Health Physics Questions and Answers - Question 228

Question 228: A licensee (e.g., radiographer, moisture density gauge operator, well logger) has a source that the licensee transports to temporary job sites in a licensee-owned vehicle. 10 CFR 20.1906 (f) exempts the licensee from doing contamination surveys during routine operations, but does not exempt the licensee from performing surveys for radiation levels.

(a) When must the licensee perform such surveys (i.e., when is the package "received")? Is it only after returning to the storage location at the end of the day?

(b) Or is each transport from one temporary site to another considered a shipment, with a "receipt" at each job site?

Answer:

(a) The source should be surveyed at the end of the work day, just prior to or immediately after storage. If the package contains quantities less than a Type A quantity, the licensee is not required to survey the surface of the package for radiation levels. If the package contains quantities of radioactive material in excess of a Type A quantity, as defined in 10 CFR 71.4 and Appendix A to 10 CFR Part 71, the licensee, in accordance with 10 CFR 20.1906 (c), shall perform monitoring as soon as practicable but not later than 3 hours after the package is received at the licensee's facility if it is received during the licensee's normal working hours, or not later than 3 hours from the beginning of the next working day if it is received after working hours.

(b) No. The package "is received at the licensee facility" when it is returned to the storage location at the end of the day. It is not necessary to survey radiation levels at temporary job sites.

(Reference: 10 CFR 20.1906, 71.4)