ML20236W536

Forwards Survey of Licensing & Insp Personnel for Response

ML20236W536
Person / Time
Issue date:	07/23/1998
From:	Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP)
To:	GENERAL, OHIO, STATE OF, OKLAHOMA, STATE OF, PENNSYLVANIA, COMMONWEALTH OF
Shared Package
ML20236W538	List: ML20236W536 ML20236W546 ML20236W557 ML20236W573
References
SP-98-065, SP-98-65, NUDOCS 9808060046
Download: ML20236W536 (51)

Text

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I l.

9 7to L ,O k UNITED STATES l*

g j

't NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20566 4 001 l k****+! July 23,1998 r ALL AGREEMENTS STATES l OHIO, OKLAHOMA, PENNSYLVANIA t

t TRANSMITTAL OF STATE AGREEMENTS PROGRAM INFORMATION (SP-98-065 )

Your attention is invited to the enclosed correspondence which contains:

INCIDENT AND EVENT INFORMATION.............

)

1 PROGRAM MANAGEMENT INFORMATION......

TRAINING COURSE INFORMATION..................

l TECHNIC AL IN FORMATION...............................

OTH E R I N FORMATIO N...... ......... ....... .............. ...XX REQUESTED RESPONSE ,

l TO SURVEY

. Sucolementary Information: As you were informed by SP-98-028, the U.S. Nuclear Regulatory

. Commissica's Office of Nuclear Material Safety and Safeguards has formed a nuclear byproduct material risk review working group composed of NRC employees and an employee of the State of Colorado. The group's goals are to identify and document the technical basis for a risk-informed approach to nuclear byproduct material regulation and to develop plans for a graded approach to regulation of that material based on risk information. The effort encompasses byproduct materials that are currently defined in Section 11.e(1) of the Atomic Energy Act of 1954, and Title 10 of the Code of Federal Regulations (CFR) Section 30.4 and l addressed by 10 CFR Parts 30-36 and 39, or the equivalent regulations of an Agreement State.

l- The working group has obtained the services of a contractor, SCIENTECH, Inc., to perform the majority of the technical work necessary to meet its goals.

The information resources available to SCIENTECH have been largely limited to published reports, the experience and training of its own staff and consultants, and the responses of members of the regulated community to a web page survey. The review group believes that information beyond that available to SCIENTECH will be valuable in meeting its goals and that, collectively, nuclear material licensing and inspection personnel have an unparalleled breadth and depth of knowledge about the systems of interest. As a result, the working group has developed a survey for distribution to NRC and Agreement State personnel involved in licensing I

and inspection of materials within the scope of its review (enclosed). The intent is to capture the " corporate knowledge" of those personnel and to augment and confirm information provided by SCIENTECH.

I Agreement States are asked to participate by distributing copies of the survey to several (e.g.,2 I j

or 3) of your experienced licensing and inspection personnel. A test of the survey indicated that it takes on the order of 1.5 to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to complete. The selected respondents should return the g 00Gu, Y l~

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\ gh l l

9800060046 980723 PDR STPRG ESGGEN SP' H I l- PDR _

L_-------__--------------.---- - - - - . - - _ - _

m e 4 SP-98-065 )

l completed survey by August 14,1998, to the individual named below. Any questions  ;

concerning the survey may be directed to Dr. Serig.

U.S. Nuclear Regulatory Commission ,

ATTN: Dennis I. Serig l Mail Stop T8F5 j Washington, D.C. 20555-0001 Phone: 301-415-7901 Fax: 301-415-5369 #

E-Mail: dis @nrc. gov This information request has been approved by OMB 3150-0029, expiration April 30,2001.

The estimated burden per response to comply with this voluntary collection is 1.5-3.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.

Forward any comments regarding the burden estimate to the Information and Records ,

Management Branch (T-6 F33), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, and to the Paperwork Reduction Project (3150-0029), Office of Management and Budget, Washington, DC 20503. If a document does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person i ot required to respond to a collection of information.

I J fn Paul H. Lohaus, Deputy Director Office of State Programs

Enclosure:

As stated ,

I.

! SP-98-065 QUL a21998 l

completed survey by August 14,1998, to the individual named below. Any questions concerning the survey may be directed to Dr. Serig.

U.S. Nuclear Regulatory Commission ATTN: Dennis 1. Serig

, Mail Stop T8F5 Washington, D.C. 20555-0001

Phone

301-415-7901 Fax: 301-415-5369 E-Mail: dis @nrc. gov This information request has been approved by OMB 3150-0029, expiration April 30,2001.

The estimated burden per response to comply with this voluntary collection is 1.5-3.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.

Forward any comments regarding the burden estimate to the Information and Records Management Branch (T-6 F33), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, and to the Paperwork Reduction Project (3150-0029), Office of Management and Budget, Washington, DC 20503. If a document does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to a collection of information.

i Original S;gneu Cy:

PAUL H. LOHAUS

. Paul H. Lohaus, Deputy Director l

Office of State Programs

Enclosure:

As stated Distribution:

DlR RF DCD (SP03)

SDroggitis (ss.20.5)

PDR (YES1) (NO_)

JLubinski PHolihan, NMSS A/S File E-MAILED TO STATES: 07/23/98 DOCUMENT NAME: G:\ ROV \ SP98065. ROV *SEE PREVIOUS CONCURRENCE.

Ti receive a cop r of this document, indicate in the box: "C" = Tbpf[ithut attachment "E" =/ Copy enclosure with attachment / enclosure "N" = No copy l OFFICE OSP l OS$c,l NMSS l OSP:DM l

NAME RVirgilio:nb PLohatIsN DSerig RBangart iNO DATE 07/16/98

• 07/ 2f/98 07/21/98* via E Mail 07h398

.OSP FILE CODE: SP_-A-4 L -- - _ _ _ _ _ ..

SURVEY OF LICENSING AND INSPECTION PERSONNEL  !

BACKGROUND. The Nuclear Regulatory Commission's (NRC's) Office of Nuclear Material Safety and Safeguards (NMSS) has established a Nuclear Byproduct Material Risk Review Group, composed of representatives from the NRC and an Agreement State. The group's goals are: (1) to identify and document a technical basis for a risk-informed approach to the regulation of nuclear byproduct material, and (2) to develop plans for a graded approach to nuclear byproduct material regulation based on risk information. The effort encompasses byproduct materials that are currently defined in Section 11.e(1) of the Atomic Energy Act of 1954, and Title 10 of the Code of Federal Regulations (CFR) Section 30.4 and addressed by 10 .

CFR Parts 30-36 and 39, or the equivalent regulations of an Agreement State.

l NRC has contracted SCIENTECH, Inc. to assist the group in its effort. The attached survey was developed to confirm and augment information gathered by Scientech and to assist in l development of plans for a graded approach to nuclear byproduct material regulation informed by risk. The survey is designed to be completed by NRC and Agreement State licensing and inspection personnel, and it has been discussed with NRC Regional Management, NRC's Office of State Programs, and the Executive Committee of the Organization of Agreement States. It asks about the typical radionuclides and quantities of material possessed and used by certain types of regulated entities (e.g., research and development synthesis laboratories, fixed gauge users, owners of exempt products), types and frequency of incidents that occur at I various facilities (e.g., non-reportable incidents such as spills, contamination), typical annual doses received by various personnel, and the respondent's perception of the risk associated with various regulated activities. However, when responding to the survey, please do not consider doses, intended or unintended, to patients during medical diagnosis or treatment.

Specifically, doses to patients is outside the scope of the Nuclear Material Risk Review Group.

INSTRUCTIONS. Please limit your answers to byproduct materials (see paragraph 1). Please answer based on your memory of experience in licensing and inspection activities. Do not review license files, inspection reports, etc. and do not consult with other staff. If you do not have experience or information about a particular subject or question, indicate that fact in the space provided. Partial responses may, however, be valuable. If you can answer parts of a question, but not all, please answer what you can. It should take approximately 1.5 to 3.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> to complete the survey. When complete, please return the survey to:

U.S. Nuclear Regulatory Commission ATTN: Dennis Serig Mail Stop: T8F5 Washington, DC 20555-0001 l E-Mail: dis @nrc.cov Fax: 301-413-5369 l

l L-____-.--

Section 1 - Questions about All Types of Operations

1. Based on your experience, indicate the percentage of workers that typically receive annual whole-body doses in the indicated ranges for each type of operation listed below under current regulations and policies for licensing and inspection. Percentages in each row should sum to 100. Mark an X in the " don't know" column if you're unfamiliar with the operation.

ND=NON-DETECTABLE Op ration <ND ND to 51 to 100 101 to 201 to 501 to > 1000 don't l 50 mrem mrem 200 mrem 500 mrem 1000 mrem know mrem R&D synthesis laboratories R&D laboratories using carbon, l hydrogen, lodine, phosphorus, and sulfur in vitro laboratory testing 10 CFR 35.100 nuclear medicine End human use research 10 CFR 35.200 - nuclear medicine with generator (s) 10 CFR 35.200 nuclear medicine without a generator 10 CFR 35.300 nuclear medicine brachytherapy using seeds brachytherapy - manual afterloading j l

brachytherapy -low dose rate remote afterloading brachytherapy high dose rate rImote afterloading brachytherapy - eye applicator 1 10 CFR 35.400 - diagnostic devices tel: therapy devices gamma stereotactic surgery l nuclear pharmacies l

vettrinary use R&D on animals well logging - tracers and field flood studies welllogging using sealed sources radiography - permanent installation 2

r I

-. I Operation <NO ND to 51 to 100 101 to 201 to 501 to > 1000 don't 50 mrem mrem 200 mrom 500 mrem 1000 mrem know nrem radiography - field use pool irrudiators self-shielded irradiators fixed gauges - gamma emitters  !

)

fixed gauges - beta emitters portaale gauges x-ray fluorescence devices gas chromatography l

other measuring devices small sealed sources or devices (s.g. those used under a gefieral license) l l vity small sealed sources or devices (s.g., those used under an exemption) manufacturing or distribution of devices containing sealed sources manufacturing of radioactive solids manufacturing of radioactive liquids manufacturing of radioactive gases incineration of waste compacting of waste i

packaging of waste i

sohdificatiors of waste other Part 30 operation (describe each): ,

l 1

i i

I l

l 3

i

2. Based on your experience, specify in the space provided what you believe to be the non-reportable incident (e.g., spill, contamination, loss of material) that is most frequent for each type of operation listed below under current regulations and policies for )

licensing and inspection. Once you have specified an incident, mark an X in the column that is your best estimate of the frequency of that incident per licensee. Mark an X in the " don't know" colurnn if you're unfamiliar with the operation.

Operation Most Frequent Type of 1 time 1 time 1 time 1 time less don't incident / week / month / quarter / year often know R&D synthesis laboratories l

R&D laboratories using carbon, l hydrogen, iodine, phosphorus, and sulfur in vitro laboratory testing i

10 CFR 35.100 - nuvear medicine End human use resea ch l

10 CFR 35.200 - nuclear medicine I with generator (s) 10 CFR 35.200 - nuclear medicine without a generator 10 CFR 35.300 - nuclear medicine br:chytherapy - using seeds brc.chytherapy - manual afterloading brachytherapy -low dose rate remote afterioading brachytherapy high dose rate remote aftertoading l

l brachytherapy eye applicator 10 CFR 35A00 diagnostic devices j 1:!etherapy devices gamma stereotactic surgery nuclear pharmacies

vctennary use f R&D on animals 4

f .

l

! Operation Most Frequent Type of 1 time 1 time 1 time 1 time less don't incident / week / month / quarter / year often know welllogging tracers and field flood studies walllogging using sealed sources radiography permanentinstallation radiography - field use poolirradiators 6 elf shieldedirradiators fixed gauges gamma emitters fi::ed gauges - beta emitters portable gauges x-ray fluorescence devices gas chromatography other measuring devices small sealed sources or devices (a.g. those used under a general license) v'.ry small sealed sources or devices (2.g., those used under an exemption) manufacturing or distribution of devices containing sealed sources manufacturing of radioactive solids manufacturing of radioactive liquids manufacturing of radioactive gases incineration of waste compacting of waste p;ckaging of waste solidification of waste ,

1 l l 5 )

i i

pw...-

l Operation Most Frequent Type of 1 time 1 time 1 time 1 time less don't incident / week / month / quarter -/ year often know other Part 30 operation (describe each):

9 i

^

l I

i 6

c__--___=__-_______

3. Based on your experience, indicate what you believe to be the radiological safety of l each type of operation listed below under normal operatina conditions and currert Regulations and Dolicies for licensina and inspection. Mark an X in the column that is your best estimate. Mark an X in the " don't know" column if you're unfamiliar with the operation.

Operation very somewhat sorv 9what ve'y don't t l safe safe unsafe unsafe know

, R&D synthesis laboratories l

l R&D laboratories using carbon, hydrogen, iodine, phosphorus, and sulfur j in vitro itsboratory testing 10 CFR 35.100 nuclear medicine and human use research 10 CFR 35.200 - nuclear medicine with generator (s) l 10 CFR 35.200 - nuclear medicine without a generator 10 CFR 35.300 nuclear medicine brachytherapy using seeds .

brachytherapy - manual aftertoading

brachytherapy low dose rate remote afterloading l brachytherapy high dose rate remote afterloading l

l 1 i brachytherapy - eye applicator 10 CFR 35.400 diagnostic devices teletherapy devices gamma stereotactic surgery nuclear pharmacies veterinary use R&D on animals well logging tracers and field flood studies well logging - using sealed sources l- radiography - permanent installation radiography field use pool irradiators self-shielded irradiators 7

I l

l l

Operation very somewhat somewhat very don't l safe safe unsafe unsafe know fixed gauges - gamma emitters fixed gauges - beta emitters portable gauges x-ray fluorescence devices l

gas chromatography other measuring devices small sealed sources or devices (e.g.

those used under a general license) very small sealed sources or devices (e.g.,

those used under an exemption) manufacturing or distribution of devices containing sealed sources manufacturing of radioactive solids manufacturing of radioactive liquids j manufacturing of radioactive gases incineration of waste compacting of waste packaging of waste solidification of waste l other Part 30 operation (describe each):

I i

8

?-

1 l 4. Based on your experience, indicate what you believe to be the radiological safety of l each type of operation listed below under off-normal operatina conditions (e.a..

I incidents accidents. failure of administrative controls) and current regulations and l colicies for licensina hild inspection. Mark an X in the column that is your best estimate.

l Mark an X in the " don't know" column if you're unfamiliar with the operation.

1 Operation very somewhat somewhat very don't safe safe unsafe unsafe know l

R&D synthesis laboratories R&D laboratories using carbon, hydrogen, lodine, pbnsphorus, and sulfur in vitro laboratory testing 10 CFR 35.100 - nuclear medicine and human use research 10 CFR 35.200 nuclear medicine with generator (s) 10 CFR 35.200 - nuclear medicine without a generator l

10 CFR 35.300 nuclear medicine brachytherapy using seeds brachytherapy - manual afterloading brachytherapy low dose rate remote afterioading brachytherapy - high dose rate remote aftertoading brachytherapy - eye applicator 10 CFR 35.400 diagnostic devices teletherapy devices gamma stereotactic surgery nuclear pharmacies veterinary use R&D on animals well logging - tracers and field flood studies welllogging using sealed sources radiography - permanent installation radiography field use poolirradiators self-shielded irradiators i

9 1

? .

Operation very somewhat somewhat very don't safe safe unsafe unsafe know fixed gauges - gamma emitters i fixed gauges - beta emitters portable gauges x-rey fluorescence devices i

gas chromatography other measuring devices small sealed sources or devices (e.g.

those used under a generallicense) very small sealed sources or devices (e g.,

those used under an exemption) 1 manufacturing or distribution of devices l containing sealed soarces I manufacturing of radioactive solids manufacturing of radioactive liquids manufacturing of radioactive gases incineration of waste compacting of waste packaging of waste solidification of waste other Part 30 operation (describe each):

l l

l l

l 10 l

1 I

5. Based on your experience, indicate what you believe to be the radiological safety of each type of operation listed below under normal operatino conditions. but without current regulations and policies for licensina and inspection. Mark an X in the column that is your best estimate. Mark an X in the " don't know" column if you're unfamiliar with the operation. l j

Operation very somewhat somewhat very don't safe safe unsafe unsafe know R&D synthesis laboratories R&D laboratories using carbon, hydrogen, iodine. phosphorus, and sulfur in vitro laboratory testing 10 CFR 35.1 0 - nuclear medicine and human use research 1

10 CFR 35.200 - nuclear medicine with l generator (s) i 10 CFR 35.200 - nuclear medicine without a generator 10 CFR 35.300 - nuclear medicine brachytherapy using seeds brachytherapy - manual aMertoading brachytherapy low dose rate remote afterloading brachytherapy - high dose rate remote afterloading brachytherapy - eye applicator 10 CFR 35.400 - diagnostic devices teletherapy devices gamma stereotactic surgery nuclear pharmacies veterinary use R&D on animals l well logging - tracers and field flood studies welllogging using sealed sources l

radiography - permanent installation l radiography - field use poolirradiators self-shielded irradiators 11 w______-_-_____-____________-___-_. . _ - _ _ ._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

l Operation very somewhat somewhat very don't safe safe unsafe unsafe know fixed gauges - gamma emitters fixed gauges - beta emitters portable gauges x-ray fluorescence devices gas chromatography other measuring devices small sealed sources or devices (e.g.

those used under a generallicense) very small sealed sources or devices (e.g., i those used under an exemption) manufacturing or distribution of devices containing sealed sources manufacturing of radioactive solids manufacturing of radioactive liquids j manufacturing of radioactive gases incineration of waste compacting of waste packaging of waste solidification of waste other Part 30 operation (describe each):

12 T

6. Based on your experience, indicate what you believe to be the radiological safety of each type of operation listed below under off. normal operatina conditions (e.a..

Incidents, accidents. failure of administrative controls) but without current regulations and oolicies for licensina and insDection. Mark an X in the column that is your best estimate. Mark an X in the " don't know" column if you're unfamiliar with the operation.

Operation very somewhat somewhat very don't safe safe unsafe unsafe know R&D synthesis laboratories R&D laboratories using carbon, hydrogen, lodine, phosphorus, and sulfur in vitro laboratory testing 10 CFR 35.100 nuclear medicine and human use research 10 CFR 35.200 - nuclear medicine with generator (s) 10 CFR 35.200 - nuclear medicine without a generator l

j 10 CFR 35.300 nuclear medicine brachytherapy using seeds brachytherapy manual afterloading brachytherapy low dose rate , emote afterloading brachytherapy - high dose rate remote afterloading brachytherapy eye applicator 10 CFR 35.400 - diagnostic devices teletherapy devices gamma stereotactic surgery nuclear pharmacies veterinary use l

R&D on animals welllogging tracers and field flood I studies ]

welllogging using sealed sources -

radiography permanentinstallation radiography. field use pool irradiators I self-shielded irradiators 13 l

l E - - - - - - - . - - - _ -- - - - - - - - - - - _ - _ - - - - - - _ - - - - - - - - - - - - - - - - - - - - - _ - - - - - - - - - - - - - - - - - - - - - _ _ - .

Operation very somewhat somewhat very don't safe safe unsafe unsafe know fixed gauges - gamma emitters fixed gauges beta emitters portable gauges x-ray fluorescence devices gas chromatography other measuring devices small sealed sources or devices (e.g.

those used under a generallicense) very small sealed sources or devices (e.g.,

those used under an exemption) manufacturing or distribution of devices containing sealed sources manufacturing of radioactive solids manufacturing of radioactive liquids manufacturing of radioactive gases incineration of waste compacting of waste packaging of waste solidification of waste other Part 30 operation (describe each):

l l

14 l

l

.. 1 .

l : .-

l; t .

l l~ 7. . Describe your criteria for the following terms as used in the above questions:

l a. "very safe" t

i-

b. ' "somewhat safe" t

l l

c. "somewhat unsafer

d. - "very unsafe" f-1 l

l e.

n  ;

?

.c l

l 15

. i.

Section 2 - Questions Concerning Specific Operations

8. Questions 8.1 through 8.4 pertain to camma emittina bvoroduct material in fixed cauaes and small calibrators. If you are not familiar with the use of these types of devices, mark an X in the box below and skip to question 9.

O Not familiar.

8.1 The following table lists isotopes and ranges of quantities that might be used in fixed aamma aauaes and small calibrators. Please mark an X in the appropriate column indicating whether, based on your knowledge, you agree or disagree that the information is correct. If you disagree, please indicate why in the comment area. If you believe additional isotopes should be considered, please add them to the table with their appropriate quantity range.

Isotope Range of Agree Disagree Comment Quantity Am-241 12 mci to 6 Ci Ba-133 10 mci to 125 mci Cd-109 50 mci to 300 mci Co-60 30 Cito 100 Cl Cs-137 10 uCi to 110 Ci l Fe-55 2 mci to 350 mci l

I l

16

l .

l l

(- l 8.2 Please rate the importance of the following barriers to worker and public dose as they )

apply to fixed aamma cauaes and small calibrators (1 is the most important and 4 is the l least important). i Barrier Rating Training, knowledge, and experience of personnelin radiation safety principles.

Training, knowledge, and experience of personnelin handling and use of the gauge l or calibrator.

Limits on the quantity of byproduct material that is incorporated in gauges and l calibrators.

i inherent safety features in the design of the gauges or calibrators.

Typical installation of gauges in locations that are not usually accessible to workers or the public. t 8.3 Many licensees implement " good practices" when using and handling byproduct material. ' Good practices" are actions that are not specifically required by the i regulations but may be included as license conditions or performed voluntarily to reduce exposures or the likelihood of accidents. Based on your experience, indicate the percentage (0 to 100) of all users of fixed oamma aauaes and small calibrators that you believe follow the " good practices" indicated below. Mark every box. Use an X if you are unsure of a percentage.

Good Practice Percentage Posting signs indicating the presence of radioactive material and advising people not to frequent the area.

1 Restricting access to the gauge or calibrator by use of locks or other physical barriers.

Training workers in the importance of appropriate handling of the gauge or calibrator.

Auditing workers and operations to ensure activities are carried cut in an appropriate l manner.  !

l i P rforming periodic inventories to verify accountability of the gauge or calibrator.

Other (please specify):

1 8.4 Please rate the importance of the following regulatory controls as they are, or could be, 17

used to regulate fixed aamma aauces and small calibrators. Consider exposures during normal operations, incidents (including both the probability of occurrence and consequences of those incidents), and costs of regulation to NRC/ Agreement States l

and licensees in your rating (1 is the most important and 4 is the least important).

Regulatory Controls Rating Preapproval review of licensee's knowledge and training and experience of personnel.

Preapproval of licensee's radiation safety program.

Preapproval of procedures for the safe use of the material.

Preapproval of facilities and operations.

I Preapproval of the equipment (sealed sources and devices) used during operations.

On-site inspections of the licensees facility and operations to verify safety and compliance at the foi!cwing frequency (mark your recommended frequency below and rate the importance of your selection in the box at the right):

O every year O every 2 years O every 3 years O every 5 years l

0 other (specify):

Mail or telephone inspections to verify safety and compliance at the following frequency (mark your recommended frequency below and rate the importance of your selection in the box at the right):

O every year O every 2 years O every 3 years O every 5 years O other (specify):

Periodic on-site inspections to verify accountability of radioactive material at the following L frequency (mark your recommended frequency below and rate the importance of your selection in the box at the right):

O every year O every 2 years O every 3 years O every 5 years O other (specify):

Periodic mail inspections to verify accountability of radioactive material at the following i

frequency (mark your recommended frequency below arid rate the importance of your selection in the box at the right):

O every year O every 2 years O every 3 years O every 5 years O other (specify):

)

18 i

Regulatory Controls Rating P:riodic telephone inspections verify accountability of radioactive material at the following fr quency (mark your recommended frequency below and rate the importance of your selection in the box at the right):

l 0 every year O every 2 years O every 3 years O every 5 years O othes (specify):

1 NRC/ Agreement State maintenance of an independent inventory of on-site inspections us rs' material and NRC/ Agreement State cross check of the inventory with users by performing periodic (rate each selection in mail inspections the box to it's right):

telephone inspections V:ndor maintenance of an independent inventory of users' material on-site inspections cnd vendor cross check of the inventory with users by performing ..

I p:riodic (rate each selection in the box to it's right): mailinspections l 1

telephone inspections  !

No regulatory controls should be placed on fixed gamma gauges and small calibrators.

Other (please specify): )

l l

1 I

19 l

L __ ._

9. Questions 9.1 through 9.4 pertain to byoroduct materialin cortable cauaes. If you are i not familiar with the use of these types of devices, mark an X in the box below and skip to question 10.

Not familiar.

9.1 The following table lists isotopes that might be used in portable cauces. Please indicate what you believe to be the typical quantity, or range of quantities, of each used in portable gauges. If, based on your experience, you disagree that a particular isotope is actually used in portable gauges, mark an X in the " disagree" column and indicate why in the comment area. If you believe additional isotopes should be considered, please add them to the table with their appropriate quantity or range of quantities.

Isotope Typical Disagree Comment Quantity Am-241 Ba-133 Cd-109 Co-60 Cs-137 Fe-55 Gd-153 1-125 i l

l l

l 20

9.2 Please rate the importance of the following barriers to worker and public dose as they apply to cortable aauaes (1 is the most important and 4 is the least important).

Barrier Rating Training, knowledge, and experience of personnelin radiation safety principles.

Training, knowledge, and experience of personnel in handling and use of the portable gauge.

Limits on the quantity of byproduct material that is incorporated in portable gauges.

Inherent safety features in the design of portable gauges.

Securing of portable gauges in locked areas when not in use or maintaining constant j surveillance of portable gauges.

9.3 Many licensees implement " good practices" when using and handling byproduct material. " Good practices" are actions that are not specifically required by the regulations but may be included as license conditions or performed voluntarily to reduce  !

exposures or the likelihood of accidents. Based on your experience, indicate the i percentage (0 to 100) of all users of portable aauaes that you believe implement the

" good practices" indicated below. Mark every box. Use an X if you are unsure of a j percentage. J Good Practice Percentage l Posting signs indicating the presence of radioactive material and advising people not to j frcquent the area.

Restricting access to the portable gauge by use of locks or other physical bariiers.

Training workers in the importance of appropriate handling of the portable gauge.

Auditing workers and operations to ensure activities are carried out in an appropriate  ;

manner.

Performing periodic inventories to verify accountability of the portable gauge.

Other (please specify):

21 l.

i' l

9.4 Please rate the importance of the following regulatory controls as they are, or could be, used to regulate portable cauaes. Consider exposures during normal operations, incidents (including both the probability of occurrence and consequences of those incidents), and costs of regulation to NRC/ Agreement States and licensees in your rating (1 is the most important and 4 is the least important).

s Regulatory Controls Rating Preapproval review of licensee's knowledge and training and experience of personnel.

Preapproval of licensee's radiation safety program.

Preapproval of procedures for the safe use of the material.

Preapproval of facilities and operations.

Preapproval of the equipment (sealed sources and devices) used during operations. 4 l

On-site inspections of the licensees facility and operations to verify safety and compliance at the following frequency (mark your recommended frequency below and rate the importance of your s::lection in the box at the right):

O every year O every 2 years O every 3 years O every 5 years O other (specify):  ;

l Mail or telephone inspections to verify safety and compliance at the following frequency (mark j your recommended frequency below and rate the importance of your selection in the box at the i right): I O everyyear O every 2 years O every 3 years O every 5 years O other (specify)-

l Psriodic on-site inspections to verify accountability of radioactive material at the following fr:quency (mark your recommended frequency below and rate the importance of your selection in the box at the right):

O every year O every 2 years O every 3 years O every 5 years O other (specify):

Periodic mail inspections to verify accountability of radioactive material at the following frequency (mark your recommended frequency below and rate the importance of your selection in the box ct the right):

O every year O every 2 years O every 3 years O every 5 years l 1

O other (specify):

(

22 l

- j l

Regulatory Controls Rating Periodic telephone inspections to verify accountability of radioactive material at the following frequency (mark your recommended frequency below and rate the importance of your selection in the box at the right):

O every year O every 2 years O every 3 years O every 5 years O other (specify):

NRC/ Agreement State maintenance of an independent on-site inspections inventory of users' material and NRC/ Agreement State cross I check of the inventory with users by performing periodic (rate mailinspections

{

cach selection in the box to it's right):

telephone inspections Vendor maintenance of an. independent inventory of users' on-site inspections l material and vendor cross check of the inventory with users by .

j performing periodic (rate each selection in the box to it's right): mailinspections telephone inspections No regulatory controls should be placed on portable gauges.

Other (piease specify): l i

i i

l l

23 1

E_-__._______.

10. Questions 10.1 through 10.4 pertain to laboratory operations usina unsealed bvoroduct material. If you are not familiar with such operations, mark an X in the box below and skip to question 11.

Not familiar.

10.1 The following table lists isotopes and typical quantities that might be used in laboratory operations usina unsealed bvoroduct material. Please mark an X in the appropriate column indicating whether, based on your knowledge, you agree or disagree that the information is correct. If you disagree, please indicate why in the comment area. If you believe additional isotopes should be considered, please add them to the table with their appropriate quantity.

Isotope Typical Agree Disagree Comment Quantity C-14 5 mci Ca-45 1 mci Cr-51 10 mci Fo-59 1 mci H-3 25 mci l-125 10 mci P-32 10 mci P-33 10 mci S-35 15 mci l

l 24 l

l

10.2 Please rate the importance of the following barriers to worker and public dose as they apply to laboratory operations usina unsealed materials (1 is the most important and 4 is the least important).

Barrier Rating Training, knowledge, and experience of personnelin radiation safety principals.

Training, knowledge, and experience of personnel in handling and use of unsealed radioactive materials in a laboratory setting.

Most laboratory use of unsealed byproduct material is with low-energy beta-emitters such as C-14, H-3, P-32, and S-35, and sometime other radionuclides, which are easily shielded.

Most laboratory use of unsealed byproduct materi9.1 involves small quantities (microcuries to a few millicuries) that is usually in a non-volatile form.

Persons handling unsealed byproduct material in laboratories usually wear protective gloves and laboratory coats.

Access to the unsealed byproduct material is controlled by physical security, or by maintaining visual oversight.

10.3 Many licensees implement " good practices" when using and handling byproduct material. " Good practices" are actions that are not specifically required by the regulations but may be included as license conditions or performed voluntarily to reduce exposures or the likelihood of accidents. Based on your experience, indicate the percentage (0 to 100) of all persons performing laboratory operations usina unsealed material that you believe implement the " good practices" indicated below. Mark every box. Use an X if uns,ure of a percentage.

Good Practice Percentage Wearing protective gloves, laboratory coats, or other protective clothing.

Using shielding (e.g., around stock vials and storage areas, portable shields in work areas).

Using hoods or glove boxes if potentially volatile materials are handled.

Perform surveys for radiation and contamination after each use or the end of each day of use.

Maintaining an inventory of unsealed byproduct material in the laboratory.

Auditing work areas and maintenance of records by Radiation Safety Officer or m:nagement.

l l 25 l

Good Practice Percentage Other (please specify):

1 10.4 Please rate the importance of the following regulatory controls as they are, or could be, used to regulate laboratory operations usina unsealed material. Consider exposures during normal operations, incidents (including both the probability of occurrence and consequences of those incidents), and costs of regulation to NRC/ Agreement States and licensees in your rating (1 is the most important and 4 is the least important).

Regulatory Controls Rating Pr: approval review of licensee's knowledge and training and experience of personnel.

Prcapproval of licensee's radiation safety program.

Preapproval of procedures for the safe use of the material.

Preapproval of facilities and operations.

Preapproval of the equipment (sealed sources and devices) used during operations.

On-site inspections of the licensees facility and operations to verify safety and compliance at the following frequency (mark your recommended frequency below and rate the importance of your s:lection in the box at the right):

O every year O every 2 years O every a years O every 5 years O other (specify):

Mail or telephone inspections to verify safety and compliance at the fLilowing frequency (mark your recommended frequency below and rate the importance of your selection in the box at the right):

O every year O every 2 years O every 3 years O every 5 years O other (specify):

1 Periodic on-site inspections to verify the persons' accountability of radioactive material at the following frequency (mark your recommended frequency below and rate the importance of your silection in the box at the right):

O every year O every 2 years O every 3 years O every 5 years O other (specify): l i

6 26 L

L_- _ ------- - - - - - - - - - - - -_ -- -- -- ---------_- D

l 1

Regulatory Controls Rating Pzriodic mail inspections to verify the persons' accountability of radioactive material at the following frequency (mark your recommended frequency below and rate the importance of your s:lection in the box at the right):

O every year O every 2 years O every 3 years O every 5 years O other (specify):

Periodic telephone inspections verify the persons' accountability of radioactive material at the following frequency (mark your recommended frequency below and rate the importance of your selection in the box at the right):

O every year O every 2 years O every 3 years O every 5 years i O other (specify):

NRC/ Agreement States maintenance of an independent on-site inspections inventory of the users' material and NRC/ Agreement State cross check of the inventory with users by performing periodic mailinspections f

(rate each selection in the box to it's right):

telephone inspections Vandor maintenance of an independent inventory of the users'. on-site inspections material and the vendor cross check of the inventory with users by performing periodic (rate each selection in the box to it's mailinspections right):

telephone inspections No regulatory controls should be placed on laboratory operations using unsealed material.

'Other (please specify):

l l

l l

h.

27

1

11. Questions 11.1 through 11.4 pertain to oackaaina byproduct material waste. If you are not familiar with such operations, mark an X in the box below and skip to question 12.

Not familiar.

11.1 The following table lists isotopes that might be involved in packaaina bvoroduct material waste. Please indicate what you believe to be the typical quantity of each in the packaging of byproduct material waste. If, based on your experience, you disagree that a particular isotope is actually involved in the packaging of byproduct material waste, mark an X in the " disagree' column and indicate why in the comment area. If you believe additional isotopes should be considered, pleace add them to the table with their appropriate quantity.

Isotope Typical Disagree Comment Quantity Ac-225 Ag-110m l Am-241 Au-195 Ba-133 l Ba-140 C-14 Ca-45 Cd-109 l Cf-252 Ce-141 Ce-144 Cl-36 Co-58 i Co-60 Cr-51 Cs-134 Cs-137 Eu-152 Fe-55 28 l

Isotope Typical Disagree Comment Quantity Fn-59 Gd-153 H-3 1-125 l-129 l-131 Ir-192 Kr-85 L2-140 Mn-54 Nb-95 Ni-59 Ni-63 P-32 P-33 Pa-234 Pb-210 Pm-147 Po-210 Rb-86 Ru-103 Ru-106 S-35 Sb-124 Sb-125 Sc-46 S:-75 Sn-113 29 t

i I _ _ _ _ _ _ _ _ _ . _ _ . . . - _ _ . _ . _ _ _ . . _ . . _ _ _ _ _ _ _ . . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ ,

v.

I l

Isotope Typical. Disagree Comment Quantity Sr-85 Sr St-90 Tc-99 Tc-99m TI-204' Xs-131m Xs-133

.Y-90 2n-65 Zr-95 l 1

1. j i

I l

1 i

30

11.2 Please rate the importance of the following barriers to worker and public dose as they apply to packaaina bvoroduct material waste (1 is the most important and 4 is the least important).

l l

l -

Barrier Rating 1

Training, knowledge, and experience of personnel in radiation safety principais. ,

i l Limiting operations to sealed sources. i l Limiting operations to small quantities of byproduct material.

l Wearing protective gloves and other types of protective clothing when handling unsealed byproduct material.

Controlling access to byproduct material through physical security or by maintaining visual oversight.

11.3 Many licensees implement " good practices" when using and handling byproduct material. " Good practices" are actions that are not specifically required by the regulations but may be included as license conditions or performed voluntarily to reduce l_

exposures or the likelihood of accidents. Based on your experience, indicate the percentage (0 to 100) of all packaaers of bvoroduct material waste that you believe implement the " good practices" indicated below. Mark every box. Use an X if unsure of a percentage.

l l Good Practice Percentage Wearing protective gloves or other protective clothing.

Using shielding (e.g., around stock vials and storage areas, portable shields in work areas).

Using hoods or glove boxes if potentially volatile materials are handled.

Performing surveys for radiation and contamination after handling unsealed material or at .

the end of each work day. I i

Performing periodic inventories of all byproduct material at the facility.

Auditing work areas and maintenance of records by Radiation Safety Officer or managqment.

l l

l l

l 31

J Good Practice Percentage Other (please specify):

I 11.4 Please rate the importance of the following regulatory controls as they are, or could be, i used to regulate packaaina bvoroduct material waste. Consider exposures during normal operations, incidents (including both the probability of occurrence and consequences of those incidents), and costs of regulation to NRC/ Agreement States and licensees in your rating. (1 is the most important and 4 is the least important).

Regulatory Controls Rating )

Preapproval review of licensee's knowledge and training and experience of personnel.

Preapproval of licensee's radiation safety program.

Preapproval of procedures for the safe use of the material.

Preapproval of facilities and operations.

Preapproval of the equipment (sealed sources and devices) used during operations.

On-site inspections of the licensees facility and operations to verify safety and compliance at the following frequency (mark your recommended frequency below and rate the importance of your s:lection in the box at the right):

O every year O every 2 years O every a years O every 5 years O other (specify):

Miil or telephone inspections to verify safety and compliance at the following frequency (mark your recommended frequency below and rate the importance of your selection in the box at the

)

J l

right):

O every year O every 2 years O every 3 years O every 5 years l

0 othe;'(specify): _

32 4

J

Regulatory Controls Rating Periodic on-site inspections to verify the persons' accountability of radioactive material at the following frequency (mark your recommended frequency below and rate the importance of your s:lection in the box at the right):

O every year O every 2 years O every 3 years O every 5 years O other (specify):

Pcriodic mail inspections to verify the persons' accountability of radioactive material at the following frequency (mark your recommended frequency below and rate the importance of your s:lection in the box L the right):

O every year O every 2 years O every 3 years O every 5 years '

O other (specify):

Periodic telephone inspections verify the persons' accountability of radioactive material at the follow!ng frequency (mark your recommended frequency below and rate the importance of your s:lection in the box at the right):

O overy year O every 2 years O every 3 years O every 5 years i

O other (spec,ify):

t l NRC/ Agreement State maintenance of an independent on-site inspections l inventory of users' material and NRC/ Agreement State cross check of the inventory with users by performing periodic (rate mailinspections cach selection in the box to it's right);

telephone inspections Vendor maintenance of an independent inventory of the users' on-site inspections 1- material and vendor cross check of the inventory with users by rnail inspections p:rforming periodic (rate each selection in the box to it's right):

telephone inspections No regulatory controls should be placed on packaging byproduct material waste.

Other (please specify):

l 23 l

l -

- j l 12. Questions 12.1 through 12.4 pertain to use of byproduct materialin a nuclear medicine l department. If you are not familiar with such operations, mark an X in the box below l and skip to question 13.

l  !

l Not familiar.

i l

1 12.1 The following table lists isotopes and typical quantities that might be used in a nuclear l medicine department. Please mark an X in the appropriate column indicating whether, based on your knowledge, you agree or disagree that the information is correct. If you l disagree, please indicate why in the comment area. In cases where a quantity is not l

stated, please indicate what you believe to be the typical quantity used in a nuclear  ;

medicine department. If you believe additional isotopes chould be considered, please i i add them to the table with their appropriate quantity.

l Isotope Range of Agree Disagree Comment Quantity Au 198 100 to ,

140 mci l Dy-165 Er-169 Ho-166 l-131 3 to 300 mci l Mo-99 2 Ci P-32 2.3 to 22.3 mci Pd-109 R3-186 25 to 35 mci Sm-153 Sn-117m Sr-89 1 to 10.8 mci l Tc-99m 50 mci to l 2 Ci I

Xe-133 10 to 100 mci Y-90 I

34

I l

I l

?

i t

1 r

i l

l I

i i

1 i

1 i

l i

I I

i I

1 I

4 35 ,

1 l

l t

1 I I L___________-.______-__-.___ .--_._-.__-;

12.2 Please rate the importance of the following barriers to worker and public dose as they

[ apply to ura of byproduct material in a nuclear medicine deoartment (1 is the most important and 4 is the least important).

Barrier Rating Training, knowledge, and experience of personnel in radiation safety principais.

Training, knowledge, and experience of personnelin handling and use of byprMia material in a nuclear rnedicine department that may include use of a generator.

Most byproduct material used in a nuclear medicine department that may include use of a generator have short half-lives.

Most byproduct material, used in a nuclear medicine department that may include use of a generator is in a non-volatile form, in quantities ranging from microcuries to tens of millicuries.

Persons handling byproduct material in a nuclear medicine department that may include use of a generator usually wear protective glover and laboratory coats. j i

Access to the byproduct material in a nuclear medicine department that may include I use of a generator is controlled by physical security, or by maintaining visual oversight.

12.3 Many licensees implement " good practices" when using and handling byproduct i material. " Good practices" are actions that are not specifically required by the I regulations but may be included as license conditions or performed voluntarily to reduce exposures or the likelihood of accidents.' Based on your experience, indicate the percentage (0 to 100) of all persons performing nuclear medicine operations that you believe implement the " good practices" indicated below. Mark every box. Use an X if unsure of a percentage.

Good Practice Percentage Wearing protective gloves, laboratory coats, or other protective clothing.

Using shielding (syringe shields, L-blocks, etcetera).

Using hoods or glove boxes if potentially volatile materials are handled.

Using long-handled tools when handling large-activity vials.

Performing surveys for radiation and contamination after each use or at the end of each day of use.

Maintaining an inventory of byproduct material in the nuclear medicine department that may include use of a generator.

l Isolating injected patients from other patients and members of the public.

f Auditing work areas and maintenance of records by Radiauon Safety Officer or management.

36

n Good Practice Percentage l

Other (please specify):

l l

~

l 12.4 Please rate the importance of the following regulatory controls as they are, or could be, l used to regulate nuclear medicine departments. Consider exposures during normal operations, incidents (including both the probability of occurrence and consequences of

those incidents), and costs of regulation to NRC/ Agreement States and licensees in your rating (1 is the most important and 4 is the least important).

i Regulatory Controls Rating l Preapproval review of licensee's knowledge and training and experience of personnel.

Preapproval of licensee's radiation safety program.

Preapproval of procedures for the safe use of the material.

Preapproval of facilities and operations, l

Preapproval of the equipment (sealed sources and devices) used during operations. 1 On-site inspections of the licensees facility and operations to verify safety and compliance at the following frequency (mark your recommended frequency below and rate the importance of your s:lection in the box at the right):

O every year O every 2 years O every a years O every 5 years O other (specify):

Mail or telephone inspections to verify safety and compliance at the following frequency (mark your recommended frequency below and rate the importance of your selection in the box at the right):

O everyyear O every 2 years O every 3 years O every 5 years O other (specify):

Periodic on-site inspections to verify the persons' accountability of radioactive material at the following frequency (mark your recommended frequency below and rate the importance of your selection in the box at the right):

O every year O every 2 years O every a years O every 5 years O other (specify):

37 i i

E--------_---_--_---__.-_-----------------.-_-- _ - - - - - - - - - - - - - - - - - - - - - . - - - - - - - - - - - - - - - . - - - - - - - - - - - - - - _ - - - - - - - - - -------------------------------------a

Regulatory Controls Rating Periodic mail inspections to verify the persons' accountability of radioactive material at the following frequency (mark your recommended frequency below and rate the importance of your selection in the box at the right):

O every year O every 2 years O every a years O every 5 years O other (specify):

Periodic telephone inspections verify the persons' accountability of radioactive material at the following frequency (mark your recommended frequency below and rate the importance of your selection in the box at the right):

O every year O every 2 years O every a years O every 5 years O other (specify):

NRC/ Agreement State maintenance of an independent on-site inspections inventory of users' material and NRC/ Agreement State noss check of the inventory with users by performing periodi ', (rate mailinspections cach selection in the box to it's right):

telephone inspections Vendor maintenance of an independent inventory of users' on-site inspections material and vendor cros check of the inventory with users by ,

performing periodic (rate each selection in the box to it's right): mailinspections telephone inspections No regulatory controls should be placed on nuclear medicine departments that may include use of a generator.

Other (please specify):

l 38

7 l -

l i i

1

13. Questions 13.1 through 13.4 pertain to manufacturers or distributors of caseous sources containing byproduct material. If you are not familiar with such operations, mark an X in the box below and skip to question 14.

Not familiar.

13.1 The following table lists isotopes and typical quantities that might be used by l manufacturers or distributors of caseous sources containing byproduct material. Please mark an X in the appropriate column indicating whether, based on your knowledge, you agree or disagree that the information is correct. If you disagree, please indicate why in the comment area. In cases where a quantity is not stated, please indicate what you believe to be the typical quantity used by manufacturers / distributors of gaseous sources containing byproduct material. If you believe additionalisotopes should be considered, please add them to the table with their appropriate quantity.

Isotope Quantity Agree Disagree Comment Br-82 H-3 1 to 25 Ci Kr-85 up to i 25 uCi I X:-133 i

l .

39 l

c____ _ _ _ _

en 13.2 Please rate the importance of the following barriers to worker and public dose as they apply to manufacturers or distributors of gaseous sources (1 is the most important and 4 is the least important).

Barrier Rating Training, knowledge, and experience of personnelin radiation safety principals.

Training, knowledge, and experience of personnelin manufacture of gaseous sources of byproduct material.

Most manufacturers / distributors of gaseous sources of byproduct material handle H-3, a low-energy beta-emitter or noble gases such as Kr-85 and Xe-133.

Using remote handling systems for transfer of gaseous byproduct material during the manufacture of gaseous sources of byproduct material.

Air monitoring in facilities which manufacture gaseous sources of byproduct material.

Controlling access to the byproduct materialin a facility which manufactures gaseous sources of byproduct material by physical security, or by maintaining visual oversight.

13.3 Many licensees implement " good practices" when using and handling byproduct material, " Good practices" are actions that are not specifically required by the regulations but may be included as license conditions or performed voluntarily to reduce exposures or the likelihood of accidents. Based on your experience, indicate the percentage (0 to 100) of all manufacturers or distributors of caseous sources that you believe implement the " good practices" indicated below. Mark every box. Use an X if unsure of a percentage.

Good Practice Percentage Wearing protective gloves, laboratory coats, or other protective clothing.

Using shielding (e.g., around storage areas, or portable shields in work areas).

Using hoods, glove boxes, hot cells, or other remote-handling systems during handling of g seous byproduct material.

P:rforming surveys for radiation and airborne byproduct material during each day of use.

Maintaining an inventory of unsealed byproduct material in the laboratory.

Auditing work areas and maintenance of records by Radiation Safety Officer or management.

l l

l 40 i

I L

l l l ..

i Good Practice Percentage l

Other (please specify):

l l

l 13.4 Piease rate the importance of the following regulatory controls as they are, or could be, used to regulate manufacturers or distributors of aaseous sources containing byproduct material. Consider exposures during normal operations, incidents (including both the probability of occurrence and consequences of those incidents), and costs of regulation to NRC/ Agreement States and licensees in your rating. (1 is the most important and 4 is the least important).  ;

Regulatory Controls Rating Preapproval review of licensee's knowledge and training and experience of personnel.

Preapproval of licensee's radiation safety program.

Preapproval of procedures for the safe use of the material.

Preapproval of facilities and operations.

Preapproval of the equipment (sealed sources and devices) used during operations.

On-site inspections of the licensees facility and operations to verify safety and compliance at the following frequency (mark your recommended frequency below and rate the importance of your  !

selection in the box at the right): l O every year O every 2 years O every a years O every 5 years O other(specify):

Mail or telephone inspections to verify safety and compliance at the following frequency (mark your recommended frequency below and rate the importance of your selection in the box at the right):

O everyyear O every 2 years O every 3 years O every 5 years  ;

i L O other (specify):

L 41

Regulatory Controls Rating Periodic on-site inspections to verify the persons' accountability of radioactive material at the following frequency (mark your recommended frequency below and rate the importance of your selection in the box at the right):

O every year O every 2 years O every 3 years O every 5 years O other (specify):

Periodic mail inspections to verify the persons' accountability of radioactive material at the following frequency (mark your recommended frequency below and rate the importance of your selection in the box at the right):

O every year O every 2 years O every 3 years O every 5 years O other (specify):

Periodic telephone inspections verify the persons' accountability of radioactive material at the following frequency (mark your recommended frequency below and rate the importance of your selection in the box at the right):

O every year O every 2 years. O every 3 years O every 5 years O other (specify):

NRC/ Agreement State maintenance of an independent on-site inspections inventory of users' material and NRC/ Agreement State cross check of the inventory with users by performing periodic (rate mailinspections ,

each selection in the box to it's right):

telephone inspections j Vendor maintenance of an independent inventory of users' on-site inspections material and vendor cross check of the inventory with users by performing periodic (rate each selection in the box to it's right): mail ,nspections i

telephone inspections No regulatory controls should be placed manufacturers or distributors of gaseous sources.

Other (please specify):

! 42 L__ - _---__--_-___ _ - . _

Section 3 - Questions Concerning How You Think Regulatory Agencies Should Make Decisions

14. Indicate what you believe is the level of importance of the factors that might be considered in regulating manufacturing, distribution, receipt, possession, use, handling, transfer, and disposal of radioactive materials. Rank each factor according to the following scale: 1 - very important; 2 - important; 3 - not important; 4 - should not be considered. Please list under "other" any additional factors that should be considered.

Regulation of persons possessing material should be based on: Rating Consensus opinion of the public Financial burden of regulation to the licensee Financial burden of regulation to the public Evaluation of radiological risk Benefit of the use of material to society Other considerations (describe any other considerations):

l l

)

l 43 w________-______.

Section 4 - Information about Yourself The following information is optional, but your response would be helpful to the survey:

15. My information regarding safe operations with radioactive materials is based on:

performing operations with radioactive materials years R&D/ laboratory use industrial use (gauges, radiography, etc.)

medical use manufacturing reactor (power or non-power)

Other (please specify):

performing radiation safety oversight of operations by others years O s&D/iaboratory use industrial use (gauges, radiography, etc.)

medical use manufacturing reactor (power or non-power)

Other (please specify):

performing licensing of radioactive materials years performing inspection of radioactive materials years performing other regulatory review of radioactive materials use years O formal education in health physics or radiation science l Degree: BA/BS MA/MS Ph.D.

O work-related training courses Other (please specify):

l 44 L-- - _ _ _ _ _ __ _ _ _ _ _ _ _ - - - - - - - - - - - - - - - . _ _ _ _ - - - - - - - - - - . _ _ _ _ _ _ _ _ _ - - - . _ - - - - - - - - - - - - - - - - - - - - - - - - _ _ _ _ _ _ _ _ _ _ _

, .,..-._._..~...__v._v, 1~

t LOOKING FOR A SAF E PLACE TO PARK l~

YOUR MONL Y BliWEEN INVESTMENTS?

Ehr$aNfahrEd6 ant

'*)

HIM l WORL D UTAH SPORTS OPIN60N Su$lNESS SCIE NCE Semnani Trades Testimon For Save $5,216 Leniency , , , ,

BY BRENT ISRAELSEN THE SALT LAKE TRIBUNE -

. Suburban M

A Target of a I 16-month FBI dtTr I 100. s r om . l investigation, . r.gg,rgs radioactive-waste , ,,,,,c,,,,,,,

magnate Khosrow . ,,o 1..u m ,,,

Semnani has agreed . 'sa-u .

l to plead guilty to a -

A - l",y,%,

misdemeanor tax - - - - > -- m- -

.me, ors.

l violation and pay a rea'uar.. t, .

$100,000 fine in Khosrow Semnani speaks at a c oa '^c ' ' * ' a'***

. utas u=xs l

exchange for his news conference with his I attorney Rod Snow after a plea testimony agamst a bargain. (Al Hartmann/ Salt . ~ ~

! former state Lake Tribune) i regulator.

t Federal prosecutors on Wednesday filed a criminal @

complaint against Semnani, charging him with aiding and ,"

I abetting the filing of a false federal income-tax return.

A subdued but confident Semnani read a prepared 3 l statement to reporters, saying " mistakes have been made." W l l ,

, .)

"I apologize to the community and to those who may [ cy have been directly impacted by this matter," said Semnani, *. '1 l who since December 1996 has been embroiled in a -

6 l financial scandal with Larry F. Anderson, former director ,d of the Utah Division of Radiation Control. "

m "

The complaint against Semnani alleges he knew that an income-tax return filed by "two Utah residents"in 1994 i was fraudulent. 2 Though the complaint does not name the residents, Semnani attorney Rod Snow revealed they are Anderson and his wife.

y' lM@5 Semnani's charge, which Snow described as a little-used, " byzantine" part of the U.S. tax code, i

essentially alleges that Semnani made payments of about jj

$40,000 to Anderson, knowing that the Andersons were - y $

not going to report them on their federal 1040 form.

No charges have been filed yet against the Andersons.

a(N w q;amwp/

i Their attomey did not return Salt Lake Tribune phone o gr .M calls. E WM-m Anderson headed the Division of f34]

1of3 7/23/98 II:35 AM l

l

~.y-- v~v=,'vw m:r evwouurwvawUFW \y./r WW.UUF MC.A.bueUUWUU Radiation Control in the late 1980s and EXTRA:

early 1990s when Semnani was p;;.w I gqqgg su m o. . developing Envirocare of Utah, a g t - E

& low-level radioactive waste company in i remote Tooele County, about 75 miles ~

. A. . i

=%

west of Salt Lake City.

In bizarre civil lawsuits filed against MMW9 .

LJ c e dl each other in fall 1996, Semnani and p. - 0:y9 Anderson acknowledged that Semnani <. sw I paid Anderson about $600,000 in real estate, cash and gold { o 1.~ ..i coins from 1987 to 1995. Some of the money may have t! J'~ % 4 WM4$

been sent to a Swiss bank account Anderson held. l The nature of the payments, however, was in dispute: p i aO.-lA  !

Anderson claims they were part of a legitimate busmess c

, - jgjjl{g arrangement and that Semnani still owes $5 million; ;c' njM Semnani maintains they were extorted by Anderson, who g.[$f had the power to harm Semnani's business venture. <o3E "As I have previously stated I believe I was the victim E37%

of extortion," Semnani said Wednesday. 3 1. E.MN Wednesday's charge against Semnani means federal p ? .l j investigators apparently do not believe Semnani is guilty fFW iH[@g/

of bribing a government official.

"This [ plea agreement] exonerates Semnani for any claim of attempting to gain a benefit" from state

)E1M e < : .: - n regulators, said Snow. 1- s J y%

Assistant U.S. attorney David Schwendiman would not WJEe comment on the specifics, other than to say, "[Semnani] is r TE Jl.]p3 going to cooperate with us."

fi.-=1 Envirocare of Utah, which is wholly owned by r .. > N4 Semnani, lauded Wednesday's development as exoneration V W.Q I for the company, which has been the subject of civil lawsuits and negative publicityC by waste-disposal business. fr three competitors in "There is no evidence of any involvement by the yc e A 1 company's officers or employees in the allegations arising out of Larry Anderson's demands,said an Envirocare WW (P T M W j press release. I: . ' L- r, G

Indeed, Snow said his press conference Wednesday, an M..H t ' .N unusual move by a criminal defendant, was intended M?P.Q j

largely as a pre-emptive strike against Envirocare competitors who might use the charge as more negative 1e-'- ,

publicity against Envirocare. Q t tQ '

When the FBI began investigating Semnani and 7 .< .g ;f

... . . D ' .

Anderson in March 1997, Semnani stepped down as president of Envirocare in an agreement with the U.S. WC.M g$ 4' 74 Department of Energy. It was unclear on Wednesday when he will retake Envirocare's helm. 0l;7 , ? nj f .: -

It is unlikely, however, that Semnani will resume his presidency of the company until the FBI has completed its . &j g g y? f mvestigation of Anderson -- a probe largely dependent on ~pjj N Semnam. .ae m M Snow said he and his client plan to " spend more time together," "have more fun together" and share more C :: # ~

?. ,

documents than ever with federal investigators. Og(?d p :7),c In the next couple of weeks, Semnani is expected to g gigg$

formally enter his plea before U.S. District Judge David $ t L '"

Winder. The agreement with the federal government calls for Semnani's full cooperation in exchange for prosecutors' MMWq OctenWfg i

1 2 of 3 7/23/9811:35 AM l s l

._m . _ _ _ _ _ _

,(

for Semnani's full cooperation in exchange for prosecutors'

.. . Eseeking no further charges against him. In addition, they will ask the judge not to incarcerate Semnani. The charge against Semnani carries a maximum fine of $100,000 and ajail sentence of up to one year.

Semnani has agreed to pay the maximum fine, Snow 3

said.

)

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'C Copyright 1998. The Salt Lake Tribune

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3 of 3 7/23/9811:35 AM ;

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SP j completed survey by August 14,1998, to the individual named below. Any questions

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concerning the survey may be directed to Dr. Serig.

U.S. Nuclear Regulatory Commission ATTN: Dennis 1. Serig Mail Stop T8F5 /

Washington, D.C. 20555-0001 Phone: 301-415-7901

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Fax: 301-415-5369

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E-Mail: dis @nrc. gov

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'This information request has been approved by OMB 3150-0029, expiration April 30,2001.

The estimated burden per response to comply with this voluntary collection is 1.5-3.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.

Forward any comments regarding the burden estimate to the information and Records

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Management Branch (T-6 F33), U.S. Nuclear Regulatory Commission, Washington, DC 20555- I 0001, and to the Paperwork Reduction Project (3150-0029), Office of Management and Budget, i Washington, DC 20503. If a document does not d,is' play a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to a collection of information.

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/ Paul H. Lohaus, Deputy Director i Office of State Programs

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Enclosure:

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As stated /

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DlR RF / dI DCO (SP03)

SDroggitis PL .". (YES_y_' ) (NO_)

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E-MAILED TO STATES:  !

l DOCUMENT NAME: G:\ROWRRGl.TR.WPD O di .

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Ta receive e copy of this document, indicate in the bar: "C" = Copy without attachmen nclosure 'E" = Copy with attachment /pNiosure "N" = No copy

+M M IOFFICE OSP // l OSP:DD / NMSS l OvP:D l l NAME RVirgilio:nb h PLohaus DSerig RBangart DATE 07/ / h /98 07/ /98 07/JI/98 07/ /98

' OSP FILE CODE: SP-A-4 '

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