ML20077S707

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Forwards Regulatory Impact Survey Being Administered for NRC
ML20077S707
Person / Time
Site: Washington State University
Issue date: 08/26/1994
From: Petrie R
WASHINGTON STATE UNIV., PULLMAN, WA
To: Stohr J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 9501240215
Download: ML20077S707 (10)


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{WashingtonStateUniversity  ;

E Socal and Econome Sciences Research Center Wilson Hall 133 Puttman WA 99164-4014 509 335-1511 ,

FAX 509 335-0116 l

August 26,1994 l l

L Philip Stohr l USNRC Region 11 I 101 Marietta Street NW Suite 2900 l Atlanta, GA 30323-0199

Dear Mr. Stohr:

Enclosed is a copy of the Regulatory Impact Survey our Center is administering for the Nuclear Regulatory Commission. 'Ihe Nuclear Regulatory Commission requested I send you a copy of this .

survey for your files. l 1

You may have already received a copy addressed to you and Douglas Collins. After looking closer at

.i NRC's request, I realized I should have sent separate copies to each of you. I'm sorry for any I inconvenience this may have caused. -j iI i

Sincerely, Lu

bkM is Renee S. Petrie Study Director i

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TO: NRC Materials Licensees FROM: Carl J. Paperiello, Director i Division of industrial and Medical Nnicar Safety Office of Nuclear Material Safety and Safeguards .;

SUlUECT: REGULATORY IMPACT SURVEY j

' I need your help. Enclosed is a survey to determine your views on the impact of the Nuclear Regulatory Conunission's regulatory activities on your licensed operation.

We will use the information from the survey to detennine how we can minimize adverse impacts on licensees

- such as yourself, while still achieving our goal of safety. We are seeking your views on the value of our regula- . .)

tions and policies. We also want your views on the licensing process, the inspection process, reporting require- j ments and enforcement. Although the survey consists of a set of questions, space is provided for additional ]

comments.

Since this survey is being sent to a random sample oflicensees, your voluntary participation is very important to the success of this project. Your frank views are important.The survey is being administered for the NRC by .:

i Pacific Northwest Laboratory (PNL) under contract to the NRC. The questionnaire is designed so as not to reveal your identity and no one at the NRC will see any completed questionnaire. About 600 surveys are being conducted. Results will be published in the NMSS Licensee Newsletter. g We anticipate that it will'take approximately 45 minutes' to complete, if you have any questions regarding this questionnaire, please call Robin Conger or Mark if attrup, PNL survey administrators, at (509) 372-4687.

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Carl J. Paperiello, Director Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards 1

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dONFIDENTIALITY STATEMENT: THE RESULTS OF THIS SURVEY WILL BE USED TO ASSIST THE NRC IN BETTER DETERMINING THE EFFECT OF ITS REGULATORY PROGRAM ON NUCLEAR SAFETY ALL INFORMATION PRO-VIDED WILL BE TREATED AS CONFIDENTIAL. ONLY MEMBERS OF THE SURVEY TEAM AND DESIGNATED ANALYSTS WILL BE PERMITTED ACCESS TO THE QUESTIONNAIRE DATA. YOUR RESPONSES WILL BE GROUPED WITH ALL OTHER RESPONDENTS FOR PURPOSES OF ANALYSIS AND WILL NOT BE REPORTED AS INDIVIDUAL ANSWERS.

(REGUL'ATIONS, POLICIES AND 3. Thinking back over the past 3 years, do you believe that the number of NRC regulations apph,-

tREGULATO_R,Y GUIDANCE cable to your licensed activity has... (Please circle The purpose of this section of the survey is to obtain Only000TOSPODSOl your porception4mgarding 1) the cost of NRC '-1. locreased si0nificantly .

regulations. 2) the usefulness of NRC regulations, 2. increased comewhat and 3) the safety impact of NRC regulations.

3. remained about Ih'o sam. e.-
4. decreased somewhat

.5f docreased significantly ;

1. How would you describe your level of knowledge of each of the following NRC regulatory docu-monts applicable to your licensed activities? 4. Thinking back over the past 3 years, do you (Please circle one response per document type-) believe the popLof comptying with NRC regula-tions has... (Please circio only one response.)

Very High _1. increased significantly High 2. increased somewhat Average ' 3. remained about the same -

Low 4. decreased somewhat Very Low 5. decreased significantlys

[ Regulations' , . 1 2 3 4 5 Regulatory Guides 1. 2 3 4 5 5.- NRC is interested in obtaining your perceptions J Policy Statements 1 2 3 4 5 about the cost of complying with some specific +

Oconse Conditions 1 2 3 4 5 NRC regulations versus the overall safety impact EBranch Technical Positions 1 2 3 4 5 of those regulations on your facility.

Information Notices 1 2 3 4 5 To what extent does each of the regulations listed below contribute to the safe operation of your facility? (Please circle the number that best repre-

2. During the past 2 years, how many times have you sents your opinion. Use NA if the regulation does not used outside consultants to assist you in each of apply to your heensed activity.)

tho following areas? (Please indicate the approxt-mate number of times in the space provided; if you Very High Contribution have not used a consultant. enter a ~0")

Need for Consultants: Number of Times Used To understand regulations _. N p i To understand the new 10 CFR Part 20 ~

To conduct training . .[ < a PART 19 - Communicatlon/ Reports to Workers NA 1 2 3 4 5 To conduct intomal audds' _ _ _ _

)' To subnut a license appbcation _

b PART 20 - Rad!ation Protection (now Part 20) NA 1 2 3 4 5 To submit a license amendment _ _

To submit a . license renewal request _ l.- . . c. PART 30 - Byproduct Matena! Licensing . NA 1 2 3 4 5 Other (specify); _

d. PART 33. Broad Scope NA 1 2 3 4 5 e.PART 34 + Radiography . NA 1 2 3 4 5
f. PART 35 - Medical Use NA 1 2 3 4 5
g. PART 36 - IrradotorS NA l' 2 3 4 5
h. PART 39 - Wel! Logging NA 1 2 3 4 5
1. PART 40 - Source Material NA 1 2 3 4 5 I PART 70 - Special Nuclear Matena! NA 1 2 3 4 5

- k. PART 71 - Transportation NA 1 2 3 '4 5l

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. 5

6. How would you rate the cost of complying with 9. How usefulis each of the regulatory guides listed each of the NRC regulations listed below? (Please below? (Please circle the number that best repre-circio the number that best represents your opinion. sents your opinion. Use NA if the regulatory guide ,

Use NA if the regulation does not apply to your does not apply to your licensed activity) licensed activity) .  ;

High Very Useful r i

Low Not Useful Not applicable Not applicable ia. P^RT 19 Communication 1 / Reports to. a. Bioasssy Program (8.9)[ ,

NA 1 2 3 4 5 Workers NA i 2 3 4 5 b. Prenatal Radiation Exposure (8.13) NA 1 2 3 4 5

b. PART 20 - Radiation Protection c. Radiation. Safety Survey at Medical 1 (now Part 20) NA 2 3 4 ,5 Institutlons (8.23) / 2 3 4 5 NA

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c. PART 30 - Byproduct Matenal Licensing NA 1 2 3 4 5 d. Calibration of Air Sampling
d. PART 33 - Broad Scope NA 1 2 3 4 5 Instruments (8.25) NA 1 2 3 4 5 elPART 34 - Radiography NA 1 2 3 4 5 c. Occupational Radiation Exposure Risk .
f. PART 35 Medical Use NA 1 2 3 4 5 L (8.29) NA 1 2 3 4 5 "g. PART 36 - trradiators - NA 1 2 3 4 5 f. Tntium Bioassay Program (8.32) NA 1 2 3 4 5
h. PART 39 - We!! Logging NA 1 2 3 4 5 g. Quality Management Program (8.33) ; NA 1. 2 3 4 5

[ i.' PAP.T 40 - Source Material NA 1 2 3 4 5 h. Occupational Radiation Dose Calculation

j. PART 70 - Special Nuclear Matenal NA 1 2 3 4 5 I.8.34) NA 1 2 3 4 5  ;

i k.PART 71 Transportation NA 1 2 3 4 5 1. Radiation Doses to Embryo / Fetus (8.36) . NA 1 2 3 4 5 '

j. ALARA Levels of Effluents (8.37) NA 1 2 3 4 5 .
k. Preparation of Application for Licensed
7. Are there any sections within the regulations . Activity (Division 10 Guides)' NA 1 2 3 4 5 listed in the previous table that you believe are I. Other (Please specify) NA 1 2 3 4 5  ;

particularly effective at enhancing the safe opera- ,

tion of your facility? (Please identify the sections r (e.g., Mld(d), ?QJ6QL 35J 3510) and explain in 10.Have you ever provided comments on proposed ,

the space provided.) NRC regulations or guidance documents? (P/ case  :

circle all that apply for each document type.)

- _ . . . = -

Guidance Document Regulations yes R co ,

no, because the process is too time consuming R GD r no because the processjs too expensive F, oD

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no, because my input will have no impact n OD no, because the process is too difficult to understand ' R GD no, because I was not aware of them in time to comment R GD

' no, Secause I had no comments to make R Go

8. Are there any sections within the regulations no, other (Please specdy)^ n GD listed in the previous table that you believe are ~

counterproductive to the safe operation of your f aciiIty? (Please identify the sectrons (e.g ,19Jf.(d),

20J00L 35J:35J0) and explain in the space pro- 11.How valuable is the NMSS newsletter to you?

vided) (Please circle only one.)

1.' very valuable

2. sornewhat valuable 3 not very valuable ~

1 4 no value

5. do not receive it e % h a.e.g m re.m. -Wh-amen-..g ,-.-...e.now--ww.se *. suisewsaw emis,i.e.,.

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14. Thinking back to that last licensing action, to what

~t.lCENSl5G_ -- extent do you agree with each of the statements in The purpose of the next set of questions is to deter- the table below? (Pleaso circle only one responso -

mine how effectively and efficiently the NRC performs per statement.)

its licensing functions.

Strongly Agree Agree Neutral Disagree

12. Based on your licensing action (s)in the past 12 Strongly Disagree months (e.g., issuanco, renewal, amendment), to Not applicablo what extent do you agree with each of the state-a.The reviewers were professional

) ments in the table below? (Please circ /o ono ro, sponse por linc.) If you have not had a licensing O 'h" ' '*"d '" "# ' # U

b. The reviewers were hofpful. NA 1 2 3 4 5 action in the last 12 months. please skip to Ques-
f. tion m c.The reviewers asked clear questions.

d.The reviewers asked only for NA 1 2 3 4 5 televant information. NA 1 2 3 4 5 e.The wviewers applied regulations -

Stmngly Agme consiston!!y with what i beliove

  1. 9' " NRC intended. NA 1 2 3 4 5 Neutral f. The reviewers asked reasonati.e Disagme questions. NA 1 2 3 4 5 g.The reviewers had sufhcient knowledge t

of my operation and institution to do

a. t understand the review process the their job adequately. nA 1 2 3 4 5 NRC uses to h.The reviewers were competent in issue a license NA 1 2 3 4 5 relevant technical fields. NA 1 2 3 4 5 renew a hcenso NA 1 2 3 4 5 amend a bconso NA 1 2 3 4 5
b. The guidance provided by the NRC 15.How timely was the NRC response to any license enables me to file the following in an applications, amendments, and/or renewal re-ethcient manner quests you made in the last twelve months?

now applications- NA 1 2 3 4 5 (Please circio one responso for each type of hcensing \

amendments NA 1 2 3 4 5 action.)

renewals - NA 1 2 3 4 5

c. The guidance provided by the NRC enables mo to feel conhdent that most 'Y " Y information I providu will be accepted by an NRC licenso reviewer. NA 1 2 3 4 5 Not at all Timely Not appucable Application ~ NA 1 2 3 4 5 j

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13.What was the last type of licensing action you had Renewal - NA 1 2 3 4 5 with the NRC7 (Please circle only one.)

1, license issuance

2. license renewal 16.lf you have experienced delays in NRC responses 3_.Llicense amendment .- to license amendments or other licensing re-quests, how have they affected your facility?

(Picase circle only one response.)

1. haven't experienced any delays
2. delays created senous operational problems  ;
3. delays created moderate o'perational problems i
4. delays created minor operahonal problems Si delays created no operational problems

17.lf you have over disagreed with a license 20. Thinking back to the last inspection you've had,4o reviewer's position on an issue, what did you do what extent do you agree with the following ,

to resolve it? (Please circio all that apply.) statements. (Please use tho scale provided and i circle tho appropriate response.) l (1.lnever disagreed with a reviewer's position .- i

2. ca:!ed the reviewer .

Strongly Agree

' 3E wrote a letter to the reviewer, Agree

4. met with the reviewer Neutral

~ 5. contacted the reviewer's management at NRC Disagree i

6. took no action Strongly Disagree i

' 7.i other (Please specify) .

a. The inspectors were professionalin

- . _ u- their conduct.- 1 2 3 4 5 b The inspectors were knowledgeable of NRC regulations. 1 2 3 4 5

c. The inspectors wore knowledgeable of '

my license condinons-_. 1 2 3 4 5 18.How free would you feel to notify NRC manage- d. The inspectors were competent in mont if you disagreed with a license reviewer's )

relevant technical fields. 1 2 3 4 5  ;

position? (Pleaso cucle only one response ) e. The inspectors had sufficient knowledge '  ;

of my operation and institution to do I Completely Free their job adoquatoty. 1 2 3 4 5 i

f. The inspectors focused on safety issues. 1 2 3 4 5

_ g. The inspectors used their timo offectively at my facility. 1 2 3 4 5 Not at all Free h The inspectors lef t me with a clear understanding of their findings. 1 2 3 4 5

. ly Duld feel . 1 2 3 4 5 1. The inspectors applied regulations consistently with what i believe NRC intendad. 1 2 3 4 5 1 T he inspectors asked reasonable questions. 1 2 3 4 5 L Uspections have provided me with valuable information. 1 2 3 4 5 ,

INSPECTIONS The purpose of this part of the queshonnaire is to 21. Are there areas of Inspections that could be cut determine how effectively and efficiently the NRC and that would have little or no effect on the safe ,

conducts its inspection achvities. Operation of your facility? (Please circle your

- .. --. . . . - . . . ...-.____-.._.a roSponSO.)

l

.1. No.

2.Yes (please describc) _ _ _ _ _ . __

19.How familiar are you with the NRC's inspection - -- - -- -- -

i process? (Pleaso cucle only one response ) If you - - - - - . . - - -- - - .

have not been inspected in the last 12 months, - - - - - . . . - - - - - -

please skip to Question 28. - - . - - -- -- --

4 Very Familiar

22. Ate there areas that are being ignored by inspec.

tors that you believe are important to the safe operation of your facility? (Please circle your Not at all Famshar f

1. No. ,

Iam* 1 2 3 4 5 2.Yes (please describe) . __ _ _ ._ _ _

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li; 23,1f you hava ever disagreed with an inspector's REPORTING REQUIREMENTS-  !

position on an issue, what did you do to resolve 117 (Please circle allthat apply) The purpose of these questions is to determine your  :

views regarding the effectiveness of NRC reporting i M1if never; disagreed witti an inspector's position L requirements.

2. called the inspector

[3Rwrote a letter to thsinspector? ,

- 4. met with the inspector

, [5fbontacted the lnspector's management at NRC- 28.How familiar are you with the NRC's reporting

  • requirements? (Please circle only one response.)  ;

6ltook no action M.J other (Please specify)

Very Familiar 24.How free would you feel to notify NRC manage-ment if you disagreed with an inspector's find-ings? (Please circle only one response.) Not Famillar

' lam,- '

1 2 3 4 5 Completely Free 29.Has your facility been cited by the NRC for failing Not at all Free to make a required report? (Please circle as many ]

as apply) l

? l woukt leoli . 1' 2 3 4 S l

1. My facility has never been cited for failing to make a' 1

~

.l required report. . . . .

.. a

2. W facHity was cited because 1, or someone at my i 25.Has an inspector's supervisor or manager ever facWty, m!suiterpreted the requpement. .,.

participated in an inspection at your facility? ,

.3. My facuity was cited because a report was made in .

(Please circle only one response.)

'an incorrect tranner.. . ,

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4. My facility was cited because a report was not made on time. ~

'. 3 Do not kriok-

5. My facility 'was citeld tiecause a required report was' )

not filed. ,

6. Other (please describe) 26.How would you describe the frequency of NRC inspections. (Please circle only one response.)

_11, NRC inspections occur too often. 30.Have you ever made a telephone report of a

2. NRC inspections occur about as often as they significant event to the NRC? (Please circle only I should, one.)
3. NRC in'spections don't occur often enough.

.1i Yes?

2.No 1 27.How would you describe the length of your NRC If yes, how would you describe NRC's requests for Inspections. (Please circle only one response.)

additional information? (Please circle only one.)

11.iNRC inspections take too long'.-

2. NRC inspections take about the right amount of An excessive amount  ;

time. ' of information

3. NRC inspection's should take longer than they do.;

No additional l Information j

' NRC asked for . 1~ 2' 3 4 5

_ _ 1

f 39.How courteously are you treated when you make a 33.In your opinion, how burdensome is each of the.

. telephone report to the NRC? (Please circle only reporting requirements listed below? (Please circle one.) one response for each reponing requirement. 11 the reporting requirement is not applicable to your li, V [1: I am n1wais treated courteousty; consed activity, please circle WA".)

2.1 am usually treated courteously.

(3l Tam, occasionally treated co'u rteouslyf Not at all Burdensome

'4. I am rarely treated courteously.

" 5. Tam ;never treated ' courteously.

6. I have never made a telephone report.

Very Durdensome Not applicable 32.In your opinion, how necessary is each of the Part 20 lmmediale Notification for lost,1 reporting requirements listed below? (Please circle one response for each reporting requirement. If the d I** *' *I**'*9 I I*** **d **I I *' I verexposure or excessive releases reponing requ;roment is not applicable to your licensed l activity, please circle WW.) - [202_201(a)(1)(i) and 20.2202(a)] NA 1 2 3 4 5 )

Part 20 + 24 Hour Notification for lost, stolen or missing licensed material or Very Necessary overexposure or excessive releases

[20.2202(b)] NA 1 2 3 4 5 1 Part 20 a 30 Day Notification for lost,

. stolen or missing licensed material or '

Not at all Necessary overexposure or excessive releases Not applicable

. [20.2201(a), 20.2201(b), 20.2201(d),

' Part 204 Immediate Notification for lost, s 2_02203(a)}(_ , , , , ,

NA 1 2 3 4 5 stolen or missing licensed material or : Part 20 2 Week Notification for lost.

-overexposurn or excessive re! cases l ,

stolen or missing licensed material or NA 1 2 3 4 5 overexposure or excessive releases (20 22C1(a)(1)(i) and 202202(a)] .

Part 20 Hour Notification for lost, [ Appendix F 111 E2.] NA 1 2 3 4 5 stolon or missing licensed material or 1 Part 30- Bankruptcy, request for -

overexposure or excessive releases termination of license, notification of NA 2 3 4 5 event that prevents immediate -

[20 2202(b)) 1

- Part 20 - 30 Day Notification for lost, L protective actions .

NA 1 2 3 4 5 stolen or missing licensed material or Part 3425 - Scaled source leak test overexposure or excessive releases - results ,

NA 1 2 3 4 5

[202201(e),202201(b),202201(d), i Part 35.33(a)(2) y Misadministrat' ion 'reporth NA 1 2 3 4 5 202203(a)] .

NA 1 2 3 4 5 Part 35.645 - Teletherapy f acility safety Part 20 - 2 Week Notification for lost. checks NA 1 2 3 4 5 stolen or missing licensed material or . Other Roporting Requirements' '

overexposure or excessive releases .(please specify) NA 1 2 3 4 5

[ Appendix F 111 E2.] NA 1 2 3 4 5 Part 30 Bankruptcy, request for'

34. Are there any changes you would recommend in termination of license, notification of NRC reporting requirements? (Please identify the
  • \'h ' P'****i* * *di"'* reporting requirement and explain in the space pro-l-pro
      • tective actions NA 1 2 3 4 5 vided.)

Par 13425 - Scaled source leak test results NA 1 2 3 4 5

'~

Part 35.33(a)(2) Misadministration report NA 1 2 3 '4 5 Part 35.645. Telethempy facility safety chocks NA 1 2 3 4 5 Other Reporting Requirements'
(please specify) . NA 1 2 3 4 5 mm

(

NNFORCEMENT: 38. Based on your participation in enforcement con-forences, to what extent do you agree with the

. The purpose of this section is to determine the statements in the table? (Please circle one re-

- offectiveness of the NRC's enforcement process in sponse for each statement.)

promoting safety and safeguards.

Strongly Agree Agree 35.How familiar are you with the NRC's Enforcement Neutral Policy? (Please circle only one response.) Disagree Strongly Disagree Very Familiar .. ,- .-

.! The enforcement conference (s) -

.. were useful. 1 2 3 4 5 The issues were clearly communicated. 1 2 3 4 5 Not at all Familiar I The fin'al enforcement action (s)'weie t:mely. .' 1 2 3 4 6

, The process for submitting an appeal was

?)aml. 2 clear to ng _ 1 2 3 4 5

~ ~

1 3[45- -

1 The basis of the NRC's final enforcement

! decision (s) were clearly communicated, 1 2 3 4 5 The root causes of the problem (s) were 36.Have you ever received a Notice of Violation clearly identified. 1 2 3 4 5 (NOV)? (Please circle only one response.) (

The necesssry corrective actions were (communicated clearly, ,

1 2 3 4 5 17.yes - . , .. ,

The NRC process of imposing civil penalties

2. no (skip to Question 37.) contnbutes to the overall nuclear safety at my facility. 1 ,2 3 4 5 Do you understand how to respond to an NOV?

? (Please circ le only one response.)

39.Have you ever received a fine or civil penalty (CP)?

, 1. yes . ,, (Please circle only one response.)

I 2. no 11.?yes;. ,

2. no (skip to Question 40.)

To what extent do you agree that the issues which result in NOV's represent significant safety is-sues? (Please circle only one response.) Do you understand how to respond to a CP7 (Please circle only one response.)

It strongly disagree l.-

l 2. disagree 1.fyes '

, 3. neutraic 2. no

4. agreo ~

l S. . strongly ag'ree l To what extent do you agree that the issues which l result in CP's represent significant safety issues?

(Please circle only one response.)

37.Have you ever participated in an enforcement I conference? (Please circle only one response.) [1. strongly disagree

( 2. disagree

) t . li Yes 1 .... . . .

3. neutral

, 2. No (Please skip to Question 39.) 4. agree l L Sc strongly agree L

45.ls the RSO position at your facility a full-tirne RSO UCENSEE CHARACTERISTICS ' dedicated position, or does the RSO also have The following questions will a!!ow us to categorize the other job responsibilities? (Please circle only one responses you have provided so that the information response.)

can be reported in summary form.

1. Full-time RSO responsibilities 1
2. RSO also has other job responsibilities.

' 3. No RSO at this facility 40.Which of the following best describes your li-censed activity? (Picase circle only one response.)

' lacademict 46.Please provide any other comments that you wish

2. medical / academic to make regarding NRC regulations, policies, 3.Emedical institution (hospital, medical center, etc.) regulatory guidance, licensing activities, inspec-tions, reporting requirements, and/or enforcement
4. medicalother
5. pharmacy / medical distribution only actions.
6. welllogging
7. gauges _(measuring systems);
8. manufacturing and distnbution 1 ' 9l services (laundry, decon., calibration, disposal, leak test). .
10. industrialradiography
11. frra'diators
12. research & development

~ 13J other source

14. Special nuclear material 41.How many individuals have been issued personal dosimetry monitoring devices for your NRC licensed activities? (Please write the numberin the space provided) 42.In what state is your licensed facility located?

(Please wnte the state in the space provided.)

43.What is your job title? (Please wnte your title in the space provided)

- -. .- t 44.0o you serve as the Radiation Safety Officer (RSO) - --

/ '

l for your facility? (Please circle only one response.)

.1.' yes 2 no --

ee

_ _ _ _ . _ _ _