ML20138K142
| ML20138K142 | |
| Person / Time | |
|---|---|
| Issue date: | 02/11/1997 |
| From: | Thompson H NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-97-034, SECY-97-034-R, SECY-97-34, SECY-97-34-R, NUDOCS 9702140297 | |
| Download: ML20138K142 (115) | |
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.............. >...als POLICY ISSUE (Information)
February 11, 1997 SECY-97-034 FOR:
The Commissioners FROM:
Hugh L. Thompson, Jr.
Acting Executive Director for Operations
SUBJECT:
BRIEFING ON PROGRESS OF MATERIALS LICENSING BUSINESS PROJECT REDESIGN PILOT PROGRAM PURPOSE:
The purpose of this paper is to report on the progress of the Business Project Redesign (BPR) pilot program, as recuested by the Commission in the Staff Requirements Memorandum (SRM). datec July 16, 1996, entitled " Briefing on BPR Project on Redesigned Materials Licensing Process (SECY-96-139)." (refer to M960703).
In addition, this paper presents the staff's plan for proceeding with further work on the new materials licensing process.
SUMMARY
This paper will discuss staff activities in the U.S. Nuclear Regulatory Commission's materials licensing BPR project that have taken place since the Commission was last briefed on July 3,1996. After the briefing, the Commission directed the staff to:
- 1) arrange Commissioner visits to the BPR laboratory: 2) review the SRM of June 16. 1995, to ensure its directives are addressed: and 3) provide a briefing regarding.how the initi;il trial of the pilot program is proceeding.
With this ) aper and the Commission briefing scheduled for February 18. 1997, those t1ree Commission directives will have been completed.
CONTACT: Patricia A. Rathbun NMSS/IMNS (301) 415-7198 NOTE: TO BE MADE PUBLICLY AVAILABLE D61 d AT THE COMMISSION MEETING ON FEBRUARY 18, 1997 D/
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BACKGROUND:
The first phase of the BPR was launched in September 1994 and completed in May 1995. A discussion of this effort was provided in SECY-95-114, dated May 5, 1995, and in NUREG-1539, " Methodology and Findings of the NRC's Materials Licensing Process Redesign," published in April 1996.
Following approval from the Commission, the second phase began in September 1995. The Comission was provided a status report on the progress of this phase in SECY-96-139, dated June 26, 1996, and in a briefing to the Commission on July 3, 1996, Since that time significant activities in performing the pilot program have been completed that will be discussed in this paper.
DISCUSSION:
Commissioners' Visits Following Comission interest in visiting the BPR laboratory, each Comissioner was invited to tour the laboratory and receive a briefing on BPR activities.
Chairman Jackson visited the laboratory on August 14, 1996, and Commissioners Rogers and Dicus on August 19, 1996.
Based on the Comissioners' comments, the staff expanded the information available on the BPR Internet website location.
New information included full-text versions of NUREG-1539.
" Methodology and Findings of the NRC's Materials Licensing Process Redesign "
and draft NUREG-1541, " Process and Design for Consolidating and Updating Materials Licensing Guidance": a "What's New in BPR" area containing information on recent BPR activities: and information notices specific to materials licenses dating back to 1979.
After their appointments to the Comission, similar visits and briefings were arranged for Commissioners McGaffigan and Diaz.
Commissioner McGaffigan visited the BPR laboratory on January 9, 1997.
Comissioner Diaz is scheduled to visit in the near future.
June 16. 1995. SRM Directives The July 16, 1996, SRM directed the staff i.o review the SRM dated June 16, 1995, which provided guidance related to SECY-95-114, and fold those requirements into a " Lessons Learned" paper.
The Comission was provided with SECY-96-205, " Briefing on Business Process Redesign Project on Redesigned Materials Licensing Process," dated September 23, 1996, which systematically addressed each of the directives from the June 16, 1995, SRM. Attachment 1 summarizes those directives and the staff actions to address them: it updates and complements SECY-96-205. Attachment 2 sumarizes staff actions in response to the SRM of July 16, 1996.
Pilot Procram Ob.iectives. Scone. and Process In accordance with Comission direction, since July 1996, the staff has concentrated BPR resources on developing a useful pilot program to test the new materials licensing process. The objective of the pilot program was to
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The Commissioners 3
demonstrate the feasibility of a computer-assisted review process for issuing new portable gauge licenses. To maintain tight control of the pilot program, i
the staff established scope parameters to guide the program:
A single license class, portable gauges, was chosen on which to base the e
pilot program. This class comprises about 19 percent of NRC's materials licenses, which represents the largest class of materials licenses and-has the potential for a significant and early economic benefit from streamlining the licensing process for this group.
Furthermore, portable gauges are relatively safe devices that incorporate features
(
engineered to enhance their safety. Also, NRC's considerable experience with licensees possessing these devices indicates that radiation exposures to workers are generally low.
Thus, portable gauges are an acceptably low-risk license class to use in testing a new licensing process.
The pilot program first evaluated the technical and quality assurance o
review subarocesses practices. These subprocesses are considered the heart of t1e license application review process, and the staff wished to j
ensure their satisfactory performance as soon as possible.
The pilot program used revised risk-informed guidance as the regulatory o
foundation for the tests. The regional pilot test was based upon the l
performance-based guidance contained in draft NUREG-1556 Volume 1.
" Consolidated Guidance About Materials Licenses. Program-Specific i
Guidance About Portable Gauge Licenses." published in September 1996 t
l (Attachment 3). This document is the first program-specific guidance intended to be used by all parties involved in the materials licensing personnel. pplicants, licensees, NRC license reviewers, and other NRC process: a The staff utilized the iterative pilot program to develop and refine an information system prototype and business practices that will be used in the new materials licensing process. The staff, working with contractor support, developed an information system prototype that illustrated the computer screens that license applicants and NRC reviewers would use in the new computer-assisted licensing process. The initial prototype was tested in a Headquarters pilot exercise on November 18 through 22. 1996, in the BPR laboratory, using information from 3reviously approved licenses to test the system. Based on the findings in t1is pilot, several significant and many minor modifications were made to the )rototype. The prototype system was then tested in Region II from January 27 t1 rough 31,1997. using new license l
applications from actual pros)ective )ortable gauge licensees, as well as I
~ mock" applications prepared )y porta)le gauge manufacturers.
l Pilot Procram Results i
The Headquarters pilot test successfully demonstrated that the new electronic l
materials licensing process is a viable mechanism for issuing license actions l
(Attachment 4). The participants performed a technical review of five previously approved new portable gauge license applications, using a prototype i
computer-assisted review program called the Licensing and Inspection ON1ine System (LIONS).
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The Commissioners 4
The Headcuarters pilot test confirmed that application reviews can be l
performec more efficiently than under the existing licensing process.
Significant accomplishments include demonstrating the utility of acquiring reference information quickly from an electronic source, and the value of user-friendly checklist summary screens in ensuring the completeness of license applications and technical reviews.
Further, as expected, several information technology and training issues were identified for the team to address, such as:
the synchronization between application and reviewer checklist items, improving and consolidating multiple screens used by reviewers, and the need for im) roving skills and experience in Windows-based applications.
Resolution of t1ese issues improved the process to be tested during the regional pilot exercise.
The pilot test conducted at Region II was the culmination of all activities com leted through BPR Phases I and II. and its objectives and scope are inc uded as Attachment 5.
A list of the eight regional pilot test participant organizations (four new license applicants and four portable gauge manufacturers) is included as Attachment 6.
Representatives from the Agreement States of Georgia. Illinois, and Texas also participated in the test in the roles of license applicant customer service representative, license reviewer, and quality assurance reviewer. A summary of comments from the pilot participants and the Agreement State representatives is provided as.
The regional pilot successfully demonstrated that the LIONS program and draft NUREG-1556. Volume 1. can be used by the regions to issue new licenses.
Four actual license applications were reviewed using the new licensing process, and four licenses were signed and issued within one working day. The major findings from the expanded pilot test are summarized in the following table:
Major Findings from Pilot Test in Region II Finding Supporting Information Computer-assisted Staff conducted independent parallel reviews using the and paper-based computer-assisted review program and a paper-based review 3rocesses review process. Technically equivalent licenses could are tec1nically be generated through either review process.
Both equivalent and processes examined the same subject areas and generated i
provide the same equivalent application deficiency items.
level of safety Proposed Four actual licenses were granted during the regional performance pilot. Total actual processing time for each license measures and was determined to be less than one working day.
This targets are supports the projection that an average cycle time of reasonable 12 days or less for all materials licenses is attainable.
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The Commissioners 5
Major Findings from Pilot Test in Region II
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Finding Supporting Information Online reference During the regional pilot, the reviewer conducting the material provides paper-based process required time to research documents an efficiency to resolve an issue. The computer-assisted reviewer advantage was able to access the online LIONS " help" system to d
instantly locate the section of guidance to resolve a similar inquiry. The same reference information is also available to applicants through the Internet on the BPR homepage.
3 The computer-Sampl* licenses, cover letters, and deficiency letters assisted review were Jrinted from the computer-assisted review process process can produce during the pilot. Actual licenses were issued from a paper copies of paper-based process because minor formatting issues in license records, electronic products must be addressed.
Printing of the enabling a
" record of decision" that documents the license transition from the reviewer's decision-making has also been demonstrated.
current paper-based docket system Positive feedback All re)resentatives from the Agreement State programs provided on pilot said t1ey would like to remain involved in the pilot experience from program. The four new license applicants stated they non-NRC would like to )articipate in future pilot tests; one participants stated that "Tle process is an order of magnitude step forward in dealing with the NRC."
Positive feedback All representatives from the Agreement States strongly provided on LIONS approved of the LIONS program structure, ease of use, program from non-comprehensiveness, and efficiency.
Some license i
NRC participants applicants had difficulty " loading" the program or i
"saving" their completed application, but were able to resolve problems on their own or with help from NRC a
staff.
Positive feedback The license applicants noted several features that made on draft NUREG-NUREG-1556. Volume 1. beneficial for conducting their 1556. Volume 1.
business.
Specifically, the document is easy to provided by non-NRC understand and use, provides appropriate level of participants detail, and clearly describes a performance-based approach.
One of the pilot participants noted that the document " reeks of common sense and logic."
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3 The Commissioners 6
Major Findings from Pilot Test in Region II Finding Supporting Information 4
Just-in-time Training in draft NUREG-1556 Volume 1. LIONS, and training was Windows was provided to regional staff the week prior effective, although to the pilot test.
Representatives from Agreement i
experience in States noted that the regional staff ap) eared very Windows skills is competent in Jerforming the review of tie applications necessary for and working t1e LIONS program, optimal staff performance The prototy)e Selected individual sub)rocesses that make up the new system and )usiness licensing 3rocess were )roken down and analyzed. The processes meet the general ro)ustness of the new process was verified, BPR design; some although the pilot activities also Jointed out which revisions are subprocesses and functions need to )e further revised.
needed Next Steos The staff proposes to continue its activities along two paths:
- 1) Guidance consolidation activities, and 2) Refinement of the information system prototype.
Guidance consolidation will be scheduled according to the stability of e
regulation of each license class and the number of licensees affected.
The next types of guidance to be consolidated include the following program codes:
fixed gauge, self-shielded irradiators, and radiography.
Refinement of the information system prototype will continue by e
releasing the limited prototype to a wider audience for further testing and evaluation.
This proposal should minimize the delay in the full product imalementation of the new materials licensing process due to barriers that must )e addressed, including regulatory policy, infrastructure development, and other implementation issues.
Specifically, certain materials licensing classes are undergoing policy direction discussions, and full implementation of a new materials licensing information system must be paced by the Office of the Chief Information Officer's (CIO) ability to bring the Agencywide Documents Access And Management System (ADAMS) project online.
Under this proposal, the staff believes that an information system that will be usable by regional license reviewers to issue new portable gauge licenses will be fully developed by October 1997.
However, workarounds to manage barrier issues such as Internet access, electronic signature, and interfaces
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The Commissioners 7
witli legacy and the ADAMS information systems will be necessary before a fully automated system can be completed. The guidance for fixed gauge and self-shielded irradiators is scheduled to be consolidated and revised beginning in March 1997. The guidance for radiography is already under development as the staff prepares to implement the new 10 CFR Part 34, as approved by the Commission in the SRM on SECY-96-152. dated October 11. 1996. As each guidance document is finalized, staff will refine and expand the information system.
CQORDINATION:
This paper has been coordinated with the Office of the' CIO, and the CIO had no technical objection. The Office of the General Counsel has no legal objection j
to this paper.
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Hugh(L. Thompson. ( r.
Acting Executive Direc i
for Operations Attachments:
1.
BPR Actions to Address June 16, 1995. SRM 2.
BPR Actions to Address July 16, 1996. SRM 3.
Draft NUREG-1556 Volume 1*
4.
New Materials Licensing Process (Figure 8.1 from NUREG-1539) 5.
Regional Pilot Test Objectives and Scope 6.
List of Regional Pilot Test Participant Organizations 7.
Summary of Agreement State Representatives and Pilot Participant Comments on the Regional Pilot Test
- Provided'to Commission Offices only DISTRIBUTION:
Commissioners OGC OCAA OIG OPA OCA CIO EDO REGIONS SECY
BPR Actions to Address June 16, 1995 SRM Item SRM Directive Status
- BPR Team Action No.
1 Extend qualified materials licenses for Comp Federal Reaister rulemaking dated January 19. 1996 five years (61FR1109)revisedregulatitgs.
2 Proceed with Phase II Cont Initiated in September 1995.
3 Separate payment of fees from issuing a Cont Actions discussed on page 6 of SECY-96-205.
license. streamline fee structure.
Current actions are with the Office of the Controller.
4 Seek Agreement State (AS) views on Comp Actions discussed on pages 6 to 8 of SECY-96-205.
improving effectiveness and efficiency.
Updated information: Representatives of process from TX. IL. and GA actively participated in the regional pilot test conducted from January 27 to 31.
1997.
5 Seek AS views on how process might Comp See response under item #4.
affect AS 6
Seek AS views on role AS take in Comp See response under item #4. Also see Attachment 6.
developing process Sumary of Agreement State Representatives and Pilot Participant Comments on the Regional Pilot Test, of tilis SECY paper.
7 Take advantage of AS experience (IL. TX)
Comp See response under item #4. Also, these states provided representatives to the Regional Pilot Test.
8 Seek views of public. regulated Comp Actions discussed on page 8 of SECY-96-205.
community and AS on five year extension.
proposal 9
At end of Phase II provide Future Will be provided when Phase II is complete.
recommendations for carrying out final Phase Attachment I
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BPR Actions to Address July 16. 1996. SRM Item SRM Directive Status BPR Team Action No.
1 Arrange Commissioner visits to the BPR Complete Three visits were conducted in August 1996. one laboratory.
was conducted in January 1997, and the final visit was conducted in February 1997.
2 Provide a paper that addresses the Complete SECY-96-205. provided to the Commission on directives in the SRM on SECY-95-114 dated September 23. 1996, addressed the SRM June 16. 1995: and address revised directives and the additional information schedules, goals, metrics, milestones, request.
Updated data on the information training plans. aroject scope and request are provided below (See following interactions witi Agreement States.
table).
3 Schedule a briefing on the progress of the Complete Briefing scheduled for February 18, 1997.
initial trial for the pilot program.
Updated Data Since Issuance of SECY-%-205 on September 23. 1996 Topic Update Revised Schedules and Headquarters and Region II pilot tests completed.
Milestones Goals and Metrics Activities discussed in SECY-96-205.
In addition. a " Management Systems and Metrics" workshop was conducted in October and December 1996 to refine performance measures. These measures were discussed with the BPR Steering Committee on January 7. 1997. At that meeting it was determined that three high-level " Assessment Metrics" (Number of Events per year: Number of Severity Level 1, 2 or 3 items of non-compliance per year: and the Average Time to complete a licensing action) will be monitored to assess the general health of the licensing process'.
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1 Updated Data Since Issuance of SECY-96-205 on September 23, 1996 Topic Update Training Plans Activities discussed in SECY-%-205, and in Attachment 6 to that paper.
In addition. NHSS has initiated actions to conduct a BPR of the Administrative Support Functions in NMSS. This BPR will redesign the secretary function to o>erate in a greater customer service and technologically advanced environment tlan in the traditional secretarial paradigm.
Project Scope Pilot testing program has proven effective for confirming foundation of BPR design and identifying further areas in need of refinement.
Interactions with Agreement Activities discussed in SECY-%-205.
In addition. Georgia. Illinois, and Texas States sent representatives to take part in the Region 11 pilot test. These representatives provided a great deal of constructive input. further confirming NRC staff conclusions and enhancing the information collected. See Attachment 7 to this paper for a summary of their coments.
l l
l
l NUREG-1556 Vol.1 i
l Consolidated Guidance About Materials Licenses i
i Program-Specific Guidance About Portable l
Gauge Licenses Draft Report for Comment i
U.S. Nuclear Regulatory Commission i
Office of Nuclear Material Safety and Safeguards I
P. C. Vacca, J. E. Whitten, S. A. Arredondo, E. R. Matson, j
W. Tmgle, S. H. Lewis, D. J. Collins, P. A. Santiago i
4 p#"%,
1
i AVAILABILITY NOTICE Availability of Reference Materials Cited in NRC Publications Most documents cited in NRC publications will be available from one of the following sources:
1.
The NRC Public Document Room, 2120 L Street, NW., Lower Level, Washington, DC 20555-0001 2,
The Superintendent of Documents, U.S. Government Printing Office, P. O. Box 37082, Washington, DC 20402-9328 3.
The National Technical information Service, Springfield, VA 22161-0002 Although the listing that follows represents the majority of documents cited in NRC publica-tions, it is not intended to be exhaustive.
Referenced documents available for inspection and copying for a fee from the NRC Public Document Room include NRC correspondence and internal NRC memoranda; NRC bulletins, circulars, information notices, inspection and investigation notices; licensee event reports; vendor reports and correspondence; Commission papers; and applicant and licensee docu-ments and correspondence, The following documents in the NUREG series are available for purchase from the Government Printing Office: formal NRC staff and contractor reports, NRC-sponsored conference pro-ceedings, international agreement reports, grantee reports, and NRC booklets and bro-Chures. Also available are regulatory guides, NRC regulations in the Code of Federal Regula-tions, and Nuclear Regulatory Commission Issuances.
Documents ava.ilable from the National Technical information Service include NUREG-series reports and technical reports prepared by other Federal agencies and reports prepared by the Atomic Energy Commission, forerunner agency to the Nuclear Regulatory Commission.
Documents available from public and special technical libraries include all open literature items, such as books, journal articles, and transactions. Federal Register notices, Federal and State legislation, and congressional reports can usually be obtained from these libraries.
Docun
- its such as theses, dissertations, foreign reports and translations, and non-NRC con-ference,roceedings are available for purchase from the organization sponsoring the publica-tion cited.
Single copies of NRC draft reports are available free, to the extent of supply, upon written request to the Office of Administration, Distribution and Mail Services Section, U.S. Nuclear Regulatory Commission, Washington DC 20555-0001.
Copies of industry codes and standards used in a substantive manner in the NRC regulatory process are maintained at the NRC Library Two White Flint North,11545 Rockville Pike, Rock-ville, MD 20852-2738, for use by the public. Codes and standards are usually copyrighted and may be purchaseri from the originating organization or, if they are American National Standards, from the American National Standards institute,1430 Broadway, New York, NY 10018-3308.
S 9.
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Contents EilSC 4
4 A BSTRACT.
.... iii FOREWORD 1x
)
ACKNOWLEDGMENT
. :i ABBREVIATIONS sil 4
i PURPOSE OF DRAIT REPORT 1-1 2 AGREEMENT STATES 2-1 3 MANAGEMENT RESPONSIBILITY
. 3-1 4
a 4 APPLICABLE REGULATIONS 4-1.
5 HOW TO FILE
. 5-1 4
1 5.1 PAPER APPLICATION.
.5-1 5.2 ELECTRONIC APPLICATION..
.5-2 j
6 WHERE TO FILE.._
6-1 7 LICENSE FEES 7-1 4
8 CONTENTS OF AN APPLICATION 8-1 8.1 ITEM I: LICENSE ACTION TYPE.....
...... 8 1 8.2 ITEM 2: APPLICANTS NAME AND MAILING ADDRESS.
. B-1 j
8.3 ITEM 3: ADDRESS (ES) WHERE LICENSED MATERIAL WILL BE USED OR POSSE 5 SED.
8-2 8.4 ITEM 4: PERSON TO BE CONTACTED ABOUT THIS APPLICATION.......
.83 4
8.5 ITEM 5: RADIOACTIVE MATERIAL - SEALED SOURCES AND DEVICES
.............. 8 3 8.6 ITEM 5: RADIOACTIVE MATERIAL - FINANCIAL ASSURANCE AND RECORDKEEPING FOR DECOMMISSIONING....
.................8-4 8.7 ITEM 6: PURPOSE (S) FOR WHICH LICENSED MATERIAL WILL BE USED.........
8-5 8.8 ITEM 7: INDIVIDUAL (S) RESPONSIBLE FOR RADIATION SAFETY PROGRAM AND THEIR TRAINING EXPERIENCE - RADIATION SAFETY OFFICER (RSO) -
15 8.9 ITEM 8: TRAINING FOR INDIVIDUALS WORKING IN OR FREQUENTING RESTRICTED l
AREAS
=8-7 m.
8.10 ITEM 9: FACILITIES AND EQUIPMENT..
........ 8-8 8.11 ITEM 10: RADIATION SAFETY PROGRAM - AUDIT PROGRAM.....
...~................. 8-8 i
8.12 ITEM 10: RADIATION SAFETY PROGRAM - TERMINATION OF ACTIVITIES -
........, 8 9 8.13 ITEM 10: RADIATION SAFETY PROGRAM -INSTRUMENTS..
.8-10 8.14 FFEM 10: RADIATION SAFETY PROGRAM - MATERIAL RECEIPT AND
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ACCOUNTABILITY.
- 8 10 8.15 ITEM 10: RADIATION SAFETY PROGRAM - OCCUPATIONAL DOSIMETRY 8 12 8.16 ITEM 10: RADIATION SAFETY PROGRAM - PUBLIC DOSE.................
8 14 8.17 ITEM 10: RADIATION SAFETY PROGRAM - OPERATING AND EMERGENCY PROCEDURES.
.8-15 v
NUREG 1556, Vol.1 (draft)
6 TABLE OF CONTENTS 8.18 ITEM 10: RADIATION SAFETY PROGRAM - LEAK TESTS..
. 8-18 8.19 ITEM 10: RADIATION SAFETY PROGRAM - MAINTENANCE..
............. 8-19 8.20 ITEM 10: RADIATION SAFETY PROGRAM -TRANSPORTATION.;
8-21 8.21 ITEM 11: WASTE MANAGEMENT-GAUGE DISPOSAL AND TRANSFER..
. 8-21 8.2211EM 12: FEES
.8 22
- 8-22 8.23 ITEM 13
- CERTIFICATION.-
9 AMENDMENTS AND RENEWALS TO A LICENSE 9-3 P
t I
l NUREG - 1556, Vol.1 (draft) vi
TABLE OF CONTENTS List of Appendices A UNITED STATES NUCLEAR REGULATORY COMMISSION FORM 313 B SUGGESTED FORMAT FOR PROVIDING INFORMATION REQUESTED IN ITEMS S TilROUGli 11 OF NRC FORM 313 C INFORMABON NEEDED FOR CilANGE OF OWNERSillP OR CONTROL APPLICATION D CRITERIA FOR ACCEPTABLE TRAINING COURSES FOR PORTABL.E GAUGE USERS E TYPICAL DUTIES AND RESPONSIBILITIES OF TliE RADIATION SAFETY OFFICER F POI 4 TABLE GAUGE AUDIT CliECKUST G INFORMATION NEEDED TO SUPPORT APPLICANT'S REQUEST TO PERFORM EXTENDED MAINTENANCE H OPERATING AND EMERGENCY PROCEDURES I
GUIDANCE FOR DEMONSTRATING Ti!AT UNMON!TORED INDIVIDUALS ARE NOT LIKELY TO EXCEED 10 PERCENT OF Tile ALLOWABLE LIMITS J
REQUESTS TO PERFORM LEAK TESTING AND SAMPLE ANALYSIS K MAJOR DOT REGULATIONS; SAMPLE BILL OF LADING L SAMPLE PORTABLE GAUGE LICENSE M REVIEW CilECKL!ST FOR PORTABLE GAUGE APPLICATION List of Tables Eau 2.1 WiiO REGULATES Tile ACTIVITY?--
.. 2-2 1.1 DOSIMETRY EVALUATION..
.12 l
List of Figures Eau
- 2. I U.S. MAP.......
.. 2-2 8.1 RSO RESPONSIBILITIES.,..
8-6 8.2 MATERIAL RECEIPT AND ACCOUNTABILITY 8-11 8.3 DOSE LIMITS.
.8-13 8.4 STORING GAUGES..
. 8-l4 8.5 PROPER HANDLING.,
.8-16 8.6 SECURITY 8 17 8.7 MAINTENANCE..
.8-19 8.8 TRANSPORTATION.
8-21 i
l 1
vii NUREG - 1556, Vol.1 (draft)
l NUREG-1556 Vol.1 Consolidated Guidance About Materials Licenses 4
Program-Specific Guidance About Portable Gauge Licenses Draft Report for Comment
]
Manuscript Completed: September 1996 Date Published: September 1996 R C. Vacca, J. E. Whitten, S. A. Arredondo, E. R. Matson, W. Tmgle*, S. H. Lewis, D. J. Collins, R A. Santiago 1
Division ofIndustrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards
'i U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
,# ~ %,,
- Division of Radiation Protection Department of Environment, Health, and Natural Resources 3825 Barrett Drive Raleigh, NC 27709-7221
L Abstract As part ofits redesign of the materials licensing process, NRC is consolidating and updating numerous guidance documents into a single comprehensive repository as described in NUREG-i
~ 1539 and draft NUREG-1541. Draft NUREG-1556, Vol,1,is the first program-specific l
guidance developed for the new process and may serve as a template for subsequent program-specific guidance. This document is ultimately intended for use by applicants, licensees, and NRC staff and will also be available to Agreement States. This document combines the guidance -
previously found in draft Regulatory Guide DG-0008, " Applications for the Use of Sealed Sources in Portable Gauging Devices," and in NMSS Policy and Guidance Directive 2-07,
" Standard Review Plan for Applications for Use of Sealed Sources in Portable Gauging Devices." This draft report takes a graded, more performance-based approach to licensing portable gauges, and reducing the information (amount and level of detail) needed in support of an application to use these devices. Note that this document is strictly for public comment and NOT for use in preparation or review of portable gauge licenses until it is published in final form.
1 i
iii NUREG - 1556, Vol.1 (draft)
FOREWORD The United States Nuclear Regulatory Commission (NRC)is using Business Process Redesign (BPR) techniques to redesign its materials licensing process. This effort is described in NUREC-1539, " Methodology and Findings of the NRC's Materials Licensing Process Redesign." A critical element of the new process is consolidating and updating numerous guidance documents into a single comprehensive repository called the Materials Electronic Library (MEL). Draft NUREC-1541, " Process and Design for Consolidating and Updating Materials Licensing Guidance," describes the approach and conceptual design of MEL.
The current document (Draft NUREG-1556, Vol.1, " Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Portable Gauge Licenses," dated September 1996) provides the first program-specific guidance for the new process and may serve as the template for subsequent documents. It is intended for use by applicants, licensees, NRC license reviewers, and other NRC personnel. It combines the guidance for applicants and licensees now found in Draft Regulatory Guide DG-0008, " Applications for the Use of Sealed Sources in Portable Gauging Devices," dated May 1995, and the guidance for licensing staff now found in Policy and Guidance Directive PG 2-07, " Standard Review Plan for Applications for the Use of Sealed Sources in Portable Gauging Devices," dated September 1994. NRC considered comments received on DG-0008 in the preparation of this report.
As described in Draft NUREC-154/, this draft NUREG report takes a graded and more performance-based approach to licensing portable gauges, i.e., it reduces the amount of information needed from an applicant seeking to possess and use a relatively safe device. These portable gauges containing sealed sources of radioactive material incorporate features engineered to enhance their safety. NRCs considerable experience with these licensees indicates that radiation exposures to workers are generally low and that sealed sources have not been damaged even when run over by heavy construction equipment A team composed of NRC staff from headquarters and regional offices drafted this document, drawing on their collective experience in radiation safety in general and as specifically applied to j
portable gauges. A representative of NRCs Office of the General Counsel provided a legal perspective. A representative of an Agreement State participated in the process and provided l
licensing, inspection, and enforcement insight into the views and practices of her State.
However, this draft NUREG report has not been endorsed by that representative or any l
Agreement State.
Draft NUREG-1556, Vol.1," Consolidated Guidance about Materials Licenses: Program-t Specific Guidance about Portable Gauge Licenses," dated September 1996, represents a transition from the current paper-based process to the new electronic process. Text shown in bold italics indicates information that will be linked electronically allowing the user, by simply
" pointing and clicking," to see the actual text of regulations, acronyms and abbreviations, and other referenced documents.
NUREG 1556, Vol.1 (draft) ix I
FOREWORD This draft report is strictly for public comment and is NOT for use in preparation or review of applications for portable gauges until it is published in final form. NRC is requesting comments such as whether a graded and more performance-based approach to licensing is valid, as well as comments on the information provided about portable gauges. In addition, to support NRC's efforts to streamline the materials licensing process, NRC is also soliciting comments and suggestions about the document's format, usefulness, etc., to make it more " user-friendly."
Please submit comments within 90 days ofits publication. Comments received after that time will be considered if practicable.
Draft NUREG-1556, Vol.1," Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Portable Gauge Licenses," dated September 1996, is also available electronically by visiting NRC's Home Page (http://www@nrc. gov) and choosing " Nuclear Materials," then " Business Process Redesign Project," and then " Draft NUREG - 1556, Vol 1."
Address comments to: Chief, Rules Review and Directives Branch, Division of Freedom of Information and Publications Services, Office of Administration, U. S. Nuclear Regulatory Commission, Washington, DC 20555-0001. Hand deliver comments to 11545 Rockville Pike, Rockville, Maryland, between 7:15 a.m. and 4:30 p.m. on Federal workdays. Comments may also be submitted through the Internet by addressing electronic mail to INTERNET:
mtl@nrc. gov.
Draft NUREG-1556, Vol.1. " Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Portable Gauge Licenses," dated September 1996, is not a substitute for NRC regulations, and compliance is not required. The approaches and methods described in this draft report are provided for information and comment only.
J: @
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h is Donald A. mol, ir ctor Division ofIndustrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards NUREG - 1556, Vol.1 (draft) x
o 4
4 Acknowledgment 4
The writing team thanks the individuals listed below for assisting in the development and review of the text. All participants provided valuable insights, observations, and recommendations.
The team also thanks Kay Avery, Eric Bazerghi, Veronica Bellone, Mary Carnahan, and Alyce J.
5 Martin of Computer Sciences Corporation, W:ndy Tingle from the State of North Carolina, i
Joseph Klinger from the State ofIllinois, Terry Frazee from the State of Washington, and Dennis
)
O'Dowd from the State of New Hampshire.
The Participants Arredondo, Sheri A.
Mallett, Bruce S.
Camper, Larry W.
Matson, Evelyn (Dixie) R.
Collins, David J.
Olmstead, William J.
Combs, Frederick C.
Paperiello, Carl J.
Cook, John R.
Potter, John P.
Cool, Donald A.
Ricci, John L.
Costello, Francis M.
Santiago, Patricia A.
Frazier, Cassandra F.
Spitzberg, D. Blair Hehl, Charles W.
Treby, Stuart A.
Henson, Jay L.
Trottier, Cheryl A.
Lewis, Stephen H.
Vacca, Patricia C.
Lohaus, Paul H.
Whitten, Jack E.
Madera, John R.
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xi NUREG 1556, Vol.1 (draft)
Abbreviations ALARA As low as reasonably achievable i
BPR Business Process Redesign
]
i DOE United States Department of Energy DOT United States Department of Transponation GPO Government Printing Office IN Information Notice MEL Materials Electronic Library NIST National Institute of Standards and Technology NMSS Office of Nuclear Materials Safety and Safeguards NRC United States Nuclear Regulatory Commission NVLAP National Voluntary Laboratory Accreditation Program OC Office of the Controller OCR Optical character reader i
OMB Office of Management and Budget kQ Reportable Quantities RSO Radiation Safety Officer SS&D BBS Scaled Source and Devices Bulletin Board System SSD Scaled Source and Device
[
Sv Sievert TEDE Total effective dose equivalent TI Transportation Index l
TLD Thennoluminescent dosimeters I
1 1
NUREG - 1556, Vol.1 (drah) xii e
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AGRIEMENT STATES Table 2.1 Who Regulates the Activity?
APPLICANT AND PROPOSED LOCATION OF WORK REGULATORY AGENCY Federal agency regardless oflocation (except that Department of Energy NRC
[DOEj and, under tr.ast circumstances, its prime contractors are exempt from licensing [10 CFR 30./2])
Non-Federal entity in non-Agreement State, US territory or possession.
NRC Non-Federal entity in Agreement State at non-Federally controlled site Agreement State Non-Federal entity in Agreement State at Federally-controlled site NOT Agreement State subject to exclusive Federal jurisdiction Non-Federal entity in Agreement State at Federally-controlled site subject NRC to exclusive Federaljurisdiction Locations of NRC Offices and Agreement States Region !V j
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Region ill 801 Warrenville Road Lisle IL 60532-4351 9 Regional Office Q Headquarters 630-829-9500
$ Field Office R@n N O 29 Agreement States Headquarters 611 Ryan Plaza Drive. Suite 400 (approx.15.000 licenses)
Washington. D.C. 20555-0001 Arhn ton, TX 76011-8064 301-41 # 7000 817 S8MO O 21 Non-Agreement States (approx.7,000 heenses)
Region 1 Walnut Creek Field Office 475 Allendale Road 1450 Mana Lane d
n o s a, PA 19406-1415 an uk, CA 94596-5368 og on, ueno a
n islands in Region 11 62-th3-912s coe 8-20-96 Figure 2.1 U.S. Map. Location ofNRC Offices and Agreement States.
Reference:
All Agreement States Letter, SI'-96-022, dated February 16,1996, is available from NRC upon request.
NUREG - 1556, Vol.1 (draft) 2-2
2 AGREEMENT STATES Certain states, called Agreement States (see Figure 2.1), have entered into agreements with the NRC that give them the authority to license and inspect byproduct, source, or special nuclear materials used or possessed within their borders. A current list of Agreement States (including names, addresses, and telephone numbers of responsible officials) may be obtained upon request from NRC's Regional or Field Offices. Any applicant other than a Federal agency who wishes to possess or use licensed material in one of these Agreement States needs to contact the responsible officials in that State for guidance on preparing an application; file these applications with State ofiicials, not with the NRC.
In general, NRC's materials licensees who wish to conduct operations at temporary jobsites in an Agreement State should contact that State's radiation control program office for information about State regulations. To ensure compliance with Agreement State reciprocity requirements, a licensee should request authorization well in advance of scheduled use.
In the special situation of work at Federally-controlled sites in Agreement States, it is necessary to know thejurisdictional status of the land in order to determine whether NRC or the Agreement State has regulatory authority. NRC has regulatory authority over land determined to be
" exclusive Federaljurisdiction," while the Agreement State has jurisdiction over non-exclusive Federaljurisdiction land. Licensees are responsible for finding out, in advance, the jurisdictional status of the specific areas where they plan to conduct licensed operations. NRC recommends that licensees ask their local contact for the Federal agency controlling the site (e.g., contract officer, base environmental health officer, district office staff) to help determine the jurisdictional status of the land and to provide the information in writing, so that licensees can comply with NRC or Agreement State regulatory requirements, as appropriate. Additional guidance on determining jurisdictional status is found in A// Agreement States Letter, SP-96-022, dated February 16,1996, which is available from NRC upon request.
Table 2.1 provides a quick way to check or which agency, if any, has regulatory authority.
2-1 NUREG - 1556, Vol.1 (draft)
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l 1 PURPOSE OF DFEFT REPORT j
This document is strictly for public comment and is NOT for use in preparation or review of applications for portable gauges until this document is published in final form.
This draft NUREG report provides guidance to an applicant in preparing a portable gauge license application as well as NRC criteria for evaluating a portable gauge license application. It is not intended to address the research and development of gauging devices or the commercial aspects of manufacturing, distribution, and service of such devices.
This draft NUREG report identifies the information needed to complete NRC Form 3/3 (Appendix A), " Application for Material License," for the use of sealed sources in portable gauging devices. The information collection requirements in 10 CFR Part 30 and NRC Form 3/3 have been approved under the Office of Management and Budget (OMB) Clearance Nos.
3150-0017 and 3150-0120, respectively.
The format within this document for each item of technical information is as follows-l Regulations-references the regulations applicable to the item; e
Criteria-outlines the criteria used to judge the adequacy of the applicant's response; e
Discussion-provides additional information on the topic sufficient to meet the needs of most readers; and Response from Applicant-provides suggested response (s), offers the option of an alternative reply, or indicates that no response is needed on that topic during the licensing process.
Notes and References are self-explanatory and may not be found for each item on NRC Form 313.
NRC Form 3/3 does not have sufficient space for applicants to provide full responses to Items 5 through 11; as indicated on the form, the answers to those items are to be provided on separate sheets of paper and submitted with the completed NRC Form 313. For the convenience of applicants and for streamlined handling of portable gauge applications in the new materials licensing process, use Appendix B to provide supponing information, attach it to NRC Form 3/3, and submit them to NRC.
Appendives C through K contain additional information on various radiation safety topics.
Appendit L is a sample portable gauge license; it contains the conditions most often found on these licenses, although not all licenses will have all conditions. Appendit M is a checklist that NRC staff can use to review applications and applicants can use to check for completeness.
1-1 NUREG - 1556, Vol.1 (draft)
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BPR Actions to Address June 16, 1995 SRM Item SRM Directive Status
- BPR Team Action No.
10 Address program coordination between HQ Cont Biweekly management teleconferences between and Regions.
Include: implementation Headquarters and regions. Daily contact between (if. how, when)
Headquarters and regions. Counterpart meetings. BPR Steering Committee Meetings, and activities conducted during the Region II pilot.
11 Report plans for applying BPR to other Future Decision pending outcome of Strategic Assessment areas of the materials program:
Process.
inspections 12 Report plans for applying BPR to other Future Decision pending Commission direction on staff plans areas of the materials program: Sealed to address recommendations in SECY 96-221.
Source & Device
" Improving NRC's Control Over, and Licensees
- Accountability for Generally and Specifically Licensed Devices."
13 Identify recommendations from GA0.
Comp Discussed on page 10 of SECY-96-205. Attachment 1.
Congressional, and internal reviews 14 Reconcile changes from BPR that diverge Cont Activities are in progress.
from past commitments responding to recommendations 15 Document rationale for proceeding with Cont Activities are in progress.
BPR changes from past commitments, produce clear record for all cases 16 Keep public and licensees informed of Cont Actions include public workshops. NHSS Licensee plans and progress of BPR Newsletter. ACMUI briefings. NUREGs. and BPR Web site.
Discussed on page 11 of SECY-96-205..
17 Establish target goal (e.g.
60 - 90 Camp Target established at an average of less than 12 days) for processing applications under days. Discussed on pages 11 and 12 of SECY-96-205.
new system.
BPR Actions to Address June 16, 1995, SRM Item SRM Directive Status
- BPR Team Action No.
18 Explain how graded approach to new Comp Discussed on pages 13 and 14 of SECY-96-205.
license review matches review level to.
safety hazard 19 Explain how new process employs Comp Discussed on page 14 of SECY-96-205. Attachment 1.
individuals or teams with specialized experience 20 Clarify how ap)1ication's information Comp Discussed on page 15 of SECY-96-205. Attachment 1.
accuracy will
)e assured in " automated In addition. NRC license reviewers will review and review" process approve all actions. The computer assists reviewers; it does not replace them. NRC staff remains responsible for ensuring the technical adequacy of licensee information.
21 Implement a small scale test program to Cont Pilot tests conducted in Headquarters on November 18 determine feasibility of larger scale through 22. 1996, and in Region II from January 27 program through 31. 1997.
22 Develop training requirements necessary Cont Discussed in SECY-%-205. Attachment 6.
Activities for successful process are underway to: 1) certify staff in reengineering.
and 2) conduct BPRs to expand role of administrative support staff.
23 Add opportunity for licensee input to Cont Discussed on page 17 of SECY-96-205. Attachment 1.
Phase II Updated information: 4 portable gauge licensee applicants and 4 gauge manufacturers participated in Region II pilot test in January 1997. A list of the participants' titles and organizations is included in Attachment 6 of this SECY paper.
24 Provide more specific breakdown of one-Cont A detailed discussion was provided on pages 17 and time and recurring costs (both $'s ano 18 of SECY-96-205. Attachment 1.
Since that paper FTEs) was submitted in September 1996, an additional
$375.000 have been spent in program support. The project is currently on budget and schedule.
BPR Actions to Address June 16, 1995. SRM Item SRM Directive Status
- BPR Team Action No.
25 Clarify how consistency between "self-Cont Discussed on page 19 of SECY-96-205. Attachment 1.
managed" teams will be assured.
- " Comp" is a completed action. " Cont" is a continuing action, and " Future" is a future action. Currently, the staff has completed action on eleven directives. is continuing activities on eleven other directives, and plans to address the three remaining directives in the future.
3 MANAGEMENT RESPONSIBILITY The NRC recognizes that effective radiation safety program management is vital to achieving safe and compliant operations. NRC also believes that consistent compliance with its regulations provides reasonable assurance that licensed activities will be conducted safely. NRC frequently
)
finds ineffective management is the underlying cause of safety and compliance problems.
Management refers to a senior-level manager who has responsibility for overseeing licensed activities.
To ensure adequate management involvement, a management representative must sign the submitted application acknowledging management's commitments and responsibility for the following:
Radiation safety, security and control of radioactive materials, and compliance with
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regulations; Completeness and accuracy of the radiation safety records and all information provided to e
NRC(10 CFR 30.9);
Knowledge about the contents of the license and application; e
Committing adequate resources (including space, equipment, personnel, time, and, if needed, contractors) to the radiation protection program to ensure that public and worker i
safety is protected from radiation hazards and compliance with regulations is maintained; and Selecting and assigning a qualified individual to serve as the Radiation Safety Officer (RSO) for their licensed activities.
For information on NRC inspection, investigation, enforcement, and other compliance programs, see " General Statement of Policy and Procedures for NRC Enforcement Actions," (NUREG-l l
//,uu), which is available from NRC upon request.
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3-1 NUREG - 1556, Vol.1 (draft)
4 APPLICABLE REGULATIONS It is the applicant's or licensee's responsibility to have up-to-date copies of applicable regulations, read them, and abide by each applicable regulation.
The following Parts of 10 CFR Chapter I contain regulations applicable to portable gauging devices:
10 CFR Part 2, " Rules of Practice for Domestic Licensing Proceedings and Issuance of Orders" i
10 CFR Part 19, " Notices, Instructions and Reports to Workers: Inspection and e
Investigations" 10 CFR Part 20, " Standards for Protection Against Radiation" 10 CFR Part 21, " Reporting of Defects and Noncompliance" 10 CFR Part 30, " Rules of General Applicability to Domestic Licensing of Byproduct Material" 10 CFR Part 71, " Packaging and Transportation of Radioactive Material" i
Part 71 requires that licensees or applicants who transport licensed material or who may offer such material to a carrier for transport must comply with the applicable requirements of the United States Department of Transportation (DOT) that are found in 49 CFR Parts 170 through 189. Copies of DOTregulations can be ordered from the Government Printing Office (GPO) whose address and telephone number are listed below.
i 10 CFR Part 150," Exemptions and Continued Regulatory Authority in Agreement States e
and in Offshore Waters under Section 274" 10 CFR Part 170, " Fees for Facilities, Materials, Import and Export Licenses and Other Regulatory Services Under the Atomic Energy Act of 1954, as Amended" 10 CFR Part 171, " Annual Fees for Reactor Operating Licenses, and Fuel Cycle Licenses i
e and Materials Licenses, Including Holders of Certificates of Compliance, Registrations, and Quality Assurance Program Approvals and Government Agencies Licensed by NRC' To request copies of the above documents, call GPO's order desk in Washington, DC at (202) 512-1800. Order the two-volume bound version of Title 10, Code of Federal Regulations, Parts 0-50 and 51-199 from the GPO, Superintendent of Documents, Post Office Box 371954, Pittsburgh, Pennsylvania 15250-7954. Request copies of the above documents from NRC's Regional or Field Offices (see Figure 2.1 for addresses and telephone numbers).
4-1 NUREG - 1556, Vol.1 (draft)
I l
l 5 HOW TO FILE j
5.1 PAPER APPLICATION Applicants for a materials license should do the following:
Be sure to use the most recent guidance in preparing an application.
i Complete NRC Form 313 (Appendix A) Items I through 4,12, and 13 on the form itself.
e Complete NRC Form 313 Items 5 through 11 on supplementary pages or use e
Appendix B.
For each separate sheet, other than Appendit B, that is submitted with the application, identify and key it to the item number on the application or the topic to which it refers.
Submit all documents, typed, on 8-1/2 x 11 inch paper.
Avoid submitting proprietary information unless it is absolutely necessary.
Submit an original, signed application and one copy.
e Retain one copy of the license application for future reference.
Deviations from the suggested wording of responses as shown in this dccument or submission of alternative procedures may require a custom review.
{
All license applications will be available for review by the general public in NRC's Public Document Rooms. Ifit is necessary to submit proprietary information, follow the procedure in 10 CFR 2.790. Failure to follow this procedure may result in disclosure of the proprietary information to the public or substantial delays in processing the application. Employee personal j
infonnation, i.e., home address, home telephone number, social security number, date of birth, radiation dose information, should not be submitted unless specifically requested by NRC.
As explained in the Foreword to this document, NRC's new licensing process will be faster and more efficient, in part, through acceptance and processing of electronic applications. NRC will i
continue to accept paper applications. However, these will be scanned and put through an optical character reader (OCR) to convert them to electronic format. To ensure a smooth transition, applicants are requested to follow these suggestions:
Submit printed or typewritten, not handwritten, text on smooth, crisp paper that will feed easily into the scanner.
Choose typeface designs that are sans serif, such as Arial, Helvetica, Futura, Univers; the text of this document is in a serif font called Times New Roman.
Choose 12-point or larger font size, Avoid stylized characters such as script, italic, etc.
e Be sure the print is clear and sharp.
Be sure there is high contrast between the ink and paper (black ink on white paper is best).
l 5-1 NUREG - 1556, Vol.1 (draft)
k How To Fil.E 5.2 ELECTRONIC APPLICATION l
As the electronic licensing process develops, it is anticipated that NRC will provide mechanisms for filing applications via Fax, on diskettes or CD-ROM, and through the Internet. Additional filing instructions will be provided as these new mechanisms become available.
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1 6 WHERE TO FILE i
Applicants wishing to possess or use licensed material in any State or U. S. territory or possession subject to NRCjurisdiction must file an application with the NRC Regional Office for the locale in which the material will be possessed and/or used. Figure 2.1 shows NRC's four Regional Offices and their respective areas for licensing purposes and identifies Agreement States. The Walnut Creek, Califomia, Field Office, can respond to routine telephone inquiries.
In general, applicants wishing to possess or use licensed material in Agreements States must file an application with the Agreement State, not NRC. However, if work will be conducted at j
Federally controlled sites in Agreement States, applicants must first determine thejurisdictional status of the land in order to determine whether NRC or the Agreement State has regulatory I
authority. See the section on " Agreement States" for additional information.
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7 LICENSE FEES Each application for which a fee is specified, including applications for new licenses and liceme 1
amendments, must be accompanied by the appropriate fee. Refer to 10 CFR 170.31 to determine the amount of the fee. NRC will not issue the new license prior to fee receipt. Once technical review I.s begun, no fees will be refunded; application fees will be charged regardless of the NRr'. disposition of an application or the withdrawal of an application.
Most NRC licensees are also subject to annual fees; refer to 10 CFR 171.16. Consult 10 CFR 171.Il for additional information on exemptions from annual fees and 10 CFR 171.16(c) on reduced annual fees for licensees that qualify as "small entities."
Direct all questions about NRC's fees or completion ofitem 12 of NRC Form 3/3 (4ppendIt A) to the Office of the Controller (OC) at NRC headquarters in Rockville, Maryland, (301) 415-7554.
7-1 NUREG - 1556, Vol.1 (draft)
8 1
8 CONTENTS OF AN APPLICATION The following comments apply to the indicated items on NRC Form 313 (Appendit A).
l 8.1 ITEM 1: LICENSE ACTION TYPE TIIIS IS AN APPLICATION FOR (Check appropriate item)
TYPE OF ACTION LICENSE NO.
[ ] A. NEW LICENSE NOT APPL.lCABLE
[ ] B. AMENDMENT TO LICENSE No.
XX-XXXXX-XX
[ ] C. RENEWAL OF LICENSE No.
XX-XXXXX-XX Check box A for a new license request.
Check box B for an amendment to an existing license, and provide license number.
l Check box C for a renewal
- of an existing license, and provide license munber.
8.2 ITEM 2: APPLICANT'S NAME AND MAILING ADDRESS List the legal name of the applicant's corporation or other legal entity with direct control over use of the radioactive material; a division or department within a legal entity may not be a licensee.
An individual may be designated as the applicant only if the individual is acting in a private capacity and the use of the radioactive material is not connected with employment in a corporation or other legal entity. Provide the mailing address where correspondence should be sent.
Note: NRC must he notified in the event of change of ownership or control and bankruptcy proceedings; see below for more details.
Timely Notification of Change of Ownership or Control:
Regulations: 10 CFR 30.34(b).
Criteria: Licensees must provide full information and obtain NRC's prior written consent before transferring ownership or control oflicensed material.
Discussion: Changes in ownership may be the results of mergers, buyouts, or majority stock transfers. Although it is not NRC's intent to interfere with the business decisions oflicensees, it
- See " Amendments and Renewals to a License" later in this document.
8-1 NUREG - 1556, Vol.1 (draft)
CONTENTS of AN APPLICATION is necessary for licensees to obtain prior NRC written consent. This is to ensure the following:
Radioactive materials are possessed, used, or controlled only by persons who have valid NRClicenses; Materials are properly handled and secured; e
Persons using these materials are competent and committed to implementing appropriate radiological controls; A clear chain of custody is established to identify who is responsible for final disposal of gauge; and Public health and safety are not compromised by the use of such materials.
Response from applicant: None from an applicant for a new license; Appendix C identifies the infermation to be provided about changes of ownership or control.
Notification of Bankruptcy Proceedings Regulation: 10 CFR 30.34(h)
Criteria: Immediately following filing of voluntary or involuntary petition for bankruptcy for or against a licensee, the licensee must notify the appropriate NRC Regional Administrator, in writing, identifying the bankruptcy court in which the petition was filed and the date of filing.
Response from applicant: None at time of application for a new license 8.3 ITEM 3: ADDRESS (ES) WHERE LICENSED MATERIAL WILL BE USED OR POSSESSED Specify the street address, city, and state or other descriptive address (such as on Highway 10,5 miles east of the intersection of Highway 10 and State Route 234, Anytown, State) for each permanent facility used as a location of storage and each facility from which the applicant will dispatch gauge users to jobsites for more than one customer. If gauges will NOT be stored at a dispatch site, so indicate. The descriptive address should be sufficient to allow an NRC inspector to find the storage location. A Post Office Box address is not acceptable.
Being granted an NRC license does not relieve a licensee from complying with other applicable Federal, State, or local regulations (e.g., local zoning requirements for storage locations).
To conduct operations at temporary jobsites (i.e., locations where work is conducted for limited periods of time and from which gauge users are NOT dispatched tojobsites for other customers),
specify " temporary jobsites anywhere in the United States where NRC maintains jurisdiction."
See Figure 2.1.
NUREG - 1556, Vol.1 (draft) 8-2
CONTENTS oF AN APPLICATioM 8.4 ITEM 4: PERSON TO BE CONTACTED ABOUT THIS APPLICATION Identify the individual who can answer questions about the application and include his or her telephone number. This is typically the proposed radiation safety officer or knowledgeable management official. The NRC will contact this individual if there are questions about the application.
Notify NRC if the contact person or his or her telephone number changes so that NRC can contact the applicant or licensee in the future with questions, concerns, or information. This notice is for "information only" and does not require a license amendment or a fee.
As indicated on NRC Form 313 (Appendit A), Items 5 through 11 should be submitted on separate sheets of paper. Applicants may use Appendix R for this purpose and should note that deviations from the suggested responses and submission of attemative procedures may require custom review.
8.5 ITEM 5: RADIOACTIVE MATERIAL - SEALED SOURCES AND DEVICES Regulation: le CFR 30.32(g).10 CFR 30.33(a)(2),10 CFR 32.210 Criteria: Licensees will only be authorized for sealed sources and devices registered by NRC or an Agreement State.
Discussion: NRC or an Agreement State performs a safety evaluation of gauges before authorizing a manufacturer to distribute the gauges to specific licensees. The safety evaluation is documented in a sealed source and device registration certificate. When issuing a portable gauge license, NRC usually provides a generic authorization to allow the licensee to possess and use any sealed source / device combination that has been registered by NRC or an Agreement State.
This method of authorization allows licensees flexibility in obtaining new source / device combinations without having to amend their licenses.
Consult with the proposed supplier to ensure that sources and devices conform to the sealed source and device designations registered with NRC or an Agreement State. Licensees may not make any changes to the sealed source, device, or source / device combination that would alter the description or specifications from those indicated in the respective registration certificates, without obtaining NRC's prior permission in a license amendment.
Response from applicant:
Identify each radionuclide that will be used in each source in the gauging device (s).
Confirm that each sealed source, device, and source / device combination is registered as an approved sealed source or device by NRC or an Agreement State.
8-3 NUREG - 1556, Vol.1 (draft)
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CONTENTS OF AN APPUCATloN Confirm that the activity per source will not exceed the maximum activity listed on the e
i approved certificate of registration issued by NRC or by an Agreement State.
Note: Information on sealed source and device registration certificates is also available electronically on NRC's Sealed Source and Devices Bulletin Board System (SS&D BBS) which may be accessed, free of charge, on the FedWorld Information Service Network. For information about the SS&D BBS, contact Michele Burgess at (301) 415-5868 or Steven Baggett at (301) 415-7273. For information on connecting to and using FedWorld, contact the FedWorld Help Desk at (703) 487-4608.
8.6 ITEM 5: RADIOACTIVE MATERIAL - FINANCIAL ASSURANCE AND RECORDKEEPING FOR DECOMMISSIONING Regulations: 10 CFR 30.34(b),10 CFR 30.35.
Criteria: Portable gauge licensees possessing sealed sources containing radioactive material in excess of the limits specified in 10 CFR 30.35 must provide evidence of financial assurance for decommissioning.
Licensees are required to maintain, in an identified location, decommissioning records related to structures and equipment where gauges are used or stored and to leaking sources. Licensees must transfer these remrds important to decommissioning either to the new licensee before licensed activities are transferred or assigned in accordance with 10 CFR 30.34(b) or to the appropriate NRC regional office before the license is terminated.
Discussion: The requirements for financial assurance are specific to the types and quantities of byproduct material authorized on a license. Most portable gauge applicants and licensees do not need to comply with the financial assurance requirements because the thresholds for sealed 6
3 sources are 3.7 x 10 gigabecquerels (100,000 curies) of cesium-137 or 3.7 x 10 gigabecquerels (100 curies) of americium-241 or californium-252. Thus, a licensee would need to possess hundreds of gauges (typically containing about 0.30 gigabecquerels (8 millicuries) of cesium-137 and 1.5 gigabecquerels (40 millicuries) of americium-241) before the financial assurance requirements would apply. Since the standard portable gauge license does not specify the maximum number of gauges that the licensee may possess (allowing the licensee flexibility in obtaining gauges as needed without amending its license), it contains a condition requiring the licensee to limit its possession of gauges to quantities not requiring financial assurance for decommissioning. Applicants and licensees desiring to povess gauges exceeding the threshold amounts must submit evidence of financial assurance.
The same regulation also requires that licensees maintain records important to decommissioning in an identified location. All portable gauge licensees need to maintain records of structures and equipment where gauges are used or stored. As-built drawings with modifications of structures l
and equipment shown as appropriate fulfill this requirement. If drawings are not available, licensees may substitute appropriate records concerning the areas and locations. In addition, if NUREG - 1556, Vol.1 (draft) 8-4
CONTENTS oF AN APPLICATION portable gauge licensee have experienced unusual occurrences (e.g., leaking sources, other incidents that involve spread of contamination), they also need to maintain records about contamination that remains after cleanup or that may have spread to inaccessible areas.
Response from applicants: No response is needed from most applicants. If financial assurance is required, submit evidence.
Licensees must transfer records important to decommissioning either to the new licensee before licensed activities are transferred or assigned in accordance with 10 CFR 30.34(h) or to the appropriate NRC regional office before the license is terminated.
Reference:
Regulatory Guide 3.66, " Standard Format and Content of Financial Assurance Mechanisms Required for Decommissioning Under 10 CFR Parts 30,40,70, and 72," is available from NRC upon request.
8.7 ITEM 6: PURPOSE (S) FOR WHICH LICENSED MATERIAL WILL BE USED Regulations: 10 CFR 30.3)(a)(1).
Criteria: Proposed activity is authorized by the Atomic Energy Act of 1954, as amended, and devices will be used only for the purposes for which they were designed and in accordance with the manufacturer's recommendations for use as specified in an approved Sealed Source and Device (SSD) Registration Sheet.
Response from applicant: Specify the purposes for which the gauging device (s) will be used other than the manufacturer's recommendations as specified on the SSD Registration Sheet.
Note:
The typical moisture-density gauge license amthorizes use "to measure physical properties of materials."
Unusual uses will be evaluated on a case-by-case basis and the authorized use condition will reflect approved uses.
8.8 ITEM 7: INDIVIDUAL (S) RESPONSIBLE FOR RADIATION SAFETY PROGRAM AND THEIR TRAINING EXPERIENCE -
RADIATION SAFETY OFFICER (RSO)
Regulations: 10 CFR 30.33(a)(3).
Criteria: RSO3 must have adequate training and experience. In the past, NRC has found successful completion of one of the following as evidence of adequate training and experience:
8-5 NUREG - 1556, Vol.1 (draft)
CONTEwrsof AN APPLICATION Portable gauge manufacturer's course for users or for RSos Equivalent course that meets Appendix D criteria e
Discussion: The person responsible for the radiation protection program is called the RSO. The RSO needs independent authority to stop operations that he or she considers ansafe. He or she mi st have sufficient time and commitment from management to fulfill certain duties and responsibilities to ensure that radioactive materials are used in a safe manner. Typical RSO duties are illustrated in Figure 8.1 and described in Appendix E. NRC requires the name of the RSO on the license to ensure that licensee management has always identified a responsible, qualified person and that the named individual knows of his or her designation as RSO.
Stop unsafe hcensed activities RSO Responsibilities O gauges and sources Regulate possession of improper Personnel training PJtOc' n W WIHhtbt# n W y
. Monitor emergency events 1
O Receipt, transfer, Ai h
disposal j
Gauge secunty "I
O Trancportation i
i
~
O Audits 4
g at Matenal disposal O Personnel w
Monitorir'o
% Gauge transport h interaction with NRC, other o #,3imes Records maintenance Annualinternal audit 62Mei,2, Figure 8.1 RSO Responsibilities. Typical duties andresponsibilities ofRSOs.
1 Response from Applicant: Provide either of the following:
Name of the proposed RSO; e
Statement that: " Prior to obtaining licensed materials, the proposed RSO will have successfully completed one of the training courses described in Criteria in the section entitled ' Individual (s) Responsible for Radiation Safety Program and Their Training and Experience - Radiation Safety Officer' in Draft NUREG-1556, Vol.1, ' Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Portable Gauge Licenses,' dated September 1996."; and
- Statement that: " Prior to being named as the RSO, future RSos will have successfully completed one of the training courses described in Criteria in the section entitled
' Individual (s) Responsible for Radiation Safety Program and Their Training and NUREG - 1556, Vol.1 (draft) 8-6
i CONTENTS OF AN APPLICATloN i
Experience - Radiation Safety Officer' in Draft NUREG-1556, Vol.1, ' Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Portable Gauge Licenses,' dated September 1996."
OR Altemative information demonstrating that the proposed RSO is qualified by training and e
experience.
Note:
It is important to notify NRC, as soon as possible, of changes in the designation of the RSO; such notifications will be handled as administrative amendments not requiring fees as long as the application contains the commitment listed in the third bullet under
" Response from Applicant."
Alternative responses will be reviewed against the criteria listed above.
8.9 ITEM 8: TRAINING FOR INDIVIDUALS WORKING IN OR FREQUENTING RESTRICTED AREAS Regulations: 10 CFR 19.11.10 CFR 19.12,10 CFR 30.7,10 CFR 30.9,10 CFR 30.10, 10 CFR 30.33.
Criteria: Authorized users must have adequate training and experience. In the past, NRC has found successful completion of one of the following as evidence of adequate training and experience:
Portable gauge manufacturer's course for users e
Equivalent course that meets Appendix D criteria Discussion: The individuals using the gauges are usually referred to as authorized users.
i Authorized users have the responsibility to ensure the surveillance, proper use, and security of the licensed material.
Response from Applicant: Provide either of the following:
e The statement: " Prior to using licensed materials, authorized users will have successfully completed one of the training courses described in Criteria in the section entitled
' Training for Individuals Working In or Frequenting Restricted Areas' in Draft NUREG-1556, Vol.1, ' Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Portable Gauge Licenses,' dated September 1996."
OR i-8-7 NUREG - 1556, Vol.1 (draft)
CoNTERIs oF AN APPljCATioN A description of the training and experience for proposed gauge users.
Note:
Records of training should be maintained.
Alternative responses will be evaluated against the criteria listed above.
8.10 ITEM 9: FACILITIES AND EQUIPMENT No information need be submitted in response to this item. The key elements for portable gauge applicants are ensuring compliance with public dose limits and maintaining adequate security and control over the gauges. These issues are covered under " Radiation Safety Program - Public Dose" and " Radiation Safety Program - Operating and Emergency Procedures."
8.11 ITEM 10: RADIATION SAFETY PROGRAM - AUDIT PROGRAM i
Regulations: 10 CFR 20.1101.10 CFR 20.210' Criteria: Licensees must review the content and implementation of their radiation protection programs annually to ensure the following:
Compliance with NRC and DO T regulations, and the terms and conditions of the license; Occupational doses and doses to members of the public are as low as reasonably
]
achievable (,1L1RA) (10 CFR 20./ /01); and j
Records of audits and other reviews of program content are maintained for 3 years.
e Discussion: Appendix Fcontains a suggested audit program that is specific to the use of portable gauges and is acceptable to NRC. All areas indicated in Appendir F may not be applicable to every licensee and may not need to be addressed during each audit.
Currently the NRC's emphasis in inspections is to perform actual observations of work in progress. As a part of their audit programs, applicants should consider performing unannounced audits of gauge users in the field to determine if, for example, Operating and Emergency Procedures are available, are being followed, etc.
It is essential that once identified, problems be corrected comprehensively and in a timely manner; Information Notice (IN) 96-28, " Suggested Guidance Relating to Development and Implementation of Corrective Action," provides guidance on this subject. The NRC will review the licensee's audit results and determine if corrective actions are thorough, timely, and sufficient to prevent recurrence. If violations are identified by the licensee and these steps are taken, the NRC can exercise discretion and may elect not to cite a violation. The NRC's goal is to encourage prompt identification and prompt, comprehensive correction of violations and deficiencies. For additional information on NRC's use of discretion on issuing violations, refer NUREG - 1556, Vol.1 (draft) 8-8
j CONTENTS oF AN APPLICATloN to " General Statement of Policy and Procedures for NRC Enforcement Actions," (NUREG 1600).
With regard to audit records,10 CFR 20.2/02(a) requires licensees to maintain records of"...
audits and other reviews of program content and implementation." NRC has found audit records that contain the following information to be acceptable: date of audit, name of person (s) who conducted audit, persons contacted by the auditor (s), areas audited, audit findings, corrective actions, and followup.
Response From Applicant: The applicant is not required to submit its audit program to the NRC for review during the licensing phase.
References:
The following documents are available from NRC upon request: JIanual Chapter
- 7/00, Appendix E, " Industrial / Academic /Research Inspection Field Notes," NUREG-1600,
" General Statement of Policy and Procedures on NRC Enforcement Actions," and IN 96-28,
" Suggested Guidance Relating to Development and Implementation of Corrective Action."
8.12 ITEM 10: RADIATION SAFETY PROGRAM - TERMINATION OF ACTIVITIES Regulations: 10 CFR 30.34(b),10 CFR 30.35(g),10 CFR 30.36(d) and (j),10 CFR 30.51(f).
Criteria: The licensee must do the following:
Notify NRC, in writing, within 60 days, when principal activities have not been conducted for a period of 24 months.
Certify the disposition oflicensed materials by submission of NRC Form 3/4,
" Certificate of Disposition of Materials," available from NRC upon request.
Before a license is terminated, send the records important to decommissioning (as required by 10 CFR 30.35(g)) to the appropriate NRC regional office. Iflicensed activities are transferred or assigned in accordance with 10 CFR 30.34(h), transfer records important to decommissioning to the new licensee.
Discussion: For guidance on the disposition oflicensed material, see the section on " Waste Management - Gauge Disposal or Transfer." For guidance on decommissioning records, see the section on "Radiocative Materials - Financial Assurance and Recordkeeping for Decommissioning."
Response from Applicant: The applicant is not required to submit a response to the NRC during the initial application. However, when the license expires or at the time the licensee ceases operations, then NRC Fonn 3/4 must be submitted.
8-9 NUREG - 1556, Vol.1 (draft)
CONTENTS oF AN APPLICATloN 8.13 ITEM 10: RADIATION SAFETY PROGRAM -INSTRUMENTS Regulations: 10 CFR 30.33(a)(2).
Criteria: A radiation survey meter should--
Be capable of detecting the type of radiation emitted by the sealed source and e
Be checked for functionality before use (e.g., with the gauge or a check source)
Discussion: Each year there are a number ofincidents involving gauges at constructim >ites (e.g., construction equipment running over the gauge). It is important to determine a, soon as possible after an incident, by the use of a radiation survey meter, whether the shielding and source are intact. Applicants should preplan how they will obtain an instrmnent (e.g., use instrument located on site or obtain from the applicant's home office or a local emergency response organization).
Response from Applicant: Provide either of the following:
A statement that: "We will either possess and use, or have access to and use, a radiation survey meter that meets the Criteria in the section entitled ' Radiation Safety Program -
Instruments' in Draft NUREG-1556, Vol.1, ' Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Portable Gauge Licenses,' dated September 1996, in the event of an incident."
OR A description of an alternative procedure for determining source integrity after an incident involving the gauge.
Note:
Alternative responses will be reviewed against the criteria listed above.
Applicants who plan to perform gauge servicing that requires detaching the source rod from the gauging device will need to possess and use a radiation survey meter that meets more stringent criteria. Refer to the section on " Radiation Safety Program -
Maintenance" and Appendiv G for more information.
8.14 ITEM 10: RADIATION SAFETY PROGRAM - MATERIAL RECEIPT AND ACCOUNTABILITY Regulations: 10 CFR 30.34(e).10 CFR 30.41,10 CFR 30.51.
NUREG - 1556, Vol.1 (draft) 8-10
J CONTENTS oF AN APPLICATION Criteria: Licensees must do the following:
4 Maintain records of receipt, transfer, and disposal of gauges and Conduct physical inventories at intervals not to exceed 6 months (or some other interval justified by the applicant) to account for all sealed sources.
Discussion: As illustrated in Figure 8.2, licensed materials must be tracked from " cradle to grave" in order to ensure gauge accountability, identify when gauges may be lost, stolen, or 2
misplaced, and ensure that the possession limit stated on the license is not exceeded. Many l
licensees record daily use of gauges in a log book as part of their accountability program; see the suggested Operating Procedures in elppendit II.
Cradle to Grave Accountability d
Semi-Annual 7
Re[
inventory:
$84 n ~,
I 7
l, g
7 l
amF am
-w Receipt 62-fh3-012 07 DispOSalOf transfer i
Figure 8.2 Material Receipt and Accountability. Licensees must maintain records ofreceipt and disposal and conduct semiannual inventories.
Response from Applicant: Provide either of the following:
i i
A statement that: " Physical inventories will be conducted at intervals not to exceed 6 e
months, to account for all sealed sources and devices received and possessed under the 4
license."
t i
OR A description of the frequency and procedures for ensuring that no gauge has been lost, i
e j
stolen, or misplaced and that the possession limit stated on the license is not exceeded.
h I
8 11 NUREG - 1556, Vol.1 (draft)
CoNTfNrs oF AN APPLICATION.
Note:
Alternative responses will be evaluated against the criteria listed above.
Inventory records should be maintained and contain the following types ofinformation:
- Radionuclide and amount (in units of becquerels or curies) of byproduct material in each sealed source; t
- Manufacturcr's name, model number, and serial number (if appropriate) of each device containing byproduct material;
- Location of each sealed source and device Date of the inventory.
i 8.15 ITEM 10: RADIATION SAFETY PROGRAM - OCCUPATIONAL DOSIMETRY Regulations: 10 CFR 20.1502,10 CFR 20.1201,10 CFR 20.1207,10 CFR 20.1208.
Criteria: Applicants must do either of the following:
i Maintain, for inspection by NRC, documentation demonstrating that unmonitored individuals are not likely to receive a radiation dose in excess of 10 percent of the allowable limits as shown in Figure 8.3.
OR Provide dosimetry processed and evaluated by a National Voluntary Laboratory e
Accreditation Program (NVLAP) approved processor that is exchanged at a frequency recommended by the processor.
)
i NUREG - 1556, Vol.1 (draft) 8 12
CoNTENrs oF AN APPL.ICATioN 4
Skin l
Eyes Dose Limits for 05S Radiation Worker 0.50 Sv u
,e
)
(6 '***)
Elbows to hands O.50 Sv (50 rems) gl
{ $
i lg 4
f Knees 5 to feet
@h O.50 Sv s
j,. (50 rems) q.,e p:
m
~
h, Total effective dose equivalent TEDE s2+3-siza-oot s.20-se (whole body) 0.05 Sv (5 rems)
Figure 8.3 Dose Limits. Dose limitsfor radiation workers.
Discussion: Under conditions of routine use (including weekly cleaning and lubrication of the gauge in accordance with manufacturer's instructions), the typical portable gauge user does not require a personnel monitoring device (dosimetry). In most accidents where a gauge has been run over and has been damaged, the shielding of the source remains intact. A gauge user also does not require dosimetry when proper emergency procedures are used. Appendix I provides guidance on preparing a written evaluation demonstrating that gauge users are not likely to exceed 10 percent of the applicable limits and thus, are not required to have personnel dosimetry.
When personnel monitoring is needed, most licensees use either film badges or thermoluminescent dosimeters (TLDs) that are supplied by a NVLAP-approved processor. The exchange frequency for film badges is usually monthly due to technical concems about film fading. The exchange frequency for TLD3 is usually quarterly. Applicants should verify that the processor is NFLAP-approved. Consult the NVLAP-approved processor for its recommended exchange frequency.
Response from Applicant: Provide either of the following:
"Either we will maintain, for inspection by NRC, documentation demonstrating that unmonitored individuals are not likely to receive a radiation dose in excess of 10 percent of the allowable limits in 10 CFR Part 20 or we will provide dosimetry processed and evaluated by a NVLAP-approved processor that is exchanged at a frequency recommended by the processor."
OR A description of an alternative method for demonstrating compliance with the referenced e
regulations.
8-13 NUREG - 1556, Vol.1 (draft)
~
CONTENTS OF AN APPLICATION Note:
Altemative responses will be evaluated against the criteria listed above.
Many licensees choose to provide personnel dosimetry to their workers for reasons other than compliance with NRC requirements (e.g., to respond to worker requests).
Reference:
NationalInstitute ofStandards and Technology (NIST) Publication 810,
" National Voluntary Laboratory Accreditation Program,1996 Directory," is published annually and is available for purchase from GPO.
8.16 ITEM 10: RADIATION SAFETY PROGRAM - PUBLIC DOSE Regulationn 10 CFR 20.1301,10 CFR 20.1302,10 CFR 20.1003,10 CFR 20.1801, 10 CFR 20.ia02.
Criteria: Licensees must do the following:
Ensure that licensed gauges will be used, transported, and stored in such a way that e
members of the public will not receive more than 1 millisievert (100 millirem) in one year, and the dose in any unrestricted area will not exceed 0.02 millisievert (2 raillirem) in any one hour, from licensed operations.
Control and maintain constant surveillance over gauges that are not in storage and secure stored gauges from unauthorized removal or use.
Public Dose f
W h
3 4
A-ao M
ge Properly stored: a sufficient distance from personnel and secured Not properly stored: too close against unauthorized to personnel. inadequate s2.ms-es2s40s access or removal "g
shielding and not secured against unauthorized access or removal Figure 8.4 Storing Gauges. Gauges should be stored awayfrom occupied areas and secured against unauthori:ed removal.
Discussion: Operating and emergency procedures regarding security and surveillance specified under that section of this document should be sufricient to limit the exposure to the public during NUREG - 1556, Vol.1 (draft) 8-14
4 a
CONTENTS oF AN APPLICATloN use and after accidents. Public dose is controlled, in part, by ensuring that gauges not in use are stored securely (e.g., stored in a locked area) to prevent unauthorized access or use. If gauges are not in storage, then authorized users must maintain constant surveillance to ensure that members of the public cannot get near the gauges nor use them, and thus receive unnecded radiation exposure.
Public dose is also affected by the choice of storage location and conditions, as illustrated in Figure 8.4. Since a gauge presents a radiation field during storage, it must be stored so that the radiation level in an unrestricted area (e.g., an office or the exterior surface of an outside wall) does not reach 1 millisievert (100 millirem) in a year or 0.02 millisievert (2 millirem) in any one hour. Use the concepts of time, distance, and shielding when choosing a permanent or temporary storage location. Decreasing the time spent near a gauge, increasing the distance from the gauge, and using shielding (brick, concrete or other solid walls) will reduce the radiation exposure.
Therefore, gauges should be stored as far away from occupied locations as possible.
Determine the radiation levels adjacent to the storage location either by direct surveys or by calculations using occupancy factors, inverse square law, shielding factors, and the known radiation levels provided by the manufacturer.
If, after making an initial evaluation, a licensee makes changes affecting the storage area (e.g.,
changing the location of gauges within the storage area, removing shielding, adding gauges, changing the occupancy of adjacent areas, moving the storage area to a new location), then the licensee must perform a new evaluation to ensure that the public dose limits are not exceeded and gauges are properly secured.
Response from Applicant: No response is required from the applicant in a license application, but this matter will be examined during an inspection.
8.17 ITEM 10: RADIATION SAFETY PROGRAM - OPERATING AND EMERGENCY PROCEDURES Regulations: 10 CFR 30.31(c),10 CFR 20.1101.10 CFR 20.1801,10 CFR 20.1802, 10 CFR 20.2201-2203,10 CFR 30.50.
Criteria: Each applicant must do the following:
Develop, implement, and maintain operating and emergency procedures containing the following elements:
- Instructions for maintaining security during storage and transportation;
- Instructions to keep the gauge under control and immediate surveillance during use;
- Step.; to take to keep radiation exposures ALARA:
- Steps to maintain accountability during use;
- Steps to control access to a damaged gauge; and 8-15 NUREG - 1556, Vol.1 (draft)
CONTENTS oF AN APPLICATION
- Steps to take, and whom to contact, when a gauge has been damaged.
If gauges are used for measurements more than 3 feet beneath the surface, require use of surface casing from the lowest depth to 12 inches above the surface, provide instructions for procedures to follow to retrieve a stuck source, and require reporting to NRC, pursuant to 10 CFR 30.50(b)f2), when it becomes apparent that efforts to recover a stuck source will be unsuccessful.
Provide copies of operating and emergency procedures to all gauge users and at eachjob site.
Proper Handling of incidents Driver nearby Y.
but out of m.-
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cordoned Supervisor area cordon 7;
(g g off area A
9 de
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a yaw
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Hey boss,
/W.c 9,2 E G, i M guess what Ernergency response perton (supervisor, RSO,
@d state official) survey Supervisor meter
{
e2-ms.o12s-Figure 8.5 Proper IIandling. Gauges are often damaged by heary equipment atjob sites and emergencyprocedures need to minimi:e radiation safety risk.
Discussion: Lost or stolen gauges and, as illustrated in Figure 8.5, gauges damaged by heavy equipment during use at job sites are the most common occurrences that present a potentially significant radiation safety risk. Figure 8.6 illustrates steps that should be taken to prevent loss, theft, or unauthorized use. Operating and emergency procedures should be developed to minimize these risks. NRC considers security of gauges extremely important and lack of security is a significant violation for which gauge licensees are fined. See Appendix H for sample procedures.
Certain portable gauges are used to make measurements more than 3 feet beneath the surface.
Unless precautionary measures are taken, it is possible for the source to be buried under dirt or concrete that collapses around the source during the measurements. Precautionary measures need to be planned in advance to prevent these sources from being buried and to recover sources should they become stuck.
Notify NRC when gauges are lost, stolen, or certain other conditions are met. Refer to the regulations for a description of when and where notifications are required.
NUREG - 1556, Vol.1 (draft) 8-16
CONTENTS oF AN APPLICATloN Security I
Constant surveillance when idle or in use Storage and transport 3
d ex g3 M
i fL-62-fh3-9128-003 J
7-25 96
)
Figure 8.6 Security. To avoidlost or stolen gauges, licensees must keep the gauges under
\\
constant surveillance, or secured against unauthori:ed use or removal.
Response from Applicant: Do either of the following:
e State: "We will develop, implement, and maintain the operating and emergency procedures in Appendh II of Draft NUREG-1556, Vol.1, ' Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Portable Gauge Licenses,' dated September 1996."
OR e State: " Operating and emergency procedures will be developed, implemented, and maintained and will meet the criteria in the section entitled ' Radiation Safety Program -
Operating and Emergency Procedures' in Draft NUREG-1556, Vol.1, ' Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Portable Gauge Licenses,' dated September 1996."
OR Submit alternative procedures.
e Note:
Altemative procedures will be reviewed against the criteria listed above.
References:
NRCIN 93-I#: " Portable Moisture-Density Gauge User Responsibilities During Field Operations," and NUREG/BR-0133, " Working Safely with Nuclear Gauges," are available from NRC upon request.
8-17 NUREG - 1556, Vol.1 (draft)
CoNTENTSoF AN APPUCATioN 8.18 ITEM 10: RADIATION SAFETY PROGRAM - LEAK TESTS Regulations: 10 CFR 30.53.
Criteria: NRC requires testing to determine whether there is any radioactive leakage from the source in the device. NRC finds testing to be acceptable ifit is conducted by an organization approved by NRC or an Agreement State or in accordance with procedures approved by NRC or an Agreement State.
Discussion: When issued, a license will require performance ofleak tests at intervals approved by the NRC or an Agreement State and specified in the Sealed Source and Device Registration Certificate. The measurement of the leak-test sample is a quantitative analysis requiring that instrumentation used to analyze the sample be capable of detecting 185 becquerels (0.005 microcurie) of radioactivity.
1 M mufacturers, consultants, and other organizations may be authorized by NRC or an Agreement State to either perform the entire leak test sequence for other licensees or provide leak test kits to licensees. In the latter case, the licensee is expected to take the leak test stimple according to the l
gauge manufacturer's and the kit supplier's instructions and return it to the kit supplier for evaluation and reporting results. Licensees may also be authorized to conduct the entire leak test sequence themselves.
Response from Applicant: Do either of the following:
e State: " Leak tests will be performed at intervals approved by the NRC or an Agreement State and specified in the Sealed Source and Device Registration Certificate. Leak tests
)
will be performed by an organization authorized by NRC or an Agreement State to provide leak testing services to other licensees or using a leak test kit supplied by an organization authorized by NRC or an Agreement State to provide leak test kits to other licemees and in accordance with the kit supplier's instructions."
OR Provide the information in Appendix J supporting a request to perform leak testing and e
sample analysis.
Note: Requests for authorization to perform leak testing and sample analysis will be reviewed on a case-by-case basis and, if approved, NRC staff will authorize via a license condition.
References:
Draft Regulatory Guide FC 412-4, " Guide for the Preparation of Applications for the Use of Radioa.:tive Materials in Leak-Testing Services," is available from NRC upon request.
NUREG - 1556, Vol.1 (draft) 8-18
CONTENTS of AN APPLICATION 8.19 ITEM 10: RADIATION SAFETY PROGRAM - MAINTENANCE Regulations: 10 CFR 20.1101.10 CFR 30.34(e).
Criteria: Procedures for routine cleaning and lubrication of the source rod and shutter mechanism (e.g., to remove caked dirt, mud, asphalt, or residues from the source rod; lubricate the shutter mechanism) must consider A LA RA and ensure that the gauge functions as designed and source integrity is not compromised.
More extensive maintenance or servicing (beyond routine cleaning and lubrication) that involves detaching the source or source rod from the device must be performed by the gauge manufacturer or a person specifically authorized by NRC or an Agreement State. Requests for specific authorization to perfarm more extensive maintenance or servicing (see Appendir G) must demonstrate that personnel performing the work do the following:
Have adequate training and experience; Use equipment and procedures that ensure compliance with regulatory requirements, and e
consider ALARA; and Ensure that the gauge functions as designed and that source integrity is not compromised.
e Routine Maintenance Extended Maintenance and Lubrication survey meter registerin9 source rod Safety radiation shielded Checklist wire brush survey meter (k
dosimetry radiation f
maintenance 3
source
=
j rod procedures
- c e2 m dld dosimeter Figure 8.7 Maintenance. Alllicensees need to perform routine cleaning and lubrication to ensure proper operation ofthe gauge. Gauge manufacturers or other service companies usually perform more extensive maintenance.
Discussion: Figure 8.7 illustrates routine cleaning and lubrication and more extensive maintenance. Licensees may perform routine cleaning and lubrication in accordance with procedures approved by NRC. The following are acceptable procedures for routine cleaning and lubrication of the source rod and shutter mechanism and contain the following elements:
Do not detach the source or source rod from the gauge.
Stand behind the gauge with the shutter opening pointed away.
Extend the source rod from the gauge and wipe and return it into the shielded position as quickly as possible.
8 19 NUREG - 1556, Vol.1 (draft)
CONTENTS of AN APPLICATION I
Do not touch the tip of the source rod.
e Use a long-handled brush or compressed air to clean the exposed mechanisms.
Perform routine cleaning and lubrication as recommended by manufacturer.
Do not perform any operation such as drilling, grinding, cutting, or chiseling on the source or source rod that could compromise the source integrity.
The NRC license will state that any cleaning, maintenance, or repair of gauges that requires detaching the source or source rod from the gauge shall be performed only by the manufacturer i
i or other persons specifically licensed by the Commission or an Agreement State to perform such services. Most licensees do not perfomi more extensive maintenance or repair operations that require detaching the source or source rod from the gauge; they usually retum the gauge to the manufacturer. Applicants seeking authorization to detach the source or source rod from the device must submit specific procedures for review. See Appendix 6 for r.1 ore information.
Response from applicant:
Routine cleaning and lubrication: Submit either of the following:
"We will develop, implement, and maintain procedures for routine cleaning and lubrication of the source rod and shutter mechanism that contain the elements listed under Discussion in the section on ' Radiation Safety Program - Maintenance' in Draft NUREG-1556, Vol.1,
' Consolidated Guidance about Materials Licenses: Program-Specific Guidance about Portable Gauge Licenses,' dated September 1996."
OR Alternative procedures for NRCS review.
More extensive maintenance or repair operations that require detaching the source or source rod from the gauge: Submit either of the following:
"We will send the gauge to the manufacturer or other person authorized by NRC or an Agreement State to perform more extensive maintenance or repair operations that require detaching the source or source rod from the gauge."
OR The information listw in Appendiv G in support of a request to perform this work "in-house."
Note:
Alternative procedures for performing routine cleaning and lubrication will be reviewed in accordance with the criteria listed above.
NUREG - 1556, Vol.1 (draft) 8-20
CONTENIs oF AN APPLICATION Information requested in Appendit G will be reviewed on a case-by-case basis; if e
approved, the license will contain a condition authorizing the licensee to perform more extensive maintenance.
8.20 ITEM 10: RADIATION SAFETY PROGRAM - TRANSPORTATION Regulations: 10 CFR 71.5,49 CFR Parts 171-178,10 CFR 20.1/01.
Criteria: Applicants must develop, implement, and maintain safety programs for public transport of radioactive material to ensure compliance with DOT regulations.
Transportation shipping Properly labeled, papers blocked, braced, secured, and away from the driver 62-fh3-9128-006 7-25-96 Figure 8.8 Transportation. Licensees often transport their gauges to andfromjob sites and must ensure compliance with Department of Transportation regulaticns.
Discussion: Figure 8.8 illustrates some DOT requirements often overlooked by ponable gauge licensees. During an inspection, NRC uses the provisions of10 CFR 71.5 and a Memorandum of Understanding with DOTto examine and enforce transportation requirements applicable to portable gauge licensees. Appendix K lists major DOT regulations and provides a sample shipping paper.
Response from Applicant: No response is needed from applicants during the licensing process; this issue will be reviewed during inspection.
References:
"A Review ofDepartment of Transportation Regulationsfor Transportation of Radioactive Materials (1996 revision)" can be obtained by calling DOT's Office of Hazardous Material Initiatives and Training at (202) 366-4900.
8.21 ITEM 11: WASTE MANAGEMENT - GAUGE DISPOSAL AND TRANSFER Regulations: 10 CFR 20.2001,10 CFR 30.41,10 CFR 30.51.
Criteria: Licensed materials must be disposed ofin accordance with NRC requirements by transfer to an authorized recipient. Appropriate records must be maintained.
8-21 NUREG - 1556. Vol.1 (draft)
CoNTENTsof AN APPLICATION Discussion: When disposing of portable gauges, licensees must transfer them to an authorized recipient. Authorized recipients are the original manufacturer of the device, a commercial firm l
licensed by the NRC or an Agreement State to accept radioactive waste from other persons, or another specific licensee authorized to possess the licensed material (i.e., their license specifically authorizes the radionuclide and the use).
Hefore transferring radioactive material, a licensee must verify that the recipient is properly
~
i authorized to receive it using one of the methods described in 10 CFR 30.4I. In addition, all packages containing radioactive sources must be prepared and shipped in accordance with NRC and DOTregulations. Records of the transfer must be maintained as required by 10 CFR 30.51.
Response from Applicant: The applicant does not need to provide a response to this item during the licensing process. However, the licensee should establish and include waste disposal procedures in its radiation safety program.
Because of the difficulties and costs associated with disposal of americium-241 sealed sources, applicants should preplan the disposal. Applicants may want to consider contractual arrangements with the source supplier as part of a purchase agreement.
The next two items on NRC Form JIJ are to be completed on the form itself.
i 8.22 ITEM 12: FEES On NRC Form 3/3, enter the fee category and the amount of the fee enclosed with the application.
8.23 ITEM 13: CERTIFICATION Individuals acting in a private capacity are required to date and sign NRC Form 313. Otherwise, representatives of the corporation or legal entity filing the application should date and sign NRC Form 3/3. Representatives signing an application must be authorized to make binding commitments and to sign official documents on behalf of the applicant. As discussed previously in " Management Responsibility," signing the application acknowledges management's commitment and responsibilities for the radiation protection program. NRC will return all unsigned applications for proper signature.
Note:
It is a criminal offense to make a willful false statement or representation on applications or correspondence (18 U.S.C.1001).
When the application references commitments, those items become part of the licensing conditions and regulatory requirements.
NUREG - 1556, Vol.1 (draft) 8-22
J 4
9 AMENDMENTS AND RENEWALS TO A LICENSE It is the licensee's obligation to keep the license current. If any of the information provided in the original application is to be modified or changed, the licensee must submit an application for a license amendment before the change takes place. Also, to continue the license after its expiration date, the licensee must submit an application for a license renewal at least 30 days before the expiration date (10 CFR 2.109,10 CFR 30.36(a)).
Applications for license amendment, in addition to the following, must provide the appropriate fee. For renewal and amendment requests applicants must do the following:
Be sure to use the most recent guidance in preparing an amendment or renewal request.
Submit in duplicate, either an NRC Form 3/3 or a letter requesting amendment or renewal.
Provide the license number.
For renewals, provide a complete and up-to-date application if many outdated documents are referenced or there have been significant changes in regulatory requirements, the licensee's organization, or radiation protection program. Alternatively, describe clearly the exact nature of the changes, additions, and deletions.
Deviations from the suggested wording of responses as shown in this document or submission of attemative procedures may require a custom review.
9-1 NUREG - 1556, Vol.1 (draft)
)
i I
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e 4
i i
l 1
1 l
Appendix A e
i l
i l
United States Nuclear Regulatory Commission Form 313 i
s 1
I, i
1 1
l, 1
j i
l 4
i 4
3
~--
1 NRC FOT.M 313 U. S. NUCLEAR REGULATORY COMM1SION APPRQvED Sy OMS: NO. 319041p EXPdtES: TMme pae)
Esemand bween por maponse W comply we eie W*rmaton collecton 10 CFR 30. 32,33 request 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> Submanal er the opphcoton m -=y M doesemme that 34,36,36,30 and 40 the oppkcent a quenhed and that adequate procer'wes meet to protect the pubhc heellh and seesty Forweni cornments regardme burden sebmste to se wdormenon end Racere Menesenant arem:h (T4 F33), u S Nucies, APPLICATION FOR MATERIAL LlcENSE
",e*s,,',', c,*'",*N4"1L"'*"fe ' " n,',; *"e.*, '"e'n@
d
,e e C
womhmenon. DC 20603 NRC nwy not conduct or sponsor, and a pomon a not pseuwed to roepend 2, e aim =*m of yearmaban unions 8 depteys e oweney vend Oue seawei nummer.
INSTRUCflONS: SEE THE APPROPRIATE UCENSE APPUCATION GUIDE FOR DETAILED INSTRUCTIONS FOR COMPLETING APPUCATION.
SEND TWO COPlES OF THE ENTIRE COMPLETED APPUCATION TO THE NRC OFFICE SPECIFIED BELOW.
l APPUCATION POR DISTftlSUTION OF EXElePT PRODUCTS PILE APPUCATIONS WITH:
IF YOU ARE LOCATED M:
DfVISION OF INDUSTRIAL AfC MEDICAL NUCLEAR SAFETY n,LsNOst. INDIANA, IOWA beeCHIGAN, IIINNESOTA, BetSSOURI, OHIO, OR== -
OFFICE OF NUCLEAR MATERIALS SAFETY AND SAFEGUARDS SSNO APPUCATIOpes TCt i
U S NUCLEAR REGULATORY rumenst w r
WASHMGTON, DC 20666 0001 MATERIALS UCENSMG SECTION U.S NUCLEAR REGULATORY ComoseON, REGION M gg g p,,g g gg 801 WARRENVILLE RD.
IF YOU ARE LOCATED let:
USLE, E, 006324361 1
CONNECTICUT DELAWARE. DtSTRICT OF COLue1944, thA100E, RAARYLAND, ALASNA, ARIEONA, ARMANSAS,CAUPORNIA, COLORADO,HAWAlt, IDAHO,MANSAS, i
MASSACMUSETTS, setW HAaIPSMIRE, NEW JERSEY, leEW YOftK, PE00NSYLVANIA, LOUIS 4ANA. IAONTANA, "*= 8% NEVADA, esEW GIERICO, NORTH DAKOTA, RHODE ISLAND, OR YERtIONT, SENO APPUCATIO888 TO:
OKLAMOesA,08t80008, PACIPlc TRUST TERRff 0 RIES, SOUTH DAKOTA, TEXAS, UTAH, i
UCENSMG ASSISTANT SECTION NUCLEAR MATERIALS SAFETY BRANCH NUCLEAR MATERLALS UCENSNG SECTION i
U S NUCLEAR REGULATORY COMMISSION, REGION I U S NUCLEAR REGULATORY COMMISSION, REGION IV 475 ALLENDALE ROAD
$11 RYAN PLAZA DRIVE, SUffE 400
$UNG OF PRUSSIA, PA 1840M415 ARUNGTON, TX 78011 4084 i
ALASAMA, PLOftIDA, OEOR044, KENTUCKY,184SS4SS4PPI,1808tTH CAROUNA PUERTO RICO, SOUTH CAROUNA TENNESSEE, VIR04tilA, VIRGIN ISLANOS, Oft WEST VlftOSdeA, 1
i SEND APPUCATIONS TO' 4
NUCLEAR MATERIALS UCENSMG SECTION i
U S NUCLEAR REGULATOftY rn-aaON REC 40N b 101 MARIETTA STREET, NW, SulTE 2000 f
ATLANTA, GA 303210100 PERSONS LOCATED M AGRossesNT STATES SEND APPUCATIO888 TO THE U.S. NUCLEAR REOULATQftY CoastelSSeOsi ONLY OF THEY WISH TO POSSESS ANO USE UCENSED
)
MATERlAL IN STATES SUBJECT TO U.S. NUCLEAR REOULATOftY COtBIA68840N JURISDICTt0068.
1 THISl$ AN APPUCATlON FOR (Check opprapnose marrV 2 NAME AND MAluNG ADDRESS OF APPUCANT (hcAusle 2, onde) 4 A NEW UCENSE 1
S AMENDMENT TO UCENSE NUMSER i
RENEWAL OF UriNSE NUMBER C
]
~
j 3 ADDRESS (ES) WHERE UCENSED MATERIAL WILL DE USED OR POSSESSED 4 NAME OF PERSON TO BE CONTACTED ASOUT THLS APPUCATION i
i f
TELEPHONE NUMBER 1
SUBMIT fTEMS 6 THROUGH 11 ON Mf2 X 11* PAPER THE TYPE AND SCOPE OF INFORMATION TO BE PROVIDED IS DESCRIBED N THE UCENuE APPUCATION GUIDE.
5 RADIDAC11VE MATERML e Element end mens number, b chemsel and/or pnyncel form, and c menemum amount 6 PURPOSE (S) FOR WHICH UCENSED MATERIAL WILL BE USED wench wil be posesseed at any one eme T NDivlDUAL(S) RESPONSIBLE FOR RADIATION SAFETY PROGRAM AND THEIR 8 TRAINNG FOR INDIVIDUALS WORKING N OR FREQUENTING RESTRICTED ARE.AS i
TRArmG EXPERN 4
)
j p FACIUTIES AND EQUIPMENT 10 RADIATION SAFETY PROGRAM
- 12. UCENSEE FEES ($ e 10 CFR f 7D and Sectan f 70,7f) 1 It WASTE MANAGEMENT g Aa40UNT FEE CATEOORY I ENCLOSED $
l 13 CERTIFICATION (towelto compuesd by appacong THE APPUCANT UNDERSTANDS THAT All STATEMENTS AND REPRESENTATIONS MADE IN THIS APPUCATION ARE BINDING
]
uPONTHe APPuCANT THE APPUCANT AND ANY OFFICIAL EXECLfflNG THIS CERTIFICATION ON BEHALF OF THE APPUCANT, NAMED N ffEM 2, CERTIFYTHAT THIS APPUCATION IS PetEPARED N COdFOftMrTY IMTH TTTLE 10 CODE OF FEDERAL REGULATIONS, PARTS 30,32. 33,34. 36,30,3e AND 40, AND THAT ALL NFORMATION CONTANED HEREN IS TRUE AND l
CORalECT TO THE BEST OF THEIR KNONLEDGE AND BEUEF.
WARNNG 16 U S C SECTION 1001 ACT OFJUNE 25.19e8 82 STAT. 748 MAKES ff A CRiksNAL OFFENSE TO MAKE A WILLFULLY F ALSE STATEMENT OR REPRESENTATION TO ANY DEPARTMENT OR AGENCY OF THE UNITED STATES AS TO ANY IAATTER WfTHW ffS JURISDICTION 1
CEmvNG OmCER - TYPEDmiNTED NAME AND Tm.E moNATuRE DATE a
FOR NRC USE ONLY TvPE OF FEE FEE LOG FEE CATEoOftY AnaOuNT fieCElvED CHECK NUMBER COMMENr8 5
APPROVED BY DATE PRNTED ON RECYCLED PAPER NitC FOftM 313 044)
NRC FORM 313 U, S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMS: NO. 31904130 EAPtRES: Tdifte m
Es,me ed nu,0.n pe, - -p, -in ins.n.-me n mec on 10 CFR 30,32,33 request 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> Sutrnesi of the appiceman a neceanery e estermme that 34,35. 36. 39 and 40 sie opphcent a quehned and that adequate procedures most e protect the pubhc heelth and esfoty Forward commeme regarding twreen esbmets to the informaton and Recores Management Branch (74 F33). U S Nuclear
'*"'*'"a-'*
APPLICATION FOR MATERIAL LICENSE "a"*' c"""*** *""'"*"" mco '"of Reducton Pmpact (3150 0120). O Management and Budget.
Weehmetsn. DC 20603 NRC may not conduct or sponsor, and a person a not requered e respond m, e soitecton at informenon uniaan a emp6eys,
curoney vehd OM8 consol number INSTRUCTIONS: SEE THE APPROPRIATE LICENSE APPLICATION GUIDE FOR DETAILED INSTRUCTIONS FOR COMPLETING APP SEND TWO COPIES OF THE ENTIRE COMPLETED APPLICATION TO THE NRC OFFICE SPECIFIED BELOW.
APPUCATION POR DISTRISUTIOei OF EAEbrT PRODUCTS PILE APPUCATIOtsS WITH:
IF YOU ARE LOCATED IN:
DIVISION OF INDUSTRnAL AND MEDICAL NUCLEAR SAFETY lLupeo S_ psosANA, IOWA, MeCHIGAN, GliefedESOTA, RAISSOUftl, OHIO, OR WLSCONSIN C7FICE OF NUCLEAR MATERIALS SAFETY AND SAFEGUARDS SENO APPUCATIOess 70-U $ NUCLEAR REOULATORY COMhmSSION WASHNGTON, DC 20666 0001 MATERIALS UCENSING SECTION AL10THER PERSONS PILE APPUCAfl0stS AS POLLOWS:
801 W ENVILL USLE, L 00632-4361 D YOU ARE LOCATED les:
ALASsLA, ARGONA ARMANSAS, CAUPORNIA COLORADO,MAWAll, IDAHO,MANSAS, CONNECTICUT, DELAWARE, DISTReCT OF COLuttelA, MAINE, GRARYLAND, MASSACHUSETTS, NEW HAMPSH6RE, NEW JERSEY, NEW YOftK PENesSYLVAN4A, LOUIS 4ANA, IIOffTANA, NE9RASKA,00EVADA, NEW ISEKICO, NORTH DAKOTA, OKLAHOGRA OREGON, PACIPlc TRUST TERRfTORIES, SOLTH DAKOTA, TEAAS, UTAH, RHODE ISLAND, oft VEmesONT. SEND APPUCATJONS TO:
WASHINGTON, OR WYOtteNO, SEND APPUCATIONS TO:
UCENSING ASSISTANT SECTION NUCLEAR MATERIALS SAFETY BRANCH NUCLEAR MATERIALS UCENSING SECTION U S NUCLEAR REGULATORY COMMISSION. REGION I U $ NUCLEAR REGULATORY COMMISSION, REGION IV 475 ALLENGALE ROAD 011 RYAN PLAZA DRIVE, SurTE 400 KING OF PRUSSIA, PA 194061415 ARUNGTON, TX 78011 8084 ALASAMA, FLOftIDA, GEOftO6A KENTUCKY, MISS4SS4PPI,000RTH CAROLINA PUERTO CrJO, SOUTN CAROUhA, TENNESSEE, VIRGINIA, VWtCIN ISLANOS, Oft WEST VIRGINlA, SENO APPUCATIONS TO:
NUCLEAR MATERIALS UCENSING SECTION U S NUCLEAR REGULATORY COMMIS$lON, REGaON N 101 MARIETTA STREET, NW, SUrTE 2900 QTLANTA, GA 30323 0199 PE000esS LOCATED IN AOftEEteENT STATES SEND APPUCATIOfe8 TO THE U.S. NUCLEAR REOULATOfty minannasearw ONLY OF THEY WLSH TO POSSESS ANO USE UCENSED teATEmiAL 100 STATES SutJECT TO U.S NUCLEAR REGULATOfty erinamalSSaOff JURISOICTIONS.
1 THl$ LS AN APPUCATION FOR (Checa apprcunees amm) 2 NAME AND MAlUNG ADDRESS OF APPUCANT (McAnse 2qo code)
A NEW UCENSE
~
AMENDMENT TO UCENSE NUMBER 8
C RENEWAL OF LICENSE NUMBER 4 NAME OF PERSON TO BE CONTACTED A8007 THIS 3 ADDRESS (ES; WHERE LCENSED MATERIAL WILL BE USED OR POSSESSED APPUCATION TELEPHONE NUMBER SUBMIT ITEMS S THROUGH 11 ON 61/2 K 11" PAPER THE TYPE AND SCOPE OF NFORMATION TO DE PROVIDED 'S DESCRISED N THE UCENSE APPLICATION GU g RADsOACTIVE MATERIAL e Element and mean number. b charmce: and/or physsel brm, and c meenmum amount 0 PURPOSE (S) FOR WHICH UCENSED MATER:AL WILL BE USED
)
whsch wall be pneseemed at any one Dme j
7 NDIVIDUAL(S) RESPONSieLE FOR RADIATION SAFETY PROGRAM AND THEIR 8 TRAINNG FOR NDIVIDUALS WORKING N OR FREQUENTING RESTRICTED AREAS TRANNG NRN S FACIUTIES AND EQUIPMENT.
10 RADLATION SAFETY PROGRAM 11 UCENSEE FEES (See to CFR f Fu and S ;,,, f 70 31) 11 WASTE MANAGEMENT l AMOUNT FEE CATEGORY lENCLOSED l 13 CERTIFCATION (efuet 8e cornr=*=8=8 Dy appecong THE APPUCANT UNDERSTANDS THAT ALL STATEMENTS AND REPRESENTATIONS MADE N THIS APPUCATION ARE BINDING UPONTHE APPUCANT.
THE APPUCANT AND ANY OFFICIAL EXECUTING THIS CERTIFICATION ON BEHALF OF THE APPUCANT, NAMED IN ITEM 2 CERTIFY THAT THIS APPUCATION IS PREPARED N CONFORMrTY WrTH TITLE 10. CODE OF FEDERAL REGULATIONS, PARTS 30. 32,33,34,35,30,30 AND 40 AND THAT ALL INFORMATION CONT ANED HEREN IS TRUE AND CDftRECT TO THE BEST OF THEIR KNCW SW AND BEUEF.
W ARNING 18 U S C SECTION 1001 ACT OFJUNE 25.1948 82 STAT 740 MAKES IT A CRRANAL OFFENSE TO MAKE A WILLFULLY F ALSE ST ATEMENT OR REPRESE ANY DEPARTMENT OR AGENCY OF THE UNffED STATES AS TO ANY MATTER WffMIN TTS JURLtlOICTION CERTIFYING OFFCER - TYPEDP8 TINTED NAME AND TITLE SIGNATURE DATE FOR NRC USE ONLY f
TvPE OF rEE rEE LOG FEE CATECORY AMOuMT ReCewsD CHECK NuMSER couMENr5 8
APPROVEDSV DATE
\\
PRINTED ON RECYCLED PAPER NRC FOftM 313 (7.se)
NRC FORM 313 U. S. NUCLEAR REGULATORY COMMISSION APPROvEDsvOMe: NO.a m ac EXPIRES: Tm pas)
Esemend bween per resp M comply we lh. w*wma a
re,uese T.I, owe S.u.,n onse e ep, co.on. -, M. ton conecoon 10 CrR 30. 32. 33 o,
= appi,ce h - es.M, F-,d comme,. re.e,.n..eeM
..ue ed - min.e.us.,,=ea e
P esci ~
u z.x.3 - A0 puM,c 1,en u ones.me. M the informeean and Recorde Management Brancn (T4 F33). U S Nuclear Reducten Protect (3150f120) -
C"""***"'"*
APPLICATION FOR MATERIAL LICENSE
"**"' ca'"**** ***""'. *"Omco of Mehgement and Buoge Weehmghn, DC 20603 NRC may not conduct or sponsor, and a per 4
noi reeuned m reseand m. e ~=~*-i or adormsena unisse li espiere e I
oweney vei.d Ous enneM nummer INSTRUCTIONS: SEE THE APPROPRIATE LICENSE APPLICATION GUIDE FOR DETAILED INSTRUCTIONS FOR COMPLETING APPLICATION, i
SEND TWO COPIES OF THE ENTIRE COMPLETED APPLICATION TO THE NRC OFFICE SPECIFIED BELOW, APPUCATION POR DtSTRIBUTION OF EKEasPT PRODUCTS FILE APPUCATIONS WITH:
IF YOU ARE LOCATED IN:
DIVISION OF INDUSTRAL ADO MEDICAL NUCLEAR SAFETY a i laansa INotANA, IOWA, IseCHieAN, telNNESOTA, seeSSOURI, OHoo, OR WISCONSIN OFFICE OF NUCLEAR MATERIALS SAFETY AND SAFEGUAROS SENO APPUCATIOsts 70-U S NUCLEAR REGULATORY madseenny WASHNOTON, DC 3066H001 MATERIALS UCENSNG SECTION U S. NUCLEAR REGULATORY rmammaanN, REGION M ALL OTHER PERSOess PILE APPUCATIONS AS POLLOWS' S01 WARRENVILLE RO IF YOU ARE LOCATED IN:
I nel F L 80632 4361 CONNECTICUT, DELAWARE, DISTRtCT OF COLuttelA laAaNE, htARYLANO, AMSMA, ARGDee4, ARMANSAS CAUPORNIA COLORADO,HAWAal, IDAHO,MANSAS.
?
04ASSACHUSETTS, NEW HARIPSHNtE, NEW JERSEY, teEW YORK, PENNSYLVAN4A, LOUISIANA, RIOefTANA, NE9RAGMA, NEVADA, NEW adEXICO, NORTH DAMOTA, j
RHODE ISLAND, OR VEResoeff, SENO APPUCATIONS 70-OMLAMOtaA, OREOON, PACIPIC TRUST TERRITORIES, SOUTH DAKOTA, TEXAS, UTAH, WASHINGTON,OR WYOldlesO, SENO APPUCATIONS TD-UCENSING ASSISTANT SECTION NUCLEAR MATERIALS SAFETY ORANCH NUCLEAR MATERIALS UCENSMG SECTION U S NUCLEAR REGULATORY tNmCCu"H, REGION l U S NUCLEAR REGULATORY COMMIS8lON, REGON IV 475 ALLENDALE ROAD S11 RvAN PLAZA ORIVE. SUITE 400 KNG OF PRUSSIA. PA 1840& 1413 ARUNGTON, TX 78011 4084 ALASAMA, FLORIDA, OEOR06A, MENTUCMY, RAIS$4SS4PPI, NORTH CAROUHA, PUERTO RICO. SOUTH CAROUNA, TENeasmass VNtOl0GA, VIRO 4N ISLANDS, Oft WEST VIRON6A, SEND APPUCATIOess TO' NUCLEAR MATER 6ALS UCENSNG SECTION U S NUCLEAR REGULATORY COMMISSION. REGION il 101 MARIETTA STREET. NW, SUITE 2000 ATLANTA, GA 303234109 PERSONS LOCATED IN AGREEMENT STATES SENO APPUCATIOe88 TO THE U.S. NUCLEAR REOULATORYr*"**"
ONLY IF THEY WISH TO pnamena AND USE UCENSED MATERIAL IN STATES SUBJECT TO U.S. NUCLEAR REOULATORy e nanassamanad Just4SOeCTIONS-THI
- 2. NAME AND MAluNG ADDRESS OF APPUCANT (Inciuse Ze coes)
_S IS AN APPUCATION FOR (Chace approsmos som) 1 A NEW UCENSE B AMENOMENT TO UCENSE NUMBER C RENEWAL OF LICENSE NUMBER 3 ADDRESS (ES) WHERE UCENSED MATERIAL WILL BE USED OR POSSESSED 4 NAME OF PERSON TO BE CONTACTED ASOUT THIS APPUCATlON TELEPHONE NUMBER Susulf ITEMS 5 THROUGH 11 ON 6112 X 11" PAPER THE TYPE AND SCOPE OF INFORMATION TO BE PROVIDED IS DESCRIBED N THE UCENSE APPLICATION GUIDE 6 RADCACTIVE MATERAL e Dement and mens number. b chemical endeor phren:el term, and c meenmum amount S PURPOSE (S) FOR WHICH UCENSED MATERAL WILL BE USED.
smach we be poseenmed at any one tme T NDIVIDUALtS) RESPONSIBLE FOR RADIATION SAFETY PROGRAM AND THEIR 8 TRAINING FOR INDIVIOUALS WORMNG W OR FREQUENTING RESTRICTED AREAS TRANNG EXPERIENCEL S FAcafnES AND EQUIPeAENT 10 RADIATION SAFETY PROGRAM
- 12. UCENSEE FEES (See 10 CFR f 70 and Secton f 70 3f)
- 11. WASTE MANAGEMENT.
g AAAOUNT FEE CATEGORY IENCLOSED 5 13 CERTIFICATION (heust to compmand Dy appemen0 THE APPUCANT UNDERSTANDS THAT ALL STATEMENTS AND REPRESENi4TIONS MADE N THIS APPUCATION ARE BNOING UPONTW APPUCANT THE APPUCANT AND ANY OFFICIAL EXECUTING THIS CERTIFICATION ON BEHALF OF THE APPUCANT, NAMED N f7EM 2, CERTFY THAT THIS APPUCATION IS PREPARED IN CONFORMITY WUM TULE 10. CODE OF FEDERAL REGULATIONS, PARTS 30,32,33,34. 35,38,30 AND 40, AND THAT ALL INFORMATION CONTANED HEREN IS TRUE AND CORRECT TO THE BEST OF THEIR MNOWLEDGE AND BEUEF.
W ARNNG 16 U S C SECTION 1001 ACT OFJUNE 25.1946 82 ST AT Tee MAMES ff A CReANAL OFFENSE TO MAME A WILLFULLY FALSE STATEMENT OR REPRESENTATION ANY DEPARTMENT OR AGENCY OF THE UNITED STATES AS TO ANY MATTER WTTHIN ITS JURISOICTION CERTIFYING OFFICER - TYPEDMtNTED NAME AND TTTLE SIGNATURE DATE FOR NRC USE ONLY TYPE OF FEE FEE LOG FEE CATEGORY AMOUNT RECETVED CHECM NUMBER COMMENTS S
APPROVED BY DATE PRINTED ON RECYCLED PAPER NRC FORM 313 F48)
t i
i 1
i t
i i
i l
Appendix B 1
i i
l Suggested Format l
for l
Providing information 1
i Requested in items 5 through 11 l
of NRC Form 313 1
l
}
4 i
i j
l
4 APPENDIX B i
ITEMS 5 & 6: MATERIALS TO BE POSSESSED AND PROPOSED USES YES NO RADIOISOTOPE MANUFACTURER /
QUANTITY MOST SPECIFY MODEL NO.
COMMON USE OTHER USES NOT LISTED l
ON SSD CERTIFICATE Cesium-137 Scaled sources in Not to exceed Measure
[] Not applicable compatible gauges as maximum activity Physical specified in Scaled per source as Properties of
[] Uses are:
Source & Device specified in Scaled Materials Registration Sheet Source & Device Registration Sheet Amenctum-241 Scaled sources in Not to exceed Measure
[] Not applicable compatible gauges as maximum activity Physical 1
specified in Scaled per source as Properties of
[] Uses are:
Source & Device specified in Scaled Materials Registration Sheet Source & Device Registration Sheet Californium-252 Scaled sources in Not to exceed Measure
[] Not applicable compatible gauges as maximum activity Physical specified in Scaled per source as Properties of
[] Uses are:
Source & Device specified in Scaled Materials Registration Sheet Source & Device Registration Sheet Other (specify)
FINANCIAL ASSURANCE REQUIRED AND El'IDENCE OF FINANCIAL ASSURANCE PROl'lDED Page B-1 NUREG - 1556, Vol, I (draft)
APPENDIX B ITEMS 7 THROUGH 11: TRAINING AND EXPERIENCE, FACILITIES AND EQUIPMENT, RADIATION SAFETY PROGRAM, AND WASTE DISPOSAL t
ITEM NO. AND TITLE SUGGESTED RESPONSE YES ALTERNATIVE PROCEDURES ATTACIIED
- 7. INDIVIDUA14S)
Pnor to obtaming licensed matenals, the proposed RSO will
[j
[]
RESPONSIBLE FOR have successfully completed one of the training courses RADIATION SAFETY described in Criteria in the section entitled " Individual (s)
PROGRAM AND Responsible for Radiation Safety Program and Their Training THEIR TRAINING and Experience Radiation Safety Officer"in draft NUREG-AND EXPERIENCE -
1556, Vol.1, dated September 1996.
RADIATION SAFETY AND OFFICER Prior to being named as the RSO, future RSO2 will have successfully completed one of the training courses described in Name:
Criteria in the section entitled " Individual (s) Responsible for Radiation Safety Program and Their Training and Experience -
Radiation Safety Officer" in draft NUREG-1556, Vol.1, dated September 1996.
- 8. TRAINING FOR Pnor to usmg heensed materials, authonred users will have
[]
[]
INDIVIDUALS successfully completed one of the training courses described in WORKING IN OR Criteria in the section entitled " Training for Individual >
FREQUENTING Working in or Frequenting Restricted Areas" in draft NUREG-RESTRICTED AREAS 1556, Vol. I, dated September 1996.
- 9. FACILITIES AND No information needs to be submitted m response to this item; Separate item 9 Response EQUIPMENT key issues are addressed under " Radiation Safety Program -
Need Not Be Submitted Public Dose" and " Radiation Safety Prograrn - Operating and With Application Emergency Procedures".
- 10. RADIATION SAFETY The applicant is not required to submit its audit program to the Need Not Be Submitted PROGRAM - AUDIT
.VRC for review during the licensing phase.
With Application PROGRAM
- 10. RADIATION SAFETY The apphcant is nel required to submit a response to de Need Not Be Submitted PROGRAM -
tennination of activities section during the initial application.
With Application TERMINATION OF llowever, when the license expires or at the time the licensee ACTIVITIES ceases operations..VRC Form 314 must be submitted.
- 10. RADIATION SA FETY We will either possess and use, or have access to and use, a
[]
[]
PROGRAM -
radiation survey meter that meets the Criteria in the section SURVEY entitled " Radiation Safety Program - Instruments" in draft INSTRUMENTS NUREG-1556, Vol.1, dated September 1996, in the event of an incident.
- 10. RADIATION SAFETY Physical inventones will be conducted at intervals not to exceed []
[]
PROGRAM -
6 mor.ths, to account for all scaled sources and devices received MATERIAL and possessed under the license.
REECEIPT AND ACCOUNTABILITY
- 10. RADIATION SAFETY Either we will mamtam, for inspection by ARC, documentation
[]
[]
PROGRAM -
demonstrating that unmonitored individuals are not likely to OCCUPATIONAL receive a radiation dose in excess of 10% of the allowable limits DOSIMETRY in 10 CFR Part 20 or we will provide dosimetry processed and evaluated by a ATLAP-approved processor that is exchanged at a frequency recommended by the processor.
- 10. RADIATRON SAFETY l he apphcant is nQ1 required to submit its response to the pubhc Need Not Be Submitted PROGRAM - PUBLIC dose section during the licensing phase. This matter will be With Application DOSE examined during an inspection.
i NUREG - 1556, Vol.1 (draft)
Page B-2
APPENDIX B ITEM NO. AND TITLE SUGGESTED RESPONSE YES ALTERNAT!YE PROCEDURES ATTACHED
- 10. RADIATION SAFETY We will develop, implement,.nd maintain the operating &
[J
[]
PROGRAM -
emergency procedures in.4ppemlix II of draft NUREG-1556, OPERATING &
Vol.1 dated September 1996.
EMERGENCY OR PROCEDURES Operating & emergency procedures will be developed.
[]
implemented, and maintained and will meet the criteria in the section entitled " Radiation Safety Program Operating and Emergency Procedures" in draft NUREG 1556, Vol.1, dated September 1996.
- 10. RADIATRON SAFETY Leak tests will be performed at intervals approved by the NRC
[]
[]
PROGRAM - LEAK or an Agreement State and specified in the Scaled Source and The information in TEST Device Registration Certificate. Leak tests will be perfonned
.4ppendix / in by an organization authorized by NRCor an Agreement State to support of a provide leak testing se vices for other licensees or using a leak request to perform test kit supplied by an organization authorized by NRC or an leak testing and Agreement State to provide leak test kits to other licensees and sample analysis is 1
in accordance with the kit supplier's instnictions.
attached.
- 10. RADIATION SAFETY ROUTINE CLEANING & LUBRICATION PROGRAM -
MAINTENANCE We will develop, implement, and maintaia procedures for
[]
[]
routine cleaning and lubrication of the source rod and shutter mechanism that contain the elements listed under Discussion in the section on " Radiation Safety Program - Maintenance" in draft NUREG-1556, Vol.1, dated September 1996.
EXTENDED MAINTENANCE j
We will send the gauge to the manufacturer or other person
[]
[]
authorized by ARC or an Agreement State to perform more extensive maintenance or repair operations that require the The information removal of the source or source rod from the gauge.
listed in Appendiv Gin support of a request to perform estended maintenance in-house is attached.
- 10. RADIATION SAFETY The applicent is not required to submit its response to Need Not Be Submitted PROGRAM -
transportation during the licensing process. Ilowever, this issue With Application TRANSPORTATION will be reviewed during inspection.
- 11. WASTE The applicant does not need to provide a response to waste Need Not Be Submitted MANAGEMENT-Management during the licensing process. However, the With Application GAUGE DISPOSAL licensee should develop, implement, and maintain gauge
& TRANSFER transfer and disposal procedures in its radiation protection program.
Page B-3 NUREG - 1556, Vol.1 (draft)
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Appendix C j
Information Needed for Change of l
Ownership or Control Application i
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1 APPENDIX C Licensees must provide full information and obtain NRC's prior written consent before transferring ownership or control oflicensed material. Provide the following information conceming changes of ownership or control by the applicant (transferor and/or transferee, as appropriate). If any items are not applicable, so state.
- 1. The new name of the licensed organization. If there is no change, the licensee should so state.
- 2. The new licensee contact and telephone number (s) to facilitate communications.
- 3. Any changes in personnel having control over licensed activities (e.g., officers of a corporation) and any changes in personnel named in the license such as radiation safety officer, authorized users, or any other persons identified in previous license applications as responsible for radiation safety or use oflicensed material. The licensee should include information conceming the qualifications, training, and responsibilities of new individuals.
- 4. An indication of whether the transferor will remain in non-licensed business without the license.
- 5. A complete, clear description of the transaction, including any transfer of stocks or assets, mergers,'etc., so that legal counsel is able, when necessary, to differentiate between name i
changes and changes ofownership.
- 6. A complete description of any planned changes in organization, location, facility, equipment, or procedures (i.e., changes in operating or emergency procedures).
- 7. A detailed description of any changes in the use, possession, location, or storage of the licensed materials.
- 8. Any changes in organization, location, facilities, equipment, procedures, or personnel that would require a license amendment even without the change of ownership.
- 9. An indication of whether all surveillance items and records (e.g., calibrations, leak tests, surveys, inventories, and accountability requirements) will be current at the time of transfer.
Provide a description of the status of all surveillance requirements and records.
- 10. Confirmation that all records conceming the safe and effective decommissioning of the facility, pursuant to 10 CFR 30.35(g),40.36(f), 70.25(g), and 72.30(d); public dose; and waste disposal by release to sewers, incineration, radioactive material spills, and on-site burials, have been transferred to the new licensee, iflicensed activities will continue at the same location, or to the NRC for license terminations.
- 11. A description of the status of the facility. Specifically, the presence or absence of contamination should be documented. If contamination is present, will decontamination occur before transfer? If not, does the successor company agree to assume full liability for the decontamination of the facility or site?
Page C-1 NUREG - 1556, Vol. I (draft)
APPENDIX C
- 12. A description of any decontamination plans, including financial assurance arrangements of the transferee, as specified in 10 CFR 30.35,40.36, and 70.25. Include information about how the transferee and transferor propose to divide the transferor's assets, and responsibility for any cleanup needed at the time of transfer.
- 13. Confirmation that the transferee agrees to cbide by all commitments and representations previously made to NRC by the transferor. These include, but are not limited to: maintaining decommissioning records required by 10 CFR 30.35(g); implementing decontamination activities and decommissioning of the site; and completing corrective actions for open inspection items and enforcement actions.
With regard to contamination of facilities and equipment, the transferee should confum, in writing, that it accepts full liability for the site, and should provide evidence of adequate resources to fund decommissioning; or the transferor should provide a commitment to decontaminate the facility before change of control or ownership.
With regard to open inspection items, etc., the transferee should confirm, in writing, that it accepts full responsibility for open inspection items and/or any resulting enforcement actions; or the transferee proposes attemative measures for meeting the requirements; or the transferor provides a commitment to close out all such actions with NRC before license transfer.
- 14. Documentation that the transferor and transferee agree to the change in ownership or control of the licensed material and activity, and the conditions of transfer; and the transferee is made aware of all open inspection items and its responsibility for possible resulting enforcement actions.
- 15. A commitment by the transferee to abide by all constraints, conditions, requirements, representations, and commitments identified in the existing license. If not, the transferee must provide a description ofits program, to ensure compliance with the license and regulations.
NUREG - 1556, Vol.1 (draft)
Page C-2
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Appendix D i
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APPLWDIX D Criteria for Acceptable Training Courses for Portable Gauge Users 25-question written test-80 percent grade (open or closed book) e I hour of radiation physics and safety: atomic structure, radioactivity and types of radiation, i
e methods (radiation detection instruments) and units of radiation measurement, isotopes and half-life, biological effects, and methods to reduce dose 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> ofregulatory requirements: licensing, dose limits, ALARA, control and surveillance, e
inventory, operating and emergency procedures (dry run of emergency procedures),
maintenance (dry run of routine maintenance), audits, recordkeeping, reciprocity, disposal, incidents, transportation, employee protection, and deliberate misconduct I hour of gauge theory, operation, routine maintenance, and field traimng e
AND Instructor qualifications:
e Bachelor's degree in a physical or life science or engineering with 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> hands-on experience with portable gauges and successful completion of 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> radiation safety
- course, OR
- an individual with the following training:
+ Successful completion of portable gauge user course
+ Successful completion of 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> radiation safety course; AND
+ 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of hands-on experience with portable gauges.
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i Appenoix E i
Typical Duties and Responsibilities i
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APPENDIX E The RSO's duties and responsibilities are illustrated in Figure 8.1 and typically include ensuring the following:
Stopping licensed activities that the RSO considers unsafe Possession of sources and gauges is consistent with the limitations in the license and the sealed source and device sheet (s)
Individuals using gauges are properly trained e
When necessary, personnel monitoring devices are used and exchanged at the proper intervals; records of the results of such monitoring are maintained Gauges are properly secured e
Proper :.uthorities are notified in case of accident, damage to gauges, fire, or theft e
i Audits are performed at least annually and documented, and corrective actions taken e
Licensed material is transported in accordance with all applicable DOT requirements e
Licensed material is disposed of properly e
I Appropriate records are maintained e
License amendment requests are made when necessary I
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Appendix F i
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APPENDIX F NOTE: All areas indicated in audit notes may not be applicable to every license and may not need to be addressed during each audit.
Licensee's name:
License No.
Auditor:
Date of Audit Telephone No.
(Signature)
- 1. AUDIT HISTORY
- a. Last audit of this location conducted on (date)
- b. Were previous audits conducted yearly? /10 CFR 20.1101/
- c. Were records of previous audits maintained? /10 CFR 20.2102/
- d. Were any deficiencies identified during last two audits or two years, whichever is longer?
- e. Were corrective actions taken? (Look for repeated deficiencies).
- 2. ORGANIZATION AND SCOPE OF PROGRAM
- a. If the mailing address or places of use changed, was the license amended?
- b. If ownership changed or bankruptcy filed, was NRC prior consent obtained or was NRC notified?
j c.
If the RSO was changed, does new RSO meet NRC training requirements?
- d. If the designated contact person for NRC changed, was NRC notified?
e.
Does the license authorize all of the types and quantities of gauges possessed?
/10 CFR 32.210/
- f. Are the actual uses of gauges consistent with the authorized uses listed on the license?
- g. Is RSO fulfilling his/her duties?
- 3. TRAINING AND INSTRUCTIONS TO WORKERS a.
Were all workers who are likely to exceed 100 mrem /yr instructed per /10 CFR 19.12/?
Refresher training provided, as needed //0 CFR 19.12/?
- c. Are training records maintained for each gauge operator?
- d. Did interviews with operators reveal that they know the emergency procedures?
- e. Did this audit include observations of operators using the gauge in a field situation?
- f. Did the operator demonstrate sefe handling and security during transportation, use and storage?
- g. HAZMAT training provided as required? /49 CFR 172.700,49 CFR 172.701, CFR 172.702,49 CFR 172.703,49 CFR I72.704/
a Page F-1 NUREG - 1556, Vol.1 (draft)
v APPENDIX F r
- 4. RADIATION SURVEY INSTRUMENTS
- a. If the licensee possesses its own survey meter, does it meet the NRC's criteria?
- b. If the licensee does not possess a survey meter, are specific plans made to have one available?
- c. Is the survey meter calibrated as required //0 CFR 20./501/?
- d. Are calibration records maintained /10 CFR 20.2103(a)/?
- 5. GAUGE INVENTORY
- a. Is a record kept showing the receipt of each gauge? /10 CFR 30.51(a)(l)/
- b. Are all gauges received physically inventoried every six months?
- c. Are records ofinventory results with appropriate information maintained?
- 6. PERSONNEL RADIATION PROTECTION i
Are AL4RA considerations incorporated into the radiation protection program?
a.
l10 CFR 20.flul(b)]
- b. Is documentation kept showing that unmonitored users receive $10% oflimit?
l10 CFR 20.lS02(a)l
- c. Did unmonitored users' activities change during the year which may put them over 10%
oflimit?
- d. If yes to c. above, was a new evaluation performed?
- e. Is extemal dosimetry required (user receiving >10% oflimit)?
And is dosimetry provided to users?
- 1) Is the dosimetry supplier Ni'L4P approved? /10 CFR 20.1501(c)/
- 2) Are the dosimeters exchanged monthly for film badges and at industry recommended frequency for TLDs?
- 3) Are dosimetry reports reviewed by the RSO when they are received?
- 4) Are the records NRC Forms or equivalent? l10 CFR 20.2104(d),10 CFR 20.2106(c)J NRC-4 " Cumulative Occupational Exposure History" completed?
e NRC-5 " Occupational Exposure Record for a Monitoring Period" completed?
- 5) If a worker declared her pregnancy, did licensee comply with 10 CFR 20.120S?
Were records kept of embryo / fetus dose per 10 CFR 20.2106(c)?
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- f. Are records of exposures, surveys, monitoring, and evaluations maintained fl0 CFR 20.2102.10 CFR 20. 2l03,10 CFR 20. 2106/
NUREG - 1556. Vol.1 (draft)
Page F-2
APPENDIX F
- 7. PUBLIC DOSE
- a. Are gauges stored in a manner to keep doses below 100 mrem in a year?
l10 CFR 20.1301(a)(1)]
- b. Has a survey or evaluation been performed per 10 CFR 20.1501(a)? Have there been any additions or changes to the storage, security, or use of surrounding areas that would necessitate a new survey or evaluation?
- c. Do unrestricted area radiation levels exceed 2 mrem in any one hour?
l10 CFR 20.1301(c)(2)]
- d. Are gauges being stored in a manner that would prevent unauthorized use or removal?
l10 CFR 20.1801]
- e. Records maintained? (10 CFR 20.2103,10 CFR 20.2107]
- 8. OPERATING AND EMERGENCY PROCEDURES
- a. Have operating and emergency procedures been developed? Do they contain the
- b. required elements?
- c. Does each operator have a current copy (telephone numbers) of the operating and
- d. emergencyprocedures?
- e. Did any emergencies occur and were they handled properly by operator?
- 9. LEAK TESTS
- a. Was each sealed source leak tested every 6 months or at other prescribed intervals?
b.' Was the leak test performed as described in correspondence with NRCand in accordance with license?
- c. Are records of results retained with the appropriate information included?
- d. Were any sources found leaking and if yes, was NRCnotified?
- 10. MAINTENANCE OF GAUGES
- a. Have procedures been established for routine cleaning and lubrication of source rod?
- b. Do the procedures contain the required elements?
Does the source rod remain attached to the gauge during cleaning?
c.
- d. Is extended maintenance performed where source rod is detached from the gauge?
- 11. TRANSPORTATION -
- a. DOT-7A or other authorized packages used?l49 CFR 173.415,49 CFR 416(b)/
- b. Package performance test records on file?
- c. Special form sources documentation?l49 CFR 173.476(a)l
- d. Package has 2 labels (ex. Yellow-II) with TI, Nuclide, Activity, and Hazard Class?
l49 CFR 172.403,49 CFR 173.441/
Package properly marked?l49 CFR I72.301,49 CFR I72.306,49 CFR I72.310.
e.
CFR I72.312,49 CFR 172.324]
Page F-3 NUREG - 1556, Vol.1 (draft)
APPENDIX F l
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- f. Package closed and sealed during transport? /49 CFR 173.475(/)/
l
- g. Shipping papers prepared and used? /49 CFR 172.200(a)/
- h. Shipping papers contain proper entries? (Shipping name, Hazard Class, UN Number, Quantity, Package Type, Nuclide, RQ, Radioactive Material, Physical and Chemical Form, Activity, category oflabel, TI, Shipper's Name, Certification and Signature, Emergency Response Phone Number, Cargo Aircraft Only (if applicable)}
/49 CFR 172.200,49 CFR 172.201,49 CFR 172.202,49 CFR 172.203, 49 CFR I72.204/
- i. Shipping papers within drivers reach and readily accessible during transport?
/49 CFR 177.718(e)/
- j. Packages blocked and braced to prevent movement? /49 CFR 177.842(d)/
- k. Placarded on vehicle, if needed? /49 CFR 172.504/
1.
Proper overpacks, if used? /49 CFR 173.25/
- m. Any incidents reported to DOT!/49 CFR 171.15,16/
- 12. AUDITOR'S INDEPENDENT SURVEY MEASUREMENTS (IF MADE)
- a. Describe the type, location, and results of measurements. Do any radiation level exceed regulatory limits?
- 13. NOTIFICATION AND REPORTS a.
Was any radioactive material lost or stolen? Were reports made? /10 CFR 20.2201, 10 CFR 30.50/
- b. Did any reportable incidents occur? Were reports made? /10 CFR 20.2202, 10 CFR 30.50/
- c. Did any overexposures and high radiation levels occur? Reported? /10 CFR 20.2203, 10 CFR 30.50}
- d. Is the licensee aware of telephone number for NRC Emergency Operations Center?
[(301) 816-5100]
- 14. POSTING AND LABELING
- a. NRC-3 " Notice to Workers" posted? /10 CFR 19.11/
- b. NRC regs., license documents posted or a notice posted? /10 CFR 19.11,10 CFR 21.6/
- c. Other posting and labeling? /10 CFR 20.1902,10 CFR 20.1904/
- 15. RECORD KEEPING FOR DECOMMISSIONING (if needed)
- a. Records kept ofinformation important to decommissioning? /10 CFR 30.35(g)/
- b. Records include all information outlined in /10 CFR 30.35(g)/?
NUREG - 1556. Vol.1 (draft)
Page F-4
APPENDIX F
- 16. BULLETINS AND INFORMATION NOTICES
- a. NRC Bulletins, NRC Information Notices, N3/SS Newsletters, received?
- b. Appropriate training and action taken in response?
- 17. SPECIAL LICENSE CONDITIONS OR ISSUES Did auditor review special license conditions or other issues (e.g., extended a.
maintenance)?
- 18. DEFICIENCIES IDENTIFIED IN AUDIT; CORRECTIVE ACTIONS Summarize problems / deficiencies identified during audit, a.
- b. If problems / deficiencies identified in this audit, describe corrective actions planned or taken. Are corrective actions planned or taken at ALL licensed locations (notjust location audited)?
- c. Provide any other recommendations for improvement.
- 19. EVALUATION OF OTHER FACTORS i
Senior licensee management is appropriately involved with the radiation protection l
a.
program and/or Radiation Safety Officer (RSO) oversight?
- b. RSO has sufficient time to perform his/her radiation safety duties?
- c. Licensee has sufficient staff to support the radiation protection program?
Page F 5 NUREG - 1556, Vol.1 (draft)
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l Information Needed 1
to W
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Perform Extended Maintenance J
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APPENDIX G Extended maintenance or servicing (beyond routine cleaning and lubrication) involves detaching L
the source or source rod from the device and is illustrated in Figure 8.7.
A typical moisture-density gauge contains 0.37 gigabecquerels (10 millicuries) of cesium-137 i-and 1.5 gigabecquerels (40 millicuries) of americium-241. In about 9 minutes, an unshielded cesium-137 source of this activity can deliver 0.05 sievert (5 rems) to a worker's hands or fingers (i.e., atremities), assuming the extremities are I centimeter from the source. Some gauges i
contain sources of even higher activities with correspondingly higher dose rates. The threshold for extremity monitoring is 0.05 sievert (5 rems) per year.
~
Thus, applicants wishing to perform extended maintenance must use personnel with special training, follow special procedures, use a radiation survey meter, use special shields, use special personnel monitoring devices, and take appropriate radiation safety precautions. Accordingly, j
provide the following information:
i' Describe the types of work, maintenance, cleaning, etc., to be performed that necessitate i
e i
detaching the source or source rod from the device. The principal reason for obtaining this i
information is to assist in the evaluation of the qualifications ofindividuals who will conduct j
the work and the radiation safety procedures they will follow.
j Identify who will perform extended maintenance, their training and experience, and why they e
are competent to perform extended maintenance.
s j
Submit procedures for safe handling of the radioactive source while the source or source rod l
e is detached from the gauge. These procedures should ensure the following:
- doses to personnel and members of the public are within regulatory limits and AL4RA; the source or source rod is secured against unauthorized removal access or under constant surveillance; E
- appropriate labels and signs are used; and
. manufacturer's instructions and recommendations are followed.
Confirm that individuals performing extended maintenance on gauges will always wear both whole body and extremity monitoring devices or that an evaluation will be available to demonstrate that these individuals are not likely to receive more than 10 percent of the applicable dose limits. The dose limits are illustrated in Figure 8.3.
Verify possession of at least one survey instrument meeting the following criteria:
Be capable of detecting the type of radiation emitted by the sealed source; Be capable of measuring from 1 to 100 mrem /hr; Be calibrated at least annually with radionuclide point sources emitting radiation of the type and energy of the sealed sources in the gauge; Page G-1 NUREG - 1556, Vol.1 (draft)
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i Be calibrated at least 2 points located at approximately 1/3 and 2/3 of each scale; i
readings within +20 percent are acceptable; j
l Be calibrated by a person specifically licensed by the NRC or an Agreement State l
to calibrate radiation detection instruments; and Be checked for functionality prior to use (e.g., with the gauge or a check source).
I Note: Records ofinstrument calibration must be maintained for 3 years after the record is made (10 CFR 20.2103).
1 Describe steps to be taken to ensure that radiation levels in areas where extended l
l maintenance will take place do not exceed 10 CFR 20.1301 limits. For example, applicants i
can do the following:
- commit to performing surveys with a survey instrument (as described above);
- specify where and when surveys will be conducted during extended maintenance; and
- commit to maintaining, for 3 years from the date of the survey, records of the survey 4.g., who performed the survey, date of the survey, instrument used, measured radiation i
levels correlated to location of those measurements), as required by 10 CFR 20.2/03.
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1 Appendix H 1
1 Operating and Emergency Procedures 4
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l APPENDIX H l
Operating Procedures l
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locked with a padlock in the shielded position, then lock the transport case.
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Sign out the gauge in a log book (that remains at the storage location) including the date(s) of use, name(s) of the authorized users who will be responsible for the gauge, and the temporary jobsite(s) where the gauge will be used.
Follow all applicable Department of Transportation (DOT) requirements when transporting the gauge.
Always maintain constant surveillance and immediate control of the gauge when it is not in storage. Atjob sites, do not walk away from the gauge when it is left on the ground. Take actions necessary to protect the gauge and yourself from danger of moving heavy equipment.
After each measurement is completed, immediately retum the source to the shielded position.
Prior to transporting the gauge in the vehicle, lock the source rod into the shielded position, place it in the transport case and lock the case, block and brace the case, and lock the case in or to the vehicle.
When the gauge is not in use at a temporary jobsite, place the gauge in a secured storage location (e.g., locked in the trunk of a car or locked in a storage shed).
Retum the gauge to its proper locked storage location at the end of the work shift.
Log the gauge into the daily use log when it is retumed to storage.
Do not touch the source rod with your fingers, hands, or any part of your body and always make sure the source rod is in the shielded position after each measurement is made.
Always wear your assigned thermoluminescent dosimeter (TLD) or film badge when using the gauge if one has been assigned.
Never wear another person's TLD or film badge.
e Never store your TLD or film badge near the gauge, if you have been assigned one.
Always keep unauthorized persons away from the area where the gauge is to be used.
Never look under the gauge when the source rod is being lowered into the ground.
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APPENDIX H Reassess compliance with public dose limits and ensure proper security of gauges after making changes affecting the gauge storage area (e.g., changing the location of gauges within the storage area, removing shielding, adding gauges, changing the occupancy of adjacent areas, moving the storage area to a new location).
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When gauges are used for measurements more than 3 feet beneath the surface, use piping, tubing, or other casing material to line the hole from the lowest depth to 12 inches above the surface.
Emergency Procedures:
If the source fails to return to the shielded position (e.g., as a result of being damaged, source becomes stuck below the surface) or if any other emergency or unusual situation arises (e.g., the gauge is struck by a moving vehicle, is dropped, is in a vehicle involved in an accident):
Immediately secure the area and keep people at least 15 feet away from the gauge until the situation is assessed and radiation levels are known. However, perform first aid for any injured individuals and remove them from the area only when medically safe to do so.
If any heavy equipment is involved, detain the equipment until it is determined there is no contamination present.
i Notify the persons in the order listed below of the situation:
NAME*
WORK PHONE NUMBER
- HOME PHONE NUMBER
- Fill in with (and update, as needed) the names and telephone numbers of the Radiation Safety Officer (RSO) or other knowledgeable licensee staff to be contacted in case of emergency.
Follow the directions provided by the person contacted above.
RSO AND LICENSEE MANAGEMENT:
Arrange for a survey to be conducted as soon as possible by a knowledgeable person using l
appropriate radiation detection instrumentation. This person could be a licensee employee l
using a survey meter located at the jobsite or a consultant. To accurately assess the radiation danger, it is essential that the person performing the survey be competent in the use of the survey meter.
NUREG - 1556, Vol.1 (draft)
Page H-2
APPENDIX H If sources will be used more than 3 feet below the surface, contact persons listed on emergency procedures need to know the steps to be followed to retrieve a stuck source and to l
convey those steps to the staff on site.
i Make necessary notifications to local authorities as well as the NRC as required. (Even if not e
required to do so, you may report ANY incident to NRC by calling NRC's Emergency Operations Center at (301) 816-5100, which is staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day and accepts collect calls.) NRC notification is required when gauges containing licensed material are lost or
'l stolen, when gauges are damaged or involved in incidents that result in doses in excess of l
10 CFR 20.2203 limits, and when it becomes apparent that attempts to recover a sources l
l stuck below the surface will be unsuccessful.
j l
Reports to the NRC must be made within the reporting timeframes specified by the regulations.
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Reporting requirements are found in 10 CFR 20.2201-2203 and 10 CFR 30.5#,
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l Guidance for Demonstrating that Unmonitored Individuals are not Likely to Exceed j
10 Percent of the Allowable Limits 1
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APPENDIX !
Dosimetry is required for individuals likely to receive, in 1 year from sources extemal to the body, a dose in excess of 10% of the applicable regulatory limits in 10 CFR 20.1201. To demonstrate that dosimetry is NOT required, a licensee needs to have available, for inspection, an evaluation to demonstrate that its workers are not likely to exceed 10% of the applicable annual limits.
The most common way that individuals MIGHT exceed 10% of the applicable limits is by performing frequent routine cleaning and lubrication of gauges. Thus, a licensee would need to evaluate the doses its workers might receive in performing these tasks to assess whether dosimetry is required.
EXAMPLE One gauge manufacturer has estimated the doses to the extremities and whole body of a person performing routine cleaning and lubrication of one ofits series of gauges. The manufacturer based its estimate on observations ofindividuals perfomiing the recommended procedure in accordance with good radiation safety practices. The manufacturer had the following types of information:
Time needed to perform the entire procedure (e.g.,10 min)
Dose rate associated with the shielded source (e.g.,0.2 mSv/hr [20 mrem /hr] at contact e
with the shield)
Time the hands were exposed to the unshielded source (e.g.,3 min) e Dose rate associated with the unshielded source at the typical distance of the hands from the source (e.g.,9 mSv/hr [900 mrem /hr) or 0.15 mSv/hr [15 mrem / min])
From this information, the manufacturer estimated that the individual performing each routine cleaning and lubrication could receive--
Less than 0.04 mSv [4 mrem] TEDE (whole body) and 0.45 mSv [45 mrem] to the hands.
The applicable limit TEDE (whole body) is 50 mSv (5 rems) per year and 10% of that value is 5 mSv (500 millirems) per year. If one cleaning / lubrication delivers 0.04 mSv (4 mrem), then an 1
individual could perform 125 of these operations each year and remain within 10% of the applicable limit.
The applicable limit for the extremities is 500 mSv (50 rems) per year and 10% of that value is 50 mSv (5 rems or 5000 millirems) per year. If one cleaning / lubrication delivers 0.45 mSv (45 mrem), then an individual could perform i11 of these operations each year and remain within 10% of the applicable limit.
Based on the above specific situation, no dosimetry is required if an individual performs fewer than 111 procedures per year.
Page1-1 NUREG - 1556, Vol.1, (draft)
APPENDIX I GUIDANCE TO LICENSEES Licensees who wish to demonstrate that they are NOT required to provide dosimetry to their workers need to prepare a written evaluation similar to that shown in the example above. The dose rates, times, and distances used in the above example may NOT be appropriate to individual licensee situations. In their evaluations, licensees need to use information appropriate to the various types of gauges on which they will perform routine cleaning and lubrication; this information may be available from gauge manufacturers or the Sealed Source and Device Registration Sheet maintained by the NRC and Agreement States.
Table 1-1 may be helpful in documenting a licensee's evaluation.
Evaluations should be reviewed periodically and revised as needed. Licensees need to check assumptions used in their evaluations to ensure that they continue to be up-to-date and accurate.
For example, workers may become lax in following good radiation safety practices so that, in the example used above, the extremities may be closer to the unshielded source, so that they receive more than 0.15 mSv (15 mrem) per minute. Altematively, workers may perform the task more slowly than the estimated 10 minutes total and 3 minutes with the hands near the unshielded source. Another example involves the purchase of new gauges containing sources of different activities, different radionuclides, or different cleaning / lubrication procedures that necessitate i
l performing a new evaluation.
Table 1.1, Dosimetry Evaluation Dosimetry Evaluation for Model Portable Gauge l
A.
Time needed to perform the entire minutes /60 hour routine cleaning and lubrication procedure on the gauge B.
Dose rate on the gauge at contact with mre n/hr the shielded source in the shielded position C.
Time the hands were exposed to the minutes /60 hour unshielded source D.
Dose rate associated with the mrem /hr unshielded source at the typical distance from the hands to the unshielded source Formula: (
- hours in Row A) x (
mrem /hr in Row B) r-(
estimated mrem) x
(
- of clean and lubrications conducted each year) = (
mrem) *Whole Body Dose Formula: (
- hours in Row C) x (
mrem /hr in Row D) =
estimated mrem x
(
- of clean and lubrications conducted each year) = (
mrem) ** Extremity Dose
- Whole Body Dose less than 500 mrem requires no dosimetry
- Extremity Dose less than 5000 mrem requires no dosimetry NUREG - 1556, Vol.1 (draft)
Page I-2
l
]
I 4
3 I
i i
l i
l Appendix J h
I 1
i Requests to Perform Leak Testing i
and 4
l Sample Analysis i.
j i
l i
l.
t i
l i
e 4
a i
'l i
.i i
APFENDIX J Information to be provided supporting request Identify the individual who will make the analysis and provide his or her qualifications to e
make quantitative measurements of radioactivity.
Commit to performing leak testing at the frequency specified in the appropriate Sealed Source and Device Registration Certificate.
Specify how and where test samples will be taken on the gauge. Describe materials used and methods of handling samples to prevent or minimize exposure to personnel.
Specify the type ofinstrument(s) that will be used for measurement, the counting efficiency, and minimum levels of detection for each radionuclide to be measured.
i Note: An instrument capable of making quantitative measurements should be used; hand-held survey meters will not normally be considered adequate for measurements.
Specify the standard sources used to calibrate the instrument; for each, specify the radionuclide, quantity, accuracy, and traceability to primary radiation standards.
Note: Accuracy of standards should be within +5% of the stated value and traceable to a primary radiation standard such as those maintained by the National Institutes of Standards and Technology (NIST).
Include a sample calculation for conversion of the measurement data to becquerels (or l
microcuries).
Provide instructions on actions to take and persons to be notified if sources are found to be leaking.
Model Procedure for Performing Leak Testing and Analysis
~
For each source to be tested, list identifying information such as gauge serial number, radionuclide, activity.
If available, use a survey meter to monitor exposdre.
Prepare a separate wipe sample (e.g., cotton swab or filter paper) for each source.
- Number each wipe to correlate with identifying information for each source.
Wipe the most accessible area where contamination would accumulate if the sealed source were leaking.
Page J-l NUREG - 1556, Vol.1 (draft)
-.. ~. ~
Appendix J 1
Using the instrument identified to, and approved by, NRC, count and record background e
count rate.
Check the instrument's counting efficiency usmg standard source of the same radionuclide as j
e the source being tested or one with similar energy characteristics. Calculate efficiency.
l i
i Count each wipe sample; determine net count rate.
e For each sample, calculate and record estimated activity in becquerels (or microcuries).
e e ' Sign and date the list of sources, data and calculations.
l i
If the wipe test activity is 185 becquerels (0.005 microcurie) or greater, notify the RSO, so l
that the source can be withdrawn from use and disposed of properly. Also notify NRC.
1
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I 4
- NUREG - 1556, Vol.1 (draft)
Page J-2 l
i 4
i i
i i,
i 1
i 5
- i i
1 i
Appendix K 1
l Major DOT Regulations; l
Sample Bill of Lading 1
1,
)
i 1
4 i
l i
j q
i
(
A i
i
APPENDIX K The major areas in the DOT regulations that are most relevant for transportation of typical portable gauges that are shipped as Type A quantities are as follows:
Table of Hazardous Materials and Special Provisions 49 CFR 172.101, App. A, Table 2:
Hazardous materials table, list of hazardous substances and reportable quantities -
Shipping Papers 49 CFR 172.200-204: general entries, description, additional description requirements, shipper's certification l
e.
Package Matkings 49 CFR 172.300,49 CFR 172.301,49 CFR 172.304,49 CFR 172.310, 49 CFR 172.324: General marking requirements for non-bulk packagings, marking requirements, radioactive material, hazardous substances in non-bulk packaging Package Labeling 49 CFR I72.400,49 CFR 172.403,49 CFR 172.406,49 CFR 172.436,49 CFR 172.437,49 CFR 172.438: General labeling requirements, radioactive materials, j
placement oflabels, specifications for radioactive labels Placarding of Vehicles 49 CFR 172.500,49 CFR 172.504,49 CFR 172.516,49 CFR 172.556: General placarding requirements, visibility and display of placards, RADIOACTIVE placard j
Emergency Response Information, Subpart G,49 CFR 172.600,49 CFR 172.602,49 CFR 172.604: Applicability and general requirements, emergency response information, emergency response telephone number Training, Subpart H,49 CFR 172.702,49 CFR 172.704: Applicability and responsibility for e
training and testing, training requirements Radiation Protection Program for Shippers and Carriers, Subpart I,49 CFR 172.800, etc.
e Shippers - General Requirements for Shipments and Packaging 49 CFR 173.403,49 CFR 173.410,49 CFR 173.412,49 CFR 173.415,49 CFR 173.476: Definitions, general design requirements, additional design requirements for Type A packages, authorized Type A packages, approval of special form radioactive materials Carriage by Public Highway 49 CFR 177.817,49 CFR 177.#42: Shipping paper, Class 7 e
(radioactive) material Page K-1 NUREG - 1556, Vol.1 (draft)
STRAIGHT BILL OF LADING ORIGINAL-NOT NETOTIABLE Shipper No.
Camer No Page I of 1
Oate
,,c,,,
iscaci Dc,. Builders, Inc.**
'Ro" s**
Moisture Density Measurements, Inc.**
7,%*,,c,',g,',y'gv gs;g,. -coo e an w.. can.,n.. n s=='
5678 Jefferson Davis Highway **
su.c 1234 A Street, NW **
D.m.n Arlington, VA**
u cao. 22222**
oma Washington, DC 20000**
ve.a.
ama nume.
BA SCRW M N
CHA%ES No.d Urifts HM
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1 RQ Radioactive material, special form n.o.s.
7 UN2974 0.41GBq (11 mci) Cs-137 and 1.9 GBq (50 mci]
2.31 GBq Am-241 m
,,,r' 41 RADIOACTIVE - YELLOW II TI = 0.4 **
USDOT 7A TYPE A Emergency Response Telephone No.:
1-800-000 -0000 (24 hrs / day) **
- SUBSTITUTE APPROPRIATE INFORMATION FOR YOU1 GAUGE AND YOUR SHIPMENT.
FsEMIT PLACARDS TENDERED:YES NO cooto j
ADDRESS C O.D FEE.
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Sample Portable Gauge License a
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' yRC FORM 374 U.S. NUCLEAR REGULATORY COMMISSloN i
2 MATERIALS LICENSE L
{
Pursuant to the Atomic Energy Act of 1954. as amended. the Energy Reorgam/ation Act of 1974 (Public Law 43-438), and Title 10. Code of g
Federal Regulations. Chapter 1. Parts 30. 31. 32,33,34. 35,36,39. 40, and 70, and in reliance on statements and representations heretof by the licensee, a license is hereby inued authorizing the licensee to receise. acquire, powen. and transfer byproduct. source. and specia 1
g material designated below; to use such material for the purpose (s) and at the plac-6) desi nated below; to
{
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persons authorized to receive it in accorda.ce with the reFulations of the applicable PartW. This license shall be deemed to contain the cond E
C specified in Section 183 of the Atomic Energy Act of 1954. as amended, and is subject to all applicable rules. reFulations and ord C
Nuclear Regulatory Commission now or hereaf ter in effect and to any conditions specified below.
g,1 wm
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w Sj In accordance with application dated Ej i'
Licensee 5
September 1, 1996, i
E 3
1.
Moisture Density Measurements, Inc.
- 3. License Number I
08-00000-00 3
! l is issued to read as follows:
3 l
3l2.
1234 A Street, NW l
3 Washington, DC 20001
- 4. Expiration Date (Insert a date, last day of the month, 5 R,=
,,.m... n. u. -. a..)
g;.
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- 5. Docket or g
Reference No.
030-00000 I
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- 6. Byproduct. Source, and/or
- 7. Chemical and/or Physical
- 8. Maximum Amount that Licensee l
g!
Special Nuclear Material Form May Possess at Any One Time l
l g
Under This License i
1 9
g!
ll b
A.
Cesium-137 A.
Sealed sources A.
No single source to l l b
registered either with exceed the maximum bl NRC under 10 CFR 32.210 activityspecifiedinIp
)l or with an Agreement the certificate of b
c l6 State and incorporated registration issued 13l l$
in a compatible portable by NRC or an 3l
$i gauging device as Agreement State l
l 9
specified in Item 9 of i
this license i l l
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a B.
Sealed sources B.
No single source to i"'
registered either with exceed the maximum j
I NRC under 10 CFR 32.210 activity specified in i l
l or with an Agreement the certificate of j
State and incorporated registration issued j
in a compatible portable by NRC or an j
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gauging device as Agreement State 3
l l$
specified in Item 9 of
- dil this license t
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IF OTHER ISOTOPES ARE REQUESTED, USE THE AB0VE FORMAT FOR EACH AUTHORIZED ISOTOPE.
jsf NOTE:
i"1 I
9.
Authorized Use l4 E
l A. and B.
To be used, for measuring physical properties of materials, in portable s
gauging devices that have been registered either with NRC under 10 CFR 32.210 or with an i
Agreement State and have been distributed in accordance with an NRC or Agreement State
- E j
specific license authorizing distribution to persons specifically authorized by an NRC or yf Agreement State license to receive, possess, and use the devices.
i Page L-1 NUREG-1556, Vol.1 (draft) 3 i
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pw_C FORM 374A U.S. NUCLEAR REGULATORY COMMISSION PAGE 2
OF 4
PAGES !j NI Lrense Number 08-00000-00 g
MATERIALS LICENSE D<det or Reference Number kI g
SUPPLEMENTARY SHEET 030-00000 El g
El
.g g
El h
a E
CONDITIONS g
i E
E 10.
Licensed material may be used or stored at the licensee's facilities located at E
(insert addresses soecified by aoolican.11 and may be used at temporary jobsites of k
N the licensee anywhere in the United States where the U. S. Nuclear Regulatory El 3
Commission maintains jurisdiction for regulating the use of licensed material.
s 3
11.
A.
Licensed material shall only be used by, or under the supervision and in the k
E 3
physical presence of, individuals who have received the training described in E
3 (insert date of aoolication. letter. etc.).
5 The Radiation Safety Officer (RS0) for this license is (insert name of RS0). who E 3
B.
-3 must have successfully completed the training described in (insert date of El aoolication. letter. etc.) before assuming the duties of RSO.
y 12.
A.
Sealed sources shall be tested for leakage and/or contamination at intervals not E to exceed the intervals specified in the certificate of registration issued by El ly NRC under 10 CFR 32.210 or by an Agreement State.
Ej lg El lB B.
In the absence of a certificate from c transferor indicating that a leak test ly has been made within the intervals speciited in the certificate of registration g
lg issued by NRC under 10 CFR 32.210 or by an Agreement State prior to the Ej lg transfer, a sealed source or detector cell received from another person shall 4
not be put into use until tested.
4 y
E i j
C.
Sealed sources need not be tested if they are in storage and are not being used.
Ej a
However, when they are removed from storage for use or transferred to another n
i y
person, and have not been tested within the required leak test interval, they El y
shall be tested before use or transfer. No sealed source shall be stored for a E ll g,
1 period of more than 10 years without being tested for leakage and/or
(
contamination.
El 3
g E '
D.
The leak test shall be capable of detecting the presence of 0.005 microcurie of
'l a
l radioactive material on the test sample.
If the test reveals the presence of l
I l
0.005 microcurie or more of removable contamination, a report shall be filed with the U. S. Nuclear Regulatory Commission in accordance with 10 CFR 30.50
?
(b)(2), and the source shall be removed immediately from service and g
ll decontaminated, repaired, or disposed of in accordance with Commission g
gl regulations.
The report shall be filed within 5 days of the date the leak test s
l result is known with the U. S. Nuclear Regulatory Commission, Region (inser't j
aooropriate Reaion and address). The report shall specify the source involved, g
the test results, and corrective action taken, g
e l
E.
Tests for leakage and/or contamination shall be performed by persons s
specifically licensed by the Commission or an Agreement State to perform such y
y services.
In addition, the licensee is authorized to collect leak test samples y
E but not perform the analysis; analysis of leak test samples must be performed by I
persons specifically licensed by the Commission or an Agreement State to perform,
such services.
(This condition is used for licensees NOT authorized to perform l
i l
NUREG-1556, Vol.1 (draft)
Page L-2 6
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===========m=====_=============
8
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NRC FORM 374A U.S. NUCLEAR REGULATORY COMMISSION PAGE 3
oF 4
PAGES g
License Number gl 08-00000-00 g
g l
MATERIALS LICENSE pocket or Reference Number El 1
g SUPPLEMENTARY SHEET 030-00000 Ej g
E E
8 m'
i U
i CONDITIONS U
8 (Continued) 8 i
N 8
leak test analysis.)
OR N
N 8
B E.
Tests for leakage and/or contamination shall be performed by the licensee or I
E other persons specifically licensed by the Commission or an Agreement State to E
B perform such services.
In addition, the licensee is authorized to colle't leak N
N test samples for analysis by persons specifically licensed by the Commission o.-
B an Agreement State to perform such services.
(This condition is used for N
3 licensees authorized to collect AND analyze leak test samples.)
5 3
3 13.
Sealed sources or source rods containing licensed material shall not be opened or E
a 3
sources removed or detached from source rods or gauges by the licensee, except as E
3 specifically authorized.
8 3
3
- 14. The licensee shall conduct a physical inventory every 6 months, or as other interval 5 g
approved by NRC, to account for all sources and/or devices received and possessed a
E p
under the license.
a a
i 15.
Each portable gauge shall have a lock or outer locked container designed to prevent W unauthorized or accidental removal of the sealed source from its shielded position. W g
The gauge or its container must be locked when in transport, storage, or when not E
ly under the direct surveillance of an authorized user.
(
W l
16.
Except for maintaining labeling as required by 10 CFR Part 20 or 71, the licensee d
lll shall obtain authorization from NRC before making any changes in the sealed source, E device, or source-device combination that would alter the description or E
lI specifications as indicated in the respective Certificates of Registration issued W
l
'I either by the Commission pursuant to 10 CFR 32.210 or by an Agreement State.
g I
E W
i
- 17. Any cleaning, maintenance, or repair of the gauges that requires detaching the g
g!
source or source rod from the gauge shall be performed only by the manufacturer or g
y l
other persons specifically licensed by the Commission or an Agreement State to g
gi perform such services.
[This condition is used if the licensee is not authorized to g
l g
l!
l perform extended maintenance.)
g g
OR g
ly The licensee may detach the source or source rod from gauges for the purpose.of g!
ig cleaning, maintenance, or repair of the gauge (s) in accordance with procedures g
y outlined in (fill in dates of aooropriate aoolication. letter).
[This condition is g
y used if the licensee is authorized to perform extended maintenance.)
g; y
hl l
- 18. The licensee is authorized to transport licensed material only in accordance with the provisions of 10 CFR Part 71, " Packaging and Transportation of Radioactive g[
g y
Material. "
y nl' p
The licensee may not possess and use materials authorized in Items 6, 7, and 8, g[
l 19.
y g
i until:
r g
A.
The licensee has constructed the facilities and obtained the equipment described hl in the application and supporting documentation; and gj g
h
= - - - - - - -......................U R E.G-15 5 6.m.V o.l. 1.(g)
Page L-3 N
WWWWWWWEWWWWWWWWWWWWWWWWWWWWWW******######
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4 OF 4
PAGES NRC FORM 374 A U.S. NUCLEAR REGULATORY COMMISSION PAGE l(!
N License Number
-kl 08-00000-00 E
j g
MATERIALS LICENSE Lkdct or Reference Number g
SUPPLEMENTARY SHEET 030-00000 El N
h CONDITIONS P
(Continued) gl N-B.
The licensee has notified the U. S. Nuclear Regulatory Commission, Region El B
(insert Reaion number and address), that the activities authorized by the Il E
)B license will be initiated.
E E
- N 20.
In accordance with the requirements set forth in 10 CFR 30.36(d), the licensee shall
- p notify the U. S. Nuclear Regulatory Comission, Region (insert Reoion number and E
- p address), in writing, of a decision not to complete the facility, acquire equipment, E E
IN or possess and use authorized material.
E y
p 21.
A.
If the licensee uses sealed sources or probes containing sealed sources at E
p depths greater than 3 feet, the licensee shall use surface casing that extends E
5 from the lowest depth to 12 inches above the surface and other appropriate El lg procedures to reduce the probability of the source or probe becoming lodged El
's below the surface.
El El n
g B.
If a sealed source or a probe containing sealed sources becomes lodged below the El g
surface and it becomes apparent that efforts to recover the sealed source or El g
probe may not be successful, the licensee shall notify the U. S. Nuclear El g
Regulatory Comission and submit the report required by 10 CFR 30.50(b)(2) and Ej g
(c). The licensee shall not abandon the sealed source or probe without El g
obtaining the Comission's prior written consent.
El El B
22.
In addition to the possession limits in Item 8, the licensee shall further restrict El g
the possession of licensed material to quantities below the minimum limit specified E ll g
g in 10 CFR 30.35(d) for establishing decomissioning financial assurance. (Do NOT use E l
this license condition if applicant provides evidence of financial assurance.)
E y
E l
g 23.
Except as specifically provided otherwise in this license, the licensee shall El g
g conduct its program in accordance with the statements, representations, and E!
procedures contained in the documents, including any enclosures, listed below. The El y
Nuclear Regulatory Comission's regulations shall govern unless the statements, E!
y representations, and procedures in the licensee's application and correspondence are E!
more restrictive than the regulations.
Ej g
l A.
Application dated (insert date).
o y
FOR THE U.S. NUCLEAR REGULATORY COMMISSION [
y E
R E
D l
DATE:
(insert license issue datel BY:
(oriainst sian.d by o nsert reviewer. neie))
e E
B, (insert reviewer's name) g (insert reviewer's NRC address) g y
E B
E R
E B
E N
5 1
g l
NUREG-1556, Vol.1 (draft)
Page L-4
.....................................a
i
}
I l
i Appendix M Review Checklist for Portable Gauge Application
' ~ ~
APPENDIX M ITEM 1: ACTION TYPE ACTION TYPE:
ADMINISTRATIVE REVIEW:
[] New
[] Current Guidance Used
[' Amendrnent
[ ] References in Application Based On Current Regulations
[] Renewal
[] All Attachments Referencedincluded
[] Signature on Application ITEM 2: LEGAL IDENTITY NAME:
i ITEMS 2 & 3: ADDRESS STORAGE & LOCATION OF USE ADDRESS:
MAILING ADDRESS.
1 Temporary Job Sites Only l l YES l j NO ITEM 4: PERSON TO BE CONTACTED ABOUTTHIS APPLICATION 1
l CONTACT PERSON:
TELEPHONE NUMBER:
I ITEMS 5 AND 6: MATERIAL TO BE POSSESSED AND USES YES NO RADIOISOTOPE MFGJMODEL NO.
QUANTITY MOST SPECIFY COMMON OTHER USES USE NOT LISTED ON SSD CERTIFICATE Cesium-137 Scaled sources in Not to exceed Measure
[] Not apphcable compatible gauges as maximum activity per Physical specified in Scaled source as specified in Properties
[] Uses are:
Source & Device Scaled Source &
ofMaterials Registration Sheet Device Registration Sheet Amencium-241 Scaled sources in Not to exceed Measure
() Not apphcable compatible gauges as maximum activity per Physical specified in Scaled source as specified in Properties I I U5'5 8'*:
Source & Device Scaled Source &
ofMaterials Registration Sheet Device Registration Sheet Cahfornium-252 Scaled sources in NJto exceed Measure U Not apphcable compatible gauges as maximum activity per Physical specified in Scaled source as specified in Properties 0 Uses are:
Source & Device Scaled Source &
ofMaterials Registration Sheet Device Registration Sheet Other(specify)
FINANCIAL ASSURANCE REQUIRED AND EVIDENCE OFFINANCIAL ASSl!RANCE PROVIDED Page M 1 NUREG - 1556, Vol.1 (draft)
APPENDIX M ITEMS 7 TIIROUGli 11: TRAINING AND EXPERIENCE. FACILITIES AND EOUIPMENT.
RADIATION SAFETY PROGRAM. AND WASTE MANAGEMENT ITEM NUMBER AND TITLE SUGGESTED RESPONSE APPLICANT'S RESPONSE YES NO OTilER YES NO ITEM 1 INDIVIDUAL (S)
Prior to obtaining licensed materiais, the RESPONSIBLE FOR proposed RSO willhave successfully RADIATION SAFETY completed one of the training courses PROGRAM AND TilEIR described in Criteria in the section entitled TRAINING AND
" Individual (s) Responsible for Radiation EXPERIENCE - RADIATION Safety Program and neir Training and SAFETY OFFICER Experience - Radiation Safety Officer" in draft NUREG-1556, Vol.1, dated NAME September 1996.
AND Prior to being named as the RSO, future RSO's will have successfully completed one of the training courses described in Criteria in the section entitled
" Individual (s) Responsible for Radiation Safety Program and neir Training and Experience - Radiation Safety Officer" in draft NUREG-1556, Vol.1, dated September 1996.
Oplional Response Criteria for Acceptable Training Courses for Radiation Safety Officer / Portable Gauge Users 25 question written (open or closed e
book) test I hour of radiation physics and safety e
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of regulatory requirements e
I hour of gauge theory, operation, routine maintenance, and field training Instructor qualifications:
Bachelor's degree in a physical or life science or engineering with 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> hands-on experience with portable gauges and successful completion of 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> radiation safety course.
OR An individual with the following e
training:
- Successful completion of portable gauge user course
- Successful completion of 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> radiation safety course
- 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of hands-on experience with portable gauge.
NUREG - 1556, Vol.1 (draft)
Page M-2
APPENDIX M ITEM NUMBER AND TITLE SUGGESTED RESPONSE APPLICANT'S RESPONSE 4
YES NO OTilER YES NO ITEM 8 TRAINING FOR Prior to using licensed materials, fNDIVIDUALS WORKING IN authorized users will have successfully OR FREQUENTING completed one of the training courses RESTRICTED AREAS described in Criteria in the section entitled
" Training for Individuals Working In or Frequenting Restricted Areas"in draft NUREG-1556, Vol.1, dated September 1996.
OptionalResnonse Criteria for Acceptable Training Courses for Radiation Safety Officer / Portable Gauge Users 25 question written (open or closed e
book) test 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of radiation physics and safety 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of regulatory requirements I hour of gauge theory, operation, routine maintenance, and field training Instructor qualifications:
Bachelor's degree in a physical or life science or engineering with 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> hands-on experience with portable gaugea and successful completion of 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> radiation safety course.
OR An individual with the following e
training:
- Successful completion of portable gauge user course
- Successful completion of 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> radiation safety course
- 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of hands-on experience with portable gauge.
ITEM 9 FACILITIES AND No information needs to be submitted in Separate item 9 Response EQUIPMENT response to this item; key issues are Need Not Be Submitted With addressed under " Radiation Safety Application l
Program - Public Dose" and " Radiation Safety Program - Operating and Emergency Procedures."
ITEM 10 RADIATION SAFETY The applicant is not required to submit its Need Not Be Submitted With PROGRAM-AUDIT audit program to the NRC for raview Application PROGRAM during the licensing phase I
i Page M-3 NUREG - 1556, Vol.1 (draft) f
APPENDIX M ITEM NUMBER ANDTITLE SUGGESTED RESPONSE APPLICANT'S RESPONSE YES NO OTHER 1
YES NO 4
ITEM 10 RADIATION SAFETY We will either possess and use, or have PROGRAM -INSTRUMENTS access to and use, a radiation survey meter that meets the Criteria in the section entitled " Radiation Safety Program -
Instruments" in draft NUREG 1556, Vol.
1, dated September 1996, in the event of an incident."
Ontional Resnonse i
A radiation survey meter should satisfy the following criteria:
l Be capable of detecting the type of e
4 radiation emitted by the sealed source J
i Be checked for functionality prior to e
use ITEM 10 RADIATION SAFETY Physical inventories will be conducted at PROGRAM - MATERIAL intervals not to exceed 6 months, to account for all sealed sources and devices RECEIPT AND ACCOUNTABILITY received and possessed under the license.
ITEM 10 RADIATION SAFETY Either we will maintain, for inspection by PROGRAM - OCCUPATIONAL NRC, documentation demonstrating that DOSIMETRY unmonitored individuals are not hkely to receive a radiation dose in excess of 10%
of the allowable limits in 10 CFR Part 20 or we will provide dosimetry processed and evaluated by a ATLAP-approved processor that is exchanged at a frequency recommended by the processor Ontional Resnonse i
Alternative response demonstrates compliance with 10 CFR Part 20 requirements.
ITEM 10 RADIATION SAFETY The applicant is nDI required to submit its Need Not Be Submitted PROGRAM - PUBLIC DOSE response to public dose section during the With Application licensing phase. This matter will be examined during an inspection.
i d
1 NUREG - 1556, Vol.1 (draft)
Page M-4
j
)
APPENDIX M ITEM NUMBER AND TITLE SUGGESTED RESPONSE APPLICANT'S RESPONSE i
YES NO OTHER j
YES NO ITEM 10 RADIATION SAFETY We will develop, implement, and maintain PROGRAM - OPERATING &
the operating & emergency procedures in EMERGENCY PROCEDURES Appent/Lt 11 of draft NUREG 1556, Vol.1, i
dated September 1996.
OR Operating & emergency procedures will be developed, implemented and maintained and will meet the criteria in the section i
entitled " Radiation Safety Program -
Operating and Emergency Procedures" in draft NUREG 1556, Vol.1, dated September 1996.
4 i
Onlional Resnonse lastructions to maintain security e
during storage and transportation Instructions to keep the gauge under e
control and immediate surveillance during use j
Steps to take to keep radiation i
=
exposures AIARA Steps to maintain accountability during use Steps to control access to a damaged e
gauge Steps to take, and whom to contact, e
when a gauge has been damaged.
j if gauges are used for measurements e
more than 3 feet beneath the surface:
use of surface casing from the lowest depth to 12 inches above the surface; instructions, procedures to retrieve a stuck source; NRC reporting requirements Copies provided to personnel and e
available at each job site Page M-5 NUREG - 1556, Vol.1 (draft)
.-~.. _.- _.__ _ _ _. _ _ -,. _ _ _ _.... _.. _. _. _. _....
ArrLwDix M d
i ITEM NUMBER AND TITLE SUGGESTED RESPONSE APPLICANT'S RESPONSE OTHER j
YES NO 4
I YES NO ITEM 10 RADIATION SAFETY Leak tests will be performed at intervals PROGRAM-LEAK TEST approved by the NRCor an Agreement State and specified in the Scaled Source I
and Device Registration Certificate. Leak tests will be performed by an organization authorized by NRC or an Agreement State to provide leak testing services for other licensees or using a leak test kit supplied by an organization authorized by NRC or an Agreement State to provide leak test kits i
to other licensees and in accordance with the kit supplier's instructions.
OR Provide the information in,1ppendh J in support of a request to perform leak testing and sample enalysis.
t Individual who will make tLe analysis; qualifications to make quantitative measurements Leak test frequency as specified in the appropriate Scaled Source and Device Registration Certificate.
How and where test samples taken; e
materials to be used; methods of handling samples to prevent or l
minimize exposure to personnel.
Type of instrument (s) used, counting efficiency, and minimum levels of detection for each radionuclide
?
Note: An instrument capable ofmaking quantitative measurements shculd be used; hand-heldsurvey meters will not normally i
be coruidered adequatefor measurements.
Standard calibration sources including e
for each: the radionuclide, quantity, accuracy, and traceability to primary radiation standards Note: Accuracy ofstandards should be within +3% ofthe stated value and traceable to a primary radiation standard such as those maintained by the National Institutes ofStandards and Technology l
(NIST).
Sample calculation to convert j
measurement data to becquerels (or microcuries)
NUREG - 1556, Vol.1 (draft)
Page M-6
APPENDIX M ITEM NUMBER AND TITLE SUGGESTED RESPONSE APPLICANT'S RESPONSE -
YES NO OTHER i
YES NO ITEM 10 RADIATION SAFETY ROUTINE CLEANING &
PROGRAM - MAINTENANCE LUBRICATION We will develop, implement, and maintain procedures for routine cleaning and lubrication of the source rod and shutter mechanism that contain the elements listed under Discussion in the section on
" Radiation Safety Program - Maintenance" in draR NUREG-1556, Vol.1, dated September 1996.
EXTENDED MAINTENANCE We will send the gauge to the manufacturer or other person authorized by NRC or an Agreement State to perform more extensive maintenance or repair operations I
that require the removal of the source or source rod from the gauge.
OPTIONAL RFSPONSE Provide the information listed in Appendh-G in support of a request to perform extended maintenance in-house.
Types of work to be performed Who will perform maintenance, training, experience, why competent Handling procedures: doses to public, j
personnel ALIRA and reg. limits;-
security; posting; mfg. instructions &
recommendations Use of whole body & extremity monitoring or evaluation to demonstrate that individuals are not likely to receive >10% of allowable limits Possess survey instrument (detects e
radiation emitted; range 1-100 mrem /hr; annual calibration w/ point source at 2 points / scale; calibrated by NRC' Agreement State licensee; checked before use) 10 CFR 20.1301 surveys (when and e
where instrument survey performed, records for 3 yrs)
ITEM 10 RADIATION SAFETY The applicant is nel required to submit its NeedNot Be Submitted With PROGRAM -
response to transportation section during Application j
TRANSPORTATION the licensing process. However, this issue will be reviewed during inspection.
Page M-7 hUREG - 1556, Vol.1 (draR)
APPENDIX M ITEM NUMBER AND TITLE SUGGESTED RESPONSE APPLICANT'S RESPONSE YES NO OTHER YES NO ITEM 11 WASTE DISPOSAL -
The applicant does act need to provide a Need Not Be Submitted With GAUGE DISPOSAL &
response to Waste Management section Application -
l
~
TRANSFER during the licensing process. However, the licensee should develop, implement, and i
maintain gauge transfer and disposal procedures in its radiation safety program.
l t
Y l
I L
r I
t NUREG - 1556, Vol.1 (draA)
Page M-8
s l
l NRC FORM s3s u.s. NUCLEAR REIULATORY COMMisslON
- 1. REPORT NUMBE?t l
D49)
(Assigned by NRC, Add Voi,, supp., Rev.,
i
$"E' BIBLIOGRAPHIC DATA SHEET
'""*""""'"**'*"*"N l
rsa marucias ca *= =ww/
- 2. TITLE AND SUBTITLE Vol 1 Draft Consolidated Guidance abou* Materials Licenses l
Program-Specific Guidance about Portable Gauge Licenses 3.
DATE REPORT PUBUSHED Draft Report hr Comment Mm YEAR j
September 1996
5 AUTHOR (S)
- 6. TYPE OF REPORT P. C. Vacca, J. E. Whitten, S. A. Arredondo, E. R. Matson, W. Tingle *, S. W. Lewis, D. J. Collins, Draft P. A. Santiago
- 7. PERIOD COVERED pnchiseve ceses) l l
- 8. PERFORMING ORGANIZATION. NAME AND ADORESS p Nac, passe Oveam, Ceco a Hogan, U $ Nucasar Angulekry Commesen. and meeting addrosa, #conteckr, j
prownse nome end meding address)
Office of Nuclear Material Safety and Safeguards
- Division of Radiation Protection Division of Industrial and Medical Nuclear Safety Department of Envircnment, Health, and Natural Resources U. S. Nuclear Regulatory Commission 3825 Barrett Drive Washington, DC 20555-0001 Raleigh, NC 27609-7221 9 SPONSORING ORGANIZATION NAME AND ADDRESS tr NRC. type "Some es abovet #conrockr. svovsfe NRC Dvamn omce a Regen. u s Nucasar Regvekry cynmusen.
and menknp encross )
Same as above
- 10. SUPPLEMENTARY NOTES
- 11. ABSTRACT r200 weda a dess)
As part of rts redesign of the materials licensing process, NRC is consolidating and updating numerous guidance documents into a single comprehensive repository as described in NUREG-1539 and draft NUREG-1541. Draft NUREG-1556, Vol.1, is the first program-specific guidance developed for the new process and may serve as a template for subsequent program-specific guidance.
This document is ultimately intended for use by applicants, licensees, and NRC staff and will also be available to Agreement States.
Thrs document combines the guidance previously found in draft Regulatory Guide DG-0008, " Applications for the Use of Sealed Sources in Portable Gauging Devices," and in NMSS Policy and Guidance Directive 2-07, " Standard Review Plan for Apphcations for the Use of Sealed Sources in Portable Gauging Devices." This draft NUREG takes a graded, more performance-basea approach to licensing portable gauges, reducing the information (amount and level of detail) needed in support of an apphcation to use these devices. Note that this document is strictly for public comment and NOT for use in preparation or review of portable gauge licenses unt'l it is publ:shed in final form.
l l
- 12. KEY WORDS/DESCRIPTORS (Lat words er pirosas shot ede esamt resserenws a beetmg me report) 3 AvA LAsitrrY ST ATLMENT unlimited materials licenses H SEWRrrYCLASSFICAMN portable gauge Frus Pope) graded approach unclassified performance-based gha nopor, program-specific cnclassified
- 15. NUMBER OF PAGES
- 16. PRICE NRc FORM 335 Q49)
The fwm m emetroniceny produced by R,e FWel Fams Inc
FIRST CLASS MAIL
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UNITED STATES POSTAGE AND FEES PAID j
NUCLEAR REGULATORY COMMISSION N
i WASHINGTON, DC 20555-0001 PERMIT NO. G47 4
4 j
PENALTY FOR PFWATE USE, $300 4
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The Materials Licensing Process Vision This vision was created in the Sp-ing,1995, by the Phase i NMSS BPR Team t
' Consolidating l
Guidance Regulatory l
I
,ig Product Design
. Center
- ma*, X i
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l Improving Customer Support
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Streamlining the l
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Licensing APfnb"Ne*1 Procu s "d
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1 Dial-up Computer Assisted Review q
Satisfied i
Licensees and 1-800-NRC-a Confident HELP Pub!ic
^
i
i Regional Pilot Test Objectives and Scope Ob.iectives:
The Regional BPR pilot has the following objectives:
1.
Verify that the new sample license created by the computer assisted BPR review process and the new manually reviewed license issued l
under NUREG 1556 are equivalent and provide the same level of l
safety.
l 2.
Verify that the automated system (hardware and software being prototyped during this pilot) and the associated business processes meet the BPR design.
L 3.
Verify that the training for the Reviewer components of Internet and l
Licensing and Inspection On-line System (LIONS) are adequate to provide the skills necessary to implement those portions of the BPR design.
4.
Observe the review and 0A components of the BPR design processes to assess that the proposed performance measures and targets are reasonable, and that the necessary data is obtainable via interim manual methods. Collect measures to verify the projected average cycle time of 12 days or less.
5.
Collect information regarding the functionality of the prototyped features for LIONS milestone capture public access to guidance (both Internet and application entry help system), and process management.
6.
Demonstrate the functionality and utility of the software and guidance (NUREG-1556) designed for submission of new license applications.
7.
Demonstrate the capability of issuing and printing a sample license which will assist in the future development of acceptable official records for materials license dockets.
8.
Actively solicit input from the Agreement States and licensees on how to improve effectiveness and efficiency of the new licensing process.
In addition. solicit input on how the new process might affect the Agreement States, and enhance the role of the Agreement l
States in the development of the new process.
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Scope:
Using portable gauge applications from eight participants, the scope of the BPR pilot will be limited to:
j 1.
Applicants creating electronic versions of applications with BPR team-designed software and electronic versions of guidance.
l 2.
Processing electronic versions of applications (received via diskette) into and out of the prototype automated Licensing and Inspection On-line System (LIONS) system.
l 3.
Assignment of technical review using the prototype automated LIONS i
system.
j 4.
Storage and retrieval of applications via the prototype automated LIONS system.
5.
Technical review of applications using on-line licensing reference l
material (consolidated guidance and other. electronic reference l
materials) and computer assisted review process (review checklists).
6.
Evaluate the 0A process for application review and sample license issuance.
7.
Review the flow of queue assignments between the technical reviewer.
0A reviewer, and the customer service representative.
8.
On-line creation and on-line review of a record of decision that i
documents the basis for the licensing action.
9.
Generation of deficiency report and/or sample official record
'l license documentation via LIONS.
- 10. Limited demonstration of the )rinting and handling of sample licensing documents through tie LIONS customer service component.
~
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(
List of Regional Pilot Test Participant Organizations Portable Gauae License ADDlicantS (Prepared actual new license applications)
Secor International Inc.
Cleveland OH 44106 ThermoScan Inspections Carmel. IN 46032 National Institute for Occupational Safety and Health (Formerly Department of Interior. Bureau of Mines)
Spokane. WA 99207 Dames and Moore Solon. OH 44139 Portable Gauae Manufacturers (Prepared " mock" new license applications) 1 Troxler Electronic Laboratories Research Triangle Park, NC 27709 Seaman Nuclear Corporation Oak Creek. WI 53154 Boart Longyear Corporation Martinez. CA 94553 l
Humboldt Scientific. Inc.
l Raleigh. NC 27606 l
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SUMMARY
OF COMMENTS RECEIVED DURING THE REGION II PILOT TEST OF THE NEW MATERIALS LICENSING PROCESS The Materials Licensing Business Process Redesign (BPR)-team conducted a pilot test of the new materials licensing process in Region II from January 27 through 31, 1997.
Participants included four applicants for actual licenses to use portable gauges, four )ortable gauge manufacturers, and staff from Region II who functioned in t1e Customer Service. Technical Review Quality Assurance (0A) Review, and Management roles.
Re l
Agreement States (Georgia. Illinois, and Texas) presentatives of three also participated in the pilot test. One portable gauge consultant submitted an application and comments after the conclusion of the pilot. The consultant's comments are included in this sumary. All of the pilot test participants expressed pleasure in being included in the testing phase of the new materials licensing process, so that their coments and suggestions can be considered in subsequent development and refinement of the process.
Comments were offered concerning two subjects:
the consolidated portable gauge licensing guidance published in draft NUREG-1556. Volume 1. and the prototype Licensing and Inspection On-line System (LIONS) license application preparation and. review program.
Comments regarding these issues are summarized below:
Draft NUREG 1556. Volume 1 Applicants and Gauge Manufacturers: Coments were generally very positive and supportive of the draft NUREG. Commenters generally thought that the document was very easy to work with and written at an appropriate level for the typical user.
They also thought that the intent of the requirements was clearly explained. One commenter noted that the document was written with the i
assumption that the reader had no 3revious experience with radioactive materials or portable gauges and tlat this was a sound approach. Two comenters plan to incorporate information from the draft NUREG into their training programs and/or company manuals. Another commenter said that, compared to previous NRC documents, the reader would have a better understanding of commitments being made to the NRC in the application.
In response to NRC questions, many commenters stated that they would access guidance on the Internet if it were available.
Other comments included the following:
" reeks of common sense and logic" "when I got it. I fell in love with it" e
"it must be well-written, because I can use it" "my highest compliments on the document" e
"all the necessary information is in one book" e
" graphics useful." " illustrations effective" e
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"never seen this much help.for applicants" "liked the performance-based approach" "liked the standard responses and the pages in Appendix B" l
"the Appendixes are really good gratified that his comments submitted on the previously-used guidance (DG-0008) were incorporated into draft NUREG-1556. Volume 1 l
Several of the gauge manufacturers had specific comments on draft NUREG-1556.
Volume 1. that the staff.will consider with other comments received on the document.
Agreement State Representatives: The Agreement State representatives stated that draft NUREG-1556. Volume 1. is ea:,y to read and use and the licensing i
process for portable gauges will be much improved by this document. They also commented that they looked forward to other licensing documents adopting the approach taken in draft NUREG-1556, Volume 1. and it should make the licensing process a lot easier for licensees and regulators.
In addition, the Agreement l
State representatives provided numerous specific comments on the document that i
the staff will consider with other comments received on the document.
Prototvoe LIONS License Apolication Preparation and Review Proaram Applicants and Gauge Manufacturers:
Comments were generally very positive and l
supportive of the LIONS application preparation program. Commenters generally thought that the software was easy to follow and work with. A number of commenters noted that administrative staff had prepared the applications i
without difficulty and only needed technical clarification regarding the use of radioactive materials.
Several commenters noted that the application entry l
program should be almost intuitive as many applicants and licensees will only i
use it once or a few times.
Most commenters indicated that they preferred the computer-based application, rather than the paper-based application.
j t
Many of the commenters stated that they did not need or use the HELP functions.
However,otherswhousedtheHELPfunctionssaidthatthe
. information was complete and ' easy to understand, and offset the need to have a separate paper copy of draft NUREG-1556. Volume 1.
Other comments included the following:
" order of magnitude ste) forward in the process" "very simple and straig1t forward" e
" instructions easy to follow" i
"seemed too easy"
" applauded the program" l
In the Region II pilot test, the participants received the application preparation program on five diskettes and had to load the program onto their computers.
Some had difficulties with the installation of the program as well as with saving and printing applications, but they were able to overcome the problems following discussion with NRC contractors or their own in-house computer ex>erts. Some of the participants offered specific suggestions for improving t1e utility and ease of use of the application entry program.
These i
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comments and suggestions are being considered as the LIONS program is further developed and refined.
In response to NRC questions, several commenters stated that they would download license application software directly from the Internet if it were available.
Agreement State Representatives:
The Agreement State representatives used the application entry portions of LIONS as well as the review, administrative, and management functions of LIONS. The Agreement States representatives stated that the program had a logical approach and was easy to learn and use. They also stated that the software would be useful in their own State programs and they would be interested in adapting LIONS to materials uses (other than portable gauges) as well as to machine sources. The Agreement State representatives agreed that the new process design is an order of magnitude improvement over the current review process.
The representatives offered numerous specific suggestions for improving the application preparation and review software.