**NRC INSPECTION MANUAL** NMSS/RGB

MANUAL CHAPTER 2800

MATERIALS INSPECTION PROGRAM

2800‑01 PURPOSE

To establish the inspection program for licensees authorized to possess,
use, transfer, and dispose of radioactive material associated with
various types of use, i.e., industrial, academic, research and
development, manufacturing, distribution, irradiators, well logging,
industrial radiography, medical programs, various types of service
(i.e., leak testing of sealed sources, calibration of instruments,
servicing of devices, collection and repackaging of radioactive waste
for final disposal), and transportation related thereto.

2800-02 OBJECTIVES

02.01 To establish the general policy for the materials inspection
programs.

02.02 To describe a performance-based inspection approach and to
identify specific conditions of poor performance which require the
licensee to be inspected more frequently.

02.03 To place the major emphasis of the materials inspection program on
timely and thorough follow-up of incidents and events.

02.04 To continue and enhance risk-informed, relative priorities for
routine inspections of all licensees and a program of special inspection
activities as specified by the Office of Nuclear Material Safety and
Safeguards (NMSS).

02.05 To aid in the achievement of a consistent process of inspection
for materials licensees.

2800-03 DEFINITIONS

03.01 Initial Inspection. The first inspection after a license is issued
to a licensee.

03.02 Inspection. The act of assessing licensee performance to determine
whether the licensee is using radioactive material safely and whether an
individual or organization is in compliance with established standards,
such as regulations, license conditions, and the licensee commitments
submitted in support of a license (and incorporated by \"tie-down\"
conditions). Inspections involve a visit to a licensee\'s facility
and/or temporary jobsite by U.S. Nuclear Regulatory Commission (NRC)
inspector(s), observations of licensed activities, interaction with
licensee personnel, and transmission of the inspection findings.
Pre-licensing visits and telephone contacts are not considered
inspections.

03.03 Inspection Plan. An inspection plan is a written outline listing
the licensee\'s activities and programs that will be covered during an
inspection.

03.04 Inspection Priorities. An inspection priority code is assigned to
a particular type of use which is authorized by a radioactive material
license. The same priority code is assigned to all licenses which
authorize that particular type of use. The priority code (i.e., 1, 2, 3,
or 5) is the interval between routine inspections, expressed in years.
Enclosure 1 lists the program codes (types of use) along with the
assigned priority codes. The priority represents the relative risk of
radiation hazard for the type of use. Priority Code 1 presents the
greatest risk to the health and safety of workers, members of the
public, and the environment. Priority Code 5 presents less potential
risk to health and safety . Because a license may authorize multiple
types of use, the priority codes are designated as primary and secondary
codes, with the shortest routine inspection interval as the primary
code.

03.05 Reactive Inspection. A reactive inspection is a special inspection
in response to an incident, allegation, or special information obtained
by NRC (i.e. , report of a medical event, other Federal agency
interests). Reactive inspections may focus on one or several issues, and
need not examine the rest of a licensee\'s program. If the reactive
inspection does not cover the activities normally reviewed on a routine
inspection, then it does not satisfy the requirement to inspect the
licensee at the routine, established interval.

03.06 Routine Inspection. Periodic, comprehensive inspections performed
at a specified interval, as defined in Enclosure 1 of this Inspection
Manual Chapter (MC).

03.07 Special Inspection Activities. Those inspection activities
specified in Section 2800-0 7 of this MC where special guidance is
needed. Those activities cover: 1) inspections of expired licenses,
terminated licenses, and licensees undergoing decommissioning; 2)
inspections of significantly expanded licensee programs; 3) reciprocity
inspections; 4) temporary job-site or field site inspections; 5) team
inspections; 6) inspections of abandoned licenses; and 7) general
licensee inspections.

03.08 Team Inspections. For the purposes of this MC only, team
inspections are defined as those inspections conducted by three or more
inspectors, or any materials inspection that includes an inspector from
outside NRC (other than members from a State=s radiation control
agency). Often, at least one of the inspectors is included on the team
because of specialty in a particular field, or at least one of the team
members comes from a different region or Headquarters. Team inspections
can be routine inspections of a major licensee, or reactive inspections
in response to a particular incident or event. Team inspections do not
include those where a supervisor or program office staff member
accompanies an inspector to evaluate the inspector\'s performance. In
this context, team inspections are not meant to cover Augmented
Inspection Teams (AITs) or Incident Investigation Teams(IITs), described
in Management Directive 8.3, \"NRC Incident Investigation Program.\"

03.09 Telephonic Contacts. These are contacts, made by telephone and
documented in the docket file, to determine the status of licensees\'
activities, to assess compliance of priority T licensees \[see Section
05.05\], or to exchange information with the licensee. Examples such as
reminding a licensee that its license is near expiration, calling to
determine whether there are sufficient licensee operations to conduct an
inspection, or calling to determine whether the licensee actively
possesses licensed material are types of telephonic contacts. Telephonic
contacts are not inspections.

2800-04 RESPONSIBILITIES AND AUTHORITIES

04.01 Director, Office of Nuclear Materials Safety and Safeguards
(NMSS). Provides overall program direction for the NRC materials
inspection program.

04.02 Regional Administrator. Oversees implementation of the materials
inspection program within their respective region.

04.03 Director, Division of Industrial and Medical Nuclear Safety (IMNS)

> a\. Develops and directs the implementation of policies, programs, and
> procedures for inspecting applicants, licensees, and other entities
> subject to NRC jurisdiction.
>
> b\. Assesses the effectiveness, uniformity, and completeness of
> implementation of the materials inspection program.
>
> c\. Approves changes to the materials inspection program.
>
> d\. Ensures that operating plans are consistent among the Regions
> responsible for materials inspections.

04.04 Director, Regional Division of Nuclear Materials Safety (DNMS)

> a\. Manages the implementation of the inspection program elements
> performed by the Regional Office.
>
> b\. Ensures, within budget limitations, that the Regional Office staff
> includes adequate numbers of inspectors to carry out the inspection
> program described in this chapter, including that which may be needed
> for reactive inspections.
>
> c\. Applies inspection resources, as necessary, to deal with
> significant issues and problems at specific facilities.
>
> d\. Coordinates, with IMNS, to obtain technical assistance, as
> necessary.
>
> e\. Recommends changes to the materials inspection program to the
> Director, IMNS.

04.05 Chief(s), Regional Inspection Branch(es)

> a\. Proposes changes to the materials inspection program.
>
> b\. Implements the Regional materials inspection program.
>
> c\. Reviews and approves inspection schedules.
>
> d\. Ensures that Regional inspectors achieve and maintain
> qualifications, in accordance with IMC 1246.
>
> e\. Appraises the performance of each inspector during actual
> inspections at least once during each fiscal year.

2800-05 BASIC REQUIREMENTS

The Materials Inspection Program designates reactive inspections \[see
Section 05.02\] as the highest priority, followed by initial inspections
\[see Section 05.03\] and routine inspections \[see Section 05.04\] for
the Priority Codes (in ascending numeric order) listed in Enclosure 1.
Telephonic contacts \[see Section 05.05\] are not inspections and are
performed as resources permit.

All routine materials inspections should be performed on an unannounced
basis, with the following exceptions.

Since considerable travel is required, inspectors may telephone
licensees located in Guam, American Samoa, Hawaii, Alaska, or other
remote locations to verify that a routine inspection can be performed
before undertaking such travel.

For inspection of Master Materials Licensees (MML), the lead region
shall notify the MML of the dates of the inspection and the
documentation that the MML should have available for the inspectors to
review. \[See IMC 2810\] The lead region should also request assist
inspections (i.e., accompaniment inspections and independent
inspections) to be completed by the regional offices. The accompaniment
inspections will be completed according to the MML=s audit schedule with
NRC inspectors accompanying the MML=s staff during the radiation safety
audits of the MML permittees. \[See IP 87129\] NRC inspectors will
complete the independent inspections according to the request from the
lead region by using the program-specific inspection procedures in
Enclosure 4. The independent inspections will be unannounced just as
routine inspections of other NRC licensees are unannounced. \[See
Section 07.08\]

The regional license reviewer shall assign a primary program code which
sets the inspection priority for each new license. Some licenses
authorize activities that can be classified under more than one program
code. If a license involves more than one type of use, each part of the
program shall be inspected in accordance with its assigned priority. For
example., a license for a medical institution (Program Code 02121,
Priority Code 5) may be amended to authorize use of a high dose rate
(HDR) remote afterloader unit (Program Code 02230, Priority Code 2). The
licensee=s primary program code would be Program Code 02230. The
HDR-related activities would be inspected during every routine
inspection while the other portions of the licensee=s program would be
inspected during every other routine inspection.

Inspection plans should be developed for complex, non-routine
inspections. Inspection plans may also be developed for any other
inspections, as decided by the region. After the inspection, the
inspection plan may be discarded. It need not be filed or kept by the
region.

05.01 [General Inspection Process]{.underline}. The purpose of this MC
is to describe the types of materials inspections and the general
inspection program. For each inspection, the inspector should implement
the process described below for pre-inspection activities, onsite
inspection activities, and post-inspection activities. The IPs listed in
Enclosure 4 provide more specific guidance for onsite inspection
activities. Section 2800-08 provides guidance for documentation of
inspection results.

To provide a reliable, uniformly implemented budgetary basis, the
inspector shall charge inspection hours in the Human Resources
Management System (HRMS, formerly the Resource Information Tracking
System \[RITS\]). For routine inspections, the inspector shall designate
the hours for the license docket number only to the program-specific
inspection procedure (i.e., Inspection Procedures 87121, 87122, 87123,
87124, 87125, 87126, 87127, 87129, 87130, 87131, 87132, 87133, and 87134
\[See paragraph 10.01.c.3 for OSHA Interface activities\]) within the
Task Codes for preparation and documentation, direct inspection onsite
activities, enforcement activities, and time spent in travel status.
There are separate Task Codes for reactive inspections, routine
inspections, allegation follow up. Telephonic contacts are not
inspections. As such the inspector shall charge time for activities
described in Enclosures 2, 3, 4, and 5 to HRMS as direct inspection
effort under Program Code PA No. 203232E, (generic TAC No. A10159).

> a\. Pre-inspection activities. The goal of inspection preparation is
> to ensure that the inspector is sufficiently familiar with the types
> of uses and the generic requirements applicable to the licensed
> program. The effort expended on inspection preparation should be based
> upon the complexity and scope of licensed activities and on the
> experience level of the individual inspector. The extent to which an
> inspector prepares for routine inspections should be based on
> discussions with the supervisor.
>
> To adequately prepare, an inspector shall review:
>
> 1\. the license to determine if it has any unusual license conditions
> that would affect the approach to the inspection, i.e., authorization
> for an incinerator, authorization for use of material at temporary job
> sites,
>
> 2\. the licensee=s recent inspection and enforcement history, i.e.,
> results of the last inspection and any outstanding open items and
> determining whether any events have been reported by the licensee
> during the current inspection cycle,
>
> 3\. any commitments made by the licensee or restrictions imposed by
> NRC as a result of a Confirmatory Action Letter or an Order issued
> since the last inspection,
>
> 4\. any notes in the file regarding special inspection emphasis, i.e.,
> license reviewer=s note to request a near term inspection regarding a
> significant licensing action. For example, an amendment for a new
> medical therapy modality under 10 CFR 35.1000 shall be inspected
> within 12 months of the date of the amendment \[see Section 07.02.b\].
>
> It is not necessary for the inspector to review all the current
> licensing documents and procedures from the docket file. For problems
> identified during the course of the routine inspection, the inspector
> should ask the licensee for pertinent procedures and backup licensing
> documents maintained onsite by the licensee. If the documents are not
> available from the licensee, the inspector should contact the region
> for assistance. This practice would apply to routine inspections only.
>
> To prepare for a reactive inspection, the inspector will review
> specific information for reactive inspections as determined by the
> inspector and his or her supervisor on a case-by-case basis \[see
> Section 05.02\].
>
> While reviewing the license, the inspector should determine if the
> licensee is authorized to possess sufficient quantities of source or
> special nuclear material to be required to report the possession of
> these materials to the Nuclear Materials Management and Safeguards
> System (NMMSS). If the licensee is authorized to possess reportable
> quantities of NMMSS materials, the inspector will contact the NMMSS
> contractor via telephone at (678) 328-1116 and request a ATask 8
> Inspection Package.@ A minimum of seven calendar days should be
> allowed prior to the start of the inspection trip to allow sufficient
> time for the package to be mailed to the inspector. The inspector
> should contact the NMMSS Project Manager, Division of Nuclear
> Security, Office of Nuclear Security and Incident Response if unable
> to contact the NMMSS contractor.
>
> Additional information regarding inspection of licensees holding NMMSS
> accounts including a complete description of the Task 8 Inspection
> package can be found in Enclosure 7.
>
> Inspectors should anticipate whether or not they will encounter
> protected information during inspection of a licensee. Inspectors
> should be aware of minimum handling requirements for
> sensitiveBunclassified information, i.e., Safeguards Information,
> Official Use Only, and Proprietary Information. For current
> instructions, contact the regional security advisor or refer to the
> security services web page, Number range
> CHAPTER[[http://www.internal.nrc.gov/ADM/DFS/dfs.html]{.underline}](http://www.internal.nrc.gov/ADM/DFS/dfs.html).
>
> The inspector should identify the location of the licensee, make
> travel arrangements, discuss special aspects of the inspection with
> his or her supervisor (i.e., inspection of temporary job sites), and
> obtain the supervisor=s approval for the travel itinerary. At least
> one week in advance of the inspection trip, the inspector shall convey
> the itinerary to the State radiation control agency to give the State
> personnel an opportunity to observe the routine inspections \[see
> Section 10.02\].
>
> Finally, the inspector selects appropriate and calibrated radiation
> detection instrumentation for the inspection and obtains the necessary
> inspection forms (such as NRC Form 591M).
>
> b\. Onsite Inspection Activities. Based on the pre-inspection
> activities, the inspector should be prepared to evaluate a licensee=s
> performance of the licensee=s radiation safety program. Inspection
> activities described below include: focus areas, performance-based
> approach, necessary review and retention of copies of a licensee=s
> records, communication of findings during an inspection, awareness of
> a licensee=s safety culture, and common elements to every inspection.
>
> 1\. The inspector should conduct the inspection in a manner that will
> develop conclusions about licensee performance relative to the
> following focus areas:
>
> \(a\) security and control of licensed material;
>
> \(b\) shielding of licensed material;
>
> \(c\) comprehensive safety measures;
>
> \(d\) radiation dosimetry program;
>
> \(e\) radiation instrumentation and surveys;
>
> \(f\) radiation safety training and practices; and
>
> \(g\) management oversight.
>
> These focus areas are structured as a performance expectation and
> address the activities or program areas most commonly associated with
> measures that prevent overexposures, medical events, or release, loss,
> or unauthorized use of radioactive material. The focus areas are
> described in Section 3 of each program-specific IP.
>
> If the inspector concludes that licensee performance is satisfactory
> from a general review of selected aspects of a focus area, the
> inspection effort expended in reviewing that particular focus area
> will be complete. If the inspector determines that the licensee did
> not meet the performance expectation for a given focus area, the
> inspector should conduct a more thorough review of that aspect of the
> licensee=s program. The increased inspection effort may include
> additional sampling, determination of whether the licensee=s
> procedures are appropriate, and a review of selected records
> maintained by the licensee documenting activities and outcomes.
>
> 2\. The inspector should use a performance-based approach to evaluate
> the focus areas. A determination regarding safety and compliance with
> NRC requirements should be based on direct observation of work
> activities, interviews with licensee workers, demonstrations by
> appropriate workers performing tasks regulated by NRC, independent
> measurements of radiological conditions at the licensee=s facility,
> and where appropriate, a review of selected records. A direct
> examination of these licensed activities and discussions with
> cognizant workers should provide an inspector with reasonable
> assurance of a licensee=s ability to safely use byproduct material and
> is preferable to a review of selected records alone.
>
> In reviewing the licensee\'s performance, the inspector should cover
> the period from the last to current inspection. However, older issues
> preceding the last inspection should be reviewed, if warranted by
> circumstances, such as incidents, noncompliance, or high radiation
> exposures.
>
> The inspector must be prepared to meet all entry requirements
> established by the licensee (i.e. , view the licensee=s safety video,
> use personal protective equipment, or meet any special requirements
> for entering sterile environments). Observations of licensee
> operations, interviews with staff, review of licensee documents to
> complement and support inspector observations, and radiation surveys
> to obtain independent and confirmatory measurements should then be
> conducted. Emphasis should be placed on observing licensee performance
> as it relates to staff training, equipment operation and adequacy,
> overall management of the licensed program, and integration of safety.
>
> The inspector shall not under any circumstances knowingly allow an
> unsafe work practice or a violation which could lead to an unsafe
> situation to occur or continue in his or her presence in order to
> provide a basis for enforcement action.
>
> Unless an inspector needs to intervene to prevent an unsafe situation,
> direct observation of work activities should be conducted such that
> the inspector=s presence does not interfere with licensed activities.
> For example, an inspector should not insist on interviews when:
>
> \(a\) a worker is delayed in performing scheduled work activities
> (i.e., delayed departure to a temporary job site)
>
> \(b\) a worker is preparing or administering dosages or doses,
>
> \(c\) a worker is providing patient care, or
>
> \(d\) a licensee is dealing with customers or members of the public.
>
> 3\. Review of licensee records and other documents should be directed
> toward verifying that current operations are in compliance and further
> review of \"historical\" records should only occur if the current
> records are out of compliance and the inspector believes it necessary
> to determine the presence of a prevalent or persistent problem. If the
> inspector finds it appropriate when an apparent violation has been
> identified, the inspector should gather copies, while onsite, of all
> records that are needed to support the apparent violation. The
> inspector should be aware whether or not the information reviewed or
> gathered has been declared as proprietary information by the licensee.
>
> In general, inspectors should use caution before retaining copies of
> licensee documents, unless they are needed to support apparent
> violations, expedite the inspection (i.e., licensee materials
> inventories), or make the licensing file more complete.
>
> In all cases where licensee documents are retained beyond the
> inspection, inspectors must follow the requirements of MC 0620.
> Inspectors shall ensure that the licensee understands that the
> retained record will become publicly available, and shall give the
> licensee the opportunity to provide redacted copies or to request
> withholding the information pursuant to the requirements of 10 CFR
> 2.390(b)(1).
>
> 4\. The inspector should advise the licensee of the inspection
> findings throughout the course of the onsite inspection and not wait
> until the exit meeting to inform licensee senior management. The
> inspector should allow ample time during the inspection for a licensee
> to correlate information about root cause, consequence, and corrective
> action for an apparent violation. The inspector shall clearly present
> apparent violations and confirm the licensees understanding and
> agreement that a violation occurred, preferably before leaving the
> site.
>
> Whenever possible the inspector should keep NRC regional management
> informed of significant findings (i.e., safety hazards, willful
> violations, and other potential escalated enforcement issues)
> identified during the course of the inspection. This will ensure that
> the inspector is following appropriate NRC guidance under such
> circumstances.
>
> 5\. To have a positive impact on maintaining safety and effectiveness,
> the inspector should develop a general sense of the licensee=s safety
> culture for licensed activities (i.e. , workers have a Aquestioning
> attitude@ and generally adhere to procedures, workers are duly
> cautious when engaged in licensed activities, worker relationships
> with supervisors are conducive to raising safety concerns). The
> inspector=s conclusions about safety culture may only be useful when
> violations are identified and linked to significant risk (i.e. , there
> are an unacceptable number of occurrences with unacceptable health and
> safety consequences).
>
> 6\. Common elements to every inspection are discussed below.
>
> \(a\) Entrance Meeting. After arriving on site, the inspector should
> inform the licensee\'s management representative of the purpose and
> scope of the inspection to be performed. This notification should be
> made as soon as practical after arriving on site. However, in certain
> instances, the inspector may choose to inform the licensee of his or
> her presence on site after initial observations of licensed activities
> currently in progress.
>
> The purpose of the entrance briefing is to inform licensee management
> that an inspection is being conducted and to indicate the tentative
> schedule for discussing or reviewing selected inspection items with
> various licensee staff personnel. However, in some instances, the
> inspector may only need to inform management of NRC\'s presence on
> site, and apprize management that an exit meeting will be conducted at
> the end of the inspection to detail the inspection findings.
>
> This is often an opportune time for the inspector to identify
> personnel to be interviewed. Scheduling interviews will enhance
> inspector efficiency and give the licensee the opportunity to have the
> most knowledgeable individuals present to respond in the areas being
> inspected.
>
> The licensee representative should be asked to identify any recent
> problems related to the licensed program, such as equipment failures
> and unusual radiological problems (i.e., excessive personnel
> exposures, unexpected releases to the environment, QA problems, etc.).
> The representative=s responses may help the inspector assess licensee
> management=s awareness of the radiation protection program.
>
> When an inspection is likely to involve proprietary information, given
> the technical area or other considerations of inspection scope, the
> inspector should discuss with licensee management during the entrance
> meeting how the information will be handled during the inspection.
>
> \(b\) Follow up on Previous Items. Determine whether the licensee
> followed up on cited violations identified during the previous
> inspection. Determine whether the licensee took the corrective actions
> as described in its response to the NOV and followed-up on safety
> concerns and unresolved issues identified during the previous
> inspection.
>
> \(c\) General Overview. The inspector should understand the current
> organization for radiation safety at the facility and the size of the
> current and anticipated radiation use program.
>
> \(1\) Organization. Interview cognizant licensee representatives about
> the current organization of the program. Examine the licensee\'s
> organization with respect to changes that have occurred in personnel,
> functions, responsibilities, and authorities since the previous
> inspection. Identify the reporting relationship and management
> structure between the licensee\'s executive management, the Radiation
> Safety Officer (RSO), and, if applicable, the Chairperson and other
> members of the Radiation Safety Committee (RSC).
>
> \(2\) Scope of Program. Interview cognizant personnel to determine the
> types, quantities, and use of byproduct material, frequency of use,
> staff size, etc., and anticipated changes in the range of the
> radiation use program. Determine if the licensee possesses material in
> accordance with a general license.
>
> \(d\) Observation of Actual Facilities and Licensed Activities.
> Ideally, the inspector should observe work in progress that involves
> NRC-regulated activities. If there is no opportunity, then the
> inspector should ask the workers to demonstrate and explain selected
> licensed activities. It is of utmost importance to inspect licensed
> activities at temporary job sites \[see Section 07.04\].
>
> \(1\) Perform a walk-through of the licensed facility to make general
> observations of the condition of the facility and the licensed
> activities being performed.
>
> \(2\) Conduct inspections of licensed operations that are a
> potentially significant contributor to dose, regardless of shift.
>
> \(3\) Perform routine inspections, when applicable, during first run
> operations.
>
> \(4\) Make direct observations of radiation safety systems and
> practices in use.
>
> \(5\) The walk-through may be performed at any time during the
> inspection. The inspector may need to return to some portions of the
> facility at a later time to observe specific activities.
>
> \(e\) Independent and Confirmatory Measurements. Independent
> measurements are those performed by the inspector without comparison
> to the licensee\'s measurements. Confirmatory measurements are those
> whereby the inspector compares his or her measurements with those of
> the licensee\'s.
>
> \(1\) The inspector should perform independent and confirmatory
> measurements in restricted, controlled, and unrestricted areas of the
> licensee\'s facility. Independent measurements should be performed on
> all inspections, unless exceptional circumstances make it impossible
> to perform the measurements (i.e. , inspector\'s detection equipment
> malfunctions during an inspection trip). Measurements of dose rates at
> the boundaries of restricted areas should be performed at the surfaces
> of the most accessible planes.
>
> \(2\) Examples of measurements that may be performed include area
> radiation surveys, wipe samples, soil samples, leak tests, air flow
> measurements, etc. These measurements should be taken in licensed
> material use areas, storage areas, effluent release points, etc.
>
> \(3\) The inspector may ask the licensee to spot‑check radiation
> levels in selected areas, using the licensee\'s own instrumentation,
> if the licensee possesses survey instrumentation. However, the
> inspector must use NRC\'s instruments for independent verification of
> the licensee\'s measurements. The inspector\'s instruments must be in
> current calibration and source checked before they leave the regional
> office.
>
> \(f\) Special License Conditions. If applicable, verify the
> licensee\'s compliance with any special license conditions that are
> unique to a particular practice, procedure, or piece of equipment used
> by the licensee. In these instances, the inspector should verify that
> the licensee understands the additional requirements, and maintains
> compliance with the special license conditions.
>
> \(g\) Exit Meeting. At the conclusion of the inspection the inspector
> should conduct an exit meeting with the most senior licensee
> representative present at the facility. As appropriate, the inspector
> should prepare NRC Form 591M before the exit meeting so that the form
> can be properly executed during the exit meeting. \[See Section
> 08.04\]
>
> If a senior management representative is unavailable for the exit
> meeting, the inspector should hold a preliminary exit meeting with
> appropriate staff onsite. As soon as practical after the inspection,
> the inspector shall hold an exit meeting directly with a senior
> management representative (and the licensee\'s RSO, if not present at
> the preliminary exit meeting). This meeting involving the licensee=s
> management and RSO will usually be held by telephone conference call.
>
> \(1\) For initial and routine inspections, the inspector should
> request the meeting and control the meeting for purposes of the
> inspection. During the meeting, the inspector shall explain any cited
> violation of NRC requirements and the inspector=s understanding of the
> licensee=s corrective action plan for each violation \[See Section
> 05.01.b.4 about keeping the licensee informed of apparent violations
> during the inspection\].
>
> To avoid the formal disputed violation process \[See NRC Enforcement
> Manual\], the inspector should confirm the licensee=s agreement and
> mutual understanding of cited violations and associated corrective
> action plans. If the licensee disagrees with a violation, the
> inspector should contact his or her supervisor before leaving the site
> to obtain further instructions. It may be necessary to continue the
> inspection or modify the cited violation. Together, the inspector and
> supervisor should make decisions about the enforcement strategy.
> Before leaving the site, the inspector should inform the licensee
> about the next steps in the enforcement process.
>
> The inspector should explain safety-related concerns or unresolved
> items identified during the inspection, and the status of any
> previously identified violations.
>
> Prompt corrective action must be initiated by the licensee for safety
> concerns or violations of significant regulatory requirements that
> affect safe operation of a licensee facility. The inspector should not
> leave the site until the concern is fully understood by the licensee
> and corrective action has been initiated. If the inspector and the
> licensee disagree on the magnitude of the concern regarding safe
> operation of the facility, regional management should be notified
> immediately.
>
> Although deficiencies identified in some areas (i.e., workers\'
> knowledge of the Part 20 requirements) are not always violations, the
> inspector should bring such deficiencies to the attention of licensee
> management at the exit meeting and also in the cover letter
> transmitting the inspection report or Notice of Violation (NOV).
>
> At the exit meeting, the inspector should verify whether the licensee
> considers any materials provided to or reviewed by the inspector to be
> proprietary in nature. If so, the inspector should assure proper
> handling of the information.
>
> \(2\) For a reactive inspection, the inspector should refer to IP
> 87103 for specific instructions about the exit meeting. It is
> particularly important that the inspector keep regional management
> informed of the inspection details and explain the exit meeting
> strategy with his or her supervisor before beginning the meeting.
> During the exit meeting, the inspector should explain the preliminary
> inspection findings including any apparent violations of regulatory
> requirements. The inspector should ask the licensee to confirm the
> licensee=s understanding of the findings. If the licensee does not
> provide additional information and disagrees with the preliminary
> findings and apparent violation(s), the inspector should assure the
> licensee that the inspector will convey the licensee=s disagreement to
> regional management. The inspector should close the meeting and
> promptly leave the site without lingering for any further discussion
> before presenting these issues to regional management. The licensee=s
> next opportunity to discuss the findings will be after the regional
> management has reviewed these matters.
>
> c\. Post-inspection activities. After returning from an inspection
> trip, the inspector shall discuss the results of the inspection trip
> with his or her supervisor. This discussion should be sufficient to
> alert management to significant enforcement, safety, or regulatory
> issues. This meeting need not be documented, but it should be held in
> all cases. To complete the inspection, the inspector documents the
> inspection results in accordance with guidance in this MC \[See
> Section 2800-08\] and other chapters, as appropriate.

05.02 [Reactive Inspections]{.underline}. Inspections performed to
follow up on incidents (i.e., medical event, overexposure, and loss or
release of significant quantities of radioactive materials) take
precedence over the routine inspection program. Regional management
shall promptly assess the preliminary information received concerning
the incident and will determine if a reactive inspection is necessary.
Regional management, in consultation with IMNS, shall also determine if
the event warrants the recommendation for an AIT or IIT, rather than a
reactive inspection. The emphasis during the reactive inspection will be
on the analysis of the sequence of events and the conditions that
existed at the time these events occurred. The analysis should lead to
the determination of contributing factors and root causes, and to the
formulation of corrective actions to prevent recurrence. Generally,
issues of compliance will be addressed after all safety issues and
program weaknesses are identified and clearly understood.

Inspections resulting from allegations will be documented in accordance
with Management Directive (MD) 8.8, AManagement of Allegations.@

Reactive inspections involving a medical event will be performed using
the guidance in Management Directive 8.10, \"NRC Medical Event
Assessment Program.\" All other reactive inspections will be performed
using the guidance in Inspection Procedure (IP) 87103, AInspection of
Material Licensees Involved in an Incident or Bankruptcy.@

A narrative inspection report will be written for all reactive
inspections. The narrative report will include a discussion of the
sequence of events leading up to the incident, the contributing and root
causes of the event, corrective actions taken or proposed by the
licensee, and a discussion of the regulations applying to the incident.
The inspector shall annotate inspection reports with the NMED Event No.
if the reactive inspection was initiated by an NMED reportable event.
Enclosure 3 provides instructions to properly Acomplete@ the record for
NMED. Enclosure 6 may be completed to document inspection findings that
were unrelated to the event \[see Section 08.03.b\].

05.03 Initial Inspections: Initial inspections of a new licensee or an
existing licensee which obtained an amendment for Program Code 02240
(Medical TherapyBOther Emerging Technology) shall be announced and
completed within 12 months of the date the new license or amendment was
issued by a Regional Office. To schedule the initial inspection, the
date in the Anext inspection date@ data element in the Licensing
Tracking System (LTS) shall be 12 months from the date the new license
or amendment was issued. The Alast inspection date@ data element in the
LTS shall be 0 (zero) or blank.

> a\. Initial inspections of all licensees. Once onsite, the inspector
> should interview licensee staff (management and technical) to
> determine if licensed material has been possessed or licensed
> operations have been performed. Methods for determining if licensed
> activities have been performed include, but are not limited to the
> following: performing a site tour, performing confirmatory
> measurements, and/or contacting distributors of radioactive material,
> such as local radiopharmacies, to see if they have distributed
> material to the licensee. If the licensee has possessed licensed
> materials or performed licensed operations, then the inspector should
> conduct an inspection in accordance with Section 05.01 and other
> applicable guidance.
>
> If it is determined that the licensee has not possessed licensed
> material or performed licensed operations, the inspector should:
>
> 1\. Determine the licensee\'s plans for future possession of licensed
> material or plans to perform licensed operations. In assessing the
> licensee\'s future plans, the inspector should determine if adequate
> facilities and equipment are in place to safely handle licensed
> material, as described in the license application.
>
> 2\. Use this opportunity to discuss the license and applicable
> regulations with the licensee. The inspector should include a
> discussion on unique license conditions.
>
> 3\. Request that the licensee notify the NRC before receipt of
> licensed material or initiation of licensed operations.
>
> 4\. Document the onsite inspection by completing a Form 591M. The
> Aprogram scope@ description in the Form 591M should include the
> licensee\'s plans for future possession of material or plans to
> perform licensed operations.
>
> 5\. Ensure that the date in the Anext inspection date@ data element in
> the LTS is 12 months from the date of the onsite visit.
>
> b\. New licenses excepted from an initial inspection. There are
> certain circumstances that require a new license to be issued to the
> licensee, but an initial inspection is not warranted.
>
> 1\. New licenses that are issued solely as a result of a licensee=s
> change of mailing address are not required to receive an initial
> inspection, if the licensee=s place of use remains the same as on the
> previous license. The Alast inspection date@ and Anext inspection
> date@ data elements in the LTS should remain the same as for the
> licensee=s previous license.
>
> 2\. New licenses that are issued as a result of a change of ownership
> or transfer of control are not required to receive an initial
> inspection unless:
>
> \(a\) the organization controlling the licensed activities changes
> substantially (i.e., changes in key personnel, authorities, or
> resources associated with the radiation safety program);
>
> \(b\) the licensee significantly increases the types, quantities, or
> forms of radioactive materials on the license;
>
> \(c\) the licensee significantly increases the different uses
> authorized on the license (i.e., adds brachytherapy to a diagnostic
> nuclear medicine license);
>
> \(d\) the licensee significantly increases the number of authorized
> users; or
>
> \(e\) the new license authorizes one or more new facilities.
>
> If none of these conditions applies, then the Alast Inspection date@
> and Anext inspection date@ data elements in the LTS should remain the
> same as for the previous license.
>
> 3\. New licenses that are issued because a licensee did not file a
> timely application for license renewal are not required to receive an
> initial inspection in accordance with this section, unless more than 6
> months have elapsed between the date the initial license expired and
> the date the renewal application was submitted. The Alast inspection
> date@ and Anext inspection date@ data elements in the LTS should
> remain the same as for the licensee=s initial license.

05.04 Routine Inspections. Routine inspection of licensees shall be
conducted at intervals in years corresponding to the inspection priority
listed in Enclosure 1. If the licensee has possessed material or
performed licensed operations since the last inspection, the inspector
should perform a routine inspection of the facility as defined in the
program-specific inspection procedure. If the licensee has not possessed
material or performed licensed operations since the last inspection, the
inspector should follow the instructions in Section 05.03(a)(1) through
(4).

05.05 [Telephonic Contacts (Priority T)]{.underline}. For certain
licensees, the regions shall use telephone contacts at 5-year intervals
in lieu of an onsite inspection, with the exception of initial or
reactive inspections. Enclosure 1 designates these licensees as priority
T. As defined in Section 2800-03, telephonic contacts are useful for
staying in touch with priority T licensees. Procedures for using the
telephonic contacts are included as Enclosure 2. A telephonic
questionnaire is attached as Enclosure 2, Exhibit 1 and standard
responses back to licensees contacted by telephone are included as
Enclosures 4 and 5. This questionnaire should be completed, signed by
the inspector, and placed in the docket file, and the Anext inspection
date@ data element in the LTS shall be changed to indicate the date of
the next telephonic contact. The inspector shall brief the supervisor
about the telephonic contact. The inspector shall charge time to HRMS as
direct inspection effort under Program Code PA No. 203232E, (generic TAC
No. A10159).

2800-06 INSPECTION INTERVALS

06.01 Scheduling Inspections. To achieve the goals of cost saving and
efficient use of staff time and travel, inspections (other than initial
inspections) may be scheduled within a window around their inspection
due date. Inspection of licensees in priorities 1, 2, and 3 may vary
around their due date by  25 percent. Inspection of priority 5
licensees and telephonic contact of priority T licensees may vary around
their due date by  1 year. Inspections will not be considered
\"overdue\" until they exceed the scheduling window. Inspections may be
scheduled before their window if the inspector receives information that
warrants earlier inspection.

06.02 [Combining Inspections]{.underline}. If a licensee holds several
licenses with different Program Codes that are assigned different
Priority Codes in Enclosure 1, a single inspection may be scheduled
whenever practicable to aid in more effective use of the inspector\'s
time spent in travel status. In the determination to combine inspections
on a continuing basis, consideration should be given to not
\"over‑inspect\" a lower‑priority license versus the need and
desirability to inspect a licensee\'s total activities for a more
complete assessment of its safety and compliance performance. The
priority designations of the lower‑priority licenses shall not be
changed in these cases; the more frequent inspections of lower‑priority
licenses shall be handled only in the scheduling process.

06.03 Inspections After Escalated Enforcement. If escalated enforcement
action has taken place for a particular licensee, a follow-up inspection
to focus on the Severity Level III or above violation(s) shall be
scheduled and conducted within 6 months of the last inspection or
sooner, in accordance with the guidance in this MC regarding reduction
of inspection interval, after completion of the escalated enforcement
action, to assess the licensee\'s follow-up actions in response to the
previous violations. Regions may perform this follow-up inspection as a
part of a routine inspection.

06.04 Reduction of Inspection Interval

> a\. The inspection interval shall not be extended beyond that
> specified by the priority system indicated in Enclosure 1. The
> interval between inspections may be reduced (shortened) and
> inspections conducted more frequently than specified in the priority
> system on the basis of poor licensee performance. The main
> consideration in reducing the inspection interval should be evidence
> of moderate to severe problems in the licensee\'s radiation safety
> program. Poor compliance history is one indicator of such problems.
> Lack of management involvement or control over the radiation safety
> program is another indicator. Specifically, licensees that meet the
> following conditions shall be considered for reduction in inspection
> interval if:
>
> 1\. A Severity Level I, II, or III violation results from the most
> recent inspection; or
>
> 2\. Issuance of an Order as a result of the most recent inspection; or
>
> 3\. A \"management paragraph\" appears in the cover letter
> transmitting the notice of violation on the most recent inspection
> (i.e., a paragraph that requires the licensee to address adequate
> management control over the licensed program); or
>
> 4\. An event requires a reactive inspection; or
>
> 5\. Repetitive violations occur.
>
> The above list is not exhaustive; the inspection interval can and
> should be reduced for any other reason deemed pertinent by regional
> management. An example would be an enforcement conference where the
> outcome did not include escalated enforcement action, but did indicate
> the need for the licensee to improve some aspect(s) of its compliance
> program.
>
> Another example would be an industrial radiography licensee or a well
> logging licensee which is authorized to use byproduct material at
> temporary job sites and the current inspection was limited to an
> office inspection and no temporary job site inspection was completed
> during the current inspection. \[See Section 07.04.\]
>
> A licensee that meets the above criteria may have its inspection
> interval reduced by any length. For example, a priority 5 licensee
> with a poor performance record could be rescheduled for its next
> inspection in 2 or 3 years, rather than 5 years, depending on the
> scope of licensed activities. Or a priority 2 licensee with a Severity
> Level III or above violation could be rescheduled for its next
> inspection in 1 year, although a follow up inspection to focus on the
> Severity Level III or above violation may have already been completed
> within 6 months. \[ See Section 06.03\] The reduction shall be valid
> only until the next inspection, but regional management shall consider
> the results of the next inspection when determining whether the
> reduced interval should be continued, changed, or returned to normal.
>
> b\. The designated inspection priority for these licensees should not
> be changed in the LTS. However, the \"next inspection date\" field in
> the LTS should be changed to contain the reduced date for the next
> inspection. To identify the reduced inspection date in the LTS, the
> letter \"R\" shall be entered under Special Inspection Codes on the
> Inspection and Enforcement Screen of the LTS.
>
> c\. To document the reduction in the interval between inspections, a
> brief note (i.e., in the inspection records) should be written by the
> inspector, approved and signed by the inspector\'s immediate
> supervisor, and placed in the docket file.

06.05 [Other Changes in Inspection Interval]{.underline}. At the
discretion of regional management, other changes in inspection interval
may be made to achieve efficiencies in the use of inspection resources
and to reduce regulatory impact on the licensee. This may include more
frequent inspections to ensure that inspectors have the opportunity to
sufficiently observe licensee operations and increase public confidence
by increasing the inspection focus on higher risk activities, without
significantly increasing the regulatory burden on licensees. For
example, rather than perform a single, large team, high impact
inspection of the license at the normal interval, more frequent
inspections may be performed by individuals or smaller teams that
specifically focus on higher risk licensee activities.

2800-07 SPECIAL INSPECTION ACTIVITIES

07.01 [Expired and Terminated Licenses and Decommissioning
Activities]{.underline}. Notification that a license has expired or is
being terminated requires prompt action (i.e., within 30 days) to ensure
that licensed material has been properly transferred or disposed of, and
that all areas where material was used may be safely released for
unrestricted use.

Inspectors should be aware of the need for security and control of
radioactive materials at these types of facilities. This may be done by
review of the licensee\'s transfer, disposal, and closeout survey data;
by confirmation that an authorized recipient has received the material;
and/or by performance of an inspection that may include confirmatory
surveys. The inspector should also review records of disposals, burials,
and public dose that may be required to be submitted to the NRC on
termination or retirement of the license. Such actions would be
conducted as soon as appropriate after notification is received.

If an inspection is performed, the inspector should also verify that the
licensee is complying with regulations for timely decontamination and
decommissioning, and meeting the required schedules for licensee action,
as specified in the decommissioning timeliness rule.

Specific guidance for performing closeout inspections is outlined in IP
83890.

07.02 [Significantly Expanded Programs]{.underline}. During routine
inspections of licensed facilities, inspectors should evaluate if
licensed activities have significantly increased or decreased since the
last inspection. A license reviewer may request a near-term onsite
inspection for a significant licensing action that was recently
completed. Both the inspectors and the reviewers should make the
inspection and licensing supervisors aware of the following changes in a
licensee=s scope of use.

> a\. Through interviews of licensee staff or observations of licensed
> activities, the inspector shall determine if:
>
> 1\. the licensee has recently increased the types, quantities, and
> uses of radioactive material;
>
> 2\. the license authorizes a physical move of a facility or a new use
> at a temporary jobsite;
>
> 3\. the license authorizes new (i.e., since the previous inspection)
> satellite facilities where materials will be used or stored;
>
> 4\. the licensee has increased the types of uses or disposal (i.e.,
> incineration or decay-in-storage) of radioactive material; and
>
> 5\. the number of authorized users has significantly increased or
> decreased.
>
> If any of the above items demonstrates a possibility that the licensed
> activities have significantly changed, then the inspector should
> document the changes to the licensee\'s program in the inspection
> records and notify the inspection supervisor.
>
> b\. A license reviewer may request a special inspection, if, during
> the licensing review process, it is determined that the licensee\'s
> program has significantly expanded. \[See the 5 points in the
> preceding paragraph.\] In that case, the license reviewer shall ensure
> that the Anext inspection date@ data element in the LTS is changed and
> shall post a notice in the docket file for the inspector \[see
> NUREG-1556, Volume 20, Section 4.12 (Significant Licensing Actions
> that Warrant Onsite Inspection) and Appendix C (Checklist C.5)\].
>
> For example, an amendment issued for a new medical therapy modality
> under 10 CFR 35.1000 (Program Code 02240) shall be inspected within 12
> months of the date of the amendment. The reviewer shall ensure that
> the next inspection date data element in the LTS was appropriately
> changed, the docket file was posted with a paper copy of the memo in
> Appendix C of the NUREG-1556 (Volume 20), and the inspection and
> licensing supervisors were notified accordingly.

07.03 Reciprocity Inspections. Section 150.20 grants a general license
to any person, with a specific license from an Agreement State
authorizing use at temporary job sites, to conduct the same activity in
areas under Federal jurisdiction. The licensee must submit an NRC Form
241, \"Report of Proposed Activities in Non-Agreement States\" 3 days
before engaging in the licensed activity.

> a\. The recipient of the NRC Form 241 is the NRC region in which the
> Agreement State that issued the license is located(licensing region).
>
> b\. MC 1220 details the process for scheduling the inspection of the
> licensee operating under reciprocity. The licensing region shall take
> immediate action to enter information from the form into the
> Reciprocity Tracking System Before reciprocity work begins, the
> licensing region shall forward the form to the NRC regional office
> having jurisdiction in the area of the licensee\'s proposed activities
> (inspecting region).
>
> c\. The inspecting region shall follow the policy and guidelines found
> in MC 1220, Appendix III, for performing inspections of reciprocity
> licensees. MC 1220 details the percentage of reciprocity licensees to
> be inspected each year. The inspectors shall use the program-specific
> procedures which are used for equivalent NRC-licensed activities.
>
> d\. The inspecting region is responsible for initiating enforcement
> action and taking other follow‑up actions, as appropriate for the
> inspection. In addition, the inspecting region shall send copies of
> inspection and enforcement documentation to the licensing region and
> to the Agreement State radiation control agency which issued the
> license that is the basis for the general license under 10 CFR 150.20.

07.04 Temporary Job Site or Field Office Inspections

> a\. Temporary Job Sites. For a licensee authorized to work at a
> temporary job site, inspectors shall make every reasonable attempt to
> include an unannounced inspection of licensed activities at such a
> location(s).
>
> 1\. During the inspection of a licensee\'s principal place of
> business, the inspector should, through discussions with the licensee
> and review of licensed material utilization records, ascertain if the
> licensee is working at the temporary job site location(s).
>
> 2\. The inspector may contact the licensee=s customer to schedule the
> temporary job site inspection. The licensee\'s customer should be
> requested not to notify the licensee of the inspection.
>
> 3\. If an unannounced inspection of the location(s) is not possible,
> then the inspector should attempt to arrange an announced inspection
> at the temporary job site(s).
>
> 4\. If a temporary job site inspection is not performed, a brief note
> will be written in the inspection records, giving an explanation for
> the missed temporary job site inspection. In certain cases, the Anext
> inspection date@ data element in the LTS may indicate a reduced
> inspection interval. \[See Section 06.04\]
>
> b\. Permanent Field Offices. Each licensing region is responsible for
> requesting an assist inspection (i.e., an inspection conducted by one
> region at the request of another region) at each permanent field
> office to be inspected, if these locations are outside the
> geographical area of the licensing region. The inspecting region
> should provide complete documentation and recommend enforcement action
> to the licensing region, which will distribute the documentation,
> initiate enforcement action, and take other follow‑up actions, as
> appropriate to the case. \[See Section 09.02\]
>
> 1\. If the license authorizes licensed activities to be conducted from
> two or three permanent facilities (main office plus one or more field
> offices), only one location must be inspected at the interval
> specified in this chapter for the type of license. If the license
> authorizes licensed activities to be conducted from 4 to 10 permanent
> facilities (main office plus 3 to 9 field offices) at least 2
> locations must be inspected at the interval specified in this chapter
> for the type of license. If the license authorizes licensed activities
> to be conducted from more than 10 permanent facilities (main office
> plus more than 9 field offices), about 20 percent of the locations
> should be inspected. Inspection of various field offices should be
> rotated to assess the licensee\'s entire program over several
> inspection cycles.
>
> 2\. If the license does not authorize licensed activities at the main
> office location, the inspection should include the main office
> location to verify the licensee=s audit program was implemented to
> determine the performance of its field office activities.
>
> 3\. If an inspection identifies significant program weaknesses (i.e.,
> Severity Level III or above violation(s), multiple Severity Level IV
> violations indicative of poor program management/oversight), the
> licensing region should consider expanding the initial review to
> include additional satellite locations to determine the extent of the
> weakness.
>
> c\. Off-Shore Waters. For a licensee working in off-shore waters, the
> regional staff should either make travel arrangements to accompany
> another federal agency to the rig to complete an unannounced
> inspection or contact the rig operators, or appropriate licensee
> contact, to request the licensee to provide travel arrangements to the
> rig when work is in progress. Before accepting transportation or
> lodging from the licensee, staff should obtain approval from the
> individual\'s immediate supervisor. This approval should be documented
> with a brief statement in the inspection records. NRC should reimburse
> the provider for the cost of transportation, lodging, or other
> services accepted during the course of inspections.

07.05 [Team Inspections]{.underline}. \[NOTE: This section is included
solely for team inspections of materials licensees. The term \"team
inspections\" is used here only for the purposes of this MC. The
requirements of other MCs or IPs for team inspections or team
assessments of nuclear reactors and fuel cycle facilities do not
apply.\]

Regional offices shall conduct team inspections of major licensees
within the region on an as-needed basis. The decision on whether to
conduct a team inspection involving agencies outside NRC (other than
State radiation control agencies) shall be made by regional management,
in consultation with IMNS. Examples of situations where team inspections
may be appropriate are:

> a\. Routine inspections of major licensees (i.e., broad-scope
> academic, broad-scope medical licensees, and large
> processor/manufacturers). A team inspection should be considered when
> the size or complexity of operations at a broad-scope licensee goes
> beyond that which one or two inspectors can cover in a week. Team
> inspections are also appropriate when the team will include an expert
> in a specialty discipline other than health physics, such as a medical
> physicist, human factors specialist, fire protection specialist,
> engineer, or other specialized fields.
>
> b\. Reactive inspections of any type of licensee where one or more
> specialists are needed on the team (of three or more inspectors).
> Also, reactive inspections of any licensee where at least one of the
> three or more inspectors is from another region or from Headquarters.
>
> c\. Routine inspections of major licensees within the year before
> license renewal. Team inspections are appropriate methods to assess
> licensees\' strengths and weaknesses, and to provide feedback to the
> licensing process. Such team inspections should include license
> reviewers on the team. However, pre-licensing visits are not
> considered inspections, and team inspections should not take the place
> of pre-licensing visits.
>
> d\. Inspections of any type (routine or reactive) that include team
> members from outside the NRC and the State radiation control agencies,
> such as members from the Department of Transportation (DOT), the
> Environmental Protection Agency (EPA), the Food and Drug
> Administration (FDA), and the Occupational Safety and Health
> Administration (OSHA). For inspections of any type that involve
> participation by outside agencies (other than State radiation control
> agencies), the region should coordinate through the NRC Regional State
> Liaison Officer with the outside agency.

At regional management discretion, inspection plans may be developed for
all team inspections. Inspection plans should be considered for team
inspections of major, broad-scope academic or medical licensees, large
manufacturers, or in cases where team members from agencies outside the
NRC (other than State radiation control agencies) are involved. \[See
examples (a) and (d) in this section\]

07.06 [Abandonment of Licensed Activities]{.underline}. Returned,
undeliverable mail to licensees should trigger a prompt follow-up. The
follow-up should include a telephone call to the licensee to establish
the licensee\'s physical address. If telephone contact is not
established, then an inspector should be sent to the licensee\'s site.
The regional decision of when to send an inspector to a licensee\'s site
should be based on the complexity of the licensed activities, and the
types and quantities of licensed material.

07.07[Inspection of Generally Licensed Devices]{.underline}. Routine
inspections of general licensees \[other than reciprocity (10 CFR
150.20)\] are not normally performed. However, if a specific licensee
also possesses generally licensed devices that require registration
under 10 CFR Part 31, the inspector should verify the adequacy of the
licensee=s control and accountability of the devices \[See IP 87124,
Focus Element 1\]. Inspections of general licensees shall also be made
to resolve issues such as allegations, incidents, or indications of
unsafe practices.

07.08 Inspection of Master Materials Licenses. A Master Materials
License (MML) is a multi-site, multi-regional materials license (Program
Code 03613) to authorize possession, use, disposal, etc., of byproduct,
source, and/or special nuclear material. The MML authorizes the MML=s
central radiation control program which includes internally managed
licensing and inspection programs that are similar to NRC=s licensing
and inspection programs. The NRC inspection of an MML is a comprehensive
evaluation of the MML=s central radiation control program.

IMC 2810 specifically describes the NRC=s organization and
administrative procedures for oversight of the MMLs. IP 87129 provides
specific guidance for NRC=s inspection of an MML.

Each licensing region (Lead Region) has assigned the project management
responsibilities for the MML to a designated NRC staff member (NRC MML
Project Coordinator). One of the coordinator=s responsibilities is the
routine inspection of the MML. As such, the Lead Region requests other
of the NRC=s regional offices (Assisting Regions) to complete assist
inspections (accompaniment inspections and independent inspections).

> a\. For accompaniment inspections, the Assisting Region=s inspectors
> shall implement IP 87129 while accompanying the MML=s staff during
> routine radiation safety audits of the MML=s permittees. The purpose
> of the accompaniment inspection is to determine whether or not the
> MML=s staff are inspecting the permittees in accordance with NRC=s
> inspection policies and procedures \[See Enclosure 4\]. In addition,
> the inspectors shall obtain information deemed necessary by the Lead
> Region for special issues relating to the inspection.
>
> 1\. IP 87129 includes forms to document the accompaniment inspections.
>
> 2\. The inspector shall provide the completed forms to the Lead
> Region=s MML Coordinator as per the established timeliness goal.
>
> b\. For independent inspections, the Assisting Region=s inspectors
> shall implement the program-specific guidance contained in the
> inspection procedures in Enclosure 4. In addition, the inspectors
> shall obtain information deemed necessary by the Lead Region for
> special issues relating to the inspection.
>
> 1\. The inspections shall be unannounced by NRC or the MML.
>
> 2\. Inspection report numbers will be provided by the Lead Region.
>
> 3\. Inspectors will provide completed inspection documentation to the
> Lead Region MML Coordinator within the established timeliness goal.
> \[See Section 2800-08\]
>
> \(a\) NRC Form 591M shall not be issued to the MML permittee=s
> management.
>
> \(b\) The Lead Region shall issue all inspection-related
> correspondence to the MML.

All allegations received by NRC inspectors shall be forwarded to the
Lead Region MML Coordinator and Office Allegation Coordinator for action
by the Lead Region. If independent follow up by NRC is needed, the Lead
Region may request the Assisting Region to assist with the follow up for
the allegation.

07.09 Inspection of Licensees Holding Nuclear Materials Management and
Safeguards System Accounts. The Nuclear Materials Management and
Safeguards System (NMMSS) is the federal database for current and
historical data on the receipt, shipment, and inventory adjustment of
certain source and special nuclear materials that are listed in
Enclosure 7. The United States government uses the NMMSS data to comply
with certain international requirements for tracking certain source and
special nuclear materials. The NMMSS database is operated by a
contractor on behalf of the U.S. Department of Energy (DOE) and the NRC.

During each routine inspection of a licensee holding a NMMSS account,
the inspector will:

1\. Review the licensee=s inventory records of licensed materials and
compare them to the information that the licensee has reported to NMMSS.

2\. Compare licensee transaction data reported to NMMSS for certain
source and special nuclear material (see Enclosure 7) with the receipt,
transfer and disposal records maintained by the licensee in accordance
with 10 CFR 40.61 or 74.19.

3\. At a minimum, physically assess the presence of a representative
sample of the NMMSS-reportable material that the licensee claims to
possess according to the licensee=s most recent report to NMMSS.

4\. Provide the licensee with the NMMSS summary of the licensee=s
administrative information and explain the process for making any needed
changes.

Additional information about reviewing NMMSS records is contained in
Enclosure 7.

2800-08 DOCUMENTATION OF INSPECTION RESULTS

08.01 [What Constitutes an Inspection]{.underline}. The following
guidance is provided to assist in determining when activities constitute
an inspection.

> a\. An inspection will be considered to have been performed if:
>
> 1\. the inspection involves a licensee that possesses or has possessed
> licensed material since the last inspection, including material
> possessed under a \"possession-only license\" or that is performing or
> has performed licensed activities since the last inspection; or
>
> 2\. the inspection is an initial inspection that has been performed in
> accordance with Section 05.03.
>
> If it is possible to inspect records or other items according to
> license conditions or NRC regulations, such activities should be
> inspected and be recorded as an inspection, whether the radiation
> safety officer (RSO) is present or not, including those licenses that
> have expired or are being processed for termination.
>
> If the RSO is not onsite, the inspector shall make a telephone call to
> contact the RSO about the inspection. At the conclusion of the
> inspection, the inspector shall re-contact the RSO to explain the
> inspection results. If the inspector is unsuccessful in announcing the
> inspection to the RSO, the inspector shall make a follow-up telephone
> call to the RSO as soon as possible after the onsite inspection.
>
> b\. An inspection will not be considered to have been performed if the
> licensee or licensee\'s representatives are not available to assist
> with the inspection, and the inspector is unable to perform inspection
> activities. The inspector will document the on-site activities by
> placing a note in the docket file, signed by the inspector, that
> briefly summarizes the attempted inspection. Together, the inspector
> and his or her supervisor should determine when another attempt will
> be made to inspect the licensee and the \"next inspection date\" data
> element in the LTS should be changed to reflect the new date. The
> region should not record an attempted inspection in the LTS as \"an
> inspection.\"
>
> c\. Regions performing assist inspections will receive credit toward
> the operating plan goals for conducting each assist inspection.
>
> d\. The HRMS allows the time spent in gathering factual material to be
> charged against the time budgeted for performing routine inspections.
> Telephone contacts are not onsite inspections even though they involve
> direct inspection effort. The inspector should charge their time to
> HRMS, Program Code PA No. 203232E, (TAC No. A10159). The fact that a
> telephone contact of a Priority T licensee was made should not be
> entered into the LTS as an inspection; however, the date of the next
> telephone contact should be indicated in the Anext inspection date@
> data element in the LTS.
>
> e\. A reactive inspection will not substitute for a routine inspection
> unless the scope of the inspection is comprehensive.

08.02 [Allegations]{.underline}. Allegations will be followed up and the
results documented and transmitted in accordance with NRC Management
Directive 8.8, \"Management of Allegations.\" No reference to follow-up
of an allegation or employee concern will be entered in the inspection
records, inspection reports, or other documents that will be filed in
the docket file for the licensee. Following is further guidance about
Achilling@ effect.

> a\. In conducting interviews or other activities with licensee
> personnel, inspectors should be sensitive to areas where employees may
> be reluctant to raise concerns about the licensee\'s program. Even if
> the licensee addresses an employee\'s concern regarding safety issues,
> there could be underlying factors that could produce a \"chilling\"
> effect or reluctance for employees to report such issues. For example,
> the following questions will help an inspector determine if problems
> exist in the licensee\'s safety program:
>
> 1\. Has there been an unexplained change in the number or nature of
> valid concerns that employees have raised with the licensee or the
> NRC?
>
> 2\. Have there been interactions with NRC personnel that suggest that
> some employees may be hesitant to raise concerns or present
> information to NRC?
>
> 3\. Are employee concerns addressed by licensee management in a timely
> manner?
>
> 4\. Is the licensee\'s corrective action successful in addressing
> employees\' concerns?
>
> b\. If any indication of a \"chilling\" effect is found, the inspector
> shall inform regional management for further review and follow-up.

08.03 [Methods of Documenting Inspection Results]{.underline}.
Inspections shall be initially documented by completing inspection
records or a narrative report.

> a\. Enclosure 5 provides the format for documenting inspections that
> result in the issuance of an NRC Form 591M. If an NRC Form 591M is not
> issued, then the inspection results will be documented on Enclosure 6
> or in a narrative report as described below, and the region will
> communicate the inspection findings to the licensee in a formal letter
> with a Notice of Violation, if appropriate. The inspection records do
> not have to be typed, but should be legible and should contain:
>
> 1\. the procedure(s) used;
>
> 2\. the focus areas examined;
>
> 3\. the status of follow-up items involving prior enforcement or
> reported licensee events;
>
> 4\. sufficient information to support cited violations, non-cited
> violations, and closed violations identified during a previous
> inspection;
>
> 5\. description of completed and anticipated corrective actions to any
> identified violations; and
>
> 6\. a succinct description of the scope of the licensee=s program.;
> and,
>
> 7\. if applicable, a statement that the licensee=s reporting to NMMSS
> was reviewed in accordance with the procedures described in Enclosure
> 7.
>
> A different inspector should be able to use the inspection records in
> preparing for a subsequent inspection, and to determine whether
> corrective actions have been taken.
>
> b\. A narrative report is required for all team inspections and
> actions involving an enforcement conference or escalated enforcement.
> For escalated cases, the narrative report need address only the areas
> in which safety concerns and violations are identified (all other
> areas may be documented using Enclosure 6). All inspection
> documentation shall be filed in the licensee\'s docket file. For
> medical events, the narrative report must follow the guidance in
> Management Directive 8.10. Additional guidance on inspection reports
> can be found in MC 0610, \"Inspection Reports.\" Narrative inspection
> reports may be used to document other types of inspections at the
> discretion of regional management.

08.04 [Methods of Transmitting Inspection Results]{.underline}. Results
of inspections may be reported to the licensee by either issuing an NRC
Form 591M , or a regional office letter either with or without a Notice
of Violation (NOV) to the licensee.

> a\. NRC Form 591M, ASafety Inspection Report@, shall be used:
>
> 1\. to document clear inspections and inspections resulting in
> Severity Level IV violations (that are neither willful nor repetitive)
> that can be corrected while the inspector is present, or that the
> licensee is able to correct easily; and
>
> 2\. to document non-cited violations (NCVs), as discussed in the
> Enforcement Manual.
>
> 3\. When the NRC Form 591M is used to document the results of an
> inspection, the inspector must ensure that each cited and non-cited
> violation on the form includes: a brief statement of the
> circumstances, including the date(s) of the violation or NCV and the
> facts necessary to demonstrate that a requirement was not met,
> reference to the regulation or license condition that was violated,
> and a description of the licensee=s corrective actions. Following are
> examples of cited violations on an NRC Form 591M:
>
> \(a\) Section 20.1101(c) requires the licensee to annually review the
> content and implementation of the radiation protection program. During
> years 2002 and 2003, the license did not complete the review. The
> licensee will complete the review in October 2004 for the period of
> January 2002 through September 2004. The licensee intends to complete
> future reviews in October of each year by completing NUREG-1556,
> Volume 2, Appendix I, Radiation Safety Program Audit.
>
> \(b\) As required by 10 CFR 34.29, the licensee did not perform a
> quarterly physical inventory during the period from February 25, 2003,
> to October 24, 2003, to account for all sealed sources and devices
> containing depleted uranium. The licensee will implement an automated
> reminder system to notify the Radiation Safety Officer to perform the
> inventories.
>
> 4\. The inspector must also ensure that the findings are documented in
> the inspection records in sufficient detail for the reader to
> determine what requirement was violated, how it was violated, who
> violated the requirement, and when it was violated. If the licensee
> provides corrective action for the violations, this information should
> also be included in the inspection records.
>
> 5\. For NCVs, the inspection records should document why the violation
> was not cited and the corrective action taken or planned.
>
> 6\. The inspector will present NRC Form 591M to the licensee at the
> conclusion of the exit interview, or, on rare occasions where
> consultation with regional management is necessary, the inspector may
> transmit NRC Form 591M from the regional office by facsimile. Other
> forms of distribution, i.e., electronic mail, may be used at the
> discretion of regional management. All non-willful, non-repetitive
> Severity Level IV violations may be cited on NRC Form 591M.
>
> 7\. The NRC Form 591M, ASafety Inspection Report@, shall include the
> name of the responsible inspector. The inspector shall sign the
> completed Form 591M and will usually provide the signed form to the
> administrative staff without further management review, unless
> instructed otherwise by the supervisor.
>
> b\. A letter, signed by regional management, shall be used:
>
> 1\. for repetitive violations;
>
> 2\. for violations involving willfulness;
>
> 3\. where an apparent Severity Level I, II, or III violation or
> problem is indicated;
>
> 4\. when an enforcement conference or a management meeting is to be
> held;
>
> 5\. where the licensee needs to take extensive corrective action or
> make programmatic changes to address the violation;
>
> 6\. where the licensee needs to perform further evaluations before
> taking corrective action;
>
> 7\. where the corrective action includes a request for an amendment to
> the license;
>
> 8\. when a specific message should be provided to the licensee;
>
> 9\. if the inspector questions the effectiveness of the licensee\'s
> planned action or the ability of the licensee to carry out the
> corrective action; or
>
> 10\. where it is appropriate to request a written response to the
> violation.
>
> If a regional office letter and NOV are to be issued, NCVs, if any,
> are to be documented in the inspection records.

2800-09 COORDINATION OF REGIONAL RESPONSIBILITY FOR INSPECTIONS

09.01 [General]{.underline}. When a license authorizes operations in
more than one region, the responsibility for inspection shall reside
with the regional office in which the licensee\'s main office is
located. The main office means the corporate office, normally the street
address listed in item 2 of the license.

09.02 [Assistance in Inspections]{.underline}. In the interest of
efficiency in use of travel time and funds, the responsible regional
office may request another regional office to conduct inspections
(assist inspections) of the activities of such licensees when the
licensee is operating outside the geographical area of the responsible
region. \[See Section 07.04(b)\] Because of the close proximity of a
licensed facility to the responsible region=s boundary, the responsible
region\'s personnel may perform the inspection activity themselves
rather than request assistance from another region. In such cases, these
activities should be coordinated between regions.

09.03 [Transfer of Responsibility]{.underline}. Notwithstanding the
above (Sections 09.01 and 09.02), when a license has an address that
places the inspection responsibility in one region, and operations under
the license routinely or predominantly occur within another region, the
inspection responsibility may be transferred to the region in which the
operations are performed. This transfer shall be done with mutual
agreement of the regional offices involved. The regional offices should
ensure that the appropriate changes are made to the LTS to show which
office has the overall responsibility for inspection and enforcement.

2800-10 COORDINATION WITH OTHER AGENCIES

10.01 Federal Agencies. NRC does not conduct inspections of licensee
compliance with the requirements of other Federal agencies, except the
U.S. Department of Transportation (DOT). However, NRC inspectors may
identify concerns that are within another agency\'s regulatory
authority. If such concerns are significant and the licensee
demonstrates a pattern of unresponsiveness, the NRC regional office, in
coordination with NMSS, should inform the appropriate liaisons within
the other agency about the concerns.

Except for DOT regulations, it is important that all inspectors
recognize and understand that they are not to make decisions regarding
activities under the purview of other agencies. Thus, in discussing the
concerns with the licensee, inspectors are cautioned not to judge
whether a given condition is a violation of another agency\'s rules or
regulations, but are to point out concerns to heighten licensee
awareness. For example, if an inspector identified concerns for lack of
fire protection, then it would be appropriate to encourage the licensee
to advise the local fire department of conditions in the facility and to
take prompt action to correct the situation. The inspector would also
advise the licensee of the inspector=s obligation to inform the NRC
supervisor who may coordinate the information with OSHA as per MC 1007.

In the case of complaints or allegations involving another federal
agency=s jurisdiction, the inspector should withhold the information
from the licensee and elevate the concerns to the attention of NRC
regional management while the inspector is still onsite. \[see Section
08.02\]

NRC has entered into several Memoranda of Understanding (MOUs), with
other Federal agencies, that outline agreements regarding items such as
exchange of trade-secret information and evidence in criminal
proceedings. These MOUs are published in the NRC Rules and Regulations
(Volume IV) and copies may be obtained from the regional office or IMNS.
The following MOUs contain information that is relevant to inspection
activities:

> a\. U.S. Department of Transportation (DOT). The NRC/DOT MOU,
> \"Transportation of Radioactive Materials\" - published in the Federal
> Register July 2, 1979, delineates DOT\'s and NRC\'s respective
> responsibilities for regulating safety in transportation of
> radioactive materials.
>
> b\. U.S. Department of Justice (DOJ)
>
> 1\. The NRC/DOJBFederal Bureau of Investigation (FBI) MOU,
> \"Cooperation Regarding Threat, Theft, or Sabotage in U.S. Nuclear
> Industry\" - published in the Federal Register May 16, 2000, provides
> a basis for contingency response planning, coordination, and
> cooperation between the FBI and the NRC, to deal effectively with
> threats, and with acts associated with theft or sabotage attempts
> against NRC-licensed nuclear facilities and activities.
>
> 2\. The NRC/DOJ MOU published in the Federal Register
> December 14, 1988, provides for coordination between the two agencies
> for matters that could lead to NRC enforcement action, as well as DOJ
> criminal prosecution. The MOU also facilitates exchange of information
> on matters within their respective jurisdictions.
>
> c\. U.S. Department of Labor (DOL)
>
> 1\. The NRC/DOL MOU, \"Cooperation Regarding Employee Protection
> Matters\" published in the Federal Register October 27, 1998, provides
> coordination of employee protection provisions in Section 211 of the
> Energy Reorganization Act of 1974. Section 211 prohibits a licensee,
> applicant, or contractor or subcontractor of same from discriminating
> against any employee who assisted or participated, or is about to
> assist or participate, in an NRC inspection.
>
> 2\. The NRC/DOLBMine Safety and Health Administration (MSHA) MOU,
> AFacilitation of Coordination and Cooperation in Areas of Mutual
> Jurisdiction and Concern,@ published in the Federal Register January
> 4, 1980, clarified the regulatory roles for NRC and MSHA for milling
> of source material, including inspection of an operating uranium mill.
>
> 3\. The NRC/DOLBOccupational Safety and Health Administration (OSHA),
> MOU, \"Worker Protection at NRC-licensed Facilities\" - published in
> the Federal Register October 31, 1988, was designed to ensure that
> there will be no gaps in the protection of workers at NRC-licensed
> facilities where the OSHA also has health and safety jurisdiction. At
> the same time, the MOU is designed to avoid NRC and OSHA duplication
> of effort in those cases where it is not always practical to sharply
> identify boundaries between the NRC\'s responsibilities for nuclear
> safety and the OSHA\'s responsibilities for industrial safety.
>
> Specific guidance on the responsibilities and interfacing activities
> for reporting non-radiological hazards to OSHA can be found in MC
> 1007. There are 4 categories of hazards that may be associated the
> licensed materials:
>
> \(a\) radiation risk from radioactive materials,
>
> \(b\) chemical risk from radioactive materials,
>
> \(c\) facility conditions that affect the safety of radioactive
> materials and thus present a risk to workers or members of the public,
> and
>
> \(d\) facility conditions that result in an occupational risk but do
> not affect the safety of licensed materials.
>
> Generally, NRC has jurisdiction over categories (a), (b), and (c).
> OSHA has authority and responsibility for category (d). Through this
> MOU, NRC supports OSHA by reporting category (d) conditions to the
> licensee, NRC, and OSHA so appropriate action(s) can be taken.
>
> Time spent on meeting the requirements of MC 1007 for category (d)
> conditions are to be charged to IP 93001, AOSHA Interface Activities.@
> Time spent on category (a), (b), and (c) conditions are to be charged
> to the program-specific inspection procedure.
>
> d\. U.S. Environmental Protection Agency (EPA)
>
> 1\. The NRC/EPA MOU, \"Regulation of Radionuclide Emissions\",
> published in the Federal Register November 3, 1980, defines in general
> terms the respective roles of the two agencies and establishes a
> framework of cooperation for avoiding unnecessary duplication of
> effort and for conserving resources in establishing, implementing, and
> enforcing standards for airborne radionuclide emissions from sources
> and facilities licensed by the NRC.
>
> 2\. The NRC/EPA MOU published in the Federal Register November 16,
> 1992, was designed to foster NRC/EPA cooperation in protecting health
> and safety and the environment on issues relating to the regulation of
> radionuclides in the environment.
>
> 3\. The NRC/EPA MOU published in the Federal Register December 22,
> 1992, concerns \"Clean Air Act Standards for Radionuclide Releases
> from Facilities Other than Nuclear Power Reactors Licensed by NRC or
> its Agreement States.\" The MOU was designed to ensure that facilities
> other than nuclear power reactors, licensed by the NRC, will continue
> to limit air emissions of radionuclides to levels that result in
> protection of the public health with an ample margin of safety.
>
> e\. U.S. Department of Health and Human Services (DHHS)
>
> The NRC/DHHSBFDA MOU published in the Federal Register December 23,
> 2002, renewed with minor changes the MOU signed by NRC and FDA on
> August 26, 1993. The MOU coordinates existing NRC and FDA regulatory
> programs for medical devices, drugs, and biological products using
> byproduct, source, or special nuclear material.
>
> f\. U.S. Department of Energy (DOE)
>
> The NRC/DOEBOffice of Waste Management MOU, AConcerning the Management
> of Sealed Sources,@ published in the Federal Register January 7, 2000,
> addresses the problem of unwanted and uncontrolled radioactive
> materials (Aorphan@ sources) and defines agreed-upon roles and
> responsibilities of the NRC and DOE in situations where the NRC is the
> lead Federal agency, where immediate health and safety hazards have
> been addressed, and where assistance with the transfer of radioactive
> material is determined to be necessary for continued protection of
> public health and safety and the environment.

10.02 State Agencies. For routine NRC inspections in both Agreement and
non-Agreement States, State radiation control program personnel shall be
notified of the inspection at least 1 week in advance, by telephone,
e-mail, or facsimile.

State personnel interested in participation may do so as observers as
long as their presence does not affect NRC\'s inspection program. State
personnel should be informed that information gathered during the
inspection is confidential and predecisional and shall not be disclosed.

Whenever possible, for reactive inspections in Agreement States, State
radiation control program personnel should be notified before the start
of the inspection so that any public inquiries that may come to the
State radiation control agency may be referred to the appropriate
regional office.

2800-11 INPUT INTO NRC TRACKING SYSTEMS

11.01 [Input into the Licensing Tracking System (LTS)]{.underline}.
Enclosure 1 provides a listing of license program codes with the
associated inspection priorities. Regions should enter data promptly
into the LTS at the time a new license is issued or an inspection has
been performed, including the dates for initial inspections of new
licensees, the last inspection date, and the next inspection date for
licensees already inspected. When changes are made to the next
inspection date (reductions in the inspection intervals), regions should
enter the data for the correct next inspection date into the LTS and
enter the Special Inspection Code on the Inspection and Enforcement
Screen, as described in Section 06.04(b).

11.02 [Input into the Nuclear Materials Events Database
(NMED)]{.underline}. NMSS manages NMED for all material-related
incidents and events. The regional office is responsible for ensuring
that NMSS is notified of all material-related incidents. The regional
office shall also forward annotated copies (NMED Event No. shall be on
each document) of all documentation regarding a material incident (i.e.,
\"Preliminary Notifications,\" reports of medical events, follow-up
inspection reports) to the NMED contractor (INEEL at this time) and the
NMED Project Manager, NMSS.

The regional office is responsible for ensuring that sufficient
information is provided for the NMED item to be considered \"complete.\"
For documents that are publicly available, entry into ADAMS meets the
requirement for forwarding documents. For documents that are not
publicly available, the regional office must forward paper copies to the
NMED contractor and the NMED Project Manager, NMSS.

The target for ensuring \"complete\" NMED records is 70 days from the
date the event is reported. The regional office shall provide the
information outlined in Enclosure 3 to classify a record as
\"complete.\" If there is a reason that the regional office can not
obtain the required information, that reason should be forwarded to the
NMED contractor and to the NMED Project Coordinator, NMSS.

2800-12 INSPECTION MANUAL CHAPTERS AND INSPECTION PROCEDURES FOR
MATERIALS PROGRAM

The Inspection Manual Chapters (MCs) and Inspection Procedures (IPs)
listed in Enclosure 4 comprise the inspection program for material
licensees. This list is organized into various topics. These documents
are to be used as guidelines for inspectors in determining the
inspection requirements for operational and radiological safety aspects
of various types of licensee activities. In performing an inspection, a
MC in addition to several specific procedures, may be needed to
adequately evaluate the licensee\'s program.

MCs and IPs in this section are classified into two categories: Routine
7) and As-Needed (N). \"Routine\" 7) means those MCs and IPs that are
generally used to evaluate licensee performance. For example, the IP
87100-series includes procedures for routine inspections of certain
types of use of byproduct material, i.e. , industrial/academic, medical,
industrial radiography, gauges, etc. However, all Aroutine@ MCs and IPs
are not appropriate for each inspection. For example, IP 84900,
ALow-Level Waste Storage,@ would not be appropriate for inspection of a
fixed or portable gauge licensee that stores devices, unless the devices
were designated for disposal. \"As-Needed\" (N) means those MCs and IPs
that are specifically used for a certain situation. For instance, MC
1120, \"Preliminary Notifications,\" is classified \"as-needed,\"
because it only applies to certain events. Similarly, IP 92703, \"Follow
Up of Confirmatory Action Letters (CALs),\" is classified \"as-needed\"
because it only applies to a licensee who has been issued a CAL.

END

Enclosures:

1\. Inspection Priority by Program Codes

2\. Telephone Contact Procedures for Priority T Licenses

> Exhibit 1 Telephone Contact Questionnaire
>
> Exhibit 2 Standard Response to Licensees Contacted by Telephone
> (Violations)
>
> Exhibit 3 Standard Response to Licensees Contacted by Telephone

(No Violations)

> 3\. Information for the Nuclear Materials Events Database (NMED)
>
> 4\. Inspection Manual Chapters and Inspection Procedures
>
> 5\. Safety Inspection Report and Compliance Inspection (NRC Form 591M)
>
> 6\. Inspection Record
>
> 7\. Information for the Inspection of Licensees Holding Nuclear
> Materials Management and Safeguards System (NMMSS) Accounts

**ENCLOSURE 1**

**INSPECTION PRIORITY CODES ASSIGNED TO PROGRAM CODES**

+------+-----+---------------------------+----------------------------+
| Pro  | Pr  | Category Title            | Remarks                    |
| gram | ior |                           |                            |
| Code | ity |                           | (from NUREG-1556, Vol. 20, |
|      | C   |                           | Appendix G)                |
|      | ode |                           |                            |
+======+=====+===========================+============================+
| 0    | 3   | Academic Type A Broad     | Radiation Safety Committee |
| 1100 |     |                           | (RSC)-approved users;33.13 |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Academic Type B Broad     | Radiation Safety Officer   |
| 1110 |     |                           | (RSO)-approved users;      |
|      |     |                           | 33.14                      |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Academic Type C Broad     | Authorized Users           |
| 1120 |     |                           | specifically named in the  |
|      |     |                           | license; 33.15             |
+------+-----+---------------------------+----------------------------+
| 0    | 2   | Medical Institution Broad | RSC-approved users for     |
| 2110 |     |                           | possession and use of a    |
|      |     |                           | wide range of              |
|      |     |                           | radionuclides in medical   |
|      |     |                           | research, diagnosis, and   |
|      |     |                           | therapy and research and   |
|      |     |                           | development.               |
+------+-----+---------------------------+----------------------------+
| 0    | 3   | Medical                   | Used as primary code and   |
| 2120 |     | InstitutionBWritten       | may be used with the       |
|      |     | Directive (WD) Required   | secondary codes for        |
|      |     |                           | research and development,  |
|      |     |                           | as appropriate. Used as    |
|      |     |                           | secondary code when the    |
|      |     |                           | license also authorizes    |
|      |     |                           | certain medical therapy    |
|      |     |                           | modalities.                |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Medical InstitutionBWD    | Used as primary code       |
| 2121 |     | Not Required              | *only* for diagnostic      |
|      |     |                           | nuclear medicine and       |
|      |     |                           | diagnostic types of use    |
|      |     |                           | under 35.1000. Used as     |
|      |     |                           | secondary code when the    |
|      |     |                           | license also authorizes    |
|      |     |                           | certain medical therapy    |
|      |     |                           | modalities.                |
+------+-----+---------------------------+----------------------------+
| 0    | 3   | Medical Private           | \[same remark as 02120\]   |
| 2200 |     | PracticeBWD Required      |                            |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Medical Private           | \[same remark as 02121\]   |
| 2201 |     | PracticeBWD Not Required  |                            |
+------+-----+---------------------------+----------------------------+
| 0    | 3   | Eye Applicators           | Institution or Private     |
| 2210 |     | Strontium‑90              | Practice                   |
|      |     |                           |                            |
|      |     | > (Sr-90)                 |                            |
+------+-----+---------------------------+----------------------------+

+------+-----+---------------------------+----------------------------+
| Pro  | Pr  | Category Title            | Remarks                    |
| gram | ior |                           |                            |
| Code | ity |                           | (from NUREG-1556, Vol. 20, |
|      | C   |                           | Appendix G)                |
|      | ode |                           |                            |
+======+=====+===========================+============================+
| 0    | 3   | Mobile Medical ServiceBWD | Use as a primary code if   |
| 2220 |     | Not Required              | the license authorizes the |
|      |     |                           | mobile service *only*. Use |
|      |     |                           | as a secondary code if the |
|      |     |                           | license authorizes medical |
|      |     |                           | use at a central facility  |
|      |     |                           | (i.e., institution or      |
|      |     |                           | private practice facility) |
|      |     |                           | in addition to the mobile  |
|      |     |                           | service.                   |
+------+-----+---------------------------+----------------------------+
| 0    | 2   | High-Dose Rate Remote     | Use as a primary code.     |
| 2230 |     | After loader (HDR)        |                            |
+------+-----+---------------------------+----------------------------+
| 0    | 2   | Mobile Medical ServiceBWD | Use as a primary code.     |
| 2231 |     | Required                  | Includes mobile HDR and    |
|      |     |                           | non-HDR modalities under   |
|      |     |                           | 10 CFR Part 35             |
+------+-----+---------------------------+----------------------------+
| 0    | 2   | Medical TherapyBOther     | Medical therapy modalities |
| 2240 |     | Emerging Technology       | used under 10 CFR 35.1000, |
|      |     |                           | i.e., liquid sources,      |
|      |     |                           | microspheres, and          |
|      |     |                           | intravascular              |
|      |     |                           | brachytherapy devices.     |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Teletherapy               | Treatment of human         |
| 2300 |     |                           | subjects only              |
+------+-----+---------------------------+----------------------------+
| 0    | 2   | Gamma Stereotactic        | Treatment of human         |
| 2310 |     | Radiosurgery (GSR)        | subjects *only*            |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | VeterinaryBNonhuman       | Routine diagnosis or       |
| 2400 |     | Subjects                  | therapy on animals. No     |
|      |     |                           | animal research.           |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | *In-Vitro* Testing        | Licenses are issued to     |
| 2410 |     | Laboratories              | individuals or facilities  |
|      |     |                           | which are not included in  |
|      |     |                           | larger programs described  |
|      |     |                           | by Program Codes 02110 or  |
|      |     |                           | 02120.                     |
+------+-----+---------------------------+----------------------------+
| 0    | 2   | Nuclear Pharmacies        | Receive bulk material used |
| 2500 |     |                           | to prepare single use      |
|      |     |                           | dosages or multi-dose      |
|      |     |                           | products which are         |
|      |     |                           | distributed to authorized  |
|      |     |                           | medical licensees. Sealed  |
|      |     |                           | sources are re-distributed |
|      |     |                           | in the original packaging  |
|      |     |                           | to authorized clients.     |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Medical Product           | Distribution of prepared   |
| 2511 |     | DistributionB32.72        | radiopharmaceuticals to    |
|      |     |                           | authorized medical         |
|      |     | Prepared                  | licensees.                 |
|      |     | Radiopharmaceuticals      |                            |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Medical Product           | Therapy sources,           |
| 2513 |     | DistributionB32.74        | calibration and reference  |
|      |     | Sources and Devices       | sources                    |
+------+-----+---------------------------+----------------------------+
| 0    | 3   | Well Logging Byproduct    | Use of sealed or unsealed  |
| 3110 |     | and/or Special Nuclear    | sources for exploration of |
|      |     | Material (SNM) Tracer and | oil, gas, or minerals in   |
|      |     | Sealed Sources            | wells.                     |
+------+-----+---------------------------+----------------------------+
| 0    | 3   | Well Logging Byproduct    | Exploration of oil, gas,   |
| 3111 |     | and/or SNM Sealed Sources | or minerals in wells;      |
|      |     | Only                      | study of subsurface        |
|      |     |                           | potable aquifers.          |
+------+-----+---------------------------+----------------------------+
| 0    | 3   | Well Logging Byproduct    | Exploration of oil, gas,   |
| 3112 |     | OnlyB Tracers Only        | or minerals in wells       |
+------+-----+---------------------------+----------------------------+
| 0    | 3   | Field Flooding Studies    | Injection of unsealed      |
| 3113 |     |                           | byproduct materials for    |
|      |     |                           | tracing oil and gas        |
|      |     |                           | reservoirs                 |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Measuring Systems Fixed   | Non-portable gauges for    |
| 3120 |     | Gauges                    | measurement or control of  |
|      |     |                           | material density, flow,    |
|      |     |                           | level, thickness, or       |
|      |     |                           | weight, etc.               |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Measuring Systems         | Moisture/density gauges    |
| 3121 |     | Portable Gauges           | contain gamma and neutron  |
|      |     |                           | sources used for           |
|      |     |                           | measurements in soils,     |
|      |     |                           | compacted soils and road   |
|      |     |                           | surfacing materials.       |
+------+-----+---------------------------+----------------------------+
| 0    | T[  | Measuring Systems         | i.e., x-ray fluorescence   |
| 3122 | ^1] | Analytical Instruments    | analyzers                  |
+------+-----+---------------------------+----------------------------+
| 0    | T   | Measuring Systems Gas     | Quality control testing of |
| 3123 |     | Chromatographs            | samples from industrial    |
|      |     |                           | process and environmental  |
|      |     |                           | conditions.                |
+------+-----+---------------------------+----------------------------+
| 0    | T   | Measuring Systems Other   | instrument calibrators,    |
| 3124 |     |                           | Krypton-85 (Kr‑85) leak    |
|      |     |                           | detectors                  |
+------+-----+---------------------------+----------------------------+
| 0    | 2   | Manufacturing and         | RSC-approved users under   |
| 3211 |     | Distribution BroadBType A | 10 CFR 33.13               |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Manufacturing and         | RSO-approved users under10 |
| 3212 |     | Distribution BroadBType B | CFR 33.14                  |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Manufacturing and         | Authorized Users           |
| 3213 |     | Distribution BroadBType C | specifically named in the  |
|      |     |                           | license under 10 CFR 33.15 |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Manufacturing and         | Smaller firms that require |
| 3214 |     | Distribution Other        | a more restrictive         |
|      |     |                           | license.                   |
+------+-----+---------------------------+----------------------------+
| 0    | 3   | Nuclear Laundry           | Cleaning of protective     |
| 3218 |     |                           | clothing contaminated with |
|      |     |                           | radioactive materials.     |
+------+-----+---------------------------+----------------------------+
| 0    | 3   | Decontamination Services  | Cleaning of scrap          |
| 3219 |     |                           | materials for authorized   |
|      |     |                           | release for unrestricted   |
|      |     |                           | use.                       |
+------+-----+---------------------------+----------------------------+
| 0    | T   | Leak Test Service Only    | Commercial service         |
| 3220 |     |                           | organizations provide leak |
|      |     |                           | test kits to clients,      |
|      |     |                           | perform measurement of     |
|      |     |                           | leak test samples from     |
|      |     |                           | clients, and issue reports |
|      |     |                           | of leak test results.      |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Instrument Calibration    | Commercial calibration     |
| 3221 |     | Services OnlyBSource Less | service                    |
|      |     | Than Or Equal To 100      |                            |
|      |     | Curies                    |                            |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Instrument Calibration    | Commercial calibration     |
| 3222 |     | Services OnlyBSource      | service                    |
|      |     | Greater Than 100 Curies   |                            |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Other ServicesBSource     | Commercial servicing for   |
| 3225 |     | Less Than Or Equal To 100 | industrial gauge, and HDR  |
|      |     | Curies                    | licensees                  |
+------+-----+---------------------------+----------------------------+
| 0    | 2   | Other ServicesBSource     | Commercial servicing for   |
| 3226 |     | Greater Than 100 Curies   | teletherapy, irradiators , |
|      |     |                           | and GSR units containing a |
|      |     |                           | total activity in the unit |
|      |     |                           | during servicing that is   |
|      |     |                           | greater than 100 curies.   |
+------+-----+---------------------------+----------------------------+
| 0    | 2   | Waste Disposal (Burial)   | Commercial and             |
| 3231 |     |                           | non-commercial             |
+------+-----+---------------------------+----------------------------+
| 0    | 3   | Waste Disposal Service    | pick up, transfer, and     |
| 3232 |     | Prepackaged Only          | storage; opening packages  |
|      |     |                           | not authorized             |
+------+-----+---------------------------+----------------------------+
| 0    | 2   | Waste Disposal Service    | Commercial operation       |
| 3233 |     | Incineration              |                            |
+------+-----+---------------------------+----------------------------+
| 0    | 2   | Waste Disposal Service    | receipt, open, compact,    |
| 3234 |     | Processing and/or         | re-package, and transfer   |
|      |     | Repackaging               | to authorized burial       |
+------+-----+---------------------------+----------------------------+
| 0    | \-[ | Incineration,             | (Secondary Code)           |
| 3235 | ^2] | Non-Commercial            |                            |
+------+-----+---------------------------+----------------------------+
| 0    | 2   | Waste Treatment Service   | Includes multiple, complex |
| 3236 |     | (Other Than Compaction)   | physical and chemical      |
|      |     |                           | waste treatment processes  |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | General License           | For fixed gauges           |
| 3240 |     | Distribution ‑ 32.51      | authorized under 10 CFR    |
|      |     |                           | 31.5                       |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | General License           | For luminous aircraft      |
| 3241 |     | Distribution ‑ 32.53      | safety devices authorized  |
|      |     |                           | under 10 CFR 31.7          |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | General License           | For calibration and        |
| 3242 |     | Distribution ‑ 32.57      | reference sources          |
|      |     |                           | authorized under 10 CFR    |
|      |     |                           | 31.8                       |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | General License           | For ice detection devices  |
| 3243 |     | Distribution ‑ 32.61      | authorized under 10 CFR    |
|      |     |                           | 31.10                      |
+------+-----+---------------------------+----------------------------+

+------+-----+---------------------------+----------------------------+
| Pro  | Pr  | Category Title            | Remarks                    |
| gram | ior |                           |                            |
| Code | ity |                           | (from NUREG-1556, Vol. 20, |
|      | C   |                           | Appendix G)                |
|      | ode |                           |                            |
+======+=====+===========================+============================+
| 0    | 5   | General License           | For certain *in-vitro*     |
| 3244 |     | Distribution ‑ 32.71      | clinical testing kits      |
|      |     |                           | authorized under 10 CFR    |
|      |     |                           | 31.11                      |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Exempt                    | For residual material in a |
| 3250 |     | Distribution‑32.11:       | product authorized under   |
|      |     | Exempt Concentrations and | 10 CFR 30.14               |
|      |     | Items                     |                            |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Exempt                    | For manufactured products  |
| 3251 |     | Distribution-32.14:       | authorized under 10 CFR    |
|      |     | Certain Items             | 30.15                      |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Exempt                    | For synthetic plastic      |
| 3252 |     | Distribution-32.17:       | resins authorized under 10 |
|      |     | Resins                    | CFR 30.16                  |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Exempt                    | For individual quantities  |
| 3253 |     | Distribution‑32.18: Small | authorized under 10 CFR    |
|      |     | Quantities                | 30.18                      |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Exempt                    | For devices authorized     |
| 3254 |     | Distribution‑32.22:       | under 10 CFR 30.19         |
|      |     | Self-Luminous Products    |                            |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Exempt                    | For devices authorized     |
| 3255 |     | Distribution‑32.26: Smoke | under 10 CFR 30.20         |
|      |     | Detectors                 |                            |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Exempt Distribution -     | For *in vivo* diagnostic   |
| 3256 |     | 32.21 - Carbon-14 Urea    | use authorized under 10    |
|      |     | Capsules                  | CFR 30.21                  |
+------+-----+---------------------------+----------------------------+
| 0    | 2   | Industrial Radiography    | Permanent radiographic     |
| 3310 |     | Fixed Location            | installation (PRI) or      |
|      |     |                           | designated field station.  |
|      |     |                           | Use as secondary code,     |
|      |     |                           | except when the license    |
|      |     |                           | authorizes the PRI *only*. |
+------+-----+---------------------------+----------------------------+
| 0    | 1   | Industrial Radiography    | Use as primary code for    |
| 3320 |     | Temporary Job Sites       | multiple temporary         |
|      |     |                           | customer locations         |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Irradiators Self Shielded | Not external beam          |
| 3510 |     | Less Than Or Equal To     |                            |
|      |     | 10,000 Curies             |                            |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Irradiators Other Less    | Panoramic (in air or under |
| 3511 |     | Than Or Equal To 10,000   | water) units; includes     |
|      |     | Curies                    | converted teletherapy      |
|      |     |                           | units                      |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Irradiators Self Shielded | Not external beam          |
| 3520 |     | Greater Than 10,000       |                            |
|      |     | Curies                    |                            |
+------+-----+---------------------------+----------------------------+
| 0    | 2   | Irradiators - Other       | Panoramic (in air or under |
| 3521 |     | Greater than 10,000       | water) units; includes     |
|      |     | curies                    | sterilization (mega-curie) |
|      |     |                           | units                      |
+------+-----+---------------------------+----------------------------+
| 0    | 3   | Research and Development  | RSC-approved users under   |
| 3610 |     | BroadBType A              | 10 CFR 33.13               |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Research and Development  | RSO-approved users under   |
| 3611 |     | BroadBType B              | 10 CFR 33.14               |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Research and Development  | Authorized users           |
| 3612 |     | BroadBType C              | specifically named in the  |
|      |     |                           | license under 10 CFR 33.15 |
+------+-----+---------------------------+----------------------------+
| 0    | 2   | Research and Development  | Master Materials Licenses  |
| 3613 |     | Broa                      |                            |
|      |     | dBMultisiteBMultiregional |                            |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Research and Development  | Non-human research         |
| 3620 |     | Other                     | subjects                   |
+------+-----+---------------------------+----------------------------+
| 0    | 5   | Civil Defense             | Instrument calibration and |
| 3710 |     |                           | training                   |
+------+-----+---------------------------+----------------------------+
| 0    | 3   | Byproduct Material        | Principle activities       |
| 3800 |     | Possession Only -         | ceased, license            |
|      |     | Permanent Shutdown        | termination request        |
|      |     |                           | pending; packaging and     |
|      |     |                           | shipping operations        |
|      |     |                           | authorized;                |
|      |     |                           | decontamination and        |
|      |     |                           | decommissioning (D&D) not  |
|      |     |                           | authorized                 |
+------+-----+---------------------------+----------------------------+
| 0    | 3   | Byproduct Material        | Principle activities       |
| 3810 |     | Standby - No Operations   | ceased, licensee undecided |
|      |     |                           | about terminating the      |
|      |     |                           | license, packaging and     |
|      |     |                           | shipping operations        |
|      |     |                           | authorized, D&D not        |
|      |     |                           | authorized                 |
+------+-----+---------------------------+----------------------------+
| 0    | D[  | Decommissioning of        | (See MC 2602) D&D may have |
| 3900 | ^3] | Byproduct Material        | been authorized according  |
|      |     | Facilities                | to an approved plan under  |
|      |     |                           | 10 CFR 30.36               |
+------+-----+---------------------------+----------------------------+
| 1    | 5   | Source Material Other     | Research or manufacturing  |
| 1200 |     | Less than 150 Kilograms   | of consumer products       |
+------+-----+---------------------------+----------------------------+
| 1    | T   | Source Material Shielding | Possession and use         |
| 1210 |     |                           |                            |
+------+-----+---------------------------+----------------------------+
| 1    | 5   | Source Material Military  | Depleted Uranium (DU);     |
| 1220 |     | Munitions Indoor Testing  | results in fragmentation   |
|      |     |                           | of DU                      |
+------+-----+---------------------------+----------------------------+
| 1    | 5   | Source Material Military  | DU                         |
| 1221 |     | Munitions Outdoor Testing |                            |
+------+-----+---------------------------+----------------------------+
| 1    | 5   | Source Material General   | DU products and devices    |
| 1230 |     | License Distribution ‑    | authorized under 10 CFR    |
|      |     | 40.34                     | 40.25                      |
+------+-----+---------------------------+----------------------------+
| 1    | 5   | Source Material Other     | Research or manufacturing  |
| 1300 |     | Greater than 150          | of consumer products       |
|      |     | Kilograms                 |                            |
+------+-----+---------------------------+----------------------------+
| 1    | 5   | Rare Earth Extraction and | Generates waste products   |
| 1700 |     | Processing                | containing source material |
|      |     |                           | not related to the nuclear |
|      |     |                           | fuel cycle                 |
+------+-----+---------------------------+----------------------------+
| 1    | 2   | Source Material           | Principle activities       |
| 1800 |     | Possession Only ‑         | ceased, license            |
|      |     | Permanent Shutdown        | termination request        |
|      |     |                           | pending; packaging and     |
|      |     |                           | shipping operations        |
|      |     |                           | authorized;                |
|      |     |                           | decontamination and        |
|      |     |                           | decommissioning (D&D) not  |
|      |     |                           | authorized                 |
+------+-----+---------------------------+----------------------------+
| 1    | 2   | Source Material Standby - | Principle activities       |
| 1810 |     | No Operations             | ceased, licensee undecided |
|      |     |                           | about terminating the      |
|      |     |                           | license, packaging and     |
|      |     |                           | shipping operations        |
|      |     |                           | authorized, D&D not        |
|      |     |                           | authorized                 |
+------+-----+---------------------------+----------------------------+
| 1    | D   | Decommissioning of Source | (See MC 2602) D&D may have |
| 1900 |     | Material Facilities       | been authorized according  |
|      |     |                           | to an approved plan under  |
|      |     |                           | 10 CFR 40.42               |
+------+-----+---------------------------+----------------------------+
| 2    | 5   | Critical Mass Material -  | Greater than 350 grams of  |
| 1310 |     | University                | enriched Uranium-235       |
|      |     |                           | (U-235), greater than 300  |
|      |     |                           | grams of Uranium-233       |
|      |     |                           | (U-233), greater than 200  |
|      |     |                           | grams of Plutonium, or any |
|      |     |                           | combination thereof        |
+------+-----+---------------------------+----------------------------+
| 2    | 5   | Critical Mass Material -  | Greater than 350 grams of  |
| 1320 |     | Other Than Universities   | enriched U-235, greater    |
|      |     |                           | than 300 grams of U-233,   |
|      |     |                           | greater than 200 grams of  |
|      |     |                           | Plutonium, or any          |
|      |     |                           | combination thereof        |
+------+-----+---------------------------+----------------------------+
| 2    | D   | Decommissioning of        | (See MC 2602) D&D may have |
| 1325 |     | Critical Mass ‑ Other     | been authorized according  |
|      |     | Than Fuel Fabrication     | to an approved plan under  |
|      |     |                           | 10 CFR 70.38               |
+------+-----+---------------------------+----------------------------+
| 2    | 3   | Special Nuclear Material  | Less than 200 grams,       |
| 2110 |     | Plutonium ‑ Unsealed,     | total, for biological and  |
|      |     | Less than Critical Mass   | chemical testing and       |
|      |     |                           | instrument calibration     |
+------+-----+---------------------------+----------------------------+
| 2    | 3   | Special Nuclear Material, | Less than 350 grams U-235  |
| 2111 |     | U‑235 and/or U‑233 -      | and/or less than 300 grams |
|      |     | Unsealed, Less than a     | U-233 for biological and   |
|      |     | Critical Mass             | chemical testing and       |
|      |     |                           | instrument calibration     |
+------+-----+---------------------------+----------------------------+
| 2    | 5   | SNM Plutonium ‑ Sealed    | Plutonium-beryllium        |
| 2120 |     | Neutron Sources, Less     | howitzer for instrument    |
|      |     | than 200 Grams            | calibration, teaching and  |
|      |     |                           | demonstration purposes,    |
|      |     |                           | and industrial             |
|      |     |                           | applications               |
+------+-----+---------------------------+----------------------------+
| 2    | T   | Power Sources with        | Heat or power generators   |
| 2130 |     | Byproduct and/or Special  | for remote locations       |
|      |     | Nuclear Material          |                            |
+------+-----+---------------------------+----------------------------+
| 2    | 5   | Special Nuclear Material  | Gauges                     |
| 2140 |     | Plutonium ‑ Sealed        |                            |
|      |     | Sources in Devices        |                            |
+------+-----+---------------------------+----------------------------+
| 2    | 5   | Special Nuclear Material  | Less than 200 grams,       |
| 2150 |     | Plutonium ‑ Sealed        | total, for biological and  |
|      |     | Sources Less than a       | chemical testing and       |
|      |     | Critical Mass             | instrument calibration     |
+------+-----+---------------------------+----------------------------+
| 2    | 5   | Special Nuclear Material, | Less than 350 grams U-235  |
| 2151 |     | U‑235 and/or U‑233 Sealed | and/or less than 300 grams |
|      |     | Sources, Less than a      | U-233 for biological and   |
|      |     | Critical Mass             | chemical testing and       |
|      |     |                           | instrument calibration     |
+------+-----+---------------------------+----------------------------+
| 2    | T   | PacemakerBByproduct,      | Surgical implantation,     |
| 2160 |     | and/or Special Nuclear    | follow up, recovery, and   |
|      |     | Material - Medical        | disposal of devices        |
|      |     | Institution               |                            |
+------+-----+---------------------------+----------------------------+
| 2    | T   | PacemakerBByproduct,      | Possession of a surgically |
| 2161 |     | and/or Special Nuclear    | implanted device by the    |
|      |     | Material - Individual     | recipient while in the     |
|      |     |                           | United States              |
+------+-----+---------------------------+----------------------------+
| 2    | 2   | PacemakerBByproduct       |                            |
| 2162 |     | and/or Special Nuclear    |                            |
|      |     | Material - Manufacturing  |                            |
|      |     | and Distribution          |                            |
+------+-----+---------------------------+----------------------------+
| 2    | 5   | Special Nuclear Material  | Includes calibration or    |
| 2170 |     | General License           | reference sources          |
|      |     | Distribution (70.39)      | authorized under 10 CFR    |
|      |     |                           | 70.19                      |
+------+-----+---------------------------+----------------------------+
| 2    | D   | Decommissioning of Other  | (See MC 2602) D&D may have |
| 2200 |     | SNM Facilities ‑ Less     | been authorized according  |
|      |     | than Critical Mass        | to an approved plan under  |
|      |     |                           | 10 CFR 70.38               |
+------+-----+---------------------------+----------------------------+
| 2    | 2   | SNM Possession Only       | Principle activities       |
| 3300 |     | (Non-Fuel)-Permanent      | ceased, license            |
|      |     | Shutdown                  | termination request        |
|      |     |                           | pending; packaging and     |
|      |     |                           | shipping operations        |
|      |     |                           | authorized;                |
|      |     |                           | decontamination and        |
|      |     |                           | decommissioning (D&D) not  |
|      |     |                           | authorized                 |
+------+-----+---------------------------+----------------------------+
| 2    | 2   | SNM Standby (Non-Fuel)-No | Principle activities       |
| 3310 |     | Operations                | ceased, licensee undecided |
|      |     |                           | about terminating the      |
|      |     |                           | license, packaging and     |
|      |     |                           | shipping operations        |
|      |     |                           | authorized, D&D not        |
|      |     |                           | authorized                 |
+------+-----+---------------------------+----------------------------+

END

ENCLOSURE 2

TELEPHONE CONTACT PROCEDURES FOR PRIORITY T LICENSEES

1\. [PROGRAM OBJECTIVES]{.underline}: The NRC developed telephone
contact procedures to maintain safety for materials possessed by certain
licensees (Priority T) after the initial inspection was completed and
the inspector determined that the licensee had satisfactorily
implemented the radiation protection program. Thereafter, an inspector
will interview the Priority T licensee at 5-YEAR intervals for the
duration of the license.

2\. [PROCEDURES]{.underline}

> a\. Using the LTS report of licensees due for inspection, select a
> Priority T licensee to interview by telephone \[see Section 05.05\].
>
> b\. Obtain the license file and identify the licensee=s point of
> contact and review pertinent details of the license that will be
> needed to evaluate the licensee=s responses to the interview
> questionnaire.(Exhibit 1).
>
> **NOTE:** If the license authorizes nuclear-powered cardiac pacemaker
> devices that contain special nuclear material (i.e., Program Codes
> 22160 or 22161), the inspector should refer to the guidance contained
> in Enclosure 7. Section 2, ANMMSS Inspection Process,@ describes
> preparation steps and onsite steps which should be adapted to complete
> this telephonic contact procedure.
>
> For example, the inspector should request the NMMSS contractor to send
> the ATask 8 Inspection Package\" which contains inventory data the
> licensee has reported to NMMSS. The inspector should also request the
> licensee to transmit a facsimile of their current inventory record.
> Compare the licensee=s current record with the NMMSS report data.
>
> If discrepancies exist, the licensee must assess the situation and
> verify the fact that NMMSS-reportable quantities are lost or missing
> or were incorrectly reported to NMMSS. The licensee is responsible for
> contacting the NMMSS contractor to correct the database.
>
> c\. Telephone the licensee and complete each item of Exhibit 1, as
> appropriate for the type of use authorized by the license. If a
> question is not applicable for the type of use, then indicate AN.A.@
> for the answer.
>
> d\. The inspector should promptly notify their supervisor if the
> licensee describes any significant problem. The supervisor should
> determine whether an inspection of the facility or a letter
> transmitting regulatory concerns is needed. If an inspection is
> warranted, the inspector should note that decision on Exhibit 1 and
> provide the completed questionnaire and license file to the supervisor
> for further action. Use Exhibit 2, AStandard Response to Licensees
> Contacted by Telephone (Concerns, Inspection to Follow),@ to notify
> the licensee that a follow up inspection may be scheduled in the near
> future. Following is a list of problems which may warrant an onsite
> inspection.
>
> 1\. licensee is unaware of licensed material or NRC regulations for
> possession, use, transfer, and disposal
>
> 2\. change in ownership or bankruptcy proceedings
>
> 3\. a qualified radiation safety officer or authorized user was not
> routinely involved
>
> 4\. unsecured or unshielded material
>
> 5\. doses in excess of 10 CFR Part 20 limits
>
> 6\. excessive radiation levels or leaking sources
>
> 7\. lost, stolen, or missing licensed material
>
> 8\. non-routine event threatens safe, secure storage (i.e., special
> maintenance or handling, fire, explosion, or damage from a natural
> disaster)
>
> 9\. decommissioning activities
>
> e\. If no problem is evident from the licensee=s responses, use
> Exhibit 3, AStandard Response to Licensees Contacted by Telephone (No
> Concerns/Violations.)@ to provide the licensee with appropriate
> documentation.
>
> f\. With the supervisor=s concurrence, the inspector may sign the
> letter and provide the package to the administrative staff.

EXHIBIT 1: TELEPHONE CONTACT QUESTIONNAIRE

\]Instructions: Complete this questionnaire as per the program
objectives and procedures for Enclosure 2.

+----------------------------------+-----------------------------------+
| Name and title of Interviewer    |                                   |
|                                  |                                   |
| Signature of Interviewer         |                                   |
+----------------------------------+-----------------------------------+
| Date of this Interview           |                                   |
|                                  |                                   |
| Date of Previous Interview       |                                   |
+----------------------------------+-----------------------------------+
| **QUESTIONS**                    | **ANSWERS**                       |
+----------------------------------+-----------------------------------+
| Licensee Name, Address, and URL  |                                   |
+----------------------------------+-----------------------------------+
| Licensee=s Point of Contact      |                                   |
|                                  |                                   |
| (Name, Address, Phone and FAX    |                                   |
| Numbers, and URL)                |                                   |
+----------------------------------+-----------------------------------+
| License Number                   |                                   |
|                                  |                                   |
| Docket Number                    |                                   |
+----------------------------------+-----------------------------------+
| 1\. Name and Title of person     |                                   |
| responsible for radiation safety |                                   |
| program:                         |                                   |
+----------------------------------+-----------------------------------+
| 2\. Describe how you prevent:    |                                   |
| (a) use by unauthorized          |                                   |
| personnel and (b) loss or theft. |                                   |
+----------------------------------+-----------------------------------+
| 3\. Describe how you maintain    |                                   |
| shielding, restrict access, and  |                                   |
| control contamination from       |                                   |
| unsealed material to prevent     |                                   |
| individuals from becoming        |                                   |
| exposed to radiation.            |                                   |
+----------------------------------+-----------------------------------+
| 4\. Describe how you determine   |                                   |
| radiation doses to workers and   |                                   |
| members of the public from       |                                   |
| licensed activities. What was    |                                   |
| the maximum dose received since  |                                   |
| the last NRC telephone contact   |                                   |
| or inspection?                   |                                   |
+----------------------------------+-----------------------------------+
| 5\. Describe radiation area      |                                   |
| surveys around licensed          |                                   |
| activities. What survey          |                                   |
| instrument (SI) was used? SI=s   |                                   |
| last calibration date? What were |                                   |
| the typical radiation levels and |                                   |
| at what distance?                |                                   |
+----------------------------------+-----------------------------------+

  ----------------------------------- -----------------------------------
  **QUESTIONS**                       **ANSWERS**

  6\. Describe leak testing of the    
  sealed source(s). How often and who 
  analyzed the leak test samples?     
  What were the most recent results?  

  7\. Describe physical inventory of  
  all byproduct material and          
  NMMSS-reportable materials in your  
  possession. When was the last       
  inventory completed? Were all the   
  sources located?                    

  8\. Describe your provisions for    
  repair and maintenance of your      
  device or source holder.            

  9\. Describe any unusual events     
  involving the byproduct material or 
  the device(s) in which it is used   
  (i.e., fire, explosion, natural     
  disaster.)                          
  ----------------------------------- -----------------------------------

EXHIBIT 2

STANDARD RESPONSE TO LICENSEES CONTACTED BY TELEPHONE

(CONCERNS, INSPECTION TO FOLLOW)

Licensee Name \[License No.\]

Address \[Docket No.\]

ATTENTION: \[Licensee Point of Contact, Title\]

SUBJECT: TELEPHONE INTERVIEW TO EVALUATE THE RADIATION SAFETY PROGRAM

Sir or Madam:

This refers to the interview by telephone on \[date\]. The interview was
an examination of activities conducted under your license as they relate
to radiation safety and to compliance with the U. S. Nuclear Regulatory
Commission (NRC) rules and regulations and with the conditions of your
license. As a result of this examination of your licensed activities, we
noted regulatory concerns that are specified below. These concerns may
be further evaluated during an onsite inspection at your facility in the
near future.

> *(List regulatory concerns. For any concern that appears to rise to a
> violation or otherwise to indicate lack of programmatic oversight, the
> region should promptly conduct an inspection and take enforcement
> action, as appropriate, based on the results of the inspection.)*

In particular, you should examine your license and the NRC=s regulations
to determine how you can correct the apparent regulatory concerns listed
above. The points listed below are especially important for your
radiation safety program:

> 1\. control access to and prevent loss of licensed material, ensure
> proper transfers and disposal of licensed material, and promptly
> report to NRC loss or theft of licensed material
>
> 2\. maintain shielding of licensed material to reduce radiation
> exposure
>
> 3\. implement comprehensive safety measures to limit other hazards
> from compromising the safe use and storage of licensed material
> evaluate radiation exposures to workers and members of the public
>
> 4\. use properly calibrated survey instruments to monitor radiation
> levels
>
> 5\. ensure that workers are knowledgeable, skilled, and empowered to
> implement the radiation protection program
>
> 6\. ensure that upper level managers are aware of the radiation
> protection program, that annual audits of the program are completed,
> and that appropriate action is taken for past performance, present
> conditions, and future needs

If you have any questions about this matter, please contact me at
\[phone, fax, email address\].

Sincerely, \[Inspector Name, Title\]

EXHIBIT 3

STANDARD RESPONSE TO LICENSEES CONTACTED BY TELEPHONE

(NO CONCERNS/VIOLATIONS)

Licensee Name \[License No.\]

Address \[Docket No.\]

ATTENTION: \[Licensee Point of Contact, Title\]

SUBJECT: TELEPHONE INTERVIEW TO EVALUATE THE RADIATION SAFETY PROGRAM

Sir or Madam:

This refers to the interview by telephone on \[date\]. The interview was
an examination of activities conducted under your license as they relate
to radiation safety and to compliance with the U. S. Nuclear Regulatory
Commission rules and regulations and with the conditions of your
license. No regulatory concerns were identified.

If you have any questions about this matter, please contact me at
\[phone, fax, email address\].

Sincerely,

> \[Inspector Name, Title\]

ENCLOSURE 3

INFORMATION FOR THE NUCLEAR MATERIALS EVENTS DATABASE (NMED)

The regional office shall forward copies of all documentation regarding
a material incident (i.e., \"Preliminary Notifications,\" reports of
medical events, follow-up inspection reports) to the NMED contractor and
the NMED Project Manager, NMSS. For publicly available documents, entry
into ADAMS meets the requirement for forwarding the documents. For
documents that are not publicly available, the regional office must
forward paper copies to the NMED contractor and the NMED Project
Coordinator, NMSS.

The NMED Event No. must be annotated on each document. The regional
office is responsible for ensuring that sufficient information is
provided for the NMED item to be considered \"complete.\" The basic
information along with the additional specific information for certain
types of events, outlined below, constitutes the Acomplete@ record.

The target for ensuring \"complete\" NMED records is 70 days from the
date the event is reported. The information identified below must be
provided to classify a record as \"complete.\" If there is a reason that
required information can not be obtained, that reason should be
forwarded to the NMED contractor and the NMED Project Manager.

[Basic Information]{.underline}:

1\. Essential Details

> a\. narrative event description
>
> b\. report identification number

c\. event date and notification date

d\. licensee/reporting party information (name, license number, and
address)

e\. site of event

> f\. whether the event is NRC reportable and the applicable reporting
> requirement

g\. cause and corrective actions

h\. number of persons involved, consequences

I. notifications: local police, FBI, other States, as needed

> j\. identify any possible generic safety concerns/potential for others
> to experience the same event

2\. Source/Radioactive Material:

a\. isotope and activity

b\. manufacturer

c\. model and serial number

3\. Device/Associated Equipment:

a\. manufacturer

b\. model and serial number

[Additional information is required for the specific event types listed
below]{.underline}:

1\. Release of Licensed Material or Contamination (NMED CODE: RLM):

a\. release type (air or water)

b\. contamination (person or surface)

c\. isotope and activity released

2\. Medical event (NMED CODE: MD2):

a\. procedure administered

b\. dose intended and dose administered

c\. isotope and activity administered

d\. organ targeted

e\. notifications: patient, physician

3\. Overexposure (EXP):

a\. radiation source and activity

b\. exposure dose

c\. exposure type (whole body, extremity, etc.)

4\. Transportation (TRS):

a\. type of transport

b\. identity of shipper

c\. package type and ID number

ENCLOSURE 4

INSPECTION MANUAL CHAPTERS AND INSPECTION PROCEDURES

+-----------+--------------------------------------------+------------+
| **MC/IP   | **Inspection Manual Chapter/Inspection     | **Routine  |
| No.**     | Procedure Title**                          | (R) or**   |
|           |                                            |            |
|           |                                            | **As       |
|           |                                            | Needed     |
|           |                                            | (N)**      |
+===========+============================================+============+
| MATERIALS |                                            |            |
| SAFETY    |                                            |            |
| PROGRAMS  |                                            |            |
+-----------+--------------------------------------------+------------+
| MC1220    | \"Processing of NRC Form 241,=Inspection   | N          |
|           | of Agreement State Licensees Operating     |            |
|           | Under the Reciprocity Provisions of 10 CFR |            |
|           | 150.20\"                                   |            |
+-----------+--------------------------------------------+------------+
| MC2810    | AMaterials Inspection Programs for         | N          |
|           | Multi-Site and Multi-Regional Broad        |            |
|           | Licensees\"                                |            |
+-----------+--------------------------------------------+------------+
| MC2815    | \"Construction and Pre-Operational         | N          |
|           | Inspection of Panoramic, Wet-Source        |            |
|           | Storage Gamma Irradiators\"                |            |
+-----------+--------------------------------------------+------------+
| MC 2882   | ATransfer of NRC License Files to          | N          |
|           | Agreement State(s)                         |            |
+-----------+--------------------------------------------+------------+
| IP 87121  | AIndustrial Radiography Programs@          | R          |
+-----------+--------------------------------------------+------------+
| IP 87122  | AIrradiator Programs@                      | R          |
+-----------+--------------------------------------------+------------+
| IP 87123  | AWell Logging Programs@                    | R          |
+-----------+--------------------------------------------+------------+
| IP 87124  | AFixed and Portable Gauge Programs@        | R          |
+-----------+--------------------------------------------+------------+
| IP 87125  | AMaterials Processor/Manufacturer          | R          |
|           | Programs@                                  |            |
+-----------+--------------------------------------------+------------+
| IP 87126  | AIndustrial/Academic/Research Programs@    | R          |
+-----------+--------------------------------------------+------------+
| IP 87127  | ARadiopharmacy Programs@                   | R          |
+-----------+--------------------------------------------+------------+
| IP 87129  | AMaster Programs@                          | N          |
+-----------+--------------------------------------------+------------+
| IP 87130  | ANuclear Medicine ProgramsBWritten         | R          |
|           | Directive Not Required@                    |            |
+-----------+--------------------------------------------+------------+
| IP 87131  | ANuclear Medicine ProgramsBWritten         | R          |
|           | Directive Required@                        |            |
+-----------+--------------------------------------------+------------+
| IP 87132  | ABrachytherapy Programs@                   | R          |
+-----------+--------------------------------------------+------------+
| IP 87133  | AMedical Gamma Stereotactic Radiosurgery   | R          |
|           | and Teletherapy Programs@                  |            |
+-----------+--------------------------------------------+------------+
| IP 87134  | AMedical Broad-Scope Programs@             | R          |
+-----------+--------------------------------------------+------------+

+-----------+--------------------------------------------+------------+
| **MC/IP   | **Inspection Manual Chapter/Inspection     | **Routine  |
| No.**     | Procedure Title**                          | (R) or**   |
|           |                                            |            |
|           |                                            | **As       |
|           |                                            | Needed     |
|           |                                            | (N)**      |
+===========+============================================+============+
| CONDUCT   |                                            |            |
| OF        |                                            |            |
| IN        |                                            |            |
| SPECTIONS |                                            |            |
+-----------+--------------------------------------------+------------+
| MC 0300   | \"Announced and Unannounced Inspections\"  | R          |
+-----------+--------------------------------------------+------------+
| MC 0330   | AGuidance for NRC Review of Licensee Draft | N          |
|           | Documents@                                 |            |
+-----------+--------------------------------------------+------------+
| MC 0312   | \"Technical Assistance for Radiation       | N          |
|           | Safety Inspections at Nuclear Fuel         |            |
|           | Facilities and Materials Licensees\"       |            |
+-----------+--------------------------------------------+------------+
| MC 1246   | AFormal Qualification Programs in Nuclear  | R          |
|           | Material Safety and Safeguards Program     |            |
|           | Area.@                                     |            |
+-----------+--------------------------------------------+------------+
| IP 40002  | AInspections to Review Allegations@        | N          |
+-----------+--------------------------------------------+------------+
| IP 87250  | \"Locating Missing Materials Licensees\"   | N          |
+-----------+--------------------------------------------+------------+
| IP 93800  | \"Augmented Inspection Team.\"             | N          |
+-----------+--------------------------------------------+------------+
| IP 93812  | \"Special Inspection.\"                    | N          |
+-----------+--------------------------------------------+------------+
| INCIDENT  |                                            |            |
| RESPONSE  |                                            |            |
+-----------+--------------------------------------------+------------+
| MC 1301   | \"Response to Radioactive Material         | N          |
|           | Incidents That Do Not Require Activation   |            |
|           | of the NRC Incident Response Center\"      |            |
+-----------+--------------------------------------------+------------+
| MC 1302   | AAction Levels for Radiation Exposures and | N          |
|           | Contamination Associated with Materials    |            |
|           | Events Involving Members of the Public\"   |            |
+-----------+--------------------------------------------+------------+
| MC 1303   | ARequesting Emergency Acceptance of        | N          |
|           | Radioactive Material by the U.S.           |            |
|           | Department of Energy (DOE)@                |            |
+-----------+--------------------------------------------+------------+
| MC 1330   | \"Response to Transportation Accidents     | N          |
|           | Involving Radioactive Materials\"          |            |
+-----------+--------------------------------------------+------------+
| MC 1360   | \"Use of Physician and Scientific          | N          |
|           | Consultants in the Medical Consultant      |            |
|           | Program\"                                  |            |
+-----------+--------------------------------------------+------------+
| IP 87103  | \"Inspection of Material Licensees         | N          |
|           | Involved in an Incident or Bankruptcy@     |            |
+-----------+--------------------------------------------+------------+

+-----------+---+--------------------------------------------+---+------------+
| **MC/IP   | * |                                            |   | **Routine  |
| No.**     | * |                                            |   | (R) or**   |
|           | I |                                            |   |            |
|           | n |                                            |   | **As       |
|           | s |                                            |   | Needed     |
|           | p |                                            |   | (N)**      |
|           | e |                                            |   |            |
|           | c |                                            |   |            |
|           | t |                                            |   |            |
|           | i |                                            |   |            |
|           | o |                                            |   |            |
|           | n |                                            |   |            |
|           | M |                                            |   |            |
|           | a |                                            |   |            |
|           | n |                                            |   |            |
|           | u |                                            |   |            |
|           | a |                                            |   |            |
|           | l |                                            |   |            |
|           | C |                                            |   |            |
|           | h |                                            |   |            |
|           | a |                                            |   |            |
|           | p |                                            |   |            |
|           | t |                                            |   |            |
|           | e |                                            |   |            |
|           | r |                                            |   |            |
|           | / |                                            |   |            |
|           | I |                                            |   |            |
|           | n |                                            |   |            |
|           | s |                                            |   |            |
|           | p |                                            |   |            |
|           | e |                                            |   |            |
|           | c |                                            |   |            |
|           | t |                                            |   |            |
|           | i |                                            |   |            |
|           | o |                                            |   |            |
|           | n |                                            |   |            |
|           | P |                                            |   |            |
|           | r |                                            |   |            |
|           | o |                                            |   |            |
|           | c |                                            |   |            |
|           | e |                                            |   |            |
|           | d |                                            |   |            |
|           | u |                                            |   |            |
|           | r |                                            |   |            |
|           | e |                                            |   |            |
|           | T |                                            |   |            |
|           | i |                                            |   |            |
|           | t |                                            |   |            |
|           | l |                                            |   |            |
|           | e |                                            |   |            |
|           | * |                                            |   |            |
|           | * |                                            |   |            |
+-----------+---+--------------------------------------------+---+------------+
| LOW-LEVEL |   |                                            |   |            |
| WA        |   |                                            |   |            |
| STE/WASTE |   |                                            |   |            |
| M         |   |                                            |   |            |
| ANAGEMENT |   |                                            |   |            |
+-----------+---+--------------------------------------------+---+------------+
| MC 2401   |   | \"Near-Surface Low-Level Radioactive Waste | N |            |
|           |   | Disposal Facility Inspection Program\"     |   |            |
+-----------+---+--------------------------------------------+---+------------+
| IP 84750  |   | ARadioactive Waste Treatment and Effluent  | R |            |
|           |   | and Environmental Monitoring\"             |   |            |
+-----------+---+--------------------------------------------+---+------------+
| IP 84850  |   | \"Radioactive Waste Management -           | R |            |
|           |   | Inspection of Waste Generator Requirements |   |            |
|           |   | of 10 CFR Part 20 and 10 CFR Part 61\"     |   |            |
+-----------+---+--------------------------------------------+---+------------+
| IP 84900  |   | \"Low-Level Radioactive Waste Storage\"    | R |            |
+-----------+---+--------------------------------------------+---+------------+
| DECOMM    |   |                                            |   |            |
| ISSIONING |   |                                            |   |            |
| IN        |   |                                            |   |            |
| SPECTIONS |   |                                            |   |            |
+-----------+---+--------------------------------------------+---+------------+
| MC 2602   |   | ADecommissioning Inspection Program For    | N |            |
|           |   | Fuel Cycle Facilities and Materials        |   |            |
|           |   | Licensees@                                 |   |            |
+-----------+---+--------------------------------------------+---+------------+
| IP 83890  |   | \"Closeout Inspection and Survey\"         | N |            |
+-----------+---+--------------------------------------------+---+------------+
| IP 87104  |   | ADecommissioning Inspection Procedures for | N |            |
|           |   | Materials Licenses@                        |   |            |
+-----------+---+--------------------------------------------+---+------------+
| RADIATION |   |                                            |   |            |
| P         |   |                                            |   |            |
| ROTECTION |   |                                            |   |            |
+-----------+---+--------------------------------------------+---+------------+
| IP 83822  |   | \"Radiation Protection\"                   | R |            |
+-----------+---+--------------------------------------------+---+------------+
| IP 87102  |   | \"Maintaining Effluents from Materials     | R |            |
|           |   | Facilities As Low As Is Reasonably         |   |            |
|           |   | Achievable (ALARA)\"                       |   |            |
+-----------+---+--------------------------------------------+---+------------+
| TRANS     |   |                                            |   |            |
| PORTATION |   |                                            |   |            |
+-----------+---+--------------------------------------------+---+------------+
| MC 1330   |   | \"Response to Transportation Accidents     | N |            |
|           |   | Involving Radioactive Materials\"          |   |            |
+-----------+---+--------------------------------------------+---+------------+
| IP 86740  |   | \"Inspection of Transportation             | R |            |
|           |   | Activities\"                               |   |            |
+-----------+---+--------------------------------------------+---+------------+
| IP 86750  |   | \"Solid Radioactive Waste Management and   | R |            |
|           |   | Transportation of Radioactive Materials\"  |   |            |
+-----------+---+--------------------------------------------+---+------------+
| REPOR     |   |                                            |   |            |
| TS/COMMUN |   |                                            |   |            |
| ICATIONS/ |   |                                            |   |            |
| FOLLOW-UP |   |                                            |   |            |
+-----------+---+--------------------------------------------+---+------------+
| MC 0230   |   | \"Morning Report\"                         | N |            |
+-----------+---+--------------------------------------------+---+------------+
| MC 0610   |   | AInspection Reports\"                      | R |            |
+-----------+---+--------------------------------------------+---+------------+

+-----------+--------------------------------------------+------------+
| **MC/IP   | **Inspection Manual Chapter/Inspection     | **Routine  |
| No.**     | Procedure Title**                          | (R) or**   |
|           |                                            |            |
|           |                                            | **As       |
|           |                                            | Needed     |
|           |                                            | (N)**      |
+-----------+--------------------------------------------+------------+
| MC 0620   | AInspection Documents and Records@         | R          |
+-----------+--------------------------------------------+------------+
| MC 0730   | AGeneric Communications Regarding Material | N          |
|           | and Fuel Cycle Issues@                     |            |
+-----------+--------------------------------------------+------------+
| MC 1120   | \"Preliminary Notifications\"              | N          |
+-----------+--------------------------------------------+------------+
| IP 92701  | \"Follow-up\"                              | R          |
+-----------+--------------------------------------------+------------+
| IP 92703  | \"Follow-up of Confirmatory Action         | N          |
|           | Letters\"                                  |            |
+-----------+--------------------------------------------+------------+
| INT       |                                            |            |
| ERACTIONS |                                            |            |
| WITH      |                                            |            |
| OTHER     |                                            |            |
| FEDERAL   |                                            |            |
| AGENCIES  |                                            |            |
+-----------+--------------------------------------------+------------+
| MC 1007   | \"Interfacing Activities between Regional  | R          |
|           | Offices of NRC and OSHA\"                  |            |
+-----------+--------------------------------------------+------------+
| IP 93001  | AOSHA Interface Activities@                | N          |
+-----------+--------------------------------------------+------------+

ENCLOSURE 5

+----------+---------+----------+----+--------+--------+-----------+
| **NRC    |         |          |    |        |        |           |
| FORM     |         |          |    |        |        |           |
| 591M U.S |         |          |    |        |        |           |
| NUCLEAR  |         |          |    |        |        |           |
| REGU     |         |          |    |        |        |           |
| LATORY** |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
| **PART 1 |         |          |    |        |        |           |
| COMM     |         |          |    |        |        |           |
| ISSION** |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
| **(      |         |          |    |        |        |           |
| 10-2003) |         |          |    |        |        |           |
| 10 CFR** |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
| *        |         |          |    |        |        |           |
| *2.201** |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
| **SAFTEY |         |          |    |        |        |           |
| IN       |         |          |    |        |        |           |
| SPECTION |         |          |    |        |        |           |
| REPORT   |         |          |    |        |        |           |
| AND      |         |          |    |        |        |           |
| CO       |         |          |    |        |        |           |
| MPLIANCE |         |          |    |        |        |           |
| INSP     |         |          |    |        |        |           |
| ECTION** |         |          |    |        |        |           |
+----------+---------+----------+----+--------+--------+-----------+
| 1\.      |         |          | 2  |        |        |           |
| L        |         |          | \. |        |        |           |
| ICENSEE/ |         |          | NR |        |        |           |
| LOCATION |         |          | C/ |        |        |           |
| IN       |         |          | RE |        |        |           |
| SPECTED: |         |          | GI |        |        |           |
|          |         |          | ON |        |        |           |
| REPORT   |         |          | AL |        |        |           |
|          |         |          | OF |        |        |           |
|          |         |          | FI |        |        |           |
|          |         |          | CE |        |        |           |
+----------+---------+----------+----+--------+--------+-----------+
| 3\.      |         | 4\.      |    |        | 5\.    |           |
| DOCKET   |         | LICENSEE |    |        | D      |           |
| N        |         | N        |    |        | ATE(S) |           |
| UMBER(S) |         | UMBER(S) |    |        | OF     |           |
|          |         |          |    |        | INSP   |           |
|          |         |          |    |        | ECTION |           |
+----------+---------+----------+----+--------+--------+-----------+
| **LIC    |         |          |    |        |        |           |
| ENSEE:** |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
| The      |         |          |    |        |        |           |
| in       |         |          |    |        |        |           |
| spection |         |          |    |        |        |           |
| was an   |         |          |    |        |        |           |
| exa      |         |          |    |        |        |           |
| mination |         |          |    |        |        |           |
| of the   |         |          |    |        |        |           |
| ac       |         |          |    |        |        |           |
| tivities |         |          |    |        |        |           |
| c        |         |          |    |        |        |           |
| onducted |         |          |    |        |        |           |
| under    |         |          |    |        |        |           |
| your     |         |          |    |        |        |           |
| license  |         |          |    |        |        |           |
| as they  |         |          |    |        |        |           |
| relate   |         |          |    |        |        |           |
| to       |         |          |    |        |        |           |
| r        |         |          |    |        |        |           |
| adiation |         |          |    |        |        |           |
| safety   |         |          |    |        |        |           |
| and to   |         |          |    |        |        |           |
| co       |         |          |    |        |        |           |
| mpliance |         |          |    |        |        |           |
| with the |         |          |    |        |        |           |
| Nuclear  |         |          |    |        |        |           |
| Re       |         |          |    |        |        |           |
| gulatory |         |          |    |        |        |           |
| Co       |         |          |    |        |        |           |
| mmission |         |          |    |        |        |           |
| (NRC)    |         |          |    |        |        |           |
| rules    |         |          |    |        |        |           |
| and      |         |          |    |        |        |           |
| reg      |         |          |    |        |        |           |
| ulations |         |          |    |        |        |           |
| and the  |         |          |    |        |        |           |
| co       |         |          |    |        |        |           |
| nditions |         |          |    |        |        |           |
| of your  |         |          |    |        |        |           |
| license. |         |          |    |        |        |           |
| The      |         |          |    |        |        |           |
| in       |         |          |    |        |        |           |
| spection |         |          |    |        |        |           |
| c        |         |          |    |        |        |           |
| onsisted |         |          |    |        |        |           |
| of       |         |          |    |        |        |           |
| s        |         |          |    |        |        |           |
| elective |         |          |    |        |        |           |
| exam     |         |          |    |        |        |           |
| inations |         |          |    |        |        |           |
| of       |         |          |    |        |        |           |
| pr       |         |          |    |        |        |           |
| ocedures |         |          |    |        |        |           |
| and      |         |          |    |        |        |           |
| repres   |         |          |    |        |        |           |
| entative |         |          |    |        |        |           |
| records, |         |          |    |        |        |           |
| in       |         |          |    |        |        |           |
| terviews |         |          |    |        |        |           |
| with     |         |          |    |        |        |           |
| pe       |         |          |    |        |        |           |
| rsonnel, |         |          |    |        |        |           |
| and      |         |          |    |        |        |           |
| obse     |         |          |    |        |        |           |
| rvations |         |          |    |        |        |           |
| by the   |         |          |    |        |        |           |
| in       |         |          |    |        |        |           |
| spector. |         |          |    |        |        |           |
| The      |         |          |    |        |        |           |
| in       |         |          |    |        |        |           |
| spection |         |          |    |        |        |           |
| findings |         |          |    |        |        |           |
| are as   |         |          |    |        |        |           |
| follows: |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
| 1        |         |          |    |        |        |           |
| .  Based |         |          |    |        |        |           |
|     on   |         |          |    |        |        |           |
|     the  |         |          |    |        |        |           |
|     in   |         |          |    |        |        |           |
| spection |         |          |    |        |        |           |
|     f    |         |          |    |        |        |           |
| indings, |         |          |    |        |        |           |
|     no   |         |          |    |        |        |           |
|     vi   |         |          |    |        |        |           |
| olations |         |          |    |        |        |           |
|     were |         |          |    |        |        |           |
|     ide  |         |          |    |        |        |           |
| ntified. |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
| 2.       |         |          |    |        |        |           |
| Previous |         |          |    |        |        |           |
|     viol |         |          |    |        |        |           |
| ation(s) |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
|  closed. |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
| 3.  The  |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
|    viola |         |          |    |        |        |           |
| tion(s), |         |          |    |        |        |           |
|     spec |         |          |    |        |        |           |
| ifically |         |          |    |        |        |           |
|     d    |         |          |    |        |        |           |
| escribed |         |          |    |        |        |           |
|     to   |         |          |    |        |        |           |
|     you  |         |          |    |        |        |           |
|     by   |         |          |    |        |        |           |
|     the  |         |          |    |        |        |           |
|     i    |         |          |    |        |        |           |
| nspector |         |          |    |        |        |           |
|     as   |         |          |    |        |        |           |
|     n    |         |          |    |        |        |           |
| on-cited |         |          |    |        |        |           |
|     vio  |         |          |    |        |        |           |
| lations, |         |          |    |        |        |           |
|     are  |         |          |    |        |        |           |
|     not  |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
|    being |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
|    cited |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
|  because |         |          |    |        |        |           |
|     they |         |          |    |        |        |           |
|     were |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
| self-ide |         |          |    |        |        |           |
| ntified, |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
|  non-rep |         |          |    |        |        |           |
| etitive, |         |          |    |        |        |           |
|     and  |         |          |    |        |        |           |
|     co   |         |          |    |        |        |           |
| rrective |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
|   action |         |          |    |        |        |           |
|     was  |         |          |    |        |        |           |
|     or   |         |          |    |        |        |           |
|     is   |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
|    being |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
|    taken |         |          |    |        |        |           |
|     and  |         |          |    |        |        |           |
|     the  |         |          |    |        |        |           |
|     r    |         |          |    |        |        |           |
| emaining |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
| criteria |         |          |    |        |        |           |
|     in   |         |          |    |        |        |           |
|     the  |         |          |    |        |        |           |
|     NRC  |         |          |    |        |        |           |
|     Enf  |         |          |    |        |        |           |
| orcement |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
|   Policy |         |          |    |        |        |           |
|     to   |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
| exercise |         |          |    |        |        |           |
|     dis  |         |          |    |        |        |           |
| cretion, |         |          |    |        |        |           |
|     were |         |          |    |        |        |           |
|     sa   |         |          |    |        |        |           |
| tisfied. |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
| > **N    |         |          |    |        |        |           |
| on-Cited |         |          |    |        |        |           |
| > Viol   |         |          |    |        |        |           |
| ation(s) |         |          |    |        |        |           |
| >        |         |          |    |        |        |           |
| was/were |         |          |    |        |        |           |
| > d      |         |          |    |        |        |           |
| iscussed |         |          |    |        |        |           |
| > i      |         |          |    |        |        |           |
| nvolving |         |          |    |        |        |           |
| > the    |         |          |    |        |        |           |
| > f      |         |          |    |        |        |           |
| ollowing |         |          |    |        |        |           |
| > requir |         |          |    |        |        |           |
| ement(s) |         |          |    |        |        |           |
| > and    |         |          |    |        |        |           |
| > Co     |         |          |    |        |        |           |
| rrective |         |          |    |        |        |           |
| > Acti   |         |          |    |        |        |           |
| on(s):** |         |          |    |        |        |           |
| >        |         |          |    |        |        |           |
| > **4.   |         |          |    |        |        |           |
| > During |         |          |    |        |        |           |
| > this   |         |          |    |        |        |           |
| > in     |         |          |    |        |        |           |
| spection |         |          |    |        |        |           |
| >        |         |          |    |        |        |           |
|  certain |         |          |    |        |        |           |
| > of     |         |          |    |        |        |           |
| > your   |         |          |    |        |        |           |
| > act    |         |          |    |        |        |           |
| ivities, |         |          |    |        |        |           |
| > as     |         |          |    |        |        |           |
| > d      |         |          |    |        |        |           |
| escribed |         |          |    |        |        |           |
| > below  |         |          |    |        |        |           |
| > and/or |         |          |    |        |        |           |
| > a      |         |          |    |        |        |           |
| ttached, |         |          |    |        |        |           |
| > were   |         |          |    |        |        |           |
| > in     |         |          |    |        |        |           |
| > v      |         |          |    |        |        |           |
| iolation |         |          |    |        |        |           |
| > of NRC |         |          |    |        |        |           |
| > requ   |         |          |    |        |        |           |
| irements |         |          |    |        |        |           |
| > and    |         |          |    |        |        |           |
| > are    |         |          |    |        |        |           |
| > being  |         |          |    |        |        |           |
| > cited. |         |          |    |        |        |           |
| > This   |         |          |    |        |        |           |
| > form   |         |          |    |        |        |           |
| > is a   |         |          |    |        |        |           |
| > NOTICE |         |          |    |        |        |           |
| > OF     |         |          |    |        |        |           |
| > VI     |         |          |    |        |        |           |
| OLATION, |         |          |    |        |        |           |
| > which  |         |          |    |        |        |           |
| > may be |         |          |    |        |        |           |
| >        |         |          |    |        |        |           |
|  subject |         |          |    |        |        |           |
| > to     |         |          |    |        |        |           |
| >        |         |          |    |        |        |           |
|  posting |         |          |    |        |        |           |
| > in     |         |          |    |        |        |           |
| > ac     |         |          |    |        |        |           |
| cordance |         |          |    |        |        |           |
| > with   |         |          |    |        |        |           |
| > 10 CFR |         |          |    |        |        |           |
| >        |         |          |    |        |        |           |
|  19.11** |         |          |    |        |        |           |
+----------+---------+----------+----+--------+--------+-----------+
| **Li     |         |          |    |        |        |           |
| censee's |         |          |    |        |        |           |
| S        |         |          |    |        |        |           |
| tatement |         |          |    |        |        |           |
| of       |         |          |    |        |        |           |
| Co       |         |          |    |        |        |           |
| rrective |         |          |    |        |        |           |
| Actions  |         |          |    |        |        |           |
| for Item |         |          |    |        |        |           |
| 4,       |         |          |    |        |        |           |
| above.** |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
| **I      |         |          |    |        |        |           |
| hereby   |         |          |    |        |        |           |
| state    |         |          |    |        |        |           |
| that,    |         |          |    |        |        |           |
| within   |         |          |    |        |        |           |
| 30 days, |         |          |    |        |        |           |
| the      |         |          |    |        |        |           |
| actions  |         |          |    |        |        |           |
| d        |         |          |    |        |        |           |
| escribed |         |          |    |        |        |           |
| by me to |         |          |    |        |        |           |
| the      |         |          |    |        |        |           |
| i        |         |          |    |        |        |           |
| nspector |         |          |    |        |        |           |
| will be  |         |          |    |        |        |           |
| taken to |         |          |    |        |        |           |
| correct  |         |          |    |        |        |           |
| the      |         |          |    |        |        |           |
| vi       |         |          |    |        |        |           |
| olations |         |          |    |        |        |           |
| ide      |         |          |    |        |        |           |
| ntified. |         |          |    |        |        |           |
| This     |         |          |    |        |        |           |
| s        |         |          |    |        |        |           |
| tatement |         |          |    |        |        |           |
| of       |         |          |    |        |        |           |
| co       |         |          |    |        |        |           |
| rrective |         |          |    |        |        |           |
| actions  |         |          |    |        |        |           |
| is made  |         |          |    |        |        |           |
| in       |         |          |    |        |        |           |
| ac       |         |          |    |        |        |           |
| cordance |         |          |    |        |        |           |
| with the |         |          |    |        |        |           |
| requ     |         |          |    |        |        |           |
| irements |         |          |    |        |        |           |
| of 10    |         |          |    |        |        |           |
| CFR      |         |          |    |        |        |           |
| 2.201    |         |          |    |        |        |           |
| (co      |         |          |    |        |        |           |
| rrective |         |          |    |        |        |           |
| steps    |         |          |    |        |        |           |
| already  |         |          |    |        |        |           |
| taken,   |         |          |    |        |        |           |
| co       |         |          |    |        |        |           |
| rrective |         |          |    |        |        |           |
| steps    |         |          |    |        |        |           |
| which    |         |          |    |        |        |           |
| will be  |         |          |    |        |        |           |
| taken,   |         |          |    |        |        |           |
| date     |         |          |    |        |        |           |
| when     |         |          |    |        |        |           |
| full     |         |          |    |        |        |           |
| co       |         |          |    |        |        |           |
| mpliance |         |          |    |        |        |           |
| will be  |         |          |    |        |        |           |
| ac       |         |          |    |        |        |           |
| hieved). |         |          |    |        |        |           |
| I        |         |          |    |        |        |           |
| un       |         |          |    |        |        |           |
| derstand |         |          |    |        |        |           |
| that no  |         |          |    |        |        |           |
| further  |         |          |    |        |        |           |
| written  |         |          |    |        |        |           |
| response |         |          |    |        |        |           |
| to NRC   |         |          |    |        |        |           |
| will be  |         |          |    |        |        |           |
| r        |         |          |    |        |        |           |
| equired, |         |          |    |        |        |           |
| unless   |         |          |    |        |        |           |
| spec     |         |          |    |        |        |           |
| ifically |         |          |    |        |        |           |
| requ     |         |          |    |        |        |           |
| ested.** |         |          |    |        |        |           |
+----------+---------+----------+----+--------+--------+-----------+
| *        | **      |          |    | *      |        | **Date**  |
| *Title** | Printed |          |    | *Signa |        |           |
|          | Name**  |          |    | ture** |        |           |
+----------+---------+----------+----+--------+--------+-----------+
| **LICE   |         |          |    |        |        |           |
| NSEE'S** |         |          |    |        |        |           |
|          |         |          |    |        |        |           |
| **       |         |          |    |        |        |           |
| REPRESEN |         |          |    |        |        |           |
| TATIVE** |         |          |    |        |        |           |
+----------+---------+----------+----+--------+--------+-----------+
| **NRC    |         |          |    |        |        |           |
| INS      |         |          |    |        |        |           |
| PECTOR** |         |          |    |        |        |           |
+----------+---------+----------+----+--------+--------+-----------+

**NRC FORM 591M PART 1(10-2003)**

+----------------------+----------+--------------+--------------------+
| **NRC FORM 591M PART |          |              |                    |
| 2 U.S NUCLEAR        |          |              |                    |
| REGULATORY           |          |              |                    |
| COMMISSION**         |          |              |                    |
|                      |          |              |                    |
| (**10-2003) 10 CFR   |          |              |                    |
| 2.201**              |          |              |                    |
|                      |          |              |                    |
| **SAFTEY INSPECTION  |          |              |                    |
| REPORT AND           |          |              |                    |
| COMPLIANCE           |          |              |                    |
| INSPECTION**         |          |              |                    |
+----------------------+----------+--------------+--------------------+
| 1\.                  |          | 2\.          |                    |
| LICENSEE/LOCATION    |          | NRC/REGIONAL |                    |
| INSPECTED:           |          | OFFICE       |                    |
|                      |          |              |                    |
| REPORT               |          |              |                    |
+----------------------+----------+--------------+--------------------+
| 3\. DOCKET NUMBER(S) | 4\.      |              | 5\. DATE(S) OF     |
|                      | LICENSEE |              | INSPECTION         |
|                      | N        |              |                    |
|                      | UMBER(S) |              |                    |
+----------------------+----------+--------------+--------------------+
| **(Continued)**      |          |              |                    |
+----------------------+----------+--------------+--------------------+

+---------+----------+---+------+----------------+---+------------------+
| **NRC   |          |   |      |                |   |                  |
| FORM    |          |   |      |                |   |                  |
| 591 M   |          |   |      |                |   |                  |
| PART 2  |          |   |      |                |   |                  |
| U.S.    |          |   |      |                |   |                  |
| NUCLEAR |          |   |      |                |   |                  |
| REG     |          |   |      |                |   |                  |
| ULATORY |          |   |      |                |   |                  |
| COMMI   |          |   |      |                |   |                  |
| SSION** |          |   |      |                |   |                  |
|         |          |   |      |                |   |                  |
| **(1    |          |   |      |                |   |                  |
| 0-2003) |          |   |      |                |   |                  |
| 10 CFR  |          |   |      |                |   |                  |
| 2.201** |          |   |      |                |   |                  |
|         |          |   |      |                |   |                  |
| **      |          |   |      |                |   |                  |
| *DOCKET |          |   |      |                |   |                  |
| FILE    |          |   |      |                |   |                  |
| INFORMA |          |   |      |                |   |                  |
| TION*** |          |   |      |                |   |                  |
|         |          |   |      |                |   |                  |
| *       |          |   |      |                |   |                  |
| *SAFETY |          |   |      |                |   |                  |
| INS     |          |   |      |                |   |                  |
| PECTION |          |   |      |                |   |                  |
| REPORT  |          |   |      |                |   |                  |
| AND     |          |   |      |                |   |                  |
| CO      |          |   |      |                |   |                  |
| MLIANCE |          |   |      |                |   |                  |
| INSPE   |          |   |      |                |   |                  |
| CTION** |          |   |      |                |   |                  |
+---------+----------+---+------+----------------+---+------------------+
| **1.    |          |   |      | **2.           |   |                  |
| LIC     |          |   |      | NRC/REGIONAL   |   |                  |
| ENSEE** |          |   |      | OFFICE**       |   |                  |
|         |          |   |      |                |   |                  |
| **R     |          |   |      |                |   |                  |
| EPORT** |          |   |      |                |   |                  |
+---------+----------+---+------+----------------+---+------------------+
| **3.    |          | * |      |                | * |                  |
| DOCKET  |          | * |      |                | * |                  |
| NUMB    |          | 4 |      |                | 5 |                  |
| ER(S)** |          | . |      |                | . |                  |
|         |          | L |      |                | D |                  |
|         |          | I |      |                | A |                  |
|         |          | C |      |                | T |                  |
|         |          | E |      |                | E |                  |
|         |          | N |      |                | ( |                  |
|         |          | S |      |                | S |                  |
|         |          | E |      |                | ) |                  |
|         |          | N |      |                | O |                  |
|         |          | U |      |                | F |                  |
|         |          | M |      |                | I |                  |
|         |          | B |      |                | N |                  |
|         |          | E |      |                | S |                  |
|         |          | R |      |                | P |                  |
|         |          | ( |      |                | E |                  |
|         |          | S |      |                | C |                  |
|         |          | ) |      |                | T |                  |
|         |          | * |      |                | I |                  |
|         |          | * |      |                | O |                  |
|         |          |   |      |                | N |                  |
|         |          |   |      |                | * |                  |
|         |          |   |      |                | * |                  |
+---------+----------+---+------+----------------+---+------------------+
| **6.    |          | * |      |                |   |                  |
| INS     |          | * |      |                |   |                  |
| PECTION |          | 7 |      |                |   |                  |
| PROCE   |          | . |      |                |   |                  |
| DURES** |          | I |      |                |   |                  |
|         |          | N |      |                |   |                  |
|         |          | S |      |                |   |                  |
|         |          | P |      |                |   |                  |
|         |          | E |      |                |   |                  |
|         |          | C |      |                |   |                  |
|         |          | T |      |                |   |                  |
|         |          | I |      |                |   |                  |
|         |          | O |      |                |   |                  |
|         |          | N |      |                |   |                  |
|         |          | F |      |                |   |                  |
|         |          | O |      |                |   |                  |
|         |          | C |      |                |   |                  |
|         |          | U |      |                |   |                  |
|         |          | S |      |                |   |                  |
|         |          | A |      |                |   |                  |
|         |          | R |      |                |   |                  |
|         |          | E |      |                |   |                  |
|         |          | A |      |                |   |                  |
|         |          | S |      |                |   |                  |
|         |          | * |      |                |   |                  |
|         |          | * |      |                |   |                  |
+---------+----------+---+------+----------------+---+------------------+
| **SUPPL |          |   |      |                |   |                  |
| EMENTAL |          |   |      |                |   |                  |
| INS     |          |   |      |                |   |                  |
| PECTION |          |   |      |                |   |                  |
| INFORM  |          |   |      |                |   |                  |
| ATION** |          |   |      |                |   |                  |
+---------+----------+---+------+----------------+---+------------------+
| **1.PR  | **2.     |   | **3. |                |   | **4. TELEPHONE   |
| OGRAM** | PR       |   | LICE |                |   | NUMBER**         |
|         | IORITY** |   | NSEE |                |   |                  |
|         |          |   | C    |                |   |                  |
|         |          |   | ONTA |                |   |                  |
|         |          |   | CT** |                |   |                  |
+---------+----------+---+------+----------------+---+------------------+
| **     |          |   |      |                |   |                  |
| Mail    |          |   |      |                |   |                  |
| Office  |          |   |      |                |   |                  |
| Inspe   |          |   |      |                |   |                  |
| ction** |          |   |      |                |   |                  |
| **Next  |          |   |      |                |   |                  |
| Ins     |          |   |      |                |   |                  |
| pection |          |   |      |                |   |                  |
| Date:** |          |   |      |                |   |                  |
|         |          |   |      |                |   |                  |
| **    |          |   |      |                |   |                  |
| Field** |          |   |      |                |   |                  |
|         |          |   |      |                |   |                  |
| *       |          |   |      |                |   |                  |
| *Temp |          |   |      |                |   |                  |
| orary** |          |   |      |                |   |                  |
+---------+----------+---+------+----------------+---+------------------+
| **      |          |   |      |                |   |                  |
| PROGRAM |          |   |      |                |   |                  |
| SCOPE** |          |   |      |                |   |                  |
+---------+----------+---+------+----------------+---+------------------+

**NRC FORM 591M PART 2 (10-2003)**

ENCLOSURE 6

INSPECTION RECORD

Region Inspection Report No. License No.

> Docket No.

Licensee (Name and Address):

Location (Authorized Site) Being Inspected

Licensee Contact: Telephone No.

Priority: Program Code:

Date of Last Inspection: Date of This Inspection: ­­­­

Type of Inspection: ( ) Initial ( ) Announced ( ) Unannounced

> ( ) Routine ( ) Special

Next Inspection Date: ( ) Normal ( ) Reduced

Justification for reducing the routine inspection interval:

Summary of Findings and Actions:

> ( ) No violations cited, clear U.S. Nuclear Regulatory Commission
> (NRC) Form 591 or regional letter issued
>
> ( ) Non-cited violations (NCVs)
>
> ( ) Violation(s), Form 591 issued
>
> ( ) Violation(s), regional letter issued
>
> ( ) Followup on previous violations

Inspector(s) Date (Name)

> (Signature)

Approved Date (Name)

> (Signature)

**PART I-LICENSE, INSPECTION, INCIDENT/EVENT, AND ENFORCEMENT HISTORY**

1\. [AMENDMENTS AND PROGRAM CHANGES]{.underline}:

> (License amendments issued since last inspection, or program changes
> noted in the license)

[AMENDMENT \#]{.underline} [DATE]{.underline} [SUBJECT]{.underline}

2\. [INSPECTION AND ENFORCEMENT HISTORY]{.underline}:

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

3\. [INCIDENT/EVENT HISTORY]{.underline}:

> (List any incidents, or events reported to NRC since the last
> inspection. Citing ANone@ indicates that regional event logs, event
> files, and the licensing file have no evidence of any incidents or
> events since the last inspection.)

**PART II - INSPECTION DOCUMENTATION**

1\. [ORGANIZATION AND SCOPE OF PROGRAM]{.underline}:

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

2\. [SCOPE OF INSPECTION]{.underline}:

> (Identify the inspection procedure(s) used and focus areas evaluated.
> If records were reviewed, indicate the type of record and time periods
> reviewed)
>
> Inspection Procedure(s) Used:

Focus Areas Evaluated:

3\. [INDEPENDENT AND CONFIRMATORY MEASUREMENTS]{.underline}:

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

4\. [VIOLATIONS, NCVs, AND OTHER SAFETY ISSUES]{.underline}:

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

5\. [PERSONNEL CONTACTED]{.underline}:

> (Identify licensee personnel contacted during the inspection,
> including those individuals contacted by telephone.)
>
> Use the following identification symbols:
>
> \# Individual(s) present at entrance meeting
>
> \* Individual(s) present at exit meeting

-END-

ENCLOSURE 7

INFORMATION REGARDING INSPECTION OF LICENSEES HOLDING

NUCLEAR MATERIALS MANAGEMENT AND SAFEGUARDS SYSTEM ACCOUNTS

1.0 Background:

> The Nuclear Materials Management and Safeguards System (NMMSS) is the
> U.S. Government's database for current and historical data on the
> receipt, shipment, and inventory adjustment of certain source and
> special nuclear materials (SNM). NMMSS data is also used to satisfy
> the reporting requirements of international agreements that the United
> States is part of regarding the tracking of certain source and special
> nuclear materials. The NMMSS database is operated by a contractor on
> behalf of the U.S. Department of Energy (DOE) and the NRC.
>
> NRC and Agreement State licensees are required by 10 CFR Parts 40, 72,
> 74, and 150 to submit reports to NMMSS if th ey ship, receive, or
> adjust their onsite inventories for materials that are equal to or
> greater than the quantities shown in Table 1 on page 5.
>
> NMMSS is also used to provide information to the U.S. D epartment of
> State to satisfy agreements with other nations that require the
> accounting of foreign-obligated source material and SNM imported to
> and exported from the United States. Foreign-obligated source material
> is source material that is tracked by NMMSS in accordance with treaty
> or agreement obligations that the United States has with other nations
> to treat nuclear materials in a manner consistent with that treaty or
> agreement. For example, certain source material may be sold by or to
> the United States with the understanding that the material will only
> be used for peaceful purposes such as power generation and not used in
> a nuclear weapons program.
>
> In practice, all foreign-obligated source material in the United
> States is located at fuel cycle facilities. It is not expected that
> any for eign-obligated material would be found at a licensee facility
> inspected under IMC 2800. However, if an inspector identifies source
> material with documented foreign obligations, then the inspector shou
> ld immediately notify the Office of Nuclear Security and Incident
> Response, Division of Nuclear Security (NSIR/DNS), NMMSS Project
> Manager. The inspector should include the material within the scope of
> the inspection under IMC 2800 until further notice. The material is
> routinely inspected under IMC 2600, "Fuel Cycle Facility Operational
> Safety and Safeguards Inspection Program."
>
> While the license a nd licensee records typically use units of
> radioactivity to quantify NMMSS-reportable materials, NMMSS uses units
> of mass (i.e., "grams") for inventory data in records and reports.
>
> **NOTE**: An inspector can readily identify foreign-obligated source
> material because NMMSS reports the quantity as "kilograms."
>
> SNM is the focus of the remainder of the [inspection]{.underline}
> guidance in this enclosure. NMMSS tracks quantities of subject
> material by material type (MT) and does not track licensee inventories
> of NMMSS-reportable material down to the item level. For example,
> NMMSS cannot provide information regarding the model number and serial
> number of devices or sources containing NMMSS-reportable material at a
> particular facility. Table 2 on page 5 indicates the MT codes for the
> materials that NRC requires to be reported to NMMSS.
>
> In preparing for the inspection, the inspector should sum the masses
> for e ach MT reported by NMMSS, and be prepared to do the same during
> the inspection when examining the licensee's inventory records. Table
> 3 on page 6 indicates the specific activities for the materials likely
> to be seen during an inspection. These factors may be used to convert
> between grams and activity units (curies) when comparing licensee and
> NMMSS records.

2.0 NMMSS Inspection Process

> 02.01 Prepa ration: If the licensee is authorized to possess
> NMMSS-reportable quantities of materials, the inspector will contact
> the NMMSS contractor (telephone (678) 328-1116) and request a "Task 8
> Inspection Package." If unable to contact the NMMSS contractor, the
> inspector should notify the NSIR/DNS NMMSS Project Manager. A minimum
> of seven calendar days should be allowed prior to the start of the
> inspection trip to allow sufficient time for the package to be mailed
> to the inspector.
>
> The Task 8 Inspect ion Package contains three documents which are
> described in Table 4, on page 6:
>
> a\. DOE/NRC Form 742, "Material Balance Report,"
>
> b\. NMMSS Report TJ-45
>
> c\. NMMSS Report D-3
>
> Inspectors are cautioned tha t at a minimum, NMMSS data is
> Sensitive-Unclassified Official Use Only (OUO) information. Since it
> will generally be necessary to take NMMSS data on the inspection,
> inspectors must be familiar with, and comply with, the OUO information
> storage and handling requirements specified in NRC Management
> Directive (MD) 12.6, "NRC Sensitive Unclassified Information Security
> Program." Any losses or compromise of OUO data must be reported to the
> NRC's Division of Facility Security in accordance with MD 12.6.
> Inspectors must also be cautious with regard to handling licensee
> information that may be classified, sensitive, or proprietary. For
> more information, contact the appropriate regional or NSIR security
> advisor, or refer to the security services web page at
> [http://www.internal.nrc.gov/ADM/DFS/dfs.html](http://www.internal.nrc.gov/ADM/DFS/dfs.html.).
>
> 02.02 On-Site Inspection: During each in spection of a licensee
> holding a NMMSS account, the inspector shall:
>
> a\. Discuss the location of all NMMSS-reportable material possessed by
> the licensee. Obtain and review the most recent record of physical
> inventory of SNM performed by the licensee. Compare the licensee's
> inventory records with t he information documented in the licensee's
> NMMSS account on the DOE/NRC Form 742, "Material Balance Report,"
> provided by the NMMSS contractor.
>
> b\. Review the records documenting the receipt, transfe r and disposal
> of material maintained by the licensee in accordance with 10 CFR
> 74.19(a)(1). Compare these records to the data in the NMMSS Report
> TJ-45 and determine that the licensee has accounted for the quantities
> of materials received, possessed, transferred, and disposed since the
> licensee submitted the most recent DOE/NRC Form 742, "Material Balance
> Report."
>
> c\. Verify the information listed on the licensee's inventory record
> by walking down the licensee's facility and (if practicable) visual ly
> identifying, at a minimum, a representative sample of the materials
> that the licensee reported to NMMSS on the most recently submitted
> DOE/NRC Form 742. If appropriate, verify the presence of the s ubject
> material with a radiation survey instrument. The intent of the
> measurement is to verify the presence of radioactive material rather
> than to determine the quantity or specific isotopic identity of the
> material present.
>
> **NOTE:** An inspector should not ask licensee personnel to open any
> container or otherwise change the container's shielding to facilitate
> this survey.
>
> If the licensee posse sses NMMSS-reportable material in sufficient
> quantity to be subject to NMMSS requirements (i.e., Table 1) and has
> not reported the material, or if discrepancies exist between the
> licensee's inventory records and the most recently submitted DOE/NRC
> Form 742, the licensee's corrective actions must include contacting
> the NMMSS contractor to revise and reconcile their reported holdings
> of NMMSS-reportable material. The licensee must adequately evaluate
> any discrepancy to determine if, in fact, NMMSS-rep ortable materials
> are lost or otherwise missing. The inspector must collect sufficient
> information to support potential short-term NRC regulatory actions,
> such as the preparation of a confirmatory action letter or an order,
> and potential longer term escalated enforcement actions.
>
> d\. Provide responsible licensee personnel with a copy of NMMSS Report
> D-3 which summarizes the administrative information contained in NMMSS
> about the licensee. Review the administrative information listed in
> the NMMSS Re port D-3 with licensee personnel to ensure that the
> information is up to date. This information includes, but is not
> limited to: mailing address

1.  physical or shipping address (for transmitting information via
    nonpostal methods that cannot use a post office box)

    3\. telephone number, FAX number, and e -mail address for primary
    technical point of contact

    4\. telephone number, fax number, and e-mail a ddress for primary
    management point of contact

    5\. the license numbers of NRC or Agreement State licenses that
    authorize the possession of subject material

    e\. If corrections to any NMMSS data are needed, the licensee should
    contact the NMMSS contractor directly by telephone. Specifically,
    for correcti ons to NMMSS Report D-3, the licensee may update their
    administrative information by using the link t o the On-Line RIS
    Update Application which is available on the NMMSS web page (lower
    left corner) at:

    <http://www.nmmss.com/NMMSST1.nsf/mainFS?OpenFrameSet>.

    By using the link, a licensee can keep their administrative
    information at NMMSS up to date. The NMMSS contractor will verify
    the licensee's changes before updating the NMMSS database.

    02.03 Inspection Documentation: If applicable, the inspector should
    include a statement that the licens ee's reporting to NMMSS was
    reviewed in accordance with the procedures described in Enclosure 7.
    The statement should be recorded under the "Program Scope" in Part 3
    of NRC Form 591M, "Safety Inspection Report and Compliance
    Inspection," along with the results of the overall inspection.

    Since inspection findings and much of the data used in these
    inspections are "Business Proprietary" or "Sensitive-Unclassified
    Official Use Only," inspection documentation must be properly
    protected at all times. Information discussing the quantities and
    forms of NMMSS-reportable materials possessed by the licensee shall
    not be included in NRC Form 591M or in any other inspection
    documentation unless the informati on is vital to adequately
    document any violations or other issues that require corrective or
    other follow-up action by the licensee or the NRC. Any inspection
    records that must contain information about quantities and forms of
    NMMSS-reportable materials will be profiled in ADAMS as
    "non-publically available" documents.

    Provide a copy of any inspection report (i.e., NRC Form 591M or
    Enclosure 6 (In spection Report), or narrative report) that
    documents a violation of NMMSS reporting requirements to the
    NSIR/DNS, NMMSS Project Manager.

    **Enclosure 7 NMMSS Quick References**

    Table 1: NMMSS Repor table Quantities

    Table 2: NMMSS Material Types

  ------------------------------------------------- ---------------------
  **MATERIAL TYPE**                                 **MT CODE**

  Foreign-obligated depleted uranium\*              MT 10

  Enriched uranium                                  MT 20

  Plutonium                                         MT 50

  Uranium 233                                       MT 70

  Foreign-obligated normal uranium\*                MT 81

  Plutonium 238                                     MT 83\*\*

  Foreign-obligated thorium\*                       MT 88

  Uranium in cascade                                MT 89
  ------------------------------------------------- ---------------------

\* Only source material that has foreign obligations is subject to NMM
SS reporting requirements.

\*\* Plutonium that is more than 10% Pu^238^ of total Pu by weight is
reporte d as Pu^238^

Number range CHAPTER**Enclosure 7 NMMSS Quick References**

Table 3: Activity to Mass Conversion Factors

  ------------------------------- ---------------------------------------
  **Isotope**                     **Specific Activity (curies/gram)**

  Uranium 234                     6.2 X 10^-3^

  Uranium 235                     2.2 X 10^-6^

  Uranium 238                     3.3 X 10^-7^

  lutonium 238                    17.3

  Plutonium 239                   0.063

  Plutonium 240                   0.23

  Plutonium 241                   104

  Plutonium 242                   0.004
  ------------------------------- ---------------------------------------

Table 4:Task 8 Inspection Package Descriptions

  ----------------------- -----------------------------------------------
  DOE/NRC Form 742,       Licensee-submitted summary of NMMSS-reportable
  Material Balance Report materials, by material type, possessed by the
                          licensee

  NMMSS Report TJ-45      Listing of transactions involving
                          NMMSS-reportable materials reported by the
                          licensee, including receipts, transfers and
                          disposals, since the most recent DOE/NRC Form
                          742

  NMMSS Report D-3        Summary of licensee administrative information
                          on record in NMMSS
  ----------------------- -----------------------------------------------

NMMSS CONTRACTOR CONTACT TELEPHONE NO.: (678) 328-1116

Contact the NMMSS Project Manager, Division of Nuclear Security, Office
of Nuclear Security and Incident Response for technical questions.

-END-

[^1]:
    > Priority T denotes a telephone contact made by an inspector to
    > evaluate the radiation protection program for Program Codes 03122,
    > 03123, 03124, 03220, 11210, 22130, 22160, and 22161. The telephone
    > contact interval is 5 years.

[^2]:
    > Program Code 03235 is used only as a secondary code for certain
    > licensees authorized to operate a noncommercial incinerator to
    > dispose of radioactive waste

[^3]:
    > The Priority D denotes a decommissioning inspection as determined
    > under MC 2602, Decommissioning Inspection Program, for Program
    > Codes 03900, 11900, 21325, and 22200. These inspections are
    > scheduled at times when the licensee is performing decommissioning
    > activities at the site.