Radiation Protection Program - Nrc

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RADIATIONPROTECTIONPROGRAMLA&akSensor Concepts & Applications, Inc.5200 Glen Arm Road, Suite AGlen Arm, MD 21057

PrefaceThis Radiation Protection Program has been written to cover multiple proceduresand situation. Some referenced uses of radioactive sources and the proceduresassociated with them may not be currently applicable to the activities at SensorConcepts & Applications, Inc. (SCA). The scale of this program is to be preparedfor changes in the growth and scope of the use of radioactive sources at SCA.Radiation Protection ProgramSCA is committed to a Radiation Protection Program (RPP) of the highest quality.Likewise SCA hereby commits to full and complete compliance with all relevantrequirements in the Code of Maryland Regulations (COMAR) 26.12.01.01"Regulations for the Control of Ionizing Radiation." This Radiation ProtectionProgram is designed to control operations conducted at SCA and off site locationsthat may result in the potential exposure of SCA personnel, members of thegeneral public and/or the environment to ionizing radiation. SCA's commitmentto the RPP is based on the fundamental principle that levels of radioactivity to beused, and exposures to all sources of ionizing radiation, are to be maintained AsLow As Reasonably Achievable (ALARA).1Revised April 2011

Table of 410.011.012.013.013.1Organizational Outline for Radiation Protection .Designation Description .Organization Chart .Training Requirements .Frequency of Training .Types of Training .Topics .Radiation M onitoring Instruments .Calibration of Dose or Exposure Rate Instruments .Calibration Records .Material Receipt and Accountability .Instructions for Source Material Receipt .Procedure for Opening Packages Containing Sources .Materials Shipping Policy .Occupational and Public Doses .Dose Limits for Individual M embers of the Public .Occupational Exposure Control .Declared Pregnant W orkers .Personnel M onitoring .Proper Dosimeter W ear .Dosimeter Care .Dosimeter Exchange .Lost or Damaged Dosimeters .Exposure Records .Safe Use of Radionuclides .Safe Use of Radiation Producing Systems/Devices .Emergency Procedures .Inadvertent Exposure from Radiation Generating Devices .Radiation Accident Involving Source M aterial .Accidental Ingestion or Inhalation of Source M aterial .M issing or Damaged Source .Surveys and M onitoring .Leak Test Procedures .Transportation .Radiation Protection Program Maintenance .Audit Scope .2Revised April 8191920202020212121

1.0 Organizational Outline for Radiation ProtectionSuperior, consistent performance in radiological control is achieved when:qualified personnel follow proven procedures, management actively monitors theworkplace, and radiation safety personnel audit activities to assess the quality ofwork from a compliance and performance standpoint. Regular review andinformed interest by senior management is required to achieve a superiorRadiation Protection Program.1.1 Designation DescriptionRadiation (Radiological) Worker:These individuals will conduct activities using radioactive materials and workwith radiation producing devices under the direction of an Authorized User.Radiation Worker responsibilities are outlined in Section 1.2.1.Authorized User:This specification of Radiation Worker will oversee operations and assist otherRadiation Workers in the radiological aspects of the job or task. An appointedAuthorized User (AU) will assume the duties of the Radiation Safety Officer(RSO) upon direction by the RSO. It is the responsibility of the AU to directlyoversee personnel and operations as to ensure compliance with radiologicalcontrol policies and procedures. AUs will be approved by the Radiation SafetyCommittee.Radiation Safety Officer:The Radiation Safety Officer (RSO) will be responsible for overseeing theRadiation Protection Program and the requirements of the radioactive materialsand radiation machine facility licenses. The responsibilities of the RSO areoutlined in Section 1.2.2.Assistant Radiation Safety Officer:The Assistant Radiation Safety Officer (ARSO) assists the RSO in themanagement of the Radiation Protection Program.Radiation Safety Committee:The Radiation Safety Committee (RSC) is a body consisting of the RSO, ARSO,Executive Manager and persons trained and experienced in the safe use ofradioactive materials and radiation producing devices. The RSC is responsible forworking with Executive Management and the RSO in implementing andmanaging the Radiation Protection Program.Executive Management:Executive Management is the individual at the senior management level who isresponsible for the oversight of the SCA's radiation safety program and has theultimate responsibility for the licenses and the activities associated with the3Revised April 2011

license. Executive Management has an important role in implementing andmanaging the radiation safety program and reports to SCA's Board of Directors.1.2 Organization ChartThe following organizational chart depicts the control hierarchy of the RadiationProtection Program:SCA's Board of DirectorsF Executive ManagementIRadiation Safety Committee ChairdiatOfficerA Radiation SafetyF Asistant Radiation Safety OfficerIAuthorized UsersF1.2.1IRadiation WorkersRadiation (Radiological) Workers1. Radiation Workers will be familiar with this Radiation Protection Programand all relevant SCA procedures. As a rule, the following responsibilitieswill be met by all Radiation Workers:2. Keep exposures to ionizing radiation As Low As Reasonably Achievable(ALARA).3. Conduct a whole body survey prior to exiting a restricted area whereunsealed radioactive material was used or whenever contamination issuspected.4. Wear the proper personal protective equipment (PPE) when working withor handling unsealed radioactive materials. PPE will not be worn outsideof controlled areas.5. There will be no eating, drinking, smoking, chewing gum, eating utensilsor application of cosmetics in areas under radiological control. Noevidence of the aforementioned activities will be discarded into trashreceptacles in controlled areas.6. Maintain good personal hygiene. Wash hands and wrists thoroughly afterexiting an area under radiological control.4Revised April 2011

7. Use double gloves when working with radioactive materials if there is anabrasion of the skin below the wrist.8. Survey the work area for radioactive contamination upon completion ofwork involving unsealed radioactive material in unsealed form.Contaminated areas must be decontaminated immediately.9. All radioactive samples, contaminated equipment and waste containerswill be appropriately labeled.10. The RSO or designee will be immediately notified of any personalcontamination, internal exposure or a major spill involving radioactivematerials.11. Report all findings during contamination surveys in units of radioactivity(e.g. DPM or microcuries).12. Report all evidence of non-compliance to the RSO, ARSO, RSC or Stateof Maryland1.2.2Radiation Safety OfficerThe Radiation Safety Officer (RSO) is charged with the implementation,maintenance, oversight and periodic modification of the Radiation ProtectionProgram. The RSO's duties and responsibilities also include ensuringradiological safety and compliance with State of Maryland, Nuclear RegulatoryCommission (NRC) and Department of Transportation (DOT) regulations and theconditions of the license. In support of this requirement the RSO will:1. Maintain surveillance of overall activities involving radioactive materialand use of radiation producing devices, including monitoring andsurveying of all areas in which radioactive material or radiation producingdevices are used.2. Ensure compliance with rules and regulations, license conditions, and theconditions of project approvals authorized by the Radiation SafetyCommittee.3. Monitor and maintain absolute and other special filter systems associatedwith the use, storage, or disposal of radioactive material.4. Provide necessary information on all aspects of radiation protection topersonnel at all levels of responsibility.5. Oversee proper delivery, receipt, and conduct radiation surveys of allshipments of radioactive material arriving at or leaving from the facility,as well as packaging and labeling of all radioactive materials leaving theinstitution.6. Distribute and process personnel radiation monitoring equipment,determine the need for and evaluate personnel radiation monitoring,review exposure records for trends and high exposures, notify individualsand their supervisors of radiation exposures approaching maximumpermissible amounts, and recommend appropriate remedial action.7. Conduct training programs and otherwise instruct personnel in the properprocedures for the use of radioactive material and radiation producing5Revised April 2011

8.9.10.11.12.13.14.15.1.2.3devices prior to use, at periodic intervals (refresher training), and asrequired by changes in procedures, equipment, regulations, etc.Supervise and coordinate any radioactive waste disposal program, whichmay include effluent monitoring. Maintain waste storage and disposalrecords.Store radioactive materials not currently in use, including waste.Perform or arrange for leak tests on all sealed sources and calibration ofradiation survey instruments.Maintain an inventory of all radioisotopes and limit the quantity ofradionuclides to the amounts authorized by SCA's Radioactive Materialslicense.Immediately terminate any activity that is found to be a threat to publichealth and safety or property.Supervise decontamination and recovery operations.Maintain other records not specifically designated above.Hold periodic meetings with, and provide reports to, the Radiation SafetyCommittee and Executive Management.Assistant Radiation Safety OfficerThe ARSO shall support the RSO in his or her daily duties to ensure compliancewith all local, state, federal, and license specific requirements or commitments.The ARSO shall adhere to all procedural guidelines and requirements for programmaintenance found in this Radiation Protection Program.1.2.4Radiation Safety CommitteeThe Radiation Safety Committee (RSC) is responsible for the oversight of SCA'sRadiation Protection Program. In fulfillment of this role, the RSC promulgatespolicies, rules and procedures for the safe use of radioactive material andradiation producing devices. The RSC has the authority to grant, deny, orwithdraw permission for the use of radioactive materials and or radiationproducing devices. It is the intent of SCA that no use of radioactive materials orradiation producing devices precedes without the knowledge and approval of theRSC. The committee will consist of: the President of SCA (ExecutiveManagement representative), the RSO, ASRO, and an Administrativerepresentative. The Radiation Safety Committee size and composition shall belarge enough to represent the spectrum of radiation users at SCA. Members shallhave been trained and have experience as radiation workers including the safehandling of radioactive materials and the use of radiation producing devices. Awritten record of all meetings will be maintained by the Chairperson.Specific duties and responsibilities of the RSC include:1. Review the training and experience of the proposed Authorized Users andthe Radiation Safety Officer (RSO) to determine that their qualificationsare sufficient to enable them to perform their duties safely and inaccordance with the regulations and the license.6Revised April 2011

2. Review and approve or deny all requests for authorization to useradioactive material, maintaining consistency with the regulations, thelicense and the As Low As Reasonably Achievable (ALARA) philosophy.3. Prescribe special conditions that will be required during a proposedmethod of use of radioactive material or radiation producing devices suchas requirements for personal monitoring, physical examinations of usersand special monitoring procedures.4. Review annually, the RSO's summary report of the occupational radiationexposure records of all personnel.5. Establish programs to ensure that all persons whose duties may requirethem to work in or frequent areas where radioactive materials or radiationproducing devices are used are appropriately trained.6. Review annually the RSO's summary report of the entire radiation safetyprogram to determine that all activities are being conducted safely, inaccordance with regulations and the conditions of the license, and areconsistent with the ALARA program and philosophy. The review mustinclude an examination of records, reports from the RSO, results ofprogram audits, written safety procedures and the adequacy of themanagement control system.7. Recommend remedial action to correct deficiencies identified in theradiation safety program.8. Maintain written minutes of all Committee meetings, including membersin attendance and members absent, discussions, actions, recommendations,and decisions9. Conduct periodic audits, in conjunction with the RSO, of the radiationprotection program. Review findings of annual audits and act uponrecommendations.1.2.5Executive ManagementEffective radiation safety program management is vital to achieving safe andcompliant operations. SCA believes that consistent compliance with applicableregulations provides reasonable assurance that licensed activities will beconducted safely. SCA also recognizes that effective management will result inincreased safety and compliance."Management" refers to the processes for conducting and controlling the radiationsafety program and to the individuals who are responsible for those processes andhave authority to provide necessary resources to ensure safety and to achieveregulatory compliance.To ensure adequate management involvement, a duly authorized executivemanagement representative must acknowledge management's commitments andresponsibility for the following:1. Radiation safety, security and control of radioactive materials, andcompliance with regulations;7Revised April 2011

2. Completeness and accuracy of radiation safety records and all informationprovided to the State of Maryland;3. Knowledge about the contents of licenses and applications;4. Compliance with current State of Maryland, NRC and Department ofTransportation (DOT) regulations and SCA's operating and emergencyprocedures;5. Commitment to provide adequate resources (including space, equipment,personnel, time, and contractors) to the radiation protection program toensure that public and workers are protected from radiation hazards andcompliance with regulations is maintained;6. Selection and assignment of qualified individuals to serve on the RadiationSafety Committee and to serve as the Radiation Safety Officer for licensedactivities; and7. Prohibition against discrimination of employees engaged in protectedactivities.2.0 Training RequirementsIndividuals working in or frequenting restricted areas must meet the followingapplicable training requirements. These training requirements shall be continuallyreviewed and revised in order to provide function-specific and need-specifictraining. Therefore these requirements may be modified. Training shall beconducted by the Radiation Safety Officer, or someone of similar training andexperience, in accordance with outlines reviewed and approved by the RadiationSafety Committee.2.1 Frequency of TrainingAs a rule, Radiation Safety training will be required:1.2.3.Before assuming duties with, or work in the vicinity of, radioactivematerials or radiation producing devices.Whenever there is a significant change in duties, regulations, or theterms of the license.Annually (refresher training).2.2 Types of TrainingIn order to meet function specific training requirements, the following types oftraining will be offered, at a minimum:1. General Employee Radiation Training (GERT), Initial2. Radiation Worker Training, Initial3. GERT, Refresher4. Radiation Worker Training, RefresherAn examination is required for Radiation Worker training completion with aminimum passing grade of seventy percent.8Revised April 2011

2.3 TopicsThe topics that are covered in any training will be designed to meet functionspecific training needs. The following topics are samples of material that may becovered during training.2.3.1General InformationA.General Awareness1.Signs and labels2.Notice to Employees3.License Scope4.Emergency response5.Restricted access, Facility requirementsB.Radiation Safety1.Radiation versus Contamination2.Internal versus External exposure3.Biological effects of radiation4.ALARA philosophy5.Use of time, distance, and shielding to minimize exposureC.2.3.2A.B.C.D.E.F.G.Regulatory requirements1.Organization of Radiation Safety Program2.Material control and accountability3.Personnel dosimetry4.Radiation safety program audits5.Materials Transfer and disposal6.Recordkeeping requirements7.Surveys: frequency, type and responsibilities8.Postings9.Labeling of containers10.Handling and reporting of incidents or events11.Licensing and inspection by the Maryland Department of theEnvironment12.Need for complete and accurate information13.Employee protection14.Deliberate misconduct, disciplinary actionsLicense-Specific Program ElementsAuthorized Users and Radiation WorkersOrdering and receiving radioisotopesApplicable regulations and License conditionsAreas where radioactive material is used or stored, Restricted AreasAreas where radiation producing devices are used, Exclusion ZonesPotential hazards associated with radioactive material or radiationproducing devices in each area where the individuals will workRadiation safety procedures9Revised April 2011

H.I.J.K.L.M.N.0.P.R.S.T.U.SCA Rules and ProceduresEach individual's obligation to report unsafe conditions to the RSOAppropriate response to spills, emergencies or other unsafe conditionsA worker's right to be informed of occupational radiation exposure, ifapplicableLocations where SCA has posted or made available: notices, copies ofpertinent regulations, and copies of pertinent licenses and licenseconditions (including applications and applicable correspondence), asrequired by State regulationsEmergency procedures:1.RSO name and telephone number2.Immediate steps to prevent or control spread of contamination3.Spill response instructionsDosimetry1.Whole body2.Extremities3.Lost or replacement badges and dose assessment4.RecordsSurvey meters and direct read dosimetry1.Use and care2.Calibration frequency3.Use of check sourcesProcedures for receiving packages containing radioactive materials1.Normal business hours2.Off-hours restriction3.Notification of user and RSO4.Security issues5.Exposure levels6.License possession limits7.Receipt of damaged or unauthorized packagesProcedures for opening and examining packages1.Package condition, leakage and contamination2.Monitoring packages3.Monitoring packing materials4.Personal Protective Equipment.5.Transferring material to usersSealed Sources1.Leak test requirements2.Inventory requirements3.Exempt quantities4.RecordsOther topics, as applicableQuestion and answer period10Revised April 2011

2.3.3A.B.C.D.E.F.G.H.I.J.K.L.Use of RadioisotopesControl procedures for obtaining permission to use radioactive materialsat SCAProcedure limitations and requirementsSafety precautions and what equipment to useLimitations and conditions relative to handling unsealed licensedmaterial (shielding, engineering control requirements, etc.)Routine survey and monitoring procedures to be followed forcontamination controlEmergency procedures concerning spills, fires, release of material,and/or accidental contamination of personnelDecontamination procedures to use and whom to contact in case of anemergencyInstructions concerning transfer of licensed materials between areasRequirements for storage, labeling of containers, and identification ofareas where licensed materials are usedPersonnel monitoring devices to use, where to obtain them, andexchange procedures and exposure resultsWaste disposal procedures to follow, limitations for disposal of liquid orsolid wastes, and procedures to use for waste storage.Records to be maintained on use and disposal of licensed materials3.0 Radiation Monitoring InstrumentsRadiation detection instrumentation will be available in sufficient types andquantities as to support the scope of SCA operations involving radioactivematerials and/or radiation producing devices.SCA currently maintains the following list of portable radiation detectioninstrumentation. This list is subject to change based on operations and therecommendations of the Radiation Safety Committee. Portable instruments willbe calibrated at yearly intervals by a licensed calibration vendor. At a minimum,portable survey instrumentation will be readily available for use within alllocations using penetrating sources of radiation ( 250 keV). The RSC willvalidate the appropriateness of the number and type of available instrumentationduring the procedure review process.PRESENT INSTRUMENT INVENTORYINSTRUMENT MAKEMODELSERIAL NUMBERIon Chamber Survey Meter451P-RYR0025Ion Chamber Survey Meter451 P-RYR0734Ion Chamber Survey Meter451P-RYR1230Ion Chamber Survey Meter451P-DE-SI6231GM pancake probe489-11OD125493Neutron probeRP-N105990Readout Meter for probes190N10619911Revised April 2011

3.1 Calibration of Dose or Exposure Rate InstrumentsSCA will employ a fully licensed vendor to perform all dose rate calibrations.Currently, Fluke Electronics Corporation, 6045 Cochran Rd., Cleveland, OH44139 or Ludlum Measurements, Inc., 501 Oak St., Sweetwater, TX performs thisservice. SCA has not requesting license authority to perform such calibrations.3.2 Calibration RecordsCalibration records, for all survey instruments, will be provided by a licensedvendor and maintained by SCA Radiation Safety staff. The RSO maintains anelectronic computer database of all radiation monitoring instruments that requireannual calibration. The RSO receives calibration certificates from the licensedvendor and enters the date of calibration into this database. The licensed vendoralso sends a reminder notification to the RSO that an instrument is due forcalibration. The RSO then contacts the Authorized User to have the instrumentsent for calibration. The Authorized User will be provided with a back-up surveyinstrument when his/her assigned instrument is sent for calibration.3.2.1Frequency of CalibrationSCA is committed to an annual calibration schedule. In addition, specialcalibrations will be performed at any time there is reason to believe that theoperating characteristics of a metering device have been changed, by repair oralteration, or whenever system performance is observed to have changedsignificantly. Routine instrument maintenance will be performed asrecommended by the manufacturer.4.0 Material Receipt and AccountabilityThe Radiation Safety Officer, or designee, will approve all orders for radioactivematerial and will ensure that the requested material, quantities, manufacturer, andmodel are authorized by the SCA license and that the possession limits are notexceeded. All packages are to be delivered during normal operating hours. Noafter hours, weekend or holiday deliveries will be accepted. All carriers should beinstructed to deliver radioactive packages directly to the RSO.Table 1 DOT LabelsPACKAGELabeled (White I,Yellow II, YellowIII)CONTENTSGas or SpecialForm greater thanType A quantitiesSURVEY TYPERadiation LevelLabeled (White I,Yellow II, YellowIII)Not Gas NorSpecial Formgreater than TypeA quantitiesContamination &Radiation Level12Revised April 2011SURVEY TIMEAs soon aspracticable, butnot later than 3hours after receiptAs soon aspracticable, butnot later than3hours after

receiptLabeled (White I,Yellow II, YellowIII)Labeled (White I,Yellow II, YellowIII)Gas or SpecialForm Less thanType A quantitiesGas or SpecialForm greater thanType A quantitiesNoneNoneContaminationNot LabeledLicensedMaterialsNoneAs soon aspracticable, butnot later than 3hours after receiptNone4.1 Instructions for Source Material Receipt4.1.1Shipping and Receiving PersonnelDuring normal working hours, immediately upon receipt of any package oflicensed material, each package must be visually inspected for any signs ofshipping damage such as crushed or punctured containers or signs of dampness.Any obvious damage must be reported to the RSO or his/her designee,immediately. Do not touch any package suspected of leaking. Request the persondelivering the package to remain until monitored by the RSO, or his/her designee.Outside of normal working hours (e.g., nights, weekends, and holidays),deliveries should be refused.Since certain packages of licensed material will have detectable externalradiation, they should be sent immediately to a designated storage area, wherethey will be checked for contamination and external radiation level as soon aspractical. They should not be allowed to remain in the receiving area any longerthan necessary, as they may be a source of exposure for receiving personnel. Ifthe instructions are not clear, or if there are questions regarding receivingpackages containing radioactive material, please contact the Radiation SafetyOfficer.4.2 Procedure for Opening Packages Containing SourcesFor packages received under this license, authorized individuals shall implementprocedures for opening each package, as follows:1. Wear gloves to prevent hand contamination.2. Visually inspect the package for any sign of damage (e.g. crushed,punctured). If damage is noted, stop and notify the RSO.3. Check DOT White I, Yellow II, or Yellow III label or packing slip foractivity of contents, to ensure shipment does not exceed license possessionlimits.4. Monitor the external surfaces of a labeled package according tospecifications in the Table 1 in 4.0.5. Open the outer package (following supplier's directions if provided) andremove packing slip. Open inner package to verify contents (compare13Revised April 2011

6.7.8.9.requisition, packing slip and label on the pig or other container). Checkintegrity of the final source container (e.g., inspecting for breakage ofseals or vials, loss of liquid, discoloration of packaging material, highcount rate on smear). Again, check that the shipment does not exceedlicense possession limits. If you find anything other than expected, stopand notify the RSO.Place the source in the secure radioactive materials storage area.Survey the packing material and packages for contamination beforediscarding. If contamination is found, treat as radioactive waste. If nocontamination is found, remove or obliterate the radiation labels prior todiscarding in the regular trash.Maintain records of receipt and package survey results.Notify the RSO and the final carrier when removable radioactive surfacecontamination or external radiation levels exceed the packaged specifiedlimits.4.3 Materials Shipping PolicyLicensed material shall not be transferred or shipped from one location to anotherwithout the approval of the RSO. Such transfers/shipments must be packaged andlabeled in accordance with DOT, NRC, or U.S. Postal Service Regulations,whichever is applicable. In addition the receiving organization must be licensedfor the material and willing to accept the liability associated with receipt andpossession of the material.5.0 Occupational and Public Doses5.1 Dose Limits for Individual Members of the PublicSCA does not allow access to its facilities by members of the general public. Inaddition, SCA's use of source materials or radiation producing devices isrestricted to controlled areas. SCA operations will be conducted so that doses toindividual members of the public will be within the regulatory limits, 0.1 Rem ina year.5.2 Occupa

The Assistant Radiation Safety Officer (ARSO) assists the RSO in the management of the Radiation Protection Program. Radiation Safety Committee: The Radiation Safety Committee (RSC) is a body consisting of the RSO, ARSO, Executive Manager and persons trained and experienced in the safe use of radioactive materials and radiation producing devices.

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