ML20137Z347

Discusses Policy & Guidance Directive 84-25 Which Reviews Licensing Policy for Large Irradiators & Stresses Importance of Careful Review of All Irradiator Applications

ML20137Z347
Person / Time
Issue date:	11/28/1984
From:	Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20137Z331	List: ML20137Z327 ML20137Z335 ML20137Z347
References
RTR-NUREG-CP-0073, RTR-NUREG-CP-73 NUDOCS 8603130023
Download: ML20137Z347 (46)

Text

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( NOV 2 81gg4 MEMORANDUM FOR: Regional Administrators Branch Chiefs Division of Fuel Cycle and Material Safety FROM:

Richard E. Cunningham. Director Division of Fuel Cycle and Material Safety

SUBJECT:

POLICY AND GUIDANCE DIRECTIVE 84-25 i

LICENSING OF LARGE IRRADIATORS The purpose of this directive is to review licensing policy for large irradiators, and to stress the importance of careful review of all irradiator applications in accordance with the policy.

"Large" irradiators are those which contain more than 10.000 curies of radioactive material, and which are not self-shielded. About 50 NRC licensees possess such irradiators. Of these, about 15 1rradiators s

contain over 1.000.000 curies of cobalt-60. Therefore, there is the potential for a serious overexposure or other incident if safety

, requirements are not strictly adhered to.

Incidents in past years involving large irradiators include overexposures, sources jammed in the "up" position, and fires. Also, during a recent inspection one licensee was found to be leaving an operating irradiator

• unattended overnight, even though the license specifically stated that an authorized user must be ptysically present during use.

It is essential that license reviewers carefully review applications involving large irradiators, and make sure that they contain clear.

unambiguous descriptions and constitments which demonstrate that NRC requirements will be met. Regulatory Guide 10.9. " Guide for the i Preparation of Applications for Licenses for the Use of Gamma Irradiators." provides the basis for review of irradiator applications.

This guide is being revised by the NMSS staff, and will be distributed to the Regions along with a Standard Review Plan. Detailed instruction on licensing irradiators was also provided during the recent training courses which were attended by representatives of all Regions.

Of particular importance in licensing irradiators are the following:

l 1. Atrainedsupervisor(authorizeduser)mustbephysicallypresent whenever an irradiator is operating. The " user condition" of the

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i license must specifically require the physical presence of a trained I supervisor. A partially trained person or night watchman is not acceptable. The supervisor must have complete training in basic '.

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2. Irradiators must have fire protection systems as discussed in Regulatory Guide 10.9.

3. Irradiators must have interlock systaas and alams as specified in10CFRSection20.203(c)(b).

We are working with the Office of Ir.spection and Enforcement on an Infomation Notice (Enclosure) which discusses the need to have a supervisor physically present when an irradiator is operating. We suggest that inspectors closely review this matter during inspections, and contact the licensing staff as appropriate when problems are encountered.

Questions regarding licensing policy for irradiators may be directed to VandyMiller(FTS 427-4002).

Original Signe'd By Richard E. Cunningham Richard E. Cunningham, Director Division of Fuel Cycle and Material Safety

Enclosure:

Infomation Notice DISTRIBUTION:

NMSS r/f FC Central File FCML r/f JHickey NBassin PCVacca VLMiller Etinger -

RABrightsen DRChapell RECunningham LCobb JJoyner KBarr WAxelson JEverett FWenslawski Record Note: All Regions and IE Headquarters reviewed a draft of this directive.

Minor coments were received and incorporated.

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SSINS NO.: 6835 IN 85-01 S

UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C. 20555 January 10, 1985 IE INFORMATION NOTICE NO. 85-01: CONTINUOUS SUPERVISION OF IRRADIATORS Addressees:

All licensees possessing irradiators that are not self-shielded and contain more than 10,000 curies of radioactive material.

Purpose:

This information notice is provided to alert recipients of a potential safety hazard and violation of NRC license requirements which can arise if licensees do not provide continuous supervision of large irradiator operations. "Large" f rradiators are those which contain more than 10,000 curies of radioactive material and which are not self-shielded. Although proper supervision and security also is important for smaller irradiators, they are not the subject of this notice.

It is expected that licensees will review this notice for applicability to their facilities, if appropriate, to preclude a similar problem occurring at their facilities. However, suggestions contained in this information notice do not constitute NRC requirements; therefore, no specific action or written response is required.

Description of Circunstances:

Some large irradiators operate 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. Recently a case came to our attention in which an irradiator was left operating overnight totally unattended.

The irradiator license specifically required the physical presence of a fully trained supervisor whenever the irradiator was in use. This provision of the license is consistent with NRC policy and good safety practice that large irra-diators should be continuously attended by a fully trained supervisor except when the radioactive sources are secured in their safe storage position.

Compliance with that requirement assures that a qualified individual is immediately available to respond to emergencies or other problems. Note that 10 CFR 20.203(c)(6) requires that large irradiators must be equipped with entry control devices and alarms to make an individual attempting to enter the exposure area aware of the hazard and to alert at least one other individual who is familiar with the irradiator and prepared to render or sumon assistance.

The NRC is closely reviewing this matter during inspections and licensing actions. Most irradiator licenses explicitly state that a trained person r.. st be physically present whenever the irradiator is being used. The NRC regional office will contact separately any irradiator licensee whose license may not be clear with respect to physical presence.

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IN 85-01 January 10, 1985 Page 2 of 2 No specific action or written response is required by this information notice.

If you have any questions about this matter, please contact the Material Licensing Branch (301) 427-4203) in NRC Headquarters or the materials licensing ,

section of your NRC regional office. i J.,4elson Grace, tor  !

Division of Quality Assurance, Safeguards, i and Inspection Programs j i Office of Inspection and Enforcement .

Technical Contacts: J. Hickey, NMSS (301)427-4203 J. Pietzger, IE i (301)492-4947 i

Attachment:

l List of Recently Issued IE Information Notices f 4

Attachment IN 85-01 January 10, 1985 LIST OF RECENTLY ISSUED IE INFORMATION NOTICES Information Date of Notice No. Subject Issue Issued to 84-94 Reconcentration Of Radio- 12/21/84 All NRC materials nuclides Involving Discharges licensees other than Into Sanitary Sewage Systems licensees that use Permitted Under 10 CFR 20.303 sealed sources only 84-93 Potential For Loss Of Water 12/17/84 All power reactor From The Refueling Cavity facilities holding an OL or CP 84-92 Crackirg of Flywheel on 12/17/84 All power reactor Cummins Fire Pump Diesel facilities holding Engines an OL or CP 84-91 Quality Control Problem 12/10/84 All power reactor Of Meteorological facilities holding Measurements Problems an OL or CP 84-90 Main Steam Line Break 12/7/84 All pressurized Effect On Environmental water reactor and Qualification Of Equipment gas cooled power C facilities holding an OL or CP 84-89 Stress Corrosion Cracking 12/7/84 All boiling water In Nonsensitized 316 reactor facilities Stainless Steel holdi1g an OL or CP 84-88 Standby Gas Treatment 12/3/84 All boiling water System Problems reactor facilities holding an OL or CP 84-87 Piping Thermal Deflection 12/3/84 All power reactor Induced By Stratified Flow facilities holding an OL or CP 84-86 Isolation Between Signals 11/30/84 All power reactor Of The Protection System facilities holding And Non-Safety-Related an OL or CP Equipment OL = Operating License CP = Construction Permit 1

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INSPECTION AND ENFORCEMENT MANUAL QASIP LICENSED MATERALS PROGRAMS INSPECTION PROCEDURE 87100 TA8LE OF CONTENTS Number Title , Pace No.

87100-01 INSPECTION OBJECTIVES 1 87100-02 INSPECTION REQUIREMENTS 1 02.01 Program Administration 1 02.01a Organization 1 02.01b Quality Assurance Program and Licensee Audits 2 Training 02.01c 3 02.01d Operating and Emergency Procedures, 3 Safety Component Defects 02.01e Reports and Notifications 4 02.01f Records 7 02.02 Authorized Materials, Uses and Users 8

. 02.02a Receipts, Transfers and Package Handling 8 Procedures

.;- 02.02b Authorized Users 9 02.02c Authorized Uses 10 02.02d Material Control 11 02.02e Area Radiation and Contamination Control 12 02.02f Packaging and Transportation 13 02.03 Physical Plant Facilities and Equipment .13

! 02.04 Radiation Protection 14 I

02.05 Radioactive Effluents and Waste Disposal 14 02.06 Confirmatory Measurements 15 87100-03 INSPECTION GUIDANCE 15 03.01 Program Administration 15 03.02 Authorized Materials, Uses, and Users 15 03.03 Physical Plant Facilities and Equipment 16 03.04 Radiation Protection 16 03.05 Radiation Effluents and Waste Disposal 17 03.06 Confirmatory Measurements 18 87100-04 REFERENCES 18 l

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Issue Date: 03/12/84

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LICENSED MATERIALS PROGRAMS 887100-01 rI PROGRAM APPLICA81LITY: 2800 87100-01 INSPECTION OBJECTIVES 01.01 To ' determine if licensed programs are being conducted in accord-ance with NRC requirements, and 01.02 To determine if licensed activities are being conducted to ensure the health and safety of workers and members of the

. general public.

87100-02 INSPECTION REQUIREMENTS .

Review of the licensed activities should be cummensurate with the scope of the licensee program. The following sections reference the main require-ments of the regulations concerning each topic and describe some of the principal license conditions.

02.01 procram Administration Review the following elements in sufficient depth to verify that organizational and administrative systems have been established to ensure safe conduct of the licensed activity.

3.

-' a. Oraanization

Reference:

Applicable license conditions.

The organizational structures will be found in license applications and may involve one or more individuals.

Examine any changes in the organization with respect to changes that have occurred in norsonnel, functions, respon-sibilities and authorities sis.:e the previous inspection.

l If individuals are named in the Itcense application, an

amendment must be provided whenever changes in personnel l are made (except for some broad and radiography licenses, where only responsibilites are defined). If there have been no changes in the organization since the previous inspection, there is no need to pursue that element in

- no need to pursue that element in any depth, except to ask the licensee if there have been changes and to make inquiries of personnel to confirm (to the inspector's sat-l isfaction) that no changes have taken place.

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i b. 0A Proaram and Licensee Audits

References:

10 CFR 34.28 Inspection and maintenance of radiographic devices, storage containers, and source changers.

Applicable license conditions.

The quality assurance program will be in the form of pro-cedures specified in the license and covering a variety of activities and methodologies. Generally, the procedures will specify limitations, "do's," and " don'ts," and how to -

perform one or more tasks. .'In any event, the licensee is bound to the procedures. The inspector should verify (pre-ferably by direct observation) the implementation of a selection of procedural activities to the extent that the inspector is satisfied that procedures are being followed.

The inspector should also verify that internal audits are performed as required. The results of audits of activities

will be found in records of audits. Examine those records with ' particular attent.fon to deficiencies found by the auditors and note corrective actions taken as a result of [.'

deficiencies found. If no corrective actions were indi- m h

cated whenever deficiencies were found, ask the licensee "J representatives what actions were taken and determine why they were not noted in the records.

Audits of field radiography sites are especially important.

If at all practicable, accompany an auditor to a field site (this may require special scheduling). Other kinds of internal audits for different categories of licensees may involve such determinations as the use of syringe shields (hospitals), whether technetium generators are properly shielded (hospitals), and whether established ALARA pro-grams are being implemented (all Itcensees). These are only i

- a few examples; the inspector should examine the licensee's com-mitments in the license to determine the kinds and

extent of audits required.

l 8 As one part of assist inspections, the inspector should de-termine that the licensee's internal inspection program is actually being carried out in that facility. For example, the date of the last internal inspection findings and actions taken to correct problems should be determined, y

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LICENSEO MATERIALS PROGRAMS 87100-02.01b The above information should be included in the inspection 3l . summary nport sent to the home region and, if negative, so

.. - stated.

' c. Trainina l

References:

10 CFR 19.12 Instructions to workers.

10 CFR 35.24 qualified expert.

Applicable license conditions.

Certain kinds of training and instruction are found in the regu1'ations; how they are implemented will be found in the Ifcense. The inspector should verify that proper training and initial instructions .are being accomplished as speci-fled in the license or regulations. Discuss with ifcensee representatives how and by whom the training is conducted and the content of the training (generally found in the license application).

Verify, pursuant to 10 CFR 19.12, that the initial instruc-tions have been given to workers who enter restricted areas.

Under the basic instructions, it is management's responsi-bility to inform the workers of precautions to take when

- entering a restricted area, kinds and uses of radioactive

. materials in that area, exposure levels, and the types of

. .,/ protective equipment to be used. The workers should also be informed of the pertinent provisions of NRC regulations and the license and the requirement to notify management of conditions observed that may, if not corrected, result in a violation of NRC requirements.

- Of the training program elements in the license applica-tion, training given to authorized users is of primary importance. One or more users of radioactive materials should be interviewed to determine that they have received l

> the required training, both in the basic instructions and that specified in the license application.

Randomly examine records of training of personnel and

, attendant tests or examinations (if applicable) to the extent that the inspector is satisfied that the training program is being implemented as requirod. Where examina-l' tions are required, read a few of the examination questions to ascertain that they are indicative of what the worker should . know to carry out his/her responsibi-lites.

d. Operatino and Emergency Procedures, Safety Component Defects

References:

' 10 CFR 34.32 Operating and emergency procedures.

3 Issue Date: 03/12/84

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LICENSED MATERIALS PROGRAMS 87100-02.01e _

dispatch of an inspector to the site to determine the A ,.

causes of overexposure and adequacy of corrective 'W l actions.

.In the case of high exposures to personnel, if the ex'posure is believed to be valid, an inspector must be dispatched to the site to conduct an inspection to support possible escalated enforcement action. This also applies to reports filed only under 10 CFR 20.405 if exposures are greater than 3 rems but less than 5 rems depending on the circumstances. An inspector need not be dispatched to a site promptly if, for ex-ample, the reprt submitted under 10 CFR 20.405 shows 3.01 rens. In thesa cases, an inspection should be ~

scheduled as soon as practicable. However, this _

decision is best left to the judgment of the region, depending on the c ircumstances set forth in the reports and by telephone communications.

During routine inspections, inspectors need only inquire if 10 CFR 20.407 reports have been submitted without going into further depth, unless the Office of Resource Management

• has requested a followup because no report was submitted. The same applies under 10 CFR 20.408 for terminated employees. Those reports should e

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only be examined at random so that the inspector is b satisfied that the reports are being generated. )a

2. Reports of loss or theft of Ifcensed radioactive mate rial will require, under a new rule change, that all events of loss or theft above some lower limit must be reported, regardless of whether licensees believe that there may be a substantial hazard involved. 8ecause of the legalities and details involved for inspection and followup purposes, two Interpretive Guides were developed. The guides should be used for foi-lowup on losses or thefts of radioactive material. The

' guides are entitled "10 CFR 20.402: ' Lost or Stolen

/'l (Missing) Radioactive Materials at Licensee's Faci-

/' 11 ties'" and "20.402: Transportation, ' Lost or Stolen

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Radioactive Sources Involved in Transportation.'"

These guides may be found in the "10 CFR" section of the IE Manual.

3. The above remaining reports deal with leak tests above limits (10 CFR 31.5, 34.25, 35.14); materials transfer reports for manufacture or transfer of certain items (10 CFR 32.12, 32.16, 31.20, 32.25, 32.29, 32.52);

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Registration Certificates - Medical Use of Byproduct Material Under General License (10 CFR 35.31); reports '%

( of medical therapeutic and diagnost nisadministra-tions (10 CFR 35.42, 35.53); and Form 241, reports of ,

activities conducted in Agreement States (10 CFR ,

150.20).

Issue Date: 03/12/84 6

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LICENSED MATERIALS PROGRAMS 87100-02.01e g leaking source. Inspections should be done for therapy mis-4 administrations that result in serious illness or death, 2 etc. . Depending on the content of the reports, where signifi-cant cause appears to exist for followup, the followup shall be done promptly to gather additional details about the

. cause of the event and the circumstances under which the event

occurre'd. Reports that indicate moderate health and safety problems may be followed up during the next inspection unless there appears to be sufficient cause for possible escalated enforcement actions. Judgment should be exercised on a case-by-case basis.

f. Records

References:

j' 10 CFR 20.401 Records of surveys, radiation monitoring, and disposal.

4 10 CFR 30.41 Transfer of byproduct material sources.

10 CFR 30.51 Records.

10 CFR 34.24 Radiation survey instrument calibration.

10 CFR 34.25 Leak testing, repair, tagging, opening, j modification, and replacement of sealed i sources.

10 CFR 34.26 Quarterly inventory.

10 CFR 34.27 Utilization logs.

_ . , 10 CFR 34.28 Inspection and maintenance of radio- ,

graphic exposure devices, storage con-

%) tainers and source changers, i

10 CFR 34.31 Training.

10 CFR 34.33 Personnel monitoring.

10 CFR 34.43 Radiation surveys.

! 10 CFR 35.21 Requirement to perform full calibration I

measurements of teletherapy units.

10 CFR 35.22 Requirement to perform periodic spot i check measurements of teletherapy units.

10 CFR 35.23 Requirement to calibrate instruments used for full calibration and spot check measurements.

10 CFR 35.24 Qualified expert.

10 CFR 35.44 Records of all misadministrations.

i 10 CFR 40.61 Records.

Applicable license conditions.

1 During the course of an inspection, most items examined will I

have attendant records to support each portion of the licensed activity. Some records should be only randomly e.xamined; i.e.,

satisfaction of the spot-checked to the inspector that the records are being maintained and complete. Other records that

' are more closely related to health and safety (such as personnel exposure records) should all be examined.

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87100-02.01f ,

However, examinations of records should not be construed as o .p the primary part cf the inspection program. Rather, obser-vations of areas where personnel work, equipment, usage, etc. , will give tne inspector a better idea of what is

. going on than records review and may also support what the records reveal. During examinations of records, look for trends, such as trends in air sampling. Records such as surveys, waste disposal, effluent releases, receipt and transfer of radioactive materials, ._ training.. . utilization . . __ .

logs and air sampling may be examined randomly until the inspector is satisfied that the records are being main-talped and are complete.

1 Records that should be examined in their AgLicaly include .

I personnel monitoring; leak testing of sealed sources; in- -

strument calibrations; raciography quarterly inventory of devices and sources; inspection and maintenance of radiographic exposure devices; source changers used; stor-age devices used; receipt and transfer records; final radiation surveys of radiographic exposure devices upon completion of usage; pocket dosimeter results and calibra-tions; and for teletheracy units, full calibration, spot-e check measurements and records of calibration of dose cali-

. brators and checks of dose calibrators. Other records to be examined may be found in license conditions such as e ALARA records, records of safety committee minutes, etc. f The extent to wnich records are to be examined, either randomly or in their entirety, will depend on the category of the licensee as well as the nistory of noncompliance of the licensee inspected. In each case, judgment will need to be exercised so that the inspector is satisfied that the l

licensed program is being operated safely to protect the health and safety of the workers and general public.

l 02.02 Authortrud Materials. Uses. and Users

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Determine from reviewing records, observing the use of radio-j active material, and discussing the activitius with licensee personnel, that the type, quantity, and use of material at the licensee's facility are authorized by the license. Specific

< records and areas to be reviewed are as follows:

a. Receipts. Transfers, and Package-handling Procedures:

i

References:

10 CFR 20.205 Procedures for picking up, receiving, and opening packages.

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10 CFR 30.41 Transfer of byproduct material. i 10 CFR 40.51 Transfer of source or byproduct material.

i Applicsble license conditions. / N f i

i Iss'ue Date: 03/12/84 8

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( b Depending on the size of the licensed program, the proce-dures (a few or many) will be found in the license appli-V)' " ' - cation. The procedures should be carefully reviewed before an inspection is conducted. The reason for such a review is to determine completeness, repeated procedures that may be

., contradictory, and procedures that should be in the app 11-cation but are missing.

The procedures for picking up, receiving, and opening pack-ages should include how and when packages will be picked up, radiation surveys and wipe tests of packages upon receipt, and procedures for, opening packages, such as where in the facility packages are received, surveyed, and opened. The procedures shoald also include what actions are to be taken if packages are contaminated in excess of .

specified Itatts and radiation levels are higher than limits (the latter would depend on the package index; i.e. ,

the dose rate at 3 feet for each category).

4 The inspector should randomly examine records of surveys of

- packages received and also determine if inventories for each licensed nuclide is within the Itcense limits. In this regard, records of inventories following receipt and transfer should always show that the materials on hand at any one time are within the license limit. The records examined should be compared with the physical inventories of materials possessed.

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By discussions with the licensee, inquire if the procedures have been changed or added to (requiring license amendment except for broad licenses). Randomly examine procedures used by the licensee to determine if they are in accordance l

' with those in the license application (if the licensee's procedures are supplementary to those in the license application).

b. Authorized Users l

\

Reforences:

10 CFR 33.17 Conditions of specific Itcenses of broad scope.

. 10 CFR 34.25 Leak testing, repair, tagging, opening, modification, and replacement of sealed I. sources.

I; App 1tcable license conditions.

C;

• Autnerized users will normally be named in the license

application, or, if the license is a broad Itcense, will be 9 Issue Date: 03/12/84

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appointed as authorized users by the radiation safety com- b-d '

mittee or isotopes committee. ins /

The inspector should determine during an inspection that named. authorized users are doing the work authorized rather than someone else not named in the license. This will depend on the wording in the license with phrases such as "used by or under the supervision of" except for radio-graphy Itcensees in which supervision for users is defined in 10 CFR 34. Guidance on the phrase "used by or under the supervision of" may be found in the "10 CFR" Section of the IE Manual under 10 CFR 30 issued on 10/1/79 entitled

" License Condition'...used by or under the supervision of...'." For some specific or broad licenses ( Types A, 8, ,

and C), the phrase for users is "under the direct super- -

vision of" which implies the authorized user should be present at the facilitdor easy contact or to observe the Inoiv1 dual (s) working under the authorized user.

Howeve'r, another phrase not often seen in ifcenses is

c. "under the direct supervision a'nd physical presence of"

' which means the authorized user must directly supervise and

- be present at the work station. Another phrase used for physicians doing patient therapy states "may only be used by." ,

The inspector must use more than the usual amount of judg- j ment during inspections to interpret the role of the .

• authorized user, considering the many license condition phrases used above. First, a determination of qualifica-tions should be made. Second, for broad licenses, the radiation safety committee appoints the authorized users based on . qualifications.

For a determination of required training, see " Training" under 02.01c of this procedure. In general, authorized users must be specifically licensed by the Commission or otherwise listed in the license application and in a license condition for specific tasks that only the indi-vidua1(s) named can perform. This includes leak testing of sealed sources, replacement of sealed sources, modification and opening for purposes of repairing or replacing sealed sources in teletherapy units and for radiography programs, changing sources from source changers or containers. Such authorized users may not be those of the licensee but of a separate firm specificzlly authorized by the Commission,

c. Authorized Uses

References:

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10 CFR 33.13 Requirements for the issuance of a Type A specific Ilcense of broad scope.

Issue date: 03/12/84 10

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. , . . . . . ~ .w.  : ,- .:.h i .;.. Q 2$5025:5.W$l?$i O. l LICENSED MATERIALS PROGRAMS 87100-02.02c j 10 CFR 33.14 Requirements for the issuance of a Type 8 g

specific license of broad scope.

- 10 CFR 35.31 General Itcense for medical use of cer-tain quantities of byproduct material.

10 CFR 35.100 Schedule A--Groups of medical uses of byproduct material.

Ap'plicable license conditions.

Authorized uses of radioactive materials, excluding broad and medical licenses, will be found in the licenses and license applications. Specific licenses will list the iso-topes, physical or chemical forms, and the maximum quanti-ties. The inspector should physically examine the inven-tory of radioactive material on hand or examine records of receipt and transfer to determine that quantities and forms are as authorized. For medical licenses of broad scope (Type A, 8. C) the maximum quantities are listed (or narrated for Type A) in 10 CFR 33.100. For broad 11-conses, any chemics) or physical form is authorized.

- Medical licensees have groups listed on the license. There are six groups. The groups, form, and authorized uses, are listed in 10 CFR 35.100. There is also a medical general license that permits the use of a limited number of iso-topes in small quantities. General licensees are not normally inspected except for cause. The inspector must

' determine that nuclides are used as authorized, parti-

cularly for human use, that could otherwise become a i misadministration if not used as authorized. For medical facilities or institutions, examine patient log books to determine that radioactive materials are used in proper chemical form on patients.

d. Material Control -

References:

1 10 CFR 20.207 Storage and control of licensed mater-1 ials in unrestricted areas.

10 CFR 34.22 Locking of radiographic exposure devices, storage containers, and source changers.

10 CFR 34.23 Storage precautions.

Applicable license conditions.

The inspector should examine storage areas in unrestricted and restricted areas. Such storage areas should be locked and have limited and controlled access. In general,there will be procedures for access controls. Additional con-trols should include loggingout radioactive material from storage arsas and logging it in after use. This is espect-ally important for medical institutions because of the use of small implant seeds for therapy. In the past, many seeds F ;-~ ) have been lost because of the failure of controls. The inspector should also determine that radioactive storage

/

11 !ssue Date: 03/12/84 l .

ildN$rMEine$nnc MMd;ys,CE$:. - 4': lg h/g.h".'h}Qih1% g q M MJ a L ,

87100-02.02e LICENSED MATERIALS PROGRAMS .-

' devices and source changers are locked when in storage and N that storage areas are also locked when not in use,

e. Area Radiation and Contamination Control D ..

References:

10 CFR 19.11 Posting of notices to workers.

10 CFR 20.105 Permissible levels-of radiation in

i restricted areas.

!I 10 CFR 20.201 Surveys.

I 10 CFR 20.203 Caution signs, labels, signals, and

! controls.

10 CFR 20.204 Caution signs, labels, signals, and .

lt controls: exceptions. -

Applicable license conditions.

ll j1 The inspector should ensure, during observation and by

l direct measurement, that the radiation levels in unre-

i stricted areas are within the limits of 10 CFR 20.105(b).

The limits are 2 mR in any one hour or 100 mR per seven

! l' consecutive days, whichever is more restrictive. For this

!i regulation, occupancy is _no,t a factor. The inspector may i ask the Itcensee to spot-check radiation levels in selected areas using the licensee's own instrumentation, or, prefer- c

l ably, the inspector may use his/her own instruments.

By definition, surveys of fadioactive materials or radia-i tion areas are supposed to be done before the fact, not after an individual gets exposed. If practicable, observe how Ifcensees conduct surveys to determine the adequacy of

surveys, particularly during the conduct of radiography l

operations. .Also, note the types of instruments used,' and

. whether they are designed for the type of radiation being

+ measured. .

! During the physical operations review (facility walk-

! through) observe that proper caution signs are being used at access points to areas containing radioactive materials, i radiation areas, and those areas containing airborne i i

radioactive materials. Randomly observe labeling on pack-ages or other containers to determine that proper informa-tion is recorded such as isotope, quantity, and date of measurement. 10 CFR 20.204 provides exceptions to posting caution signs, primarily for medigal institutions.  ;

Some types of licenses, such as those for teletherapy rooms, radiography (fixed or permanent facilities), and irradiator operations also require signals or alarms, both visible and audible. The inspector should examine these to determine operability. In addition, during the walkthrough i examine locations where notices (NRC Form 3) to workersare.' i i posted. These should be located so that employees may examine them on their way to and from work locations.

Issue Date: 03/12/84 12 3

_ .;p.: .u . ...L..a...:N...~.; bbi U'.ib;] %.5.N:.5 0 $5Li.b uY R ab?;1blE$ $

=. u . . . . - -. . .

f LICENSED MATERIALS PROGRAMS 87100-02.02f

,, f. Packagina and Transportation

~

References.

10 CFR 71 Packaging of Radioactive Material for

- Transport and Transportation of Radio- ,

active Materials Under Certain Condi-l tions. .

l 49 CFR 170-199 Use IE Insper. tion Procedure No. 86740,

" Transportation" as applicable.

. 02.03 Physical Plant Facilities and Equipment General Most of the following line items are found in license applica-tions and will vary, depending on the type of licensed activity, and may not be all inclusive. These items should be inspected during the facility tour (operations review). Other items may be identified in the regulations and may also be repeated in the license appilcation for implementation of the requirements.-

References:

10 CFR 20.3(17) Unrestricted area.

h);.

10 CFR 20.202(b)(2) Radiation area.

10 CFR 20.202(b)(3) High radiation area.

10 CFR 20.207(a) and (b), 10 CFR 34.23 and Appiteation Storage precautions.

10 CFR 34.21 Limits on levels of radiation for radio-graphic exposure devices and storage con-tainers.

10 CFR 34.29 Permanent radiographic installations.

10 CFR 34.34 10 CFR 35.22 Requirements to calibrate instru-cents used for full calibration and spot-check measurements.

10 CFR 34.41 Security 10 CFR 35.21 Requirements to perform full calibration measurements of teletherapy units.

Integration of receiving, processing, shipping, and administra-l tive areas.

i Plant utility services and backup services.

l' Operations - fabrication (hoods, other equipment, radiography devices, etc.).

Ventilation and exhaust systems.

Teletherapy units.

1. Other applicable license conditions.

l I

13 Issue Date: 03/12/84

l. .

hJyh:ihOldadshe@-ilNECr/dMMCh;gl@cc T d.,946 22WdMN N LICENSED MATERIALS PROGRAMS' 87100-02.03 .

Review and verify that the equipment and the physical facility promote safe conduct of the licensed activity. The facility and QN equipment should conform to that described in the license appli-cation and the equipment should be operable. Systems, subsystems, and equipment important to the safe handling of materials and for protection of operating personnel and the public. should be (1) examined for operability and (2) designed to carry out intended functions.

02.04 Radiation Protection Use IE Inspection Procedure 83822 " Radiation Protection" as applicable. .

! 02.05 Radicactive Effluents and Waste Disposal I

} Regulatory references and license applications:

-l 10 CFR 20.106 Radioactivity in effluents to unrestricted d

• areas.

l 10 CFR 20.301 General requirement.

I 10 CFR 20.302 Method for obtaining approval of proposed l disposal procedures.

i 10 CFR 20.305 Treatment or disposal by incineration.

10 CFR 20.306 Disposal of specific wastes. f '

10 CFR 20.401 Records of surveys, radiation monitoring, ( }

and disposal. A /j 10 CFR 30.51 Records.

i Records.

Systems.

Monitoring equipment '

1. Calibration

2. Physical controls

.; 3. Testing Administrative procedures.

Environmental monitoring.

. License requirements of waste site recipient.

' Other applicable license conditions.

Review and verify that waste-handling equipment, monitoring equipment, and/or administrative controls are adequate to main-

.j tain radioactive effluents within the limits established by the i

license and other regulatory requirements and are ALARA.

Examine the waste release records generated since the last inspection, all annual or semiannual reports, all pertinent non-

' routine event reports, and a random selection of Ifquid and air-borne waste release records. Randomly select procedures for both liquid and airborne systems and verify that the procedural I.

i steps are being followed. The verification should be made by whatever means available; i . e. , perform an observation of an h

i operation, a review or selected records, etc.

l 14 Issue Date: 03/12/84 .

w iM r- w .m. ,_

. x l .: $ ..~.u." : ai.w.w w , S :.k.. E .S & T:8 k % $ L W L t M .W h t % M i. % .H ..:. a . l LICE" 88 MATERIALS PROGRAMS 87100-02.06 p 02.06 Confirmatory Measurements C51mpare/ verify on a sampling basis survey results or data that are used by the licensee to show compliance with the regulations or license conditions. Examples of confirmatory measurements are:

a. physical surveys

b. split samples, etc.

87100-03 INSPECTION GUIDANCE General:-

All inspections sbuld include a mix of records and procedures review, observations, confirmatory measurements, and discussions with personnel involved in the " hands on" work. -

03.01 Procram Administration a.- The. regulatory requirements related to the organization and administration of the licensed program will be contained in the license condition. The organization should be examined to verify that the responsibilities and authorizations of designated individuals comply with license conditions.

N b. The inspection is a verification of implementation of the h required program. In the review to verify implementation, the inspector should pay attention to the scope of the pro-gram; frequency of licensee audits; the use of qualified auditors; procedure for recording and reporting deficien-cies to management; methods and completion of followup actions by management; and the policy regarding announced and unannounced audits.

c. In verifying the implementation of the approved or required training program *, pay attention to completion of require-ments related to: initial training, periodic retraining, on-the-job training, and tests and examinations of trainees (if

! applicable).

d. Regulatory requirements related to procedures will be con-l It is necessary to verify I

tained in license conditions.

that operating and emergency procedures have been devel-oped, are r.dequate and functional, and have been reviewed and approved by management.

! e. No guidance.

f. No guidance.

I j',^

\'

15 Issue Date: 03/12/84

Y N %Oba @gMy ;ggjy y;,;,. g.  ;; , , , -

13 $5: a 8=W LICENSED MATERIALS PROGRAMS .

87100-03.02 03.02 Authorized Materials. Uses and Users General: Authorized materials, uses, and users are generally described and authorized by the license, or as otherwise author-ized in 10 CFR Part 33.

a. Receipt and transfer of materials should generally be detailed in procedures sufficient to provide assurance of compliance with regulatory requirennts. ItSpecific require-is necessary to ments are set forth in 10 CFR 20.205.

assure that only authorized persons are involved in the transfer and receipt of materials. .

The frequency of inventories is dictated by need or as .

specifically set forth in certain parts of 10 CFR or in license conditions. License inventories can be used for two purposes: (1) to track the use of material, and (2) to verify that the licensee is only receiving materials autho-rized in the amounts listed in the license.

b. No guidance.

c. No guidance.

s

d. Various These strategies for control of materials should be place. are generally defined by procedures andin [e )%p should assure that use is lialted to authorized users and U#

that secure storage is provided.

i

e. No guidance,

f. Specific guidance is set forth in IE Inspection Procedure 86740. s 03.03 Physical Plant Facilities and Equipment Descriptions of the physical plant are generally found in the applications for a license and subsequent amendments that are usually tied down to a license condition. The actual or as-built facility should be configured to provide safe working areas separated from unrestricted areas and sufficient access controls to preclude unauthorized entry. The facility should include utili-ties and other services sufficient to cope with emergencies, such as loss of power, loss of contamination control, etc.

Plant equipment is generally described in documents as noted

- above. Plant equipment should be appropriate to the sqope of the licensed program. Processing equipment, associated pro-cess control equipment and ventilation and exhaust systems should be suf ficient to provide safe use, handling and storage r '

of the materials in use.

Issue Date: 03/12/84 16

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LIrENSED MATERIALS rR0 GRAMS 87100-03.05 03.04 Radiation Protection

- Specific guidance is set forth in Inspection Procedure No.

~ ' 83822.

03.05 Radioactive Effluents and Waste Disposal n.' No guidance.

b. No guidance.

c. Review the reports and records for obvious mistakes, anoma-Ious measurements, trends, missing data (compare the recorded data with the requirements), and verify the accuracy of the data in the report or record with the li-consee if any of these aspects are identified or suspected. -

The objective of a calibration is to ensure the continued adequacy and operability of the instrument system. The adequacy of the system is judged on the basis of its stabi-lity with time and ability to reproduce measurements within acceptable limits (that must be specified by the licenses in his calibration procedures) over the useful range of the instrument. The useful range must encompass the normal and reasonable expected values of the monitored variable, including valees expected from anticipated operational occurrences.

The term " calibration" may be defined in license require-ments, but if it is not, use the following:

" A CHANNEL CALIBRATION shall be the adjustment, as neces-sary of the channel output such that it responds within the necessary range and accuracy to known values of the para-meter which the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel including the sensor and alarm and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST. The CHANNEL CALIBRATION may be performed by any series of sequential overlapping or total channel steps such that the entire channel is calibrated."

The calibration procedure and method used should:

1. check the response over the range of the readout device; for example, 1/4, 1/2, 3/4;

2. verify the actuation at prescribed setpoints of alarms or other automatic functions of the system;

3. require periodic (i.e. , at least quarterly) compar-isons of monitor readings against the concentra-

r. s] tions (or release rates) of radioactive material in the monitored release path;

/

.g 17 Issue Date: 03/12/84 S

i W .S//N il,r:d1dE h H^ndin kU @ :$ M i b T S BiR M154h'fd;ihA 2 & in de d r M LICENSED MATERIALS. PROGRAMS 87100-03.05 *

4. verify that the sensitivity of the monitor is within '

an acceptable range--the background radiation, inter-nel to the monitor from buildup of radioactive mate-rials or from external sources, remains at an accep-

. table level; C. be performed using a written procedure approved by appropriate plant supervision; and

6. require documentation of the results and review and approval of the results by appropriate plant super-vision.

The setpoints of effluent and process monitors should be set -

forth in written procedures along with instructions that des- ~

cribe the rules and authority required to change specified set-points. The bases for each setpoint should be known by the operators / technicians' and should be explained in plant proce-dures.

The comparison of monitored readings with laboratory measure-ments of radioactive material in the release path is made pri-marily to ensure the response of the monitor is within an acceptable range for values which form the bases for the alarm and trip setpoints.

f '

d. No guidance. .o

e. No guidance,

f. No guidance.

g. No guidance.

h. No guidance.

1. No guidance.

j. No guidance,

k. No guidance.

1.' No guidance,

m. No guidance.

i .

03.06 Confirmatory Measurements

~

Confirmatory measurements should be in sufficient scope to verify survey results or data as found in the licensee's Examples--radiation levels in an unrestricted area; records.

airflow to process or fume hoods; and air samples in process .h areas.

Issue Date: .03/12/84 18

. .h.O. . L.b.S.l A 5 $ $$ S E DN.Nl$:NS k:DE.&O$0.!'. .:-..:.. ..; .. . . . . .

LICENSE 0 MATERIALS PROGRAMS 87100-03 04 87100-04 A00!TIONAL REFERENCES Procram Administration (Section 03.01)

RG 7.1 Administrative Guide for Packaging and Transporting Radioactive Material.

RG 7.7 Administrative Guide for Verifying Compliance With Packaging Requirements for Shipments of Radioactive Materials.

RG 8.2 Administrative Practices in Radiation Monitoring.

RG 8.7 Occupational Radiation Exposure Records System.

RG 8.10 Operating Philosophy for Maintaining Occupational Radiation -

- Exposures As Low As Is Re.sonably Achievable.

l RG 8.13 Instruction Concerning Prenatal Radiation Exposure.

RG 8.15 Acceptable Programs for Respiratory Protection.

KG 8.18 Information Relative to Ensuring That occupational Radiation

• . Exposures at Medical Institutions Will Be As Low As Reasonably Achievable.

., ., RG 10.1 Compilation of Reporting Requirements for Persons Subject to NAC

.j q Regulations.

lf ) RG 10.2 Guidance to Academic Institutions Applying for Specific Byproduct j

Materials Licenses of Limited Scope.

1

.i RG 10.3 Guide for the Preparation of Applications for Special Nuclear Material License of Less Than Critical Mass Quantities.

RG 10.5 Applications for Ty'pe A Licenses of Broad Scope.

I Guide for the Preparation of Applications for Use of Sealed i RG 10.6 Sources and Devices for the Performance of Industrial Radio-

'. graphy.

RG 10.7 Guide for the Preparation of Applications for Licenses for Labor-

'l - atory Use of Sma11 Quantities of Byproduct Materfa1.

RG 10.8 Guide for the Preparation of Applications for Medical Programs.

• RG 10.9 Guide for the Preparation of Applications for Licenses for the Use j of Gamma Irradiators.

DRAFT RG Guide for the Preparation of Applications for Licenses in Medical

'l Teletherapy Programs.

T'S Authorized Materials, Uses and Users (Section 03.02) lj ( Y)

RG 6.1 Leak Testing Radioactive Brachytherapy Sources.

,j 24

'I 19 !ssue Date: 03/12/84 e- - . _ . _ . , _

n .s.A_. _1=0'u.

. . :i::> iRiEk:u. &u%GC ShiluM46hSO5sud1% s l

LICENSED MATERIALS PROGRAMS 87100-04 RG 7.2 Packaging and Transporting of Radioactively Contaminated Bio- 3 logical Materials.

RG 7.3 Procedures for Picking up and Receiving Packages of Radioactive Material.

RG 7.4 Leakage Tests on Packages for Shipment of Radioactive Materials.

RG 8.21 Health Physics Surveys for Oyproduct Material at NRC-Licensed Processing and Manufacturing Plants.

Physical Plant Facilities and Eautoment (Section 03.03)

RG 3.2 Efficiency Testing of Air-Cleaning Systems Containing Devices for Removal of Particles. .

RG 8.1 Radiation Symbol.

RG 8.5 Immediate Evacuation Signal.

Radiation Protection (Section 03.04)

RG 8.3 Film Badge Performance Criteria.

RG 8.4 Direct-Reading and Indirect-Reading Pocket Dosimeters.

RG 8.6 Standard Test Procedures for Geiger-Mueller Counters. [)

O -

RG 8.7 Occupational Radiation Exposure Records System.

RG 8.9 Acceptable Concepts, Models, Equations and Assumptions for a Bioassay Program.

RG 8.14 Personnel Neutron Oosimeters.

I RG 8.15 Acceptable Programs for Respiratory Protection.

RG 8.20 Applications of Bioassay for I-125 and I-131.

RG 8.21 Health Physics Surveys for Byproduct Material at NRC-Licensed Processing and Manufacturing Plants.

RG 8.23 Health Physics Surveys at Medical Institutions.

RG 8.25 Calibration and Error Limits of Air Sampling Instruments for Total Volume of Air Sampled.

RG 8.28 Audible Alarm Dosimeters.

3 Radioactive Effluents and Waste Ofsposal_ (Section 03.05)

J RG 4.15 Quality Assurance for Radiological Monitoring Programs (Normat<%

l Operations) - Effluent Streams and the Environment.

Issue Date: 03/12/84 20

_m.~~ x _ - - - . - _ . _.

Nluy6..u.&J.%G ~L:,4.2 ay2 . . . . .~. .wa...,. . . .. .

LICENSED MATERIALS PROGRAMS 87100-04 RG 7.1 Administrative Guide for Packaging and Transporting Radioactive s

) Material.

RG 7. 4 LU Eage Tests on Packages for Shipment of Radioactive Materials.

Requirements for Shipments of Radioactive Materials.

RG 7. 5 Administrative Guide for obtaining Exemptions From certain NRC Requirements Over Radioactive Material Shipments.

RG 7.7 Administrative Guide for Verifying Compliance With Packaging.

Transportation

. IN 79-21 Transporting and Commercial 8urial of Radioactive Waste.

IN 80-24 Low Level Waste Burial Criteria.

IN 80-25 Transportation of Pyrophoric Uranium.

IN 80-32 Clarification of Certain Requirements for Exclusive Use Shipments of Raviioactive Materials.

IN 80-32 Rev. 1 - same. -

IN 81-02 Transportation of Padiography Devices. ,

IN 81-32 Transfer and/or Disposal of Spent Generators.

IN 82-24 Water Leaking From Uranium (H-FLU 0a!DE).

IN 82-47 Transportation of Type A Quantities of Non-Fissile Radioactive Materials.

Medical IN 80-33 Determination of Teletherapy Timer Accuracy.

IN 80-35 Leaking and Dislodged Iodine-125 Irplant Seeds.

IN 80-35 Supplement 1 Leaking and Dislodged 1-125 Implant Seeds.

IN 81-32 Transfer and/or Disposal of Spent Generators.

IN 82-33 Control of Radiation Levels in Unrestricted Areas Adjacent to Orachytherapy Patients.

END

. 21 Issue Date: 03/12/84 o

- . . - _ _ _ ~ - . _ . , , .m_.__,--,--%

7. .. ..

• / \" UNITED STATES '

i e' NUCLEAR MEGULATORY COMMISSION 5 f OFFICE OF INSPECTION AND ENFORCEMENT WasNngton, D.C. 20555 i

.( } ' . ......

.p .

INSPECTION AND ENFORCEMENT MANUAL

• OASIP INSPECTION PROCEDURE 83822 RA0!ATION PROTECTION PROGRAM APPLICA8{LITY: 2600, 2800 R l .

83422-01 INSPECTION OBJECTIVE To detamine whether the licensee is complying with regulatory require- -

ments related to radiation protection, and to evaluate the adequacy of certain aspects of the licensee's radiation protection program.

83822-02 INSPECTION REQUIREMENTS 02.01 Radiation Protection Procedures

. Verify that changes in the radiological protection procedures

- %y -' made since the last inspection are consistent with regulations

' and license requirements.

02.02 Instruments and foufoment i

Verify that radiation protection instruments and equipment are operable, have the proper alars settings (if applicable), ,and are calibrated in accordance with license re'quirements and licensee procedures.

02.03 Exoosure controls

a. External Exoosure Determine compliance with the following regulatory require-ments:

1. 10 CFR 20.202(a) (personnel monitoring)

2. 10 CFR 20.101(a) (permissible doses)

3. 10 CFR 20.101(b) (extended permissible doses)

4. 10 CFR 20.104(a) (exposure of minors 7

5. 10 CFR 20.102 (exposure history)

Al h Issue Date: 01/01/84

, - - _ . . _ _ _ _ _ _ _ _ . . _ _ . . . . _ . . _ _ _ _ _ _ . _ . . _ _ . . _ , , , _ _ _ . _ _ _ . . , _ _ . _ .__.,_.__.-_..,s, _ __

.2 . . ._

. . . ., e RADIATION PROTECTION ,

43822-02.03a6

6. 10 CFR 20.401(a) (exposure records) f

.J 2

~

b. Internal Exposure Determine compliance.with the following regulations: .

1. 10 CFR 20.103(a)(1) ' 'and (a)(2) (internal ~ exposure i

" limits)

2. 10 CFR 20.103(a)(',) (air sampling and bioassay pro-

gram)

3. 10 C'R 20.103(b)(1) (use of enginaering controls)

4. 10 CFR 20.103(b)(2) (40-hour control measure and i evalues. ions)

c. Respiraton; 'rotection For facilities with a respir.atory protection program, in

accordance with 10 CFR 20.103(c), also determine comp 11-ance with the following:

l R

1. 10 CFR 20.103(c.) (certification by MICSH/MSHA) i

2. 10 CFR 20.103(c)(1) (selection of equipment) s

3. 10 CFR 20.103(c)(2) (maintenance, training, and R

• fitting)

R

4. 10 CFR 20.103(c)(3) (policy statement re: routine, R emergency, and relief) 4 5, 10 CFR 20.103(c)(4) (special capabilities)

R

6. 10 CFR 20.103(d) (protection factors) 4

7. 10 CFR 20.103(e) (allowancis of protection factors A for unacproved equipment) f 02.04 Post!nc. Labeline, and Control

a. Postino and Labelinc Determine c:mplianca with tne following regulations anc

• license pescedures:

1, 10 CFR 20.203(b) (radiation area)

2. 10 CFR 20.203(c) (high radiation area)

3. 10 CFR 20.203(d) (airborne radioactivity area) 01/01/84 2 Issue Date: .

--...,.,..--._e-. *

.- s -- - - - , . _ . . , , - - , ,

, , . , , - - _ - - - _ . ~ . - . _ _ - . , - - , , , -, - ,---,, ----.--

~

, . .u . ., . I- . . . . s.

... . ... . ..cEl,55.0 .51!%'l G.1~5N&lk.i.$c$0..:uldY:Shk 83822-02.04.4

. RdOIATIONPRCTECTION

[ T 4. 10 CFR 20.203(e) (radioactive materials area)

\f/

5. 10 CFR 20.203(f) (container labeling)

. . 5. Other posting and labeling requirements specified in

.. the license or licensee procedures

. 6. Control Determine compliance with the following regulations.

! license requirements, and licensee procedures: .

j .

, 1. 10 CFR 20.203(c) (high radiation area access)

2. 10 CFR 20.207 (storage area)

. 3. Radiological Work Permit systes specified in license l requirements or licensee procedures j ,

4. Controls for radioactive, or contaminated areas and equipment specified in license requirements or licensee procedures

!:1 .

c. Postina of Notices i

3.,

Determine compliance with 10 CFR 19.11.

~[

'd Surveys

/ 02.05 o'

,., a. Recuirements Determine compliance with'the following regulations:

.! 1. 10 CFR 20.201(b) (surveys) 1 10 CFR 20.401(b) (survey records) 2 2.

l .

1

b. Leak Tests

t Verify compliance with license requiree.ents for leak test-ing of radioactive sealed sources.

02.06 Notifications and Reports

}

I -

a. To the NRC o

' Determine compliance with the following regulations and

,I license requirements:

.)

1. 10 CFR 20.402 (loss or theft of sisterial)

2. 10 CFR 20.403 (incidents) l* r iI

.s

?

3 !ssue Date: 01/01/84 i

RADIATION P4STECTICN -

83822-02.0623 9

3. 10 CFR 20.405 (overexposure) ,

4. 10 CFR 20.408 (termination of work report) i  :

5. Other radiation protection reports required by the

. license

b. To the frYividual .

Determine compliance with 10 CFR 19.13.

! .T .

f 83822-03 INSPECTION GUIDANCE ,

i t .

General Review of the licensee's HP log book or file on HP

! problems may be useful to identify areas deserving special j , attention. Particular attention should be directed towards .

identifying trends and ascertaining whether corrective actions

were directed toward the cause and not merely the symptoms.

F I , Regulatory Guides 8.8 and 8.10 may bi discussed in terms of providing useful guidance to the licensee regarding ALAAA. .If

• the licensee has a documented ccomitment to ALARA, implement-

' ation of the ' program should be discussed with management. With .

respect to implementing ALARA commitments, citations will 'not be made for failure to achieve ".1.imits" (or goals) that are l

i more restrictive tnan regulatory requirements. R

'\

Thelicenseemayhavesubmittedcertainofhisradiationp L g

- tion procedures, or his radiation protection manual, alon d with the license apolication and in some cases, those proced-2 t

ures or the manual may be incorporated into license recuire-j ments. There: are references to licensee procedures throughout i'

tnis inspecti'on peccedure; however, tnis is not done for all d nspection areas. The absence of. a notation regarding licensee

} .

proced'u'res is: not intended to precluce the inspector from in-i specting a gfven area against licensee procedures if snere is l an applicable license requirement.

1 taciation Protectfen prececures 4

03.01 1

Review all substantive changes to crocedures whien have been 1

isolemented since the last inscocticn; verify that limits, ij precautions, controls, etc., specifiec in the procecures are consistant with regulations and license requirements.

r 03.02 Instruments and Ecufement l

Rancomly select instruments of each major type and examine R i

a.

3 them to verify operamility and proper alarm settings , if l alarm settings a.e applicable. These may include portable

' survey instruments, fixed monitoring equipment, constant air (

menitors, portable air samplers, film badges and TLDs, an" .,

pocket cosimeters. j 1

01/01/84 4

! Issue Date:

I

1. i. .,: - .. c.. . .Y ?l. ....... .1:. N5.551$Di.'.$0h .SC$?Md!V:r.S$Nb W.5NY:iM E"L. :. .

Ric!ATION P C ECN ?,

83822-03.02

- b. Review the most recent calibration records of the instrv-

' ment (s) selected for inspection to assure that the calibra-(',k4) .

tion and surveillance program for these instruments are being accomplished in accordance with license requirements er licensee procedures.

c. V4Hfy that the licensee has a system (a schedule, card e

file, etc.) which identifies all the instruments and identifies when they are due for calibration or fune.tional,

. testing.

d. Verify that the procedures used 'to calibrate the instru-ments selected above contain: review and approval require-ments of the licensee's procedural system or license requirements, acceptance criteria including vtlues for trip settings that confom to license requirements, if applic- .

amle, and detailed. stepwise instructions.

03.03 Exposure Controls .

. a. External Exposu're

1. Examine any changes made in procedures for control and use of personnel monitoring equipment; verify that limits, precautions, controls, etc., specified in the h procedures are consistent with regulations and ifcense jj requirements.

Examine the type of ' monitor'ing devices used, the period of use or exchange period, and the number used to determine if tnese aspects seem consistent with the monitoring program. Determine who the supplier is, and if the service has been changed since the last inspec-tion, determine the reasons for the change.

l For pocket dosimeters ce pocket chambers, determine when they are read and recharged, the number used, and review the cali3 ration procedure or leak test proca-dure.

Evaluate the adecuacy of the licensee's procedures or system for evaluating and using personnel monitoring data to control and minimize exposures.

2. Review reports of exposure sumaries generated since the last inspection to determine compliance.

3. Select all individuals who have current exposures R in excess of 10 CFR 20.101(a) limits and verify that Fom NRC 4 was completed prior to exceeding theR

-. 10 CFR 20.101(a) limit for each individual.

! i 5 Issue Date: 01/01/84

a ~- t' -

~

i- . ... _ . .

RADIATION PRCTECTION

.~

83822-03.03ac 4.- Determine, by discussion with supervision, if sincrs i have been permitted to work in restricted areas and; t if so, determine compliance with 10 CFR 20.104(a) by

)

review of exposure records,.

5. Review all NRC Forms 5 to determine compliance. R

- ., b. Internal Exposure l

' s- 1. During review of exposure evaluations in 03.03b4 t ~ , below, determine compliance with the internal-exposu s I

. . limits.

2. Review randomly selected air sampling and bicassay

' - records and independently verify airborne ccncentra-tions as appropriate. .

3. By observation, discussion, and revie'w of documenta-tion, verify that temporary engineering controls are l

considered and used to the extent practicable. Evalu-I ation of fixed process and engineerthg controls will be performed by the Division of I.icens'ing; the in-spection program will evaluate the use of temporary engineering controls.

i

4. Review documentation of evaluations performed as the result of suspected ovecexposures or when the 40 MPCC '

hour control value was exceeded. Include verificatio i I

of the following: Q

' (a) Appropriateness of preventative measures institu-tad following an exposure greater than the 40 2 MPC-hour control value (b) Proper use of 25% and 5% MPC-nour exclusions 4 l

For facilities with a respiratory protection program, l

include in 03.03ba, the fc11cwing:

l

c. Reseiratory Protection

1. Determine that the. equipment is certified by NIOSH/ R l* MSHA R

R

2. Detemine proper selection of acui;: ment.

3 Determine by review of records and discussions that a

!I 3.

maintenance and training program is conducted anc

', that it is administered and conducted in accordance

~ with written procedures. Determine by review of re-

~3 cords, discussions, anc ceservations that respirator

!s .

i- -,

,a l1 Issue Date: 01/01/84 I

~ . - . , - , .-- . - . . . -

- - . . . . : .. . . i. . 5.Z..n.2. N O D fDi.sh S%b M.:.l5f& WitA.% iin A.. .. I:d . .

y ,... .

g.,, ,- - ; -

~

83822-03.03c3

. RAc!ATICN PROTECTION g

users are individually fitted for respirators and

.m, that respiratory equipment is operationally tested immediately prior to each use.

4. Randomly select several control requirements and deter-eine compliance by review of records, discussions, or observation. .

'. 5. In the selection and use of respiratory protective equipment, the ALARA statement of 10 CFR 20.103(b)(2) is met by selection of equipment to provide a protec-tion factor greater than the multiple by. which peak concentrations are expected to exceed the values of Table I, Appendix 5, 10 CFR Part 20.

03.04 Postina.Labelfac, and Control .

a. PostinoandLabeljg ,

Inspect representative areas to verify compliance; pay particular attention to " temporary" work areas that may be required for maintenance activity, etc.

Inspect a random sampling of containers in work or stor- R R

- age areas.

- I . b. Control

1. Randomly select high radiation areas to verify that R access is controlled in accordance with regulations or license requirements.

2. Inspect areas where radioactive material is located R.

or stored in an unrestricted area.

. 3. Review a random selection of RWPs on file and those RR currently in effect.

4. Review a random selection of records and inspect work t..eas to detemine compliance with controls.

c. Postino of Notices Determine, by questioning of management, hew the if censee complies with the requiremer.ts of 10 CFR 19.11; inspect bulletin boards or other places where notices are po'sted; question a few individuals to determine if they are awareR of the posting of notices.

h( "Xl 1 .

7 Issue Date: '01/01/84

_m ,c_ , , . . , , _ _ _ . _ . _ _ _ , , _ . _ , . . . - - - - - , . .

Idd ., . ;.L s iIi.1. . . . ,, .J . ;. . -. . J . . J.. . . . , . . .... a.

. 8382203.05 RAC!AT!CN cR0Ti!CTION 03.05 surveys

a. Requirements Verify that the lic'ensee has established schedules ' for periodic surveys of work areas of the plant and facility sita; verify that surveys are conducted using approved

~; pr9cedures; review a random selection of survey records R to see that surveys are being performed according to schedules; and verify that the survey rasults are reviewed  !

by appropriate supervision.

Verify specifically that schedule and procedural require-ments for surveys appear adequate to demonstrate compliance

.. with the following aspects of the regulations and with pertinent license requirements. -l

1. 10 CFR 20.101 and 20.104 (permissible doses)

Determine whether due consideration is given to energy, beta exposure, and extremity exposure, and whether neutron surveys a're performed if appropriate. .

2. 10 CFR 20:103 and 20.104 (exposure to airborne radio-activity)

Determine whether both particulates and halogens arm considered, if appropriate.

3. 10 CFR 20.203 (posted areas) l

4. 10 CFR 20.105(b) (radiation in unrestricted areas)

b. Leak Tests Inspect a random selection of records of leak tests of R radioactive sealed sources. R 03.06 Notifications and Recorts

a. To the NRC The objective is to deteWne if the licensee is reporting all the events and data recuirea by the regulations and the license. The inspector should have reviewec those reports i submitted since the last inspection; therefore, a deter-mination should be made whether events have occurred wnich

' - have not been reported. A discussion with management, operating personnel, maintenance, and health physics personnel, and review of RYPs, log books, and other cata during the course of the inspection should aid in this ceter nination. .

i Issue Date: 01/01/84 8 1

__ _ . - ~ . - - - - - , - ,.%-r.' ,.,,-,,x , .--.,,~. ~ . - , . .

y~... ~ .

. .2.:- . 'st. >.. 0 3. n z/t.:..i'iO.O,,. L Jsh.;i.d.i.j.23 h ;1 f,9 h...,7 .

23822-03.050 RADIATION PROTECT!ON For followup on the corrective actions taken by' the ti-consee as a result of reports, see Inspection Procedure M) .

90826, Followup Nonroutine Events.

b. To the Individual -

)

Detarmine by discussion with individuals selected at ran- R

- dos (identified during the course of inspection of other requirements) whether they were notified in accordance

- with 10 CFR 19.13.

9 END e

I l

i 1

'i .

p**e 1 9 I , .

9 Issue Date: 01/01/84

.f

$ll66 l P-OO13 (p p""%,I *.

.. UNITED STATES YL w h 4""~o4fa i E NUCLEAR REGULATORY COMMISSION

%  ! OFFICE OF INSPECTION AND ENFORCEMENT

• g, ,/ Washington, D.C. 20555 INSPECTION AND ENFORCEMENT MANUAL DI INSPECTION PROCEDURE 83890 CLOSE0VT INSPECTION AND SURVEY PROGRAM APPLICABILITY: 2600, 2800 83890-01 INSPECTION OBJECTIVE The objective of the procedure is to verify that a facility where licensed

. materials were used has been decontaminated to acceptable levels and- to assure that the facility will not present a radiation hazard to future occupants.

83890-02 INSPECTIOr4 REQUIREMENTS 02.01 Preliminaiy Review. Determine the scope of the licensee's pro-j gram ano the potential for site contamination.

02.02 Disposition of Materials

a. Confirm by inspection of records (inventory, transfer, dis-posal, etc.) and Form NRC-314," Certification of Disposition of Materials," that licensed material has been transferred to an authorized recipient, and/or

b. Verify by inspection of the licensee's facility that licensed material and radioactive / contaminated equipment, materials, scrap, etc. are not being used or stored. This should be done following receipt and evaluation of reports R cf the facility's status as required by 10CFR 30.36, 40.42, R and 70.38. R 02.03 Surveys by Regional Offices. The NRC regional office will R review each proposed retirement of expired, superseded, or ter- R minated license to determine the necessity of performing aR closeout survey. The review will be on a case-by-case basis R using the following criteria. R

a. Those facilities that meet the following criteria do not R require a confirmatory survey: R f 1. An adequate closeout survey has been conducted by the R licensee. R l

Issue Date: 04/10/85

83890-02.03a CLOSEOUT INSPECTION & SURVEY

2. Use has been limited to small quantities of radio- R n nuclides with half-lives of 60 days or less. R F

3. The use of sealed sources only (if leak tests have R been <0.005 pCi). R

4. The use of limited materials that pose a very low risk R to public health and safety. R

b. Those facilities that meet the following criteria do R require a confirmatory survey: R

1. Use of unsealed radionuclides with half-lives in R excess of 60 days where significant residual contami- R nation is possible. R

2. A significant safety issue has occurred (for example R an enforcement conference and civil penalties during R the course of the license) other than licensees in R'

. a.3. R

3. Politically sensitive issues, such as cases pending R before a hearing board, or other technical issues that R have been brought to the attention of the NRC by con- R cerned citizens or elected public officials. ,

R

4. An adequate closeout survey has not been conducted by R the licensee. R 02.04 The Conduct of Confirmatory Surveys. Determine by performing a R survey that there is no residual radioactivity greater that the R criteria in Appendix A (attached) or that the contamination pre- R sent in the facility or in the environs does not pose a radia- R tion hazard to the public. This survey should include measure- R ments for both fixed and removable contamination (as appropri- R ate). If the potential for contamination exists outside the R facility, environmental samples should be taken. R 02.05 Reports and Records

a. For licensees subject to the reporting requirements, verify by reviewing records and files that:

1. Personnel exposure and monitoring reports required by 10 CFR 20.407 have been submitted to the NRC for the calendar year in which the license has expired or is being terminated, and i

2. Reports of personnel exposures for terminated employ-ees or employees no longer working with radioactive materials required by 10 CFR 20.408 and 19.13 have .

been submitted to both the NRC and the employee. 1 Issue Date: 04/10/85 2

CLOSEOUT INSPECTION & SURVEY 83890-02.05b

b. Determine what plans or arrangements have been made for preserving records required by 10 CFR 20.401(c).

02.06 Burial of Waste. Determine if waste has been buried on the site.

If burial has occurred, do the following:

a. Obtain information on the type and quantity of the mate-rials buried. Also identify the following: radionuclides, type of packaging, specific location of burial, depth and spacing used for burial. Obtain information on the planned use of the area after the license is terminated.

b. Conduct a surface survey to determine the radiation levels at the burial site.

c. Submit the information acquired under 02.06 a. and b. to R the NMSS licensing staff for final action. R

. 02.07 Final Inspection Report. Prepare a final inspection report in accordance with IE Manual Chapter 1005, which summarizes the actions taken under this inspection procedure and the findings and evaluations of the inspection staff. Submit the report to the licensing staff.

83890-03 INSPECTION GUIDANCE 03.01 No guidance 03.02 No guidance 03.03 No guidance 03.04 Conduct of Confirmatory Surveys R

a. Buildings, rooms, furniture, systems and equipment; venti-lation ducts, filters, sinks, drains, traps and sumps; overhead fixtures, walls and floors, etc., should all be considered as areas to be surveyed. The number of the confirming measurements made by the inspector will vary with the magnitude of the potential for contamination and the thoroughness of the licensee's survey.

b. The number and type of samples collected for analysis will depend on the determination that a potential exists for facility and environmental contamination and on other find-ings; i.e., the material involved, extent of area affected, nature of media involved, etc.

c. "As appropriate" is determined on the basis of the poten-tial for environmerital contamination and the inspector's

( professional judgmerit.

3 Issue Date: 04/10/85

• O 83890-03.04d CLOSE0VT INSPECTION & SURVEY

d. Radiation levels should be below those listed in the attached Appendix A, " Guidelines for Decontamination of f

Facilities and Equipment Prior o Release for Unrestricted Use or Termination of Licenses for Byproduct, Source or Special Nuclear Material." The guidelines in Appendix A should be made available and used by the licensee during decontamination and/or decommissioning. If levels exceed those listed in Appendix A, the licensee should demonstrate that reasonable efforts to decontaminate the facility do not result in an appreciable reduction in the radiation levels. If the radiation levels are greater than the accepted levels and the licensee had made a reasonable effort to decontaminate the facility, the licensing staff should be consulted in determining an acceptable radiation level for release of the facility.

03.05 Reports and Records. Although certain licensees are not required

, to report personnel exposures, and the limitations of a license ,

removes the legal obligation to maintain the records required by 10CFR 20.401(c), the licensee should be informed that retention of these records is highly recommended.

03.06 Burial of Waste. Information is required to determine whether long-term control of the area will be required. Radiation levels and geographical coordinates or other specific means of identi-fication should be recorded on a map, diagram, photo, or other si,1111ar document.

03.07 Final Inspection Report. The final inspection report becomes the official certification of the disposal of licensed material.

The final inspection report forms the basis for retiring and eventually disposing of both the licensing and inspection files.

END i

Issue Date: 04/10/85 4

? .*

APPENDIX A, 83890 CLOSEOUT INSPECTION & SURVEY

( APPENDIX A GUIDELINES FOR DECONTAMINATION OF FACILITIES AND EQUIPMENT PRIOR TO RELEASE FOR UNRESTRICTED USE OR TERMINATION OF LICENSES FOR BYRODUCT, SOURCE, OR SPECIAL NUCLEAR MA'iERIAL July 1982 l

f f

U. S. Nuclear Regulatory Commission Division of Fuel Cycle & Materials Safety Washington, D. C. 20555 1

(

A-1 Issue Date: 04/10/85

4 83890, APPENDIX A CLOSE0UT INSPECTION & SURVEY The instructions in this guide in conjunction with Table 1 specify the radionuclides and radiation exposure rate limits that should be used in decontamination and survey of surfaces or premises and equipment prior to abandonment or release for unrestricted use. The limits in Table 1 do not apply to premises, equipment, or scrap containing induced radioactivity for which the radiological considerations pertinent to their use may be differ-ent. The release of such facilities or items from regulatory control is considered on a case-by-case basis.

1. The licensee shall make a reasonable effort to eliminate residual con-tamination.

2. Radioactivity on equipment or surfaces shall not be covered by paint, plating, or other covering material unless contamination levels, tis determined by a survey and documented, are below the limits specified in Table 1 prior to the application of the covering. A reasonable effort must be made to minimize the contamination prior to use of any

. covering.

3. The radioactivity on the interior surfaces of pipes, drain lines, or duct work shall be determined by making measurements at the traps, and other appropriate access points, provided that contamination at these locations is likely to be rsiresentative of contamination on the inter-ior of the pipes, drain lines, or duct work. Surfaces of premises, equipment, or . scrap which are likely to be contaminated but are of such size, construction, or location as to make the surface inacces-sible for purpose of measurement shall be presumed to be contaminated in excess of the limits.

4. Upon request, the Commission may authorize a licensee to relinquish possession or control of premises, equipment, or scrap having surfaces contaminated with materisis in excess of the limits specified. This may include, but would not be limited to, special circumstances such as razing of buildings, transfer of premises to another organization continuir.g work with radioactive materials, or conversion of facili-ties to a long-term storage or standby status. Such a request must:

a. Provide detailed, specific information describing the premises, equipment or scrap, radioactive contaminants, and the nature, extent, and degree of residual surface contamination.

b. Provide a detailed health and safety analysis which reflect that the residual amounts of materials on surface areas, together with other considerations such as prospective use of the premises, equipment or scrap, are unlikely to result in an unreasonable risk to the health and safety of the public.

i Issue Date: 04/10/85 A-2

APPENDIX A, 83890 CLOSE0VT INSPECTION & SURVEY

5. Prior to release of premises for unrestricted use, the licensee shall

( make a comprehensive radiation survey which establishes that contami-nation is within the limits specified in Table 1. A copy of the survey report shall be filed with the Division of Fuel Cycle and Mate-rial Safety, USNRC, Washington, D.C. 20555, and also the Administrator of the NRC Regional Office, having jurisdiction. The report should be filed at least 30 days prior to the planned date of abandonment. The survey report shall:

a. Identify the premises,

b. Show that reasonable effort has been made to eliminate residual contamination.

c. Describe the scope of the survey and general procedures followed.

d. State the findings of the survey in units specified in the instruction.

Following review of the report, the NRC will consider visiting' the facilities to confirm the survey.

J

(

A-3 Issue Date: 04/10/85

^

.. .. n ..

TA8t[ l

~

ACCLPTABLE SURFACE CONTAMINAil0N LEVELS ptMayggg[b e f g MAggggHbdf NtKt IDtS 8 AVtRAG[b c f

.o

- - - a g

U-nat. II-235. (1-238, and 16.000 dpm /100 cm2 1.000 dpa e/100 cm2 5.000 dpa e/100 cm 2 r-associated decay products M 20 dpe/100 cui 300 dpe/100 cm2 transuranics. Ra-226. Ra-228 100 dpm/100 cm 2 Ih-230. Ih-228. Pa-231 At-221. I-125. 1-129 Ih-nat. Th-232. Sr-90, 3000 dpm/100 cm2 200 dpm/l00 cm2 pa-??). Ra-224. U-232, 1-126 1000 dps/100 cm 2 _

1-131. 1-133 licta-garsra emit ters (nucildes 1000 dpa sy/100 cm2 with detay rodes other than 15.000 dpm sy/100 ce2 R 5000 dpm sy/100 cm2 alpha cminion or spontaneous g

fininn) catept ir-90 and -

- ethers noted above.

E

- _ ______ blished for alpha- and beta-gamuna-emitting tuhcre surf ace contamination by both alpha- and beta-gassna-emitting nucIldes exists, the Ilmits esta nuclides should apply independently, ting the [!

O bA s used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material d with the as determined instrumentation.

M by c counts per minute observed by an appropriate detector for background, efficiency, and geometric factors associate 1 square meter. for objects of less surface area, the average @

H (Heasurements of average contaminant should not be averaged over more than .

shoald be derived for each such object.

$ N d ihe onsa: mum contae nation level applies to an area of not more than 100 cm2 g

2 of surface area should be determined by wiping that area witn dry filter or sof t g

E 'lhe amount *Jf removable radicartive materlat per 100 cm i l on the wipe with an appropriate instrument of d d @

g absorbant paper, applying moderate upressure, and assessing the amount of radioactive mater aWhen removab 6n.wn cfficiency.

propurtionally and the entire surface should be wiped. sn l h ld not esceed g

-' I lhe average and maulmum radiation levels associated with surface contamination resultingQ from C 0.2 mrad /hr at ~

j, tntal absori.er.

I

wuc ,

/%.7

.? t UNITED STATES

E 0 NUCLEAR REGULATORY COMMISSION 3 'i OFFICE OF INSPECTION AND ENFORCEMENT S

( j# Washington, D.C. 20555 INSPECTION AND ENFORCEMENT MANUAL QASIP

. INSPECTION PROCEDURE 83895 FOLLOWUP ON EXPIRED LICENSES PROGRAM APPLICABILITY: 2800 83895-01 INSPECTION OBJECTIVE The objective of this procedure is to follow up on expired licenses. The

.NRC licensing staff will provide the inspection staff with a list of expired licenses requiring followup action. It is the responsibility of the inspection staff to verify that the licensee complies with 10 CFR 30.3.

83895-02 INSPECTION REQUIREMENTS 02.01 Review the Materials Master File to verify that the expired

"' license is carried in Status 1.

02.02 Assess the potential for resicual contamination at the li-censee's facility. If the possibility of such contamination exists, instruct the licensee to furnish NRC with a closecut survey. If necessary, conduct a closeout inspection (IE Inspec-tion Procedure 83890).

02.03 Contact the licensee to determine the status of the licensed operation. Take the following action based on the status of the licensee's program:

a. The licensee never acquired or has already disposed of the byproduct material.

Inrtruct the licensee to submit Form NRC-314, "Certifica-tion of Cisposition of Material," to the Region.

b. The licensee currently possesses material and does not plan to renew the license.

Issue a notice of violation to the licensee stating that he is in violation of 10 CFR 30.3. At the same time instruct him to dispose of the material to an authorized recipient and submit Form NRC-314, " Certification of Disposition of Material," to the Region.

Issue Date: 11/08/83

83895-02.03c FOLLOWUP ON EXPIRED LICENSES

c. The licensee currently possesses material and plans to renew the license. )

Issue a notice of violation to the licensee stating that he is in violation of 10 CFR 30.3, must store the byproduct material, and must apply for a new license. If adequate storage facilities are not available instruct the licensee to transfer the material to an authorized recipient until a new license has been issued. Obtain verification from the licensee that he has applied for a new license.

02.04 Prepare a final inspection report in accordance with IE Manual Chapter 1005 which states that the facility may be released for unrestricted use. Form NRC-314 should be attached to the ,

report. Submit the inspection report to the licensing staff no later than six months after being notified of the expired license, unless there are extenuating circumstances.

02.05 Af ter submitting the final inspection report to the licensing staff, update the Materials Master File: Set the next inspection date equal to "9999".

02.06 Monitor the license status in the Materials Master File. If the license is not changed from Status 1 to Status 4 within 3 months, contact the licensing staff. If further action on the part of the inspection staff is warranted, take appropriate .

action.

• 83895-03 INSPECTION GUIDANCE NOTE: The final digit of the items listed below refers specifically to the final digit of the inspection requirement; that is, Section 031 offers guidance for Section 021, etc.

03.01 It is necessary to verify that the license is actually listed as Status 1 in the Materials Master File. Occasionally, the NRC licensing staff has provided the inspection staff with a list of expired licenses that are not in Status 1. In these cases, followup action was completed by the licensing staff.

03.02 Residual contamination is defined to mean any level which ap-proaches, equals, or exceeds the levels provided in Appendix A (attached), " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material."

IE h ucedure 83890, " Closeout Inspection and Survey," should not be conde::ted until the licensee's survey report meets the levels provided in the document " Guidelines for Decontamination of Facil-ities and Equipment Prior to Release for Unrestricted Use or Term-ination of Licenses for Byproduct, Source, or Special Nuclear Material."

Issue Date: 11/08/83 ._ _ __ __ _

FOLLOWUP ON EXPIRED LICENSES 83895-03.03

. 03.03 No guidance.

03.04 The final inspection report is the Comission's official certi-fication that the licensee no longer possesses byproduct mate-rial. The final inspection report will provide the basis for retiring and eventually disposing of both the licensing and inspection files.

03.05 No guidance.

. 03.06 The status of the expired licenses must be tracked by the in-spection staff to verify that the license is retired.

The status of licenses can be tracked by obtaining a computer printout of all licenses in your region listed in Status 1, excluding categories S&R.

END

(..

t:

I Issue Date: 11/08/83

FOLLOWUP ON EXPIRED LICENSES APPENDIX A, 83895

( APPENDIX A GUIDELINES FOR DECONTAMINATION OF FACILITIES AND EQUIPMENT PRIOR TO RELEASE FOR UNRESTRICTED USE OR TERMINATION OF LICENSES FOR BYPRODUCT, SOURCE, OR SPECIAL NUCLEAR MATERIAL July 1982 U. S. Nuclear Regulatory Commission Division of Fuel Cycle & Materials Safety Washington, D. C. 20555 A-1 Issue Date: 11/08/83

_- - . _ - - _ _ _ _ _ ___ _ _ _ _ _._ _ ____ ______ _ _ _ . _1 __ _ _ - _ . _ . . _ - . . _

83895, APPENDIX A FOLLOWUP ON EXPIRED LICENSES The instructions in this guide in conjunction with Table 1 specify the radionuclides and radiation exposure rate limits that should be used in I decontamination and survey of surfaces or premises and equipment prior to abandcament or release for unrestricted use. The limits in Table 1 do not apply to premises, equipment, or scrap containing induced radioactivity for which the radiological considerations pertinent to their use may be different. The release of such facilities or items from regulatory control is considered on a case-by-case basis.

1. The licensee shall make a reasonable effort to eliminate residual contamination. .

2. Radioactivity on equipment or surfaces shall not be covered by paint, plating, or other covering material unless contamination levels, as determined by a survey and documented, are below the limits specified in Table 1 prior to the application of the covering. A reasonable effort must be made to minimize the contamination prior to use of any covering.

3. The radioactivity on the interior surfaces of pipes, drain lines, or ductwork shall be determined by making measurements at the traps, and other appropriate access points, provided that contamination at these locations is likely to be representative of contamination on the in-terior of the pipes, drain lines, or ductwork. Surfaces of premises, equipment, or scrap which are likely to be contaminated but are of such size, construction, or location as to make the surface inacces- n si ble for pur' ose p of measurement shall be presumed to be contamin-ated in excess of the limits.

4. Upon request, the Commission may authorize a licensee to relinquish possession or control of premises, equipment, or scrap having sur-faces contaminated with materials in excess of the limits specified.

This may include, but would not,be limited to, special circumstances such as razing of buildings, transfer of premises to another organiza-tion continuing work with radioactive materials, or conversion of facilities to a long-term storage or standby status. Such requests must; t

a. Provide detailed, specific information describing the premises, equipment or scrap, radioactive contaminants, and the nature, extent, and degree of residual surface contamination,

b. Provide a detailed health and safety analysis which reflect that the residual amounts of materials on surface areas, together with other considerations such as prospective use of the prem-ises, equipment or scrap, are unlikely to result in an unreason-able risk to the health and safety of the public.

Issue Date: 11/08/83 A-2

(,

• e t , *..

V, t TABLE I ACCEPTABLE SURFACE C0flTAMINAil0N ((VELS .

NtKt 1D(5 8 AVfRACLbcf mggpaggb d f gggg yggg gb e f y

U-nat. U-235. U-238. and g associated decay products 5.000 dpm e/100 cm 2 IS.000 dpm e/100 cm2 1.000 dpm e/100 cm 2 g t-M Iramuranics. Ra-226. Ra-228 lh-210. Ih-228. Pa-231 100 dpm/100 cm2 300 dps/100 cm2 20 dpe/100 cm2 p.

Ac-227. I-125. 1-129 lb.r.at. Ih-232. Sr-90 Ri-??). Ra-2/4 U-232. I-126, 1000 dpe/100 c,2 3000 dpm/100 cm2 200 dpm/100 cm2 l-Ill. 1-11)

Octa-garwa emitters (nuclites esith decay rodes other that aIpha emissinn or 5pontaneous 5000 dpa py/100 c 2 15.000 dpm ay/100 cm 2 1000 dpm ay/100 c 2 R g

fissinn) encept 5r-90 and s sthers noted above. .

s w .

4there surface contamination by both alpha- and beta-gasmaa-emitting nucIldes calsts, the lletts estabitshed for alpha- and beta-gamma emitting nuclides should apply independently.

bas used in this tabl . dpm (disintegrations per minute) means the rate of emission by radioactive material as deterufned by correctieg the O tounts per minute observed by an appropriate detector for backjround, ef ficiency, and geometric factort associated with the instrumertation. p O

(Heesurements of average contaminant should not be averaged over more than I sepsare meter, for objects of less surface area, the average h

• O shoald be derived for each such object. .

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gdihe maximum contamination level applies to an area of not more than 100 cm2 E 'the amount of removable radioactive material per 100 cm2 of surface area should be determined by wiping that ares with dry filter er sof t M g ahtorb*nt paper, applying moderate pressure, and assessing the amount of radioaClive material on the wipe with an appropriate (Astrument Of

- kn.wn ef ficiency. When removable contamination on objects of less surface area is determined, the pertinent levels should be reduced E U

e proportionally and the entire surface should be wiped.

l D C l d the I average and maalaum radiation levels assulated with surface contaminatten resulting from beta-gamma emitters should not esteed p

!  % 0.2 mrad /hr at I cm and 1.0 mrad /ht at I cm. respectively, measured through not mere than F milligrams per sepsare cencimeter of z I $ intal aburt,er. $

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