There is normally no radioactive contamination problem associated with the use of sealed sources in a radiography program. However, if the source capsule should fail because of wear, corrosion, radiation damage, mechanical damage, or for other reasons, the radioactive material inside the capsule may escape and produce a hazard to those who come in contact with the material. Sealed source capsules have failed, and for this reason § 31.105 of Part 31 requires that each sealed source be tested for leakage at intervals not to exceed 6 months. This section also requires that the leak test be capable of detecting the presence of 0.005 microcuries of removable contamination on the sealed source.

Distributors of sealed sources generally supply with each source a certificate which indicates the results and date of the last leak test made. If such a certificate is not received, the source is not to be put into service until a leak test has been performed and the results of the test received. Thereafter, the source must be tested for leakage at intervals not to exceed 6 months. Records of the leak testing of each sealed source identifying the source tested, date of the test and the results of the test in units of microcuries must be maintained for Commission inspection.

The leak testing of sealed sources may be performed only by persons who are specifically authorized by the Commission to do so.

In establishing a program for leak testing, an applicant may choose one of three approaches:

1. He may utilize the services of a consultant or commercial organization, licensed by the Commission to take the smears, evaluate the smears, and report results to the custom

er.

2. He may utilize one of the leak test kits

commercially available. In using these kits, the licensee would be required to (a) take the smear in accordance with specific instructions supplied with the kit, (b) survey the smear for possible gross contamination and (c) send it to the supplier of the kit who evaluates the smear and reports the results to the customer. The licensee using the kit must have specific authorization from the Commission to use this procedure.

3. He may establish his own procedures, and be licensed by the Commission to perform his own leak tests, to include taking and evaluating the smear.

The applicant may choose to utilize a commercially available leak test kit supplied by the manufacturer of the equipment or other commercial organization. Detailed instructions for use are included in each of these kits by the supplier of the kit. Many of the kits referred to in Item 2 above are authorized for use only with specific types of equipment. The application should identify the kit to be used, indicate that the kit will be used in accordance with the instructions provided, and identify the sources, and/or equipment which will be tested using the kit.

Should the applicant desire to conduct his own leak test, the application must contain the information required by § 30.24 (g) (6) of Part 30. The information must provide a description of the instrumentation to be used in evaluating the smear, including its sensitivity, and should include a description of the calibrating and standardizing procedures with a sample calculation showing conversion of results to the required microcurie units. Survey instruments are generally not designed for such measurements and may not be acceptable for this use. A description of the material to be used in taking the smear,

the points on the equipment which will be smeared, the radiation safety and radiation exposure control procedures to be followed during the smearing process, and a description of the methods planned for handling and disposing of the samples should be covered. The application must also specify the training, qualifications, and experience of the person or persons who will take and evaluate the

smears.

Should any leak test reveal the presence of 0.005 microcuries of removable contamination, the source must be considered to be leaking and must be removed from service. Surveys should be made to determine the extent of any contamination which may have spread to personnel, equipment, or facilities, and appropriate decontamination or other control measures taken. A report must be

filed, within 5 days of the test, with the Director, Division of Licensing and Regulation, U.S. Atomic Energy Commission, Washington 25, D.C. A copy of the report must also be sent to the appropriate address listed in Appendix D of Part 20. The report should contain a description of the equipment involved including the make and model number, and must state the results of the test. A description of the surveys which have been made to determine the extent of any contamination spread to personnel, equipment or facilities, and the results of such surveys should be included, along with a description of the corrective steps which have been taken. If plans have been made for the transfer, disposal or repair of the equipment, such plans should also be specified in the report.

The applicant for a license to use byproduct material for radiography must submit in triplicate the completed Form AEC-313R, and all required attachments. Any changes to existing radiography programs will require the issuance of an appropriate license amendment. An application submitted for such an amendment must describe in detail the proposed changes.

Information which has been previously submitted by an applicant may be incorporated into the application by reference. However, the applicant should be sure that the

reference is clear and specific and that the referenced information is appropriate to the radiography program described in the application. (Form AEC-313R is reprinted on the following page.)

Submission of an incomplete application will either result in a delay in issuance of the requested license because of correspondence necessary to obtain the information required, or may, in the case of significant omissions or deficiencies, result in denial of the license application.

An Applicant for a "Byproduct Material License" to possess and use reactor-produced radioisotopes in the form of sealed sources for radiography must complete FORM AEC-313R, and must attach to the completed form the additional information indicated. Three copies of the entire application should be sent to the United States Atomic Energy Commission, Division of Licensing and Regulation, Washington 25, D.C., Attention: Isotopes Branch.

An AEC licensing guide entitled, "Industrial Radiography" contains additional information regarding Commission regulations ap

plicable to the use of sealed sources in radiography. A copy of the guide may be obtained by writing to the address specified above. The guide includes copies of the Commission regulations, Part 30, "Licensing of Byproduct Material"; Part 31, "Radiation Safety Requirements for Radiographic Operations"; and Part 20, "Standards for Protection Against Radiation." The applicant is encouraged to obtain a copy of the guide and to use it in preparing the license application.

Item No.

(a) Identify the legal entity in whose name the license should be issued and who is to be legally responsible for possession and use of the sealed sources of byproduct material.

(b) Check appropriate block indicating organizational structure of applicant. If applicant is other than an individual, the appropriate section on the reverse side of the form must be completed. Use supplemental sheets to provide any additional information which is necessary to explain the legal structure of the applicant.

2 List previous byproduct material licenses by number. If the application is for renewal or amendment of an existing license, the license number should be included and the word "renewal" or "amendment" inserted.

3 List all locations at which the sealed sources will be used and/or stored. If use will be made at temporary or "field" sites, the name of each State in which the sealed sources will be used on a temporary basis should be included. The name and location at which sealed sources will be used on a permanent basis should be identified by the street address, city and State.

4 List the information called for at the head column for each model sealed source to be used for radiography. Follow the alphabetical keying system provided on any supplemental sheets which are attached to the application.

5 Specify the radiographic exposure devices and/or storage containers which will hold the sealed sources identified in Item 4. Each device and/or storage container should be alphabetically keyed to the appropriate source listed in Item 4. If an exposure device or storage container is to be custom fabricated, a complete description of its design and construction should be attached. The limits on levels of radiation for radiographic exposure devices and storage containers set forth in Part 31, Section 31.101 should be considered.

6 Information which has been previously submitted to the Commission may be referred to by date of the document transmitting that information.

(a) Describe the facilities which have been established for conducting radiography. Where a room or rooms have been constructed for this purpose, a sketch should be included which describes dimensions of the room, including wall thickness and materials of construction; areas adjacent to, above, and below the facility; area security safeguards such as locks, posting signs, warning lights, and interlocking systems; position of operator relative to source exposure point; and source positioning limitations which may be necessary to maintain control of radiation levels external to the facility. The applicant should determine the anticipated radiation levels in areas adjacent to the facility in order to establish the necessary control over areas in which radiation levels may exceed the limitations contained in Part 20, Section 20.105(b).

(b) Describe the radiation detection instrumentation which will be used. Each instrument should be identified by the name of its manufacturer and model number; the type of radiation detected; the sensitivity range in mr/hr; the number of such instruments available; and the intended use. The applicant should refer to the radiation survey instrument requirements of Part 31, Section 31.104.

(c) Describe the procedures to be followed for calibration of radiation survey instruments. If instruments will be calibrated by an outside service organization, that organization should be identified by name and address. The applicant should refer to Part 31, Section 31.104 for instrument calibration frequency requirements.

(d) Identify the organization that will supply film badges and list the make and model number of pocket dosimeters or pocket chambers to be used. Refer to Part 31, Section 31.203 and Part 20, Section 20.202.

(e) Attach a copy of the operating and emergency procedures in the form in which they will be supplied to radio

Item No.

graphic personnel. Specific requirements on the content of operating and emergency procedures are contained in Part 31. Be sure to include instructions to personnel on all applicable items in Section 31.202.

Attach a schedule or description of the program for training of radiographers and radiographers' assistants. The schedule or description must contain the information required by Part 30 regarding training programs and must be in sufficient detail to demonstrate that individuals completing the program will meet the requirements for radiographers and radiographers' assistants set forth in Part 31. Refer to Sections 30.24(g)(2) and 31.201.

(g) Describe the internal inspection system or other management control which will be exercised to assure that Commission regulations; license provisions; and the operating and emergency procedures are followed by radiographers and radiographers' assistants. Refer to Part 30, Section 30.24(g)(4).

(h) Attach a description of the overall organizational structure pertaining to the radiography program as it will be conducted under the license. This must include specific delegations of authority and responsibility for operation of the program. Refer to Part 30, Section 30.24(g)(5).

(1) The applicant who desires to conduct his own leak tests should describe the procedures he has established for performing such tests. This must include a description of the method of performing the test (e.g., points on equipment to be smeared and method of taking the smear); the instrumentation which will be used for measuring the quantity of radioactive material which may have been removed by the test; and the pertinent experience of the person who will perform the test and analyze the results. Applicants not desiring to conduct their own leak test may have such tests performed by persons specifically authorized by the Commission to do so. The applicant should refer to Part 31, Section 31.105 for specific leak testing requirements.