ML20133C611
| ML20133C611 | |
| Person / Time | |
|---|---|
| Issue date: | 12/12/1996 |
| From: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Cool D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-3 NUDOCS 9701080010 | |
| Download: ML20133C611 (22) | |
Text
-.-
ppatog UNITED STATES g
g NUCLEAR REGULATORY COMMISSION j
'C WASHINGTON, D.C. 20555-0001 4 *****,o 9
December 12, 1996 l
MEMORANDUM T0: Donald A. Cool, Director Division of Industrial and Medical Nuclear Safety, NMSS
/
[
FROM:
John W. N. Hickey, Chief ioning/ -
l Low-Level Waste and Deco Projects Branch l
l Division of Waste Management, NMSS l
SUBJECT:
DWM REVIEW COMMENTS ON DRAFT INSPECTION PROCEDURES 87111-87114 and 87115-87119 In response to your requests of November 12 and 22,1996, the Division of Waste Management's comments on the above-referenced inspection procedures (IPs) are provided below and in the attached markups of selected pages of the inspection procedures. Our comments are IP-generic and should be applied to all the draft IPs.
l 1.
Under the subheadings " Financial Assurance and Decommissioning" and/or l
" Decommissioning Timeliness" in the text of the IPs, references to NRC Inspection Manual chapters and inspection procedures related to decommissioning should be rewritten as follows:
For Planning and conducting inspections of licensees undergoing decommissioning, refer to: IMC 2605, " Decommissioning Procedures for Fuel Cycle and Materials Licensees;" the "NMSS Handbook for Decommissioning fuel Cycle and Materials Licensees;" IMC 2602,
" Decommissioning Inspection Program for Fuel Cycle Facilities and Materials Licensees;" and IP 87104, " Decommissioning Inspection Procedure for Materials Licensees."
gg 2.
Under the subheading " Decommissioning Timeliness" in Section 02 of the T"M l
text (Inspection Requirements), insert the following sentence after the O'ruvsc4p$
first sentence in the subsection:
ncop%
(Du l
For additional information, see NRC Administrative Letter 96-05, l
" Compliance with the Rule Timeliness in Decommissioning of Material l
Facilities," dated November 5, 1996.
l l
CONTACT: Ronald B. Uleck, DWM i
(301) 415-6722 y
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t D. Cool.
t 3.
It is important to know when a delay in decommissioning may have been granted by NRC. Therefore, add the following line to item 3.C in the
" Decommissioning Timeliness Inspection Field Notes:"
Date NRC granted delay:
c i
4.
Other minor comments'as shown on the attached markup pages.
4
Attachment:
As stated TICKET: DWM-051/53-DISTRIBUTION: - Centraldile' LLDPE/f' DWM r/f NMSS r/f DWM t/f Surmeier PUBLIC DFlack JBuckley DSchmidt LBykoski RNelson TCJohnson J
To receive a copy of this document in amatt bon en "0FC:" Line enter:
"C" = copy without attachment /enetosure; "E" = Copy with attadment/ enclosure; ale" = Ile copy
[ Path & Filename:S:\\DWM\\LLDP\\RBU\\DWM5053.01 3
1 0FC A LDP LLDPr LLOV 1
NAME buleck M1 JHNkey DATE 12/H /96 12//J/96 12//f/96 0FFICIAL RECORD COPY Category:
Proprietary ACNW: YES N0 s
IG : YES NO N
LSS : YES N0 f
Delete file after distribution:
Yes /
No
t D. Cool 1 1
l 3.
It is important to know when a delay in decommissioning may have been granted by NRC. Therefore, add the following line to item 3.C in the "Decomissioning Timeliness Inspection Field Notes:"
j Date NRC granted delay:
4.
Other minor comments as shown on the attached markup pages.
Attachment:
As stated
\\
@ dC$ 9Mthu.fInun0 f
Decommissionina Timeliness.
Review compliance with the Dec mmissioning Timeliness Rule requirements in 10 CFR 30.J6(d) through (h). This is one area of the field notes that should be completed on all inspections.
If i
the license to conduct principal activities has expired or been revoked:
if the licensee has made a decision to permanently cease principal activities at the site. in any separate building or at any outdoor area; or if there has been a 24-ronth duration when no principal activities were conducted at the site. In any separate building, or at any outdoor area. then the decommissioning timeliness requirements in 10 :FR 30.36.
40.42. 70.38, or Part 72 apply.
If this is the case, complete in full the " Decommissioning Timeliness Inspection Field Notes." Attachment A to Append 1x A.
02.12 Transoortation. Verify that the licensee's procedures and documentation are sufficient to ensure that licensed material is transported in accordance with 10 CFR Part 71 and 007 regulations for transportation of radioactive materials.
02.13 Postino and labelina. Verify that the licensee has posted the appropriate i
documents, notices, forms, and caution signs as required.
Also verify that containers of licensed material are labeled appropriately.
02.14 Generic Communications of Information.
Confirm that the licensee is receiving the applicable bulletins. in
- n t.... ' ices. NMSS Newsletter, etc.
Verify that the licensee has taken appropriate action in response to these notices.
02.15 Notifications and Reports. Determine compliance with the regulaticas and license requirements for notification and reports to NRC.
02.16 Special License Condit1cns.
If applicable. review the licensee's compliance with any special license conditions.
02.17 intdecendent and Confirmatory Measurements.
Compare and verify, on a sampling basis, survey results or date that are used by the licensee to show Conduct independent compliance with the regulations or license conditions.
measurements to ascertain the radiological conditions of the facility. Conduct these independent measurements on all inspections under this inspection procedure, unless warranted by special circumstances.
If independent measurements were not made, provide a justification in the field notes explaining why independent measurements were not performed.
The inspector shall use radiation detection instruments calibrated at intervals not to exceed six months.
02.18 Exit Meetina.
The inspector will conduct an exit meeting with senior licensee management and the RSO to discuss the preliminary inspection findings.
These will include any apparent violations, safety-related concerns, and any items identified during the inspection.
Discuss any negative unresolved Performance Evaluation Factors (PEFs) and encourage the licensee to respond w the PEFs of concern.
For further guidance, refer to IP 87107
" Performance Evaluation Factors."
02.19 Post Insoection Actions.
After an inspection, the inspector shall summarize the findings with his/her appropriate NRC supervisor.
This is especially important if there are, or are expected to be, controversial issues arising from the findings.
Inspectors shall also meet with regional licensing staff when any pertinent licensing issues are raised during the inspection, when inspection findings R7113 ATTACHMENT ' Issue Date:
XX/XX/XX
Accountant certify each year that the licensea nasses a financial test.'
The financial test ratios for parent company guarantees and self-guarantees are specified in Section II. Appendix A and Appendix C.
respectively, to 10 CFR Part 30.
f.
Decommissionina Timeliness.
Determine whether the license to conduct a principal activity h-.xpired or been revoked.
If the license remains in effect, determine if the licensee has made a decision to cease principal activities at the site or in any separate building or outdoor Finally. determine if there has been a area including burial grounds.
24-month duration in which no principal activities have been conducted in such areas.
A principal activity is one which is essential to the purpose for which a license was issued or amended, and does not include storage incidental to decontamination or decommissioning.
If the licensee meets any of the above conditions, the decommissioning timeliness requirements apply, and the inspector must complete the Decomissioning Timeliness Inspection Field Notes. Attachment A to Appendix A.
The requirements of 10 CFR 30.36. 40.42, and 70.38 do not apply to released rooms within a building where principal activities are still on-However, in those cases, the going in other parts of the same building.
inspector should follow the guidance in 03.11.e. regarding confirmatory measurements of the released area. Once principal activities have ceased in the entire building, then the decommissiar..:9 timeliness requirements will take effect.
The Decommissioning Timeliness Rule became effective on August 15. 1994.
In completing Attachment A of the field notes, specific guidance is If the needed regarding the timing of the notification requirements.
license has expired or been revoked, or if the licensee has made a decision to permanently cease princir.al activities, and the licensee orovided NRC notification before Auaust 15. 1994. then August 15.1994 is considered to be the date for initiating the decommissioning calendar (i.e., date of natification).
If there has been a 24-month duration in which no principal activities have been conducted at the location before the effective date of the rule, but the licensee did not notify NRC then the 24-month time period of inactivity is considered to be initiated on August 15. 1994, and the licensee must provide notification to NRC within d
either 30 or 60 days of August 15.1996 (depending on whether the 7
g licensee requests a delay).
W \\
l k
There is an exemption to the decommissioning timeliness requirements.
p The provisions in the Decommissioning Timeliness Rule in 10 CFR
~
40.42(d)(4) for the 24-month period of inactivity. 40.42(f) for the D
Q./[4 for the timing of content of the decommissioning plan, and 40.42(g) completion of the plan do not apply to the reclamation of waste disposal
,g
)*
,l QU P pr areagnd!cr tailig impound Ont'; at urar,im. rcccvery facilitics a@~
-ther = = ills ?
NRC has a stringent enforcement policy with respect to violations of the Failure to comply with the decommissioning timeliness requirements.
Decommissioning Timeliness Rule (failure to notify NRC. failure to meet decommissioning standards. failure to complete decomissioning activities in accordance with regulation or license condition, or failure to meet required decomissioning schedules without adequate justification) may be classified as a Severity Level III violation and may result in 87113 Issue Date:
XX/XX/XX
consideration of monetary civil penalties or other enforcement actions, as appropriate.
Decommissioning timeliness issues can be complex. For situations where an inspector has questions about the licensee's status and whether the decommissioning timeliness standards apply, he/she should immediately l
contact regional management.
i PFor planning and conducting inspections of licensees undergoing l
g
[p#ho decommissioning, refer to IMC 2602. " Decommissioning Inspection Program for Fuel Cycle Facilities and Materials Licensees;"
"Decomissioning Inspection Procedure for Materials Licensees:" and the draft Decommissioning Manual Chapter and Handbook.
v 03.12 Transoortation.
The inspector should review: the licensee's hazardous material training:
packages and associated documentation: vehicles (including placarding, cargo alocking, and bracing, etc.): shipping papers; and any incidents reported to DOT.
This is an ideal area for the inspector to make observations of 1.censee practices.
The DOT and NRC regulations for transportation of radioactive materials were recently revised, and the revisions generally became effective April 1.1996.
For further inspection guidance, refer to IP 86740. " Inspection of Transportation Activities." Inspectors should also refer closely to " Hazard Communications for C'a.
7 (Radioactive) Haterials." the NRC field raference charts on hazard commu... cations for transportation of radioactive materials, which contain references to the new transportation requirements, and are useful field references for determining compliance with the transportation rules on labeling.
placarding, shipping papers, and package markings.
l 03.13 Postino and labelina.
The inspector should determine whether proper f
caution signs are being used at access points to areas containing licensed materials, radiation areas, and those areas containing airborne radioactive materials.
10 CFR 20.1903 provides exceptions to posting caution signs. When applicable, the inspector should also randomly examine signals and alarms to determine operability.
The inspector should also randomly observe labeling on packages or other containers to determine that proper information (e.g.
- isotope, quantity, and date of measurement) is recorded.
Areas with radiation hazards should be conspicuously posted, as required by 10 CFR 20.1902.
Depending on the associated hazard, controls may include tape.
rope, or structural barriers to prevent access.
If volatile licensed materials area, such an area should be controlled for airborne are used in an contamination.
High radiation areas should be strictly controlled to prevent unauthorized or inadvertent access.
Such controls may include, but are not limited to, direct surveillance, locking the high radiation area, warning lights.
and audible alarms. Areas occupied by radiation workers for long periods of timo and common use areas should be controlled in accordance with licensee procedures and be consistent with the licensee's ALARA program.
The inspector should Cso examine locations where notices to workers are posted.
Applicable documents, notices, or forms should be posted in a sufficient number of places to permit individuals engaged in licensed activities to observe them on the way to or from any particular licensed activity location to which the postings would apply.
03.14 Generic Comunications of Information. Through discussions with licensee management and the RSO. the inspector should verify that the licensee is 87113 Issue Date:
XX/XX/XX.--
3.
DECOMMISSIONING PLAN /$CHEDULE REQUIREMENTS A.
Licensee is required to submit a decommissioning plan per 10 CFR 30.36(g). 40.42(g). 70.38(g). or 10 CFR Part 72?
( )Y( )N If "No" to 3. A.. answer the following items 8. - F.
B.
The decommissioning work senpe a covered by current license conditions
()Y()N C.
Decommissioning has been initiated within 60 da s of t
ation t C
r NRC has granted a de ay
()Y()N g
If licensee hhs initiated decormiissioning, give date D.
the decommissioning was initiated:
Initiation date:
E.
If decommissioning has been completed, it was completed within 24 months of notification to NRC
( ) N/A ( )Y( )N If decommissioning is still scheduled to be completed it is on schedule to be completed within 24 months of notification to NRC
( ) N/A ( )Y( )N Basis for Findings:
i l
87113. Appendix A. Att. A Att. A-2 Issue Date:
XX/XX/XX
REVIEW OF DRAFT INSPECTION PROCEDURFS 87111-87114 Duane W. Schmidt NMSS/DWM/ URB This reviewer has no major comments. The following are a few minor editorial comments.
i l
- 1. In Appendix A to Procedure 87112, for Panoramic Irradiator Programs, the section numbering has repeated numbers (there are two each of sections 11 and 12).
l
- 2. In the appendices to the procedures (the field notes pages), one section discusses the receipt, use, transfer, and control of materials. In this section, there is a check-off item for wiping all incoming packages "...unless exempted..." (or similar language). Actually, " excepted" may be a better term than " exempted" because the language refers to exceptions, written into the regulations, for gases and special form. See table below for pages affected, l
- 3. In two locations in the appendices, " principal," meaning primary, has been m.
pelled as l
" principle." See table below for pages affected.
i
- 4. In Appendix A to Procedure 87113," symbol'is misspelled on page A-5.
Pages Affected by Editorial Comments For comments:
l
- 2. Change " exempted" to Procedure number
" excepted"
IP 87113 A-8 A-19 and Att A-1 IP 87114 A-13 and Att B-1 l
l y
pp Qllow
~AJ l
I l
1
C.
Process and storage systems and equipment:
(1)
Used as described in license [L/C]
()Y()N (2)
Operable [L/C]
()Y()N D.
Air-handling systems and equipment as described in license [20.1701. L/C]
()Y()N l
1 Basis for Findings:
4 6.
MATERIALS RECEIPT. USE. TRANSFER. AND CONTROL 1
A.
Isotope, chemical form. quantity and use as authorized [L/C]
()Y()N l
B.
Package receipt and transfer:
(1)
Describe how packages are received and by whom:
spec $bh@y
(
r w
est p >hsusa s s,.es f'
spe% \\
tw.
(2)
Written package opening procedur established and followed [20.
6(e)]
()Y()N (3)
All incoming p w'
T labels wioed, unless e pts ases and special I
form) [20.1906
()Y( )N (4)
Incoming packages surveyed aer [20.1906(b)(2)]
()Y()N (5)
Monitoring in (3) and (4) a)ove, performed within time specified [20.1906(c)]
()Y( )N (6)
Transfer (s) between licensees performed per [30.41]
()Y()N
[
(7)
All sources surveyed before shipment and transfer [20.1501(a). L/C]
()Y()N (8)
Records of surveys and receipt / transfer maintained [20.2103(a). 30.51]
()Y()N l
(9)
Transfers among licensee's authorized i
users or locations performed as required
[L/C]
( ) N/A ( ) Y ( ) N (10) Arrangements made for packages 1
containing quantities of radioactive material in excess of Type A quantity
[20.1906(a)]
( ) N/A ( ) Y ( )N (11) Package receipt / distribution activities evaluated for compliance with 20.1301 l
[20.1302]
( ) N/A ( ) Y ( ) N l
87111. Appendix A A-8 Issue Date:
XX/XX/XX
s.,.
j 12.
COMPLIANCE WITH DECOMMISSIONING TIMELINESS RULE
)
A.
License to conduct a rinciple activity hal expired or been revoke w
g
()Y()N j
B.
Licensee has made a decision to permanently l
Cease principal activities, at the entire site.
j or any separate buildings, or any outdoor areas.
including inactive burial grounds
()Y()N t
C.
A 24-month duration has passed in which no l
principal activities, have been conducted under f
. the license at the site, or at any separate i
buildings, or any outdoor areas including j
inactive burial grounds
()Y()N j
D.
If "Yes" to either A or B or C:
(1)
Identify Site /B1dg/ Area:
(2)
Date of occurrence of A. B or C:
l NOTE: If "No" to A and B and C. Decommissioning Timeliness Rule does not apply.
If "Yes" to either A or 8 or C. then complete Attachment B. " Decommissioning Timeliness Field Notes." for this licensee.
Basis for Findings:
13.
TRANSPORTATION (10 CFR 71.5(a) and 49 CFR 170-189)
( ) N/A A.
Licensee shipments are:
( ) delivered to common carriers
( ) transported in licensee's own private vehicle
( ) both
( ) no shipments since last inspection B.
Licensee Transoorts: [canplete sections (1) - (4). as applicable]
(1)
Limited Quantities, and/or Instruments and
( ) N/A Manufactured Articles:
(Radioactive Material.
excepted package. (additional info]
- 7. UN 2910)
(a)
Package meets general design recuirements (173.410]
()Y( )N (b)
Raciation level 5 0.005 mSv/hr (0.5 mrem /hr) (Exclusive use instruments and articles. 2 mrem /hr)
()Y()N (c)
Contamination less than 173.443 limits.
OC examination / test performed prior to each shipment [173.475(1)]
()Y()N (d)
Limited Quantity Package marked
" Radioactive" [173.421(a)(4)]
()Y()N 87111. Appendix A A-18 Issue Date:
XX/XX/XX
.. ~
4 APPENDIX A - ATTACHMENT B DECOMMISSIONING TIMELINESS INSPECTION FIELD NOTES Licensee:
Date of Inspection:
1.
COMPLIANCE WITH DECOMMISSIONING TIMELINESS RULE (NOTE: Repeat the answers given in Section 12 of the main body of the field notes.
The issues in subsequent sections are dependent on the answers to these questions.)
yLc.;pl A.
License to conduct a ri ciple ctivity bm expired or been revok
()Y()N B.
Licensee M1 made a decision to aermanently cease principal activities, at t1e entire site, or any separate buildings, or any outdoor areas, including inactive burial grounds
()Y()N C.
A 24-month duration has passed in which no principal activities, have been conducted under the license at the site. or at any separate buildings, or any outdoor areas including inactive burial grounds
()Y()N D.
If "Yes" to either A or B or C above:
(1)
Identify Site / Bldg / Area:
(2)
Date of occurrence of A. B, or C:
I 2.
NOTIFICATION REQUIREMENTS A.
Licensee has provided written notification to NRC within 60 days of the occurrence of 1.A., 1.B., or 1.C. above
()Y()N If "Yes," date of notification:
B.
If the licensee is requesting to delay initiation of the decommissioning process, the licensee Ms provided written notification to NRC within 30 days of occurrence of 1.A.
1.B..
or 1.C. above
( ) N/A ( ) Y ( ) N If "Yes " date of notification:
Basis for Findings:
Issue Date:
XX/XX/XX Att. B-1 87111. Appendix A. Att. B
.. _ _ _ _ _ _ _. _ _ _ _ _ _ - _. _ _ _ _ _ =
6.
EQUIPMENT AND INSTRUMENTATION A,
Instruments and equipment (1)
Appropriate operable survey instrumentation possessed and readily accessible
[36.57(c). L/C]
()Y()N (2)
Calibrated as required (20.1501. 36.57(c). L/C] ( ) Y ( ) N (3)
Meter able to detect 0.05 mrem /hr [36.57(e)]
()Y()N (4)
Procedures established to identify and report safety component defects [21.21]
()Y()N 8.
Calibration records maintained [36.81(f).
()Y()N 20.2103(a))
l C.
Conductivity meters f
(1)
Appropriate operable meter possessed
(-) Y ( ) N (2)
Calibrated at least annually [36.63(b)]
()Y()N j
D.
Fixed process or area monitors operable and calibrated at the required frequency [L/C]
()Y()N
)
l 7.
nATERIALS RECEIPT. USE. TRANSFER. AND CONTROL A.
Isotope. chemical form quantity and use as authorized [L/C]
()Y()N l
B.
Licensed materials secured to prevent unauthorized removal or access [20.1801, 1802]
()Y()N (1)
Licensed material in storage in controlled or unrestricted areas is secured from unauthorized removal or access (20.1801]
()Y()N l
(2)
Licensed material in controlled or l
unrestricted areas and not in storage l
is controlled and under constant surveillance [20.1802]
()Y()N l
(3)
Access to restricted areas is limited
()Y()N
[20.1003]
C.
Describe how packages are received and by whom:
1 d;
'N D.
Written package opening procedures established f " exu-@1 4 Asb
)
and followed [20.1906(e)]
7
( ) N/A ( ) Y ( ) N g
l'em e-@ A "
E.
~
cMgesNthDOTlabelswioed.
l unles exempte [20.1906(b)(1)]
( ) N/A ( ) Y ( ) N l
F.
Incoming packages surveyed [20.1906(b)(2)]
( ) N/A ( ) Y ( ) N Issue Date:
XX/XX/XX A-9 87112. Appendix A l
(3)
Radiation monitor with audible alarm (36.29(a)) ( )Y( )N (4)
Conveyors stop upon alarm [36 29(a)]
()Y( )N (5)
Action limits set for contam1rmuon levels [L/C]( )Y( )N (6)
Licensee's survey techniques and methods sensitive enough to detect contamination level [L'C]
( )Y( )N Basis for Findings:
f ll
> l s > cl uud
- a T sk ru L us y
.follo ucAh
- tso, 11.
RADIATION PROTECTION A.
Licensee performed exposure evaluation (20.1501)
( )Y( )N B.
Licensee incorporated ALARA considerations in the radiation protection program [20.1101(b)]
( )Y( )N C.
External dosimetry
( ) N/A (1)
Licensee monitors workers as requi.ed
[20.1502. 36.55]
()Y( )N (2)
Supplier Frequency (3)
Supplier is NVLAP-approved [20.1501(c). 36.55]
( )Y( )N (4)
Dos 1 meters exchanged at required frequency
[36.55. L/C]
()Y( )N (5)
Dosimetry records maintained [20.2103]
()Y( )N (6)
Pocket dosimeters used [36.55(b)]
()Y()N (7)
Pocket dos 1 meters checked annually for 30%
()Y( )N
( ) N/A 0.
Reports (1)
Reviewed by frequency (2)
Inspector reviewed personnel monitoring records for period to (3)
Prior dose determined for individuals likely to receive doses [20.2104]
( )Y( )N (4)
Maximum exposures TE0E Other (5)
TEDEs within limits [20.1201]
( )Y( )N (6)
NRC forms or equivalent [20.2104(d). 2106(c)]
(a)
( )Y( )N Complete:
()Y( )N (b)
NRC Form 5 ( )Y( )N Complete:
( )Y( )N 87112. Appendix A A 16 issue Date:
XX/XX/XX
(7)
Worker declared her pregnancy a, writing during i
inspection period (review recoros)
( ) N/A ( )Y( )h If" Yes." licensee in compliance with dose to embryo / fetus [20.1208]
( )Y( )N l
and records maintained (20 2106(e)]
( )Y( )N E.
Who performed PSEs at this facility (number of people involved and doses received) [20.1206. 2104. 2105. 2204] ( ) N/A F.
Records of exposures. surveys, monitoring, and evaluations maintained [20.2102. 2103. 2106. L/CJ
()Y()N 1
G.
Licensee advises each worker annually of worker's dose [19.13(b))
()Y()N Basis for Findings:
t 2. >L>dq usad 12.
RADICACTIVE WASTE MANAGEMENT
( ) N/A A.
Effluents
( ) N/A (1)
Release into sanitary sewer [20.2003)
( ) N/A ( )Y( )N (a)
Material is readily soluble or readily dispersible [20.2003(a)(1)]
( )Y( )N (b)
Monthly average release concentrations do not exceed Appendix B values
[20.2003]
( )Y( )N (c)
No more than 5 Ci of H-3. 1 Ci of C-14 and 1 Ci of all other radionuclides
)N combined released in a year [20.2003]
()Y(
(d)
Procedures to ensure representative sampling and analysis properly implemented [20.1501(a)(2). L/C]
( )Y( )N (2)
Release to septic tanks (20.1003)
( ) N/A ( )Y( )N (a)
Within unrestricted limits
()Y( )N
[ App B. Table 2]
B.
Records of surveys and material accountability are
()Y()N maintained [20.2103. 2108]
Basis for Findings:
l Issue Date:.XX/XX/XX A-17 87112. Appendix A
14.
COMPLIANCE WITH DECOMMISSIONING TIMELINESS RULE A.
License to conduct a rinciple ctivity !1aji
( )Y( )N expired or been revok-
,g B.
Licensee h2i made a decistorr40 permanently cease principal activities, at*the entire site.
or any separate buildings, or a'ny outdoor areas.
Including inactive burial grounds
( )Y( )N C.
A 24-month duration has passed in which no principal activities. have been conducted under the license at the site, or at any separate buildings, or any outdoor areas. including inactive burial grounds
()Y( )N D.
If "Yes" to either A or B or C:
(1)
Identify Site / Bldg / Area:
(2)
Date of occurrence of A, B, or C:
NOTE:
If "No" to A and B and C. Decommissioning Timeliness Rule does not apply.
If "Yes" to either A or B or C. then complete Attachment 8.
" Decommissioning Timeliness Field Notes." for this licensee.
Basis for Findings:
15.
TRANSPORTATION (10 CFR 71.5(a) and 49 CFR 170-189)
( ) N/A A.
Licensee Transoorts: [ccmplete sections (1) - (4). as applicable]
(1)
Limited Quantities, and/or Instruments and
( ) N/A Manufactured Articles:
(Radioactive Material, excepted package. (additional info]. 7. UN 2910)
(a)
Package meets general design requirements (173.410)
( )Y( )N (b)
Radiation level 5 0.5 mrem /hr (0.005 Sv/hr) (Exclusive use instruments and articles. 2 mrem /hr)
( )Y( )N (c)
Contamination less than 173.443 limits.
OC examination / test performed prior to each shipment [173.475(1)]
( )Y()N (d)
Limited quantity package marked "Radioacti,e" [173 421(a)(4)]
()Y( )N (e) 173.422 certification statement attached / enclosed ("This package i
conforms to the conditions and limitations specified in.
")
( )Y( )N 1
Issue Date:
XX/XX/XX A-19 87112, Appendix A
t APPEN0lX A - ATTACHMENT a DECOMMIS$10NING TIMEllNESS INSPECTION FIELD NOTES l
l Licensee:
Date of Inspection:
l.
COMPLIANCE WITH DECOMMISSIONING TIMELINESS RULE (NOTE: Repeat the answers given in Section 12 of the main body of the field notes.
The issues in subsequent sections are dependent on the answers to these questions.)
,,tg
(
A.
License to conduct a rin iple ctivity has
( )Y()N expired or been revoke 8.
Licensee has made a decision to permanently cease principal activities, at the entire site.
or any separate buildings, or any outdoor areas,
( )Y( )N including inactive burial grounds C.
A 24-month duration has passed in which no principal activities. have been conducted under the license at the site, or at any separate buildings or any outdoor areas including inactive burial grounds
( )Y( )N 0.
If "Yes" to either A or 8 or C above:
(1)
Identify Site / Bldg / Area: _
(2)
Date of occurrence of A. B. or C:
2.
NOTIF[ CATION REQUIREMENTS A.
Licensee has provided written notification to NRC within 60 days of the occurrence of 1.A.
1.B.. or
( )Y( )N 1.C. above If "Yes." date of notification-B.
If the licensee is requesting to delay initiation of the decommissioning process, the licensee has provided written notification to NRC within 30 days of occurrence of 1.A., 1.B.. or 1.C. above
( ) N/A ( )Y( )N If "Yes." date of notification:
l Comments:
l Issue Date:
XX/XX/XX Att. A-1 87112. Appendix A. Att. A
_... _.. _ _.._ _ _.___.._ _ _. _.. _ _ __ _ _ _ _. ~
B.
Identify licensee personnel contacted during the inspection (including those individuals contacted by telephone).
b s
Use the following identification
- Individuals present at entrance g
- Individuals present at exit meeting
+ Individuals contacted by telephone C.
Authorized for multiple locations of use
()Y()N i
D.
Authorized for multiple permanent field office locations
()Y()N 4
(1) Inspection performed at multiple field offices
.()Y()N i
(2) If "Yes." list office locations inspected:
E.
Authorized for temporary job site locations
()Y()N (1) Inspection performed at terncary job site (s)
()Y()N (2) If "hu." describe why not:
4 Issue Date:
XX/XX/XX A-5 87113. Appendix A
6.
INSprrTION AND MAINTENANCE A.
Licensee has program established [39.43(b)]
()Y()N B.
Equipment inspected daily and semiannually [39.43]
()Y()N C.
Records of defects maintained [39.43(b)]
()Y()N l
D.
Removal, repair, opening, drilling, or modification of sources by persons specifically licensed [39.43]
()Y()N l
l E.
Procedures established to identify and report safety component defects [21.21]
()Y()N Basis for Findings:
l l
7.
MATERIALS RECEIPT. USE. TRANSFER. AND CONTROL A.
Isotope, chemical form quantity and use as I
authorized [L/C]
()Y()N 8.
Sources acquired after July 14, 1989 meet (39.41]
()Y()N 9
C.
Licensed materials secured to prevent unauthorized removal or access (20.1801, 1802]
()Y()N i
l (1)
Licensed material in storage in controlled 1
or unrestricted areas is secured from j
unauthorized removal or access [20.1801]
()Y()N (2)
Licensed material in controlled or unrestricted areas and not in storage is controlled and under constant surveillance [20.1802]
()Y()N (3)
Access to restricted areas is limited
[20.1003]
D.
Describe how packages are received and by whom:
4.1 "
% g <W a W&
E.
Written package opening procedures established g* '
l and followed [20.1906(e)]
()Y()N
" ep. 7
<..L 4
F.
A1] inc
'ng packages with DOT labels wip_ed unless l
exempt ses and special form) [20.1906(b)(1)]
()Y()N i
wp l
G.
Incoming packages surveyed [20.1906(b)(2)]
()Y()N H.
Monitoring, in (F) and (G) above, performed within time specified [20.1906(c)]
()Y()N 87113. Appendix A A-8 Issue Date:
XX/XX/XX
q JT.
i Y
COMPLIANCEWITHDECOMMISSIONINGTIMNtbWULE l
15.
i A.
License to conduct a rincip > activity !Las
()Y()N expired or been revoke ~
4 B.
Licensee has maae a decision to permanently cease principal activities. at the entire site.
or any separate buildings, or any outdoor areas, including inactive burial grounds
( ) Y (-) N C.
A 24-month duration has passed in which no principa1 activitles. have been conducted under the license at the site, or at any separate buildings or any outdoor areas, including inactive burial grounds
()Y()N D.
If "Yes" to either A or 8 or C:
(1)
Identify Site / Bldg / Area:
(2)
Date of occurence of A. 8. or C:
NOTE: If "No" to A and 8 and C. decommissioning timeliness rule does not apply.
If "Yes" to either A or 8 or C. then complete Atcachr'nt A. " Decommissioning Timeliness Field Notes." for this licensee.
l Basis for Findings:
16.
TRANSPORTATION (10 CFR 71.5(a) and 49 CFR 170-189)
( ) N/A A.
Licensee Transoorts: [ complete sections (1) - (4), as applicable]
(1)
Limited Quantities. and/or Instruments and
( ) N/A Manufactured Articles:
(Radioactive Material.
excepted package. [ additional info]. 7. UN 2910)
(a)
Package meets general design requirements [173.410]
( )Y( )N (b)
Radiation level 5 0.005 mSv/hr (0.5 mrem /hr) (Exclusive use instruments and articles. 2 mrem /hr)
()Y()N (c)
Contamination less than 173.443 limits.
Oc examination / test performed prior to each shipment [173.475(1)]
()Y()N (d)
Limited Quantity Package marked
" Radioactive" [173.421(a)(4)]
()Y()N 1
(e) 173.422 certification statement i
attached / enclosed ("This package conforms to the conditions and limitations specified in.
")
( )Y( )N 4
issue Date:
XX/XX/XX A-19 87113. AppeMix A
c
?
APPENDIX A - ATTACHMENT A DECOMMISSIONING TIMEllNESS INSPECTION FIELD NOTES Lisensee:
Date of Inspection:
COMPLIANCE WITH DECOMMISSIONING TIMEllNESS RULE 1.
(NOTE: Repeat the answers given in Section 12 of the main body of the field notes.
The issues in subsequent sections are dependent on the answers to 7LJpl these questions.)
g A.
License to conduct a pri iple activity 11g
()Y()N expired or been revoked l
8.
Licensee 'ld made a decision to aermanently cease principal activities, at t1e entire site.
l or any separate buildings, or any outdoor areas, I
()Y()N including inactiva burial grounds C.
A 24-month duration has passed in which no principal activities, have been conducted under the license at the site, or at any separate l
buildings, or any outdoor areas including
()Y( )N l
inactive burial grounds D
If "Yes" to either A or B or C above:
l l
(1)
Identify Site / Bldg / Area:
l (2)
Date of occurence of A. B, or C:
I 2.
NOT:FICATION REOUIREMENTS A.
Licensee has provided written notification to NRC within 60 days of the occurrence of 1.A.
1.B., or
()Y()N 1.C. above If "Yes." date of notification:
B.
If the licensee is requesting to delay initiation of the decommissioning process, the licensee !!al provided written notification to NRC within 30 days of occurrence of 1.A.
1.B.
or 1.C. above
( ) N/A ( ) Y ( )N if "Yes." date of notification:
Basis for Findings:
i Issue Date:
XX/XX/XX Att. A-1 B7113. Appendix A. Att. A
~,_
12.
COMPLIANCE WITH DECOMMISSIONING TIMELINESS RULE N
I Y
c; A.
License to conduct a rant @eactiviyhE expired or been revoke
( )Y( )N B.
Licensee !1aji made a decision to permanently cease principal activities, at the entire site.
or any separate buildings. or any outdoor areas, including inactive burial grounds
( )Y( )N C.
A 24-month duration has passed in which no principal activities, have been conducted under the license at the site. or at any separate buildings, or any outdoor areas, including inactive burial grounds
()Y()N D.
If "Yes" to either A or 8 or C:
(1)
Identify Site /81dg/ Area:
(2)
Date of occurrence of A. 8. or C:
NOTE: If "No" to A and B and C. Decommissioning Timeliness Rule does not apply.
If "Yes" to either A or 8 or C. then complete A"achment 8. " Decommissioning Timeliness Inspection Field Notes." for this licensee.
Basis for Findings:
13.
TRANSPORTATION (10 CFR 71.5(a) and 49 CFR 170-189)
( ) N/A A.
Licensee Transoorts: (complete sections (1, - (4). as applicable]
(1)
Liniited Quantitles, and/or Instruments and
( ) N/A Manufactured Articles:
(Radioactive Material.
excepted package. [ additional info], 7. UN 2910)
(a)
Package meets general design requirements [173.410]
( )Y( )N (b)
Radiation level s 0.005 mSv/hr (0.5 mrem /hr) (Exclucive use instruments and articles. 2 mrem /hr)
( )Y( )N (c)
Contamination less than 173.443 limits.
OC examination / test performed prior to each shipment [173.475(1)]
( )Y( )N (d)
Limited Quantity Package marked
" Radioactive" [173.421(a)(4)]
( )Y( )N (e) 173.422 certification statement attached / enclosed ("This package conforms to the conditions and limitations specified in.
")
( )Y( )N issue Date:
XX/XX/XX A-13 87114. Appendix A
r 1
APPENDIX A ATTACHMENT B DECOMMISSIONING TIMELINESS INSPECTION FIELD NOTES Licensee Date of Inspection:
.l.
COMPLIANCE WITH DECOMMISSIONING TIMELINESS RULE (NOTE: Repeat the answers given in Section 12 of the main body of the field notes.
The issues in subsequent sections are dependent on the answers to these questions.)
l A.
License to conduct a ei iciple ctivity has expired or been revok
()Y()N B.
Licensee has made a decision to permanently cease principal activities, at the entire s1te.
l or any separate buildings. or anv n" Moor areas.
Including inactive burial grounds
( )Y( )N C.
A 24-month duration has passed in which no principal activities, have been conducted under the license at the site. or at any separate buildings. or any outdoor areas. including inactive burial grounds
( )Y( )N D.
If "Yes" to either A or 8 or C above:
(1)
Identify Site / Bldg / Area:
(2)
Date of occurrence of A. B or C:
2.
NOTIFICATION REQUIREMENTS A.
Licensee has provided written notification to NRC within 60 days of the occurrence of 1.A.
1.B.
or 1.C. above
( )Y( )N If "Yes." date of notification:
B.
If the licensee is requesting to delay initiation of the decommissioning process, the licensee has provided written notification to NRC within 30 days of occurrence of 1.A.
1.B.
or 1.C. above
( ) N/A ( ) Y ( )N If "Yes." date of notification:
Basis for Findings:
Issue Date:
XX/XX/XX Att. B-1 87114. Appendix A. Att. B