ML20248K433

Requests Issuance of Encl IP 87114 for Use by Regions. Summary of Comments & Resolutions Attached.This Document, When Issued Will Replace Existing Guidance for Insp of Fixed & Portable Gauge Programs Contained in IP 87100

ML20248K433
Person / Time
Issue date:	05/28/1998
From:	Cool D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Gillespie F NRC (Affiliation Not Assigned)
References
NUDOCS 9806100118
Download: ML20248K433 (57)

Text

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Msy 28, 1998 MEMORANDUM TO: Fr nk P. Gillespie, Director Division of Inspection and Support Programs, NRR FROM: Donald A. Cool, Director Division of Industrial and Medical Nuclear Safety, NMSS

SUBJECT:

REQUEST TO ISSUE INSPECTION PROCEDURE 87114, FIXED AND PORTABLE GAUGE PROGRAMS We request that you issue the attached Inspection Procedure (IP) 87114 for use by the regions. It was distributed to the regions in draft form for review and comment. A summary of I

comments and resolutions is also attached.

This is another in a series of inspection procedures that will result from revision of the inspection procedures in IP 87100 to eliminate the checklist approach and substitute a performance based approach using an " Inspection Record" and " Inspection References." This document, when issued, will replace the existing guidance for inspection of fixed and portable gauge programs contained in IP 87100.

Attachments: As stated, cc: R. Blough, RI D. Collins, Ril C. Pederson, Rill R. Scarano, RIV J. Ricci, TTC CONTACT: Ronald E. Zeiac, NMSS/IMNS (301)415-6316 DISTRIBUTION:

NRC Central File S. Baggett IMNS r/f S. Merchant NMSS r/f R. Borchardt G. Klingler DOCUMENT NAME: G:iucy/87114is.

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. May 28, 1998 l_ e .. .

MEMORANDUM TO: Frank P. Gill ,spie, Director 4- Division of Inspection and Support Programs. NRR FROM: Donald A. Cool, Director Division of Industrial and Medical Nuclear Safety, NMSS

SUBJECT:

REQUEST TO ISSUE INSPECTION PROCEDURE 87114, FlXED AND PORTABLE GAUGE PROGRAMS We request that you issue the attached Inspection Procedure (IP) 87114 for use by the regions. It was distributed to the regions in oraft form for review and comment. A summary of comments and resolutions is also attached.

This is another in a series of inspection procedures that will result from revision of the inspection procedures in IP 87100 to eliminate the checklist approach and substitute a performance based approach using an

• Inspection Record" and " Inspection References." This document, when issued, will replace the existing guidance for inspection of fixed and portable gauge programs contained in IP 87100.

Attachments: As stated.

cc: R. Blough, RI D. Collins, Ril C. Pederson, Rill R. Scarano, RIV J. Ricci, TTC CONTACT: Ronald E. Zelac, NMSS/IMNS (301)415-6316 DISTRIBUTION

. NRC Central File S. Baggett IMNS r/f S. Merchnt NMSS r/f R. Borchardt G. Klingler DOCUMENT NAME: G:iucyis71141s PDR1YEs_NO WAWTa0 WTa50 gyt;$_je b iMNs/SEc6 E *

/ 198 To recotve a copy of this document indicate in the box:

"C"= Copy w/o att/ encl "E" = Co'gr w/att/end."N" = No copy Mm OFC 3GB C .RGB n IMNSp s NAME helac/II hiccohe y _

MboE DATE 4/;13 /98 .5/.1 7 /98 SJJ /98 OFFICIAL RECORD COPY

_ . . . . . _ _ _ _ _ _ _ _________________a

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[*' i UNITED STATES j j

,- NUCLEAR REGULATORY COMMISSION l o WASHINGTON, D.C. 2055Mm01

'% #"g May 28, 1998 l

l MEMORANDUM TO: Frank P. Gillespie, Director Division ofInspection and Support Programs, NRR FROM: Donald A. Cool, Director d

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Division of Industrial and Medical Nuclear Safety, NMSS '[b j

SUBJECT:

REQUEST TO ISSUE INSPECTION PROCEDURE 87114, FIXED AND PORTAGLE GAUGE PROGRAMS We request that you issue the attached Inspection Procedure (IP) 87114 for use by the regions. It was d'stributed to the regions in draft form ':r review and comment. A summary of comments and resolutions is also attached.

This is another in a series of inspection procedures that will result from revision of the inspection procedures in IP 87100 to eliminate the checklist approach and substitute a performance based approach using an " Inspection Record" and " Inspection References." This document, when issued, will replace the existing guidance for inspection of fixed and portable gauge programs contained in IP 87100.

Attachments: As stated.

cc: R. Blough, Ri D. Collins, Ril C. Pederson, Rlli R. Scarano, RIV J. Ricci, TTC CONTACT: Ronald E. Zelac, NMSS/IMNS (301)415-6316

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DOCUMENT ISSUING FORM To: NRR. DISP. Director From: Donald A. Cool. Director. Division of Industrial and Medical Nuclear Safety. NMSS (Originating Director)

, 1. Number and title of document 87114. Fixed and Portable Gauce Programs

2. Type of document 3. Type of action

_ Manual Chapter (MC) .2Linspection Procedure (IP) .X.New document (number)

_ Appendix _ Temporary Instruction (TI) _X. Revision (of IP 87100)

_Technied Guidance .__10 CFR Guidance _ Deletion 4.a. If a new IP is being prepared, state its need or purpose, whether it is for the " Core" Inspection Program, the SALP category it applies to, the direct inspection hours needed to perform it, and the inspection frequency,

b. If a Tl or IP is being revised, state the reason for the revision, and if applicable,the resulting change in direct inspection hours or FTE, if any.

Core Program: _Yes.X_No SALP Category: N/A DIE: N/A inspection Frequency: N/A Statement: Ibis orocedure is to be usesi in olace of IP 87100 for the insoection of figggl_and oortable aauce oroaram licensee oroarams. It reflects a performance based insoection anoroach. Comoared to IP 87100. it chances the format. eliminates the field notes. adds an insoection record section. and adds a references section.

c. For any proposed addition in direct inspection hours that results from a or b above, state the increase in proposed hours and identify where the proposed corresponding reduction in direct inspection hours is to occur (Note: the total " Core" hours is a fixed number and cannot be increased without permission from the NRR Office Director).

DIE increase resulting from 4a or 4b: N!% '

Proposed reduction, IP No.:NB Details of reduction: NB

d. If new training requirements or the revision of currenttraining requirements are needed as 9

_______________a

the result of the new IP, Tl or revision of existing procedures, these should be identified.

The group responsible for establishing and presenting the training should also be identified New training course required? _Yes XNo Revision to existing training course? _2L.Yes _No Lead Branch for establishing training:

Training to be given by:

Brief description of proposed training: Add discussion on the revised format of the orocedure.

5. Attach a WP6.1 floppy disk with a hard copy of the document.

a. Has document been reviewed by the technical editor? lyes _No If not, state why

6. Special exhitsits (anything that cannot be put in Wordperfect such as drawings, reductions, '

or block diagrams) are attached? .

_Yes 1No _N/A

7. Attach a summary of comments and resolutions. State comment,its source, and if not adopted why. Is summary attached? lyes _No __N/A

8. All approval signatures must be obtained in the order listed below: Check items 1-7 above and ensure all documents (floppy disk with file in WordPerfed & hard copy, special exhibits, comment summary and resolution, and any background inkrmation) are attached to this form before r ing ) for agpr als.

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a. onal . Zelac 4 d.

Originato Date 'l '

PlPB, Manual Coord1Date

b. o ohine con e.

( Originator Branch Chief /D6t PIPB, Branch Chief /Date

c. Dor M o (4h# f.

IMNS Division Director /Date DISP, NRR, Director /Dats

9. Date received by PIPB 10. Change notice number and issue Manual Coordinator date:

END

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INSPECTION PROCEDURE 87114 FIXED AND PORTABLE GAUGE PROGRAMS COMMENT RESOLUTION Beaion Ill:

No comments.

Reaion IV:

1. Comment:

I We believe the revised IPs have still not hit the mark in terms of field note format. We believe an all-or-nothing approach to the " narrative vs. checklist" format is not the best solution. The perspective in Region IV is that some inspection areas lend themselves more to a ge'1eral narrative format and rome to a more detailed checklist format. This would suggest more of a hybna field note format.

1. Resolution:

The consensus that prompted revision of the 87100 series procedures was that it was desirable to discontinue the checklist approach to inspection of materials facilities. The decision to use the present format was jointly reached by regional and headquarters management at the January,1997 Divisio a Directors Counterpart Meeting. However, if experience with the use of the narrative :)rmat procedurer indicates that such a hybrid would be the optimum approach, then the matter will be reconsidered.

2. Comment:

The new field notes now require extensive narrative description, requiring much more time to record (more like a formal renort). This new approach requires more work to document the inspection.

2. Resolution:

Not every element of the procedure must be addressed during each inspection. See the prominently boxed guidance in Appendix A, Fixed and Portable Gauge inspection Record, at the beginning of Part Il-Inspection Documentation (page A-3). The documentation required for areas covered need only provide sumcient detail to describe what activities and procedures were observed and/or demonstrated to, in part, substantiate the inspection findings.

Also, the format is identical to that in IP 87115, " Nuclear Medicine Programs," which was pilot tested without significant comments on this point. Finally, the decision to use the present format was jointly reached by regional and headquarters management at the l

January,1997 Division Directors Counterpart Meeting; it is not subject to change at this time.

3. Comment:

The former check list field notes have been reduced to appendices called " Inspection References." These references are too general to be of real use during the heat of an inspection.

3. Resolution:

Appendix B is intended to serve as a listing of applicable regulatory documents that may prove helpful to the inspector in preparing for an inspection. It was not provided to serve as a prompt dunng an inspection. Also, the inspection record was prepared to briefly state summary topics, without details requiring review during an inspection, and to specifically avoid the appearance of a checklist approach. From these perspectives, we believe Appendix B should remain as it is.

4. Comment:

The new format requires the inspector to flip back and forth between the Appendix B inspection reference requirements and the main body of the inspection record.

4. Resolution:

See Comment / Resolution No. 3, above. No changes were made.

5. Comment:

Absence of the currently used yes/no checklist makes it more difficult to track and record during the inspection whether the licensee was in compliance with a specific requirement.

6. Resolution:

The consensus at the January,1997 Division Directors Counterpart Meeting was that the checklist approach focused too much on inspector activity, documenting the inspection procesr., rather than on licensee performance. The preferred approach was that inspections should be conducted following planning to measure licensee performance. Accordingly, no changes were made.

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7. Comment:

Documenting the inspection findings after the inspection in a pure narrative format as proposed is also less efficient of the inspector's time and is not as effective. For example, unless the narrative specifically addresses a particular inspection item, the inspection record will not document its results or whether that specific item was even reviewed during the inspection. The Yes/No/NA format at least captures this information in a more efficient manner, with a following narrative description of any problem area identifed.

7. Resolution:

The inspection Documentation portion (Part II) of the inspection Report (Appendix A) can be completed in the field to record items covered during the inspection, rather than being filled out later by transcription from notes. Items to be covered during the inspection can be entered in the appropriate section of the documentation form while planning for the inspection. Field-decision additional items being covered would be added to the appropriate section of the documentation form during the inspection. Also, see Comment / Resolution Nos.1 & 2. above, for related discussion. No change'., were mace.

8. Comment:

The current detailed formats are very helpful to the inspector while performing the inspection and should be preserved for such use. if only [one] form is to be used, then it would be better to drop the proposed pure narrative format and retum to the old detailed check list to document inspections. A preferable alternative, however, would be to take the middle ground whereby the rnost important inspection items or items grouped into a category would be check listed.

8. Resolution:

See Comment / Response No.1, above. No changes were made.

9. Comment:

I also disagree with the approach taken in the draft inspection procedures to de-emphasize the review of records (see page 1 of the procedure). Records review is important since it often leads to identification of problem areas in the licensee's program that often do not see the light of day even if personnel are interviewed or observed in the performance of licensed activities.

9. Resolution:

The wording is similar to that in the presently used IP 87100, Licensed Materials 3

__L_ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . . . _ _ . . . _ _ _ . __ _ _

Programs, and identical to that which appears in the also presently used IP 87110, Industrial / Academic Research Programs, and IP 87120, industrial Radiography Programs, in all of these IP's, the intent is to emphasize the 'importance of a mix of activities, including review of records, to an effective inspection. No changes we's made.

10. Comment:

Instead of providing detailed guidance to the inspector to maximize his or her time doing performance-based inspections, the procedure often sends the inspector to another procedure or reference to find a requirement or agency policy.

10. Resolution:

The revised inspection procedures reviewed at the January,1997 Division Directors Counterpart Meeting, being comprehensive and using a checklist approach, were deemed too long, too detailed, and too difficult to use in the field. The present narrative-approach inspection procedure was prepared to relieve those difficulties. It is simplified and separates field-use inspection documentation from sections associated with inspection preparation and inspection final administrative closure. Also, the format is identical to that in IP 87115, " Nuclear Medicine Programs," which was pilot tested without comment on this point. Accordingly, no changes were made.

11. Comment:

9 Change Appendix B to provide more specific references to regule.nons or standard license conditions instead of just general references.

11. Resolution:

l The consensus that prompted revision of the 87100 series procedures was that it was desirable to discontinue the checklist approach to inspection of materials facilities.

Revising Appendix B in the manner suggested would resurrect the checklist approach in disguised form, and would therefore defeat the intent of the revisions. Appendix B is intended to be simply a list of references that may prove helpful to the inspector in preparing for an inspection. Therefore, no changes were made.

12. Comment:

The use of letters to designate both appendices and attachments to appendices is confusing. Change one to numbers.

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12. Resolation:

To reduce possible confusion, the pages of the attachment have been changed to AA-1, etc. to distinguish them from the pages of the appendix (A-1, etc.). The letter designation for the attachment (A) to the appendix (A) has been retained. The format is identical to that in IP 87115, " Nuclear Medicine Programs," which was pilot tested without comment on this point.

13. Comment:

Whenever possible, include the specific value or enteria instead of directing the inspector to recalculate it each time. Instead of:

"With the pssible exception of americium-241, possession of quanWes of material in fixed and portable gauges that would require submission of a financial assurance instrument by these licensees is unlikely." (Section 03.11.d.

paragraph 3),

replace with:

"If the amount of americium-241 possessed by the licensee is less than 100 Curies, it is unlikely that the licensee is required to submit a financial assurance instrument. For more details, see 10 CFR 30.35 (B) and (D) and Appendix B to Part 30."

13. Resolution:

The wording in the referenced section was changed to the following.

"If the amount of americium-241 possessed by f.e licensee is less than 100 Curies, it is unlikely that the licensee possesses quantities of radioactive material in fixed and portable gauges that would require submission of a financial assurance instrument. For more details, see 10 CFR 30.35 (b) and (d) and Appendix B to Part 30."

The inspection procedure was reviewed to locate any other sections where changes in line with the suggestion could be made. None were found. However, in line with the suggestion of the comment, the wording of Section 02.09.a, " Area Surveys," was modified to more specifically indicate the inspection requirement.

14. Comment:

(Section 02.08.b,

• Operating and Emergency Procedures")

NRC does not normally approve gauge licensees' emergency procedures, as licensees are allowed to simply commit to implementing and maintaining appropriate procedures.

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See page M-6 of Appendix M to NUREG-1556, Vol.1.

14. Resolution:

The inspection requirement stated in this section is explained in the corresponding l

inspection guidarece section,03.08.b. The inspector is to verify that the emergency procedures in use agree with those found in the license application and amendments.

Their origin is not the issue. Also, the inspection procedure is for use with both portable and fixed gauges. Draft NUREG-1556, Vol. 4, Consolidated Guidance About Fixed Gauge Licenses, directs a whole class of applicants to submit their own emergency procedures, not referencing the NUREG procedures. Accordingly, no changes were made.

l

15. Comment:

(Section 02.11.e, " Decommissioning Timeliness")

The above guidance appears to conflict with part of the guidance provided by John Hickey, Chief, Low-Level Waste and Decommissioning Branch, in his memorandum of August 12,1997, subject title: IMPLEMENTATION OF 10 CFR 30.36 (d). Specifically, paragraphs 2 snd 3 state that licensees are not required to notify NRC for those licensees who decide to permanently cease principal activities, or when no principal ,

activities have been conducted for a period of 24 months, in any separate building or outdoor area, unless the separate building area contains residual radioactivity such that the building or outdoor area is unsuitable for release with NRC requirements. It would be preferable to direct the inspector to obtain the last leak tests for affected sources and to tell the licensee to submit an amendment request to delete the building which is no longer used.

15. Resolution:

The results of the most recent leak tests for affected sources would not provide information about previous occurrences (for example, leaking sources) which could impact the decommissioning of separate huildings, outdoor areas, or the entire siM.

Notwithstanding this, the section was modified by the addition of the following sentence to reflect the comment.

Note that for separate buildings or outdoor areas, the decommissioning timeliness rule requirements do not apply unless the buildings or outdoor areas contain residual radioactivity rendering them unsuitable for release in accordance with NRC requirements.

16. Comment: i i

(Section 02.11.e, " Decommissioning Timeliness") )

Change the reference in the last sentence from '" Decommissioning Timeliness  !

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Inspection Field Notes," Attachment B to Appendix A,' to '" Decommissioning Timeliness Inspection Attachment," Attachment A to Appendix A.'

16. Resolution:

The indicated changes were made.

17. Comment:

(Section 03.03.a, " Organization")

l This section states, in part, "If the owner or individuals named in the license have l changed, determine whether the licensee has submitted appropriate notification to l NRC."

! The regulations require more than notification of the NRC. They require that the NRC approve the transfer before it occurs. Specifically,10 CFR 30.34(b) requires, in part, that no license be transferred to any person unless the Commission gives its consent in writing. The IP should read " ..lf the ownership of the license has changed, determine whether the licensee had, per the requiremeras of 10 CRF 30.34(b), requested and received prior approval for the change from NRC." If the licensee had not received prior approval to an ownership change, have it submit the required information detailed in Attachment 1 to information Notice 89-25, Revision 1.

17. Resolution:

The inspection elernent is broader than ownership changes. It also covers personnel changes. Using the suggested wording would eliminate the guidance on personnel changes. To incorpora:e the thought of the suggested change, the section was modified by adding the following sentence at its end.

Note that transfer of control of any license to any person requires prior approval for the change from NRC (10 CFR 30.34(b)).

18. Comment:

(Section 03.05, " Facilities")

This section states, in part,

• Descriptions of the facilities are generally found in the application for a license and subsequent amendments that are usually tied down to a license condition."

Where in the past this statement was true, under the Appendix M to NUREG-1556, Vol.

1, licensees are no longer required to submit a description of the facilities. They only need to submit an address, and rooms and buildings used are not identified. Also, if 7

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they use a location as a temporary job site for less than 180 days, they need not inform NRC.

18. Resolution:

The comment applies to portable gauge licenses but not to fixed gauge licenses. For added guidance, the following sentence was added to the section.

Note that facility descriptions are not required for licenses issued using the guidance in NUREG-1556, Vol.1, " Consolidated Guidance About Portable Gauge Licenses: Program-Specific Guidance About Portabfe Gauge Licenses," published May,1997.

19. Comment:

(Section 03.06.b, " Equipment and Instrumentation")

Most fixed and portable gauge licensees do not have Part 21 procedures, and during the monthly conference calls it has been suggested that this is an area not to review.

19. Resolution:

The draft guidance provided for fixed gauge licenses in draft NUREG-1556, Vol. 4,

" Consolidated Guidance About Materials Licenses: Program-Specific Guidance About Fixed Gauge Licenses," published October 1997, indicates that procedures to ensure compliance with 10 CFR 21.21 for gauge malfunction are to be developed, implemented, and maintained. Accordingly, no change was made.

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20. Comment:

l

(

(Section 03.07.a, " Receipt and Transfer of Licensed Materials")

Gauge licensees are normally not required to do receipt surveys because the sources are special form and they are less that a Type A quantity; see the exemptions in 10 '

CFR 20.1906(b)(1) and (2). Also, package receipt survey procedures are not normally found in the license application. In fact, Appendix M to NUREG-1556, Vol.1, in the section on Material Receipt and Accountability, only requires the licensee to conduct physicalinventories.

20. Resolution:

The section was extensively revised to concentrate guidance to comparison of submitted procedures, if any, to procedures in use. The descriptiori of appropriate content for a receipt procedure was deleted, as that is a licensing concem, not an inspection matter.

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21. Comment:

(Section 03.07.b, " Authorized Uses")

The section states, in part, " Licenses will list the isotopes, physical or chemical forms, and the maximum possession limits."

Many portable gauge licenses do not list the maximum possession limit, and Appendix M to NUREG-1556, Vol.1 does not require this information. They are tied only to the limits in 10 CFR 30.35(d).

21. Resolution:

Licenses for both fixed and portable gauges typically have possession limits for each isotope which limit the activity on a per-source basis, to the maximum activity specified in the registration issued by NRC or an Agreement State. The wording was changed to read: "...and the per-source maximum possession limits."

22. Comment:

(Section 03.08.b,." Operating and Emergency Procedures")

The section states, in part, "The emergency procedures will be approved by the NRC and reviewed and updated by the licensee. Any revision requires an amendment to '

the license."

Licensees' emergency procedures are not approved by the NRC, and revisions to the emergency procedures do not require an amendment to the license. See item 10, Radiation Safety Program-Operating & Emergency Procedures in Appendix M to NUREG-1556, Vol.1.

22. Resolution:

Few portable gauge licenses have been issued to-date under the Consolidated Guidance (NUREG-1556, Vol.1), where reference to but not submission of emergency procedures is possible. Previously, specific emergency procedures were required in the license application. To cover both situations, the section wording was modified to the following.

The emergency procedures will be as approved by or descri%d to NRC, and reviewed and updated by the licensee. Revisions of emergency procedures approved by NRC require amendments to the license.

. Corresponding modification was also made to Section 02.08.b, " Operating and -

Emergency Procedures."

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_.__._m ___ . _ _ ______.___ _ _ _ _ _____ _ _ . ___ _ . _ _ _ _l___-_

23. Comment:

(Section 03.09.a. " Area Surveys")

This portion of the IP is not very helpful to the inspector. Licensees only need to have access to a survey meter in the event of an incident. Most portable gauge licensees do not conduct radiation surveys with survey meters, and many do not possess a survey meter. lf they do a survey at all, it is a calculation to demonstrated compliance with public dose limits. They must be able to demonstrate compliance with the 100 millirem / year limit. A work sheet and table would be useful. The table would list the various models of gauges and the dose rates at 1 ft. based on the i manufacturers' literature. The work sheet would incorporate the guidance in Appendix 1 to NUREG-1556, Vol.1.

23. Resolution:

The guidance to which the comment applies is provided only for inspections of either fixed or portable gauge licensees that are required to conduct surveys. Particularly because such licensees are few in number and inspector experience with them would correspondingly be limited, providing guidance for these inspections is thought to be beneficial.

The task of the inspector for most gauge license inspections is to review the required licensee documentation demonstrating that unmonitored occupationally exposed iMividuals and individual members of the public are not likely to exceed Part 20 dose limits. The Consolidated Guidance document (NUREG-1556, Vol.1 and, when final, Vol. 4, for fixed gauges) is available to the inspector and would hopefully be useful in preparing for gzge licensee inspections, including this item. Accordingly, no change was made.

24. Comment:

(Section 03.10, " Radiation Protection")

The section state that "10 CFR 19.13(b) requires that each licensee shall advise each worker annually of the worker's dose as shown in dose records maintained by the licensee."

Under current licensing guidance as described in Appendix M to NUREG-1556, Vol.1, personnel monitoring in not required if the licensee can demonstrate by documentation that unmonitored personnel are not likely to receive a dose exceeding 10% of allowable Part 20 limits.

l 24. Resolution:

The sechon also states: "The licensee must advise all workers for whom monitoring is -

required (and, therefore, dose records are required)." to complete the guidance.

Therefore, no change was made.

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26. Comment:

(Section 03.11.d," Financial Assurance and Decommissioning")

The section states, in part, "If applicable, inspectors should identify any areas that have been released for unrestricted use since the last inspection and perform confirmatory measurements to verify that radiation and contamination levels are l below release limits. Licensee survey records and other documentation should be l reviewed to verify that the basis for releasing each area is adequately documented in j the licensee's decommissioning records."

l This portion is not very helpful to the inspector. Most gauge licensees do not conduct physical surveys of areas where gauges were stored or installed. Instead, they use the results of leak tests on their gauges to demonstrate that the sources were not leaking; therefore, there cannot be any residual contamination. The IP should acknowledge this fact and suggest that the inspector review and obtain leak tect results, inventory records, and other records to determine if there had been any potential contamination. The licensee may need to submit a license amendment, and the inspector should suggest to the licensees that they contact the license reviewer.

Buildings or areas cannot be released without the last leak test resu'ts.

26. Resolution:

The guidance in this section is broad so as to cover both licensees which have had leaking sources and those which have not. Confirmatory measurements by the inspector are appropriate. The licensee may have survey records in the documentation of the decommissioning. The section was modified to specifically include leak test records in the documentation to be reviewed. Also, see Comment / Resolution No.15, above.

27. Comment:

(Section 03.11.d," Financial Assurance and Decommissioning")

The next paragraph in 6 03.11.d addresses financial assurance. The [ earlier) comments [about providing specific criteria] apply.

27. Resolution:

See Comment / Resolution No.13.

28. Comment:

(Section 03.14, " Generic Communications of Information")

The IP should provide guidance on who in NRC to contact if the licensee is not receiving generic communications. j 11

~ 28. Resolution:

The following wording was added to the section.

If the licensee is not receiving applicable generic communications from NRC, the_ inspector should (through regional licensing staff, if this function is separate) verify that the licensee is entered in the License Tracking System (LTS) with correct codes, points of contact, and addresses.

29. Comment:

(Section 03.15, " Notifications and Reports")

To make the IP useful to the inspector, it should include a summary table on reporting requirements.

29. Resolution:

" Notifications and Reports" is a topic (No.12) in the inspection report (Appendix A, Part II, " Inspection Documentation"). Areas to be considered are provided in the associated inspector prompt. Appendix B, " Fixed and Portable Gauge inspection

. References," for use in preparing for an inspection, has a corresponding section d

- (No.12) which provides a listing of the relevant regulatory citations for this topic and these licensees. Finally, an objective of the current revisions was to create an inspection procedure of reasonable length, avoiding duplication whenever possible.

For these reasons, no change was made.

30. Comment:

(Section 03.18. " Year-2000 issues")

$ 03.18 references Information Notice 97-61, "U.S. Department of Health and Human Services Let'er to Medical Device Manufacturers, on the Year 2,000 Problem." Neither fixed nor portable gauge licensees were sent copies of this IN.

30. Resolution:

The indicated text was eliminated.

31. Comment:

(Section 03.18, " Year-2000 issues")

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. This section also states, "inforr'n the licensee of the NRC list server on the year-2000 )

problem, and encourage its use in sharing any identified problems and solutions."

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I The IP should facilitate the inspection process by providing the method of accessing the list server. Something like: "To subscribe to this list, internet e-mail may be sent to listproc@nrc. gov with the message: subscribe year-2000 usemame, where the usemame is the first and last name of the individual making the request (e.g., John Doe)."

31. Response:

Since the suggested wording is contained in IN 96-70, referenced in the same section of the guidance, it was not added. However, a prompt guiding the inspector

o IN 96-70 was added to the list server wording.

32. Comment:

9 03.20 refers several times to " inspection field notes." With the issuance of this new IP methodology, " inspection field notes are replaced by " inspection record."

The IP should be internally consistent with its terminology.

32. Resolution:

Wording in the referenced section and throughout the document has been modified accordingly.

33. Comment:

Draft IP 87114 does not address what to inspect regarding a licensee's program for cleaning and maintenance of portable and/or fixed gauges,if they choose to conduct non-routine maintenance in-house. See page M-8 and Appendix G of NUREG-1556, Vol.1. Failure to properly maintain gauges can result in greatly increased potential for significant radiation exposure from source shutters that are stuck in the open position caused by a lack of cleaning and maintenance.

33. Resolution:

It is highly unlikely that a licensee will conduct non-routine maintenance or other non-routine operations during the course of an inspection. Accordingly, to cover l this item, the inspector can review procedures and records, and interview designated staff. The specific obligations of the licensee for this item would appear in the license application and/or license amendment request (s). These obligations can be addressed under the following requirements sections:

5 02.03.d, " Authorized Users";

9 02.07.b " Authorized Users";

! 9 02.08.b, " Operating and Emergency Procedures";

9 02.10.b, " Radiation Protection Procedures"; and, possibly, 13

G 02.16, "Special License Conditions."

The corresponding guidance provided for most of these requirements sections would cover inspecting non-routine maintenance and/or non-routine operations without modification.

Additionally, a requirement section, 02.07.d," Maintenance of Gauges," ar d a l corresponding guidance section, S 03.07.d, " Maintenance of Gauges," were added to augment the existing procedure elements.

34. Comment:

Discussions of areas such as organization and management oversight are somewhat '

detailed. As these areas will differ greatly depending on the size and make up of 3 licensee, it might be a little confusing for inexperienced inspectors. They might spend _a great deal of time looking for management structure, etc. that isn't there.

34. Resolution:

The referenced guidance sections start ($ 03.03.a. " Organization") by noting that the organizational structure will usually be found in the license application [which the inspector should review prior to the inspection] and may involve one or more individuals. This should serve as a sufficient prompt for the less experienced i inspector, to avoid unnecessary time on this item during the inspection.

Accordingly, no change was made.

35. Comment:

Specific comments in the form of [a] redline and strikeout version of the Wordperfect IP file are attached.

35. Resolution:

The specific comments were all incorporated into the text.

14

NRC INSPECTION MANUAL IM08 INSPECTION PROCEDURE 87114 FIXED AND PORTABLE GAUGE PROGRAMS PROGRAM APPLICABILITY: 2800 l

l 87114-01 INSPECTION OBJECTIVES 01.01 To determine if licensed activities are being conducted in a manner that will protect the health and safety of workers and the general public.

01.02 To determine if licensed programs are being conducted in accordance with U.S. Nuclear Regulatory Commission (NRC) requirements.

87114-02 INSPECTION REQUIREMENTS Review of the licensed activities will be commensurate with the scope of the licensee's program. A determination regarding safety and compliance with NRC requirements will be based on direct observation of work activities, interviews with workers, demonstrations by workers performing tasks regulated by NRC, and independent measurements of radiation conditions at the facility, rather than exclusive reliance on a review of records. ,

1 In reviewing the licensee's performance, the inspector should cover the period from the last inspection forward. However, issues preceding the last inspection should be reviewed, if warranted by circumstances, such as incidents, non-compliance, or high radiation exposures.

Some of the following areas may not be applicable to all fixed and portable gauge licensees.

02.01 Preparation. Preparation will include reviewing documents, making travel arrangements. coordinating with appropriate staff, notifying appropriate State agencies, and selecting necessary equipment. In particular, the inspector shall identify whether any license amendments have been issued since the last inspection. or whether the licensee has informed NRC of any major program changes since the last inspection. The inspector shall also review regional event logs and files to determine if the licensee has had any incidents or events since the last inspection.

02.02 Entrance Briefina. When the inspector arrives at the licensee's facility, he/she will inform an available senior management representative of the purpose and scope of the inspection. '

Issue Date: XX/XX/XX ,

87114

02.03 General overview

.. a. Organization. Evaluate by: (1) interviewing the cognizant licensee representatives about the current organization of the program: (2) examining the licensee's organization with respect to changes that have occurred in personnel functions. responsibilities. and authorities since the previous inspection: and (3) identifying the reporting relationship and management structure between the licensee's executive management and the Radiation Safety Officer (RS0).

b. Scooe of Proaram. Evaluate by interviewing cognizant personnel to deter-mine the types, quantities, and use of licensed material, frequency of use. staff size etc.

c. Manaaement Oversicht. In the course of interviewing cognizant personnel, determine if management oversight is sufficient to provide the licensee staff with adequate resources and authority to administer the i

licensed program.

1. RSO - Determine whether the RSO has been ap,nointed, is named on the license. has sufficient authority, and fulfills the appropriate duties commensurate with the size and scope of licensed activities.

2. Audits - Verify that audits are performed as required. Verify that the results of the audits are reviewed and addressed.

3. ALARA (As Low As Is Reasonably Achievable) - Verify that the licensee's radiation protection program includes provisions for keeping doses ALARA.

d. Authorized Users. Determine that only authorized individuals perform and/or supervise licensed activities. Verify that these individuals are quali fied. Also verify that authorized users perform an appropriate level of supervision, as required by the license or regulations.

02.04 Walk-Throuah Orientation Tour. Perform a walk-through tour of the licensed facility to make general observations of the condition of the facility and the licensed activities being performed.

02.05 Facilities. Verify that the facility conforms to that described in the license application: that material receipt. use, and storage areas are secured; and that the licensee uses processes or other engineering controls to maintain doses as low as is reasonably achievable (ALARA).

02.06 Eauioment and Instrumentation.

a. Verify that equipment and instrumentation .are appropriate, operable.

calibrated. adequately maintained, and conform to the description in the license.

b. Verify that the licensee has established and implemented procedures to identify and report safety compcnent defects per the requirements of 10 CFR Part 21.

87114 , Issue Date: XX/XX/XX i

02.07 Materials

.. a. Receiot and Transfer of Licensed Material . Verify that the licensee is receiving packages and making transfers of licensed material in accordance with NRC and applicable U.S. Department _ of Transportation (DOT) regulations and license conditions.

b. Authorized Uses. Determine from observing the use of licensed material, discussing the activities with licensee personnel, and reviewing records, that the type quantity, and use of licensed material at the licensee's facility are authorized by the license and/or Sealed Source and Device (SSD) Registration Sheet (s). To the extent practical, ensure by physical confirmation, that the licensee's inventory is complete and accurate.

c. Material Security and Control. Verify that the licensee has established procedures for maintaining security and control of licensed material not in storage and that these procedures are understood and implemented by appropriate personnel. Verify that licensed material. in storage. in controlled or unrestricted areas, is secure from unauthorized removal or access. Verify that access to restricted areas is limited by the licensee.

d. &lintenance of Gauces. Verify that the licensee performs routine maintenance on all of its nuclear gauges. Verify that the manufacturer or a person specifically authorized by NRC or an Agreement State performs non-routine maintenance or repair of nuclear gauges.

02 08 Trainina i

a. General Trainina. Verify that appropriate training and initial instructions are being accomplished as specified in the license and/or regulations.

b. Doeratina and Emeraency Procedures. Verify that operational procedures are being followed by observing licensee personnel perform tasks at selected work stations and by a comparison of their performance with established procedures. Also examine the licensee's emergency procedures to determine that these procedures are as approved by or described to NRC.

Through discussions with workers, verify that licensee personnel understand and implement the established procedures and are aware of procedural revisions. Document in the inspection record what activities the inspector observed.

02.09 Area Radiation and Contamination Control

a. Area Survevs. Verify during observations and by direct measurements, that radiation levels in unrestricted areas are within the liinits of 10 CFR Part 20. and that any restricted areas are properly posted and access-controlled.

b. Leak Tests. Verify that leak tests of sealed sources are performed at the required frequency. Also verify that leak tests are analyzed in

=accordance with the license. If records of leak test results show ,

contamination in excess of the regulatory requirements. verify that the i licensee made appropriate notifications and removed the source from service.

Issue Datei XX/XX/XX ,

87114

]

l

_-___- ___-____________-__ _ L

02.10 Radiation Protection

• , a. Radiation Protection Proaram. Verify that a radiation protection program commensurate with the licensee's activities is being implemented and documented, and that the program is being reviewed at least annually, both for content and implementation.

b. Radiation Protection Procedures. Verify that changes in the radiological protection procedures made since the last inspection are consistent with regulations and license requirements. [ Note that some procedures may require prior NRC approval before the licensee can make changes.]

c. Instruments and Eouioment. If the licensee is. required to possess radiation detection instruments. verify that instruments and equipment are operable, and are calibrated and checked for appropriate response in accordance with license requirements and licensee procedures.

I d. Personnel Dosimeters. Verify that personnel dosimetry devices are worn I

by appropriate licensee personnel. Dosimetry devices appropriate to the type, energy, or emitted radiation, and the anticipated radiation fields, should have been issued to facility personnel. Verify that dosimeters are processed by a National Voluntary Laboratory Accreditation Program (NVLAP)-approved and-accredited processor. If no dosimetry devices are wo n. evaluate the licensee's demonstration that personnel are not likely to receive in excess of ten percent of the Part 20 occupational dose limit.

Verify that pursuant to 10 CFR 19.13(b) the licensee advises each monitored worker annually of the worker's dose as shown in records maintained by the licensee pursuant to the grovisions of 10 CFR 20.2106.

" Records of individual monitoring results.

02.11 Waste Manaaement

a. Waste Storace and Disoosal. Typically, gauges will be returned to the supplier / manufacturer or transferred to another licensee. Fixed and portable gauge licensees may store gauges that have been removed from service and are awaiting transfer from the licensee's facility. If such storage is performed. verify that the gauges are stored and controlled in a secure and safe manner, and that radiation levels in unrestricted areas surrounding the storage area do not exceed the limits of 10 CFR 20.1301.

" Dose limits for individual members of the public."

Sources contained in fixed and portable gauges are not usually transferred to a licensed land disposal facility. If the licensee transfers licensed material for offsite disposal, such as at a burial site, review the licensee's procedures and records to verify that each shipment is accompanied by a shipment manifest that includes all the required information. Also review the licensee's procedures and records to verify that each package intended for shipment to a licensed land disposal facility is labeled, as appropriate, to identify it as Class A. B, or C waste in accordance with the classification criteria of 10 CFR 61.55

[ Subsection III.A.2 of Appendix F to 10 CFR 20.1001-20.2401].

b. Transfer. Verify that wastes are transferred to an authorized recipient specifically licensed to receive radioactive waste.

87114 , Issue Date: XX/XX/XX

c. Records. Verify that records of waste storage. transfer. and disposal are maintained in accordance with the requirements of Part 20 and the license.

d. Financial Assurance and Decommissioning. Review the licensee's records of information important to the safe and effective decommissioning of the facility. Verify that the records are complete, updated. and assembled appropriately. in accordance with the requirements in 10 CFR 30.35(g).

Review the licensee's list of restricted areas required under 10 CFR 30.35(g)(3) and determine whether areas / rooms have been released since the last inspection. If areas / rooms have been released. verify that the licensee has adequately documented the basis for releasing each area / room and has adequately decontaminated any areas / rooms in which leaking sources were used or stored. Document the location of the released areas / rooms in the inspection record. and document your findings regarding the adequacy of the licensee's decontamination, if applicable.

With the possible exception of americium-241. possession of quantities of material. in fixed and portable gauges. that would require submission of a financial assurance instrument by these licensees is unlikely. If a financial assurance instrument is required, the following applies.

If a parent company guarantee or a self-guarantee is used to ensure decommissioning financial assurance, review the licensee's financial assurance file to ensure that 10 C R f art 30. Appendix A or Appendix C requirements are met.

Verify whether radiological conditions at the facility have changed since the financial assurance instrument and/or decommissioning plan was submitted such that either document needs to be changed to address the new radiological conditions. Examples of changes are radiological incidents such as leaking sources or source ruptures. Unauthorized changes by the licensee to processes, types, or quantities of licensed materials, possessed, or chemical or physical forms of licensed materials, may also prompt a reevaluation of whether the financial assurance instrument and/or decommissioning plan remains sufficient. If the inspector identifies changes that may affect the financial assurance instrument or decommissioning plan, he/she should immediately notify regional l

management.

e. Decommissioning Timeliness. Review compliance with the Decommissioning Timeliness Rule requirements in 10 CFR 30.36(d) through (h). This is one area of the inspection record that should be completed on all inspections.

If the license to conduct principal activities has expired or has been revoked: if the licensee has made a decision to permanently cease principal activities at the site, in any separate building, or at any outdoor area; or if there has been a 24-month duration when no principal activities were conducted at the site, in any separate building, or at any outdoor area. then the decommissioning timeliness requirements in 10 CFR 30.36. 40.42, 70.38 or 10 CFR Part 72 apply. If this is the case, complete in full the Decommissioning Timeliness Inspection Attachment."

Attachment A to Appendix A. Note that for separate buildings or outdoor areas. the decommissioning timeliness rule requirements do not apply unless the buildings or outdoor areas contain residual radioactivity rendering them unsuitable for release in accordance with NRC requirements.

Issue Date: XX/XX/XX 87114

02.12 Transportation. Verify that the licensee's procedures and documentation are sufficient to ensure that licensed material is transported in accordance with

.- 10 CFR Part 71 and DOT regulations for transportation of radioactive materials.

02.13 Postina and Labelina. Verify that the licensee has posted the appropriate documents, notices. forms, and caution signs. as required. Also verify that containers of licensed material are labeled appropriately.

02.14 Generic Communications of Information. Confirm that the licensee is receiving the applicable bulletins. information notices. NMSS Licensee Newsletter, etc. Verify that the licensee has taken appropriate action in response to these notices.

02.15 Notifications and Reoorts. Determine compliance with the regulations and license requirements for notification and reports to NRC.

02.16 Soecial License Conditions. If applicable, review the licensee's compliance with any special license conditions.

02.17 Independent and Confirmatory Measurements. Compare and verify, on a sampling basis, survey results or data that are used by the licensee to show compliance with the regulations or license conditions. Conduct independent measurements to ascertain the radiological conditions of the facility. Conduct

these independent measurements on all inspections under this inspection l procedure, unless warranted by special circumstances. If independent measurements were not made, provide a justification in the inspection record explaining why independent measurements were not performed. The inspector shall use radiation detection instruments that are calibrated. at a minimum, on an annual basis.

02.18 Year-2000 Issues. Verify that the licensee has reviewed its computer software and embedded systems to ensure that any potential year-2000 problems have been identified and corrected.

02.19 Exit Meetina. The inspector will conduct an exit meeting with senior licensee management and the RSO to discuss the preliminary inspection findings, including any apparent violations, safety-related concerns, and any unresolved items identified during the inspection.

02.20 Post-Insoection Actions. After an inspection, the inspector shall summarize the findings with his/her NRC supervisor. This is especially important if there are, or are expected to be, controversial issues arising from the findings.

Inspectors shall also meet with regional licensing staff when any pertinent licensing issues are raised during the inspection, when inspection findings impact on any licensing actions, or to give feedback on how the licensee has addressed recent licensing actions. This meeting shall be documented in the l

inspection record.

1 Additionally, in some instances, inspection findings will warrant communication with enforcement staff. Office of Investigations staff. State liaison staff, or Federal agencies with whom NRC has Memoranda of Understanding (MOUs). Similarly, if information related to year-2000 problems and solutions is obtained, it is to be conveyed to the NMSS Year-2000 Coordinator.

87114 ,

Issue Date: XX/XX/XX

The inspector will ensure that inspection findings are clearly documented, and reported to the licensee as appropriate. The inspector shall also follow the

.. requirements of Inspection Manual Chapter (IMC) 0620. " Inspection Documents and Records." regarding notifying the licensee that retained information is subject to public disclosure and giving the licensee the opportunity to request withholding it (see IMC 0620. Section 04.06.b.).

87114-03 INSPECTION GUIDANCE General. An examination of the licensee's records should not be considered the primary part of the inspection program. Rather, observations of activities in progress , equipment, facilities and use areas, etc., are seen as a better indicator of the licensee's overall radiation safety program than a review of records, alone.

Some of the requirement and guidance sections of this procedure instruct the inspector to " verify" the adequacy of certain aspects of the licensee's program.

Whenever possible. " verification should be accomplished through discussions, observations, and demonstrations.

In the records reviewed. look for trends such as increasing doses. Records such as surveys, receipt and transfer of radioactive materials, training. and utilization logs may be examined randomly until the inspector is satisfied that the records are being maintained and are complete. Other records that are more closely related to health and safety (such as personnel dose-monitoring records and incident reports) should be examined in detail. The type of records that were reviewed and the time seriods covered by these records should be noted in the appropriate " Basis for rindings" section(s) of the inspection record.

Retain a copy of each pertinent record that is needed to substantiate an inspection finding, such as a violation. Those copies shall be attached to the inspection record or, when applicable to a written inspection record. When an inspector identifies an apparent violation, he/she should gather copies from the licensee, while on site, of all records that are needed to support the apparent violation. In general, inspectors should use caution before retaining copies of licensee documents, unless they are needed to support apparent violations:

expedite the inspection (e.g., licensee materials inventories): or make the licensing file more complete. In all cases where licensee documents are retained beyond the inspection, follow the requirements of IMC 0620. Especially ensure that the licensee understands that the retained record will become publicly available, and give the licensee the opportunity to request withholding the information, pursuant to the requirements of 10 CFR 2.790(b)(1).

The inspector should keep the licensee apprised of the inspection findings throughout the course of the inspection and not wait until the exit meeting.

Whenever possible the inspector should keep NRC management informed of significant findings (e.g. , safety hazards, willful violations. and other potential escalated enforcement issues), identified during the course of the inspection.

03.01 Preparation. Before the inspection, the inspector should do the following:

e~ Review the licensee's previous inspection history (at a minimum review the past two inspections), the license, and the status of any allegations or Issue Date: XX/XX/XX , 87114 l

incidents. Note the licensee's commitments in response to previous violations, for followup during the inspection:

e Review regional event / incident logs, event / incident files. and the docket file to determine whether the licensee was involved in any incidents or events. If NRC did receive notification of an incident, review that incident during the inspection and document the licensee's followup in the inspection record:

e In the inspection record, complete the administrative information the inspection compliance history the listing of any license amendments or program changes since the last inspection, and the description of any incidents or events that have occurred since the last inspection; e Determine the dates that the licensee submitted the most recent financial assurance instrument and decommissioning plan (if applicable);

e Discuss the licensee's program with previous inspector (s) and/or license reviewer (s). as necessary; e Notify the appropriate State radiation control program personnel:

• Review pending licensing actions:

e Obtain a map of the area and/or directions:

e Make travel arrangements and prepare itinerary; e Select calibrated instruments and perform source check:

e Select appropriate documents: and e Select appropriate equipment to take.

In selecting the appropriate documents. the inspector should consider taking'the applicable regulations inspection record. generic communications license. NRC forms, etc.

In selecting the ap3ropriate equipment tha inspector should consider the licensee to be inspected. The equipment may include safety glasses, safety shoes, etc.

During the inspection, focus (among other areas) on whether the licensee is in compliance with any license amendments issued since the last inspection or with any program changes described by the licensee since the last inspection. This requires review of documentation submitted in support of the licensing action, before the inspection. The inspection represents NRC's first opportunity to verify whether the licensee has enacted the most recent changes to the license.

03.02 Entrance Briefina. After arriving on site, the inspector should inform the licensee's management representative of the purpose and scope of the inspection to be performed. This notification should be made as soon as practical after arriving on site. However, in certain instances (i.e. .

unannounced inspections at temporary field sites) the inspector may choose to inform the licensee of his/her presence on site after initial observations of licensed activities' currently in progress.

87114 , Issue Date: XX/XX/XX

The purpose of the entrance briefing is to inform licensee management that an inspection is being conducted. and to indicate the tentative schedule for

.e discussing or reviewing selected inspection items with various licensee staff personnel. However. in some instances. the inspector may only need to inform management of NRC's presence on site. and apprise management that an exit briefing will be conducted, at the end of the inspection, which will detail the inspection findings.

This is often an opportune time for the inspector to identify personnel to be interviewed. Scheduling interviews will enhance inspector efficiency and give the licensee the opportunity to have the most knowledgeable individuals present to respond in the areas being inspected.

Certain inspection items involving visual observations and/or records review are better performed unannounced; therefore, these types of items should not be discussed during the entrance briefing.

03.03 General Overview. The inspector will interview the cognizant licensee representatives to gain information concerning organization, scope, and management oversight of the radiation safety program.

a. Organization. The licensee's organizational structure will usually be found in the license application and may involve one or more individuals.

Determine the reporting structure tetween executive management and the RSO. Determine whether the RSO has suf ficient access to licensee management. Through discussions with licensee staff, the inspector should determine if changes in ownership or staffing have occurred. If the owner or individuals named in the license have changed, determine whether the licensee has submitted appropriate notification to NRC. This information must be provided whenever changes in ownership or personnel are made (except for some licenses where only responsibilities are defined). Ask licensee management if changes have occurred. or are anticipated, and ask 3ersonnel to confirm (to the inspector's satisfaction) that no changes lave taken place. If there have been no changes in the organization since the previous inspection. there is no need to pursue this element in further detail. Note that transfer of control of any license to any person requires prior approval for the change from NRC (10 CFR 30.34(b)).

The inspector should review any organizational change in the RSO position, authorities, responsibilities, and reoorting chains. The inspector should be sensitive to changes that reduce the ability of the RS0 to resolve concerns or issues related to the safe conduct of the radiation protection program. The inspector should ask licensee management and the RSO about the RSO's authority and about any changes that may impact on the RS0's duties, responsibilities, or effectiveness.

b. Scone of Proaram. Through discussions with licensee personnel, the inspector can obtain useful information about the types and quantities of material, frequency of use. incidents, temporary job site locations, etc. .

which cannot always be gained by reviewing records alone. This is also an opportunity for the inspector to discern the actual size and scope of the licensee's program, and to determine if significant changes have occurred since the previous inspection.

The portable gauges possessed by the licensee are required to be as described in the Sealed Source and Device (SSD) Registration Certificates or Sheets, unless a license amendment was submitted by the licensee and Issue Date: XX/XX/XX , 87114

,o approved by NRC which allowed modification of a device. Licensees should

, have copies of or access to these SSD Certificates in addition to the

.o manufacturers' manuals for operation and maintenance.

The manufacturer's name, model number of each gauging device in which sealed sources will be used, and the number of its registration-certificate are not identified in portable gauge licenses. Furthermore.

the manufacturer's name and model number of each sealed source used in-each gauging device, along with its registration certificate number, are not identified on the license. In addition, licensees do not have to amend their license to obtain new source / device combinations. Therefore, inspectors will not be able to look at the license to identify the number and types of gauges the licensee possess. However.'one way to determine which gauges the licensee has in its possession is to review their most recent semi-annual inventory record.

c. Manaaement Oversicht. The inspection is a verification of the licensee's implementation of the required program. In the review to verify implementation, the inspector should pay particular attention to the scope of the program: frequency of licensee audits and the use of qualified auditors: procedures for recording and reporting deficiencies to management: and methods and completion of followup actions by management.

1. P50 - The RSO is the individual. appointed by licensee management and identified on the license who is responsible for implementing the radiation safety program. The inspector should verify that this individual is knowledgeable about the program, and ensures that i activities are being performed in accordance with approved procedures and the regulations. The inspector should verify tlat. when deficiencies are identified. the RS0 has sufficient authority, without prior approval of licensee management, to implement corrective actions, including termination of operations that pose a threat to health and safety.

2. Audits - The frequency and scope of audits of the licensed program will vary. However, note that at a minimum licensees are required, by 10 CFR 20.1101(c). to review the radiation safety program content and implementation at least annually. The results of audits should be documented. Examine these records with particular attention to deficiencies identified by the auditors, and note any corrective actions taken as a result of deficiencies found. If no corrective actions were taken, determine why the licensee disregarded deficiencies identified during audits, and whether the lack of corrective actions caused the licensee to be in non-compliance with regulatory requirements.

d. Authorized Users. Authorized users may either be named in the license application or be appointed by the licensee, depending on the type of license issued and/or the wording in the license. For those appointed by

' the licensee. verify that the authorized user is trained in accordance with the approved criteria and has knowledge commensurate with operational duties.

Determine that the authorized users are personally performing or, if permitted in the license. supervising the authorized work, rather than someone else not named in the license. The level of supervision will.

depend on the wording in the license conditions or regulations. Some 87114 1 , Issue Date: XX/XX/XX

, ~

licenses have conditions such as " . used by or under the supervision of. " For some licenses that have the condition ". . under the direct

,e supervision of ." the authorized user must be physically present at the facility for easy contact or to observe the individual (s) working.

Another phrase used is " may only be used by . ." Finally. " . under the direct supervision and physical presence of " means the authorized user must directly supervise and be present at the work station.

Considering the many license condition phrases, the inspector must exercise judgment to interpret the role of the authorized users.

When the wording of the license condition is "... used by or under the supervision of .. " an authorized user named on the license is considered to be supervising the use of licensed materials when he/she directs personnel in the conduct of operations involving the licensed material.

This does not imply that the authorized user must be present at all times during the use of such materials. The authorized user / supervisor is responsible for assuring that personnel under his/her supervision have been properly trained and instructed and is responsible for the supervision of operations involving the use of licensed materials whether he/she is present or absent.

03.04 Walk-Throuah Orientation Tour. The inspector should make initial observations of licensed activities to determine that materials are being safely handled and that good health ohysics I ractices are followed. The inspector should look at areas of use and storage to make an initial assessment of the licensee's ALARA program with regard to facility design, engineering controls, house-keeping practices, etc. The inspector should ensure that observations of activities are documented in the inspection record.

03.05 Facilities. Descriptions of the facilities are generally found in the application for a license and subsequent amendments that are usually tied down to a license condition. The actual or as-built facility should be configured to provide safe working areas separated from unrestricted areas and sufficient access controls to preclude unauthorized entry. Adequate protection of shield integrity must be provided. including fire protection. The inspector should also be aware of potential industrial safety hazards for referral to the U.S.

Department of Labor's Occupational Safety and Health Administration.

03.06 Eouioment and Instrumentation

a. Equipment and instrumentation should be appropriate to the scope of the licensed program. The inspector should verify that if the licensee possesses survey instrumentation. the instrumentation has the appropriate l range of use. The inspector should also verify that the survey instruments are calibrated at the appropriate frequency and checked for operability before use. All survey and monitoring instruments possessed should have current calibrations appropriate to the types and energies of radiation to be detected. Maintenance of safety-related components must be performed by authorized persons.

b. Inspectors should verify that licensees have procedures for reporting defects in accordance with 10 CFR Part 21. Fixed and portable gauge licensees need only address identification and reporting requirements.

Issue Date: XX/XX/XX , 87114

. o 03.07 Materials

.,o a. Receiot and Transfer of Licensed Materials. Depending on the size of the licensed program, the package receipt and transfer procedures'may be found in the license application. When available, these procedures should be carefully reviewea before an inspection is conducted. By discussions with the licensee, determine' if submitted procedures have been changed or modi fied. Some changes will require a license amendment, whereas minor changes (updating telephone numbers, editing procedures for clarity. .etc.)

may not require NRC approval. Randomly examine procedures used by the licensee to determine if they are in accordance with those identified in the license application. if 'any, and determine whether these changes warrant a license amendment. If gauges arrive or are being transferred during the course of an inspection, the inspector should observe, when practical, personnel performing the associated procedures.

Inquire into the licensee's practices, if applicable, of loaning, renting, or leasing nuclear gauges to other entities. If the gauge is loaned or rented to another licensee, ensure that the transfer is properly completed and appropriate records are maintained. If the loan or rental is to a non-licensee. ensure that control and safety of possession and use of the source is maintained by the gauge owner.. Verify that the methods used to ensure such control are adequate.

The inspector should determine if inventories for each radionuclides are within the license limits. Records of inventories should indicate / demonstrate that the materials on hand at any one time are within the licensee's possession limit. Licensee's inventory records should contain 1) the radionuclides and amount (in units of becquerels or curies) of byproduct material in each sealed source: 2) the manufacturer's name, model number, and serial number (if appropriate) of each device containing byproduct material: 3) location of each sealed source and device; and 4) the date of the inventory. When practical, the records examined should be compared with a physical inventory of materials possessed.

b. Authorized Uses. Authorized uses of licensed material will be found in the licenses and license applications. Licenses will list the isotopes, physical or chemical forms, and the per-source maximum possession limits.

The inspector should physically examine the inventory of radioactive material on hand or examine records of receipt and transfer. to determine that quantities and forms are as authorized. Additionally the inspector should verify that the licensee's use of licensed material is limited to that which is authorized in the license,

c. Material Security and Control. Examine areas where licensed materials are used and stored. Storage areas should be locked and have limited and controlled access. Licensed material should be under constant surveillance or physically secured. The licensee should have procedures for access controls. Controls may include a utilization log to indicate when licensed material is taken from and returned to storage areas. The ins)ector should verify that adequate controls are in place and worcing effectively.

d. Maintenance of Gauaes. Licensees must routinely clean and maintain gauges according to the manufacturer's recommendations and instructions.

Procedures for routine cleaning and lubrication of the source rod and shutter mechanism (e.g. , to remove caked dirt. mud, asphalt, or residues 87114 , Issue Date: XX/XX/XX

r from the source rod: lubricate the shutter mechanism) must include ALARA provisions 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. The license will contain a condition if the licensee is authorized to perform non-routine maintenance on gauges.

03.08 Trainino

a. General Trainina. Certain kinds of training and instruction are found in the regulations; how they are implemented will be found in the license.

Discuss with the licensee how, and by whom, training is conducted, and the content of the training provided to workers (generally found in .the license application).

Verify. pursuant to 10 CFR 19.12. that initial instructions have been given to workers who are likely to receive in a year an occupational dose in excess of 1 mSv (100 mrem). Under the basic instructions. ,it is management's responsibility to inform the workers of precautions to take when entering a restricted area, kinds and uses of radioactive materials in that area. exposure levels, and the types of protective equipment to be used. The workers should also be informed of the pertinent provisions of NRC regulations and the license. and the requirement to notify management of conditions observed that may, if not corrected, result in a violation of NRC requirements. Also verify that authorized users and workers understand the mechanism for raising safety concerns.

Of the training program elements in the license application. training

given to authorized users, and those individuals under the supervision of authorized users, is of primary importance. One or more users of radioactive materials should be interviewed to determine that they have received the required training, both in the basic instructions and in that specified in the license application. Note that the training should be provided to workers before the individual's performance of licensed activities. Examine the periodic retraining program and records.

Randomly examine . records of training of personnel and attendant examinations or tests (if applicable) to the extent that the inspector is satisfied that the training program is being implemented as required. 1 Where examinations are required. read a few of the examination questions to ascertain that they are indicative of what the worker should know to carry out his/her responsibilities.

The inspector should also observe related activities and discuss the radiation safety training received by selected individuals to ensure that appropriate training was actually received by these individuals.

Authorized users and supervised individuals should understand the radiation protection requirements associated with their assigned activities. The licensee's radiation safety training may include, but is not limited to, demonstrations by cognizant facility personnel, formal lectures, testing. films, and " dry runs" for more complex or hazardous operations.

Issue Date: XX/XX/XX , 87114

b. Operatina and Emeroency Procedures. Operating and emergency procedures will be found in license applications and may vary from step-by-step

,, procedures to more generalized procedures for lower-inspection-priority licenses. The emergency procedures will be approved by the NRC. and reviewed and updated by the licensee. Any revision requires an amendment to the license. All authorized users should have copies of the operating and emergency procedures with them during the use of gauges.

Some licensees may have agreements with other agencies (i.e., fire, law

, enforcement, and medical organizations) regarding response to emergencies.

l Discuss with the licensee's representatives what has been done to ensure that agencies (involved in such agreements) understand their roles in emergency responses.

03.09 Area Radiation and Contamination Control

a. Area Survevs. lhe inspector may ask the licensee to spot-check radiation levels in selected areas, using the licensee's own instrumentation. if the licensee possesses survey instrumentation. However, the inspector must use NRC's instruments for independent verification of the licensee's measurements. (The inspector's instruments shall be calibrated and source checked before he/she leaves the regional office.)

If practical, observe how licensees conduct surveys, if required, to determine the adequacy of surveys. Also, note the types of instruments used, and whether they are designed and calibrated for the type of radiation being measured. Verify that the licensee conducts surveys in unrestricted areas and controlled areas to show compliance with the public dose limits.

b. Leak Tests. Through discussions with licensee personr.el and/or by demonstration of leak test procedures, the inspector should verify that leak tests are performed in accordance with the manufacturer's recommendations and/or license. Verify that required periodic inventories are being conducted.

03.10 Radiation Protection. Specific guidance is set forth in NRC Inspection Procedure (IP) 83822. " Radiation Protection."

Section 19.13(b) requires that each licensee shall advise each worker annually of the worker's dose, as shown in dose records maintained by the licensee.

Verify, through discussions with workers and management, and through recor.is review, that the licensee has advised workers of their doses annually. The licensee must advise all workers for whom monitoring is required (and, therefore.

dose records are required). The licensee must advise these workers of internal and external doses from routine operations, and doses received during planned special exposures, accidents, and emergencies. The report to the individual must be in writing and must contain all the information required in 10 CFR 19.13(a).

03.11 Waste Manaaement

a. Waste Storaae and Discosal. For fixed and portable gauge licensees, this will normally be limited to gauges that have been removed from service and are awaiting transfer. Verify that the waste is protected from fire and the elements, that package integrity is adequately maintained, that the storage area is properly ventilated, and that adequate controls are in 87114 , Issue Date: XX/XX/XX

r--

e effect to minimize the risk from other hazardous materials. Verify that the licensee has appropriate methods to track the items in storage.

Inspection effort should be directed at verifying that written procedures have been established in a manner approved by management. The procedur.es should be readily available to any persons having responsibility for low-level waste classification and preparation for transfer of such wastes to land disposal facilities. if appropriate.

For further inspection guidance. refer to IP 84850, " Radiation Waste Management - Inspection of Waste Generator Requirements of 10 CFR Part 20 and 10 CFR Part 61."

I b. Transfer. Ascertain if the licensee has an adequate method of determining l that recipients of radioactive wastes are licensed to receive such waste (i.e., licensee obtains a copy of the waste recipient's current license before the transfer).

c. Records. Each licensee is required to maintain records of the disposal of licensed material made under 10 CFR 20.2002-2005.10 CFR Part 61, and disposal by burial in soil. These records must be retained until the Commission terminates each pertinent license requiring the record. The inspector should review these records to verify that disposals are made in accordance with the applicable regulations, and that records are complete and accurate for each type of disposal.

d. Financial Assurance and Decommissioning. The decommissioning record-keeping requirements are applicable to all materials licensees, including sealed source licensees, and are specified in 10 CFR 30.35(g). These records should contain, among otner information: (1) records of unusual occurrences involving the spread of contamination in and around the facility, equipment, or site: (2) as-built drawings and modifications of structures and equipment in restricted areas where radioactive materials are used and/or stored, and locations of possible inaccessible contamination; and (3) records of the cost for decommissioning. This list is not all inclusive of the information and requirements given in 10 CFR 30.35(g). On all inspections the inspector should ensure that the licensee has such decommissioning records, that the records are complete.

that they are updated as required, and that the decommissioning records are assembled or referenced in an identified location.

If applicable, inspectors should identify any areas that have been releasea for unrestricted use since the last inspection and perform confirmatory measurements to verify that radiation and contamination levels are below release limits. Licensee survey recordu, source leak test results, and other documentation should be reviewed to verify that the basis for releasing each area is adequately documented in the licensee's decommissioning records.

With the possible exception of americium-241. possession of quantities of nterial in fixed and portable gauges that would require submission of a financial assurance instrument by these licensees is unlikely. If the licensee is required to address financial assurance, the following guidance applies. If the licensee uses a parent company guarantee or a self-guarantee as a funaing method. the inspector should verify that the licensee has a Certified Public Accountant certify each year that the licensee passes a financial test. The financial test ratios for Issue Date: XX/XX/XX , 87114

T parent-company guarantees and self-guarantees are specified in Section II.

Appendix A and Appendix C. respectively, to Part 30.

e. Decommissioning Timeliness. Although such an instance will be unusual at a gauge licensee.'s facility. the inspector should also identify any unused buildings or outdoor areas that remain contaminated from licensed operations and verify that the licensee is complying with regulations for.

timely decontamination and decommissioning and meeting the required schedules for licensee action. as specified in the Decommissioning Timeliness Rule [10 CFR 30.36(d) through (h)). If the decommissioning timeliness . requirements apply, the inspector must complete the Decommissioning. Timeliness Inspection Attachment. Attachment A to Appendix A.

The Decommissioning Timeliness Rule became effective on August 15. 1994.

In completing the Attachment B inspection record, specific guidance is needed regarding the timing of the notification requirements. If the license has expired or been revoked, or if the licensee has made a decision to permanently cease principal activities, and the licenree orovided NRC notification before Auoust 15. 1994, then August 15, 1994, is considered to be the date for initiating the decommissioning calendar (i .e. . date of notification). If tt.ere has been a 24-month duration in which no principal activities have been conducted at the location before the effective date of the rule, but the licensee did not notify NRC. then the 24-month time period of inactivity is considered to be initiated on August 15, 1994, and the licensee must provide notification to NRC within either 30 or 60 days of August 15.1996 (depending on wiuther the licensee requests a delay).

NRC has a stringent enforcement policy with respect to violations of the decommissioning timeliness requirements. Failure to comply with the Decommissioning Timeliness Rule (failures to: (a) notify NRC: (b) meet decommissioning standards: (c) complete decommissioning activities, in accordance with regulation or license condition; or (d) meet required decommissioning schedules without adequate justification) may be classified as a Severity Level III violation. and may result 'in consideration of monetary civil penalties or other enforcement actions, as appropriate.

Decommissioning timeliness issues can be complex. For situations where I an inspector has questions about the licensee's status ar.d whether the {

decommissioning timeliness standards apply. he/she should immediately contact regional management.

For planning and conducting inspections of licensees undergoing decommissioning, refer to IMC 2602. " Decommissioning Inspection Program for Fuel Cycle Facilities and Materials Licensees": IP 87104

" Decommissioning Inspection Procedure for Materials Licensees:" and the draft Decommissioning Manual Chapter and Handbook.

03.12 Transportation. The insoector should review: the licensee's hazardous material training: packages anc associated documentation: vehicles (including placarding. cargo blocking, and bracing, etc ): shipping papers: and any incidents reported to DOT. This is an ideal area for the inspector to make.

observations of licensee practices. especially for portable gauge licensees.

87114 , Issue Date: XX/XX/XX

I l

For further inspection guidance refer to IP 86740. " Inspection of Transportatial Activities." Inspectors should also refer closely to " Hazard Communications for Class 7 (Radioactive) Materials." the NRC field reference charts on hazard communications for transportation of radioactive materials, which contain references to the new transportation requirements. and are useful field references for determining compliance with the transportation rules on labeling, placarding shipping papers. and package markings.

03.13 Postina and Labelina. The inspector should determine whether proper caution signs are being used at access points to areas containing radioactive materials and radiation areas. Section 20.1903 provides exceptions to posting caution signs. The inspector should also randomly observe labeling on packages or other containers to determine that proper information (e.g.. isotope, quantity, and date of measurement) is recorded.

Areas with radiation hazards should be conspicuously posted, as required by 10 CFR 20.1902. Depending on the associated hazard, controls may include tape.

rope, or structural barriers to prevent access. Such controls may include, but are not limited to, di ect surveillance. locking the area, warning lights, and audible alarms. Areas occupied by radiation workers for long periods of time and I

common-use areas should be controlled in accordance with licensee procedures and be consistent with the licensee's ALARA program.

The inspector should also examine locations wtere notices to workers are posted.

l Applicable documents, notices. or forms should be posted in a sufficient number l of places to permit individuals engaged in licensed activities to observe them on the way to or from any particular licensed activity location to which the postings would apply.

03.14 Generic Communications of Information. Through discussions with licensee management and the RSO. the inspector should verify that the licensee is receiving the applicable bulletins. information notices. NMSS Licensee Newsletter. etc. , and that the information contained in these documents is disseminated to appropriate staff personnel. Also verify that the licensee has taken appropriate action in response to these NRC communications, when a response is required.

If the licensee is not receiving ap31icable generic communications from NRC the inspector should (through regional ~ icensing staff. if this function is separate) verify that the licensee is entered in the License Tracking System (LTS) with correct codes. points of contact. and addre nes.

03.15 Notifications and Reoorts. The inspector should determine the licensee's compliance for notifications and reports to the Commission. The licensee may be required to make notifications after loss or theft of material, overexposure, incidents. high radiation levels, safety-related equipment failure. etc.

Through discussions with licensee personnel, and by a review of representative records, the inspector should verify that notifications and/or reports were appropriately submitted to NRC.

Verify that the licensee has quick access to the telephone number of the NRC Operations Center.

03.16 Soecial License Conditions. Some licenses will contain special license conditions that are unique to a particular practice procedure, or piece of equipment used by the licensee. In these instances, the inspector should verify Issue Date: XX/XX/XX , 87114

that the licensee understands the additional requi rements. and maintains compliance with the special license conditions. The inspector should also note

.. that some special license conditions will state an exemption to a particular NRC requirement. I 03.17 Independent and Confirmatory Measurements. The inspector should perform independent and confirmatory measurements in restricted. controlled, and unrestricted areas of the licensee's facility. Measurements of dose rates at the boundaries of restricted areas should be performed at the surfaces of the most accessible planes. These measurements should be taken in licensed material use i areas, storage areas, etc. Confirmatory measurements are those whereby the '

l inspector compares his/her measurements with those of. the licensee's.

Independent measurements are those performed by the inspector independently of the licensee's measurements. To perform the independent or confirmatory measurement, use NRC radiation detection equipment that is calibrated, at a minimum, on an annual basis.

03.18 Year-2000 Issues. Verifying that the licensee has reviewed its computer software and . embedded systems to ensure that any potential year-2000 probleme have been identified and corrected can be accomplished. in part, by covering the following points: (a) confirm that the licensee received Information Notice (IN) 96-70. " Year 2000 Effect on Computer System Software": (b) inform the licensee of the NRC list server on the year-2000 problem (see IN 96-70) and encourage its use in sharing a'1y identified problems and solutions: (c) determine whether the licensee has identified any potential problems and if so, taken corrective action. (Note that if information related to year-2000 licensee-identified problems and associated corrections is obtained during the inspection, the inspector is to convey it to the NMSS Year-2000 Coordinator.)

03.19 Exit Meetina. When the inspection is over, there should be an exit meeting with the most senior licensee representative present at the facility.

If a senior management representative is unavailable for the exit meeting, the inspector may hold a preliminary exit meeting with appropriate staff on site.

However, there must be a formal exit meeting with a senior management representative (and the licensee's RSO. if not present at the preliminary exit meeting) as soon as practical after the inspection. This meeting will usually be held by telephone conference call.

During the exit meeting. the licensee representatives should be told the preliminary inspection findings --

including any apparent violations of regulatory requirements, safety-related concerns, or unresolved items identified

' during the inspection -- and the status of any previously identified violations.

The licensee must immediately address any significant safety concerns.

If the inspector identifies safety concerns or violations of significant regulatory requirements that affect safe operation of a licensee facility. the licensee must initiate prompt corrective action. The inspector should not leave the site until the licensee fully understands the concern and has initiated corrective action. If the inspector and the licensee disagree over how significantly the concern impacts continued safe operation of the facility, regional management should be notified immediately.

Although deficiencies identified in some areas (e.g. , workers' knowledge of the Part 20 requirements) are not always violations, the inspector should bring such deficiencies to the attention of licensee management at the exit meeting and also in the cover letter transmitting the inspection report or Notice of Violation.

87114 , Issue Date: _XX/XX/XX

03.20 Post-Insoection Actions. Regional office policy will dictate with whom the inspector will review his or her inspection findings (e.g. the inspector's

,. supervisor), following the guidance in IMC 2800. " Materials Inspection Program."

Thel inspector should discuss the findings in detail that is commensurate with the scope of the licensee's program. Violations, items of concern. and unresolved items should be discussed in sufficient depth for management to make appropriate decisions regarding enforcement actions, referral to other State and Federal agencies, and decisions on the scheduling of future inspections of the licensee's facility The inspector should also discuss inspection findings with licensing staff. This information exchange can be particularly useful if the licensee is having its license renewed or has recently submitted a license amendment request. The inspector should inform licensing staff about how the licensee has addressed (or failed to address) special license amendments or recent licensing actions.

Licensir.g information requested by the licensee should also be discussed with the licensing staff.

Inspectors should be aware that NRC has entered into several MOUs. with other Federal agencies, that outline agreements on items such as exchange of information and evidence in criminal proceedings. The inspector should ensure that the exchange of information relevant to inspection activities is made in accordance with the appropriate MOU.

The inspector may report the results of inspections to the licensee either by issuing an NRC Form 591 or a regional office letter to the licensee, following the guidance in IMC 2800. The inspector must also ensure that the findings are documented in the inspection record, in sufficient detail for the reader to determine what requirement was violated. how it was violated, who violated the requirement, and when it was violated. . The inspection record should not be used i as merely a checklist to note areas reviewed. It should be used to describe what procedures or activities were observed and/or demonstrated by the licensee during the inspection, and any items of concern identified that were not cited as a violation of regulatory requirements.

Inspectors may complete the inspection record either by hand or electronically.

If the inspector is documenting the inspection record in electronic format, the sub-items under major sections that are not applicable or not reviewed may be deleted. However, the heading itself (e.g. , " Radioactive Waste Management." or

" Transportation") should remain in the inspection record, and the inspector should enter appropriate remarks about why the section is not applicable 'or not reviewed.

For further inspection guidance, refer to Section 07.04 of IMC 2800.

87114-04 REFERENCES A listing of IMCs and IPs applicable to the inspection program for materials licensees can be found in Section 2800-11 of IMC 2800. These documents are to be used as guidelines for inspectors in determining the inspection requirements for operational and radiological safety aspects of various types of licensee activities.

Specific references to regulatory requirements can be located in the " Fixed and PortaMe Gauge Inspection Record" appendix, following this IP.

END Issue Date: XX/XX/XX , 87114

-Appendices:

5 A. " Fixed and Portable Gauge Inspection Record" B. " Fixed and Portable Gauge References' i

87114 , Issue Date: XX/XX/XX

• g l

APPENDIX A

.o FIXED AND PORTABLE GAUGE INSPECTION RECORD Region Inspection record No. License No.

Licensee (Name and Address): Docket No.

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Licensee

Contact:

Telephone No.

Priority: Program Code:

Date of Last inspection:

Date of This inspection:

Type of Inspection: ( ) Announced ( ) Unannounced

( ) Routine ( ) Special

( ) Initial Next inspection Date ( ) Normal ( ) Reduced ( ) Extended Justification for change in normal inspection frequency:

Summary of Findings and Actions:

( ) No violations cited, clear U.S. Nuclear Regulatory Commission (NRC) Form 591 or regionalletter issued

( ) Non-cited violations (NOV's)

( ) Violation (s), Form 591 issued

( ) Violation (s), regional letter issued

( ) Followup on previous violations inspector (s) Date (Sign Name)

(Print Name)

Approved Date (Sign Name)

(Print Name)

Issue Date: XX/XX/XX A-1 87114. Appendix A

I o a PART l-LICENSE, INSPECTION, INCIDENT / EVENT, AND ENFORCEMENT HISTORY

1. AMENDMENTS AND PROGRAM CHANGES:

(License amendments issued since last inspection, e program changes noted in the license.)

AMENDMENT # DATE SUBJECT

2. INSPECTION AND ENFORCEMENT HISTORY:

(Unresolved issues; previou; and repeat violations; Confirmatory Action Letters; and orders) i

3. INCIDENT / EVENT HISTORY:

(List any incidents, or events reported to NRC since the last inspection. Citing "None" indicates that regional event logs, event files, and the licensing file have no evidence of any incidents or events since the last inspection.)

87114, Appendix A A-2 Issue Date: XX/XX/XX

, b.

.o PART 11 -INSPECTION DOCUMENTATION References that correspond to each inspection documentation topic are in inspection Procedure 87114, Appendix B, " Fixed and Portable Gauge inspection References."

The inspeciion documentation part is to be used by the inspector to assist with the performance of the inspection. Note that not all areas indicated in this part are required to be addressed during RaCh inspection. However, for those areas not covered during the inspection, a notation ("Not Reviewed" or *Not Applicable") should be made in each section, where applicable.

All areas covered during the inspection should be documented in sufficient detail to describe what activities and procedures were observed and/or demonstrated. In addition, the types of records that were reviewed and the time periods covered by those records should be noted. If the licensee demonstrated any practices at your request, describe those demonstrations. The observations and demonstrations you describe in this report, along with measurements and some records review, should substantiate your inspection findings.

Attach copies of alllicensee documents and records needed to support violations.

i Note: Fill in relevant information for additional locations and temporary job sites. Note location involved and details at each location or site.

1. ORGANIZATION AND SCOPE OF PROGRAM:

(Management organizational structure; authorized locations of use, including field offices and temporaryjob sites; type, quantity, and frequency of byproduct material use; staff size; delegation of authority)

2. MANAGEMENT OVERSIGHT:

(Management support to radiation safety; Radiation Safety Officer (RSO); program audits or inspections; as low as is reasonable achievable (ALARA) reviews; control and supervision by authorized users)

Issue Date:.XX/XX/XX ,

A-3 87114 Appendix A

,3

3. FACILITIES:

(Facilities as described; uses; control of access; engineering controls; calibration facilities; shielding)

~ 4. EQUIPMENT AND INSTRUMENTATION:

(Operable and calibrated survey instruments; procedures 10 CFR Part 21 procedures)

5. MATERIAL USE. CONTROL. AND TRANSFER:

(Materials and uses authorized; security and control of licensed materials; and procedures for receipt and transfer of licensed material) l 87114, Appendix A ,A4 issue Date: XX/XX/XX l-E - - - -

. eu

6. - AREA RADIATION SURVEYS AND CONTAMINATION CONTROL:

(Radiological surveys; leak tests; inventories; handling of radioactive materials; records; contamination control; public doses)

7. TRAINING AND INSTRUCTIONS TO WORKERS:

(Training and retraining requirements and documentation; interviews and observations of routine work; staff knowledge of all routine activities; 10 CFR Parts 19 and 20 requirements; emergency response)

8. RADIATION PROTECTION:

(Radiation protection program with ALARA provisions; access control; dosimetry; exposure evaluations; dose and survey records and reports; annual notifications to workers; bulletins and other generic communications)

I i

Issue Date: XX/XX/XX ,

A-5 87114, Appendix A o__z__________ _ _ - - - - - - - - - - - - -

I I

9. RADIOACTIVE WASTE MANAGEMENT:

(Disposal or transfer of sources; packaging, control, and tracking procedures; records) l 1

10. DECOMMISSIONING:

(Records relevant to decommissioning; decommissioning plan / schedule; notification requirements; cost estimates; funding methods; financial assurance; and Timeliness Rule requirements; changes in radiological conditions since decommissioning plan was submitted)

11. TRANSPORTATION:

(Quantities and types of licensed material shipped; packaging design requirements; shipping papers; hazardous materials HAZMAT communication procedures; retum of sources; procedures for monitoring radiation and contamination levels of packages; HAZMAT training; and records and reports) 87114, Appendix A' A-6 issue Date: XX/XX/XX

.o o i

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.e

~ 12. NOTIFICATIONS AND REPORTS:

(Reporting and followup of theft; loss; incidents; overexposure; safety-related equipment failures; change in RSO, authorized user; and radiation exposure reports to individuals)

13. POSTING AND LABELING:

(Notices; license documents; regulations; bulletins and generic information; area postings; and labeling of containers of licensed material)

14. INDEPENDENT AND CONFIRMATORY MEASUREMENTS:

(Areas, both restricted and unrestricted, surveyed, and comparison of data with licensee's results and regulations; and instrument type and calibration date)

Issue Date: XX/XX/XX ,

A-7 87114. Appendix A

.t-

15. VIOLATIONS. NCVs. AND OTHER SAFETY ISSUES:

(State requirement and how and when licensee violated the requirement. For NCVs, indicate why the violation was not cited. Attach copies of all licensee documents needed to support violations.)

16. PERSONNEL CONTACTED:

[ldentify licensee personnel contacted during the inspection (including those individuals contactea by telephone.)

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Use the following identification symbols:

1. individual (s) present at entrance meeting

• Individual (s) present at exit meeting

17. PERFORMANCE EVALUATION FACTORS (PEFsi:

A. Lack of senior management involvement with the radiation safety program and/or RSO oversight ()Y()N B. Radiation Safety Officer too busy with other assignments ()Y()N C. Insufficient staffing ()Y()N D. Radiation Safety Committee fails to meet or functions inadequately ( ) N/A ()Y()N E. Inadequate consulting services or inadequate audits conducted () N/A ()Y()N Remarks (consider the above assessment and/or other pertinent PEFs with regard to the licensee's oversight of the radiation safety program): ,

l

18. Soecial Conditions or issues:

(Special license conditions; year-2000 effects of computer software and embedded systems) 87114, Appendix A A-8 issue Date: XX/XX/XX

I L

1 PART lli - POST-INSPECTION ACTIVITIES

, i

1. REGIONAL FOLLOWUP ON PEFs:

1

2. DEBRIEF WITH REGIONAL CTAFF:

(Post-inspection communication with supervisor, regionallicensing staff, Agreement State Officer; and/or State Liaison Officer) l

3. YEAR-2000 ISSUES:

(Convey, to the NMSS Year-2000 Coordinator, all year-2000 licensee-identified problems and corrective actions taken.) l l

I END issue Date: XX/XX/XX- A-9 87114, Appendix A C_______________----------- - - - - - - - - - - - - - - - - _ - - - - - - - - - - - - - - - - - - - - - - - --

APPENDIX A - ATTACHMENT A

>d DECOMMISSIONING TIMELINESS INSPECTION ATTACHMENT Licensee:

Date of Inspection:

1. COMPLIANCE WITH DECOMMISSIONING TIMELINESS RULE (NOTE: Repeat the answers given in Section 12 of the main body of the inspection record. The issues in subsequent sections are dependent on the answers to these questions.)

A. License to conduct a principal activity has expired or been revoked. ()Y()N B Licensee has made a decision to permanently cease principal activities, at the entire site, or at any separate buildings, or at any outdoor areas, including inactive burial grounds. ()Y()N C. A 24-month duration has passec in which no principal activities have been conducted under the license at the site, or at any separate buildings, or at any outdoor areas, including inactive burial grounds. ()Y()N I D. If "Yes" to either A or B or C above:

)

(1) Identify Site / Bldg / Area:

]

(2) Date of occurrence of A, B, or C:

i l

2. NOTIFICATION REQUIREMENTS A. Licensee has provided written notification to the U.S.

Nuclear Regulatory Commission (NRC) within 60 days of the occurrence of 1.A.,1.B., or 1.C. above ()Y()N If "Yes," date of notification:

B. If the licensee is requesting to delay initiation of the decommissioning process, the licensee has provided written notification to NRC within 30 days of occurrence of 1.A.,1.B.,

or 1.C, above. ( ) N/A ( ) Y ( ) N If "Yes," date of notification:

Basis for Findings:

Issue Date: XX/XXJXX AA-1 Appendix A, Att. A

, y

3. DECOMMISSIONING PLAN / SCHEDULE REQUIREMENTS A. Licensee is required to submit a decommissioning plan per 10 CFR 30.36(g),40.42(g),70.38(g), or 10 CFR Part 727 ()Y()N If "No" to 3.A., answer the following items B. - F.:

B. The decommissioning work scope is covereo by current license conditions. ()Y()N C. Decommissioning has been initiated within 60 days of notification to NRC, or NRC has granted a delay. ()Y()N D. If licensee has initiated decommissioning, give date the decommissioning was initiated:

Initiation date:

E. If decommissioning has been completed, it was completed within 24 months of notification to NRC. ( ) N/A ( ) Y ( ) N F. If decommissioning is still scheduled to be completed, it is on schedule to be completed within 24 months of notification to NRC. ( ) N/A ( ) Y ( ) N Basis for Findings:

I I

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l I

Appendix A, Att. A AA-2 issue Date: XX/XX/XX

l a *

.s's if "Yes" to 3.A., answer the following items G. - J.;

G. The decommissioning plan has been submitted to NRC within 12 months of notification. ()Y()N If"Yes," date of submittal:

If NRC approved, date of NRC approval:

H. Has the licensee submitted an alternative schedule request? ()Y()N If"Yes,"date of submittal:

1. If decommissioning has been completed, it was completed within 24 months after approval of the decommissioning plan. ( ) N/A ( ) Y ( ) N J. If decommissioning is still scheduled to be completed, it is en schedule to be completed within 24 months after approval of the decommissioning plan. ( ) N/A ( ) Y ( ) N Basis for Findings:

Violations identified, if any:

i I

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Issue Date: XX/XX/XX , AA-3 Appendix A, Att. A

__-_-__________-____________-_____________a

o -

. APPENDIX B

.U FIXED AND PORTABLE GAUGE INSPECTION REFERENCES

1. ORGANIZATION AND SCOPE OF PROGRAM NUREG-1556, Vol.1 Consolidated Guidance About Materials Licenses:

Program-Specific Guidance About Portable Gauge Licenses.

License application and applicable license conditions.

2. MANAGEMENT OVERSIGHT A. Radiation Safety Officer Applicable license conditions.

B. Audits, Reviews, or inspections 10 CFR 20.1101 Radiation protection programs.

10 CFR 20.2102 Records of radiation protection programs.

Applicable license conditions.

C. Use by Authorized Individuals Applicable license conditions. '

D. ALARA 10 CFR 20.1101 Radiation protection programs.

3. FACILITIES A. Access Control 10 CFR 20.1601,1602 Control of access to high/very high radiation areas.

10 CFR 20.1801 Security of stored material.

10 CFR 20.1802 Control of material not in storage.

Applicable license conditions.

B. Engineering Controls 10 CFR 20.1101 Radiation protection programs.

Applicable license conditions.

4. EQUIPMENT AND INSTRUMENTATION A. Survey instruments 10 CFR 20.1501 General.

10 CFR 20.2103 Records of surveys.

Applicable license conditions.

Issue Date: XX/XX/XX B-1 87114, Appendix B

?

. B. Safety Component Defects s J Applicable license conditions.

5. MATERIAL USE. CONTROL. AND TRANSFER A. License and Applicable License Conditions B. Security and Control 10 CFR 20.1003 Definitions.

10 CFR 20.1801 Security of stored material.

10 CFR 20.1802 Control of material not in storage.

C. Receipt and Transfer of Licensed Material 10 CFR 20.1302 Compliance with dose limits for individual members of the public.

10 CFR 20.1906 Procedures for receiving and opening packages.

10 CFR 20.1501 Surveys.

10 CFR 20.2103 Records of sur<eys.

10 CFR 30.41 Transfer of byproduct material.

10 CFR 30.51 Records of recaipt and transfer.

6. 6HEA RADIATION SURVEYS AND CONTAMINATION CONTROL A. Area Surveys 10 CFR 20.1302 Compliance with dose limits for individual members of the public.

10 CFR 20.1501 General.

10 CFR 20.2103 Records of surveys.

10 CFR 20.2107 Records of dose to individual members of the public.

Applicable license conditions.

B. Leak Tests and Inventories Applicable license conditions.

7. TRAINING AND INSTRUCTIONS TO WORKERS General 10 CFR 19.12 Instruction to workers.

Knowledge of 10 CFR Part 20 radiation protection procedures and requirements.

Applicable license conditions.

8. RADIATION PROTECTION A. Radiation Protection Program

1. Exposure evaluation 10 CFR 20.1501 General.

2. Programs 87114, Appendix B 'B-2 issue Date: XX/XX/XX J

• '. 10 CFR 20.1101 Rrdiation prot:ction programs.

[) B. Dosimetry -

1. Dose Limits 10 CFR 20.1201 Occupational dose limits for adults.

10 CFR 20.1202 Compliance with requirements for summation of external and internal doses.

10 CFR 20.1207 Occupational dose limits for minors.

10 CFR 20.1208 - Doses to an embryo / fetus.

2. External 10 CFR 20.1501 General.

10 CFR 20.1502 Conditions requiring individual monitoring of external and internal occupational dose.

Apolicable license conditions.

C. Records 10 CFR 20.2102 Records of radiation protection programs.

10 CFR 20.2103 Records of surveys.

10 CFR 20.2104 Determination of prior occupational dose.

10 CFR 20.2106 Records of individual monitoring results.

9. RADIOACTIVE WASTE MANAGEMENT A. Disposal 10 CFR 20.1904 Labeling containers.

10 CFR 20.2001 General requirements.

10 CFR 20.2103 Records of surveys.

10 CFR 20.2108 Records of waste disposal.

B. Waste Management

1. General 10 CFR 20.2001 Waste disposal: General requirements.

IP 84850 " Radioactive Waste Management - Inspection of Waste Generator Requirements of 10 CFR Part 20 and 10 CFR Part 61."

2. Waste storage areas 10 CFR 20.1801 Security of stored material.

10 CFR 20.1902 Posting requirements.

10 CFR 20.1904 Labeling containers.

Applicable license conditions.

3. Packaging, Control, and Tracking 10 CFR Part 20, Requirements for low-level waste transfer for Appendix F disposal at land disposal facilities and manifests.

10 CFR 20.2006 Transfer for disposal and manifests.

10 CFR 61.55 Waste classification.

10 CFR 61.56 Waste characteristics.

Issue Date: XX/XX/XX.- B-3 87114, Appendix B

'." 4. Trensf;r l ,) 10 CFR Part 20, Requirements for low-level waste transfer for Appendix F disposal at land disposal facilities and manifests.

10 CFR 20.2001 General requirements.

10 CFR 20.2006 Transfer for disposal and manifests.

5. Records 10 CFR 20.2103 Records of surveys.

10 CFR 20.2108 Records of waste disposal.

10. DECOMMISSIONING 10 CFR 30.36 Expiration and termination of licenses and decommissioning of sites and separate buildings or outdoor areas.

IMC 2602 Decommissioning Inspection Program for Fuel Cycle Facilities and Materials Licensees.

IP 87104 Decommissioning inspection Procedure for Materials Licensees.

IMC 2605 Decommissioning Procedures for Fuel Cycle and Materials Licensees.

NUREG/BR-0241 NMSS Handbook for Decommissioning Fuel Cycle and Materials Licensees.

11. TRANSPORTATION A. General NRC Charts Hazard Communication for Class 7 (Radioactive)

Materials.

10 CFR 71.5 Transportation of licensed material.

Tl 2515/133 Implementation of Revised 49 CFR Parts 100-179 and 10 CFR Part 71.

B. Shippers - Requirements for Shipments and Packaging

1. General Requirements 49 CFR Part 173, Class 7 (radioactive) materials.

Subpari 49 CFR 173.24 General requirements for packagings and packages.

49 CFR 173.448 General transportation requirements.

49 CFR 173.435 Table of A, and A2 values for radionuclides.

2. Transport Quantities 10 CFR 71.4 Definitions.

a. All quantities 10 CFR 71.4 Definitions.

49 CFR 173.410 General design requirements.

49 CFR 173.441 Radiation levellimitations.

49 CFR 173.443 Contamination control.

49 CFR 173.475 Quality control requirements prior to each shipment of Class 7 (radioactive) materials.

87114, Appendix B B-4 issue Date: XX/XX/XX

T

) 49 CFR 173.476 Approval of special form Class 7

. (radioactive) materials.

44

b. Limited quantities 49 CFR 173.421 Excepted packages for limited quantities of Class 7 (radioactive) materials.

49 CFR 173.422 Additional requirements for excepted packages containing Class 7 (radioactive) materials.

c. Type A quantities i

49 CFR 173.412 Additional design requirements for Type A packages.

49 CFR 173.415 Authorized Type A packages.

49 CFR 178.350 Specification 7A; general packaging, Type A.

d. Type B quantities IP 86740, Section 2 Inspection of transportation activities.

e. (LSA) material an i (SCO) 49 CFR 173.403 Definitions.

49 CFR 173.427 Transport requirements for low specific activity (LSA) Class 7 (radioactive) materials and surface contaminated objects (SCOs).

3. HAZMAT Communication Requirements 49 CFR 172.200-205 Shipping papers.

49 CFR 172.300-338 Marking.

49 CFR 172.400-450 Labeling.

49 CFR 172.500-560 Placarding.

49 CFR 172.600-604 Emergency response information.

C. H,^2 MAT Training 49 CFR 172.702 Applicability and responsibility for training and testing.

49 CFR 172.704 Training requirements.

D. Transportation by Public Highway 49 CFR 171.15 Immediate notice of certain hazardous materials incidents.

49 CFR 171.16 Detailed hazardous materials incident reports.

49 CFR 177.800 Purpose and scope of this part and responsibility for compliance and training.

49 CFR 177.816 Driver training.

49 CFR 177.842 Loading and unloading: Class 7 (radioactive) material.

12. NOTIFICATIONS AND REPORTS 10 CFR 19.13 Notifications and reports to individuals.

10 CFR 20.2201 Reports of theft or loss of licensed material.

10 CFR 20.2202 Notification ofincidents.

Issue Date: XX/XX/XX ,

B-5 87114, Appendix B

) 10 CFR 20.2203 Reports of exposures, radiation Isvels, and concentrations of

, radioactive material exceeding ths constraints or limits.

. / 10 CFR 30.50 Reporting requirements.-

13. POSTING AND LABELING 10 CFR 19.11 Posting of notices to workers.

10 CFR 21.6 Posting requirements.

10 CFR 20.1902 Posting requirements.

10 CFR 20.1903 Exemptions to posting requirements.

10 CFR 20.1904 Labeling containers.

10 CFR 20.1905 Exemptions to labeling requirements.

14. INDEPENDENT AND CONFIRMATORY MEASUREMENTS No references.

15. VIOLATIONS. NON-CITED VIOLATIONS. AND OTHER SAFETY ISSUES NUREG/BR-0195, Rev.1 NRC Enforcement Manual.

NUREG-1600 General Statement of Policy and Procedures for NRC Enforcement Actions.

16. EEBSONNEL CONTACTED No references.

17. PERFORMANCE EVALUATION FACTORS IP 87101 Performance Evaluation Factors.

i l

l l

END i

87114, Appendix B ,

B-6 issue Date: XX/XX/XX

.