Consolidated Guidance 

About Materials Licenses

Program-Specific Guidance About 

Industrial Radiography Licenses

Final Report

Office of Nuclear Material Safety and Safeguards

NUREG-1556

Volume 2, Rev. 1 
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Consolidated Guidance 

About Materials Licenses

Program-Specific Guidance About 

Industrial Radiography Licenses

Final Report

Manuscript Completed: October 2015

Date Published: February 2016

Prepared by: 

J. B. Carrico

R. Clark

L. Dimmick

C. Gordon

T. Simmons

R. J. Torres

Office of Nuclear Material Safety and Safeguards

 

NUREG-1556

Volume 2, Rev. 1 

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. 

Paperwork Reduction Act Statement 

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 (OMB), approval numbers 3150-0014; 3150-0035; 

3150-0017; 3150-0001; 3150-0007; 3150-0214; 3150-0008; and 3150-0120. 

Public Protection Notification 

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.

v 

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: 

Volume 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 Including Electron Capture Devices and X-Ray 

Fluorescence Analyzers 

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 

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 Program-Specific Guidance About Possession Licenses for Production of 

Radioactive Materials Using an Accelerator 

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, and NRC staff. This revision provides a general 

update to the previous information contained in NUREG–1556, Volume 2, issued August 1998. 

See Appendix A of this NUREG for a list of documents considered in the development of this 

NUREG–1556 report. 
vi 

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

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 or Agreement State 

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 NRC staff to make the determinations needed to issue or renew 

a license. 

The comments received during the public comment period for NUREG–1556, Volume 2, 

Revision 1, were summarized and addressed in a document that can be located on the NRC’s 

Agencywide Documents and Management System (ADAMS) under ML15033A308. Access to 

ADAMS is available on the public Web site at: http://www.nrc.gov/reading-rm/adams.html. The 

comments received by NRC included general corrections, comments on training, and comments 

on safety culture. 

_______________________________________________________ 

Josephine M. Piccone, Director 

Division of Material Safety, State, Tribal, and Rulemaking Programs 

Office of Nuclear Material Safety and Safeguards
vii 

TABLE OF CONTENTS 

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

FORWARD ................................................................................................................................... v 

FIGURES ..................................................................................................................................... xi 

TABLES ....................................................................................................................................... xi 

ACKNOWLEDGMENTS ............................................................................................................ xiii 

ABBREVIATIONS ...................................................................................................................... xv 

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

2 AGREEMENT STATES ................................................................................................. 2-1

2.1 Jurisdiction Determination .................................................................................. 2-1

2.2 Reciprocal Recognition of Specific Licenses ...................................................... 2-3

3 MANAGEMENT RESPONSIBILITY .............................................................................. 3-1

3.1 Commitments and Responsibilities .................................................................... 3-1

3.2 Safety Culture ..................................................................................................... 3-2

4 APPLICABLE REGULATIONS ..................................................................................... 4-1

5 HOW TO FILE ................................................................................................................ 5-1

5.1 Application Preparation ...................................................................................... 5-1

5.2 Where to File ...................................................................................................... 5-1

5.3 Paper Applications ............................................................................................. 5-2

5.4 Electronic Applications ....................................................................................... 5-2

6 IDENTIFYING AND PROTECTING SENSITIVE INFORMATION ................................. 6-1

7 APPLICATION AND LICENSE FEES ........................................................................... 7-1

8 CONTENTS OF AN APPLICATION .............................................................................. 8-1

8.1 Item 1: License Action Type .............................................................................. 8-1

8.2 Item 2: Name and Mailing Address of Applicant................................................ 8-2

8.2.1 Notification of Bankruptcy Proceedings ............................................... 8-2

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

or Possessed ...................................................................................................... 8-2

8.4 Item 4: Person To Be Contacted about This Application ................................... 8-4

8.5 Item 5: Radioactive Material .............................................................................. 8-5

8.5.1 Sealed Sources and Devices ............................................................... 8-5

8.5.2 Financial Assurance and Recordkeeping for Decommissioning .......... 8-7

8.6 Item 6: Purpose(s) for Which Licensed Material Will Be Used .......................... 8-8

8.7 Item 7: Individual(s) Responsible for Radiation Safety Program and 

Their Training and Experience ........................................................................... 8-9

8.7.1 Radiation Safety Officer ....................................................................... 8-9

8.8 Item 8: Training for Radiographers and Radiographer’s Assistants ................ 8-11

8.9 Item 9: Facilities and Equipment ..................................................................... 8-14

8.10 Item 10: Radiation Safety Program ................................................................. 8-19

8.10.1 Audit and Review of Program ............................................................ 8-20

8.10.2 Radiation Monitoring Instruments ...................................................... 8-22

8.10.3 Material Receipt and Accountability ................................................... 8-22
viii 

8.10.4 Minimization of Contamination ........................................................... 8-25

8.10.5 Leak Tests ......................................................................................... 8-26

8.10.6 Occupational Dose ............................................................................ 8-27

8.10.7 Public Dose ........................................................................................ 8-29

8.10.8 Quarterly Maintenance ...................................................................... 8-30

8.10.9 Operating and Emergency Procedures ............................................. 8-31

8.10.9.1 Operating and Emergency Procedures: Handling 

and Use of Sealed Sources and Radiography 

Exposure Devices ........................................................... 8-34

8.10.9.2 Operating and Emergency Procedures: Methods 

and Occasions for Conducting Required Radiation 

Surveys ........................................................................... 8-35

8.10.9.3 Operating and Emergency Procedures: Methods 

for Controlling Access to Radiographic Areas ................ 8-36

8.10.9.4 Operating and Emergency Procedures: Methods 

and Occasions for Locking and Securing 

Radiographic Exposure Devices, Storage 

Containers, and Sealed Sources .................................... 8-40

8.10.9.5 Operating and Emergency Procedures: Personnel 

Monitoring and the Use of Personnel Monitoring 

Equipment ...................................................................... 8-41

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 ........ 8-43

8.10.9.7 Operating and Emergency Procedures: Daily 

Inspection and Maintenance of Radiographic 

Equipment ...................................................................... 8-44

8.10.9.8 Operating and Emergency Procedures: Ratemeter 

Alarms or Off-Scale Dosimeter Readings ....................... 8-46

8.10.9.9 Procedure for Identifying and Reporting Defects 

and Noncompliance As Required By 

10 CFR Part 21 ............................................................... 8-47

8.10.9.10 Notification of Proper Persons in the Event of an 

Accident or Emergency .................................................. 8-47

8.10.9.11 Minimizing Exposure of Persons in the Event of an 

Accident or Emergency .................................................. 8-50

8.10.9.12 Source Recovery (Retrieval) .......................................... 8-50

8.10.9.13 Maintenance of Records ................................................. 8-53

8.10.10 Security Program for Category 1 and Category 2 Radioactive 

Material .............................................................................................. 8-54

8.11 Item 11: Waste Management .......................................................................... 8-55

8.11.1 Disposal or Transfer of Radiography Sealed Sources 

Containing Byproduct Material or Devices Containing Depleted 

Uranium ............................................................................................. 8-55

8.12 Item 12: License Fees ..................................................................................... 8-56

8.13 Item 13: Certification ....................................................................................... 8-56

9 LICENSE AMENDMENTS AND RENEWALS ............................................................... 9-1

9.1 Timely Notification of Transfer of Control ........................................................... 9-1
ix 

10 APPLICATIONS FOR EXEMPTIONS ......................................................................... 10-1

11 TERMINATION OF ACTIVITIES ................................................................................. 11-1

APPENDICES 

APPENDIX A LIST OF DOCUMENTS CONSIDERED IN DEVELOPMENT OF 

 THIS NUREG ............................................................................................. A–1 

APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION FORM 313 ..................... B–1 

APPENDIX C SUGGESTED FORMAT FOR PROVIDING INFORMATION 

 REQUESTED IN ITEMS 5 THROUGH 11 OF U.S. NUCLEAR 

 REGULATORY COMMISSION FORM 313 ............................................... C–1 

APPENDIX D LICENSING GUIDANCE FOR LAY–BARGE, OFFSHORE PLATFORM, 

AND UNDERWATER RADIOGRAPHY ..................................................... D–1 

APPENDIX E RADIOGRAPHER AND RADIOGRAPHER’S ASSISTANT TRAINING .... E–1 

APPENDIX F SIX–MONTH RADIOGRAPHER/RADIOGRAPHER'S ASSISTANT 

INSPECTION CHECKLIST ......................................................................... F–1 

APPENDIX G RADIATION SAFETY PROGRAM AUDIT ................................................. G–1 

APPENDIX H MODEL RADIATION SURVEY INSTRUMENT CALIBRATION 

PROGRAM ................................................................................................ H–1 

APPENDIX I REQUESTS TO PERFORM LEAK TESTING AND SAMPLE 

ANALYSIS .................................................................................................. I–1 

APPENDIX J GUIDANCE FOR DEMONSTRATING THAT INDIVIDUAL 

MEMBERS OF THE PUBLIC WILL NOT RECEIVE DOSES 

EXCEEDING THE ALLOWABLE LIMITS .................................................. J–1 

APPENDIX K INFORMATION FOR APPLICANTS TO CONSIDER WHEN 

DEVELOPING PROCEDURES FOR OPERATING RADIOGRAPHY 

EQUIPMENT .............................................................................................. K–1 

APPENDIX L TRANSPORTATION............ ....................................................................... L–1 

APPENDIX M DAILY MAINTENANCE CHECK OF RADIOGRAPHIC EQUIPMENT ...... M–1 

APPENDIX N SUGGESTED EXAMPLE OF A ROUTINE 

EMERGENCY PROCEDURE .................................................................... N–1 

APPENDIX O MODEL DELEGATION OF AUTHORITY .................................................. O–1 

APPENDIX P CHECKLIST FOR REQUESTS TO WITHHOLD PROPRIETARY 

 INFORMATION FROM PUBLIC DISCLOSURE 

 (UNDER 10 CFR 2.390) .............................................................................. P–1 

APPENDIX Q SAFETY CULTURE POLICY STATEMENT .............................................. Q–1

xi 

FIGURES 

Figure Page 

2-1 U.S. Map: Locations of NRC Offices and Agreement States. ....................................... 2-1 

8-1 Location of Use or Possession. ...................................................................................... 8-4 

8-2 Typical Duties and Responsibilities of RSOs. .............................................................. 8-11 

8-3 Example Diagram of a Permanent Radiographic Installation ....................................... 8-16 

8-4 Material Receipt and Accountability ............................................................................. 8-25 

8-5 Annual Dose Limits for Occupationally Exposed Adults. .............................................. 8-28 

8-6 Posting ......................................................................................................................... 8-38 

8-7 Surveillance and Posting at a Temporary Jobsite With Multiple Floors and 

 Access Points ............................................................................................................... 8-39 

8-8 Security. ....................................................................................................................... 8-41 

8-9 The Well-Dressed Radiographer. ................................................................................. 8-42 

8-10 Transportation. ............................................................................................................. 8-43 

8-11 Emergency Procedures. ............................................................................................... 8-52

D–1 Offshore Platform ......................................................................................................... D–1 

D–2 Lay-Barge ..................................................................................................................... D–3 

J–1 Diagram of Office and Radiography Exposure Device Storage Area............................ J–3 

TABLES 

Table Page 

2-1 Who Regulates the Activity? .......................................................................................... 2-2 

3-1 Traits of a Positive Safety Culture .................................................................................. 3-3 

8-1 Record Maintenance .................................................................................................... 8-24 

8-2 Surveys Required for Radiographic Operations ........................................................... 8-35 

8-3 Regulatory-Required Notifications ............................................................................... 8-48 

E–1 10 CFR Part 34, “Radiographer and Radiographer's Assistant 

 Training Requirements” ................................................................................................. E–1 

J–1 Information Known About Each Device ......................................................................... J–2 

J–2 Calculational Method, Part 1: Hourly and Annual Dose Received From Device 1 ....... J–3 

J–3 Calculational Method, Part 1: Hourly and Annual Dose Received From Device 2 ....... J–4 

J–4 Calculational Method, Part 1: Total Hourly and Annual Dose Received From 

 Devices 1 and 2 ............................................................................................................ J–4 

J–5 Calculational Method, Part 2: Annual Dose Received From Devices 1 and 2 ............. J–5 

J–6 Calculational Method, Part 3: Summary of Information ................................................ J–6 

J–7 Calculational Method, Part 3: Annual Dose Received From Devices 1 and 2 ............. J–6 

J–8 Approximate Half-Value Layers for Typical Shielding Materials in Inches .................... J–7 

J–9 Calculational Method, Part 4: Annual Dose Received From Devices 1 and 2 ............. J–8 

J–10 Combination Measurement–Calculational Method ....................................................... J–9 

xiii 

ACKNOWLEDGMENTS 

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 

that assisted in the development of this report. 

The working group also thanks Lisa Dimmick, John O’Donnell, Monica Ford, Tara Weidner, 

Tomas Herrera, and Duane White for developing the formatting and language used in many 

parts of the report. 

The Participants for this Revision 

Bielecki, Jessica 

Carrico, J. Bruce 

Chidakel, Susan 

Clark, Russell 

Dimmick, Lisa 

Gordon, Craig 

Olmstead, Joan 

Simmons, Toye 

Torres, Roberto J. 

Troxler, Ann 

Wright, Megan

xv 

ABBREVIATIONS 

ADAMS Agencywide Documents Access Management System 

AEA Atomic Energy Act 

ALARA as low as is reasonably achievable 

ANSI American National Standards Institute 

bkg background 

Bq becquerel 

CFR Code of Federal Regulations 

Ci curie 

cm centimeter 

Co cobalt-60 

COC certificate of compliance 

cpm counts per minute 

DOJ U.S. Department of Justice 

DOT U.S. Department of Transportation 

dpm disintegrations per minute 

DU depleted uranium 

ft foot 

GBq Gigabecquerel 

GPO Government Printing Office 

GPS global positioning system 

Gy gray 

h hour 

HVL half-value layer 

IN information notice 

Ir iridium-192 

μCi microcurie 

LLEA local law enforcement agency 

MDA minimum detectable activity 

m meter 

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 Material Safety and Safeguards 

NRC U.S. Nuclear Regulatory Commission 

NSTS National Source Tracking System 

NSTTR National Source Tracking Transaction Reports 

NVLAP National Voluntary Laboratory Accreditation Program 

OMB Office of Management and Budget 

PII Personally Identifiable Information 

R roentgen 

RIS regulatory issue summary 

RQ reportable quantities 

RSO radiation safety officer 

SSD sealed source and device 

SSR Suggested State Regulations 

std standard 
xvi 

Sv sievert 

TBq Terabecquerel 

TEDE total effective dose equivalent 

T time 

TI Transport Index 

TLD thermoluminescent dosimeter 

U.S.C. United States Code
1-1 

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, as authorized under the Title 10 of the Code of 

Federal Regulations (10 CFR) Part 34, “Licenses for Industrial Radiography and Radiation 

Safety Requirements for Industrial Radiographic Operations.” The radionuclides most 

commonly used for radiography are cobalt-60 and iridium-192; however, other radionuclides 

(e.g., californium-252, ytterbium-169, selenium-75) with unique radiological characteristics might 

also be used. This report does not address the research and development of radiography 

devices and associated equipment, or the commercial aspects of manufacturing, distribution, 

and service of such devices or equipment. 

Chapter 8, “Contents of an Application,” of this guide identifies the information needed to 

complete NRC Form 313, “Application for Materials License,” (see Appendix B of this NUREG) 

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 

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

10 CFR Part 34 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 about the topic. 

• Response from Applicant—provides suggested response(s), 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 of this NUREG 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, NUREG–1556, 

Volume 2, Revision 1, Appendix C, “Suggested Format for Providing Information Requested in 

Items 5 through 11 of NRC 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.” To describe units of radiation exposure or dose, rem and its International 
1-2 

System of Units equivalent, sievert (Sv) [1 rem = 0.01 Sv], are used. This is done because 

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

radioactive material emits beta and gamma rays, 1 roentgen is assumed to equal 1 rad, which is 

assumed to equal 1 rem. For alpha and neutron–emitting radioactive material, 1 rad is not 

equal to 1 rem. Determination of dose equivalent (rem) from absorbed dose (rad) from alpha 

particles and neutrons 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 and 

neutrons.
2-1 

2 AGREEMENT STATES 

2.1 Jurisdiction Determination 

Certain States, called Agreement States (see Figure 2-1), have entered into agreements with 

the U.S. Nuclear Regulatory Commission (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, which are used or 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. These applications should be filed with State officials, not with the NRC. In areas 

under exclusive Federal jurisdiction within an Agreement State, NRC continues to be the 

regulatory authority. 

Figure 2-1. U.S. Map: Locations of NRC Offices and Agreement States 

 
2-2 

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

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

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

Indian Tribes.2

 

The NRC has regulatory authority over land determined to be “exclusive Federal jurisdiction,” 

while the Agreement State may have 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. Additional guidance on determining 

jurisdictional status is found in the Office of Nuclear Material Safety and Safeguards (NMSS) 

procedures in the State Agreement (SA) series, SA-500, “Jurisdiction Determination,” which is 

available at https://scp.nrc.gov/. Once on the Web site, use the link for “NMSS Procedures” in 

the left-hand column under “Resources & Tools.” 

Table 2-1 provides a quick way to evaluate 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, regardless of location (except that 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 U.S. Department of Energy and 

U.S. 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 

Federally recognized Indian Tribe or tribal member on Indian Tribal land NRC 

Non-Federal entity on federally recognized Indian Tribal land NRC3

Federally recognized Indian Tribe or tribal member outside of Indian 

Tribal land in Agreement State 

Agreement State 

Non-Federal entity in Agreement State Agreement State4

 

2

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.bia.gov.

3

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 may be States that exercise regulatory authority over these areas, based on treaties or agreements with 

specific tribes. 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 

determine the jurisdictional status of the tribal lands and identify the appropriate regulatory agency for licensing 

and reciprocity. 

4

Section 274m. of the Atomic Energy Act (AEA) withholds to the NRC regulatory authority over radioactive materials 

covered under the Section 274b. agreements when the activity can affect the Commission’s authority to protect the 

common defense and security, to protect restricted data, or guard against the loss or diversion of special nuclear 

material. (This is an uncommon situation, that NRC usually evaluates on a case-by-case basis.) Individuals or 

companies wishing to possess or use licensed material should contact the licensee to determine the jurisdictional 

status for specific AEA radioactive materials they intend to possess or use. 
2-3 

Table 2-1. Who Regulates the Activity? 

Applicant and Proposed Location of Work Regulatory Agency

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

subject to exclusive Federal jurisdiction 

Agreement State4

Non-Federal entity in Agreement State at federally controlled site subject 

to exclusive Federal jurisdiction 

NRC 

Non-Federal entity in Agreement State conducting industrial radiography 

at a Part 50 or 52 reactor site, including construction, preoperational, and 

operational phases 

Agreement State 

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

numbers of responsible officials) is available at https://scp.nrc.gov. A request for the list can 

also be made to an NRC regional office. 

2.2 Reciprocal Recognition of Specific Licenses 

Performing licensed activities in other jurisdictions is possible through reciprocal recognition of 

specific licenses (i.e., reciprocity). Agreement States have reciprocity provisions that permit 

NRC licensees to perform licensed activities under circumstances when an Agreement State is 

the regulatory authority (See Section 2.1). NRC licensees and Agreement State licensees are 

subject to the regulations of the regulatory authority as indicated in Section 2.1. To ensure 

compliance with an Agreement State’s reciprocity requirements, licensees are advised to 

request authorization from the appropriate Agreement State radiation control program office well 

in advance of the scheduled use of licensed material. 

Agreement State licensees that wish to conduct licensed activities in areas under NRC 

jurisdiction must either obtain a specific NRC license or file for reciprocity with the appropriate 

NRC regional office for the Agreement State that issued their license. Failure to file for 

reciprocity or obtain a specific NRC license before working in areas under NRC jurisdiction can 

result in NRC enforcement action, which may include civil penalties. The reciprocity filing must 

be renewed annually. 

Specific guidance regarding NRC licensees filing for reciprocity in Agreements States and 

Agreement State licensees filing for reciprocity with the NRC or another Agreement State are 

provided in NUREG–1556, Volume 19, “Consolidated Guidance About Materials 

Licenses: 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).” 

3-1 

3 MANAGEMENT RESPONSIBILITY 

The U.S. Nuclear Regulatory Commission (NRC) recognizes that effective management of 

radiation safety programs is vital to achieving safe, secure, 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, 

security, and compliance. 

“Management,” as used in this volume, 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. 

3.1 Commitments and Responsibilities 

Pursuant to the Title 10 of the Code of Federal Regulations (10 CFR) 30.32(c), each application 

must be signed by the applicant or licensee or a person duly authorized to act for and on behalf 

of the applicant or licensee. If it is not clear whether the application was signed by someone 

duly authorized to act for and on behalf of the applicant or licensee, NRC license reviewers may 

ask for additional assurances that the individual who signed the application is duly authorized to 

act for and on the behalf of the applicant or licensee. The signature on an application 

acknowledges the licensee’s commitments and responsibilities, including the following: 

• to ensure radiation safety, security, and control of radioactive materials and compliance 

with regulations; 

• to ensure that radiation safety records and all information provided to the NRC are 

complete and accurate (10 CFR 30.9, “Completeness and accuracy of information”); 

• to affirm the licensee’s knowledge about the contents of the license and application; 

• to comply with NRC and Department of Transportation (DOT) regulations, the licensee’s 

operating, emergency, and security procedures, and NRC license commitments; 

• 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; 

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

• to select and assign 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; 

• to ensure that radiation workers have adequate training; 

• to prevent discrimination of employees engaged in protected activities 

(10 CFR 30.7, “Employee protection”); 
3-2 

• to provide information to employees about the employee protection and deliberate 

misconduct provisions in 10 CFR 30.7, “Employee protection,” and 10 CFR 30.10, 

“Deliberate misconduct;” 

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

(see Section 9.1, “Timely Notification of Transfer of Control,” of this NUREG); and 

• to notify 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, “Notification of Bankruptcy Proceedings,” of 

this NUREG. 

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, under “Document Collections,” at http://www.nrc.gov/reading-rm.html. 

3.2 Safety Culture 

Individuals and organizations performing regulated activities are expected to 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 safety-related components, and 

applicants for a license, certificate, permit, authorization, or quality assurance program approval, 

subject to NRC authority. 

“Nuclear safety culture” is defined in the NRC’s safety culture policy statement (76 FR 34773; 

June 14, 2011) 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). Refer to Table 3-1 for the traits of a positive safety culture 

from NRC’s safety culture policy statement. 

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. 

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. Safety 
3-3 

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 safety culture trait specified in Table 3-1 as 

“Continuous Learning” (opportunities to learn about ways to ensure safety are sought out and 

implemented). However, licensees should be aware that this is just an example, and should 

consider reviewing their radiation safety programs in order to develop and implement a safety 

culture commensurate with the nature and complexity of their organizations and functions. 

Refer to Appendix Q of this NUREG 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/about-nrc/safety-culture.html. 

Table 3-1. Traits of a Positive Safety Culture 

Leadership Safety Values

and Actions

Problem Identification and 

Resolution Personal Accountability

Leaders demonstrate a 

commitment to safety in their 

decisions and behaviors. 

Issues potentially impacting 

safety are promptly identified, 

fully evaluated, and promptly 

addressed and corrected, 

commensurate with their 

significance. 

All individuals take personal 

responsibility for safety. 

Work Processes Continuous Learning

Environment for Raising 

Concerns

The process of planning and 

controlling work activities is 

implemented so that safety is 

maintained. 

Opportunities to learn about 

ways to ensure safety are 

sought out and implemented. 

A safety conscious work 

environment is maintained 

where personnel feel free to 

raise safety concerns without 

fear of retaliation, 

intimidation, harassment, 

or discrimination. 

Effective Safety 

Communications

Respectful Work 

Environment Questioning Attitude

Communications maintain a 

focus on safety. 

Trust and respect permeate 

the organization. 

Individuals avoid 

complacency and 

continuously challenge 

existing conditions and 

activities in order to identify 

discrepancies that might 

result in error or inappropriate 

action. 

4-1 

4 APPLICABLE REGULATIONS 

It is the applicant’s or licensee’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 (10 CFR) 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 10 CFR regulations can be found under the “Basic References” 

link at the U.S. Nuclear Regulatory Commission’s (NRC’s) online library at 

http://www.nrc.gov/reading-rm.html. For viewing in a browser, the following list includes direct 

links to the rules: 

• 10 CFR Part 2 “Agency Rules of Practice and Procedure” 

• 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 37 “Physical Protection of Category 1 and Category 2 Quantities of 

 Radioactive Material” 

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

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

• 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” 

 
4-2 

• 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 these documents may be obtained by calling the Government Publishing Office 

Customer Contact Center toll free at 866-512-1800, in Washington, DC; calling 202-512-1800; 

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

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 can also be accessed from the “NRC Library” link on the NRC’s public Web 

site at http://www.nrc.gov. Regulations are periodically amended, and the NRC (as well as all 

other Federal agencies) is required to publish notice of such amendments in the 

Federal Register.
5-1 

5 HOW TO FILE 

5.1 Application Preparation 

Applicants for a materials license should do the following: 

• Use the most recent guidance in preparing an application. 

• Complete the U.S. Nuclear Regulatory Commission (NRC) Form 313 (Appendix B of this 

NUREG), Items 1 through 4, 12, and 13, on the form itself. A link to the form is available 

at http://www.nrc.gov/reading-rm/doc-collections/forms/. 

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

Appendix C of this NUREG. 

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

experience, and 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 pages, as 

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

application or the topic to which it refers. 

• Avoid submitting proprietary information and personally identifiable information. If 

submitted, proprietary, personal privacy, security-related, and other sensitive information 

should be clearly identified according to Title 10 of the Code of Federal Regulations

(10 CFR) 2.390, “Public inspections, exemptions, requests for withholding” (see 

Chapter 6, “Identifying and Protecting Sensitive Information”). 

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 the 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 determine 

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

States,” for additional information. 

 
5-2 

5.3 Paper Applications 

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 all documents, typed, on 81⁄2 × 11-inch or legal-sized paper that will feed easily 

into a document scanner. 

• Choose typeface designs that are sans serif, such as Arial, Helvetica, or Futura. 

• Use an 11-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). 

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, “Certification”). 

5.4 Electronic Applications 

Applications may be submitted in electronic form via the NRC’s Electronic Information 

Exchange, or CD-ROM. Detailed guidance on making electronic submissions can be obtained 

by visiting the NRC’s Web site at http://www.nrc.gov/site-help/e-submittals.html. The guidance 

discusses, among other topics, the formats the NRC can accept, the use of electronic 

signatures, and the treatment of nonpublic information.
6-1 

6 IDENTIFYING AND PROTECTING SENSITIVE INFORMATION 

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

available for review in the U.S. Nuclear Regulatory Commission (NRC) Public Document Room 

and electronically at the NRC Library. For more information on the NRC Library, visit 

www.nrc.gov. 

The applicant or licensee should identify, mark, and protect sensitive information against 

unauthorized disclosure to the public. License applications that contain sensitive information 

should be marked as indicated below, in accordance with Title 10 of the Code of Federal 

Regulations (10 CFR) 2.390, before the information is submitted to the NRC. Key examples are 

as follows: 

• Proprietary Information and 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. Appendix P includes a checklist for 

requests for withholding information from public disclosure. 

• Personally Identifiable Information: Personally identifiable information (PII) about 

employees or other individuals should not be submitted unless specifically requested by 

the NRC. Examples of PII are social security number, home address, home telephone 

number, date of birth, and radiation dose information. If PII is submitted, a cover letter 

should clearly state that the attached documents contain PII, and the top of every page 

of a document that contains PII should be clearly marked as follows: “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, and Information Notice (IN) 

2013-22, “Recent Licensing Submittals Containing Personally Identifiable Information,” 

dated November 15, 2013, which can be found on the NRC’s Generic Communications 

Web page under “Regulatory Issue Summaries” and “Information Notices,” respectively: 

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

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

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

plan or execute an attack against facilities or citizens in the U.S. 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, a cover letter should clearly state that 

the attached documents contain sensitive security-related information and the top of 

every page of a document that contains such information should be clearly marked: 

“Security Related Information—Withhold under 10 CFR 2.390.” For the pages having 

security-related sensitive information, an additional marking should be included (e.g., an 

editorial note box) adjacent to that material. 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 Web page under “Regulatory Issue 

Summaries”: http://www.nrc.gov/reading-rm/doc-collections/gen-comm/. Additional 
6-2 

information on procedures and any updates is available at http://www.nrc.gov/readingrm/sensitive-info.html. 

The regulations list various forms of information that can be protected from public disclosure. 

These include: 

• trade secrets and commercial or financial information 

• interagency or intragency memoranda or letters that would not be available by law to a 

party other than an agency in litigation with NRC 

• certain records or information compiled for law enforcement purposes 

• geological and geophysical information and data, including maps, or information 

concerning wells 

• personnel, medical, or other information, the disclosure of which would constitute a 

clearly unwarranted invasion of personal privacy 

In 10 CFR 2.390, NRC specifies the procedures and requirements for persons to submit 

sensitive information to NRC so that it may be properly protected from disclosure. This 

regulation is available electronically on the NRC Web site: http://www.nrc.gov/reading-rm/doccollections/cfr. 

Except for personal privacy information, which is not subject to the affidavit requirement, if NRC 

determines that the application or affidavit is deficient (i.e., does not contain the required 

information as outlined in 10 CFR 2.390), the applicant will be notified that additional information 

is needed and that the review will continue when the required information is received. 

If the request is denied, in whole or in part, NRC will give the applicant the option of withdrawing 

the information or application, as permitted in 10 CFR 2.390. If the applicant decides not to 

withdraw the information or application, NRC will notify the applicant in writing that the request 

for withholding has been denied and that NRC will disregard any references concerning the 

proprietary status of the information. 

Any part of a license application or information provided by a licensee or applicant that the NRC 

determines should be withheld from public disclosure will be handled in accordance with 

Management Directive 12.6, “NRC Sensitive Unclassified Information Security Program,” and 

the licensee or applicant will be notified in writing that NRC plans to honor the request. 

Management Directive 12.6 is available electronically on the NRC Web site: 

http://www.nrc.gov/reading-rm/doc-collections/management-directives/. 
6-3 

Anyone submitting a request to withhold information from public disclosure should thoroughly 

review 10 CFR 2.390 and be familiar with its requirements and limitations. 

Withholding from public inspection shall not affect the right, if any, of persons properly and 

directly concerned to inspect the documents. If the need arises, NRC may send copies of this 

information to NRC consultants working in that area. NRC will ensure that the consultants have 

signed the appropriate agreements for handling proprietary information. 

If the basis for withholding this information from public inspection should change in the future, 

such that the information could then be made available for public inspection, the licensee or 

applicant should promptly notify the NRC. The licensee or applicant also should understand 

that NRC may have cause to review this determination in the future; for example, if the scope of 

a Freedom of Information Act request includes the information in question. In all review 

situations, if NRC makes a determination adverse to the above, the licensee or applicant will be 

notified in advance of any public disclosure. Anyone submitting commercial or financial 

information they believe to be privileged, confidential, or a trade secret must remember that the 

NRC’s policy is to achieve an effective balance between legitimate concerns for the protection 

of competitive positions and the right of the public to be fully apprised of the basis for, and the 

effects of, licensing or rulemaking actions. It is within NRC’s discretion to withhold such 

information from public disclosure. 

7-1 

7 APPLICATION AND LICENSE FEES 

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

Refer to Title 10 of the Code of Federal Regulations (10 CFR) 170.31, “Schedule of fees for 

materials licenses and other regulatory services, including inspections, and import and export 

licenses,” to determine the amount of the fee. The U.S. Nuclear Regulatory Commission (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 of an application has 

begun, no fees will be refunded. Application fees will be charged regardless of the NRC’s 

disposition of an application or the withdrawal of an application. 

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

Note that in order to pay reduced fees, a licensee that qualifies as a “small entity” must provide 

proper certification of this status to the NRC each year along with its annual fee payment. 

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. 

8-1 

8 CONTENTS OF AN APPLICATION 

The following information applies to the indicated items on the U.S. Nuclear Regulatory 

Commission (NRC) Form 313 (Appendix B of this NUREG). 

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

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

security programs satisfy regulatory requirements and are adequate to protect public health and 

safety and minimize danger to life and property. Consideration should be given, when 

developing the application, to the concepts of keeping exposure as low as is reasonably 

achievable (ALARA), minimizing contamination, and maintaining control of radioactive materials. 

Title 10 of the Code of Federal Regulations (10 CFR) 20.1101(b) states, “The licensee shall 

use, to the extent practical, 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 Is Reasonably Achievable,” 

discusses the ALARA concept and philosophy. The application should document ALARA 

considerations, including establishing administrative action levels and monitoring programs. 

10 CFR 20.1406, “Minimization of contamination,” 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 these 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. 

8.1 Item 1: License Action Type 

Item 1 of NRC Form 313 states the following: 

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. Note that a prelicensing visit may be conducted prior to 

issuance of the license. Also note that an initial security inspection may be conducted in 

accordance with NRC Inspection Manual Chapter 2800, “Materials Inspection Program,” before 

issuance of the license. 

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

Check box C for a renewal of an existing license and provide the license number. See “License 

Amendments and Renewals” in Chapter 9 of this report. 
8-2 

8.2 Item 2: Name and Mailing Address of Applicant 

List the legal name of the applicant’s corporation or other legal entity with direct control over use 

of the radioactive material. A division or department within a legal entity may not be a licensee. 

An individual may be designated as the applicant only if the individual is acting in a private 

capacity and the use of the radioactive material is not connected with employment in a 

corporation or other legal entity. Provide the mailing address where correspondence should be 

sent. 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 and the transfer approved before control of the license is 

transferred (see Section 9.1, “Timely Notification of Transfer of Control”). The NRC must also 

be notified when bankruptcy proceedings have been initiated (see Section 8.2.1, “Notification of 

Bankruptcy Proceedings”). 

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 

subject to all applicable NRC regulatory requirements. The NRC must be notified 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, and the NRC may request that the U.S. Department of 

Justice (DOJ) represent the NRC’s interests in the bankruptcy proceeding. 

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

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

involuntary petition for bankruptcy by or against the licensee. 

Reference: See NUREG–1556, Volume 15, “Consolidated Guidance About Materials 

Licenses: 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) for each 

facility. The descriptive address should be sufficient to allow an NRC inspector to find the 

facility location. A post office box address is not acceptable (see Figure 8-1). In addition, 

applicants are encouraged to provide global positioning system (GPS) coordinates, as 

appropriate, 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 
8-3 

the applicant will dispatch equipment to jobsites. 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 license amendment is required before receiving, using, or storing licensed material at an 

address or location not already listed on the license. 

An NRC license does not relieve a licensee from complying with other applicable Federal, State, 

or local regulations (e.g., local zoning requirements). 

If an applicant submits documents that give the exact location of use and storage for any 

amount of radioactive material, the applicant should mark these documents as “Security Related 

Information—Withhold under 10 CFR 2.390.” See Chapter 6, “Identifying and Protecting 

Sensitive Information,” for more details. 

Response from Applicant: 

• If a device will be used in a permanent radiographic installation, provide the specific 

address of each location. If applicable, describe the locations of use of the property 

outside of the installation where radiographic operations will be conducted. 

• If radiography equipment will be stored or used at a field station, provide the specific 

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

describe the locations outside of the field station where radiographic operations will 

be conducted. 

• If radiography operations will be conducted at temporary jobsites (i.e., locations where 

work is conducted for limited periods of time), the address may be stated as “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 stations, which, as specified in 10 CFR 34.13(j), must be 

identified in the application. Residential locations where industrial radiographic equipment is 

stored prior to dispatch to temporary jobsites must be treated as a field station. 

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, in accordance with 10 CFR 34.101(c) (a license amendment or authorization by the 

NRC regional office is not required). 
8-4 

Figure 8-1. Location of Use or Possession 

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

Decommissioning,” licensees must maintain permanent records that describe 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 leaking radioactive 

sources or other unusual occurrences involving the possible 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 a telephone 

number where the individual may be contacted. Also include business cell phone numbers and 

e-mail addresses. This individual, usually the radiation safety officer (RSO), will serve as the 

point of contact during the review of the application. If this individual is not a full-time employee 

of the licensed entity, his or her position and relationship to the licensee should be specified. 

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

telephone number, cell phone number, or e-mail address changes. Notification of a contact 

change is only provided for informational purposes 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 (see Appendix B of this NUREG), Items 5 through 11 should be 

submitted on separate sheets of paper. Applicants may use Appendix C of this NUREG for this 

purpose and should note that using the suggested wording of responses and committing to use 

the model procedures in this report will facilitate the NRC’s review. 

RPh17a.ppt

082898

32 Elm St.

City, ST 12345 P.O. Box XXXX

City, ST 12345

32 ELM St.

An acceptable location of use or possession specifies street address, city, State, 

and zip code and does not include a post office box number.
8-5 

8.5 Item 5: Radioactive Material 

8.5.1 Sealed Sources and Devices 

Regulations: 10 CFR 30.3, 10 CFR 30.32(g), 10 CFR 30.33(a)(2), 10 CFR 32.210, 

10 CFR 34.20, 10 CFR Part 37

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 compatible 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). Licensees must also protect Category 1 and 

Category 2 quantities of radioactive material from theft and diversion. 

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 compatible 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 

the use of radiographic equipment is 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. If the 

manufacturer and supplier are no longer in service, a copy of the SSD registration certificate 

may be requested from the NRC or the issuing Agreement State. 

Licensees must demonstrate that associated equipment meets the performance requirements in 

10 CFR 34.20. Regulatory Issue Summary (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 
8-6 

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 licensees can demonstrate that their associated equipment meets the 

performance requirements stated in 10 CFR 34.20. 

Radiography sealed sources are usually at or above Category 2 quantities, as defined in 

10 CFR Part 37 (see Section 8.10.10, “Security Program for Category 1 and Category 2 

Radioactive Material,” for more information on the applicability of 10 CFR Part 37). Applicant 

and licensee information on manufacturers, model numbers, and possession limits is sensitive 

and should be marked accordingly (see Chapter 6, “Identifying and Protecting Sensitive 

Information”). Category 1 and Category 2 sources must be tracked in the National Source 

Tracking System (NSTS), in accordance with 10 CFR 20.2207. 

After the NRC license is issued, the licensee needs to create an account in the NSTS to track, 

from cradle to grave, sealed sources with activities exceeding the activities listed in Appendix E 

of 10 CFR Part 20, “Nationally Tracked Source Thresholds.” The receipt, transfer, and disposal 

transactions of NSTS sources must be reported in accordance with 10 CFR 20.2207. More 

information on NSTS can be found in the NRC Web site at 

http://www.nrc.gov/security/byproduct/ismp/nsts.html. 

Response from Applicant: 

• Identify each radionuclide that will be used for performing radiography. 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, and specify the total amount in kilograms. 

• For each sealed-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 registration certificate and provide the sealed source and device registry number 

with the application. 

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

changers, and sealed sources containing byproduct material. 

• 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. 

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

device and sealed source containing byproduct material that will not be used for 

performing radiography. 
8-7 

8.5.2 Financial Assurance and Recordkeeping for Decommissioning 

Regulations: 10 CFR 30.34(b), 10 CFR 30.35, 10 CFR 30.51 (f), 10 CFR 34.13(k) 

Criteria: Industrial radiography licensees authorized to possess sealed sources containing 

byproduct material with a half-life greater than 120 days and 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. Pursuant to 10 CFR 30.35(g), licensees must transfer records important to 

decommissioning to new licensees before licensed activities are transferred or assigned, 

according to 10 CFR 30.34(b). Furthermore, pursuant to 10 CFR 30.51(f), prior to license 

termination, each licensee shall forward the records required by 10 CFR 30.35(g) to the 

appropriate NRC regional office. 

Decommissioning records described above are not required for temporary jobsite locations. 

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

 Gigabecquerels 

(GBq) [10,000 curies (Ci)] of cobalt-60 and 3.7 × 106

 GBq [100,000 Ci] of cesium-137 or 

byproduct material with half-lives less than 120 days (e.g., iridium-192, ytterbium-169). Thus, a 

licensee would need to possess hundreds of sealed sources before the financial assurance 

requirements would apply. Applicants and licensees desiring to possess sources exceeding 

the threshold amounts must submit evidence of financial assurance. Licensees may follow 

the guidance provided in NUREG–1757, Volume 3, “Consolidated Decommissioning 

Guidance—Financial Assurance, Recordkeeping and Timeliness.” 

The regulations in 10 CFR 30.35(g) 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 records important 

to decommissioning and transfer these records to an NRC or Agreement State 

licensee before licensed activities are transferred or assigned, in accordance with 

10 CFR 30.34(b). Furthermore, pursuant to 10 CFR 30.51(f), prior to license 

termination, we shall forward the records required by 10 CFR 30.35(g) to the appropriate 

NRC regional office.” 
8-8 

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 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 34.13 

Criteria: An application for a license will be approved if the proposed activity is authorized by 

the Atomic Energy Act of 1954, as amended, and sealed 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 

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 and 

provide specific operating and emergency procedures to address these unique operations. 

The NRC will authorize radiography for lay-barges, offshore platforms, and underwater by 

specific license conditions. 

Response from Applicant: 

• Indicate using Appendix C of this NUREG that the equipment will be only used for 

industrial radiography.

AND 

• If applicable, specify the purposes for which the source(s) and device(s) will be used, 

other than for industrial radiography, as specified on the SSD registration certificate. 

(An example of a use other than industrial radiography is a cesium-137 sealed source in 

an instrument calibrator to calibrate radiation survey meters).

AND 

• If applicable, specify the purposes for which the source(s) and device(s) will be used for 

uses other than those specified and approved in the SSD registration certificate. 

 
8-9 

AND 

• In addition, specify any plans to perform industrial radiography underwater, on laybarges, or on offshore platforms. Refer to Appendix D of this NUREG. 

8.7 Item 7: Individual(s) 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 the RSO. The 

RSO is the key to overseeing and ensuring safe and secure operation of the licensee’s 

radiography program. The RSO should have independent authority to stop operations that he 

or she considers unsafe. He or she should have sufficient time, support, and commitment from 

management to fulfill certain duties and responsibilities to ensure that radioactive materials are 

used in a safe and secure manner. This management support includes resource allocation. He 

or she should be involved with developing and implementing a security program in accordance 

with 10 CFR Part 37. 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 

the same management support and decision-making authority as the RSO 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. Applicants 

should 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 communication with responsible management officials. Also, applicants should 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 
8-10 

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 devices and radiation areas, transporting the 

radiography equipment to temporary jobsites, securing the materials, 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 radiography using sealed sources. See NUREG–1556, Volume 2, Revision 1, 

Appendix O, “Model Delegation of Authority,” as an example of how to document a person 

accepting the responsibility of becoming an RSO. 

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 

• 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). 
8-11 

• 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. 

Figure 8-2. Typical Duties and Responsibilities of RSOs

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, 10 CFR 37.43 

Criteria: Radiographers and radiographer’s assistants must have adequate training 

and experience. Any licensee that possesses and aggregated Category 1 or Category 2 

quantity of radioactive material must implement a training program for those individuals 

implementing the security program. 

rad0001a.ppt

072198

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

Radiation survey meter calibration and

maintenance
8-12 

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 and security 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. 

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

radiographer’s assistants and require that all radiographers be certified by a certifying entity. 

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 of this NUREG as an aid to determining the 

specific training requirements for radiographers and radiographer’s assistants. For existing 

licensees, no licensing actions are required when radiographers are certified. The NRC will 

verify radiographer certification during routine NRC inspections. 

Since 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 radiation 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 
8-13 

practical examination before participating in a radiographic operation. The person conducting 

internal inspections should have a minimum of 1 year of actual experience as a radiographer. 

In accordance with 10 CFR Part 37, any licensee that possesses an aggregated Category 1 or 

Category 2 quantity of radioactive material must implement a training program in accordance 

with 10 CFR 37.43, “General security program requirements,” to ensure that those individuals 

who may have a responsibility to implement portions of the security program possess and 

maintain the knowledge, skills, and abilities to carry out their assigned duties and 

responsibilities effectively. For additional guidance on implementing 10 CFR Part 37 

requirements, see NUREG–2155, “Implementation Guidance for 10 CFR Part 37, “Physical 

Protection of Category 1 and Category 2 Quantities of Radioactive Material.” Additional 

information regarding best practices for protection of risk-significant radioactive material 

is available in NUREG–2166, “Physical Security Best Practices for the Protection of 

Risk-Significant Radioactive Material.” 

Please note, under 10 CFR Part 37, security plans are not to be submitted to the NRC for 

review and approval. 

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. 

• Submit all training program descriptions noted in 10 CFR 34.43, except for those training 

and examination program topics listed in 10 CFR 34.43(g). 

• 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 practical field examination that will be given to prospective radiographers 

and radiographer’s assistants. This should include the use of the exposure device, 

sealed sources, daily inspection of devices and associated equipment, and the use of 

survey instruments. The NRC suggests using the checklist in Appendix F of this 

NUREG as a source of potential areas to review during the practical 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 of this NUREG. 

• 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. 
8-14 

• 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 of this NUREG provides a sample checklist. 

Experience and training with radiography using x-ray training by itself will not be considered 

adequate experience for performing radiography using sealed sources. 

8.9 Item 9: Facilities and Equipment 

Regulations: 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, 10 CFR Part 37 

Criteria: Licensees must specifically identify and describe permanent radiographic installations 

and field stations and any other locations where radiography will be conducted and provide 

physical protection of Category 1 and Category 2 quantities of radioactive material. 

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 

radiographic installation. 

The one primary (and perhaps the most important) reason licensees have for conducting 

radiography in a permanent radiographic installation is that they do not have to implement 

additional access-control requirements to assure public safety. 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 one hour), the regulation does not specify 

radiation limits to allow for design flexibility for moving equipment into and out of the installation 

or other considerations. Radiation levels slightly exceeding these levels outside of the facility 

should only be considered or allowed when the higher levels 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, 

“Security Program for Category 1 and Category 2 Radioactive Material”). An NRC licensee 

must implement enhanced security measures, as required by 10 CFR Part 37, for aggregated 

radioactive material of Category 2 or greater. 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 
8-15 

conducted. In addition, the new permanent radiographic installation must be authorized on the 

license before licensed material is transferred to it. 

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 visible-audible 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.” 

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 one 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 one hour are considered 

acceptable. If the radiation levels will exceed 0.02 mSv [2 mrem] in any one 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 cm [1 ft] 

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 one 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 one hour 

or 1 mSv [100 mrem] in a year. 
8-16 

Security-Related Information—Withhold under 10 CFR 2.390* 

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

Figure 8-3. Example Diagram of a Permanent Radiographic Installation

A field station is a facility where licensed material may be stored or used and from which 

equipment may be dispatched. Radiographic operations may be conducted outside a 

permanent radiographic installation, outside a field station or outside the place of 

business, as if the work was performed “in the field” at a temporary jobsite, provided the 

licensee complies with all NRC regulatory requirements. 

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. 

Radiography equipment cannot be dispatched from a temporary jobsite to perform work 

at a different temporary jobsite. If equipment is dispatched from a temporary jobsite, 

then the location must be authorized as a field station on the license. 

Note: 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. 

rad0013a.ppt

072198

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
8-17 

In accordance with 10 CFR Part 37, any licensee that possesses an aggregated Category 1 or 

Category 2 quantity of radioactive material must, 

• implement the physical protection requirements in 10 CFR Part 37 for material in use 

and storage, at both permanent and temporary jobsites; and 

• in accordance with 10 CFR 37.49 and 10 CFR 37.53, be able to monitor and 

immediately detect and assess any unauthorized entries into security zones, including 

those surrounding mobile devices. 

For additional guidance on implementing 10 CFR Part 37 requirements, see NUREG–2155, 

“Implementation Guidance for 10 CFR Part 37, “Physical Protection of Category 1 and 

Category 2 Quantities of Radioactive Material.” Additional information regarding best practices 

for protection of risk-significant radioactive material is available in NUREG–2166, “Physical 

Security Best Practices for the Protection of Risk-Significant Radioactive Material.” 

Please note, under 10 CFR Part 37, security plans are not to be submitted to the NRC for 

review and approval.

Response from Applicant: Provide the following: 

Provide the following for each Permanent Radiographic Installation. 

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

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

• 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 in = 1 ft. Drawings to this 

scale that do not fit on 8-1/2 × 11-inch paper may be provided as sectional drawings. 

Sketches or drawings should also include a compass directional arrow to indicate 

“North.” 

• 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 radiographic 

installation listed in Item 3 (e.g., located in an industrial park, an office complex) and its 

current use. If any proposed permanent radiographic 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 

0.02 mSv [2 mrem] in any one hour and less than 1 mSv [100 mrem] per year. 
8-18 

• 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. Provide the radiation level in all directions around the 

installation, including the roof. The radiation level should not exceed 0.02 mSv [2 mrem] 

in any one hour. Clearly identify the type of sealed source (radionuclide), the amount of 

radioactive material in the sealed source (activity), and the position or location of the 

sealed source within the installation for the calculations or measurements. 

• Indicate whether or not radiography will be performed at the place of business outside of 

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

of a permanent radiographic 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.” 

Note: Local municipalities may limit the use of radioactive material to certain zone areas. 

Variances will be considered if construction requirements preclude shielding the radiographic 

installation roof1

 to meet the requirement not to exceed 0.02 mSv [2 mrem] in any one hour. 

Provide the following information to obtain approval for a variance: 

• 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 sealed sources or type (radionuclide) 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 radiographic installation roof exceed 1.0 mSv [100 mrem] in any 

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

variance: 

 

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. 
8-19 

• 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 one hour at 30 cm [1 ft] 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 

Provide the following information for each Field Station. 

• 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 industrial radiography will be performed at the place of business 

outside of a field station.

• If radiography will be performed at a site outside a field station, provide a diagram of the 

location where industrial 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.” 

Note: Certain records described in the regulations that pertain to radiation safety shall 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. 

Provide the following information for Temporary Jobsite. 

• Indicate in Item 3 of the application that the applicant is requesting authorization to 

perform work at temporary jobsites anywhere in the U.S. where the NRC maintains 

jurisdiction for regulating the use of licensed material, including areas of exclusive 

Federal jurisdiction within Agreement States. 

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: 
8-20 

• steps to keep radiation exposures ALARA 

• a 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 

• a program to inspect the job performance of radiographic personnel 

• a 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 and Review of Program 

Regulations: 10 CFR 20.1101, 10 CFR 20.2102, 10 CFR 37.33, 10 CFR 37.55 

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

and access authorization programs annually to ensure the following: 

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

(as applicable) and the terms and conditions of the license 

• occupational doses and doses to members of the public are ALARA 

• access authorization program is effective and complies with 10 CFR Part 37, Subpart B 

• security program is effective and complies with 10 CFR Part 37, Subpart C 

• records of audits and other reviews of program content are maintained for 3 years 

Discussion: Appendix G of this NUREG 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 proposing to perform unannounced audits of 

industrial radiography to observe whether radiation safety procedures are being followed. 

Licensees should consider providing specialized audit training, if staff other than the RSO are 

used to conduct audits of the performance of radiographers and radiographer’s assistants. See 

Appendix G of this NUREG for applicable audit program areas for potential specialized training. 
8-21 

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 routinely 

reviews licensee’s records to verify whether appropriate corrective actions were implemented in 

a timely manner to address recurrence. It is in the best interest of the licensee to identify 

potential violations of regulatory requirements and take necessary steps to correct them. The 

NRC can opt to exercise discretion and may elect not to cite the licensee for these violations if 

prompt and effective corrective actions are implemented. The NRC’s Enforcement Policy may 

be found online at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html and 

the Enforcement Manual may be found online at http://www.nrc.gov/aboutnrc/regulatory/enforcement/guidance.html. For examples of the NRC’s use of discretion in 

issuing a notice of violation, refer to the most recent version of NRC’s enforcement documents 

at http://www.nrc.gov/reading-rm/doc-collections/enforcement/.

Licensees must maintain records of audits and other reviews of program content and 

implementation for 3 years from the date of the record, in accordance with 10 CFR 20.2102. 

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 

In accordance with 10 CFR Part 37, any licensee that possesses an aggregated Category 1 or 

Category 2 quantity of radioactive material must, 

• in accordance with 10 CFR 37.33, review its access authorization programs at least 

annually to confirm compliance with the requirements of Subpart B of 10 CFR Part 37 

and ensure that comprehensive actions are taken to correct any noncompliance that is 

identified; and 

• in accordance with 10 CFR 37.55, review its security program at least annually to 

confirm compliance with the requirements of Subpart C of 10 CFR Part 37 and ensure 

that comprehensive actions are taken to correct any noncompliance that is identified. 

For additional guidance on implementing 10 CFR Part 37 requirements, see NUREG–2155, 

“Implementation Guidance for 10 CFR Part 37, “Physical Protection of Category 1 and 

Category 2 Quantities of Radioactive Material.” Additional information regarding best practices 

for protection of risk-significant radioactive material is available in NUREG–2166, “Physical 

Security Best Practices for the Protection of Risk-Significant Radioactive Material.” 

Please note, under 10 CFR Part 37, security plans are not to be submitted to the NRC for 

review and approval.

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

radiation safety and security programs 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. 
8-22 

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 Web page 

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 

sources should be capable of accurately measuring the radiation fields produced by the sealed 

source in use. Radiation survey instruments shall 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 radiation 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 radiation 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, which are both calibrated and operable, at each location where radioactive material 

is present to make the required radiation surveys. The radiation survey instruments must be 

capable of measuring 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 of this NUREG 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, 10 CFR 37.75, 10 CFR 37.77 
8-23 

Criteria: Licensees must do the following: 

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

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

by 10 CFR 20.2207(g). 

• 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. 

• Preplan, coordinate, and provide advance notification of shipment of Category 1 

quantities of radioactive material and coordinate shipment of Category 2 quantities of 

radioactive material. 

Discussion: As illustrated in Figure 8-4, licensed materials must be tracked from “cradle to 

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

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

inventories, which shall be conducted at intervals not to exceed 3 months, shall account for all 

sealed sources and devices containing depleted uranium (i.e., specifically locate, verify the 

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

Receipt, inventory, transfer, and disposal records must be maintained for the times specified in 

Table 8-1. Typically, these records contain the following types of information: 

• radionuclide and activity (in units of becquerels or curies) of byproduct material in each 

sealed source 

• manufacturer’s or distributor’s name, model number, and serial number of each sealed 

source containing byproduct material 

• manufacturer’s or distributor’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 

• for materials transferred or disposed, the date of the transfer or disposal, the name and 

license number of the recipient, and a description of the affected radioactive material 

(e.g. radionuclide, activity, manufacturer’s or distributor’s name and model number, 

serial number) 
8-24 

Table 8-1. Record Maintenance 

Type of Record How Long Record Must Be Maintained 

Receipt For 3 years after the date the record was made 

Inventory For 3 years after the date the record was made 

Transfer For 3 years after the date the record was made 

Disposal Until the NRC terminates the license 

Important to Decommissioning* Until the site is released for unrestricted use 

*See Section 8.5.2, “Financial Assurance and Recordkeeping for Decommissioning,” for more details. 

The regulations in 10 CFR 20.2207 require that each licensee that manufactures, transfers, 

receives, disassembles, or disposes of a nationally tracked source shall complete and submit an

NSTTR to the NRC. The NSTTRs are maintained in the NSTS, a secure 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 the source activity decays enough to no longer be 

of concern. 

In addition to general security requirements for shipment and transfer of Category 1 and 

Category 2 quantity of radioactive materials, in accordance with 10 CFR Part 37.75 and 37.77, 

any licensee that ships Category 1 quantities of radioactive material must preplan and 

coordinate shipment, and must provide advanced notification of shipments. Under 

10 CFR 37.75, any licensee that ships Category 2 quantities of radioactive material must 

coordinate the shipment of such material. For additional guidance on implementing 

10 CFR Part 37 requirements, see NUREG–2155, “Implementation Guidance for 10 CFR 

Part 37, “Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material.” 

Additional information regarding best practices for protection of risk-significant radioactive 

material is available in NUREG–2166, “Physical Security Best Practices for the Protection of 

Risk-Significant Radioactive Material.” 

Please note, under 10 CFR Part 37, security plans are not to be submitted to the NRC for 

review and approval. 

Note: Licensees who receive, transfer, and dispose of nationally tracked sources (i.e., sealed 

sources containing a quantity equal or greater than Category 1 or Category 2 levels of any 

radioactive material listed in Appendix E of 10 CFR Part 20) must complete and submit to the 

NSTS, a National Source Tracking Transaction Report by the close of the next business day 

after the transaction has occurred. In addition, licensees must reconcile the inventory of 

nationally tracked sources possessed by the licensee against that licensee’s data in the NSTS. 

This reconciliation must be conducted during the month of January in each year. Licensees 

must submit to the NSTS confirmation that the data in NSTS is correct by January 31 of 

each year. 
8-25 

Figure 8-4. Material Receipt and Accountability. Licensees Must Maintain Records of 

Receipt, Transfer, 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 develop, implement, and maintain procedures for ensuring accountability of 

licensed materials at all times.”

AND

• “We will comply with the NSTS reporting requirement, as described in 10 CFR 20.2207.” 

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, because they are included in responses to other items 

of the application. 

rad0002a.ppt

072198

Cradle to Grave Accountability

Quarterly 

Inventory:

Jan

7 April

7

Transfer

 or

Disposal

Record

Record

Receipt

Receipt Disposal or Transfer 
8-26 

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

sources,” should identify defective sources. Leaking sealed 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 sealed 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 submitted by the applicant 

and approved by the NRC or an Agreement State. Leak test records shall be retained for 3 

years after they are made or until the source in storage is removed. 

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 leak-test 

sample according to the device manufacturer’s and the kit supplier’s instructions and return it to 

the kit supplier for analysis 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. 

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. 

Some Agreement States may model their regulations using the Suggested State Regulations 

(SSR). The SSR require, in part, that an applicant describe the procedures for performing leak 

testing of sealed sources or exposure devices containing depleted uranium shielding and that 

the description include the qualifications of the individual who analyzes the samples. In the 

comparable requirement in 10 CFR 34.13(h), there is a requirement to describe the 

qualifications of the person authorized to do leak testing, in addition to the qualifications of the 

person who analyzes the wipe samples. The NRC has determined that the SSR requirement 

for leak testing is compatible with the requirements in 10 CFR 34.13(h) and does not result in 

any conflicts, duplications, or gaps. 

Response from Applicant: State either of the following: 

• “Leak test sample collection and analysis 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 sample collection kit supplied by an organization 
8-27 

licensed by the NRC or an Agreement State to provide leak test kits and sample analysis 

services to other licensees and according to the instructions provided in the leak test 

sample collection kit.” 

OR 

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

Appendix I of this NUREG 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). 

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. At permanent radiographic 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 work 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 ionchamber pocket dosimeters and require special means to change the preset alarm function. 

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. 
8-28 

TOTAL EFFECTIVE DOSE EQUIVALENT (TEDE) = SUM OF THE EFFECTIVE DOSE 

EQUIVALENT (FOR EXTERNAL EXPOSURES) + THE COMMITTED DOSE 

EQUIVALENT (FOR INTERNAL EXPOSURES). 

Figure 8-5. Annual Dose Limits for Occupationally Exposed Adults 

Film badges must be replaced at intervals not to exceed 1 month, and TLDs or other personal 

dosimetry devices that are evaluated using an accredited NVLAP processor 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 devices are processed and 

evaluated by an NVLAP-accredited processor. 

• A statement that film, TLD, or other personal dosimetry devices will be exchanged at the 

required frequency and will be assigned to and worn by radiography personnel. 

• A statement that the required personnel monitoring equipment, including 0-2 mSv 

[0-200 mrem] dosimeters or electronic personal dosimeters, will be worn by 

radiography 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 and are operational. 

• A statement that pocket dosimeters and alarm ratemeters will be checked for correct 

response to radiation at intervals not to exceed 12 months. If adjustment is necessary, 

state either that the devices will be returned to the manufacturer or persons licensed by 

Agreement State or NRC to calibrate such devices or provide in-house procedures if 

adjustments are made in-house. 

Dose Limits for Adult

Radiation Worker

(10 CFR 20.1201)

Total effective dose equivalent TEDE

(whole body) 0.05 Sv (5 rem)

Eyes (Lens) 

0.15 Sv 

(15 rem) 

Skin 

0.50 Sv 

(50 rem)

Elbows to 

hands 

0.50 Sv 

(50 rem)

Knees to feet

0.50 Sv

(50 rem)

rad0003a.ppt

072298
8-29 

Note: The NIST maintains a directory of laboratories that are NVLAP-approved at 

http://ts.nist.gov/standards/scopes/dosim.htm. 

8.10.7 Public Dose 

Regulations: 10 CFR 20.1301, 10 CFR 20.1302 

Criteria: Licensees must do the following: 

• Ensure that industrial 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 one hour. 

Discussion: Public dose is defined in 10 CFR Part 20 as “the dose received by a member of 

the public from exposure to radiation or to radioactive material released by a licensee, or to any 

other source of radiation under the control of a licensee.” Public dose excludes doses received 

from background radiation and medical procedures. Whether the dose to an individual is an 

occupational dose or a public dose depends on the individual’s assigned duties. It does not 

depend on the area (restricted, controlled, or unrestricted) where the individual is when he or 

she receives the dose. 

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 and control. 

Public dose is also affected by the choice of the permanent radiographic installation and storage 

locations and physical conditions. Since radiation levels around a permanent radiographic 

installation or storage area will vary based on the type and strength of sealed sources used, the 

frequency of use, and scatter radiation from radiographic operations, it is not sufficient to 

perform surveys with portable radiation survey meters to determine the annual public dose. Use 

of area monitors, such as environmental TLDs, may be 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. 
8-30 

Response from Applicant: No response is required from the applicant in a license application, 

but this matter will be examined during an inspection. 

Appendix J of this NUREG 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), 10 CFR 21 

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 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 of equipment problems and specific maintenance are required by 10 CFR 34.73. 

The licensee should evaluate whether the equipment problem meets a 10 CFR Part 21 

reporting requirement. 

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. Another example is the performance of a misconnect 

test on the radiographic camera, including the radioactive source assembly, to test the integrity 

of the entire locking system in accordance with the manufacturer’s recommendations. The 

performance of this test will detect long–term wear or damage of control and locking mechanism 

components, including the control cable and sealed-source connectors, simultaneously. A 

radiographic camera must not be used if the camera fails a misconnect test. 

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 assembly, disassembly, reassembly, and reinstallation of the locking mechanism and outlet 

port mechanism of a radiography camera can be performed by the licensee in accordance with 

the recommendations of the equipment manufacturer. This type of activity is considered 

nonroutine maintenance that needs to be reviewed by the NRC on a case by case basis. The 

applicant needs to submit to the NRC specific procedures in support for this type of nonroutine 

maintenance. If such procedures are approved, the NRC will specifically authorize this activity 

by license condition. 
8-31 

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 on the U.S. Department of Energy’s Web site for Information of 

Radioactive Material Packaging at

http://rampac.energy.gov/certificates/certificate_retrieval_page.htm

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 

guidance provided in Sections 8.10.8, “Quarterly Maintenance,” and 8.10.9, “Operating 

and Emergency Procedures,” of NUREG–1556, Volume 2, Revision 1 should be of 

assistance in the development of the applicant’s procedures. 

AND 

• If applicable, submit nonroutine maintenance procedures for NRC review and approval. 

The applicant should develop procedures specific to its equipment and program, and in 

accordance with the recommendations of the equipment manufacturer. 

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 34.41(c), 10 CFR 34.45, 10 CFR 37.21(a), 

10 CFR 37.45 

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. Licensees that possess Category 1 or Category 2 quantities 

of radioactive material must also establish, implement, and maintain its access authorization 
8-32 

program and coordinate, to the extent practicable, with local law enforcement authorities, for 

responding to threats to the licensee’s facility. 

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 and inspection program that includes the performance of 

misconnect tests. (Refer to section 8.10.8, “Quarterly Maintenance”) 

• 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 

• offshore platform, lay–barge, and/or underwater radiography procedures, if such 

authorization is requested (Refer to Appendix D of this NUREG for further guidance) 

• record maintenance 

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, to 

include appropriate radiation safety practices. 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. 
8-33 

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. 

Note: The procedures required by 10 CFR 34.45, “Operating and emergency procedures,” are 

not substitutes for the DOT requirements in 49 CFR Part 172, Subpart G—Emergency 

Response Information. Licensees must comply with the appropriate U.S. DOT regulations as 

applicable, including those involving Emergency Response Information, if needed when 

transporting radioactive material. 

In accordance with 10 CFR Part 37, any licensee that possesses an aggregated Category 1 or 

Category 2 quantity of radioactive material must, 

• in accordance with 10 CFR 37.21(a), establish, implement and maintain its access 

authorization program in accordance with the requirements of 10 CFR Part 37, 

Subpart B; 

• in accordance with 10 CFR 37.45, attempt to coordinate with their local law enforcement 

agency (LLEA) for responding to threats to a licensee’s facility. Such activities are 

recommended for temporary jobsites. 

For additional guidance on implementing 10 CFR Part 37 requirements, see NUREG–2155, 

“Implementation Guidance for 10 CFR Part 37, “Physical Protection of Category 1 and Category 

2 Quantities of Radioactive Material.” Additional information regarding best practices for 

protection of risk-significant radioactive material is available in NUREG–2166, “Physical Security 

Best Practices for the Protection of Risk-Significant Radioactive Material.” 

Please note, under 10 CFR Part 37, security plans are not to be submitted to the NRC for 

review and approval.

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 industrial radiography 

• radiographic equipment and radiation safety procedures unique to underwater 

industrial radiography 

• methods appropriate for use of industrial radiography equipment in water environments 
8-34 

• applicable inspection and maintenance procedures unique to lay–barge, offshore 

platform, or underwater industrial radiography equipment 

• emergency procedures unique to lay–barge, offshore platform, or underwater industrial 

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. 

Discussion: The crankout device is normally used for industrial radiography. Separate 

instructions are not necessary for each different model of a given type of exposure 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 sealed-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 radiation survey 

instruments, dosimetry, and surveys during and after movement of sealed sources. 

Response from Applicant:

• Provide operating and emergency procedures with step-by-step instructions for using 

each type of radiographic device. 

• Include operating and emergency procedures with instructions for performing source 

exchanges. 

• Instructions for crankout devices should be separate from those for other categories of 

exposure devices. 

Manufacturers’ manuals, bulletins and updates, and similar documents should not be 

incorporated into the procedures; rather, information should be extracted from them and 

paraphrased. 

Appendix K of this NUREG provides information for applicants to consider when developing 

their procedures for operating radiography equipment. 
8-35 

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 to comply with regulatory requirements. 

Discussion: In general, surveys are required whenever a sealed 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. 

Response from Applicant: Submit operating and emergency procedures for conducting 

radiation surveys. Where applicable, the operating and emergency procedures must include 

each of the surveys included in Table 8-2. 

Table 8-2. 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 one 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 
8-36 

Table 8-2. Surveys Required for Radiographic Operations 

Requirement Frequency Radiation Survey Limits

10 CFR 34.49(c) After every sealed-source 

exchange or when an 

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 

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 34.43, 10 CFR 34.51, 10 CFR 34.53, 10 CFR 37.49, 

10 CFR 37.53 

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, and to prevent theft and 

diversion. 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. Licensees that possess an 

aggregrated Category 1 or Category 2 quantity of radioactive material must also be able to 

monitor and immediately detect and assess any unauthorized entries into security zones. 

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 
8-37 

example, personnel should be instructed to terminate the radiographic exposure immediately 

before confronting the person who entered the restricted area. 

All areas where radiographic operations are conducted require posting of the radiation areas 

and the high-radiation areas, as shown in Figure 8-6. 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 one 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 one 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 8-7 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. 

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. 

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: 
8-38 

• 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 

radiographer’s assistant. 

Figure 8-6. 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 One Hour.

rad0008b.ppt

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Source

2 mrem

in one hour

DANGER

High Radiation

Area

DANGER

High Radiation

Area

CAUTION

Radiation

Area
8-39 

Figure 8-7. Surveillance and Posting at a Temporary Jobsite With Multiple Floors and 

Access Points. Adequate Control of the Restricted Area at This Type of 

Jobsite Requires Several Personnel and Many Postings.

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 where 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] from any external surface of the vehicle, and the 

vehicle shall be locked when it is used for storage. Industrial radiographic exposure devices 

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 an exposure 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. 

rad0005d.ppt

072298

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
8-40 

In accordance with 10 CFR Part 37, any licensee that possesses an aggregated Category 1 or 

Category 2 quantity of radioactive material must implement the physical protection requirements 

for material in permanent radiographic installations, storage, and at temporary jobsites. In 

accordance with 10 CFR 37.49 and 37.53, licensees must be able to monitor and immediately 

detect and assess any unauthorized entries into security zones, including those surrounding 

mobile devices. For additional guidance on implementing 10 CFR Part 37 requirements, see 

NUREG–2155, “Implementation Guidance for 10 CFR Part 37, “Physical Protection of 

Category 1 and Category 2 Quantities of Radioactive Material.” Additional information regarding 

best practices for protection of risk-significant radioactive material is available in NUREG–2166, 

“Physical Security Best Practices for the Protection of Risk-Significant Radioactive Material.” 

Please note, under 10 CFR Part 37, security plans are not to be submitted to the NRC for 

review and approval. 

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, 10 CFR Part 37 

Criteria: NRC regulations require radiographic equipment to be locked and secured to protect 

the public and radiographers from an inadvertent exposure to radiation and to prevent theft and 

diversion of Category 1 and Category 2 quantities of radioactive material. 

Discussion: All radiographic equipment (i.e., radiographic 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 sealed 

source must automatically be secured in the shielded position each time the sealed 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 8-8, radiographers 

must never 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 where all entryways are locked and the 

requirements of 10 CFR 34.33 are met. 
8-41 

In accordance with 10 CFR Part 37, any licensee that possesses an aggregated Category 1 or 

Category 2 quantity of radioactive material, must implement the physical protection 

requirements for material in use and storage, at both permanent and temporary jobsites, as well 

as during transport. For additional guidance on implementing 10 CFR Part 37 requirements, 

see NUREG–2155, “Implementation Guidance for 10 CFR Part 37, “Physical Protection of 

Category 1 and Category 2 Quantities of Radioactive Material.” Additional information regarding 

best practices for protection of risk-significant radioactive material is available in NUREG-2166, 

“Physical Security Best Practices for the Protection of Risk-Significant Radioactive Material.” 

Please note, under 10 CFR Part 37, security plans are not to be submitted to the NRC for 

review and approval.

Response from Applicant: Submit operating and emergency procedures that include 

procedures for locking and securing radiographic equipment. 

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 8-9, all radiographers or radiographer’s assistants are 

required to wear: 

• direct-reading dosimeters and either film badges, TLDs, or other personal 

dosimetry devices 

Figure 8-8. Security. To Avoid Lost or Stolen Devices, Licensees Must Keep the 

Radiographic Exposure Devices Under Constant Surveillance or Secured 

Against Unauthorized Use or Removal. 

Alarm ratemeters when they are engaged in radiographic operations, except for a permanent 

radiographic installation. Film badges, TLDs, or other personal dosimetry devices must be 

assigned to and worn by only one individual. To ensure full-scale reading capability, directSecurity

rad0006a.ppt

072298

DANGER

High Radiation

Area

Storage and transport

Constant surveillance when

idle or in use
8-42 

reading dosimeters, such as pencil (pocket) dosimeters or electronic personal dosimeters, must 

be recharged or reset at the start of each work 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 work shift. Proper operation of alarm 

ratemeters must be checked each day before 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 direct reading dosimeter reading after each exposure and during 

the work shift; however, there is no regulatory requirement for the direct reading 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. 

Response from Applicant: The operating procedures must include instructions for proper use 

of personnel monitoring equipment. 

Figure 8-9. The Well-Dressed Radiographer. The Radiographer Is Equipped With the 

Required Personnel Monitoring Devices and Radiation Survey Instrument. 
8-43 

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 Part 37, Subpart D, 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. Licensees must also preplan, 

coordinate and provide advance notification of shipment of Category 1 quantities of radioactive 

material and coordinate shipment of Category 2 quantities of radioactive material. 

Discussion: Figure 8-10 illustrates some often-overlooked DOT requirements. During an 

inspection, 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 of this NUREG contains a list of major DOT 

regulations applicable to transporting radiographic devices. 

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 radiographic exposure device or storage container within the transporting 

vehicle. The instructions should specify how to prevent the package from moving during 

transport, referred to as blocking and bracing. 

Figure 8-10. Transportation. Radiography Licensees Often Act as a “Private Carrier” to 

Transport Their Radiographic Exposure Devices to and From Sites and 

Must Ensure Compliance With DOT Regulations 

• Preparing shipping papers. The instructions should specify that the papers must be 

completed before transporting the licensed material and must be accessible in the 

Transportation

rad0011b.ppt

072398

Properly labeled,

blocked, braced,

secured, and away

from the driver

Shipping

Papers

Figure does not show vehicle placards. Placards may 

be required per DOT regulations. 
8-44 

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 exposure 

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 (e.g., Radioactive White I or 

Radioactive Yellow II), and marked when required with a statement that indicates the 

inner package complies with prescribed specifications. 

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. Therefore, 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, must ensure that these packages are shipped and maintained 

in accordance with the COC. 

In accordance with 10 CFR Part 37, any licensee transferring a Category 1 or Category 2 

quantity of radioactive material must implement the physical protection in transit requirements in 

10 CFR Part 37, Subpart D. For additional guidance on implementing 10 CFR Part 37 

requirements, see NUREG–2155, “Implementation Guidance for 10 CFR Part 37, “Physical 

Protection of Category 1 and Category 2 Quantities of Radioactive Material.” Additional 

information regarding best practices for protection of risk-significant radioactive material 

is available in NUREG–2166, “Physical Security Best Practices for the Protection of 

Risk-Significant Radioactive Material.” 

Please note, under 10 CFR Part 37, security plans are not to be submitted to the NRC for 

review and approval. 

Response from Applicant: Submit operating and emergency procedures for transporting 

sealed sources containing byproduct material, radiographic 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 each day it is used. 
8-45 

Discussion: Visual and operability checks must be performed on radiographic exposure 

devices, radiation 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 sealed sources are adequately shielded, and the 

required labeling is present. Licensees must check radiation survey instrument operability using 

check sources or other appropriate means. The radiographic 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 work shift, if the equipment is used on more 

than one work 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 of visible and audible alarms must be checked for 

operability daily before use with a radiation source, and faulty radiographic equipment must be 

labeled and repaired within 7 days, with compensatory measures taken in the interim. 

Compensatory measures taken include the following: 

• The faulty equipment is immediately taken out of service and labeled as defective. 

• The radiographer or radiographer’s assistant 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 

work 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 work shift. Alarm ratemeters shall be checked for alarm function at the 

beginning of each work shift. Records are to be maintained. 

Appendix M of this NUREG provides example instructions for daily inspection of radiographic 

exposure devices and equipment. 
8-46 

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 OffScale 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 radiographic 

exposure 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 an 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 to the individual 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 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 sealed source is in the safe storage position 

in the radiographic 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. 
8-47 

• If the RSO or designee cannot rule out radiation exposure to the individual, 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. In addition to reporting 

to the NRC, the licensee should contact the manufacturer regarding the equipment defects. 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. 

8.10.9.10 Notification of Proper Persons in the Event of an Accident 

or Emergency 

Regulations: 10 CFR 30.50, 10 CFR 34.27, 10 CFR 34. 45(a)(10), 10 CFR 34.101, 10 CFR 

37.57, 10 CFR 37.81, 10 CFR 20.2201, 10 CFR 20.2202, 10 CFR 20.2203 

Criteria: Operating and emergency procedures must ensure that appropriate notifications are 

made to the NRC during and after an incident. 

Discussion: The emergency procedures should clearly identify the names and telephone 

numbers of the RSO and/or 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 up to date. 

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 to individuals. 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 of this NUREG for 

additional guidance in the preparation of emergency procedures. Table 8-3 describes events 

that require notification or reports. 
8-48 

Table 8-3. 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) 

& (b)(1) 

Whole body dose greater than 0.25 Sv 

[25 rem] 

immediate 30 days 10 CFR 20.2202(a)(1)(i) 

10 CFR 20.2203(a)(1) 

Extremity dose greater than 2.5 Gy 

[250 rad] 

immediate 30 days 10 CFR 20.2202(a)(1)(iii) 

10 CFR 20.2203(a)(1) 

Whole body dose greater than 0.05 Sv 

[5 rem] in 24 hours 

24 hours 30 days 10 CFR 20.2202(b)(1)(i) 

10 CFR 20.2203(a)(1) 

Extremity dose greater than 0.5 Sv 

[50 rem] in 24 hours 

24 hours 30 days 10 CFR 20.2202(b)(1)(iii) 

10 CFR 20.2203(a)(1) 

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) & 

(ii) 

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) & (c)(2) 

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) & 

(c)(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) & 

(c)(2) 

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 assembly to its 

fully shielded position and secure it in this 

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) 

Storage and 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) 

 
8-49 

Table 8-3. Regulatory-Required Notifications (Continued) 

Typical NRC Notifications Required for Radiography Licensees

Event

Telephone 

Notification

Written 

Report

Regulatory 

Requirement

Determine that an unauthorized entry 

resulted in an actual or attempted theft, 

sabotage, or diversion of Category 1 or 

Category 2 quantity of radioactive 

material. 

As soon as 

possible after 

initiating a 

response, but 

not at the 

expense of 

causing delay 

or interfering 

with the LLEA 

response, but 

no later than 

4 hours after 

discovery. 

30 days 10 CFR 37.57(a)&(c) 

Assess any suspicious activity related to 

possible theft, sabotage, or diversion of 

Category 1 or Category 2 quantities of 

radioactive material 

As soon as 

possible, but 

no later than 

4 hours after 

notifying the 

LLEA. 

none 10 CFR 37.57(b) 

Determination that a shipment containing 

a Category 1 quantity of material is lost 

or missing in transport. 

Within 1 hour 

of the 

determination 

notify LLEA 

and NRC 

operations 

center. 

30 days 

and 

periodic 

updates 

[10 CFR 

37.79(c)] 

10 CFR 37.81(a)&(g) 

Determination that a shipment containing 

a Category 2 quantity of material is lost 

or missing in transport. 

Within 4 

hours of the 

determination.

Within 24 

hours if the 

material has 

not yet been 

located and 

secured. 

30 days 10 CFR 37.81(b)&(g) 

Discovery along the route of any actual 

or attempted theft or diversion, or 

suspicious activity, related to a Category 

1 quantity of material in transport. 

Upon 

discovery 

notify LLEA 

and NRC 

operations 

center as 

soon as 

possible. 

30 days 

(except no 

report for 

suspicious 

activity) 

10 CFR 37.81(c)&(g) 
8-50 

Table 8-3. Regulatory-Required Notifications (Continued) 

Typical NRC Notifications Required for Radiography Licensees

Event

Telephone 

Notification

Written 

Report

Regulatory 

Requirement

Discovery of any actual or attempted 

theft or diversion, or suspicious activity, 

related to a Category 2 quantity of 

material in transport. 

As soon as 

possible. 

30 days 

(except no 

report for 

suspicious 

activity) 

10 CFR 37.81(d)&(g) 

Upon recovery of any lost or missing 

Category 1 quantity of material. 

As soon as 

possible. 

None 10 CFR 37.81(e) 

Upon recovery of any lost or missing 

Category 2 quantity of material. 

As soon as 

possible. 

None 10 CFR 37.81(f) 

Note: Telephone notifications must be made to the NRC Operations Center at 301-816-5100 or 

by facsimile to 301-951-0550, 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 accident or 

emergency. See Table 8-3. Please note, under 10 CFR Part 37, security plans are not to 

be submitted to the NRC for review and approval.

8.10.9.11 Minimizing Exposure of Persons in the Event of an Accident or 

Emergency 

Emergency Procedures 

Regulations: 10 CFR 34.45(a)(11) 

Criteria: To maintain exposures as low as possible in the event of an emergency. 

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 8-11. 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 of this 

NUREG provides an example of a routine emergency procedure. 

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 Recovery (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 recovery operations, also known as 

source retrieval, must have appropriate equipment, training, and procedures. 
8-51 

Discussion: Applicants must develop source recovery procedures if their own radiographic 

personnel with appropriate training and experience will conduct source recovery. If procedures 

and training and experience documentation are submitted, the NRC will review and approve 

applicants to perform source recovery. If source recovery 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 recovery will have a specific license condition 

authorizing these activities. In addition, these individuals would be authorized to perform source 

recovery for other licensees. 

The NRC will review the applicant’s procedures for source recovery 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 recovery 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 recovery. 

• A clear statement that no sealed source or suspected sealed-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 

cranking out the source fully into the collimator (if there are no kinks in the guide tube) to 

provide some shielding from the source (see Appendix N of this NUREG), using lead 

shot bags, sandbags, steel plates, remote handling devices, and culverts cut lengthwise. 

• Additional dosimetry to be used during source recovery {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. 
8-52 

Figure 8-11. Emergency Procedures. These Steps Provide Guidance in an Emergency

• Appropriate use of radiation survey instruments, including a procedure prohibiting the 

use of alarming ratemeters or electronic dosimeters or pocket ionization chambers as 

substitutes for radiation survey instruments. 

• Criteria for requesting outside assistance. 

• Instructions for reducing the radiation exposure to other personnel and members of the 

public during recovery operations. 

• Notification of the RSO, RSO designee, and management. 

• Specific training with a dummy source, including practice with special tools, shielding, 

and additional dosimetry. 

• Notification to the NRC or Agreement State. 

Radiography personnel should not attempt to perform operations involving recovery of sealed 

sources, unless they have actual practice in recovery operations using a dummy sealed source 

with the appropriate handling tools, survey instruments, and dosimetry. 

 

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
8-53 

Response from Applicant: 

• Submit the following statement: “We will not perform sealed source recovery and will 

use the services of a person specifically licensed by the NRC or an Agreement State to 

perform the recovery of our sealed sources.” 

OR 

• Submit operating and emergency procedures that include sealed source recovery 

instructions 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 industrial 

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 radiation 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 each 

applicable field station and temporary jobsites in accordance with 10 CFR 34.89. 

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 that ensure 

proper maintenance of records. 
8-54 

8.10.10 Security Program for Category 1 and Category 2 Radioactive Material 

Regulations: 10 CFR Part 37, 10 CFR 20.2207 

Criteria: Licensees must ensure the security of Category 1 and Category 2 radioactive 

material. 

Note: The regulations in 10 CFR Part 37 apply to licensees that possess an aggregated 

Category 1 or Category 2 quantity of radioactive material, as specified in Appendix A to 10 CFR 

Part 37. The requirements in 10 CFR 20.2207 for submitting National Source Tracking 

Transaction Reports (NSTTR) are applicable to those licensees that manufacture, transfer, 

receive, disassemble, or dispose of sealed sources containing a quantity equal to or greater 

than the Category 1 or Category 2 levels of radioactive material listed in Appendix E to 

10 CFR Part 20. 

Discussion: 

Requirements in 10 CFR Part 37, “Physical Protection of Category 1 and Category 2 Quantities 

of Radioactive Material” 

In accordance with 10 CFR Part 37, licensees authorized to possess Category 1 or Category 2 

quantities of radioactive material must establish, implement, and maintain a security program to 

ensure physical protection of the radioactive material. 

Table 1 of Appendix A, “Category 1 and Category 2 Radioactive Materials,” to 10 CFR Part 37, 

lists Category 1 and Category 2 threshold quantities of radioactive material. The applicant 

should refer to this table to determine whether its proposed activities would be subject to the 

10 CFR Part 37 requirements. 

Licensees authorized to hold Category 1 or Category 2 quantities of radioactive material must 

establish access authorization programs in accordance with 10 CFR Part 37, Subpart B. Before 

giving individuals unescorted access to such quantities of radioactive material, licensees must 

conduct prior background investigations of these individuals, in accordance with 10 CFR 37.25. 

This would include at least radiographers and radiographer’s assistants. 

In accordance with 10 CFR 37.41(b), licensees must establish a security program designed to 

monitor and, without delay, detect, assess, and respond to any actual or attempted efforts to 

gain unauthorized access to Category 1 or Category 2 quantities of radioactive material. 

Per 10 CFR Part 37, Subpart D, licensees must provide for physical protection of Category 1 or 

Category 2 quantities of radioactive materials in transit. These requirements apply to licensees 

delivering such material to a carrier for transport, as well as cases in which licensees are 

transporting such material. Please note that the Subpart D requirements applicable to the 

transport of Category 1 quantities of radioactive material are more stringent than those 

applicable to Category 2 quantities. 

Applicants and licensees are required to implement the 10 CFR Part 37 security requirements 

before they take possession of an aggregated Category 1 or Category 2 quantity of 

radioactive material. 
8-55 

For additional guidance on implementing 10 CFR Part 37 requirements, see NUREG–2155, 

“Implementation Guidance for 10 CFR Part 37, Physical Protection of Category 1 and 

Category 2 Quantities of Radioactive Material.” Additional information regarding best practices 

for protection of risk-significant radioactive material is available in NUREG–2166, “Physical 

Security Best Practices for the Protection of Risk-Significant Radioactive Material.” 

Requirements in 10 CFR 20.2207, “Reports of transactions involving nationally tracked sources” 

The regulations in 10 CFR 20.2207 require that each licensee that manufactures, transfers, 

receives, disassembles, or disposes of a nationally tracked source shall complete and submit an 

NSTTR to the NRC. The NSTTRs are maintained in the NSTS, a secure 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 the source activity decays enough to no longer be 

of concern.

Response from Applicant: No response is required from an applicant or licensee. 

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 industrial radiography sealed sources containing 

byproduct material, or dispose of radiography exposure 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, “Records.” 

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 for the transfer or disposal of 

licensed material. 

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 for the transfer or disposal of licensed material as part of a 

purchase agreement. 
8-56 

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 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 for fees questions is Fees.Resource@nrc.gov. 

8.13 Item 13: Certification 

A representative of the corporation or legal entity filing the application should sign and date 

NRC Form 313. The representative signing the 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 to and responsibility for the radiation protection program. The NRC 

will return all unsigned applications for proper signature. 

Notes:

• It is a criminal offense to knowingly and willfully make a false statement or 

representation on applications or correspondence (18 U.S.C. 1001). 

• When the application references commitments, those items will be incorporated into the 

license and, therefore, become binding regulatory requirements. 
9-1 

9 LICENSE AMENDMENTS AND RENEWALS 

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 changed, 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 either a U.S. Nuclear Regulatory Commission (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, including all required 

program elements outlined in Appendix C of this NUREG. Training documentation for 

personnel currently listed on the license does not need to be submitted as part of the 

renewal application. 

9.1 Timely Notification of Transfer of Control 

Regulation: 10 CFR 30.34(b) 

Criteria: Licensees must provide all supporting information and obtain the NRC’s prior, written 

consent before transferring control of the license, also referred to as a “change of ownership” 

and/or “transferring 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, under 10 CFR 30.34(b) and the Atomic Energy Act, licensees must obtain prior NRC 

written consent before transferring control of the license to ensure the following: 

• Radioactive materials are possessed, used, or controlled only by persons who have 

valid NRC licenses or Agreement State licenses. 

• Materials are properly handled and secured. 

• Persons using these materials are capable, 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. 

• Adequate financial assurance is provided for compliance with the applicable NRC 

requirements, if required. 

• Public health and safety are not compromised by the use of such materials. 
9-2 

Response from Applicant: No response is required from an applicant for a new license. 

However, current licensees should refer to NUREG–1556, Volume 15, “Consolidated Guidance 

About Materials Licenses: Guidance About Changes of Control and About Bankruptcy Involving 

Byproduct, Source, or Special Nuclear Materials Licenses,” for more information about transfer 

of control (i.e., ownership). 

Reference: For further information, see Regulatory Issue Summary (RIS) 2014-08, “Regulatory 

Requirements for Transfer of Control (Change of Ownership) of Specific Materials Licenses,” 

dated May 27, 2014. This RIS can be found on the NRC’s Generic Communications Web page 

under “Regulatory Issue Summaries”: http://www.nrc.gov/reading-rm/doc-collections/gen-comm/
10-1 

10 APPLICATIONS FOR EXEMPTIONS 

Regulations: Title 10 of the Code Federal Regulations (10 CFR) 19.31, 10 CFR 20.2301, 

10 CFR 30.11, 10 CFR 34.111, 10 CFR 37.11 

Criteria: Licensees may request exemptions from the U.S. Nuclear Regulatory Commission 

(NRC) 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. Licensees may also use existing specific exemptions outlined in the 10 CFR 

regulations if they meet the established criteria. 

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, “Specific exemptions;” 10 CFR 34.111, “Applications for 

exemptions;” and 10 CFR 37.11, “Specific exemptions”). 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. Requests for exemptions submitted to the NRC must 

identify the regulation for which the exemption is being requested and include a justification for 

the requested exemption. 

Unless the NRC has granted an exemption in writing, licensees must comply with all 

applicable regulations. 

11-1 

11 TERMINATION OF ACTIVITIES 

Regulations: Title 10 of the Code Federal 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 U.S. Nuclear Regulatory Commission (NRC), in writing, within 60 days of the 

occurrence of any of the following: 

– Expiration of its license. 

– A decision to permanently cease principal activities1

 at the entire site 

– A decision to permanently cease principal activities1 in any separate building or 

outdoor area that contains residual radioactivity such that the building or area is 

unsuitable for release according to NRC requirements. 

– No principal activities1

 under the license have been conducted for a period of 

24 months. 

– No principal activities1

 have been conducted for a period of 24 months in any 

separate building or outdoor area that contains residual radioactivity such that 

the building or area is unsuitable for release according to 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, a 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, leak test results). 

• 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 under 10 CFR 30.36(d), 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. 

 

1

Principal activities are activities that are essential to achieving the purpose(s) for which the license was issued or 

amended. Storage during which no licensed material is accessed for use or disposal and activities incidental to 

decontamination or decommissioning are not principal activities. 
11-2 

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 

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 

List of Documents Considered in Development of this NUREG 

Office of Nuclear Material Safety and Safeguards Letter 

FSME-10-019, “Reporting Requirements for Industrial Radiography,” March 12, 2010, 

(Agencywide Documents Access and Management System (ADAMS) 

Accession No. ML100610424). 

NUREGs 

NUREG–2155, “Implementation Guidance for 10 CFR Part 37, “Physical Protection of Category 

1 and Category 2 Quantities of Radioactive Material,” February 2013 

(ADAMS Accession No. ML13053A061) 

NUREG–2166, “Physical Security Best Practices for the Protection of Risk-Significant 

Radioactive Material” (ADAMS Accession No. ML14150A382) 

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-2007-04 “Personally Identifiable Information Submitted to the U. S. Nuclear Regulatory 

Commission,” March 9, 2007 (ADAMS Accession No. ML063470597). 

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). 

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). 
A–2 

RIS 2014-08 “Regulatory Requirements for Transfer of Control (Change of Ownership) of 

Specific Materials Licenses,” May 27, 2014 (ADAMS Accession 

No. ML13260A342) 

RIS 2015-03 “Identifying and Reporting Security Incidents Under 10 CFR Part 37,” February 

24, 2015 (ADAMS Accession No. ML14255A037) 

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). 

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). 
A–3 

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). 

IN 13-22 “Recent Licensing Submittals Containing Personally Identifiable Information,” 

November 15, 2013 (ADAMS Accession No. ML13247A109) 

APPENDIX B 

U.S. NUCLEAR REGULATORY COMMISSION FORM 313

B–1 

U.S. Nuclear Regulatory Commission Form 313 

Please use the most current version of this form, which may be found at: 

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

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 U.S. Nuclear Regulatory Commission 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, maximum activity per source, and total possession 

limit. 

• 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. 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. 

• 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 records important 

to decommissioning and transfer these records to an NRC or 

Agreement State licensee before licensed activities are 

transferred or assigned, in accordance with 10 CFR 30.34(b). 

Furthermore, pursuant to 10 CFR 30.51(f), prior to license 

termination, we shall forward the records required by 10 CFR 

30.35(g) to the appropriate NRC regional office. 

AND

• If financial assurance is required, submit evidence following 

NUREG–1757, Volume 3. 

[ ] 

[ ] 

6 PURPOSE(S) FOR WHICH LICENSED MATERIAL 

WILL BE USED 

Equipment will be used for the following: 

• industrial radiography 

• underwater radiography (see Appendix D) 

• lay-barge radiography (see Appendix D) 

• offshore platform radiography (see Appendix D) 

• other than radiography (example, Cs-137 instrument calibrator) 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 
C–3 

Item 

No.

Title and Criteria Yes Description 

Attached

7 INDIVIDUAL(S) RESPONSIBLE FOR RADIATION SAFETY 

PROGRAM AND THEIR TRAINING AND 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 (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. 

 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 
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. 

• Submit all training program descriptions noted in 10 CFR 34.43, 

except for those training and examination program topics listed in 

10 CFR 34.43(g). 

• 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 practical field 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 Radiographic Installations

Provide the following information for each permanent radiographic 

installation: 

• Provide an annotated sketch or drawing of the facility and its 

surroundings. (Note: Diagrams of facilities should be marked: 

“Security-related information—Withhold under 10 CFR 2.390.”) 

Sketches or drawings should also include a compass directional 

arrow to indicate “North.” 

• 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 entrance ways 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 

radiographic facility listed in Item 3 (e.g., located in an industrial 

park, an office complex) and its current use. 

• If a proposed permanent radiographic facility is a private 

residence, provide diagrams of the installation 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 0.02 millisievert (mSv) [2 millirem (mrem)] 

in any one hour and less than 1 mSv [100 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. 

• Indicate whether or not radiography will be performed at the place 

of business outside of a permanent radiographic installation. If 

radiography will be performed at a site outside of a permanent 

radiographic installation, provide a diagram of the location where 

radiography may be performed and its surroundings, including a 

description of adjacent property. 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 
C–6 

Item 

No.

Title and Criteria Yes Description 

Attached

9 FACILITIES AND EQUIPMENT 

Permanent Radiographic 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 2 mrem [0.02 mSv] in any one hour: 

• means of preventing 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 sealed sources or type 

(radionuclide) 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 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

 In addition to the above, provide the following information to obtain 

approval for a variance if radiation levels on the radiographic 

installation roof exceed 100 mrem [1.0 mSv] in any one 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 100 mrem [1.0 mSv] in any one 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 or not industrial radiography will be performed at 

the place of business outside of a field station. 

• If radiography will be performed at a site outside a field station, 

provide a diagram of the location where industrial radiography 

may be performed and its surroundings, including a description of 

adjacent property. 

Temporary Jobsites 

Indicate in Item 3 of the application that the applicant is requesting 

authorization to perform work at temporary jobsites anywhere in the 

U.S. where the U.S. Nuclear Regulatory Commission maintains 

jurisdiction for regulating the use of licensed material, including areas 

of exclusive Federal jurisdiction within Agreement States. 

[ ] 

[ ] 

[ ] 

[ ] 

10 RADIATION SAFETY PROGRAM 

1. Audit and Review of 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 
C–8 

Item 

No.

Title and Criteria Yes Description 

Attached

10 RADIATION SAFETY PROGRAM 

2. Instruments 

We will possess and use calibrated and operable radiation survey 

meters. 

AND

Calibration will be performed by an NRC or Agreement State licensee 

specifically authorized to perform instrument calibration. 

OR

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. 

Identify the qualifications of the individuals who will perform the 

calibrations. 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

3. 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. 

AND 

We will develop, implement, and maintain procedures for ensuring 

accountability of licensed materials at all times. 

AND

We will comply with NSTS reporting requirements as described in 

10 CFR 20.2207 

[ ] 

[ ] 

[ ] 
C–9 

Item 

No.

Title and Criteria Yes Description 

Attached

10 RADIATION SAFETY PROGRAM 

4. 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 

5. Leak Tests 

Leak tests sample collection and analysis 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 

sample collection kit supplied by an organization licensed by the NRC 

or an Agreement State to provide leak-test kits and sample analysis 

services to other licensees and according to the instructions provided 

in the leak-test sample collection 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 of NUREG—

1556, Volume 2, Revision 1. 

• We will follow alternate procedures. 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 
C–10 

Item 

No.

Title and Criteria Yes Description 

Attached

10 RADIATION SAFETY PROGRAM 

6. 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 0–200 mrem [0–2 mSv] dosimeters or electronic 

personal dosimeters. 

All radiography personnel will wear alarming ratemeters, except those 

personnel at permanent radiography installations where other 

appropriate alarming or warning devices are in use and are 

operational. 

Pocket dosimeters and alarm ratemeters will be checked for correct 

response to radiation 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. 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

7. 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. Appendix J provides additional information for 

determining that radiation doses for other licensee personnel and 

members of the public will not exceed allowable limits. 

Need Not Be 

Submitted With 

Application 
C–11 

Item 

No.

Title and Criteria Yes Description 

Attached

10 RADIATION SAFETY PROGRAM 

8. Quarterly Maintenance

Submit the quarterly maintenance procedures to the NRC for review 

and approval. The applicant should develop procedures specific to its 

equipment and program. The guidance provided in Sections 8.10.8, 

“Quarterly Maintenance,” and 8.10.9, “Operating and Emergency 

Procedures,” of NUREG–1556, Volume 2 should be of assistance in 

the development of the applicant’s procedures. 

If applicable, submit nonroutine maintenance procedures for NRC 

review and approval. The applicant should develop procedures 

specific to its equipment and program, and in accordance with the 

recommendations of the equipment manufacturer. 

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. 

[ ] 

 [ ] 

[ ] 

9. Operating and Emergency Procedures 

(Note: If requesting authorization for underwater, lay-barge, or 

offshore radiography, provide appropriate additional information 

as described in Appendix D). 

Handling and Use of Sealed Sources and Radiography Exposure 

Devices

Submit operating and emergency procedures that provide step-bystep instructions for using each type of radiographic device. 

Submit operating and emergency procedures that provide instructions 

for performing source exchanges. Instructions for crankout devices 

should be separate from those for other categories of exposure 

devices. 

 

[ ] 

Methods and Occasions for Conducting Radiation Surveys 

Submit operating and emergency procedures that, where applicable, 

include each of the radiation surveys included in Table 8-2. 

 

[ ] 

10 RADIATION SAFETY PROGRAM 

Methods for Controlling Access to Radiographic Areas 

Submit the procedures to control access to radiographic operations 

and storage areas. 

 

[ ] 
C–12 

Item 

No.

Title and Criteria Yes Description 

Attached

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, radiographic exposure 

devices, and source changers. 

 

[ ] 

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 or 

Emergency

Submit operating and emergency procedures that include appropriate 

instructions for notifying the RSO and other personnel in the event of 

an accident or emergency. See Table 8-3. 

 

 

[ ] 

Minimizing Exposure of Persons in the Event of an Accident or 

Emergency—Emergency Procedures 

Submit operating and emergency procedures that include instructions 

for minimizing exposure of persons in the event of an accident. 

 

[ ] 
C–13 

Item 

No.

Title and Criteria Yes Description 

Attached

Source Recovery (Retrieval) 

We will not perform sealed source recovery and will use the services 

of a person specifically licensed by the NRC or an Agreement State 

to perform the recovery of our sealed sources. 

OR 

Submit operating and emergency procedures that include instructions 

for sealed source recovery procedures and specific training. 

[ ] 

[ ] 

Maintenance of Records 

Submit operating and emergency procedures that ensure proper 

maintenance of records 

 

[ ] 

10. Security Program 

Licensees must ensure the security and control of licensed material. 

In accordance with 10 CFR Part 37, “Physical Protection of 

Category 1 and Category 2 Quantities of Radioactive Material,” 

licensees authorized to possess Category 1 or Category 2 quantities 

of radioactive material must establish, implement, and maintain a 

security program to ensure physical protection of the radioactive 

material. 

 Need Not 

Be 

Submitted 

With 

Application 

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 for 

the transfer or disposal of licensed material. 

Need Not Be 

Submitted With 

Application 

Note: Under 10 CFR Part 37, security plans are not to be submitted to the NRC for review 

and approval.

APPENDIX D 

LICENSING GUIDANCE FOR LAY–BARGE, OFFSHORE PLATFORM, AND 

UNDERWATER RADIOGRAPHY

D–1 

Licensing Guidance for Lay–Barge, Offshore Platform, and Underwater Radiography 

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. 

Figure D–1. Offshore Platform 

Offshore Platform Radiography Safety Issues 

• The use of crankout devices for offshore platform radiography has some inherent risk. If 

a sealed source cannot be retracted and/or a disconnect were to occur, source recovery 

resources and expertise may not be readily available. Licensee staff may need the 

appropriate training to perform sealed source recovery operations and be authorized to 

perform such operations under their current license. The licensee should also consider 
D–2 

that shielding may not be available and the difficulty of keeping people away from the 

exposure area. 

• There may be specific physical or space configurations that the licensee needs to 

consider to ensure compliance with the limit of 0.02 mSv [2 mrem] in any one hour in 

unrestricted areas required by Title 10 of the Code of Federal Regulations 

(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 industrial 

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 10 CFR 34.41(c), a licensee may only conduct lay-barge, offshore platform, or 

underwater radiography if procedures have been approved by the U.S. Nuclear Regulatory 

Commission (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), that are unique to offshore 

platform radiography, should minimize the potential for a sealed source disconnect. 

(2) Emergency procedures, as required by 10 CFR 34.45(a), unique to offshore platform 

industrial radiography, should address unintentional sealed 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, radiation 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 industrial radiography 

and 10 CFR 34.46, “Supervision of radiographers’ assistants,” for supervision of 

radiography assistants. 

(4) Operating and emergency procedures and practices, as required to comply with 

10 CFR 34.45(a), should ensure that industrial 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 that the sealed source cannot be fully retracted 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. 

Figure D–2. Lay-Barge 

Lay–Barge Radiography Safety Issues 

• The use of crankout devices for lay–barge radiography has some inherent risk because 

of motion between source (attached to pipe) and crankout device (attached to barge). 

• If a sealed source cannot be retracted and/or a disconnect were to occur, source 

recovery resources and expertise may not be readily available. Licensee staff may need 

the appropriate training to perform sealed source recovery operations and be authorized 

to perform such operations under their current license. The licensee should also 

consider that shielding may not be available and the difficulty of keeping people away 

from the exposure area. 

• There may be specific physical or space configurations that the licensee needs to 

consider to ensure compliance with the limit of 0.02 msv [2 mrem] in any one hour in an 

unrestricted area required by 10 CFR 20.1301. For lay-barges, industrial radiography 
D–4 

should be restricted to the shielded enclosures on the barges, where it is intended to 

be done. 

• Members of the public on the lay–barge (e.g., welders, divers) could receive doses well 

above regulatory limits, in the event of a sealed source disconnect event. 

• Lay–barge operators (who are production oriented) cannot override industrial 

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 and emergency 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), that radiographic personnel can direct 

personnel as necessary for radiation safety both during normal operations and in the 

event that the sealed source cannot be fully retracted, or other emergency. 

Basic Description of Underwater Radiography 

Underwater radiography is a specialized technique that requires additional safety considerations 

because of the use of radiographic equipment submerged in water. For underwater 

radiography, exposure devices are to be provided with additional safety features. The 

necessary features include: 

• A depth rating stating the maximum depth at which the device may be safely used. 
D–5 

• Seals that either prevent the entry of gas or water into parts that are not designed to 

withstand them or, if designed to cope with water and gas, allow them to escape during 

ascent to the surface. 

• A windout exposure or shutter control mechanism that can be operated outside the 

controlled area. 

Underwater Radiography Safety Issues 

• Adequacy of the design of the industrial radiography equipment that is going to be used 

in a water environment. 

• If a sealed source cannot be retracted and/or a disconnect were to occur underwater, 

source recovery resources and expertise may not be readily available. Licensee staff 

may need the appropriate training to perform sealed source recovery operations 

underwater and be authorized to perform such underwater operations under their 

current license. 

• Adequacy of radiation safety training of divers. 

• Before the radiographic equipment is taken into the water, the control mechanism and 

guide tube are to be connected to the exposure container; the connections need to be 

confirmed to be secure; and the source assembly has to be in the secured position. 

• A short line with a buoy and an emergency location device (for example, a strobe light) 

are to be securely attached to the exposure device. This will aid recovery from the water 

if the exposure device is dropped. 

• All equipment, such as radiation survey meters to be used underwater, needs to be 

specifically suited to the purpose. 

• Divers could receive doses well above regulatory limits in the event of a sealed source 

disconnect event. 

• 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 underwater 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 underwater 

radiography, address unintentional source disconnects and recovery. These procedures 

should address minimizing radiation exposure for all personnel (including divers) during 
D–6 

a disconnect event, considering issues such as staff training, availability of portable 

shielding, survey instruments, dosimetry, and radiographic equipment that is appropriate 

for underwater use. 

(3) Operating procedures and practices unique to underwater 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 and emergency procedures and practices, as required by 10 CFR 34.45(a), 

should ensure that radiography personnel have the authority necessary to protect 

personnel from radiation doses in excess of regulatory limits. These procedures and 

practices should include provisions to ensure that underwater radiographic operations 

are conducted only in those locations shielded for such operations. The procedures and 

practices should also ensure that radiographic personnel can direct personnel as 

necessary for radiation safety, both during normal operations, and in the event that the 

sealed source cannot be fully retracted or during any other emergencies. 
APPENDIX E 

RADIOGRAPHER AND RADIOGRAPHER’S ASSISTANT TRAINING

E–1 

Radiographer and Radiographer’s Assistant Training

Table E–1. 10 CFR Part 34, “Radiographer and Radiographer’s Assistant 

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. 

 
E–2 

Table E–1. 10 CFR Part 34, “Radiographer and Radiographer’s Assistant 

Training Requirements” (Continued)

Requirement Training Criteria

34.43(b) Radiographer

D. Must Receive Copies of and 

Instruction in: 

NRC Regulations 

10 CFR Part 34 

• 10 CFR 30.7, 10 CFR 30.9, 10 CFR 30.10, and 

• 10 CFR 37.43 

• 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 70 percent (suggested) 

F. Receive Equipment Training Training includes: 

• exposure devices 

• sealed sources 

• associated equipment 

• radiation 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 of this NUREG) 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 

 
E–3 

Table E–1. 10 CFR Part 34, “Radiographer and Radiographer’s Assistant 

Training Requirements” (Continued)

Requirement Training Criteria

34.43(c) Radiographer’s Assistant

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, 10 CFR 30.10, and 

 10 CFR 37.43 

• 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 70 percent (suggested) 

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 

• radiation 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 of this NUREG) 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.: 

Radiation Survey Meter Functionality: Yes ________ No ________ 

Calibrated: Yes ____ No _____ Daily/Source Check for Operation: Yes _______ No________ 

Dosimetry: TLD/Film Badge/Other Personal dosimetry device and Pocket Dosimeter: 

Yes ________ No _________ 

Calibrated: Yes ________ No ________ 

Alarming Ratemeter: Yes ________ No ________ Calibrated: Yes ________ No ________ 

□ Were other individuals working within the restricted area wearing film badges/TLDs, 

dosimeters, and alarming ratemeters? 

□ 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’s 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’s assistant properly survey the radiographic camera? 

□ Did the radiographer properly supervise the radiographer’s assistant? 

□ Was the radiographic camera properly locked and secured to prevent unauthorized 

removal (two independent barriers)? 

□ Were the security requirements in 10 CFR Part 37 implemented? 

□ Was the restricted area properly controlled for radiological exposure? 
F–2 

□ Were calculations or surveys performed to determine the restricted area boundary? 

□ Was the high-radiation area under continuous direct observation except where entry is 

prevented at permanent radiographic installations. 

□ Were sealed sources 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’s assistant possess and use a copy of the operating 

and emergency procedures and (NRC rules and regulations for protection against 

radiation? 

□ Were there any other safety items found to be lacking? If yes, explain in Remarks. 

Remarks: 

Audit performed by: 
APPENDIX G 

RADIATION SAFETY PROGRAM AUDIT

G–1 

Radiation Safety Program Audit [20.1101(c)] 

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/C1

] 

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] 

4. Potential RSO designee(s) identified, if applicable (34.13) 

C. Radiographers and radiographer’s assistants named in documents [34.43, 34.79; L/C]. 

D. Commensurate security program implemented (37). 

Training, Retraining, and Instructions to Workers 

A. Instructions to workers [19.12] 

B. Parts 19, 20, 21, 34; 37, 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); 34.43; L/C] 

1. Written tests completed by all radiographers and radiographer’s assistants. 

 

1

L/C refers to license condition. 
G–2 

2. Oral tests 

3. All radiographers completed on-the-job training 

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 percent 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)(7)] 

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 [34.43(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); 34.33(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 
G–3 

1. Storage facilities as described in license [L/C] 

2. Sealed Sources locked in exposure devices [34.23] 

3. Exposure devices secured to prevent tampering or unauthorized removal [34.23; 

20.1801; 20.1802] 

4. NRC notified of any temporary jobsite exceeding 180 days (34.101(c)) 

5. Current storage locations comply with the applicable enhanced security program 

requirements [37.74] 

D. Industrial radiography conducted at location identified on license [L/C] 

E. Security of radioactive materials [10 CFR 37] 

Background Investigations and Access Control Program [10 CFR 37, Subpart B] 

Physical Protection Requirements During Use [10 CFR 37, Subpart C] 

Physical Protection in Transit [10 CFR 37, Subpart D] 

Records [10 CFR 37, Subpart F] 

Equipment 

A. Radiography exposure devices, sealed 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; 34.43(b)(3)] 

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)] 

C. During radiographic operations, sealed sources are secured in the shielded position each 

time the source is returned to that position [34.49(b)] 

D. Leakage and contamination tests 

1. Sealed sources 

a. Leak-test method approved [34.27(a)] 

b. Leak tests performed at 6-month intervals [34.27(c)] 

c. Leakage is less than 185 becquerels (Bq) (0.005 microcuries (μCi) [34.27(d)] 

2. Depleted uranium (DU) shielding with S-tubes 

a. Test every 12 months [34.27(e)] 
G–4 

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(a)] 

2. Contain all required information [34.69] 

3. Most recent inventory conducted on: < date > 

4. Annual reconciliation conducted on: < date > 

F. Utilization Logs 

1. Utilization logs maintained [34.71] 

2. Contain all required information [34.71] 

Instrumentation 

A. Describe the survey instruments possessed: 

 Model No. Range: 

B. Capable of measuring 0.02 millisievert (mSv) (2 millirem (mrem)) per hour (h) through 0.01 

Sv (1 rem)/h [34.25(a)] 

C. Operable and calibrated radiation 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(b)] 

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) (dose 

limits to individuals members of the public in accordance with) [20.1501(a)] 

B. Records maintained [20.2103] 

C. Survey after each exposure, including the exposure device and the guide tube, ensuring that 

the sealed source has returned to the shielded position [34.49(b)] 

D. Survey of device any time the source is exchanged and when placed in storage (including 

vehicles) to ensure sealed source is in the shielded position [34.49(c)] 

E. Protection of members of the public [20.1301 and 20.1302] 

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 [20.1301(a)(1)], or 

b. for an individual continuously present in an unrestricted area, the external dose 

would not exceed 0.02 mSv [2 mrem] in an hour and 0.5 mSv [50 mrem] in a year 

[20.1302(b)(2)] 

2. Unrestricted area radiation levels do not exceed 0.02 mSv [2 mrem] in any one hour 

[20.1301(a)(2)] 
G–5 

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 

 Type of Dosimeter 

3. Verify supplier is approved by the National Voluntary Laboratory Accreditation Program 

[20.1501(c), 34.47(a)] 

4. Dosimeters exchanged at required frequency [34.47(a)(3); L/C] 

5. Dosimetry records maintained [20.2106; 34.83(c)] 

B. Pocket Dosimeters and Electronic Personal Dosimeters 

1. Model No. Range 

 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 percent) at intervals not to exceed 12 months 

[34.47(c)] 

5. Off-scale dosimeter procedure and records [34.47; 34.83(d)] 

6. Dosimetry records maintained [20.2106; 34.83(a)] 

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 with an accuracy of ±20 percent of the true radiation dose 

rate [34.47(g))(2)] 

4. Calibrated 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] 
G–6 

6. Fetal and pregnant worker exposure [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 is 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 [20.1101(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] 

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/disposal 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 
G–7 

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 [71.17(c)(1)] 

4. Two labels with Transport Index, Nuclide, Hazard Class [49 CFR 172.403; 172.441] 

5. Properly marked (Shipping name, UN number2

, 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 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 173.25] 

F. Security Plans 

1. Components of a security plan [49 CFR 172.802] 

G. 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 

 

2

The UN number identifies the hazardous substance. The UN number is universally recognized and assigned by the 

United Nations. 
G–8 

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] 

Recordkeeping for Decommissioning 

A. Decommissioning records in independent and identifiable location [30.35(g)] 

B. Decommissioning 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. Inadequate consulting service or inadequate audits
APPENDIX H 

MODEL RADIATION SURVEY INSTRUMENT CALIBRATION PROGRAM

H–1 

Model Radiation Survey Instrument Calibration Program 

Note: This model provides acceptable procedures for calibrating radiation 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 (10 CFR) 34.25, “Radiation survey 

instruments.” 

Training 

Before independently calibrating radiation survey instruments, an individual should complete 

both classroom and on-the-job training as follows: 

• Classroom training may be in the form of lecture, video, computer-based, or self-study 

and will cover the following subject areas: 

– principles and practices of radiation protection 

– radioactivity measurements, monitoring techniques, and the use of radiation 

detection instruments 

– mathematics and calculations basic to using and measuring radioactivity 

– biological effects of radiation 

• On-the-job training will be considered complete if the individual has completed both of 

the following: 

– observing authorized personnel performing radiation survey instrument 

calibration 

– conducting radiation survey meter calibrations under the supervision and in the 

physical presence of an individual authorized to perform calibrations 

Facilities and Equipment 

To reduce doses received by individuals not calibrating radiation survey instruments, 

calibrations will be conducted in an isolated area of the facility or at times when no one else is 

present. 

The calibration source used for calibrating dose and dose rate measuring instruments should be 

well-collimated, and the calibration area should be designed to minimize scatter of radiation, 

which could affect the calibration process. 

The calibration area should be appropriately controlled so that persons entering the area will be 

aware if a radiation source is in use. Posting signs signaling a radiation area may also be 

required. 

Individuals conducting calibrations of radiation survey instruments will wear assigned dosimetry. 

Individuals conducting calibrations will use a calibrated and operable radiation survey 

instrument to ensure that unexpected changes in exposure rates are identified and corrected. 

 
H–2 

Calibration Sources for Dose and Dose Rate Measuring Instruments 

A radioactive sealed source or sealed sources will be used for calibrating dose and dose rate 

measuring radiation survey instruments, and this source should have the following 

characteristics: 

• The source should approximate a point source. 

• Calibration fields from gamma sources should be known with an accuracy when 

compared to secondary or primary national standards of 5 percent for dose rates greater 

than or equal to 1.0 μGy/h [0.1 mrad/h] and 10 percent for dose rates less than 

1.0 μGy/h [0.1 mrad/h]. 

• The source should contain a radionuclide that emits radiation of identical or similar type 

and energy as the environment in which the calibrated device will be used.. 

• The source should be strong enough to give an exposure rate of at least 

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}. 

Note: Inverse square and radioactive decay laws should be used to correct changes in 

exposure rate due to changes in distance or source decay. 

Calibration of Dose or Dose Rate Measuring Instruments 

There are three kinds of scales frequently used on dose or dose–rate radiation survey meters. 

These are calibrated as follows: 

• Linear readout instruments with a single calibration control for all scales will 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 will be adjusted on 

each scale. After adjustment, check the response of the instrument at approximately 

20 percent and 80 percent of full scale. Instrument readings should be within ±x of the 

conventionally true value for the following ranges: 

– background to 10 μGy/h [1.0 mrad/h]; ±x = ±30 percent 

– 10 μGy/h [1.0 mrad/h] to 1.0 mGy/h [100 mrad/h]; ±x = ±20 percent 

– 1.0 mGy/h [100 mrad/h] to 10 Gy/h [1000 Rad/h]; ±x = ±10 percent 

• Logarithmic readout instruments, which commonly have a single readout scale 

spanning several decades, normally have two or more adjustments. Adjust the 

instrument for each scale according to site specifications or the manufacturer’s 

specifications. After adjustment, check the calibration at a minimum of one point on 

each decade. Instrument readings should have a maximum deviation from the 

conventionally true value, as described for linear readout instruments. 

• Digital readout instruments should be calibrated the same as linear readout 

instruments. 
H–3 

Note: Readings above 2.58 × 10−4

 coulomb/kilogram/hour [1 roentgen/hour] need not be 

calibrated, unless the licensee expects to make measurements at higher dose rates; regardless, 

such scales should be checked for operation and response to radiation. 

Calibration of Surface Contamination Measurement Instruments 

Instruments used to detect surface contamination usually consist of a count-rate meter and a 

detector that is appropriate for the type of radiation(s) being measured. 

The efficiency of radiation survey meters must be determined by using radiation sources with 

similar energies and types of radiation that users of the radiation survey instrument intend to 

measure. 

If each scale has a calibration potentiometer, the reading should be adjusted to respond to the 

calibration source at approximately 80 percent of full scale, and the response at approximately 

20 percent of full scale should be observed. If only one calibration potentiometer is available, 

the response should be adjusted at mid-scale on one of the scales, and response on the other 

scales should be observed. The instrument efficiency factor (e.g., cpm/dpm) thus obtained 

should have a signal-to-noise ratio, including the compilation of source and instrument 

uncertainties, of ±x for the following ranges: 

• alpha measurement

0.01 Bq/cm2

 to 2.0 Bq/cm2 (60 to 12,000 dpm/100 cm2); ±x = ±20% 

 2.0 Bq/cm2

 to 200 Bq/cm2 (12,000 to 1,200,000 dpm/100 cm2); ±x = ±10% 

• beta measurement

0.05 Bq/cm2

 to 2.0 Bq/cm2 (300 to 12,000 dpm/100 cm2); ±x = ±20% 

2.0 Bq/cm2

 to 200 Bq/cm2 (12,000 to 1,200,000 dpm/100 cm2); ±x = ±10% 

Calibration Records

Calibration records, for all radiation survey instruments, should indicate the procedure used and 

the results of the calibration. The records should include the following: 

• the owner or user of the radiation survey instrument 

• a description of the radiation survey 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 

• the exposure reading indicated with the radiation survey instrument in the “battery 

check” mode (if available on the instrument) 
H–4 

• for radiation survey instruments with external detectors, the angle between the radiation 

flux field and the detector (i.e., parallel or perpendicular) 

• for radiation survey instruments with internal detectors, the angle between radiation flux 

field and a specified surface of the instrument 

• for radiation 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 and signature of the individual who performed the calibration and the date on 

which the calibration was performed 

The following information will be attached to the radiation survey instrument as a calibration 

sticker or tag: 

• for dose and dose rate measuring instruments, the source radionuclide used to calibrate 

the radiation survey instrument (with correction factors) for each scale 

• for surface contamination measurement instruments, the efficiency of the radiation 

survey instrument, for each of the radionuclides 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 

Reference: Detailed information about portable radiation survey instrument calibration may be 

obtained by referring to American National Standards Institute (ANSI)-N323AB-2013, “American 

National Standard for Radiation Protection Instrumentation Test and Calibration, Portable 

Survey Instruments.” 
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 testing 

and sample analysis independently. 

Classroom training may be in the form of lecture, online, video, hands-on, or self-study and 

should 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 testing and sample analysis 

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, and gas-flow proportional counter 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: 

MDA =

2.71 + 4.65 ඥbkg ×t

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 
I–2 

For example: 

where: bkg = 200 cpm 

E = 0.1 counts per disintegration (10 percent efficient) 

t = 2 minutes 

 

MDA = 

2.71 + 4.65 ඥ200 cpm × 2 minutes

2 × 0.1 = 

2.71 + 4.65 √400

0.2

 

=		

2.71 + 4.65ሺ20ሻ

0.2 		=		

2.71 + 93

0.2 		=		

95.71

0.2

 

=		

478.55 disintegrations

minute 

 

becquerels ሺBqሻ		=		

1 disintegration

second 

MDA =		

478.55 disintegration

minutes × 

minute

60 seconds = 7.976 Bq 

 

Note: The MDA equation shown above assumes that counting times for the background 

measurement and for the sample will be equal. MDA equations for non-equal counting times, 

as well as derivations of equations and discussions of limitations, can be found in 

“Decommissioning Health Physics–A Handbook for MARSSIM Users,” Eric W. Abelquist, 

published by Taylor & Francis Group, 2001. 

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 sealed source to be tested, list identifying information such as sealed source 

serial number, manufacturer, model number, radionuclide, and activity. 

• Use a radiation 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. 
I–3 

• Wipe the most accessible area where contamination would accumulate if the sealed 

source were leaking (see manufacturer’s instructions). 

• Select instrumentation that is sensitive enough to detect 185 Bq [0.005 microcuries 

(μCi)] of the radionuclide contained in the sealed source. 

• Using the selected instrument, count and record background count rate. 

• 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. The 

calibration source must be in the same configuration as the sample. 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 the counting efficiency of the detector. 

 

Efficiency in cpm/Bq =

[(cpm from std) – (cpm from bkg)]

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). The activity 

of the sample in becquerels may be calculated using the following formula: 

 

Activity of sample [Bq] = [(cpm from wipe sample) - (cpm from bkg)]

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) in accordance with 10 CFR 34.27. 

Reference: See NUREG–1556, Volume 18, “Consolidated Guidance About Materials Licenses: 

Program-Specific Guidance About Service Provider Licenses, if the applicant wants to provide 

leak testing and sample analysis as a commercial service provider. 
I–4 

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 a 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 

one 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 one 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 one 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 sealed source is in the shielded position are taken from either the sealed source and device 

(SSD) registration certificate, 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 radiography exposure 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 and the portion of time that both the radiography exposure device and the 
J–2 

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 that could be received. 

Example 1

To better understand the calculational method, Mo-Rad, Inc., a hypothetical industrial 

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 m 

[3.3 ft]. Figure J–1 is Joe’s sketch of the areas in question, and Table J–1 summarizes the 

information Joe has on each device. 

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 
J–3 

Figure J–1. Diagram of Office and Radiography Exposure Device Storage Area. This 

Sketch Shows the Areas Described in Examples 1 and 2.

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 (i) the radiography 

exposure devices are constantly present (i.e., 24 hours per day), (ii) both devices remain in 

storage with no other use, and (iii) 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 

exposure 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 exposure 

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 

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
J–4 

Table J–2. Calculational Method, Part 1: Hourly and Annual Dose Received From 

Device 1 

Step 

No. Description

Device 1 

Input Data Results

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 a year. 

0.76 × 24 × 365 = 0.76 × 

8,760 = 6,658

Table J–3. Calculational Method, Part 1: Hourly and Annual Dose Received from 

Device 2

Step 

No. Description

Device 2 

Input Data Results

1 Dose received in 1 hour at known distance from exposure 

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 exposure 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 a year 

0.34 × 24 × 

365 = 0.34 × 

8,760 = 2,978

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 J.2 and J.3, in mrem in 1 

hour 

0.76 0.34 0.76 + 0.34 = 1.1
J–5 

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

8 TOTAL ANNUAL DOSE RECEIVED from 

Step 6 of Tables J.2 and J.3, in mrem in 

a year 

6,658 2,978 6,658 + 2,978 = 

9,636

Note: The sum in Step 7 demonstrates compliance with the limit of 2 mrem in any one hour. 

Reevaluate if assumptions change. If the sum in Step 8 exceeds 100 mrem in a 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 

one 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. 

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 radiography exposure 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 

a year 

1.1 × 780 = 858
J–6 

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. 

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 a year 

312 × 0.76 = 237 480 × 0.34 = 163
J–7 

Table J–7. Calculational Method, Part 3: Annual Dose Received From Devices 1 and 2

Step 

No. Description Device 1 Device 2

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 a year 

237 + 163 = 400

Note: If the result in Step 17 is greater than 100 mrem in a yr, the licensee must take corrective 

actions. Joe notes that the result in Step 17 does not show compliance with the limit of 

100 mrem in a yr. Since the result in Step 17 is higher than 100 mrem in a 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. Approximate Half-Value Layers for Typical Shielding Materials in Inches 

Steel Lead Concrete

Ir-192 0.5 0.25 1.7 

Co-60 0.8 0.5 2.1 

• Take corrective action (e.g., move radiation exposure 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 firewall. 
J–8 

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 16 

237 163 

19 Number of HVLs (thickness of shielding material 

divided by 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 

20 Fraction of radiation dose transmitted through 

shield: 0.5 (total number of HVLs from step 19); 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 = 0.26 

21 Multiply the results of Step 20 by the results of 

Step 18 = ANNUAL DOSE RECEIVED FROM 

EACH DEVICE, in mrem in a year. 

0.2 × 237 = 47 0.26 × 163 = 42

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 a year. 

47 + 42 = 89 

Note: If the result in Step 22 is greater than 100 mrem in a 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 is 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 radiographic 

exposure 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 radiation survey meters sufficiently sensitive to 

measure background levels of radiation. However, licensees must exercise caution when 
J–9 

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. 

This rate is well below the minimum sensitivity of most commonly available Geiger-Mueller 

radiation 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 mSvin a yr [100 mrem in a 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 in 

a yr [100 mrem in a yr]. 

Example 2 

As in Example 1, Joe is the RSO for Mo-Rad, Inc., an industrial 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 workspace 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.

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 

 100/720 = 0.14 
J–10 

Table J–10. Combination Measurement—Calculational Method 

Step 

No.

Description Input Data and Results

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 a year 

365 × 24 × 0.14 = 8,760 × 0.14 

= 1,226

Part 2 

(This Part is calculated in the same manner as shown in Part 2 of Example 1)

 

Part 3 

(This Part is calculated in the same manner as shown in Part 3 of Example 1)

Note: For the conditions described above, Step 3 indicates that the dose received in any 

one hour is less than the limit of 2 mrem in any one hour. However, if there were any changes, 

then the licensee would need to reevaluate the potential doses that could be received in any 

one 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 radiation 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 one 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 radiographic exposure device and the guide tube to determine that the 

sealed source is in a shielded position. 

• Lock the device and remove the key. 

Note: The U.S. Nuclear Regulatory Commission considers the following very important: 

radiation 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 radiation survey meter. Note that the 

surface reading should not exceed 2 millisievert per hour (mSv/h) [200 millirem per hour 

(mrem/h)]. 
K–2 

(2) Establish and post the restricted and high-radiation areas. 

(3) Attach the end of the sealed source guide tube to the exposure device. 

(4) Connect the other end of the source guide tube to the empty side of the source changer. 

(5) Unlock the empty side of the source changer. 

(6) Unlock the camera and crank out the sealed source from the camera into the 

source changer. 

(7) Survey the source changer and guide tube to verify that the sealed source is in the fully 

shielded position inside the source changer. 

(8) Lock the source changer. 

(9) Disconnect the source guide tube and drive cable to the source pigtail. Replace the dust 

cap on the source changer. 

(10) Remove the sealed source identification plate from the radiography exposure device and 

affix the plate to the side of the sealed 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 sealed source to the drive cable. 

(4) Connect the source guide tube to the source changer. 

(5) Unlock the source changer and retract the new sealed source into the exposure device. 

(6) Survey the exposure device and guide tube to ensure that the sealed source is in the 

fully shielded position. 

(7) Lock the exposure device. 

(8) Disconnect the source guide tube and drive accessories. 

(9) Affix the new sealed source identification plate on the exposure device. 
APPENDIX L 

TRANSPORTATION 

L–1 

Transportation 

Note: The reference charts included at the end of this appendix are for reference only and are 

not a substitute for DOT and NRC transportation regulations. 

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. 49 CFR 172.101, Table 2 to Appendix A-Radionuclides —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 
L–2 

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 

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 172.704—Training requirements (includes types of training, when it must be 

conducted, need for refresher training every 3 years, recordkeeping) 

H. Safety and Security Plans—49 CFR Part 172, Subpart I 

1. 49 CFR 172.800—Applicability and purpose 

2. 49 CFR 172.802—Components of a security plan 

I. 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] 
L–3 

J. 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/. 
L–4 
L–5 
L–6 
L–7 

 
L–8 
L–9 

 
L–10 

 
L–11 

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 

radiographic 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 radiation 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 radiation 

survey meter, obtain another meter and start over. 

(2) Check the radiation survey meter for an appropriate reading with a check source or the 

radiographic exposure device. If reading is not acceptable, obtain another radiation 

survey meter and start again. 

Note: The RSO or calibration vendor should determine the acceptable radiation survey 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, crimping, kinking, 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 radiographic exposure device for damage to fittings, lock, fasteners, 

and labels. 
M–2 

• Check for any impairment of the locking mechanism. 

• 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 sealed 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: 

• Attempt to crank out the source fully into the collimator, which will provide some 

shielding to prevent exposures to the radiographer, radiographer assistant, and 

members of the public. 

Note: Almost all the time that a source cannot be returned to the radiographic camera, 

the source is able to be pushed out to the collimator. The only time this is not the case 

is when there is a kink in the guide tube sufficient to prevent movement of the control 

assembly altogether. 

• 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 recovery until the situation has been discussed with the RSO or 

other knowledgeable personnel. 

• Do not panic. Sealed source recovery 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 sealed 

source recovery 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 is reasonably achievable. Emergency 

equipment may include high-range dosimeters, extra lead shielding, or remote tongs. 
N–2 

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; 

when 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;” and when radiographic exposure 

devices fail to operate as designed. 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, 10 CFR 30.50, 10 CFR 37.57, and 

10 CFR 37.81. 
APPENDIX O

MODEL DELEGATION OF AUTHORITY 

O–1 

Model Delegation of Authority 

Memo To: Radiation Safety Officer 

From: Chief Executive Officer 

Subject: Delegation of Authority 

You, _______________________________, have been appointed radiation safety officer and 

are responsible for ensuring the safe and secure use of radiation. You are responsible for 

managing the Radiation Protection Program, identifying radiation protection problems, initiating, 

recommending, or providing corrective actions, verifying implementation of corrective actions, 

stopping unsafe activities, and ensuring compliance with regulations. You are hereby delegated 

the authority necessary to meet those responsibilities, including prohibiting the use of byproduct 

material by employees who do not meet the necessary requirements and shutting down 

operations, when justified, to maintain radiation safety. You are required to notify management 

if staff does not cooperate and does not address radiation safety issues. In addition, you are 

free to raise issues with the U.S. Nuclear Regulatory Commission at any time. It is estimated 

that you will spend _____ hours per week conducting radiation protection activities. 

____________________________________ ____________________ 

Signature of Management Representative Date 

I accept the above responsibilities, 

_____________________________________ ____________________ 

Signature of Radiation Safety Officer Date 

cc: Affected department heads 

APPENDIX P

CHECKLIST FOR REQUESTS TO WITHHOLD PROPRIETARY 

INFORMATION FROM PUBLIC DISCLOSURE (UNDER 10 CFR 2.390)

P–1 

Checklist for Requests to Withhold Proprietary Information From Public 

Disclosure (Under 10 CFR 2.390)

In order to request that the U.S. Nuclear Regulatory Commission (NRC) withhold information 

from public disclosure, the applicant or licensee must submit the information, including an 

affidavit, in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, “Public 

Inspections, Exemptions, Requests for Withholding.” The applicant should submit all of the 

following: 

 A proprietary copy of the information. Brackets should be placed around the material 

considered to be proprietary. This copy should be marked as proprietary. 

 A non-proprietary copy of the information. Applicants should white out or black out the 

proprietary portions (i.e., those in the brackets), leaving the non-proprietary portions 

intact. This copy should not be marked as proprietary. 

 An affidavit that: 

 Is notarized. 

 Clearly identifies (such as by name or title and date) the document to be withheld. 

 Clearly identifies the position of the person executing the affidavit. This person 

must be an officer or upper-level management official who has been delegated the 

function of reviewing the information the organization is seeking to withhold and is 

authorized to apply for withholding on behalf of the organization. 

 States that the organization submitting the information is the owner of the 

information or is required, by agreement with the owner of the information, to treat 

the information as proprietary. 

 Provides a rational basis for holding the information in confidence. 

 Fully addresses the following issues: 

 Is the information submitted to, and received by, the NRC in confidence? 

Provide details. 

 To the best of the applicant’s knowledge, is the information currently available in 

public sources? 

 Does the applicant customarily treat this information, or this type of information, 

as confidential? Explain why. 

 Would public disclosure of the information be likely to cause substantial harm to 

the competitive position of the applicant? If so, explain why in detail. The 

explanation should include the value of the information to your organzation, the 

amount of effort or money expended in developing the information, and the ease 

or difficulty for others to acquire the information. 

APPENDIX Q 

SAFETY CULTURE POLICY STATEMENT 

Q–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. 

 
Q–2 

The following are traits of a positive safety culture: 

(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. 




NUREG-1556, Vol. 2

Revision 1, Final

Consolidated Guidance About Materials Licenses: Program-Specific 

Guidance About Industrial Radiography Licenses