rapiscan systems, submittal of radiation protection plan. · rapiscan laboratories, inc radiation...

Supplemental Material submitted in support of a new Part 70 LicenseApplication by:

Rapiscan Laboratories, Inc520 Almanor AvenueSunnyvale, CA 94085

Docket# 70-7021

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RapiscanTMsystemsAn OSI Systems Company

RADIATION PROTECTION PLAN

January 13, 2011

This document is for use in complying with TITLE 17, PublicHealth, Division 1, Chapter 5, Sanitation(Environmental), Subchapter 4, Radiation (commencing at section30100), the California Regulations for Protection Against Radiationas adopted by The California Radiologic Health Branch pertainingto the use of Radioactive Materials and Radiation EmittingDevices. Sites in other states must reference their state or theNRC regulations, depending upon jurisdiction.

Michael Gray, Director of Radiation Safety and Compliance2805 Columbia StreetTorrance, California 90503Office (310) 349-2311Mobile(310) 897-9328 (24/7/365)

RAPISCAN LABORATORIES, INC RADIATION PROTECTION PLAN

1.1 Purpose and Applicability

The purpose of the Radiation Protection Plan (RPP) is to summarize theregulations and safety practices that apply to radiological operations and toestablish radiation protection policies at the Rapiscan Laboratories andtemporary job sites. From these policies, specific implementing procedures andforms shall be developed to assure and demonstrate compliance with theapplicable regulations and to maintain radiation exposures, resulting fromlicensed and registered radiological operations, to a level as low as is reasonablyachievable (ALARA).

In order to ensure compliance with the regulations and in the interest ofmaintaining doses due to operations ALARA, this Plan and its implementationshall be reviewed at least annually by the designated facility RSO. The reviewwill assess the effectiveness of the Plan by providing appropriate regulatory andradiation protection direction. The review will be documented and changes to theRPP will be made based upon the recommendations of the RSO.

The RPP provides a general description of company radiological policies and asummary of programs to be incorporated to ensure the safe and proper use ofsources of ionizing radiation at the Rapiscan Laboratories facility and provides adescription of the intended use of these sources. While this RPP has beenwritten for the Rapiscan Laboratories, this document will also serve as theRadiation Protection Plan for use and implementation at "temporary job sites" inCalifornia, other Agreement States or Non Agreement States with NRCjurisdiction.

This plan applies to all personnel who enter or conduct business at this siteincluding subcontractors, vendors, visitors and guests. Adherence to strictradiological controls, policies and procedures ensures all work involving sourcesof radiation is performed in a manner that minimizes the possibility ofoccupational exposures and exposures to members of the public to ionizingradiation well within regulatory limitations.

1.2 Jurisdiction

In the event of a conflict between the requi.rements of the RPP and applicableState Radiation Control regulations or the facility license and/or registration, therequirements of the applicable State Radiation Control regulations or facilitylicense and/or registration conditions shall take precedence. An updated copy ofthe applicable California regulations shall be maintained at the facility by theRSO and copies made available to employees upon request of the RSO.

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1.3 Enforcement

Managers and supervisors have and are expected to exercise the authority toenforce the radiation protection practices as set forth within this manual andimplementing procedures. The enforcement duties of managers and supervisorsinclude but are not limited to:

1. Taking immediate action to correct radiation safety violations which theypersonally observe.

2. Preparing documentation of the violation as may be specified inimplementing procedures.

3. Counseling/disciplining, in accordance with site procedures and Companystandard personnel practices, any subordinates who have committedradiation safety violations.

1.4 Violations

Disregard for violations of the RPP standards and policies may be grounds fordisciplinary action. Radiation safety performance should be taken intoconsideration during periodic employee evaluations.

1.5 Interpretation

In cases where questions arise about the interpretation of standards in the RPP,the RSO shall provide the official interpretation.

1.6 Documentation/Reference Materials

Documentation used to develop the Radiation Protection Plan includes, in part,the reference materials listed below:

* California Code or Regulations Title 17 Division 1 Chapter 5 Subchapter 4

* Radiation Machine Registrations/Permits

" US NRC Regulatory Guide 6.9

" US NRC Regulations 10 CFR Parts 1-50, Parts 70, 71 and 110

• US NRC Regulatory document NUREG-1 556 V17

* OSHA Regulation 29 CFR 1910.1096

* NCRP 144 Radiation Protection for Particle Accelerator Facilities

" LINAC Operating Procedures

* California Radiologic Health Branch, Notice to Employees, Form RHB 2364

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1.7 RPP Manual Changes

Any individual, group or department within Rapiscan Laboratories may request achange to the requirements of this manual. Requests shall be made in writing tothe RSO stating the specific proposed change to be made and the basis.

Change requests shall be evaluated and acted upon expeditiously.Administrative changes should be completed within 30 days; substantivechanges require an amendment to the State- or NRC-issued license orregistration and may take several months to receive approval.

The RSO shall make an initial determination whether a proposed change isadministrative or substantive in nature. If the RSO concurs with the proposedchange, he/she will make the necessary changes to the implementingprocedure(s) or prepare a submittal to the regulatory agency. In general,administrative changes involve organization names, position titles, procedureupdates and/or revisions and other non-technical issues that do not impact alicensing or registration condition. Substantive changes include addition,deletion, or modification of program requirements that may be interpreted asproviding a lesser degree of protection to employees or the general public.

The RSO shall make the final decision regarding whether a change isadministrative or substantive. The RSO has the authority for final approval ofadministrative changes. Substantive changes will be submitted as anamendment to the applicable State Radiation Control Agency for approval.

All administrative and/or substantive changes shall be documented in the annualreview of the RPP.

1.8 Temporary Changes to the RPP

To provide a means to respond quickly to changing situations, temporarychanges or exceptions to the requirements (i.e. administrative changes) in theRPP may be approved by the RSO. The nature of and reason for the temporarychange or exception shall be documented.

Temporary changes or exceptions shall be effective for no longer than 90 daysduring which time the manual should be formally revised to make the change orexception permanent. The period of time during which a cha.nge or exception isin effect may not be extended.

1.9 Definitions

1. Absorbed Dose: Energy imparted by ionizing radiation per unit mass of irradiatedmaterial. The conventional unit of absorbed dose is the Rad and the StandardInternational (SI) unit is the Gray (Gy).

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2. Access Control Point: An area established to provide control over the entry to andexit from a Restricted Area.

3. Accessible Area: An area that can reasonably be occupied by a significant portionof an individual's body, such as the head or most of the trunk.

4. Accountable (Licensed Quantities) Sealed Radioactive Source: A sealedradioactive source having a half-life equal to or greater than 30 days and anisotopic activity equal to or greater than the corresponding value provided in 10CFR 30.71, Schedule B.

5. Accuracy: The degree of agreement of the observed value with the conventionallytrue value of the quantity being measured.

6. Activated Products: Activated products are radioactive materials produced by theinteraction of radiation produced by a LINAC and target materials; these arenormally short lived, but care must be taken when approaching potentially activeareas/materials.

7. Activity: Rate of disintegration (transformation) or decay of radioactive material.The conventional unit of activity is the Curie (Ci) and the Standard International unitis the Becquerel (Bq).

8. Administrative Controls: The formal procedures or controls established andadministered by management to ensure safety and controlled radiologicaloperations within the facility in accordance with license, registrations, regulations,corporate policy, and the ALARA principle.

9. Administrative Limit: A limit established by the licensee and/or registrant for thepurpose of maintaining radiation dose below regulatory limits.

10. Adult: Individual 18 or more years of age.

11. Agreement State means any state with which the Nuclear RegulatoryCommission has entered into an effective agreement under section 274b of theAtomic Energy Act of 1954, Title 42, United States Code, Section 2021 (b)(formerly section 274(b)).

12. ALARA: The acronym for "as low as is reasonably achievable". In concept, itmeans making every reasonable effort to maintain exposures to radiation as farbelow the dose limits in these Basic Standards as is practically consistent with thepurpose for which the activity is undertaken and taking into account:

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a. The state of technology;b. The economics of improvements in relation to the state of technology;c. Benefits to public health and safety, and other societal and socioeconomic

considerations; andd. Utilization of radiation in the public interest.

13. Audit: An evaluation of the effectiveness of the Radiation Protection Program todetermine the adequacy of and adherence to established procedures, instructions,specifications, regulations and standards, and other applicable permitting andlicensing requirements.

14. Authorized User (AU): An AU is an individual specifically authorized by a licenseor registration that possesses the authority to initiate or authorize the emission ofionizing radiation from a radiation emitting device like a cabinet x-ray machine, x-ray emitting devices such as full body x-ray scanners, CT scanners, acceleratordevice or any other radiation emitting device manufactured by or under testingand evaluation by Rapiscan Laboratories or to handle and use or authorize thehandling and use of a radioactive material sealed source device by activatingswitches, controls, or event sequences which allow the production and emissionof radiation from the source holder.

15. Background Radiation: Radiation from cosmic sources, naturally occurringradioactive materials including radon (except as a decay product of source orspecial nuclear material), and global fallout as it exists in the environment from thetesting of nuclear explosive devices. Background radiation does not includeradiation from sources of radiation subject to licensing or regulation.

16. Background (Ambient): The radiation level within any area resulting from thecombination of environmental background radiation and generally low-levelradiation from radioactive materials and sources within the facility.

17. Barrier: Anything acting to obstruct a passage.

18. Boundary: The physical line defining two separate areas. For example, theboundary between a radiation area and a non-radiation area.

19. Cabinet X-ray System: means an x-ray system with the x-ray tube installed orused in a permanent enclosure in which the enclosure is intended to contain atleast that portion of the material being irradiated. The enclosure:

a. May be the architectural structure or may be independent of thearchitectural structure;

b. Shall provide attenuation of the radiation to meet the requirements of theFDA Performance Standards contained in 21 CFR 1020.40; and

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c. Shall exclude personnel from its interior during the generation of x-radiation. This definition shall not include x-ray systems used by licensedpractitioners of the healing arts.

20. Calibrate: To adjust and/or determine:

a. The response or reading of an instrument relative to a series ofconventionally true values.

b. To determine the strength of a radiation source relative to a standard orconventionally true value.

21. Check Source: A radioactive source, not necessarily calibrated, which is used toconfirm the continuing satisfactory operation of a radiation instrument.

22. Collective Dose: The sum of the individual doses received in a given period oftime by a specific population from exposure to a specific source of radiation.

23. Confidence Level: The degree of statistical assurance that activity measured ordetected by a counting instrument or system is actually related to the sample beinganalyzed and not due to background.

24. Controlled Area: An area outside the restricted area but inside the site boundary,access to which can be limited for any reason.

25. Corrective Action(s): Action(s) taken to improve areas of performance or toeliminate causes of adverse trends in performance identified during the assessmentprocess.

26. DOT: U.S. Department of Transportation.

27. Declared Pregnant Woman (DPW): A woman who has voluntarily informed heremployer, in writing, of her pregnancy and the estimated date of conception.

28. Deep Dose Equivalent (DDE) (Hd): Applies to external whole body exposure, is thedose equivalent at a tissue depth of 1 cm (1000 mg/cm 2).

29. Designated User (DU): A DU is a trained and qualified occupational workerauthorized by an Authorized User to initiate the emission of ionizing radiationfrom a radiation emitting device like a cabinet x-ray machine, x-ray emittingdevices such as full body x-ray scanners, CT scanners, accelerator device or anyother radiation emitting device manufactured by or under testing and evaluationby Rapiscan Laboratories or to handle and use a radioactive material sealedsource device by activating switches, controls, or event sequences which allowthe production and emission of radiation from the source holder provided thisDesignated User is under the supervision of an Authorized User.

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The Authorized User shall be onsite during these activities but does not have tobe present 100% of the time at the project/experimental location on site. TheDesignated User is responsible for informing the Authorized User of his/heractivities as needed during operations and upon completion of operations. TheDesignated User shall comply with all procedures and complete all applicableforms and logs.

The RSO shall maintain a current list of all Authorized Users and DesignatedUsers in writing at the Rapiscan Laboratories facility.

30. Direct Reading Dosimeter (DRD): A monitoring device consisting of a collectionchamber coupled with an optical lens and calibrated scale. DRD's are normallyused as a secondary dosimetry device to provide individuals with an immediateestimate of their external radiation exposure.

31. Document: Procedures, plans, forms or manuals which are used to control and/ordocument activities that affect quality or radiation safety, or implement regulatoryrequirements.

32. Dose or Radiation Dose: A generic term that means absorbed dose, doseequivalent, effective dose equivalent, committed dose equivalent, committedeffective dose equivalent, or total effective dose equivalent, as defined in other textin this document.

33. Dose Equivalent (HT): Means the product of the absorbed dose in tissue multipliedby a quality factor and all other necessary modifying factors at the location ofinterest. The units for dose equivalent are the Rem and the Sievert (Sv).

34. Dosimeter: Any of several types of devices used to measure radiation doses.Common types include TLD, film, and direct reading dosimeters.

35. Dosimetry Processor: An accredited individual or organization that processes andevaluates individual monitoring equipment in order to determine the radiation dosedelivered to the equipment.

36. Embryo/Fetus: The developing human organism from conception until the time ofbirth.

37. Engineering Controls: Term used for the general class of devices and associatedmethods used to reduce personnel exposure to radiation. Examples of engineeringcontrols are shielding, warning lights and labels and safety interlocks.

38. Entrance or Access Point: Any location, through which an individual could gainaccess to radiation areas or to sources of radiation. This includes entry or exitportals of sufficient size to permit human entry, irrespective of their intended use.

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39. Estimated Dose: Dose that is normally based on results obtained from secondarydosimeters or surveys.

40. Exempt Quantity Sealed Radioactive Source: A sealed radioactive source thatdoes not require a USNRC or State license and the radioactive quantity does notexceed the values contained in 10 CFR 30.71, Schedule B.

41. Exposure: Means being exposed to ionizing radiation or to radioactive material.

42. External Dose: That portion of the dose equivalent received from sources ofradiation outside the body.

43. Extremity: Means hand, elbow, arm below the elbow, and foot, knee, or leg belowthe knee.

44. Eye Dose Equivalent (LDE): Applies to the external exposure of the lens of theeye, taken as the dose equivalent at a tissue depth of 0.3 cm (300 mg/cm2).

45. Government Agency: Means any executive department, commission, andindependent establishment, corporation wholly or partly owned by the UnitedStates of American, which is an instrumentality of the United States, or anyboard, bureau, division, service, office, officer, authority, administration, or otherestablishment in the executive branch of the Government.

46. Gray (Gy): Is the SI unit of absorbed dose. One gray is equal to an absorbeddose of 1 Joule/Kilogram (100 rads).

47. High Radiation Area: Means an area, accessible to individuals, in which radiationlevels from radiation sources external to the body could result in an individualreceiving a dose equivalent in excess of 0.1 Rem (1 mSv) in 1 hour at 30centimeters from the radiation source or 30 centimeters from any surface that theradiation penetrates.

48. Individual: Means any human being.

49. Individual Monitoring:

a. The assessment of dose equivalent by the use of devices designed to beworn by an individual; or

b. The assessment of dose equivalent by the use of survey data.

50. Individual Monitoring Devices: Devices designed to be worn by a single individualfor the assessment of dose equivalent including devices such as film badges,TLD's, direct reading dosimeters, or an alternative such as an electronic dosimeter.

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51. Licensed Material: Means source material, special nuclear material, or byproductmaterial received, possessed, used, transferred or disposed of under a generalor specific license issued by the Department or Commission.

52. Limits (Dose Limits): The permissible upper bounds of radiation doses.

53. Low Dose Waiting Area (LDWA): An identified area where dose rates are lowerthan at other locations within the work area.

54. Member of the Public: Means any individual except when that individual isreceiving an occupational dose.

55. Minor: An individual less than 18 years of age.

56. Monitoring Period: The period during which an individual wears dosimetry. Theperiod begins when an individual is issued dosimetry and continues until thedosimetry is returned or determined not to be performing monitoring for theindividual to whom it was issued (e.g., lost or damaged dosimeter, employeetermination, return of badge, etc.). The normal monitoring period is monthly orquarterly.

57. Nationally Tracked Source: A sealed source containing a quantity equal to orgreater than Category 1 or Category 2 levels of any radioactive material listed inAppendix E of 10 CFR 20. In this context, a sealed source is defined asradioactive material that is sealed in a capsule or closely bonded, in a solid formand which is not exempt from regulatory control. It does not mean materialencapsulated solely for disposal, or nuclear material contained in any fuelassembly, subassembly, fuel rod, or fuel pellet. Category 1 nationally trackedsources are those containing radioactive material at a quantity equal to or greaterthan the Category 1 threshold. Category 2 nationally tracked sources are thosecontaining radioactive material at a quantity equal to or greater than the Category2 threshold but less than the Category 1 threshold.

58. Nonstochastic Effect: Means health effects, the severity of which varies with thedose and for which a threshold is believed to exist. Radiation induced cataractformation is an example of a Nonstochastic effect.

59. NRC: Nuclear Regulatory Commission or its duly authorized representatives.

60. Occupational Dose: The dose received by an individual in the course ofemployment in which the individual's assigned duties involves exposure toradiation. Occupational dose does not include a dose received from backgroundradiation, as a patient from medical practices, from voluntary participation inmedical research programs, or as a member of the public.

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61. Occupational Dose Limit: The maximum legally allowable dose to individualsduring a specific time period, as defined by the applicable Federal and StateRadiation Control Agency Standards for Protection Against Radiation.

62. Official Dose (Record Dose): The dose determined and recorded for an individualfor the purpose of demonstrating compliance with applicable monitoringrequirements and dose limits. The official dose is normally based on the results ofprimary dosimeter processing, but could be based upon calculations from surveydata or other recognized techniques.

63. Performance Test/Response Test: A procedure whereby an instrument or acomponent is evaluated against accepted criteria for continuing satisfactoryoperation.

64. Person: An individual, trust, firm, joint stock company, corporation (including agovernment corporation), partnership, association, state, municipality, commission,political subdivision of a state, any interstate body, any governmental agency of thisstate, and any department, agency or instrumentality of the United Statesgovernment.

65. Personnel Monitoring Equipment: Any of the dosimeters or equipment worn by aperson to measure or evaluate that individual's own dose.

66. Physical Controls: Barriers, signs, gates, doors, fences, etc., which are used tocontrol the access of personnel into areas of the facility (e.g., Restricted Areas,Radiation Area).

67. Positive Control: Control over access such that no unauthorized individuals mayenter the area.

68. Posting: A standardized sign or label which bears the standard trefoil symbol inmagenta or purple or black on a yellow background and information concerning aspecific radiological hazard.

69. Primary Dosimeter: A device used to monitor and assess a single individual'srecords dose (e.g., Film badge or TLD).

70. Public Dose: Dose received by a member of the public from exposure to radiationand/or radioactive material released by the registrant, or to any other source ofradiation under the control of the registrant. Public dose does not includeoccupational dose or doses received from background radiation, as a patient frommedical practices, or voluntary participation in medical research programs.

71 . Quarter: A period of time equal to one fourth of the year observed by the registrant(approximately 13 consecutive weeks), providing the beginning of the first quarter in

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a year coincides with the starting date of the year and that no day is omitted orduplicated in consecutive quarters.

72. Rad: The special unit of absorbed dose. One Rad is equal to an absorbed dose of100 ergs/gram or 0.01 joule/kilogram (0.01 Gy).

73. Radiation (Ionizing Radiation): Includes all ionizing electromagnetic waves andcorpuscular emissions such as, but necessarily limited to, gamma rays and x rays,alpha and beta particles, electrons, neutrons, and protons, and other nuclearparticles, but not radio waves or visible, infrared, or ultraviolet light.

74. Radiation Area: An area, accessible to individuals, in which radiation levels couldresult in an individual receiving a dose equivalent in excess of 0.005 Rem (0.05mSv) in 1 hour at 30 centimeters from the source of radiation or from any surfacethat the radiation penetrates.

75. Radiation Machine: Any machine designed to generate ionizing radiation as itsprimary function; these do not contain radioactive material other than possiblycalibration sources.

76. Radiation Safety Officer: An individual who is a member of the radiation safetycommittee, who is qualified through training and experience to oversee theradiation safety aspects of radioactive material use in the institution and typicallylisted on the license or registration as the individual responsible for radiationsafety.

77. Radiation Worker (Occupational Worker): Radiation Workers are trained andqualified for unescorted access to restricted areas for performance of work whichmay involve direct or indirect exposure to ionizing radiation or contact withradioactive materials.

78. Radiological Control Group (RCG): The RCG shall be any group or teamworking on, or having specific authority and responsibility over a project thatrequires the use of a accountable (licensed quantities) radioactive sealed source,which shall bear the primary responsibility for ensuring radiation protectionactivities when using such sources in conjunction with their project and informingthe RSO of the RCG's proposed activities.

79. Radiological Occurrence Report (ROR): A report generated to document the facts,record the apparent and/or root causes, track the resolution and aid establishingthe presence of trends in radiological events. An ROR is classified as either"deficiency" or "incident".

80. Radionuclide: Any one of the radioactive nuclides. Often incorrectly confused withisotope.

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81. Regulations: Means applicable Federal and State Radiation Control Agencyfederal requirements.

82. Rem: The special unit of any of the quantities expressed as dose equivalent. Thedose equivalent in Rem is equal to the absorbed dose in Rad multiplied by thequality factor (1 Rem = 0.01 Sievert).

83. Restricted Area: Means an area, access to which is limited by the registrant for thepurpose of protecting individuals against undue risks from exposure to radiationand/or radioactive materials. A Restricted Area does not include areas used asresidential quarters, but separate rooms in a residential building may be set apartas a Restricted Area.

84. Sealed Source: means any radioactive material that is permanently encapsulatedin such manner that the radioactive material will not be released under the mostsevere conditions likely to be encountered by the source.

85. Secondary Dosimeter: A device used to assess an individual's unofficial dose andcapable of being read directly by the individual in the field.

86. Shallow-Dose Equivalent (Hs): Applies to the external exposure of the skin or anextremity, is taken as the dose equivalent at a tissue depth of 0.007 centimeters(7mg/cm2) averaged over an area of 1 square centimeter.

87. Shielding: Any material used to reduce radiation exposure. Alpha radiation isusually stopped by the outer dead layers of skin, a piece of paper, or a few inchesof air. A thin piece of wood or 10 to 30 feet of air will attenuate most beta radiation.Depending on the energy of gamma radiation, several inches of any heavy metalsuch as lead or several feet of less dense materials such as water or concrete caneffectively attenuate most gamma rays.

88. Sievert: The SI Unit of any of the quantities expressed as dose equivalent. Thedose equivalent in Sieverts is equal to the absorbed dose in grays multiplied by thequality factor (1Sv = 100 Rem).

89. Source Custodian: An individual who is trained and designated to maintaincognizance over accountability and control of assigned sealed radioactivesources. For most purposes, this shall be the Radiation Safety Officer (RSO).

90. Source Material: Means,

(1) Uranium or thorium or any combination of uranium and thorium in anyphysical or chemical form; or

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(2) Ores that contain, by weight, one-twentieth of 1 percent (0.05 percent), ormore, of uranium, thorium, or any combination of uranium and thorium.Source material does not include special nuclear material.

91. Source User: An individual who by virtue of training and authorization ispermitted to use radioactive sealed sources. There shall be two types of SourceUsers; authorized users and designated users.

92. Special Nuclear Material: Means,

(1) Plutonium, uranium-233, uranium enriched in the isotope 233 or in theisotope 235, and any other material that the Department or Commission,pursuant to the provisions of section 51 of the Act, determines to bespecial nuclear material, but does not include source material; or

(2) Any material artificially enriched by any of the foregoing but does notinclude source material.

93. Standard (Instrument or Source):

a. National Standard - An instrument, source, or other system or devicemaintained and promulgated by the U.S. National Institute of Standards andTechnology (NIST).

b. Transfer Standard - A physical measurement standard that has beencompared directly or indirectly with the national standard. This standard istypically a measurement instrument or a radiation source used as alaboratory standard.

c. Laboratory Standard - An instrument, source, or other system or devicecalibrated by comparisons with a standard other than that of a U.S. NationalStandard.

94. Stochastic Effects: Health effects that occur randomly and for which the probabilityof the effect occurring, rather than its severity, is assumed to be a linear function ofdose without threshold. Hereditary effects and cancer are examples of stochasticeffects.

95. Survey: An evaluation of the radiological conditions and potential hazards incidentto the production, use, transfer, release, disposal, or presence of radioactivematerials or other sources of radiation. When appropriate, such an evaluationincludes a physical survey of the location of a source of radiation andmeasurements or calculations of levels of radiation or concentrations or quantitiesof radioactive material present.

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96. TLD: Means Thermoluminescence Dosimeter: An integrating detector whereradiation energy is absorbed (trapped) and can be read out later by thermalexcitation of the detector. (ANSI N13.15-1985).

97. Total Effective Dose Equivalent (TEDE): The sum of the deep dose equivalent (forexternal exposures) and the committed effective dose equivalent (for internalexposures).

98. Total Organ Dose Equivalent (TODE): The sum of the deep dose equivalent andthe committed dose equivalent to the organ receiving the highest dose.

99. Unofficial Dose: The dose determined for an individual for exposure controlpurposes or for purposes of demonstrating that monitoring is not required.

100. Unrestricted Area: An area, access to which is neither limited nor controlled bythe registrant.

101. Very High Radiation Area: Means an area, accessible to individuals, in whichradiation levels from radiation sources external to the body could result in anindividual receiving an absorbed dose in excess of 500 rads (5 grays) in 1hour at 1 meter from a radiation source or 1 meter from any surface that theradiation penetrates.

102. Visitor: An escorted individual who enters the Restricted Area.

103. Week: Seven consecutive days starting on Sunday.

104. Whole Body (WB): Means, for purposes of external exposure, the head, trunk(including male gonads), arms above the elbow, or legs above the knee.

105. Year: Means the period of time beginning in January used to determinecompliance with the provisions of these Basic Standards. The registrant maychange the starting date of the year used to determine compliance by theregistrant provided the change is made at the beginning of the year and that noday is omitted or duplicated in consecutive years.

1.10 Responsibilities

No radiation protection program can provide adequate protection unless all peopleinvolved are aware of and perform their responsibilities. Each individual sharesresponsibility for their own radiation protection as well as for their co-workers andindividual members of the public.

Key responsibilities under the Radiation Protection Program are outlined below.Specific responsibilities under the Radiation Protection Program shall be outlined inthe implementing procedures.

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The highest member of facility management has ultimate responsibility for ensuringthe Radiation Protection Program at the facility is developed and implemented in amanner consistent with regulatory requirements and policies.

The facility RSO shares the primary responsibility for development, implementation,and oversight of the Radiation Protection Program with other supervisors andreports directly to the Corporate RSO.

The program in general includes:

1. Compliance with the Radiation Protection Program.2. Ensuring employees supervised by them are properly trained.3. Scheduled review of staff activities to ensure compliance with the

Radiation Protection Program.4. Preparation and maintenance of procedures.5. Accuracy and completeness of records.6. Storage of records.

All facility employees are responsible for following regulatory requirements andradiation safety procedures to the best of his/her ability and knowledge.These responsibilities include proper use of personnel monitoring equipment (ifrequired), notifying management of any potential or real radiation hazards orimproper practices, and maintaining his/her individual radiation exposure and thatof others ALARA. The facility ALARA policy shall be presented and explained toindividuals upon initial employment and in refresher training. The ALARA policyshould be posted on employee bulletin boards. Employees are encouraged tosubmit recommendations for improvements to the work place, especially if they willresult in lower doses.

All employees shall be made aware of and heed the instructions on the "Notice toEmployees" posted near the work area and throughout the facility in severalconspicuous locations for viewing.

Employees are requested to contact management first regarding potentialregulatory or licensing/registration violations before contacting the State RadiationControl Agency. However, any employee who is not satisfied with themanagement response regarding a potential violation is encouraged to contact theState Radiation Control Agency for resolution of the concern.

Any individual monitored for occupational dose who has had a medical treatmentinvolving radioactive material shall inform his/her supervisor and the RSO as soonas practical after the treatment upon returning to work to assure the treatment is notaccidentally confused with the worker's occupational exposure.

Female occupational workers desiring exposure protection for the embryo/fetusmust notify their supervisor and facility RSO, and "declare" in writing; as soon as

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exposure protection is desired so appropriate controls can be instituted. The RSOshall limit the dose to an embryo/fetus when notified by the occupational worker, inwriting, of the pregnancy and the estimated date of conception.

1.11 Radiation Safety Officer (RSO)

This RPP is intended to provide policies and procedures to be implemented atRapiscan Laboratories and temporary job sites related to the use and testing ofradiation emitting devices or any other licensed or registered radiation emittingdevice and radioactive material in sealed sources and devices.

The Corporate Radiation Safety Officer, facility Radiation Safety Officer, and thefacility Assistant Radiation Safety Officer, shall be collectively responsible for theimplementation of this program and assurance that operations at the site areconducted in full compliance with regulations in effect in the jurisdiction of use.

The RSO shall ensure the organization is properly staffed to ensure protection ofworkers and the general public from potential radiation hazards. RadiationProtection staffing levels shall be periodically reviewed to ensure adequate staffinglevels are maintained consistent with current activities. The RSO shall have accessto engineering, operations, maintenance and other personnel needed to supportthe Radiation Protection Program.

All production of ionizing radiation from radiation emitting devices and radioactivematerials in sealed sources shall be under the oversight, direction andsupervision of the facility RSO. The facility RSO is the single point ofaccountability and responsibility between the regulatory agencies and the usersof ionizing radiation at this site.

The RSO or designee (ARSO) shall be responsible for coordinating and deliveryof all training programs related to general radiation safety or project specificradiation safety, maintain all records related to the use of ionizing radiation,responsible for the issuance and exchange of personal dosimetry devices,ensure all radiation instruments used for performing radiation surveys shall bemaintained in proper working order and shall be properly calibrated at intervalsdictated by regulations in the jurisdiction of use.

The RSO shall be responsible for all notification and reporting requirementsrelated to the use of ionizing radiation, including reporting requirementsassociated with the transportation radioactive material sealed sources anddevices to and from the site.

The Corporate RSO for Rapiscan Systems is Mike Gray. He has a dotted linereport to Ajay Mehra, President of Rapiscan Systems. Mike Gray is responsiblefor the radiation safety of all Rapiscan sites and oversees the RSO's for eachsite.

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The following chart is an organizational chart for the RSO's for RapiscanSystems"

Ajay MehraPresident

Mike GrayCorporate RSO

Ed Franco Mershad Shahabidin Steve NorrisAssistant Radiation RSO - Sunnyvale . RSO - US Cargo

SafetyOfficer Pittsburg, CA Apex, NC

Radiation Safety Officers

The facility Radiation Safety Officer for Rapiscan Laboratories is Mr.Mershad A. Shahabidin.

The facility Assistant Radiation Safety Officer for Rapiscan Laboratories isMr. Ed Franco.

The facility RSO, may be contacted at the following phone numbers:Office: (310) 349-2494; after hours: (424) 236-0314.

The facility Assistant RSO, may be contacted at the following phonenumbers: Office: (408) 961-9743; after hours: (650) 346-9202.

1.12 Training Requirements and Policy

All individuals authorized to enter the Restricted Area unescorted who work with orfrequent the area in which sources of radiation are operated shall receiveinformation and training in radiation safety.

Information and training shall be consistent with the requirements of the AccessControl Program. The depth of the training will be commensurate with the potentialradiation safety hazards the person may face in his/her work and the regulatorytraining requirements.

At a minimum, State regulations require those who may receive an occupationaldose greater than 100 mRem in one year shall be:

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1. Informed of the storage, transfer, or use of sources of radiation in therestricted area;

2. Instructed in the hazards associated with exposure to radiation or sources ofradiation at the facility, in precautions or procedures to minimize radiationexposure and in the purposes and functions of protective devices used;

3. Instructed in, and instructed to observe, to the extent within the worker'scontrol, the applicable parts of the regulations and the facility license,registration and RPP for protection of individuals from radiation;

4. Instructed in the operating and emergency procedures applicable to theactivities in which the individual is involved;

5. Instructed of their responsibility to report promptly to management anycondition that may lead to or cause a violation of regulations, license orregistration condition or any procedural violations, especially those whichcould result in unnecessary exposure of individuals to radiation;

6. Instructed in the response to make to warnings made in the event of anyunusual occurrence or malfunctions that may involve exposure of individualsto radiation; and

7. Advised that workers may request radiation exposure reports specified in theregulations, if monitoring is required.

In addition to the above requirements, training includes instruction on radiationexposure to the unborn child as recommended in U.S. NRC Regulatory Guide 8.13,procedures for declaration of pregnancy for females desiring protection of theembryo/fetus and training in the requirements of the States Standards forProtection Against Radiation regulations.

The training program shall meet these requirements using a combination of severalor all of the following techniques: classroom training, web based training courses,power point presentation, on-the-job training, practical exercises, demonstrations,and informal discussions. Individuals who require radiation safety training shallattend an appropriate training session upon employment and receive periodicrefresher training at least annually (10-14 months from previous training).

All occupational workers shall not be allowed to operate any radiation emittingmachine (e.g., a cabinet x-ray system) until such individual has:

(1) Received copies of, instruction in, and demonstrated understanding of, theuser's operating and emergency procedures by obtaining a passing gradeof at least 80% on a written examination covering this material. The writtenexamination shall be at least 50 questions in length; and

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(2) Demonstrated competence to use the radiation machine by obtaining apassing grade of at least 80% on a practical examination covering thismaterial. The practical examination shall be at least 25 questions inlength.

Training records for all .individuals shall be maintained by the facility RSOindefinitely.

In addition to radiation safety training for unescorted occupational workers whowork with or frequent the Restricted Area, Rapiscan Laboratories shall provideradiation safety awareness training upon initial employment and on an annualfrequency thereafter to those employees who require occasional access to therestricted area, but do not perform work on or operate equipment generatingradiation. These workers shall be considered "members of the public" andexposure to sources of radiation shall be less than 2 mRem in one hour and lessthan 100 mRem in one year.

Visitors or temporary contractors who require access to a restricted area shall bebriefed and "escorted" at all times while frequenting the restricted area. Visitorsor temporary contractors shall be considered members of the public andexposure to sources of radiation shall be less than 2 m.Rem in one hour and lessthan 100 mRem in one year. Visitors or temporary contractors shall be instructedto remain with their escort at all times while frequenting the restricted area.

Only trained and qualified occupational workers may escort visitors or temporary

contractors within the Restricted Area.

1.13 Procedure Development

Radiation Protection Program implementing procedures shall be developed inaccordance with State Radiation Control Agency regulations and the programs andpolicies of the RPP and corporate policies and procedures. The review processshall ensure all procedures are:

1. Clear in scope, applicability, limiting conditions and precautions.2. Uniform in procedure identification and current status.3. Consistent in format (for organization, instruction step format, instruction

step designation, caution and note format, and page format).4. Written with clear, easily understood text, using standard grammar,

nomenclature and punctuation shall present instructional steps in a concise,logical sequence.

5. Written using definitions that are consistent throughout the RadiationProtection Program manual. Definitions shall be consistent with regulatorystandards. To the extent practicable, definitions shall be consistent with

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other technical guidance documents (e.g., ICRP, NCRP, ANSI Standards,Regulatory Guides, etc.).

1.14 Technical Verification of Procedures

Procedures shall undergo technical verification and review to ensure compliancewith regulatory requirements, all applicable license and registration requirements,compliance with the Radiation Protection Program, and conformance to the extentpracticable, with applicable technical guidance documents. Procedure review shallassure compatibility with all other operational procedure manuals and documents.Reviews shall ensure the procedure can be performed as written andresponsibilities are clearly defined and consistent with position descriptions.

1.15 Approval and Control of Procedures

All Radiation Protection Program procedures shall be approved by the RSO.Procedures shall be issued and controlled in accordance with corporate qualityassurance program document control policies and procedures.

1.16 Radiation Protection Logs, Records, and Turnovers

Implementation of the Radiation Protection Program results in generation of recordsdemonstrating compliance with Federal and State Radiation regulations. Examplesof such records include results of facility and project specific radiation surveys,calibration records of survey instruments, personnel monitoring exposure records,sealed source leak test records and records of training. Radiation Protectionrecords shall be controlled in accordance with regulatory and license andregistration requirements as well as the Radiation Protection Programrequirements.

Records shall be accurate and legible and shall utilize standard terminology andabbreviation. Records review shall be performed to ensure completeness,accuracy and timeliness. Temporary storage systems shall be established, asnecessary, to store those records needed for day-to-day functioning of the program.Temporary storage systems shall assure safe retention with provision for retrievaland shall comply with corporate requirements.

Records shall be retained for a minimum of ten years, unless otherwise noted in theapplicable State Radiation Control Agency regulations.

1.17 Notifications and Reports

Notifications to employees shall be made in accordance with the requirements ofthe State Radiation Control Agency regulations. In addition, written annual reportsof external occupational dose shall be provided to workers as applicable. Workersshall receive copies of all reports pertaining to them that are required to besubmitted to the State Radiation Control Agency.

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Notification and reports required to be made to the State Radiation Control Agency(e.g., overexposures, excessive radiation levels, unplanned damage to the x-raymachine, etc.) shall be made within the required time frames outlined in the StateRadiation Control Agency and the radiation protection program procedures.

Notification shall be made immediately to the State Radiation Control Agency bytelephone after discovery of any event involving any radioactive material sealedsource or radiation emitting device that has caused, may have caused or threatensto cause any of the following conditions:

An individual to receive:

1) A total effective dose equivalent of 25 Rem or more;

2) An eye dose equivalent of 75 Rem or more; or

3) A shallow dose equivalent to the skin or extremities of 250 Rad or more;

Prevention of immediate protective actions necessary to avoid exposure toradiation that could exceed regulatory limits (events may include fires, explosions,etc.).

A report to the State Radiation Control Agency shall be made by telephone within24 hours after discovery a radioactive material sealed source or radiation emittingdevice may have caused or threatens to cause any of the following event involvingloss of control of a radioactive material sealed source or if a source of radiation mayhave caused or threatens to cause any of the following conditions:

An individual to receive in a period of 24 hours:

1) A total effective dose equivalent exceeding 5 Rem;

2) An eye dose equivalent exceeding 15 Rem; or

3) A shallow dose equivalent to the skin or extremities exceeding 50 Rem;

An event in which equipment is disabled or fails to function as designed when:

1) The equipment is required by regulation or license condition to:

(i) Prevent exposures to radiation exceeding regulatory limits, or

(ii) Mitigate the consequences of an accident;

2) An unplanned fire or explosion damaging any device, container orequipment when:

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(i) The damage affects the integrity of the device, container orequipment.

2.0 ALARA Policy

Federal and State Radiation Control Agency regulations require the owner of asource of radiation and/or radioactive material to develop, document, andimplement a radiation protection program commensurate with the scope and extentof licensed and/or registered activities. In addition, the regulations require theowner to use, to the extent practicable, procedures and engineering controls basedupon sound radiation protection principles to achieve occupational doses anddoses to members of the public which are "as low as is reasonably achievable".

In order to comply with the regulations and to ensure a safe and healthyenvironment for workers and members of the public, operations shall beperformed in a manner such that doses are maintained "as low as reasonablyachievable" (ALARA). The ALARA Occupational Exposure Control Programdescribes the methods used to ensure this objective is met as provided inAttachment 1.

The acronym ALARA, "As Low as is Reasonably Achievable", means making everyreasonable effort to maintain individual dose to radiation as far below the doselimits contained in the State Radiation Control Agency regulations as is practical,consistent with the purpose for which the registered activity is undertaken. Theeconomics of improvements in relation to the state of technology and in relation tobenefits to the public health and safety shall be taken into account.

The ALARA concept is intended to be an optimization principle rather than anabsolute minimization of exposures. The ALARA concept is set forth in theCompany ALARA Policy.

2.1 Radiation Safety Committee (ALARA Review Committee)

* The Radiation Safety Committee is responsible for establishing policiesgoverning the procurement, use, storage and disposal of radioactive materialsealed sources and radiation-producing devices.

" The Committee includes individuals experienced in the use or application ofradioactive materials and radiation devices and provides a peer review of theseuses among Authorized Users at Rapiscan Laboratories and temporary job sites.The Committee shall meet at least quarterly to review jobs/tasks/experimentswhich require ALARA Design input.

* The Rapiscan Laboratories RSO shall act as Chairman of the Committee and

retained all minutes of each meeting.

2.2 Key ALARA Program Elements

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There are several key elements of an effective ALARA program. Managementrecognizes the importance of ALARA and is committed to maintaining individualand collective dose to ionizing radiation as low as reasonably achievable.However, dose reduction to ionizing radiation is the responsibility of each andevery individual.

Management and the RSO are responsible for evaluating and implementing theapplicable key elements of this program, however, every individual is encouragedto participate in making recommendations that would further lead to reductions inpersonnel exposures.

The registrant incorporates, but is not limited to, the following key elements intothe ALARA Program.

* Regulatory Controls* Radiation Protection Program Procedures* Standardized Operating and Emergency Procedures* Engineering Controls* Administrative Controls* Personnel and/or Area Monitoring (If Required)* Warning Signs, Labels and Lights* Training* Work-In-Progress Surveillance* Routine Radiation Surveys and Inspections• Routine Testing of Safety Devices

3.0 Personal Monitoring Program Policies

Regulations establish a total effective dose equivalent (TEDE) limit and a totalorgan dose equivalent (TODE) limit for "occupationally" exposed adults, minors anddeclared pregnant females. The TEDE is the sum of the deep dose equivalent(DDE) from external exposures and the committed effective dose equivalent(CEDE) from internal exposures. The TODE is the sum of the DDE and thecommitted dose equivalent (CDE) to any individual organ and tissue.

Monitoring of an individual's "occupational" dose is required by State RadiationControl Agency regulations if the external dose is likely to exceed 10% of anyoccupational dose limit appropriate for the individual. Although it is unlikely for anyemployee to receive an occupational dose in excess of 10% of any of the externaloccupational dose limits from operations at the Rapiscan Laboratories andtemporary job sites, personal monitoring of employees who routinely frequent orwork in a restricted area shall be monitored for external radiation dose.

Monitoring of the intake of radioactive material is required by regulations if theintake is likely to exceed 10% of the Annual Limit of Intake (ALl) during the year for

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an occupationally exposed individual, including the embryo/fetus of a declaredpregnant woman. Rapiscan Laboratories does not perform operations involvingradioactive materials which could create a loose surface or airborne radioactivityenvironment since all radioactive materials are in the form of sealed sources whichare properly stored. when not in use and leak tested routinely every 6 months forthose sealed sources used frequently and are of continued use and sourcestrength. As a result, no internal dose monitoring is required or shall beperformed.

All personnel dosimeters (except for direct and indirect reading pocket ionizationchambers and those dosimeters used to measure the dose to the extremities) thatrequire processing to determine the radiation dose shall be processed andevaluated by a dosimetry processor: (1) Holding current accreditation from theNational Voluntary Laboratory Accreditation Program (NVLAP) of the NationalInstitute of Standards and Technology; and (2) Approved in this accreditationprocess for the type of radiation or radiations included in the NVLAP program thatmost closely approximates the type of radiation or radiations for which the individualwearing the dosimeter is monitored." Accredited dosimetry processing servicesshall be used if personnel monitoring is performed or required.

Records of occupational dose monitoring results shall be maintained. Reports ofindividual monitoring results shall be made available to monitored individuals on anannual basis.

Routine personnel monitoring reports are not required to be made to Federal or theState Radiation Control Agency; however, records shall be made available forreview by regulatory personnel.

Rapiscan Laboratories RPP policies and procedures also address requirements forprotection of individual members of the public, whether living in the vicinity of thefacility or visiting. Policies are also presented for administrative dose limits,emergency exposures, embryo/fetus monitoring, and dose assessments.

3.1 Occupational Dose Limits

The following annual dose limits apply to all employees and contractors who mayreceive an occupational dose at the facility. Occupational dose is defined as theradiation dose an individual receives in a restricted area and other work-relatedradiation dose the person receives, but does not include medical dose, dose due tobackground radiation, or dose received while a member of the public.

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Annual Administrative Occupational Dose Limits for Adults are as follows:

1. Whole Body - The more limiting of a total effective dose equivalent(TEDE) equal to 1.0 Rem (1000 mRem) or the sum of the deep doseequivalent and committed dose equivalent to any individual organ ortissue, other than the lens of the eye, equal to 2.0 Rem.

2. Skin - A shallow dose equivalent equal to 5.0 Rem.

3. Lens of the Eye - An eye dose equivalent equal to 1.5 Rem.

4. Extremities - A shallow dose equivalent equal to 5.0 Rem.

Annual Administrative Occupational Dose Limits to Minors are as follows:

1. The dose limits for minors shall be 10 percent of the correspondingadministrative dose limit for adults.

Occupational Dose Limits to Embryo/Fetus are as follows:

1. The dose to the embryo/fetus of declared pregnant women shall belimited to 500 mRem during the entire time of pregnancy. Substantialvariations in dose rate shall be avoided.

2. The dose to the embryo/fetus shall be taken as the sum of the deepdose equivalent (DDE) to the declared pregnant woman" and theinternal dose (CEDE) to the embryo/fetus from radionuclide's in theembryo/fetus and in the declared pregnant woman during thepregnancy. If the declared pregnant female has never been exposedto or monitored for internal dose, it is not necessary to determine theCEDE.

3. Upon declaration of pregnancy, the occupational dose to theembryo/fetus from the date of conception to the date of declarationshall be determined, including any occupational dose received atother facilities during the current year. The primary dosimeter shallbe read monthly, if one is issued.

4. If the dose to the embryo/fetus exceeds or is within 50 mRem of thedose limit (i.e., 500 mRem) at the time a woman declares herpregnancy, the embryo/fetus shall be allowed to receive up to anadditional 50 mRem during the remainder of the pregnancy.

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3.2 Dose Limits for Individual Members of the Public

The TEDE received by individual members of the public from licensed and/orregistered operations involving sources of ionizing radiation shall not exceed 100mRem in a year. In addition, the dose in any unrestricted area from externalsources shall not exceed 2 mRem in any one hour.

Compliance with these annual dose limits is required to be documented.Documentation shall show the total effective dose equivalent to the individual likelyto receive the highest dose does not exceed the dose limits.

Compliance with the dose limits for individual members of the public shall bedemonstrated through measurements and/or calculations based on the results ofroutine area radiation surveys, area dosimetry monitoring, occupancy times or acombination of all for those individuals who work in the unrestricted area of thefacility and for those individuals who may occasionally frequent the restricted area.

3.3 Personnel Monitoring for External Radiation

Regulations require the use of individual monitoring devices for any adult, minor, orembryo/fetus likely to receive a dose in excess of 10 percent of the limits foroccupational exposures to sources external to the body.

All individuals who may receive an occupational dose in excess of 10 percent of thelimits for annual administrative occupational dose for adults as listed in Section 3.1and who routinely frequent or work in the restricted area shall receive radiationsafety training as stated in Section 2.2 and a primary dosimetry monitoring badge.

When utilized, primary dosimetry shall be processed by a laboratory or vendormaintaining accreditation by the National Voluntary Laboratory AccreditationProgram (NVLAP). In addition, primary dosimetry devices shall be capable ofmeasuring the deep dose equivalent (DDE) at a tissue depth of 1.0 centimeter,measuring the eye dose equivalent (LDE) at a tissue depth of 0.3 centimeter, andcapable of measuring the skin dose equivalent (SDE) at a tissue depth of 0.007centimeter.

Personnel monitoring equipment shall be placed at the location on the bodyexpected to receive the highest whole body exposure. When exposure conditionswill lead to relatively uniform whole body dose (deep dose equivalent), thedosimeter shall be worn on the front of the body between the neck and waist.If exposure conditions will lead to non-uniform dose to the whole body, the

dosimeter should be moved to the body location of highest dose.

Primary dosimeters shall normally be processed, at a minimum, on a quarterlyexchange cycle. Primary dosimeters shall be processed under the followingcircumstances:

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1. After routine badge exchange.

2. When individual monitoring is no longer required.

3. Upon employment termination.

4. When over-exposure of an individual has occurred or is suspected.

5. When special, non-routine circumstances (e.g. declared pregnant woman)cause the need for knowledge of an individual's current official dose asdirected by the RSO.

Occupational workers shall be instructed during radiation safety training that lost ordamaged personnel monitoring equipment shall be reported to the RSOimmediately. An exposure investigation shall be performed.

3.4 Visitors

Visitors are not subject to individual monitoring, record keeping, and reportingrequirements.

Visitors shall be escorted or under the direct observation of an escort at all timeswhile in the Restricted Area. Visitors shall not receive a dose greater then 100mRem during any calendar year or greater than 2.0 mRem in any one hour.

3.5 Declared Pregnant Woman (Declared Pregnant Woman) Exposure Policy

Based on recommendations of the National Council on Radiation Protection andMeasurements (NCRP) and Federal and State Radiation Control Agency regulatoryrequirements, controls are established for the protection of the embryo/fetus duringa female occupational workers pregnancy. These controls shall ensure compliancewith regulatory requirements and protect the rights of the female occupationalworker.

Declaration of pregnancy is voluntary and entirely at the discretion of the woman(medical proof is not required). To declare pregnancy, the woman shall inform thefacility RSO, in writing, of the pregnancy and provide an estimated date ofconception so the estimated dose to the embryo/fetus prior to declaration can bedetermined.

A woman may withdraw her declaration of pregnancy at any time and for anyreason by notifying the facility RSO in writing. Any woman who does not declareher pregnancy shall be subject to the normal administrative occupational dose limitsand shall not be subject to special controls or treatment with respect to workassignments involving exposure to radiation even if she is pregnant.

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Efforts shall be made to avoid substantial variation above a uniform monthlyexposure to the embryo/fetus of a declared pregnant woman (e.g. exposures aboveabout 55 mRem in any month should be avoided).

It is unlikely that a pregnant woman will exceed the 500 mRem per gestation periodlimit. However, if an "occupational female worker" chooses to declare herpregnancy, the Declared Pregnant Woman shall be issued a primary dosimeter andthe primary dosimeter shall be processed monthly.

The limit of 500 mRem for the term of the pregnancy is only for "declaredoccupationally exposed females". All other pregnant females at the facility who areconsidered "members of the public" are limited to 100 mRem for the entire year,therefore no declaration of pregnancy is necessary or required.

The RSO shall inform the Declared Pregnant Woman of the results in writing each

month upon receipt of the results.

3.6 Medical Radionuclide Intakes

Occupational dose does not include dose received due to medical administration ofradionuclides. Therefore, individuals monitored for occupational dose with aprimary dosimeter shall be instructed to inform the RSO prior to entering theRestricted Area when medical treatments involving radionuclides have beenadministered. After being informed of a medical intake, the RSO should obtain, ifpossible, documentation signed by the individual stating the date of treatment,radionuclide used, amount of intake, and medical procedure.

The RSO and the worker's supervisor shall assess what work restrictions may benecessary until the medical radionuclides have cleared to avoid problems withexposure to co-workers or exposure to co-workers external dosimeters.

Primary dosimetry issued to the occupational worker shall NOT be worn by theindividual while the radiopharmaceutical is being eliminated from the body sincethis dose is not considered occupational dose. The RSO will clear the worker toperform as an Authorized or Designated user when the external dose rateassociated with the medical radionuclide is trice the background rate.

3.7 External Dose Assessments

The results of primary dosimeters shall be reviewed quarterly by the RSO. A doseassessment shall be performed whenever the primary dosimeter reading issuspect, the primary dosimeter was damaged and could not be read, dosimetrywas lost or as deemed necessary by the RSO.

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Dose assessments shall be reviewed and approved by the RSO prior to assigninga dose other than that measured by a primary dosimetry device. The individualshall sign the dose assessment verifying the information provided by the individualis accurate. The results of the dose assessment shall be filed in the individual'sexposure history file.

Dose assessments should include the following as applicable:

1. Results of dosimeters worn by other individuals working in the same workarea under similar exposure conditions during the same exposure period.

2. Calculations based on measured dose rates and the estimated time spent inthe work area by the individual involved.

3. Investigation of survey data and comparisons of results.

4. Evaluation of all areas entered by the individual.

3.8 Routine Personnel Exposure Reports

Annual exposure reports are not required to be submitted to any Federal or StateRadiation Control Agency, however all exposure records shall be retained by theRSO.

An annual summary report of the individual radiation dose received should be sentto each worker who was issued primary dosimetry during a calendar year by April 1of the following year on an NRC Form 5 or equivalent form.

When requested by an individual, a written exposure report shall be provided toeach such individual within 30 days of the request or within 30 days of exposuredetermination, whichever is later.

3.9 Radiation Exposure Record Keeping

Records of individual monitoring shall be kept by the RSO on clear and legiblerecords containing all information required.

All radiation exposure records should use the conventional unit, Rem, or multiplesthereof and shall clearly and specifically indicate the quantities (e.g. deep doseequivalent) and units (e.g., Rem or mRem) of all recorded values. Records ofembryo/fetus dose shall be maintained with those of the mother, including thesigned declaration of pregnancy form.

3.10 Privacy Protection

Personnel radiation exposure records should be maintained by the RSO in locked

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file cabinets. Access by other personnel shall be authorized by the RSO only forlegitimate business needs.

4.0 Instrument Inventory and Control

Issue, control and accountability of radiation protection instrumentation shall beperformed in accordance with established procedures and shall be consistent withregulatory requirements. In addition, equipment issue, control, and accountabilityshall conform to industry standards and guidance.

A sufficient inventory of operable and calibrated radiation detection instrumentationshall be established and maintained to satisfy the following considerations:

1. Effective measurement of radiation exposure appropriate to enable theassessment of radiations at the energies and intensities anticipated.

2. Maximum number of personnel and separate work areas and equipmentrequiring surveillance.

3. Frequency and types of surveys or measurements required to supportnormal and anticipated activities.

4. Allowance for repair and calibrations.

Instruments that are broken, fail an instrument inspection, exhibit unstable andfluctuating, erroneous or abnormal readings or require calibration shall be tagged"out of service". Out-of-service instruments shall be segregated from operableinstruments and placed in a designated location until they can be repaired and/orcalibrated.

4.1 Calibration

Calibration of radiation detection instrumentation should be performed inaccordance with ANSI N323A-1997, "Radiation Protection Instrumentation Test andCalibration" or most recent revision and/or equivalent standards and shall beperformed in accordance with manufacturer procedures. Calibration shall beconsistent with regulatory requirements and should conform to industry standardsand guidance.All instruments shall be calibrated prior to first use, following any repair,maintenance, or modifications that could affect calibration, and after failure of aresponse test requiring adjustments or repair that could affect calibration. Thecalibration frequency for radiation detection instruments shall be a minimum ofannually.

Offsite calibration of radiation detection instrumentation by a qualified licensedvendor or the manufacturer is acceptable if calibration certification is supplied by

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the vendor or manufacturer, including traceability of calibration sources, and suchcalibration certification is reviewed for completeness and accuracy prior to use ofthe instrument. Radiation detection instrumentation shall be calibrated usingNational Institute of Standards and Technology (NIST) traceable sources, orequivalent. The sources shall be of the type, energy and geometry representativeof the radiation to be measured.

4.2 Operational Tests

Operation of radiation detection instruments shall only be performed by personnelqualified in the use of the instrument. Additionally, operation shall be performed inaccordance with the operational procedure for each type of instrument in use.Operation shall be performed in accordance with regulatory requirements and shallconform to industry standards and guidance.

4.3 Maintenance and Repair

Maintenance and repair of radiation protection instrumentation shall be performedby qualified personnel or a qualified vendor or the manufacturer. Onlymodifications approved by the instrument manufacturer should be made to aninstrument.

5.0 Restricted Area Access Controls

Access to the Rapiscan Laboratories and temporary job site Restricted Area shallbe controlled, authorized, and possibly restricted based on the operationsconducted within the Restricted Area. Only those individuals who have receivedthe required radiation safety training will be authorized "unescorted" access. TheRSO is responsible for ensuring each individual who requires unescorted accessto the restricted area receive regulatory required radiation safety training uponinitial employment and annual refresher radiation safety training thereafter. Onlytrained and qualified Authorized Users or supervised Designated Users shalloperate radiation emitting devices for which they have been trained to operateand/or handle/use radioactive material sealed sources.

The Access Control Program has been developed for the purpose of protectingindividuals against undue risks from access to sources of ionizing radiation.

Regulatory and administrative requirements and limitations, engineering controls,warning signs, labels and lights, access controls, training and a radiation surveyprogram have been incorporated to accomplish this objective and to meet the intentof an effective ALARA Program.

5.1 General Access Control Requirements

Access to the facility where a source of radiation and/or radioactive material sealedsources is present shall classify each individual as:

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1. Visitor/Temporary Contractor,

2. Rapiscan Laboratories employees who do not require routine access to theRestricted Area shall be classified as a Non-Occupational Worker (Memberof the Public), or

3. Rapiscan Laboratories employees or contractors who will require frequentaccess to the Restricted Area shall be classified as an Occupational Worker.

The following minimum Restricted Area access requirements are for each classification.

1. Visitors/Temporary Contractors

a. Read and sign the Radiation Safety Acknowledgment Formb. No dosimetry requiredc. Escort required

2. Employees - Non-Occupational Workers (Members of the Public)

a. Complete New Employee Radiation Safety Awareness Trainingb. No dosimetry requiredc. No escort required

3. Employees - Occupational Workers

a. Complete New Employee Radiation Safety Trainingb. Receive a copy of U.S. NRC Regulatory Plan 8.13 (females only)c. Dosimetry requiredd. No escort requirede. Complete Annual Refresher Radiation Safety Training each year

every 10-14 months

5.2 Administrative Access Control Requirements

Each visitor/temporary contractor shall enter the facility through the maindesignated facility entrance.

Each visitor/temporary contractor who requires entry into the Restricted Area shallread and sign the Radiation Safety Acknowledgment Form provided to them. Aqualified occupational worker is responsible for ensuring the visitor/temporarycontractor is escorted at all times during his/her entry into the Restricted Area.

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6.0 Radiological Surveys

Radiological surveys are performed in order to identify, quantify and evaluate thepotential hazards associated with the radiological conditions in the Restricted Area.Survey information is used to inform individuals of the radiologicalconditions/hazards in the area, to demonstrate compliance with regulatorystandards and to ensure personnel exposures to radiation are maintained ALARA.

The performance frequency and detail level of surveys shall consider the likelihoodof changing conditions, the intensity of the radiation source, the radiological hazardof specific areas and the personnel occupancy within various areas in order toanticipate personnel radiation doses and to ensure and verify personnel exposureto ionizing radiation are adequately controlled and monitored.

6.1 General Survey Requirements

Specific implementing procedures shall be developed to:

1. Identify situations and conditions requiring surveys, including routinesurveys.

2. Perform specific radiation surveys.3. Document and review survey results.4. Provide instruction for basic skills and techniques for performing surveys.

Radiation surveys shall be performed upon initial startup of new radiation sourcesand radiation generating equipment, periodically during operation of sources ofradiation and, in some cases, after the discontinuance of operations.

The RSO and the Radiological Control Group (RCG) shall determine and establishthe frequency and type of radiation survey(s) required to be performed during theoperation of a source of radiation. These requirements shall be listed on theRadiation Work Permit (RWP).

Radiation surveys shall be performed in the immediate general areas surroundingthe radiation source and/or equipment to verify radiological conditions are withinexpected range and limitations for work to be performed.Radiation surveys shall be performed outside the Restricted Area (UnrestrictedArea) to demonstrate compliance with the member of the public dose limits asrequired by the RWP.

6.2 Survey Documentation and Review

Surveys shall be legible and accurate and documented in a timely manner. Surveydocuments shall identify:

1. The date, time and location of the survey.

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2. The instrument used, including the make, model and serial number3. The instrument calibration due date.4. The name and signature of the surveyor.5. The results of the measurements and analyses.6. The name and signature of the individual that reviewed the survey results.

6.3 Routine and Non-Routine Survey Frequencies

Routine radiation surveys shall be performed, as necessary, and in areasthroughout the Restricted Area and Unrestricted Area as determined by the RSO.Non-routine radiation surveys shall be performed as directed by the RSO and asrequired by a radiation work permit (RWP).

Below are examples of routine and non-routine radiation surveys that may, but notlimited to, be directed by the facility RSO.

1. Monthly, quarterly, or semi-annual radiation survey of the Restricted Areaand Unrestricted Area based on radiological activities and conditions and asdirected by the RSO and/or RWP.

2. Routine radiation surveys of the radioactive material sealed source storageroom.

3. Individual radiation exposure investigation survey (lost or damageddosimetry badge).

4. Post-maintenance radiation survey (X-ray generator replacement, collimatoradjustments or shielding modifications).

5. Radiation emitting device movements.6. In Accordance with the requirements listed on the Radiation Work Permit

(RWP).

7.0 Radiation Work Permit (RWP)

A RWP is a document prepared by the RSO or ARSO, with input from theRadiological Control Group (RCG), to inform individuals of the conditions that existin the Restricted Area and the radiological (e.g., dosimetry requirements, surveyrequirements) and non-radiological requirements (e.g., safety glasses, safetygloves) while performing radiological activities.

7.1 Types of Radiation Work Permits

There are two types of Radiation Work Permits used to control facility radiologicaloperations within the Restricted Area.

General RWPs: General RWPs may be requested and issued for radiologicaloperations or projects where the radiological conditions are well known and notexpected to change substantially. General RWPs may be approved for use up to 12months.

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Specific RWPs: Specific RWPs may be requested and issued for radiologicaloperations or projects which are not performed routinely and the radiologicalconditions could vary substantially during operations and testing. Specific RWPsare limited to the duration of the proposed operation or project, not to exceed 3months.

7.2 RWP Process

Detailed implementing procedures and forms shall be developed and used todocument the RWP process. Prior to radiological operations within the RestrictedArea, the individual(s) who need to perform radiological operations shall submit anRWP Request which shall be reviewed by the RSO or ARSO who will determine ifthe RWP shall be a General or Specific RWP.

Based on the information provided in the RWP Request, a RWP shall be issuedand signed by the RSO or ARSO.

Prior to operations, all personnel intending to perform operations shall attend a pre-job briefing and sign an attendance form indicating they have been informed of theradiological and non-radiological conditions and potential hazards, informed of allsafety requirements, dosimetry monitoring requirements and radiation surveyrequirements.

When radiological operations are to commence, each individual must sign in on aRWP Sign In form documenting, at a minimum, the date and time of all entries andexits from areas such as radiation, radioactive material storage or high radiationareas.

Upon completion of the operations or project, the RSO shall terminate the RWPand file all paperwork by RWP number assigned. The RWP can be used in theevent an individual loses his/her dosimetry badge, if a dosimetry badge measuresabnormal readings, to evaluate total collective dose for the operation or project tohelp identify methods for dose reduction.

Rapiscan Laboratories operates and tests enclosed radiation emitting devices suchas baggage and cabinet x-ray machines, full body scanners and CT baggagescanners which are limited to very low external surface dose, therefore no RWPprocess shall be used for these devices.

The RWP program shall be used primarily for operations such as linear acceleratoroperations, neutron generator operations, sealed source handling, use and testingoperations and any other radiological operation deemed necessary by the RSO,ARSO or the RCG.

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8.0 Radioactive Material Sealed Sources

A program to control sealed radioactive sources is necessary to preventunplanned exposures and the loss of sources.

Rapiscan Laboratories has codified a general requirement indicating that allradioactive sealed sources, both accountable (also known as "licensedquantities") and exempt, shall be used, handled, and stored in a mannercommensurate with the hazards associated with operations involving the sourcesand in accordance with Rapiscan Laboratories Radioactive Material SealedSource Accountability and Control Guide provided as Attachment 2. Foraccountable sealed radioactive sources, specific measures, including inventoriesand source leak tests, shall be implemented in accordance with this guide.

8.1 Exempt Quantity Sealed Sources

Exempt quantities are sources with very low activity levels. Exempt quantitysources do not require a license for possession or leak tests, but are subject toalmost all of the same storage, use, transportation, labeling and otherrequirements as licensed quantities. Typically, exempt sources are small sealedsources used for calibration or as "check sources."

8.2 Non Exempt Quantity Sealed Sources

The following minimum guidelines apply to non exempt quantity sources:

Each source shall be listed on a company inventory roster with the followinginformation:

* Radioisotope,

* Activity,

* Manufacturer,

" Calibration or reference date,

" Source serial number, if available,

" Storage location,

" Name of individual possessing the source.

Sources shall not be permitted to leave the site under any circumstance exceptby written authorization of the RSO and in accordance with U.S. DOTregulations.

8.3 Maintenance of Non Exempt Quantity Sealed Sources

Individuals possessing sealed sources shall contact the RSO to confirm their

37


sources do not require leak testing in accordance with California RadiationProtection Regulations.

If a non exempt quantity source is lost, the RSO shall be notified immediately.

If a non exempt quantity sealed source breaks, becomes damaged, or thesealant is compromised, the RSO shall be notified immediately.

Non exempt quantity sources which decay beyond the useful life shall beproperly stored in the designated radioactive material sealed source storageroom until the RSO makes arrangements for proper disposal.

8.4 Use of Non Exempt Sealed Sources

Since there are many sealed sources of different activities and nuclidesmaintained at Rapiscan Laboratories and temporary job sites, the RSO isresponsible for ensuring all Authorized Users and Designated Users understandthe hazards of each sealed source prior to initial use. Sealed sources shall behandled properly with respect to their inherent hazards. In order to keepdistances maximized, the use remote handling devices or other devices, such astongs, shall be used as needed based on the radiological hazard.

All sealed sources shall be accounted for and secured against unauthorizedremoval when not in use. When removing sources from storage and replacingthem into storage, a "Use Log" shall be completed.

During normal operation of tests and research, and with prior approval,radioactive sources may be removed from and returned to the source storagearea at the end of daily operations. The sources will only be removed from thestorage area by authorized users on Rapiscan Laboratories' radioactive materialslicense and only for the purpose of the approved project.

All radioactive sources shall be logged out when removed from their storagecontainers. Logged information will include: in/out date and time, name ofauthorized user, source type, and source ID. Sources in use will be theresponsibility of the authorized user until returned and logged in to the storagecontainer.

8.5 Receipt and Shipping of Radioactive Materials

Receipt and shipping of radioactive materials shall be in compliance withapplicable US DOT regulations, 49 CFR Parts 100-185; in particular 49 CFRparts 171, 172, and 173. In addition to US DOT regulations, the transport ofspecial nuclear materials shall be performed in accordance with 10 CFR Parts 71and 74. If radioactive materials are transported by air domestically orinternationally, the shipment shall meet ICAO and IATA requirements as well.

38


Only persons who have received training on U.S. DOT' hazardous materialsregulations, IATA and ICAO Dangerous Goods requirements, and the properpackaging of radioactive (special nuclear) materials may prepare shipments fortransport. These employees must be retrained every two (2) years.

Site inspections for compliance with these regulations are performed by theCalifornia Department of Public Health-Radiological Health Branch, the USDepartment of Transportation (DOT), and the Federal Aviation Administration(FAA).

9.0 Radioactive Waste

In general, Low Level Radioactive Waste (LLRW), other than activation products,is not expected to be generated at any Rapiscan Laboratories' facility. If disposalof any radionuclides which have half lives of less than 120 days is necessary,these radionuclides may be stored on site for decay.

If disposal of any radionuclides which have half lives of 120 days or longer, theyshall be collected, labeled, stored in the source storage room, and disposed of asradioactive waste by a licensed radioactive waste contractor.

10.0 Temporary Job Sites and Reciprocity

NRC Form 241 or an Agreement State equivalent shall be filed to obtainauthorization to work under temporary job sites in other states, which is known asreciprocity. The NRC and most Agreement States require a minimum of threebusiness days notice prior to conducting activities under reciprocity. EachAgreement State has a separate fee which must be paid prior to receivingauthorization. The regulations are similar among states but not the same so inaddition to reading each state's regulations prior to conducting work the stateshould be contacted for clarification on any requirements. Reciprocity is typicallygood for up to 180 days in a calendar year, though times vary by state.

Federal facilities, such as military installations, are under the jurisdiction of theNRC. Note that in some complex sites, such as airports, federal and statejurisdiction may be different based upon the building being used. The NRCretains a master list of which sites are under exclusive federal jurisdiction, if thereis any question.The RSO or ARSO are responsible for preparing the reciprocity agreement.

11.0 Record Quality Assurance

All records required for licensing and/or registration and regulatory compliance shallbe legible throughout their required lifetime, which is generally 10 years or moreafter generation. Records can be originals, microfilms, or copies provided thatmicrofilms and copies are authenticated by authorized personnel and are capableof producing legible, accurate, and complete records during the required retention

39


period. Records shall include all pertinent information, such as stamps, initials, andsignatures. Safeguards against tampering and loss of records shall be taken toensure record security. Quality Assurance of records will be maintained inaccordance with facility policies and procedures.

11.1 Units of Measurement for Notices, Reports, and Records

The regulations require use of certain units for all quantities in radiation programrecords. These units include the SI units, Sievert, or Gray, or the Curie, Rad, Rem,and multiples thereof and the units shall be clearly indicated on all required records.In addition, it is required that clear distinction be made among the quantitiesentered on records. For example, dose equivalent quantities shall be clearlydefined as total effective dose equivalent, shallow dose equivalent, eye doseequivalent, deep dose equivalent, committed dose equivalent, or committedeffective dose equivalent.

11.2 Notices and Reports to Employees

Regulations require the following items be posted conspicuously so workers canobserve them as they go to and from the Restricted Area:

1. California Radiologic Health Branch, Notice to Employees, Form RHB 2364

2. State Radiation Control Agency Regulations (Standards for Protection AgainstRadiation)

3. Radiation Machine Operating Procedures

4. Certificates of Registration

5. Any Notice of Violations issued by the State Radiation Control Agency

6. The Response to all Notice of Violations issued by the State Radiation ControlAgency

In lieu of posting of the above, the regulations allow a Notice describing thedocument and the location where it can be examined. Form RHB 2364, Notices ofViolation and the registrant's responses shall be posted. These documents shallremain posted in accordance with the instructions provided by the State RadiationControl Agency.

It shall be Company policy to provide each individual monitored for occupationaldose, upon written request, at anytime throughout a calendar year, a written reportof the individual's occupational dose.

At the written request of former employees, a summary report of occupational doseby year shall be provided within 30 days from the date of the written request orwithin 30 days after the occupational dose has been determined. In addition,workers terminating employment may request a report or estimate of theoccupational dose received during the current quarter or calendar year.

40


11.3 Notification of Incidents

The regulations divide radiological incidents into two notification classes:immediate notification and 24-hour notification. Reports made to the StateRadiation Control Agency shall be made in a manner such that names ofindividuals are stated in a separate and detachable portion.

11.4 Reports of Overexposures, Excessive Radiation Levels, and ConcentrationsExceeding Limits

A written report shall be issued to the State Radiation Control Agency within 30days for:

1. Any incident requiring immediate or 24-hour notification,2. Exceeding dose limits for any occupationally exposed adult,3. Exceeding dose limits for any occupationally exposed minor,4. Exceeding dose limits for an embryo/fetus of a declared pregnant woman,5. Exceeding dose limits for an individual member of the public,6. Radiation levels in the restricted area exceeding the regulatory limits,7. Radiation levels in the unrestricted area exceeding 10 times any regulatory

limit.

Each report shall describe the extent of exposure of individuals to radiation andinclude:

1. Estimates of each individual's dose,2. Levels of radiation involved,3. Cause of the elevated dose or dose rate,4. Corrective actions taken to prevent recurrence, including a schedule for

achieving conformance with requirements.

Reports shall provide descriptions of each involved individual by name, socialsecurity number and date of birth such that the information on individuals is statedin a separate and detachable portion.

11.5 Leak Test Records

A source leak test shall be performed as soon as possible, prior to actual use ofthe source, by the facility RSO, ARSO or an Authorized User approved in writingby the facility RSO, if the sealed source has not been leak tested within six (6)months from the date of the most recent manufacturers leak test.

Records of leak test performance shall be retained for a minimum of three years.However, all of this facility's tests will be retained indefinitely in the RSO officewith the most recent copy maintained at the sealed source site.

41


If a leak test exceeds 0.005 pCi of removable contamination, the source mustremoved from use and the proper notifications made.

11.6 Notice of Registration Termination

If Rapiscan Laboratories ever decides to terminate a license or registration, theregulations require written notification of that intent no less than 30 days prior to thetermination.

11.7 Recordkeeping Requirements and Policy

Rapiscan Laboratories shall maintain documents generated to demonstratecompliance with the radiation protection program and that could be related to healthand safety of occupational workers or individual members of the public. Theserecords shall be maintained indefinitely.

11.8 Documentation of the Radiation Protection Program

The regulations require the radiation protection program be documented. TheRadiation Protection Plan, procedures and other records such as radiation surveys,training records, instrument calibration records, dosimetry records, andaudits/surveillances will be maintained to document the implementation of theradiation protection program. In addition, an annual review of the RadiationProtection Plan shall be performed, documented and records kept of these reviews.Records of the radiation protection program will be retained indefinitely inaccordance with regulatory requirements.

11.9 Records of Prior Occupational Dose

The regulations require the registrant to determine occupational dose for thecurrent year and to attempt to obtain records of lifetime cumulative occupationaldose for each individual who is likely to receive an occupational dose requiringmonitoring.

No individual will be authorized to participate in a Planned Special Exposure,therefore, no attempt to obtain prior occupational dose for previous years isnecessary.

For an occupational dose received during the current year, a written statementdisclosing the nature and amount of the occupational dose is acceptable. Thestatement shall be signed by the individual or the individual's most recent employerfor work involving radiation exposure. Reports can be provided via letter, telegram,or electronic media provided the authenticity of the information can be established.

11.10 Records of Current Occupational Dose

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Rapiscan Laboratories shall maintain records of doses for all individuals required tobe monitored. Records shall include, in part:

1. The deep dose equivalent to the whole body, eye dose equivalent, shallowdose equivalent to the skin, and shallow dose equivalent to extremities;

2. Internal dose assessments are not required since there is no radioactive

material contained within the cabinet x-ray system.

11.11 Records of Doses to the Embryo/Fetus

Records of doses to the embryo/fetus shall be maintained in accordance with thecurrent occupational dose record requirements and policy. The records shall bekept with the records of dose to the declared pregnant woman. The declaration ofpregnancy shall also be kept on file with the dose records.

11.12 Records of Doses from Accidental and Emergency Conditions

Dose records for individuals due to accident and emergency conditions shall bemaintained in accordance with the requirements and policy for currentoccupational dose records.

11.13 Records of Dose to Individual Members of the Public

Rapiscan Laboratories shall maintain records sufficient to demonstrate compliancewith the dose limit for individual members of the public. These records shall beretained indefinitely. All records of measurements and evaluations includingradiation surveys, calibrations of equipment and any other supporting informationshall be retained indefinitely.

11.14 Records of Radiation Surveys

Radiation survey records include any surveys made to comply or to demonstratecompliance with the regulations and standards. Examples include surveys forradiation emission leakage at the external surfaces of the x-ray equipment andgeneral area radiation surveys of the Restricted and Unrestricted Area surroundingthe cabinet x-ray machine(s). Company policy is to retain all survey recordsindefinitely and until a determination is made by management the records are nolonger needed.

11.15 Records of Training

Training records shall be maintained and include a list of trainees attending trainingand refresher training records along with a syllabus containing the training topics.The regulations do not set a specific retention time for training records; however,

43


company policy is to maintain training records indefinitely after termination ofregistration until determination is made by management the records are no longerneeded. The minimum time period for records retention shall be ten (10) years.

11.16 Sealed Source Inventory Records

The RSO, in accordance with regulatory requirements, shall create and maintainan inventory of all sealed sources located at the site at 6 month intervals. A copyof each site's inventory shall be available for on-site review. Master copies shallbe available for review in the RSO office. Sealed sources shall be stored in alocked room, enclosure, fenced area or other secured area and within acontainer such that low levels of ionizing radiation may not be an issue withrespect to the location where personal monitoring devices may be stored.

In the event an exempt or licensed sealed source is damaged, a leak test shallbe performed and the source shall be removed from service. Documentation ofall such incidents shall be retained by the RSO. Notification or Reportingrequirements as defined by regulations in the jurisdiction of use shall be adheredto by the RSO. Records shall be retained for a period of time specified byregulations in the jurisdiction of use.

11.17 Use Logs

Each radioactive material sealed source and/or radioactive sealed source deviceshall have a folder containing a Use Log Form. Each time a sealed source orsealed source device is used or activated and used to produce ionizing radiation;the Use Log must be completed.

The Use Log shall be completed whether the system is used for testing,demonstration or for client product evaluations. There are no exceptions - ifradiation is produced, the Use Log shall be completed. It is not necessary tomake an entry each time the source is "turned on".

The requirement is to log the date and time of the test/use. One log entry maycover multiple on/off sequences during the test or demonstration. The purpose isto note when the radiation was produced, the estimation of "beam time", and todocument those present at that time.

A valid Use Log entry contains the following:

" Date of test/demonstration," Start and end time of test or demonstration,* Name of those responsible for conducting the test," Notations, i.e. notes on malfunctioning safety systems, improper beam

production, etc.

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RAPISCAN LABORATORIES, INC RADIATION PROTECTION-PLAN

11.18 Annual Audits

Annual audits of the Radiation Safety Program shall be performed anddocumented as a report to Executive Management and shall be distributed to theRadiation Safety Committee. Copies of annual reports shall be available forinspection by regulatory authorities. At a minimum such audits shall document allinstances of non-conformance with regulations and operational policies in effectat the site with respect to the use of radiation, instances of unusual exposures orexposure histories trending towards threshold levels requiring or resulting incorrective measures, lapses of training, "near-miss" documentation, andreporting on any instrument or equipment malfunctions that could have resultedin unnecessary exposures. The audit shall encompass an audit of the facility inregards to all of the elements of radiation safety, employee interviews to test theirknowledge of the radiation safety protocols, and a review of programs,procedures and policies related to the radiation safety program.

11.19 Additional Records

The RSO shall keep records of all radioactive materials licenses, sealed sourceand device registrations (SSDR), radiation machine registrations, and anyamendments or terminations of the authorizations.

In the event of an inspection from the RHB or NRC (as applicable), the records ofeach inspection shall be kept indefinitely by the RSO. If any violations are cited,the written notice of these violations must be posted in a conspicuous placewithin 2 days of its receipt. The notice must remain posted for 5 days or until theviolation is corrected, whichever is longer.

Certain other records are also maintained. These include all instrument logs,calibrations and repairs, radiological occurrence reports, routine surveillancerecords, investigations, audits, inspections, related regulatory correspondence, andany other documentation the RSO considers prudent to maintain. Retention ofthese records is expected to be on the order of many years. The minimum timeperiod for records retention shall be ten (10) years.

12.0 Emergency Response Plan

Rapiscan Laboratories shall develop an emergency response plan that coversevents involving radioactive material sealed sources and radiation emittingdevices. This plan is enclosed as Attachment 3.

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List of Attachments

Attachment 1: ALARA Occupational Exposure Control Program.

Attachment 2: Radioactive Material Sealed Source Accountability and ControlGuide

Attachment 3: Emergency Response Plan for Events Involving RadioactiveMaterial Sealed Sources and Radiation Emitting Devices

46

Rpsca y sAn OSI Systems Company

As Low as Reasonably Achievable(ALARA)

Occupational Exposure Control Program GuideFor

Rapiscan Laboratories Inc.

January 13, 2011

Michael GrayDirector of Radiation Safety and ComplianceRadiation Safety OfficerRapiscan Systems Inc.Radiation Safety Office (310) 349-2311 Office24-Hour Emergency (310) 897-9328

RAPISCAN ALARA Occupational Exposure Control Program 1

Purpose and Applicability

This Guide provides an acceptable methodology for establishing and operatingan occupational "as low as is reasonably achievable" (ALARA) program thatcomplies with State and Federal requirements and provides the administrativeand operational guidelines for Rapiscan Laboratories, Inc. and temporary jobsites. This document shall be referred to as the ALARA Occupational ExposureControl Program.

Definitions

Terms defined in 10 CFR 20 and California Regulations Title 17 Division 1Chapter 5 Subchapter 4 are used throughout this Guide. A comprehensive list ofdefinitions has been included in the Radiation Protection Program manual.

Jurisdiction

This document describes Rapiscan Laboratories, Inc. and temporary job siteplans and measures for implementing the ALARA process and shall apply to allRapiscan Laboratories employees, staff and contractors. With respect to ionizingradiation, all activities shall be specifically governed and/or regulated by the laws,regulations and standards in effect in the State of California. A copy of Californiaradiation regulations shall be available for review to any staff member, employeeor contractor at the site, upon request. Copies of relevant California regulationsshall be located in the office of the facility Radiation Safety Officer and AssistantRadiation Safety Officer.

The effective implementation of this document will ensure compliance withapplicable sections of regulations that are in effect regarding the licensee topossess and use radiation emitting devices and/or radioactive material sealedsources within the State of California. Should any section of this documentconflict or be found in disagreement with regulations of the State of California,California regulations shall prevail and shall not be superseded by any content ofthis guidance document.

ALARA Policy and Management Commitment

It is the policy of Rapiscan Laboratories and its management, to conductradiological operations in a manner that ensures the health and safety of allemployees, contractors, and visitors.

Rapiscan management shall demonstrate their support of the ALARA programthrough direct communication, instruction, inspection of the workplace, andactions including:


Management decisions that place ALARA considerations before cost orschedule considerations

* Encouragement of and praise for workers who identify ALARA solutions;* Support of the Radiation Safety Office and Radiation Safety Committee;* Publication of ALARA success stories.

All site personnel shall be made aware of management's commitment to ALARAand occupational workers shall be instructed on their responsibility to complywith management's ALARA commitment statement which shall be periodicallyupdated and reaffirmed.

Rapiscan Laboratories ALARA Policy states:

It is the policy of Rapiscan Laboratories to conduct its radiological operations in amanner that ensures the health and safety of all its employees, contractors, andthe general public. In achieving this objective, Rapiscan Laboratories shallensure radiation exposures to its workers and the public are maintained belowregulatory limits and deliberate efforts shall be taken to further reduce exposuresto as low as reasonably achievable. Rapiscan Laboratories is fully committed toimplementing a radiation protection program of the highest quality thatconsistently reflects this policy.

Management and the Radiation Safety Office shall periodically perform work-in-progress reviews of occupational workers adherence to sound ALARA practicesand procedures with respect to ionizing radiation and shall also take intoconsideration the workers attention to industrial safety and compliance in thecourse of evaluations. Performance of workers shall be considered as part ofannual performance reviews and considerations for promotions and taskassignments.

State regulations require to the extent practical, procedures and engineeringcontrols based upon sound radiation protection principles to achieveoccupational doses and doses to members of the public that are as low as isreasonably achievable (ALARA). ALARA program policies, plans and proceduresfor maintaining occupational exposures ALARA has been incorporated as part ofthe Rapiscan Laboratories' Radiation Protection Program (RPP).

Measures include incorporating ALARA considerations into the design of newfacilities and modifications of existing facilities, as well as activities that pose thepotential for significant occupational dose. Administrative controls are utilized asmeasures which supplement engineered controls and are integrated into thework planning process.


ALARA Program

ALARA is an approach to radiation protection with the intent of maintaining,monitoring and controlling individual and collective dose to employees,contractors and visitors to levels as low as reasonable, taking into considerationsocial, technical, economic, practical and public policy considerations. ALARA isnot a dose limit, but a process for maintaining doses that are as far asreasonably achievable below the applicable limits as specified in regulatoryrequirements on occupational radiation protection. ALARA may be consideredan "operational philosophy".

Assumptions and Dependencies

The ALARA philosophy works on the supposition that penetrating radiation dosesincrease one's risk of cancer - the smaller the dose, the smaller the risk.Although this premise has not been proven at low doses of radiation (such as,acute whole body doses of 10 Rem or less), regulations generally require sometype of formal plans and measures for applying the ALARA process tooccupational exposures.

From a technological and regulatory standpoint, ALARA applies to the TotalEffective Dose Equivalent (TEDE) which is the Deep Dose Equivalent (DDE)from an external exposure to the whole body plus the committed effective doseequivalent (CEDE) from internally deposited radioisotopes. The TEDE limit of 5Rem/year (5,000 mRem) is based upon establishing a reasonably lowoccupational latent cancer risk.

Occupational exposures to the extremities, skin, and eyes are consideredseparately from the whole body, with higher set dose limits. These deterministicdose limits exist to prevent radiation damage to a worker (as opposed to simplylimiting one's risk to cancer). Because deterministic exposures have not beenshown to contribute to an increased risk of cancer, they are not formally includedin the ALARA program. However, from an operational standpoint, it is importantto stay well below the dose limits so that operations can proceed withoutimpediment.

Formal Plans and Measures

The method of implementing an ALARA program is highly dependent on thecomplexity and magnitude of potential radiological hazards associated with theradiological activity. The elements of an effective ALARA program are included inthis guide and included, in part, in the Radiation Protection Plan. The degree offormality and the level of detail contained in this guide and other pertinentdocumentation such as implementing procedures shall be commensurate withthe magnitude of the radiological hazard associated with the radiological activity.


A radiological activity with higher collective dose and/or potential for significantoccupational doses shall have more detailed ALARA documentation than anactivity with low collective doses and/or potential for significant occupationaldoses.

The results of ALARA planning and evaluations shall be incorporated into theRadiation Work Permit Program. A Radiation Work Permit shall be written forradiological activities of a "general" nature with low individual and low collectivedose potentials where radiation levels are low and radiological conditions arestable. For those radiological activities with a potential for higher individual orhigher collective doses, operations may require "specific" additional surveys,dosimetry, hold points or personal protective equipment and/or monitoring.

ALARA Training

ALARA training is included in the Initial and Refresher Radiation Safety Trainingthat is required for all occupational workers who work with, or frequent aRestricted Area where sources of radiation and/or radioactive material sealedsources are stored and used. In addition to general ALARA awareness training,the Radiation Safety Officer and management shall incorporate, as necessary,additional training which can include, but is not limited to, mock-up training, dryruns, safety device checks and/or emergency drills when preparing for uniquetasks where exposure may be higher than during than normally low level workexposures. Refresher training is required annually within 10-14 months from theprevious years training.

Training records shall be maintained and shall include a list of trainees attendingtraining and refresher training records. The regulations do not set a specificretention time for training records; however, company policy is to maintain trainingrecords indefinitely after termination of the license until determination is made bymanagement the records are no longer needed. The minimum time period forrecords retention shall be ten (10) years.

Specialized ALARA training shall be developed for personnel who plan, prepare,schedule, estimate, or engineer activities that have the potential for significantradiological consequences. The purpose of training these personnel in ALARAconcepts and techniques is to empower them to include ALARA considerations inthe early phases of job planning and engineering. This training shall provide thebasics of ALARA concepts and the use of ALARA-related equipment such as, butnot limited to, special monitoring devices, shielding, and special tools.


ALARA Design Review

State regulations require that measures be taken to maintain radiation exposuresin Restricted Areas ALARA. The primary method used shall be engineeredcontrols (e.g., confinement, access controls, safety interlock devices and visualwarning indicator lights and/or audible warning sounds or sirens, remote handlingtools and equipment and shielding). Administrative controls shall be incorporatedonly as supplemental methods and for specific activities where engineeredcontrols are demonstrated to be impractical.

State regulations further require that during routine operations, the combinationof engineered controls and administrative controls shall prevent the anticipatedoccupational dose to occupational workers and members of the public fromexceeding regulatory. Engineered controls typically include features that areused to control the-work environment, such as permanent structures, systems,and controls, including shielding, remote controls, area monitoring cameras(CCTV), and the use of designs and materials that facilitate operations,maintenance, and other activities.

The ALARA design review shall include six discrete phases:

1. Individual and Collective Dose assessment;

2. Review of projected radiological conditions against the trigger points ornumerical criteria established by management to initiate a review;

3. Identification of the applicable radiological design criteria;

4. Review of similar facilities, designs, and processes to assist in theselection of optimum ALARA design features and less costly alternativesusing approved numerical criteria;

5. Incorporation and documentation in the design package of features toreduce the exposure of personnel; and,

6. Post-construction review of effectiveness of ALARA engineering featuresto provide feedback to the design engineers and help refine the designprocess.

The ALARA design review shall be conducted and documented in accordancewith an approved procedure and the design review package shall be readilyretrievable.


Radiation Safety Office Responsibilities

The Radiation Safety Officer, Corporate Radiation Safety Officer and/or theRadiation Safety Committee whom possess expertise in radiation protection,shall perform an independent ALARA design review that includes the followingelements:

Review the general configuration of the facility and/or equipment,considering traffic patterns, location of radiation areas, location of fixedmonitoring equipment, and adequacy of space for anticipated operations,equipment movements, maintenance, production, research, anddisassembly of project areas.

Verify that radiological design criteria are consistent with applicablefederal/state regulations, recognized standards and guides, and with thefollowing corporate directives relating to radiological and non-radiologicalsafety.

Evaluate and confirm the adequacy of specific control devices for reducingoccupational doses, including shielding, hoods, glove boxes,containments, interlocks, barricades, shielded cells, decontaminationfeatures, and remote operations.

Verify that the design will be able to maintain personnel entry control foreach radiological area, commensurate with existing or potentialradiological hazards within the area.

Verify that each entrance or each access point to high and very highradiation areas will have the control features required by State regulations.

Assess the adequacy of planned radiological monitoring and determinewhether the proposed instrumentation is appropriate for the expectedtypes, levels, and energies of the radiation(s) to be encountered, andwhether it has sufficient redundancy and capability for operation undernormal operating conditions and during emergencies.

Radiation Safety Committee (ALARA Review Committee)

The Radiation Safety Committee is responsible for establishing policiesgoverning the procurement, use, storage and disposal of radioactive materialsealed sources and radiation-producing devices. The Committee includesindividuals experienced in the use or application of radioactive materials andradiation devices and provides a peer review of these uses among AuthorizedUsers at Rapiscan Laboratories and temporary job sites. The Committee shallmeet at least quarterly to review jobs/tasks/experiments which require ALARADesign input.


The Rapiscan Laboratories Radiation Safety Officer shall act as Chairman of theCommittee and retained all minutes of each meeting.

Authorized Users

Authorized Users are responsible for:

Providing information and input needed for proper tasks associated withplanning and design review of facilities, equipment and operations,

Assist in gathering and forwarding information for formal ALARA reviews,design reviews, and other information required to support organizationaldecisions,

Participating in the ALARA goal process for workers who are likely toreceive individual doses exceeding 0.1 Rem/year (1OOmRem/yr),

Investigating increasing trends in doses to individual workers or dosesassociated with performance of specific tasks,

Ensuring the constant reinforcement of the ALARA program requirementsin their Radiological Control Group,

Incorporating the ALARA philosophy and recommendations as appropriatein activities under their direct supervision or control,

Identifying and reporting activities that may be novel or unique and shouldbe considered for ALARA review,

* Maintaining oversight of Designated Users during radiological operations.

Designated Users (Occupational Workers)

Designated Users are responsible for:

Informing Authorized Users, supervisors, project managers and RSO ofproposals for reducing exposures,

Implementing the ALARA requirements specified in plans and proceduresrelevant to their specific tasks and operations,

Consulting with the Authorized User, Project manager and/or RSO prior tobeginning work where concerns of exposure may be present,

Providing information and feedback during pre-job briefings and postevent reviews for continuous improvement of the radiological safetyprogram,

Becoming an active participant in their own safety and the safety of theirco-workers.


Optimization Methodology

In developing and justifying facility designs or modifications and physicalcontrols, optimization methods are required to assure that occupational exposureis maintained ALARA. Optimization methodology provides the technical andmanagerial basis for setting numerical criteria for ALARA decisions in the designof facilities, project/experimental areas within the Restricted Area, developmentor review of work processes, and the design/purchase of special tools andequipment. Selection of an appropriate cost-benefit factor for reducingoccupational dose involves a judgment of the relative value of dose, normally interms of dollars per Rem avoided.

Job/Task/Experiment Reviews

A formal ALARA job/task/experiment review shall be performed for work orexperiments with the potential to exceed the established numerical radiologicalcriteria. The following are examples of criteria that should trigger a formal ALARAreview.

The estimated individual or collective dose is greater than pre-established

criteria.

There is potential for significant radiological exposures.

Individuals will enter areas where exposure rates could exceed pre-established criteria.

The ALARA job/task/experiment review shall encompass three discrete phases:

(1) Pre-job planning and dose assessment.

(2) Specification and implementation of ALARA controls and dosetracking.

(3) Post-job review.

Pre-job Planning and Dose Assessment:

Pre-job planning shall include an estimate of the collective dose resulting fromthe job/task/experiment and a determination regarding whether the numericalcriteria for an ALARA job/task/experiment review will be exceeded. Theestimates may be based on actual or historical radiological monitoring results. Ifa review is required, the next step is to identify appropriate ALARA controls andalternatives. This should include an assessment of the cost of controls againstnumerical criteria.

RAPISCAN ALARA Occupational Exposure Control Program

ALARA Controls:

During the work or experiment, the RSO or management shall include periodicwork-in-progress inspections to ensure ALARA controls are being implementedand the Radiation Work Permit instructions and requirements are being met andare effective. Typical ALARA controls implemented in the field includeappropriate use of shielding and personal protective equipment, monitoring ofstay times, minimization of time in radiological areas, maximizing distances fromradioactive sources, and effective use of mock-up training and pre-job briefings.In addition, individual and collective doses should be tracked and periodicallycompared to the dose estimates to determine if intervention is needed.

Post-Job Review:

Post-Job Review criteria shall be established to trigger a formal post-job review.The post-job review should compare the actual person-hours and person-Remwith the estimates, evaluate the effectiveness and cost of the ALARA controls,document the lessons learned, and make recommendations on ways to controldose for similar activities. The ALARA review shall be documented and recordsshall be readily retrievable.

Consideration of Non-Radiological Hazards

Due to the complex nature of many Rapiscan Laboratories activities, acombination of radiological and non-radiological hazards may be encountered.Identification of non-radiological hazards is critical to the ALARA processbecause efforts to apply the ALARA process may inadvertently increase risksfrom non-radiological hazards. An integrated safety management approach thatoptimizes worker protection from all hazards shall be considered in the ALARAprocess for a given radiological activity.

The work planning process shall integrate the consideration of other industrial,physical, and chemical hazards that an individual may encounter. Efforts tomaintain worker doses ALARA shall ensure the risk of personnel injury fromother hazards is not disproportionately increased.

An integrated approach during the work planning process will ensure that alloccupational hazards are appropriately considered and the ALARA process isfollowed.

Operations Reviews

The RSO shall review each radiological operation or routine activity during whichworkers may be in close proximity to ionizing radiation. The purpose of thereview is to identify potential sources of personnel dose and the controls


necessary to reduce that dose. The review also ensures appropriate controls fornormal operations and "upset" conditions are integrated into radiologicaloperations.

During this review, the RSO shall consider the following:

* Individual dose expected to each worker involved in the operation.• Potential dose consequence to workers and public for "off-normal"

operations.Whether the projected dose could be reduced or eliminated byusing less radioactive material or lower energies, shielding withoutintroducing offsetting problems, or tools such as remote handlingdevices.

* Is the work area appropriate for the type of work being performed,* Is the area properly posted.* Are appropriate monitoring requirements included in the operation.* Has proper consideration been given to non-radiological hazards

and the appropriate controls to mitigate these potential hazards.

Based on these considerations, the RSO may identify appropriate controls usinga graded approach.

Typical operational ALARA controls include:

* Using tools, shielding, and work space as appropriate.* Minimizing time in the radiological area." Maximizing distance from radiological sources.* Monitoring "stay times".* Effective use of mock-up training and drills.* Holding pre-start briefings.

Pre-job briefings shall occur for all jobs/tasks/experiments which require a"Specific" Radiation Work Permit to discuss workplace conditions; current doserates and any stay time other important restrictions or potential "hold points"during the radiological activity. This pre-job briefing shall be documented and allindividuals briefed shall sign the RWP Pre-Job Briefing Form. No individual shallparticipate on a job/task/experiment until they have received the Pre-job briefingfor the "specific" RWP in which the individual shall perform work under itsauthorization.

When considering the operations, emergency egress routes which minimizeemployees' dose must be considered. In emergency situations, egress routesmay be directed through areas not normally traveled. It is important to considerthe establishment of these routes in the design process.

RAPISCAN ALARA Occupational Exposure Control Program

Employees with critical emergency facility and equipment shutdownresponsibilities must secure radiation-emitting devices and secure radioactivematerial sealed sources provided these actions preclude the individual(s) fromundue risk or danger prior to exiting the building.

In the event of a fire, the RSO and Fire Department shall be notified immediately.The RSO or other designee must inform the FD of the exact location of the fireand of the potential exposure risk(s), if at all possible.

The event shall be documented on a Radiological Occurrence Report (ROR) andforwarded to the RSO. An investigation will be performed to understand thecause of the event and determine whether any unanticipated exposuresoccurred.

The ROR investigation will determine what type of notification (immediate, 24-hour notification or written report) will be necessary for State notification.

Formal ALARA Reviews

A formal ALARA review shall be performed based upon the criteria in Table 1and documented. This review does not need to be conducted if the cost,together with the costs of documentation, outweighs the potential value of anybenefits. The ALARA review should be conducted in the following three distinctphases:

" During the planning phase." While work is being conducted." Following the completion of the work.

During the planning phase of an operation or task, the RSO shall:

* Review each task as outlined in the RWP Request Form.* Based on survey data or anticipated radiological conditions, estimate the

the total dose for each task, by taking the products of the total estimated timefor each task and the anticipated dose rates and record the estimated totalcollective dose for each task on the actual RWP Form.

* Identify those discrete functions of a task that may result in adisproportionate fraction of the dose.


Table 1 Conditions Requiring a Formal ALARA Review

1. Individual whole body dose from an operation/task is expected to exceed0.05 Rem (>50 mRem)

2. Collective dose of all personnel performing the task is expected to exceed0.5 Rem (> 500 mRem)

3. Operation/task is expected to require entry by individual into areas withexposure rates exceeding 0.1 R/hr (> 100 mR/hr) at 30 cm. (High RadiationArea Entry).

No individuals shall be permitted entry into a Very High Radiation Areawhile the source of radiation is operating and the Very High Radiationcondition exists.

Dose Investigations and Thresholds

The RSO shall investigate all primary and/or secondary dosimeter readings orresults that exceed certain thresholds identified in Table 2. The results shall bedocumented on an Exposure Investigation Report and shall be included in therecords maintained for dosimetry exposure reports. If any of the thresholds inTable 3 are surpassed, the Project Manager and/or RSO shall conduct anddocument a Post-Job ALARA review. The post-job ALARA review may involveoccupational workers, members of EH&S, the RSO and others that may havebeen affected by the situation.

Table 2 Dose Thresholds

Whole Body Film : Wlhole Body FilmDose Type" x. and gamma , w/ x gamma & Extremity.TLD

neutronDeep Photon 100 mRem 100 mRem NANeutron 20 mRem 50 mRem NAShallow 100 mRem 300 mRem NAExtremity NA NA 1000 mRem

Table 3 Post Job Interview Thresholds

1. The actual dose exceeds the pre-job estimate by more than 25%2. A stop work order is issued for radiological purposes3. Operations resulted in an injury report4. Significant "lessons learned" are identified5. Notifications to Corporate RSO of "worker concern"6. Notification by regulatory agency of situation of concern


Summary of Dose Investigations and Thresholds

Table 4 summarizes the ALARA Program thresholds.

Table 4 ALARA Program Thresholds

'Acbtion Threshold Peff6ormd ByConduct and Document a For all radiological Site RSO, work/projectFormal ALARA Review operations involving the supervisor, may be assisted

use of radioactive by Corporate RSOmaterial sealed sourcesand/or radiation emittingdevices with a potentialto exceed any of thedose limits outlined inTable 1

Conduct and document an For Individuals who Site RSO, occupationalExposure Investigation exceed the Dose worker(s) receiving theReport Threshold values dose and possible

contained in Table 2 consultation w/ CorporateRSO

Establish individual ALARA Individual external dose Site RSO, w/ assistance ofgoals is expected to exceed work supervisor/project

0.05 Rem (50 mRem) for manager, in consultation w/a specific corporate RSOjob/task/experiment or0.5 mRem (500 mRem)

Conduct an ALARA Pre- For all jobs/tasks or RSO, in conjunction withJob Briefing experiments that may working group or

exceed the dose limits radiological control groupoutlined in Table 1 and (RCG), or specificfor every "Specific RWP" individuals performing theissued to perform task/operation.radiologicaltasks/operations.

Conduct a Post-job review As specified in Table 3 RSO in conjunction with_ __ Isupervisor/project manager

Conduct a design review Modification of facilities Specific affected workor major equipment group w/ RSO and project

manager/work supervisor


Internal Audits

Internal audits shall be conducted by the site RSO at a minimum of once peryear, or more frequently as dictated by regulatory requirement. Audits shall bedocumented and copies forwarded to the Corporate Radiation Safety Officer.The audit should identify relative strengths, weaknesses, and areas ofvulnerability or non-compliance. Audits shall review the administrative controlsand assure that they are in conformance with regulatory requirements. Areasfound to be deficient shall include remarks on how the site RSO and workersplan to bring the deficient program area into full conformance.

Records

Several classes of records, plans, drawings, surveys, shielding plans, dosimetryrecords, RWP records, ALARA Reviews, Exposure Investigation Reports andPost Job ALARA reviews will be generated to document and demonstrate aneffective ALARA Program.

These records shall be retained in accordance with State regulatoryrequirements and the requirements established by Rapiscan Laboratories QualityAssurance procedures and the requirements outlined in Section 11 of theRapiscan Laboratories Radiation Protection Plan.

RapiscanTMsystemsAn OSI Systems Company

Radioactive Material Sealed SourceAccountability and Control Guide

ForRapiscan Laboratories Inc.

January 13, 2011


RAPISCAN RADIOACTIVE MATERIAL SEALED SOURCE9210671 ACCOUNTABILITY AND CONTROL GUIDE

Purpose and Applicability

This guide is intended for use at licensed Rapiscan Laboratories and temporaryjob sites where radioactive material sealed sources may be received, transferred,used and stored.

Strict adherence to this Guide and supporting implementing procedures andtraining ensures compliance with applicable federal and state regulationsregarding receipt, transfer, use, leak testing and storage of radioactive materialsealed sources licensed by the State or Nuclear Regulatory Commission (NRC).

Jurisdiction and Applicable Law

In the event of a conflict between the requirements of the Rapiscan LaboratoriesRPP and applicable Federal and/or State Radiation Control regulations or thefacility license and/or registration, the requirements of the applicable StateRadiation Control regulations or facility license and/or registration conditions shalltake precedence. An updated copy of the applicable California regulations shallbe maintained at the facility by the Radiation Safety Officer and copies madeavailable to employees upon request of the Radiation Safety Officer.

Accountable (Licensed Quantities) and Exempt QuantitySources Controls

Rapiscan Laboratories has established an accountability program for the receipt,transfer, use and leak testing of radioactive material sealed sources to preventunauthorized acquisition, unplanned exposures and the loss of these sealedsources.

A complete source inventory shall be performed every six (6) months and theupdated inventory is posted. Radioactive material sealed sources shall beclassified as "Exempt", "Not in Use", or "Leak Test Required".

Radioactive material sealed source use is controlled by minimizing the number ofpersonnel who have keys to the locked sealed source storage room and whenremoved, the Authorized User shall record this removal and subsequent returnon a radioactive material sealed source check-out/check-in log.

Exempt quantity radioactive material sealed sources are not required to beinventoried or leak tested. However, exempt quantity sealed sources and theindividuals using them are still subject to all other applicable RapiscanLaboratories policies and procedures applicable to radioactive material control,posting and labeling.

RAPISCAN LABORATORIES, INC. SEALED RADIOACTIVE SOURCE PAGE 1

ACCOUNTABILITY CONTROL GUIDE

Implementation Guidance

This section provides guidance for establishing and operating a radioactivematerial sealed source accountability and control program. Key components ofthe program include:

" Organization and responsibilities* Training* Sealed Source Acquisition" Shipping procedures" Labeling, storage, and documentation" Inventory requirements" Sealed Source leak testing" Handling and Use" Disposal• Control and transfer

Radiation Safety Officer (or Assistant RSO) Responsibilities

The Rapiscan Laboratories Radiation Safety Officer is ultimately responsible forthe development and oversight of the radioactive material sealed sourceaccountability and control program. The RSO may delegate these responsibilitiesto the Assistant RSO when the RSO is not available. The Corporate RSO, facilityRSO or the Assistant RSO are the only individuals with signature authority forsealed source acquisition approval and transfer of sealed sources off site.It is the ultimate responsibility of the facility Radiation Safety Officer to obtain aState radioactive material license amendment, prior to receipt, authorizing thereceipt, possession and use of all accountable (licensed quantities) radioactivesealed sources.

The RSO, Assistant RSO or Authorized Users, designated in writing by the RSO,shall be the only individuals authorized to perform the sealed source leak tests.

Authorized Users (AU)

An AU is an individual specifically authorized by the State or NRC specificradioactive material license that possesses the authority, in part, to retrieve fromstorage, handle and use or authorize the handling and use of a radioactivematerial sealed source.

Designated Users (DU)

A DU is a Rapiscan Laboratories trained and qualified occupational workerauthorized by an AU, in part, to handle and use a radioactive material sealedsource provided this Designated User is under the supervision of an AuthorizedUser. The Authorized User shall be onsite during these activities but does nothave to be present 100% of the time at the project/experimental location on site.



The Designated User is responsible for informing the Authorized User of his/heractivities as needed during operations and upon completion of operations. TheDesignated User shall comply with all procedures and complete all applicableforms and logs throughout operations and sealed source use.

Only the RSO, ARSO or an Authorized User is authorized to access the lockedradioactive material storage area to acquire, inspect, check out and check inradioactive material sealed source(s). Once the radioactive material sealedsource has been properly checked out in writing, the RSO, ARSO or AuthorizedUser may transfer temporary responsibility for sealed source handling and use toa Designated User.

The Designated User is responsible for the safe possession, handling and useuntil such time responsibility is transferred back to an Authorized User who maycheck in the sealed source in writing placing the sealed source(s) back in theproper locked radioactive material storage room.

Radiation Control Group (RCG) Responsibilities

The RCG is any group or team of Authorized Users and Designated Usersworking on, or having specific authority and responsibility over aproject/experiment that requires the use of an accountable (licensed quantities)radioactive sealed source(s), which shall bear the primary responsibility forensuring radiation protection activities when using such sources.

The RCG is responsible for:

" Obtaining written authorization from the Corporate RSO, RapiscanLaboratories facility RSO or Assistant RSO before any radioactive materialsealed source acquisition can be made when new sealed sources arenecessary for the project/experiment.

" Coordinating the scheduled receipt of all newly acquired sealed sources forthe project/experiment with the facility RSO or Assistant RSO to ensurereceipt and inventory procedures are properly implemented prior to use.

* Maintaining records related to the accountability and control of sealedsources,

* Maintaining proper handling, use and storage for the duration of theproject/experiment,

" Informing to the facility RSO or Assistant RSO of any potential unsafeconditions or actual radiological occurrences and/or safety violationsassociated with the handling, use and/or storage of sealed sources during theproject/experiment,

• Maintaining compliance with ALARA controls and the requirements of theProject/Experiment Radiation Work Permit (RWP) requirements establishedby the facility RSO or Assistant RSO,

* Maintaining project/experiment records and reports which clearly describe theactivities of the project/experiment, including, in part, a description of sealedsources (i.e., assigned serial number, radionuclide, activity) used during theproject/experiment.


ACCOUNTABILITY CONTROL GUIDETraining Requirements and Policy

All individuals authorized to enter the Restricted Area unescorted who work with orfrequent the area in which radioactive material sealed sources and sources ofradiation are operated shall receive information and training in radiation safety.

Authorized Users and Designated Users who will possess, handle and useradioactive material sealed sources shall receive additional training as needed andas determined by the Corporate RSO, the facility RSO or Assistant RSO in theproper precautions to be taken when handling sources which require specialinstructions and handling procedures and controls such as byproduct materialsealed sources with radiation exposure levels in excess of 100 mR/hr on contact,special nuclear materials, depleted uranium, transuranics and/or weapons gradeplutonium as examples.

This additional training shall be documented and retained by the facility RSO.

RSO Notifications and Approvals

The RCG representative shall notify and obtain approval of the RSO prior to:

* Obtaining a purchase order for the acquisition of any radioactive materialsealed source (Licensed or Exempt Quantities),

" Any major change in the use of a sealed source,* Transfer of a sealed source to a new permanent storage location, to an

authorized temporary job site or any other off site transfer,* Any modification of a device containing a radioactive sealed source,* Operation or use of any sealed source for which any associated engineering

control or safety feature has failed, not yet been installed, or has beendeliberately by-passed.

" In the event of the loss of, or suspected or actual damage to, any radioactivesealed source.

Receipt of Radioactive Material Sealed Sources

Receipt

The facility RSO or Assistant RSO shall be notified immediately upon the arrivalof all accountable and exempt quantity sealed radioactive sources.

Upon receiving a shipment of a radioactive material sealed source, the RSO orARSO will perform a radiation survey of the external surface of the shippingpackage and inspect packaging for damage.

When applicable, the RSO shall prepare and mail a letter indicating "verificationof receipt" to the vendor/shipper of the source.

Radioactive sealed sources shall be assigned a Rapiscan Laboratories serialnumber, added to the sealed source inventory list and placed in storage.



A file folder identified by the Rapiscan Laboratories assigned serial number shallbe created and shall include, but not limited to, the following documents:

" Manufacturer's certificate of calibration," Manufacturer's certificate of leak test prior to shipment or the most recent leak

test certificate

A source leak test shall be performed as soon as possible, prior to actual use ofthe source, by the facility RSO, ARSO or an Authorized User approved in writingby the facility RSO, if the sealed source has not been leak tested within six (6)months from the date of the most recent manufacturers leak test.

A form similar to Appendix A, Change Source Status Form shall be completed foreach new radioactive sealed source.

Labeling RequirementsUnder Agreement States provisions, labels may read, "Caution: RadioactiveMaterial" and include the internationally recognized symbol for radiation. Thewords and symbol shall be in magenta or black on a yellow background.

Descriptive labels are usually applied directly to the source device or sourceholder and include the identity of the radionuclide, source activity, date of assay(calibration date or reference date), model and serial number of both the sourceand the source holder, and a method for contacting the manufacturer (usually aphone number).

Labels may include radiation levels "on contact", removable contamination levels,dates monitored, and names of the individual performing the monitoring. Thisinformation is usually documented and attached to the shipping paperwork. Thisis not always possible due to the amount of information and size and spacelimitations.

Rapiscan Laboratories labels or tags shall be applied to all radioactive sealedsources, regardless of source activity, to help identify the sealed source,minimize the risk of loss, mishandling, improper disposal or unauthorized use.

All worn, damaged or missing sealed source label or tag shall be replaced assoon as possible and prior to use.

Documentation RequirementsThe facility RSO or Assistant RSO shall retain all generated and accompanyingpaperwork upon receipt. All documents associated with a sealed source are tobe kept in a file folder dedicated to the specific sealed source serial numberassigned by Rapiscan Laboratories.

The binder documents should include, but not limited to, the followingdocuments:

" Manufacturer's certificate of calibration," Manufacturer's certificate of leak test prior to shipment or most recent leak

test certificate," Sealed Source Device Registry documentation and any attached revisions, if

applicable,

RAPISCAN LABORATORIES, INC. SEALED RADIOACTIVE SOURCE PAGE 5ACCOUNTABILITY CONTROL GUIDE

" Bill of Lading," Dangerous Goods Declarations,* Manufacturer's Guidelines for Operation, Use and Maintenance (Sealed

Source Device).

Tracking Requirements

All sources are received and inspected, inventoried and tracked by a RapiscanLaboratories assigned sealed source serial number. Each sealed source foldershall be placed in a central filing location in the Radiation Safety Office. Duplicatefolders may be produced and made available for specific temporary job siteswhere the sealed source may be used.

Radioactive Sealed Source StorageProper radioactive sealed source storage practices limit unauthorized use andminimize the potential for damage, rupture, excessive personnel exposure, orloss.

Upon completion of all receipt procedures, all radioactive sealed sources shall betransferred to the designated locked radioactive material storage room.

The locked radioactive material storage area shall be surveyed routinely asdirected by the facility RSO. Additional surveys shall be performed wheneverthere could be a change in status as a result of adding a new sealed source tothe storage unit or changes to shielding that may affect radiological conditions.

Rapiscan Laboratories has 3 shielded source storage holes imbedded in the floorfor storage of Cf-252 sources. For ALARA purposes it has been policy to wipetest only the cover and the upper portions of the source hole and not the sourcesthemselves.

Inventory

A complete sealed source inventory shall be performed every six (6) months andthe updated inventory posted. The sealed sources shall be inventoried andclassified as "Exempt", "Not in Use", or "Leak Test Required".

Since inventories and leak testing are both required at six-(6) month intervals,.both are likely to occur at the same time when possible to minimize the numberof entries and time in the area. These inventories shall accomplish the following:

" Establish the physical location of each source," Verify the presence and adequacy of postings and labels,• Verify adequacy of storage locations, containers and devices.

RAPISCAN LABORATORIES, INC. SEALED RADIOACTIVE SOURCE PAGE 6ACCOUNTABILITY CONTROL GUIDE

Leak Test Methodology

The integrity of an accountable (licensed quantity) radioactive sealed sourceshould be established by a wipe test or other leak test method as recommendedin one of the following documents:

* ISO/DIS Report 9978, Radiation Protection Sealed Radioactive SourcesLeakage Test Methods (ISO 1990),

* ISO/TR Report 4826, Sealed Radioactive Sources - Leak Test Methods,(ISO1979),

" ISO Report 1677, Sealed Radioactive Sources - General (ISO 1977)," NCR{P Report No. 40, Protection Against Radiation from Brachytherapy

Sources (NCRP 1972)," ANSI N43.6-1977, Sealed Radioactive Sources - Classification (ANSI 1977),* Appendix V of NUREG 1556, Volume 11, Consolidated Guidance about

Materials Licenses (NRC 1998).

Testing Accountable Radioactive Check Sources

Radioactive material may be electroplated onto the foil area of the check orcalibration source. Do not test electroplated sources by wiping the foil directly.

Test by checking the storage container for radioactivity. Check sources, withelectroplated radioactive material should not be stored with other sources ascontact with other items may remove some of the deposited radioactive material.

The integrity of an accountable (licensed quantity) radioactive sealed sourcecontained within a shield, device, or holder apparatus may be checked by wipingthe area where contamination is most likely to occur.

Never perform leak testing on high-activity sources which involves direct physicalcontact with the source capsule. Sealed sources used in GaRDS inspection orVEDS systems have high whole-body or extremity doses which can result fromtypical, leak test procedures. Remote handling devices or indirect monitoringtechniques, such as monitoring accessible source holder areas likely to leak arerecommended.

Exempted Sealed Sources from Leak Testing

An accountable radioactive sealed source is not subject to mandatory periodicleak testing if the sealed source has been removed from service as indicated bylabeling reading, "Out of Service -Do Not Use". However, unless some otherradiological event precludes leak testing, these sources should be leak testedperiodically to determine the condition of the source. Such sources shall bestored in a controlled location, subject to periodic inventory, and leak testing priorto being returned to service. The last known leak test for these sources shouldbe recorded on a form similar to Appendix A.



Inaccessible Sources ExceptionAn accountable sealed source is not subject to periodic leak testing if the sealedsource is located in an area that may be unsafe for human entry or is otherwiseinaccessible, e.g., in a very high radiation area. If a source is determined to beinaccessible for inventory or leak testing, record this condition on the inventoryreport and perform the leak test after the sealed source is removed from thearea.

This provision does not apply to sources that are located in instruments or otherdevices located in accessible areas, nor to sources considered inaccessible dueto radiological conditions created by the presence of the source itself.

Leak tests may be performed on these sources by wiping the instrument ordevice consistent with the information in this Guide. When the source becomesaccessible, the required inventories and source leak tests should be completedprior to completing these measures. If a sealed source cannot be leak tested atthe proper time, the source should be removed from service until the leak test isperformed. If a source is installed in an inaccessible area, the device should notbe used until the source has been leak tested.

Passing or Failing Leak TestingWipe samples obtained from leak testing shall be transferred off-site to alicensed laboratory specifically licensed to perform these services. The facilityRSO shall provide the necessary information adequate enough for the licensedfacility to know what radioisotope has been wiped, the date the sample wasobtained and other pertinent information requested by the laboratory.

The RSO should obtain and maintain a copy of the laboratories license whichauthorizes the leak testing services which are being provided to RapiscanLaboratories.

A source passes the leak test if analysis of the test sample or smear indicatesthat the sample has removable loose surface contamination of less than 0.005micro curies (185 Bq) from the area wiped.

The facility RSO shall instruct the laboratory provided leak test analysis servicesto inform the facility RSO in the event a wipe test has failed.

A test result that reveals the presence of removable loose surface contaminationgreater than 0.005 micro cures (185 Bq) is an indication the sealed source isdamaged or the integrity of the sealant has been compromised. The leakingsource must be controlled in a manner that minimizes the spread of radioactivecontamination. Any sealed source that fails a leak test shall be immediatelyremoved from service and tagged as such.

The Corporate RSO shall be notified immediately upon notification of the resultsof a failed leak test.



Containment

A leaking source shall be placed in a separate container to prevent the spread ofradioactive contamination. All personnel and equipment exposed to the leakingsource shall be checked for contamination; including transport vehicles, if any,since the time of the last known satisfactory leak test, the radioactive materialstorage area and the general work area where the sealed source was used. Ifcontamination is found, monitoring facility areas for loose surface contaminationshall be expanded until no radioactive contamination is found. The contaminatedarea shall be isolated and decontaminated to levels below U.S. Regulatory Guide8.16 levels prior to release for general access.

The Corporate RSO and facility RSO shall determine the best course fordisposition which may include returning the leaking source back to themanufacturer for evaluation or have it removed by a licensed radioactive wastebroker or licensed radioactive waste processor for proper disposal.

Accountable radioactive sealed sources capable of generating external radiationfields in excess of 100 millirem/hour (lmSv/hour) at 30 cm require specialprotection precautions, including posting in immediate and adjacent areas, dosereduction methods, and special dosimeter and monitoring procedures.

Radiation monitoring shall occur during and after use of such sources to verifythe adequacy of controls, and return of the source to a safe condition. Obsolete,excess, or leaking sources shall be disposed of according to the RSO'sinstructions. These radiological activities shall be controlled by the RadiationWork Permit program and procedures.

Lost SourcesImmediately upon knowledge or notification of a lost accountable sealed source,the Authorized User shall notify the RSO who in turn shall notify all members ofthe RCG and the Corporate Radiation Safety Officer. All members of the RCGshall participate in a formal search of all designated use locations, likely transferpaths, and possible collection points. Notify appropriate authorities as dictatedby regulatory guidelines. An Radiological Occurrence Report (ROR) shall beinitiated and an investigation shall be conducted by facility management todetermine the root cause of the loss and initiate corrective and preventiveactions.



Disposing of Radioactive Shipping Labels & Other Yellow Waste(Clean Yellow Waste)

The radioactive sealed source shipping container and other "yellow" materialswhich could be "conceived" as potentially radioactive but are not such asradioactive shipping labels, radiological signs, postings, tags, etc. that are yellowin nature and contain any radiation related phrases, terminology or words,markings or symbols (3 Blade trefoil symbol) shall not be disposed of in normalwaste bins transferred to local landfills.

Rapiscan Laboratories policy shall be to remove all radioactive shipping labels,radiological signs, postings, tags, etc. that are yellow in nature and contain anyradiation related phrases, terminology or words, markings or symbols (3 Bladetrefoil symbol) completely.

This "clean yellow waste" shall be maintained within the radioactive materialstorage area in a container marked or labeled "Clean Yellow Waste".

This policy shall be discussed and included in initial radiation safety training.

RecordsAppendices A and B are examples of typical "Accountable Radioactive SealedSource Accountability Forms". A form similar to Appendix A, Change of SourceStatus Form, shall be completed for each new radioactive sealed source. Thisform shall be used to document initial receipt and inventory of the source, leaktesting, and changes in sealed source status.

The facility RSO shall maintain all original sealed source related records, forms,leak test results, etc. in a file tracked by the Rapiscan Laboratories assignedserial number.

A form similar to Appendix B, Leak Test and Inventory Form shall be used forsealed source inventories or leak tests are scheduled.

Special Nuclear Materials

A separate log shall be kept for the use of Special Nuclear Materials. Therequired documentation shall include the manufacturer name, model, and serialno. of the source, date signed out, Authorized User, location of use, and the datesigned back in.

Special nuclear materials shall be included in 6 month intervals audits, and shallbe electronically reported to the NRC in materials status reports on an annualbasis within 60 days of the most recent audit period. Reports shall include allinformation listed on NRC Form 742.

Procedures shall be put in place for maintaining a chain of custody for sourcesbelonging to the federal government or another organization which will be in use



temporarily. This documentation shall include the manufacturer, model, andserial no. of the source, date received, Authorized User, location of use, and thedate returned.

Special nuclear materials transferred to other licensees shall be electronicallyreported in nuclear material transaction reports to the NRC. Reports shallinclude all information listed on NRC Form 741. Reports shall be filed by theclose of business on the following date sources were shipped. The receipt ofspecial nuclear materials shall be electronically reported to the NRC within 10days.

The transport of special nuclear materials must be performed in accordance withUS NRC regulations 10 CFR Part 71 and 74 and US DOT 49 CFR 173.Documentation shall be kept of the shipment and receipt of all special nuclearmaterials. For shipments of materials the recipient shall be contacted bytelephone at the time of shipment to confirm that the package is being sent. Thename of the person spoken to and the date of the call shall be recorded. It is therecipient's responsibility to contact the other party to confirm receipt anddocument the call. If a call is not received at the expected time, the RadiationSafety Officer or his designee will contact the recipient'to confirm receipt. Lostsources shall be reported to the NRC within 1 hour of discovery.

Nationally Tracked Source Procedures

At the time this document was written Rapiscan did not have any NationallyTracked Sources in its possession.

In the event that one or more are acquired they will be registered in the NationSource Tracking System (NSTS). See the table below for a listing of whichsources constitute nationally tracked sources (include page 2 of Attachment F).Sources which are sent to another licensee or for disposal are required to bereported. Sources required to be reported in the NSTS will be inventoried on anannual basis by January 3 1 st of each year, and reconciled with the onlineinventory. Use at temporary job sites or under reciprocity is not required to bereported as it is still considered to be in use by the licensee.

RAPISCAN LABORATORIES, INC. SEALED RADIOACTIVE SOURCEACCOUNTABILITY CONTROL GUIDE

PAGE 11

NaUonalf Tracked Sources

Radioactive Category I Categay 1 Category I Catgory 2Mamerial (Tka) (0) (Tlq) (Ci)

Aenfirf-227 20 540 0.2 SA

Afeurtdum-241 60 1600 0.6 16

Americm-241/'3e 60 1,600 0.6 16

Cai fo•iiMv-2"2 20 S40 0.2 A.4

Coba•-,60 30 81.0 0.3 8.1

Cuattun-244 5s L,400 0.5 14

Cesium- 137 100 2,700 L 27

GadoarLjum-.53 A000 27,000 10 270

uidiwn- 192 8o 2,200 0.8 22

P•laIut m-2M 60 LI00 0.6 16

Pftouium-239fb 60 LIGN 0.6 L6

Pokmipum-210 60 L,600 0.6 L6

Proamiliiu-147 40,000 [,100,000 400 11,000

Radbhn-22. 40 L,100 0.4 Ll

Sehiem-S; 20w S,400 2 54

shohukm-90 L,000 27,000 14 270

Thowm-228 20 540 0.2 S4

1Thorim-229 20 S40. 0.2 SA

Tlulkun-170 20,000 540,000 200 5,400

YLterbium-L69 300 8,100 3 8l

If U&S NRIC



Emergency Notifications

The following Emergency Notification Phone Numbers shall accompany all

transportation documents:

Corporate Radiation Safety Officer / Rapiscan Systems, Inc.

Mr. Michael GrayOffice: (310)349-2467Mobile: (310) 97-9328After Hours: (951) 784-4743Email: [email protected]

Rapiscan Laboratories Facility Radiation Safety Officer

Mr. Mershad A. Shahabidin

Office: (310) 349-2494, after hours: (424) 236-0314

Rapiscan Laboratories Assistant Radiation Safety Officer

Mr. Ed Franco

Office: (408) 961-9743; after hours: (650) 346-9202

State Regulatory Authority:

California Department of Health ServicesRadiologic Health Branch, MS 7610P.O. Box 997414Sacramento, CA 95899-7414Phone (916) 327-5106

Local Emergency Phone Number:

Police/fire/medical emergency: 911


PAGE 13

APPENDIX A

CHANGE OF SOURCE STATUS FORM

.SOURCE DESCRIPTIONSource Holder Model Number:Source Holder Serial Number:Source Holder Manufacturer:Source Capsule Model Number:Source Capsule Serial Number:Radionuclide:Original Activity:Physical Form:Radiation Reading at Reference Distance:

Radiation Type:Date Determined:

SOURCE STATUSDate of Receipt:Reason for Status Change:

Date of Update:

Lost Returned to storage Storage awaiting disposal

Disposed Returned to manufacturer. Decayed below accountabilitythreshold

Active in-use Source integrity failed New source- initial entry

General Transfer of possession Transferred to different locationmaintenance II

SHIPPING RECORDS (if shipped to new owner)Shipping P.O. Number:Shipping Organization:Carrier:Individual / Firm Receiving Source:Receiver's License Number:

INITIAL RECEIPT LEAK TESTDate of Test:Test sample taken by:Test sample analyzed by:

Test Results: El Passed El Failed (if failed, note actions taken below)

VERIFICATION OF RSO REVIEW:

Signature of RSO: Date:



APPENDIX B

LEAK TEST AND INVENTORY FORM

SOURCE DESCRIPTIONSource Holder Model Number:Source Holder Serial Number:Source Holder Manufacturer:Source Capsule Model Number:Source Capsule Serial Number:'Radionuclide: Radiation Type:

Original Activity: Calibration Date:

Radiation Reading at Reference Distance: (TI at time of receipt

SOURCE BI-ANNUAL LEAK TESTSample taken by:Sample analyzed by:Date sample taken:

Leak Test Results: El Passed El Failed (If "Failed", note actions taken below)Notes (Indicate if test was for other than bi-annual requirement)

SOURCE BI-ANNUAL INVENTORY VERIFICATIONDate of inventory verification:Location of source at time of inventory:'

SOURCE MONITORING / SURVEY RESULTSExposure Rate survey at point of contact over collimator port)Date of survey:Instrumentation Used:Exposure Rate:Survey Performed By:

VERIFICATION OF REVIEW BY RSO

Signature of RSO: Date-


PAGE 15

USE LOG

Enter all applicable data for the sealed source indicated below.

• Sod~rce: Devic.e ManufacturerSource Device Model NumberSource Device Serial Number,Radioisotope:.. .,ActivityCal ib6ation.. Date

[Date6f Use.:'.".. _____.__"__.__.__..__..__""

Nam• of Auth•rized Use.R esponsiblefor the Sealed Source Activities for Use .I

PERSONNEL: List each person present inside the Restricted Area during Use.Name '.... Film Finger Radiatioan

(Please Print) Badge TLD. TrainingY/N Y/N Y/NY/N Y/N Y/NY/N Y/N Y/NY/N Y/N Y/NY/N Y/N Y/NY/N Y/N Y/NY/N Y/N Y/N

ALARA InformationPurpose of Usle(imging tests, detectortjests, etc)Start Time :•f UseEndTir.•.e~o6fJ4se <7.•......, ....

Number of Activations .Average tim mof "beam" productionE'tirated total time of beam..production...•adhtiaon .WorPei.rmit4(WP" ).. #

Safety Systems / Interlocks (If Applicable)•Strobe Lights Operational: Y / N / NA If "NO": contact RSO before

operating.Source "ON" Warni..ng ... Operational: Y / N / NA If "NO", contact RSO before

Lights .operating

.Audible Warning Systems: Operational: Y / N / NA If "NO", contact RSO beforeoperating

:HRA or.VHRA Controls Operational: Y / N / NA If "NO", explain on reverse side

Established ."".._



NOTES

Rapiscan Laboratories Emergency Response Plan

RapiscanT.systemsAn OSI Systems Company

Emergency Response Plan for EventsInvolving Radioactive Material Sealed

Sources and Radiation Emitting Devices

January 13, 2011


-I-


Introduction

Rapiscan Laboratories, Inc. is primarily a Research and Development facility licensed by theState of California, Radiological Health Branch, to receive, transport, possess, use, and storeradioactive sealed sources consisting of multiple radioisotopes with a wide range ofradioactivity concentrations.

A large majority of these radioactive sealed sources are encapsulated in a hard resin or acrylicmaterial in a solid physical form (check sources) or electroplated plates or foils. Inventories ofliquid radioactive sources represent a small fraction of the radioactive source inventorymaintained and used at the Rapiscan Laboratories facilities.

Unless a radioactive sealed source is in use, all radioactive sealed sources are stored in asingle radioactive materials storage area room which is clearly posted and locked at all timeswith limited and controlled access only by the facility Radiation Safety Officer (RSO), AssistantRadiation Safety Officer (ARSO) and any licensed Authorized User.

In addition to the radioactive sealed source inventory, Rapiscan Laboratories operates severaldifferent types of radiation emitting devices which include non-human-use baggage andcabinet x-ray inspection systems, full body scanning systems (backscatter x ray), CT baggagescanners and linear accelerators used for testing.

Purpose

The purpose of this Emergency Response Plan is to identify the roles and responsibilities ofkey facility personnel during a radiological emergency and to describe the initial responses ofthese key individuals in the event of an incident involving radioactive material sealed sourcesor radiation emitting devices.

Rapiscan Laboratories shall contact and communicate routinely with local police and firedepartments, provide for routine inspections and facility tours and discuss the potentialradiological hazards that exist at Rapiscan Laboratories facilities and discuss methods toreduce and/or eliminate potential hazards.

The Rapiscan Laboratories RSO should provide, as necessary, radiological training andinformation to local police and fire departments so they are fully aware of the properprocedures, personnel protective equipment to be used and the necessary controls which shallbe implemented to release individuals and equipment from the affected area(s).

-2-


Radioactive Liquid Spills

1. Immediately notify all persons in the area of the spill.

2. Stop the spill immediately, if possible, and confine the spill immediately by absorbingstanding or pooled liquids with paper towel or other absorbent material. Do not smear orwipe the area, attempt to absorb the liquids into the absorbent material withoutincreasing the area of the spill.

3. Isolate the immediate area and notify the facility RSO and/or ARSO.

4. Evacuate all unnecessary personnel as well as any potentially contaminated personnel.Personnel decontamination shall be initiated as quickly as possible to minimizeexposures.

5. Permit only the minimum number of persons in the area necessary to deal with the spill.

6. Use personal protective equipment (lab coats, gloves, shoe coverings, eyeprotection) as dictated by the RSO, based on the circumstances.

7. Immediately discard all contaminated absorbent material into a labeled radioactivewaste container.

8. After the spill is removed, begin to survey the affected and adjacent areas anddecontaminate as necessary.

9. The facility RSO shall initiate a Radiological Occurrence Report (ROR) to determine thecause and actions required to prevent reoccurrence.

Damaged or Failed Radioactive Sealed Sources

Rapiscan Laboratories has a number of radioactive sealed sources. Generally, these sourcesare encapsulated in a hard resin or acrylic material and are not likely to leak under conditionsof normal usage. However, due to accidents or abuse, the encasement of these sources maybe damaged or break apart. In such an event, a leak resulting in radioactive contaminationcould occur.

Typically these sources are small and have very low activities but, because of the type ofradioisotopes encased in the material, a leak resulting in contamination of personnel couldpresent a serious problem and a challenge to decontamination efforts. In some cases,regulatory guidelines require the appropriate state agency be contacted and the broken sealedsource reported.

-3-


Generally, the situation will be manageable and contamination can be contained to a verylocalized area in the vicinity of the source if Authorized and Designated Users adhere to thefollowing guidelines.

In the event of a broken or leaking sealed source:

1. Do not move the source! Do not attempt to "put the source back together". Do nothandle the source to inspect it. If you are holding the source at the time it breaks gentlylie the source down.

2. Notify any workers in the area of the damaged source and instruct them to stay awayfrom the area where the source is located.

3. Notify the RSO immediately.

4. Stay near the source location and remain available to the RSO.

5. The RSO will monitor for contamination of personnel. If contamination is found,appropriate decontamination procedures will be initiated.

6. After monitoring personnel, The RSO will initiate actions to recover and contain allfragments of the source and then proceed with monitoring the area where the sourcebroke for contamination.

7. Decontamination action will be initiated as needed.


Damaged or Failed Leak Tested Radioactive Plated Sources

Rapiscan Laboratories has a few sources defined as "plated" sources. These sources are notsealed and the radioactive material is not enclosed as it is with sealed sources. Typically,plated sources are small metallic disks or foils with the radioactive material electrochemically"plated" onto one side of the disk or foil. This deposition of radioactive material is not sealedand is easily removed due to inappropriate handling, misuse, or improper storage of thesource.

Preventing Contamination from "Plated" Sources

1. Always handle the source with tongs and always wear gloves.

2. Always hold the source by the "edges" avoiding contact with the plated surface area.

3. Do not drop the source or allow the plated surface to come into contact with othermaterial or surfaces.

-4-


4. Plated sources shall be segregated from other sources and materials within theradioactive material storage area. Each plated source should have a dedicatedcontainer that is properly labeled.

5. Do not allow plated sources to "migrate" from one storage container to another. Crosscontamination of the plated sources is highly likely which may compromise the integrityof the source for research purposes.

6. If a plated source is dropped or if an accident occurs this may dislodge the radioactivematerial from the surface of the plated disk; call the Radiation Safety Officerimmediately.

7. Do not attempt to handle or inspect dropped or damaged plated sources. Wait forassistance from the Radiation Safety Officer.

8. The Radiation Safety Officer will monitor personnel for contamination and then proceedto monitor the incident area.

9. Decontamination actions will be initiated as needed by the Radiation Safety Officer.


Emergency Response for a Fire Involving Radioactive Sealed Sources

1. The primary designated radioactive material storage room shall be equipped with a fireextinguisher in the event of a small fire within.

2. This storage area shall be maintained and organized using shelves, containers,shielded containers (pigs) and other suitable containers that significantly reduce thepotential for fire. Combustible materials within this area shall be minimized andcontainerized. No flammable liquids shall be stored in the room.

3. In the event of a fire, follow proper procedures of notifying facility, security and local firedepartment personnel.

4. If the fire is small and can be extinguished quickly and safely, extinguish the fire andthen evacuate the area immediately and contact the Radiation Safety Officerimmediately. Follow procedures above for clean up and decontamination of the area ifrequired.

5. If the fire can not be extinguished quickly and safely, notify all personnel in theimmediate area to evacuate and sound the fire alarm.

6. All personnel shall follow normal evacuation procedures and begin to account for allpersonnel.

-5-


7. Upon arrival of the fire department, the Radiation Safety Office staff shall meet the firstresponders and inform them of the location and potential loose surface contaminationand airborne radioactivity hazards. Radiation hazards from Rapiscan Laboratoriessealed sources is minimal as most sealed sources are well below 100 mR/hr on contact.

8. Fire fighters shall be instructed to wear their Self Contained Breathing Apparatus at alltimes inside the Restricted Area.

9. The Radiation Safety Office staff shall set up a contamination control point outside theeffected area to allow fire fighters to properly exit the area, be monitored forcontamination and to collect potentially contaminated materials and equipment.

10. For a major fire, once extinguished, there will be large amounts of liquids and debris toremove. The priority shall be to decontaminate and/or remove all personnel from theaccident scene, contain liquids, secure unfiltered ventilation systems and then step backfrom the scene to properly plan and prepare for clean up efforts.

11. The Radiation Safety Officer, or designee, shall be responsible for immediately notifyingthe State of California Radiological Health Branch.

12. The facility RSO shall initiate a Radiological Occurrence Report (ROR) to determine thecause and actions required to prevent reoccurrence and submit this report to the Stateof California Radiological Health Branch within 24 hours.

Emergency Response for Sealed Source Irradiators

Rapiscan Laboratories operates, tests and evaluates equipment designed to generate thincollimated beams or fields of radiation onto very small areas. These sealed source systemsare used primarily for cargo inspections at ports and borders.

Sealed Source Irradiator Devices

Rapiscan Laboratories sealed source irradiators devices which generate radiation in a passivemanner in shielded rooms or cells. High Radiation Area controls such as warning lights, CCTV,safety interlocks, audible alarms, locked interlocked gates and administrative controls areimplemented to control entry into these areas during operations and testing. Unauthorizedentry during testing will activate the safety interlocks

The actual source capsule of radioactive material (e.g., 1 Curie CO-60 or 1 or 2 Curie Cs-137)is located inside the shielded container housing. These systems are equipped with"Emergency Stop" buttons which immediately remove the power to the system which, in part,are located "outside" the High Radiation Area. In the event of a malfunction or loss of electricalpower, the source actuator "fails safe" placing the source capsule in its normal shieldedposition.

-6-


Accelerator (Machine) Radiation-Emitting Devices

Machine radiation-emitting devices, such as linear accelerators, are equipped with numeroussafety features which allow the operator outside the High Radiation Area to secure radiationemission and power to the system immediately.

Rapiscan Laboratories accelerator operations are also fixed-based devices which generateradiation in a passive manner in shielded rooms or cells. High Radiation Area controls such aswarning lights, CCTV, safety interlocks, audible alarms, locked interlocked gates andadministrative controls are implemented to control entry into these areas during operations andtesting. Unauthorized entry during testing will activate the safety interlocks when entry isattempted during operations.

These systems are equipped with Emergency Stop buttons which immediately remove thepower to the system which, in part, are located "outside" the High Radiation Area. In the eventof a malfunction or loss of electrical power, the accelerator "fails safe" preventing thegeneration of radiation.

Over Exposures to Ionizing Radiation

While extremely unlikely, in the event an individual receives a potential over exposure from anunplanned/unauthorized entry from either a sealed source irradiator or from an accelerator, anExposure Investigation Report and Radiological Occurrence Report shall be initiatedimmediately.

Precise exposure times and resultant immediate effects and delayed effects will depend uponwhich source an individual had been exposed, duration of exposure and distance from thesource. Any dose determination will have to be "reconstructed" via time and activity analysis.'

Any and all individuals potentially or actually receiving an over exposure shall be transported tothe nearest hospital oncology department for observation and evaluation. Individual dosimetrydevices shall be collected and sent off site for emergency processing.

The information outlined in Attachment 1, Emergency Procedures below shall be providedfor each facility and posted in several conspicuous areas where employees have ready accessto this emergency contact information.

-7-


Attachment 1EMERGENCY PROCEDURES

Name of Facility:

Radiation Safety Officer:

Phone Number: After Hours:

Assistant Radiation Safety Officer:

Phone Number: After Hours:

Police Department: Phone Number:

Fire Department: Phone Number:

Accidental exposure: Accidental exposure is considered to be unintentional x-ray exposure to any part ofthe human body. This can occur if safety and operational procedures are not followed or if the equipment is notproperly installed or serviced.

Measures to be taken in the event of accidental or suspected overexposure to radiation:

1. The Radiation Emitting Device Operator shall:

a. Turn off the machine and disconnect the power;b. Record names of all personnel that might have been exposed;c. Contact the Radiation Safety Office immediately and report the incident. The RSO or Assistant RSO shall

contact the Rapiscan Corporate Radiation Safety Officer immediately.d. The Radiation Safety Office shall ensure effected staff exposed is immediately dispatched to the

emergency room of the hospital indicated below to be seen by the radiation oncologist on duty.

Name of Hospital or Health Care Facility:

Hospital Emergency Contact Telephone Numbers:

It is the responsibility of the Radiation Safety Office staff member(s) accompanying the exposure victim(s) to thehospital or health care facility to advise the attendant medical staff that accidental exposure to ionizing radiationhas occurred. The hospital/health care facility emergency staff should then undertake the protocol for postexposure to ionizing radiation.

2. The Rapiscan Laboratories Radiation Safety Officer shall immediately initiate an accident investigation and filea preliminary report with the State of California and other regulatory authorities having jurisdiction of the facility inwhich the source of radiation is located as soon as sufficient details about the accident become available.

Post this document in several conspicuous areas where employees will have readyaccess to emergency contact phone numbers.

8-

Rapi4scanT.systemsAn OSI Systems Company

RADIATION SAFETYMANUAL

PITTSBURG, CA SITE

4~l07/28/10 Page 1 of 28

Rapiscan Radiation Safety Manual Page 2 of 28

Contents1.0 PURPOSE AND SCOPE ........................................................................................... 32.0 CONTACT INFO ..................................................................................................... 33 .0 D E F IN IT IO N S ................................................................................................................. 34.0 DOCUM ENTATION/ REFERENCE MATERIALS ..................................................... 55.0 RADIATION SAFETY ORGANIZATION ....................................................................... 66.0 RADIATION SAFETY OFFICER & AUTHORIZED USERS ..................................... 67.0 RESPONSIBILITIES ................................................................................................. 68.0 EQUIPM ENT ................................................................................................................. 8

8.1 Survey Meters ..................................................................................................... 88 .2 T o o ls ......................................................................................................................... 9

9.0 PROCEDURES ...................................................................................................... 99.1 Reviews and audits ............................................................................................... 99 .2 D o s e ........................................................................................................................ 1 0

9 .2 .1 L im its ................................................................................................................ 1 09 .2 .2 E x p o s u re .......................................................................................................... 1 19 .2 .3 D o s im e try ......................................................................................................... 1 1

9 .3 P o s tin g s .................................................................................................................. 1 29.3.1 Radiation Areas ........................................................................................... 129.3.2 W ork and Public Areas ................................................................................. 13

9 .4 S u rv e y s ................................................................................................................... 1 49 .5 U s e L o g s ................................................................................................................. 1 59.6 Reports and Notifications .................................................................................... 16

9.6.1 Employee notifications ................................................................................ 169.6.2 Agency Notifications ..................................................................................... 169.6.3 Amendments to Registrations and Reports ................................................... 18

9 .7 T ra in in g ................................................................................................................... 1 89 .7 .1 O p e ra to rs ......................................................................................................... 1 89 .7 .2 S e rv ic e rs .......................................................................................................... 1 99 .7 .3 V is ito rs ............................................................................................................. 2 0

9 .8 R e c o rd s ................................................................................................................... 2 09 .9 S e a le d S o u rce s ....................................................................................................... 2 09.11 Shipping/Receiving/Transporting Radioactive Materials ...................................... 219 .12 A re a C o n tro ls .......................................................................................................... 2 29.13 Changes to the Linac development Areas ........................................................... 239 .14 N e w D e v ice s ........................................................................................................... 2 39.15 Special Projects .................................................................................................. 239.16 Servicing of Devices ........................................................................................... 249 .1 7 A c c id e n ts ................................................................................................................. 2 49.18 Radioactive materials ........................................................................................... 259.19 Radioactive W aste ............................................................................................... 25

1 0 .0 S E C U R IT Y ................................................................................................................... 2 611.0 W ORK PERMITS ................................................................................................... 26

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1.0 PURPOSE AND SCOPE

The purpose of this document is to outline the methods used to control exposure to radiationproduced at Rapiscan's Pittsburg, CA facility by linac and special nuclear material (SNM).

This document applies to the facility and employees who will be authorized to perform workat the site.

This program includes the radiation protection methods for the use of a linear accelerator onloan from Los Alamos National Lab, and SNM including Pu-239 and HEU. Since the NRCdoes have jurisdiction over radiation machines (see definition below), OSHA and Cal RHBwill have jurisdiction. The regulations governing the operation of a radiation machine are 29CFR1 910.1096 for Federal OSHA, and Title 17, Division 1, Chapter 5, Subchapter 4 for CalRHB.

The use, possession, licensing, transport and security of the SNM is governed by NRC andCalifornia RHB regulations. The citations for these regulations regarding each segment ofthis program will be referenced within the applicable section.

All employees and visitors must follow the procedures outlined in this manual and theassociated protocols and procedures. There is no exception to any rule without prior writtenpermission from the site or corporate RSO.

2.0 CONTACT INFO

2.1.1 The phone number info for the RHB Headquarters is: (916) 327-5106.

2.1.2 The phone number for the Richmond Regional Office of the RHB (Region 4) is:

(510) 620-3416.

3.0 DEFINITIONS

3.1 Activated products - Activated products are radioactive materials produced by the

interaction of radiation produced by the linac and target materials; these are normally

short lived, but care must be taken when approaching potentially active

areas/materials.

3.2 ALARA - as low as reasonably achievable; refers to a practice to reduce occupational

doses to a level that is "as low as reasonably achievable"; Appendix A discusses in

detail, the ALARA principles to be used at the site.

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3.3 Authorized User - an individual who is authorized by license or registration condition

to use a source of radiation and/or handle radioactive materials.

3.4 Cal OSHA - California Division of Occupational Safety and Health.

3.5 Device - means any machine capable of producing radiation or containing radioactive

material.

3.6 Dose - the amount of radiation received per unit of time, usually stated in mrem/hr

(US) or pSv/hr (metric); this normally applies to persons.

3.7 Exposure - the total dose received during an event or length of time or the ionization

of air produced by a radiation machine.

3.8 High radiation area - an area in which the dose rate is greater than 100 mrem/hr at 30

cm from the source of the radiation.

3.9 LDE - Lens Dose Equivalent; the dose equivalent to the eye.

3.10 Linac - linear accelerator.

3.11 LINAC Use Log - a written log in which each and every use of the linac must be

registered; the details will be discussed in a later section.

3.12 Member of (the) Public - refers to anyone that does not receive occupational dose or

who is not a radiation worker or authorized user.

3.13 NCRP - National Council on Radiation Protection and Measurements.

3.14 NRC - Nuclear Regulatory Commission.

3.15 OSHA - Occupational Safety and Health Administration.

3.16 Radiation area - an area in which the dose rate is greater than 5 mrem/hr at 30 cm

from the source of the radiation.

3.17 Radiation machine - any machine designed to generate ionizing radiation as its

primary function; these do not contain radioactive material other than calibration

sources.

07/28/10NA


3.18 Radiation worker- a person who receives or may receive an occupational dose.

3.19 RHB - Radiologic Health Branch of the Department of Public Health in the State of

California.

3.20 RSO - Radiation safety officer; the person directly responsible for maintaining the

safety of employees and visitors in regards to the dangers of ionizing radiation present

at the site; (See RSO section for a list of the additional responsibilities for the RSO).

3.21 SDE - Shallow Dose Equivalent; dose equivalent to the skin or extremities.

3.22 SNM Use Log - a written log in which each and every use of the SNM's used on site

must be registered; the details will be discussed in a later section.

3.23 TEDE - Total Effective Dose Equivalent; total dose equivalent to the body.

3.24 Very high radiation area - an area in which the dose rate is greater than 500 rad/hr at

1 m from the source of the radiation.

4.0 DOCUMENTATION/ REFERENCE MATERIALS

4.1 California Code or Regulations Title 17 Division 1 Chapter 5 Subchapter 4.

4.2 Radiation Machine Registration/Permit.

4.3 US NRC Regulatory Guide 6.9.

4.4 US NRC Regulations 10 CFR Parts 1-50.

4.5 US NRC Regulatory document NUREG-1556 V17.

4.6 OSHA Regulation 29 CFR 1910.1096.

4.7 NCRP 144 Radiation Protection for Particle Accelerator Facilities.

4.8 Linac Operating Procedures.

4.9 Shielding Plan for Pittsburg, CA site.

4.10 California Radiologic Health Branch, Notice to Employees, Form RHB 2364.

07/28/10hA.


4.11 Rapiscan's Cargo Screening Protocols.

5.0 RADIATION SAFETY ORGANIZATION

5.1 The Corporate RSO for Rapiscan Systems is Mike Gray. He is a dotted line report to

Ajay Mehra, President of Rapiscan Systems. Mike is responsible for the radiation

safety of all Rapiscan sites and oversees the RSOs for each site.

5.2 The following chart is an organizational chart for the RSOs of Rapiscan Systems

SAjay Mehra

President

......................... ............

Mike GrayCorporate RSO

I ] Mer'had sh"h"bidin.Ed Franc.. RSO - Sunnyvale & .Stev Nord.

Safety Support Pittsburg, CA RSO -

6.0 RADIATION SAFETY OFFICER & AUTHORIZED USERS

6.1 Radiation safety officer:

6.1.1 The Radiation Safety Officer for Rapiscan's Pittsburg, CA site is Mr. Mershad A.

Shahabidin.

6.1.2 To contact the RSO: work (310) 349-2494; after hours (424) 236-0314.

6.2 Authorized operators/servicers:

6.2.1 Timothy Shaw

6.2.2 Cathie Condron

6.2.3 Craig Brown

6.2.4 Mashal Elsalim

6.2.5 Michael King

7.0 RESPONSIBILITIES

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7.1 Responsibilities of the RSO

7.1.1.1 It is the responsibility of the site RSO to ensure that work is carried out in

accordance with the requirements of state and Federal regulations and for

taking all reasonable steps to ensure that these rules are followed at all times.

7.1.1.2 To prohibit any non-compliant activity associated with Rapiscan, its employees,

and contractors.

7.1.1.3 To ensure that survey meters are properly calibrated and maintained.

7.1.1.4 To ensure that personnel follow proper procedures when servicing or operating

the linac.

7.1.1.5 To ensure that engineering controls, such as interlocks, alarms, lights, etc., are

kept in good working order.

7.1.1.6 To ensure that radioactive materials are well accounted for, and that possession

limits stated on Rapiscan's radioactive materials license are not exceeded.

7.1.1.7 To make amendments to licenses, registrations and permits with the State of

California, as necessary.

7.1.1.8 To ensure that exposure levels are kept as low as reasonably achievable.

7.1.1.9 To assure that all authorized employees are properly trained in the operation

and service of linac devices.

7.1.1.10 To ensure that unauthorized removal of the linac and SNM is prohibited.

7.1.1.11 To ensure that personnel are provided with personal monitoring devices, as

necessary; and that the doses received by individuals are reported to them,

quarterly, annually, and upon receiving a dose in excess of the limits specified in

the ALARA program attached to this document as Appendix A.

7.1.1.12 To ensure that at least monthly audits for compliance are conducted, and to

maintain the results of these audits.

07/28/10NhRSIratet- ~jfSft - ,1


7.1.1.13 To act as a liaison between Rapiscan and consultants and/or regulatory

authorities.

7.1.2 Responsibilities of Management

7.1.2.1 To assure that resources are made available to the RSO and employees which

provide or ensure protection against the effects of radiation.

7.1.2.2 To enforce the procedures and policies that outline appropriate behavior and

which are established by this program and others.

7.1.3 Responsibilities of authorized users

7.1.3.1 It is the responsibility of authorized users to become familiar with and abide by

the rules set forth in this document and the regulations of the California RHB.

7.1.3.2 To follow operation, maintenance, and repair procedures when using or

servicing the device.

7.1.3.3 To follow proper safety procedures during the startup, operation, and shutdown

of the device.

7.1.3.4 To be cognizant of the dangers of radiation and take extreme care in assuring

that they nor any other person are exposed to undue radiation.

7.1.4 Responsibilities of Employees

7.1.4.1 No unauthorized employees are expected to be at this site.

7.1.5 Responsibilities of Visitors

7.1.5.1 It is the responsibility of visitors to the Pittsburg site, to abide by the rules set

forth in this document, the regulations of the California RHB, and the direction of

authorized users and the site RSO.

8.0 EQUIPMENT

8.1 Survey Meters

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8.1.1 Enough survey meters must procured to assure that all types of radiation

produced on site will be measured, including neutron.

8.1.2 At least two survey meters must be available and one kept on the premises at all

times. One meter is a primary meter, and the other, a backup.

8.1.3 All survey meters must be calibrated annually. {Note: calibrations must be

staggered so that one survey meter is available at all times.}

8.1.4 Survey meters must be kept in good repair and working order. Prior to using a

survey meter, check the battery condition, any cables for cracks or breaks, and

check the function of the meter with a check source.

8.1.5 Any damage or malfunctions to any meter must be reported to the RSO as soon

as possible.

8.2 Tools

8.2.1 All tools used for servicing the linac shall be removed from the linac area before

operating the device. This is due to the possibility of activation. If tools are left in

proximity to the linac during beam-on, the tools must be surveyed prior to use.

Tools which become activated must not be used unless and until the radiation

level returns to background.

8.2.2 Tools used for handling radioactive materials or their containers must be marked

as such and not used for any other purposes. This is due to the fact that

contamination may be present on the tools.

8.3 Shielding

8.3.1 Shielding has been placed in the exact locations where it is needed. DO NOT

move or modify the shielding in any way without prior written consent from the

site RSO.

9.0 PROCEDURES

9.1 Reviews and audits

07/28/10 NhRS1,m .dt, ayý W.IC


9.1.1 In order to meet the intentions of radiation protection outlined in OSHA's Ionizing

Radiation standard 29 CFR 1910.1096, this program must be reviewed on at

least an annual basis, as applicable. {Note: the OSHA standard incorporates

the NRC's regulation of radiation protection: 10 CFR 20.1101.}

9.1.2 An audit of the implemented program must be performed at least annually, or as

needed. This must include, inspection of the facility, employee interviews, and a

review of programs, procedures and policies related to the radiation safety

program. It is highly recommended that monthly audits be performed as the

project is only expected to last several months.

9.1.3 Rapiscan's facility may be inspected for compliance with applicable regulations

from the California RHB or other authorities having jurisdiction at the agencies'

discretion. If an inspector from the California RHB does visit the site,

accommodations must be made for the inspector if at all feasible.

9.1.4 Rapiscan has certain rights in regards to these inspections, but full cooperation is

expected by the RHB or other agency, unless the inspection creates an undue

burden to the company.

9.2 Dose

9.2.1 Limits

9.2.1.1 ALARA: Rapiscan has embraced the concept of ALARA, in which radiation

levels are kept "As Low As Reasonably Achievable". This is achieved through

the implementation of this program, the ALARA program included in Appendix

A, and the periodic audits and reviews outlined in the Reviews and Audits

Section of this program.

9.2.1.2 "Members of the public" are limited to doses of 100 mrem/yr or 2 mrem/hr. No

member of public shall receive more than this dose. If this dose is exceeded, an

Exposure Investigation Form must be completed and submitted to the RSO.

07/28/10 NhR.


9.2.1.3 Although regulations specify that occupationally exposed employees are limited

to 5 rem/yr, the ALARA goal is to limit employees to 10% or 500 mrem per year.

The trend of industry and recommendation of the ICRP is to adopt a policy of

500 mrem/yr and meet the spirit of the ALARA principle. Rapiscan has adopted

this policy.

9.2.1.4 Female employees have the right to declare their pregnancy to their employer.

This declaration is voluntary and must be in writing using the Pregnancy

Declaration Form in Appendix C of this document. Once a pregnancy has

ended, it must be undeclared in the same manner using the Un-declaring

Pregnancy Form in the same appendix.

9.2.1.5 Regulations require that declared pregnant workers do not receive more than

500 mrem/gestation period. It is highly recommended that women who are, may

become, or are planning to become pregnant, inform their supervisor or the

RSO as soon as reasonable. Provisions will be made for women to perform

their duties and receive less dose during their pregnancy.

9.2.1.6 Pregnant workers have the right to request to be reassigned to a different job

with no occupational dose until pregnancy is over. Rapiscan may or may not

honor this request if the dose rate is within the limits for pregnant workers.

9.2.2 Exposure

9.2.2.1 Employees and visitors, who are not authorized users, are prohibited from

entering areas in which radiation levels are above those stated above, unless

they have received proper training, been provided dosimetry, and are

accompanied by an authorized user.

9.2.2.2 Employees who are expected to receive some dose in excess of the limit for

''members of public," must be provided and wear the appropriate dosimetry.

9.2.3 Dosimetry

07/28/10aN1-


9.2.3.1 Dosimetry must be provided for all employees who work with or near the linac

device or who may otherwise receive an occupational dose of ionizing radiation

prior to starting work in the radiation area(s). Dosimetry is to be issued and

documented on the Dosimetry Issue Form in Appendix D.

9.2.3.2 Dosimetry must be appropriate for the radiation expected; in the case of the

linac and SNM, the radiation generated is the emission of neutrons, betas,

alphas, gamma rays, an X-rays.

9.2.3.3 Rapiscan has determined that TLD (thermo-luminescent dosimetry) are the

appropriate dosimeters for all radiation of concern at the facility and provide

these badges to authorized users. TLD's will be exchanged monthly.

9.2.3.4 Anyone who will enter the linac area must be issued an electronic dosimeter,

and the audible alarm shall be set tol100 mrem/hr. (See Work Permit Section)

9.2.3.5 It is forbidden for employees to share or exchange dosimeters, and employees

must not take dosimeters home. Dosimetry is to be preferentially stored on a

peg board at the site when not in use. The control dosimeter shall also be

stored on the same peg board.

9.2.3.6 Area dosimeters are also placed inside and outside of the facility to provide a

history of the dose rates in these areas. These dosimeters are also to be

exchanged monthly.

9.2.3.7 No visitor will be allowed access to the facility without clearance to enter the

facility from the RSO. While on site, a visitor must wear the dosimetry provided

to him/her.

9.3 Postings

9.3.1 Radiation Areas

07/28/10N1 Ra dM Sd


9.3.1.1 Posting: all areas must be posted with properly colored signs (yellow on

magenta) made from material appropriate for the environment in which they are

being posted. These signs must also be posted in a conspicuous area and

visible to persons outside the radiation area to assure employees are aware of

the hazards and dangers within the area.

9.3.1.2 Radioactive materials

9.3.1.2.1 All areas in which radioactive materials are stored, must be posted:

"CAUTION" or "DANGER, RADIOACTIVE MATERIALS."

9.3.1.3 Radiation area

9.3.1.3.1 All areas inside the fence (including the fence) surrounding the "Navy Building"

at the Pittsburg site shall be posted as a radiation area and include the words

"CAUTION, RADIATION AREA". This is to also include the water tower

adjacent to the building.

9.3.1.4 High radiation area

9.3.1.4.1 Areas with radiation levels at or above 100 mrem/hour at 30 cm from the

source of the radiation must be marked "CAUTION" or "DANGER, HIGH

RADIATION AREA". Because of the nature of the radiation from the linac and

SNM, it is highly recommended that "DANGER, HIGH RADIATION AREA" be

used.

9.3.1.5 Very high radiation area

9.3.1.5.1.1 Areas with radiation levels at or above 500 rad/hour must be posted

"GRAVE DANGER, VERY HIGH RADIATION AREA."

9.3.2 Work and Public Areas

9.3.2.1 The most recent revisions of Form RHB 2364, "Notice to Employees," must be

posted in a conspicuous location in the workplace, and is available on-line at

http://www.dhs.ca.aov/rhb.

07/28/10W9A.SI £ t-S~t, T


9.3.2.2 A copy of all registrations must be kept on site and made available to all

employees. These registrations must be posted conspicuously in the

workplace.

9.3.2.3 A copy of the operating and emergency procedures or information regarding

how they may be obtained or reviewed must be posted in a conspicuous place,

as well.

9.3.2.4 Any notice of violation received from the California Radiologic Health Branch

(RHB) must be posted for employees to view within 2 days after the receipt of

the notice and for 5 days or until the violation has been corrected, whichever is

later.

9.3.2.5 A- copy of the California RHB codes must be made available to all employees.

Posting the link to the online California codes and referencing in particular Title

17, Division 1, Chapter 5, Subchapter 4, in a conspicuous location as well as

how to contact the RSO in case of questions regarding these regulations, is

acceptable.

9.4 Surveys

9.4.1 All survey meters shall be checked for operability prior to use by verifying battery

power, cable connections, operation with a check source, and verifying the

calibration date. If the meter is shown to not perform properly from any of these

checks, remove the survey meter from service and inform the RSO as soon as

possible.

9.4.2 A survey form is included in Appendix E of this manual. This form is to be used

when performing weekly and other surveys. Completion of the form shall include

the name of the person performing the survey, date, model and serial number of

instrument used (including probe model and serial number), background level,

radiation level and units, and location referenced on a survey map.

07/28/10hA.R


9.4.3 Survey maps, which show the date and measurements throughout the linac/SNM

area, esp. in proximity to the SNM, shall be placed on the outside of the linac

area to ensure that employees are aware of the radiation level in the area. A

copy of each map and the corresponding survey form must be posted and also

kept by the RSO.

9.4.4 Surveys of the facility must be performed and documented at least weekly with

the linac in normal operating conditions. Do not prolong linac shots in order to

obtain survey readings.

9.4.5 Immediately after the wait period, surveys of the radiation level within the linac

room must be performed prior to approaching the linac or cargo container to

assure that no activation products have be generated after beam-on. These

surveys do not need to be documented.

9.5 Use Logs

9.5.1 A linac use log must be kept on site at all times. This log must be completed

each time the linac is used. That is to say, if an experiment is run on a particular

day and the linac is activated several times during that day, there will only need

to be one entry in the log, but the total "beam on" time must be listed.

9.5.1.1 Entries must be made in the log each working day for the duration of the linac

trails. If there is no "beam on" time in a day, it must be stated as such.

9.5.2 A separate log must be kept for the use of the SNM.

9.5.3 The linac and SNM use logs are included in Appendix F.

9.5.4 Use logs must contain the following:

9.5.4.1 Date of test.

9.5.4.2 Start and end times of the test.

9.5.4.3 Name of person conducting test.

07/28/10

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9.5.4.4 Names of those persons (employees, visitors, contractors, etc.) authorized to be

on site for the experiment.

9.5.4.5 Notes regarding the operation or malfunctions of the machine or incidents

regarding the radioactive material.

9.6 Reports and Notifications

9.6.1 Employee notifications

9.6.1.1 In the event that an employee is exposed to unexpected radiation or

contaminated with radioactive material, the employee must be notified

immediately or as soon as reasonably possible, using the Exposure

Investigation Form included in Appendix B.

9.6.1.2 In the event that an employee is required to wear a personal monitoring device,

the employee must be made aware of exposures reported through the

monitoring device contractor. These reports are to be provided to the users

upon receipt from the contractor.

9.6.1.3 If an employee wishes to receive a copy of his/her dose records, they may do so

using the Request for Dose Records Form in Appendix G.

9.6.2 Agency Notifications

9.6.2.1 In the event that an employee or member of the public is exposed to radiation or

radioactive material in excess of the regulatory limits specified in Cal RHB

regulations outlined below, the RSO must be notified immediately. The RSO will

then make the determination of reporting requirements to the California RHB

based upon state regulations.

9.6.2.1.1 If an individual receives a dose in excess of the following dose limits the

California RHB must be notified immediately by telephone:

" TEDE: 25 rem or more.

* LDE: 75 rem or more.

* SDE: to the skin or extremities; 250 rad or more.

07/28/10NhRSXa.U..1.1. O - ,1


" An intake during a period of 24 hours exceeding 5 times the

annual limit for a radionuclide.

" Names of persons involved in the incident must be filed on a

separate attachment.

9.6.2.1.2 If an individual receives a dose in excess of the following dose limits the

California RHB must be notified within 24 hours by telephone:

* TEDE exceeding 5 rem in 24 hours.

* LDE exceeding 15 rem in 24 hours.

* SDE to skin or extremities exceeding 50 rem in 24 hours.

* An intake during a period of 24 hours exceeding the annual limit

for a radionuclide.

• Names of persons involved in the incident must be filed on a

separate attachment.

9.6.2.2 If the linac or SNM is lost, stolen, or attempted to be stolen the RSO must be

notified immediately by telephone. The RSO must then notify the California

RHB immediately by telephone.

9.6.2.3 A follow up investigation shall be performed immediately, as well, and a written

report determining the cause and future preventative action must be submitted

to the California RHB within 30 days as per 10 CFR 20.2201 and must include:

9.6.2.3.1 Description of licensed material involved, including type, quantity, chemical and

physical form.

9.6.2.3.2 Description of circumstances under which the loss or theft occurred.

9.6.2.3.3 Statement of disposition or probable disposition involved.

9.6.2.3.4 Exposures of individuals to radiation, the circumstances under which they were

exposed, and possible TEDE to persons in unrestricted areas.

9.6.2.3.5 Names of persons involved in the incident must be filed on a separate

attachment.

07/28/10N1


9.6.2.3.6 Actions that will be taken to recover the licensed material.

9.6.2.3.7 Procedures or measures that have been or will be taken to prevent the

recurrence of the loss or theft.

9.6.2.3.8 An additional follow up written report must be filed with the California RHB

within 30 days of the initial written report, if further information is discovered.

9.6.2.4 In the event that the radioactive material is involved in a fire or other incident,

the RSO must be notified as soon as possible by phone. After the incident a

record of the event must be filed using the Radiological Occurrence Report in

Appendix H. The RSO must then notify the California RHB as stipulated in

section 30295 of the regulations.

9.6.2.5 The RSO must be notified of any other significant events that involve radiation

or radioactive material using the Radiological Occurrence Report, to determine

the course of action to be taken and to determine any notification requirements.

The site RSO will consult with the Corporate RSO to determine these

requirements.

9.6.3 Amendments to Registrations and Reports

9.6.3.1 The RSO must review all amendments to licenses and/or registrations.

9.6.3.2 An Executive Officer of Rapiscan must sign an amendment request for any

radioactive material license that may become necessary.

9.7 Training

9.7.1 Operators

9.7.1.1 Operators of the linac must be trained in the following prior to being authorized

to use linac devices:

07/28/10 hA.Ra W-5ýy Ic


9.7.1.1.1 Radiation safety - operators of the linac must be trained in radiation safety

including the inherent dangers of the device, and what methods are to be taken

to protect themselves and others from these dangers; further details of the

training materials are listed in Appendix I. Refresher training must be

performed annually. Trainees must acknowledge receiving the training on the

Radiation Safety Training Acknowledgement Form in Appendix I.

9.7.1.1.2 Proper operation of the linac - this training must be performed once, and

operators must be trained on any operational changes to the device.

9.7.1.1.3 Lockout/tagout awareness - as required by OSHA/Cal OSHA, in order to

prevent the inadvertent startup of a linac being serviced, service providers must

follow proper lockout/tagout procedures. Operators of the linac must be trained

in the awareness of lockout/tagout annually.

9.7.1.1.4 Shutdown - operators must be trained in the preferred method of shutdown of

the linac as well as emergency shutdown procedures.

9.7.1.1.5 Start-up - operators must be trained in the proper start up procedures of the

linac device, especially following an emergency shutdown.

9.7.2 Servicers

9.7.2.1 Servicers of the linac must be trained in the following:

9.7.2.1.1 Radiation safety - servicers of the linac must be trained in radiation safety

including the inherent dangers of the device, and what methods are to be taken

to protect themselves and others from these dangers; further details of the

training materials are listed in Appendix I. Refresher training must be

performed annually.

9.7.2.2 Proper operation of the linac. This training must be performed once, and

servicers must be trained on any operational changes to the device.

07/28/10NhR.


9.7.2.3 Lockout/tagout procedures - as required by OSHA/Cal OSHA, in order to

prevent the inadvertent startup of a linac being serviced, service providers must

follow proper lockout/tagout procedures. Servicers of the linac must be trained

in the complete lockout/tagout program annually.

9.7.3 Visitors

9.7.3.1 Visitors who will be working at the Pittsburg facility must receive the appropriate

training or have appropriate experience prior to entering the facility. Personnel

on site are responsible for refusing access to persons not properly trained or

authorized. The RSO is responsible for assuring the training is provided to

visitors.

9.8 Records

9.8.1 The RSO will keep the following records or designate someone to keep them:

9.8.1.1 Licensing and registration documentation.

9.8.1.2 Dosimetry and exposure reports.

9.8.1.3 Training records and syllabus of all radiation safety training sessions.

9.8.1.4 Surveys of areas and devices.

9.8.1.5 Radiation Safety Program reviews.

9.8.1.6 Audit findings (from internal or third party audits).

9.8.1.7 Inspection reports (from the RHB).

9.8.1.8 Other applicable records pertaining to the facility, devices, employees,

customers, etc.

9.9 Sealed Sources

9.9.1 Sealed sources must be handled properly with respect to their inherent hazards.

The use of tongs is recommended when handling the sources.

07/28/10

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9.9.2 Sealed sources must be accounted for and secured against unauthorized

removal when not in use.

9.9.3 Sealed sources must be leak tested at least every 6 months, or as specified on

the source's device registration (SSD).

9.9.4 If a leak test exceeds 0.005 pCi of removable contamination, the source must

removed from use and the CA RHB must be notified immediately.

9.9.5 Sources must be inventoried at least every 6 months.

9.9.6 Sources in storage need only to be leak tested every 10 years.

9.10 Chain of Custody

9.10.1 If sources are transferred, even temporarily, to or from another licensee or

government agency, a Chain of Custody Form (included in Appendix J) must be

completed prior to the transfer. These forms must be given to the RSO for

keeping until the project is complete and the sources have returned to the proper

licensee.

9.11 Shipping/Receiving/Transporting Radioactive Materials

9.11.1 Receipt of radioactive materials

9.11.1.1 Upon receipt of a source, the outer package must be immediately inspected for

visual damage. If the package is significantly damaged, the shipment must be

rejected. The package must be quarantined; the delivery driver must

immediately notify the shipping company and follow the guidance given by the

shipping company's compliance person. A record of this event must be made

by Rapiscan.

9.11.1.2 The package must then be surveyed to assure that the radiation levels around

the package are within regulatory limits. If the survey measures high radiation

levels, clear the area around the package and contact the RSO immediately.

07/28/10 Bps"V£RS


9.11.1.3 Once received, the package must be opened to verify that the source or source

container has not been damaged, and that the serial number of the source can

be verified against the shipping records and other pertinent documents. If the

source appears damaged, a wipe must be taken to assure that no removable

contamination is present on the container and other areas as necessary.

Results of these wipe tests and a record of the damage to the device must be

maintained.

9.11.2 Transport of radioactive materials

9.11.2.1 Transport of SNM must be performed in accordance with 10 CFR Parts 71 and

74.

9.11.3 Preparation and shipping of radioactive materials

9.11.3.1 Only persons who have received training on DOT's hazardous materials

regulations and the proper packaging of radioactive (special nuclear) materials

may prepare the shipment for transport. A wipe must be performed on the

container to assure that no removable contamination is present prior to

transporting the package. And a survey of the package must be performed to

assure that radiation levels do not exceed the limits, unless the package meets

the criteria of an "excepted package".

9.12 Area Controls

9.12.1 Warning lights must be mounted inside and outside of the linac operating areas,

and must be activated when the linac is energized.

9.12.2 Emergency shut-off switches must be located inside the linac operating areas

and shut down the primary power to the device.

9.12.3 Interlocks must be put in place on the doors to the linac room to assure that

persons in or around the device are not unduly exposed.

07/28/10

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9.12.4 Shielding sufficient to reduce the dose rates to acceptable levels shall be

installed on the inside of the linac area to prohibit exposure to persons on the

outside of the room. Shielding must be visually inspected and surveyed at least

weekly and after any incident which has potentially damaged the shielding to

ensure its integrity. Any abnormalities must be documented on a Radiological

Occurrence Form and forwarded to the RSO.

9.12.5 Surveys of the areas must be posted outside the room as stated in "Surveys".

9.12.6 Signs and other postings must be posted as outlined in "Postings".

9.12.7 Administrative procedures must be put into place to assure that only authorized

personnel are permitted in the radiation areas.

9.12.8 The linac and SNM must be secured against unauthorized removal. This is

discussed further in the Security Section.

9.12.9 Interlocks and safety devices shall be tested weekly to assure that they are

functioning correctly. Records of these functional checks must be kept on file at

least for the duration of the experiment. These tests are outlined in the "Safety

Protocols for Linac/SNM Use."

9.13 Changes to the Linac development Areas

9.13.1 No changes are to be made to the linac, shielding, containers, etc. without the

prior written approval of the site RSO.

9.14 New Devices

9.14.1 In the event a new device is installed at the facility, the RSO or a designee will

apply for the radiation machine registration in accordance with applicable

California RHB regulations.

9.14.2 The RSO may recommend changes to the device if he/she sees that the device

may be out of compliance.

9.15 Special Projects

07/28/10h wi. A." nl-1


9.15.1 New special projects involving radiation, radiation emitting devices, radioactive

material, or any combination thereof, must be brought to the attention of the RSO

for review. The RSO is responsible for overseeing the safety of the employees

working on the project.

9.15.2 Any employee involved in special projects involving radiation, radiation emitting

devices, radioactive sources, radioactive material, or any combination thereof,

must be trained in the safety practices of the project before proceeding with the

hands-on portion of the project.

9.16 Servicing of Devices

9.16.1 In the event that a device needs to be serviced, repaired, maintained, or

upgraded, the following steps must be followed:

9.16.1.1 Work must be performed by following the proper shutdown and lockout/tagout

procedures.

9.16.1.2 Assure that the device is prepared for operation, before energizing it.

9.16.1.3 Perform area surveys of the device at incremental power levels.

9.16.1.4 Fix any leaks immediately.

9.16.1.5 The device must not be put back into service until repaired.

9.17 Accidents

9.17.1 Fire

9.17.1.1 In case of a fire, the linac area must be evacuated immediately, except for those

employees who perform critical shutdown procedures.

9.17.1.2 Employees with critical shutdown procedures, must perform shut downs of the

linacs provided that they are not putting themselves at undue risk prior to exiting

the building.

9.17.1.3 The Pittsburg Fire Department (PFD) must be notified immediately.

07/28/10;;I.


9.17.1.4 The RSO must be notified immediately.

9.17.1.5 The RSO or other designee must inform the PFD of the exact location of the fire

and of the potential exposure risk(s), if at all possible.

9.17.1.6 After the event, the event must be documented on the Radiological Occurrence

Form and forwarded to the RSO. An investigation will be performed to

understand the cause of the event and determine whether any unanticipated

exposures occurred.

9.18 Radioactive materials

9.18.1 Tools and other objects which have been exposed to the radiation from the linac

may contain activated products, (radioactive materials). Caution must always be

used when handling materials in the linac room.

9.18.2 Using a survey meter to determine the amount of dose from a target will help to

assure that if and when they are safe to handle.

9.18.3 Any radioactive material must be stored in locations where they are secure from

unauthorized removal.

9.18.4 Activation products may be present when entering the linac room. Review the

"Safety Protocols for Linac/SNM Use" for proper wait times and handling

procedures.

9.19 Radioactive Waste

9.19.1 There is no Low Level Radioactive Waste (LLRW) expected to be generated.

9.19.2 Any radionuclides generated which have a half-life of longer than 120 days, may

be stored on site for decay.

9.19.3 If radionuclides are generated that have half-lives of longer than 120 days, they

will be collected as radioactive waste.

9.19.4 Radioactive waste must not be discarded with normal refuse. A licensed

radioactive waste contractor must be contacted to properly dispose of this waste.

07/28/10NhR-1- "1RWlWa y - ,1


10.0 SECURITY

10.1 The facility must have a continually monitored alarm system to assure that there are

no unauthorized entries. Keys and/or keypads must be installed on the entrances to

the building and the radioactive source room.

10.2 Keys and codes to the facility are not to be given to anyone other than authorized

users listed in this program.

10.3 Removal of sources from their storage containers or the building is prohibited unless

previously approved by the site RSO.

10.3.1 During normal operation, radioactive sources will be removed from the storage

area and returned to the source area at the end of daily operations. The sources

will only be removed from the storage area only by authorized users on Rapiscan

Laboratories' radioactive materials license and for the purpose of the project

listed in this program.

10.3.2 All radioactive sources must be logged out when removed from their storage

location. Logged information will include: in/out date and time, responsible user,

source type, and source ID. Sources in use will be the responsibility of the

authorized user until returned and logged in to the storage location.

10.3.3 Radioactive sources will be scanned with the inspection system, either alone, in

combination with other sources, or surrounded by standard cargo materials.

After scanning any sources, a hand-held survey meter will be used to check the

source for remnant activation prior to removal of the source from the inspection

zone or cargo container.

10.3.4 Radioactive sources will be stored in a locked location in the non-shielded

section of the building, far enough from the operator's room that the radiation

dose rate in the operator's room will not be affected by the sources. Pu and HEU

sources must not be in the building at the same time.

11.0 WORK PERMITS

07/28/10

29RS


11.1 All uses of the linac MUST be performed using the radiation work permit system.

11.2 This system is outlined in the Radiation Work Permit Work Instruction and its included

forms located in Appendix K.

07/28/10

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12.0 LIST OF APPENDICES

Appendix Description

A ALARA Program

B Exposure Investigation Form

C Pregnancy Declaration Form

C Pregnancy Un-declared Form

D Dosimetry Issue Form

E Survey Form

F LINAC Use Log

F SNM Use Log

G Request for Dose Records Form

H Radiological Occurrence Report

I Radiation Safety Training Acknowledgement Form

I Training Syllabus

J Chain of Custody Form

K Work Permit

07/28/10291Aml.a d

s ystemsAn OSI Systems Company

As Low as Reasonably Achievable(ALARA)

Occupational Exposure Control Program GuideFor

Pittsburg Facility1451 Loveride Rd.

Pittsburg, CA 94565

Michael GrayDirector of Radiation Safety and Compliance

Radiation Safety OfficerRapiscan Systems Inc.

Radiation Safety Office (310) 349-2311 Office24-Hour Emergency (310) 897-9328

RAPISCAN ALARA Occupational Exposure Control Program9210670 Control Guide

Table of ContentsPurpose and A pplicability ............................................................................................ -]

Jurisdiction ................................................................................................................... 1-1Policy and M anagem ent Com m itm ent ......................................................................... 1-1

D efinitions ........................................................................................................................ 2-1A LARA Program ............................................................................................................. 3-1

A ssum ptions and Dependencies .................................................................................. 3-1Training ........................................................................................................................ 3-2D esign Criteria ............................................................................................................. 3-2D esign Requirem ents ................................................................................................... 3-2Design Review s ................................................................. 3-3

Integrated Safety M anagem ent process ................................................................... 3-3RSO Responsibilities ............................................................................................... 3-3O perations Review s ................................................................................................. 3-4

Dose Investigations and Thresholds ............................................................................ 3-5Individual A LARA G oals ........................................................................................ 3-6Forn al A LARA Reviews ........................................................................................ 3-6

Internal A udits ............................................................................................................. 3-7Sum m ary of D ose Investigations and Thresholds ....................................................... 3-8Records ........................................................................................................................ 3-9Consideration of N on-radiological H azards .............................................................. 3-10Attitudes Towards Safety ........................................................................................... 3-10Balancing Doses and Other H azards .......................................................................... 3-11Responsibilities .......................................................................................................... 3-12A uthorized U sers ....................................................................................................... 3-12Radiological W orkers (Designated Users) ................................................................. 3-12Radiation Safety O ffi cer and Radiation Safety Staff ................................................. 3-13Resources for M ore Inform ation ................................................................................ 3-13

List of TablesTable 3-1 Dose Thresholds ............................................................................................ 3-5Table 3-2 Post Job Interview Thresholds ........................................................................ 3-5Table 3-3 Conditions Requiring a Form al ALA RA Review .......................................... 3-7Table 3-4: ALA RA Program Thresholds ........................................................................ 3-8

Copyright © 2005 Rapiscan Systems All Rights Reserved

Rap scanrmsystemsAn OSI Systems Company

RAPISCAN ALARA Occupational Exposure Control Program 1-19210670 Control Guide Purpose and Applicability

Purpose and ApplicabilityThis document provides the administrative and operational guidelinesfor the Pittsburg test facility in Pittsburg, California and shall bereferred to as the ALARA Occupational Exposure Control Program.

JurisdictionThis document describes Rapiscan's Pittsburg facility formal plansand measures for implementing the ALARA process and shall appliesto all Rapiscan Systems, Inc. employees, staff and contractorsperforming work at the Pittsburg, California facility. With respect toionizing radiation all activities shall be specifically governed and/orregulated by the laws, regulations and standards in effect in the Stateof California. A copy of California radiation regulations shall beavailable for review to any staff member, employee or contractor atthe site, upon request. Copies of relevant California regulations shallbe located in the offices of the facility's General Manager and in theRadiation Safety Office. The effective implementation of thisdocument will ensure compliance with applicable sections ofregulations that are in effect regarding the licensing to possess anduse linear accelerators and/or radioactive material sealed sourcedevices within the State of Californa. Should any section of thisdocument conflicts or be found in disagreement with regulations ofthe State of California, California regulations shall prevail and shallnot be superseded by any content of this guidance document.

Management CommitmentIt is the policy of Rapiscan Systems, Inc., and the U.S. CargoOperations facility to conduct radiological operations in a manner thatensures the health and safety of all employees, contractors, andvisitors. In achieving this objective Rapiscan Systems, Inc. and themanagement of the U.S. Cargo Operations facility shall ensure thatradiation exposures to its workers and others entering radiologicallycontrolled areas is maintained below regulatory limits, takingdeliberate efforts to reduce exposures to as low as reasonablyachievable (ALARA).

Rapiscan Systems, Inc. and the U.S. Cargo Operations facilitymanagement team are committed to implementing a high qualityradiological control program in line with this policy.

The workforce shall comply with this policy during the planning and

Policy and

Rapiscan.systemsAn OSI Systems Company

RAPISCAN ALARA Occupational Exposure Control Program 1-29210670 Control Guide Purpose and Applicability

execution of all work.

Management of the facility shall periodically review workersadherence to safety with respect to ionizing radiation and shallconsider the attention to safety and compliance in the course orevaluation of workers as part of annual performance reviews andconsiderations for promotions as well as routine task assignments.

Rap scan.systemsAn OSI Sytnrns Company

RAPISCAN ALARA Occupational Exposure Control Program 2-19210670 Control Guide Definitions

DefinitionsTerms defined in 10 CFR 835, and 10 CFR 20, and California Code of Regulations,Title 17 are used in this Guide in a manner consistent with regulatory definitions.Definitions below may include terms and terminology not applicable to theimmediate planned uses of ionizing radiation at the facility but are designed to allowfor the flexible use of this document at a number of site operations within the UnitedStates.

Accountable sealed radioactive source A sealed radioactive source having a half-life equalto or greater than 30 days and an isotopic activity equal to or greater than the correspondingvalue provided in appendix E of 10 CFR, Section 835

Agreement State means any state with which the United States Atomic Energy Commissionor Nuclear Regulatory Commission has entered into an effective agreement under section274b of the Atomic Energy Act of 1954, Title 42, United States Code, section 2021(b)(formerly section 274(b)).

ALARA: As Low As Reasonably Achievable. An approach to radiation protectionto manage and control individual and collective doses to the work force and generalpublic, taking into account social, technical, economical, practical, and public policyconsiderations. ALARA is not a dose limit, but a process whose objective is tomaintain doses as far below the applicable limits as reasonably achievable.

Authorized User: means an individual who is authorized by license or registrationcondition to use a source of radiation.

Committed Effective Dose Equivalent (CEDE): The effective dose equivalent that will bedelivered to a person during tile 50 years following an intake of radioactive material. TheCEDE is e4measured in units of rem.

Controlled Area: means an area, outside of a restricted area but insidethe site boundary,access to which can be limited by the licensee or registrant for any reason.

Deterministic Effects: Effects that increase in severity with increasing dose.

Dose: A general term that refers to the sum of the effective dose equivalent (fromexternal radiation) and the committed effective dose equivalent (CEDE) from internalradiation dose. Unless otherwise specified, doses to the extremities are not includedin the TEDE. Dose is measured in units of remn.

Entrance (or Access Point): means any location through which an individual couldgain access to radiation areas or to a source of radiation. This includes entry or exitportals of sufficient size to permit human entry, irrespective of their intended use.

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Exempt sealed radioactive source: A sealed radioactive source that does not meet theaccountability criteria established in the definition of the term "accountable sealed radioactivesource" provided in 10 CFR 835.2 (a). Generally, these are small check sources.

High Radiation Area: means an area, accessible to individuals, in which radiation levelsfrom sources external to the body could result in an individual receiving a dose equivalent inexcess of 0.1 remn (I mSv) in one hour at 30 cm from the source or from any surface that theradiation penetrates.

Individual Monitoring: May be defined as any or all of the following:

(a) the assessment of dose equivalent by the use of devices designed to be worn by anindividual;

(b) the assessment of committed effective dose equivalent by bioassay or by determination oftime weighted air concentrations to which an individual has been exposed;

(c) the assessment of dose equivalent by use of survey data

Individual Monitoring Devices: means devices designed to be worn by single individualsfor the assessment of dose equivalent such as film badges, thermolumninescent dosimeters(TLDs) and pocket ionization chambers.

Member of the public: means any individual except when that individual is receiving anoccupational dose

Minor: means an individual less than 18 years of age.

Non-stochastic effect: means health effects, the severity of which varies with the dose andfor which a threshold is believed to exist. Radiation induced cataract formation is an exampleof a non-stochastic effect (also called deterministic effect).

Planned Special Exposure: A planned exposure received by a radiological workeronly in an exceptional situation. Doses from planned special exposures are accountedfor separately from routine occupational exposures. Planned special exposures shallbe performed only under the oversight of the Radiation Safety Officer and shall bedocumented by a pre-work formal ALARA review. Except for emergencies oremergency response situations, planned special exposures will not be performedwithout consultation of the regulatory authority in the jurisdiction of use.

Radiation: means gamma rays and x-rays, alpha and beta particles, high speedelectrons, protons and neutrons and other nuclear particles, and electromagneticradiation consisting of associated and interacting electric and magnetic wavesincluding those with frequencies between 3 x10 8 cycles per second and 3 x 1024

cycles per second and wavelengths between I x 101 4 centimeters and 1200centimeters as defined in G.S. 104E-5(12).

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Radiation Safety Officer: An individual who is a member of the radiation safety committee,who is qualified by reason of training and experience to oversee the radiation safety aspectsof radioactive material use in the institution.

Radiological Area: Any area within a controlled area defined as a Radiation Area,High Radiation Area, or Very High Radiation Area.

Radiological Control Group (RCG): Adopted from the Department of Energy (DOE)terminology for Radiological Control Organization. (RCO). The RCG shall be any group orteam working on, or having specific authority and responsibility over a project that requiresthe use of a non-exempt radioactive sealed source, which shall bear the primary responsibilityfor ensuring radiation protection activities when using such sources in conjunction with theirproject. ( Applicable to Rapiscan Systems teams only: Examples of RCG's include VEDSGroup, MAS/OSM Group, GaRDS Group, Linac 4MeV Group, Field Service / Repair Group,Quality Assurance Group, Assembly Teams, Sales Demonstration Teams.

Sealed source: means any radioactive material that is permanently encapsulated in suchmanner that the radioactive material will not be released under the most severe conditionslikely to be encountered by the source.

Source Custodian: An individual who is trained and designated to maintain cognizance overaccountability and control of assigned sealed radioactive sources. For most purposes, thisshall be the Radiation Safety Officer (RSO).

Source User: An individual who by virtue of training and authorization is permitted to useradioactive sealed sources. There shall be two types of Source Users; authorized users anddesignated users.

Authorized User (AU): An AU shall be the only type of user to possess the authority toactually initiate the emission of ionizing radiation from any sealed source device byactivating switches, controls, or event sequences which allow the production andemission of radiation firom the source holder.

Designated User (DU): A DU is a worker who may be present and involved with theactive use of a radioactive sealed source, but for whom there is no authority granted toactually engage or activate the source in such a manner as to deliberately initiate therelease or emission of ionizing radiation or the production of a beam from the sourceholder device.

Stochastic Effects: Effects that have an increasing probability of occurring withincreasing dose.

Total Effective Dose Equivalent (TEDE): The sum of the committed doseequivalent (CEDE) from internally deposited radionuclides and the effective doseequivalent from external radiation. The TEDE is measured in units of remn.

Rapiscan1.systemsAn OSI Systems Comnpany

RAPISCAN ALARA Occupational Exposure Control Program 3-19210670 Control Guide ALARA Program

ALARA ProgramAs Low As Reasonably Achievable (ALARA) is an approach toradiation protection to maintain and control individual and collectivewhole body dose exposure to employees and visitors to levels as lowas reasonable, taking into consideration social, technical, economic,practical and public policy considerations. ALARA is not a doselimit, but a process for maintaining doses that are as far as reasonablyachievable below the applicable limits as specified in regulatoryrequirements on occupational radiation protection. ALARA may beconsidered an "operational philosophy".

Assumptions and DependenciesThe ALARA philosophy works on the supposition that penetratingradiation doses increase one's risk of cancer - the smaller the dose,the smaller the risk. Although this premise has not been proven atlow doses of radiation (such as, acute whole body doses of 10 rem orless), regulations generally require some type of formal plans andmeasures for applying the ALARA process to occupationalexposures.

From a technological and regulatory standpoint, ALARA applies tothe Total Effective Dose Equivalent (TEDE) which is the EffectiveDose Equivalent (EDE) from an external exposure to the whole bodyplus the committed effective dose equivalent (CEDE) friom internallydeposited radioisotopes. The TEDE limit of 5 remn/year (5,000 mrerm)is based upon establishing a reasonably low occupational latentcancer risk.

Occupational exposures to the extremities, skin, and eyes areconsidered separately from the whole body, with higher set doselimits. These detenninistic dose limits exist to prevent radiationdamage to a worker (as opposed to simply limiting one's risk tocancer). Because deterministic exposures have not been shown tocontribute to an increased risk of cancer, they are not formallyincluded in the ALARA program. However, from an operationalstandpoint, it is important to stay well below the dose limits so thatoperations can proceed without impediment.

RapIscanI 1systemsAn OSI Sys;terns Company

RAPISCAN ALARA Occupational Exposure Control Program 3-2

9210670 Control Guide ALARA Program

TrainingALARA training is included in the Initial Radiation Safety Trainingthat is required for all workers that work with, or frequently near, x-rays, accelerator beams or radioactive material sealed sources. Inaddition to such general training, management at the site shall becertain to consider mock-up training, dry runs, and drills whenpreparing for unique tasks where exposure may be higher than duringthe typical work exposures.

ALARA training for designers and engineers occurs through regularinteractions and consultations with the Radiation Safety Office andthe Corporate or Site Radiation Safety Officer. During planning anddesign phases of product development, facility design, or operations,the participation of the members of the Radiation Safety Office isimperative to assure a design engineered for achieving complianceand worker safety.

Design CriteriaDuring routine operations, the combination of physical designfeatures for engineering and administrative controls shall ensure thatdoses are kept below regulatory limits. Physical design features(engineered safety controls) such as confinement, locking storageunits, safety interlocks, shielding, etc., shall be the primary method ofreducing exposures.

Administrative procedures, such as plans, policies, signs. labels, etc.serve as secondary controls. Occasionally, administrative controlsare used in place of physical controls if the former are shown to beimpractical. Personal Protective Equipment (PPE) shall provide thethird tier of radiological control.

The combined use of engineering controls, administrative controlsand PPE assures that personnel exposure firom external sources ofradiation shall be limited to 10% of the applicable limit (that is, awhole body dose of 0.5 remn/year, or 500 mrem /year).

Design RequirementsFacility design and materials shall include features that facilitateoperations, maintenance, and the movement and storage ofaccelerators and/or radioactive material sealed sources in a mannerthat minimizes exposure to workers at the site.

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Structural shielding materials shall meet the following minimumrequirements:

* All shielding shall be of assured quality, uniformity, andpermanency,

* Lead shields shall be protected from mechanical damage andmounted in a manner that prevents cold flow from the shield'sown weight,

* Joints at floors and ceilings shall be mounted to ensure that theoverall protection and stability of shielding is not impaired,

" Provisions shall be made to ensure that nails, rivets, or screwsthat penetrate shields are covered to match protection to theunpenetrated shield,

" The lead equivalent of doors and observations windows shall notbe less than that required for the shield in which they are located,

" Clearances around doors shall be shielded in a manner to matchthe shielded level required for the door itself.

Design ReviewsThe Radiation Safety Office shall be involved in preliminary and on-going evaluations of facilities and equipment. The facility manageror project manager should notify the Site RSO of pending meetingson such topics as they pertain to the use of ionizing radiation.

Integrated Safety Management ProcessIt is imperative to note that design review shall not be limited to thedesign of physical structures or facilities, but shall also apply to the"design processes" of planning tests, evaluations, proceduresinvolving assembly, and other such tasks where the production ofionizing radiation shall be employed. It shall be a requirement thatissues of safety and compliance, including radiological and generalsafety, shall be integrated into all such processes.

RSO ResponsibilitiesDuring the design review, the RSO should:* Review the general configuration of the facility and equipment,

consider traffic patterns; location and size of rooms in thevicinity; location of survey equipment, adequate space forplacement of all required postings, notices and labels; andevaluate the adequacy of space for anticipated operations,maintenance, production, research, and demonstrations,



* Verify that radiological considerations are consistent withapplicable regulations and recognized standards and guides,

" Evaluate and confirm the adequacy of specific control devices forreducing occupational doses, including shielding, containments,interlocks, barricades, audible and visual warning indicators, andother similar measures,

* Verify that the design will be able to maintain personnel entrycontrol for each radiological area of operations, commensuratewith existing or potential hazards within the area,

" Verify that each entrance or access point to High Radiation Areaswill have entry control features required by regulations, includingprovision for emergency egress,

" Assess the adequacy of planned radiation monitoring equipmentand if such instrumentation has sufficient redundancy andcapability for the operations in normal and emergency workingconditions.

Operations ReviewsThe RSO shall review each radiological operation or routine activityduring which workers may be in close proximity to ionizing radiation.The purpose of the review is to identify potential sources of personneldose and the controls necessary to reduce that dose. The review alsoensures that appropriate controls for normal operations and "upset"conditions are integrated into radiological operations.

During this review, the RSO should consider the following:" Individual dose expected to each worker involved in the

operation," Potential dose consequence to workers and public for "off-

normal" operations,* Whether the projected dose could be reduced or eliminated by

using

i. less radioactive material or lower energiesii. shielding, without introducing offsetting problems, or,iii. tools, such as remote handling devices.

" Is the work area appropriate for the type of work beingperformed,

* Is the area is properly posted,* Are appropriate monitoring requirements included in the

operation.

Based on these considerations the RSO should identify appropriate

Rapiscan,,systemsAn OSI Systems Company


controls using a graded approach. Typical operational ALARAcontrols include:* Using tools, shielding, and work space as appropriate,* Minimizing time in the radiological area,* Maximizing distance from radiological sources,* Monitoring "stay times,"* Effective use of mock-up training and drills* Holding pre-start briefings. Pre-start briefings should occur just

before performing any high consequence or complicated work todiscuss workplace conditions; current dose rates, and any staytime restrictions.

Dose Investigations and ThresholdsThe RSO shall investigate anomalous dosimeter readings or resultsthat exceed certain thresholds identified in Table 3-1. The resultsshall be documented, at a minimum, by way of a written reportcreated by the RSO (Site or Corporate) and shall be included in therecords maintained for dosimetry exposure reports. If any of thethresholds in Table 3-2 is surpassed, the work supervisor and/or RSOshall conduct and document a post job review. The post job reviewmay involve workers, members of EH&S, the RSO and others thatmay have been affected by the situation.

Table 3-1 Dose Thresholds

Whole Body Film Whole Body FilmDose Type:: x and gamma w/ x, gamma & Extremity TLD

neutronDeep Photon 100 mrem 100 mrem NANeutron 20 mrem 50 mrem NAShallow 100 mrem 300 mrem NAExtremity NA NA 1000 mrem

Table 3-2 Post Job Interview Thresholds

I. The actual dose exceeds the pre-job estimate by more than 25%2. A stop work order is issued for radiological purposes3. Operations resulted in an injury report4. Significant "lessons learned' are identified5. Planned special exposure provisions are requested6. Notifications to Corporate RSO of "worker concern"7. Notification by regulatory agency of situation of concern

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Individual ALARA Goals

The RSO and/or work supervisor shall identify any individuals who,by nature of his/her work, a potential for a whole body dose of morethan 0.1 rem/year may be possible and establish ALARA goals forthese individuals. ALARA goals should adhere to the following:

* Be based upon historical radiation doses and projected workload,and may be modified tIp or down, for specific individuals toreflect actual conditions,

0 Reflect a challenging upper bound of dose that the worker isexpected to receive (but is NOT a dose limit),

* Be established in conjunction with the facility manager and/orproject manager,

* Be tracked to ensure the work supervisor, project manager andworker are aware of the accumulated dose. The cause of dosesthat approach or exceed the ALARA goal should be scrutinized.

The above procedure is a "goal" not a limit. If a worker isapproaching or has exceeded his ALARA goal, the supervisor,worker and RSO shall evaluate the work to determine additional dosesaving measures as appropriate. In some cases, exceeding the goalmay simply mean that the individual has had a greater than plannedworkload or has worked around higher dose rate material. In anycase both the worker and the work supervisor should be explicitlyaware of the situation.

Formal ALARA Reviews

A formal ALARA review should be based upon the criteria inTABLE 3-3 and documented using the form in Appendix B. Thisreview does not need to be conducted if the cost, together with thecosts of documentation, outweighs the potential value of any benefits.The ALARA review should be conducted in the following threedistinct phases:

" During the planning phase," While work is being conducted," Following the completion of the work.

During the planning phase of an operation or task, the RSO should:* Estimate the dose to each individual performing that task," Identify those discrete functions of a task that may result in a

disproportionate fraction of the dose,

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Identify appropriate ALARA controls and alternatives, and makesome comparison between the cost of implementation of thosecontrols and anticipated dose reduction to be obtained if controlsare implemented.

Table 3-3 Conditions Requiring a Formal ALARA Review1. Individual whole body dose from an operation/task is expected to exceed 0.1

rem/year2. Collective dose of all personnel performing the task is expected to exceed 1

remn/year3. Operation/task is expected to require entry by individual into areas with dose rates

exceeding 1 rem/hr at 30 cm.

The ALARA controls identified by the RSO should be incorporatedinto the safety plan and made a routine part of operations asappropriate. The RSO and program supervisor should make periodicinspections during work to ensure that ALARA controls areimplemented and effective. Item #3 above is not to be a factor in theperformance of tasks at the Pittsburg, California site.

Internal AuditsInternal audits shall be conducted by the site RSO at a minimum ofonce per year, or more firequently as dictated by regulatoryrequirement. Audits shall be documented and copies forwarded to theCorporate Radiation Safety Officer. The audit should identifyrelative strengths, weaknesses, and areas of vulnerability or non-compliance. Audits shall review the administrative controls andassure that they are in conformance with regulatory requirements.Areas found to be deficient shall include remarks on how the siteRSO and workers plan to bring the deficient program area into fullconformance.


RAPISCAN ALARA Occupational Exposure Control Program 3-8Control Guide ALARA Program9210670

Summary of Dose Investigations and ThresholdsTable 3-4 summarizes the ALARA Program thresholds.

Table 3-4: ALARA Program Thresholds

Action :Threshold:• . Performed ByConduct an operational All radiological operations Site RSO, work/projectALARA review involving linear accelerator supervisor, may be assisted

x-ray production or use of by Corporate RSOlicensed quantity ofradioactive material as asealed source

Conduct a dosimeter As specified in Table I of Site RSO, in consultationinvestigation this document w/ Corporate RSOEstablish individual Individual external doses Site RSO, w/ assistance ofALARA goals are expected to exceed 0.1 work supervisor/project

rem/yr from all operations manager, in consultation w/corporate RSO

Conduct a prestart briefing Initially for all radiological RSO, in conjunction withtasks/operations. Over time working group orreduced to only those tasks radiological control groupwith complicated or high (RCG), or specificconsequence work or where individuals performing thethe dose to individual is task/operation.expected to exceed 0.1 remnin seven days.

Conduct a Post-job review As specified in TABLE 2 RSO in conjunction withsupervisor/project manager

Conduct a formal ALARA As specified in TABLE 3 RSOreview

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Conduct a design review Modification of facilities or Specific affected workmajor equipment group w/ RSO and project

manager/work supervisorMaintain detailed records to Individual dose is expected Site RSO in consultation w/support optimized decisions to exceed 1 rem/yr Project Manager/Workmade during design phase Supervisor and corporate

RSO

Records

A formal dose investigation shall be conducted for any dose thatexceeds limits specified in 10 CFR 835.202. The investigation reportshall be included in records of exposure history reports.

Quality Assurance staff should be involved with the RSO andradiation safety staff in the review and approval of documents andany legal records used to demonstrate compliance with the ALARAprogram requirements.

At a minimum, the following records shall be maintained:* All records regarding or pertaining to dose assessments for the

purposes of estimating doses for specific tasks or operations,* All recorded exposures of individuals,* Completed design review packages for facilities and equipment,* Formal ALARA reviews for operations that exceed thresholds in

Table 3-3.

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Records should be detailed enough to support the optimizationdecisions made for operations that result in expected annual dosesexceeding I rein to an individual.

Other actions taken to maintain occupational exposures as low asreasonably achievable should also be documented. The level of effortexpended in documenting and implementing ALARA decisionsshould attempt to match the potential dose savings.

Consideration of Non-radiological HazardsThe Radiation Safety Officer should evaluate, in conjunction withother safety personnel, general non-radiological hazards as well asspecific tasks or operations. The attitude of management and workerstowards general safety may indicate the attitude towards radiologicalsafety.

Attitudes Towards SafetyEven small accidents in non-radiological areas may signal a lapse inconcern or attentiveness to safe operations. Such lapses shall beconstrued as "weak signals" that may belie the potential for a largerand more serious event. In addition, the RSO should not dismissreports of safety issues simply because the issue does not reside in hisarea of authority. Dismissive behavior conveys the wrong message toconcerned workers and could mask deeper program deficiencieswhereby workers, over time, gradually become complacent.

The RSO should not wait for reports of safety concerns, but should beproactive in seeking them out. The Radiation Safety Site Safety Planfor Rapiscan Systems, Inc. and the U.S Cargo Operation's facilityincludes a section on "neari misses." Such activities play an importantrole in the overall safety at the site including such non-event issues.In seeking out safety concerns in a proactive manner, the RSO shouldbecome familiar with those operational or line workers that actuallyengage in the day-to-day activities where such injuries may occur.

Workers at the operational level may quickly learn which proceduresor processes to modify to save time (or money) and how such processre-engineering may compromise safe operations. Operational levelworkers are the RSO's best resource for knowing which proceduresare working and which ones are likely to be ignored. The RSO canlearn which process are so overburdened with safety procedures thatsafety enhancing efforts have inadvertently led to an unintendedreduction in safe practices.

Rap scan CsystemsAn OSI Sytm Cn:mpanqy


9210670 Control Guide ALARA Program

Balancing Doses and Other Hazards

The RSO should be mindful of industrial, chemical and physicalhazards that are also present during his evaluation of facilities andplanning processes. Efforts to maintain doses as low as reasonablyachievable should not disproportionately increase the risk ofpersonnel injury from other hazards. The impact of contributing andor conflicting occupational hazards shall be considered whenoptimizing worker radiation dose.

Contributing / Conflicting Factors• Excessive protective clothing used to control personnel exposure

(lead aprons, vests, gloves) may contribute to conditions of heatstress, physical exhaustion, or reduced mobility or flexibilitynecessary to perform a task. Thus, a worker's slower, moredeliberate movement, in a radiological area or task may increasethe radiation dose to the worker or inadvertently give risk toanother hazard.

* Certain painting, coating, and welding operations may requirerespirators and face shields. These can impair visual acuity andcommunications among workers.

* The noise level in the work environment. Other nearbyoperations should not produce so much noise that audiblewarning systems cannot be heard. To reduce noise, hearingprotection may be provided to workers. However, this raises thepossibility that audible warning systems, indicating theproduction of radiation, may not be heard.

In light of these contributing and conflicting factors, it is best to usean integrated approach in the planning of facilities and workprocesses that encompasses all occupational hazards and the ALARAprocess. This is best accomplished by communication betweenvarious safety, planning, and design teams including feedback andfirom the operational level teams



ResponsibilitiesThis section profiles the responsibilities of specific classes ofradiation users.

Authorized UsersAuthorized Users are responsible for:

" Providing information and input needed for proper tasksassociated with planning and design review of facilities,equipment and operations,

* Assist in gathering and forwarding information for formalALARA reviews, design reviews, and other information requiredto support organizational decisions.,

* Participating in the ALARA goal process for workers who arelikely to receive individual doses exceeding 0.1 rem/year,

* Investigating increasing trends in doses to individual workers ordoses associated with performance of specific tasks,

* Ensuring the constant reinforcement of the ALARA programrequirements in their RCG,

" Incorporating the ALARA philosophy and recommendations asappropriate in activities under their direct supervision or control,

" Identifying and reporting activities that may be novel or uniqueand should be considered for ALARA review.

Radiological Workers (Designated Users)Designated users are responsible for:

* Informing supervisors, project managers and RSO of proposalsfor reducing exposures,

" Implementing the ALARA requirements specified in plans andprocedures relevant to their specific tasks and operations,

" Consulting with the work supervisor, project manager and/orRSO prior to beginning work where concerns of exposure maybe present,

* Providing information and feedback during pre-start briefingsand post event reviews for continuous improvement of theradiological safety program,

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Becoming active participants in their own safety and the safety oftheir team mates.

Functioning in supportive roles only with no authority to initiatedthe energizing of a linear accelerator and/or radioactive materialsealed source device system or initiation of beam production

Radiation Safety Officer and Radiation Safety Staff

In addition to duties and responsibilities as delineated in regulatoryrequirements, The RSO and staff shall be responsible for:

* Providing technical support and assistance to supervisors,planners, schedulers, and design engineers and sales staff so as toreduce occupational doses,

* Providing input for new or modified facilities or equipmentduring the planning phase to ensure that design and physicalcontrols are optimized, external exposures to radioactive sourcesare minimized, and appropriate materials are selected for thepurpose of shielding,

* Reviewing radiation dosimeter data and conductinginvestigations if the indicated dose exceeds pre-establishedcriteria. Notifying supervisors and workers of results of reviewsand investigations as appropriate,

* Providing supervisors and workers with periodic dose reports forindividuals with ALARA goals,

" Providing program areas with information regarding doses toworkers in that program area and addressing, as appropriate,safety trends, notable problems, and lessons learned.

Resources for More InformationNational Council on Radiological Protection and Measurements(NCRP), Publication 127, "Operational Radiation Safety Program"(1998)10 CFR 835, Radiological Protection10 CFR Part 20 and Part 34Regulations for the Control of Radiation in Mississippi, Section 45-14 (For use by staff at Ferson Technologies only)California Code of Regulations, Title 17 (For use by Torrance andSunnyvale facilities only)

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Control Guide ALARA Program9210670

Rapiscani.systemsAn OSI Systems Company


APPENDIX BFORMAL ALARA REVIEW FORM

Use this form to document formal ALARA reviews, which are typically conductedduring the safety assessment phase of planning specific tasks or procedures.

Operation being reviewed:

Evaluation By:

Evaluation date:

Assistance provided by:

Estimate of highest individual whole body dose friom this operation:

> 0.1 rem > 0.5 remn > I rem < 5 rem Other:

Task portion that results in ALARA controls and alternativesdisproportionate fraction of dose

Estimated dose reduction:

Estimated cost of reduction efforts:

Comments: (include make/model of measuring instrumentation)

Post-job review: __ Not required __ Required as per TABLE 2

RSO Signature: Date:

Rapiscan.,systemsAn OSI Systems Comparny

Exposure Investigation Form

SECTION I - PERSONNEL INFORMATIONTODAYS DATE

NAME

EMPLOYERSSN

TLD #MONITORING PERIOD UNDER INVESTIGATION

FROM TO

SECTION II - REASON FOR INVESTIGATION (CHECK ONE)

1. LOST PRIMARY DOSIMETER 5. IMPROPER USE OF DOSIMETRY

2. DAMAGED PRIMARY DOSIMETER 6. OTHER (SPECIFY):

3. PRIMARY DOSIMETR SUSPECT RESULTS

4. EXPOSED TO DOSE OTHER THANOCCUPATIONAL DOSE

SECTION III - PRELIMINARY INVESTIGATION

AVERAGE EXPOSURE RATE IN THE RESTRICTED AREA INDIVIDUAL WHOSE DOSE IS UNDER INVESTIGATION:

HIGHEST EXPOSURE RATE IN THE RESTRICTED AREA

AVERAGE DOSE OF INDIVIDUALS WHO WORK IN THE RESTRICTED CURRENT MONTH TEDE

AREA CURRENT QUARTER TEDE

CURRENT YEAR TEDEOTHER PERSONNEL IN RESTRICTED AREA DURING THE SAMEMONITORING PERIOD UNDER INVESTIGATION VALUES ABOVE DO NOT INCLUDE MONTIORING PERIOD

CURRENTLY UNDER INVESTIGATIONNAM E!TLD #

DOSE RESULTS

NAMEITLD #

DOSE RESULTS

NAMEITLD #

DOSE RESULTS

LOCATION WHERE EVENT OCCURRED IS THERE A POTENTIAL FOR OVER EXPOSURE .*YES

:;• f• ... NO.

SII RES, RESTRICT INDIVIDUAL FROM RESTRICTED• REA ANDNOTIFY THE STATE AS REQUIRED.

SECTION IV - REMARKS

DOS-FR-0007 Page 1 of 2

Exposure Investigation Form (Continued)

SECTION - V DOSE ASSIGNMENT BASED ON (CHECK ALL THAT APPLY)

PRIMARY DOSIMETRY RESULTS ESTIMATE BASED ON OTHER INDIVIDUAL DOSES FOR THE SAMEMONITORING PERIOD

CALCULATIONOTHER (EXPLAIN BELOW)

ESTIMATE BASED ON SURVEY DATA

SECTION VI - INDICATE ASSUMPTIONS, DOSE CALCULATIONS, AND OTHER PERTINENT INFORMATION

SECTION VII - DOSE ASSIGNMENT INFORMATION

DOSE ASSIGNED (REM)

DDE CEDE________________

LDE CDE.. " "._..._• .

SDEWB TEDE_•____.______.._:

SDE,ME TODE____,__

COMPLETE ALL BLANKS, N/A AREAS WHERE

NO DOSE ASSIGNMENT IS NECESSARY

SECTION VIII - REVIEWS/REMARKS

SECTION IX - APPROVAL/SIGNATURES

INDIVIDUAL'S SIGNATURE: DATE

RADIATION SAFETY OFFICER SIGNATURE DATE

FILE THIS REPORT IN THE INDIVIDUAL'S DOSIMETRY FILE

DOS-FR-0007 Page 2 of 2

RADIATION WORK PERMIT LOG

RWP # DATE TIME WORK DESCRIPTION DATE f TIME INTIALSINITIATED INITIATED TERMINATED TERMINATED

I + t - I

4 + - 4

t I + t I

I 4 4 * 4

RAD-RWP-FR-0005 Page I of 2

RAD-RWP-FR-0005 Page 2 of 2

Date: Radiation Work Permit Manual Log-in Sheet Page 1 of

TLD Badge Electronic Name (Print Legibly) RWP Date Time Electronic IN OUT TOTAL# Dosimeter Number Dosimeter (mRem) (mRem) (mRem)

# Job Task (e.g., HCV Driver, Cal. Due

Image CR Ops. Marshall) Date

Out

Out

I __ ____ ____ ___ _ __ _ __ __ Out_

______________ ___________ _______________________________ ut _______In

___________________ ________________ _________________________________________ ____________Out____

________ _______ _______ In_ ___ _[ ___________ _____________________________ _______________I ____ _______0_______d_

_______ _____ I _____________ _______Out[ ________

___ __ ___I ___ __ I ___ __ ___ __ __ ___ _ ___ __ __ __ __ __ __ _

_____________________________ I ________ ___Out___

_______________________ __________________ ________________________________________________ ________________________ Ou _____________E___III_____ut__

I______ TOLIJ___________________________ ____________ In ____ ____

_______________________________ IOt______ ______ f ___________________________Out_______

RSO Review: Date

RAD-RWP-FR-0004 Page 1 of I

ALARA BRIEF ATTENDANCE SHEET

RWP Number Date:

Work Location:

Job Description:

An ALARA Brief was conducted on the above job. The below-listed individuals attended and received thefollowing specific instructions pertaining to the work:

Access Control/RWP Requirements:

RSOHold Points/Radiation Survey Requirements:

Dosimetry Requirements & Limitations:

Miscellaneous:

TLD TLDBadge NAME Badge NAME

Number Number

III .11__ I: _______ J __ I ________

4- *II I

RSO:

RAD-RWP-FR-0003 Page I of I

RADIATION WORK PERMITPage 1 of 2

RWP # RWP Activated:

RWP Expires:(Date) (Time)

(Time)(Date)

Location of Operation: Equipment to be Operated :

Description of work (Accelerator Adjustment, Routine Test Scanning, Rad Detect Testing, Cargo Scanning, etc.)

TASK LIST Estimated Average Exposure Total # of Total EstimatedManr-hours Rates to Personnel Personnel Man-rnRem

(mR/hr).1.

2.

3..

4.

5.

6.

7.

8.

Total: Ttl

PROTECTIVE CLOTHING AND EQUIPMENT REQUIREMENTS

[] Hard Hat [xl TLDSafety Glasses [x] Alarming Electronic Dosimeter (Pre-Set to Alarm at I mR/hr and 10 mR Cumulative)

[] Face Shield [] Extremity Dosimeter (During RAM Source Handling'and/or Leak Testing)Goggles [] Special Dosimetry (Neutron Dosinetry Required for Handling Neutron Source)

[] Safety shoes[] Hearing Protection

POSTING/PERMITS/BRIEFINGS REQUIRED

[ Hot Work [ ] Lockout/Tag out [] ALARA Pre-job brief required [ ] Post Radiation Survey

High Radiation Area Postings [] Exclusion Area Boundary [ ] Notice to Employees [ I Post Copy of RWP

RAD-RWP-FR-0002 Page I of 2

RADIATION WORK PERMITPage 2 of 2

RWP # RWP Activated:(Date) (Time)

RWP Expires:(Date) (Time

RADIOLOGICAL COVERAGE INSTRUCTIONS[x] Initial Exclusion Area Boundary Survey (Initial Start-Up) RSO Hold Points:

1. An Initial Radiation Survey of the Exclusion Area Boundary shall be[x] Intermittent Surveys During Scanning and/or Testing performed immediately upon accelerator activation AND Prior to

Operation and/or Testing. The Exclusion Area Boundary shall be[] Continuous Surveys of maintained less than 2 mR/hr at all times.

[x] Final Exclusion Area Boundary Survey 2. A Final Radiation Survey of the Exclusion Area Boundary andExclusion Area shall be performed AFTER final termination of

[] Interlock Bypassed accelerator activation and operations/testing AND before removing theExclusion Area Boundaries.

GENERAL INSTRUCTIONS1. Read this RWP carefully. By signing in on the RWP log-in sheet, you are acknowledging that you have read and

understand the RWP requirements and that you shall comply with all instructions. At the job site you must wear all of thepersonal protective equipment indicated by this permit and/or area posting.

2. NO Interlock May be Bypassed without RSO Authorization.3. NO Interlock shall be used to Shut-Off the accelerator except in an Emergency or during Testing.4. The Project Leader shall be present at ALL Times During Normal Scanning Operations.5. Notify the RSO Immediately Upon ANY Unauthorized Entry Into the Exclusion Area.6. YOU are responsible for tracking your own exposure. Check your Electronic Dosimeter frequently. Leave the area

immediately if your dosimeter alarms and report to the RSO.7. Attend all ALARA Briefings and review the most current radiation survey data.

SPECIAL INSTRUCTIONS1. Only "Qualified" Accelerator Operators are authorized to Unlock and Operate the Control Panel for the Accelerator.2. Interlocks May be Bypassed ONLY to Test, Adjust, Maintain, and/or Rearrange Equipment provided a ConspicuousIndication of Such Condition is made at the Control Panel. (This does NOT authorize the operation of the accelerator with theHigh Radiation Area Warning Devices or Emergency Shut-Off Switches Incapable of Operation).3. The Radiation Safety Officer (RSO) is the ONLY person authorized to Allow Interlocks to be Bypassed. This RWP DoesNOT Authorize Interlocks to be Bypassed.4. In the Event an Interlock is activated or tripped, Accelerator Operations shall terminate and a Radiological Occurrence ReportShall be Initiated. No Accelerator Operations Shall recommence without RSO authorization.5. Secure Accelerator Operations and Inform the RSO Immediately if the Operator's Room Radiation Detector Alarms at thepre-set limit of 50 uR/hr.6. Secure Accelerator Operations if Any Individual Electronic Dosimeter Alarms above the Pre-Set Exposure Rate and/orCumulative Daily Exposure Settings. Limit for Exposure Rate shall be pre-set at I mR/hr and a Cumulative Daily Exposure of10 nmR.

REVIEW AND APPROVAL

Project Leader: Date:

Radiation Safety Officer: Date:

TERMINATION[] RWP Terminated On Date: Time:

Terminated & Reviewed By: Date:


RADIATION WORK PERMIT REQUEST

RWP # DATE REQUESTED:

(Assigned By the RSO)Location of Operation: Equipment to be Operated (HCV 4):

Description of work (Accelerator Collimator Alignment., Routine Test Scanning, Rad Detect Testing, Factory Acceptance Testing, etc.)

HAZARDS: Check those that are present or may be present:High Energy X-Ray Radiation Emissions _

___Heavy Moving EquipmentGas (SF6), vapor, fumes, dust, mnist 5Noise

-Safety Interlock Bypassed _Elevated work -Electrical hazards

__Explosive or flammable materialsPower tools

-Draining liquids

HeatLockoutfTagoutSlip & Trip HazardsOverhead cranesHot WorkSplashing or running waterOtherOther

TASK LIST totalman-hours

1.

2.

3.,

4.

5.

6.

7.

Total:

Estimated Start Date: Estimated Start Time: am or pm

Estimated Stop Date: Estimated Stop Time: am or pm

Date Approval Needed:

Comments:

Requester: Date:

RAD-RWP-FR-000 I Page I of I

Rapiscan Chain of Custody

This form is to be used each and every time custody of sources of radioactive materials is exchangedbetween Rapiscan and the DHS, DNDO, or any other entity.

Recipient:

I understand and accept the responsibilities of receiving the sources listed below. I contest that I ampart of an entity which is licensed to possess these sources.

Recipient Company Name:

Printed name: Date:

Signature of Recipient: Time:

Transferor:

I hereby transfer possession of the sources listed on this form to the aforementioned recipient, alongwith all responsibilities for handling and accountability of them.

Transferor Company Name:

Printed name: Date:

Signature of Recipient: Time:

Source(s) transferred:

Sealed Unsealed Nuclide: Activity:

SN:


SN:


SN:


SN:

A copy of this signed document must be delivered to both parties.

Rapiscan Radiation Safety Training Topics

Course Outlineo Basic Overviewo Regulatory Agencieso Definitionso Responsibilitieso Doseo Exposureo Radiationo Biological Effectso Equipment Hazardso Radiation Protectiono ALARA

* Shielding* Surveys and Monitoring

o Linac Safetyo Dosimetryo Access Controlo Safe Working Practiceso Trainingo Notificationso Additional Relevant Regulationso Inspectionso Radioactive Materials

Workers Rights/Pregnancy Declaration

Radiation Safety Training Acknowledgment Form"INSTRUCTION TO WORKERS"

Section I (Please Print Clearly)Name: Sex: Male FemaleSection IIIn accordance with the regulatory requirements of Title 10, Code of Federal Regulations, Part 19, and theapplicable State regulations regarding Notice to Employees - Instruction to Workers, the followinginformation is provided to inform you of the extent of the hazards to which you may be exposed.

This facility utilizes a linear accelerator (LINAC) to inspect cargo containers for radioactive materials.During the testing of this system, there will be generation and presence of neutron, gamma, and x-rayradiation. Radiation levels in excess of the member of public levels will be received by employee whoremain on site during the testing of the linac. Radiation is ONLY produced when the linac is turned on andactivated.

If you are a female linac operator and you become pregnant or trying to become pregnant, we ask youinform your facility Radiation Safety Officer. Your facility RSO can provide you with additional informationabout radiation and pregnancy and discuss your options with you.

There will also be radioactive materials and sources located inside the linac room. These sources maygenerate radiation levels in excess of the member of public level. Do not handle the source with yourhands, and do not handle the sources more than necessary.

It is your responsibility to maintain your exposure to radiation to as low as reasonably achievable(ALARA). Your exposure to radiation will be monitored by a personal radiation monitoring device asrequired when dose levels are expected to exceed 100 mrem/yr or 2 mrem/hr. Always practice soundradiation principles around any source of radiation. Minimize your time around the linac and radioactivesources, and maximize your distance.

In the event of an emergency, follow employee instructions for safely evacuating the facility. Radiationgenerated by the linac can be stopped by simply turning off the machine or activating the "E-Stop" button.

By signing this form, you are certifying you have read the above information and you understand yourresponsibilities, understand your rights to be informed, and have received appropriate response to yourquestions.

Signature Date

Radiological Occurrence Report

Section A Date/Time of Occurrence

Description of Radiological Occurrence:1. Building/Area2. Equipment Involved3. Description of Work

4. Description of Equipment

5. Individual(s) Involved: E] Unknown (Check if individuals involved are unknown)Name SS# Badge# Work Group Supervisor

6. Detailed Description of Occurrence: (Use additional pages as necessary)

7. Immediate Corrective Action:

Prepared By: Date:


ROR# Assigned : Deficiency Incident

ADM-FR-O001 Page I of 3


Section B (To Be Completed By Lead Investigator) /ROR#Deficiency - Incident

Investigation Results (Attach Additional Pages as Necessary)Include: 1) Description of Occurrence; 2) Root Cause Determination; 3) hmnediate Corrective Actions; 4)Corrective Actions to Prevent Recunence; 5) Completion Dates of Corrective Actions

Lead Investigator Signature/Date /

Team Member Signature/Date /

Team Member Signature/Date /

Forward To RSO When Completed

ADM-FR-0001 Page 2 of 3


Section C (To Be Completed By RSO) . ROR#DeficiencyI IncidentRoot Cause Evaluation Adequate? - Yes [ NoCorrective Actions Adequate? [ Yes L-- NoWas the State Radiation Control Office Notified? D Yes F] No - Not Required(If YES, attach a copy of the written report)

Additional Comments:


Senior Manager: Date:(Required for Incidents Only)

The infonrmation and actions required in Sections A, B and C has been verified complete. No additionalactions are required. This ROR is closed.

ADM-FR-O001 Page 3 of 3

Request for Occupational Dose Records

Attention: Dosimetry Department

Date:

To:

Subject: Request for Occupational Radiation Exposure

In accordance with provisions of Title 10 Code of Federal Regulations, please provide a report of theoccupational dose history for the individual named below on an NRC Form 4 or equivalent for previous yeardose and/or a NRC Form 5 or equivalent for current year dose. Please indicate any planned special exposuresor exposures in excess of annual limits. Please indicate whether the reported doses are based on records orestimates (pending final dose determination).

Name:

Social Security Number:

Periods of Exposure:

Please forward your report to the attention of the Radiation Safety Officer. We request that all reports sent byfax be followed with a hard copy suitable for rnicrofilniing. Thank you for your assistance.

I hereby authorize the release of the above requested information to:

Signature of the IndividualAuthorizing Release of Information:

Date:

DOS-FR-0004 Page I of I

Rapiscan SNM USE LOG

Date Source User Time Time Persons on Site Source #1 Source #2 Source #3 Source #4 Notes and

Removed Returned SN SN SN SN Incidents

+ 4 4 I I + + 4

4 4 + I. 4 1

Page _ of _



Page _ of _



4- 4 4- 4- 4 4 + + F

Page _ of _

Rapiscan LINAC USE LOG

Date Operator Start End LINAC Output Persons on Site Notes and IncidentsTime Time Setting

Date Operator Start End LINAC Output Persons on Site Notes and IncidentsTime Time Setting

Page: _of

Page: of

Appendix E

Rapiscan Radiation Survey Form

Name of person performing the survey:

Date of survey:

Survey Meter information:

Make/Brand: Model:

Serial Number: Calibration Due Da

Background reading: in units

Area being surveyed:

te:

Measurement and# uDescription/Commentunits

1

2

3

4

5

6

7

8

9

Note: Indicate locations of surveys on an area map.

IRACInfal£ 1laiu ae - tfg C07/28/10 Page 1 of 2

Rapiscan Radiation Survey Form

Appendix A (continued)

Area Map

Page 2 of 2

07/28/10 I RS.Ra~ln$-

PRIMARY DOSIMERTY ENROLLMENT FORM

1. NAME

LAST

6. HOME MAILING ADDRESS

FIRST MIDDLE

2. SSN _

3. DATE OF BIRTH

4. SEX MALE FEMALE

5. DEPARTMENT ASSIGNED:

EXPOSURE INFORMATION

8. NOT INCLUDING THIS FACILITY - HAVE YOU EVER BEEN MONITORED - BY FILM BADGE OR TLD - FOR "OCCUPATIONAL DOSE TO RADIATION? (CIRCLE ONE)

9. NOT INCLUDING THIS FACILITY - HAVE YOU BEEN MONITORED - BY FILM BADGE OR TLD - FOR "OCCUPATIONAL DOSE TO RADIATION DURING THE CURRENT CALENDAR YEAR? (CIRCLE ONE)

10. HAVE YOU EVER BEEN MONITORED FOR OCCUPATIONAL DOSE BY THIS FACILITY? (CIRCLE ONE)

* IF YOU ANSWERED YES TO ITEMS 8 AND/OR 9, LIST ALL FACILITIES WHERE YOU WERE MONITORED ON

PAGE 2.

YES*

YES*

YES

NO

NO

NO

II. I HAVE RECEIVED AN (CHECK ONE) __ ESTIMATED -RECORD

OCCUPATIONAL DOSE (TEDE) IN THIS CURRENT YEAR ._..__OFIF MONITORED, BUT NO DOSE RECEIVED) (Initials).

OR

REM (INCLUDE ZERO

12. I HAVE NOT RECEIVED OR BEEN MONITORED FOR AN OCCUPATIONAL DOSE (TEDE) IN THIS CURRENTYEAR _ (State the Year - Ex. 2004) (Initials)

BY SIGNING BELOW, I ACKNOWLEDGE THAT ALL INFORMATION PROVIDED ON THIS FORM IS TRUE AND ACCURATE TO THE BEST OF M1KNOWLEDGE AND THIS INFORMATION SHALL BE USED TO DETERMINE MY ALLOWABLE CURRENT YEAR OCCUPATIONAL DOSE.

SIGNATURE. DATE:

RSO USE ONLY

TLD NUMBER ASSIGNED:

RAD-DOS-FR-0001 Page 1 of 2

LIST FACILITIES WHERE YOU WERE MONITORED DURING THE CURRENT OR PREVIOUS YEARS AND THE DOSE RECEIVED BELOW. IF YOl

HAVE DOSE RECORDS AVAILABLE, PLEASE INCLUDE COPIES IN THIS PACKAGE.

NAME/ADDRESS OF FACILITY DATES YOU WERE MONITORED DOSE RECEIVED (REM)

DDE CEDE

LDE CDE

SDE, WB TEDE

SDE. ME TODE

ARE THESE EXPOSURES RECORD OR ESTIMATE? ARE THESE ROUTINE OR PLANNED SPECIAL EXPOSURES?

.. RECORD .. ESTIMATE '" ROUTINE PSE

NAMEIADDRESS OF FACILITY DATES YOU WERE MONITORED DOSE RECEIVED (REM)

DDE CEDE

LDE CDE

SDF, WH TEDE

SDE, ME TODE


.. RECORD .. ESTIMATE .. ROUTINE PSE


DDE CEDE

LDE CDE

SDE, WB TEDE

SDE, ME TODE


.. RECORD .. ESTIMATE .. ROUTINE PSE


DDE CEDE

LDE CDE

SDE, WB TEDE

SDE, ME TODE


RECORD ESTIMATE .. ROUTINE .. PSE

BY SIGNING BELOW, I ACKNOWLEDGE THAT ALL INFORMATION PROVIDED ON TIUS FORM IS TRUE AND ACCURATE TO THE BEST OF MsKNOWLEDGE.

SIGNATURE: DATE:

RAD-DOS-FR-0001 Page 2 of 2

Notification to be Removed from Declared Pregnant Woman Status

SECTION I

Name: Badge #:

I am hereby notifying the RSO that I wish to be removed from DPW status.

I understand that my annual occupational administrative TEDE limit will be reestablished at the administrativedose limits.

Employee's Signature: Date: / /

Supervisor's Signature: Date: / /

SECTION II

The above named worker has been removed from DPW status and applicable administrative dose limits havebeen reestablished.

RSO: Date:

SECTION III

SECTION IV of the Declaration of Pregnancy form, DOS-FR-0005 has been completed.

RSO: Date:

Comments:

DOS-FR-0006 Page I of I

Rapiscan Pittsburg Site

Radiation Protection Work InstructionSubject: Document No.: Pages:

Radiation Work Permit Preparation, Review, Approval RAD-RWP-WI-0001 1 of 8and Use

Effective Date: Revision Date: Revision Level:

Reviewed By: RSO Approval:

1. PURPOSE AND SCOPE

This procedure describes the process for initiating, preparing, approving, and using Radiation WorkPermits (RWP's) prior to the activation of the linear accelerator at the Rapiscan Systems, Pittsburg, CAfacility.

2. REFERENCES

2.1 California Standards for Protection Against Radiation, Title 17, Division 1, Chapter 5,Subchapter 4, Group 3, California Department of Public Health, Radiologic Health Branch.

2.2 GUIDE FOR ACQUIRING RADIATION AL CHINES WHICH CAN OPERATEIN EXCESS OF 500 KVP, California Department of Public Health, Radiologic Health Branch.

2.3 Rapiscan Systems Radiation Safety Manual and Cargo Scanning Protocols

3. RESPONSIBILITIES

3.1 The Radiation Safety Committee has responsibility for review and approval of all programsassociated with the safe use of the accelerator.

3.2 The Radiation Safety Committee shall consist of the Radiation Safety Officer and one or moreindividuals trained or experienced in the safe use of accelerators.

3.3 The Radiation Safety Committee shall meet at least once a quarter or as deemed necessary. Arecord of the minutes from these meetings shall be recorded and maintained for review.

RAD-RWP-WI-0001 REV. 0 Pagel1 of 8

3.4 The Radiation Safety Officer (RSO) is responsible for:

3.4.1 Development, oversight and implementation of the RWP program as it applies to theactivation of an accelerator and the radiological controls to ensure compliance with theregulations and Rapiscan policies.

3.4.2 Review of doses received due to operations performed under RWP's.

3.4.3 Recognizing and implementing additional controls to ensure that work performeduinder RWP's is ALARA.

3.4.4 Review and approval of RWP's.

3.4.5 Suspending or terminating activities being performed under a RWP when requiredbased upon worker safety considerations.

3.5 The Project Leader is responsible for:

3.5.1 Integration and implementation of the Safety Program, as it applies to non-radiologicalhazards, into the RWP Program.

3.5.2 Assignment of personnel protective clothing and equipment requirements for non-radiological hazards.

3.5.3 Determining the safety related (e.g., OSHA) pennits and monitoring required for non-radiological hazards.

3.5.4 Specifying non-radiological training requirements for entries.

3.5.5 Recommending changes to work processes or equipment to ensure appropriate safetymeasures are taken.

3.5.6 Suspending or terminating activities being performed under a RWP when requiredbased upon worker safety considerations.

3.5.7 Ensuring personnel comply with Radiation Protection requirements.

3.5.8 Ensuring personnel are aware of the radiological and non-radiological conditions in thework area.

3.5.9 Informing the Radiation Safety Officer of any changes or anticipated changes in workscope.

3.5.10 Informing the Radiation Safety Officer when work performed under a RWP iscompleted.

RAD-RWP-WI-000 I REV. 0 Page 2 of 8

3.6 Qualified Accelerator Operators are responsible for:

3.6.1 Controlling access to and activities authorized by the RWP.

3.6.2 Informing support personnel of radiological and non-radiological conditions and of thepotential for those conditions to change.

3.6.3 Suspending or terminating activities being performed under a RWP when requiredbased upon radiological conditions.

3.6.4 Conducting surveys of radiological conditions and keeping accurate and legiblerecords.

3.6.5 Monitoring worker compliance with RWP requirements.

3.7 All Workers are responsible for the following:

3.7.1 Understanding the nature of work to be performed under the RWP through reading theRWP and directing questions regarding the RWP to the Radiation Safety Officer.

3.7.2 Attending pre-job briefs when required by the RWP.

3.7.3 Logging in on the correct RWP sign-in sheet.

3.7.4 Observing radiological and non-radiological postings.

3.7.5 Compliance with verbal and written instructions and procedures, including instructionson RWP's.

3.7.6 Maintaining an awareness of radiological and non-radiological conditions in the workarea.

3.7.7 Logging out of the RWP sign-in sheet.

3.7.8 Attending post-job debriefs when required.

4. DEFINITIONS

4.1 ALARA: Means "As Low as is Reasonably Achievable." The basic philosophy of radiationprotection is to maintain radiation exposures ALARA below the regulatory requirements."Reasonable" means that costs, benefits, and risks are considered in trying to keep doses low.

4.2 Constant or Continuous Coverage: Refers to job coverage where a dedicated radiation surveytechnician is assigned to provide coverage for individuals working under a Radiation WorkPermit (RWP) or performing a specified task covered by a RWP.

RAD-RWP-WI-0001 REV. 0 Pagre 3 of 8

4.3 Exclusion Area: The area controlled by the RSO, boundaries and postings in which no individualmay enter at any time during accelerator operations.

4.4 Radiation Work Permit (RWP)." A document prepared by the RSO, with input from the ProjectLeader, to inform individuals of radiological and non-radiological conditions that exist in theimmediate and adjacent areas surrounding the accelerator and all requirements and controls thatshall be in place prior to, during, or after entry to the scanning area.

4.5 Specific Radiation Work Permit: A RWP that describes the control measures in place foraccelerator operations. A Specific RWP shall only be authorized for use no more than 24 hours.

5. SAFETY PRECAUTIONS

5.1 The linear accelerator shall be operated in accordance with Reference 2.2 and shall not beactivated without the authorization of the Radiation Safety Officer in the form of a RadiationWork Permit (RWP).

6. OVERVIEW

A RWP is a document prepared by the Radiation Safety Officer, with input fi'om the Project Leader, toinform individuals of the conditions that exist in the work area and the radiological and non-radiologicalrequirements for the job. This procedure addresses initiation, preparation, approval, and use of an RWP.

7. PROCEDURE

7.1 Initiating a RWP

7.4.1 A RWP is required for all operations of the accelerator when and only when theaccelerator is to be activated.

7.4.2 The Project Leader or any "qualified" accelerator operator may request a SpecificRWP by completing RAD-RWP-FR-0001, Radiation Work Permit Request, using thefollowing guidance:

(1) Area where work is to be performed.

(2) The date of the request.

(3) Detailed description of the work to be performed. Attach additionaldocuments as necessary (e.g., work procedures, drawings, diagrams, etc.).

(4) Hazards or conditions that may occur as a result of this activity.

(5) An estimate of the total time the accelerator shall be activated within the24 hour period.

(6) Estimated start date and time.

RAD-RWP-WI-0001 REV. 0 Page 4 of 8

(7) Estimated completion date and time.

(8) Date that approval of the RWP is needed.

(9) Name (printed), initials, date, location, and phone extension.

(10) Additional comments as needed..

7.4.3 The Project Leader or qualified accelerator operator shall submit the RWP request tothe Radiation Safety Officer for review and evaluation.

7.4.4 The Radiation Safety Officer shall review the RWP request forn and resolve anyquestions with the requestor.

7.5 RWP Preparation

7.5.1 Preparation of the RWP shall be performed by the RSO using the request forn andinput from the Project Leader and other sources, as appropriate.

7.5.2 Assign the next available RWP Number, and record on RAD-RWP-FR-0005.

a. "Anticipated Area Dose Rate" - Enter the expected average and maximum workarea dose rates for each task in mrem/hr.

b. "Estimated Man-Rein" - Calculate an estimated man-rem for each task asfollows:

(1) Calculate the cumulative estimated external dose (DDE) for eachtask by multiplying the work area dose rate in mrern per hourtimes the man-hours to perform the task as follows:(2) Sum the external dose estimates to obtain the estimated man-remn for each task.

DDE (man - rem,) =imrem / hr x 0. 001 rem / mrem x man - hrc. Radiological Coverage Instructions.

(i) Check radiological coverage requirements when surveillance is required.

7.6 Approving a RWP

7.6.1 The Radiation Safety Officer shall review and approve all RWP's.

7.6.2 Approval shall be indicated by signature appearing in the APPROVALS section.

7.6.3 When the RWP is active, a copy of the RWP, and a copy of the most recent survey forthe area shall be maintained in the Operator's Room.

7.6.4 RWP Log-in sheets shall be collected and maintained on a daily basis and reviewed bythe RSO.


7.7 Using the RWP

7.7.1 The RSO shall:

a. Maintain the original copy of a RWP and any supporting documentation.

b. Post the following at the Operator's Room.

(2) A copy of the RWP.

(3) A copy of the most recent exclusion area boundary survey.

c. Conduct briefings as necessary or if radiological conditions or controls changethat warrant a briefing.

(1) Perform the briefing using a survey which reflects current conditions in thework area. The briefing should consist of:

(a) RWP requirements.

(b) Anticipated and actual radiological conditions in the area.

(c) Identification of actions which should be taken to reduce exposure.

(d) Special requirements of the RWP.

(2) Document the briefing on RAD-RWP-FR-0003.

d. Monitor work performed uinder RWP to ensure compliance with requirements.

e. IF any of the following conditions are met, THEN consider exercising stop workauthority:

(1) Work is not being conducted in accordance with the RWP.

(2) Radiological or job scope change has occurred such that the RWPrequirements are no longer adequate.

(3) Work is being performed or is anticipated to be performed in a manner thatis not in accordance with Radiation Protection Program policies,procedures or good Health Physics or ALARA practices.

7.7.2 Workers shall:

a. Read the RWP and other documents prior to the first entry.


b. Complete RAD-RWP-FR-0003.

NOTE

Signing in on RAD-RWP-FR-0004 indicates the individual has read and understandsthe requirements of the RWP.

7.8 Stoppage of Work on a RWP

7.8.1 Any individual may stop work when:

a. Work being performed under a RWP is outside the scope of the RWP.

b. Workers are not complying with the provisions of a RWP.

c.. Conditions vary from those described on the RWP and pose an immediate hazardto individuals in the area.

7.8.2 A "stop work" order given shall only be overruled or rescinded by the individualissuing the stop work order.

7.9 Terminating a RWP

7.9.1 A Radiation Work Permit issued for the activation of the accelerator shall only beissued for a 24 hour period.

7.9.2 At the end of the 24 hour period, if not sooner, the Operator's Room operator or otherqualified accelerator operator shall remove the RWP copy from the Operator's Roomand collect the completed RWP Log-In sheets and return these documents to the RSOfor termination.

7.9.2 When terminating the RWP:

a. The RSO shall review the RWP and the RWP Log-In sheets for accuracy and/oranomalies.

b. Write or stamp "TERMINATED" in RED on the RWP, sign and date.

c. Record the Termination Date on RAD-RWP-FR-0005.

8. RECORDS

8.1 The RSO shall maintain a notebook for each RWP. This folder should contain at a minimum:

8.1.1 The RWP request.

8.1.2 The Original RWP


8.1.3

8.1.4

Results of all radiation surveys perfonmed.

The Radiation Work Permit Log-In Sheets

9. FORMS

RAD-RWP-FR-0001

RAD-RWP-FR-0002

RAD-RWP-FR-0003

RAD-RWP-FR-0004

RAD-RWP-FR-0005

Radiation Work Permit Request

Radiation Work Permit

Radiation Work Permit ALARA Brief Attendance

Radiation Work Permit Log-In Sheet

Radiation Work Permit Log


CL-w.2

"E P%-.

-y " ,PITNEY BOWES

02 1P $ 009.3700002184697 SEP 22 2011

MAILED FROM ZIPCODE94085.

Document Control Desk, Director

Office of Nuclear Safety and Safeguards

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

rapiscan systems, submittal of radiation protection plan. · rapiscan laboratories, inc radiation...

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