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DUTIES AND RESPONSIBILITIES

OF
THE RADIATION SAFETY OFFICER

In behalf of the Licensee, Readycon Trading and Construction Corp. the following are the
Duties and Responsibilities of the appointed Radiological Health & Safety Officer
(ARHSO) in the absence and in the support of the RHSO:

1. To ensure and implement all Safety Programs under CPR Part 3, Part 4, & Part 16
applicable to portable nucleonic gauges or devices as well as the following specific
Radiation safety Programs:
8.2 Training program
8.3 Personnel Monitoring Program
8.4 Radiation Detection Instrument(s) and Radiation Monitoring Program
8.5 Leak Testing of the Nucleonic Device
8.6 Maintenance of the Nucleonic Device
8.7 Transportation of Devices to Field Locations (applicable only to portable
gauges)
8.8. Operating and Emergency Procedures
8.9 Annual Audit of radiation Safety Program
8.10 Inventories of
8.11 Record Keeping Requirements
8.12 Security Measures for Radioactive Materials against Theft or Malevolent Use
8.13 Waste Management

2. To ensure that all terms and conditions of the PNRI License of the Licensee are
being met and that the information contained in the license are up-to-date.
3. To ensure that all users have read and understood the Licensees Safety Operation
and Emergency Procedures.
4. To ensure that the use of nucleonic device is only by authorized individuals or
operators.
5. To ensure the safety of all authorized users, office personnel and public from
unnecessary exposures to ionizing radiation of the nucleonic device.
6. To ensure the safety of the nucleonic device or sealed sources from lost and
damage.
7. In case of theft the nucleonic device, to notify immediately the proper authorities:
Security Guards, Barangay Chairman, Tanods, Police, Administrative Manager
and the PNRI for assistance for the immediate retrieval.
8. To serve as the contact person to give assistance and all information to PNRI
Officers and authorities in case of theft, emergency or damage of the nucleonic
device.
9. To have on hand as references CPR Part 3, Part4 and Part 16 and all other PNRI
required radiation safety and security manuals and pamphlets.
8.2 TRAINING PROGRAM/SYLLABUS

1. All supervisors and operators working near or operating nucleonic devices are
subject to the limits on occupational exposures and therefore, must attend a
Factory Radiation Safety Course to be conducted by the RSHO to be designated
as an authorized operator.
2. The Factory Radiation Safety Training Course will deal on the following topics:
A. Radiation Physics – (2 hrs.)
a. Atomic Structures
b. Radiation Measurement
B. Radiological Safety – (8 hrs.)
a. Radiation Exposure Unit
b. Effects of Radiation Exposure
c. Methods of Reduce Exposure
d. Occupation Exposure Limits
e. Personnel Monitoring
C. Regulatory Requirements – (2 hrs.)
a. Licensing
b. Storage
c. Disposal
d. Incidents
e. Record Keeping
f. Safety Program
g. Leak Test
D. Transportation and Shipping – (2hrs.)
a. Test and Certification
b. Labeling
c. Transportation by Motor Vehicle or Common Carrier
E. Emergency Program – (2 hrs.)
F. Gauge Security Program – (2 hrs.)
G. Equipment and Maintenance – (4 hrs.)
H. Equipment Surveying (Survey Meter Application) & Gauge Operation – (4hrs.)
8.3 PERSONNEL MONITORING PROGRAM

1. The Licensee through his RHSO will secure film badges from the PNRI Radiation
Protection Section for each of their authorized operators, supervisor, ARHSO and
RHSO working with the nucleonic device to monitor their monthly radiation dose
absorbed.

2. The RHSO will ensure that all authorized users or personnel will be issued a personal
Film Badge for each one of them working with nucleonic device.

3. The RHSO will secure new Film Badges from PNRI, Radiation Protection Service
every 60 days for each authorized operators and personnel working with the nucleonic
devices.

4. The RHSO will ensure that all authorized users or personnel that will be exposed
regularly to the radiations of nucleonic device will be wearing their assigned Film
Badge at all times during operations or maintenance.

5. The RHSO will return to PNRI Radiation Protection Section all used and unused film
badges from all authorized users for exposure processing as well as to secure new
film badges every 60 days.

6. The RHSO will maintain a Record File of the PNRI Film Badges Exposure Reports
every 60 days for each authorized users.

7. The RHSO will provide each authorized user their individual personal exposure report
every 60 days and its total yearly exposure throughout the use of nucleonic device in
the project to make sure that the individual user does not exceed the yearly allowable
maximum exposure limit.

8. The RHSO will provide all personnel their total radiation exposure report that has
resigned and will request for their total exposure report for all the years exposed during
work for their new job in another company for the monitoring of their continuous
radiation exposure and limit.

9. The RHSO will investigate each authorized users that has unusually high exposure
report to prevent or decrease unnecessary exposures of the users in the next period.

10. A Film Badge Rack will be installed at a non-radiation area convenient to all film
badges after work.

11. The RHSO will ensure that the Film Badges are properly worn on the torso area of the
body of the users. It is clipped on the shirt pockets or collar of the user.

12. The Control Film Badge will always be placed in the Film Badge Rack.

13. All authorized users will have their own personal Film Badge assigned to themselves
placed in a designated section in the Rack to avoid picking up and wearing the wrong
Film Badge.

14. Film Badges are not shared nor borrowed.


8.4 RADIATION DETECTION INSTRUMENTS & RADIATION MONITORING
PROGRAM

1. The Radiological Health and Safety Officer (RHSO) will ensure at all times that a
radiation detection instrument or survey meter with a range of 10 uSv through 10
mSv per hour will be available at all times to monitor the radiations emitted by the
nucleonic device in accordance to its factory Radiation Profile at each jobsite.

2. The RHSO will ensure that the Radiation Detection Instrument of Survey Meter is
calibrated every twelve (12) months by PNRI Radiation Protection Section.

3. The RHSO will ensure that the Calibration Certificates for each Radiation Detection
Instruments or Survey Meters are accordingly filed in the Survey Meter Radiation
Readings Record File.

4. The RHSO must ensure that all authorized operators of nucleonic devices are
properly trained in the use of the Survey Meter and the recording of radiation
readings accordingly filed in the Survey Meter Radiation Readings Record File.

5. The RHSO will ensure that all authorized operators must have a Survey Meter for
monitoring the radiation of the nucleonic device being used in separate areas of
their project.

6. The RHSO will ensure that the portable nucleonic device will be surveyed for its
radiations at its 1-meter distances from the top, rear, front and sides and similarly
at its surfaces before and after use.

7. The RHSO will ensure that all Survey Meter Readings for each nucleonic devices
taken before and after its use, will be filed accordingly in each Survey Meter
Radiation Readings Record File.

8. The RHSO will ensure that before and after servicing or maintenance, the
nucleonic device will be surveyed for its radiations at all sides, recorded and filed
in its Survey Meter Radiation Readings Record File. The nucleonic device may be
leaking if Radiation Readings taken from it are unusually higher than the Factory
Radiation Profile or Isodose Curve or radiation readings detected are higher than
185 Bq.

9. The RHSO must ensure that defective Survey Meters will be replaced immediately.
8.5 LEAK TESTING PROGRAM

1. The RHSO will ensure that all nucleonic device or devices in use or stored will
Leak Tested every six (6) months by the PNRI Radiation Protection Section.

2. The RHSO will obtain from the PNRI the Leak Test Certificate for each nucleonic
device Leak Tested.

3. The RHSO will file the Leak Test Certificates accordingly in the Leak Test
Certificate Record File.

4. The RHSO will ensure that the proper transport of the nucleonic device will be
done in accordance to PNRI CPR Part 4 procedures to transport the nucleonic
device to the PNRI Radiation Protection Section from its Storage Facility and back
after the Leak Test Procedure.

5. Leak Test Readings above 185 Bq or higher than the nucleonic device’s Factory
Radiation Profile or Isodose Curve means that the nucleonic device maybe
leaking. In this case, arrangements with PNRI and Vicstar shall be discussed
whether the nucleonic device will be repaired or disposed.

6. Leaking nucleonic device cannot be shipped back to the manufacturer. Therefore,


arrangements for the disposal of the nucleonic device should be made with PNRI.
8.6 MAINTENANCE PROGRAM

1. The RHSO will ensure that only authorized operators or those designated to
handle maintenance will be allowed to perform maintenance on the nucleonic
device on their scheduled maintenance periods.

2. The RHSO will ensure that only experienced electronic technicians from the
nucleonic device authorized distributor will be allowed to handle repair and
services in accordance with the Maintenance & Service manual of the
manufacturer.

3. The RHSO will ensure that maintenance of the nucleonic device will be in
accordance to the Periodic Maintenance and Service Procedures from the
manufacturer.

4. The RHSO will ensure that Survey Meter Readings taken before and after the
maintenance or service procedures at one (1) meter distances and surfaces at all
sides of the nucleonic device.

5. The RHSO will ensure that Survey Meter Readings taken before and after the
maintenance or service procedures will be filed accordingly in the nucleonic
device’s Survey Meter Readings Record File.

6. The RHSO will ensure that no removal of the Sealed Sources will be allowed.

7. The RHSO will ensure that authorized operators or technicians designated to


perform maintenance or repair services on the nucleonic device must wear their
personal Film Badges at all times during the procedures.
8.7 TRANSPORTATION OF DEVICES TO FIELD LOCATION PROGRAM

1. The RHSO will ensure that Survey Meter Readings will be taken on the nucleonic
device from one (1) meter distances from all sides and from all the surfaces of the
nucleonic device before and after transport and filed accordingly in the Survey
Meter Readings Record File.

2. The RHSO will ensure that the nucleonic device will not be allowed for transport if
Survey Meter Readings are higher than the Factory Radiation Profile or its isodose
curve.

3. The RHSO will ensure that CPR Part 4 will be complied within the transport of the
nucleonic device.

4. The RHSO will ensure that all authorized operators assigned to transport the
nucleonic device are wearing their Film Badges and are carrying a Survey Meter.

5. The RHSO will ensure that the nucleonic device is encased in its usual DOT 7A
Type A Shipping or Carrying Case with Yellow II Label 0.5 Transport Index.

6. The RHSO will ensure that the nucleonic device will be transported in the trunk or
at the rear most area of the transport enclosed van.

7. The RHSO will ensure that the transport vehicle or van is locked and secured
properly to prevent the nucleonic device from getting stolen during transport or
while in the use in the field.

8. The RHSO will ensure that at every withdrawal of the nucleonic device from its
storage facility as well as its return must be properly recorded and filed in its
Storage/Withdrawal Record File.

9. The RHSO will ensure that in the field, the nucleonic device is stored in a suitable
locked storage room against theft and damage.

10. The RHSO will ensure that authorized operators transporting the nucleonic device
are carrying with them a proper Transport Certificate from the origin of the
nucleonic device (storage facility) to its project destination or outside its licensed
area and back to its origin. A copy of the Transport Certificate should always be
filed in its Transport Certificate Record File.
8.8 OPERATING & EMERGENCY PROCEDURE

1. Operating Procedures (Please See Attached)

2. In case of an emergency (fire, earthquake, and etc.), the designated operator must
exhaust all means to close the shutter of the Troxler Gauge.

3. In case of accident or damage to the Troxler Gauge, the RHSO or authorized users
must survey the Troxler Gauge with a Survey Meter for any unusual or excessive
radiation over the indicated allowable Radiation Readings.

4. If the Troxler Gauge had been damaged and found leaking or has unusual high
radiation readings, the area must be cordoned off to everyone to the dose rate that
is safe at a radiation of 5 meters away from the Gauge or the gauge is immediately
packed in its transport case and stored in its storage room.

5. The damaged Troxler Gauge must never be left unattended.

6. The RHSO must make a record of the incidents, accidents and the appropriate
action made and file a formal report at the PNRI within 24 hours from the time of
the incident.

7. The RHSO should also request PNRI for further advice and investigation if needed.

8. The RHSO should also inform the manufacturer or their agent for advice for the
possible repair or disposal of the Troxler Gauge.

9. In case of theft, RHSO will do all means to recover the Troxler Gauges & report
the theft immediately to the police for recovery and the PNRI.

10. The RHSO should keep PNRI informed of the status of the lost Gauge every month
or immediately the moment it is recovered.
8.9 ANNUAL AUDIT OF RADIATION SAFETY PROGRAM

1. The RHSO will ensure to audit or review annually together with his ARHSO and
authorized operators all their Radiation Safety Programs if they are accordingly
implemented or not.

2. The RHSO will ensure to audit and review annually together with his ARHSO and
authorized operators the applicability of all Radiation Safety Programs and delete
inapplicable Safety Programs.

3. The RHSO will ensure to determine together with his ARHSO and authorized
operators will new applicable Radiation Safety Programs to be included with the
existing Radiation Safety Program to improve them.

4. Penalties will be discussed to be imposed on those found to be lacking in the


implementation of the Radiation Safety Programs.
8.10 INVENTORIES PROGRAM

1. The RHSO will ensure the proper recordings at all times of the in and out of the
nucleonic device or devices from its storage facility and to be aware of its physical
location at all times.

2. The RHSO will ensure the proper recording of new additional nucleonic devices
and the total inventory of their good and spent nucleonic devices in their storage
facility.

3. The RHSO will ensure that the nucleonic devices are physically accounted for in
the storage facility weekly before the weekend and after the weekend.

4. The RHSO will ensure that the nucleonic devices are accounted for weekly and
properly protected by security during long vacations and resignations of the RHSO
and ARHSO.

5. The RHSO will file with the PNRI the Annual Inventory Report of their nucleonic
devices on-hand and disposed.
8.11 RECORD KEEPING REQUIREMENTS

1. The RHSO will ensure to maintain a complete Annual Inventory Report Record
File for all the nucleonic devices on-hand and disposed by the company.

2. The RHSO will ensure to maintain a complete Certificate of Calibration Record File
for the yearly re-calibration of the Survey Meters being used.

3. The RHSO will ensure to maintain a complete PNRI Leak Test Certificates Record
File for the leak testing certificates for each of the nucleonic devices.

4. The RHSO will ensure to maintain a complete PNRI Film Badge Exposure Reports
Record File for each authorized operators.

5. The RHSO will ensure a complete Survey Meter Readings Report Record File for
each of the nucleonic devices.

6. The RHSO will maintain a complete PNRI Yearly Storage Facility inspection
Report Record File.

7. The RHSO will maintain a complete yearly PNRI Radioactive Materials License
Record File of the company.

8. The RHSO will maintain a complete Waste Management Report Record File for
spent nucleonic devices if any.

9. The RHSO will ensure to maintain each record for three years or until the sealed
source is transferred or disposed. Records of personnel and nucleonic device
radiation monitoring shall be kept and preserved until PNRI authorizes their
disposition.
9. SECURITY MEASURES FOR RADIOACTIVE MATERIALS AGAINST THEFT OR
MALEVOLENT USE

The RHSO ensure to establish a Security Plan against unauthorized use, theft, lost or
damaged of the nucleonic devices used for the rapid determination of wet density, dry
density, moisture content, % moisture, % voids, %compaction, of soil sub-bases asphalt
pavement in road or authorized operators and company security while the nucleonic
device or devices are present in the company’s premises or project area and when in
transport.

1. The RHSO will ensure to have a Security Plan in Storage for the nucleonic devices as
follows:

a) The Storage Facility will be made of concrete, concrete blocks and steel door with
heavy duty padlock for the storage of the nucleonic devices when not in use.

b) The Storage Facility will be constructed as much as possible to be fire, water and
most of all, burglar proofed located in the area that will be safe for the public and
from any heavy vehicle accidents that may damage the nucleonic devices in
storage.

c) The Storage Facility must be located at a site that is easily guarded at all times by
the company security guards.

d) The Storage Facility will have only one suitable common steel padlocked door
entrance and exit for authorized personnel storing or withdrawing the nucleonic
devices visible to security personnel.

e) The Storage Facility will be marked at all sides with the usual radioactive warning
signs.

f) The steel door entrance of the Storage Facility will have a warning sign “For
Authorized Personnel Only” installed or painted on.

g) A Perimeter Fence made of cyclone wires will be installed around at a minimum


distance of 1-2 meters away from the Storage Facility high enough to prevent entry
over the fence of unauthorized people or loiter near on in the Storage Facility Area.

h) The Perimeter Fence will have a warning sign “For Authorized Personnel Only”
installed at the front entrance and at all sides of the fence.

i) A heavy duty Padlock will also be installed at the entrance gate of the Perimeter
Fence.

j) A red warning flashlight light will light up as well as an alarm bell sounding out,
maybe installed whenever the entrance gates of the Perimeter Fence and Storage
Facility are opened to warn all concerned with security of the nucleonic devices of
legal or illegal intrusion by authorized or non-authorized personnel.

k) A burglar alarm may also be installed in the Storage Facility to quickly alert
everyone in case of theft or unauthorized removal of Nucleonic Devices.

l) The Security Agency of the company must be informed accordingly by


management that it is also their duty to ensure the security of the nucleonic device
from theft and unauthorized removal from their Storage Facility.
m) The Security Agency will be held liable in case of theft or unauthorized removal of
the nucleonic devices inside their Storage Facility in their area of responsibility.

n) The Security Guards of the company should inspect the presence of the nucleonic
devices in the Storage Facility and should be aware of their location 24 hours a
day.

o) The Security Office and personnel assigned must maintain securely and safely the
Keys of Padlocks of the Storage Facility and Perimeter Fence gate.

p) The Security Guards assigned must always escort or accompany authorized


personnel to the Storage Facility and open the designated Padlocks.

q) The Security Guards assigned must always secure a written permit from the RHSO
or ARHSO in the absence of RHSO authorizing the authorized personnel or
operators to withdraw and transport the nucleonic devices to their designated
project sites.

r) The Security Guard that received the written permit to withdraw the nucleonic
device or devices must file the written permit in a specific Withdrawal Permit
Record File for record purposes.

s) The Security Guard should also log in their proper logbook each time the nucleonic
devices are withdrawn and returned into the Storage Facility.

t) The RHSO shall be the only authorized signatory of the written withdrawal permit
or the ARHSO in the absence of RHO.

u) The written withdrawal permit for the nucleonic devices must be in triplicate or
more indicating the present or withdrawal date, the purpose of the withdrawal of
the nucleonic devices, the serial numbers of the nucleonic devices, the testing site
where the nucleonic devices will be used, when the device will be returned and the
printed name of the drawee with his or her signature signed over the name.

v) A copy of the withdrawal permit for the nucleonic devices must be kept on file by
the RHSO for Record Keeping, the original copy to be presented to the Security
Guard concerned with the Storage Facility and security of the nucleonic devices
for their specific file and a copy for the drawee signed by the security guard for the
drawee to present to anyone concerned when inspected to show proof of
authorized use of the nucleonic device or devices.

w) The RHSO, ARHSO and all the authorized operators will be the only personnel
allowed to enter the perimeter area and the Storage Facility of the nucleonic
device.

x) The names of the RHSO, ARHSO and all the authorized operators will be
submitted to the Security Office for all Security Guards to allow only them in the
Storage Facility.

y) Anyone unauthorized seen or caught in the Perimeter Fence should be replaced


immediately apprehended and brought out for investigation for violating the
Security Plan.

z) The Padlocks of the Storage Facility and Perimeter Fence should be replaced
immediately if found faulty, tampered or its keys reproduced without authorization.

2. The Security Plan of the Troxler Nuclear Moisture-Density Gauges during transport
are the following:
a) Only the authorized operators of the RHSO will be allowed to transport the
nucleonic devices to their jobsites and return them back to their Storage Facility
accordingly after use.

b) Only closed van transport vehicle with heavy duty rear door will be used for the
transport of the nucleonic devices to jobsites.

c) The nucleonic devices must always be transported in their Standard Transport


Case locked as well as their Standard Transport Cases.

d) The driver of the closed transport van will drive the van safely to avoid unnecessary
accidents travelling to the jobsites.

e) The nucleonic devices will be brought to jobsites within the licensed area only.

f) If the nucleonic devices will be used outside the licensed area, CPR Part4 must be
complied with and a Transport Certificate will be issued by the RHSO to
accompany the nucleonic device prior to scheduled trip.

g) All authorized operators must assure the security of the nucleonic devices against
theft, lost or damage at all times under their care.

h) During breaks or rest time, a good temporary locked Storage Facility for the
nucleonic devices must be located and used.

i) All authorized users must bring along in the field a couple of heavy duty Padlocks
to lock the nucleonic devices in a temporary Storage facility.

j) The nucleonic devices must be locked inside their Standard Transport Cases as
well as the Transport Cases padlocked while in the temporary Storage Facility.

k) In the field and quite far from the Storage Facility of the nucleonic devices, the
closed transport van securely locked may be used as a temporary storage facility
for the nucleonic devices locked in their locked Standard Transport Cases if no
good temporary Storage Facility could be found.

l) The closed transport van must be equipped with a reliable anti-theft alarm device
to warn all those concerned if there is unauthorized entry in the transport van and
to prevent carnaping of the transport van while it is parked.

m) A security guard within the project jobsite if available should be assigned to guard
the transport van while it is parked.

n) The transport van should be parked in a secured and guarded parking area while
the authorized operators are at rest.

o) The closed transport vans must be well secured from theft or carnaping whenever
it is used as a temporary Storage Facility.

p) The RHSO or ARHSO must be informed by the authorized operators and for
advice if returning the nucleonic devices to its actual Storage Facility will be
impractical with their present location and situation.

q) The RHSO must give all the authorized users a written instruction and contact
numbers on how to immediately contact him or her or the ARHSO in case of
emergencies, accidents, theft or loss of the nucleonic devices at the field.
3. Emergency Plans in case of theft, lost or damaged for the nucleonic devices in the
storage facility or in transit:

a) The RHSO must have on hand the contact numbers of the nearest police
department and barangay official to inform them immediately of the loss of their
nucleonic devices and to request them for their full assistance and cooperation to
recover the lost nucleonic device.

b) The Security Agency of the company must also inform immediately the nearest
police department and barangay officials for the theft or loss of nucleonic device
or devices and their assistance to recover them.

c) The Security Agency of the company must inform the RHSO immediately about
the theft or loss of the nucleonic device or devices for his information and advice
for their immediate recovery.

d) The RHSO must provide the Security Agency, his ARHSO and all authorized
operators his immediate contact number in case of emergencies, theft or loss of
the nucleonic devices.

e) The ARHSO should be trained or capable to act in behalf of their RHSO in case of
emergencies, theft or loss of the nucleonic devices when the RHSO is still
unavailable.

f) The RHSO must have several colored pictures of the nucleonic devices on hand
to distribute among all those concerned in the recovery of the lost nucleonic
devices for their easy reference.

g) All authorized operators should be trained in what to do or contact first in case of


loss of the nucleonic devices in their care in the field.

h) All authorized operators must have on hand always the contact numbers or the
nearest police department, barangay officials, RHSO and ARHSO.

i) The authorized operators should immediately inform the police and barangay
officials in case of theft or loss of nucleonic devices for their immediate recovery
and their RHSO for his immediate response to the incident.

j) If seen to be good, the management of the company should offer a reward with no
questions asked for the immediate return of the lost nucleonic devices.

k) Management should place an announcement in the town’s newspaper and in a


good nationwide circulated newspaper for anyone to give information for the
immediate recovery or return of their lost nucleonic device or devices.

l) The RHSO must inform PNRI immediately of the loss of their nucleonic device or
devices and submit as soon as possible a written incident report on the matter
within 30 days after the incident.

m) The RHSO, management, the Security Agency and all concerned in the company
must exhaust all means to retrieve the lost nucleonic device or devices.

n) The RHSO will inform the PNRI monthly on the developments in their work to
retrieve the lost nucleonic device or devices.

o) The RHSO will continue to maintain their Radioactive Material License and
implement all the requirement of the license even if their nucleonic device or
devices have not been found.
p) When the RHSO resigns from his or her job, he or she must immediately turn-over
all his duties and responsibilities properly to his Assistant RHSO and the Safety
Manager or Project Manager also advised of the resignation to take over
immediately the Security of the nucleonic devices in case they have no ARHSO
until they have a new RHSO.

q) The Safety and Project Managers of the company must formally designated the
new RHSO and Assistant RHSO immediately to take over the job and Radiation
Safety Programs of the previous RHSO.

r) The new RHSO must immediately amend the company’s PNRI Radioactive
Materials License to correct all changes in their authorized operators if any.

s) The Safety Manager or Project Manager must notify PNRI of the loss of their RHSO
and/or ARHSO and will make immediate arrangements with PNRI to allow them to
take responsibility if possible in securing the nucleonic devices at their storage
facility at all time, to cease and desist in using them until they have a new RHSO
and ARHSO.

t) Id the company has more projects or use for the nucleonic devices in the time
being, all nucleonic devices must be temporarily stored at the PNRI for safe
keeping if they no longer have an RHSO to continue all the Radiation Safety
Programs and the requirements of their license.

u) The RHSO, ARHSO, Security Agency of the company and all authorized operators
will review annually their present Security Plan to see if all plans are applicable
and additional security plans or measures should be added.

v) The RHSO will have a mock trial yearly of their Security Plans for theft, lost or in
case of accidents for their nucleonic devices to train everyone concerned for their
proper emergency response to the situations.
10. WASTE MANAGEMENT

1. The RHSO will maintain an Annual Inventory Report Record File and a file for all the
nucleonic devices of the licensee disposed or returned to the supplier or
manufacturer.

2. The RHSO will ensure that depleted or damaged nucleonic devices are returned to
the manufacturer for disposal if not leaking.

3. If the Licensee encounters difficulty in shipping the damaged nucleonic devices to


the manufacturer, the RHSO will make arrangements with the PNRI for the proper
disposal of the damaged nucleonic devices at this end.

4. The RHSO will arrange with PNRI the safe transport of the damaged nucleonic
device to the supplier of manufacturer in accordance to CPR Part 4 if applicable.

5. The RHSO will estimate amount of activity of waste involved and is calculated from
the date of measurement of the activity of the sealed sources after it was
manufactured found in the Gauge Certificate using the half-life formula.

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