

floor) will reduce the radiation exposure of personnel and members of the public. Alternatively, 

the remote location of and access to a permanent radiographic installation could prevent 

members of the public from receiving 1 mSv (100 mrem) in a year. 

If, after an initial evaluation, a licensee makes changes affecting the permanent radiographic 

installation storage area (e.g., changing the location of devices within the storage area, 

removing shielding, adding devices, changing the occupancy of adjacent areas, moving the 

storage area to a new location), then the licensee must perform a new evaluation to ensure that 

the public dose limits are not exceeded and devices are properly secured.

Response from Applicant: No response is required from the applicant in a license 

application, but this matter will be examined during an inspection. 
42

Appendix J provides additional information for determining that radiation doses for other 

licensee personnel and members of the public will not exceed allowable limits. 

8.10.8 Quarterly Maintenance 

Regulations: 10 CFR 34.31, 10 CFR 34.73, 10 CFR 71.101(g) 

Criteria: The licensee shall have written procedures for inspecting and maintaining 

radiographic exposure devices, source changers, associated equipment, transport and storage 

containers, and survey instruments. Inspection and maintenance must be conducted at 

intervals not to exceed every 3 months, or before the first use thereafter, to ensure the proper 

functioning of components important to safety. The licensee must also have procedures 

necessary to maintain the Type B packaging used to transport radioactive materials, ensure 

that Type B packages are shipped properly, and maintain Type B packages in accordance with 

the certificate of compliance (COC) issued by the NRC or other agencies approving such 

transport packages. 

If equipment problems are found, the equipment must be withdrawn from service until repaired. 

Records are required. 

Discussion: These procedures are intended to allow the licensee’s staff to evaluate 

equipment used in radiography for safe continued use, to provide a record of this evaluation, 

and to guide the staff in maintenance. Equipment found to be unsuitable for service must be 

withdrawn until repair and an evaluation for return to service is made. These procedures may 

be based on the manufacturer’s recommendations. The procedures are to be specific to the 

equipment. For example, radiography drive cable assemblies should be cleaned and lubricated 

(when operationally appropriate) in accordance with the recommendations of the equipment 

manufacturer or the cable manufacturer. Procedures are also required for Type B packaging 

used to transport radioactive materials. These procedures are to be used for shipping and 

maintenance and may be properly drawn from the manufacturer’s procedures and information 

submitted as a basis for the COC or other transport package approval. 

The general license requirements of 10 CFR 71.101, “Quality assurance requirements,” apply 

to all NRC licensees that transport, or deliver to a carrier for transport, licensed material in an 

NRC-approved transport package. Transport package users must do the following: 

• Register with the NRC before their first use of the package. 

• Obtain a copy of the COC, or other approval of the package, and comply with the terms 

and conditions of the certificate or approval. 

NRC licensees using NRC-approved transport packages are responsible for ensuring that all of 

these requirements have been met and that they are using currently authorized packages (see 

list of approved packages in NUREG-0383, “Directory of Certificates of Compliance for 

Radioactive Materials Packages”). 

Response from Applicant:

• Submit the quarterly maintenance procedures to the NRC for review and approval. The 

applicant should develop procedures specific to its equipment and program. The 
43

guidance provided in Sections 8.10.8 and 8.10.9 of NUREG-1556, Volume 2 should be 

of assistance inthe development of the applicant’s procedures. 

AND 

• State: “Before using a new sealed source/device combination, we will have written 

inspection and maintenance procedures that address the use of the new equipment as a 

Type B transport package. In addition, we will provide training to radiographic personnel 

before using a new sealed source/device combination.” 

8.10.9 Operating and Emergency Procedures 

Regulations: 10 CFR 34.13(d), 10 CFR 34.45 

Criteria: As a part of the radiation safety program, operating and emergency procedures must 

be established and submitted to the NRC as part of the application package. Sections 8.10.9.1 

through 8.10.9.13 discuss the specific operation and emergency procedures. In addition, if 

radiographers will perform other operations, such as source exchange, leak testing, quarterly 

(not to exceed 3 months) inspection and maintenance of equipment, and instrument calibration,

the operating and emergency procedures should include appropriate procedures and 

instructions for these operations. 

Each licensee should consider the following information when developing, implementing, and 

maintaining operating and emergency procedures: 

• Handling and use of sealed sources and devices to maintain radiographic exposures 

within dose limits. 

• Conducting radiation surveys. 

• Access control to radiographic areas. 

• Securing of exposure devices during storage and transport. 

• Personnel monitoring and use of personnel monitoring equipment. 

• Transport of exposure devices to field locations in accordance with DOT requirements. 

• Equipment maintenance program. 

• Immediate response actions to an off-scale dosimeter or ratemeter alarm. 

• Reporting defects as required by 10 CFR Part 21. 

• Actions to take and when to notify (licensee personnel and other agencies) when an 

incident occurs. 

• Source recovery procedures, if authorization for source recovery is requested. 

• Record maintenance. 
44

Discussion: The purpose of operating and emergency procedures is to provide radiography 

personnel with specific guidance for all operations they will perform. These topics should be 

included in the operating and emergency procedures and need not be presented in order of 

importance. A sequential set of procedures and instructions from the beginning to the end of 

the workday is an acceptable format. Instructions for nonroutine operations (e.g., quarterly (not 

to exceed 3 months) inspection and maintenance or instrument calibration) may be included as 

separate appendices. 

It is not necessary for operating and emergency procedures to be specific to a particular make 

and model of exposure device, source changer, or survey instrument. Procedures submitted to 

the NRC should provide sufficient guidance and instruction for each specific type of device. For 

example, you may submit a single operating procedure for crankout devices regardless of the 

manufacturer or a single operating procedure for other categories of exposure devices 

regardless of manufacturer. 

Note: Providing specific operating and emergency procedures for a particular manufacturer’s 

make and model number will require an amendment to the license to obtain the NRC’s 

authorization for a new sealed source/device combination. 

Applicants who plan to conduct lay-barge, offshore platform, or underwater radiography are 

required to have their procedures approved by the NRC in accordance with 10 CFR 34.45, 

“Operating and emergency procedures.” If you plan to conduct lay-barge, offshore platform, or 

underwater radiography, your radiation safety program will be reviewed to ensure that it 

contains procedures that specifically address the following: 

• Transport of licensed material. 

• Storage facilities for licensed material. 

• Methods for restricting access to radiation areas.

• Radiation safety procedures and radiographer responsibilities unique to lay-barge, 

offshore platform, or underwater radiography. 

• Radiographic equipment and radiation safety procedures unique to underwater 

radiography. 

• Methods appropriate for use of equipment in water environments. 

• Applicable inspection and maintenance procedures unique to lay-barge, offshore 

platform, or underwater radiography equipment. 

• Emergency procedures unique to lay-barge, offshore platform, or underwater 

radiography. 

Operating and emergency procedures must be submitted to the NRC for review. 

8.10.9.1 Operating and Emergency Procedures: Handling and Use of Sealed Sources and 

Radiography Exposure Devices 

Regulations: 10 CFR 34.41, 10 CFR 34.45, 10 CFR 34.46, 10 CFR 34.47, 10 CFR 34.49, 

10 CFR 34.51 

Criteria: Licensees must establish operating and emergency procedures. 
45

Discussion: The crankout device is normally used for radiography. Separate instructions are 

not necessary for each different model of a given type of device since the operation of each 

type is essentially the same regardless of the manufacturer. Some applicants may choose to 

use one basic instruction for all crankout devices; others may choose to have separate 

instructions for each model. Either approach is acceptable.

Specific procedures should be required for performing source exchanges, including those at 

temporary jobsites, field stations, and in permanent radiographic installations. The procedures 

should contain warnings of areas of concern during source exchanges. Incidents of sources 

becoming dislodged from the shielded position indicate the importance of training personnel in 

the appropriate techniques. Procedures should require the use of survey instruments, 

dosimetry, and surveys during and after movement of sources. 

Response from Applicant:

• Provide step-by-step instructions for using each type of radiographic device. 

• Include instructions for performing source exchanges. 

• Instructions for crankout devices should be separate from those for other categories of 

exposure devices. 

Manufacturers’ manuals and similar documents should not be incorporated into the 

procedures; rather, information should be extracted from them and paraphrased. 

Appendix K provides information for applicants to consider when developing their procedures 

for operating radiography equipment. 

8.10.9.2 Operating and Emergency Procedures: Methods and Occasions for Conducting 

Required Radiation Surveys 

Regulations: 10 CFR 20.1301(a)(2), 10 CFR 20.1302(a)(1), 10 CFR 20.1906, 

10 CFR 34.20(a), 10 CFR 34.21, 10 CFR 34.27(c)(1), 10 CFR 34.27(e), 10 CFR 34.49(b), 

10 CFR 34.49(c), 49 CFR 172.403, 49 CFR 173.441 

Criteria: Perform radiation surveys during use, movement, and storage of licensed material to 

ensure its safe use and comply with regulatory requirements. 

Discussion: In general, surveys are required whenever a source is manipulated or moved. 

Surveys should be made with a radiation survey instrument calibrated in accordance with 

10 CFR 34.25, “Radiation survey instruments.” The following table provides examples of 

surveys made during radiographic and associated operations that should be included in the 

operating and emergency procedures. 
46

Table 8.1 Surveys Required for Radiographic Operations 

Requirement Frequency Radiation Survey Limits

10 CFR 20.1301(a)(2) During the first exposure for 

each set up of radiographic 

device 

Boundary of restricted area at temporary 

jobsite does not exceed 0.02 mSv 

(2 mrem) in any 1 hour 

10 CFR 20.1302(a)(1) At intervals not to exceed 

12 months 

Unrestricted area in vicinity of permanent 

radiographic installation or storage area 

does not exceed 1 mSv (100 mrem) per 

year 

10 CFR 20.1906 Each receipt of package External radiation levels when a package 

is received does not exceed 2 mSv/h 

(200 mrem/h) 

10 CFR 34.20(a) Each installation of new 

source in exposure device 

Exposure rate does not exceed 2 mSv/h 

(200 mrem/h) on surface and 0.1 mSv/h 

(10 mrem/h) at 1 meter 

10 CFR 34.21 Each installation of new 

source in a storage 

container or source changer

Exposure rate does not exceed 2 mSv/h 

(200 mrem/h) at any exterior surface and 

0.1 mSv/h (10 mrem/h) at 1 meter from 

any exterior surface with the sealed 

source in the shielded position 

10 CFR 34.27(c)(1) At intervals not to exceed 

6 months 

Contamination level for leak tests of 

sealed sources does not exceed 185 Bq 

(0.005 μCi) 

10 CFR 34.27(e) At intervals not to exceed 

12 months 

Contamination level for leak tests of 

S-tube of exposure device does not 

exceed 185 Bq (0.005 μCi) 

10 CFR 34.49(b) After every radiographic 

exposure 

Confirm source has returned to a 

shielded position 

10 CFR 34.49(c) After every source 

exchange or exposure 

device is placed in storage 

Confirm source is in shielded position 

49 CFR 172.403 Every movement of 

licensed material on public 

roads 

Confirm exposure rates meet labeling of 

package (i.e., Yellow II) and determine 

Transport Index 

49 CFR 173.441 Every movement of a 

package labeled Yellow III 

Exposure rates in and around vehicle do 

not exceed 0.002 mSv/h (2 mrem/h) in 

driver’s seat, 2 mSv/h (200 mrem/h) on 

surface and 0.1 mSv/h (10 mrem/h) at 

2 meters from vehicle 

Response from Applicant: Where applicable, the operating and emergency procedures must 

include each of the surveys included in Table 8.1 above. 
47

8.10.9.3 Operating and Emergency Procedures: Methods for Controlling Access to 

Radiographic Areas 

Regulations: 10 CFR 20.1801, 10 CFR 20.1802, 10 CFR 20.1902(a), 10 CFR 20.1902(b), 

10 CFR 34.33, 10 CFR 34.41(a), 10 CFR 34.51, 10 CFR 34.53 

Criteria: Each licensee must control access to areas where licensed material is either used or 

stored to prevent the unnecessary exposure of members of the public. This can be achieved 

through the use of posting, by locking devices and areas where licensed materials are stored, 

and by maintaining constant control and continuous surveillance of areas where radiographic 

operations are conducted. Operating and emergency procedures should include steps for 

radiographic personnel to ensure that access to licensed materials is controlled for the types of 

operations that will be performed. 

Discussion:

Field/Temporary Jobsites

When radiographic operations are performed outside a permanent radiographic installation, at 

least two qualified radiographic personnel must be present to provide constant surveillance of 

the operations and be capable of providing immediate assistance to prevent unauthorized entry 

to the restricted area. At least one of the individuals must be a radiographer; the other may be 

another radiographer or a trained radiographer’s assistant. Operating procedures must comply 

with the two-man rule for radiographic operations at any locations other than permanent 

radiographic facilities. 

Radiographic personnel are required to maintain continuous direct visual surveillance of 

operations to protect against unauthorized entry to the high-radiation area during radiographic 

operations. Radiographic personnel should be instructed to keep the perimeter of the restricted 

area under continuous surveillance to prevent unnecessary exposure of individuals. Operating 

procedures should specify steps for responding to unauthorized entry to the restricted area. 

For example, personnel should be instructed to terminate the radiographic exposure 

immediately before confronting the person who entered the restricted area. 
48

rad0008b.ppt

081398

Source

2 mrem

in one hour

DANGER

High Radiation

Area

DANGER

High Radiation

Area

CAUTION

Radiation

Area

Figure 8.7 Posting. A radiographer is likely to use only a single rope barrier. The 

radiation area and restricted area would be combined into one and located at the 

boundary of 2 mrem in any 1 hour. 

All areas where radiographic operations are conducted require posting of the radiation areas 

and the high-radiation areas, as shown in Figure 8.7. Specific exceptions to posting listed in 

10 CFR 20.1903, “Exceptions to posting requirements,” do not apply to industrial radiography 

(10 CFR 34.53, “Posting”). However, it is acceptable to post the perimeter of the restricted area 

rather than the perimeter of the radiation area. Personnel should be instructed to post signs 

stating “Caution Radiation Area” at the point where radiation levels have been calculated to 

reach 0.02 mSv (2 mrem) in any 1 hour. A confirming survey during the first exposure of the 

source should be conducted to confirm the location of the boundary, and any necessary 

adjustments should be made. As a “rule of thumb,” radiographers should establish the 

boundary where measured exposure levels do not exceed 0.02 mSv/h (2 mrem/h). 

The perimeter of the high-radiation area must be posted with a sign or signs stating “Caution (or 

Danger) High-Radiation Area” at the point where radiation levels have been calculated to reach 

1 mSv (100 mrem) in any 1 hour. A confirming survey of the high-radiation area perimeter 

should not be conducted, since such a survey could lead to unnecessary exposure of 

personnel. 

Surveillance of the restricted area at facilities with multiple levels and multiple access points, or 

where members of the public are close to the radiographic operations (e.g., boilers, commercial 

manufacturing plants, or power plants during outages), can usually be performed only when 

more than two radiographic personnel are assigned to the job. Figure 8.8 provides one 

example of such a temporary jobsite. Operating procedures and instruction to personnel should 

include specific steps for these circumstances to ensure that access into the restricted area is 

properly controlled. These special instructions may include the use of additional personnel to 

assist radiographic personnel in controlling access into the restricted area, providing instruction 

to other workers in the area, or making announcements over the public address system before 

and during radiographic operations. 
49

rad0005d.ppt

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CAUTION

Radiation

Area

CAUTION

Radiation

Area

CAUTION

Radiation

Area

CAUTION

Radiation

Area

CAUTION

Radiation

Area

CAUTION

Radiation

Area

CAUTION

Radiation

Area

CAUTION

Radiation

Area

BUILDING

UNDER

CONSTRUCTION

Figure 8.8 Surveillance and posting at a temporary jobsite with multiple floors and 

access points. Adequate control of the restricted area at this type of job site requires 

several personnel and many postings.

Permanent Radiographic Installations

For permanent radiographic installations, instruct personnel about posting each entrance to the 

facility with a sign or signs stating “Caution (or Danger) High-Radiation Area,” and provide 

procedures to ensure that the visible-audible signal system is operable. The operability of the 

visible-audible system must be checked daily. The following procedures may be used: 

• Expose a radiation source in the permanent installation with all entrances closed. 

• Determine that each visible signal in and outside the installation is functional. 

• Open the door to each entrance into the installation to activate the audible alarm. 

• Close the entrance and confirm that the alarm stops. If the installation has more than 

one entrance, only one entrance should be tested at a time. 

• Record results of test. 
50

In the event that an entrance control device or an alarm fails to operate properly at the 

permanent radiographic installation, the installation may continue to operate for up to 7 days 

while the defective equipment is fixed, provided that the following is true: 

• The entrance control device is labeled as defective. 

• Radiography personnel maintain continuous, direct, and visual surveillance of access 

installation points. 

• Radiography personnel use an alarming rate meter. 

• The radiographer must be accompanied by at least one other qualified radiographer or 

individual who has at a minimum met the requirements of 10 CFR 34.43(c). 

Storage Areas

Radiographic equipment containing licensed materials stored in controlled or unrestricted areas 

must be secured from unauthorized removal or access. Operating procedures should specify 

how stored licensed materials should be secured. 

A vehicle used to transport licensed material can also be used for storage at locations such as 

temporary jobsites or overnight lodging. If the applicant plans to use vehicles for storage, there 

should be procedures and instructions to personnel about proper posting of the vehicle. 

Vehicles should be posted with a sign stating “Caution—Radioactive Material” on the entrance 

to the area of the vehicle were licensed material is stored. A physical survey should be 

performed to confirm that the area around the storage facility is an unrestricted area. Radiation 

levels may not exceed 0.02 mSv/h (2 mrem/h) at 18 inches (45 centimeters) from any external 

surface of the vehicle, and the vehicle shall be locked when it is used for storage. Radiographic 

equipment stored at temporary jobsites must be secured at a location that prevents access by 

unauthorized personnel. This usually requires that the equipment be locked in a cabinet or 

other secure area where key access is controlled by site management and radiographic 

personnel. It is not acceptable for a device to be chained to a post and left unattended at the 

place of use during lunch, breaks, or after hours. Storage of exposure devices at a private 

residence is unacceptable unless it has been identified and approved in a license. 

Response from Applicant: Submit the procedures to control access to radiographic 

operations and storage areas. 

8.10.9.4 Operating and Emergency Procedures: Methods and Occasions for Locking and 

Securing Radiographic Exposure Devices, Storage Containers, and Sealed Sources 

Regulations: 10 CFR 34.20, 10 CFR 34.23 

Criteria: NRC regulations require radiographic equipment to be locked and secured to protect 

the public and radiographers from an inadvertent exposure to radiation. 

Discussion: All radiographic devices (i.e., gamma cameras, sealed source storage containers, 

and source changers) are required to have a lock or outer locked container to maintain the 

sealed source in its shielded position. During radiographic operations, the source must 

automatically be secured in the shielded position each time the source is returned. 

Radiographers must not attempt to circumvent the automatic securing features or tamper with 

the safety features of radiographic devices. As shown in Figure 8.9, radiographers must never 
51

leave the exposure device at the temporary jobsite (including in a storage area or vehicle) 

without securing it properly from unauthorized removal or tampering. Radiographers and 

radiographer’s assistants must ensure that the exposure device and storage or source 

containers are maintained locked (and if key locked, with the key removed at all times) when 

they are not under the direct supervision of the radiographer or the radiographer’s assistant, 

except at permanent radiographic installations. 

Response from Applicant: Submit operating and emergency procedures that include 

procedures for locking and securing radiographic equipment. 

Security

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DANGER

High Radiation

Area

Storage and transport

Constant surveillance when

idle or in use

Figure 8.9 Security. To avoid lost or stolen devices, licensees must keep the devices 

under constant surveillance or secured against unauthorized use or removal. 

8.10.9.5 Operating and Emergency Procedures: Personnel Monitoring and the Use of 

Personnel Monitoring Equipment 

Regulations: 10 CFR 34.45(a)(5), 10 CFR 34.47 

Criteria: Provide procedures for appropriate use of personnel monitoring equipment. 

Discussion: As shown in Figure 8.10, all radiographers or radiographer’s assistants are 

required to wear: 

• Direct-reading dosimeters and either film badges, TLDs, or other personal dosimetry 

devices. 

• Alarm ratemeters when they are engaged in radiographic operations. 

Film badges, TLDs, or other personal dosimetry devices must be assigned to and worn by only 

one individual. To ensure full-scale reading capability, direct-reading dosimeters, such as 

pencil (pocket) dosimeters or electronic personal dosimeters, must be recharged or reset at the 

start of each shift so that the dosimeters will be capable of reading the full scale. Personnel 

should be instructed that direct-reading dosimeters must be read and recorded at the beginning 

and end of each shift. Proper operation of alarm ratemeters must be checked each day before 
52

use to ensure that the alarm functions properly. The manufacturer’s recommended procedures 

should be followed. 

Include instructions about how and where dosimetry devices are to be stored when not in use. 

The storage place should be dry, with a low-radiation background area, and cool so that the 

devices will not be affected by adverse environmental conditions. 

It is good practice to check the dosimeter reading after each exposure and during the work 

shift; however, there is no regulatory requirement for the dosimeter to be read during the work 

shift. 

All radiographers or radiographer’s assistants are required to wear alarm ratemeters except at 

permanent radiographic facilities where other appropriate alarm or warning devices (e.g., visible 

and audible alarms) are in routine use and are operable. 

The Well-Dressed

Radiographer

rad0010a.ppt

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Alarm

Ratemeter

Pocket

Dosimeter

Film

Badge

Survey

Meter

Figure 8.10 The well-dressed radiographer. The radiographer is equipped with the 

required personnel monitoring devices and survey instrument. 

Response from Applicant: The operating procedures must include instructions for proper use 

of personnel monitoring equipment. 

8.10.9.6 Operating and Emergency Procedures: Transporting Sealed Sources to Field 

Locations, Securing Exposure Devices and Storage Containers in Vehicles, Posting 

Vehicles, and Controlling Sealed Sources During Transportation 

Regulations: 10 CFR 71.5, 49 CFR Parts 171–178 

Criteria: Licensees must develop, implement, and maintain procedures for transporting 

radioactive material to ensure compliance with DOT regulations. 
53

Discussion: Figure 8.11 illustrates some often overlooked DOT requirements. During an 

inspection, the NRC uses the provisions of 10 CFR 71.5, “Transportation of licensed material,” 

and a memorandum of understanding with DOT to examine and enforce transportation 

requirements applicable to radiography licensees. Appendix L contains a list of major DOT 

regulations applicable to transporting radiographic devices. 

Transportation

rad0011b.ppt

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Properly labeled,

blocked, braced,

secured, and away

from the driver

Shippi

ng

Papers

Figure 8.11 Transportation. Licensees often transport their radiographic devices to and 

from sites and must ensure compliance with DOT regulations. 

Instructions to personnel should not reference DOT requirements. Information should be 

extracted, paraphrased, and placed into the instructions so that personnel know exactly what 

they are expected to do. The following items should be covered in instructions to personnel: 

• Labeling containers appropriately (i.e., when to use labels Radioactive White I, 

Radioactive Yellow II, or Radioactive Yellow III). 

• Securing the exposure device or storage container within the transporting vehicle. The 

instructions should specify how to prevent the package from moving during transport. 

• Preparing shipping papers. The instructions should specify that the papers must be 

completed before transporting the licensed material and must be accessible in the 

driver’s compartment at all times. 

• Placarding both sides, the front, and the back of the vehicle with “RADIOACTIVE” 

placards if the package being transported requires a Radioactive Yellow III label. If the 

vehicle requires placarding and the package radiation levels exceed 2 mSv/h 

(200 mrem/h) or the transport index exceeds 10, the exterior surfaces and passenger 

compartment of the vehicle must be surveyed to ensure that the radiation levels do not 

exceed 0.02 mSv/h (2 mrem/h) from any exterior surface and 0.02 mSv/h (2 mrem/h) in 

the passenger compartment. Include instructions to personnel on the measures to take 

if the radiation level exceeds 0.02 mSv/h (2 mrem/h) in the passenger compartment 

(e.g., adding more shielding or repositioning the device within the vehicle). If an 

exposure device is transported in an overpack, the procedures should include 

instructions that the overpack must be properly marked with the shipping name and 

identification number, labeled (Radioactive White I or Radioactive Yellow II), and 

marked when required with a statement that indicates the inner package complies with 

prescribed specifications. 
54

Because the licensee may have authorization to possess and use several sealed source/device 

combinations that are registered by the NRC or an Agreement State and meet the safety 

performance requirements of 10 CFR 34.20, the applicant must, before using a new sealed 

source/device combination, develop written inspection and maintenance procedures for it and 

for the corresponding Type B transport package. In addition, the applicant must provide 

adequate training for radiographic personnel before using a new sealed source/device 

combination. 

The applicant’s inspection and maintenance procedures for radiographic equipment, which are 

also used for Type B packages, should ensure that these packages are shipped and 

maintained in accordance with their COC. 

Response from Applicant: Submit operating and emergency procedures for transporting 

sealed sources containing byproduct material, exposure devices, and source changers. 

8.10.9.7 Operating and Emergency Procedures: Daily Inspection and Maintenance of 

Radiographic Equipment 

Regulations: 10 CFR 34.31, 10 CFR 34.33, 10 CFR 34.45(a)(7), 10 CFR 34.47, 

10 CFR 34.73, 10 CFR 34.83 

Criteria: The licensee shall perform visual and operability checks before using radiography 

equipment on each day it is used. 

Discussion: Visual and operability checks must be performed on radiographic exposure 

devices, survey meters, associated equipment, and transport and storage containers before 

use each day that the equipment is used. These checks are intended to ensure that the 

equipment is in good working condition, the sources are adequately shielded, and the required 

labeling is present. Licensees must check survey instrument operability using check sources or 

other appropriate means. The exposure device may be used as a check source. 

Inspection records shall contain information about equipment problems found in daily checks 

and quarterly (not to exceed 3 months) maintenance inspections. Records shall include the 

date of check or inspection, name of inspector, equipment involved, any problems found, and 

what repair or maintenance, if any, was done. 

Instructions to personnel using radiographic equipment must clearly state that inspections are 

to be made before the equipment is used each day. While not a requirement, good practice 

would be to inspect the equipment before the start of each shift, if the equipment is used on 

more than one shift in the day. 

The procedures should specify the items that are to be checked and the steps that are to be 

taken if any defects are found. If problems are found, the equipment must be removed from 

service until it is repaired. 

Equipment manufacturers can provide a list of items that should be checked in the daily 

inspection of radiography equipment. 

Permanent radiographic installation visible and audible alarms must be checked for operability 

daily before use, and faulty radiographic equipment must be labeled and repaired within 7 days, 
55

with compensatory measures taken in the interim. Compensatory measures taken include the 

following: 

• The faulty equipment is immediately labeled as defective. 

• The radiographer must be accompanied by at least one other qualified radiographer or 

individual who has at a minimum met the requirements of 10 CFR 34.43(c). 

• Continuous surveillance requirements are implemented until repairs are completed. 

• Alarm ratemeters shall be worn and checked for alarm function at the beginning of each 

shift. 

• Records must be maintained of faulty equipment. 

Direct-reading dosimetry devices must be read and the exposures recorded at the beginning 

and end of each shift. Alarm ratemeters shall be checked for alarm function at the beginning 

of each shift. Records are to be maintained. 

Appendix M provides example instructions for daily inspection of radiographic devices and 

equipment. 

Response from Applicant: Submit operating and emergency procedures for daily inspection 

and maintenance of radiographic equipment. 

8.10.9.8 Operating and Emergency Procedures: Ratemeter Alarms or Off-Scale Dosimeter 

Readings 

Regulations: 10 CFR 34.43(b)(2), 10 CFR 34.45(a)(8), 10 CFR 34.47(d) 

Criteria: Licensees must instruct personnel in the following: 

• appropriate handling and use of sealed radionuclide sources and radiography devices 

• methods and occasions for conducting radiation surveys; controlling access to radiation 

areas; and locking, securing, and transporting storage containers, radiographic 

exposure devices, and sealed radionuclide sources 

• the licensee’s license and operating and emergency procedures 

• actions to be taken if a dosimeter shows an off-scale reading or an alarm ratemeter 

alarms (e.g., sounds) unexpectedly 

• procedures to be followed if a personal dosimeter (processed by NVLAP processor) is 

lost or damaged 

• procedures for notifying the proper persons in the event of an accident 

Discussion: If an individual’s self-reading pocket dosimeter is found to be off scale, an 

individual’s electronic personal dosimeter reads above 2 mSv (200 mrem), or an alarm 

ratemeter alarms (e.g., sounds) unexpectedly, the RSO or designee must be notified 

immediately. If the RSO or designee cannot rule out radiation exposure as the root cause, the 

individual’s personal dosimetry device must be sent for processing within 24 hours. The 

affected individual may not resume work with licensed radioactive material until the RSO or 
56

designee has determined the individual’s radiation exposure. There are no exceptions to this 

requirement. 

If any of the events described above should occur, personnel should be instructed to do the 

following at a minimum: 

• Stop work immediately and ensure that the source is in the safe storage position in the 

exposure device, and vacate the radiation area. 

• If the alarm ratemeter alarms (e.g., sounds), evaluate pocket dosimeter reading. 

• Notify the individual specified in the emergency procedures. 

• Notify the RSO or designee of the problem. 

• If pocket dosimeter is off scale, do not resume operations until authorized by the RSO or 

designee. 

• If the RSO or designee cannot rule out the exposure, then process the personal 

dosimetry device within 24 hours. 

Response from Applicant: Submit operating and emergency procedures to address 

ratemeter alarms or off-scale dosimeters. 

8.10.9.9 Procedure for Identifying and Reporting Defects and Noncompliance As Required By 

10 CFR Part 21 

Regulations: 10 CFR Part 21, 10 CFR 30.50, 10 CFR 34.101(a)(3)

Criteria: Licensees must notify the NRC if defects are found in radiography equipment. 

Discussion: Equipment defects that could create a substantial safety hazard or equipment 

failures involving NRC-regulated activities must be reported to the NRC. For example, a failure 

of a lock box or a failure of the coupling between the source assembly and the control cable are 

defects that must be reported to the NRC. Radiography personnel should be instructed to 

report any malfunction or defect in radiography equipment to management, so that 

management can take appropriate action. IN 91-39, “Compliance with 10 CFR Part 21, 

Reporting of Defects and Noncompliance,” dated June 17, 1991, provides additional guidance 

on determining whether a safety hazard exists and sample procedures for identifying and 

reporting defects. 

Response from the Applicant: Submit operating and emergency procedures for notifying 

management of equipment malfunction or defect. 

IN 91-39, “Compliance with 10 CFR Part 21, Reporting of Defects and Noncompliance,” dated 

June 17, 1991, can be found on the NRC’s Generic Communications webpage under 

Information Notices : http://www.nrc.gov/reading-rm/doc-collections/gen-comm/. 
57

8.10.9.10 Notification of Proper Persons in the Event of an Accident 

Regulations: 10 CFR 30.50, 10 CFR 34. 45(a)(10), 10 CFR 34.101(a), 10 CFR 20.2201, 

10 CFR 20.2202, 10 CFR 20.2203 

Criteria: Operating and emergency procedures must ensure that appropriate notifications are 

made during and after an incident. 

Discussion: The emergency procedures should clearly identify the names and telephone 

numbers of the RSO and other persons who can provide assistance in an emergency or 

accident. Such persons may also include the exposure device manufacturer and State and 

local agencies. The emergency procedures should always be available to radiography 

personnel during radiography and must be as up to date as possible. 

NRC regulations also require telephone notification and/or a written report based on the 

discovery of certain events. Licensees must notify the NRC when radiographic devices are lost 

or stolen or if there is indication of overexposure. Licensees must notify the NRC when 

radiographic device components fail, such as unintended source disconnects or locking 

mechanism failures. Refer to the regulations listed above or to Appendix N for additional 

guidance in the preparation of emergency procedures. Table 8.2 describes events that require 

notification or reports. 

Table 8.2 Regulatory-Required Notifications 

Typical NRC Notifications Required for Radiography Licensees

Event Telephone 

Notification

Written 

Report

Regulatory Requirement

Theft or loss of material immediate 30 days 10 CFR 20.2201(a)(1)(i) 

Whole body dose greater than 0.25 Sv 

(25 rem) 

immediate 30 days 10 CFR 20.2202(a)(1)(i) 

Extremity dose greater than 2.5 Sv 

(250 rem) 

immediate 30 days 10 CFR 20.2202(a)(1)(iii) 

Whole body dose greater than 0.05 Sv 

(5 rem) in 24 hours 

24 hours 30 days 10 CFR 20.2202(b)(1)(i) 

Extremity dose greater than 0.5 Sv 

(50 rem) in 24 hours 

24 hours 30 days 10 CFR 20.2202(b)(1)(iii) 

Whole body dose greater than 0.05 Sv 

(5 rem) 

none 30 days 10 CFR 20.2203(a)(2)(i) 

Dose to individual member of public 

greater than 1 mSv (100 mrem) 

none 30 days 10 CFR 20.2203(a)(2)(iv) 

Defect in equipment that could create a 

substantial safety hazard 

2 days 30 days 10 CFR 21.21(d)(3)(i) 
58

Typical NRC Notifications Required for Radiography Licensees

Event Telephone 

Notification

Written 

Report

Regulatory Requirement

Event that prevents immediate protective 

actions necessary to avoid exposure to 

radioactive materials that could exceed 

regulatory limits 

immediate 30 days 10 CFR 30.50(a) 

Equipment is disabled or fails to function 

as designed when required to prevent 

radiation exposure in excess of regulatory 

limits 

24 hours 30 days 10 CFR 30.50(b)(2) 

Unplanned fire or explosion that affects 

the integrity of any licensed material or 

device, container, or equipment with 

licensed material 

24 hours 30 days 10 CFR 30.50(b)(4) 

Leak test of sealed source or guide tube 

greater than 185 Bq (0.005 μCi) 

none 5 days 10 CFR 34.27(d) 

Unintentional disconnect of source 

assembly from control cable 

none 30 days 10 CFR 34.101(a)(1) 

Inability to retract source to a safe 

shielded position 

none 30 days 10 CFR 34.101(a)(2) 

Failure of any component to perform its 

intended function which is critical for safe 

operation of device 

none 30 days 10 CFR 34.101(a)(3) 

Use of licensed material at any location 

not on license for more than 180 days in 

a calendar year 

notify NRC 

regional 

office 

none 10 CFR 34.101(c) 

Note: Telephone notifications shall be made to the NRC Operations Center at (301) 816-5100, 

except as noted. The Center is staffed 24 hours a day and accepts collect calls. NRC 

notification is required when licensed materials are lost or stolen or involved in an incident that 

may have resulted in doses in excess of NRC limits.

Response from Applicant: Submit operating and emergency procedures that include 

appropriate instructions for notifying the RSO and other personnel in the event of an 

emergency. 

8.10.9.11 Minimizing Exposure of Persons in the Event of an Accident 

Emergency Procedures

Regulations: 10 CFR 34.45(a)(11) 

Criteria: To maintain exposures as low as possible in the event of an emergency. 
59

Discussion: An emergency situation may be considered to exist whenever an abnormal event 

occurs or the source has failed to return to the safe position. Since it is not possible to specify 

all possible situations that would constitute an emergency, a general instruction is acceptable 

as shown in Figure 8.12. This general instruction should describe licensee actions to maintain 

the dose at a minimal level after an abnormal event is identified. The instruction should include 

routine emergency actions, such as evacuating personnel from the area, posting the restricted 

area, maintaining surveillance of the restricted area, and notifying the RSO. Appendix N 

provides an example of a routine emergency procedure. 

rad0005e.ppt

072298

1. Move Away from Source at Once 2. Calm Down and Think

3. Reconfirm Restricted Area (2mR/hr)

5. Call the RSO

4. Maintain Surveillance

CAUTION

Radiation

 Area

CAUTION

Radiation

 Area

I’ll go call

for help!

CAUTION

Radiation

 Area

CAUTION

Radiation

 Area

Figure 8.12 Emergency procedures. These steps provide guidance in an emergency.

Response from Applicant: Submit operating and emergency procedures that include 

instructions for minimizing exposure of persons in the event of an accident. 

8.10.9.12 Source Retrieval 

Regulations: 10 CFR 34.45(a)(12), 10 CFR 34.101(a), 10 CFR 34.101(b) 

Criteria: Each licensee who intends to perform source retrieval operations must have 

appropriate equipment, training, and procedures. 

Discussion: Applicants must develop source retrieval procedures if their own radiographic 

personnel with appropriate training and experience will conduct source retrievals. If procedures 
60

are submitted, the NRC will review and approve applicants to perform source retrieval. If 

source retrieval procedures are not submitted for review, then source retrieval activities must be 

conducted by an NRC or Agreement State licensee whose license specifically authorizes these 

activities. 

Licensees specifically approved to perform source retrievals will have a specific license 

condition authorizing these activities. In addition, these individuals would be authorized to 

perform source retrievals for other licensees. 

The NRC will review the applicant’s procedures for source retrieval with respect to keeping 

exposures ALARA and controlling exposures to radiation. Since it is not possible to specify all 

potential exposure situations, a general procedure is acceptable. A retrieval procedure should 

contain the following elements: 

• Warnings stating that only specifically authorized individuals, or personnel supervised by 

such authorized individuals and working in their presence, are allowed to perform 

retrievals. 

• A clear statement that no source or suspected source containing items such as a stuck 

source in a guide tube will be handled directly. 

• Expedient methods of reducing unintended exposure to staff and the public, such as 

using lead shot bags, sandbags, steel plates, remote handling devices, and culverts cut 

lengthwise. 

• Additional dosimetry to be used during source retrievals (e.g., pocket dosimeters with a 

range greater than 2 mSv (200 mrem) or finger badges). 

• Methods of restricting access to the area, including establishing a restricted area and 

obtaining outside help in controlling access. 

• Appropriate use of survey instruments, including a procedure prohibiting the use of 

alarming dosimeters or electronic dosimeters as substitutes for survey instruments. 

• Criteria for requesting outside assistance. 

• Instructions for reducing the exposure to other personnel and members of the public 

during recovery operations. 

• Notification of the RSO, RSO designee, and management. 

• Specific training, including practice with special tools, shielding, and additional dosimetry 

with a dummy source. 

• Notification of the NRC or Agreement State. 

Radiography personnel should not attempt to perform operations involving retrieval or recovery 

unless they have actual practice in retrieval operations using a dummy source with the 

appropriate handling tools, survey instruments, and dosimetry. 
61

Response from Applicant:

• Submit the following statement: “We will not perform source retrievals and will use the 

services of a person specifically licensed by the NRC or an Agreement State to perform 

the retrievals of our sources.” 

OR 

• Submit source retrieval procedures and specific training for NRC review in accordance 

with the criteria listed above. 

8.10.9.13 Maintenance of Records 

Regulations: 10 CFR 34.45(a)(13), 10 CFR 34.47, 10 CFR 34.71, 10 CFR 34.73, 

10 CFR 34.83, 10 CFR 34.85, 10 CFR 34.87, 10 CFR 34.89 

Criteria: The licensee shall meet NRC record requirements to support operating and 

emergency procedures. 

Discussion: Personnel must generate and maintain certain records when performing 

radiography operations, including the following: 

• Utilization logs showing the following: 

– Description, including the make, model, and serial number of the device used. 

– Identification and signature of the radiographer.

– Where the device is used and dates of use and the dates the device is removed 

and returned to storage. 

• Records of daily inspection of equipment. 

• Pocket dosimeter readings made at the beginning and end of a work shift and recorded. 

• Results of the physical survey to ensure that the sealed source is in its shielded position 

when a radiographic exposure device is placed in a storage area (as defined in 

10 CFR 34.3, “Definitions”) and an indication as to whether that survey was the last one 

performed in the workday. 

Examples of other operations that may require records include quarterly (not to exceed 

3 months) inspection and maintenance, instrument calibration, and shipment of packages. 

Radiography personnel should also be aware of the records that must be maintained at 

temporary jobsites. Radiographers performing radiographic duties should be given specific 

instructions for recordkeeping. These should not include instructions about records that are the 

responsibility of management and supervision. 

Response from the Applicant: Submit operating and emergency procedures which ensure 

proper maintenance of records. 

8.10.10 Security Program 

Regulations: 10 CFR 20.1801, 10 CFR 20.1802, and 10 CFR 20.2207 
62

Criteria: Licensees must ensure the security and control of licensed material. 

Discussion: The regulations in 10 CFR 20.1801, and 10 CFR 20.1802 require licensees to 

secure radioactive materials from unauthorized removal or access while in storage and to 

control and maintain constant surveillance over licensed material that is not in storage. 

The regulations in 10 CFR 20.2207, “Reports of transactions involving nationally tracked 

sources,” require that each licensee who manufactures, transfers, receives, disassembles, or 

disposes of a nationally tracked source shall complete and submit a National Source Tracking 

Transaction Report (NSTS). The NSTS is a major security initiative of the NRC. The NSTS is a 

secure, accessible and easy-to-use computer system that tracks high-risk radioactive sources 

from the time they are manufactured or imported through the time of their disposal or export, or 

until they decay enough to no longer be of concern. 

In addition to the regulations, the NRC in 2005 began issuing Orders imposing security 

requirements on licensees who possessed radioactive materials quantities of concern 

(RAMQC). The Orders required licensees to implement enhanced security to control access to 

RAMQC and to protect sensitive security-related information. In 2007, the NRC issued 

additional Orders to the same licensees requiring fingerprinting and criminal history records 

checks for unescorted access to RAMQC. The specific radionuclides and associated 

thresholds were based on the Category 1 and Category 2 quantities described in the 

International Atomic Energy Agency’s “Code of Conduct on the Safety and Security of 

Radioactive Sources.” 

Applicants and licensees should visit the NRC’s public Web site (www.nrc.gov) and select the 

Nuclear Security tab at the top of the NRC home page for additional information regarding the 

security of licensed material or any enhanced security requirements imposed by Orders. 

Please contact the appropriate regional office for questions regarding the security of licensed 

material or any enhanced security requirements imposed by the Orders. 

8.11 Item 11: Waste Management 

8.11.1 Disposal or Transfer of Radiography Sealed Sources Containing Byproduct 

Material or Devices Containing Depleted Uranium 

Regulations: 10 CFR 20.2001, 10 CFR 30.41, 10 CFR 30.51, 10 CFR 20.2207 

Criteria: Licensed materials must be disposed of in accordance with NRC requirements by 

transfer to an authorized recipient. Appropriate records must be maintained. 

Discussion: Licensees who dispose of radiography sealed sources containing byproduct 

material, or dispose of radiography devices containing depleted uranium, must transfer them to 

an authorized recipient licensed by either the NRC or an Agreement State. Before transferring 

radioactive material, a licensee must use one of the methods described in 10 CFR 30.41, 

“Transfer of byproduct material,” to verify that the recipient is properly authorized to receive it. 

In addition, all packages containing radioactive sources must be prepared and shipped in 

accordance with NRC and DOT regulations. Records of the transfer must be maintained as 

required by 10 CFR 30.51. 
63

If source activity exceeds activities listed in Appendix E, “Nationally Tracked Source 

Thresholds,” to 10 CFR Part 20, the transfer transaction must be reported in accordance with 

10 CFR 20.2207. 

Response from Applicant: The applicant does not need to provide a response to this item 

during the licensing process. However, the applicant should establish and include waste 

disposal procedures in its radiation safety program. 

Because of the difficulties and costs associated with disposal of sealed sources containing 

byproduct material and devices containing depleted uranium, applicants should preplan the 

disposal. Applicants may want to consider contractual arrangements with the sealed source 

and device supplier as part of a purchase agreement. 

The next two items on NRC Form 313 are to be completed on the form itself. 

8.12 Item 12: License Fees 

On NRC Form 313, enter the appropriate fee category from 10 CFR 170.31 and the amount of 

the fee enclosed with the application. 

Direct all questions about NRC’s fees or completion of Item 12 of NRC Form 313 to the Office 

of the Chief Financial Officer at NRC Headquarters in Rockville, MD, (301) 415-7554. 

Information about fees may also be obtained by calling NRC’s toll free number, (800) 368-5642, 

extension 415-7554. The e-mail address is Fees.Resource@nrc.gov. 

8.13 Item 13: Certification 

Regulations: 10 CFR 34.11 and 10 CFR 30.32(c) 

Criteria: To ensure adequate management involvement, a duly authorized management 

representative pursuant to 10 CFR 34.11, “Application for a specific license,” must sign the 

submitted application acknowledging management’s commitments and responsibilities. 

Discussion: Individuals acting in a private capacity are required to date and sign NRC Form 

313. Otherwise, representatives of the corporation or legal entity filing the application should 

date and sign NRC Form 313. Representatives signing an application must be authorized to 

make binding commitments and to sign official documents on behalf of the applicant. As 

discussed previously in Chapter 3, “Management Responsibility,” signing the application 

acknowledges management’s commitment and responsibilities for the radiation protection 

program. The NRC will return all unsigned applications for proper signature. 

Response from Applicant: Certifying Officer signs and dates the application.

Notes:

• It is a criminal offense to make a willful false statement or representation on an 

application or correspondence (18 U.S.C. 1001). 

• When the application references commitments, those commitments can become part of 

the license conditions and regulatory requirements. Therefore, the applicant is 

responsible for proper implementation of commitments.

65

9. AMENDMENTS AND RENEWALS TO A LICENSE 

It is the licensee’s obligation to keep the license current. If any of the information provided in 

the original application is to be modified or will change, the licensee must submit an application 

for a license amendment before the change takes place. The change is not in effect until the 

amendment has been issued. Also, to continue the license after its expiration date, the 

licensee must submit an application for a license renewal at least 30 days before the expiration 

date (10 CFR 2.109(a), 10 CFR 30.36(a)). 

Applicants for license amendment or renewal should do the following: 

• Use the most recent guidance in preparing an amendment or renewal request. 

• Submit, in duplicate, either an NRC Form 313 or a letter requesting amendment or 

renewal. 

• Provide the license number and docket number. 

• For renewals, provide a complete and up-to-date application if many outdated 

documents are referenced or there have been significant changes in regulatory 

requirements, NRC guidance, the licensee’s organization, or the licensee’s radiation 

protection program. Alternatively, describe clearly the exact nature of the changes, 

additions, and deletions. 

9.1 Timely Notification of Transfer of Control

Regulation: 10 CFR 30.34(b) 

Criteria: Licensees must provide full information and obtain the NRC’s prior written consent

before transferring control of the license. 

Discussion: Transferring control may be the result of mergers, buyouts, or majority stock 

transfers. Although it is not the NRC’s intent to interfere with the business decisions of 

licensees, it is necessary for licensees to obtain prior NRC written consent to ensure the 

following: 

• Radioactive materials are possessed, used, or controlled only by persons who have 

valid NRC or Agreement State licenses. 

• Materials are properly handled and secured. 

• Persons using these materials are competent and committed to implementing 

appropriate radiological controls. 

• A clear chain of custody is established to identify who is responsible for disposition of 

records and licensed material. 

• Public health and safety are not compromised by the use of such materials. 
66

Response from Applicant: No response is required from an applicant for a new license. 

However, current licensees should refer to Appendix O to this report or to NUREG-1556, 

Volume 15 for more information on transfer of ownership. 
67

10. APPLICATIONS FOR EXEMPTIONS 

Regulations: 10 CFR 19.31, 10 CFR 20.2301, 10 CFR 30.11 

Criteria: Licensees may request exemptions to regulations. The licensee must demonstrate 

that the exemption is authorized by law; will not endanger life, property, or the common defense 

and security; and is otherwise in the public interest. 

Discussion: Various sections of NRC’s regulations address requests for exemptions 

(e.g., 10 CFR 19.31, “Application for exemptions”; 10 CFR 20.2301, “Applications for 

exemptions”; 10 CFR 30.11(a)). These regulations state that the NRC may grant an 

exemption, acting on its own initiative or on an application from an interested person. 

Exemptions are not intended to revise regulations or to apply to large classes of licensees and 

are generally limited to unique situations. Exemption requests must be accompanied by 

descriptions of the following: 

• Exemption requested, basis, and justification for the requested exemption. 

• Proposed compensatory safety measures intended to provide a level of health and 

safety equivalent to the regulation for which the exemption is being requested. 

• Alternative methods for complying with the regulation and an explanation as to why 

compliance with the existing regulation is not feasible. 

Until the NRC has granted an exemption in writing, the NRC expects strict compliance with all 

applicable regulations. 

69 

11. TERMINATION OF ACTIVITIES 

Regulations: 10 CFR 30.34(b), 10 CFR 30.35(g), 10 CFR 30.36(d), 10 CFR 30.36(g), 

10 CFR 30.36(h), 10 CFR 30.36(j), 10 CFR 30.51(f) 

Criteria: The licensee must do the following: 

• Notify the NRC, in writing, within 60 days of any of the following: 

– Expiration of its license. 

– A decision to cease licensed activities permanently at the entire site. 

– A decision to cease licensed activities permanently in any separate building or 

outdoor area that contains residual radioactivity such that the building or area is 

unsuitable for release in accordance with NRC requirements. 

– No principal activities having been conducted at the entire site under the 

license for a period of 24 months. 

– No principal activities have been conducted for a period of 24 months in any 

separate building or outdoor area, if it contains residual radioactivity making it 

unsuitable for release in accordance with NRC requirements. 

Submit a decommissioning plan, if required by 10 CFR 30.36(g). 

Conduct decommissioning, as required by 10 CFR 30.36(h) and 10 CFR 30.36(j). 

Submit, to the appropriate NRC regional office, completed NRC Form 314, “Certificate of 

Disposition of Materials” (or equivalent information), and information demonstrating that the 

premises are suitable for release for unrestricted use (e.g., results of final survey). 

Before a license is terminated, send the records required by 10 CFR 30.51(f) to the appropriate 

NRC regional office. If licensed activities are transferred or assigned in accordance with 

10 CFR 30.34(b), transfer records important to decommissioning to the new licensee in 

accordance with 10 CFR 30.35(g). 

Discussion: To comply with the above criteria, before a licensee can decide whether it must 

notify the NRC, the licensee must determine whether residual radioactivity is present and, if so, 

whether the levels make the building or outdoor area unsuitable for release, according to NRC 

requirements. A licensee’s determination that a facility is not contaminated is subject to 

verification by NRC inspection. 

For guidance on the disposition of licensed material, see Section 8.11 “Waste Management.” 

For guidance on decommissioning records, see Section 8.5.2, “Financial Assurance and 

Recordkeeping for Decommissioning.” 

Response from Applicant: The applicant is not required to submit a response to the NRC 

during the initial application. The licensee’s obligations in this matter begin when the license 

expires or at the time the licensee ceases operations, whichever is earlier. These obligations 
70

are to undertake the necessary decommissioning activities, to submit NRC Form 314 or 

equivalent information, and to perform any other actions summarized in “Criteria” above. 

Reference: NRC Form 314 is available at http://www.nrc.gov/reading-rm/doc-collections/forms. 
APPENDIX A 

LIST OF DOCUMENTS CONSIDERED IN DEVELOPMENT OF THIS

NUREG 

A-1

Office of Federal and State Materials and Environmental Management Programs Letter 

FSME-10-019, “Reporting Requirements for Industrial Radiography,” March 12, 2010, 

(Agencywide Documents Access and Management System (ADAMS) Accession 

No. ML100610424). 

Orders 

EA-05-090 “Order Imposing Increased Controls,” November 14, 2005 (ADAMS Accession 

No. ML053130218). 

EA-07-305 “Order Imposing Fingerprinting and Criminal History Records Check 

Requirements for Unescorted Access to Certain Radioactive Material (Effective 

Immediately) and Opportunity to Request a Hearing,” December 5, 2007 

(ADAMS Accession No. ML073250084). 

Regulatory Issue Summaries (RISs) 

RIS 2005-10 “Performance-Based Approach for Associated Equipment in 10 CFR 34.20,” 

June 10, 2005 (ADAMS Accession No. ML051590049). 

RIS 2005-15 “Reporting Requirements for Damaged Industrial Radiographic Equipment,” 

August 3, 2005 (ADAMS Accession No. ML052100127). 

RIS-2005-31 “Control of Security-Related Sensitive Unclassified Non-Safeguards Information 

Handled by Individuals, Firms, and Entities Subject to NRC Regulation of the 

Use of Source, Byproduct, and Special Nuclear Material,” December 2005 

(ADAMS Accession No. ML053480073). 

RIS-2007-07 “Clarification of Increased Controls for Licensees That Possess Collocated 

Radioactive Material During Transportation Activities,” April 5, 2007 (ADAMS 

Accession No. ML070250497). 

RIS-2007-14 “Fingerprinting Requirements for Licensees Implementing the Increased Control 

Order,” June 5, 2007 (ADAMS Accession No. ML071500056). 

RIS-2007-23, “Date for Operation of National Source Tracking System,” October 4, 2007 

(ADAMS Accession No. ML072680241). 
A-2

RIS-2008-02, “Actions To Increase the Security of High Activity Radioactive Sources,” 

February 1, 2008 (ADAMS Accession No. ML080150638).

RIS 2008-24 “Security Responsibilities of Service Providers and Client Licensees,” 

October 3, 2008 (ADAMS Accession No. ML082200597). 

RIS 2009-15 “National Source Tracking System Annual Inventory Reconciliation,” 

December 3, 2009 (ADAMS Accession No. ML093170822).

Information Notices (INs) 

IN 83-81 “Entry into High Radiation Areas from Areas Which Are Not Under Direct 

Surveillance,” December 7, 1983 (ADAMS Accession No. ML0829703291). 

IN 84-25 “Recent Serious Violations of NRC Requirements by Radiography Licensees,” 

April 16, 1984 (ADAMS Accession No. ML0829703570). 

IN 85-57 “Lost Iridium-192 Source Resulting in the Death of Eight Persons in Morocco,” 

July 16, 1985 (ADAMS Accession No. ML0311801880). 

IN 87-45 “Recent Safety-Related Violations of NRC Requirements by Industrial 

Radiography Licensees,” September 25, 1987 (ADAMS Accession 

No. ML031130602). 

IN 87-47 “Transportation of Radiography Devices,” October 5, 1987 (ADAMS Accession 

No. ML082910458). 

IN 88-66 “Industrial Radiography Inspection and Enforcement,” August 22, 1988 (ADAMS 

Accession No. ML031150170). 

IN 89-25 “Unauthorized Transfer of Ownership or Control of Licensed Activities,” Rev. 1, 

December 7, 1994 (ADAMS Accession No. ML082320739). 

IN 90-15 “Reciprocity: Notification of Agreement State Radiation Control Directors 

Before Beginning Work in Agreement States,” March 7, 1990 (ADAMS 

Accession No. ML031130264). 

IN 91-23 “Accidental Radiation Overexposures to Personnel Due to Industrial 

Radiography Accessory Equipment Malfunctions,” March 26, 1991 (ADAMS 

Accession No. ML031190662). 

IN 91-60 “False Alarms of Alarm Ratemeters Because of Radiofrequency Interference,” 

September 24, 1991 (ADAMS Accession No. ML031190235). 

IN 93-05 “Locking of Radiography Exposure Devices,” January 14, 1993 (ADAMS 

Accession No. ML031080041). 

IN 93-69 “Radiography Events at Operating Power Reactors,” September 2, 1993 

(ADAMS Accession No. ML031070112). 
A-3

IN 95-44 “Ensuring Compatible Use of Drive Cables Incorporating Industrial Nuclear 

Company Ball-Type Male Connectors,” September 26, 1995 (ADAMS 

Accession No. ML031060191). 

IN 96-20 “Demonstration of Associated Equipment Compliance with 10 CFR 34.20,” 

April 4, 1996 (ADAMS Accession No. ML031060147). 

IN-96-28 “Suggested Guidance Relating to Development and Implementation of 

Corrective Action,” May 1, 1996 (ADAMS Accession No. ML092450179). 

IN 96-53 “Retrofit to Amersham 660 Posilock Radiography Camera to Correct 

Inconsistency in 10 CFR Part 34 Compatibility,” October 15, 1996 (ADAMS 

Accession No. ML031060041). 

IN 97-35 “Retrofit to Industrial Nuclear Company (INC) IR100 Radiography Camera to 

Correct Inconsistency in 10 CFR Part 34 Compatibility,” June 18, 1997 (ADAMS 

Accession No. ML031050568). 

IN 97-86 “Additional Controls for Transport of the Amersham Model No. 660 Series 

Radiographic Exposure Devices,” December 12, 1997 (ADAMS Accession 

No. ML031050028). 

IN 97-87 “Second Retrofit to Industrial Nuclear Company IR100 Radiography Camera to 

Correct Inconsistency in 10 CFR Part 34 Compatibility,” December 12, 1997 

(ADAMS Accession No. ML031050023). 

IN 97-91 “Recent Failures of Control Cables Used on Amersham Model 660 Posilock 

Radiography Systems,” December 31, 1997 (ADAMS Accession 

No. ML031050007). 

IN 98-16 “Inadequate Operational Checks of Alarm Ratemeters,” April 30, 1998 (ADAMS 

Accession No. ML031050179). 

IN 01-03 “Incident Report Requirements for Radiography Licenses,” April 6, 2001 

(ADAMS Accession No. ML010800026). 

IN 04-13 “Registration, Use, and Quality Assurance Requirements for NRC-Certified 

Transportation Packages,” June 30, 2004 (ADAMS Accession 

No. ML041810535). 

APPENDIX B 

U.S. NUCLEAR REGULATORY COMMISSION FORM 313

B-1 

United States Nuclear Regulatory Commission Form 313

APPENDIX C 

SUGGESTED FORMAT FOR PROVIDING INFORMATION REQUESTED 

IN ITEMS 5 THROUGH 11 OF 

U.S. NUCLEAR REGULATORY COMMISSION FORM 313

C-1 

Suggested Format for Providing Information Requested in Items 5 through 11 of NRC 

Form 313 

Item 

No.

Title and Criteria Yes Description 

Attached

5 RADIOACTIVE MATERIAL

Sealed Sources and Devices

• Identify each radionuclide that will be used for performing 

radiography. 

• Identify the manufacturer (or distributor) and model number of 

each sealed source. 

• Identify the manufacturer (or distributor) and model number of 

each exposure device. Indicate if a device is only to be used in a 

permanent radiographic installation. 

• Identify the manufacturer (or distributor) and model number of 

each source changer. 

• If depleted uranium is used as shielding material, specify the 

total amount (in kilograms). 

• Confirm that each sealed source, device, and source/device 

combination possessed is registered as an approved sealed 

source or device by the U.S. Nuclear Regulatory Commission 

(NRC) or an Agreement State and will be possessed and used in 

accordance with the conditions specified in the registration 

certificate. 

• Confirm that associated equipment is compatible with the 

exposure devices, source changers, and sealed sources 

containing byproduct material. 

• Confirm that only radiographic exposure devices, source 

assemblies or sealed sources, and associated equipment which 

meet the requirements specified in Title 10 of the Code of 

Federal Regulations (10 CFR) 34.20, “Performance 

requirements for industrial radiography equipment,” will be used 

in radiographic operations. 

• Identify each radionuclide and the manufacturer (or distributor) 

and model number of each sealed source and/or device 

containing byproduct material that will not be used for performing 

radiography. 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 
C-2 

Item 

No.

Title and Criteria Yes Description 

Attached

5 RADIOACTIVE MATERIAL

Financial Assurance and Recordkeeping for Decommissioning

• 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. 

OR

• If financial assurance is required, submit evidence following 

NUREG-1757, Volume 3. 

[ ] 

[ ] 

6 PURPOSE(S) FOR WHICH LICENSED MATERIAL

WILL BE USED

Equipment will only be used for the following: 

• industrial radiography 

• underwater radiography 

• lay-barge radiography (see Appendix D) 

• off-shore platform radiography (see Appendix D) 

• other than radiography 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 
C-3 

Item 

No.

Title and Criteria Yes Description 

Attached

7 INDIVIDUALS RESPONSIBLE FOR RADIATION SAFETY 

PROGRAM AND THEIR TRAINING EXPERIENCE

Radiation Safety Officer (RSO)

• The name of the proposed RSO and other potential designees 

who will be responsible for ensuring that the licensee’s radiation 

safety program is implemented in accordance with approved 

procedures. 

AND

• Demonstrate that the RSO has sufficient independence and 

direct communication with responsible management officials by 

providing a copy of an organizational chart, by position, 

demonstrating day-to-day oversight and coordination with 

management in radiation safety activities. 

AND EITHER

• The specific training and experience of the RSO and other 

potential designees. Include the specific dates of certification 

and/or training in radiation safety. 

• Documentation to show that the RSO has a minimum of 

2,000 hours of hands-on experience as a qualified radiographer 

in industrial radiographic operations. 

• Documentation to show that the RSO has obtained formal 

training in the establishment and maintenance of a radiation 

protection program. 

OR

• Alternative information demonstrating that the proposed RSO is 

qualified by training and experience. 

• Documentation to show that the RSO has obtained formal 

training in the establishment and maintenance of a radiation 

protection program. 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 
C-4 

Item 

No.

Title and Criteria Yes Description 

Attached

8 TRAINING FOR RADIOGRAPHERS AND RADIOGRAPHER’S 

ASSISTANTS

• 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. 

• While you do not need to provide a description of the 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. 

• 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. 

• Submit a description of your program for inspecting the job 

performance of each radiographer and radiographer’s assistant 

at intervals not to exceed 6 months, as described in 

10 CFR 34.43(e). 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 
C-5 

Item 

No.

Title and Criteria Yes Description 

Attached

9 FACILITIES AND EQUIPMENT

Permanent Radiography Installations

Provide the following information for each permanent radiography 

installation: 

• Provide an annotated sketch or drawing of the facility and its 

surroundings. Diagrams of facilities should be marked: 

“Security-related information—Withhold under 10 CFR 2.390.” 

• Identify the scale to which the sketch or drawing is made. 

• Identify the type, thickness, and density of shielding materials on 

all sides, including the floor and the roof. 

• Identify the locations of entranceways and other points of access 

to the facility. 

• Describe the areas adjacent to the facility and the distance to 

these areas. Include information on areas adjacent to, above, 

and below the facility. 

• Describe the general location of each proposed permanent 

facility listed in Item 3 (e.g., located in an industrial park, an 

office complex) and its current use. 

• If a proposed permanent facility is a private residence, provide 

diagrams of the facility that include the building, the proposed 

restricted area(s), and adjacent areas, including above and 

below the restricted areas. (Note: Local municipalities may limit 

the use of radioactive material to certain zone areas.) 

• Restricted areas do not include residential quarters. 

• Explain how radiation levels in unrestricted areas will be 

maintained at less than 1 millisievert (mSv) (100 millirem 

(mrem)) per year. 

• Describe the visible-audible signal system or entrance control 

system and its locations. 

• Provide the results of radiation-level calculations or actual 

radiation measurements adjacent to, above, and below the 

facility. 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 
C-6 

Item 

No.

Title and Criteria Yes Description 

Attached

9 FACILITIES AND EQUIPMENT

Permanent Radiography Installations

Provide the following information to obtain approval for a variance if 

construction requirements preclude shielding the roof to meet the 

requirement not to exceed 0.02 mSv (2 mrem) in any 1 hour: 

• means of access to the roof 

• procedures for ensuring that no individual is on the roof or could 

gain access to the roof during radiography 

• a commitment that the roof will be posted with “Caution (or 

Danger) Radiation Area” sign(s) 

• steps taken to minimize radiation on the roof 

• limitations (if needed) on positioning of sources or type (isotope) 

and amount of radioactive material that may be used in the 

installation to ensure that areas adjacent to, above, and below 

the installation will be unrestricted areas during the performance 

of radiography 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

 Provide the following information to obtain approval for a variance if 

radiation levels on the radiography installation roof exceed 1.0 mSv 

(100 mrem) in any 1 hour: 

• a commitment that the roof will be posted with a “Caution (or 

Danger) High-Radiation Area” sign(s) 

• evidence of constant surveillance of the roof by closed-circuit 

television 

• a description of a control device that would automatically reduce 

the radiation level to 1 mSv (100 mrem) in any 1 hour at 

30 centimeters from the radiation source if someone enters the 

roof 

• a description of a control device that activates a visible-audible 

signal so that both an individual entering the roof and the 

radiographer on duty are made aware of the entry 

[ ] 

[ ] 

 

[ ] 

[ ] 
C-7 

Item 

No.

Title and Criteria Yes Description 

Attached

9 FACILITIES AND EQUIPMENT

Field Stations

Provide the following information for each field station: 

• Describe the storage location(s) at the address(es) listed in 

Item 3 of the application, and submit a diagram showing where 

the radiography camera will be stored at the field stations. 

• Indicate whether radiography and source exchanges will be 

performed at the place of business outside of a permanent 

facility as if the work were “in the field.” 

• For radiography or source exchanges performed at the place of 

business as if the work were “in the field,” provide a diagram of 

the location where radiography may be performed and its 

surroundings, including a description of adjacent property. 

[ ] 

[ ] 

[ ] 

10 RADIATION SAFETY PROGRAM

Audit Program

The applicant is not required to, and should not, submit its audit 

program to the NRC for review during the licensing phase. (See 

Appendix G for a sample radiation safety program audit). Audits will 

be reviewed during inspections to determine compliance with NRC 

regulations. 

Need Not Be 

Submitted With 

Application 

Instruments 

We will possess and use calibrated and operable radiation survey 

meters. 

Calibration will be performed by an NRC or Agreement State 

licensee specifically authorized to perform instrument calibration. 

Calibration is to be performed in-house, and the model procedures 

in Appendix H will be followed. 

Calibration is to be performed in-house, and alternate procedures 

will be followed. 

The qualifications of the individuals who will perform the calibrations 

must be identified. 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 
C-8 

Item 

No.

Title and Criteria Yes Description 

Attached

10 RADIATION SAFETY PROGRAM

Material Receipt and Accountability

Physical inventories will be conducted and documented at quarterly 

intervals (not to exceed 3 months) to account for all sealed sources 

containing byproduct material and devices containing depleted 

uranium received and possessed under the license. 

[ ] 

Minimization of Contamination

The applicant is not required to provide a response to the 

minimization of contamination, if the applicant’s responses meet the 

criteria for the following sections: “Radioactive Material—Sealed 

Sources and Devices”; “Facilities and Equipment”; “Radiation Safety 

Program—Leak Tests”; “Radiation Safety Program—Operating and 

Emergency Procedures”; and “Waste Management—Sealed

Source/DU Device Transfer and Disposal.” 

Need Not Be 

Submitted With 

Application 

Leak Tests

Leak tests will be performed by an organization authorized by the 

NRC or an Agreement State to provide leak-testing services to other 

licensees, or by using a leak-test kit supplied by an organization 

licensed by the NRC or an Agreement State to provide leak-test kits 

and services to other licensees, and according to the instructions 

provided in the leak-test kit. 

OR

Leak testing will be done by the applicant. 

• The information in Appendix I supporting a request to perform 

leak testing and sample analysis is attached. 

• We will follow the model procedures in Appendix I.

• We will follow alternate procedures. 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 
C-9 

Item 

No.

Title and Criteria Yes Description 

Attached

10 RADIATION SAFETY PROGRAM

Occupational Dosimetry

Radiography personnel will wear film, thermoluminescent dosimeter, 

or other personal dosimetry processed and evaluated by a 

processor accredited by the National Voluntary Laboratory 

Accreditation Program and exchanged at the required frequency. 

Radiographic personnel will wear the required personnel monitoring 

equipment, including 0-to-2-mSv (200-mrem) dosimeters or 

electronic personal dosimeters. 

All radiography personnel will wear alarming ratemeters set to alarm 

at ±20 percent of 500 millirem per hour (mrem/h), except those 

personnel at permanent radiography installations where other 

appropriate alarming or warning devices are in use.

Pocket dosimeters and alarm ratemeters will be checked for correct 

response at intervals not to exceed 12 months. 

• If adjustment is necessary, the devices will be returned to the 

manufacturer. 

• If adjustment is necessary, in-house procedures for adjustments 

are described. 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

Public Dose

The applicant is not required to, and should not, submit a response 

to the public dose section during the licensing phase. Public dose 

will be reviewed during inspections to determine compliance with 

NRC regulations. 

Need Not Be 

Submitted With 

Application 

10 RADIATION SAFETY PROGRAM

Quarterly Maintenance

Submit the procedures to the NRC for review and approval as 

operating and emergency procedures or as shipping package 

procedures as needed. 

Before using a new sealed source/device combination, we will have 

written inspection and maintenance procedures that address the use 

of the new equipment as a Type B transport package. In addition, 

we will provide training to radiographic personnel before using a new 

sealed source/device combination. 

[ ] 

[ ] 
C-10 

Item 

No.

Title and Criteria Yes Description 

Attached

Operating and Emergency Procedures

Handling and Use of Sealed Sources and Radiography 

Exposure Devices

Submit operating and emergency procedures which provide step-bystep instructions for using each type of radiographic device. 

Submit operating and emergency procedures which provide 

instructions for performing source exchanges. 

 

[ ] 

[ ] 

Methods and Occasions for Conducting Radiation Surveys

Submit operating and emergency procedures which, where 

applicable, include each of the surveys included in Table 8-1. 

 

[ ] 

Methods for Controlling Access to Radiographic Areas

Submit the procedures to control access to radiographic operations 

and storage areas. 

 

[ ] 

10 RADIATION SAFETY PROGRAM

Methods and Occasions for Locking and Securing 

Radiographic Exposure Devices, Storage Containers, and 

Sealed Sources

Submit operating and emergency procedures that include 

procedures for locking and securing radiographic equipment. 

 

[ ] 

Personnel Monitoring and the Use of Personnel Monitoring 

Equipment

Submit operating procedures that include instructions for proper use 

of personnel monitoring equipment. 

 

[ ] 

Transporting Sealed Sources to Field Locations, Securing 

Exposure Devices and Storage Containers in Vehicles, Posting 

Vehicles, and Controlling Sealed Sources during 

Transportation

Submit operating and emergency procedures for transporting sealed 

sources containing byproduct material, exposure devices, and 

source changers. 

 

[ ] 
C-11 

Item 

No.

Title and Criteria Yes Description 

Attached

Daily Inspection and Maintenance of Radiographic Equipment

Submit operating and emergency procedures for daily inspection 

and maintenance of radiographic equipment. 

 

[ ] 

Ratemeter Alarms or Off-Scale Dosimeter Readings

Submit operating and emergency procedures to address ratemeter 

alarms or off-scale dosimeters. 

 

[ ] 

Procedure for Identifying and Reporting Defects and

Noncompliance as Required by 10 CFR Part 21

Submit operating and emergency procedures for notifying 

management of equipment malfunction or defect. 

 [ ] 

10 RADIATION SAFETY PROGRAM

Notification of Proper Persons in the Event of an Accident

Submit operating and emergency procedures that include 

appropriate instructions for notifying the RSO and other personnel in 

the event of an emergency. 

 

[ ] 

Minimizing Exposure of Persons in the Event of an Accident—

Emergency Procedures

Submit operating and emergency procedures that include 

instructions for minimizing exposure of persons in the event of an 

accident. 

 

[ ] 

Source Retrieval

We will not perform source retrievals and will use the services of a 

person specifically licensed by the NRC or an Agreement State to 

perform the retrievals of our sources. 

Submit operating and emergency procedures that include 

instructions for source retrieval procedures and specific training. 

[ ] 

[ ] 

Security Program

Licensees must ensure the security and control of licensed material. 

The regulations in 10 CFR 20.1801 and 20.1802 require licensees to 

secure radioactive materials from unauthorized removal or access 

while in storage and to control and maintain constant surveillance 

over licensed material that is not in storage. 

 Need Not 

Be 

Submitted 

With 

Application 
C-12 

Item 

No.

Title and Criteria Yes Description 

Attached

11 WASTE MANAGEMENT

Disposal or Transfer of Radiography Sealed Sources 

Containing Byproduct Material or Devices Containing Depleted 

Uranium

The applicant does not need to provide a response to this item 

during the licensing process. However, the applicant should 

establish and include waste disposal procedures in its radiation 

safety program. 

Need Not Be 

Submitted With 

Application 
APPENDIX D 

LICENSING GUIDANCE FOR LAY-BARGE AND OFFSHORE 

RADIOGRAPHY

D-1 

Basic Description of an Offshore Platform

An offshore platform, often referred to as an oil platform or oil rig, is a large structure used to 

house workers and machinery needed to drill wells in the ocean bed, extract oil or natural gas, 

process the produced fluids, and ship them to shore. Depending on the circumstances, the 

platform may be attached to the ocean floor, consist of an artificial island, or be floating. 

Offshore Platform Radiography Safety Issues

 The use of crankout devices for offshore platform radiography has some inherent risk. 

If a source disconnect were to occur, source recovery resources and expertise may not 

be available. Licensee staff may not have received the appropriate training to perform 

source retrieval operations and may not be authorized to perform such operations under 

their current license. (Shielding may not be available and also it is difficult to keep 

people away from source). 
D-2 

 There may be specific physical or space configurations that the licensee needs to 

consider to ensure compliance with the limit of 2 millirem in any 1 hour in unrestricted 

areas required by 10 CFR 20.1301. 

 Members of the public on an offshore platform (e.g., welders, divers) could receive 

doses well above regulatory limits in the event of a source disconnect event. 

 Offshore platform operators (who are production oriented) cannot override radiography 

companies on radiation safety issues. Written arrangements should be in place to allow 

radiography company representatives to stop work if there is a radiation safety issue. 

As required by Title 10 of the Code of Federal Regulations (10 CFR) 34.41(c), a licensee may 

only conduct lay-barge, offshore platform, or underwater radiography if procedures have been 

approved by the NRC or by an Agreement State. Based on the above potential hazardous 

conditions, licensees must provide operating and emergency procedures for lay-barge, offshore 

platform, or underwater radiography that address the following safety aspects: 

(1) Procedures, as required to comply with 10 CFR 34.45(a), unique to offshore platform 

radiography, should minimize the potential for a source disconnect. 

(2) Emergency procedures, as required by 10 CFR 34.45(a), unique to offshore platform 

radiography, should address unintentional source disconnects and recovery. These 

procedures should address minimizing radiation exposure for all personnel on the 

offshore platform during a disconnect event, including considerations such as staff 

training, availability of portable shielding, survey instruments, dosimetry, and other 

equipment. 

(3) Operating procedures and practices unique to offshore platform radiography should 

ensure compliance with the requirements of 10 CFR 34.41, “Conducting Industrial 

Radiographic Operations,” for personnel to be present during radiography and 

10 CFR 34.46, “Supervision of radiographers’ assistants,” for supervision of radiography 

assistants. 

(4) Operating procedures and practices, as required to comply with 10 CFR 34.45(a), 

should ensure that radiography personnel have the authority necessary to protect 

personnel on an offshore platform from radiation doses in excess of regulatory limits. 

These procedures and practices should include provisions to ensure that radiographic 

operations are conducted only in those locations shielded for such operations (if those 

enclosures are relied upon to control dose) and that radiographic personnel can direct 

personnel as necessary for radiation safety both during normal operations and in the 

event of a disconnect or other emergency.
D-3 

Basic Description of Lay-Barges

An aspect of the petroleum industry is the ability to transport the petroleum from the ocean floor 

to the coastal refineries for processing. This transport is facilitated by use of underwater 

pipelines that are laid on the ocean floor by pipe lay-barges. These lay-barges allow sections of 

piping to be welded together on deck, radiographed to ensure weld quality, coated to prevent 

corrosion, and subsequently lowered to the ocean floor. These activities are performed 

sequentially as an assembly-line process onboard the barges. These pipe lay-barges are 

configured in either a side-lay or center-lay arrangement, which dictates how the pipe is 

assembled on the lay-barge. Work onboard these lay-barges can be hazardous because of the 

close proximity of the pipe to the workers, as well as the relative motion that is created between 

components and personnel as a result of ocean waves and currents. 

Lay-Barge Radiography Safety Issues

 The use of crankout devices for lay-barge radiography has some inherent risk. 

Disconnects are more likely than with the previously used pipeliner devices because of 

motion between source (attached to pipe) and crankout device (attached to barge). 

 If a source disconnect occurs and the source recovery resources and expertise are not 

on the barge, licensee staff may not have received the appropriate training to perform 

source retrieval operations and may not be authorized to perform such operations under 

their current license. (Shielding is not available and it is difficult to keep people away 

from the source.) 

 There may be specific physical or space configurations that the licensee needs to 

consider to ensure compliance with the limit of 2 mrem in any 1 hour in an unrestricted 

area required by 10 CFR 20.1301. For lay-barges, radiography should be restricted to 

the shielded enclosures on the barges where it is intended to be done. 
D-4 

 Members of the public on the offshore platform (e.g., welders, divers) could receive 

doses well above regulatory limits in the event of a source disconnect event. 

 Lay-barge operators (who are production oriented) cannot override radiography 

companies on radiation safety issues. Written arrangement should be in place to allow 

radiography company representatives to stop work if there is a radiation safety issue. 

As required by 10 CFR 34.41(c), a licensee may only conduct lay-barge, offshore platform, or 

underwater radiography if procedures have been approved by the NRC or by an Agreement 

State. Based on the above potential hazardous conditions, licensees must provide operating 

and emergency procedures for lay-barge, offshore platform, or underwater radiography that 

address the following safety aspects. 

(1) Procedures, as required by 10 CFR 34.45(a) and unique to lay-barge radiography, are 

designed to minimize the potential for a source disconnect. 

(2) Emergency procedures, as required by 10 CFR 34.45(a) and unique to lay-barge 

radiography, address unintentional source disconnects and recovery. These procedures 

should address minimizing radiation exposure for all personnel onboard the lay-barge 

during a disconnect event, considering issues such as staff training, availability of 

portable shielding, survey instruments, dosimetry, and other equipment. 

(3) Operating procedures and practices unique to lay-barge radiography should ensure 

compliance with the requirements of 10 CFR 34.41 for personnel to be present during 

radiography and the requirements of 10 CFR 34.46 for supervision of radiography 

assistants. 

(4) Operating procedures and practices, as required by 10 CFR 34.45(a), should ensure 

that radiography personnel have the authority necessary to protect personnel onboard 

the lay-barges from radiation doses in excess of regulatory limits. These procedures 

and practices should include provisions to ensure that radiographic operations are 

conducted only in those locations shielded for such operations (if those enclosures are 

relied upon to control dose) and that radiographic personnel can direct personnel as 

necessary for radiation safety both during normal operations and in the event of a 

disconnect or other emergency. 
APPENDIX E 

RADIOGRAPHER AND ASSISTANT RADIOGRAPHER TRAINING

E-1 

Radiographer and Assistant Radiographer Training

Table E.1 10 CFR Part 34, “Radiographer and Assistant Radiographer 

Training Requirements” 

Requirement Training Criteria

34.43(a)(1) Radiographer

A. Receive Training in 

10 CFR 34.43(g) Topics 

(Classroom Training—

Approximately 40 hours in 

Length) 

Topics in 10 CFR 34.43(g) 

Fundamentals of Radiation Safety 

· characteristics of gamma radiation 

· units of radiation dose and quantity of radioactivity 

· hazards of exposure to radiation 

· levels of radiation from licensed material 

· methods of controlling radiation dose (time, distance, 

and shielding) 

Radiation Detection Instruments 

· use, operation, calibration, and limitations 

· survey techniques 

· personnel monitoring equipment 

Equipment to be Used 

· operation and control of radiographic exposure 

equipment, remote handling equipment, storage 

containers, and pictures or models of source 

assemblies (pigtails) 

· storage, control, and disposal of licensed material 

· inspection and maintenance of equipment 

Requirements of Pertinent Federal Regulations 

Case Histories of Accidents in Radiography 

B. On-the-Job Training—

2 months or 320 hours 

Under the supervision of a qualified radiographer 

C. Certification by a 

Certifying Entity 

Radiographer Certification 

Radiographers must be certified by a certifying entity and 

the licensee must ensure that training on the subjects listed 

in 10 CFR 34.43(g) has been conducted. 

 

34.43(b) Radiographer
E-2 

Requirement Training Criteria

D. Must Receive Copies of and 

Instruction in: 

(Training—Approximately 

8 hours in Length) 

NRC Regulations 

10 CFR Part 34 

· 10 CFR 30.7, 10 CFR 30.9, and 10 CFR 30.10 

· Applicable parts of 10 CFR Part 19 and 10 CFR Part 20 

· Applicable DOT regulations and 10 CFR Part 71 

The NRC License 

The Licensee’s Operating and Emergency Procedures 

E. Pass Written or Oral 

Examination on Licensee’s 

Operating and Emergency 

Procedures 

· 50 questions 

· Passing Grade 80% 

F. Receive Equipment Training

(Approximately 4 hours 

in Length) 

Training includes: 

· exposure devices 

· sealed sources 

· associated equipment 

· survey meters 

· daily inspection 

G. Demonstrate Understanding 

in Use of Equipment by 

Passing Practical Exam 

Questions on topics determined by the licensee. 

Use the Six-Month Radiographer/Radiographer's Assistant 

Inspection Checklist (Appendix F) as a potential source of 

questions. 

H. Annual Refresher Training Review the following: 

· radiation safety review 

· new procedures or equipment 

· new regulations 

· observations and deficiencies during audits and 

discussion of any significant incidents or accidents 

involving radiography 

· employee questions 

I. Records To be maintained in accordance with 10 CFR 34.79 

34.43(c) Assistant Radiographer
E-3 

Requirement Training Criteria

A. Must Receive Copies of and 

Instruction in: 

(Training—Approximately 

8 hours in Length) 

NRC Regulations: 

· 10 CFR Part 34 

· 10 CFR 30.7, 10 CFR 30.9, and 10 CFR 30.10 

· applicable parts of 10 CFR Part 19 and 10 CFR Part 20 

· applicable DOT regulations and 10 CFR Part 71 

The NRC License 

The Licensee’s Operating and Emergency Procedures 

B. Pass Written Exam · 25–50 questions 

· closed book 

· passing grade 80% 

C. Receive Equipment Training

(Approximately 4 hours in 

Length) 

Training under the supervision of a qualified radiographer 

that includes: 

· exposure devices 

· sealed sources 

· associated equipment 

· survey meters 

· daily inspection 

D. Demonstrate Understanding 

in Use of Equipment by 

Passing Practical Exam 

25–50 questions on topics determined by the licensee. The 

NRC suggests using the Six-Month 

Radiographer/Radiographer's Assistant Inspection 

Checklist (Appendix F) for a potential source of questions. 

E. Annual Refresher Training Review the following: 

· any significant item identified in the annual review of the 

radiation safety program 

· new procedures or equipment 

· new regulations 

· observations and deficiencies during audits and 

discussion of any significant incidents or accidents 

involving radiography 

· employee questions 

F. Records To be maintained in accordance with 10 CFR 34.79. 

APPENDIX F 

SIX-MONTH RADIOGRAPHER/RADIOGRAPHER’S ASSISTANT 

INSPECTION CHECKLIST 

F-1 

Six-Month Radiographer/Radiographer’s Assistant Inspection Checklist 

Date: Time: 

Radiographic Location: 

Radiographer/Radiographer Assistant: 

Last Six-Month Performance Observation: Date: By: 

Device Model No.: _______________________Serial No.: 

Survey Meter Functionality: Yes ________ No ________ 

Calibrated: Yes ____ No _____ Daily/Source Check for Operation: Yes _______ 

No________ 

Dosimetry: TLD/Film Badge and Pocket Dosimeter: Yes ________ No _________ 

Calibrated: Yes ________ No ________ 

Alarming Dosimeter: Yes ________ No ________ Calibrated: Yes ________ No ________ 

□ Were other individuals working within the restricted area wearing film badges/TLDs, 

dosimeters, and alarm dosimeters? 

□ Was the restricted area posted with a “CAUTION (or DANGER) RADIATION AREA” 

sign(s)? 

□ Was the restricted area properly controlled to prevent unauthorized entry? 

□ Was the high-radiation area posted with a “CAUTION (OR DANGER) HIGH-RADIATION 

AREA” sign(s)? 

□ Was the utilization log properly filled out? 

□ Did the radiographer/radiographer assistant have sufficient knowledge of safety rules? 

(Ascertained by oral questions) 

□ Was the radiographer working with properly inspected and operable equipment? 

□ Did the radiographer/radiographer assistant properly survey the source projector? 

□ Did the radiographer properly supervise the radiographer assistant? 

□ Was the source projector properly locked and secured to prevent unauthorized removal? 

□ Was the restricted area properly controlled for radiological exposure? 

□ Were calculations or surveys performed to determine the restricted area boundary? 
F-2 

□ Was the high-radiation area under continuous direct observation except where entry had 

been prevented? 

□ Were radioactive isotopes stored properly and kept locked to prevent removal? 

□ Was the storage area posted with a “CAUTION (or DANGER) RADIOACTIVE 

MATERIAL” sign(s)? 

□ Did the radiographer/radiographer assistant possess and use a copy of the operating and 

emergency procedures and (State or NRC) rules and regulations for protection against 

radiation? 

□ Were there any other safety items found to be lacking? If yes, explain in Remarks. 

Remarks: 
APPENDIX G 

RADIATION SAFETY PROGRAM AUDIT

G-1 

Radiation Safety Program Audit 

Annual Radiation Protection Industrial Radiography Audit 

Date of this Audit Date of Last Audit 

Next Audit Date 

Auditor Date 

 (Signature) 

Management Review Date 

 (Signature) 

Note: Except where noted, references are to Title 10 of the Code of Federal Regulations

(10 CFR). 

Organization and Scope of Program 

A. Organizational structure (specify any changes) 

1. Matches license requirements [L/C3

] 

2. Multiple authorized locations of use and/or field sites authorized 

3. List of location(s) inspected—attached or reference 

4. Brief description of scope of activities, including types of equipment, types and 

quantities of use involving byproduct material, frequency of use, staff size, etc. 

B. Radiation Safety Officer (RSO) 

1. Named on license [L/C] 

2. Fulfills duties as RSO [34.42(c)] 

3. Meets requirements [34.42] 

C. Radiographers and radiographer’s assistants named in documents [34.43, 34.79; L/C]. 

D. Commensurate security program implemented. 

Training, Retraining, and Instructions to Workers 

A. Instructions to workers [19.12] 

B. Parts 19, 20, 21, 34; the license; and operating and emergency procedures are furnished to 

all radiographers and radiographer’s assistants [34.43(b)(1), (c)(1)] 

C. Training program description the same as that submitted with license application or as 

amended? [34.13(b); L/C] 

1. Written tests completed by all radiographers and radiographer’s assistants. 

2. Oral tests 

3. All radiographers completed on-the-job training 

 

3

 L/C refers to license condition. 
G-2 

4. Periodic training program implemented 

5. Records maintained [34.79] 

D. Part 20. Workers cognizant of requirements for:

1. Radiation safety program [20.1101] 

a. Occupational exposure annual limits [20.1201; 20.1202] 

b. Public annual dose limits [20.1301; 20.1302] 

2. U.S. Nuclear Regulatory Commission (NRC) Forms 4 and 5 

3. 10% monitoring threshold [20.1502] 

4. Dose limits to embryo/fetus and declared pregnant worker [20.1208] 

5. Procedures for opening packages [20.1906] 

Operating and Emergency Procedures 

A. Procedures current? [34.45; 34.81; 34.89] 

B. Procedures contain information specified 

C. Procedures submitted to the NRC [34.13(d)] 

Internal Audits or Inspections 

A. Audits/inspections of each radiographer and radiographer’s assistants conducted at 

6-month intervals or after as appropriate [34.111(e); 34.42(e); L/C] 

B. Equipment check before use each day [34.31(a)] 

C. Equipment inspection and maintenance performed at 3-month intervals [34.31(b)] 

D. Records maintained [34.73] 

Facilities 

A. Permanent radiographic installation [34.3; 34.33] 

1. High-radiation area posted [20.1601(a); 20.2902(b)] 

2. Entrance controls are as described [20.1601(a); L/C] 

a. Visible and audible radiation signals 

b. Visible signal actuates if entry is attempted when source is exposed 

c. Audible signal actuates if entry is attempted when source is exposed 

d. System tested daily with radiation source 

e. Records maintained for 3 years [34.75] 

B. Temporary high-radiation area entry controlled [20.1601(b); 34.31] 

C. Storage area 

1. Storage facilities as described in license [L/C]

2. Sources locked in devices [34.23] 
G-3 

3. Devices secured to prevent tampering or unauthorized removal [34.23; 20.1801; 

20.2803] 

4. Storage locations comply with the appropriate security program measures 

D. Field radiography conducted at location identified on license [L/C] 

Equipment 

A. Radiography devices, source assemblies, and source changers in use meet requirements 

[34.20] 

B. Associated equipment in use complies with requirements [34.20] 

C. Awareness that associated equipment must comply with 34.20 

D. Source changers and storage containers meet radiation level limits [34.21] 

E. Equipment exempted by specific license condition is used in accordance with license 

commitments and authorization 

Materials 

A. Isotope, chemical/physical form, quantity, and use as authorized [L/C] 

B. All sealed sources not fastened to or contained in an exposure device are tagged 

[34.20(b)(4)(I)] 

C. During radiographic operations, sources are secured in shielded position each time source 

is returned to that position [34.49(b)] 

D. Leakage and contamination tests 

1. Sealed sources 

a. Leak-test method approved [34.27(c)] 

b. Leak tests performed at 6-month intervals [34.27] 

c. Leakage is less than 185 becquerels (Bq) (0.005 microcuries (μCi) 

2. Depleted uranium (DU) shielding with S-tubes 

a. Test every 12 months [34.27] 

b. DU is less than 185 Bq (0.005 μCi) 

3. Records maintained for 3 years [34.67] 

E. Inventories 

1. Conducted quarterly (not to exceed 3 months) [34.29] 

2. Contain all required information [34.69] 

3. Most recent inventory conducted on: < date > 

F. Utilization Logs 

1. Utilization logs maintained [34.71] 

2. Contain all required information [34.71] 
G-4 

Instrumentation 

A. Describe the survey instruments possessed: 

 Model No. Quantity 

B. Capable of measuring 0.02 millisievert (mSv) (2 millirem (mrem)) per hour (h) through 0.01 

Sv (1 rem)/h [34.25] 

C. Operable and calibrated survey instruments available and used on each job [34.25(a)] 

D Calibration performed at intervals not to exceed 6 months or after servicing [34.25(a)] 

E. Records maintained for 3 years [34.65] 

Radiation Surveys 

A. Area or facility surveys conducted to show compliance with 20.1301 and 20.1302(a) 

[20.1501(a)] 

B. Records maintained [20.2103] 

C. Survey after each exposure, including the exposure device and the guide tube, ensuring 

that the source has returned to the shielded position [34.49(b)] 

D. Survey of device when placed in storage (including vehicles) to ensure source is in shielded 

position [34.49(c)] 

E. Protection of members of the public [20.1301] 

1. Adequate surveys made to demonstrate: 

a. the total effective dose equivalent to the individual likely to receive the highest dose 

does not exceed 0.1 mSv (100 mrem) in a year, or 

b. for an individual continuously present in an unrestricted area, the external dose 

would not exceed 0.02 mSv (2 mrem) in any 1 hour and 1 mSv (100 mrem) in a year 

[20.1301(a)(1); 20.1302(b)] 

2. Unrestricted area radiation levels do not exceed 0.02 mSv (2 mrem) in any 1 hour 

[20.1301(a)(2)] 

3. Records maintained [20.2103, 20.2107] 

Personnel Radiation Protection 

A. Dosimetry 

1. Workers monitored as required [20.1502; 34.47(a); L/C] 

2. Exchange Frequency Supplier 

3. Verify supplier is approved by the National Voluntary Laboratory Accreditation Program 

[20.1501(c)] 

4. Dosimeters exchanged at required frequency [L/C]

5. Dosimetry records maintained [20.2106; 34.83(c)]

B. Pocket Dosimeters and Electronic Personal Dosimeters 

1. Model No. Range 
G-5 

 Model No. Range 

2. Read and recorded at start of each shift [34.47(b)] 

3. Daily readings recorded [34.47(b)] 

4. Dosimeters checked for response (±20%) at intervals not to exceed 12 months 

5. Off-scale dosimeter procedure and records [34.47; 34.87(d)] 

C. Alarm Ratemeters 

1. Model No. Range 

2. Checked that alarm functions properly at start of each shift [34.47(g)(1)] 

3. Preset at 5 mSv (500 mrem)/h [34.47(g))(2)] 

4. Calibrated to ±20% at intervals not to exceed 12 months [34.47(g)(4)] 

5. Records maintained [34.83(b)] 

D. Dosimetry Reports 

1. Reviewed by Frequency .

2. Reviewed personnel monitoring records for interval (from to )

3. Maximum exposures: TEDE extremity 

 other 

4. NRC Forms (or equivalent) [20.2104(d); 20.2106(c)] 

a. NRC Form 4—occupational exposure history 

b. NRC Form 5—current occupational exposure 

5. Maximum exposures in compliance with annual limits [20.1201] 

6. Fetal and pregnant worker exposure [20.1206; 20.2106(e)] 

a. Worker declared pregnancy in writing during the audit interval 

b. If yes, licensee in compliance? Records maintained? 

7. Dosimetry records maintained [34.83] 

E. Radiation Protection Program 

1. Program includes provisions for keeping dose as low as reasonably achievable (ALARA) 

[20.1101] 

2. Procedures and engineering controls used to achieve ALARA [20.1101(b)] 

3. Content and implementation reviewed annually by licensee [20.101(c)] 

4. Records of program reviews maintained [20.2102(a)(2)] 

F. Planned Special Exposures (PSEs) [20.1206] 

1. PSEs performed? 

2. If so, when, where, and why? 

3. Records maintained [20.2105; 20.2106; 20.2204] 
G-6 

Receipt and Transfer of Radioactive Material 

A. Procedures established and followed for picking up, receiving, and opening packages 

[20.1906(e)] 

B. Incoming packages surveyed [20.1906(b)(2); L/C] 

C. Shipment of sources since last inspection 

1. Used container authorized by license or certificate of compliance (COC) [L/C; COC] 

2. Transfers [30.41] 

3. All sources surveyed before shipment and transfer [20.1501(a); 49 CFR 173.475(I); L/C] 

D. Records of surveys and receipt/transfer maintained [20/2103(a); 30.51; 34.63] 

E. Transactions entered into the National Source Tracking System, including annual 

reconciliation [20.2207] 

Transportation (10 CFR 71.5(a) and 49 CFR 170–189) 

A. Shipments are: 

□ Delivered to common carriers 

□ Transported in company’s private vehicle 

□ Both 

□ No shipments since last audit 

B. HAZMAT training [49 CFR 172.700–172.704] 

C. Packages: 

1. Authorized packages used [49 CFR 173.415; 173.416] 

2. Performance test records on file 

a. Special form sources [49 CFR 173.476(a)] 

b. DOT-7A packages [49 CFR 173.415(a)] 

3. COCs on file with the NRC for Type B [71.12(c)(1)] 

4. Two labels with Transport Index, Nuclide, Hazard Class [49 CFR 172.403; 172.441] 

5. Properly marked (Shipping name, UN number4

, Package type, Reportable quantity 

(RQ), Name and address of consignee [49 CFR 172.301; 172.310; 172.324; 172.101] 

6. Closed and sealed during transport [49 CFR 173.475(f)] 

D. Shipping papers 

1. Prepared and used [49 CFR 172.200(a)] 

2. Proper (Shipping name, Hazard class, UN number, Quantity, Package type, Nuclide, 

RQ, Radioactive material, Physical and chemical form, Category of label, Transport 

Index, Shipper’s name, Certification and signature, Emergency response phone 

 

4

 The UN number identifies the hazardous substance. The UN number is universally recognized and 

assigned by the United Nations. 
G-7 

number, “Limited Quantity,”“Cargo Aircraft Only” if applicable) [49 CFR 172.200–

172.204; 175.700] 

3. Readily accessible during transport 

E. Vehicles 

1. Placarded [49 CFR 172.504] 

2. Cargo blocked and braced [49 CFR 177.842(d)] 

3. Proper overpacks (shipping name, UN number label, statement of inner packaging 

complies with specification packaging) [49 CFR 171.15; 171.16] 

F. Any transportation incidents reported to DOT National Response Center [49 CFR 171.15; 

171.16] 

Auditor’s Independent Measurements 

A. Survey Instrument 

Serial No. 

Last Calibration 

B. Auditor’s measurements were compared with audited person’s measurement 

C. Describe the type, location, and results of measurements; attach a diagram/survey sheet 

and refer to this section 

Notifications and Reports 

A. Reports to individuals, public and occupational, monitored to show compliance with Part 20 

[19.13; 30.50] 

B. Theft or loss [20.2201; 30.50] 

C. Incidents [20.2202; 30.50; 34.101] 

D. Overexposures and high radiation levels [20.2203; 30.50] 

E. Annual reports furnished to the NRC [20.2206(b), (c)] 

F. Reporting of defects and noncompliance [21.21] 

Posting and Labeling 

A. Radiation areas [20.1902(a)] 

B. High-radiation areas [20.1902(b)] 

C. Use or storage areas [20.1902(e)] 

D. Containers or devices labeled [20.1904(a)] 

E. NRC Form 3 [19.11] 

F. Parts 19, 20, 21 (Section 206 of Energy Reorganization Act) OR notification of location of 

required documents [19.11; 21.6] 

G. Other posting and labeling [20.1902; 20.1904] 
G-8 

Recordkeeping for Decommissioning 

A. Records in independent and identifiable location [30.35(g)] 

B. Records include all required data [30.35(g)] 

Generic Communications and Newsletters 

A. Communications received and reviewed 

B. Appropriate response to bulletin, generic letters, etc. 

Special License Conditions or Issues 

Evaluate special license conditions for data, actions 

Performance Evaluation Factors 

These indicators may provide an indication of the status of the radiation safety program as 

perceived by management. 

A. Lack of senior management involvement with the radiation safety program and/or RSO 

oversight 

B. RSO too busy with assignments other than radiation safety 

C. Insufficient staffing 

D. Radiation Safety Committee fails to meet or functions inadequately 

E. Inadequate consulting service or inadequate audits 
APPENDIX H 

MODEL PROCEDURE FOR CALIBRATING 

SURVEY INSTRUMENTS

H-1

Model Instrument Calibration Program 

Note: This model provides acceptable procedures for calibrating survey instruments. 

Applicants may either adopt this model procedure or develop an alternate procedure to meet 

the requirements of Title 10 of the Code of Federal Regulations Section 34.25, “Radiation 

Survey Instruments.” 

Training 

Before allowing an individual to perform survey instrument calibrations, the Radiation Safety 

Officer (RSO) will ensure that he or she has sufficient training and experience to perform 

independent survey instrument calibrations. 

Classroom training may be in the form of lecture, videotape, or self-study and will cover the 

following subject areas: 

• principles and practices of radiation protection 

• radioactivity measurements, monitoring techniques, and instrument use 

• mathematics and calculations basic to using and measuring radioactivity 

• biological effects of radiation 

Appropriate on-the-job-training consists of the following: 

• observing authorized personnel performing survey instrument calibration 

• conducting survey meter calibrations under the supervision and in the physical 

presence of an individual authorized to perform calibrations 

Facilities and Equipment for Calibration of Dose Rate or Exposure Rate Instruments 

• To reduce doses received by individuals not calibrating instruments, calibrations will be 

conducted in an isolated area of the facility or at times when no one else is present. 

• Individuals conducting calibrations will wear assigned dosimetry. 

• Individuals conducting calibrations will use a calibrated and operable survey instrument 

to ensure that unexpected changes in exposure rates are identified and corrected. 

Model Procedure for Calibrating Survey Instruments 

A radioactive sealed source or sealed sources used for calibrating survey instruments will do 

the following: 

• approximate a point source 

• have its apparent source activity or the exposure rate at a given distance traceable by 

documented measurements to a standard certified to be accurate within ±5 percent by 

the National Institutes of Standards and Technology (NIST) 
H-2

• approximate the same energy and type of radiation as the environment in which the 

calibrated device will be employed 

• For dose rate and exposure rate instruments, the source should be strong enough to 

give an exposure rate of at least about 7.7×10-6 coulombs/kilogram/hour 

(30 milliroentgen/hour) at 100 centimeters (cm) (e.g., 3.1 gigabecquerels (85 mCi) of 

cesium-137 or 7.8×102

 megabecquerels (21 mCi) of cobalt-60). 

The three kinds of scales frequently used on dose or dose rate survey meters are calibrated as 

follows1

:

 

1

 American National Standards Institute, “Radiation Protection Instrumentation Test and Calibration,” 

ANSI N323A-1997.

• Linear readout instruments with a single calibration control for all scales shall be 

adjusted at the point recommended by the manufacturer or at a point within the normal 

range of use. Instruments with calibration controls for each scale shall be adjusted on 

each scale. After adjustment, the response of the instrument shall be checked at 

approximately 20 percent and 80 percent of full scale. The instrument’s readings shall 

be within ±15 percent of the conventionally true values for the lower point and 

±10 percent for the upper point. 

• Logarithmic readout instruments, which commonly have a single readout scale spanning 

several decades, normally have two or more adjustments. The instrument shall be 

adjusted for each scale according to site specifications or the manufacturer’s 

specifications. After adjustment, calibration shall be checked at a minimum of one point 

on each decade. Instrument readings shall have a maximum deviation from the 

conventionally true value of no more than 10 percent of the full decade value. 

• Meters with a digital display device shall be calibrated the same as meters with a linear 

scale. 

Notes: 

• Readings above 2.58×10-4 coulomb/kilogram/hour (1 roentgen/hour) need not be 

 calibrated, but such scales should be checked for operation and response to radiation. 

• The inverse square and radioactive decay law should be used to correct changes in 

 exposure rate resulting from changes in distance or source decay. 

Surface Contamination Measurement Instruments 

• The efficiency of survey meters must be determined by using radiation sources with 

energies and types of radiation similar to those that the survey instrument will be used 

to measure. 

• If each scale has a calibration potentiometer, the reading shall be adjusted to read the 

conventionally true value at approximately 80 percent of full scale, and the reading at 

approximately 20 percent of full scale shall be observed. If only one calibration 

potentiometer is available, the reading shall be adjusted at midscale on one of the 

scales, and readings on the other scales shall be observed. Readings shall be within 

20 percent of the conventionally true value. 
H-3

Calibration Records 

Calibration reports, for all survey instruments, will indicate the procedure used and the data 

obtained. The description of the calibration will include the following: 

• the owner or user of the instrument 

• a description of the instrument, including the manufacturer’s name, model number, 

serial number, and type of detector 

• a description of the calibration source, including the exposure rate at a specified 

distance or activity on a specified date 

• for each calibration point, the calculated exposure rate or count rate, the indicated 

exposure rate or count rate, the deduced correction factor (the calculated exposure rate 

or count rate divided by the indicated exposure rate or count rate), and the scale 

selected on the instrument 

• for instruments with external detectors, the angle between the radiation flux field and 

the detector (i.e., parallel or perpendicular) 

• for instruments with internal detectors, the angle between radiation flux field and a 

specified surface of the instrument 

• for detectors with removable shielding, an indication of whether the shielding was in 

place or removed during the calibration procedure 

• the exposure rate or count rate from a check source, if used 

• the name of the person who performed the calibration and the date it was performed 

The following information will be attached to the instrument as a calibration sticker or tag: 

• for exposure rate meters, the source isotope used to calibrate the instrument (with 

correction factors) for each scale 

• the efficiency of the instrument for each isotope the instrument will be used to measure 

(if efficiency is not calculated before each use) 

• for each scale or decade not calibrated, an indication that the scale or decade was 

checked only for function but not calibrated 

• the date of calibration and the next calibration due date 

• the apparent exposure rate or count rate from the check source, if used 

APPENDIX I 

REQUESTS TO PERFORM LEAK TESTING 

AND SAMPLE ANALYSIS

I-1 

Requests to Perform Leak Testing and Sample Analysis 

Note: This model provides acceptable procedures for performing leak testing and sample 

analysis. Applicants may either adopt this model procedure or develop an alternate procedure 

to meet the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 

Section 34.27, “Leak Testing and Replacement of Sealed Sources.” 

Training 

Before allowing an individual to perform leak testing, the licensee must ensure that he or she 

has sufficient classroom and on-the-job training to show competency in performing leak tests 

independently. 

Classroom training may be in the form of lecture, videotape, or self-study and will cover the 

following subject areas: 

• principles and practices of radiation protection 

• radioactivity measurements, monitoring techniques, and instrument use 

• mathematics and calculations used for measuring radioactivity 

• biological effects of radiation 

Appropriate on-the-job-training consists of the following: 

• observing authorized personnel collecting and analyzing leak-test samples 

• collecting and analyzing leak-test samples under the supervision and in the physical 

presence of an individual authorized to perform leak tests 

Facilities and Equipment 

• To ensure achieving the required sensitivity of measurements, analyze leak tests in a 

low-background area. 

• Use a calibrated and operable survey instrument to check leak-test samples for gross 

contamination before they are analyzed. 

• Analyze the leak-test sample using an instrument that is appropriate for the type of 

radiation to be measured (e.g., NaI (Tl) well-counter system for gamma emitters, liquid 

scintillation for beta emitters, gas-flow proportional counters for alpha emitters). 

• If the sensitivity of the counting system is unknown, determine the minimum detectable 

activity (MDA). The MDA may be determined using the following formula: 
I-2 

MDA = 2.71 + 4.65 √(BR × t) = Minimum Detectable Activity 

 t × E 

where: MDA = minimum detectable activity in disintegrations per minute (dpm) 

 bkg = background count rate in counts per minute (cpm) 

 t = background counting time in minutes 

 E = detector efficiency in counts per disintegration 

For example: 

where: bkg = 200 counts per minute (cpm) 

 E = 0.1 counts per disintegration (10% efficient) 

 t = 2 minutes 

 MDA = 2.71 + 4.65 √(200 cpm × 2 minutes) = 2.71 + 4.65√(400)

 2 × 0.1 0.2 

 = 2.71 + 4.65 (20) = 2.71 + 93 = 95.71

0.2 0.2 0.2 

 = 478.55 disintegrations

 minute 

 becquerels (Bq) = 1 disintegration

 second 

 Bq = 478.55 disintegration × minute = 7.976 Bq 

 minutes 60 seconds 

Frequency for Conducting Leak Tests of Sealed Sources 

Leak tests will be conducted at the frequency specified in the respective sealed source and 

device registration certificate. 

Procedure for Performing Leak Testing and Analysis 

• For each source to be tested, list identifying information such as sealed source serial 

number, radionuclide, and activity. 

• If available, use a survey meter to monitor exposure. 

• Prepare a separate wipe sample (e.g., cotton swab or filter paper) for each source. 

• Number each wipe to correlate with identifying information for each source. 

• Wipe the most accessible area where contamination would accumulate if the sealed 

source were leaking. 

• Select an instrument that is sensitive enough to detect 185 Bq (0.005 microcuries (μCi)) 

of the radionuclide. 

• Using the selected instrument, count and record background count rate. 
I-3 

• Check the instrument’s counting efficiency using a standard source of the same 

radionuclide as the source being tested or one with similar energy characteristics. 

Accuracy of standards should be within ±5 percent of the stated value and traceable to 

primary radiation standards such as those maintained by the National Institute of 

Standards and Technology. 

• Calculate efficiency. 

For example: [(cpm from std) - (cpm from bkg)] = efficiency in cpm/Bq 

 activity of std in Bq 

where: cpm = counts per minute 

 std = standard 

 bkg = background 

 Bq = becquerel 

• Count each wipe sample; determine net count rate. 

• For each sample, calculate and record estimated activity in Bq (or millicuries). 

For example: [(cpm from wipe sample) - (cpm from bkg)] = Bq on wipe sample 

 efficiency in cpm/Bq 

• Sign and date the list of sources, data, and calculations. Retain records for 3 years 

(10 CFR 20.2103(a)). If the wipe test activity is 185 Bq (0.005 μCi) or greater, notify the 

radiation safety officer (RSO), so that the source can be withdrawn from use and 

disposed of properly. Also notify the U.S. Nuclear Regulatory Commission (NRC). 

Reference: See NUREG-1556, Volume 18, “Program-Specific Guidance About Service 

Provider Licenses,” issued November 2000. 

Sampling and Analysis for Depleted Uranium as a Result of S-Tube Breakthrough 

Note: As an ALARA safety measure for devices with an S-tube configuration, the source 

should be transferred to a source changer before the S-tube is tested for breakthrough. 

The wipe test sample should be obtained from the areas of the tube where wear is likely to be 

most severe, at the first curve nearest the ends of the radiography device. The sample should 

be analyzed for alpha contamination. Alpha contamination present indicates that wear has 

broken through the S-tube to expose the depleted uranium. 

Alpha counting sensitivity should be able to detect 185 Bq (0.005 μCi) of contamination. 

A worn S-tube could create equipment operating difficulties. Upon verification of the presence 

of alpha-particle emitting uranium, the radiographic exposure device should be removed from 

use until an evaluation of the wear of the S-tube has been made. Should the evaluation reveal 

that the S-tube is worn through, the device may not be used again. No user repairs are 

permitted. 

APPENDIX J 

GUIDANCE FOR DEMONSTRATING THAT INDIVIDUAL MEMBERS OF 

THE PUBLIC WILL NOT RECEIVE DOSES EXCEEDING THE 

ALLOWABLE LIMITS

J-1 

Guidance for Demonstrating That Individual Members of the Public Will Not Receive 

Doses Exceeding the Allowable Limits 

Licensees must ensure the following: 

• The radiation dose received by individual members of the public resulting from the 

licensee’s possession or use of licensed materials does not exceed 1 millisievert (mSv) 

(100 millirem (mrem)) in one calendar year. 

Members of the public include persons who live, work, or may be near locations where 

industrial radiography devices are used or stored and employees whose assigned duties do 

not include the use of licensed materials and who work in the vicinity where devices are used 

or stored. 

• The radiation dose in unrestricted areas does not exceed 0.02 mSv (2 mrem) in any 

1 hour. 

• Typical unrestricted areas may include offices, shops, laboratories, areas outside 

buildings, property, and nonradioactive equipment storage areas. The licensee does 

not control access to these areas for purposes of controlling exposure to radiation or 

radioactive materials. However, the licensee may control access to these areas for 

other reasons, such as security. 

• Licensees must show compliance with both portions of the regulation. Radiographic 

operations at temporary jobsites must be demonstrated to have doses to the public in 

unrestricted areas that do not exceed 0.02 mSv (2 mrem) in any 1 hour. For storage 

areas and permanent radiographic facilities, calculations or a combination of 

calculations and measurements (e.g., an environmental thermoluminescent device 

(TLD)) is often used to prove compliance with levels of 0.02 mSv (2 mrem) in any 1 hour 

and 1 mSv (100 mrem) in a calendar year. 

Calculational Method 

For ease of use by most industrial radiography licensees, the examples in this appendix use 

conventional units. The conversions to International System of Units (SI) units are as follows: 

1 foot (ft) = 0.305 meter (m); 1 mrem = 0.01 mSv. 

The calculational method takes a tiered approach, going through a three-part process starting 

with a worst-case situation and moving toward more realistic situations. It makes the following 

simplifications: (1) each device is a point source, (2) typical radiation levels encountered when 

the source is in the shielded position are taken from either the sealed source and device (SSD) 

registration sheet, the maximum dose levels allowed for a transport package (exposure device) 

labeled YELLOW III, or the manufacturer’s literature, and (3) no credit is taken for any shielding 

found between the devices and the unrestricted areas. 

Part 1 of the calculational method is simple but conservative. It assumes that a member of the 

public is present 24 hours a day, and it uses only the inverse square law to determine if the 

distance between the device and the affected member of the public is sufficient to show 

compliance with the public dose limits. Part 2 considers not only distance, but also the time that 

a member of the public is actually in the area under consideration. Part 3 considers distance 
J-2 

and the portion of time that both the device and the affected member of the public are present. 

Part 4 considers the distance, the portion of time that both the device and the affected member 

of the public are present, and the shielding provided by the structural materials or shielding 

materials specifically added by the licensee. Using this approach, licensees make only those 

calculations that are needed to demonstrate compliance. In many cases, licensees will need to 

use the calculational method through Part 1 or Part 2. These calculations typically result in 

higher radiation levels than would exist at typical facilities, but provide a method for estimating 

conservative doses which could be received. 

Example 1 

To better understand the calculational method, Mo-Rad, Inc., a hypothetical radiography 

licensee, is demonstrated. Yesterday, the company’s president noted that the new device 

storage area is close to his secretary’s desk and he asked Joe, the Radiation Safety Officer 

(RSO), to determine if the company is complying with the U.S. Nuclear Regulatory 

Commission’s (NRC’s) regulations. 

The secretary’s desk is near the wall separating the reception area from the designated, locked 

device storage area, where the company is storing its two devices. Joe measures the 

distances from each device to the wall and assumes that each device would have the maximum 

dose rate allowed under NRC or U.S. Department of Transportation (DOT) regulations: 

2 millisievert per hour (mSv/h) (200 millirem per hour (mrem/h)) on the surface and 0.1 mSv/h 

(10 mrem/h) at 1 meter. Figure J.1 is Joe’s sketch of the areas in question, and Table J.1 

summarizes the information Joe has on each device. 

rad0007d.ppt

072398

A Bird’s Eye View of Office and Device Storage Area

12 Feet

18 Feet

Device Storage Room

Ir192

Device

Co60

Device

Hallway

Figure J.1 Diagram of office and device storage area. This sketch shows the areas 

described in Examples 1 and 2.
J-3 

Table J.1 Information Known about Each Device 

Description of Known 

Information

Device 1 Device 2

How device is stored Ir-192 exposure device 

(Type B container) 

Co-60 exposure device 

(Type B container) 

Dose rate in mrem/h encountered 

at specified distance from the 

device 

10 mrem/h at 1 m (3.3 ft) 10 mrem/h at 1 m (3.3 ft) 

Distance in ft to secretary’s chair 12 ft 18 ft 

Example 1: Part 1 

Joe’s first thought is that the distance between the devices and the secretary’s chair may be 

sufficient to show compliance with the regulation in Title 10 of the Code of Federal Regulations 

(10 CFR) 20.1301. Taking a worst case approach, he assumes that (1) the devices are 

constantly present (i.e., 24 hours per day), (2) both devices remain in storage with no other use, 

and (3) the secretary is constantly sitting in the desk chair (i.e., 24 hours per day). Joe 

proceeds to calculate the dose she might receive hourly and yearly from each device, as shown 

in Tables J.2 and J.3 below. 

Table J.2 Calculational Method, Part 1: Hourly and Annual Dose 

Received from Device 1 

Step 

No.

Description Device 1 

Input Data

Results

1 Dose received in 1 hour at known distance from device 

(e.g., from manufacturer’s data), in mrem/h 

10 10 

2 Square of the distance (ft) at which the Step 1 rate was 

measured, in ft2

(3.3) 2 10.9 

3 Square of the distance (ft) from the device the 

secretary’s desk in an unrestricted area, in ft2

(12) 2 144 

4 Multiply the results of Step 1 by the results of Step 2 

(this is an intermediate result) 

10 × 10.9 = 109 

5 Divide the result of Step 4 by the result of Step 3 to 

calculate the dose received by an individual at the

secretary’s desk, HOURLY DOSE RECEIVED FROM 

DEVICE 1, in mrem in 1 hour. 

109/144 = 0.76

6 Multiply the result of Step 5 by 24 hours per day (h/d) × 

365 days per year (d/yr) = MAXIMUM ANNUAL DOSE 

RECEIVED FROM DEVICE 1, in mrem in 1 year. 

0.76 × 24 × 365 = 

0.76 × 8,760 = 

6,630
J-4 

Table J.3 Calculational Method, Part 1: Hourly and Annual Dose 

Received from Device 2 

Step 

No.

Description Device 2 

Input Data

Result

s

1 Dose received in 1 hour at known distance from device 

(e.g., from manufacturer’s data), in mrem/h 

10 10 

2 Square of the distance (ft) at which the Step 1 rate was 

measured, in ft2

(3.3) 2 10.9 

3 Square of the distance (ft) from the device to the 

secretary’s desk in an unrestricted area, in ft2

(18) 2 324 

4 Multiply the results of Step 1 by the results of Step 2 

(this is an intermediate result) 

10 × 10.9 = 109 

5 Divide the result of Step 4 by the result of Step 3 to 

calculate dose received in 1 hour by an individual at the 

secretary’s desk, HOURLY DOSE RECEIVED FROM 

DEVICE 2, in mrem in 1 hour 

109/324 = 0.34

6 Multiply the result of Step 5 by 24 h/d × 365 d/yr = 

MAXIMUM ANNUAL DOSE RECEIVED FROM DEVICE 

2, in mrem in 1 year 

0.34 × 24 × 365 = 

0.34 × 8,760 = 

2,950

To determine the total hourly and total annual dose received, Joe adds the pertinent data from 

the preceding tables. 

Table J.4 Calculational Method, Part 1: Total Hourly and Annual Dose Received from 

Devices 1 and 2 

Step 

No.

Description Device 1 Device 2 Sum

7 TOTAL HOURLY DOSE RECEIVED from 

Step 5 of Tables K.3 and K.4, in mrem in 

1 hour 

0.76 0.34 0.76 + 0.34 = 1.1

8 TOTAL ANNUAL DOSE RECEIVED from 

Step 6 of Tables K.3 and K.4, in mrem in 

1 year 

6,630 2,950 6,630 + 2,950 = 

9,580

Note: The sum in Step 7 demonstrates compliance with the limit of 2 mrem in any 1 hour. 

Reevaluate if assumptions change. If the sum in Step 8 exceeds 100 mrem/yr, proceed to 

Part 2 of the calculational method. 

At this point, Joe is pleased to see that the total dose that an individual could receive in any 

1 hour is only 1.1 mrem, but notes that an individual could receive a dose of 9,580 mrem in a 

year, much higher than the 100-mrem limit.
J-5 

Example 1: Part 2 

Joe reviews his assumptions and recognizes that the secretary is not at the desk 24 hours per 

day. He decides to make a realistic estimate of the number of hours the secretary sits in the 

chair at the desk, keeping his other assumptions constant (i.e., the devices are constantly 

present (24 hours per day), both devices remain in storage with no other use). He then 

recalculates the annual dose received. 

Table J.5 Calculational Method, Part 2: Annual Dose Received 

from Devices 1 and 2 

Step 

No.

Description Results

9 A. Average number of hours per day that individual spends in area 

of concern (e.g., secretary sits at desk 5 h/d; the remainder of 

the day the secretary is away from the desk area copying, 

filing, etc.) 

B. Average number of days per week in area (e.g., secretary is 

part time and works 3 days/week) 

C. Average number of weeks per year in area (e.g., secretary 

works all year ) 

5 

3 

52 

10 Multiply the results of Step 9.A by the results of Step 9.B by the 

results of Step 9.C = AVERAGE NUMBER OF HOURS IN AREA 

OF CONCERN PER YEAR

5 × 3 × 52 = 780

11 Multiply the sum in Step 7 by the results of Step 10 = ANNUAL 

DOSE RECEIVED FROM DEVICES CONSIDERING REALISTIC 

ESTIMATE OF TIME SPENT IN AREA OF CONCERN, in mrem in 

1 year 

1.1 × 780 = 860

Note: If Step 11 exceeds 100 mrem in a year, proceed to Part 3 of the calculational method. 

Although Joe is pleased to note that the calculated annual dose received is significantly lower, 

he realizes it still exceeds the annual limit of 100 mrem. 

Example 1, Part 3 

Again Joe reviews his assumptions and recognizes that the devices are not always in storage 

when the secretary is seated at the desk. As he examines the situation, he realizes he must 

consider each device individually. 
J-6 

Table J.6 Calculational Method, Part 3: Summary of Information 

Summary

Information on When Devices Are Present in the Storage Area:

· Device 1: An iridium-192 exposure device located in the storage area overnight and used 

every day at temporary jobsites all year and returned to the storage location at the end of 

each day. The device is usually present during the secretary’s first and last hours of work 

each day. 

· Device 2: A cobalt-60 exposure device located in the storage area continuously (24 h/d) 

for 8 months of the year; for the remaining 4 months of the year, it is at temporary jobsites. 

Information from Example 1, Part 2, on When the Secretary Is Sitting at the Desk:

· 5 days per week 

· 3 days per week 

· 52 weeks per year 

Table J.7 Calculational Method, Part 3: Annual Dose Received 

from Devices 1 and 2 

Step 

No.

Description Device 1 Device 2 

12 Average number of hours per day device is in 

storage while secretary is present 

2 5

13 Average number of days per week device is in 

storage while secretary is present 

3 3

14 Average number of weeks per year device is in 

storage while secretary is present 

52 32

15 Multiply the results of Step 12 by the results of 

Step 13 by the results of Step 14 = TOTAL 

HOURS EACH DEVICE IS STORED PER YEAR

WHILE SECRETARY IS PRESENT

2 × 3 × 52 = 312 5 × 3 × 32 = 480

16 Multiply the results of Step 15 by the results of 

Step 7 = ANNUAL DOSE RECEIVED FROM 

EACH DEVICE, in mrem in 1 year 

312 × 0.76 = 237 480 × 0.34 = 163

17 Sum the results of Step 16 for each device = 

TOTAL ANNUAL DOSE RECEIVED 

CONSIDERING REALISTIC ESTIMATE OF TIME 

SPENT IN AREA OF CONCERN AND TIME 

DEVICE IS IN STORAGE, in mrem in 1 year 

237 + 163 = 400

Note: If the result in Step 17 is greater than 100 mrem/yr, the licensee must take corrective 

actions.
J-7 

Joe notes that the result in Step 17 does not show compliance with the limit of 100 mrem/yr. 

Since the result in Step 17 is higher than 100 mrem/yr, Joe has to do one or more of the 

following: 

• Consider whether the assumptions used to determine occupancy and the time each 

device is in storage are accurate, revise the assumptions as needed, and recalculate 

using the new assumptions. 

• Calculate the effect of any shielding located between the device storage area and the 

secretarial workstation. Listed below are typical half-value layers (HVLs) for iridium-192 

and cobalt-60. 

Table J.8 Half-Value Layers for Typical Shielding Materials 

Steel HVL (inches) 

Lead

Concrete

Ir-192 0.5 0.25 1.7 

Co-60 0.8 0.5 2.1 

• Take corrective action (e.g., move devices within storage area, move the storage area, 

move the secretarial workstation) and perform new calculations to demonstrate 

compliance 

• Designate the area outside the storage area as a restricted area and the secretary as 

an occupationally exposed individual. This would require controlling access to the area 

for purposes of radiation protection and training the secretary, as required by 

10 CFR 19.12, “Instruction to workers.” 

Example 1, Part 4 

Joe decides to take into account the amount of shielding provided by the wall between the 

secretary’s desk and the storage area where the two devices are located. The wall between 

the secretary’s office and the storage area is a 4-inch-thick concrete fire wall. 

Table J.9 Calculational Method, Part 4: Annual Dose Received 

from Devices 1 and 2 

Step 

No.

Description Device 1 Device 2

18 Annual dose received from each device from 

Step 15 

237 163

19 Number of HVLs (thickness of shielding 

material/thickness for one HVL); if more than one 

shielding material, evaluate each shielding material 

separately by type of radionuclide.

4.0/1.7 = 2.35 4.0/2.1 = 1.9
J-8 

Step 

No.

Description Device 1 Device 2

20 Fraction of radiation dose transmitted through 

shield: 0.5 (total number of HVLs); if more than 

one shielding material, then sum the number 

results from Step 19 by radionuclide.

0.5(2.35) = 0.2 0.5(1.9) = 0.27

21 Multiply the results of Step 20 by the results of 

Step 18 = ANNUAL DOSE RECEIVED FROM 

EACH DEVICE, in mrem in 1 year 

0.2 × 237 = 47 0.27 × 163 = 44

22 Sum the results of Step 21 for each device = 

TOTAL ANNUAL DOSE RECEIVED 

CONSIDERING REALISTIC ESTIMATE OF TIME 

SPENT IN AREA OF CONCERN, TIME DEVICE 

IS IN STORAGE AND SHIELDING OF 

STRUCTURAL MATERIALS, in mrem in 1 year 

47 + 44 = 91

Note: If the result in Step 22 is greater than 100 mrem/yr, the licensee must take corrective 

actions. 

Joe is glad to see that the results in Step 22 show compliance with the annual limit of 

100 mrem. 

Note that in the example, Joe evaluated the unrestricted area outside only one wall of the 

device storage area. Licensees also need to make similar evaluations for other unrestricted 

areas and to keep in mind the principle of maintaining doses as low as reasonably achievable 

(ALARA), taking reasonable steps to keep radiation dose received below regulatory 

requirements. In addition, licensees need to be alert to changes in situations (e.g., moving any 

of the devices closer to the secretarial workstation, adding a device to the storage area, 

changing the secretary to a full-time worker, or changing the estimate of the portion of time 

spent at the desk) and to perform additional evaluations, as needed. 

RECORDKEEPING: As required by 10 CFR 20.2107, “Records of dose to individual 

members of the public,” licensees must maintain records demonstrating compliance with the 

dose limits for individual members of the public. 

Combination Measurement—Calculational Method 

This method, which allows the licensee to take credit for shielding between the device and the 

area in question, begins by measuring radiation levels in the areas, as opposed to using 

manufacturer-supplied rates at a specified distance from each device. These measurements 

must be made with calibrated survey meters sufficiently sensitive to measure background levels 

of radiation. However, licensees must exercise caution when making measurements with 

currently calibrated radiation survey instruments. A maximum dose of 1 mSv (100 mrem) 

received by an individual over an interval of 2,080 hours (i.e., a work year of 40 hours per week 

for 52 weeks per year) is equal to less than 0.5 microsievert (0.05 mrem) per hour. 
J-9 

This rate is well below the minimum sensitivity of most commonly available Geiger-Mueller 

survey instruments. 

Instruments used to make measurements for calculations must be sufficiently sensitive. An 

instrument equipped with a scintillation-type detector (e.g., NaI (Tl)) or a micro-R meter used in 

making very low gamma radiation measurements should be adequate. 

Licensees may also choose to use environmental TLDs. TLDs used for personnel monitoring 

(e.g., lithium fluoride)) may not have sufficient sensitivity for this purpose. Generally, the 

minimum reportable dose received is 0.1 mSv (10 mrem). Suppose a TLD monitors dose 

received and is changed once a month. If the measurements are at the minimum reportable 

level, the annual dose received could have been about 1.2 mSv (120 mrem), a value in excess 

of the limit of 1 mSv/yr (100 mrem/yr). If licensees use TLDs to evaluate compliance with the 

public dose limits, they should consult with their TLD supplier and choose more sensitive TLDs, 

such as those containing calcium fluoride, that are used for environmental monitoring in 

unrestricted areas next to the device storage area for monitoring. This direct measurement 

method would provide a definitive measurement of actual radiation levels in unrestricted areas 

without any restrictive assumptions. Records of these measurements can then be evaluated to 

ensure that rates in unrestricted areas do not exceed the limit of 1 mSv/yr (100 mrem/yr). 

Example 2 

As in Example 1, Joe is the RSO for Mo-Rad, Inc., a radiography licensee. The company has 

two devices stored in a designated, locked storage area that adjoins an unrestricted area where 

a secretarial workstation is located. See Figure J.1 and Table J.1 for information. Joe wants to 

see if the company complies with the public dose limits at the secretarial station. 

During the winter while all the devices were in storage, Joe placed an environmental TLD badge 

in the secretarial work space for 30 days. Joe chose a winter month so he did not have to keep 

track of the number of hours that each device was in the storage area. The TLD processor 

sent Joe a report indicating that the TLD received 100 mrem. 

Parts 2 and 3 are calculated in the manner shown in Example 1. 

Table J.10 Combination Measurement—Calculational Method 

Step 

No.

Description Input Data and Results

Part 1

1 Dose received by TLD, in mrem 100

2 Total hours TLD exposed 24 h/d × 30 d/mo = 720

3 Divide the results of Step 1 by the results of Step 2 to 

determine HOURLY DOSE RECEIVED, in mrem in 

1 hour 

0.14

4 Multiply the results of Step 3 by 365 d/yr × 24 h/d = 

8,760 hours in 1 year = MAXIMUM ANNUAL DOSE 

RECEIVED FROM DEVICES, in mrem in 1 year 

365 × 24 × 0.14 = 8,760 × 

0.14 = 1,226
J-10 

Step 

No.

Description Input Data and Results

Part 2

 

Part 3

Note: For the conditions described above, Step 3 indicates that the dose received in any 

1 hour is less than the limit of 2 mrem in any 1 hour. However, if there are any changes, then 

the licensee would need to reevaluate the potential doses which could be received in any 

1 hour. Step 4 indicates that the annual dose received would be much greater than the annual 

limit of 100 mrem allowed by the regulations. 

In Step 2, Joe can adjust for a realistic estimate of the time the secretary spends in the area as 

he did in Part 2 of Example 1. 

If the results of Joe’s evaluation in Part 2 show that the annual dose received in a year exceeds 

100 mrem, then he can make adjustments for realistic estimates of the time spent in the area of 

concern while the devices are actually in storage, as in Part 3 of Example 1. (Recall that the 

TLD measurement was made while all the devices were in storage—that is, 24 hours per day 

for the 30 days that the TLD was in place.)
APPENDIX K 

INFORMATION FOR APPLICANTS TO CONSIDER WHEN 

DEVELOPING PROCEDURES FOR OPERATING RADIOGRAPHY 

EQUIPMENT

K-1 

Information for Applicants To Consider When Developing Procedures for Operating 

Radiography Equipment 

Caution: Always use a calibrated, operable survey meter and wear proper dosimetry while 

performing the following operations: 

Crankout Device 

• Establish and post the restricted area and high-radiation area. 

• Locate the source shield at the desired distance from the object to be radiographed. 

• Mount the source tip firmly, using jigs or other attachments, with the tip in the exact 

exposure position. 

• Locate the control unit at a maximum distance from the source shield with the control 

tubes laid out as straight as possible. 

• Join the control cable to the unit following the manufacturer’s instructions. 

• Unlock the device. 

• Turn the handcrank steadily to move the source out of the source shield to the exposure 

position. 

• Survey the perimeter of the restricted area to be sure that radiation levels do not exceed 

0.02 millisievert (mSv) (2 millirem (mrem)) in any 1 hour. 

• Maintain continuous surveillance over the restricted area during an exposure, keeping 

all persons from entering. 

• After completing the exposure, retract the source by turning the crank until the “safe” 

position is indicated. 

• Survey the entire circumference of the device and the guide tube to determine that the 

source is in a shielded position. 

• Lock the device and remove the key. 

Pipeliner Device 

• Establish and post the restricted area and high-radiation area. 

• Unlock the device. 

• Stand as far away as possible and out of the direction of the beam and expose the 

source (e.g., use the “stretch technique”). 

• Survey the perimeter of the restricted area to be sure that the radiation levels do not 

exceed 0.02 mSv (2 mrem) in any 1 hour. 

• Maintain continuous surveillance over the restricted area during an exposure, keeping 

all persons from entering. 

• After completing the exposure, return the source to the shielded position.
K-2

• Survey the device to determine that the source is in a shielded position. 

• Lock the device. 

Note: The U.S. Nuclear Regulatory Commission considers the following very important: 

surveys of the restricted area, continuous surveillance of the restricted area during an 

exposure, the survey of the device and guide tube, and locking the device. 

Source Exchange 

Removing the Old Source

(1) Survey the shipping container upon receipt with a survey meter. Note that the surface 

reading should not exceed 2 millisievert per hour (mSv/h) (200 millirem per hour 

(mrem/h)). 

(2) Attach the end of the source guide tube to the exposure device. 

(3) Connect the other end of the source guide tube to the empty side of the source changer. 

(4) Unlock the empty side of the source changer. 

(5) Unlock the camera and crank out the source from the camera into the source changer. 

(6) Survey the source changer and guide tube to verify that the source is in the safe 

position. 

(7) Lock the source changer. 

(8) Disconnect the source guide tube and drive cable to the source pigtail. Replace the 

dust cap on the source changer. 

(9) Remove the source identification plate from the exposure device and affix the plate to 

the side of the source changer loaded with the old source. 

Installing the New Source

(1) Remove the dust cap on the source changer lock body identified with the new source 

tag. 

(2) Align the camera and source guide tube with the source changer. 

(3) Connect the new source to the drive cable. 

(4) Connect the source guide tube to the source changer. 

(5) Unlock the source changer and retract the new source into the exposure device. 
K-3 

(6) Survey the exposure device and guide tube to ensure that the source is in the safe 

position. 

(7) Lock the exposure device. 

(8) Disconnect the source guide tube and drive accessories. 

(9) Affix the new source identification plate on the exposure device. 

APPENDIX L 

TRANSPORTATION

L-1 

Transportation 

The following are the major areas in U.S. Department of Transportation (DOT) regulations most 

relevant for transporting radiographic exposure devices and source changers that are shipped 

as Type B quantities: 

A. Table of Hazardous Materials and Special Provisions—49 CFR 172.101 

1. 49 CFR 172.101—Hazardous Materials Table [proper shipping name, hazard class, 

identification number] 

2. Table 2, Appendix A to 49 CFR 172.101—List of Hazardous Substances and Reportable 

Quantities [for radionuclides] 

B. Shipping Papers—49 CFR 172.200 

1. 49 CFR 172.201—General entries [on shipping papers] 

2. 49 CFR 172.202—Description of hazardous material on shipping papers 

3. 49 CFR 172.203—Additional description requirements 

4. 49 CFR 172.204—Shipper’s certification [if applicable] 

C. Package Markings—49 CFR 172.300 

1. 49 CFR 172.301—General marking requirements for non-bulk packaging 

2. 49 CFR 172.304—Marking requirements 

3. 49 CFR 172.310—Radioactive material [Type B] 

4. 49 CFR 172.324—Hazardous substances in nonbulk packaging [designation of 

“reportable quantities” with the letters “RQ”] 

D. Package Labeling—49 CFR 172.400 

1. 49 CFR 172.400(a)—General labeling requirements 

2. 49 CFR 172.403—Radioactive materials [types and contents of labels] 

3. 49 CFR 172.406—Placement of labels 

E. Placarding of Vehicles—49 CFR 172.500 

1. 49 CFR 172.504—General placarding requirements 

2. 49 CFR 172.516—Visibility and display of placards 

3. 49 CFR 172.556—RADIOACTIVE placard 

F. Emergency Response Information—Subpart G 

1. 49 CFR 172.600—Applicability and general requirements 

2. 49 CFR 172.602—Emergency response information 
L-2 

3. 49 CFR 172.604—Emergency response telephone number 

G. Training—Subpart H 

1. 49 CFR 172.702—Applicability and responsibility for training and testing [for HAZMAT 

employees] 

2. 49 CFR 172.702—Training requirements (includes types of training, when it must be 

conducted, need for refresher training every 3 years, recordkeeping) 

H. Shippers—General Requirements for Shipments and Packaging—49 CFR Part 173 

1. 49 CFR 173.25—Requirements for use and labeling of overpacks 

2. 49 CFR 173.403—Definitions 

3. 49 CFR 173.411—General design requirements 

4. 49 CFR 173.413—Additional design requirements for Type B packages 

5. 49 CFR 173.416—Authorized Type B packages [includes packaging certification 

requirements] 

6. 49 CFR 173.441—Radiation levels 

7. 49 CFR 173.471—Additional requirements for Type B packages approved by NRC 

8. 49 CFR 173.476—Approval of special form radioactive materials [includes requirement 

for documentation of special form status] 

I. Carriage by Public Highway—49 CFR Part 177 

1. 49 CFR 177.817—Shipping paper [location of shipping papers during transport] 

2. 49 CFR 177.842—Class 7 (radioactive) material [includes requirement for blocking and 

bracing during transport] 

Applicants should visit the U.S. DOT Web site for additional information on transportation 

requirements: http://www.dot.gov/. 
APPENDIX M 

DAILY MAINTENANCE CHECK OF RADIOGRAPHIC EQUIPMENT 

M-1 

Daily Maintenance Check of Radiographic Equipment 

The radiographer or radiographer’s assistant shall perform a daily maintenance check of the 

exposure device and related radiographic equipment. This inspection will be performed before 

using the equipment on each day the equipment is to be used. Report defective equipment to 

the Radiation Safety Officer (RSO) immediately. Do not attempt to use defective equipment. 

After the inspection, document the results of the inspection. 

(1) Inspect the survey meter for battery check, zero, and operation. If batteries are low, 

replace, then check for operability. If not able to correct a problem with the survey 

meter, obtain another meter and start over. 

(2) Check survey meter with a check source (which should give a reading of millirem) 

(or check with camera which should give a reading of millirem) as indicated 

on the survey meter. If reading is not acceptable, obtain another meter and start again. 

Note: The RSO or calibration vendor should determine the acceptable meter reading for each 

survey meter and post the expected reading on each instrument. This reading shall be 

obtained and noted at the time of calibration. 

(3) Inspect the remote-control radiographic equipment as follows: 

• Inspect the cables for cuts, breaks, and broken fittings. 

• Carefully inspect approximately 1 foot of the drive cable immediately next to the 

male connector. Take care not to introduce any dirt or dust on the drive cable 

during this inspection. In addition to the previously mentioned items, the 

examination of the cable should look for any of the following: 

– excessive or uneven wearing 

– fraying 

– unraveling 

– nicks 

– kinks or bends 

– loss of flexibility (abnormal stiffness) 

– excessive grit or dirt 

– stretching 

• Inspect the crank unit for damage and loose hardware. 

• Check operation of the control for freedom of drive cable movement. 

• Inspect the guide tube for cuts, crimps, and broken fittings. 

• Survey for radiation levels and record readings. The radiation levels should be 

about the same as those in the previous day’s inspection, unless there has been 

a source change. 

• Check that all safety plugs are in place. 

• Inspect the exposure device for damage to fittings, lock, fasteners, and labels. 

• Check for any impairment of the locking mechanism.
M-2 

• If provided by the manufacturer or distributor, use the go/no-go tool to determine 

if the locking ball will function as intended. 

(4) Record the results of the daily inspection. 
APPENDIX N 

SUGGESTED EXAMPLE OF A ROUTINE EMERGENCY PROCEDURE 

N-1 

Suggested Example of a Routine Emergency Procedure 

Emergency Procedure 

If the source fails to return to the shielded position or if any other emergency or unusual 

situation arises (e.g., vehicle accident, off-scale dosimeter), take the following actions: 

• Immediately secure the area and post the restricted area at the 0.02 millisievert per hour 

(mSv/h) (2 millirem per hour (mrem/h)) radiation level; maintain continuous surveillance 

and restrict access to the restricted area. 

• Notify the radiation safety officer (RSO) or management personnel. 

• Take no further actions until instructions are received from the RSO. 

• Do not attempt source retrieval until the situation has been discussed with the RSO or 

other knowledgeable personnel. 

• Do not panic. Source retrieval can be performed with very little exposure when properly 

planned by trained personnel who are specifically authorized by the U.S. Nuclear 

Regulatory Commission (NRC) or an Agreement State to conduct source retrieval 

operations. 

• Notify the persons listed below of the situation, in the order shown. 

Name*

Work Phone Number* Home Phone Number*

 

* Fill in with (and update, as needed) the names and telephone numbers of appropriate 

personnel (e.g., the RSO or other knowledgeable licensee staff, licensee’s consultant, 

device manufacturer) to be contacted in case of emergency. 

• Follow the directions provided by the person contacted above. 

Radiation Safety Officer and Licensee Management 

Discuss emergency operating procedures, and ensure no operations are conducted until the 

situation has been discussed with and approved by the RSO or other knowledgeable staff, 

consultants, or device manufacturer. Management should have access to emergency 

equipment to keep doses to radiographers as low as reasonably achievable. Emergency 

equipment may include high-range dosimeters, extra lead shielding, or remote tongs. 

Notify local authorities as well as the NRC as required. (Even if notification is not required, ANY 

incident may be reported to the NRC by calling the agency’s Emergency Operations Center at 

(301) 816-5100, which is staffed 24 hours a day and accepts collect calls.) NRC notification is 

required when sources or devices containing licensed material are lost or stolen and when 
N-2 

radiographic sources or equipment are involved in incidents that may have cause or threaten to 

cause an exposure in excess of the limits found in Title 10 of the Code of Federal Regulations 

(10 CFR) 20.2202, “Notification of incidents.” Reports to the NRC must be made within the 

reporting timeframes specified by the regulations. Notification and reporting requirements are 

found in 10 CFR 20.2201–2203, 10 CFR 21.21, 10 CFR 34.101, and 10 CFR 30.50. 
APPENDIX O 

INFORMATION NEEDED FOR TRANSFER OF CONTROL 

APPLICATION 

O-1 

Information Needed for Transfer of Control Application 

Licensees must provide full information and obtain prior written consent from the 

U.S. Nuclear Regulatory Commission (NRC) before transferring control of the license; some 

licensees refer to this as “transferring the license.” Provide the information listed below 

concerning changes of control by the applicant (transferor and/or transferee, as appropriate). If 

any items are not applicable, so state. 

(1) The new name of the licensed organization. If there is no change, the licensee should 

so state. 

(2) The new licensee contact and telephone number(s) to facilitate communications. 

(3) Any changes in personnel having control over licensed activities (e.g., officers of a 

corporation) and any changes in personnel named in the license, such as radiation 

safety officer, authorized users, or any other persons identified in previous license 

applications as responsible for radiation safety or use of licensed material. The licensee 

should include information concerning the qualifications, training, and responsibilities of 

new individuals. 

(4) An indication of whether the transferor will remain in nonlicensed business without the 

license. 

(5) A complete, clear description of the transaction, including any transfer of stocks or 

assets, mergers, or other actions, so that legal counsel is able, when necessary, to 

differentiate between name changes and transfer of control. 

(6) A complete description of any planned changes in organization, location, facility, 

equipment, or procedures (i.e., changes in operating or emergency procedures). 

(7) A detailed description of any changes in the use, possession, location, or storage of the 

licensed materials. 

(8) Any changes in organization, location, facilities, equipment, procedures, or personnel 

that would require a license amendment even without the transfer of control. 

(9) An indication of whether all surveillance items and records (e.g., calibrations, leak tests, 

surveys, inventories, and accountability requirements) will be current at the time of 

transfer. Provide a description of the status of all surveillance requirements and 

records. 

(10) Confirmation that all records concerning the safe and effective decommissioning of the 

facility, in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 

30.35(g), 10 CFR 40.36(f), 10 CFR 70.25(g), and 10 CFR 72.30(d); public dose; and 

waste disposal by release to sewers, incineration, radioactive material spills, and onsite 

burials have been transferred to the new licensee, if licensed activities will continue at 

the same location, or to the NRC for license terminations. 

(11) A description of the status of the facility. Specifically, document the presence or 

absence of contamination. If contamination is present, will decontamination occur 
O-2 

 before transfer? If not, does the successor company agree to assume full liability for the 

decontamination of the facility or site? 

(12) A description of any decontamination plans, including financial assurance arrangements 

of the transferee, as specified in 10 CFR 30.35, 10 CFR 40.36, and 10 CFR 70.25 (all of 

these sections are entitled, “Financial Assurance and Recordkeeping for 

Decommissioning”). Include information about how the transferee and transferor 

propose to divide the transferor’s assets and responsibility for any cleanup needed at 

the time of transfer. 

(13) Confirmation that the transferee agrees to abide by all commitments and 

representations previously made to the NRC by the transferor. These include, but are 

not limited to maintaining decommissioning records required by 10 CFR 30.35(g), 

implementing decontamination activities and decommissioning of the site, and 

completing corrective actions for open inspection items and enforcement actions. 

With regard to contamination of facilities and equipment, the transferee should confirm, 

in writing, that it accepts full liability for the site and should provide evidence of adequate 

resources to fund decommissioning, or the transferor should provide a commitment to 

decontaminate the facility before transferring control. 

With regard to open inspection items, the transferee should confirm, in writing, that it 

accepts full responsibility for open inspection items and any resulting enforcement 

actions, or the transferee should propose alternative measures for meeting the 

requirements, or the transferor should provide a commitment to close out all such 

actions with the NRC before license transfer. 

(14) Documentation that the transferor and transferee agree to transferring control of the 

licensed material and activity, documentation of the conditions of transfer, and 

documentation that the transferee is made aware of all open inspection items and its 

responsibility for possible resulting enforcement actions. 

(15) A commitment by the transferee to abide by all constraints, conditions, requirements, 

representations, and commitments identified in the existing license. Lacking this, the 

transferee must provide a description of its program to ensure compliance with the 

license and regulations. 
APPENDIX P 

SAFETY CULTURE STATEMENT OF POLICY 

P-1 

Safety Culture

The safety culture policy statement was published in the Federal Register 

(76 FR 34773) on June 14, 2011 and can be found at: 

http://www.gpo.gov/fdsys/pkg/FR-2011-06-14/pdf/2011-14656.pdf. It is also posted in NRC’s 

Agencywide Documents Access and Management System (ADAMS) Accession Number 

ML11146A047. 

Safety Culture Policy Statement 

The purpose of this Statement of Policy is to set forth the Commission’s expectation that 

individuals and organizations establish and maintain a positive safety culture commensurate 

with the safety and security significance of their activities and the nature and complexity of their 

organizations and functions. This includes all licensees, certificate holders, permit holders, 

authorization holders, holders of quality assurance program approvals, vendors and suppliers of 

safety-related components, and applicants for a license, certificate, permit, authorization, or 

quality assurance program approval, subject to NRC authority. The Commission encourages 

the Agreement States, Agreement State licensees and other organizations interested in nuclear 

safety to support the development and maintenance of a positive safety culture, as articulated 

in this Statement of Policy. 

Nuclear Safety Culture is defined as the core values and behaviors resulting from a collective 

commitment by leaders and individuals to emphasize safety over competing goals to ensure 

protection of people and the environment. Individuals and organizations performing regulated 

activities bear the primary responsibility for safety and security. The performance 

of individuals and organizations can be monitored and trended and, therefore, may be used to 

determine compliance with requirements and commitments and may serve as an indicator of 

possible problem areas in an organization’s safety culture. The NRC will not monitor or trend 

values. These will be the organization’s responsibility as part of its safety culture program. 

Organizations should ensure that personnel in the safety and security sectors have an 

appreciation for the importance of each, emphasizing the need for integration and balance to 

achieve both safety and security in their activities. Safety and security activities are closely 

intertwined. While many safety and security activities complement each other, there may be 

instances in which safety and security interests create competing goals. It is important that 

consideration of these activities be integrated so as not to diminish or adversely affect either; 

thus, mechanisms should be established to identify and resolve these differences. A safety 

culture that accomplishes this would include all nuclear safety and security issues associated 

with NRC regulated activities. 

Experience has shown that certain personal and organizational traits are present in a positive 

safety culture. A trait, in this case, is a pattern of thinking, feeling, and behaving that 

emphasizes safety, particularly in goal conflict situations, e.g., production, schedule, and the 

cost of the effort versus safety. It should be noted that although the term ‘‘security’’ is not 

expressly included in the following traits, safety and security are the primary pillars of the NRC’s 

regulatory mission. Consequently, consideration of both safety and security issues, 

commensurate with their significance, is an underlying principle of this Statement of Policy. 

The following are traits of a positive safety culture: 
P-2 

(1) Leadership Safety Values and Actions—Leaders demonstrate a commitment to safety in 

their decisions and behaviors; 

(2) Problem Identification and Resolution—Issues potentially impacting safety are promptly 

identified, fully evaluated, and promptly addressed and corrected commensurate with their 

significance; 

(3) Personal Accountability—All individuals take personal responsibility for safety; 

(4) Work Processes—The process of planning and controlling work activities is implemented so 

that safety is maintained; 

(5) Continuous Learning—Opportunities to learn about ways to ensure safety are sought out 

and implemented; 

(6) Environment for Raising Concerns—A safety conscious work environment is maintained 

where personnel feel free to raise safety concerns without fear of retaliation, intimidation, 

harassment, or discrimination; 

(7) Effective Safety Communication—Communications maintain a focus on safety; 

(8) Respectful Work Environment—Trust and respect permeate the organization; and 

(9) Questioning Attitude—Individuals avoid complacency and continuously challenge existing 

conditions and activities in order to identify discrepancies that might result in error 

or inappropriate action. 

There may be traits not included in this Statement of Policy that are also important in a positive 

safety culture. It should be noted that these traits were not developed to be used for inspection 

purposes. 

It is the Commission’s expectation that all individuals and organizations, performing or 

overseeing regulated activities involving nuclear materials, should take the necessary steps to 

promote a positive safety culture by fostering these traits as they apply to their organizational 

environments. The Commission recognizes the diversity of these organizations and 

acknowledges that some organizations have already spent significant time and resources in 

the development of a positive safety culture. The Commission will take this into consideration 

as the regulated community addresses the Statement of Policy.
BIBLIOGRAPHIC DATA SHEET

(See instructions on the reverse)

NRC FORM 335

(12-2010)

NRCMD 3.7

U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

 (Assigned by NRC, Add Vol., Supp., Rev.,

 and Addendum Numbers, if any.)

NUREG-1556, Volume 2,

Revision 1

3. DATE REPORT PUBLISHED

MONTH

November

YEAR

2011

4. FIN OR GRANT NUMBER

2. TITLE AND SUBTITLE

Consolidated Guidance About Materials Licenses: Program-Specific Guidance About Industrial

Radiography Licenses (NUREG-1556, Volume 2, Revision 1) - Draft Report for Comment

5. AUTHOR(S)

J. Bruce Carrico, Lisa Dimmick, Craig Gordon, Toye Simmons, Roberto Torres, and Ann Troxler

6. TYPE OF REPORT

Technical

7. PERIOD COVERED (Inclusive Dates)

August 1998 to November 2011

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address; if contractor,

Division of Materials Safety and State Agreements

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type "Same as above"; if contractor, provide NRC Division, Office or Region, U.S. Nuclear Regulatory Commission, 

Same as above

provide name and mailing address.)

and mailing address.)

10. SUPPLEMENTARY NOTES

11. ABSTRACT (200 words or less)

This technical report contains informaiton intended to provide program-specific guidance and assist applicants and licensees in

preparing applications for materials licenses for industrial radiography. In particular, it describes the types of informaiton needed

to complete U.S. Nuclear Regulatory Commission (NRC) Form 313, "Application for Materials Licenses." This document

describes both the methods acceptable to the NRC license reviewers in implementing the regulations and the techniques used

by the reviewers in evaluating the application to determine if the proposed activities are acceptable for licensing purposes.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.)

NUREG-1556

Volume 2

Radiography

Industrial Radiography

License

14. SECURITY CLASSIFICATION

13. AVAILABILITY STATEMENT

unlimited

(This Page)

unclassified

(This Report)

unclassified

15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (12-2010)

Office of Federal and State Material and Environmental Management Programs

11545 Rockville Pike

Rockville, MD 20852


UNITED STATES 

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

--------------------

OFFICIAL BUSINESS
NUREG-1556, Vol. 2

Rev. 1, Draft

Consolidated Guidance About Materials Licenses: Program-Specific 

Guidance About Industrial Radiography Licenses