**NRC INSPECTION MANUAL** IMNS/RGB

INSPECTION PROCEDURE 87121

INDUSTRIAL RADIOGRAPHY PROGRAMS

PROGRAM APPLICABILITY: 2800

87121-01 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.

87121-02 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
industrial radiography 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.

87121-03 INSPECTION GUIDANCE

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.

Common elements to all inspections include 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 areas should be reviewed during each inspection of
all industrial radiography licensees.

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}.

a.  [Security]{.underline}. Through direct observation and licensee
    staff interviews, determine that all entrances to radiographic
    facilities are normally closed, locked or otherwise secured to
    prevent unauthorized entry. This should include main facility gates,
    main building entrances, doors to radiographic storage facilities,
    etc.

    1.  If any entrance or area are found to be 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 found to be unsecured, examine
        areas where radioactive materials are used and stored. Storage
        areas should be locked and have limited and controlled access.
        Radioactive material use areas should be under constant
        surveillance or physically secured.

b.  [Facilities]{.underline}. Through direct observation and licensee
    staff interviews, verify that any permanent radiographic
    installation is configured in accordance with the design and
    performance requirements found in 10 CFR Part 34. Specifically,
    verify that the facility has an operable independent entrance
    control or visible‑audible alarm system pursuant to 10 CFR 34.33.
    Observe staff tests of the entrance controls and/or radiation
    warning signals, to confirm operability during the inspection.

    Verify that permanent radiographic facilities are shielded so that
    the radiation levels in adjacent areas, including the roof, do not
    exceed 0.02 millisievert (mSv) (2 millirem \[mrem\]) in any 1 hour.
    This evaluation should consider the maximum allowable source
    quantity and any other limitations on positioning within the
    facility.

c.  [Receipt and Transfer of Licensed Material]{.underline}. Through
    observation and interviews, verify that the licensee receives
    packages and makes transfers of licensed material in accordance with
    NRC and applicable U.S. Department of Transportation (DOT)
    regulations and license conditions. Through discussions with
    licensee personnel, determine how the licensee ensures that
    transfers are made to authorized recipients. Focus on how the
    licensee receives packages, opens packages, and how and when package
    radiation surveys are performed (including wipe tests). Also
    determine what actions the licensee takes (or should take) when
    surveys reveal packages that are contaminated in excess of specified
    limits, and/or radiation levels that are higher than expected. If
    packages arrive during the course of an inspection, the inspector
    should, when practical, observe personnel performing the package
    receipt surveys.

d.  [Physical Inventory]{.underline}. Through interviews and review of
    records, verify that, as required by 10 CFR 34.29(a), the licensee
    conducts quarterly physical inventories to account for all licensed
    material received and possessed under the license. Verify that
    inventory records are maintained in accordance with 10 CFR 34.69.
    Verify that sealed sources, and radiographic exposure devices used
    by the licensee are in accordance with sealed source and device
    (SS&D) registrations sheets issued by NRC or an Agreement State. In
    order to make an assessment in this area, the inspector may ask the
    licensee how they ensure that they only use registered sources and
    devices. If practical, the inspector should verify that the
    inventory includes all radiographic exposure devices and storage
    containers containing depleted uranium and calibrators used for
    calibrating survey instruments.

e.  [Material Security and Control]{.underline}. Examine areas where
    radioactive materials are stored. Storage areas should be locked and
    have limited and controlled access. Radiographic exposure devices
    and storage containers must be physically secured to prevent access
    or removal by unauthorized personnel. Transport packages (including
    overpacks) containing licensed material must be locked and
    physically secure in the transport vehicle.

    The inspector should make every reasonable effort to perform a
    \"field inspection\" at a temporary job site of the licensee. This
    inspection should be unannounced. If possible, make some of the
    observations of the licensee\'s operations before announcing your
    presence. During the field inspection, verify that the boundaries of
    the restricted area are controlled and posted; the radiation levels
    at the boundary of the restricted area do not exceed 0.02 mSv (2
    mrem) in any 1 hour; and that the operations are conducted by [at
    least two]{.underline} qualified individuals. Ask the licensee how
    they ensure that the radiation level limits (2 mrem in any 1 hour)
    are complied with, and make an assessment of the adequacy of the
    methods. Verify that the high radiation area is under constant
    surveillance, as required by 10 CFR 34.51.

    At job sites where other workers are present, interview them to
    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, this would be an indication of the licensee\'s good
    safety practices. Inspectors should keep in mind that, as
    non-licensees, such persons have no obligation to cooperate with the
    NRC.

f.  [Area Surveys]{.underline}. The inspector should verify that
    radiation levels at the boundary of the restricted area do not
    exceed 0.02 mSv (2 mrem) in any one hour. This will require the
    inspector to determine the instantaneous exposure rate and the
    number of radiographic exposures performed by the licensee. The
    inspector may ask the licensee to spot‑check radiation levels in
    selected areas, using the licensee\'s own instrumentation. However,
    the inspector should use NRC\'s instruments for independent
    verification of the licensee\'s measurements. The inspector should
    use a survey instrument that has been calibrated within the last 6
    months. This will enhance the credibility of the inspector=s survey
    results if there is any disagreement between the readings obtained
    from the licensee=s instruments and the inspector=s (NRC=s). Ensure
    that the licensee\'s survey meters are operational and have been
    calibrated within the last 6 months.

    The inspector should verify that the radiographer or radiographer\'s
    assistant performs a survey of the exposure device and guide tube
    after each exposure of the source. The survey must be sufficient to
    confirm that the source has returned to its shielded position. If
    practical, observe how licensee conducts surveys, to determine the
    adequacy of surveys. (See FE-5)

g.  [Leak Tests]{.underline}. Through interviews with licensee staff and
    review of records, verify that required leak tests are performed at
    the required interval. Determine if the licensee exchanges or
    returns their iridium 192 sources to the vendor less than six months
    from the date that they were received, negating the need to perform
    periodic (six months) leak tests.

    1.  If the licensee performs leak tests, verify that the wipe of a
        sealed source is taken from the nearest accessible surface to
        the sealed source where contamination might accumulate (i.e.,
        the point on the camera or source exchanger where the guide tube
        or transfer tube connects) and at intervals not to exceed
        6 months.

    2.  Verify that devices containing depleted uranium are leak tested
        annually, to verify the integrity of the \"s\" tube.

    3.  The licensee should verify that the licensee\'s leak test
        analyses (or that of it=s leak test services vendor) has
        sufficient sensitivity to measure 183 Becquerels
        (0.005 microcurie) for each type of isotope present on its
        license. Through discussions with licensee personnel and/or
        review of pertinent records, determine if the licensee had a
        leaking source or indication that the integrity of any \"s\"
        tubes was compromised. 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.

h.  [Waste Storage and Disposal]{.underline}. Determine if the licensee
    possesses any industrial radiographic sources or other licensed
    sources that have been removed from service. Verify that the sources
    are stored and controlled in a secure and safe manner, and that
    radiation levels in unrestricted areas surrounding the storage area
    do not exceed the limits of 10 CFR 20.1301, \"Dose Limits for
    Individual Members of the Public."

    In the rare 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
    \[Subsection III.A.2 of Appendix G to Part 20\].

i.  [Incidents and Unusual Occurrences]{.underline}. Review and evaluate
    any incident or unusual occurrence that took place since the last
    inspection. Verify if incidents were required to be reported, and,
    if so, that proper reporting procedures were followed. For incidents
    or unusual occurrences 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.

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}.

a.  [Equipment]{.underline}. Through interviews with key licensee
    personnel, verify that the types and quantities possessed by the
    licensee are within any applicable license limits (including SS&D
    registry limits) and that the licensee is using approved
    combinations of sources and devices. Verify that all sealed sources
    (source assemblies), radiography devices (cameras), and source
    changers used by the licensee (unless specifically exempted) meet
    10 CFR 34.20 requirements. Confirm that licensees are aware that
    associated equipment needs to comply with 10 CFR 34.20. Refer to
    Regulatory Issue Summary 2005-10, APerformanceBBased Approach for
    Associated Equipment in 10 CFR 34.20,@ (ML051590049) for additional
    information about acceptable methods to demonstrate that associated
    equipment complies with 10 CFR 34.20.

> If the associated equipment appears to be modified or defective
> (defective equipment may be an indication of a modification), the
> inspector should verify whether or not the licensee had developed and
> implemented a testing program to demonstrate that modified components
> meet the performance criteria in 10 CFR 34.20. The inspector should
> alert the inspection supervisor who may extend the inspection and
> request an SS&D reviewer to evaluate the licensee=s modification of
> the equipment. The expectation is that the design safety features of
> the industrial radiography system were not compromised by a
> replacement component of associated equipment that was modified by the
> licensee. Before using a modified system, the licensee is required to
> demonstrate that the replacement component meets the performance
> criteria in 10 CFR 34.20(a)(1) and (2), (b)(3), (c)(5) and (8), and
> (e).

b.  [Routine and Non-Routine Maintenance]{.underline}. Through direct
    examination, assess the condition of licensee equipment, i.e.
    cameras, drive cables, source changers, etc. The examination should
    be sufficiently thorough to detect any of the following conditions:
    excessive or uneven wearing, fraying, unraveling, nicks, kinks or
    bends, loss of flexibility (abnormal stiffness), excessive grit or
    dirt, and stretching. The inspector may refer to Appendix O, ADaily
    Maintenance Check of Radiographic Equipment,@ NUREG-1556, Vol. 2,
    AConsolidated Guidance About Materials Licenses: Program-Specific
    Guidance About Industrial Radiography Licenses@ (August, 1998).

    1.  Should a defect, such as a damaged cable, be found in use,
        notify an appropriate licensee representative and then expand
        the scope of the examination. Monitor actions, if any, taken by
        the licensee in response to this discovery. Should the licensee
        elect to not take action, the inspector should consult with
        regional management.

    2.  Verify that the licensee has an inspection and maintenance
        program that complies with 10 CFR 34.31(a) and provides for
        visual and operability checks of radiographic equipment, survey
        meters, transport containers, associated equipment, and source
        changers before use and quarterly to ensure that the equipment
        is in good working condition.

    3.  Verify that the licensee=s inspection and maintenance program
        ensures that the sources are adequately shielded, and that the
        required labeling is present.

The inspector should verify that the licensee is aware of the
requirements contained in 10 CFR Part 21 and 10 CFR 34.101(a), and has
procedures in place for reporting defects and certain equipment
failures.

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.

a.  [Operational Limits]{.underline}. Verify that industrial radiography
    devices (and sources) are used in accordance with any operational
    limits described in the applicable SSD sheet. Through observation
    and discussions with the licensee, assess that: (1) storage
    conditions for the devices that should be protected from fire and
    the elements, (2) package integrity is appropriately maintained, and
    that (3) controls are in effect to minimize the risk from other
    hazardous materials.

b.  [Temporary Job Site Hazards]{.underline}. During inspections of
    licensed activities at temporary job sites, verify that licensee
    personnel ensure that devices are protected from heavy construction
    equipment, welding equipment, high voltage lines, and other
    industrial hazards.

c.  [Fire Protection]{.underline}. Materials licensees are not required
    by NRC regulations to implement a fire protection program. However,
    in many cases, the risk posed to radiological safety by fires is
    comparable to or exceeds the risk from other events involving
    licensed activities. Determine if licensees have a plan in place for
    preventing fires and combating fires that might occur. Any perceived
    problems/deficiencies (i.e., improper storage of combustible or
    flammable material, fire extinguishers out of service, lack of fire
    alarm or detection system, lack of fire suppression system) noted by
    the inspector should be brought to the licensee=s attention and
    discussed with regional management. Proper fire protection systems
    can be evidenced by the licensee=s involvement with the local fire
    department.

d.  [Transportation]{.underline}. Through direct observation, verify
    that the licensee properly transports radiographic devices. Examine
    packages (including overpacks) for proper labeling, review
    associated certification documentation. Examine vehicles for proper
    blocking and bracing of shipping containers. Verify that shipping
    papers are complete and available. Survey packages and vehicles to
    verify compliance with 10 CFR Part 71 and U. S. Department of
    Transportation (DOT) regulations for transportation of radioactive
    materials.

e.  Through interviews of licensee staff, determine if there were any
    incidents required to be reported to the DOT. For further inspection
    guidance, refer to IP 86740, \"Inspection of Transportation
    Activities.\" Inspectors should also refer to \"Hazard
    Communications for Class 7 (Radioactive) Materials.\" These field
    reference charts, related to hazard communications for
    transportation of radioactive materials, are useful field references
    for determining compliance with the transportation rules on
    labeling, placarding, shipping papers, and package markings. They
    also contain references to the DOT regulatory requirements.

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.

a.  Through observation, verify that personnel dosimetry devices (film
    badges, TLDs, or OSDs) are worn by appropriate licensee personnel,
    including all radiographers and radiographer=s assistants. Also
    verify that direct reading dosimeters and alarm ratemeters are also
    worn by appropriate personnel. Note that alarm ratemeters are not
    required to be worn when radiography is being performed at permanent
    radiographic installations. Dosimetry devices appropriate to the
    type, energy of emitted radiation, and the anticipated radiation
    fields, must be issued to licensee personnel. Verify that any
    dosimeters, that require processing to determine the radiation dose,
    are processed by a National Voluntary Laboratory Accreditation
    Program (NVLAP) accredited processor.

b.  Verify that, pursuant to 10 CFR 19.13(b), the licensee advises each
    worker annually of the worker\'s dose as shown in records maintained
    by the licensee pursuant to the provisions of 10 CFR 20.2106,
    \"Records of individual monitoring results.\" Verify that this has
    been done by asking workers and management if the written report
    requiring this information has been provided to each of them within
    the last year. The report must include external doses from routine
    operations, accidents, and emergencies. The report to the individual
    must contain all of the information required in 10 CFR 19.13(a).

> Verify that, pursuant to 10 CFR 20.2206(c), the licensee submits
> annual reports of individual monitoring, on or before April 30 of each
> year (covering the previous year) to the REIRS Project Manager, Office
> of Nuclear Regulatory Research.

c.  Verify that an evaluation has been performed that demonstrates that
    the use and storage of sealed sources will not likely result in
    exposures to members of the public or radiation levels in
    unrestricted areas that are in excess of the regulatory limits. For
    storage areas that are located adjacent to unrestricted areas,
    licensees must ensure (through measurement or calculation) that
    doses in the unrestricted areas do not exceed 2 millirem (mrem) in
    any one hour or 100 mrem in a year to the maximally exposed member
    of the public.

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}.

a.  Through observation, verify that survey instrumentation has the
    appropriate range of use. Also verify that the survey instruments
    are properly calibrated at 6‑month intervals. Verify that all survey
    instruments, pocket dosimeters, and alarming rate meters, in use,
    have current calibrations. The technical adequacy of calibration
    procedures at facilities that perform their own calibrations should
    be examined. Verify that the licensee performs an appropriate
    operability check before use on each day the equipment is used.

b.  If the licensee is authorized to both collect and analyze leak test
    samples, determine if the type of counting equipment is appropriate
    for the samples being analyzed and the sensitivity required. Also
    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.  [Certification]{.underline}. Through review of records, verify that
    radiographers are certified by a recognized certifying entity. Ask
    to see the radiographer=s certificate, or verify through other
    appropriate means that all radiographers, observed performing in
    that role are, in fact, certified.

b.  [General Training]{.underline}. Interview one or more radiographers
    and/or radiographers= assistants to determine that they possess the
    adequate knowledge and understanding of the licensee=s operating and
    emergency procedures. The interviews should include discussions
    about actual or hypothetical emergency conditions in order to assess
    the worker=s response to such conditions. Whenever practical,
    observe licensed activities in progress to assess the worker=s
    understanding of the radiation protection requirements associated
    with their assigned activities.

    Verify that all industrial radiography personnel understand the
    mechanism for raising safety concerns and the proper response to
    warnings made in the event of any unusual occurrence or malfunction
    that may involve exposure to radiation and radioactive material. 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.

    1.  If the licensee provides their own training, determine that
        instructors who provide classroom training to individuals in the
        principles of radiation and radiation safety have knowledge and
        understanding of the principles beyond those obtainable in a
        course similar to the one given to prospective radiographers.

    2.  Individuals who provide instruction in the hands-on use of
        radiography equipment should be qualified radiographers with at
        least 1 year of experience in performing radiography or possess
        a thorough understanding of the operation of radiographic
        equipment (e.g., manufacturers= service representatives).

        Observe related activities (i.e., transportation of licensed
        materials, surveys and equipment checks, and maintenance
        activities) and interview personnel to assure that appropriate
        training was actually received by these individuals. Note that
        if a radiographer or radiographer\'s assistant has not
        participated in an industrial radiographic operation for more
        than 6 months, they must demonstrate knowledge of training
        requirements by a practical examination, before these
        individuals can participate in a radiographic operation. Verify
        that radiographers understand that they must directly supervise
        radiographic operations and that radiographers= assistants are
        aware that they can operate radiographic equipment only under
        the direct supervision (direct observation) of radiographers.

        Verify that licensees are performing refresher training, for
        radiographers and radiographers\' assistants, at least every
        12 months.

c.  [Operating and Emergency Procedures]{.underline}. 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.
    Also examine the licensee\'s emergency procedures to determine that
    these procedures are as approved by or described to NRC. Through
    discussions with workers, verify that licensee personnel understand
    and implement the established procedures and are aware of procedural
    revisions.

    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.

d.  [Posting and Labeling]{.underline}. Verify that proper caution signs
    are being used at access points to areas containing licensed
    materials, radiation areas, and high radiation areas. (Note: The
    exemptions under 10 CFR 20.1903 do not apply to radiographic
    operations.) Also spot-check labeling on packages or other
    containers to determine that proper information (e.g., radionuclide,
    quantity, and date of measurement) is recorded.

    Verify that storage areas, radiation areas, and high radiation areas
    at temporary job sites are conspicuously posted as required.
    Depending on the associated hazard and licensing requirements,
    controls may include tape, rope, or structural barriers to prevent
    access into the restricted area.

    Examine 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 assertive 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.

87121-04 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