Number range CHAPTER

**NRC INSPECTION MANUAL** IMNS/RGB

INSPECTION PROCEDURE 87123

WELL LOGGING PROGRAMS

PROGRAM APPLICABILITY: 2800

87123-01 INSPECTION OBJECTIVES

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

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

87123-02 INSPECTION REQUIREMENTS

The review of the licensed activities will be commensurate with the
scope of the licensee\'s program. The inspector's evaluation of a
licensee's program will be based on direct observation of work
activities, interviews with workers, demonstrations by workers
performing tasks regulated by NRC, and independent measurements of
radiation conditions at the facility, rather than exclusive reliance on
a review of records.

The structure and the emphasis of the inspection will be on the
following Focus Elements (FE) that describe the outcomes of an effective
well logging radiation safety program:

02.01 [FE-1]{.underline}. The licensee should control access to and
prevent loss of licensed material so as to limit radiation exposure to
workers and members of the public to values below 10 CFR Part 20 limits.

02.02 [FE-2]{.underline}. The licensee should maintain shielding of
licensed materials in a manner consistent with operating procedures and
design and performance criteria for devices and equipment.

02.03 [FE-3]{.underline}. The licensee should implement comprehensive
safety measures to limit other hazards from compromising the safe use
and storage of licensed material.

02.04 [FE-4]{.underline}. The licensee should implement a radiation
dosimetry program to accurately measure and record radiation doses
received by workers or members of the public as a result of licensed
operations.

02.05 [FE-5]{.underline}. The licensee should provide radiation
instrumentation in sufficient number, condition, and location to
accurately monitor radiation levels in areas where licensed material is
used and stored.

02.06 [FE-6]{.underline}. The licensee should ensure that workers are:

a.  knowledgeable of radiation uses and safety practices;

b.  skilled in radiation safety practices under normal and accident
    conditions; and,

c.  empowered to implement the radiation safety program.

02.07 [FE-7]{.underline}. The licensee's management system should be
appropriate for the scope of use and should ensure:

a.  awareness of the radiation protection program;

b.  that audits for ALARA practices are performed; and,

c.  that assessments of past performance, present conditions and future
    needs are performed and that appropriate action is taken when
    needed.

Usually the inspector's evaluation will examine licensee activities back
to the date of the previous inspection. However, issues preceding the
last inspection should be reviewed, if warranted by circumstances, such
as incidents, repetitive violations, or high radiation exposures.

87123-03 INSPECTION GUIDANCE

[General Guidance]{.underline}

The following inspection guidance is designed to assist the inspector in
evaluating the performance of the licensee's radiation safety program.
The guidance is organized by the individual focus elements described
above. The timing and sequence of inspection activities are left to the
inspector's discretion based on the circumstances and conditions at the
time of the actual inspection. Furthermore, inspectors should not feel
constrained by the guidance in this procedure. If an inspector obtains
information that indicates that a problem may exist in an area within
the NRC's jurisdiction that is not specifically addressed in this
procedure, the inspector should redirect, or otherwise expend,
inspection effort to address that problem. For additional information
relating to the evaluation of radiation safety programs, inspectors
should refer to Inspection Procedure (IP) 83822, "Radiation Protection."

Some of the requirement and guidance sections of this procedure instruct
the inspector to \"verify\" the adequacy of certain aspects of the
licensee\'s program. Whenever possible, verification should be
accomplished through discussions, observations, and demonstrations
rather than exclusive reliance on review of records. An examination of
the licensee\'s records should not be considered the primary part of the
inspection program.

In the records reviewed, look for trends such as increasing doses.
Records such as surveys, waste disposal, receipt and transfer of
licensed materials, training, and utilization logs, may be examined
randomly until the inspector is satisfied that the records are being
maintained and are complete. Other records that are more closely related
to health and safety (such as personnel dose-monitoring records and
incident reports) should be examined in detail.

Common elements to all inspections include preparation, entrance and
exit meetings with appropriate licensee management, including the
radiation safety officer (RSO), observations of facilities and work in
progress, independent confirmatory surveys, and the evaluation of
program scope and any special license conditions. Specific guidance
regarding these common elements can be found in IMC 2800.

Each of the following Focus Elements should be reviewed during each
inspection of all well logging licensees. Inspectors should select
sub-elements for review that are representative of the licensee's scope
of use. If the licensee is using byproduct material at a temporary job
site, then the inspector should consider those activities for the review
of each Focus Element.

[Specific Guidance]{.underline}

03.01 [FE-1:The licensee should control access to and prevent loss of
licensed material so as to limit radiation exposure to workers and
members of the public to values below 10 CFR Part 20 limits]{.underline}

[Facilities]{.underline}

a.  Through direct observation, verify that all entrances to licensee
    facilities are normally closed, locked or otherwise secured to
    prevent unauthorized entry. This should include main facility gates,
    main building entrances, doors to waste storage facilities (if the
    licensee has used unsealed materials for subsurface tracer studies),
    etc.

    1.  If any entrance or area is unsecured, determine, through
        questioning of licensee staff, the reason for the area or
        entrance being unsecured. Determine if the licensee failed to
        follow established procedures in securing the area or if
        additional training of staff is needed. Determine if the
        licensee's facility is configured to separate working areas from
        unrestricted areas.

    2.  If entrances or other areas are unsecured, examine areas where
        radioactive materials are used and stored. Storage areas must be
        locked and have limited and controlled access. Radioactive
        material use areas must be under constant surveillance or
        physically secured.

b.  Through observations, verify that use and storage areas, including
    radioactive waste storage facilities (if the licensee has used
    unsealed materials for subsurface tracer studies), are locked and
    have limited and controlled access. At a minimum, radioactive
    material use areas should be under constant surveillance during
    normal business hours when licensee personnel are present or
    physically secured against unauthorized access. Storage areas must
    be physically secured when unattended.

c.  Observe the licensee's operation at a temporary job site. This
    inspection should be unannounced. If possible, make arrangements
    with licensee management or the licensee's client to observe the
    licensee\'s field operations before announcing your presence.

> Through interviews of other workers who are present at the field site,
> determine their understanding of the licensee\'s access control.
> Although these workers may not have or need any knowledge of the
> licensee\'s operations, if they were informed of the licensee\'s
> operations, i.e., to maintain a practical safe distance from licensed
> operations, this would be an indication of the licensee\'s good safety
> practices. As non-licensees, such persons have no obligation to
> cooperate with the NRC.

1.  If other workers are unaware of basic radiation safety practices,
    determine if the licensee failed to provide instructions. Assess the
    role of other workers at the field site and the potential for
    radiation exposures of unacceptable consequence to other workers.

[Receipt and Transfer of Licensed Materials]{.underline}

a.  Through observations and interviews of licensee personnel, verify
    that the licensee: 1) properly secures package receipt areas, such
    as loading docks or other shipping and receiving areas; 2) inspects
    packages for damage; 3) performs appropriate package receipt
    surveys; 4) opens packages in a safe manner; 5) assures that
    packages are properly prepared for transport; and 6) controls
    packages in a secure manner prior to pickup by courier personnel or
    transport by licensee personnel. If unable to observe the receipt of
    packages, request that personnel who normally receive packages for
    the licensee to demonstrate package receipt processes and surveys.

    1.  If packages are left unattended, assess the licensee's receipt
        procedures, including instructions provided to couriers, to
        assure that packages are being delivered to the appropriate
        location(s).

    2.  If surveys of packages (whether during receipt or preparation
        for shipment) are not adequate to verify that radiation and
        contamination levels are within regulatory limits, interview
        licensee staff and the RSO further to assess worker knowledge.
        Deficiencies regarding instrumentation should be reviewed in
        more depth in Focus Element 5 (Section 03.05, below).

b.  Through interviews of licensee personnel and review of selected
    transfer documentation, verify that the licensee has an adequate
    method of determining that recipients of radioactive shipments are
    licensed to receive such materials.

[Physical Inventory]{.underline}.

a.  Through observation, physically examine the inventory of radioactive
    material on hand and review selected records of receipt and transfer
    to verify that quantities and forms are as authorized on the
    license, including Sealed Source and Device (SSD) registry limits.

    1.  Assess how the licensee ensures that only registered SSD
        combinations are used.

    2.  Verify that the licensee\'s use of byproduct material is limited
        to that which is authorized in the license. For example, a
        licensee may not use sealed sources in a well without a surface
        casing or inject licensed material into a fresh water aquifer
        except as specifically authorized by the Commission.

    3.  Verify that the inventory, including radioactive markers (10 CFR
        39.37, 39.47) is complete.

b.  Through interviews of the RSO and selected licensee personnel,
    determine whether the licensee has experienced any events since the
    last inspection, involving lost, missing, or stolen licensed
    materials.

    1.  Review and evaluate any such incident or unusual occurrence that
        took place since the last inspection. If such incidents were
        required to be reported, verify, through interview of the RSO
        and review of event reports, that a complete and timely report
        was made to the NRC.

    2.  For incidents or unusual occurrences that were not required to
        be reported, determine that the licensee performed sufficient
        investigation to identify the cause of the incident, and took
        appropriate corrections to prevent recurrence of the situation
        leading to the incident or unusual occurrence.

    3.  Verify that the licensee has adequate procedures in place for
        the abandonment of irretrievable sources. Verify that the
        licensee has a written agreement with the well owner/operator
        for recovery or abandonment of sources (10 CFR 39.15).

03.02 [FE-2: The licensee should maintain shielding of licensed
materials in a manner consistent with operating procedures and design
and performance criteria for devices and equipment]{.underline}

[Routine and Non-Routine Maintenance]{.underline}

Through interviews of licensee staff and observation of the licensee's
equipment, verify that the licensee has inspection and maintenance
programs required under 10 CFR 39.43 and that associated records of
defects are available. The equipment items involved in the program
should include source holders, logging tools, uranium sinker bars,
source-handling tools, storage containers, and transport containers. The
program should ensure that no physical damage is visible and that the
required labeling is legible. Physically examine a representative sample
of source handling tools to determine their condition and their ability
to adequately secure a source during transfer to and from its source
storage container. Physically examine source storage containers to
ensure that they are in good condition and that design safety features
function as intended.

a.  If licensee staff did not check well logging equipment each day
    before use and semiannually or if physical damage is evident or
    illegible labels are apparent, assess the licensee's process for
    completing the checks. Determine how the licensee failed to
    implement the written procedure.

b.  If unauthorized individuals removed sealed sources from source
    holders or logging tools, assess the licensee's process for
    dismantling well logging equipment and the potential for radiation
    exposures. Determine how the licensee failed to implement the
    written procedure.

c.  If individuals were not specifically approved by NRC or an Agreement
    State to open, remove, or modify a sealed source or to remove (e.g.,
    chisel, drill, or cut) a stuck sealed source from the source holder,
    assess the licensee's process for performing the operation and the
    potential for radiation exposures. Determine how the licensee failed
    to obtain approval from NRC or an Agreement State.

[Area Radiation Surveys]{.underline}

Through interviews of selected licensee personnel, including the RSO,
verify specifically that schedule and procedural requirements for
surveys are adequate to demonstrate compliance with the regulations and
with pertinent license requirements. Determine whether due consideration
is given to gamma and neutron emissions from the radionuclides involved,
and to total body exposure and extremity exposure.

Verify that the licensee has established schedules for periodic surveys
of work and storage areas of the facility site. Observe surveys in
progress by licensee personnel. Determine the adequacy of the
surveyor\'s knowledge in checking the survey instrument for proper
operation with a dedicated check source and in the use of the instrument
for conducting radiation surveys. Review a random selection of survey
records to verify that surveys are performed according to schedules;
assess that the survey results are reviewed by an appropriate supervisor
and that corrective actions have been taken, as appropriate.

Request that licensee personnel spot-check radiation levels in selected
areas using the licensee\'s instrumentation. Compare the results with
those obtained using the NRC\'s instruments.

03.03 [FE-3: The licensee should implement comprehensive safety measures
to limit other hazards from compromising the safe use and storage of
licensed material]{.underline}

The inspector should be attentive to potential industrial safety hazards
for referral to the U.S. Department of Labor\'s Occupational Safety and
Health Administration (see Manual Chapter 1007). The focus should be on
potential non-radiological hazards personally observed or brought to the
inspector's attention by licensee staff.

[Operational Limits]{.underline}

Verify that well logging sources are used in accordance with any
operational limits described in the applicable SSD sheet. Sources have
limits for temperature, pressure, corrosive chemical exposure, etc.
Also, inspectors should assess that sources in storage are protected
from fire (see "Fire Protection below) and the elements, that package
integrity is appropriately maintained, and that controls are in effect
to minimize the risk from other hazardous materials.

[Temporary Job Site Hazards]{.underline}

During inspections of licensed activities at temporary job sites, verify
that licensee personnel ensure that sources are protected from heavy
equipment; such as cranes, drill pipe, etc.; welding equipment; high
voltage lines; and other industrial hazards.

[Fire Protection]{.underline}

In many cases, the risk posed to radiological safety by fires is
comparable to or exceeds the risk from other events involving licensed
activities. During the course of inspection of the licensees facilities,
be alert to potential fire hazards. An effective licensee fire
protection program should (1) prevent fires from starting, (2) rapidly
detect, control, and extinguish those fires that do occur, and (3)
provide protection for structures, systems, and components important to
safety so that a fire that is not promptly extinguished by fire
suppression activities will not prevent the licensee from taking actions
to safely control licensed material and prevent the spread of
contamination and unnecessary exposures to workers or the public.

Through observation and discussion with the licensee, while touring the
facilities, assess firesafe conditions and equipment, i.e., that: (1)
work areas are generally uncluttered and free of combustible debris, (2)
incompatible materials (i.e., materials labeled as "corrosive",
"flammable", or "oxidizer") are isolated from each other and enclosed by
fire resistant barriers, (3) fire detection systems are operable, (4)
fire suppression systems are operable, (5) portable fire extinguishers
are unexpired (check maintenance tags), (6) electric switches and
electric motors are explosion-proof, arc welders or open flames are
administratively controlled in work areas that also contain flammable or
combustible liquids or gases or highly reactive chemicals, and that (7)
the local fire department is involved with the licensee's fire
protection program.

Through observations and discussions with licensee staff, assess that:
(1) radioactive waste is protected from fire and the elements, (2)
package integrity is appropriately maintained, (3) the storage area is
ventilated, and (4) controls are in effect to minimize the risk from
other hazardous materials.

Any problems/deficiencies noted should be promptly brought to the
licensee's attention and discussed with Regional management.

Licensees should be practical in approaching the safety of the device in
the event of fire. They should not endanger themselves to protect the
source, but should be able to provide radiological hazard information to
emergency medical and fire personnel who respond to the fire.

[Industrial/Chemical Hazards]{.underline}

Through observations and interviews of licensee personnel, determine
that the licensee controls the use/storage of hazardous (corrosive or
combustible) chemicals near well logging equipment which could degrade
performance or render safety features inoperable. If the licensee is
required to implement an emergency plan, verify that the plan includes
these hazards, as appropriate, as initiating events.

[Transportation]{.underline}

Verify that licensed material is packaged and transported (or offered
for transport) in accordance with 10 CFR Part 71 and U. S. Department of
Transportation (DOT) regulations for transportation of radioactive
materials. The inspector should refer to IP 86740, \"Inspection of
Transportation Activities\" for further inspection guidance. Also the
field reference charts, \"Hazard Communications for Class 7
(Radioactive) Materials,\" are useful for determining compliance with
the transportation requirements for minimum packaging, shipping papers,
marking and labeling packages, placarding vehicles, and package and
vehicle radiation limits and contamination limits.

a.  Observe the preparation of radioactive materials for shipment.
    Verify that the proper packaging is used for the type of
    materials/devices shipped. Verify that the licensee properly marks
    and labels packages in accordance with DOT requirements. Verify that
    the licensee performs appropriate examinations to confirm that
    package radiation and contamination levels are within applicable DOT
    limits prior to offering them for transport. Verify that proper
    shipping papers are prepared for each package/shipment and that, if
    necessary, the licensee maintains and offers appropriate placards to
    common carriers.

b.  If the licensee tests and certifies its own DOT Type A packaging
    materials, review test procedures and required certification
    documentation for selected packages. Verify that the packaging
    materials are used in the same or similar configurations as in their
    certification testing.

c.  Verify that any DOT Type B containers are used in accordance with
    their Certificates of Compliance (COCs) issued by the NRC. The
    licensee must maintain copies of the COCs for the packages that it
    has used and ensure that it follows the instructions and limitations
    of the COCs when preparing the packages for shipment.

d.  If the licensee reported any transportation incidents, review the
    licensee's actions in response to the incidents.

e.  In the case where a licensee may have transferred a source to a
    burial site for offsite disposal, review the licensee\'s procedures
    and records to verify that each shipment is accompanied by a
    shipment manifest that includes all the required information. Also
    review the licensee\'s procedures and records to verify that each
    package intended for shipment to a licensed land disposal facility
    is labeled, as appropriate, to identify it as Class A, B, or C waste
    in accordance with the classification criteria of 10 CFR 61.55
    \[Subsection III.A.2 of Appendix G to Part 20\]. Verify that records
    are maintained that demonstrate compliance with the requirements for
    the disposal of licensed material made under 10 CFR 20.2002-2005, 10
    CFR Part 61, and disposal by burial in soil. For further inspection
    guidance, refer to IP 84850, \"Radioactive Waste Management -
    Inspection of Waste Generator Requirements of 10 CFR Part 20 and 10
    CFR Part 61."

03.04 [FE-4: The licensee should implement a radiation dosimetry program
to accurately measure and record radiation doses received by workers or
members of the public as a result of licensed operations]{.underline}

A radiation dosimetry program includes all of the licensee's activities
that measure the radiation dose to workers and members of the public as
the result of licensed activities. These activities would include for
example, the measurement of quantities of licensed materials present,
radiation and contamination levels, and the concentration of licensed
materials in effluent streams. For additional guidance relating to
personnel dosimetry, refer to Inspection Procedure (IP) 83822,
"Radiation Protection."

[Personnel Dosimetry]{.underline}

a.  Through interviews of the RSO, determine whether the licensee had
    made a prospective analysis of anticipated annual doses (internal
    and external) to workers. If the licensee's analysis indicated that
    monitoring was not required, verify the assumptions and outcomes.

b.  If the licensee monitors worker exposures (internal and external),
    notwithstanding a prospective analysis indicating that monitoring
    was not required, review selected reports of monitoring results.
    Verify, based on the review of reports of monitoring results, that
    worker doses adequately reflect the nature and scope of the
    licensee's activities.

    1.  If monitoring results do not reflect the nature and scope of the
        licensee's activities, or if there is wide variability in the
        range of doses for specific job categories (i.e., one worker
        consistently receives significantly more exposure than all other
        workers each month), discuss this variability with the RSO to
        determine that he/she is aware of the disparity.

    2.  Through interviews of workers and observations of activities in
        progress, determine the basis for the disparity in doses or
        verify the RSO's assessment of the disparity.

c.  Through interviews of workers and observations of activities in
    progress, verify that radiation monitors are worn appropriately and
    are recording the highest dose for which they are intended.

    1.  If monitors are not (or cannot be) worn in the most appropriate
        location to record the highest dose received by the
        individual(s), through interviews of the RSO, verify that the
        licensee has performed assessments (through surveys,
        calculation, or both) of occupational exposures received and
        adjusted the dose of record for the worker(s).

    2.  Review the results of the licensee's assessment and verify the
        assumptions and outcomes. Verify that the dose of record for the
        affected worker(s) has been adjusted and that the adjusted dose
        is within the applicable regulatory limit and ALARA.

d.  Through interviews of the RSO and review of records of external
    monitoring results, determine whether processing (collection,
    process, and assessment) of monitoring devices is being performed in
    a timely manner.

e.  Through interviews of the RSO and workers who handle volatile
    radionuclides (i.e., radioiodine), verify that the licensee has
    established an appropriate monitoring frequency for the
    identification of intakes of radioactive materials. Verify that the
    licensee has established administrative action levels for
    investigating intakes. Through a review of bioassay records, verify
    that, when those levels are exceeded, the licensee appropriately
    investigates the intakes. Verify that the licensee's process for
    converting intake measurements to dose uses appropriate calculations
    and methodologies. \[Note--the unsealed radionuclides used for
    subsurface tracer studies are generally non-volatile.\]

f.  Through reviews of dosimetry reports and annual licensee evaluations
    of public dose, and interviews of the RSO and selected licensee
    personnel, verify that the licensee has not experienced any events,
    since the last inspection, involving exposures to occupational
    workers or members of the public that were in excess of any
    regulatory limit.

    1.  Review and evaluate any such incident or unusual occurrence that
        took place since the last inspection. If such incidents were
        required to be reported, verify, through interview of the RSO
        and review of event reports, that a complete and timely report
        was made to the NRC.

    2.  For incidents or unusual occurrences that were not required to
        be reported, verify that the licensee performed sufficient
        investigation to identify the cause of the incident, and took
        appropriate corrections to prevent recurrence of the situation
        leading to the incident or unusual occurrence.

[Contamination Control]{.underline}

Through interviews of selected licensee staff, including the RSO, the
inspector should verify that personnel have an adequate understanding of
the procedures to be followed in the event that the licensee's sources
are ruptured or licensed materials have caused contamination.
Occasionally, well logging tools containing sources become lodged, or
otherwise immobilized in the well. When this happens, operations are
initiated to retrieve the tools from the well. The inspector should
verify that the drilling fluids (mud) are monitored for radioactive
materials whenever retrieval operations are ongoing.

Note that, in accordance with 10 CFR 39.67, the licensee is required to
make radiation surveys of each area where licensed materials are used
and stored. In particular, the licensee is required to perform a
radiation survey at temporary job sites before and after each subsurface
tracer study, to confirm the absence of contamination. Licensees must be
authorized to knowingly inject radioactive materials into fresh water
aquifers. If practical, observe how licensees conduct surveys to
determine the adequacy of such surveys. Also, note the types of
instruments used, and whether they are designed and calibrated for the
type of radiation being measured.

The inspector should determine if workers take smears or instrument
readings in areas that are potentially contaminated and accessible to
facility personnel. Particular attention should be given to well heads
and storage areas. The inspector should also perform independent
measurements, as needed, to verify licensee assumptions or measurements.

[Leak Tests]{.underline}

Through discussions with licensee personnel and/or by demonstration of
leak test procedures, verify that leak tests are performed in accordance
with the manufacturer\'s recommendations and/or license. In accordance
with 10 CFR 39.35, verify that the wipe of a sealed source is taken from
the nearest accessible point to the sealed source where contamination
might accumulate, at intervals not to exceed 6 months (or other
frequencies in accordance with the sealed source and device evaluation
certificate).

Verify that the licensee\'s leak test analyses (or that of it's leak
test services vendor) has sufficient sensitivity to measure 185
Becquerels (0.005 microcurie) for each type of isotope present on its
license. Through discussions with licensee staff and/or review of
pertinent records, determine if the licensee had a leaking source. If
leak test results show contamination in excess of the regulatory limits,
verify that the licensee made appropriate notifications, evaluations,
and removed the source from service.

03.05 [FE-5: The licensee should provide radiation instrumentation in
sufficient number, condition, and location to accurately monitor
radiation levels in areas where licensed material is used and
stored]{.underline}

Through observations of portable radiation detection and measurement
equipment in use and available for use, determine whether the quantity
and type are adequate for the licensee's radiation detection and
measurement needs. Verify that instruments used to meet regulatory
requirements (i.e., area and transportation surveys; bioassay and leak
test analyses) have been routinely calibrated and maintained.

[Survey Instruments]{.underline}

a.  Through observations and demonstrations, determine whether selected
    licensee survey instruments in use and available for use are
    operational (battery check) and respond appropriately to radiation
    (instrument source check). Compare licensee instrument readings to
    the NRC instrument. Verify that licensee's instrument response is
    comparable to the NRC instrument (+20%).

b.  Through interviews of the RSO and workers, and by observation,
    determine whether the licensee has a system for tagging out
    inoperable and out-of-service survey instruments.

[Instrument Calibration and Maintenance]{.underline}

a.  If the licensee uses a vendor to calibrate instruments, verify
    through interviews of the RSO that the vendor is authorized by the
    NRC or an Agreement State to perform that service.

b.  Through interviews and demonstrations, determine that licensee
    personnel who perform in-house instrument calibrations are
    knowledgeable of the calibration procedures for each type of
    instrument used by the licensee. Assess that calibrations include a
    determination of "as found" condition before adjustments are made.
    Assess that personnel understand how to maintain their doses (deep
    dose and extremity) ALARA during calibration procedures, especially
    if large activity sealed sources are used.

c.  If the licensee performs maintenance/repair on survey instruments,
    through interviews of appropriate licensee personnel and the RSO,
    determine whether the licensee possesses instrument manufacturer
    manuals and that any replacement parts used are "like-for-like."

[Bioassay Instruments]{.underline}

Through observations and interviews of the RSO and workers, verify that
the licensee's instrumentation for performing in vivo bioassay
measurements is adequate for those measurements. Determine that bioassay
probes and scalers are compatible. Determine that licensee staff perform
a response check using appropriate sources (such as a barium-133 source
to simulate iodine-131) and a suitable background measurement before
taking bioassay measurements.

[Leak Test Analysis]{.underline}

If the licensee is authorized to both collect and analyze leak test
samples, the inspector should determine if the type of counting
equipment is appropriate for the samples being analyzed and the
sensitivity required. The inspector should determine if the laboratory
instrumentation is calibrated for the appropriate geometries of the
samples to be analyzed and is routinely checked for proper operation.
The licensee should maintain calibration records, control charts, and
maintenance and repair records, to demonstrate proper operation of
laboratory instrumentation.

03.06 [FE-6: The licensee should ensure that workers are knowledgeable
of radiation uses and safety practices; skilled in radiation safety
practices under normal and accident conditions; and empowered to
implement the radiation safety program]{.underline}

a.  [Authorized Users]{.underline}. Authorized users (logging
    supervisors and logging assistants) may either be named in the
    license application or be appointed by the licensee, depending on
    the type of license issued and/or the wording in the license. For
    those appointed by the licensee, verify that the authorized user is
    trained in accordance with the approved criteria and has knowledge
    commensurate with operational duties.

> Through observations and interviews of logging supervisors and logging
> assistants, assess implementation of radiation safety practices for
> well logging activities (i.e., loading of sources into tools,
> leak-testing procedures, maintenance activities). Verify their ability
> to recognize unsafe radiological conditions and to respond
> appropriately to emergency situations. Also verify that logging
> supervisors and logging assistants understand the mechanism for
> raising safety concerns to licensee managers.
>
> Review selected training records to determine that examinations or
> tests (if applicable) have been implemented and are appropriate. Read
> a few of the examination questions to ascertain that they are
> indicative of what the worker should know to carry out his/her
> responsibilities.
>
> Note that, at a minimum, the licensee is required to provide safety
> reviews, as defined in 10 CFR 39.2, for logging supervisors and
> logging assistants at least once during each calendar year.

b.  [General Training]{.underline}. Verify, pursuant to 10 CFR 19.12,
    that initial instructions have been given to workers who in the
    course of employment are likely to receive in a year an occupational
    dose in excess of 1 mSv (100 mrem). Under the basic instructions, it
    is management\'s responsibility to inform the workers of the
    storage, transfer, or use of radiation and/or radioactive material;
    health protection problems associated with exposure to radiation;
    precautions or procedures to minimize exposure; and the purposes and
    functions of protective devices employed. The workers should also be
    informed of the pertinent provisions of NRC regulations and the
    license, and the requirement to notify management of conditions
    observed that may, if not corrected, result in a violation of NRC
    requirements.

c.  [Operating and Emergency Procedures]{.underline}. Operating and
    emergency procedures will be found in license applications and may
    vary from step-by-step procedures to more generalized procedures.
    The emergency procedures will be approved by the NRC, and reviewed
    and updated by the licensee. Any revision requires an amendment to
    the license.

> Some licensees may have agreements with other agencies (i.e., fire,
> law enforcement, and medical organizations) regarding response to
> emergencies. Discuss with the licensee\'s representatives what has
> been done to ensure that agencies (involved in such agreements)
> understand their roles in emergency responses.
>
> Verify that licensee personnel are knowledgeable of the operational
> procedures by observing the performance of tasks at selected work
> stations and by a comparison of their performance with established
> procedures. Determine that the licensee\'s emergency procedures have
> been approved by or described to NRC. Through discussions with
> workers, assess that licensee personnel understand and implement the
> established procedures and are aware of procedural revisions.
> Determine the licensee has adequate procedures in place for handling
> irretrievable, abandoned sources.
>
> Through discussions with licensee staff, assess the licensee's
> handling of tracer materials. Verify, when practical (and when
> required), that well logging personnel wear appropriate protective
> clothing during their work activities. Requirements for protective
> clothing may be found in the licensee\'s procedures. Assess that all
> waste items (i.e., empty vials, gloves, napkins, cans, etc.) are
> appropriately packaged, labeled, and transported from the job site to
> the licensee\'s waste storage location, and that the licensee has
> appropriate methods to track the items in storage.

d.  [Posting and Labeling]{.underline}. Determine that proper caution
    signs are being used at access points to areas containing licensed
    materials and radiation areas. Section 20.1903 provides exceptions
    to posting caution signs. The inspector should also randomly observe
    labeling on packages or other containers to determine that proper
    information (e.g., isotope, quantity, and date of measurement) is
    recorded.

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

03.07 [FE-7: The licensee's management system should be appropriate for
the scope of use and should ensure awareness of the radiation protection
program; that audits for ALARA practices are performed; and that
assessments of past performance, present conditions, and future needs
are performed, and that appropriate action is taken when
needed]{.underline}

The NRC holds the licensee responsible for the radiation protection
program; therefore, it is essential that strong management controls and
oversight exist to ensure that licensed activities are conducted
properly. Management responsibility and liability are sometimes under
emphasized or not addressed in applications and are often poorly
understood by licensee employees and managers. Senior management should
delegate to the RSO sufficient authority, organizational freedom, and
management prerogative to communicate with and direct personnel
regarding NRC regulations and license provisions and to terminate unsafe
activities involving byproduct material.

Through observations, interviews and the review of selected records,
determine that senior licensee management is fulfilling its
responsibility of ensuring the effective operation of the radiation
safety program. Specific areas of management focus should include:

-   Maintaining awareness of significant events such as the loss or
    theft of licensed materials.

-   Maintaining radiation safety, security and control of radioactive
    materials, and compliance with regulations.

-   Committing adequate resources (including space, equipment,
    personnel, time, and, if needed, contractors) to the radiation
    protection program to ensure that members of the public and workers
    are adequately protected from radiation hazards and that compliance
    with regulations is maintained.

-   Obtaining the NRC\'s prior written consent before transferring
    control of the license;

-   Notifying the appropriate NRC regional administrator in writing,
    immediately following filing of petition for voluntary or
    involuntary bankruptcy (10 CFR 30.34(h)).

-   Assuring the appropriate response, when applicable, to generic
    communications from the NRC.

-   Assuring that adequate provisions have been made to fund the safe
    and effective decommissioning of licensee facilities. (10 CFR 30.35)

-   Notifying the NRC of the decision to discontinue licensed activities
    or to decommission a facility in which licensed activities took
    place. (10 CFR 30.36)

-   Notifying the NRC of defects or other radiation safety equipment
    malfunctions in accordance with the requirements of 10 CFR Part 21.

-   Maintaining awareness of issues and measures to ensure worker
    performance and safety are not being compromised due to safety
    significant human performance issues.

a.  [RSC (where required or used)]{.underline}. Through the review of
    records, and interviews of the RSO and RSC members, determine that
    the committee is made up of a representative from each type of
    program area, the RSO, and a representative from management. If
    practical, attend and observe the conduct of an RSC meeting. Review
    meeting minutes (and interview selected committee members when
    practical) to determine the committee\'s effectiveness. Determine
    that the RSC meets at the required frequency as specified in the
    license application, other commitment documents, or in a specific
    license condition. Topics of discussion during committee meetings
    should include ALARA reviews, incidents, generic communications,
    authorized users and uses, waste issues, audits, etc.

> Determine if the committee has been effective in seeking out areas
> needing improvement, rather than just responding to events and
> information from outside sources. Determine whether the RSC has
> recommended any specific actions and assess the implementation of
> those recommendations. The inspector\'s review should be of sufficient
> depth and detail to provide an overall assessment of the committee\'s
> ability to identify, assess, and resolve issues. Also consider the
> effectiveness of the RSC to communicate the results of audits and
> trend analyses to appropriate personnel performing licensed
> activities.

b.  [RSO]{.underline}. Through the review of records, and interviews of
    the RSO and authorized users, verify that the RSO has been appointed
    by licensee management, identified on the license, and is
    responsible for implementing the radiation safety program.
    Determine, through interviews, that this individual is knowledgeable
    about the program, and ensures that activities are being performed
    in accordance with approved procedures and the regulations.
    Determine that, when deficiencies are identified, the RSO has
    sufficient authority, without prior approval of the RSC or licensee
    management, to implement corrective actions, including termination
    of operations that pose a threat to health and safety.

> Determine that the knowledge and training of any radiation safety
> staff are commensurate with their assigned duties. Verify that the
> radiation safety staff levels, including numbers and types of
> positions, are as described in the license application.

1.  If the inspector identifies high staff turnover or prolonged
    shortfalls in staffing levels, through interviews and observation
    determine if these shortfalls have had a negative impact on licensee
    performance.

2.  If so, discuss these findings with the RSO and senior licensee
    management to determine the source of the staffing issues and the
    licensee's plans to address the deficiency. The issue should also be
    brought to the attention of regional management.

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c.  [Audits]{.underline}. Through reviews of audit records and
    interviews, verify that the radiation safety program content and
    implementation is reviewed at least annually. The results of all
    audits must be documented in accordance with 10 CFR 20.2102(a)(2).
    Examine these records with particular attention to deficiencies
    identified by the licensee's auditors, and note any corrective
    actions taken as a result of deficiencies found.

    1.  If no corrective actions were taken, determine why the licensee
        disregarded deficiencies identified during audits.

    2.  Determine if the lack of corrective actions caused the licensee
        to be in non-compliance with regulatory requirements.

87123-04 REFERENCES

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

END