ML20246N278

Request for OMB Review & Supporting Statement Re Survey of Source & Device Users.Estimated Respondent Burden Is 4,400 H

ML20246N278
Person / Time
Issue date:	07/17/1989
From:	Amenta A NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:
References
NUDOCS 8907190336
Download: ML20246N278 (10)

Text

- - _ _.

'l W-tr 83 Request forOMB ReviewDESIGNATED ORICI!?A!,' /

qw Sepicter 1983)-

Cortified By

(/M

import

rit -

- Read instructions t>efore completing form. Do not use the same SF 83 Send three copies of this form, the material to be revierted, and for =

l to request both an Executive Order 12291 review and approval under paperwork-three copies of the supporting statement, to:

the Paperwork Reduction Act.

Answer att questions in Part 1.lf this request is for review under E.0; Office of Information and Regulatory Affairs

.12291,-complete Part il and sign the r?g: hitory certification. If this Office of Management and 8udget '

1 recuest is for approval under the Paperwork Reduction Act and 5 CFR Atterttion: Docket Library, Room 3201 1320. skip Pirt 11, complete Part til and sign the paperwork certification.

Washington, DC 20503 PART l.-Complete This Part for All Requests.

Departrnent/ agency and Bureau / office originating request f

2. Agency code U. S. Nuclear Regulatory Commission' 3

1-5 0

3. f42me of person who can best answer questions rega' dang this request Telephone number

' Steve Baggett

! ( 301 )492-0542

'4, Titte of intorrnation coitecten or rulemaking

-Survey of Source and Device Users

^$. t egat authonty for unforrnatson toilection or rule (co umted States Code, Pubhc Law, or Enecutwe Order)

. 42 usc _220Mc)

. or

6. _Affected pubhc (check all the apply) 5 3 Federalagencies or employees r

1 O Indmdaals or househosos

'3 C farms 6 3 Non-profitinstitutions 2 3 State orlocalgovernments 4 3 Businesses or other for profit 7 3 $rnallbusinesses ororgantrations

PART ll,-Complete This Part Only if the Request is for OMB Review Under Executive Order 12291

7. Regutation identifier N rDer (R:N)

~ _ _ _ _. or, None assigned O b, Type of submssion (c%v o% esce cangry)

Type of review requested Classificar;on State of development 1 D Standard 1 O uaior i O Proposed or draft 2 O pending

2. O Nonma,o, 2 O rinaiorintenmes.a.witnpriorproposai 3 0 Emergency 3 0 rinai or interim finai. witnout pnor preposai 4 0 statutoryorjudiciardeadiin.

9. CFR ssetion affected CFR

-10. Does th s regulation contain reportirg or recordkeeping requirements that require OMB approval under the Paperwork Reduction Act and 5 Cf R Ino?

O ves O No

11. lf a major ruie,is there a regulatary irr, pact analysis attached?

1 O ves 2 O No if"N3" did OMB waive the analysis) 3 0 ves 4 0 No Certification for Regulatory Submissions in submitting this tequest fus.DMB rewew, the aJthori2ed regulatory contact and the program official certify that the requirements.)f E.O.12291 and any applicable pohey directives have been comphed with Signature of prgram officia!

Date l

I signsture of authorireo regu$atory contact Date 12.40M6 use only)

Standsed rorm 03 (ftev. 9-83)

Preveut editsons obsolete g3103

! N$N 754o Oo 634.4034 Presenbed by OM8 5 CFR 20 and C.o.12291 8907190336 890717

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I PDR ORO EU$0MB 8

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. PART llL-Complita This Ptrt Cnly if thJ Request is f:r Apprsval ci a C ll2ctlin

- of information Under the Paperwork Reduction Act and 5 CFR 1320.

13. Abstract-Describe needs, uses and affected public in 50 words or less

" Radioactive Materials, Radiation Safety" NRC will conduct a snail,. telephone, or site' visit survey of general licensees under 10 CFR Part 31 to verify what devices are in their poss ion, to verify compliance with NRC regulations, and to datermine the utility of a formalized ma urvey program. NRC will also conduct a survey of m

cartain specific licensees to determine twir source / device inventory.

14. Type of information collection (check only one) information collections not contained in rules

'i Ib Regular submission 2

Ernergency submissbn (certification attached)

Information collections contained in rules h[

3 O cmsting regulation (no chanKe Pi;oposed) 6 Fi' eintenm final withcut pnot NPRM

7. Enter date of expected or actuai Federal 4 O Notice of proposed rulemaking(NPRM)

AL degular submission '

Register publication at th:s stage of rulemaking 5 0 rmai. NeRu was proviousiy pubbsned B O Err ergency submission (certification attached)

(month, day, year):

15. Type of review requested (check only one)

I h Nnw coHection -

4 O Reinstatement of a previously approved coUection for which approval -

h'$ '*Pd 2 O Rev ion of a currentry approved conection 3 O Extension of the exparation date of a carrertry approved coliection 5 0 cmsting coiiection in use without an oMB controi nurnber -

without any cha te in the substance or in the method of collection T 6. Agency rtport form number (s)(#ctude standard / optional form numberts))

t2. Purpose of information collection (check as enany as apply)

Not applicable 1 O Apphcation for benefits 2 O erogram evaiuation 17, Annual rep.,,t g or desciosure burden 3 0 ceneraipurposestatist,cs 12,000 4 E Regulatoryorcomphance 1 Number of ! mpondents.

0.33 3 g progr,rn niann,ngo enanagemert 2 Number of tesponses per respondent 3 Totar annua! responses (Iine 1 times hne 2) 4,000 e O gese,ren 1.I 7-0 Audit 4 Hours per response 5 Total hours Ume 3 times ne 41 4dOO o

A 8. Annual recordkeeping burden

23. Frequency of txordkeepchg or reporting (check all that appO I Numtier of reen"1 keepers 1 O Recordkeeping 2 Annualhours N,ecordkeeper, Reporting 3 Total recordkeeping hours (line 1 times line 2) 2 On occasion 4 Recordkeeping retention penod yea $

3 0 weekiy

19. Total annual burden 4 C Montnly 4,400 5

Quarterly 1 Requested (line 17 5 plus Ime 18J).

0 s O semtannuany 2 tn current OMB inventory

+ 4,400 7 O Annually 3p,tt,rine,(im,;;e,,im,y) bplanation of difference 8

Bienniavy 4 Program change

+ 4,400 9 {0 otner(desenbe)

One-t-ime sur. rey 5 Adjustment

20. Current (most recent) OMB control number or comrnent number

24. Respondents' obligation to comply (check the strongest obligation that applies) 1 C Voluntary

21. Requested enperation date 2 C Required to obtain or retain a benefit l years from approval date 3 8] Mandatory AS, Are the respondents pnmenty educational agencies or inst.tutions or is the primary purpose of the collection related to Federal education pro;; rams? O ves

...~s

1. 6, Ooes'the agency use samphrg to select resp,ondents.,r does the agency recommend or prescnbe the use of samphng or statistical analysis

, Oyes t

, No i

s by respondents?

27. Regulatory euther;ty for the mtormation cohection CFR

or FR

nr. Otner (specify)

Peperwork Certification lo s.ubrmttirg tNs requrist for OMB approval, the agency head the senior official or an authorged representatwe, certifies that the requirements of 5 CFR 1320, the Privacy Act, statistical standards or directives, and any other apphcable information pokcy directives have been comphed witn Date Signature of preg'am official i

03 e Sgnature of agency head, the senior official or an auhorized representative Joyce A. Amenta, Designated Scutor Official

.i f'or,Information Resources Management g/gg I

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NART lil.-Complete This Part Only if the Request is for Approval of a Collection of inform ation Under the Paperwork Reduction Act and 5 CFR 1320.

1. Abstract-Oescribe needs, uses and affected public in 50 words or less

/) Radioactive Materials, Radiation. Safety" 3

,NRC will conduct a nil,. telephone, or site' visit survey of. general licensees under 10 CFR Part 3' to brify what devices are in their possession, to verify compliance with NRC regulations, and to

dotarmine the utility of-a formalized mail survey program. NRC will also conduct a survey of

' 4certain specific licensees to detert. w 3 heir eource/ device inventory.

14. Type of information collection (check on!y one) a.

Information collections not containedin rules

~ b Regular submission '

2 O Emergency submission (cert <6 cat,on attached) l Information collections containedin rules

~ 3 O Existing reguation(no change proposed; e rinai or intenm final without poor NPRM

7. Enter date of expected or actual federal '

med ni emaking(NPRM)

A O Regular submission Register pubhcation at this stage of rulemaking 4 O Notice of p.

l 5 0 rinnimeRM was previous y pubnsned B O Eme gency submission (cert,6 cation attached)

. (month, day. year)

15. Type of review requested (check only one)

' 1 $ New coilection 4 C Reinstaternent of a previously approved collection for which approval

"'5**P"'d 2 O Revision of a currentir approved coiiection 3 C tatension of the empiration date of a currerfly approved collection 5 O cristing coriect.on in use without an OMB control number without any charge in the substance or in the snethod of collection

16. Agency seoort form narrber(s)(,r'ctude standard /optionalform numbens))

22. Purpose of information collection (check as many as applyi Not applicable 1 O Apphcation for benefits 2 O Program Wah,ation L 17. Annual reporting or d:sclosure burden 3 0 ceneraipurpose statistics 12,000 4 E Regulatory orcompiiance

- ! Number of respondents.

O.33 5 g program pianningor managemert 2 Number o' responses per respondent.

3 Totar annud responses (1,ne l t,mes t,ne t) 4,000 s O Ruearen 4 Hou s per response 1.1 7 O Audit r

_5 het hours nec 3 t,mes one o,

4,400 _ L A S. Annual recordkeeping burden

23. Frequency of recordkeeping or reputting(check allthatapply) 1 Number of recordkeepers 1 C Recordkeeping 2 Annualhours per ter* jkeeper.

Reporting 3 Total recordkeeping hours (line j times hoe 2) 2 O On occasion 4 Recordkeeping retention penod years 3 0 wee <ir

19. Total annual burden 4 O Montnir 4,400 5 0 overteriy 1 R0 guested (line J 7 5plus kne 18-3).

6 0 semi-annuairy 0-2 in current On inventory 3 Difference (line 1 less hne 2)

+ 4,400 7 O Annua 4 Explanation of ditterence 6 O B:ennially

_. + 4,400 9 0 Otner(desence):

One-t w survey 4 Prograrn change 5 Adjustment.

20. Current (most recent) OMB controi number or comment number

24. Respondents' obhgation to comply (check the sfrongest obhgattor' that applies) 1 O voiuntary

' 21. R$ quested expiration date 2 O Required to obtain or retain a benefit 3 years from approval date 3 0 Manetory

25. Are the respondents pnmarily educatior at agencies or institutions or is tne pnmary purpose of the collection related to Federal education programs? O ves E No

26. Does the agenc use samplirg to telect respondents or does the agency recommend or prescribe the use of samphng or statistical analysis

. O yes E No by respondents N Regulatory authority for the information collection CFR

or FR

or,Other (specoty)-

Paperwork Certification

- In submitting this request for OMB approval, the agency head, the senior off:cial or an authonzed representative, certifies that the requirements of 5 CFR 1320, the Pnvacy Act, statistical standards or directives,and any other apphcable information pokey crectives have been complied with.

Signature of program official Date Sign:ture of agency head, the senior officiat or an authorizee represeMative Date Joyce A.- Amenta, Designated Senior Official

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Y SUPPORTING STATEMENT FOR SURVEY 0? SOURCE AND DEVICE USERS DESCRIPTION OF THE INFORMATION COLLECTION i

We are requesting OMB clearance on two related information collection activities by this one submission.

The first is to contact certain general licensees to verify what devices are in their possession, that they are complying with the rules and requirements of the general license provisions of 10 CFR Part 31, and to determine the utility of a formalized mail survey program.

The second is to contact certain classes of specif'c licensees to determine their source / device inventory.

The only dif ference between the two surveys is that the contacts with the general licensees will collect specific information about compliance with the regulations in 10 CFR Part 31 while surveys of specific licensees will collect only inventory information.

This is necessary sine the general licensee is not required to file an application with NRC and receive written approval from NRC prior to use of the byproduct material, as is the case with specific licensees.

Furthermore, specific.

licensees are periodically inspected to determine how they are complying with the terms and conditions of their license, while general licensees normally are not inspected.

Under special studies conducted during the summer of 1984 and 1985, the NRC contacted a number of persons that use devices under the general license provision.

The contacts were made under OMB approval number 3150-0124.

These l

studies acquired data on licensee performance that allowed MRC to determine the j

scope of the accountability problems with devices used und' r the general license.

No such study has been done for specific licensees that are inspected at a low l

frequency.

However, past inspections of these types'of licensees have revealed a need for more frequent regulatory presence.

Further, the Commission has directed the staf f to determine the source / device inventory of certain specific 1 4ensees.

The study will require NRC staff (regular, part-time, co-op employees), or licensees, or NRC contractors to complete a questionnaire and refer this information to NRC Headquarters, where it will be analyzed.

The surveys will be done by a combination of mail, telephone and site visits to acquire the needed information.

The type of questions that are to be asked are enclosed.

NEED FOR THE COLLECTION OF INFORMATION General Licensees From past studies, we found that general licenses do not, in all cases, adhere to the rules and regulations.

Furthermore, final dispositions of some devices could not be determined by the user.

NRC is not staffed to routinely inspect

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general licensees and traditionally has had little contact with users of general licensed devices.

This survey is needed to contact a maximum of 6000 general licensees and determine their compliance with the regulation in 10 CFR Part 31, ensure that they are aware of their' obligations under NRC regulations, and determine the utility of a formalized mail survey program.

Such a formalized program would be instituted by rulemaking, subject to OMB clearance.

Specific. Licensees

. Specific licensees possessing certain sealed sources.containing transuranic or large quantities of cesium-137 are not able to dispose of them at commercial burial sites, because the concentration of the radionuclides exceeds the limit's of '10 CFR Section 61.55.

Further, no vendor will accept the return o' these sources after they are sold.

The Commission has directed the staff to survey licensees that have surplus sources and determine the scope of the problem with disposal of unwanted sources.

A specific l'censee is typically authorized to possess and use any number of seMe" sources and devices, up to a maxit.um possession limit for identified radionuclides specified in its licenses.

Therefore, NkC cannot determine the number of sealed sources and devices that a licensee actually possesses by just reading the license.

Furthermore, there is no requirement for licensees to inform NRC of sealed sources that they are unable to transfer or dispose of.

Therefore, each specific licensee must be contacted to acquire information on the number of surplus sources in its possessi,on.

The information collected will be used to develop procedures under which surplus sealed sources which exceed the concentration limits of Section 61.55 may be transferred to the Department of Energy (D0E) for interim storage.

DOE is the Federal agency responsible for acceptance of these surplus sources.

NRC inspectors cannot be used to collect the information because of cost and higher priority work.

Thus, NRC must conduct a mail and telephone survty of these licensees to obtain the information.

AGENCY 05E OF INFORMATION

_l t

General Licensees The information from contacting the 6000 general licensees will be used to determine the utility of a formalized mail survey program to improve tracking of devices.

This information will also be used to support rulemaking activities currently under way to require general licensees to periodically report their sealed source inventory.

J

\\

Specific Licensees

]

I The information collected will be used to determine the inventory of sources

)

and devices in a population of low risk licensees.

This information will enable NRC to assess the magnitude of the problems of accountability and disposal, and allow NRC to advise DOE about the crgency with which 00E should I

i

_3 establish a facility for the interim storage and disposal of the sealed sources or devices that exceed the concentrations in 10 CFR Section 61.55.

I I

RE00CTION OF BURDEN THROUGH INFORMATION TECHNOLOGY There are no legal obstacles to reducing the burden associated with this information collection by the use of automated equipment.

However, licensees typically do not maintain records as required by the regulations on automated equipment.

Therefore, the use of computers for the reporting requested is not practical.

EFFORT TO IDENTIFY DUPLICATIONS The Information Requirements Control Automat.ed System (IkCAS) was searched to identify duplication.

In selecting licenfees to contact under this survey, care will be taken to avoid users that have been recently inspected, that have been involved in previous studies or that have been involved in recent licensing actions.

In some instances, the survey questions may duplicate information on transfers of devices that licensees are currently required to submit under the regu-lations of 10 CFR Part 31.

For example, if the general licensee transferred a device and if the device was not transferred in order to obtain a replacement, then the general licensee was required to report the disposition of that device.

If the general licensee did report the transfer, the question about transferred devicer in Item 12 of the survey questionnaire may elicit the same information.

However, the duplication is anticipated to be small and is necessary in order to investigate indications that those current requirements may not be effective in maintaining accountability of the radioactive material.

EFFORT TO,USE SIMILAR INFORMATION Thet a u no similar information available to the NRC.

EFFORT TO REDUCE SMALL BUSINESS BdRDEN Because the majority of general or specific licensees are small businesses, the questionnaire w ; designed to get only the information that is essential to NRC's mission.

It is not possible to further reduce the burden on small entities by less complete collection of information or less frequent contact.

CONSEQUENCE OF LESS FREQUENT COLLECTIONS This one time survey will be performed over a three year time period. The option of not. doing the survey would greatly impair NRC's mission to evaluate the general and specific license program and to protect the public health and safety.

CIRCUMSTANCES WHICH JUSTIFY VARIATION FROM OMB GUIDELINES There is no variation from OMB guidelines.

I i

u

. CONSULTATIONS OUTSIDE THE NRC Regulatory groups responsible for radiation control in the 29 Agreement States have recommended that the survey be performed and documented.

Those groups are contributing to the study by sharing with NRC the results of surveys and inspections of their licensees.

Several vendors of devices have been consulted and they have offered assistance it NRC has difficulty in contacting users of devices under the general licenses.

Further, these vendors have offered assistance in locating documentation on the transfer of devices to and from specific licensees.

CONFIDENTIALITY OF INFORMATION NRC provides no pledge of confidentiality for the collection of information,.

except for proprietary information.

Responses and results obtained through the-questionnaire will be desensitized to remove any company confidential information and possibly released to the public as a technical report.

This is needed to protect the confidentiality of vendors' quarterly reports of transfer that contain proprietary information.

JUSTIFICATION FOR SENSITTVE QUESTIONS q

1 The questionnaire does not contain any sensitive questions.

ESTIMATE OF BURDEN General Licensees Number and Type of Respondents An estimated _400,000 devices are used under the general license provision of section 31.5.

It is not possible to obtain an exact number of general licensces.

However, we have estimated that there are approximately 35,000 users under this general license.

We plan to contact a maximum of 6,000 users by mail, telephone and site survey over a 3 year time period.

We further estimate that a maximum of 3000 of these same users will have to be visited because they did not respond to the mail or telephone survey.

The actual number of contacts depends on the available resources (both NRC staff and contractor).

Currently Nk" has obligated contract funds to contact 3,000 general licensees.

NRC wili nrovide the contractor with a list of general licensees and the devices they possess. This list will he generated from vendors' quarterly reports of transfer that are filed as required by 10 CFR Section 32.52.

Specific Licensees Number and Type of Respondents l

There are about 8000 specific licenses issued by NRC.

The licenses cover a wide range of uses and conditions of use.

Because of the method NRC uses to license these fac'lities, it is not possible to obtain an estimate of the number of source / devices possessed by this type of licensee.

We plan to contact a number of categories of licensees whose facilities pose minimal risk to the public health and safety.

This is estimated to be a maximum of 6,000

[

licensees over a three year period.

The actual number of contacis will depend on available resnurces (both NRC staff and contract).

1

, Reasonableness of the Schedule for Collecting Information The needed information would be collected during a single mailed correspondence or during a single telephone interview or during-a single visit after setting up the appointment by telephone.

Method of Collecting the Information NRC will use regular, part-time, co-op students or contractors to conduct the survey and perform follow-up on non-respondents by telephone contact and by onsite visits.

A copy of the survey questionnaire may be completed by the contract interviewer, by phone, on the vasis of user-answered short questions or by mail.

An alternative considered was that of a large number of inspections by 4RC's Inspection and Enforcement personnel.

This alternative was not pursued because of a short supply of inspectors and the need to use j

available inspectors on higher priority work.

_ Gen.eral License Cost Summary We estimate that approximately 50 percent (3,000) of the recipients will respond to the mail or telephone survey.

Each respondent would spend 30 mint.tes (0.5 hr). The burden on licensees would be 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> (3,000 X 0.5) over 3 years, or 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> annually.

At $60 per hour, this represents a cost to licensees of $30,000 per year.

The 3,000 recipients who do not respond to the mail or telephone survey would be visited.

The general licensee that is visited would spend 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

The burden en licensees wo ld be 6,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> over 3 years, or 2,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> annually.

At $60 per hour,, this represents a cost to licensees of $120,000 per year.

The total burden of mail and telephone responses and site visits is estimated to be 2,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> annually.

The total cost to licensees is estimated to be l

$150,000 annually.

These estimates are based on consideration of the short questions to be asked and the expected short oral and written responses and past experiences with the surveys conducted under OMB Approval Number 3150-0124.

Specific License Cost Su_mmar,y We estimate that approximately 70 percent (4,200) of the specific licensees will repond to the mail or telephone survey.

Each respondent would spend 30 mirut<es (0.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />).

The burden on licensees would be 2,100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> (4,200 X 0.5) over 3 years, or 700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> anntially.

At $60 per hour, this represents a cost to licensees of $42,000 per year.

The 1,830 recipients who supply incomplete information or who do not respond to to mail or telephone survey would be visited.

The visit would require a O=--___-_______--_--___________

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licensee to spend about.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

The burden on licensees'would be 3,600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> (1800 X 2) over 3 years ~, or 1,200 hour0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br />s-annually.

At $60 per hour, this a

represents a cost to. licensees c:, 372,00^ per year.

]

The total burden of mail and telephone. responses and site visits is estimated:

to be 1,900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br />. annually.

The total cost to-licensees is estimated to be

$114,000 annually.

. ESTIMATE.0F COST TO THE FEDERAL GOVERNMENT This information collection will be done over a period of-three years.

It is

. difficult to predict cost to the government; since the cost depends on what mechanism is used to conduct the survey.

If contractors are used the impact on

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~

the government would involve contract managing and analysis of,the contractor's--

reports We estimate that this would take about six ~ staff months over a three year period at a total cost of approximately $60,000 ($20,000 annually).

In-addition, the estimated contract cost for the project is $250,000.

Conversely, if NRC staff conduct the entire survey it is estimated to'take about nine staff years over a three year period, or $374,000 annual' (3 x 2080 hrs /yr x $60/hr),

i PUBLICATION FOR STATISTICAL USE None.

COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS.

Statistical methods are not used in the collection of 'information.

Licensees to be surveyed are chosen based'on-their license type, i.e.

well-logging, gauges, etc.

Enclosure:

Survey Questionnaire h

t.

N' L-_-_.~.._~___..___._--____,_

1 e

s SURVEY QUESTIONNAIRE

'1..

Name and address of the licensee. Name and telephone number of individual contacted. Principal business of the general-licensee.

2 Purpose for which the source / device (s) are used (e.g., gas chromatography, X-Ray fluorescence, exit lights, or static eliminators.)-

l 3.

For each source / device, identify the following:

a.

Manufacturer or initial transferor b.

Model number c.

Radionuclides in the source or device d.

-Quantity of radioactivity in the source and date of determination of the quantity

)

e.

Date the source or device was received f.

Date of source replacement, if any g.

Condition of the source or device

• 4.

Name of individual or company who installed the device.

• 5.

Does the device have a durable, legible, clearly visible label?

• 6.

Does the general licensee have a copy of the general license?

• 7.

Does the general licensee have a copy of the initial radiation survey performed at the time of. installation?

• 8.

Leak Tests. (if applicable):

a.

Have the tests been performed b.

Name of firm or person who performed the test c.

Does the licensee have records of leak test results

• 9.

On-Off Mechanism and Indicator Tests (if applicable):

a.

Have the tests been performed b.

Name of firm or person who performed the test c.

Does the licensee have records of on-off mechanism and H

indicator test

10. Has the device been moved from its original location? If so, by whom?

l

11. Does the licensee have personnel who are aware of the license conditions i

and responsible for assuring compliance with the license conditions?

Enclosure

= _ - - _ _ _ _ _

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12. Has the licensee made any transfer of source / devices? If so, were the source / devices transferred to specific licensees?

' *13. Your observations of the program conducted by the general licensee.

For.

example, are gauges in a dirty environment sc that labels become obscured?

Have gauges been removed from use and stored in uncontrolled areas, etc.?

14. Any observations regarding environment of use as it relates to stress

^

imposed on safety aspects of the gauge (e.g., use of a gauge on a slass melting furnace where'the gauge may be subjected to high temperatures).

15. Are you having difficulty in finding an' authorized recipient to purchase, dispose, or store any sources and/or devices that you no longer want? If yes, please elaborate.

• Question for general licensees only - will take only a few minutes to answer.

Note:

In some instances, one or more of the above items will not be applicable, e.g.

Item 8 would not apply to devices containing krypton-85 or tritium and Item 9 would not apply to devices containing tritium.