**NRC INSPECTION MANUAL** DWM

INSPECTION PROCEDURE 83890

CLOSEOUT INSPECTION AND SURVEY

PROGRAM APPLICABILITY: 2600, 2800

83890-01 INSPECTION OBJECTIVE

01.01 To ensure that Final Surveys performed at material licenses are
conducted as stated in the licensee's decommissioning plan (DP).

01.02 To verify that the sites have been decontaminated to acceptable
radiological levels for unrestricted or restricted use.

83890-02 INSPECTION REQUIREMENTS

02.01 [Preliminary Review]{.underline}. Review the licensee's
Decommissioning Plan to determine the scope of site contamination and
the licensee\'s decontamination and final survey program.

02.02 [Inspection of Final Surveys and Disposition of
Materials]{.underline}

a.  Verify, by inspection, the licensee\'s implementation of the final
    survey program to confirm the acceptability of the final survey
    results. See Appendix A, \"Final Survey Program Inspection Area,\"
    for a detailed inspection checklist for the licensee\'s final survey
    program.

b.  Confirm, by inspection of records (inventory, transfer, disposal,
    etc.), that licensed material is being, or has been, transferred to
    an authorized recipient.

c.  Confirm, by inspection of records, that materials and equipment are
    released in accordance with all applicable regulations and license
    conditions.

d.  Verify, by inspection of the licensee's facility that licensed
    material and radioactive/contaminated equipment, materials, scrap,
    etc. are not being used or stored. This should be done following
    receipt and evaluation of reports of the facility's status as
    required by 10 CFR 30.36, 40.42, and 70.38.

02.03 [Confirmatory Surveys]{.underline}. NUREG-1575, "Multi-Agency
Radiation Survey and Site Investigation Manual," (MARSSIM) defines a
confirmatory survey as "a type of survey that includes independent
(third-party) measurements, sampling, and analyses to verify the
findings of a final status survey." Surveys and sampling should be
conducted simultaneously with the licensee during the licensee's final
status surveys. The

inspector should collect side-by-side or split samples with the licensee
for comparative purposes, as well as comparing infield instrument
readings and sensitivity. Where practical, counting samples previously
collected and counted by the licensee is also acceptable. In areas where
work-in-process surveys cannot be conducted, or samples collected,
after-the-fact confirmatory surveys and sampling may be performed. Sites
where NRC's work-in-process surveys and sampling have not identified
significant weaknesses in the final survey program may not require
after-the-fact surveying and sampling. However, after-the-fact
confirmatory surveys may be required for sites where significant
unresolved weaknesses were previously identified or where repetitive
violations were identified. The goal is to conduct sufficient
confirmatory surveys and sampling so that the NRC can conclude that the
licensee's survey program is being implemented in a manner that provides
confidence in the results. The in-process approach has resulted in
significant savings in cost, assured a more accurate final status
survey, and helped the licensee in maintaining its release schedule.

The lead Nuclear Regulatory Commission (NRC) office for the facility
will review each proposed retirement of expired, superseded, or
terminated license to determine the necessity of performing a
confirmatory survey. The review will be on a case-by-case basis using
the following criteria.

a.  Those facilities that meet the following criteria do not require a
    confirmatory survey:

    1.  An adequate closeout survey has been conducted by the licensee.

    2.  Use has been limited to small quantities of radionuclides with
        half-lives of 120 days or less.

    3.  The use of sealed sources only (if leak tests have been \<0.005
        µCi).

    4.  The use of limited materials that pose a very low risk to public
        health and safety.

b.  Those facilities that meet the following criteria do require a
    confirmatory survey:

    1.  Partial site release where in-process inspection is not
        practical.

    2.  Repetitive Violations.

    3.  Significant lack of Public or Congressional confidence with
        clean-up efforts at the site.

    4.  Significant unresolved weaknesses identified during the
        inspection of the licensee's final survey program.

02.04 [The Conduct of Confirmatory Surveys]{.underline}. If a
confirmatory survey is necessary, it should be performed to determine if
the licensee's results are accurate and sufficient to demonstrate that
the facility meets NRC requirements.

02.05 [Reports and Records]{.underline}

a.  For licensees subject to the reporting requirements, verify by
    reviewing records and files that:

    1.  Personnel exposure and monitoring reports required by 10 CFR
        20.2206 have been submitted to the NRC for the calendar year in
        which the license has expired or is being terminated, and

    2.  Reports of personnel exposures for terminated employees or
        employees no longer working with radioactive materials required
        by 10 CFR 19.13 have been submitted to both the NRC and the
        employee.

b.  Determine what plans or arrangements have been made for preserving
    records required by 10 CFR §§ 20.2102-20.2110.

02.06 [Burial of Waste]{.underline}. Determine if waste has been buried
onsite. If burial has occurred, review the licensee's actions to
historically assess, characterize, survey, and model the burial site.
The licensee should model its former burial sites for compliance with 10
CFR Part 20, Subpart E.

02.07 [Final Inspection Report]{.underline}. Prepare a final inspection
report in accordance with NRC Manual Chapter 0610, which summarizes the
actions taken under this inspection procedure and the findings and
evaluations of the inspection staff.

83890-03 INSPECTION GUIDANCE

03.01 [Preliminary Review]{.underline}. Review the general licensing
history of the facility and the regulations for license termination.

03.02 [Inspection of Final Survey]{.underline}. Review any license
conditions related to decontamination of the facility, the
decommissioning plan, any approved final survey programs, and/or final
survey reports, as applicable. The inspection of the licensee's final
survey program should occur while the licensee is in the process of
performing the final survey. The purpose of this "in-process' final
survey inspection is to provide confidence that the licensee's survey
results are accurate and representative of the condition at the
facility. See Appendix A, "Final Survey Program Inspection Area," for
detailed inspection checklist for the licensee's final survey program.

03.03 [Confirmatory Survey Preparation]{.underline}. Review license
records such as the DP for types of radioactive material used onsite,
the occurrence of any significant safety issues, and any special
concerns about the site expressed by stakeholders. Also review
NUREG-1575, MARSSIM.

03.04 [Conduct of Confirmatory Surveys]{.underline}. It may be necessary
for NRC, or an NRC contractor, to conduct confirmatory measurements to
provide supplemental information after the licensee has completed its
final survey, in addition to the findings of the in-process inspection,
to ensure that the survey results reported by the licensee are accurate
and representative of the conditions at the facility. However,
comprehensive confirmatory surveys should only be necessary if there is
significant doubt about the licensee\'s final survey results. For
example, a confirmatory survey would be needed if an in-process
inspection of the licensee\'s final survey program identifies
significant, unresolved weaknesses that are not administrative in nature
(i.e., measurement results and/or soil concentration levels in units not
comparable to the release criteria, inadequate classification of an
area, or improper instrument calibration), licensee has a history of
repetitive violations that reduce NRC\'s confidence in the survey
results; significant lack of public or Congressional confidence in
clean-up efforts at the site; or the site is too small (e.g., partial
site release) for an in-process inspection. Note that the inspector may
perform limited measurements (split samples, \"side-by-side,\" direct
measurements, etc.) as part of the in-process inspection of a
licensee\'s ongoing final survey program. During the inspection,
buildings, rooms, furniture, systems and equipment; ventilation ducts,
filters, sinks, drains, traps and sumps; overhead fixtures, walls and
floors, etc., should all be considered as areas to be surveyed.

03.05 [Reports and Records]{.underline}. Although certain licensees are
not required to report personnel exposures, and the limitations of a
license removes the legal obligation to maintain the records required by
10 CFR 20.2101-20.2110, the licensee should be informed that retention
of these records is highly recommended. Licensee should be informed the
record keeping requirements for decommissioning.

03.06 [Final Inspection Report]{.underline}. The final inspection report
becomes the official certification of the disposal of licensed material.
The final inspection report forms the basis for retiring and eventually
disposing of both the licensing and inspection files.

END

**APPENDIX A**

**FINAL SURVEY PROGRAM INSPECTION AREA**

I.  [CONSIDERATION FOR DESIGNING FINAL STATUS SURVEY
    INSPECTION]{.underline}

    A.  Has the final survey report been submitted to the Nuclear
        Regulatory Commission?

    B.  Has the licensee final survey program been previously inspected?

    C.  If the final survey report is not submitted, is the licensee's
        final survey in-process?

    D.  Has the final survey plan been submitted and approved by an NRC
        license reviewer?

II. [INSPECTION AREAS FOR LICENSEE FINAL SURVEYS]{.underline}

    A.  Inspections should be made against commitments in the DP and the
        licensee\'s final survey plan (which would have been approved
        during Decommissioning Plan (DP) review).

    B.  For facilities that require a significant decontamination
        effort, all the inspection areas listed below should be
        inspected while the licensee\'s final survey program is in
        progress. For facilities that do not require a significant
        decontamination effort, only some of the inspection areas below
        may apply, and it may not be practical to inspect these areas
        until after the licensee\'s final survey is completed and the
        licensee\'s final survey report has been submitted to NRC.

    C.  Inspection of a licensee\'s final survey may include independent
        confirmatory measurements by the inspector or NRC contractor.
        The extent of the confirmatory measurements, and whether the use
        of an NRC contractor is warranted, depends on a number of
        factors that are discussed in Section II.B. In most cases,
        limited in-process confirmatory surveys should be sufficient.

    D.  For each inspection, the inspector should identify which
        inspections (listed below) are covered.

III. [LICENSEE FINAL SURVEY PLANS AND PROCEDURES]{.underline}

     A.  Determine if all potential contaminants have been identified.

     B.  Review the Organization and Responsibilities for
         adequacy/completeness:

         1.  Survey program documentation

         2.  Responsibilities and qualifications of the survey staff

     C.  Review the Quality Assurance/Quality Control program for
         adequacy/completeness:

         1.  Organizational structure

         2.  QA Program

         3.  Document Control/Records Management program

         4.  Equipment Maintenance and Control program

         5.  Audits and Corrective Action program

     D.  Determine if the laboratory analytical procedures, including
         QA/QC, are acceptable, and if the results are adequately
         documented.

     E.  Determine if the licensee prepared an adequate Final Status
         Survey (FSS) plan in accordance with guidance documents.

     F.  Determine if the field and laboratory instrumentation used, or
         planned to be used, were adequate/appropriate for scanning,
         direct measurements, and analysis for the radionuclides of
         concern (ROCs).

     G.  Determine if the calibration accounted for the ROCs

     H.  Review ROCs, area classification, survey unit size, estimated
         mean and standard deviation.

     I.  Review the methods used to address the impact of multiple ROCs
         in FSS planning.

     J.  Review instrument use procedures:

         1.  Minimum Detectable Concentration (MDC) calculations

         2.  Actual vs. required scan sensitivity; and

         3.  Calibration, including accounting for multiple
             radionuclides and any environmental factors that may
             influence instrument performance.

     K.  Select survey units/areas for confirmation:

         1.  Determine scan coverage based on classification.

         2.  Review analytical procedures for appropriateness for
             measuring the ROCs.

         3.  Cross-check FSS data packages against plan requirements.

     L.  For soil sampling, determine sampling depth requirements and
         sampling intervals. At a minimum, samples should be collected
         from anomalous or other judgmental areas, together with
         selected licensee-archived samples, for confirmatory analysis.
         The necessity for, and the specific numbers of, other
         random/systematic samples should be separately evaluated, using
         the Data Quality Objectives (DQO) process.

     M.  For structure surfaces, direct measurements should include, at
         a minimum, anomalous or judgmental areas and comparative
         measurement locations. The necessity for, and the specific
         numbers of, other random/systematic samples should be
         separately evaluated, using the DQO process.

     N.  If project documentation is complete, accurate, and represents
         current radiological conditions relative to the release
         criteria, then recommend acceptance; if insufficient, then
         provide technical comments.

     O.  Calculate action levels to investigate anomalies identified
         during verification/confirmatory surveys.

     P.  Evaluate each anomaly identified during
         verification/confirmatory surveys, for compliance.

         1.  Is it acceptable relative to size and concentration?

         2.  Has the licensee adequately addressed it?

         3.  Is it within the bounds of survey unit classification?

     Q.  Review if confirmatory analyses or measurements agree with the
         site's reported results.

     R.  Review if systematic agreement (randomly selected) and
         judgmental (location selected using professional judgment based
         on site knowledge) samples and measurements are less than the
         Derived Concentration Guidance Level.

IV. NRC CONFIRMATORY SURVEY

    A.  Review whether or not a confirmatory survey is justified.

        1.  Significant, unresolved, weaknesses identified during the
            inspection of the licensee\'s final survey program.

        2.  Repetitive violations

        3.  Significant public or Congressional interest

        4.  Partial site release where an in-process inspection is not
            practical

    B.  If a confirmatory survey is justified, determine if an NRC
        Contractor should be used. Meeting one or more of the three
        criteria listed below will, in general, justify the use of a
        contractor.

        1.  Licensee\'s final survey involves unique or complex
            technical issues.

        2.  Confirmatory survey is expected to require more than a
            person-week effort to complete field surveys and sampling.

        3.  Confirmatory survey is very high priority project that
            cannot be completed by NRC staff in a timely manner.

END

NOTE: Some licensees are decommissioning under NUREG/CR-5849. NUREG 1575
Rev.1 should not be applied to these licensees.