Attachment_41 _CDP_Radiation_Safety_Program.pdf

U.S. Department of Homeland Security Federal Emergency Management Agency Center for Domestic Preparedness

CDP Radiation Safety Program

CDP 5304.0

(March 2010)

Contract Use Only

Copy ____ of ____

CDP Radiation Safety Program Table of Contents CDP 5304.0 Rev. 0 (Mar 10) i

TABLE OF CONTENTS

Introduction

Annex A – Ionizing Radiation

Annex B – Safety Standards, Dosimetry & Recordkeeping

Annex C – Special Reporting Requirements

Appendix A – References

Appendix B – Glossary

Appendix C – Radiation Management Flow Chart

Appendix D – Approved Permanent Location Storage Areas

CDP Radiation Safety Program Introduction CDP 5304.0 Rev. 0 (Mar 10)

Introduction

1. PURPOSE. This program establishes policies and procedures for the use of, licensing, disposal, transportation, safety design, and inventory control of ionizing radiation sources used by the Department of Homeland Security (DHS), Federal Emergency Management Agency (FEMA), Center for Domestic Preparedness (CDP). It also provides radiation exposure standards, dosimetry monitoring, and accident reporting instructions. Its objective is to assure safe use of radiation sources and compliance with all applicable Federal and State regulations.

2. APPLICABILITY. This program applies to all elements of the CDP and all activities supported by the CDP involving procurement, receipt, handling, transporting, storage, use, maintenance, and disposal of radioactive materials and other sources of ionizing radiation. This program also applies to contractors, sub contractors, and all other individuals who work in (or visit) CDP facilities.

3. REFERENCES. Required, related and referenced publications are listed in Appendix A.

4. EXPLANATION OF TERMS. Abbreviations and special terms used within this program are explained in the glossary, Appendix B.

5. RESPONSIBILITIES.

a. Superintendent, CDP will:

(1) Designate in writing a qualified individual to serve as the CDP Radiation Safety Officer (RSO);

(2) Ensure a written Radiation Safety Program is established to provide compliance with applicable Federal and State regulations.

b. Director, Operations and Support will:

Ensure that adequate personnel are assigned, and the necessary facilities and equipment are available to manage the CDP Radiation Safety Program.

CDP Radiation Safety Program Introduction CDP 5304.0 Rev. 0 (Mar 10)

c. CDP Safety and Occupational Health Manager/CDP RSO will:

(1) Establish written policies and procedures to assure compliance with applicable Federal and State radiation safety regulations and directives;

(2) Ensure that an internal or external audit of the Radiation

Safety Program is conducted annually;

(3) Direct the CDP Radiation Safety Program;

(4) Serve as technical advisor to the CDP Superintendent and senior management on matters pertaining to the acquisition, use, storage, and disposal of all radioactive materials;

(5) Perform and/or oversee radiation surveys required to document that operations involving the use of radiation sources are conducted in compliance with all Federal and State regulations and directives;

(6) Review plans and procedures relating to operations conducted or being proposed which involve radioactive materials

d. CDP Contractor Project Managers that conduct operations involving ionizing radiation sources will:

(1) Ensure adequate facilities, personnel and equipment are available to comply with applicable Federal and State regulations regarding the use of radiation sources;

(2) Provide management assistance in the enforcement of policies and procedures established within this program.

6. DEVIATIONS.

a. This program document serves as the Nuclear Regulatory Commission's (NRC) mandated Radiation Safety Program document and as such becomes a condition of the NRC license.

b. Request for deviations will be reviewed and forwarded through the office of the CDP RSO.

c. Deviations will be documented and a copy of the deviation granted will be maintained by the CDP RSO.

CDP Radiation Safety Program Annex A Ionizing Radiation Rev. 0 (Mar 10)

Annex A Ionizing Radiation

1. GENERAL.

a. Compliance with NRC regulations and NRC licenses

(1) All personnel working with radioactive material under an authority issued by the CDP will comply with all applicable NRC regulations and conditions of NRC licenses.

(2) All Directors, Assistant Directors, Contractor Project

Managers, and Supervisors will ensure that personnel working with radioactive materials are aware of applicable regulations and conditions that apply.

b. Sources of ionizing radiation used that do not require NRC licensing will be controlled to the same extent as those requiring licensing.

c. Shielding and control designs. The CDP RSO will evaluate all design plans for use with any source of ionizing radiation capable of generating a "Radiation Area" as defined in the glossary.

d. Any area accessible to individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of

0.005 Rem (0.05 mSv) in 1 hour at 30 centimeters from the

radiation source or from any surface that the radiation penetrates will be designated a radiation area. There are no high or very high radiation areas at the CDP.

2. NUCLEAR REGULATORY COMMISSION LICENSES.

a. The issuance of an NRC license is required for the possession of by-product, source, and/or special nuclear material.

b. The management of the CDP NRC license is conducted through the CDP RSO.

c. Requests for radioactive materials not already authorized by the current NRC license will be processed through the CDP RSO office. Requisition of sources requiring NRC licensing will not be initiated until necessary NRC license amendments are received.

3. NON-NRC LICENSED RADIATION SOURCES.

a. Radioactive materials not requiring NRC licensing are authorized for use by the CDP RSO.

b. Exempt quantities of radioactive material may be possessed and used only by CDP RSO approval and will be inventoried annually.

c. Applicable authorizations will be approved and implemented prior to the acquisition of any radiation sources.

4. INVENTORY MANAGEMENT.

a. Current radiation inventories are required to ensure the CDP does not exceed the established limits of possession assigned by the CDP NRC license.

b. Procurement of all radiation sources will be coordinated through the

CDP RSO office.

(1) Requested radioactive isotope and activity will be verified against license authorization and current inventory to ensure that material is authorized and that possession limits are not exceeded.

(2) All radioactive material will be processed through the radiation safety office. If special handling is necessary (chemical surety material, biological material, classified, etc…) appropriate personnel will work in conjunction with the radiation safety office to ensure proper handling and safety precautions.

c. The CDP RSO will ensure active inventories are documented and maintained. An inventory check will be conducted at the end of each training exercise as well as every six months to ensure the control of radioactive materials.

d. Records of isotope inventories will be maintained and will include, at a minimum, the following information: radionuclide, quantities, manufacturer's name and model numbers and the date of the inventory.

5. LEAK TEST.

a. Sealed sources of radioactive material authorized by the CDP NRC license are required to have periodic leak testing unless specifically exempted by the NRC.

(1) Sealed sources designed to emit alpha radiation will be leak tested at least every three months.

(2) Sealed sources designed to emit beta/gamma radiation will be leak tested at least every six months.

(3) Sealed sources that are designated as “in storage” and/or awaiting disposal shall be leak tested every 10 years.

b. Radioactive material authorized under a manufacturer's general license will be leak tested at a frequency not to exceed that required by the manufacturer.

c. Results of leak tests will be in units of microcurie (µCi) and maintained on file.

6. SURVEYS.

a. Surveys will be conducted monthly to ensure the magnitude and extent of radiation levels of radioactive materials do not exceed regulatory limits.

b. Portable radiation instrumentation used to quantify radiation levels or to make determination of the presence and extent of radioactive contamination will be calibrated "Active" through the Test Measurement and Diagnostic Equipment (TMDE) Activity or approved commercial calibration facility. Calibration frequencies will be in accordance with manufacture’s specifications, but will not exceed a period of at least once per year.

c. Records of required surveys will be maintained by the CDP RSO.

7. RADIOACTIVE MATERIALS DISPOSAL.

a. Transfer of unwanted radiation sources will be coordinated through the CDP RSO office. No radioactive material or sources of radiation will be disposed of through the use of normal trash removal.

b. Unwanted radiation sources will be transferred using the following general guidelines:

(1) Items that have other hazardous materials as well as a radioactive component will be segregated and all hazards identified at the time of request for disposal.

(2) Radioactive material will remain on the inventory until physical transfer of material has occurred.

(3) Sealed sources of radioactive material, not known to be leaking, will be placed in an intermediate container (i.e., zip lock bag or single clear trash bag). Sources known or suspected of leaking will be placed in double bags.

(4) The CDP RSO will maintain the active inventory for items designated for disposal.

c. Equipment containing radiation sources will only be transferred or sent for disposal to licensed and/or permitted facilities. Transfers and/or disposals will follow all pertinent NRC and Department of Transportation (DOT) regulations.

d. Records of transfer and/or disposal of radioactive material will be maintained by the CDP RSO and kept for a minimum of three years.

8. SERVICE and/or REPAIR PROCEDURES

On site service and/or repair of chemical agent monitors shall be accomplished utilizing the below procedures. In addition, service and/or repair technicians coming on site to perform service and/or repair of chemical agent monitors will receive one to two hours of site and source specific training before beginning work.

NOTE: Pages 5 – 8 outline procedures for APD 2000.

Pages 9-21 outline procedures for ICAM.

SIEVE REPLACEMENT, GENERAL MAINTENANCE, AND/OR REPAIR

PROCEDURES FOR APD 2000

CAUTION

Do not disassemble the cell containing the Ni-63 radioactive source

OP.# OPERATION DESCRIPTION

Return & Repair Step 1.) Leak test

a. Using filter paper or a cotton bud, wipe a random area approximately 100 sq/cm of the unit surface.

b. Analyze the smear using a Liquid Scintillation counter (LSC).

c. Verify the dpm level reported by the LSC is less than 100. If so proceed to operation 20.

d. If over 100 dpm report to the Radiation Safety Officer for instructions of how to proceed.

Step 2.) Disassembly and General Maintenance: Check Unit for visual damage. Record any findings on APD2000 Repair/Evaluation Sheet.

Step 3.) Remove inner chassis from APD as follows:

a. Remove four screws used to attach Front Bezel.

b. Remove Protective Cap and Nut from Aux. Port connector.

c. Remove Nozzle Cover and Nut securing Nozzle at front of APD.

d. Push on Nozzle to begin to remove chassis from Case.

e. While removing chassis, feed Aux. Port connector through opening in Case.

OP.# OPERATION DESCRIPTION

Cont’d

f. When unit is fully removed from Case, loosen CCA screws to allow for removal of Battery Wire connector. Remove connector and tighten screws back.

g. Remove Charcoal Filter by loosening and removing fittings on both ends.

h. Disconnect Ammonia Source by removing connector and two screws at Sieve Pack.

Step 4.) Replace Charcoal and Sieve as follows:

a. Replace Charcoal Filter

b. Remove Sieve Pack Lid by removing screws.

Discard screws and sieve material.

c. Refill Sieve Pack with new sieve material and install new screws.

d. Reinstall Ammonia Source.

e. Remove MGP radiation detector board.

f. Check Membrane: clean or replace as required.

g. Check Inline Filter and replace as required.

h. Refit MGP radiation detector board.

i. Perform leak test to ensure that the sieve pack is not leaking.(Pneumatic leak) Step 5.) Run recirculation pump unit overnight.

Step 6.) Reassemble unit.

Step 7.) Check unit with confidence sample.

Step 8.) Repeat operation 10 for final radiation leak wipe test.

Serial #_________ APD 2000 Repair/Evaluation Sheet

Sales Order Number Date Received:

Repaired by:

Serviced by:

Date: ATTN:

Hours to complete: Phone:

Inspected by:

Warranty:

Non-Warranty: Problem:

Charge #

Part ID Part No.

General Maintenance Comments / other Sieve n/a Charcoal n/a Ammonia source 2429256

Upgrade Battery Cap 2428626 AUX Port 2428606 Software n/a RAD Detector 2429260

Repair Parts List Cell, Rear 2428821 Cell,Front End 2428824 Cell, Drift Tube 2428826 Confid. Sample 442-642 Carrying Strap 2428628 Inlet Cap 2428623 Bezel Panel 2428627 RAD Detector 2429260 Duracell Batteries 74336983 Sensor Board 2428613 Processor Board 2428609 Head Amp 2428616 Pump Assy 2427591-30 Membrane 2428046 Motor 2428230-467 Horn Assy 2428047 Control Panel 2429203 Cell Assy 2429249

Tracking Number : Date Shipped:

Carrier :

RMA #__________

Customer:

Shipping Information:

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A

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R

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SIEVE REPLACEMENT PROCEDURE FOR ICAM

Step 1. Perform a radiation wipe test of the unit as follows:

a. Using filter paper or a cotton bud wipe a random area approximately 100 sq/cm of the unit surface.

b. Analyze the smear using a Liquid Scintillation counter (LSC).

c. Verify the dpm level reported by the LSC is less than 100.

d. If over 100 dpm report to the Radiation Safety Officer for instructions of how to proceed.

Step 2. Remove the nut and serial number rings.

Step 3. Carefully slide module out from case, but not so far as to stress the flex circuit.

Step 4. Remove flex circuit connector using the tab.

Step 5. Remove the electric insulation sheet.

Step 6. Remove two screws holding connector bracket so it will pivot out.

Step 7. Disconnect two electrical connectors as shown below.

Step 8. Completely unthread captive screw.

Step 9. Grasp the unit as shown and remove sieve pack per the directional arrows in photos below.

Step 10. Remove the two screws retaining the acetone source, then the source itself.

Step 11. Invert the acetone source as shown and note the volume in the translucent portion. It may be necessary to tap lightly to get all the fluid down. If the fluid comprises less than half of the translucent portion it should be replaced.

Step 12. Remove the five screws, empty the old sieve and refill with new.

Replace screws and torque to 120 ±8 in. oz.

Minimum Required Level

NOTE: NEW SIEVE SHOULD BE

EXPOSED TO THE OPEN

ATMOSPHERE AS LITTLE AS

POSSIBLE. IF THE SIEVE PACK IS

NOT GOING INTO A UNIT IT

SHOULD BE IN A DESICANT

CONTAINER.

Step 13. Place the acetone source assembly in the appropriate hole with the wire orientated as shown.

Step 14. Verify that the o-ring is over the acetone source wire as shown below.

Step 15. Secure the acetone source in the sieve pack assembly with the two screws. Torque to 65 ±3 in. oz.

Step 16. Secure the wire to the sieve pack body using the o-ring as shown.

Step 17. Assemble the sieve pack into the monitor assembly and tighten captured screw until it is fully seated against the cell assembly (shown below).

Sieve Pack fully seated in frame

Step 18. Reinstall the clear protective cover.

Step 19. Carefully insert the module into the case. Stop the monitor module assembly about ¾ the way into the case so you can connect the display to the PCB.

Step 20. Insert the connector tab into the slot on the electric insulation sheet as shown below.

Step 21. Fold the flex circuit towards the front of the ICAM and push the module into the case while pulling the film wire out.

Step 22. When the flex circuit gets hard to pull out put a screwdriver through the loop of the film wire (as shown below) and use it to guide the film wire out until the module goes completely into the case.

Step 23. Reinstall the nut and serial number rings. Torque to 85 ±5 in/lbs.

Step 24. Perform another radiation wipe test of the unit as follows:

a. Using filter paper or a cotton bud wipe a random area approximately 100 sq/cm of the unit surface.

b. Analyze the smear using a Liquid Scintillation counter (LSC).

c. Verify the dpm level reported by the LSC is less than 100.

d. If over 100 dpm report to the Radiation Safety Officer for instructions of how to proceed.

Step 25. Start unit up and allow to run overnight.

Step 26. After overnight run, challenge unit with confidence sample to verify proper operation.

CDP Radiation Safety Program Annex B Safety Standards, Dosimetry, and Recordkeeping Rev. 0 (Mar 10)

Annex B Safety Standards, Dosimetry, and Recordkeeping

It is the responsibility of the licensee and all users of radiation sources to conduct operations to ensure that radiation exposures received by workers and members of the general public are below those limits established by Federal and State regulations. Furthermore, doses shall be maintained at levels that are As Low As Reasonably Achievable (ALARA).

2. IONIZING RADIATION.

a. The Code of Federal Regulations (CFR) Title 10, Part 20, prescribes the maximum annual exposures to workers and members of the general public. While it is understood that 10 CFR applies only to the NRC Licensed materials, the CDP accepts those limits for all sources of ionizing radiation.

b. The following table identifies the standards as specified by 10 CFR

Part 20:

Category Maximum 1,2,3 Member of the General Public 100 mrem (TEDE) in a calendar year4 Fetus/embryo of occupationally exposed declared pregnant worker

500 mrem (DDE of mother + ED due to radionuclides in fetus/embryo) for entire pregnancy

Occupationally Exposed Adult 5 rem TEDE in a calendar year Lens of the Eye 15 rem EDE in a calendar year Individual Organ 50 rem DDE+CDE in a calendar year Skin or Extremity 50 rem SDE in a calendar year Occupationally Exposed Minor 10% of applicable limit for adult

1. Maximum doses will be the limit listed in this table or the current version of 10 CFR Part 20, which ever is the most restrictive.

2. Abbreviations: TEDE = Total Effective Dose Equivalent; DDE = Deep

Dose Equivalent; ED = Effective Dose; EDE = Effective Dose Equivalent;

CDE = Committed Dose Equivalent; SDE = Shallow Dose Equivalent

3. OSHA standard for occupational exposure of adults and for the lens of the eye is 1¼ rem in a calendar quarter. OSHA standard for skin of whole body is 7½ rem in a calendar quarter. OSHA standard for hands and forearms; feet and ankles is 18¾ rem in a calendar quarter.

4. The dose in any unrestricted area from external sources of ionizing radiation will not exceed 2 mrem in any one hour.

c. All CDP employees conducting operations involving ionizing radiation sources must comply with the above exposure criteria.

d. Dosimetry. Occupationally exposed individuals requiring monitoring will only use dosimeters supplied by the CDP RSO. The CDP Dosimetry Program will be managed by the CDP RSO.

(1) Dosimetry will be issued based on the following criteria:

(a) Personnel likely to receive 10% of any limits established above.

(b) Personnel entering restricted areas where the external radiation requires the posting of a "Radiation Area, High Radiation Area, or Very High Radiation Area" sign.

(c) Personnel not permanently assigned to the CDP meeting the requirements above may be issued a dosimeter as a "Visitor/Student".

(2) Storage of dosimeters while not being worn will only be allowed in locations authorized by the CDP RSO.

(3) Individuals assigned dosimeters will contact the CDP RSO immediately if any of the following situations occur:

(a) Dosimeter is lost or damaged during wear period.

(b) Dosimeter is inadvertently exposed (i.e. dosimeter falls off during set-up and not noticed until after exposure.)

(c) Dosimeter is worn by an individual other than the individual it is assigned.

3. RADIOACTIVE CONTAMINATION.

a. Operations with radioactive materials will be conducted to ensure that radioactive contamination is avoided.

b. Contamination in "restricted areas" will be maintained below the applicable levels in the table below:

1. Where surface contamination by both alpha and beta-gamma nuclide exists, the limits established for alpha and beta-gamma emitting nuclides should apply independently.

2. As used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as determined by correcting the counts per minute observed by an appropriate detector for background, efficiency, and geometric factors associated with the instrumentation.

3. Measurements of average contamination should not be averaged over more than 1 square meter. For objects of less surface area, the average should be derived for each object.

4. The maximum contamination level applies to an area of not more than 100 cm2.

5. The amount of removable radioactive material per 100 cm2 of surface area should be determined by wiping that area with filter or soft absorbent paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency. When removable contamination on objects of less surface area is determined, the pertinent levels should be reduced proportionally and the entire surface should be wiped.

c. Areas of contamination above the limits stated above will be decontaminated to levels below those listed.

d. Equipment stored and/or used in restricted areas identified for release to unrestricted areas will be surveyed to ensure that contamination levels are as far below the limits as practicable.

Nuclide Average2,3 Maximum2,4 Removable2,5

Alpha emitters

100 dpm/100 cm2

300 dpm/100 cm2

20 dpm/100 cm2

Beta-Gamma emitters

5,000 dpm/100 cm2

15,000 dpm/100 cm2

1,000 dpm/100 cm2

CDP Radiation Safety Program Annex C Special Reporting Requirements Rev. 0 (Mar 10)

Annex C Special Reporting Requirements

a. Accidents and/or incidents involving radiation sources requiring reporting as described below, will be reported to the CDP RSO at

(256) 847-2266 or (256) 310-6346.

b. The CDP RSO will be responsible for conducting an appropriate investigation and making any additional notifications as required.

2. IONIZING RADIATION. The following situations will require notification of the CDP RSO:

a. Any accident or incident where occupational workers or members of the general public are likely to receive an exposure greater than normal anticipated exposures.

b. The loss of control of any radioactive material.

c. Contamination levels indicated within a restricted area ten times greater than the limits specified in Annex B, paragraph 3.b.

d. Contamination levels indicated within an unrestricted area greater than the limits specified in Annex B, paragraph 3.b.

CDP Radiation Safety Program Appendix A References Rev. 0 (Mar 10)

Appendix A References

1. Title 10, Code of Federal Regulations, Chapter I, Nuclear Regulatory

Commission

2. Title 21, Code of Federal Regulations, Chapter I, Subchapter J, Radiological Health

3. Title 29, Code of Federal Regulations, Chapter XVII, Occupational

Safety and Health Administration

4. Title 49 Code of Federal Regulations Department of Transportation

5. NUREG-1556, Volume 1 Program-Specific Guidance About Portable

Gauge Licenses

6. NUREG-1556, Volume 7 Program-Specific Guidance About Academic, Research and Development, and Other Licenses of Limited Scope

7. USNRC Regulatory Guide 8.13 Instruction Concerning Prenatal

Radiation Exposure

8. USNRC Regulatory Guide 8.29 Instruction Concerning Risk for

Occupational Radiation Exposure

CDP Radiation Safety Program Appendix B Glossary Rev. 0 (Mar 10)

Appendix B Glossary

1. ALARA. Acronym for "As Low As Reasonably Achievable" means making every effort to maintain exposures to radiation as far below applicable dose limits as is practical consistent with the purpose for which the source of radiation is required.

2. Authorized User. An individual who has been authorized by the

Radiation Safety Committee to possess and use CDP radiation sources.

3. Background Radiation. Radiation received from cosmic, terrestrial, inhaled radionuclides, and other sources of radiation not resulting from the possession, use, or disposal of a radiation source.

4. Committed Dose Equivalent. The dose equivalent to organs or tissues of reference that will be received from an intake (internal exposure) of radioactive material by an individual during the 50-year period following the intake.

5. Committed Effective Dose Equivalent. The sum of the products of the weighing factors applicable to each of the body organs or tissues that are irradiated and the committed dose equivalent to these organs or tissues.

6. Declared Pregnant Woman. A woman who has voluntarily informed her employer, in writing, of her pregnancy and the estimated date of conception.

7. Decommission. To remove (as a facility) safely from service and reduce residual radioactivity to a level that permits release of the property for unrestricted use and termination of the NRC License, or CDP Permitted operations.

8. Deep Dose Equivalent. Applies to external whole-body exposure and is the dose equivalent to a tissue depth of 1 centimeter (1000 mg/cm2).

9. Deviation. A departure from the requirements of this program document.

10. Effective Dose Equivalent. The sum of the products of the dose equivalent to the organ or tissue and the weighting factors applicable to each of the body organs or tissues that are irradiated. The units of dose equivalent are the rem and the Sievert (Sv).

11. Exposure. In risk management, the frequency and length of time subjected to a hazard.

12. High Radiation Area. An area, accessible to individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of 0.1 rem (1 mSv) in 1 hour at 30 centimeters from the radiation source or from any surface that the radiation penetrates.

13. Ionizing Radiation. Charged subatomic particles and ionized atoms with kinetic energies greater than 12.4 eV, electromagnetic radiation with photon energies greater than 12.4 eV, and all free neutrons and other uncharged subatomic particles (except neutrinos and antineutrinos).

14. Member of the Public. Any individual that is not involved with the direct possession, use or disposal of a radiation source.

15. Occupational Dose. Exposure received in the course of employment in which duties involve the exposure to radiation sources or radioactive materials.

16. Radiation Area. An area, accessible to an individual, in which radiation levels could result in an individual receiving a dose equivalent in excess of

0.005 rem (0.05 mSv) in 1 hour at 30 centimeters from the radiation source or from any surface that the radiation penetrates.

17. Restricted Area. An area whose access is controlled for the purpose of minimizing exposure of individuals to sources of radiation.

18. Sealed Source. A radioactive material that is permanently bonded or fixed in a capsule or matrix designed to prevent release and dispersal of the radioactive material under the most severe conditions which are likely to be encountered in normal use and handling and which is used in that configuration.

19. Shallow Dose Equivalent. Applies to external exposure of the skin or an extremity and is taken as the dose equivalent at a tissue depth of 0.007 centimeter (7 mg/cm2) averaged over an area of 1 square centimeter.

20. Survey. The evaluation of a facility or operation to determine the effectiveness of the radiation safety program. Surveys may include, but are not limited to, review of operations, the taking of and analysis of physical measurement.

21. Unrestricted Area. An area, access to which is neither limited nor controlled for the purpose of ionizing radiation safety.

22. Very High Radiation Area. An area, accessible to individuals, in which radiation levels could result in an individual receiving an absorbed dose is excess of 500 rads (5 gray) in 1 hour at 1 meter from a radiation source or any surface that the radiation penetrates.

CDP Radiation Safety Program Appendix C Radiation Management Flow Chart Rev. 0 (Mar 10)

Appendix C Radiation Management Flow Chart and Training Requirements

CDP RSO

(40 HR)

Alternate RSO / Authorized Custodian /

Source Manger

(40 HR)

Supervisors / Users

(1 - 2 HR)

CDP Radiation Safety Program Appendix D Facility Drawings Rev. 0 (Mar 10)

Appendix D Approved Permanent Location Storage Areas

See Attached Facility Drawings