ML22004A280

NUREG1556 Vol. 18 Rev. 1 App. B Checklist (1)

ML22004A280
Person / Time
Issue date:	01/04/2022
From:	Office of Nuclear Material Safety and Safeguards
To:
Park J,NMSS/REFS/ELRB
Shared Package
ML22004A136	List: ML22004A236 ML22004A246 ML22004A248 ML22004A275 ML22004A278 ML22004A280 ML22004A282
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Download: ML22004A280 (19)

Text

APPENDIXB SUGGESTED FORMAT FOR PROVIDING INFORMATIONiREQUESTED IN ITEMS 5 THROUGH 11 OF NRC FORM 31~

Suggested Format for Providing Information Requested in Items 5 through 11 of NRC Form 313

• Appendix B is designed to be used for all types of applicants requesting a :Service provider license. All applicants should complete Tables B-1 through B--4, as applitJ:able.

After selecting the applicable items that need to be addressed, refer to the'. corresponding sections in the NUREG. It is necessary for applicants to provide the level :of detail required for the individual types of seivice(s) requested in the application. Note that p~oviding information for very limited licerises (e.g., leak-test service provider) requires less info_i-mation than would be required for a commercial nuclear laundry or a waste management licens~. Applicants for service provider licenses- requiring authorization for types and quantities of material specific for broad scope licenses should refer to NUREG-1556, Vol. 11, "Consolidate_p Guidance About Material Licenses: Program-Specific Guidance About Licenses of Broad ~cope." Applicants for service provider licenses requiring authorization for research and developffient should refer to NUREG-1556, Vol. 7, "Consolidated Guidance About Material Licenses: ,Program-Specific Guidance About Academic, Research and Development, and Other LicenSes of Limited Scope Including Electron Capture Devices and X-Ray Fluorescence Analyzers." :

B-1

Table B-1. Items 5 & 6: Unsealed Radioactive Materials To Be PoJsessed and Proposed Uses Unsealed Tbtal Activity Use Radionuclide Chemical or Physical Form ~equested Code*

I - f/f Gas l\2f' Liquid -s-solid Other: Specify /1µ~ '-/0 u li Gas D Liquid Solid D Other: Specify I Gas Liquid Solid D Other: Specify Gas D Liquid Solid Other: Specify Is the a pp licant g oing to p ossess or take p ossession from its clients of' ur sealed radionuclides?

Provide a response and explain. Jif)..W w, 1) hE.-fyV~ttl t)Yt-ra 11vr t,t,ns&

J Yes No Explain: ~ }J<f).11y,8 yr,/11(J--r511!4V6y-f, cfa~Y 1~"

Table B-2. Items 5 & 6: Sealed Radioactive Materials To Be Poss, ssed and Proposed Uses M . ,1 Total Device Sealed Source ax1mure Radionuclide Manufacturer and Device Activity er Source Use (Sealed Source) Model No. Registration No. Sourc~ Activity Code 1- crt Va"<"1~?.:tS 'i.:1 t GJ.. J n-0-5Sl. ~ Vi:,;rJat.tS l(p-fd /cJ~d u I Is the applicant going to possess, or take possession from its clients of, sealed radionuclides and/or devices? Provide a response and explain. , P~ I Je ,~

j_t,,.(tw l5r ~p.J -rv'T 'rCC'-f(/ . 'fY'{' rC"rl,:,u .

O Yes No Explain: .....,,)1 f-yi--,w0fcrrcJ fo !pVf";!.i~n_eis--fo~~-k

. "e'WtY6 -/ti or>Jol>acvr.,11'/I~ as '('e,c.cM 1 ~ '

Table B- 3. Items 5 & 6: Source and Special uclear Materials To Be Possessed and 11 1sj% *'1171 Proposed Uses Source Material Material Mass Activit Use Code*

Depleted Kilograms Uranium Uranium-238 Grams MB Thorium-232 Grams MB Other: Specify Grams MB al Nuclea Uranium-234 Grams .

al Nuclea Material Mass Activit Use Code*

Uranium-235 Grams Plutonium-238 Grams Plutonium-239 Grams

• Use code represents the purpose for which licensed material will be possessed or used. Use codes are provided below B-2

Use Code* Low-Risk Activities:

A. analysis of Leak-Test Samples (no collection)

B. analysis of Environmental Samples (no collection)

C. sample Collection and Analysis of Leak Tests D. sample Collection and Analysis of Environmental Samples E. calibration of instrument/dosimeter using low-activity sources F. service/repair of gas chromatographs, X-ray fluorescence analyzers, and/or similar devices G. training/instruction to individuals on radiation safety-related topics  !

H. other low-risk services not identified above, where radioactive material is used for commercial service activities Use Code* High-Risk Activities:

I. service and/or repair of portable nuclear gauges (including remova,l of source rod)

J. service and/or repair of fixed gauges K. service and/or repair of fixed gauges mounted on a mobile object, Uke a truck or railcar L. storage of radioactive material for other entitles M. use of unsealed material in tracer studies (e.g., use inside pipes ih;a refinery)

N. use of remote activated robotics in radioactive contaminated areas;

0. calibration of survey instruments and personnel dosimetry equipment as a service for others.

• P. installation, radiation surveys, routine and preventive maintenance*; adjustment or repair of high-dose rate (HOR) remote afterloaders, teletherapy, or gamma stereotactic radiosurgery units that require access to the sealed source(s), drivjng units, or other electronic components that could expose the sealed source, reduc_'e the shielding, or compromise the radiation safety of the device or safety systems

• Q. installation, relocation, removal from service, disposal, radiation sU:rveys, routine or preventive maintenance, adjustment, training, or repair of (1) self-shielded irradlators [American National Standards Institute (ANSI)

Category l irradiators]. *

(2) Title 10 of the Code of Federal Regulations (1 0 CFR) Part 36 irradiators (ANSI Categories II, 111, and IV irradiators) --

B-3

R. nuclear laundry services S. retrieval of industrial radiography sealed sources T. decontamination and decommissioning services {NUREG-1 757, VOiume 1)

U. waste management services, including, packaging and repackaging of radioactive waste for transportation, commercial incineration, compaction, super com'paction, solidification, or vitrification V. other high-risk services not identified above, excluding activities inVolving critical mass quantities of special nuclear material

• If the applicant desires to perform tracer/field studies in which licensed material is deliberately released to the environment, please provide the following information: *

• a complete application describing the type and amount of material 10 be used, the location of use, and training and experience of the individual using Jhe material

• a copy of the applicant's operating and emergency procedures

• a description of the amount of radioactive material to be released it;l the field, decontamination procedures at the conclusion of the experiment,. i( appropriate, and procedures for minimizing releases '

• a description of the expected radiation dose to humans

• a sample agreement letter between the applicant and the applican('s customer acknowledging the use of radioactive materials at the customer's site.

• a letter from the appropriate state health authorities, indicating thatthey have reviewed the applicant's application and concur with the applicant's request B-4

Table B-4. Items 5.3 through 11: Training and Experience, Faciliti~s and Equipment, Radiation Safety Program , and Waste Disposal Item Description Nos. Title and Criteria Yes No NIA Attached RADIOACTIVE MATERIA L 5.3 Recordkeeping For Decommissioning Provide the following statement: Pursuant to i I 10 CFR 30.35(9), 10 CFR 40.36(f), and 10 CFR 70.25(9), and 10 CFR 70.51 (b )(3), as appropriate, we will maintain drawings and records important to decommissioning and will transfer these records to an NRC or Agreement State licensee before licensed activities are transferred. Furthermore, pursuant to 10 CFR 30.51(f), 10 CFR 40.61(f), and 10 CFR 70.51(a), as appropriate, prior to license termination , we will forward the records required by 10 CFR 30.35(9), 10 CFR 40.36(f), and 10 CFR 70.25(9), as appropriate, to the appropriate NRC regional office or to assign the records to the appropriate NRC regional office before the license is terminated."

5.4 Financial Assurance Financial assurance is not required for most service provider applicants. If the applicant is going to possess radioactive material but wants to keep the possession limits below the requirem ents for financial assurance, commit to the following statement:

'We shall restrict the possession of licensed material to quantities below the minimum limit specified in 10 CFR 30.35(d), 10 CFR 40.36(b),

and/or 10 CFR 70.25(d) for establish ing decommissioning financial assurance."

OR

_:::,. If financial assurance is required, submit evidence of financial assurance following the p,,,q'k,4

~

guidance in NUREG- 1 757, Volume 3. I ~t' B-5

Table B-4. Items 5.3 through 11: Training and Experience, Faciliti~s and Equipment, Radiation Safety Program, and Waste Disposal (Contin~ed)

Item II Description Nos. Title and Criteria Yes No N/A Attached 5.5 Emergency Plans II Low Risk Activities:

The applicant is not required to submit a D response to emergency plans during the licensing process.

If an emergency plan is required as described in 10 CFR 30.32(i), provide either:

An evaluation showing that the maximum off-site dose due to a release of radioactive materials D r/

would not exceed 0.01 Sv [1 rem] effective dose equivalent or 0.05 Sv [5 rem] to the thyroid; OR An emergency plan for responding to the release D D that contains the information specified in 10 CFR 30.32(i)(3).

7 lndividual(s) Responsible For Radiation Safety Program And Their Training Experience 7.1 Radiation Safety Officer Provide the name of the proposed RSO who will be responsible for ensuring that the licensee's rad iation safety program is implemented in accordance with approved procedures.

AND Demonstrate that the RSO has sufficient independence and direct communication with responsible management officials by providing a copy of an organizational chart by position and demonstrating day-to-day oversight of the radiation safety activities.

AND Confirm that the RSO will be available for emergencies and can be on-site within J

24-48 hours, if applicable.

AND B-6

Table B-4. Items 5.3 through 11: Training and Experience, Facilities and Equipment, Radiation Safety Program, and Waste Disposal (Continued)

Item Description Nos. Title and Criteria Yes No N/A Attached 7.1 Radiation Safety Officer Provide the specific training and experience of the RSO, and include the specific dates of training in radiation safety.

I

,~t,~~

Provide alternative information demonstrating that the proposed RSO is qualified by training and experience (e.g., Board Certification by the American Board of Health Physicists, completion of a bachelor's and/or master's degree in the sciences with at least one year of experience in the conduct of a radiation safety program of comparable size and scope).

OR 7.2 Authorized Users And Radiation Workers Provide either of the following:

A statement that "Before using licensed material, 'ri authorized users will receive the training described in Appendix D of NUREG-1 556, Volume 18, Revision 1, 'Consolidated Guidance About Materials Licenses: Program-Specific Guidance About Service Provider Licenses."'

OR A description of the training and experience for proposed authorized users.

AND A description of the radiation safety training involving the use of licensed material that will be provided as a service to customers , if training is provided by the service provider.

8 Training For Individuals Working In Or Frequenting Restricted Areas Provide either of the following:

A statement that "Before working in the vicinity of r£ licensed materials, personnel will have successfully completed training commensurate with assigned duties."

OR B-7

Table B-4. Items 5.3 through 11: Training and Experience, Facilities and Equipment, Radiation Safety Program, and Waste Disposal (Contin'r'ed)

Item Description Nos. Title and Criteria Yes No , N/A Altac)'led 8 Training For Individuals Working In Or l']

Frequenting Restricted Areas A description of the radiation safety training program, including topics covered, groups of workers, assessmen t of training, qualifications of instructors, and the method and frequency of refresher traininq.

9 Facilities And Equipmen t Low Risk Activities:

For service providers performing low-risk activities, no facility description is required.

Provide the location where these services will be pe1formed.

AND Indicate if services will be performed at temporary jobsites. No facility description is required.

High Risk Activities:

For service providers petforming the high-risk activities that will not take possession of radioactive material, provide the location where these services will be performed. Also indicate if services will be performed at temporary jobsites.

OR B---8

Table B-4. Items 5.3 through 11: Training and Experience, Faciliti,s and Equipment, Radiation Safety Program, and Waste Disposal (Continued)

Item Description Nos. Title and Criteria Yes No N/A Attached 9 Facilities And Equipment For those services listed in the high-risk group where permanent facilities are specifically identified on the license, provide the following information, as applicable to the service the 1,-r,Jt

~

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applicant intends to perform:

Submit a drawing or sketch of the proposed permanent facility that fulfills the following requirements:

1. Identify area(s) assigned for the receipt, J storage, security, preparation, handling, waste storage, and measurement of radioactive materials, including sealed sources and devices.

2. Show the relationship and distance between restricted areas and adjacent unrestricted I

areas.

3. Indicate the scale, or include dimensions on J each drawing or sketch. The same scale should be used for all sketches and drawings. The recommended scale is 1/4 inch = 1 foot. Drawings to this scale that do not fit on 8-1 /2 x 11-inch paper may be provided as sectional drawings. Please also include a compass directional arrow to indicate "North."

4. Specify shielding materials (e.g ., concrete, d lead) and means for securing radioactive materials from unauthorized removal.

5. Illustrate area(s) where explosive, d flammable, or other hazardous materials may be stored;

6. Identify area(s) where radioactive materials may become airborne. The diagram should J

contain descriptions of the ventilation systems, with pertinent airflow rates, filtration equipment, sample collection points, and monitoring systems; B-9

Table B-4. Items 5.3 through 11: Training and Experience, Facilities and Equipment, Radiation Safety Program, and Waste Disposal (Contin~ed)

Item Description Nos. Title and Criteria Yes No N/A Attached 9 Facilities and Equipment

7. Identify specialized handling tools, facility J safety interlocks designed to prevent operation of radiological safety systems, in the event that operation of a system could result in accidental exposure or release of material [e.gWJigh efficiency pa~late air (HEPA) filters, ventilation system, afety door interlocks, etc.] or equipmen ;

8. Identify radioactive waste handling

./

equipment that includes, for example, incinerators, compactors, solidification equipment, hold-up tanks, and sample collection points; In addition, describe:

1. Engineered safety systems (e.g£area £ monito:E interlocks, alarms);

2. Protective clothing (such as latex or rubber r/

gloves, lab coats or coveralls, respirators, booties, and face shields), auxiliary shielding, absorbent materials, secondary containers for wastewater storage for decontamination purposes, plastic bags for storing such items as contaminated items, etc., that will be available for use when handling unsealed or uncontained radioactive materials;

3. [The general location of each proposed rn' permanent facility (e.g., an industrial park, an office complex) and its current us( ] If any proposed permanent facility is a private residence, provide diagrams of the installation that include the building, the proposed restricted area or areas, and adjacent areas, including above and below the restricted areas; provide commitments that restricted areas do not include residential quarters, and explain how radiation levels in unrestricted areas will be maintained at less than 1 mSv [100 mrem]

per year.

B-10

Table B-4. Items 5.3 through 11 : Training and Experience, Facilities and Equipment, Radiation Safety Program, and Waste Disposal (Continued)

Item Description Nos. Yes No N/A Attached Title and Criteria 9 Facilities and Equipmen t

4. The proposed nuclear laundry facilities, if applicable, used for contaminated protective equipment and clothing . Specify how the contaminat ed waste water from the lau ndry machines or sinks is disposed. Operating and emergency procedures should address decontamination of the laundry area and equipment.

10 Radiation Safety Program 10.1 Operating and Emergency Procedures 11 Low Risk Activities:

Applicants who perform low-risk licensed activities are not required to submit operating procedures but should provide emergency procedures for all likely scenarios.

High Risk Activities:

Applicants who perform high-risk licensed tJ activities should submit their operating and emergency procedures for radiologica l conditions that might be encountered as part of their license application.

10.2 Material Receipt and Accountability Provide the following statement: "We will develop, implement, and maintain procedures for r/

ensuring accountabi lity of licensed materials at all times."

AND Provide the following statement, if applicable: d "We will comply with the National Source Tracking System (NSTS) reporting requiremen ts, as described in 10 CFR 20.2207."

AND B-11

Table B-4. Items 5.3 through 11: Training and Experience, FacilitiE!,s and Equipment, Radiation Safety Program, and Waste Disposal (ContinlJed)

Item Description Nos. Title and Criteria Yes No : N/A Attached 10.2 Material Receipt and Accountability Provide either of the following: J A statement that "Physical inventories will be conducted at intervals not to exceed 6 months, to account for all sealed sources and devices received and possessed under the license.

Records of inventory will be maintained for a period of 5 years from the date of each inventory, and will include the radionuclides, quantities, manufacturer's name and model numbers, and the date of the inventory."

OR A description of the procedures for ensuring that no sealed sources have been lost, stolen, or misplaced.

10.3 Radiation Monitoring Instruments Provide one of the following:

• Describe the instrumentation that will be used to perform the required radiological surveys and state that "We will use instruments that meet the radiation monitoring instrument specifications published in Appendix F of NUREG-1556, Volume 18, Revision 1, 'Consolidated Guidance About Materials Licenses: Program-Specific Guidance About Service Provider Licenses.' We reserve the right to upgrade our survey instruments as necessary,"

OR Describe the instrumentation that will be used to perform the required radiological surveys and state, "We will use instruments that meet the radiation monitoring instrument specifications published in Appendix F NUREG-1556. Volume 18, Revision 1, 'Consolidated Guidance About Materials Licenses: Program-Specific Guidance About Service Provider Licenses.' Additionally, we will implement the model radiation survey meter calibration program published in Appendix F ofNUREG-1556. Volume 18. Revision 1.

'Consolidated Guidance About Materials Licenses: Program-Specific Guidance About Service Provider Licenses.' We reserve the right to upnrade our survey instruments as necessap1.

B-12

Table B-4. Items 5.3 through 11: Training and Experience, Facilities and Equipment, Radiation Safety Program, and Waste Disposal (ContinOed)

Item Description Nos. Title and Criteria Yes No :NIA Attached OR 10.3 Radiation Monitoring Instruments Describe alternative equipment and/or procedures for ensuring that appropriate radiation-monitoring equipment will be used during licensed activities, and that proper calibration and calibration frequency of survey equipment will be performed. Include a statement that: "We reserve the right to upgrade our survey instruments as necessary.

10.4 Surveys Choose one of the following:

Provide the following statement: "We will conduct surveys and maintain contamination levels in accordance with the survey frequencie s and contamination levels published in Section 8.10.4 of NUREG-15 56, Volume 18, Revision 1, "Consolidated Guidance About Materials Licenses: Program-Specific Guidance About Service Provider Licenses.'"'

OR Submit a description of an alternative survey tri method and frequency for demonstrating how to evaluate a radioloaical hazard.

10.5 Leak Tests Provide one of the following:

A statement that: "Leak tests sample collection and analysis will be perforined by an organization authorized by NRC or an Agreement State to provide leak testing services to other licensees. Leak tests may be collected by the licensee using a leak test kit supplier's instructions. Such leak test kits will be supplied by an organization authorized by the NRC or an Agreement State to provide leak tesing services."

OR B-13

Table B-4. Items 5.3 through 11: Training and Experience, Facilities and Equipment, Radiation Safety Program, and Waste Disposal (Contin~ed)

Item Description Nos. Title and Criteria Yes No N/A Attached 10.5 Leak Tests A statement that: "Leak testing and analysis will be done by the applicant." Provide the J

information in Appendix G of this NU REG supporting a request to perform leak testing and sample analysis, and either (1) state that the applicant will follow the model procedures in Appendix G of NUREG-1556, Volume 18, Revision 1, "Consolidated Guidance About Materials Licenses: Program-Speciff_ Guidance About Service ProvideI_}icenses, or~ ) submit alternative procedures. 1 10.6 Occupational Dose Provide one of the following:

A statement that: "We will maintain, for inspection 0 1 by the NRC, documentation demonstrating that unmonitored individuals are not likely to receive a radiation dose in excess of the limits in 10 CFR 20.1502."

OR A statement that: "We will monitor individuals in ~

accordance with the criteria in the Section 8.10.6,

'Radiation Safety Program-Occupational Dose' in NUREG-1556, Volume 18, Revision 1, "Consolidated Guidance About Materials Licenses: Program-Specific Guidance About Service Provider Licenses.""

OR, IN LIEU OF THESE STATEMENTS Provide a description of an alternative method for J demonstrating compliance with the referenced reoulations.

8 - 14

Table B-4. Items 5.3 through 11: Training and Experience, Facilities and Equipment, Radiation Safety Program, and Waste Disposal (Continued)

Item Description Nos. Title and Criteria Yes No : N/A Attached 10.7 Public Dose No response is required from the applicant in a license application, but compliance will be evaluated durina insoection.

10.8 Transportation No response is needed from applicants during the licensing phase. Transportation issues will be reviewed during inspection.

10.9 Routine Maintenan ce Provide either of the following:

A statement that: 'We will implement and 0 J maintain procedures for conducting routine maintenanc e of devices according to each manufactu rer's (or distributor's ) written recommen dations and instructions."

OR Provide alternative routine maintenanc e 0 procedures for NRC's review.

10.9 Nonroutin e Maintenan ce Provide the following:

Obtain prior NRG approval, if OEM replaceme nt parts cannot be used, for sealed source shielding, the source driving unit, or other electrical or mechanica l componen t that could expose the source, reduce the shielding around the source, or compromis e the radiation safety of 0

the device or the source AND B-15

Table B-4. Items 5.3 through 11: Training and Experience, Faciliti~s and Equipment, Radiation Safety Program, and Waste Disposal (Continued)

Item Description Nos. Title and Criteria Yes No  ; NIA Attached 10.9 Nonroutine Maintenance A statemen t that: "We will have the device manufact urer (or distributo r) or other person authorize d by NRC or an Agreeme nt State to perform nonroutin e maintena nce of devices."

OR Provide alternative procedures for the NRC's review addressing the information listed in Appendix K of NUREG- 1556, Volume 18, Revision 1, "Consolid ated Guidance About Materials Licenses : Program- Specific Guidance About Service Provider Licenses ."

10.10 Audit and Review of Program Na: response is needed from applicant s during the licensing phase. The licensee' s program for auditing its radiation safety program may be reviewed during inspection. .

10.11 S~curity Program for Risk Significant Radioactive Material Licensee s must ensure the security and control of licensed material.

In addition, 10 CFR Part 37 describes increased security measure s for certain types and amounts of radioactiv e material.

No response is required from the applicant or licensee. Complian ce with access authoriza tion and security program requirem ents may be reviewed durino NRC insoections.

B-16

Table B--4. Items 5.3 through 11: Training and Experience, Facilitie_S and Equipment, Radiation Safety Program, and Waste Disposal {Contin~ed)

Item I Description Title and Criteria Yes No : N/A Attached Nos.

11 Waste Management Provide the following:

A statement that: "We will use the model waste procedures published in Appendix M of NUREG-1556, Volume 18, Revision 1, 'Consolidated Guidance About Materials Licenses: Program-Specific Guidance About Service Provider Licenses."'

OR If the applicant wishes to use only selected model procedures, provide a statement that: "We will use the model waste procedures that are published in Appendix M of NUREG-1556, Volume 18, Revision 1, 'Consolidated Guidance About Materials Licenses: Program-Specific Guidance About Service Provider Licenses"'

(specify below);

(1) Decay-In-Storage (2) Disposal of Liquids Into Sanitary Sewerage (3) Incineration (4) Compaction AND If the applicant wishes to compact or incinerate radioactive waste, provide the requested information concerning these activities in Appendix M of this NUREG.

OR Provide procedures for waste management by any of the methods described in Section 8.11, "Waste Management of this NUREG. Applicants should contact the appropriate regional office of the NRC for guidance as to how to obtain approval of any method(s) of waste disposal other than those discussed in this section.

B-17

Table B-4. Items 5.3 through 11: Training and Experienc e, Facilities and Equipmen t, Radiation Safety Program, and Waste Disposal (Continyed)

Item Descriptio n Title, and Criteria Yes No N/A Attached Nos.

11 Waste Manageme nt OR If needed, the applicant should request authorization for extended interim storage of waste. Applicants should use the references at the end of Section 8.11, "Waste Management" of this NUREG for guidance and submit the required information with the application.

B-18